UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Badger Meter, Inc.
(Exact name of registrant as specified in its charter)
| Wisconsin | 001-06706 | 39-0143280 | ||||||
| (State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
4545 W. Brown Deer Road, Milwaukee, Wisconsin 53223
(Address of principal executive offices)
William R. A. Bergum
Vice President – General Counsel and Secretary
(414) 371-5707
(Name and telephone number, including area code, of person to contact in connection with this report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015. |
Section 1 – Conflict Minerals Disclosure
| Item 1.01 | Conflict Minerals Disclosure and Report |
Conflict Minerals Disclosure
A copy of Badger Meter, Inc.’s (the “Company”) Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at https://www.badgermeter.com/supply-chain/.
| Item 1.02 | Exhibit |
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 – Exhibits
| Item 2.01 | Exhibits |
The following exhibit is filed as part of this report.
| Exhibit No. |
Description | |
| 1.01 | Conflict Minerals Report of Badger Meter, Inc. | |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
BADGER METER, INC.
| By: | /s/ William R. A. Bergum |
May 31, 2016 | ||||
| William R. A. Bergum Vice President – General Counsel and Secretary |
(Date) |
EXHIBIT INDEX
| Exhibit No. |
Description | |
| 1.01 | Conflict Minerals Report of Badger Meter, Inc. | |
Exhibit 1.01
Badger Meter, Inc.
Conflict Minerals Report
For the Reporting Period from January 1, 2015 to December 31, 2015
This report for the period from January 1, 2015 to December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (the Rule). The Rule was adopted to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Rule imposes reporting obligations on Securities and Exchange Commission (SEC) registrants whose manufactured products contain certain minerals which are necessary to the functionality or production of their products.
If a registrant determines that any columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten (Subject Minerals), are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured, the registrant must conduct in good faith a Reasonable Country of Origin Inquiry (RCOI) regarding those Subject Minerals that is reasonably designed to determine whether any of the Subject Minerals originated in the Democratic Republic of the Congo or an adjoining country (Covered Countries) or are from recycled or scrap sources.
If, following the completion of the RCOI, a registrant knows that any of the necessary Subject Minerals originated in a Covered Country and are not from recycled or scrap sources, or has reason to believe that its necessary Subject Minerals may have originated in the Covered Countries and has reason to believe that its necessary Subject Minerals did not come from recycled or scrap sources, then the registrant must exercise due diligence on the source and chain of custody of the Subject Minerals that conforms to a nationally or internationally recognized due diligence framework and describe such due diligence in this separate Conflict Minerals Report.
In accordance with the Organisation for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, the related supplements on tin, tungsten, tantalum and gold (the Guidance) and the Rule, this report is available on our website at https://www.badgermeter.com/supply-chain/.
Consistent with the provisions of the Rule, the SEC’s Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule, dated April 29, 2014, and the SEC’s Order Issuing Stay, dated May 2, 2014, this Conflict Minerals Report has not been audited by a third party.
| 1. | Company Overview |
This report has been prepared by the management of Badger Meter, Inc. (herein referred to as Badger Meter, the Company, we, us or our). The information includes the activities of all majority-owned subsidiaries that are required to be consolidated.
Badger Meter is an innovator in flow measurement, control and communications solutions, serving water utilities, municipalities and commercial and industrial customers worldwide. Our products measure water, oil, chemicals and other fluids, and are known for accuracy, long-lasting durability and for providing and communicating valuable and timely measurement data. Our product lines fall into two categories: sales of water meters and related technologies to municipal water utilities (municipal water) and sales of meters to various industries for water and other fluids (flow instrumentation). We estimate that over 80% of our products are used in water applications when both categories are grouped together.
Supply Chain
Because Badger Meter does not deal directly with mineral processors like smelters and refiners, we rely on our direct suppliers to provide origin information on all applicable minerals contained in components or materials supplied to us. We also request that our suppliers advise Badger Meter of any sources of conflict minerals that are supplied to them from their suppliers.
| 2. | Reasonable Country of Origin Inquiry |
In order to determine the origin of the Subject Minerals used in the manufacture of our products, Badger Meter conducted a RCOI in good faith. To complete the RCOI, Badger Meter surveyed its suppliers using the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (further described in Section 3 below).
It is not practical to survey the entirety of our supplier base; therefore, we restricted our survey to suppliers providing products containing Subject Minerals. We then prioritized our list of suppliers by spending and administered the surveys. The goal was to capture information from the suppliers representing the majority of Badger Meter’s purchases of these products.
Survey Responses
As part of our RCOI, Badger Meter surveyed 1,012 direct suppliers. We received responses from 70% of the suppliers surveyed (which represents 96% of our overall purchases). We reviewed these responses to ensure each response was complete and consistent with the reported data and followed up with suppliers whose responses did not meet these criteria to obtain more accurate responses.
A majority of the responses received were provided at a company level, many of which did not specify the smelters or refiners used for components supplied to Badger Meter. For responses that did not specify smelters or refiners, Badger Meter contacted the corresponding suppliers to request complete information.
Among the supplier responses we received that we determined contained complete, valid information, we received the following information:
| • | Approximately 81% of supplier responses indicated that, to the best of such supplier’s knowledge, the Subject Minerals in the components and materials that it supplied to Badger Meter in 2015 did not originate from a Covered Country; and |
| • | Approximately 19% of supplier responses indicated that, to the best of such supplier’s knowledge, the Subject Minerals in the components and materials that it supplied to Badger Meter in 2015 may have originated in a Covered Country. |
Based on the results above, Badger Meter determined that it had reason to believe that, during 2015, Subject Minerals necessary for the functionality or production of its products may have originated from a Covered Country and may not be from recycled or scrap sources. Badger Meter conducted its RCOI in good faith, and it believes that such inquiry was reasonable to allow it to make the determination. Accordingly, Badger Meter proceeded to exercise due diligence on the source and chain of custody of the Subject Minerals (further described in Section 3 below).
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| 3. | Due Diligence Process |
Our due diligence measures have been designed to conform to the framework provided in the Guidance.
| 3.1 | Establish Strong Company Management Systems |
Conflict Minerals Policy
We have adopted the following conflict minerals policy:
Badger Meter is committed to working with our global supply chain to ensure compliance with the SEC’s conflict minerals rules. We have established a conflict minerals compliance program that is designed to follow the framework established by the OECD. Our enterprise is fully engaged in implementing that program.
Our standard purchase order terms and conditions, used with suppliers, have been updated to include conflict mineral due diligence and reporting requirements. Any direct sourcing by Badger Meter of tin, tungsten, tantalum and gold will not be intentionally sourced from conflict sources. As we become aware of instances where minerals in our supply chain potentially finance armed groups, as discussed in the Rule, we will work with our suppliers to find alternate conflict-free sources.
We are committed to promoting economic development in Africa through responsible commercial engagement, driving employee awareness, as well as through our corporate citizenship activities.
Management Team
Badger Meter has designated its Import/Export, Purchasing, and Cost Accounting departments as the departments responsible for overseeing our conflict minerals due diligence efforts. The Import/Export department is responsible for reporting on due diligence efforts to Badger Meter’s senior management, as well as coordinating due diligence efforts with Badger Meter’s suppliers and third-party consultants.
Supply Chain Controls
As discussed above, Badger Meter does not deal directly with the smelters and refiners in our supply chain. Instead, we rely on the information provided to us by our direct suppliers, as well as third-party verification programs like the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program, to identify and verify the smelters and refiners in our supply chain.
Engagement with Suppliers
Badger Meter continually strives to make conflict minerals compliance an integral part of its relationships with its direct suppliers. Through a third party, we communicate our expectations regarding conflict minerals compliance to our direct suppliers on an annual basis, and undertake multiple rounds of engagement with suppliers who are unable or unwilling to meet the requirements of our conflict minerals policy. Additionally, as part of our current sourcing processes, we conduct a review of a new supplier’s conflict mineral due diligence practices prior to sourcing material from them.
3
Grievance Mechanisms
Any individual or company that has a reasonable suspicion that conflict minerals are present in Badger Meter’s supply chain should alert Badger Meter or our third-party conflict mineral management team of the specifics regarding the suspicion. Badger Meter will perform due diligence on any reasonable inquiries, and will address any conflict minerals that are identified with the offending supplier.
| 3.2 | Identify and Assess Risk in the Supply Chain |
To identify and assess the risk in our supply chain, Badger Meter contracted with a third-party company to manage our conflict mineral survey process. The third-party contractor was responsible for contacting suppliers, collecting responses and reviewing the responses for completeness, inconsistencies, errors and applicability. In performing its survey, the contractor used the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template, which was developed to facilitate disclosure and communication of information regarding refiners and smelters that provide material to a company’s supply chain.
After determining the full list of smelters and refiners (as reported by our suppliers) involved in processing the minerals used in materials and components supplied to Badger Meter, we cross-checked those smelters and refiners against lists published by various third-party audit programs, such as the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program, as well as the U.S. Department of Commerce’s list of all known mineral processing facilities worldwide, published in September 2014. Based on these cross-checks, we were able to determine the relative level of risk with respect to conflict minerals within our supply chain.
| 3.3 | Design and Implement a Strategy to Respond to Risks |
After identifying the relative level of risk within our supply chain, we designed and implemented a strategy to respond to those risks.
In the event that we could not verify that a particular smelter or refiner was conflict-free based on third-party audit programs, we (1) engaged with the smelter or refiner, either directly or through our supplier, to determine the status of its efforts to become verified as conflict-free and (2) directed our suppliers to ensure that all smelters and refiners in their supply chains are either verified as conflict-free or publicly committed to becoming so. Suppliers and smelters or refiners who refuse to move toward conflict-free status run the risk of being removed from our supply chain.
| 3.4 | Third-Party Audits of Supply Chain Due Diligence at Identified Points in the Supply Chain |
As discussed above, Badger Meter does not have a direct relationship with the smelters and refiners in its supply chain and does not perform or direct audits of those entities. Instead, Badger Meter supports third-party audits through engagement with its direct suppliers and makes use of the resources provided by third-party audit programs like the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program.
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| 3.5 | Report on Supply Chain Due Diligence |
This Conflict Minerals Report is being filed with the SEC as an exhibit to Badger Meter’s specialized disclosure report on Form SD and is available on our website at https://www.badgermeter.com/supply-chain/.
| 4. | Due Diligence Results |
As a result of the due diligence measures described above, Badger Meter believes that, to the best of its knowledge, the smelters and refiners listed in Annex I to this report may have processed the Subject Minerals in products manufactured by Badger Meter. Because a majority of the responses received were provided at a company level, we are unable to associate specific smelters or refiners with specific components supplied to—and therefore specific products manufactured by—Badger Meter.
Badger Meter does not have sufficient information to conclusively determine the countries of origin of the Subject Minerals used in its products. However, based on the information provided by the suppliers, smelters and refiners in Badger Meter’s supply chain, as well as other publicly available sources of information, Badger Meter believes that the countries of origin of its Subject Minerals include the countries listed in Annex II to this report. Badger Meter also believes that some of the Subject Minerals in its products may have come from scrap or recycled sources.
Of the 366 smelters and refiners identified for calendar year 2015, 177 were verified as conflict-free under the Conflict-Free Smelter Program, while 189 have not been verified as conflict-free under the Conflict-Free Smelter Program. Of the 189 smelters and refiners that have not been verified as conflict-free, Badger Meter identified one tin smelter that may be sourcing its ore from the Covered Countries. After conducting further due diligence regarding that smelter, Badger Meter determined that the smelter is listed on the Conflict-Free Smelter Program’s Active List, meaning that the smelter has committed to undergo an audit from the Conflict-Free Smelter Program and enact any corrective actions that may be found necessary. Badger Meter will continue to monitor this smelter until it is certified as conflict-free by the Conflict-Free Smelter Program. Overall, based on information received from the suppliers, smelters and refiners in its supply chain, Badger Meter has no reason to believe any of the facilities not verified as conflict-free have sourced Subject Minerals that directly or indirectly finance or benefit armed groups.
| 5. | Steps Taken to Mitigate Risk |
Since the end of the period covered in our most recent Conflict Minerals Report, which was filed with the SEC on June 1, 2015, we have implemented the following continuous processes to improve our due diligence and mitigate the risk of conflict minerals entering our supply chain:
| • | Continue working with suppliers to help them understand Badger Meter’s expectations regarding due diligence over the Subject Minerals in our supply chain, including our suppliers’ due diligence over their own supply chains; |
| • | Communicate our expectation to our suppliers that they transition their supply chain toward smelters and refiners verified as conflict-free by the Conflict-Free Smelter Program; |
| • | For suppliers who cannot immediately transition to a conflict-free supply chain, request that those suppliers develop, communicate, and implement a plan to source from conflict-free smelters and refiners in the future; and |
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| • | Engage with industry programs to encourage the adoption and improvement of relevant tools and standards. |
In addition, we are considering contacting smelters and refiners identified in our due diligence whom have not been verified by CFSI as conflict free with the goal of improving our supply chain and decreasing the potential for conflict material to enter our supply chain.
| 6. | Forward-Looking Statements |
Certain statements contained in this Conflict Minerals Report may contain forward-looking statements that involve risks and uncertainties that could cause actual results to differ materially from those in the forward-looking statements. The words “anticipate,” “believe,” “estimate,” “expect,” “think,” “should,” “could” and “objective” or similar expressions are intended to identify forward-looking statements. All such forward-looking statements are based on our then-current views and assumptions and involve risks and uncertainties. Some risks and uncertainties that could cause actual results to differ materially from those expressed or implied in forward looking statements include, among other things, our suppliers’ willingness and ability to comply with our conflict minerals-related compliance requests, the degree to which we are able to determine our suppliers’ use of conflict-free smelters and refiners, the impact of industry-wide initiatives like the Conflict-Free Smelter Program, smelters’ and refiners’ willingness and ability to comply with the Conflict-Free Smelter Program, our effectiveness in managing the conflict minerals RCOI and due diligence processes, and the costs of our compliance. All of these factors are beyond our control to varying degrees. Shareholders, potential investors and other readers are urged to consider these factors carefully in evaluating the forward-looking statements contained in this Conflict Minerals Report and are cautioned not to place undue reliance on such forward-looking statements. The forward-looking statements made in this document are made only as of the date of this document and we assume no obligation, and disclaim any obligation, to update any such forward-looking statements to reflect subsequent events or circumstances.
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Annex I
List of Smelters and Refiners
| Metal | Smelter Name | Smelter Location | ||
| Gold | Acade Noble Metal (Zhao Yuan) Corporation | China | ||
| Gold | Accurate Refining Group | United States | ||
| Gold | Aida Chemical Industries Co. Ltd. | Japan | ||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | ||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||
| Tin | Alpha | United States | ||
| Tantalum | Alpha Metals Korea Ltd. | Korea, Republic Of | ||
| Tin | Amalgamet | United States | ||
| Tantalum | American Iron and Metal | Canada | ||
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | Brazil | ||
| Gold | Argor Heraeus | Switzerland | ||
| Gold | Asahi Pretec Corporation | Japan | ||
| Gold | Asaka Riken Co., Ltd. | Japan | ||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | ||
| Gold | Aurubis AG | Germany | ||
| Tantalum | Bangka | Indonesia | ||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||
| Gold | Bauer Walser AG | Germany | ||
| Gold | Boliden AB | Sweden | ||
| Tin | Brinkmann Chemie AG | Germany | ||
| Gold | C. Hafner GmbH + Co. KG | Germany | ||
| Tin | C. Hafner GmbH + Co. KG | Germany | ||
| Gold | Caridad | Mexico | ||
| Gold | CCR Refinery – Glencore Canada Corporation | Canada | ||
| Gold | Cendres & Métaux SA | Switzerland | ||
| Tin | CFC Cooperativa dos Fundidores de Cassiterita da Amazônia Ltda. | Brazil | ||
| Gold | CHALCO Yunnan Copper Co. Ltd. | Australia | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | ||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
A-1
| Metal | Smelter Name | Smelter Location | ||
| Gold | Chimet | Italy | ||
| Gold | China Golddeal | China | ||
| Tin | China Minmetals | China | ||
| Tin | China Rare Metal Materials Company | China | ||
| Tin | China Tin Group Co., Ltd. | China | ||
| Tantalum | China Tin Smelter Co., Ltd. | China | ||
| Tin | CHOFU WORKS | China | ||
| Gold | Chugai Mining | Japan | ||
| Gold | CIF | Brazil | ||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | China | ||
| Gold | Codelco | Chile | ||
| Tin | Complejo Metalurgico Vinto S.A. | Bolivia | ||
| Tin | Confidential | China | ||
| Tantalum | Conghua Tantalum and Niobium Smeltry | China | ||
| Tantalum | Cookson Alpha Metals (Shenzhen) Co., Ltd. | China | ||
| Tin | Cooper Santa | Brazil | ||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | Brazil | ||
| Tantalum | Corporation Berhad (MSC) | Malaysia | ||
| Tantalum | CV Duta Putra Bangka | Indonesia | ||
| Tin | CV Duta Putra Bangka | Indonesia | ||
| Tin | CV Gita Pesona | Indonesia | ||
| Tantalum | CV JusTindo | Indonesia | ||
| Tin | CV JusTindo | Indonesia | ||
| Tantalum | CV Makmur Jaya | Indonesia | ||
| Tin | CV Makmur Jaya | Indonesia | ||
| Tantalum | CV Nurjanah | Indonesia | ||
| Tin | CV Nurjanah | Indonesia | ||
| Tin | CV Prima Timah Utama | Indonesia | ||
| Tin | CV Serumpun Sebalai | Indonesia | ||
| Tin | CV United Smelting | Indonesia | ||
| Tin | CV Venus Inti Perkasa | Indonesia | ||
| Tantalum | D Block Metals, LLC | United States |
A-2
| Metal | Smelter Name | Smelter Location | ||
| Gold | Daejin Indus Co. Ltd | Korea, Republic of | ||
| Gold | DaeryongENC | Korea, Republic of | ||
| Gold | Daye Nonferrous | China | ||
| Gold | Do Sung Corporation | Korea, Republic of | ||
| Gold | Doduco | Germany | ||
| Gold | Dongguan Standard Electronic Material.Co.,Ltd | China | ||
| Gold | Dowa | Japan | ||
| Tin | Dowa | Japan | ||
| Tantalum | Duoluoshan | China | ||
| Gold | Eco-System Recycling Co., Ltd. | Japan | ||
| Tantalum | Electro.oy Metal Pte. | Singapore | ||
| Gold | Elemetal Refining, LLC | United States | ||
| Tin | Elmet S.L.U. (Metallo Group) | Spain | ||
| Tin | EM Vinto | Bolivia | ||
| Tin | Estanho de Rondônia S.A. | Brazil | ||
| Gold | Ethiopian Minerals Development Share Company | Ethiopia | ||
| Tantalum | Exotech Inc. | United States | ||
| Tantalum | F&X Electro-Materials Ltd. | China | ||
| Gold | Faggi Enrico S.p.A. | Italy | ||
| Tantalum | Feinhutte Halsbrucke GmbH | Germany | ||
| Gold | Feinhütte Halsbrücke GmbH | Germany | ||
| Tin | Feinhütte Halsbrücke GmbH | Germany | ||
| Tin | Fenix Metals | Poland | ||
| Gold | Ferro Corporation | China | ||
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | ||
| Tantalum | FIR Metals & Resource Ltd. | China | ||
| Gold | FSE Novosibirsk Refinery | Russian Federation | ||
| Tin | Fuji Metal Mining | Thailand | ||
| Gold | Fujian Nanping | China | ||
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | China | ||
| Tungsten | Ganxian Shirui New Material Co., Ltd. | China | ||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
A-3
| Metal | Smelter Name | Smelter Location | ||
| 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 | ||
| 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 | ||
| Tantalum | Global Advanced Metals Aizu | Japan | ||
| Tantalum | Global Advanced Metals Boyertown | United States | ||
| Tungsten | Global Tungsten & Powders Corp. | United States | ||
| Tin | Gold Bell Group | Singapore | ||
| Gold | Guangdong Jinding Gold Limited | China | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | ||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | ||
| Tin | Guangxi China Tin Group Co., LTD | China | ||
| Tin | Guangxi Pinggui PGMA Co. Ltd. | China | ||
| Tantalum | Guangxi Zhongshan Gold Bell Smelting Corp | China | ||
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | China | ||
| Tantalum | H.C. Starck Co., Ltd. | Thailand | ||
| Tantalum | H.C. Starck GmbH Goslar | Germany | ||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany | ||
| Gold | Harima Smelter | Japan | ||
| Gold | Harmony Gold Refinery | South Africa | ||
| Gold | Heimerle + Meule GmbH | Germany | ||
| Tin | Heimerle + Meule GmbH | Germany | ||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||
| Gold | Heraeus Ltd Hong Kong | Hong Kong | ||
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | ||
| Tantalum | Heraeus Precious Metals GmbH & Co. KG | Germany | ||
| Tantalum | Heraeus Technology Center | Hong Kong | ||
| Gold | Heraeus Zhaoyuan Precious Metal Materials Co., | China |
A-4
| Metal | Smelter Name | Smelter Location | ||
| Gold | Hisikari Mine | Japan | ||
| Tantalum | Hi-Temp Specialty Metals, Inc. | United States | ||
| Tantalum | Huaxi Guangxi Group | China | ||
| Tin | Huichang Jinshunda Tin Co., Ltd. | China | ||
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | ||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China | ||
| Gold | Hwasung CJ Co., Ltd. | Korea, Republic of | ||
| Tungsten | Hydrometallurg, JSC | Russian Federation | ||
| 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 | ||
| Tin | Jean Goldschmidt International | Belgium | ||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||
| Gold | Jiangxi Copper Company Limited | China | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China | ||
| Tin | Jiangxi Nanshan | 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 | ||
| Gold | Jinlong Copper 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 | ||
| Gold | Johnson Matthey Inc | United States | ||
| Gold | Johnson Matthey Ltd | Canada | ||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | ||
| Gold | JX Nippon Mining & Metals Co., Ltd | Japan | ||
| Tin | Kai Unita Trade Limited Liability Company | China | ||
| Tantalum | Kaimeng (Geiju) Industry and Trade Co., Ltd. | China |
A-5
| Metal | Smelter Name | Smelter Location | ||
| Gold | Kanfort Industrial (Yantai) | China | ||
| Gold | Kazakhmys Smelting LLC | Kazakhstan | ||
| Gold | Kazzinc | Kazakhstan | ||
| Tantalum | KEMET Blue Metals | Mexico | ||
| Tantalum | KEMET Blue Powder | United States | ||
| Tungsten | Kennametal Huntsville | United States | ||
| Gold | Kennecott Utah Copper | United States | ||
| Tin | Ketapang | Indonesia | ||
| Gold | KGHM Polska Miedź Spółka Akcyjna | Poland | ||
| Tantalum | King-Tan Tantalum Industry Ltd. | China | ||
| Tin | Kobe Steel, Ltd. | Japan | ||
| Gold | Kojima Chemicals Co., Ltd | Japan | ||
| Gold | Korea Metal Co., Ltd. | Korea, Republic of | ||
| Tantalum | Kupol | Russian Federation | ||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | ||
| Gold | L’ azurde Company For Jewelry | Saudi Arabia | ||
| Gold | Lingao Gold | China | ||
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | China | ||
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | China | ||
| Tin | Liuzhou China Tin Group Company Ltd - Laibin Smelter | China | ||
| Gold | London Bullion Market Association | United Kingdom | ||
| Tantalum | LSM Brasil S.A. | Brazil | ||
| Gold | LS-Nikko Copper Inc | Korea, Republic of | ||
| Gold | Luoyang ZIJIN YINHUI Gold Smelting Co. Ltd. | China | ||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | Brazil | ||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | ||
| Gold | Materion | United States | ||
| Gold | Matsuda Sangyo Co. Ltd | Japan | ||
| Tin | MATSUSHIMA KINZOKU | Japan | ||
| Tin | Melt Metais e Ligas S/A | Brazil | ||
| Tin | Metahub Industries Sdn. Bhd. | Malaysia |
A-6
| Metal | Smelter Name | Smelter Location | ||
| Tantalum | Metal Do | Japan | ||
| Tin | Metallic Resources, Inc. | United States | ||
| Tin | Metallo-Chimique N.V. | Belgium | ||
| Tantalum | Metallurgical Products India (Pvt.) Ltd. | India | ||
| Gold | Metalor Switzerland | Switzerland | ||
| Gold | Metalor Technologies (Hong Kong) Ltd | Hong Kong | ||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | ||
| Gold | Metalor USA Refining Corporation | United States | ||
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | Mexico | ||
| Tantalum | Mineração Taboca S.A. | Brazil | ||
| Tin | Mineração Taboca S.A. | Brazil | ||
| Tin | Mineração Taboca S.A. | Brazil | ||
| Tin | Minmetals Ganzhou Tin Co. Ltd. | China | ||
| Tin | Minsur | Peru | ||
| Tantalum | Mitsubishi Electric Metecs, Co., Ltd. | Japan | ||
| Gold | Mitsubishi Materials Corporation | Japan | ||
| Tin | Mitsubishi Materials Corporation | Japan | ||
| Tantalum | Mitsui Mining & Smelting | Japan | ||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Tantalum | Molycorp Silmet A.S. | Estonia | ||
| Gold | Morris and Watson | New Zealand | ||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey | ||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | China | ||
| Tin | Nathan Trotter & Co., Inc. | United States | ||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | ||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam | ||
| Gold | Nihon Material Co. LTD | Japan | ||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | ||
| Gold | Nippon Mining & Metals | Japan | ||
| Gold | Norddeutsche Affinererie AG | Germany | ||
| Tin | Novosibirsk Integrated Tin Works | Russian Federation |
A-7
| Metal | Smelter Name | Smelter Location | ||
| Tantalum | NTET, Thailand | Thailand | ||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | ||
| Tantalum | O.M. Manufacturing Phils. Inc. | Philippines | ||
| Gold | Ohio Precious Metals LLC. | United States | ||
| Gold | Ohura Precious Metal Industry Co., Ltd | Japan | ||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | Russian Federation | ||
| Gold | OJSC Kolyma Refinery | Russian Federation | ||
| Tin | Operaciones Metalurgical S.A. | Bolivia | ||
| Gold | PAMP SA | Switzerland | ||
| Gold | Pan Pacific Copper Co. LTD | Japan | ||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | ||
| Gold | Perth Mint (Western Australia Mint) | Australia | ||
| Tin | Phoenix Metal Ltd. | Rwanda | ||
| Tantalum | Plansee SE Reutte | Austria | ||
| Tungsten | Pobedit, JSC | Russian Federation | ||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | ||
| Tantalum | PT Alam Lestari Kencana | Indonesia | ||
| Tin | PT Alam Lestari Kencana | Indonesia | ||
| Gold | PT Aneka Tambang (Persero) Tbk | 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 | ||
| Tantalum | PT Babel Surya Alam Lestari | Indonesia | ||
| Tantalum | PT Bangka Kudai Tin | Indonesia | ||
| Tin | PT Bangka Kudai Tin | Indonesia | ||
| Tin | PT Bangka Putra Karya | Indonesia | ||
| Tantalum | PT Bangka Timah Utama Sejahtera | Indonesia | ||
| Tin | PT Bangka Timah Utama Sejahtera | Indonesia | ||
| Tin | PT Bangka Tin Industry | Indonesia |
A-8
| Metal | Smelter Name | Smelter Location | ||
| Tin | PT Belitung Industri Sejahtera | Indonesia | ||
| Tantalum | PT BilliTin Makmur Lestari | Indonesia | ||
| Tin | PT BilliTin Makmur Lestari | Indonesia | ||
| Tin | PT Bukit Timah | Indonesia | ||
| Tin | PT DS Jaya Abadi | Indonesia | ||
| Tin | PT Eunindo Usaha Mandiri | Indonesia | ||
| Tantalum | PT Fang Di MulTindo | Indonesia | ||
| Tin | PT Fang Di MulTindo | Indonesia | ||
| Tantalum | PT HP Metals Indonesia | Indonesia | ||
| Tin | PT HP Metals Indonesia | Indonesia | ||
| Tin | PT Inti Stania Prima | Indonesia | ||
| Tin | PT Justindo | Indonesia | ||
| Tin | PT Karimun Mining | Indonesia | ||
| Tantalum | PT Koba Tin | Indonesia | ||
| Tin | PT Koba Tin | 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 Seirama Tin Investment | Indonesia | ||
| Tin | PT Stanindo Inti Perkasa | Indonesia | ||
| Tantalum | PT Sumber Jaya Indah | Indonesia | ||
| Tin | PT Sumber Jaya Indah | Indonesia | ||
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia | ||
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia | ||
| Tin | PT Timah (Persero), Tbk | Indonesia | ||
| Tantalum | PT Timah Nusantara | Indonesia | ||
| Tin | PT Timah Nusantara | Indonesia | ||
| Tin | PT Tinindo Inter Nusa | Indonesia | ||
| Tin | PT Tirus Putra Mandiri | Indonesia |
A-9
| Metal | Smelter Name | Smelter Location | ||
| Tin | PT Tommy Utama | Indonesia | ||
| Tin | PT Wahana Perkit Jaya | Indonesia | ||
| Tantalum | PT Yinchendo Mining Industry | Indonesia | ||
| Tin | PT Yinchendo Mining Industry | Indonesia | ||
| Tantalum | Pure Technology | Russian Federation | ||
| Gold | PX Précinox SA | Switzerland | ||
| Gold | Qiankun Gold and Silver | China | ||
| Tantalum | QuantumClean | United States | ||
| Gold | Rand Refinery (Pty) Ltd | South Africa | ||
| Tin | REDRING SOLDER (M) SDN BHD | Malaysia | ||
| Gold | Republic Metals Corporation | United States | ||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China | ||
| Tin | Rohm und Haas | United States | ||
| Gold | Royal Canadian Mint | Canada | ||
| Tin | Rui Da Hung | Taiwan | ||
| Gold | Sabin | United States | ||
| Gold | Samduck Precious Metals | Korea, Republic of | ||
| Gold | SAMWON METALS Corp. | Korea, Republic of | ||
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | Vietnam | ||
| Tantalum | Sanhwa Non-Ferrous Metal Ind. Co., Ltd. | Korea, Republic of | ||
| Gold | SAXONIA Edelmetalle GmbH | Germany | ||
| Gold | Schone Edelmetaal B.V. | Netherlands | ||
| Gold | SEMPSA Joyería Platería SA | Spain | ||
| Gold | Senju Metal Industry Co., Ltd. | Japan | ||
| Tin | Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co. Ltd. | China | ||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | ||
| Gold | Shanghai Gold Exchange | China | ||
| Gold | So Accurate Group, Inc. | United States | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | ||
| Tin | Soft Metais Ltda. | Brazil | ||
| Gold | Solar Applied Materials Technology Corp. | Taiwan |
A-10
| Metal | Smelter Name | Smelter Location | ||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | ||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | ||
| Gold | Suzhou Xingrui Noble | China | ||
| Tantalum | Taki Chemicals | Japan | ||
| Tantalum | Tamura | Japan | ||
| Gold | Tanaka Kikinnzoku Kogyo K.K. | Japan | ||
| Tantalum | Tantalite Resources | South Africa | ||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam | ||
| Tantalum | Telex Metals | United States | ||
| Tin | Thailand Smelting and Refining Co. Ltd. | Thailand | ||
| Tin | Thaisarco | Thailand | ||
| 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 | Toyo Smelter & Refinery (Ehime) | Japan | ||
| Tantalum | Traxys | France | ||
| Gold | UBS AG | Switzerland | ||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | ||
| 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 | UYEMURA | United States | ||
| Gold | Valcambi SA | Switzerland | ||
| Tin | VQB Mineral and Trading Group JSC | Vietnam | ||
| Gold | Western Australian Mint trading as The Perth Mint | Australia | ||
| Tin | White Solder Metalurgia e Mineração Ltda. | Brazil | ||
| Gold | WIELAND Edelmetalle GmbH | Germany | ||
| Tungsten | Wolfram Bergbau und Hütten AG | Austria | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
A-11
| Metal | Smelter Name | Smelter Location | ||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | ||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | ||
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan | ||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China | ||
| Tin | Yifeng Tin Industry (Chenzhou) Co Ltd | China | ||
| Gold | Yokohama Metal Co., Ltd. | Japan | ||
| Tin | Yunnan Chengfeng | China | ||
| Gold | Yunnan Copper Industry Co., Ltd. | China | ||
| Gold | Yunnan Metallurgical Group Co., Ltd | China | ||
| Tantalum | Yunnan Tin Corp. | China | ||
| Tin | Yunnan Tin Group (Holding) Company Limited | China | ||
| Tin | YunXi | China | ||
| Tantalum | Zhejiang Huangyan Xinqian Electrical Parts Factory | China | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | ||
| Tantalum | Zhuzhou Cemented Carbide | China | ||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | China |
A-12
Annex II
List of Countries of Origin for Subject Minerals
| Australia | Peru | |
| Austria | Philippines | |
| Belgium | Poland | |
| Bolivia | Russia | |
| Canada | Rwanda | |
| Chile | Saudi Arabia | |
| China | Singapore | |
| Estonia | South Africa | |
| Ethiopia | South Korea | |
| France | Spain | |
| Germany | Sweden | |
| India | Switzerland | |
| Indonesia | Taiwan | |
| Italy | Thailand | |
| Japan | Turkey | |
| Kazakhstan | United Kingdom | |
| Kyrgyzstan | United States | |
| Malaysia | Uzbekistan | |
| Mexico | Vietnam | |
| Netherlands | Zimbabwe | |
| New Zealand |
A-13