DocumentExhibit 1.01
Teleflex Incorporated
Conflict Minerals Report
For the Year Ended December 31, 2019
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, 2019 to December 31, 2019 (the “2019 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 Access. 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, diagnostic and intra-aortic balloon catheters as well as capital equipment 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 prostatice 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. |
• | Urology. Our urology product portfolio provides bladder management for patients in the hospital and individuals in the home care markets. |
• | 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 2019, 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 77% of our purchases of such products in 2019. 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 104 in-scope direct suppliers from whom we requested information in 2019, 81 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 2019 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 2019 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 Corporate Vice President Manufacturing and Supply Chain 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 5.12 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 utilized 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 continue to publicize 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
1.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.
2.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.”
3.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 5.12 of the CMRT. Of the 300 SORs identified by our suppliers that also were on the RMI smelter list, 234 were listed as RMAP Conformant and are considered “conflict-free.” An additional seven facilities are active in the RMAP audit process as of April 22, 2020. 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 2019 (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 2019. All information included in the table below is as of April 22, 2020, 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 2019 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
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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 Refinery DMCC | CID002560 | Conformant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | Conformant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | Conformant |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | 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 | Conformant |
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 + Metaux S.A. | CID000189 | Conformant |
Gold | CGR Metalloys Pvt Ltd. | CID003382 | Not Enrolled |
Gold | Chimet S.p.A. | CID000233 | Conformant |
Gold | Chugai Mining | CID000264 | 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. East Plant | CID000425 | Conformant |
Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 | Conformant |
Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 | Conformant |
Gold | Emirates Gold DMCC | CID002561 | Conformant |
Gold | Fidelity Printers and Refiners Ltd. | CID002515 | Not Enrolled |
Gold | Fujairah Gold FZC | 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 | 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 | HwaSeong 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 | Conformant |
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 | LT Metal Ltd. | CID000689 | 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 | Metalurgica Met-Mex Penoles 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 | Moscow Special Alloys Processing Plant | CID001204 | Conformant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | CID001220 | Conformant |
Gold | Navoi Mining and Metallurgical Combinat | CID001236 | Not Enrolled |
Gold | NH Recytech Company | CID003189 | Non Conformant |
Gold | Nihon Material Co., Ltd. | CID001259 | Conformant |
Gold | Ogussa Osterreichische 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 Precinox 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 PMR B.V. | CID002582 | 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 | Active |
Gold | Sai Refinery | CID002853 | Not Enrolled |
Gold | Samduck Precious Metals | CID001555 | Conformant |
Gold | Samwon Metals Corp. | CID001562 | Not Enrolled |
Gold | SAXONIA Edelmetalle GmbH | CID002777 | Conformant |
Gold | SEMPSA Joyeria Plateria S.A. | CID001585 | Conformant |
Gold | Shandong Humon Smelting Co., Ltd. | CID002525 | Not Enrolled |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 | Not Enrolled |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | Conformant |
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 | Sovereign Metals | CID003383 | Not Enrolled |
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 HiMetal Co., Ltd. | 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 | Conformant |
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 | Valcambi S.A. | CID002003 | Conformant |
Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 | Conformant |
Gold | WIELAND Edelmetalle GmbH | CID002778 | Conformant |
Gold | Yamakin 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 | CP Metals Inc. | CID003402 | Active |
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 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 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 | 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 | PRG Dooel | CID002847 | Conformant |
Tantalum | QuantumClean | CID001508 | Conformant |
| | | | | | | | | | | |
Tantalum | Resind Industria e Comercio Ltda. | CID002707 | Conformant |
Tantalum | Solikamsk Magnesium Works OAO | CID001769 | Conformant |
Tantalum | Taki Chemical Co., Ltd. | CID001869 | Conformant |
Tantalum | Telex Metals | CID001891 | Conformant |
Tantalum | Ulba Metallurgical Plant JSC | CID001969 | Conformant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 | Conformant |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 | 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 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 | Non 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 Rondonia S.A. | CID000448 | Not Enrolled |
Tin | Fenix Metals | CID000468 | Conformant |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CID003410 | Not Enrolled |
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 Co., Ltd. | CID003116 | Conformant |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CID002849 | Conformant |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 | Conformant |
Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 | Conformant |
Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 | Conformant |
Tin | Luna Smelter, Ltd. | CID003387 | Conformant |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CID003379 | 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 | Non 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 Metalurgicas S.A. | CID001337 | Conformant |
Tin | Pongpipat Company Limited | CID003208 | Not Enrolled |
Tin | Precious Minerals and Smelting Limited | CID003409 | Active |
Tin | PT Artha Cipta Langgeng | CID001399 | Conformant |
Tin | PT ATD Makmur Mandiri Jaya | CID002503 | Conformant |
Tin | PT Menara Cipta Mulia | CID002835 | Conformant |
Tin | PT Mitra Stania Prima | CID001453 | Conformant |
Tin | PT Refined Bangka Tin | CID001460 | Conformant |
Tin | PT Timah Tbk Kundur | CID001477 | Conformant |
Tin | PT Timah Tbk Mentok | CID001482 | 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 Mineracao Ltda. | CID002036 | Conformant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | Conformant |
Tin | Yunnan Tin Company Limited | CID002180 | Conformant |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 | Conformant |
Tungsten | A.L.M.T. Corp. | CID000004 | Conformant |
Tungsten | ACL Metais Eireli | CID002833 | Conformant |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | CID003427 | Active |
Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 | Conformant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 | Conformant |
Tungsten | China Molybdenum Co., Ltd. | CID002641 | Not Enrolled |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | Conformant |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CID000281 | Not Enrolled |
Tungsten | CP Metals Inc. | CID003448 | Active |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CID003401 | 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 | 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 | Conformant |
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 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 Xianglu Tungsten Co., Ltd. | CID002647 | Active |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | Conformant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | Conformant |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | CID003408 | Active |
Tungsten | Kennametal Fallon | CID000966 | Conformant |
Tungsten | Kennametal Huntsville | CID000105 | Conformant |
Tungsten | KGETS Co., Ltd. | CID003388 | Conformant |
Tungsten | Lianyou Metals Co., Ltd. | CID003407 | Conformant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | Conformant |
Tungsten | Masan Tungsten Chemical LLC (MTC) | CID002543 | Conformant |
Tungsten | Moliren Ltd. | CID002845 | Conformant |
Tungsten | Niagara Refining LLC | CID002589 | Conformant |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 | Conformant |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 | Conformant |
Tungsten | Unecha Refractory metals plant | CID002724 | Conformant |
Tungsten | Wolfram Bergbau und Hutten 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 |