UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
INTERPHASE CORPORATION
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(Exact name of registrant as specified in its charter) | ||
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Texas |
1-35267 |
75-1549797 |
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(State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
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4240 International Parkway, Suite 105, Carrollton, Texas |
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75007 |
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(Address of principal executive offices) |
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(Zip Code) |
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Jennifer Kosharek (214) 654-5000
(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:
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[x] |
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014. |
Section 1 – Conflict Minerals Disclosure
Interphase Corporation (“we” or “our”) evaluated its current product lines and determined that certain products we manufacture contain cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tantalum, tin, and tungsten (“Conflict Minerals”). We are unable with absolute assurance to determine the origin of the Conflict Minerals in our products and cannot exclude the possibility that some may have originated in the Democratic Republic of the Congo or an adjoining country and may not have come from recycled or scrap sources. Our due diligence exercise failed to clarify the Conflict Minerals’ country of origin, whether the Conflict Minerals finance or benefit armed groups in those countries, or whether the Conflict Minerals came from recycled or scrap sources. For that reason, we are required to submit a Conflict Minerals Report.
Item 1.01 Conflict Minerals Disclosure and Report
A copy of the Interphase Corporation’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at http://www.iphase.com/products/conflict_materials/.
Item 1.02 Exhibit
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.
SIGNATURE
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.
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Interphase Corporation |
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By: /s/ Jennifer Kosharek |
Date: June 1, 2015 |
| Chief Financial Officer and | |
| Vice President of Finance |
Exhibit 1.01
Interphase Corporation
Conflict Minerals Report
For The Year Ended December 31, 2014
This report for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). Please refer to the Rule and the 1934 Act Release No. 34-67716 for definitions to the terms used in this report, unless otherwise defined herein. The Rule was adopted by the Securities and Exchange Commission (“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 Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain Conflict Minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tantalum, tin, and tungsten. These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
If a registrant can establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”), or from recycled and scrap sources, they must submit a Specialized Disclosure Form (“Form SD”) which describes the Reasonable Country of Origin Inquiry completed.
If a registrant has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody. The registrant must annually submit a report, Conflict Minerals Report, to the SEC that includes a description of those due diligence measures.
Interphase Corporation is a “smaller reporting company” as defined in Rule 12b-2 of the Securities Exchange Act of 1934. The report presented herein is not audited as Rule 13p-1 under the Securities Exchange Act of 1934 provides for a temporary transition period in 2013, 2014, 2015 and 2016 for a smaller reporting company whereby the Conflict Minerals Report is not subject to an independent private sector audit.
1. Conflict Minerals Disclosure
This report has been prepared by management of Interphase Corporation (herein referred to as “Interphase,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries.
In accordance with the Rule, Interphase has filed this Form SD and the associated Conflict Minerals Report; both of which are posted on our publically available website at http://www.iphase.com/products/conflict_materials/.
1.1 Company Overview
Interphase Corporation is a diversified information and communications technology company, committed to innovation through the process of identifying, developing and introducing new products and services. The Company offers products and services from embedded computing solutions, engineering design services, and contract manufacturing services to a new line of embedded computer vision products.
Embedded solutions include communications networking products for connectivity, interworking and packet processing. Clients for this product line include Alcatel-Lucent, GENBAND, Hewlett Packard, and Samsung.
The engineering design and manufacturing services serve a wide variety of industries within the electronics market, from machine-to-machine and Internet of Things designs utilizing Cellular, GPS and Wi-Fi tracking solutions to cost-saving redesigns for manufacturability. Interphase Productization services provide customers with the full suite of rapid design and manufacturing services required to quickly take a project from design concept to full production in the marketplace.
The penveu® product line, from the embedded computer vision line of business, addresses both the education and enterprise markets. penveu® is a handheld device that adds interactivity to projectors and large screen displays, turning flat surfaces into an interactive display.
Founded in 1974, the Company is located in Carrollton, Texas, with sales offices in the United States and Europe.
1.2 Product Description
In 2014, our principal products primarily include solutions in the following three categories, supporting various form factors such as AMC, PCI-X, PCIe, CPCI, and PMC as well as related software applications:
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Network Connectivity |
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T1/E1 communication controllers that primarily support SS7 signaling |
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OC-3/STM-1 ATM network interface cards |
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Ethernet network interface cards |
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Interworking |
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OC-3/STM-1 interworking modules |
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Gateway Appliances (broadband access gateway and media converter) |
● Multi-core Packet Processors
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GigE packet processors |
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10 GigE packet processors |
Please refer to our Annual Report on Form 10-K for the year ended December 31, 2014 for definitions of these key terms and products.
We conducted an analysis of our products and found that Conflict Minerals are necessary to the functionality or production of our products.
1.3 Supply Chain and Reasonable Country of Origin Inquiry
We rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us – including sources of Conflict Minerals that are supplied to them from lower tier suppliers. We typically do not enter into contracts with our suppliers and, therefore, we cannot impose flow-down requirements. However, our suppliers are expected to adopt policies and due diligence and reporting measures with respect to Conflict Minerals and to require their suppliers to adopt similar policies and measures. In addition, as described below, we are working with our suppliers to ensure they provide the Conflict Minerals sourcing information.
Our reasonable country of origin inquiry (“RCOI”) employed a combination of measures to determine whether the necessary Conflict Minerals in our products originated from the Covered Countries. Our primary means of determining country of origin of necessary Conflict Minerals was by conducting a supply-chain survey with direct suppliers using the conflict minerals reporting template developed by the Electronic Industry Citizenship Coalition (“EICC”) and The Global e-Sustainability Initiative (“GeSI”) (the “Template”). The Template provides a common industry approach for the collection of sourcing information related to Conflict Minerals.
It is not practicable to conduct a survey of all our suppliers and we believed a reasonable approach would be to conduct a survey of the suppliers that were active in 2014. This included suppliers where the nature of the component, or the location of the supplier, indicated that those components were likely to contain Conflict Minerals. We surveyed 90% of our direct suppliers representing 100% of our 2014 expenditures for direct components. We assessed our industry as well as others and confirmed that this risk-based approach is consistent with how many peer companies are approaching the Rule.
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Therefore, we are unable with absolute assurance to determine the origin of the Conflict Minerals in our products and cannot exclude the possibility that some may have originated in the Covered Countries and may not have come from recycled or scrap sources. Our due diligence exercise failed to clarify the Conflict Minerals country of origin, whether the Conflict Minerals finance or benefit armed groups in those countries, or whether the Conflict Minerals came from recycled or scrap sources. For that reason, we are required under the Rule to submit to the SEC a Conflict Minerals Report as an exhibit to Form SD. This report must include:
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a description of the measures we took to exercise due diligence on the Conflict Minerals’ source and chain of custody |
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a description of the products manufactured or contracted to be manufactured that are not DRC conflict free |
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the facilities used to process the Conflict Minerals |
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the country of origin of the Conflict Minerals |
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the efforts to determine the mine or location of origin |
1.4 Conflict Minerals Policy
We have adopted the following Conflict Minerals Policy:
Interphase Corporation is committed to respecting human rights in our own operations and in our global supply chain; while at the same time, promoting economic development in Africa through responsible commercial engagement and driving employee awareness. As part of this commitment to corporate responsibility, we are working with our global supply chain to ensure compliance with the SEC’s conflict minerals rule.
We have established a Conflict Minerals compliance program that is designed to follow the framework established by the Organisation for Economic Co-operation and Development (“OECD”). Our Company is fully engaged in implementing the program. Likewise, our suppliers are expected to adopt policies and due diligence and reporting measures with respect to Conflict Minerals and to require their suppliers to adopt similar policies and measures.
As we become aware of instances where minerals in our supply chain potentially finance armed groups, as defined in the SEC’s conflict minerals rule, we will work with our suppliers to find economical, alternate conflict-free sources.
2. Due Diligence Process
2.1 Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the framework in The Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements (“OECD Guidance”) for gold, tin, tantalum and tungsten.
2.2 Establish Strong Company Management Systems
As described above, Interphase Corporation has adopted a Conflict Minerals Policy which is also posted on our website at http://www.iphase.com/products/conflict_materials/.
Internal Team
Interphase has established a management system for Conflict Minerals. Our management system is sponsored by the Chief Financial Officer and includes executive-level representatives and a team of subject matter experts from relevant functions such as manufacturing, quality assurance, purchasing, finance and legal. The team of subject matter experts is responsible for implementing our Conflict Minerals compliance strategy and is led by our Vice President of Operations who acts as the Conflict Minerals Program Manager. Senior management is briefed about the results of our due diligence efforts on a periodic basis.
Control Systems
As we do not typically have a direct relationship with Conflict Minerals smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our sector and other sectors through our use of the reporting template developed by the EICC and GeSI.
Controls include, but are not limited to, our Code of Conduct which outlines expected behaviors for all Interphase employees, our Conflict Minerals Policy and our policy for Complaints and Concerns Regarding Questionable Accounting or Auditing Matters.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have contacted our 2014 active suppliers. Feedback from this engagement has allowed us to collect valuable sourcing information related to Conflict Minerals. This information includes, but is not limited to, metals used in the production of our components, data to determine reasonable country of origin, upstream supplier information, a listing of smelters, supplier due diligence processes, and conflict minerals policies.
Grievance Mechanism
We have a longstanding grievance mechanism whereby employees are encouraged to report any concerns regarding violations of rules or regulations of the SEC or irregularities related to the Company’s disclosures and reporting obligations. Our policy for Complaints and Concerns Regarding Questionable Accounting or Auditing Matters is available on our website at http://www.iphase.com/investor/governance/.
Maintain Records
We have adopted procedures to retain relevant documentation.
2.3 Identify and Assess Risk in the 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 to identify actors upstream from our direct suppliers.
We have identified 270 direct suppliers for the 2014 calendar year. We rely on these suppliers, whose components contain Conflict Minerals, to provide us with information about the source of Conflict Minerals contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers. Many of the largest suppliers are also SEC registrants and subject to the Rule.
2.4 Design and Implement a Strategy to Respond to Identified Risks
In response to this risk assessment, Interphase has an approved risk management plan, through which the conflict minerals program is implemented, managed and monitored. Updates to this risk assessment are provided periodically to senior management.
As part of our risk management plan, to ensure suppliers understand our expectations, we have utilized online training available from various sources including the EICC and the GeSI, requested suppliers to complete the Template, publicized a Conflict Minerals Statement and adopted a Conflict Minerals Policy.
As described in our Conflict Minerals Policy, we will work with any of our suppliers whom we have reason to believe are supplying us with Conflict Minerals from sources that may support conflict in the DRC or any adjoining country to find an alternative source of Conflict Minerals that does not support such conflict, as provided in the OECD Guidance.
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Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
We typically do not have a direct relationship with Conflict Minerals smelters and refiners and do not perform or direct audits of these entities within our supply chain.
2.6 Report on Supply Chain Due Diligence
This report documents our supply chain due diligence.
3. Due Diligence Results
3.1 Request Information
We conducted a survey of those suppliers described above using the Template described above. The Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the Template contains questions about the origin of Conflict Minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are available on EICC’s website. The Template is being used by many companies in their due diligence processes related to Conflict Minerals.
3.2 Survey Responses
We received responses from approximately 70% of the suppliers surveyed using the Conflict-Free Sourcing Initiative (“CFSI”) template revision 3.02. We reviewed the responses against criteria developed to determine which required further engagement with our suppliers. These criteria included untimely or incomplete responses as well as inconsistencies within the data reported in the Template. We have worked directly with these suppliers to provide revised responses.
Responses included the names of 273 entities listed by our suppliers as smelters or refiners. Approximately 56% of these entities were identified as having undergone assessment through the Conflict-Free Smelter Program (“CFSP”) and have been validated to be in compliance with the protocols. We compared these facilities to the CFSP Compliant Smelter List, and where a supplier indicated that the facility was certified as conflict-free, we ensured that the name was listed on the CFSP Compliant Smelter List. Interphase supports the refinement and expansion of the list of smelters that participate and comply with the CFSP. Approximately 3% of the suppliers that responded were unable to identify the smelters whose Conflict Minerals went into parts supplied to Interphase.
3.3 Smelter or Refiner Facilities Used to Process Conflict Minerals
Appendix A sets forth a list of smelters or refiners by mineral type, provided by our suppliers, which lists the country of origin of the facility and whether or not each facility was CFSP compliant,
3.4 Country of Origin and Efforts to Determine Mine or Location of Origin
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Through our implementation of the OECD conflict minerals compliance program and requesting our suppliers to complete the Template, we have determined that seeking information about Conflict Minerals 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 Conflict Minerals in our supply chain. Appendix B provides a summary list all of the countries of origin for each mineral type for the smelters and refiners reported by our suppliers, collected as a result of our RCOI efforts.
Based upon the information received and reported, we are not able to determine the country of origin for all of the Conflict Minerals used in our supply chain, and thus, we are not able to conclusively state that none of the Conflict Minerals originated in a Covered Country or financed or benefited armed groups in those countries.
4. Steps to be Taken to Mitigate Risk
Interphase intends to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary Conflict Minerals in our products could benefit armed groups in the DRC or adjoining countries:
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Continue to engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
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Request suppliers to update the content of their survey responses as new revisions of the Template become available. |
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Require new suppliers to complete the Template before commencing a purchasing relationship. |
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Engage any of our suppliers found to be supplying us with Conflict Minerals from sources that support conflict in the DRC or any adjoining country to establish an alternative economical source of Conflict Minerals that does not support such conflict. |
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Monitor the EICC, GeSI, and OECD for best practices and build leverage over the supply chain in accordance with the OECD Guidance. |
APPENDIX A
CONFLICT MINERAL SOURCING INFORMATION BY SMELTER
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Metal |
Smelter Name |
Country |
Comment |
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Gold |
Aida Chemical Industries Co. Ltd. |
Japan |
CFSP Compliant |
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Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. |
Germany |
CFSP Compliant |
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Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
Uzbekistan |
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Gold |
AngloGold Ashanti Córrego do Sítio Minerção |
Brazil |
CFSP Compliant |
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Gold |
Argor-Heraeus SA |
Switzerland |
CFSP Compliant |
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Gold |
Asahi Pretec Corporation |
Japan |
CFSP Compliant |
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Gold |
Asaka Riken Co Ltd |
Japan |
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Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
Turkey |
CFSP Compliant |
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Gold |
Aurubis AG |
Germany |
CFSP Compliant |
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Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Philippines |
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Gold |
Bauer Walser AG |
Germany |
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Gold |
Boliden AB |
Sweden |
CFSP Compliant |
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Gold |
C. Hafner GmbH + Co. KG |
Germany |
CFSP Compliant |
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Gold |
Caridad |
Mexico |
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Gold |
CCR Refinery – Glencore Canada Corporation |
Canada |
CFSP Compliant |
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Gold |
Cendres & Métaux SA |
Switzerland |
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Gold |
Chimet S.p.A. |
Italy |
CFSP Compliant |
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Gold |
China National Gold Group Corporation |
China |
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Gold |
Chugai Mining |
Japan |
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Gold |
Codelco |
Chile |
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Gold |
Daejin Indus Co. Ltd |
Korea, Republic Of |
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Gold |
DaeryongENC |
Korea, Republic Of |
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Gold |
Daye Non-Ferrous Metals Mining Ltd. |
China |
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Gold |
Do Sung Corporation |
Korea, Republic Of |
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Gold |
Doduco |
Germany |
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Gold |
Dowa |
Japan |
CFSP Compliant |
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Gold |
Eco-System Recycling Co., Ltd. |
Japan |
CFSP Compliant |
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Gold |
FSE Novosibirsk Refinery |
Russian Federation |
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Gold |
Gansu Seemine Material Hi-Tech Co Ltd |
China |
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Gold |
Guangdong Jinding Gold Limited |
China |
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Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
China |
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Gold |
Heimerle + Meule GmbH |
Germany |
CFSP Compliant |
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Gold |
Henan Sanmenxia Lingbao City Jinyuan Mining Industry Co., Ltd. |
China |
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Gold |
Heraeus Ltd. Hong Kong |
Hong Kong |
CFSP Compliant |
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Gold |
Heraeus Precious Metals GmbH & Co. KG |
Germany |
CFSP Compliant |
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Gold |
Heraeus USA |
United States |
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Gold |
Heraeus Zhaoyuan Precious Metal Materials Co.,Ltd. |
China |
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Gold |
Hop Hing electroplating factory Zhejiang |
China |
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Gold |
Hunan Chenzhou Mining Industry Group |
China |
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Gold |
Hwasung CJ Co. Ltd |
Korea, Republic Of |
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Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
China |
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Gold |
Ishifuku Metal Industry Co., Ltd. |
Japan |
CFSP Compliant |
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Gold |
Istanbul Gold Refinery |
Turkey |
CFSP Compliant |
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Gold |
Japan Mint |
Japan |
CFSP Compliant |
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Gold |
Jiangxi Copper Company Limited |
China |
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Gold |
Jinlong Copper Co., Ltd. |
China |
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Gold |
Johnson Matthey Inc |
United States |
CFSP Compliant |
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Gold |
Johnson Matthey Ltd |
Canada |
CFSP Compliant |
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Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
Russian Federation |
CFSP Compliant |
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Gold |
JSC Uralelectromed |
Russian Federation |
CFSP Compliant |
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Gold |
JX Nippon Mining & Metals Co., Ltd. |
Japan |
CFSP Compliant |
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Gold |
Kazzinc Ltd |
Kazakhstan |
CFSP Compliant |
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Gold |
Kennecott Utah Copper LLC |
United States |
CFSP Compliant |
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Gold |
Kojima Chemicals Co., Ltd |
Japan |
CFSP Compliant |
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Gold |
Korea Metal Co. Ltd |
Korea, Republic Of |
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Gold |
Kunshan Jinli chemical industry reagents co.,Ltd. |
China |
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Gold |
Kyrgyzaltyn JSC |
Kyrgyzstan |
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Gold |
L' azurde Company For Jewelry |
Saudi Arabia |
CFSP Compliant |
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Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd |
China |
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Gold |
LS-Nikko |
Korea, Republic Of |
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Gold |
LS-NIKKO Copper Inc. |
Korea, Republic Of |
CFSP Compliant |
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Gold |
Luoyang Zijin Yinhui Metal Smelt Co Ltd |
China |
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Gold |
Materion |
United States |
CFSP Compliant |
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Gold |
Matsuda Sangyo Co., Ltd. |
Japan |
CFSP Compliant |
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Gold |
Metalor Technologies (Hong Kong) Ltd |
Hong Kong |
CFSP Compliant |
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Gold |
Metalor Technologies (Singapore)Pte, Ltd |
Singapore |
CFSP Compliant |
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Gold |
Metalor Technologies Ltd. (Suzhou) |
China |
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Gold |
Metalor Technologies SA |
Switzerland |
CFSP Compliant |
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Gold |
Metalor USA Refining Corporation |
United States |
CFSP Compliant |
|
Gold |
Met-Mex Peñoles, S.A. |
Mexico |
CFSP Compliant |
|
Gold |
Mitsubishi Materials Corporation |
Japan |
CFSP Compliant |
|
Gold |
Mitsui & Co. Precious Metals Inc. Hong Kong Branch |
Hong Kong |
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Gold |
Mitsui Mining and Smelting Co., Ltd. |
Japan |
CFSP Compliant |
|
Gold |
Moscow Special Alloys Processing Plant |
Russian Federation |
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|
Gold |
Nadir Metal Rafineri San. Ve Tic. A.ª. |
Turkey |
CFSP Compliant |
|
Gold |
Navoi Mining and Metallurgical Combinat |
Uzbekistan |
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|
Gold |
Nihon Material Corporation |
Japan |
CFSP Compliant |
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Gold |
Niihama Nickel Refinery |
Japan |
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Gold |
Nippon Mining & Metals |
Japan |
|
|
Gold |
Ohio Precious Metals, LLC |
United States |
CFSP Compliant |
|
Gold |
Ohura Precious Metal Industry Co., Ltd |
Japan |
CFSP Compliant |
|
Gold |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) |
Russian Federation |
CFSP Compliant |
|
Gold |
OJSC Kolyma Refinery |
Russian Federation |
|
|
Gold |
PAMP SA |
Switzerland |
CFSP Compliant |
|
Gold |
Penglai Penggang Gold Industry Co Ltd |
China |
|
|
Gold |
Priorsky Plant of Non-Ferrous Metals |
Russian Federation |
|
|
Gold |
PT Aneka Tambang (Persero)TBK |
Indonesia |
CFSP Compliant |
|
Gold |
PX Précinox SA |
Switzerland |
CFSP Compliant |
|
Gold |
Rand Refinery (Pty) Ltd |
South Africa |
CFSP Compliant |
|
Gold |
Royal Canadian Mint |
Canada |
CFSP Compliant |
|
Gold |
Sabin Metal Corp. |
United States |
|
|
Gold |
Saijyo,Ehime,Japan |
Japan |
|
|
Gold |
Samduck Precious Metals |
Korea, Republic Of |
|
|
Gold |
SAMWON METALS Corp. |
Korea, Republic Of |
|
|
Gold |
Schloetter Co. Ltd. |
United Kingdom |
|
|
Gold |
Schone Edelmetaal |
Netherlands |
CFSP Compliant |
|
Gold |
SEMPSA Joyería Platería SA |
Spain |
CFSP Compliant |
|
Gold |
Shandong Zhaojin Gold & Silver Refinery Co. Ltd |
China |
CFSP Compliant |
|
Gold |
So Accurate Group, Inc. |
United States |
|
|
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
Russian Federation |
|
|
Gold |
Solar Applied Materials Technology Corp. |
Taiwan |
CFSP Compliant |
|
Gold |
Sumitomo Metal Mining Co., Ltd. |
Japan |
CFSP Compliant |
|
Gold |
Tai zhou chang san Jiao electron Co.,Ltd |
China |
|
|
Gold |
Tanaka Kikinzoku Kogyo K.K. |
Japan |
CFSP Compliant |
|
Gold |
The Great Wall Gold and Silver Refinery of China |
China |
|
|
Gold |
The Hutti Gold Company |
India |
|
|
Gold |
The Refinery of Shandong Gold Mining Co., Ltd |
China |
CFSP Compliant |
|
Gold |
Tokuriki Honten Co., Ltd |
Japan |
CFSP Compliant |
|
Gold |
Tongling nonferrous Metals Group Co.,Ltd |
China |
|
|
Gold |
Torecom |
Korea, Republic Of |
|
|
Gold |
Umicore Brasil Ltda |
Brazil |
CFSP Compliant |
|
Gold |
Umicore Precious Metals Thailand |
Thailand |
CFSP Compliant |
|
Gold |
Umicore SA Business Unit Precious Metals Refining |
Belgium |
CFSP Compliant |
|
Gold |
United Precious Metal Refining, Inc. |
United States |
CFSP Compliant |
|
Gold |
Valcambi SA |
Switzerland |
CFSP Compliant |
|
Gold |
Western Australian Mint trading as The Perth Mint |
Australia |
CFSP Compliant |
|
Gold |
Xstrata Canada Corporation |
Canada |
|
|
Gold |
Yamamoto Precision Metals |
Japan |
CFSP Compliant |
|
Gold |
Yantai Guodasafina High-Tech Environmental Refinery Co. Ltd. |
China |
|
|
Gold |
Yantai Zhaojin Lai Fuk Precious Metals Ltd |
China |
|
|
Gold |
Yokohama Metal Co Ltd |
Japan |
|
|
Gold |
Yunnan Copper Industry Co Ltd |
China |
|
|
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
China |
CFSP Compliant |
|
Gold |
Zijin Mining Group Co. Ltd |
China |
CFSP Compliant |
|
Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
China |
CFSP Compliant |
|
Tantalum |
Conghua Tantalum and Niobium Smeltry |
China |
CFSP Compliant |
|
Tantalum |
Duoluoshan |
China |
CFSP Compliant |
|
Tantalum |
Exotech Inc. |
United States |
CFSP Compliant |
|
Tantalum |
F&X Electro-Materials Ltd. |
China |
CFSP Compliant |
|
Tantalum |
Global Advanced Metals (Cabot) |
United States |
|
|
Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. |
China |
CFSP Compliant |
|
Tantalum |
H.C. Starck GmbH |
Germany |
|
|
Tantalum |
Hi-Temp |
United States |
CFSP Compliant |
|
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
China |
CFSP Compliant |
|
Tantalum |
Jiujiang Tanbre Co.,Ltd |
China |
CFSP Compliant |
|
Tantalum |
King-Tan Tantalum Industry Ltd |
China |
CFSP Compliant |
|
Tantalum |
LSM Brasil S.A. |
Brazil |
CFSP Compliant |
|
Tantalum |
Metallurgical Products India (Pvt.) Ltd. |
India |
CFSP Compliant |
|
Tantalum |
Mineração Taboca S.A. |
Brazil |
CFSP Compliant |
|
Tantalum |
Mitsui Mining & Smelting |
Japan |
CFSP Compliant |
|
Tantalum |
Molycorp Silmet A.S. |
Estonia |
CFSP Compliant |
|
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
China |
CFSP Compliant |
|
Tantalum |
QuantumClean |
United States |
CFSP Compliant |
|
Tantalum |
RFH Tantalum Smeltry Co., Ltd |
China |
CFSP Compliant |
|
Tantalum |
Shanghai Jiangxi Metals Co. Ltd |
China |
|
|
Tantalum |
Solikamsk Metal Works |
Russian Federation |
CFSP Compliant |
|
Tantalum |
Taki Chemicals |
Japan |
CFSP Compliant |
|
Tantalum |
Telex |
United States |
CFSP Compliant |
|
Tantalum |
Ulba |
Kazakhstan |
CFSP Compliant |
|
Tantalum |
Zhuzhou Cement Carbide |
China |
CFSP Compliant |
|
Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd |
China |
|
|
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
China |
CFSP Compliant |
|
Tantalum |
|
China |
CFSP Compliant |
|
Tantalum |
KEMET Blue Metals |
Mexico |
CFSP Compliant |
|
Tantalum |
Plansee SE Liezen |
Austria |
CFSP Compliant |
|
Tantalum |
H.C. Starck Co., Ltd. |
Thailand |
CFSP Compliant |
|
Tantalum |
H.C. Starck GmbH Goslar |
Germany |
CFSP Compliant |
|
Tantalum |
H.C. Starck GmbH Laufenburg |
Germany |
CFSP Compliant |
|
Tantalum |
H.C. Starck Hermsdorf GmbH |
Germany |
CFSP Compliant |
|
Tantalum |
H.C. Starck Inc. |
United States |
CFSP Compliant |
|
Tantalum |
H.C. Starck Ltd. |
Japan |
CFSP Compliant |
|
Tantalum |
H.C. Starck Smelting GmbH & Co.KG |
Germany |
CFSP Compliant |
|
Tantalum |
Plansee SE Reutte |
Austria |
CFSP Compliant |
|
Tantalum |
Global Advanced Metals Boyertown |
United States |
CFSP Compliant |
|
Tantalum |
Global Advanced Metals Aizu |
Japan |
CFSP Compliant |
|
Tantalum |
Kemet Blue Powder |
United States |
CFSP Compliant |
|
Tantalum |
Furuuchi chemical K.K. |
Japan |
|
|
Tin |
Alpha |
United States |
CFSP Compliant |
|
Tin |
China Rare Metal Materials Company |
China |
CFSP Compliant |
|
Tin |
CNMC (Guangxi) PGMA Co. Ltd. |
China |
|
|
Tin |
Copper Santa |
Brazil |
CFSP Compliant |
|
Tin |
CV JusTindo |
Indonesia |
|
|
Tin |
CV Makmur Jaya |
Indonesia |
|
|
Tin |
CV Nurjanah |
Indonesia |
|
|
Tin |
CV Serumpun Sebalai |
Indonesia |
|
|
Tin |
CV United Smelting |
Indonesia |
CFSP Compliant |
|
Tin |
Dowa Metals & Mining Co.Ltd |
Japan |
CFSP Compliant |
|
Tin |
EM Vinto |
Bolivia |
CFSP Compliant |
|
Tin |
Estanho de Rondônia S.A. |
Brazil |
|
|
Tin |
Feinhütte Halsbrücke GmbH |
Germany |
|
|
Tin |
Fenix Metals |
Poland |
|
|
Tin |
Geiju Non-Ferrous Metal Processing Co. Ltd. |
China |
CFSP Compliant |
|
Tin |
Gejiu Jin Ye Mineral Co., Ltd. |
China |
|
|
Tin |
Gejiu Zi-Li |
China |
|
|
Tin |
Guangxi Huaxi Group Co.,Ltd |
China |
|
|
Tin |
Huichang Jinshunda Tin Co. Ltd |
China |
|
|
Tin |
Jia Tian |
China |
|
|
Tin |
Kai Unita Trade Limited Liability Company |
China |
|
|
Tin |
Linwu Xianggui Smelter Co |
China |
|
|
Tin |
Liuzhou China Tin |
China |
|
|
Tin |
Magnu's Minerais Metais e Ligas LTDA |
Brazil |
CFSP Compliant |
|
Tin |
Malaysia Smelting Corp |
Malaysia |
CFSP Compliant |
|
Tin |
Melt Metais e Ligas S/A |
Brazil |
CFSP Compliant |
|
Tin |
Metallic Resources Inc |
United States |
|
|
Tin |
Metallo Chimique |
Belgium |
|
|
Tin |
Mineração Taboca S.A. |
Brazil |
CFSP Compliant |
|
Tin |
Minsur |
PERU |
CFSP Compliant |
|
Tin |
Mitsubishi Materials Corporation |
Japan |
CFSP Compliant |
|
Tin |
Nathan Trotter & Co.,Inc. |
United States |
|
|
Tin |
Novosibirsk Integrated Tin Works |
Russian Federation |
|
|
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
Thailand |
|
|
Tin |
OM MANUFACTURING PHILIPPINES,INC |
Philippines |
CFSP Compliant |
|
Tin |
OMSA |
Bolivia |
CFSP Compliant |
|
Tin |
PT Alam Lestari Kencana |
Indonesia |
|
|
Tin |
PT Artha Cipta Langgeng |
Indonesia |
CFSP Compliant |
|
Tin |
PT Babel Inti Perkasa |
Indonesia |
CFSP Compliant |
|
Tin |
PT Babel Surya Alam Lestari |
Indonesia |
|
|
Tin |
PT Bangka Kudai Tin |
Indonesia |
CFSP Compliant |
|
Tin |
PT Bangka Putra Karya |
Indonesia |
CFSP Compliant |
|
Tin |
PT Bangka Timah Utama Sejahtera |
Indonesia |
|
|
Tin |
PT Belitung Industri Sejahtera |
Indonesia |
CFSP Compliant |
|
Tin |
PT BilliTin Makmur Lestari |
Indonesia |
|
|
Tin |
PT Bukit Timah |
Indonesia |
CFSP Compliant |
|
Tin |
PT DS Jaya Abadi |
Indonesia |
CFSP Compliant |
|
Tin |
PT Eunindo Usaha Mandiri |
Indonesia |
CFSP Compliant |
|
Tin |
PT Fang Di MulTindo |
Indonesia |
|
|
Tin |
PT HP Metals Indonesia |
Indonesia |
|
|
Tin |
PT Karimun Mining |
Indonesia |
|
|
Tin |
PT Koba Tin |
Indonesia |
|
|
Tin |
PT Mitra Stania Prima |
Indonesia |
CFSP Compliant |
|
Tin |
PT Prima Timah Utama |
Indonesia |
CFSP Compliant |
|
Tin |
PT Refined Banka Tin |
Indonesia |
CFSP Compliant |
|
Tin |
PT Sariwiguna Binasentosa |
Indonesia |
CFSP Compliant |
|
Tin |
PT Stanindo Inti Perkasa |
Indonesia |
CFSP Compliant |
|
Tin |
PT Sumber Jaya Indah |
Indonesia |
|
|
Tin |
PT Tambang Timah |
Indonesia |
CFSP Compliant |
|
Tin |
PT Timah (Persero), Tbk |
Indonesia |
CFSP Compliant |
|
Tin |
PT Timah Nusantara |
Indonesia |
|
|
Tin |
PT Tinindo Inter Nusa |
Indonesia |
CFSP Compliant |
|
Tin |
PT Yinchendo Mining Industry |
Indonesia |
|
|
Tin |
Rui Da Hung |
Taiwan |
|
|
Tin |
Soft Metais, Ltda. |
Brazil |
CFSP Compliant |
|
Tin |
Thaisarco |
Thailand |
CFSP Compliant |
|
Tin |
Tongding Metal Material Co.,Ltd. |
China |
|
|
Tin |
Westfalenzinn |
Germany |
|
|
Tin |
White Solder Metalurgia e Mineração Ltda. |
Brazil |
CFSP Compliant |
|
Tin |
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. |
China |
|
|
Tin |
Yunnan Tin Company, Ltd. |
China |
CFSP Compliant |
|
Tungsten |
A.L.M.T. Corp. |
Japan |
|
|
Tungsten |
Kennametal Huntsville |
United States |
|
|
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
China |
|
|
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
China |
|
|
Tungsten |
Dayu Weiliang Tungsten Co., Ltd. |
China |
|
|
Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
China |
CFSP Compliant |
|
Tungsten |
Global Tungsten & Powders Corp. |
United States |
CFSP Compliant |
|
Tungsten |
HC Starck GmbH |
Germany |
|
|
Tungsten |
Hunan Chenzhou Mining Group Co |
China |
|
|
Tungsten |
Hunan Chun-chang non-ferrous Smelting & Concentrating Co., Ltd. |
China |
CFSP Compliant |
|
Tungsten |
Japan New Metals Co., Ltd. |
Japan |
CFSP Compliant |
|
Tungsten |
Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
China |
|
|
Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
China |
CFSP Compliant |
|
Tungsten |
Kennametal Fallon |
United States |
|
|
Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. |
Vietnam |
|
|
Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd |
Vietnam |
CFSP Compliant |
|
Tungsten |
Wolfram Bergbau und Hütten AG |
Austria |
CFSP Compliant |
|
Tungsten |
Wolfram Company CJSC |
Russian Federation |
|
|
Tungsten |
Xiamen Tungsten Co., Ltd. |
China |
CFSP Compliant |
|
Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
China |
|
|
Tungsten |
Zhuzhou Cemented Carbide Group Co Ltd |
China |
|
|
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
China |
CFSP Compliant |
|
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
China |
|
|
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
China |
|
|
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
China |
|
|
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
China |
CFSP Compliant |
|
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
China |
CFSP Compliant |
|
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
China |
CFSP Compliant |
|
Tungsten |
Jiangxi Richsea New Materials Co., Ltd. |
China |
|
|
Tungsten |
Ganzhou Grand Sea W & Mo Group Co Ltd |
China |
CFSP Compliant |
|
Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. |
China |
CFSP Compliant |
|
Tungsten |
H.C. Starck GmbH |
Germany |
|
|
Tungsten |
H.C. Starck Smelting GmbH & Co.KG |
Germany |
|
|
Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
Vietnam |
|
|
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
China |
|
APPENDIX B
COUNTRY OF ORIGIN SUMMARY BY CONFLICT MINERAL
|
Gold |
Australia, Belgium, Brazil, Canada, Chile, Germany, Hong Kong, India, Indonesia, Italy, Japan, Kazakhstan, Republic of Korea, Kyrgyzstan, Mexico, Netherlands, Philippines, Russian Federation, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, United Kingdom, United States, Uzbekistan |
|
Tantalum |
Austria, Brazil, China, Estonia, Germany, India, Japan, Kazakhstan, Mexico, Russian Federation, Thailand, United States |
|
Tin |
Belgium, Bolivia, Brazil, China, Germany, Indonesia, Japan, Malaysia, Peru, Philippines, Poland, Russian Federation, Taiwan, Thailand, United States |
|
Tungsten |
Austria, China, Germany, Japan, Russian Federation, United States, Vietnam |