Exhibit 1.01
Conflict Minerals Report
For the Year Ended December 31, 2019
This is the Conflict Minerals Report (this “Report”) of Powell Industries, Inc. (referred to herein as, “Powell”, the “Company”, “we”, “us” or “our”) for calendar year 2019 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Please refer to Section 13(p) of the Exchange Act and the general instructions to the Specialized Disclosure Report on Form SD for definitions of certain terms used in this Report, unless otherwise defined herein.
This Report for the year ended December 31, 2019 is presented to comply with Rule 13p-1 under the Exchange Act (the “Rule”). 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 “Dodd-Frank Act”). 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 tin, tantalum, tungsten, and gold. For the purposes of this Report, tin, tantalum, tungsten and gold shall be collectively referred to as the 3TGs. These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.
Company Overview
Powell Industries, Inc. was incorporated in the state of Delaware in 2004 as a successor to a Nevada company incorporated in 1968. The Nevada company was the successor to a company founded by William E. Powell in 1947, which merged into the Company in 1977. We are headquartered in Houston, Texas, and our major subsidiaries, all of which are wholly owned, include: Powell Electrical Systems, Inc.; Powell (UK) Limited; Powell Canada Inc. and Powell Industries International, B.V.
Our website is powellind.com. We make available, free of charge on or through our website, copies of our Annual Reports on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934 as soon as is reasonably practicable after we electronically file such material with, or furnish it to, the Securities and Exchange Commission (SEC). Additionally, all of our reports filed with the SEC are available via their website at http://www.sec.gov. We have also posted on our company website Powell's Conflict Minerals policy statement at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."
We develop design, manufacture and service custom-engineered equipment and systems which (1) distribute, control and monitor the flow of electrical energy and (2) provide protection to motors, transformers and other electrically powered equipment. Our principal products include integrated power control room substations (PCRs®), custom-engineered modules, electrical houses (E-Houses), traditional and arc-resistant distribution switchgear and control gear, medium-voltage circuit breakers, monitoring and control communications systems, motor control centers and bus duct systems. These products are designed for application voltages ranging from 480 volts to 38,000 volts and are used in oil and gas refining, onshore and offshore oil and gas production, petrochemical, liquid natural gas terminals, pipeline, terminal, mining and metals, light rail traction power, electric utility, pulp and paper and other heavy industrial markets. Our product scope includes designs tested to meet both U.S. and international standards, under both the American National Standards Institute (ANSI) and International Electrotechnical Commission (IEC). We assist customers by providing value-added services such as spare parts, field service inspection, installation, commissioning, modification and repair, retrofit and retrofill components for existing systems and replacement circuit breakers for switchgear that is obsolete or that is no longer produced by the original manufacturer. We seek to establish long-term relationships with the end users of our systems as well as the design and construction engineering firms contracted by those end users. We believe that our culture of safety and focus on customer satisfaction, along with our financial strength, allow us to continue to capitalize on opportunities in the industries we serve.
Product Description
Our broad and complex product range may contain conflict minerals within the following components:
• | Tantalum, used in capacitors, |
• | Tin, used in soldered components, |
• | Tungsten, used in coatings, alloys, heating elements and electrodes, |
• | Gold, used in circuit boards, electrodes and electronic components. |
Description of RCOI
In conducting the RCOI, Powell engaged a third-party service provider. Assent Compliance (“Assent”) to assist with the effectiveness of our conflict minerals program. We identified the scope of our inquiry by first completing a supplier list extraction from our preferred vendor list. This list was then filtered to remove service providers, indirect materials suppliers and inactive suppliers (minimum of one year since last purchase).
This was intended to ensure that all suppliers surveyed provided items to Powell that were used in final products in the year 2019. Once the filtering was completed, we populated the list with contact information. This list, composed of 884 suppliers, was then provided to Assent for upload to their Assent Compliance Manager software system (the “Assent Compliance Manager”).
Assent conducted the supplier survey portion of the RCOI. The supplier survey utilized a template developed by the Responsible Business Alliance® and The Global e-Sustainability Initiative (RBA/GeSI) called the Conflict Mineral Report Template (CMRT). The CMRT was developed to facilitate general disclosures and information regarding smelters that provide materials to the supplier. It includes questions regarding the supplier’s conflict-free minerals policy, the engagement process with its direct suppliers and identification of the smelters used by the supplier.
Non-responsive suppliers were contacted a minimum of ten times. Eight communications were sent from the Assent Compliance Manager, as well as one follow up communication from the Assent Compliance Supply Chain team, in addition to one-on-one communications. After three months of non-responsiveness, suppliers were then contacted by Powell management, as an escalation to encourage their response to Assent.
Assent communications included training and education on the completion of the CMRT form as well as access to Assent’s learning management system, Assent University. All in-scope suppliers were provided access to the Conflict Minerals Training course and this training was monitored and tracked in Assent's system for future reporting and transparency.
The below metrics provide a summary of the data collected, number of suppliers in scope and responses.
Due Diligence Process
Powell’s due diligence measures have been designed to conform, in all material respects, with the framework in the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for 3TG (collectively, the “OECD Guidance”). In 2019, the due diligence process was aimed to help Powell assess and respond to risk in its supply chain by investigating the source of its products down the chain to the smelters and refiners and the strength of its suppliers’ conflict minerals programs. The following is a brief summary of certain aspects of our due diligence process.
A. | Establish Strong Powell Management Systems |
In accordance with our due diligence framework and compliance efforts:
• | We have communicated to all of our in-scope suppliers our efforts to comply with Section 1502 of the Dodd-Frank Act pursuant to a compliance statement and other communications (together, the “Compliance Statement”). We requested that our in-scope suppliers provide a comprehensive conflict minerals declaration for all conflict minerals in the form of the CMRT v.5.12 or higher. We provide our Compliance Statement to all new suppliers and plan to provide annual related compliance statement communications to our entire supply base. | ||
• | We implemented internal compliance efforts, including internal reporting requirements, to support our supply chain due diligence process. | ||
• | We implemented a risk mitigation response plan to address business relationships with suppliers that are DRC conflict undeterminable (as defined in Item 1.01(d)(5) of Form SD). Our program includes continuous monitoring to adjust our strategies as sourcing data improves and new information is received. | ||
Powell has adopted a company policy with respect to conflict minerals which is posted on our website at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."
Internal Team
Powell has established a management system for conflict minerals. Our management system is sponsored by the Chief Financial Officer as well as executive-level representatives and a team of subject matter experts from relevant functions, such as our Supply Chain Director, Corporate Controller, Vice President of Research and Product Development, Trade Compliance and Category Manager.
The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and senior management is briefed about the results of our due diligence efforts.
Control Systems
Controls include, but are not limited to, our code of conduct which outlines expected behaviors for all Powell employees and a conflict minerals policy which can be found on our website at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."
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. Contracts with our suppliers are frequently in force for three to five years or more and we cannot unilaterally impose new contract terms and flow-down requirements. As we enter into new contracts, or our contracts renew, we are adding a clause to require suppliers to provide information about the source of 3TG and smelters. It will take a number of years to ensure that all our supplier contracts contain appropriate flow-down clauses. In the meantime, as described below, we are working with selected suppliers to ensure they provide the 3TG sourcing information until the contracts can be amended.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have, through Assent, provided education on the conflict minerals regulation. We have leveraged the existing communications within the Company, specifically the procurement department, to encourage supplier interactions with Assent as well as to help suppliers understand the requirement for completion of their CMRTs. Feedback from this engagement has allowed us to enhance the training and focus and adapt it to each user’s needs. It has also allowed for our supplier communications to be more focused and to clarify expectations.
Grievance Mechanisms
We have multiple longstanding grievance mechanisms whereby employees, contractors, suppliers and agents can report violations of Powell’s policies. There are established escalation protocols for reporting grievances internally, as well as the EthicsPoint hotline, which is independently managed. Our ethics and reporting Hotline can be found at https://powellind.ethicspoint.com.
Maintain Records
We have also adopted a policy to retain relevant documentation. Such documentation will be retained for minimum of five years in company secured shared drive files.
B. | Identify and Assess Risks in Our Supply Chain |
We identified direct material suppliers to capture possible 3TG risk suppliers. As we progress, we expect that transparency in our supply chain will increase to allow for better risk assessment at more detailed levels of our supply chain. We intend to continue communicating with our suppliers regarding conflict minerals.
Based on assessed risks, our RCOI covered applicable suppliers.
Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance: Assent uses 3 factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags.
1. | Geographic proximity to the DRC and covered countries; |
2. | Responsible Minerals Assurance Process (RMAP) audit status; |
3. | Credible evidence of unethical or conflict sourcing. |
Based on this criteria the following facilities have been identified as being of highest concern to the supply chain:
Standard Smelter Name | Smelter Facility Location | Smelter ID | ||
African Gold Refinery | UGANDA | CID003185 | ||
Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 | ||
Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 | ||
Sudan Gold Refinery | SUDAN | CID002567 | ||
Tony Goetz NV | BELGIUM | CID002587 | ||
As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above facilities produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Powell. As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context.
In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
C. | Design and Implement a Strategy to Respond to Identified Risks |
We believe that our RCOI was reasonably designed and executed in good faith to determine the existence and source of the 3TGs in our supply chain, including from recycled or scrap sources (as defined in Item 1.01(d)(6) of Form SD). We utilized the CMRT template v5.12 or higher for our RCOI. We conducted our effort to send surveys in good faith, utilizing up to three rounds of communications with our suppliers. We evaluated survey responses to identify: (i) the use and source of the 3TGs; and (ii) any warning signs indicating that conflict minerals may have come from one of the Covered Countries. We intend to make additional inquiries on a case-by-case basis during 2020 to clarify or obtain more information as necessary. We tracked results of our supply chain diligence process and periodically reported the results to our executive leadership team.
Because of Powell’s size, the complexity of its products, and the depth, breadth, and constant evolution of its supply chain, it is difficult to identify parties upstream from its direct suppliers. Powell continues to work with suppliers to identify the upstream sources of the 3TGs through the CMRTs, follow up on invalid responses on the CMRTs, use of a risk-based assessment of identified smelters and assessment of the conflict minerals programs of its suppliers, as described below in this Report. Information and findings from this process are stored in the Assent Compliance Manager, a database that can be tracked and audited.
Certain of the responses to the surveys included the names of facilities listed by the suppliers as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. We and our consultant compared these facilities listed in the responses to the list of smelters maintained by the Responsible Minerals Initiative (RMI) and, if a supplier indicated that the facility was certified as “Conflict-Free,” we confirmed that the name was listed by the RMI.
In accordance with OECD Guidance, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free pose a significant risk to the supply chain. In the Assent Compliance Manager, risk is classified based on 3 scoring criteria that we outlined in the previous section.
Powell does not have a direct relationship with conflict minerals smelters and refiners and, as a result, does not perform or direct audits of these entities within its supply chain. Powell captured smelter and refiner information as part of the CMRT, as some suppliers provided the names of facilities it used as smelters or refiners. Assent compared the facilities identified by the suppliers to the list of smelters maintained by the RMI.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). At this stage in conflict minerals compliance it is well-known that many companies are in the middle of the process and do not have many answers beyond “unknown”. The criteria from the questionnaire used to evaluate the strength of the program are:
• | Have you established a conflict minerals sourcing policy? |
• | Have you implemented due diligence measures for conflict-free sourcing? |
• | Do you review due diligence information received from your suppliers against your company’s expectations? |
• | Does your review process include corrective action management? |
When suppliers meet or exceed those criteria (Yes to at least A, E, G, H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our applicable products, including (1) seeking information about 3TG smelters and refiners in our supply chain by requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI lists, (3) conducting the due diligence review and (4) obtaining additional documentation and verification, as applicable. As mentioned above, our existing policy related to relevant documentation of our conflict mineral compliance process requires that documentation will be retained for a period of at least five years.
D. | Implement Targeted Independent Third-Party Due Diligence |
We engaged Assent to assist in the RCOI, data collection and survey process. Assent supports industry associations that administer independent third-party smelter and refinery audit programs and encourages targeted suppliers and/or facilities to participate in comparable due diligence validation activities.
E. | Report on Supply Chain Due Diligence |
We have responded to various customer requests for information regarding our conflict minerals determination.
Powell reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC. We also disclose our company policy with respect to conflict minerals on our website at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."
Due Diligence Results
For the 2019 reporting year, Powell received CMRT forms from 71.5% of the suppliers surveyed. All submitted forms are accepted and classified as valid or invalid in order to retain all data. Suppliers were contacted if they submitted invalid forms and were encouraged to resubmit a valid form. As of May 1, 2020, there were 8 invalid or incomplete supplier submissions.
While due diligence is ongoing and the information received continues to improve in quantity and quality, the majority of the responses received provided data at a company or divisional level or did not specify the smelters or refiners used for materials specifically supplied to us. We have decided to disclose validated smelters provided to us by our supply chain. However, we cannot definitively determine whether any of the 3TGs reported by the suppliers were contained in materials supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. As a result, we are unable to identify all smelters and refiners as well as all the countries of origin of the 3TGs that are contained in the applicable products
As of May 1, 2020, Powell validated 307 smelters or refiners identified within its supply chain. If a supplier indicated that the facility was certified as “conflict-free,” such status was confirmed by Assent if the facility was listed by the RMI as certified.
Many suppliers within Powell’s supply chain are still unable to provide the smelters or refiners used for products supplied. Furthermore, many of the suppliers provided responses at the company or division level and indicated an “unknown” status in terms of determining the origin of the 3TGs. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our Assent follows up on these, urging suppliers to resubmit with increased smelter information. There are still suppliers unable to provide the smelters or refiners used for materials supplied to us.
In cases where any red-flagged smelters were reported on a CMRT by a supplier, risk mitigation activities were initiated. Through Assent, the suppliers were asked to submit a product-level CMRT to better identify the connection between the smelters or refiners they listed and the products they provide to us. Suppliers were also guided to Assent University where they were provided with educational materials on mitigating the risk of smelters or refiners in the supply chain.
Appendix I lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix I any smelters or refiners that we have not been able to validate. Appendix II also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and RMI. Powell supports the refinement and expansion of the list of participating smelters through our membership in the RMI program.
The large majority of the responses received either provided data at a company or subsidiary level and chose not to provide information at the component level, or did not specify the smelters or refiners used for components supplied to Powell. Accordingly, we are unable to determine, in those cases, whether any of the 3TGs reported by the suppliers were contained in components or parts supplied to us, or to validate that any of the smelters or refiners identified are actually in our supply chain.
Steps to Improve Future Due Diligence and Supply Chain Risk Mitigation
Powell intends to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in its products could benefit armed groups in the Covered Countries:
• | Reinforce conflict minerals policy statement on website and specified requirements in standard terms and conditions for any new or renewed supplier contracts. |
• | Continue engagement with suppliers and direct them to training resources to increase the response rate and improve the content of the supplier survey responses. |
• | Engage any suppliers found to be supplying Powell with conflict minerals to establish an alternative source of conflict minerals that does not support the conflict in the Covered Countries. |
• | Define and improve best practices and build leverage over its supply chain in accordance with the OECD Guidance. |
• | Smelter Risk Evaluation through Assent, comprehensive and ongoing analysis is conducted by their smelter library manager to assess sourcing risk. The information is then used to provide supplier feedback and conduct outreach with higher risk suppliers. |
Based on its due diligence process as of the date of this Report, Powell has found no instances where it was necessary to terminate a supplier contract or to find a replacement supply of any conflict minerals.
Appendix I
Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID |
Gold | 8853 S.p.A. | ITALY | CID002763 |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
Gold | African Gold Refinery | UGANDA | CID003185 |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
Gold | Asahi Pretec Corp. | JAPAN | CID000082 |
Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 |
Gold | Aurubis AG | GERMANY | CID000113 |
Gold | Bangalore Refinery | INDIA | CID002863 |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
Gold | Boliden AB | SWEDEN | CID000157 |
Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | CID003421 |
Gold | Caridad | MEXICO | CID000180 |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
Gold | CGR Metalloys Pvt Ltd. | INDIA | CID003382 |
Gold | Chimet S.p.A. | ITALY | CID000233 |
Gold | Chugai Mining | JAPAN | CID000264 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | CID003348 |
Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 |
Gold | Dowa | JAPAN | CID000401 |
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | CID003195 |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 |
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 |
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | CID002584 |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 |
Gold | Gold Coast Refinery | GHANA | CID003186 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 |
Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | CID002562 |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
Gold | Italpreziosi | ITALY | CID002765 |
Gold | JALAN & Company | INDIA | CID002893 |
Gold | Japan Mint | JAPAN | CID000823 |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 |
Gold | Kazzinc | KAZAKHSTAN | CID000957 |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
Gold | Kundan Care Products Ltd. | INDIA | CID003463 |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 |
Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 |
Gold | L'Orfebre S.A. | ANDORRA | CID002762 |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 |
Gold | Marsam Metals | BRAZIL | CID002606 |
Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 |
Gold | Morris and Watson | NEW ZEALAND | CID002282 |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
Gold | PAMP S.A. | SWITZERLAND | CID001352 |
Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 |
Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
Gold | PX Precinox S.A. | SWITZERLAND | CID001498 |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 |
Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 |
Gold | Royal Canadian Mint | CANADA | CID001534 |
Gold | SAAMP | FRANCE | CID002761 |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 |
Gold | Safimet S.p.A | ITALY | CID002973 |
Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 |
Gold | Sai Refinery | INDIA | CID002853 |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA | CID002525 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
Gold | Shirpur Gold Refinery Ltd. | INDIA | CID002588 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
Gold | Sovereign Metals | INDIA | CID003383 |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 |
Gold | Sudan Gold Refinery | SUDAN | CID002567 |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
Gold | T.C.A S.p.A | ITALY | CID002580 |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 |
Gold | Tony Goetz NV | BELGIUM | CID002587 |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
Gold | Torecom | KOREA, REPUBLIC OF | CID001955 |
Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 |
Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
Gold | Yamakin Co., Ltd. | JAPAN | CID002100 |
Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
Tantalum | Asaka Riken Co., Ltd. | JAPAN | CID000092 |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA | CID003402 |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | CID000456 |
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 |
Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 |
Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 |
Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
Tantalum | KEMET Blue Metals | MEXICO | CID002539 |
Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
Tantalum | NPM Silmet AS | ESTONIA | CID001200 |
Tantalum | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | CID002847 |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
Tin | Alpha | UNITED STATES OF AMERICA | CID000292 |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 |
Tin | China Tin Group Co., Ltd. | CHINA | CID001070 |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | CID003356 |
Tin | Dowa | JAPAN | CID000402 |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 |
Tin | Fenix Metals | POLAND | CID000468 |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | CID003410 |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
Tin | Luna Smelter, Ltd. | RWANDA | CID003387 |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | CID003379 |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
Tin | Metallo Belgium N.V. | BELGIUM | CID002773 |
Tin | Metallo Spain S.L.U. | SPAIN | CID002774 |
Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 |
Tin | Minsur | PERU | CID001182 |
Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
Tin | Pongpipat Company Limited | MYANMAR | CID003208 |
Tin | Precious Minerals and Smelting Limited | INDIA | CID003409 |
Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 |
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
Tin | Soft Metais Ltda. | BRAZIL | CID001758 |
Tin | Super Ligas | BRAZIL | CID002756 |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | CID002834 |
Tin | Thaisarco | THAILAND | CID001898 |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
Tin | Yunnan Tin Company Limited | CHINA | CID002180 |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 |
Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 |
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
Tungsten | China Molybdenum Co., Ltd. | CHINA | CID002641 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000281 |
Tungsten | CP Metals Inc. | UNITED STATES OF AMERICA | CID003448 |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | CID003401 |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
Tungsten | GEM Co., Ltd. | CHINA | CID003417 |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | CID003182 |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | CID002647 |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | CID003408 |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | CID003388 |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | CID002543 |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | CID003416 |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 |
Appendix II
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.
Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Djibouti, Dominican Republic, DRC or an adjoining country (Covered Countries), Ecuador, Egypt, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Korea, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Vietnam, Zambia, Zimbabwe