EX-1.01 2 tfx2018531-exhibit101.htm EXHIBIT 1.01 Exhibit
Exhibit 1.01
Teleflex Incorporated
Conflict Minerals Report
For the Year Ended December 31, 2018

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, 2018 to December 31, 2018 (the “2018 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.
•
Interventional. Our interventional products include a variety of catheters, guidewires, drainage devices, introducers and other products used by interventional cardiologists, interventional radiologists, vascular surgeons and vein practices.
•
Interventional Urology. Our interventional urology product portfolio includes the UroLift System, which provides a minimally invasive treatment for lower urinary symptoms due to benign prostate hyperplasia, or BPH.
•
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.

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 2018, we reviewed the products that we manufacture or contract to manufacture to identify the potential presence of 3TG. The review utilized information that we compiled in prior years that was derived from examination of bills of material and utilization of scanner technology (which analyzes the element composition of certain of our products), and, where necessary, 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 (the “Potential 3TG Products”). As a result, we identified suppliers (which are referred to in this report as “in-scope direct suppliers”) that provided the Potential 3TG Products and, therefore, were 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. Our purchases of the Potential 3TG Products from the in-scope direct suppliers from whom we requested information constituted approximately 85% of our purchases of such products in 2018. In seeking this information, we utilized the cross-industry, standardized Conflict Minerals Reporting Template (“CMRT”), which was developed by the Responsible Minerals Initiative (“RMI”). 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 RMI, 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 RMI, which we have access to as a member of the RMI.
Of the 109 in-scope direct suppliers from whom we requested information in 2018, 75 in-scope direct suppliers provided information to us. In applying RMI 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 RMI 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 RMI 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 RMI, 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 2018 Report Year.

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 (3rd 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 2018 Report Year:

Establish strong company management systems
1.
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.

2.
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 Global Head of Manufacturing 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. 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.
3.
Our CM Consultant assisted us in aggregating and analyzing data collected from in-scope direct suppliers as part of our RCOI efforts, utilizing the CMRT version 5.11 or higher

4.
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.

5.
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.

Identify and assess risk in the supply chain

As noted above, a number of our in-scope direct suppliers provided 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 RMI’s Responsible Minerals Assurance Process (“RMAP”) and whether, with respect to those SORs that did 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 provided, through our CM Consultant, 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 RMI’s Standard Smelters and Refiners List (which includes SORs that have committed to undergo a RMAP 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 Standard Smelters and Refiners List was confirmed, the SOR was referenced against the RMAP to determine if the facility is conformant with RMAP assessment protocols (“RMAP Conformant”).

If an SOR was not RMAP Conformant, 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 met the RMI definition of an SOR of a 3TG mineral was assigned a risk of high, medium or low based on the following five scoring criteria:

•
Geographic proximity to the Covered Countries;
•
RMAP audit status;
•
Known mineral source country of origin;
•
Credible evidence of unethical or conflict sourcing; and
•
Peer Assessments conducted by credible third-party sources.
    
Design and implement a strategy to respond to risks

 
 
a.
We utilize 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.”
 
 
c.
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

Our CM Consultant is a member of the RMI, which approves auditors to enable them to conduct RMAP audits of SORs on behalf of its members. Our CM Consultant utilizes the RCOI information provided to members of the RMI 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 RMAP Conformant.

Report on supply chain due diligence

 
 
1.
Teleflex annually files with the SEC a Specialized Disclosure Report on Form SD, which includes, as an exhibit, its Conflict Minerals Report.


 
 
2.
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 solely 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 RMI Standard Smelter List that accompanied version 5.11 of the CMRT. Of the 319 SORs identified by our suppliers that also were on the RMI smelter list, 255 were listed as RMAP Conformant and are considered “conflict-free.” An additional five facilities are active in the RMAP audit process as of May 13, 2019. The remaining 59 facilities are not currently engaged with the RMAP 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 RMI. 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 2018 (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. 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 response rate and 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 RMI SOR lists) and by providing product specific information as to the origin of 3TG contained in purchased material supplied to us).

7. 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.
 




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 Co-operation 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. Further, we expect our suppliers to source conflicts minerals used in our supply chain responsibly in an effort to help end the violent conflict in the DRC.

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 2018. All information included in the table below is as of May 13, 2019, and the “RMI Audit Status” reflected in the table for each SOR represents such SOR’s status as of such date. SORs listed as “Conformant” may not have been RMAP Conformant for all of 2018 and may not continue to be so listed for any future period. SORs listed as “Active” are participants in the RMAP and have committed to undergo an audit or are participating in one of the cross-recognized certification programs.

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.
Smelter Table

Metal
Standard Smelter Name
Smelter ID
RMI Audit Status
Gold
8853 S.p.A.
CID002763
Conformant
Gold
Abington Reldan Metals, LLC
CID002708
Non Conformant
Gold
Advanced Chemical Company
CID000015
Conformant
Gold
African Gold Refinery
CID003185
Not Enrolled
Gold
Aida Chemical Industries Co., Ltd.
CID000019
Conformant
Gold
Al Etihad Gold LLC
CID002560
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
Conformant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
Conformant
Gold
Argor-Heraeus S.A.
CID000077
Conformant
Gold
Asahi Pretec Corp.
CID000082
Conformant
Gold
Asahi Refining Canada Ltd.
CID000924
Conformant
Gold
Asahi Refining USA Inc.
CID000920
Conformant
Gold
Asaka Riken Co., Ltd.
CID000090
Conformant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
Not Enrolled
Gold
AU Traders and Refiners
CID002850
Conformant
Gold
Aurubis AG
CID000113
Conformant
Gold
Bangalore Refinery
CID002863
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
Conformant


Gold
Boliden AB
CID000157
Conformant
Gold
C. Hafner GmbH + Co. KG
CID000176
Conformant
Gold
Caridad
CID000180
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CID000185
Conformant
Gold
Cendres + Métaux S.A.
CID000189
Conformant
Gold
Chimet S.p.A.
CID000233
Conformant
Gold
Chugai Mining
CID000264
Active
Gold
Daejin Indus Co., Ltd.
CID000328
Conformant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CID000343
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
CID002867
Not Enrolled
Gold
Dijllah Gold Refinery FZC
CID003348
Not Enrolled
Gold
DODUCO Contacts and Refining GmbH
CID000362
Conformant
Gold
Dowa
CID000401
Conformant
Gold
DS PRETECH Co., Ltd.
CID003195
Conformant
Gold
DSC (Do Sung Corporation)
CID000359
Conformant
Gold
Eco-System Recycling Co., Ltd.
CID000425
Conformant
Gold
Emirates Gold DMCC
CID002561
Conformant
Gold
Fidelity Printers and Refiners Ltd.
CID002515
Not Enrolled
Gold
Fujairah Gold FZE
CID002584
Not Enrolled
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
CID002852
Not Enrolled
Gold
Geib Refining Corporation
CID002459
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CID002243
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CID001909
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CID002312
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CID000651
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
Not Enrolled
Gold
HeeSung
CID000689
Conformant
Gold
Heimerle + Meule GmbH
CID000694
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CID000707
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
Conformant
Gold
Hunan Chenzhou Mining Co., Ltd.
CID000767
Not Enrolled
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CID000773
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
CID000778
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
Conformant
Gold
International Precious Metal Refiners
CID002562
Not Enrolled
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
Conformant
Gold
Istanbul Gold Refinery
CID000814
Conformant
Gold
Italpreziosi
CID002765
Conformant
Gold
Japan Mint
CID000823
Conformant
Gold
Jiangxi Copper Co., Ltd.
CID000855
Conformant


Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
Not Enrolled
Gold
JSC Uralelectromed
CID000929
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
CID000937
Conformant
Gold
Kaloti Precious Metals
CID002563
Not Enrolled
Gold
Kazakhmys Smelting LLC
CID000956
Not Enrolled
Gold
Kazzinc
CID000957
Conformant
Gold
Kennecott Utah Copper LLC
CID000969
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
CID002511
Active
Gold
Kojima Chemicals Co., Ltd.
CID000981
Conformant
Gold
Korea Zinc Co., Ltd.
CID002605
Conformant
Gold
Kyrgyzaltyn JSC
CID001029
Conformant
Gold
Kyshtym Copper-Electrolytic Plant ZAO
CID002865
Not Enrolled
Gold
L'azurde Company For Jewelry
CID001032
Not Enrolled
Gold
Lingbao Gold Co., Ltd.
CID001056
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
Not Enrolled
Gold
L'Orfebre S.A.
CID002762
Conformant
Gold
LS-NIKKO Copper Inc.
CID001078
Conformant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
Not Enrolled
Gold
Marsam Metals
CID002606
Conformant
Gold
Materion
CID001113
Conformant
Gold
Matsuda Sangyo Co., Ltd.
CID001119
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
CID001149
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
CID001147
Conformant
Gold
Metalor Technologies S.A.
CID001153
Conformant
Gold
Metalor USA Refining Corporation
CID001157
Conformant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
CID001161
Conformant
Gold
Mitsubishi Materials Corporation
CID001188
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
CID002509
Conformant
Gold
Modeltech Sdn Bhd
CID002857
Non Conformant
Gold
Morris and Watson
CID002282
Not Enrolled
Gold
Morris and Watson Gold Coast
CID002866
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
CID001204
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.
CID001220
Conformant
Gold
Navoi Mining and Metallurgical Combinat
CID001236
Not Enrolled
Gold
NH Recytech Company
CID003189
Active
Gold
Nihon Material Co., Ltd.
CID001259
Conformant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
Conformant


Gold
Ohura Precious Metal Industry Co., Ltd.
CID001325
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326
Conformant
Gold
OJSC Novosibirsk Refinery
CID000493
Conformant
Gold
PAMP S.A.
CID001352
Conformant
Gold
Pease & Curren
CID002872
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CID001362
Not Enrolled
Gold
Planta Recuperadora de Metales SpA
CID002919
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
Conformant
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
Conformant
Gold
PX Précinox S.A.
CID001498
Conformant
Gold
QG Refining, LLC
CID003324
Not Enrolled
Gold
Rand Refinery (Pty) Ltd.
CID001512
Conformant
Gold
Refinery of Seemine Gold Co., Ltd.
CID000522
Not Enrolled
Gold
Remondis Argentia B.V.
CID002582
Conformant
Gold
Republic Metals Corporation
CID002510
Conformant
Gold
Royal Canadian Mint
CID001534
Conformant
Gold
SAAMP
CID002761
Conformant
Gold
Sabin Metal Corp.
CID001546
Not Enrolled
Gold
Safimet S.p.A
CID002973
Conformant
Gold
SAFINA A.S.
CID002290
Not Enrolled
Gold
Sai Refinery
CID002853
Not Enrolled
Gold
Samduck Precious Metals
CID001555
Non Conformant
Gold
SAMWON Metals Corp.
CID001562
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
CID002777
Conformant
Gold
SEMPSA Joyería Platería S.A.
CID001585
Conformant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
Not Enrolled
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
Conformant
Gold
Shangdong Humon Smelting Co., Ltd.
CID002525
Not Enrolled
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
Conformant
Gold
Singway Technology Co., Ltd.
CID002516
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
Conformant
Gold
Solar Applied Materials Technology Corp.
CID001761
Conformant
Gold
State Research Institute Center for Physical Sciences and Technology
CID003153
Not Enrolled
Gold
Sudan Gold Refinery
CID002567
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
CID001798
Conformant
Gold
SungEel HiTech
CID002918
Conformant
Gold
T.C.A S.p.A
CID002580
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
Conformant


Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
Conformant
Gold
Tokuriki Honten Co., Ltd.
CID001938
Conformant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CID001947
Not Enrolled
Gold
Tony Goetz NV
CID002587
Non Conformant
Gold
TOO Tau-Ken-Altyn
CID002615
Not Enrolled
Gold
Torecom
CID001955
Conformant
Gold
Umicore Brasil Ltda.
CID001977
Conformant
Gold
Umicore Precious Metals Thailand
CID002314
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
CID001980
Conformant
Gold
United Precious Metal Refining, Inc.
CID001993
Conformant
Gold
Universal Precious Metals Refining Zambia
CID002854
Not Enrolled
Gold
Valcambi S.A.
CID002003
Conformant
Gold
Western Australian Mint trading as The Perth Mint
CID002030
Conformant
Gold
WIELAND Edelmetalle GmbH
CID002778
Conformant
Gold
Yamamoto Precious Metal Co., Ltd.
CID002100
Conformant
Gold
Yokohama Metal Co., Ltd.
CID002129
Conformant
Gold
Yunnan Copper Industry Co., Ltd.
CID000197
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
Conformant
Tantalum
Asaka Riken Co., Ltd.
CID000092
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
Conformant
Tantalum
D Block Metals, LLC
CID002504
Conformant
Tantalum
Exotech Inc.
CID000456
Conformant
Tantalum
F&X Electro-Materials Ltd.
CID000460
Conformant
Tantalum
FIR Metals & Resource Ltd.
CID002505
Conformant
Tantalum
Global Advanced Metals Aizu
CID002558
Conformant
Tantalum
Global Advanced Metals Boyertown
CID002557
Conformant
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CID000291
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
Conformant
Tantalum
H.C. Starck Co., Ltd.
CID002544
Conformant
Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
Conformant
Tantalum
H.C. Starck Inc.
CID002548
Conformant
Tantalum
H.C. Starck Ltd.
CID002549
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
CID002550
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
CID002545
Conformant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
CID002842
Conformant
Tantalum
Jiujiang Janny New Material Co., Ltd.
CID003191
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CID000917
Conformant


Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
Conformant
Tantalum
KEMET Blue Metals
CID002539
Conformant
Tantalum
KEMET Blue Powder
CID002568
Conformant
Tantalum
LSM Brasil S.A.
CID001076
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
CID001163
Conformant
Tantalum
Mineracao Taboca S.A.
CID001175
Conformant
Tantalum
Mitsui Mining and Smelting Co., Ltd.
CID001192
Conformant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
Conformant
Tantalum
NPM Silmet AS
CID001200
Conformant
Tantalum
Power Resources Ltd.
CID002847
Conformant
Tantalum
QuantumClean
CID001508
Conformant
Tantalum
Resind Industria e Comercio Ltda.
CID002707
Conformant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CID001522
Conformant
Tantalum
Solikamsk Magnesium Works OAO
CID001769
Conformant
Tantalum
Taki Chemicals
CID001869
Conformant
Tantalum
Telex Metals
CID001891
Conformant
Tantalum
Ulba Metallurgical Plant JSC
CID001969
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CID002508
Conformant
Tin
Alpha
CID000292
Conformant
Tin
An Vinh Joint Stock Mineral Processing Company
CID002703
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CID003190
Conformant
Tin
China Tin Group Co., Ltd.
CID001070
Conformant
Tin
CV Ayi Jaya
CID002570
Conformant
Tin
CV Dua Sekawan
CID002592
Conformant
Tin
CV Gita Pesona
CID000306
Conformant
Tin
CV Tiga Sekawan
CID002593
Conformant
Tin
CV United Smelting
CID000315
Conformant
Tin
CV Venus Inti Perkasa
CID002455
Conformant
Tin
Dowa
CID000402
Conformant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
CID002572
Non Conformant
Tin
EM Vinto
CID000438
Conformant
Tin
Estanho de Rondônia S.A.
CID000448
Not Enrolled
Tin
Fenix Metals
CID000468
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CID002848
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
CID000942
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
Conformant


Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
Conformant
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CID003116
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CID002849
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CID002844
Non Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CID000760
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CID001231
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
CID002468
Conformant
Tin
Malaysia Smelting Corporation (MSC)
CID001105
Conformant
Tin
Melt Metais e Ligas S.A.
CID002500
Conformant
Tin
Metallic Resources, Inc.
CID001142
Conformant
Tin
Metallo Belgium N.V.
CID002773
Conformant
Tin
Metallo Spain S.L.U.
CID002774
Conformant
Tin
Mineracao Taboca S.A.
CID001173
Conformant
Tin
Minsur
CID001182
Conformant
Tin
Mitsubishi Materials Corporation
CID001191
Conformant
Tin
Modeltech Sdn Bhd
CID002858
Conformant
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
Conformant
Tin
Operaciones Metalurgical S.A.
CID001337
Conformant
Tin
Pongpipat Company Limited
CID003208
Not Enrolled
Tin
PT Aries Kencana Sejahtera
CID000309
Conformant
Tin
PT Artha Cipta Langgeng
CID001399
Conformant
Tin
PT ATD Makmur Mandiri Jaya
CID002503
Conformant
Tin
PT Babel Inti Perkasa
CID001402
Conformant
Tin
PT Babel Surya Alam Lestari
CID001406
Conformant
Tin
PT Bangka Prima Tin
CID002776
Conformant
Tin
PT Bangka Serumpun
CID003205
Conformant
Tin
PT Bangka Tin Industry
CID001419
Conformant
Tin
PT Belitung Industri Sejahtera
CID001421
Conformant
Tin
PT Bukit Timah
CID001428
Conformant
Tin
PT DS Jaya Abadi
CID001434
Conformant
Tin
PT Inti Stania Prima
CID002530
Conformant
Tin
PT Karimun Mining
CID001448
Conformant
Tin
PT Kijang Jaya Mandiri
CID002829
Conformant
Tin
PT Menara Cipta Mulia
CID002835
Conformant
Tin
PT Mitra Stania Prima
CID001453
Conformant
Tin
PT Panca Mega Persada
CID001457
Conformant
Tin
PT Premium Tin Indonesia
CID000313
Conformant
Tin
PT Prima Timah Utama
CID001458
Conformant


Tin
PT Refined Bangka Tin
CID001460
Conformant
Tin
PT Sariwiguna Binasentosa
CID001463
Conformant
Tin
PT Stanindo Inti Perkasa
CID001468
Conformant
Tin
PT Sukses Inti Makmur
CID002816
Conformant
Tin
PT Sumber Jaya Indah
CID001471
Conformant
Tin
PT Timah (Persero) Tbk Kundur
CID001477
Conformant
Tin
PT Timah (Persero) Tbk Mentok
CID001482
Conformant
Tin
PT Tinindo Inter Nusa
CID001490
Conformant
Tin
PT Tirus Putra Mandiri
CID002478
Conformant
Tin
PT Tommy Utama
CID001493
Conformant
Tin
Resind Industria e Comercio Ltda.
CID002706
Conformant
Tin
Rui Da Hung
CID001539
Conformant
Tin
Soft Metais Ltda.
CID001758
Conformant
Tin
Super Ligas
CID002756
Not Enrolled
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
CID002834
Conformant
Tin
Thaisarco
CID001898
Conformant
Tin
Tin Technology & Refining
CID003325
Conformant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
CID002574
Not Enrolled
Tin
White Solder Metalurgia e Mineração Ltda.
CID002036
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
Conformant
Tin
Yunnan Tin Company Limited
CID002180
Conformant
Tungsten
A.L.M.T. TUNGSTEN Corp.
CID000004
Conformant
Tungsten
ACL Metais Eireli
CID002833
Conformant
Tungsten
Asia Tungsten Products Vietnam Ltd.
CID002502
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CID002645
Conformant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
Conformant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CID002536
Non Conformant
Tungsten
Global Tungsten & Powders Corp.
CID000568
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
Conformant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
CID002542
Conformant
Tungsten
H.C. Starck Tungsten GmbH
CID002541
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CID000766
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
Conformant
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CID003182
Active


Tungsten
Hydrometallurg, JSC
CID002649
Conformant
Tungsten
Japan New Metals Co., Ltd.
CID000825
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
Conformant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CID002647
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
Conformant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
Not Enrolled
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
Conformant
Tungsten
Kennametal Fallon
CID000966
Conformant
Tungsten
Kennametal Huntsville
CID000105
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
Conformant
Tungsten
Moliren Ltd
CID002845
Conformant
Tungsten
Niagara Refining LLC
CID002589
Conformant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
CID002827
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CID002815
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
Conformant
Tungsten
Unecha Refractory metals plant
CID002724
Conformant
Tungsten
Wolfram Bergbau und Hütten AG
CID002044
Conformant
Tungsten
Woltech Korea Co., Ltd.
CID002843
Conformant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
CID002082
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CID002830
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
Conformant