UNITED STATES
SECURITIES
AND EXCHANGE COMMISSION
Washington,
D.C. 20549
FORM SD
Specialized
Disclosure Report
|
MERITOR, INC. |
|
(Exact name of the registrant as specified in its charter) |
| Indiana | 1-15983 | 38-3354643 |
| (State or other jurisdiction of | (Commission File Number) | (IRS Employer Identification No.) |
| incorporation) |
| 2135 West Maple Road, Troy, Michigan | 48084-7186 | |
| (Address of principal executive offices) | (Zip code) |
| Mark R. Schaitkin | (248) 435-1000 | |
| (Name and telephone number, including area code, of the person to contact in connection with this report.) | ||
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
✓ Rule13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017
SECTION 1 - CONFLICT MINERALS DISCLOSURE
Item 1.01 Conflict Minerals Disclosure and Report
For the year ended December 31, 2017, based upon the results of its due diligence, Meritor, Inc. (“Meritor”) is unable to exclude the presence of “conflict minerals” (as defined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”)) in certain of its products or to determine the origin of any conflict minerals in its manufactured products. Accordingly, Meritor cannot exclude the possibility that some of its products contain conflict minerals which may have originated in the Democratic Republic of the Congo or an “adjoining country” (as defined in Section 1502 of the Dodd-Frank Act). As a result, Meritor is filing a Conflict Minerals Report as Exhibit 1.01 to this Form SD.
Conflict Minerals Disclosure
A copy of the Meritor’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD and is publicly available at www.meritor.com.
Item 1.02 Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
SECTION 2 – EXHIBITS
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
MERITOR,
INC.
(Registrant)
| By: | /s/ April Miller Boise | May 16, 2018 | ||
| April Miller Boise | (Date) | |||
| Senior Vice President, Chief Legal | ||||
| Officer & Corporate Secretary | ||||
MERITOR, INC.
Conflict Minerals Report
For The Year Ended December 31, 2017
This report, for the year ended December 31, 2017, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Conflict Minerals Rule”). The Conflict Minerals Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). The Conflict Minerals Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. “Conflict Minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold (“3TG”). These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
Each registrant must submit a Form SD which describes the reasonable country of origin inquiry completed by the registrant and, if the registrant is unable to establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo or certain adjoining countries (the “Covered Countries”) or from recycled or scrap sources or elects not to disclose the source of its Conflict Minerals, then the registrant must also submit a Conflict Minerals Report to the SEC that includes a description of its due diligence efforts on the Conflict Minerals source and chain of custody.
1. Company Overview
This report has been approved by the management of Meritor, Inc. (herein referred to as “Meritor”, “we”, “us” or “our”). The information includes the activities of all majority-owned subsidiaries and any less than majority-owned subsidiaries that are consolidated in Meritor’s financial results. It does not include the activities of any entities that are not required to be consolidated in Meritor’s financial results, except to the extent that those entities supply products to Meritor which may contain any of the Conflict Minerals.
Meritor is a premier global supplier of a broad range of integrated systems and components to original equipment manufacturers (“OEMs”) and the aftermarket for the commercial vehicle, transportation and industrial sectors. Meritor serves commercial truck, trailer, off-highway, military, bus and coach and other industrial OEMs and certain aftermarkets. Our principal products are axles, undercarriages, drivelines, brakes and braking systems.
Supply Chain
Due to the complexity of our products and the number of direct suppliers supplying products to Meritor, we rely on our direct suppliers to provide information on the origin of the 3TG contained in the products they supply to us—including sources of 3TG that are supplied to them from their lower tier suppliers. Accordingly, in 2014, Meritor published a new version of our Supplier Quality System Requirements (“SQSR”) manual which is incorporated by reference into our purchase orders and other agreements and which obligates our suppliers to exercise due diligence on the source and chain of custody of any Conflict Minerals incorporated in their products sold to Meritor and to report those findings to Meritor. To ensure that these findings are, in fact, reported to Meritor, we worked directly with a large group of selected suppliers, as described below.
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The suppliers selected by Meritor for inquiry were those direct suppliers who supplied any production parts to Meritor in 2017, where the parts in question, by their nature, could potentially contain 3TG.
Reasonable Country of Origin Inquiry
Based upon the results of our due diligence, we are unable to rule out the presence of 3TG in certain of our products or to determine the origin of all 3TG which may be contained in our products. Accordingly, we cannot exclude the possibility that some of our products may contain 3TG which may have originated in one or more of the Covered Countries. For that reason, we are required, under the Conflict Minerals Rule, to submit a Conflict Minerals Report to the SEC as an exhibit to Form SD.
Because of our size, our global presence, the complexity of our products and the depth, breadth and constant changes within our supply base, it is difficult to identify those potential sources of 3TG upstream from our direct suppliers. Accordingly, we participate in a number of industry-wide initiatives to determine those possible suppliers of 3TG as described in Section 2.2 below.
In accordance with the Organization for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the Conflict Minerals Rule, this report is available on our website at http://meritor.com/policy/conflict-minerals-information.aspx.
Conflict Minerals Policy
Meritor is committed to working with our global supply chain to ensure compliance with the SEC’s conflict minerals rules. Meritor intends to source responsibly in support of its intent not to manufacture products that contain Conflict Minerals that support armed conflict in any of the Covered Countries. To that end, we have established a conflict minerals compliance program that is designed to follow the framework established by the OECD. As part of that program, Meritor requires that relevant suppliers conduct conflict minerals due diligence and report their results to us.
To help ensure that we source responsibly, we have also adopted an internal Conflict Minerals Policy to guide the conduct of our employees.
In addition, Meritor has published a Conflict Minerals Statement on our website at http://meritor.com/policy/conflict-minerals-information.aspx.
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2. Due Diligence Process
2.1. Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the framework in the OECD Guidance and the related supplements for gold and for tin, tantalum and tungsten.
2.2. Management Systems
As described above, Meritor has adopted an internal Conflict Minerals Policy, for its employees, and a publicly available Conflict Minerals Statement which is posted at http://www.meritor.com.
Internal Team
Meritor has established a Conflict Minerals Team reporting to Meritor’s SVP & Chief Procurement Officer. The core team includes representatives from our procurement, sales and legal groups, with support, as needed, from our IS and engineering groups. Senior management is periodically briefed about the results of our due diligence efforts.
Control Systems
Because we do not have any direct relationships with 3TG smelters and refiners, we are engaged, and actively participate, with other major manufacturers in the automotive industry and other sectors, in the following industry-wide initiatives to disclose upstream actors in the supply chain: the National Association of Manufacturers and the Automotive Industry Action Group (“AIAG”) Conflict Minerals Work Group.
In addition to adopting a Conflict Minerals Policy which outlines expected behaviors for all Meritor employees, our expectations for our suppliers are set forth in our SQSR manual.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have contacted all relevant suppliers and asked them to complete, on the i-Point Conflict Minerals Platform, a CMRT Template (described in Section 3 below) and have followed up with all suppliers who failed to respond or who have provided inadequate or questionable responses.
Meritor Helpline Reporting
Through our internal Conflict Minerals Policy and the Conflict Minerals Statement on our website, we have encouraged our employees and suppliers to contact the Meritor Helpline to report instances in which Meritor’s products may contain Conflict Minerals from a Covered Country (other than from a scrap or recycled source) which have not already been discovered by, or reported to, Meritor or which Meritor may not have previously disclosed in its Form SD or its Conflict Minerals Report.
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Records Maintenance
We intend to retain relevant documentation in accordance with Meritor’s standard records retention policies.
2.3. Identify and Assess Risk in the Supply Chain
Because of our size, our global presence, the complexity of our products and the depth, breadth and constant changes within our supply base, it is difficult to identify those potential sources of 3TG upstream from our direct suppliers. Accordingly, we participate in a number of industry-wide initiatives to determine those possible suppliers of 3TG as described in Section 2.2 above.
Through Meritor’s internal systems and processes, we identified 452 direct suppliers whose products could potentially contain 3TG. We rely on those direct suppliers to provide us with information about the source of Conflict Minerals, if any, contained in the products they supply to us. In turn, those direct suppliers are similarly reliant upon information provided by their suppliers. Many of our largest direct suppliers are also SEC registrants and, therefore, are also subject to the Conflict Minerals Rule.
2.4. Design and Implement a Strategy to Identify and Respond to Risks
Meritor has an approved risk management plan, through which our conflict minerals program is implemented, managed and monitored.
As described above, we participate in the following industry-wide initiatives to determine potential upstream suppliers of 3TG: the National Association of Manufacturers and the AIAG Conflict Minerals Work Group.
As part of our risk management plan, to ensure that our suppliers understand our expectations, we have described our intention to source responsibly in the Conflict Minerals Statement available on our website at http://meritor.com/policy/conflict-minerals-information.aspx, have referenced those expectations in our SQSR manual, have sent each of the suppliers whose products may contain 3TG information on the Conflict Mineral regulations, have encouraged our suppliers to join i-Point and to participate in i-Point’s educational seminars, and have encouraged our suppliers to contact members of our Conflict Minerals Team to address any questions they may have.
In addition, in an effort to assist other companies to comply with the Conflict Mineral regulations and to raise awareness of the initiatives in our industry, a member of the Meritor Conflict Minerals Work Team has participated in a number of seminars on the topic and has previously spoken, as a subject matter expert, at an Annual Conflict Minerals Compliance and Supply Chain Transparency Conference hosted by the Marcus Evans Group.
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As described in our Conflict Minerals Policy, Meritor intends to source responsibly in support of its intent not to manufacture products that contain Conflict Minerals that support armed conflict in any of the Covered Countries.
2.5. Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. We support audits through our active participation in the AIAG Conflict Minerals Work Group. Through this group Meritor is helping to fund travel for members to attend supplier education sessions and on-site smelter visits.
2.6. Report on Supply Chain Due Diligence
In addition to this report, see our website at http://meritor.com/policy/conflict-minerals-information.aspx for further information about our supply chain due diligence.
3. Due Diligence Results
Requests for Information
We conducted a survey of those direct suppliers described above using the template known as the Conflict Mineral Reporting Template (the “CMRT Template”). The CMRT Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, its engagement with its direct suppliers, and a listing of the smelters used by the company and its suppliers. In addition, the template contains questions about the origin of conflict minerals used in the supplier’s products, as well as the supplier’s own due diligence efforts. Written instructions, recorded training illustrating the use of this tool and the latest version of it are available on the “Responsible Minerals Initiative” (RMI) website (formerly known as the Conflict-Free Sourcing Initiative or CFSI). The CMRT Template is widely used by many companies in their due diligence processes related to Conflict Minerals. To ensure that we have received reliable responses from our suppliers, we reviewed all of our supplier responses against criteria we developed to determine which responses merited further inquiry with our suppliers. These criteria call for follow-up of untimely or incomplete responses as well as those containing inconsistencies within the data reported in the CMRT Template. In addition, we applied a higher level of scrutiny to responses from direct suppliers who are foundries and those who supply electronic components to Meritor. Where necessary, we have worked directly with these suppliers in order to obtain acceptable revised responses.
Survey Responses
Using the information gathered from our direct suppliers over the past several years as well as our internal business systems which track production shipments, Meritor contacted all of its suppliers whose products could potentially contain 3TG, including those suppliers who in previous reporting years responded that they had no 3TG in their products. As was the case in 2015 and in 2016, except as noted in the succeeding paragraph, Meritor again received acceptable responses from 100% of these Meritor suppliers.
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On September 16, 2017 Meritor announced that it had acquired the full product portfolio of a company named Fabco Holdings, Inc. and its affiliates. Following completion of the acquisition, Meritor expanded the scope of its conflict mineral activity to include Fabco’s direct material suppliers and, at this point in time, Meritor has received responses from 86 of these additional suppliers, accounting for 87% of Fabco’s total direct material spend in 2017. Information from these suppliers has been consolidated into this report. When all respondents are combined they represent over 99% of Meritor’s total annual spend.
Since 2013, one of Meritor’s stated Conflict Mineral goals has been to increase the percentage of “Product Level” declarations received from its suppliers who indicated the possible presence of 3TG in their products (a “Product Level” declaration being a response indicating whether the actual product supplied to Meritor by such supplier contained 3TG as opposed to a “Company Level” declaration meaning that the supplier sells products which contain 3TG, but cannot identify whether any 3TG is in the specific products sold to Meritor). Meritor assumed that, at a Product Level, fewer supplier responses would indicate the use of 3TG in the products being sold to Meritor and those responses would also show a smaller number of smelters as being involved in the production of those products. As in all previous reporting years, these assumptions were proven to have been correct.
In 2017, of the 452 suppliers surveyed, 53 (12%) reported some type of 3TG in their products. Of those 53 suppliers indicating the presence of 3TG, 13 of them provided a Product Level response, while the remaining 40 suppliers provided a Company Level response, meaning that 3TG may or may not actually be present in the components or materials that these suppliers provided to Meritor. In those 40 Company Level declarations, 29 (72%) reported that tin was the only 3TG present in their products, while the remaining 11 (28%) reported that other types of 3TG were present in the products they sell. By comparison, of the 13 Product Level supplier declarations, 11 (85%) reported tin as their only 3TG and 2 (15%) indicated other 3TG in the products they sell to Meritor. Meritor’s core team remains committed to increasing the percentage of Product Level declarations in its effort to more accurately identify the Meritor products which actually contain 3TG.
4. Efforts to Determine Mine or Location of Origin
Through our participation in the AIAG Conflict Minerals Work Group, the OECD implementation programs, and requesting our suppliers to complete the CMRT Template, we have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG, if any, in our supply chain.
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Smelters or Refiners
For the 2017 reporting year, Meritor identified a total of 317 smelters whose names were provided on CMRT Template’s furnished by its suppliers. Relevant information about all smelters disclosed in Meritor’s supplier responses is set forth on Exhibit 1 to this Conflict Minerals Report. At the time of this report, 80% of the 317 smelters have been audited and are listed in the RMI’s public records as “Conformant” and another 3% are listed as “Active”, which means they have committed to the audit process and are at various stages of the audit cycle. The remaining 17% of the named smelters were listed by the RMI as “Alleged”, with CID numbers assigned to them by the RMI. The presence of a CID number indicates that the RMI is aware of the company being reported as a smelter/refiner and may be actively working to verify its status and potential compliance as a Conflict Free smelter. However the exact status of all “Alleged” smelters remains unknown as it is not published in RMI’s public information.
Meritor continues to monitor the RMI website for the status of those companies as part of its on-going due diligence and supports the further refinement and expansion of the list of conflict free smelters through our active participation in the AIAG Conflict Mineral Work Group and our association with i-Point.
While some of these smelters or refiners have been verified as being on the conflict free smelter list, other remaining mines or locations of origin of the 3TG in our products remain unknown. As to the companies responding “yes” to the presence of 3TG products in a Company Level declaration, Meritor is unable to determine whether any of the Conflict Minerals reported by these suppliers were in fact contained in products they supplied to Meritor, and is therefore unable to validate that any of the smelters or refiners identified by those suppliers are actually in our supply chain. Meritor’s experience indicates that many of those smelters identified in our suppliers’ Company Level declarations may not be involved in the specific products supplied to Meritor. Meritor’s conflict mineral team remains committed to increasing the percentage of Product Level declarations in its effort to more accurately identify which smelters are actually a part of Meritor’s supply chain.
5. Steps to be Taken to Mitigate Risks
For 2018, we intend to take the following steps to improve the due diligence we conduct in order to identify and mitigate any risk that the Conflict Minerals in our products could benefit armed groups in the Covered Countries:
| a. |
Continue to work with our suppliers who have indicated the presence of 3TG at a Company Level to obtain Product Level declarations in an effort to more accurately determine which of their products actually contain 3TG, thereby allowing Meritor to better identify the specific smelters within the Meritor supply chain. | |
| b. |
Continue to take appropriate actions with regard to any “red flag” smelters found to be in our supply base. | |
| c. |
Assist Meritor’s Tier 1 suppliers to attain a higher response rate from their lower tier suppliers as a result of their supply chain due diligence. |
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| d. |
Continue to educate our suppliers on Meritor’s higher expectations relating to Product Level responses and accurate smelter lists. | |
| e. |
Work with any suppliers found to be supplying Meritor with 3TG from sources that support armed conflict in the Covered Countries to establish an alternative source of 3TG that does not support such conflict. | |
| f. |
Work with the AIAG to define and improve best practices in order to build leverage over the supply chain in accordance with the OECD Guidance. | |
| g. |
Work with the AIAG to help expand the list of conflict free smelters and refiners. | |
| h. |
Monitor legislative changes to the Conflict Mineral rules to ensure compliance. |
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Meritor 2017 Conflict Mineral Report Exhibit #1 (Smelter Information)
| Smelter Name (*) | Location of Smelter | Smelter Identification |
| A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 |
| ACL Metais Eireli | BRAZIL | CID002833 |
| Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
| Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
| Al Etihad Gold LLC | UNITED ARAB EMIRATES | CID002560 |
| Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 |
| Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
| Alpha | UNITED STATES OF AMERICA | CID000292 |
| AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
| Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
| Asahi Pretec Corp. | JAPAN | CID000082 |
| Asahi Refining Canada Ltd. | CANADA | CID000924 |
| Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
| Asaka Riken Co., Ltd. | JAPAN | CID000090 |
| Asaka Riken Co., Ltd. | JAPAN | CID000092 |
| Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
| AU Traders and Refiners | SOUTH AFRICA | CID002850 |
| Aurubis AG | GERMANY | CID000113 |
| Bangalore Refinery | INDIA | CID002863 |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
| Boliden AB | SWEDEN | CID000157 |
| C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
| CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
| Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
| Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
| Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
| Chimet S.p.A. | ITALY | CID000233 |
| China Tin Group Co., Ltd. | CHINA | CID001070 |
| Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
| CV Ayi Jaya | INDONESIA | CID002570 |
| CV Dua Sekawan | INDONESIA | CID002592 |
| CV Gita Pesona | INDONESIA | CID000306 |
| CV Tiga Sekawan | INDONESIA | CID002593 |
| CV United Smelting | INDONESIA | CID000315 |
| CV Venus Inti Perkasa | INDONESIA | CID002455 |
| D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
| Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 |
| DODUCO Contacts and Refining GmbH | GERMANY | CID000362 |
| Dowa | JAPAN | CID000401 |
| Dowa | JAPAN | CID000402 |
| DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
| Eco-System Recycling Co., Ltd. | JAPAN | CID000425 |
| EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
| Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
| Exotech Inc. | UNITED STATES OF AMERICA | CID000456 |
| F&X Electro-Materials Ltd. | CHINA | CID000460 |
| Fenix Metals | POLAND | CID000468 |
| FIR Metals & Resource Ltd. | CHINA | CID002505 |
| Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 |
| Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 |
| Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
| Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 |
| Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 |
| Gejiu Jinye Mineral Company | CHINA | CID002859 |
| Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
| Global Advanced Metals Aizu | JAPAN | CID002558 |
| Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
| Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 |
| Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
| Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
| Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 |
| Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 |
| Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 |
| H.C. Starck Co., Ltd. | THAILAND | CID002544 |
| H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 |
| H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 |
| H.C. Starck Ltd. | JAPAN | CID002549 |
| H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 |
| H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 |
| H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 |
| H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
| HeeSung Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
| Heimerle + Meule GmbH | GERMANY | CID000694 |
| Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
| Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
| Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 |
| HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
| Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 |
| Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 |
| Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 |
| Hunan Litian Tungsten Industry Co., Ltd. | CHINA | CID003182 |
| Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
| Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
| Istanbul Gold Refinery | TURKEY | CID000814 |
| Italpreziosi | ITALY | CID002765 |
| Japan Mint | JAPAN | CID000823 |
| Japan New Metals Co., Ltd. | JAPAN | CID000825 |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
| Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
| Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
| Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | CID000244 |
| Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | CID001231 |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
| Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | CID002535 |
| Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
| Jiujiang Janny New Material Co., Ltd. | CHINA | CID003191 |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
| Jiujiang Nonferrous Metals Smelting Company Limited | CHINA | CID000917 |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 |
| JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 |
| JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
| Kazzinc | KAZAKHSTAN | CID000957 |
| KEMET Blue Metals | MEXICO | CID002539 |
| KEMET Blue Powder | UNITED STATES OF AMERICA | CID002568 |
| Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
| Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
| Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
| KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 |
| King-Tan Tantalum Industry Ltd. | CHINA | CID000973 |
| Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
| Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
| Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
| L'Orfebre S.A. | ANDORRA | CID002762 |
| LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
| LSM Brasil S.A. | BRAZIL | CID001076 |
| Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
| Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
| Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
| Marsam Metals | BRAZIL | CID002606 |
| Materion | UNITED STATES OF AMERICA | CID001113 |
| Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
| Melt Metais e Ligas S.A. | BRAZIL | CID002500 |
| Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
| Metallo Belgium N.V. | BELGIUM | CID002773 |
| Metallo Spain S.L.U. | SPAIN | CID002774 |
| Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
| Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
| Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
| Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
| Metalor Technologies S.A. | SWITZERLAND | CID001153 |
| Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
| Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
| Mineracao Taboca S.A. | BRAZIL | CID001175 |
| Mineracao Taboca S.A. | BRAZIL | CID001173 |
| Minsur | PERU | CID001182 |
| Mitsubishi Materials Corporation | JAPAN | CID001188 |
| Mitsubishi Materials Corporation | JAPAN | CID001191 |
| Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
| Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 |
| MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
| Modeltech Sdn Bhd | MALAYSIA | CID002857 |
| Modeltech Sdn Bhd | MALAYSIA | CID002858 |
| Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
| Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
| Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
| Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
| Nihon Material Co., Ltd. | JAPAN | CID001259 |
| Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
| NPM Silmet AS | ESTONIA | CID001200 |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | CID002543 |
| O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
| Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
| OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
| OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
| Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
| PAMP S.A. | SWITZERLAND | CID001352 |
| Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
| Planta Recuperadora de Metales SpA | CHILE | CID002919 |
| Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | CID002847 |
| Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
| PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
| PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
| PT Artha Cipta Langgeng | INDONESIA | CID001399 |
| PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
| PT Babel Inti Perkasa | INDONESIA | CID001402 |
| PT Bangka Prima Tin | INDONESIA | CID002776 |
| PT Bangka Tin Industry | INDONESIA | CID001419 |
| PT Belitung Industri Sejahtera | INDONESIA | CID001421 |
| PT Bukit Timah | INDONESIA | CID001428 |
| PT DS Jaya Abadi | INDONESIA | CID001434 |
| PT Eunindo Usaha Mandiri | INDONESIA | CID001438 |
| PT Inti Stania Prima | INDONESIA | CID002530 |
| PT Karimun Mining | INDONESIA | CID001448 |
| PT Kijang Jaya Mandiri | INDONESIA | CID002829 |
| PT Lautan Harmonis Sejahtera | INDONESIA | CID002870 |
| PT Menara Cipta Mulia | INDONESIA | CID002835 |
| PT Mitra Stania Prima | INDONESIA | CID001453 |
| PT O.M. Indonesia | INDONESIA | CID002757 |
| PT Panca Mega Persada | INDONESIA | CID001457 |
| CV Serumpun Sebalai | INDONESIA | CID000313 |
| PT Prima Timah Utama | INDONESIA | CID001458 |
| PT Refined Bangka Tin | INDONESIA | CID001460 |
| PT Sariwiguna Binasentosa | INDONESIA | CID001463 |
| PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
| PT Sukses Inti Makmur | INDONESIA | CID002816 |
| PT Sumber Jaya Indah | INDONESIA | CID001471 |
| PT Timah (Persero) Tbk Kundur | INDONESIA | CID001477 |
| PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 |
| PT Tinindo Inter Nusa | INDONESIA | CID001490 |
| PT Tommy Utama | INDONESIA | CID001493 |
| PX Precinox S.A. | SWITZERLAND | CID001498 |
| QuantumClean | UNITED STATES OF AMERICA | CID001508 |
| Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
| Remondis Argentia B.V. | NETHERLANDS | CID002582 |
| Republic Metals Corporation | UNITED STATES OF AMERICA | CID002510 |
| Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
| Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
| RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
| Royal Canadian Mint | CANADA | CID001534 |
| Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
| SAAMP | FRANCE | CID002761 |
| Safimet S.p.A | ITALY | CID002973 |
| SAFINA A.S. | CZECH REPUBLIC | CID002290 |
| Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 |
| SAXONIA Edelmetalle GmbH | GERMANY | CID002777 |
| Schone Edelmetaal B.V. | NETHERLANDS | CID001573 |
| SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
| Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
| Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 |
| SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
| Soft Metais Ltda. | BRAZIL | CID001758 |
| Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
| Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
| South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CID002815 |
| Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
| SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
| T.C.A S.p.A | ITALY | CID002580 |
| Taki Chemical Co., Ltd. | JAPAN | CID001869 |
| Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
| Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 |
| Telex Metals | UNITED STATES OF AMERICA | CID001891 |
| Thaisarco | THAILAND | CID001898 |
| The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 |
| Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
| Torecom | KOREA, REPUBLIC OF | CID001955 |
| Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
| Umicore Brasil Ltda. | BRAZIL | CID001977 |
| Umicore Precious Metals Thailand | THAILAND | CID002314 |
| Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
| Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 |
| United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
| Valcambi S.A. | SWITZERLAND | CID002003 |
| Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | CID002011 |
| Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
| White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
| WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
| Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
| Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 |
| Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
| Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 |
| XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
| Yamakin Co., Ltd. | JAPAN | CID002100 |
| Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | CID002307 |
| Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
| Yunnan Tin Company Limited | CHINA | CID002180 |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
| Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
| An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
| Caridad | MEXICO | CID000180 |
| Chugai Mining | JAPAN | CID000264 |
| CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 |
| Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
| Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 |
| Duoluoshan | CHINA | CID000410 |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 |
| Elemetal Refining, LLC | UNITED STATES OF AMERICA | CID001322 |
| Estanho de Rondonia S.A. | BRAZIL | CID000448 |
| Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
| Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 |
| Ganzhou Yatai Tungsten Co., Ltd. | CHINA | CID002536 |
| GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 |
| Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
| Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 |
| Guangdong Jinding Gold Limited | CHINA | CID002312 |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
| Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
| Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
| HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 |
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 |
| Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
| Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 |
| Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 |
| Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 |
| L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 |
| Lingbao Gold Co., Ltd. | CHINA | CID001056 |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 |
| Morris and Watson | NEW ZEALAND | CID002282 |
| Morris and Watson Gold Coast | AUSTRALIA | CID002866 |
| Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 |
| Pease & Curren | UNITED STATES OF AMERICA | CID002872 |
| Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 |
| Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 |
| Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 |
| Sai Refinery | INDIA | CID002853 |
| Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 |
| So Accurate Group, Inc. | UNITED STATES OF AMERICA | CID001754 |
| State Research Institute Center for Physical Sciences and Technology |
LITHUANIA |
CID003153 |
| Sudan Gold Refinery | SUDAN | CID002567 |
| Super Ligas | BRAZIL | CID002756 |
| Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 |
| Tony Goetz NV | BELGIUM | CID002587 |
| TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 |
| Universal Precious Metals Refining Zambia | ZAMBIA | CID002854 |
| Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 |