0000897069-16-000919.txt : 20160531 0000897069-16-000919.hdr.sgml : 20160531 20160531170431 ACCESSION NUMBER: 0000897069-16-000919 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20151231 1.02 20151231 FILED AS OF DATE: 20160531 DATE AS OF CHANGE: 20160531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: REGAL BELOIT CORP CENTRAL INDEX KEY: 0000082811 STANDARD INDUSTRIAL CLASSIFICATION: MOTORS & GENERATORS [3621] IRS NUMBER: 390875718 STATE OF INCORPORATION: WI FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-07283 FILM NUMBER: 161686770 BUSINESS ADDRESS: STREET 1: 200 STATE ST CITY: BELOIT STATE: WI ZIP: 53511 BUSINESS PHONE: 6083648800 MAIL ADDRESS: STREET 1: 200 STATE STREET CITY: BELOIT STATE: WI ZIP: 53511-6254 FORMER COMPANY: FORMER CONFORMED NAME: BELOIT TOOL CORP DATE OF NAME CHANGE: 19730522 FORMER COMPANY: FORMER CONFORMED NAME: RECORD A PUNCH CORP DATE OF NAME CHANGE: 19690320 SD 1 cg767.htm


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
Form SD
 
SPECIALIZED DISCLOSURE REPORT



Regal Beloit Corporation
 
(Exact Name of Registrant as Specified in Charter)
 
 
 
Wisconsin
1-7283
39-0875718
(State or Other Jurisdiction
of Incorporation)
(Commission File No.)
(I.R.S. Employer
Identification Number)
     
     
200 State Street Beloit, WI
 
53511
(Address of Principal Executive Offices)
 
(Zip Code)
     
     
Mark J. Gliebe
 
(608) 364-8800
(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:
 
 
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.
 
 


1



Section 1 - Conflict Minerals Disclosure
 
Item 1.01 Conflict Minerals Disclosure and Report
 
Conflict Minerals Disclosure
 
A copy of Regal Beloit Corporation's Conflict Minerals Report is provided as Exhibit 1.02 hereto and is publicly available in the SEC filings section of our website (http://investors.regalbeloit.com/phoenix.zhtml?c=116222&p=irol-sec).
 
Item 1.02 Exhibit
 
Section 2 – Exhibits
 
Item 2.01 Exhibit
 
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
 

2



 
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 undersigned hereunto duly authorized.
 
REGAL BELOIT CORPORATION



Date:  May 31, 2016                                                                          By:  /s/ Thomas E. Valentyn
                                                                                                     Thomas E. Valentyn
                                                                                                                                
Vice President, General Counsel & Secretary




3
EX-1.01 2 cg767101.htm

Exhibit 1.01
 
Regal Beloit Corporation
Conflict Minerals Report
For the Year Ended December 31, 2015
 
This Conflict Minerals Report (the “Report”) of Regal Beloit Corporation (the “Company,” “we,” “Regal”,“us,” “our”) has been prepared pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Rule”), for the reporting period January 1, 2015 to December 31, 2015.
 
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the conflict minerals specified in the Rule are intentionally added and necessary to the functionality or production of those products.  Conflict Minerals are defined in section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The specified minerals, which we collectively refer to in this Report as the “3TGs,” are gold, , tantalum, tin and tungsten, respectively.  The “Covered Countries” for the purposes of this Report are the DRC and the adjoining countries.  As described in this Report, during the reporting period between January 1, 2015 and December 31, 2015, certain of the Company’s operations manufactured, or contracted to manufacture, products for which the 3TGsare intentionally added and necessary to the functionality or production.
 

 
Forward-looking Statements
 
Statements we make in this Conflict Minerals Report, which express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements, including statements relating to our compliance efforts and expected actions identified under the “Process Improvement Considerations” section of this Report. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other things, our ability to implement improvements in our conflict minerals program and identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see our other filings with the Securities and Exchange Commission (“SEC”), including our Annual Report on Form 10-K for the year ended December 31, 2015. Undue reliance should not be placed on these forward-looking statements, which are effective only as of the date of this report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.
 
4


 
Summary
 
Through our Reasonable Country of Origin Inquiry (“RCOI”) and due diligence efforts, we identified forty-one (41) smelters and/or refiners (“SORs”) as either sourcing Conflict Minerals from the Covered Countries or giving us reason to believe they are sourcing Conflict Minerals from the Covered Countries. Of those 41 smelters, 37 are recognized as compliant with the Conflict Free Smelter Program (“CFSP”).  The following sections describe in detail our RCOI, our due diligence framework and the results of our due diligence efforts.
 
Company Overview
 
We are a global manufacturer of electric motors and controls, electric generators and controls, and mechanical motion control products.
 
Description of the Company’s Products Covered by this Report
 
This Report relates to products: (i) for which an of the 3TGs are intentionally added and necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2015.
 
These products, which are referred to in this Report collectively as the “Covered Products,” are the following:

1. Electric motors and controls (may contain tin and tin and gold respectively)
2. Electric generators and controls (may contain tin and tin and gold respectively)
3. Electric motor capacitors (may contain tin)
4. Gear reducers (may contain tin)
5. Electronic switchgears (may contain tin and gold)
6. Actuators (may contain tin, gold, tantalum and tungsten)
7. Servo systems (may contain tin, gold, tantalum and tungsten)
8. Conveyor systems (may contain tin, gold, tantalum and tungsten)
9. Power transmission products including gearboxes, transfer cases, transmissions, worm gears and other gears (may contain tin)
10. Drive systems and controllers (may contain tin, gold, tantalum and tungsten)
11. Loadbanks (may contain tin, gold, tantalum and tungsten)
12. Other electrical/electronic components (may contain tin, gold, tantalum and tungsten)
5


 

 
Reasonable Country of Origin Inquiry
 
Our supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between us as the manufacturer of the Covered Products and the original sources of Conflict Minerals.  In this regard, we do not typically purchase Conflict Minerals directly from mines, smelters or refiners.  We must therefore rely on our suppliers to provide information regarding the origin of Conflict Minerals that are included in the Covered Products.  Moreover, we believe that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and therefore have taken steps to identify the applicable smelters and refiners of Conflict Minerals in our supply chain.

We believe that we conducted a good faith reasonable country of origin inquiry, or RCOI, to provide a reasonable basis for us to determine whether we source Conflict Minerals from the Covered Countries.  This good faith RCOI was designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources.  We are utilizing the supplier engagement approach outlined by the Conflict Free Sourcing Initiative (“CFSI”), including the utilization of their Conflict Minerals Reporting Template (“CMRT”).

As the first step in our RCOI, we determined which of our products would most likely contain the 3TGs.  After review, it was decided that substantially all of the products that we manufacture are Covered Products.  Next, we identified six (6) main component part groups used in the Covered Products that were most likely to contain 3TGs.  We further refined our list of in scope suppliers by filtering out service providers, indirect materials suppliers, and inactive suppliers. It was deemed appropriate not to filter this list any further. Utilizing our supply chain data systems, suppliers providing parts in those component part groups were identified.  Because some key contact information for those suppliers was not available in our systems, we initiated a process to gather that information.

Once supplier contact information was obtained, that information as well as the applicable part group information was uploaded into the web-based compliance tool. Along with our third-party service provider, we then conducted the supplier survey portion of the RCOI. Our in scope suppliers were contacted via a Software as a Service (“SaaS”) platform called Material Disclosure that enables its users to complete and track supplier communications, and request that suppliers complete and upload a CMRT for the products they provide to us.  Included in the supplier requests was a link to our Conflict Minerals Policy (“Policy”) to reinforce our commitment to sourcing responsibly and to make clear the responsibility of each of our suppliers to support us to fulfill this commitment.

As indicated in our Policy, we require suppliers to provide their Conflict Minerals information using the CFSI’s CMRT.  To provide suppliers flexibility, we allowed them to provide their responses to the CMRT by submitting their completed CMRT via e-mail, by uploading the CMRT to the compliance website or to directly answer a questionnaire in Material Disclosure that mimicked the CMRT.  For those suppliers who provided their Conflict Minerals information without using the CMRT, e-mails were promptly sent indicating that the information was not acceptable and that the CMRT must be used.  All submitted CMRTs are maintained on the servers of the compliance website.
6


 

During our review and analysis of the submitted CMRTs, it was clear that many suppliers erroneously assumed that the country of operation of the smelter as listed in the CMRT was the country of origin of the Conflict Minerals.  This led to incorrect and inconsistent responses to many of the questions in the submitted CMRTs.

Suppliers providing CMRTs that lacked key information, especially a list or other identification of SORs were contacted by Regal via telephone.  Those suppliers were then monitored for their responses.

Because of recent acquisitions as well as better supplier contact information, we expanded our RCOI from 1,200 suppliers contacted for the 2014 reporting period to 1800 suppliers in the 2015 reporting period.  The supplier response rate to our RCOI was approximately 26%.

We consolidated and reviewed all SORs information received from suppliers.  The initial consolidated list of organizations suppliers identified as smelters was in excess of 4,000.  It was noted that some smelters were duplicated due to the use of various alternate names.  After consulting the CMRT, the CFSI website and other internet sites, the duplicates were removed.  Further consolidation was completed with the help of an outside consultant.  There remained 312 smelters consistent with the definition used by the CFSI organization (135 gold, 47 tantalum, 85 tin and 45 tungsten).  The 312 smelters are indicated in Annex 1.  The 312 smelters identified this year compares to 255 smelters identified in our 2014 RCOI.  After directly contacting all 312 smelters and performing a risk assessment regarding responses, 41 smelters were either identified as sourcing Conflict Minerals from the Covered Countries or we had reason to believe they source Conflict Minerals from the Covered Countries. The 41 smelters are indicated in Annex II.  Of the 41 smelters, 10 are gold smelters, 24 tantalum smelters, 3 tin and 4 tungsten.  This assessment was based on information obtained directly from the smelters and from other public information available at the time with the assistance of the aforementioned conflict minerals consultant.

In accordance with the Rule and the results of our RCOI, we believed we were required to exercise due diligence on the conflict minerals’ source and chain of custody relating to those suppliers using the 41 smelters noted above.
 
7


 
Conflict Minerals Policy
 
We developed our Policy and published it on our website in April 2013 at http://investors.regalbeloit.com/phoenix.zhtml?c=116222&p=irol-govconflictmineral.  Further, Regal supports conflict-free minerals trade in the DRC and Covered Countries and will not avoid sourcing from conflict-free organizations in the region.  In addition to our efforts directly related to Conflict Minerals, we already had a strong company commitment to conducting business in an ethical manner as detailed in our Code of Business Conduct & Ethics as well as our Global Anti-Corruption Policy, both of which are also available on our website (http://investors.regalbeloit.com/phoenix.zhtml?c=116222&p=irol-govIntComp).  These documents detail how we conduct our business. We also have an Integrity Alert line through which suppliers, customers, company employees or any interested stakeholder can communicate their thoughts, concerns and grievances regarding Conflict Minerals or, more generally, any of our business practices.  A link to our Integrity Alert Line is available here. (http://investors.regalbeloit.com/phoenix.zhtml?c=116222&p=irol-govIntegrity)
 
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 Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”).  We utilize all five steps of the OECD Guidance for downstream companies.

Establish Strong Company Management Systems

Regal is committed to sourcing conflict-free minerals from the DRC and Covered Countries, and as such, we have communicated our Policy to our suppliers and customers. Our Policy was provided to suppliers during our RCOI process. Our Policy is provided to customers requesting Conflict Minerals information.  This Policy is publicly available on our website as discussed above.

Consistent with the OECD Guidance, we formed an internal team tasked with supporting supply chain due diligence.  This team consists of vice presidents from the following functional groups: Legal, Supply Chain, Technology, Engineering Services, and Environmental, Health, Safety and Sustainability (EHSS).  Additional members of the committee included the Director of Supplier Quality and Development and our materials compliance manager.  As needed, we also called upon the vice president of Information Technology and other groups for support.

We utilized the CFSI’s CFSP as a compliance standard for upstream due diligence. All responses from suppliers and source smelters are recorded and stored for a minimum of five years. We have implemented an RCOI process. Conflict minerals compliance is included as a requirement in our Supplier Quality Manual as well as our standard agreement template for suppliers.  Conflict minerals compliance process and documentation review have been added as new requirements of our Supplier Audit Assessment and Production Part Approval Process.
8



 
Regal Beloit Corporation joined CFSI in 2015 and is continuing its membership in 2016.

Identify and Assess Risk in the Supply Chain
 
For upstream due diligence, we have adopted the processes and protocols of the CFSP. We believe that all 3TGs “necessary to the functionality of the products” have been identified, the suppliers of those 3TGs have been identified and smelter data has been collected from those that responded to our RCOI.  Responses provided by suppliers have undergone a review for accuracy.

Design and Implement a Strategy to Respond to Identified Risks
 
We have implemented a plan to report Conflict Minerals findings to Charles A. Hinrichs, Vice President, Chief  Financial Officer, who is the member of senior management appointed for this role. A process has been adopted to aggregate and update the list of smelters.  Furthermore, a process has been adopted to review supplier responses, follow up with delinquent suppliers, and update supplier information.  A risk management process has been adopted that manages smelters that cannot provide country of origin information, identifies high-risk smelters, tracks and records compliance information for individual smelters, and communicates these results back to Mr. Hinrichs.  We require new suppliers to complete a CMRT as part of becoming an approved supplier to Regal Beloit.
 
Carry out an Independent Third Party Audit of Refiner’s Due Diligence Practices
 
We have utilized the risk management and due diligence processes of the CFSP and the CFSP’s independent third party audit process performed on smelters that source from the Covered Countries.  This includes other programs accepted by the CFSP, including the certification processes of the London Bullion Market Association (LBMA), The Responsible Jewellery Council (RJC), and the Tungsten Industry – Conflict Minerals Council (TI-CMC).  To be identified as conflict free, we require smelters to be compliant with the requirements of the CFSP requirements if they are sourcing from the Covered Countries.
 
Report on Supply Chain Due Diligence
 
In accordance with the OECD Guidance and the Conflict Minerals Rule, this Conflict Minerals Report is also available on our website (http://investors.regalbeloit.com/phoenix.zhtml?c=116222&p=irol-sec).
 

9


 
Due Diligence Results

Of the 41 smelters either identified as sourcing conflict minerals from Covered Countries or those which Regal Beloit has reason to believe source conflict minerals from the Covered Countries, 37 smelters (7 gold, 24 tantalum, 2 tin and 4 tungsten) were compliant with the CFSP assessment.  The four smelters we have reason to believe are sourcing from the Covered Countries and that are not compliant with the CFSP assessment are as follows:
 

Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Sudan Gold Refinery
SUDAN
Tin
Phoenix Metal Ltd.
RWANDA

The smelters were reviewed against publicly available information to determine if there was any reason to believe that they directly or indirectly finance or benefit armed groups in conflict region of the DRC.  This investigation included a review of reports to the UN by the UN Group of Experts on the Democratic Republic of the Congo, publications by the non-governmental organizations the Enough Project, Global Witness, and the Southern Africa Resource Watch, publications by Radio Okapi, and a general search of the Internet.
 
Of the 4 smelters listed above, Phoenix Metal Ltd. is currently active in the CFSP, but not yet compliant.  The review of publically available information indicated that there was no reason to believe that Phoenix Metal directly or indirectly financed or benefited armed groups in the Covered Countries.  The remaining 3 smelters are not active in the CFSP.  The review of publically available information concerning Al Etihad Gold Refinery DMCC did not indicate that this smelter was directly or indirectly financing or benefiting armed groups in the Covered Countries.  Information regarding Kaloti Precious Metals and Sudan Gold Refinery also did not indicate that these smelters were directly financing or benefiting the armed groups in the Covered Countries, however, the information obtained indicates that Kaloti and Sudan Gold Refinery do not appear to match the core values of Regal as indicated in our Policy; as such, Regal is actively working with our supply chain to remove these smelters from our supply chain via our risk mitigation process.

Risk Mitigation Process

The following is an outline of the process we have developed and are currently working relative to the 7 suppliers who have indicated that Kaloti Precious Metals and Sudan Gold Refinery are in their supply chains and thus Regal’s.

· Since the 7 suppliers provided company level information during our RCOI rather than part specific information, we will conduct a review of engineering drawings and material specifications and conduct chemical analysis as appropriate to identify which if any of the parts supplied by the 7 suppliers contain gold.  If described information is inconclusive, engage with the supplier to confirm the presence of gold, in accordance with the requirements of the SEC rules, in the parts being supplied to Regal.  (On-going since February 29, 2016)
10


 

· For parts where gold is confirmed intentionally added and necessary to functionality, request smelter information specific to the gold used in those parts. (On-going since February 29, 2016)

· If the smelters so identified are linked to the gold used in the parts, ensure that suppliers are actively trying to remove these smelters from their supply chains and will communicate with Regal the results of their activities. (Initiated with 1 supplier on April 6, 2016; other suppliers pending)

· For suppliers failing to actively remove or failing to communicate their progress to remove these smelters from their supply chains, Regal will remove these suppliers from its supply chain. (Decision to be made by June 30, 2016)

Facility and Mine Information
 
Based on the information provided by our suppliers and our own due diligence efforts, we believe that, to the best of our knowledge, the smelters that may have been used to process the Conflict Minerals in our products include the smelters listed in Annex 1 below.  Further, some of the smelters used by Regal Beloit's suppliers that have been identified to or we have reason to believe may source from the Covered Countries have been identified to source from the DRC, Rwanda, Burundi and Tanzania.  Information regarding the mines from which minerals processed at these smelters were sourced is not always publicly available and was not disclosed by these smelters. Accordingly, we are not able to identify with certainty all of the countries of origin of the conflict minerals processed at the indicated smelters.
 
11

 
Additional Risk Factors
 
The statements above are based on the RCOI process and due diligence performed in good faith by Regal Beloit Corporation.  A number of factors could introduce errors or otherwise affect our conclusion.  These factors include, but are not limited to the following:
 
1. Gaps in supplier data
2. Gaps in knowledge of the chemistry of the component parts and materials provided by suppliers
3. Gaps in smelter data and the source of their conflict minerals
4. Errors or omissions in survey responses provided by suppliers
5. Errors or omissions by smelters
6. Gaps in supplier education and knowledge
7. Supplier uncertainty regarding country of operation of the smelter and/or refiner versus country of origin of the conflict minerals
8. Not all instances of conflict minerals necessary to the functionality or production of our Covered Products were identified
9. Timeliness of data
10. Public information not discovered during a reasonable search
11. Errors in public data
12. Language barriers and translation
13. Supplier and smelter unfamiliarity with the protocol relating to the Rule
14. Oversights or errors in conflict free smelter audits
15. DRC-sourced materials being declared secondary materials
16. Companies going out of business in 2015
17. Certification programs not being equally advanced for all industry segments and metals
18. Smuggling of DRC conflict minerals to countries beyond the Covered Countries
 
12


 

Process Improvement Considerations

We intend to take the following steps to improve our processes surrounding conflict minerals to further mitigate any risk that the necessary conflict minerals in our Covered Products could benefit armed groups in the Covered Countries:

1. Engage with suppliers and direct them to training resources to attempt to increase the response rate and to improve the quality of the content of suppliers’ conflict minerals information, especially smelter information.
2. Identify those suppliers who do not have a conflict minerals program and work with the suppliers to set up a program.
3. Engage with suppliers to encourage them to implement responsible sourcing and to have them encourage smelters and refiners to obtain a “conflict-free” designation from an independent third-party auditor.
4. For suppliers found to be using smelters sourcing from, or for which we have reason to believe are sourcing from, the Covered Countries and who are not compliant with the requirements of the CFSP, we encourage them to use CFSP compliant smelters.
5. Expand our knowledge of the chemistry of the component parts and materials contained in our Covered Products by conducting chemical analysis and/or requesting specific chemical information from our suppliers on each component part or material used in the Covered Products to further identify those suppliers providing conflict minerals and their derivatives.  To date we have conducted analysis of over 16,000 materials used in over 6,000 component parts.
13


 
Annex I

List of Smelters and Refiners Identified in Regal Beloit Corporation’s Supply Chain

Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
Gold
Advanced Chemical Company
UNITED STATES
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Aktyubinsk Copper Company TOO
KAZAKHSTAN
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 SA
SWITZERLAND
Gold
Asahi Pretec Corporation
JAPAN
Gold
Asahi Refining Canada Limited
CANADA
Gold
Asahi Refining USA Inc.
UNITED STATES
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
AURA-II
UNITED STATES
Gold
Aurubis AG
GERMANY
Gold
Bangalore Refinery (P) Ltd.
INDIA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Bauer Walser AG
GERMANY
Gold
Boliden AB
SWEDEN
Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
Caridad
MEXICO
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Cendres + Métaux SA
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
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
Faggi Enrico S.p.A.
ITALY
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Gold
Geib Refining Corporation
UNITED STATES
Gold
Guangdong Jinding Gold Limited
CHINA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Henan Yuguang Gold & Lead Co., Ltd.
CHINA
Gold
Heraeus Ltd. Hong Kong
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY

14


 
Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Company Limited
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 Metal Co., Ltd.
KOREA, REPUBLIC OF
Gold
Korea Zinc Co. Ltd.
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
L' azurde Company For Jewelry
SAUDI ARABIA
Gold
Lingbao Gold Company Limited
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
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
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
MEXICO
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalor Technologies SA
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
Morris and Watson
NEW ZEALAND
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 Kolyma Refinery
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
PAMP SA
SWITZERLAND
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA

15


 
Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
Gold
PX Précinox SA
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Republic Metals Corporation
UNITED STATES
Gold
Royal Canadian Mint
CANADA
Gold
Sabin Metal Corp.
UNITED STATES
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 SA
SPAIN
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Shenzhen Zhonghenglong Real Industry 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
Super Dragon Technology Company
TAIWAN
Gold
T.C.A S.p.A
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
The Great Wall Gold and Silver Refinery of China
CHINA
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.
BRAZIL
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Umicore SA Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Gold
Valcambi SA
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
Zhongkuang Gold Industry Co., Ltd.
CHINA
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
Zhuzhou Smelting Group Co., Ltd.
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
16


Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
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
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
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
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
CHINA
Tin
Alpha
UNITED STATES
Tin
An Thai Minerals Company Limited
VIET NAM
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
Chenzhou Yunxiang Mining and Metallurgy Company Limited
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 Gita Pesona
INDONESIA
Tin
CV Serumpun Sebalai
INDONESIA

17


 

Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
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. (Metallo Group)
SPAIN
Tin
EM Vinto
BOLIVIA
Tin
Estanho de Rondônia S.A.
BRAZIL
Tin
Feinhütte Halsbrücke GmbH
GERMANY
Tin
Fenix Metals
POLAND
Tin
Gejiu Jinye Mineral Co., Ltd.
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
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Tin
Linwu Xianggui Ore Smelting 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
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 Alam Lestari Kencana
INDONESIA
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 Kudai Tin
INDONESIA
Tin
PT Bangka Prima Tin
INDONESIA
Tin
PT Bangka Timah Utama Sejahtera
INDONESIA
Tin
PT Bangka Tin Industry
INDONESIA
Tin
PT Belitung Industri Sejahtera
INDONESIA
Tin
PT BilliTin Makmur Lestari
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 Fang Di MulTindo
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA
Tin
PT Justindo
INDONESIA


18

Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
Tin
PT Karimun Mining
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Pelat Timah Nusantara Tbk
INDONESIA
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 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 Tirus Putra Mandiri
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
Super Ligas
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
Xianghualing Tin Industry Co., Ltd.
CHINA
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Tin Group (Holding) Company Limited
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
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 Jincheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Ganxian Shirui New Material Co., Ltd.
CHINA
Tungsten
Ganzhou Haichuang Tungsten Industry Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Non-ferrous Metals Smelting 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 Chuangda Vanadium Tungsten Co., Ltd. Yanglin
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION

19


 

Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
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
Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd
CHINA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Niagara Refining LLC
UNITED STATES
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Tungsten
Pobedit, JSC
RUSSIAN FEDERATION
Tungsten
Sanher Tungsten Vietnam Co., Ltd.
VIET NAM
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA

20


 
Annex II

List of Smelters and Refiners Sourcing or Believed to be Sourcing from the Covered Countries

Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
Argor-Heraeus SA
SWITZERLAND
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
PAMP SA
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Sudan Gold Refinery
SUDAN
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Tantalum
Duoluoshan
CHINA
Tantalum
F&X Electro-Materials Ltd.
CHINA
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
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
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
KEMET Blue Powder
UNITED STATES
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
Plansee SE Liezen
AUSTRIA
Tantalum
Plansee SE Reutte
AUSTRIA
Tantalum
Taki Chemicals
JAPAN
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN

21


 
Subject Mineral
Smelter or Refiner Name
Country Location of Smelter or Refiner
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Phoenix Metal Ltd.
RWANDA
Tin
Thaisarco
THAILAND
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA

 
22