EX-1.01 2 tfx201661-exhibit101.htm EXHIBIT 1.01 Exhibit


Exhibit 1.01
Teleflex Incorporated
Conflict Minerals Report
For the Year Ended December 31, 2016

This Conflict Minerals Report of Teleflex Incorporated (herein referred to as “we,” “us,” “our,” “Teleflex” or the ”Company”) for the reporting period from January 1, 2016 to December 31, 2016 (the “2016 Report Year”) is provided pursuant to the requirements of Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). This report is not audited.

In this report, the term “3TG” is used to refer to cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten.

The information contained in any website referenced herein is not incorporated by reference into this report.

1. Company Overview

Teleflex is a global provider of medical technology products that enhance clinical benefits, improve patient and provider safety and reduce total procedural costs. We primarily design, develop, manufacture and supply single-use medical devices used by hospitals and healthcare providers for common diagnostic and therapeutic procedures in critical care and surgical applications. We market and sell our products to hospitals and healthcare providers worldwide through a combination of our direct sales force and distributors. Our products include the following:

Vascular. Our vascular access products, which are primarily catheters and related devices, facilitate a variety of critical care therapies.

Surgical. Our surgical products are predominantly comprised of single-use products, appliers and sutures used in a variety of surgical procedures, access ports, and fluid management products.

Anesthesia. Our anesthesia portfolio includes a variety of airway and pain management products.

Respiratory. Our respiratory products are used in a variety of care settings that include oxygen therapy products, aerosol products, spirometry products, and ventilation management products.

Cardiac. Products in this portfolio include both diagnostic and intra-aortic balloon catheters as well as capital equipment.

OEM. Our OEM division designs, manufactures and supplies custom components and instruments for original equipment manufacturers of medical device products.

2. Supply Chain Overview

We purchase the materials, components and finished goods that are necessary to the functionality or production of products we manufacture or contract to manufacture (which are collectively referred to in this report as “purchased materials”) from a large number of suppliers in diverse geographic locations. As a purchaser, we are several steps removed in the supply chain from the actual mining and processing of minerals that are in the purchased materials used for our products. Given the complexity of our supply chain, we rely on our suppliers to provide information pertinent to the origin of the 3TG contained in purchased materials supplied to us, including sources of 3TG that are provided to our direct suppliers by other suppliers in earlier stages of the supply chain. A large number of our direct suppliers and their suppliers are not subject to Securities and Exchange Commission (“SEC”) regulations; therefore, our ability to obtain information responsive to the Rule’s requirements is subject to the cooperation of these suppliers.



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3. Description of Reasonable Country of Origin Inquiry Efforts

Our reasonable country of origin inquiry (“RCOI”) was designed to facilitate our collection of conflict minerals data from our direct suppliers with respect to our products. Our RCOI efforts followed a process that was developed by our Conflict Minerals Team (as described in the “Due Diligence” section of this report), with the assistance of our third party conflict minerals consultant (which is referred to in this report as our “CM Consultant”), and after review of certain cross-industry information and selected published guidelines.

The process we implemented for RCOI conflict minerals data collection generally included, but was not limited to, the following measures:

1.
In 2016, we reviewed the products that we manufacture or contract to manufacture to identify the potential presence of 3TG. The review utilized information that we obtained prior to 2016 through examination of bills of material and utilization of scanner technology (which analyzes the element composition of certain of our products); where necessary, we supplemented this information by contacting some of our suppliers to obtain additional information regarding product content. We also referenced the results of our prior year RCOIs. Based on our review, we determined that 3TG is or may be contained in certain of our products, primarily those containing electronics or metals. As a result, we identified suppliers (which are referred to in this report as “in-scope direct suppliers”) that we considered likely to use 3TG in purchased materials they supply to us. We requested information from the in-scope direct suppliers to determine whether the purchased materials they supplied to us contained 3TG and to identify the smelters or refiners (referred to as “SORs”) used in processing the minerals. In seeking this information, we utilized the cross-industry, standardized Conflict Minerals Reporting Template (“CMRT”), which was developed by the Conflict Free Sourcing Initiative (“CFSI”). We used third party software to manage data collection, track supplier responses and provide reports summarizing the data collection process and overall status of the RCOI effort. A follow-up protocol was used when necessary in those instances where the information provided by a supplier was deemed incomplete, invalid or inconsistent.

2.
In connection with the information requests, we directed our in-scope direct suppliers to educational and training materials provided on websites maintained by third parties, including the CFSI, Organisation for Economic Co-operation and Development (“OECD”) and our CM Consultant’s website.

3.
We checked the SOR information we received from our in-scope direct suppliers against country of origin information maintained by the CFSI, which we have access to as a member of the CFSI.

All of our 79 in-scope direct suppliers provided information in response to our request. In applying CFSI country of origin information to the data provided by our in-scope direct suppliers, we determined that the purchased materials used in our products may have originated from the Democratic Republic of the Congo (“DRC”) or an adjoining country that shares an internationally recognized border with the DRC (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia) (collectively referred to below as the “Covered Countries”). However, the CFSI country of origin information did not cover many of the smelters identified by our suppliers. In addition, with respect to gold, a number of SORs are not audited by CFSI but by the London Bullion Market Association (“LBMA”) or the Responsible Jewellery Council (“RJC”). While gold refinery audits conducted by the LBMA and the RJC are recognized by the CFSI, the LBMA and the RJC do not provide country of origin information with respect to SORs that they have audited.

Based on the RCOI, we determined that certain of the 3TG contained in our products may have originated in the Covered Countries and did not originate solely from recycled or scrap sources. Accordingly, Teleflex exercised due diligence on the source and chain of custody of such 3TG and is filing this Conflict Minerals Report for the 2016 Report Year.


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4. Due Diligence

Our due diligence processes and efforts are designed to conform, in all material respects, to the framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2 nd Edition) (the “OECD Guidance”) and the related supplements for gold and for tin, tantalum and tungsten. The following is a discussion of the measures undertaken by Teleflex for the 2016 Report Year:

Establish strong company management systems

a.
Teleflex has adopted a Conflict Minerals Policy Statement and made it publicly available at http://www.teleflex.com/en/aboutUs/suppliers/conflictMineralPolicy/index.html. The policy statement is attached to this report as Appendix A.

b.
Teleflex has established a management system for the performance of supply chain due diligence and compliance with applicable reporting regulations. Oversight of these due diligence and reporting functions is the responsibility of our Conflict Minerals Steering Committee, which includes our Chief Financial Officer, our Senior Vice President of Global Operations and other members of management. The Conflict Minerals Steering Committee has established a Conflict Minerals Team that is responsible for implementing our conflict minerals due diligence and reporting processes. The Conflict Minerals Team is led by personnel knowledgeable about subject matters such as procurement, regulatory compliance and financial reporting. The Conflict Minerals Team reports to the Conflict Minerals Steering Committee on a semi-annual basis and on such other occasions as deemed appropriate. The Conflict Minerals Steering Committee provides reports to the Audit Committee of our Board of Directors on at least an annual basis with respect to the due diligence process and compliance with reporting obligations. In addition, we developed protocols for communication with in-scope direct suppliers and established record keeping procedures for retention of relevant documentation. Information regarding compliance with conflict minerals reporting was made available to all Teleflex employees through our internal employee intranet, and we provided training to our procurement and other personnel.

c.
We implemented data management software, and our CM Consultant assisted us in aggregating and analyzing relevant data. We collected data from in-scope direct suppliers regarding the presence of 3TG in purchased materials and the sourcing of such 3TG, utilizing the CMRT version 4.1 or higher.

d.
Our in-scope direct suppliers provide information on the origin of the 3TG contained in purchased materials, including identification of the sources of 3TG that are supplied to them from earlier stages of the supply chain.

In accordance with the OECD Guidance calling for the strengthening of company engagement with in-scope direct suppliers, we have, in cooperation with our CM Consultant, provided educational materials to these suppliers regarding SEC Conflict Minerals reporting requirements.

We utilized our CM Consultant’s Learning Management System to provide all in-scope suppliers access to Conflict Minerals training courses.

e.
We established a grievance mechanism in the form of an email inbox, available to the public at conflict.minerals@teleflex.com. The grievance mechanism is designed to enable our employees and members of the public to identify issues that may exist in connection with our conflict minerals data collection and reporting process. We have publicized the existence of the grievance mechanism through our website and internal corporate communications.


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Identify and assess risk in the supply chain

Our in-scope direct suppliers provide us with information about the source of 3TG contained in purchased materials that they provide to us. We assess supplier risk based on the likelihood that a supplier provides 3TG that may originate from non-conflict free sources. As described in more detail below, our assessment of the magnitude of supplier risk is based on (i) our assessment of the risk that the in-scope direct supplier’s due diligence program will not be strong enough to effectively identify each SOR in the supply chain that is the source of 3TG contained in purchased materials, and otherwise to meaningfully assist us in reducing risk in the supply chain (which we refer to in this report as “supplier process risk”) and (ii) our assessment of the extent to which SORs that are identified by our in-scope direct suppliers as an SOR of 3TG contained in purchased materials do not participate in CFSI’s Conflict Free Smelter Program (“CFSP”) and whether, with respect to those SORs that do not participate, there exists other evidence of unethical or conflict sourcing (which we refer to in this report as “SOR facility risk”).

With respect to supplier process risk, we evaluate the strength of the in-scope direct supplier’s program in identifying SORs and risk in the supply chain. Evaluating the strength of the program can provide important information that assists us in determining key risk mitigation measures as the program progresses. The criteria used to evaluate the strength of the in-scope direct supplier’s program are:

Does the supplier have a policy in place that includes conflict-free sourcing?
Has the supplier implemented due diligence measures for conflict-free sourcing?
Does the supplier verify due diligence information received from its suppliers?
Does the supplier’s verification process include corrective action management?

We assess the strength of the in-scope direct supplier’s program based upon the extent to which the supplier meets these criteria.

As part of our risk management plan and to enhance in-scope direct suppliers’ understanding of our expectations, we have, through our CM Consultant, provided video and written training on Conflict Minerals and the CMRT.

Utilizing the SOR information provided by our in-scope direct suppliers, we assessed SOR facility risk by cross checking the identified SORs against the CFSI’s Active Smelters and Refiners List (which includes SORs that have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or RJP Chain-of-Custody Certification). Once the SOR’s inclusion on the Active Smelters and Refiners List was confirmed, the SOR was referenced against the CFSP to determine if the facility is compliant with CFSP assessment protocols (“CFSP Compliant”).

If an SOR was not CFSP compliant, our CM Consultant either attempted to contact the SOR to gather information about its sourcing practices or conducted research to determine the facility’s sourcing practices.

Each facility that meets the CFSI definition of an SOR of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
    
    Geographic proximity to the Covered Countries;
    CFSP audit status;
    Known or plausible evidence of unethical or conflict sourcing.

SORs that are not certified as CFSP Compliant are generally classified as high risk because they pose a significant risk to the supply chain.


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Design and implement a strategy to respond to risks

a.
We have established a reporting protocol under which the Conflict Minerals Team reports to the Conflict Minerals Steering Committee, which, in turn, provides reports to the Audit Committee. The protocol is designed to enable the Conflicts Minerals Team to report, among other things, any identified risk in the supply chain.

b.
Our risk management strategy includes an evaluation of our in-scope direct suppliers for compliance with our expectation, as expressed in the Teleflex Conflict Minerals Policy Statement, that our suppliers “undertake reasonable due diligence within their supply chains to determine the origin of the conflict minerals contained in materials and products they supply to Teleflex.” At-risk suppliers (i.e., suppliers we believe are not complying with our expectations) are reviewed by the Teleflex Conflict Minerals Team to consider further action on an individual supplier basis.

c.
The Conflict Minerals Team was able to identify, monitor and track performance of our risk mitigation efforts and provide performance information to our Conflict Minerals Steering Committee.

d.
When high risk facilities were reported on a CMRT by one of our in-scope direct suppliers, risk mitigation activities were initiated. Our CM Consultant provided correspondence to the supplier, instructing it to commence risk mitigation actions, including submission of product specific CMRTs, to enhance our ability to identify the presence of 3TG in purchased materials.

Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain

Teleflex is a member of the CFSI, which coordinates independent third-party audits of SORs on behalf of its members. Teleflex utilizes the RCOI information provided to members of the CFSI to determine the possible country of origin of the conflict minerals used in its products and to determine whether SORs identified by its suppliers are CFSP Compliant.

Report on supply chain due diligence

a.
Teleflex annually files with the SEC a Specialized Disclosure Report on Form SD, which includes, as an exhibit, its Conflict Minerals Report.

b.
Teleflex makes its Conflict Minerals Policy Statement publicly available at http://www.teleflex.com/en/aboutUs/suppliers/conflictMineralPolicy/index.html.

5. Due Diligence Results

Teleflex sought to identify, through the measures described in Section 4 above, the risk that the 3TG in products it manufactures or contracts to manufacture finance or benefit armed groups in the supply chain. As used herein, the term “armed group” refers to an armed group that is identified as a perpetrator of serious human rights abuses in annual Country Reports on Human Rights Practices under section 116(d) and 502B(b) of the Foreign Assistance Act of 1961 relating to the Covered Countries.

Based on our due diligence efforts described in Section 4 above, we do not have sufficient information to conclusively determine the countries of origin of the 3TG in our products or whether the 3TG in our products are from recycled or scrap sources. Most responding in-scope direct suppliers did not provide specific information as to the origin of the 3TG contained in purchased materials they supply to us. Rather, they advised us only as to the SORs from which 3TG used in any of their materials, components or finished goods originated (regardless of whether those products were supplied to us). Any facility reported by a supplier to Teleflex as an SOR was cross-referenced with the CFSI Standard Smelter List that accompanied version 4.2 of the CMRT. There were 310 SORs

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identified. Of these, 245 were confirmed to be compliant to CFSP sourcing audit assessment protocol and are considered “conflict-free”. An additional 11 facilities are active in the CFSP audit process. The remaining 54 facilities are not currently engaged with the CFSP audit program but have been contacted by our CM Consultant on our behalf to encourage them to undertake such an audit. Moreover, many of the SORs identified by our suppliers were not included in the smelter information provided by the CFSI. Therefore, we do not have sufficient information to determine if any of our products contained 3TG that originated from SORs whose procurement practices entail a risk that the minerals it processes finance or benefit armed groups.

Appendix B to this report contains a list of those SORs identified by our in-scope direct suppliers as potentially having processed the necessary 3TG contained in our products in 2016 (which, because most responding suppliers did not provide specific information as to the origin of 3TG included in purchased materials that they supply to us, may include smelters from which 3TG used in our products did not originate).

6. Due Diligence Improvements in 2016

In 2016, we improved our risk identification process by refining the supplier scoping process through the product and supplier review process described in Section 3 above. We also improved the training provided to both our suppliers and relevant personnel. Additionally, when high risk facilities were reported on a CMRT by one of our in-scope direct suppliers, risk mitigation activities were initiated, which included instructing the supplier to commence risk mitigation actions, including submission of product specific CMRTs, to enhance our ability to identify the presence of 3TG in purchased materials.

7. Future Due Diligence Measures

Teleflex continues to explore ways in which it can enhance its due diligence efforts. Among the measures under consideration are increased communications with our suppliers to improve the quality of information included on their CMRTs (e.g. by improving the accuracy of SOR names entered on the CMRTs (which would enhance our efforts to match the SORs against the relevant CFSI SOR lists) and by providing product specific information as to the origin of 3TG contained in purchased material supplied to us).

8. Limitations on Our Due Diligence Efforts

We are a downstream purchaser of parts and components. As a result, we do not have data relating to the original sources of materials necessary to the functionality or manufacture of our products. We must rely on our suppliers who, in turn, must rely on their upstream suppliers in the supply chain to obtain necessary information. Information supplied by various entities in the supply chain may be inaccurate or incomplete. Moreover, we continue to encounter supplier unfamiliarity with the data gathering process required by the Rule, which we believe has delayed the provision of information and may increase the risks that information provided will be inaccurate or incomplete.




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Appendix A 

Teleflex Conflict Minerals Policy Statement

On August 22, 2012, the U.S. Securities and Exchange Commission (SEC) adopted a final rule to implement reporting and disclosure related to “conflict minerals,” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The rule requires manufacturers who are SEC filers to disclose whether the products they manufacture or contract to manufacture contain “conflict minerals” that are “necessary to the functionality or production” of those products.

Conflict minerals refer to tin, tantalum, tungsten and gold (commonly referred to as “3TG”), regardless of where they are sourced, processed or sold. The final rule is intended in part to bring greater supply chain transparency to the use of such minerals originating from the Democratic Republic of Congo and adjoining countries in an effort to help end the violent conflict which has been financed, in part, by the exploitation and trade of conflict minerals.

Tin, tungsten, tantalum and gold are essential in the manufacture of a variety of electronic and medical devices and other products, including some of Teleflex’s products. Teleflex is committed to institute procedures and reporting systems, and to conduct the necessary diligence to comply with the final rule.

Specifically, we are:

1.
using a documented reasonable due diligence process, which conforms to the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-Risk Areas, and are working closely with our suppliers to determine the presence of 3TG in our supply chain;
 
2.
taking steps to determine the use, country of origin and chain of custody of 3TG minerals in our global product portfolio; and

3.
committed to improve, over time, the ability to track and trace conflict minerals in our supply chain.

Teleflex sources from numerous suppliers and, a large number of our suppliers and their suppliers are private companies or international companies which are not subject to SEC regulations; therefore, Teleflex must rely on the cooperation of its suppliers in the implementation of this policy and in enabling Teleflex to meet its SEC disclosure and reporting obligations on a timely basis. Teleflex expects its suppliers to undertake reasonable due diligence within their supply chains to determine the origin of the conflict minerals contained in materials and products they supply to Teleflex.

Suppliers and other external parties are encouraged to contact us at conflict.minerals@teleflex.com if they wish to seek guidance on this policy or if they wish to report concerns.








Appendix B
SOR Information

In connection with our reasonable country of origin inquiry and due diligence, as applicable, our in-scope direct suppliers identified to us the SORs listed below as potentially having processed the necessary 3TG contained in our products in 2016. All information included in the table below is as of April 27, 2017, and the “CFSI Audit Status” reflected in the table for each SOR represents such SOR’s status as of such date. SORs listed as “compliant” may not have been compliant for all of 2016 and may not continue to be so listed for any future period.

The large majority of the responses we received from the supplier survey either provided data at a company or divisional level or did not specify the SORs from whom 3TG in the purchased materials were derived. We therefore are unable to determine whether the 3TG reported by the suppliers were contained in purchased materials. As a result, we were unable to determine the extent to which purchased materials contained 3TG derived from the SORs listed below.
Metal
 Standard Smelter Name
Smelter Facility Location
 Smelter ID
CFSI Audit Status
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
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 MiedŸ Spó³ka 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.ª.
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.
VIET NAM
CID002825
Not Enrolled
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
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
VIET NAM
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
VIET NAM
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 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
VIET NAM
CID002574
Not Enrolled
Tin
VQB Mineral and Trading Group JSC
VIET NAM
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.
VIET NAM
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
VIET NAM
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.
VIET NAM
CID001889
Compliant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Compliant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
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