EX-1.01 2 a2017formsdcmrexhibit-may3.htm EXHIBIT 1.01 Exhibit


Exhibit 1.01

TriMas Corporation
Conflict Minerals Report
For the Reporting Period January 1, 2016 to December 31, 2016

TriMas Corporation (“TriMas” or the “Company”) is filing this Conflict Minerals Report (“CMR”) for the reporting period January 1, 2016 to December 31, 2016 (the “Reporting Period”) as an exhibit to its Form SD (“Form SD”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). TriMas manufactures or contracts to manufacture “products” that may contain conflict minerals, as defined by the Rule, present in its supply chain that may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) and may not be from recycled or scrap sources. Accordingly, TriMas is filing this CMR as an exhibit to Form SD to describe the due diligence measures taken to determine the source and chain of custody of the conflict minerals used in its products during the Reporting Period.

1)    Reasonable Country of Origin Inquiry

In accordance with the Rule and Form SD, TriMas conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the conflict minerals included in its products during the Reporting Period to determine whether any of such conflict minerals originated in the Covered Countries and/or whether any of such conflict minerals may be from recycled or scrap sources.

a)
Supplier Engagement

To complete the RCOI, TriMas’ in-scope tier 1 suppliers (“Tier 1 Suppliers”) were requested to provide information regarding the presence and sourcing of conflict minerals used in the products supplied to TriMas. The program utilized the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (“CMRT,” also referred to as “surveys” or “declarations”). Suppliers were offered two options to submit the required information, either by uploading a completed CMRT or by completing an online survey version of the template directly to a third-party platform operated by Assent Compliance, a vendor retained by TriMas.

During the supplier survey, suppliers were contacted via Assent Compliance Manager, a SaaS platform, operated by Assent Compliance, that enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRT forms directly to the platform for risk assessment and management. In their responses, suppliers specified whether information was being provided at the company level or the product level. Non-responsive suppliers were contacted a minimum of three times by Assent Compliance Manager and then were also managed by the Assent Compliance supply chain team in one-on-one communications. This included two follow ups from the supply chain team. For the 2016 reporting period, TriMas received responses from 470, or 91%, of its 516 surveyed suppliers. Of the 470 suppliers that provided a response, approximately 104 reported that their products contained either tin, tantalum, tungsten or gold (“3TG”) necessary to the functionality or production of their products.

Automated data validation on all submitted CMRTs is included in the program. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. For the 2016 reporting period, TriMas had 19 invalid CMRTs, or 4% of submitted responses.

As mentioned above, the CMRTs received allowed TriMas to collect and compile, via Assent Compliance Manager, all answers from the CMRT with respect to smelter information reflected in the CMRTs. With respect to smelter information reflected in the CMRTs, there were suppliers who did not provide smelter lists. Without having full smelter information for TriMas products from all suppliers in scope, TriMas is unable to determine that there is no sourcing from the Covered Countries. In connection with its evaluation of the CMRTs, TriMas and Assent undertook due diligence to validate supplier reports.





b)    Information Cut-Off

The deadline for suppliers to submit RCOI information for the Reporting Period was May 8, 2017.

2)    Due Diligence Process

Based on the information obtained pursuant to the RCOI process described above, the Company conducted additional due diligence to determine the source and chain of custody of the conflict minerals used in its products during the Reporting Period.

TriMas’ due diligence process is based on the Organization for Economic Cooperation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements. The OECD Guidance was written for both upstream1 and downstream2 companies in the supply chain. As TriMas is a downstream company in the supply chain, TriMas’ due diligence practices were tailored accordingly. Due diligence measures undertaken by TriMas included the following:

a)Establish Strong Company Management Systems

Adopt A Conflict Minerals Policy

TriMas adopted a Responsible Sourcing and Conflict Minerals Policy (“Conflict Minerals Policy”). This policy is available on TriMas’ website at www.trimascorp.com/supplier.htm.

Assemble An Internal Team To Support Supply Chain Due Diligence

TriMas’ Senior Management Compliance Committee (the “SMCC”) identified individuals representing multiple TriMas departments and business units to oversee and drive conflict minerals compliance. Together with Assent Compliance, TriMas’ Chief Compliance Officer worked with the Company’s business units to complete tasks associated with the supplier due diligence process. Individual leads within the business units further facilitated the diligence process to collect information regarding the presence and sourcing of conflict minerals in the products supplied to TriMas.

Establish A System Of Controls And Transparency Over The Supply Chain

To provide better transparency within TriMas’ supply chain and to facilitate communication of policies and expectations, TriMas engaged a third-party information management service provider (Assent Compliance) to complement internal management processes. The Assent Compliance online system and processes are used to identify suppliers in TriMas’ supply chain and collect, store, and review information on conflict minerals sourcing practices, track information on SORs, and flag risks based on SOR sourcing practices. This system is designed to allow collection and housing of data on supply chain circumstances, which can be updated to reflect changes within the supply chain, such as new customer-supplier relationships and new products.

TriMas mandated compliance in its supply chain with TriMas’ Conflict Minerals Policy through its contractual terms and conditions.

TriMas maintains an ethics hotline accessible at www.trimascorp.com through which a party, including TriMas employees and suppliers, may submit reports or concerns regarding compliance, including with respect to conflict minerals.

________________
1 Upstream companies refer to those between the mine and smelters or refiners (“SOR”). As such, the companies typically include miners, local traders, or exporters from the country of mineral origin, international concentrate traders, and SORs.
2 Downstream companies refer to those entities between the SOR and retailer. As such, the companies typically include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers, and retailers.




Implement Internal Measures Taken To Strengthen Company Engagement With Suppliers

TriMas has increased its supply chain transparency by identifying risks within its supply chain. TriMas is committed to conducting business in a socially responsible manner and partnering with suppliers who are similarly committed. TriMas’ supplier compliance process requires that suppliers comply with various contract provisions, legal requirements and industrial standards under local, regional and national laws and regulations of the countries in which the suppliers conduct business. Through this process, TriMas remains engaged with its supply base from a compliance perspective.

During this reporting period, we utilized the Conflict Minerals Reporting Template (CMRT) version 4.2 to collect conflict minerals declarations from our Tier 1 Suppliers. These declarations were uploaded into the Assent Compliance Manager web-based reporting platform. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements, and increase the rate of responses we have received from our suppliers to our survey requests. Assent followed up with suppliers to ensure proper completion of the CMRT, and all communication with suppliers has been documented to reflect the degree of success of these efforts.

This reporting year, TriMas placed a strong emphasis on supplier education and training. To accomplish this, we utilized Assent’s Learning Management System, Assent University, and provided all Tier 1 Suppliers access to a comprehensive Conflict Minerals training course. This training is tracked and evaluated based on completion of course modules. All Tier 1 Suppliers are encouraged to complete all relevant modules of the conflict minerals course, which include active learning techniques and testing at the end of each module.

Reporting Mechanism

We have established reporting mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Conflict Minerals Policy.

b)
Identify and Assess Risk in Our Supply Chain

TriMas identified 516 Tier 1 Suppliers. We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. We believe many of our largest suppliers are suppliers to other SEC registrants that are subject to the Rule.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as DRC-conflict free by third party sources such as the Conflict-Free Sourcing Initiative (“CFSI”) or the London Bullion Market Association (“LBMA”) Responsible Gold Programme, may pose a significant risk. Where a smelter is not identified as conflict free by such sources, we rate the risk as high, medium or low. This rating is based on various factors, including whether the smelter/refiner has been identified as a valid smelter/refiner and has an associated Smelter Identification Number (under the CFSI, this is known as a CID), and the smelter’s geographic location, including proximity to the Covered Countries.

We calculate supplier risk based on the chance that a supplier provides 3TGs that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that Supplier on their CMRT.

Additionally, each supplier is evaluated on the strength of its conflict minerals program (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of a supplier’s program are:

•Do you have a policy in place that includes DRC conflict-free sourcing?
•Have you implemented due diligence measures for conflict-free sourcing?
•Do you verify due diligence information received from your suppliers?
•Does your verification process include corrective action management?




The more positive the responses to these questions indicate a stronger conflict sourcing initiative.

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

In accordance with our Conflict Minerals Policy, if a supplier we have engaged gives us reason to believe that it may be supplying us with 3TG from sources that may support conflict in a Covered Country, we encourage the supplier to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we may initiate steps to find replacement suppliers.

Once surveys were returned, Assent reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the CFSI Conflict-Free Smelter Program (CFSP). If an SOR was not validated by the CFSP, Assent either attempted to contact the SOR to gather more information about its sourcing practices or conducted Internet research to determine whether there are any additional publicly available sources of information regarding the SOR’s sourcing practices.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free may pose a significant risk to the supply chain. Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:

•Geographic proximity to the DRC and covered countries;
•Conflict-Free Smelter Program (CFSP) audit status;
•Known or plausible evidence of unethical or conflict sourcing.

Per these criteria, the following facilities have been identified as being of highest concern:

•
Tony Goetz NV - CID002587
•
Kaloti Precious Metals - CID002563
•
Phoenix Metals - CID002507
•
Universal Precious Metals Refining Zambia - CID002854
•
Fidelity Printers and Refiners - CID002515
•
Sudan Gold Refinery - CID002567

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

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.

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




c)
Design and Implement a Strategy to Respond to Risks

As part of TriMas’ strategy to mitigate risk and to ensure suppliers understand our expectations, we have provided video, recorded training, and documented instructions through Assent Compliance. Responses to the reporting CMRT were reviewed with specific suppliers where clarification was needed. As described in our Conflict Minerals Policy, we intend to engage any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in the DRC or any adjoining country to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.

Suppliers that may expose the Company to unacceptable risks, either due to unacceptable responses to our inquiries or a refusal to respond, may be evaluated by the SMCC.

d)
Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

TriMas does not have a direct relationship with conflict minerals smelters or refiners and as a result, TriMas does not perform direct audits of these entities in its supply chain. TriMas relies on the efforts of the industry associations that administer independent third-party smelter and refinery audit programs and encourages suppliers with more direct relationships with smelters to participate in comparable due diligence validation activities.

Assent Compliance conducts outreach to all smelters and refineries that are not enrolled in the CFSI’s Conflict Free Smelter Program (CFSP) on behalf of TriMas. The purpose of this outreach is to encourage participation in the CFSP and to inquire about the facility’s sourcing practices and infrastructure.

e)
Report Annually on Supply Chain Due Diligence

TriMas’ Form SD and CMR are publicly available at www.trimascorp.com and meet the OECD recommendation to report annually on supply chain due diligence.

3)    Diligence Results

TriMas identified 516 Tier 1 Suppliers for the CMR for the Reporting Period. Approximately 91% of the Tier 1 suppliers responded to TriMas’ conflict minerals survey and 32% of the responding suppliers indicated one or more of the regulated conflict minerals metals as necessary to the functionality or production of the products supplied to TriMas. Based on the RCOI and the due diligence measures described in this CMR, specifically the fact that most CMRTs are at the company level and not the product level specifically pertaining to TriMas products, TriMas was unable to validate that any of the SORs identified by suppliers are in its supply chain.

The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the SORs identified by our direct suppliers may contain SORs that processed conflict minerals that our direct suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the SORs were used to process the conflict minerals necessary to the functionality or production of our products during 2016. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin identified were the country of origin of conflict minerals in our products during 2016, and therefore also unable to determine the source and chain of custody of those conflict minerals. In addition, the third-party audits conducted by the CFSI, the LBMA and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the CFSI Conflict-Free Smelter Program or the LBMA Responsible Gold Programme and, as a result, are not responsible for the quality of these audits or the audit findings.

For all responses that indicated a smelter, Assent Compliance compared the facilities listed to the list of smelters maintained by the “CFSI.” If a supplier indicated that the facility was certified as “Conflict-Free,” Assent confirmed that the name was



listed by CFSI as a certified smelter. As of May 8, 2017, we have validated 313 SORs and we are working to validate the additional SOR entries from the submitted CMRTs. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any SORs that we have not been able to validate. Appendix A 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 CFSI.

4)    Steps to Improve Due Diligence and Mitigate Risk

TriMas will work to continuously improve its supply chain due diligence efforts through the following measures:

a)
Continue supply chain due diligence efforts and engagement with suppliers to identify sources of conflict minerals;
b)
Continue to clearly communicate expectations with regard to supplier compliance, transparency and sourcing;
c)
Continue to engage with suppliers that provided incomplete or uncertain smelter information or did not respond to our survey request;
d)
Continue to compare RCOI results to information collected via independent conflict free smelter validation programs; and
e)
Contact smelters identified as a result of the RCOI process and request their participation in obtaining a “conflict free” designation from an industry program.

 Forward-Looking Statements

Any "forward-looking" statements, within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934, contained herein, including those relating to the Company's business, financial condition or future results, involve risks and uncertainties with respect to, including, but not limited to: the Company's leverage; liabilities imposed by the Company's debt instruments; market demand; competitive factors; supply constraints; material and energy costs; intangible assets, including goodwill or other intangible asset impairment charges; technology factors; litigation; government and regulatory actions; the Company's accounting policies; future trends; general economic and currency conditions; the potential impact of Brexit; various conditions specific to the Company's business and industry; the Company's ability to identify attractive acquisition candidates, successfully integrate acquired operations or realize the intended benefits of such acquisitions; potential costs and savings related to facility consolidation activities; future prospects of the Company; and other risks that are detailed in the Company's Annual Report on Form 10-K for the fiscal year ended December 31, 2016. These risks and uncertainties may cause actual results to differ materially from those indicated by the forward-looking statements. All forward-looking statements made herein are based on information currently available, and the Company assumes no obligation to update any forward-looking statements.



APPENDIX A

In connection with our reasonable country of origin inquiry and due diligence, as applicable, our suppliers identified to us the smelters and refiners listed below as potentially having processed the necessary 3TG contained in our products in 2016. All information included in the table is as of May 8, 2017.

Any facility reported by a supplier to us as a smelter was cross-referenced with the CFSI Standard Smelter List that accompanied version 4.2 of the CMRT. There were 310 legitimate smelters identified. Of these, 246 have been certified compliant to CFSP sourcing audit assessment protocol and are considered “conflict-free.” An additional 12 facilities are active in the CFSP audit process. The remaining 55 facilities are not currently engaged with the CFSP audit program but have been contacted by Assent on our behalf to encourage them to undertake such an audit.

The large majority of the responses we received from the supplier survey provided data at a company or divisional level or were unable to specify the smelters or refiners used for components supplied to us. We are therefore unable to determine whether the 3TG’s reported by the suppliers were contained in components or parts supplied to us. Therefore we were unable to validate that any of these smelters or refiners listed here are actually in our supply chain.

Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
CFSI Audit Status
Gold
Abington Reldan Metals, LLC
UNITED STATES
CID002708
Active
Gold
Advanced Chemical Company
UNITED STATES
CID000015
Compliant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Compliant
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
CID002560
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Compliant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
CID000058
Compliant
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Compliant
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Compliant
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Compliant
Gold
Asahi Refining USA Inc.
UNITED STATES
CID000920
Compliant
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Compliant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
Not Enrolled
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Compliant
Gold
AURA-II
UNITED STATES
CID002851
Not Enrolled
Gold
Aurubis AG
GERMANY
CID000113
Compliant
Gold
Bangalore Refinery
INDIA
CID002863
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Compliant
Gold
Boliden AB
SWEDEN
CID000157
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Compliant
Gold
Caridad
MEXICO
CID000180
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Compliant
Gold
Cendres + Métaux S.A.
SWITZERLAND
CID000189
Active
Gold
Chimet S.p.A.
ITALY
CID000233
Compliant



Gold
Chugai Mining
JAPAN
CID000264
Not Enrolled
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
Compliant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
Not Enrolled
Gold
DODUCO GmbH
GERMANY
CID000362
Compliant
Gold
Dowa
JAPAN
CID000401
Compliant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Compliant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID000425
Compliant
Gold
Elemetal Refining, LLC
UNITED STATES
CID001322
Compliant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Compliant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
Not Enrolled
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
CID000522
Not Enrolled
Gold
Geib Refining Corporation
UNITED STATES
CID002459
Active
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
Not Enrolled
Gold
Gujarat Gold Centre
INDIA
CID002852
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000651
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
Not Enrolled
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Compliant
Gold
Heraeus Ltd. Hong Kong
CHINA
CID000707
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Compliant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
CID000778
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Compliant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Compliant
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Compliant
Gold
Japan Mint
JAPAN
CID000823
Compliant
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Compliant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
Not Enrolled
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
Not Enrolled
Gold
Kazzinc
KAZAKHSTAN
CID000957
Compliant
Gold
Kennecott Utah Copper LLC
UNITED STATES
CID000969
Compliant
Gold
KGHM Polska Miedź Spółka Akcyjna
POLAND
CID002511
Active



Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Compliant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Compliant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Compliant
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
Not Enrolled
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
Not Enrolled
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Compliant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Not Enrolled
Gold
Materion
UNITED STATES
CID001113
Compliant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Compliant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Compliant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Compliant
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Compliant
Gold
Metalor USA Refining Corporation
UNITED STATES
CID001157
Compliant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
CID001161
Compliant
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Compliant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Compliant
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Not Enrolled
Gold
Morris and Watson
NEW ZEALAND
CID002282
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
CID001220
Compliant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Active
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Compliant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Compliant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Compliant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Compliant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Compliant
Gold
PAMP S.A.
SWITZERLAND
CID001352
Compliant
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Not Enrolled
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Compliant
Gold
PX Précinox S.A.
SWITZERLAND
CID001498
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Compliant
Gold
Remondis Argentia B.V.
NETHERLANDS
CID002582
Not Enrolled



Gold
Republic Metals Corporation
UNITED STATES
CID002510
Compliant
Gold
Royal Canadian Mint
CANADA
CID001534
Compliant
Gold
SAAMP
FRANCE
CID002761
Not Enrolled
Gold
Sabin Metal Corp.
UNITED STATES
CID001546
Not Enrolled
Gold
SAFINA A.S.
CZECH REPUBLIC
CID002290
Not Enrolled
Gold
Sai Refinery
INDIA
CID002853
Not Enrolled
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Compliant
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
CID001562
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Compliant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
CID001573
Compliant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
CID001585
Compliant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
Not Enrolled
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Compliant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Compliant
Gold
Singway Technology Co., Ltd.
TAIWAN
CID002516
Compliant
Gold
So Accurate Group, Inc.
UNITED STATES
CID001754
Not Enrolled
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Compliant
Gold
Solar Applied Materials Technology Corp.
TAIWAN
CID001761
Compliant
Gold
Sudan Gold Refinery
SUDAN
CID002567
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Compliant
Gold
T.C.A S.p.A
ITALY
CID002580
Compliant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Compliant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Compliant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Not Enrolled
Gold
Tony Goetz NV
BELGIUM
CID002587
Active
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Not Enrolled
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Compliant
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Compliant
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Compliant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Compliant
Gold
United Precious Metal Refining, Inc.
UNITED STATES
CID001993
Compliant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
CID002854
Not Enrolled
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Compliant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
CID002030
Compliant
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Compliant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
CID002100
Compliant



Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Compliant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Compliant
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
CID002243
Compliant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
CID000291
Compliant
Tantalum
D Block Metals, LLC
UNITED STATES
CID002504
Compliant
Tantalum
Duoluoshan
CHINA
CID000410
Compliant
Tantalum
Exotech Inc.
UNITED STATES
CID000456
Compliant
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Compliant
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002505
Compliant
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Compliant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
CID002557
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Compliant
Tantalum
H.C. Starck GmbH Goslar
GERMANY
CID002545
Compliant
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
CID002546
Not Enrolled
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Compliant
Tantalum
H.C. Starck Inc.
UNITED STATES
CID002548
Compliant
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492
Compliant
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
CID000731
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002512
Compliant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID002842
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Compliant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Compliant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002506
Compliant
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Compliant
Tantalum
KEMET Blue Powder
UNITED STATES
CID002568
Compliant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
CID000973
Compliant
Tantalum
LSM Brasil S.A.
BRAZIL
CID001076
Compliant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Compliant
Tantalum
Mineração Taboca S.A.
BRAZIL
CID001175
Compliant
Tantalum
Mitsui Mining & Smelting
JAPAN
CID001192
Compliant
Tantalum
Molycorp Silmet A.S.
ESTONIA
CID001200
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Compliant



Tantalum
Plansee SE Liezen
AUSTRIA
CID002540
Not Enrolled
Tantalum
Plansee SE Reutte
AUSTRIA
CID002556
Compliant
Tantalum
Power Resources Ltd.
MACEDONIA
CID002847
Compliant
Tantalum
QuantumClean
UNITED STATES
CID001508
Compliant
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
CID002707
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
CID001522
Compliant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Compliant
Tantalum
Taki Chemicals
JAPAN
CID001869
Compliant
Tantalum
Telex Metals
UNITED STATES
CID001891
Compliant
Tantalum
Tranzact, Inc.
UNITED STATES
CID002571
Compliant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Compliant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Compliant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
CID002307
Compliant
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
CHINA
CID002232
Compliant
Tin
Alpha
UNITED STATES
CID000292
Compliant
Tin
An Thai Minerals Co., Ltd.
VIETNAM
CID002825
Not Enrolled
Tin
An Vinh Joint Stock Mineral Processing Company
VIETNAM
CID002703
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Compliant
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Compliant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
CID000278
Not Enrolled
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
CID000295
Compliant
Tin
CV Ayi Jaya
INDONESIA
CID002570
Compliant
Tin
CV Dua Sekawan
INDONESIA
CID002592
Compliant
Tin
CV Gita Pesona
INDONESIA
CID000306
Compliant
Tin
CV Serumpun Sebalai
INDONESIA
CID000313
Compliant
Tin
CV Tiga Sekawan
INDONESIA
CID002593
Compliant
Tin
CV United Smelting
INDONESIA
CID000315
Compliant
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Compliant
Tin
Dowa
JAPAN
CID000402
Compliant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIETNAM
CID002572
Active
Tin
Elmet S.L.U.
SPAIN
CID002774
Compliant
Tin
EM Vinto
BOLIVIA
CID000438
Compliant
Tin
Estanho de Rondônia S.A.
BRAZIL
CID000448
Not Enrolled
Tin
Fenix Metals
POLAND
CID000468
Compliant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Compliant
Tin
Gejiu Jinye Mineral Company
CHINA
CID002859
Compliant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Active



Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Compliant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908
Active
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Not Enrolled
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Compliant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Compliant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Not Enrolled
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
CID000244
Compliant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Compliant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Compliant
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Compliant
Tin
Metallic Resources, Inc.
UNITED STATES
CID001142
Compliant
Tin
Metallo-Chimique N.V.
BELGIUM
CID002773
Compliant
Tin
Mineração Taboca S.A.
BRAZIL
CID001173
Compliant
Tin
Minsur
PERU
CID001182
Compliant
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Compliant
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002858
Not Enrolled
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
CID001231
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIETNAM
CID002573
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Compliant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Compliant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
CID001337
Compliant
Tin
Phoenix Metal Ltd.
RWANDA
CID002507
Not Enrolled
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Compliant
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Compliant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Compliant
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Compliant
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Compliant
Tin
PT Bangka Tin Industry
INDONESIA
CID001419
Compliant
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Compliant
Tin
PT Bukit Timah
INDONESIA
CID001428
Compliant
Tin
PT Cipta Persada Mulia
INDONESIA
CID002696
Compliant
Tin
PT DS Jaya Abadi
INDONESIA
CID001434
Compliant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
CID001438
Compliant
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Compliant
Tin
PT Justindo
INDONESIA
CID000307
Not Enrolled
Tin
PT Karimun Mining
INDONESIA
CID001448
Compliant
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829
Compliant



Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002870
Compliant
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Compliant
Tin
PT O.M. Indonesia
INDONESIA
CID002757
Compliant
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Compliant
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Compliant
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Compliant
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Compliant
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Compliant
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816
Compliant
Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
Compliant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
CID001477
Compliant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
CID001482
Compliant
Tin
PT Tinindo Inter Nusa
INDONESIA
CID001490
Compliant
Tin
PT Tommy Utama
INDONESIA
CID001493
Compliant
Tin
PT Wahana Perkit Jaya
INDONESIA
CID002479
Compliant
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
CID002706
Compliant
Tin
Rui Da Hung
TAIWAN
CID001539
Compliant
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Compliant
Tin
Thaisarco
THAILAND
CID001898
Compliant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIETNAM
CID002574
Not Enrolled
Tin
VQB Mineral and Trading Group JSC
VIETNAM
CID002015
Compliant
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
CID002036
Compliant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Active
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Compliant
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
CID000004
Compliant
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Not Enrolled
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIETNAM
CID002502
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Compliant
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
CID000345
Not Enrolled
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Compliant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Compliant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
CID002536
Not Enrolled
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
CID000568
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Compliant



Tungsten
H.C. Starck GmbH
GERMANY
CID002541
Compliant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
CID002542
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Compliant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Compliant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Compliant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Compliant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Compliant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002647
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Compliant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313
Not Enrolled
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Compliant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Compliant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
CID002535
Compliant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Compliant
Tungsten
Kennametal Fallon
UNITED STATES
CID000966
Compliant
Tungsten
Kennametal Huntsville
UNITED STATES
CID000105
Compliant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Compliant
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
CID002845
Compliant
Tungsten
Niagara Refining LLC
UNITED STATES
CID002589
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIETNAM
CID002543
Compliant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Compliant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID002815
Compliant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIETNAM
CID001889
Compliant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Compliant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIETNAM
CID002011
Compliant
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
CID002044
Compliant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Compliant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Compliant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Compliant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095
Compliant




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