DocumentExhibit 1.01
Juniper Networks, Inc.
Conflict Minerals Report for the Year Ended December 31, 2020
This Conflict Minerals Report (this “Report”) for Juniper Networks, Inc. (the “Company”, “Juniper”, “our” or “we”) covers the reporting period from January 1, 2020 to December 31, 2020 and is presented in accordance with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) registrants whose manufactured products contain “conflict minerals” that are necessary to the functionality or production of their products. The term “conflict minerals” is defined in the Rule as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, which are currently limited to tin, tantalum and tungsten (collectively, “3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC (collectively, the “Covered Countries”). The adjoining countries are the Republic of the Congo, the Central African Republic, South Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania, and Angola.
Throughout this Report, whenever a reference is made to any document, third-party material, or website (including Juniper’s website), such reference is for general information only and does not incorporate information from such document, material, or website into this Report, unless expressly incorporated by reference herein.
Overview
Company Overview
Juniper designs, develops, and sells products and services for high-performance networks to enable customers to build scalable, reliable, secure and cost-effective networks for their businesses, while achieving agility and improved operating efficiency through automation.
Product and Supply Chain Overview
The Company sells high-performance network products and service offerings across routing, switching, Wi-Fi, network security, and software-defined networking technologies. Our supply chain and operations team manage relationships with our global supply chain, which includes our contract manufacturers, original design manufacturers, certain components suppliers, warehousing and logistics. Our contract manufacturers and original design manufacturers are responsible for all phases of manufacturing, from prototypes to full production, and assist with activities such as material procurement. Given our downstream position in the supply chain, we do not have any direct relationships with the smelters or refiners in our supply chain, and we therefore rely on our first-tier suppliers to provide information about the sources of 3TG used in our products.
Industry Alignment Overview
Since 2011, Juniper has supported the development of industry tools and programs that provide a common means to report or collect due diligence information on the source and chain of custody of 3TG through our membership in the Responsible Minerals Initiative (the “RMI”). The RMI is a recognized industry coalition focused on addressing and advancing the responsible sourcing of 3TG in the supply chain. Through the RMI and its workgroups, including the Due Diligence Practices Team, Sensing and Prioritization Team, and Smelter Engagement Team, Juniper has been engaged and continues to work with industry peers in an effort to ensure that our reasonable country of origin inquiry (“RCOI”) and due diligence processes are aligned with industry approaches. The primary objective of this alignment is to help ensure that the 3TG in our products is sourced responsibly.
Through our participation in the RMI, we seek to maximize the efficiency and effectiveness of our efforts to identify 3TG smelters and refiners in our supply chain and to encourage their participation in the RMI’s Responsible Minerals Assurance Process (the “RMAP”). The RMAP is a voluntary initiative in which an independent third-party validates smelter and refiner due diligence management systems, in line with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including supplements thereto (the “Guidance”). As it is a standardized protocol, we, along with other participants in the electronics industry, rely on the RMAP or equivalent industry-wide programs for audits of 3TG smelters and refiners.
Additionally, through the RMI and its workgroups, Juniper monitors the social, health and safety, and human rights impacts of the industry’s efforts to promote responsible sourcing in the Covered Countries and uses that information to inform our
compliance program. In order to avoid negative impact on the livelihoods of those in the mining communities in the Covered Countries, we do not embargo the sourcing of 3TG from the Covered Countries and encourage our suppliers to continue to responsibly source 3TG from the Covered Countries.
Products Covered by this Report
The Company determined that 3TG was necessary to the functionality or production of products that we manufactured or contracted to be manufactured during the 2020 calendar year. We determined that only our routing, switching, Wi-Fi, network security, and software-defined networking hardware products that are being manufactured were within the scope of the Rule, based on the criteria that they contain components that may contain 3TG that is necessary to the functionality or production of the products.
For further information concerning our products, see the subheading “Products, Services and Technology” in “Item 1. Business” of our Annual Report on Form 10-K for the year ended December 31, 2020, filed with the SEC on February 12, 2021.
Reasonable Country of Origin Inquiry
RCOI Overview and Process
Juniper was required to undertake a RCOI with respect to the necessary 3TG in its in-scope products that is reasonably designed to determine whether any of the necessary 3TG originated in any of the Covered Countries and whether they were not from recycled or scrap resources. Based on our RCOI design, we surveyed suppliers that provide physical components that become part of our end products or provide manufacturing services for our end products (collectively, “direct suppliers”), including those direct suppliers that are internally categorized as preferred or strategic. Preferred and strategic direct material suppliers are those that provide what are identified as the most critical technologies and can have a broad impact across Juniper. For the reporting period covered by this Report, the direct suppliers surveyed (the “Surveyed Suppliers”) represented an aggregate of approximately 99% of our total direct materials expenditures in 2020.
To determine whether necessary 3TG in our products originated in the Covered Countries, we retained a third-party service provider (“Service Provider”) to assist us in surveying our Surveyed Suppliers and provide an analysis of the resulting data. We utilized the then-latest revision of the RMI’s Conflict Minerals Reporting Template (“CMRT”) to conduct a survey of all Surveyed Suppliers through the Service Provider's platform. Some of our other compliance activities described in this Report were performed on our behalf by the Service Provider.
We requested that all Surveyed Suppliers complete a CMRT, and we provided training and educational materials to assist such suppliers on best practices and the completion of the CMRT. The training program was intended to help ensure the quality and completeness of the CMRTs received from the Surveyed Suppliers. The Service Provider monitored and tracked all communications via its data management platform. Both Juniper and the Service Provider contacted Surveyed Suppliers that were initially unresponsive in completing a CMRT.
Automated data validation was performed on all submitted CMRTs. This helped to identify contradictory answers in CMRTs, informed our follow-up with Surveyed Suppliers, and we believe ultimately increased the accuracy of submissions. Data validation was based on completion of questions in the CMRT and on an analysis of internal consistency among responses in the CMRT. Following the data validation process, CMRTs were accepted and classified as valid or invalid. Surveyed Suppliers that submitted an invalid CMRT, meaning that the CMRT contained contradictory or incomplete information, were contacted and requested to resubmit a valid and complete form. Unresolved contradictory or incomplete information impacts the accuracy and completeness of Juniper’s smelter and refiner list.
Based on data collected from April 12, 2021 through May 17, 2021, approximately 71% of the Surveyed Suppliers submitted a CMRT.
RCOI Results
Our RCOI identified 333 known smelters and refiners that appear on the lists maintained by the RMI that may have been in our 2020 supply chain. Based on Juniper’s RCOI, we concluded that 112 of these smelters and refiners sourced 3TG entirely from outside of the Covered Countries, including from recycled or scrap sources. We determined that 25 of the identified smelters and refiners sourced 3TG in whole or in part from within the Covered Countries, but all 25 of these smelters and refiners were designated as “Conformant” by the RMAP (as defined on Appendix A). Juniper’s conclusions concerning the origin of 3TG are based on information provided by the RMI to its members.
For the 2020 reporting period, Juniper was unable to determine the origin of at least a portion of the necessary 3TG in its in-scope products. None of the necessary 3TG contained in its in-scope products were determined to directly or indirectly finance or benefit armed groups in a Covered Country, and Juniper has never identified an instance of 3TG in its in-scope products financing or benefitting armed groups in a Covered Country. However, Juniper did not conclude that any of its in-scope products were “DRC conflict-free.”
Based on the results of our RCOI, we conducted due diligence for 2020. These due diligence efforts are discussed below.
Due Diligence
Design of Due Diligence Program
We designed our due diligence measures to conform, in all material respects, to the framework in the Guidance. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps.
The following describes activities undertaken by Juniper with respect to each of the due diligence-related steps in conformance with the Guidance.
Step 1: Establish Strong Company Management Systems
We have established management systems that conform to Step 1 of the Guidance and that include the following elements:
Conflict Minerals Policy: Juniper has published and communicated to our suppliers a company policy stating our commitment to responsible sourcing of 3TG and our ongoing effort with suppliers to achieve a conflict-free supply chain. This policy can be viewed on our website at https://www.juniper.net/us/en/company/citizenship-sustainability/supply-chain. The policy is periodically reviewed by our internal conflict minerals operations team and has been approved by Juniper’s conflict minerals executive champions, who are currently the Corporate Vice President of Supply Chain Operations and the Senior Vice President, General Counsel. It is also integrated into our Juniper Business Partner Code of Conduct (https://www.juniper.net/assets/us/en/local/pdf/additional-resources/business-partner-code-of-conduct.pdf), which requires suppliers to exercise due diligence on the source of 3TG and make this information available to Juniper upon request.
Governance structure: Juniper has established a conflict minerals governance structure that includes senior management responsibility for the program. In addition, a conflict minerals operations team comprised of individuals from Supply Chain Operations, Engineering, Sales and Legal supports the program during different stages. The conflict minerals operations team meets when there are significant changes to the development, implementation, or maintenance of Juniper’s conflict minerals program. The executive champions establish the goals of the conflict minerals operations team, receive regular updates on the status of the program through the Corporate Social Responsibility Executive Committee meeting, and approve any significant changes to the program.
Juniper uses the Service Provider to assist us with collecting and evaluating supply chain information regarding 3TG and identifying potential risks, and in the development and implementation of additional due diligence steps with suppliers in regard to conflict minerals.
Juniper also is engaged in multi-stakeholder initiatives to address responsible sourcing of 3TG. Through its membership in the RMI, Juniper utilizes the RMI for public policy engagement relating to the responsible sourcing of 3TG and to advance initiatives to reduce the use of raw materials that may support conflict.
Control systems and transparency: Juniper expects our suppliers to exercise due diligence on the source and chain of custody of any 3TG used in the production of the in-scope products, materials, or components sold to Juniper. These expectations are communicated to our suppliers through the supplier onboarding process and business reviews. Juniper seeks to strengthen our relationship with our suppliers by providing training and through our Business Partner Code of Conduct. If suppliers do not abide by Juniper’s policies or meet Juniper’s performance expectations, we may escalate the matter in the supplier business review process and take the non-compliance into account in supplier performance scorecards. Supplier non-compliance and poor performance on scorecards may result in a determination to suspend the supplier, disengage from the supplier, or take other corrective actions with respect to the supplier.
We have taken steps to strengthen our due diligence efforts over time. For example, in 2018 and 2019, Juniper implemented program improvements to mitigate risk, including (1) implementation of corporate social responsibility criteria in the direct supplier onboarding process to identify potential labor, environmental, health and safety, and ethics risks, including those associated with responsible minerals sourcing and (2) strengthening the supplier scorecard by adding three new metrics to assess a supplier’s compliance with Juniper’s conflict minerals requirements across all manufacturing partners and commodities that may contain 3TG. These enhancements were implemented to provide more transparency in our expectations and evaluations, promote more granular responsible sourcing discussions with our suppliers, and drive initiatives that will support Juniper's goal of responsible minerals sourcing and a conflict-free supply chain, including suppliers conducting due diligence in accordance with the Guidance and sourcing from Conformant smelters.
Further, in 2020, Juniper implemented initiatives to support the improvements that were discussed in our Conflict Minerals Report for calendar year 2019. These improvements include conflict minerals refresher training for the global commodity management team, which enables the team to comprehend the requirements of the Rule and the importance of responsible minerals sourcing, and to better articulate Juniper’s expectations in their engagements with suppliers.
Supplier engagement: We engage with suppliers to request that they complete a valid CMRT for the in-scope products that they supply to us. Juniper has adopted engagement procedures that include steps of supplier engagement and escalation such as in-person meetings, business reviews, outreach conducted by commodity managers, sharing of best practices and training resources, and identification of corrective actions. When entering into or renewing supplier master purchase agreements, we include our Business Partner Code of Conduct. We provide all in-scope suppliers access to conflict minerals education and training resources through the Service Provider's Learning Management System. Additional training is provided to certain suppliers who report smelters or refiners of potential concern.
If we determine that a supplier has not complied with Juniper’s conflict minerals policy, has not met Juniper’s performance expectations or has sourced minerals that finance or benefit armed groups, the matter is escalated to Juniper’s Corporate Vice President of Supply Chain Operations to determine whether Juniper should suspend the supplier, disengage from the supplier, or take other corrective actions with respect to the supplier.
Grievance mechanisms: Employees, business partners, suppliers, and customers are encouraged to immediately alert Juniper to any events of a questionable, fraudulent, or illegal nature that are, or may be, in violation of Juniper’s Worldwide Code of Business Conduct or Juniper’s Business Partner Code of Conduct, including any events relating to the source of 3TG in products supplied by our suppliers. Information may be submitted through email to integrity@juniper.net, by phone to the toll-free Juniper Integrity Hotline at +1-855-410-5445, online at integrity@juniper.net, or directly to Juniper’s Chief Compliance Officer. Information can be submitted anonymously and will be kept confidential to the fullest extent practicable and allowed by law.
Records maintenance: Juniper has implemented an electronic document retention policy to retain certain 3TG-related documents for a period of five years, including supplier responses to CMRTs.
Step 2: Identify and Assess Risk in the Supply Chain
We identify and assess risk in our supply chain in conformance with Step 2 of the Guidance. Our compliance steps include surveying our supply chain using the CMRT, aggregating and analyzing the responses, and following up with suppliers for clarification or with requests for further information when their responses trigger specified quality control flags.
The primary risk we identified with respect to the 2020 reporting period related to the nature of the responses received. Approximately 29% of the Surveyed Suppliers did not submit a CMRT and approximately 65% of the responses received provided data at a company level or did not specify the smelters or refiners that processed the 3TG in the products, materials or components supplied to Juniper. Additionally, approximately 25% of the Surveyed Suppliers indicated that they received information regarding their supply chains from less than 100% of their suppliers and, therefore, they may not have provided a comprehensive list of all smelters and refiners in their supply chains.
As part of our due diligence, we compared the smelters and refiners listed in the CMRTs received to the lists of smelters and refiners maintained by the RMI. See Appendix A below for a list of the known smelters and refiners listed in the CMRTs provided by our suppliers, along with the compliance status of such smelters and refiners.
Each smelter or refiner is assigned a risk of high, medium, or low based on the following five factors: (1) its geographic proximity to the Covered Countries; (2) known mineral source country of origin; (3) its RMAP audit status; (4) credible evidence of unethical or conflict sourcing; and (5) peer assessments conducted by third-party sources believed to be credible by
the Service Provider. In addition to the risk mitigation steps described below, we request that suppliers that identify smelters or refiners that are categorized as high risk submit a product-level CMRT, and such suppliers are directed to educational resources on the Service Provider’s website. If the supplier is not able to provide a product-level CMRT or confirm that the high-risk smelter or refiner is not in Juniper’s supply chain, Juniper requests that the supplier provide a corrective action plan.
Additionally, suppliers’ CMRT responses are used to evaluate their program strength. We use the following criteria to evaluate the strength of a program: (1) whether the supplier has a conflict minerals sourcing policy; (2) whether the supplier has implemented 3TG due diligence measures; (3) whether the supplier reviews due diligence information received from its own suppliers against the expectations set forth in its policy; and (4) whether the supplier has a corrective action process. Suppliers that meet or exceed these criteria (answer “Yes” to all four criteria) are deemed to have a “strong” program; otherwise their program is deemed to be “weak.” For 2020, approximately 9% of the Surveyed Suppliers that completed a CMRT were identified as having a “weak” program. In addition to the risk mitigation steps discussed below, if a supplier’s program is deemed to be weak, the supplier is provided with additional guidance and education through the Service Provider’s learning tools.
Identifying and assessing risks related to (1) information relevance, accuracy and comprehensiveness, (2) geographic proximity and (3) program strength is intended to help us address Step 2 of the Guidance.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
The results of our due diligence are shared with the executive champions (currently our Corporate Vice President of Supply Chain Operations and Senior Vice President, General Counsel) through our Corporate Social Responsibility Executive Committee meetings, as well as with the Audit Committee of our Board of Directors, which, among other responsibilities, is charged with oversight of risk management and financial reporting and compliance.
We address any risks identified through the process described in Step 2 on a case-by-case basis. Regarding suppliers who do not respond to the Service Provider’s outreach, Juniper’s conflict minerals and supply chain operations teams contact these suppliers directly and request that such suppliers submit a CMRT. Other actions considered in our corrective action framework include, depending upon the particular circumstances, requesting a product-level CMRT and that the supplier take corrective action to ensure that any high-risk smelters or refiners are not in Juniper’s supply chain. We may also provide a supplier with additional guidance and education regarding the Rule, the Guidance, and/or our compliance expectations.
Through our participation in the RMI, we also address smelter- and refiner-related risks and seek to exercise leverage over smelters and refiners to become Conformant. We provide the RMI with Juniper’s lists of smelters and refiners that are not Conformant or Active and those entities disclosed by suppliers that are not listed as known smelters or refiners by the RMI in order to assist the RMI with prioritizing (1) outreach to those known smelters and refiners that are not participating in the RMAP and (2) research regarding those commonly reported entities that are not identified as a smelter or a refiner.
Step 4: Carry Out Independent Third-Party Audits of Supply Chain Due Diligence at Identified Points in the Supply Chain
Given that we are a downstream supplier, many steps removed from the mining or processing of 3TG, and that we do not purchase raw ore or refined 3TG, Juniper relies on independent third-party audits of smelters and refiners. Juniper supports such independent third-party audits, including those conducted by the RMAP, through our financial support for the RMI.
Juniper also actively supports the goal of increasing smelter and refiner participation in the RMAP through our participation in the RMI pursuant to which we provide the RMI with Juniper’s lists of smelters and refiners that are not Conformant or Active. This assists the RMI with prioritizing outreach to known smelters and refiners to encourage them to participate in the RMAP.
Step 5: Report on Supply Chain Due Diligence
This Report and the associated Form SD are filed annually with the SEC and are made publicly available on our website at https://www.juniper.net/us/en/company/citizenship-sustainability/supply-chain/#tab=dtabs-4.
Future Steps to Mitigate Risk
For 2021, we anticipate continuing to focus on collaborating with industry participants through our membership in the RMI to improve the systems of transparency and control in 3TG supply chains.
In addition, as part of our ongoing compliance and sustainability efforts, we intend to continue the implementation of the following efforts identified in last year’s Conflict Minerals Report:
•Request that suppliers complete CMRTs on a product-specific basis, to enable us to determine which smelters and refiners actually process 3TG contained in our products.
•Encourage our suppliers that have not already done so to implement due diligence procedures through targeted outreach that provides guidance and resources to improve program strength and increase rate of response (to achieve 100%) from their own suppliers.
•Encourage our suppliers to source only from Conformant smelters and refiners by (1) awarding higher supplier Compliance, Risk and Sustainability scores to those who only utilize Conformant smelters and refiners and (2) continuing to request facilities that are not listed as Conformant by the RMI to obtain an independent third-party audit. A supplier’s Compliance, Risk and Sustainability score is an input in the supplier performance scorecard.
•Measure the overall performance improvement of the supply chain by tracking supplier performance against selected metrics, including data quality and completeness and the percentage of reported smelters and refiners that are Conformant, with the goal of identifying areas for further improvement and further engagement with suppliers and the RMI.
Due Diligence Results
Survey Results
For the 2020 reporting year, Juniper received CMRTs from approximately 71% of the Surveyed Suppliers. We conducted outreach to request corrections to invalid data; however, approximately 2% of the Surveyed Suppliers did not correct the inaccuracies or gaps in their submitted CMRT. Accordingly, those CMRTs were treated as invalid submissions.
Smelters and Refiners Potentially in Juniper’s Supply Chain
Based on our RCOI and due diligence, we identified 333 known smelters and refiners of 3TG that may be in our supply chain in 2020. See Appendix A below for a list of these smelters and refiners, along with their conformance status. Appendix A does not include the names of entities received through our due diligence process that, as of May 17, 2021, were not listed on the RMI’s list of known smelters and refiners.
A summary of the known smelters and refiners for the 3TG that may be in our supply chain and their RMAP conformance status is provided below:
| | | | | | | | |
| RMAP Status | Number of Smelters and Refiners | Approximate Percentage of Total |
| Conformant | 237 | 71% |
| Active | 24 | 7% |
| Not Enrolled | 72 | 22% |
| Total Smelters and Refiners | 333 | 100% |
A summary of the approximate percentages of smelters and refiners by metal type that are conformant with RMAP is provided below:
| | | | | |
| Metal | Approximate Percentage of RMAP Conformant Smelters and Refiners |
| Gold | 63% |
| Tantalum | 100% |
| Tin | 69% |
| Tungsten | 83% |
It may be the case that not all of the smelters and refiners listed in the CMRTs that we received processed necessary 3TG contained in Juniper’s in-scope products, since, as noted earlier in this Report, approximately 65% of the Surveyed Suppliers reported their CMRT at a “company level.” In addition, Surveyed Suppliers may have also reported smelters and refiners that were not in Juniper’s supply chain due to the over-inclusiveness of the information received from their suppliers or for other reasons. Finally, the smelters and refiners reflected in Appendix A may not include all of the smelters and refiners in Juniper’s supply chain, since approximately 25% of the Surveyed Suppliers indicated that they received information regarding their supply chains from less than 100% of their suppliers, and therefore the Surveyed Suppliers may not have identified all smelters and refiners in their supply chains, and because approximately 29% of the Surveyed Suppliers did not respond to Juniper’s inquiries.
As of the date of this Report and for the reporting period covered by this Report, we have not identified a supplier, smelter or refiner that we have reason to believe is sourcing 3TG contained in our in-scope products that is directly or indirectly financing
or benefiting an armed group. However, given that we have received insufficient information with respect to certain smelters and refiners that may have processed 3TG in our products, we have not determined that any of our products are “DRC conflict-free.”
Country of Origin Information and Efforts to Determine Mine Location
The identified countries of origin of the 3TG processed by the Conformant smelters and refiners listed in the table in Appendix A may have included the countries in the categories listed below, as well as other countries. The listed countries of origin are derived from information made available by the RMI to its members on March 26, 2021. Except for the DRC, the RMI does not indicate individual countries of origin for the 3TG processed by Conformant smelters and refiners. Instead, the RMI indicates country of origin by category: L1, L2 and CC. The categories are based on sourcing risk, as indicated below.
L1—Countries that are not identified as conflict regions or plausible areas of smuggling or export of 3TG from the Covered Countries. Countries of origin include: Australia, Bolivia, Brazil, China, Colombia, Ethiopia, France, Ghana, Indonesia, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Sierra Leone, Spain, Taiwan, Thailand, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan and Venezuela.
L2—Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG. Countries of origin include: Mozambique and South Africa.
CC—The nine countries adjoining the DRC. Countries of origin include: Burundi, Rwanda, Tanzania, and Uganda.
Alternatively, or in addition, approximately 68% of the known smelters and refiners listed in the table in Appendix A did source or may have sourced from recycled or scrap sources.
Because the RMI generally does not indicate individual countries of origin of the 3TG processed by Conformant smelters and refiners, Juniper was not able to determine the countries of origin of the 3TG processed by the listed Conformant smelters and refiners with greater specificity. In addition, for some of the listed Conformant smelters and refiners, origin information is not disclosed by the RMI. Juniper did not determine the countries of origin of the 3TG processed by other smelters and refiners listed on Appendix A.
Juniper endeavored to determine the mine or location of origin of the necessary 3TG contained in its in-scope products by conducting a supply-chain survey with suppliers using the CMRT and through the information made available by the RMI to its members, as well as the other measures described in this Report.
Forward-Looking Statements
This Report, including the section entitled “Future Steps to Mitigate Risk,” contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995 regarding our business, products and 3TG compliance efforts, including steps we intend to take to mitigate the risk that the 3TG in our products benefits armed groups, and the industry’s 3TG-related compliance efforts. Words such as “expects,” “anticipates,” “targets,” “goals,” “projects,” “would,” “could,” “intends,” “plans,” “believes,” “seeks,” “estimates,” variations of such words, and similar expressions are intended to identify such forward-looking statements. Forward-looking statements by their nature address matters that are, to different degrees, uncertain, and these forward-looking statements are only predictions and are subject to risks, uncertainties, and assumptions that are difficult to predict. While forward-looking statements in this Report are based on reasonable expectations of our management at the time that they are made, you should not rely on them. Forward-looking statements are inherently subject to risks and uncertainties and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include, without limitation, the risk that information reported to us by our direct suppliers or industry information used by us may be inaccurate; the risk that smelters or refiners may not participate in the RMAP; political and regulatory developments, whether in the Covered Countries, the United States or elsewhere; the risk that industry organizations and initiatives, such as the RMI and the RMAP, may not be an effective source of external support in our conflict minerals compliance process; as well as risks discussed under the heading “Risk Factors” in our most recent Annual Report on 10-K or subsequent Quarterly Report on Form 10-Q and in other reports we file with the SEC. Readers are urged not to place undue reliance on these forward-looking statements, which speak only as of the date of this Report. We undertake no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this Report.
Appendix A
Smelters and Refiners List
The below table lists the smelters or refiners that were identified by the Surveyed Suppliers through their CMRTs and that are, as of May 17, 2021, listed on the RMI’s list of known smelters and refiners. This list includes the Metal, Standard Smelter Name, Smelter Facility Location, Smelter ID, and RMI Audit Status. As indicated in the Report to which this Appendix is attached, this list has been created based on Surveyed Supplier responses. It may be the case that not all of the smelters and refiners listed in CMRTs that we received have processed necessary 3TG contained in Juniper’s in-scope products, since approximately 65% of the Surveyed Suppliers reported their CMRT at a “company level.” In addition, this list may include reported smelters and refiners that were not in Juniper’s supply chain due to the over-inclusiveness of the information received from Surveyed Suppliers or for other reasons. In addition, the smelters and refiners listed below may not include all of the smelters and refiners in Juniper’s supply chain, since approximately 25% of the Surveyed Suppliers indicated that they received information regarding their supply chains from less than 100% of their suppliers and therefore the Surveyed Suppliers may not have identified all smelters or refiners in their supply chain, and because approximately 29% of Surveyed Suppliers did not respond to Juniper’s inquiries.
| | | | | |
| * | RMI Audit Status is as of May 17, 2021. For purposes of this table, “Conformant” denotes that the smelter or refiner participates in the RMAP and has been listed as “conformant” by the RMI, which includes those smelters and refiners described as “re-audit in progress,” and “Active” denotes that the smelter or refiner is a participant in the RMAP and has committed to undergo an RMAP assessment, has completed the relevant documents, and has scheduled the on-site assessment. “Not Enrolled” means that the smelter or refiner is listed on the Smelter Look-up tab of the CMRT but is not Conformant or Active. Smelter and refiner status reflected in this Appendix is based solely on information made publicly available by the RMI, without independent verification by Juniper. |
| | | | | | | | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | Smelter ID | | RMI Audit Status* |
| Gold | | Advanced Chemical Company | | UNITED STATES OF AMERICA | | CID000015 | | Conformant |
| Gold | | Aida Chemical Industries Co., Ltd. | | JAPAN | | CID000019 | | Conformant |
| Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | GERMANY | | CID000035 | | Conformant |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | UZBEKISTAN | | CID000041 | | Conformant |
| Gold | | AngloGold Ashanti Corrego do Sitio Mineracao | | BRAZIL | | CID000058 | | Conformant |
| Gold | | Argor-Heraeus S.A. | | SWITZERLAND | | CID000077 | | Conformant |
| Gold | | Asahi Pretec Corp. | | JAPAN | | CID000082 | | Conformant |
| Gold | | Asaka Riken Co., Ltd. | | JAPAN | | CID000090 | | Conformant |
| Gold | | Aurubis AG | | GERMANY | | CID000113 | | Conformant |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | PHILIPPINES | | CID000128 | | Conformant |
| Gold | | Boliden AB | | SWEDEN | | CID000157 | | Conformant |
| Gold | | C. Hafner GmbH + Co. KG | | GERMANY | | CID000176 | | Conformant |
| Gold | | CCR Refinery - Glencore Canada Corporation | | CANADA | | CID000185 | | Conformant |
| Gold | | Cendres + Metaux S.A. | | SWITZERLAND | | CID000189 | | Conformant |
| Gold | | Chimet S.p.A. | | ITALY | | CID000233 | | Conformant |
| Gold | | Chugai Mining | | JAPAN | | CID000264 | | Conformant |
| Gold | | DSC (Do Sung Corporation) | | KOREA, REPUBLIC OF | | CID000359 | | Conformant |
| Gold | | DODUCO Contacts and Refining GmbH | | GERMANY | | CID000362 | | Conformant |
| Gold | | Dowa | | JAPAN | | CID000401 | | Conformant |
| Gold | | Eco-System Recycling Co., Ltd. East Plant | | JAPAN | | CID000425 | | Conformant |
| Gold | | OJSC Novosibirsk Refinery | | RUSSIAN FEDERATION | | CID000493 | | Conformant |
| Gold | | LT Metal Ltd. | | KOREA, REPUBLIC OF | | CID000689 | | Conformant |
| Gold | | Heimerle + Meule GmbH | | GERMANY | | CID000694 | | Conformant |
| Gold | | Heraeus Metals Hong Kong Ltd. | | CHINA | | CID000707 | | Conformant |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | CHINA | | CID000801 | | Conformant |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | JAPAN | | CID000807 | | Conformant |
| Gold | | Istanbul Gold Refinery | | TURKEY | | CID000814 | | Conformant |
| Gold | | Japan Mint | | JAPAN | | CID000823 | | Conformant |
| Gold | | Jiangxi Copper Co., Ltd. | | CHINA | | CID000855 | | Conformant |
| Gold | | Asahi Refining USA Inc. | | UNITED STATES OF AMERICA | | CID000920 | | Conformant |
| Gold | | Asahi Refining Canada Ltd. | | CANADA | | CID000924 | | Conformant |
| Gold | | JSC Uralelectromed | | RUSSIAN FEDERATION | | CID000929 | | Conformant |
| | | | | | | | | | | | | | | | | | | | | | | | | | |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | JAPAN | | CID000937 | | Conformant |
| Gold | | Kazzinc | | KAZAKHSTAN | | CID000957 | | Conformant |
| Gold | | Kennecott Utah Copper LLC | | UNITED STATES OF AMERICA | | CID000969 | | Conformant |
| Gold | | Kojima Chemicals Co., Ltd. | | JAPAN | | CID000981 | | Conformant |
| Gold | | Kyrgyzaltyn JSC | | KYRGYZSTAN | | CID001029 | | Conformant |
| Gold | | LS-NIKKO Copper Inc. | | KOREA, REPUBLIC OF | | CID001078 | | Conformant |
| Gold | | Materion | | UNITED STATES OF AMERICA | | CID001113 | | Conformant |
| Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN | | CID001119 | | Conformant |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | CHINA | | CID001147 | | Conformant |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | CHINA | | CID001149 | | Conformant |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | SINGAPORE | | CID001152 | | Conformant |
| Gold | | Metalor Technologies S.A. | | SWITZERLAND | | CID001153 | | Conformant |
| Gold | | Metalor USA Refining Corporation | | UNITED STATES OF AMERICA | | CID001157 | | Conformant |
| Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | MEXICO | | CID001161 | | Conformant |
| Gold | | Mitsubishi Materials Corporation | | JAPAN | | CID001188 | | Conformant |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN | | CID001193 | | Conformant |
| Gold | | Moscow Special Alloys Processing Plant | | RUSSIAN FEDERATION | | CID001204 | | Conformant |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.S. | | TURKEY | | CID001220 | | Conformant |
| Gold | | Navoi Mining and Metallurgical Combinat | | UZBEKISTAN | | CID001236 | | Conformant |
| Gold | | Nihon Material Co., Ltd. | | JAPAN | | CID001259 | | Conformant |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | JAPAN | | CID001325 | | Conformant |
| Gold | | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | | RUSSIAN FEDERATION | | CID001326 | | Conformant |
| Gold | | PAMP S.A. | | SWITZERLAND | | CID001352 | | Conformant |
| Gold | | Prioksky Plant of Non-Ferrous Metals | | RUSSIAN FEDERATION | | CID001386 | | Conformant |
| Gold | | PT Aneka Tambang (Persero) Tbk | | INDONESIA | | CID001397 | | Conformant |
| Gold | | PX Precinox S.A. | | SWITZERLAND | | CID001498 | | Conformant |
| Gold | | Rand Refinery (Pty) Ltd. | | SOUTH AFRICA | | CID001512 | | Conformant |
| Gold | | Royal Canadian Mint | | CANADA | | CID001534 | | Conformant |
| Gold | | Samduck Precious Metals | | KOREA, REPUBLIC OF | | CID001555 | | Conformant |
| Gold | | SEMPSA Joyeria Plateria S.A. | | SPAIN | | CID001585 | | Conformant |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | CHINA | | CID001622 | | Conformant |
| Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | CHINA | | CID001736 | | Conformant |
| Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | RUSSIAN FEDERATION | | CID001756 | | Conformant |
| Gold | | Solar Applied Materials Technology Corp. | | TAIWAN, PROVINCE OF CHINA | | CID001761 | | Conformant |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | JAPAN | | CID001798 | | Conformant |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | JAPAN | | CID001875 | | Conformant |
| Gold | | The Refinery of Shandong Gold Mining Co., Ltd. | | CHINA | | CID001916 | | Conformant |
| Gold | | Tokuriki Honten Co., Ltd. | | JAPAN | | CID001938 | | Conformant |
| Gold | | Torecom | | KOREA, REPUBLIC OF | | CID001955 | | Conformant |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | BELGIUM | | CID001980 | | Conformant |
| Gold | | United Precious Metal Refining, Inc. | | UNITED STATES OF AMERICA | | CID001993 | | Conformant |
| Gold | | Valcambi S.A. | | SWITZERLAND | | CID002003 | | Conformant |
| Gold | | Western Australian Mint (T/a The Perth Mint) | | AUSTRALIA | | CID002030 | | Conformant |
| Gold | | Yamakin Co., Ltd. | | JAPAN | | CID002100 | | Conformant |
| Gold | | Yokohama Metal Co., Ltd. | | JAPAN | | CID002129 | | Conformant |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | CHINA | | CID002224 | | Conformant |
| Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | CHINA | | CID002243 | | Conformant |
| Gold | | SAFINA A.S. | | CZECH REPUBLIC | | CID002290 | | Conformant |
| Gold | | Umicore Precious Metals Thailand | | THAILAND | | CID002314 | | Conformant |
| Gold | | Geib Refining Corporation | | UNITED STATES OF AMERICA | | CID002459 | | Conformant |
| Gold | | MMTC-PAMP India Pvt., Ltd. | | INDIA | | CID002509 | | Conformant |
| Gold | | KGHM Polska Miedz Spolka Akcyjna | | POLAND | | CID002511 | | Conformant |
| Gold | | Singway Technology Co., Ltd. | | TAIWAN, PROVINCE OF CHINA | | CID002516 | | Conformant |
| Gold | | Al Etihad Gold Refinery DMCC | | UNITED ARAB EMIRATES | | CID002560 | | Conformant |
| Gold | | Emirates Gold DMCC | | UNITED ARAB EMIRATES | | CID002561 | | Conformant |
| Gold | | T.C.A S.p.A | | ITALY | | CID002580 | | Conformant |
| Gold | | REMONDIS PMR B.V. | | NETHERLANDS | | CID002582 | | Conformant |
| Gold | | Korea Zinc Co., Ltd. | | KOREA, REPUBLIC OF | | CID002605 | | Conformant |
| | | | | | | | | | | | | | | | | | | | | | | | | | |
| Gold | | Marsam Metals | | BRAZIL | | CID002606 | | Conformant |
| Gold | | TOO Tau-Ken-Altyn | | KAZAKHSTAN | | CID002615 | | Conformant |
| Gold | | SAAMP | | FRANCE | | CID002761 | | Conformant |
| Gold | | L'Orfebre S.A. | | ANDORRA | | CID002762 | | Conformant |
| Gold | | 8853 S.p.A. | | ITALY | | CID002763 | | Conformant |
| Gold | | Italpreziosi | | ITALY | | CID002765 | | Conformant |
| Gold | | SAXONIA Edelmetalle GmbH | | GERMANY | | CID002777 | | Conformant |
| Gold | | WIELAND Edelmetalle GmbH | | GERMANY | | CID002778 | | Conformant |
| Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | AUSTRIA | | CID002779 | | Conformant |
| Gold | | AU Traders and Refiners | | SOUTH AFRICA | | CID002850 | | Conformant |
| Gold | | Bangalore Refinery | | INDIA | | CID002863 | | Conformant |
| Gold | | SungEel HiMetal Co., Ltd. | | KOREA, REPUBLIC OF | | CID002918 | | Conformant |
| Gold | | Planta Recuperadora de Metales SpA | | CHILE | | CID002919 | | Conformant |
| Gold | | Safimet S.p.A | | ITALY | | CID002973 | | Conformant |
| Gold | | DS PRETECH Co., Ltd. | | KOREA, REPUBLIC OF | | CID003195 | | Conformant |
| Gold | | Eco-System Recycling Co., Ltd. North Plant | | JAPAN | | CID003424 | | Conformant |
| Gold | | Eco-System Recycling Co., Ltd. West Plant | | JAPAN | | CID003425 | | Conformant |
| Gold | | Metal Concentrators SA (Pty) Ltd. | | SOUTH AFRICA | | CID003575 | | Conformant |
| Gold | | Heraeus Precious Metals GmbH & Co. KG | | GERMANY | | CID000711 | | Active |
| Gold | | International Precious Metal Refiners | | UNITED ARAB EMIRATES | | CID002562 | | Active |
| Gold | | C.I Metales Procesados Industriales SAS | | COLOMBIA | | CID003421 | | Active |
| Gold | | Augmont Enterprises Private Limited | | INDIA | | CID003461 | | Active |
| Gold | | Alexy Metals | | UNITED STATES OF AMERICA | | CID003500 | | Active |
| Gold | | Metallix Refining Inc. | | UNITED STATES OF AMERICA | | CID003557 | | Active |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | TURKEY | | CID000103 | | Not enrolled |
| Gold | | Caridad | | MEXICO | | CID000180 | | Not enrolled |
| Gold | | Yunnan Copper Industry Co., Ltd. | | CHINA | | CID000197 | | Not enrolled |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | | CHINA | | CID000343 | | Not enrolled |
| Gold | | Refinery of Seemine Gold Co., Ltd. | | CHINA | | CID000522 | | Not enrolled |
| Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | CHINA | | CID000651 | | Not enrolled |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | CHINA | | CID000671 | | Not enrolled |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | | CHINA | | CID000767 | | Not enrolled |
| Gold | | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | | CHINA | | CID000773 | | Not enrolled |
| Gold | | HwaSeong CJ CO., LTD. | | KOREA, REPUBLIC OF | | CID000778 | | Not enrolled |
| Gold | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | RUSSIAN FEDERATION | | CID000927 | | Not enrolled |
| Gold | | Kazakhmys Smelting LLC | | KAZAKHSTAN | | CID000956 | | Not enrolled |
| Gold | | L'azurde Company For Jewelry | | SAUDI ARABIA | | CID001032 | | Not enrolled |
| Gold | | Lingbao Gold Co., Ltd. | | CHINA | | CID001056 | | Not enrolled |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | CHINA | | CID001058 | | Not enrolled |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | CHINA | | CID001093 | | Not enrolled |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | CHINA | | CID001362 | | Not enrolled |
| Gold | | Sabin Metal Corp. | | UNITED STATES OF AMERICA | | CID001546 | | Not enrolled |
| Gold | | Samwon Metals Corp. | | KOREA, REPUBLIC OF | | CID001562 | | Not enrolled |
| Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | CHINA | | CID001619 | | Not enrolled |
| Gold | | Super Dragon Technology Co., Ltd | | TAIWAN, PROVINCE OF CHINA | | CID001810 | | Not enrolled |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | | CHINA | | CID001909 | | Not enrolled |
| Gold | | Tongling Nonferrous Metals Group Co., Ltd. | | CHINA | | CID001947 | | Not enrolled |
| Gold | | Morris and Watson | | NEW ZEALAND | | CID002282 | | Not enrolled |
| Gold | | Guangdong Jinding Gold Limited | | CHINA | | CID002312 | | Not enrolled |
| Gold | | Fidelity Printers and Refiners Ltd. | | ZIMBABWE | | CID002515 | | Not enrolled |
| Gold | | Shandong Humon Smelting Co., Ltd. | | CHINA | | CID002525 | | Not enrolled |
| Gold | | Shenzhen Zhonghenglong Real Industry Co., Ltd. | | CHINA | | CID002527 | | Not enrolled |
| Gold | | Kaloti Precious Metals | | UNITED ARAB EMIRATES | | CID002563 | | Not enrolled |
| Gold | | Sudan Gold Refinery | | SUDAN | | CID002567 | | Not enrolled |
| Gold | | Fujairah Gold FZC | | UNITED ARAB EMIRATES | | CID002584 | | Not enrolled |
| Gold | | Tony Goetz NV | | BELGIUM | | CID002587 | | Not enrolled |
| Gold | | Shirpur Gold Refinery Ltd. | | INDIA | | CID002588 | | Not enrolled |
| Gold | | Abington Reldan Metals, LLC | | UNITED STATES OF AMERICA | | CID002708 | | Not enrolled |
| | | | | | | | | | | | | | | | | | | | | | | | | | |
| Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | | INDIA | | CID002852 | | Not enrolled |
| Gold | | Sai Refinery | | INDIA | | CID002853 | | Not enrolled |
| Gold | | Modeltech Sdn Bhd | | MALAYSIA | | CID002857 | | Not enrolled |
| Gold | | Kyshtym Copper-Electrolytic Plant ZAO | | RUSSIAN FEDERATION | | CID002865 | | Not enrolled |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | | GERMANY | | CID002867 | | Not enrolled |
| Gold | | Pease & Curren | | UNITED STATES OF AMERICA | | CID002872 | | Not enrolled |
| Gold | | JALAN & Company | | INDIA | | CID002893 | | Not enrolled |
| Gold | | State Research Institute Center for Physical Sciences and Technology | | LITHUANIA | | CID003153 | | Not enrolled |
| Gold | | African Gold Refinery | | UGANDA | | CID003185 | | Not enrolled |
| Gold | | Gold Coast Refinery | | GHANA | | CID003186 | | Not enrolled |
| Gold | | NH Recytech Company | | KOREA, REPUBLIC OF | | CID003189 | | Not enrolled |
| Gold | | QG Refining, LLC | | UNITED STATES OF AMERICA | | CID003324 | | Not enrolled |
| Gold | | Dijllah Gold Refinery FZC | | UNITED ARAB EMIRATES | | CID003348 | | Not enrolled |
| Gold | | CGR Metalloys Pvt Ltd. | | INDIA | | CID003382 | | Not enrolled |
| Gold | | Sovereign Metals | | INDIA | | CID003383 | | Not enrolled |
| Gold | | Kundan Care Products Ltd. | | INDIA | | CID003463 | | Not enrolled |
| Gold | | Emerald Jewel Industry India Limited (Unit 1) | | INDIA | | CID003487 | | Not enrolled |
| Gold | | Emerald Jewel Industry India Limited (Unit 2) | | INDIA | | CID003488 | | Not enrolled |
| Gold | | Emerald Jewel Industry India Limited (Unit 3) | | INDIA | | CID003489 | | Not enrolled |
| Gold | | Emerald Jewel Industry India Limited (Unit 4) | | INDIA | | CID003490 | | Not enrolled |
| Gold | | K.A. Rasmussen | | NORWAY | | CID003497 | | Not enrolled |
| Gold | | Sancus ZFS (L’Orfebre, SA) | | COLOMBIA | | CID003529 | | Not enrolled |
| Gold | | Sellem Industries Ltd. | | MAURITANIA | | CID003540 | | Not enrolled |
| Gold | | MD Overseas | | INDIA | | CID003548 | | Not enrolled |
| Tantalum | | Asaka Riken Co., Ltd. | | JAPAN | | CID000092 | | Conformant |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA | | CID000211 | | Conformant |
| Tantalum | | Exotech Inc. | | UNITED STATES OF AMERICA | | CID000456 | | Conformant |
| Tantalum | | F&X Electro-Materials Ltd. | | CHINA | | CID000460 | | Conformant |
| Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA | | CID000616 | | Conformant |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA | | CID000914 | | Conformant |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | CHINA | | CID000917 | | Conformant |
| Tantalum | | LSM Brasil S.A. | | BRAZIL | | CID001076 | | Conformant |
| Tantalum | | Metallurgical Products India Pvt., Ltd. | | INDIA | | CID001163 | | Conformant |
| Tantalum | | Mineracao Taboca S.A. | | BRAZIL | | CID001175 | | Conformant |
| Tantalum | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN | | CID001192 | | Conformant |
| Tantalum | | NPM Silmet AS | | ESTONIA | | CID001200 | | Conformant |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA | | CID001277 | | Conformant |
| Tantalum | | QuantumClean | | UNITED STATES OF AMERICA | | CID001508 | | Conformant |
| Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | CHINA | | CID001522 | | Conformant |
| Tantalum | | Solikamsk Magnesium Works OAO | | RUSSIAN FEDERATION | | CID001769 | | Conformant |
| Tantalum | | Taki Chemical Co., Ltd. | | JAPAN | | CID001869 | | Conformant |
| Tantalum | | Telex Metals | | UNITED STATES OF AMERICA | | CID001891 | | Conformant |
| Tantalum | | Ulba Metallurgical Plant JSC | | KAZAKHSTAN | | CID001969 | | Conformant |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | CHINA | | CID002492 | | Conformant |
| Tantalum | | D Block Metals, LLC | | UNITED STATES OF AMERICA | | CID002504 | | Conformant |
| Tantalum | | FIR Metals & Resource Ltd. | | CHINA | | CID002505 | | Conformant |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | CHINA | | CID002506 | | Conformant |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA | | CID002508 | | Conformant |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | CHINA | | CID002512 | | Conformant |
| Tantalum | | KEMET Blue Metals | | MEXICO | | CID002539 | | Conformant |
| Tantalum | | H.C. Starck Co., Ltd. | | THAILAND | | CID002544 | | Conformant |
| Tantalum | | H.C. Starck Tantalum and Niobium GmbH | | GERMANY | | CID002545 | | Conformant |
| Tantalum | | H.C. Starck Hermsdorf GmbH | | GERMANY | | CID002547 | | Conformant |
| Tantalum | | H.C. Starck Inc. | | UNITED STATES OF AMERICA | | CID002548 | | Conformant |
| Tantalum | | H.C. Starck Ltd. | | JAPAN | | CID002549 | | Conformant |
| Tantalum | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY | | CID002550 | | Conformant |
| Tantalum | | Global Advanced Metals Boyertown | | UNITED STATES OF AMERICA | | CID002557 | | Conformant |
| Tantalum | | Global Advanced Metals Aizu | | JAPAN | | CID002558 | | Conformant |
| | | | | | | | | | | | | | | | | | | | | | | | | | |
| Tantalum | | Resind Industria e Comercio Ltda. | | BRAZIL | | CID002707 | | Conformant |
| Tantalum | | Jiangxi Tuohong New Raw Material | | CHINA | | CID002842 | | Conformant |
| Tantalum | | PRG Dooel | | NORTH MACEDONIA, REPUBLIC OF | | CID002847 | | Conformant |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CHINA | | CID000228 | | Conformant |
| Tin | | Alpha | | UNITED STATES OF AMERICA | | CID000292 | | Conformant |
| Tin | | Dowa | | JAPAN | | CID000402 | | Conformant |
| Tin | | EM Vinto | | BOLIVIA (PLURINATIONAL STATE OF) | | CID000438 | | Conformant |
| Tin | | Fenix Metals | | POLAND | | CID000468 | | Conformant |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | CHINA | | CID000538 | | Conformant |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | CHINA | | CID000555 | | Conformant |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | CHINA | | CID000942 | | Conformant |
| Tin | | China Tin Group Co., Ltd. | | CHINA | | CID001070 | | Conformant |
| Tin | | Malaysia Smelting Corporation (MSC) | | MALAYSIA | | CID001105 | | Conformant |
| Tin | | Metallic Resources, Inc. | | UNITED STATES OF AMERICA | | CID001142 | | Conformant |
| Tin | | Mineracao Taboca S.A. | | BRAZIL | | CID001173 | | Conformant |
| Tin | | Minsur | | PERU | | CID001182 | | Conformant |
| Tin | | Mitsubishi Materials Corporation | | JAPAN | | CID001191 | | Conformant |
| Tin | | Jiangxi New Nanshan Technology Ltd. | | CHINA | | CID001231 | | Conformant |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND | | CID001314 | | Conformant |
| Tin | | Operaciones Metalurgicas S.A. | | BOLIVIA (PLURINATIONAL STATE OF) | | CID001337 | | Conformant |
| Tin | | PT Artha Cipta Langgeng | | INDONESIA | | CID001399 | | Conformant |
| Tin | | PT Babel Inti Perkasa | | INDONESIA | | CID001402 | | Conformant |
| Tin | | PT Babel Surya Alam Lestari | | INDONESIA | | CID001406 | | Conformant |
| Tin | | PT Mitra Stania Prima | | INDONESIA | | CID001453 | | Conformant |
| Tin | | PT Prima Timah Utama | | INDONESIA | | CID001458 | | Conformant |
| Tin | | PT Refined Bangka Tin | | INDONESIA | | CID001460 | | Conformant |
| Tin | | PT Stanindo Inti Perkasa | | INDONESIA | | CID001468 | | Conformant |
| Tin | | PT Timah Tbk Kundur | | INDONESIA | | CID001477 | | Conformant |
| Tin | | PT Timah Tbk Mentok | | INDONESIA | | CID001482 | | Conformant |
| Tin | | PT Tinindo Inter Nusa | | INDONESIA | | CID001490 | | Conformant |
| Tin | | Rui Da Hung | | TAIWAN, PROVINCE OF CHINA | | CID001539 | | Conformant |
| Tin | | Soft Metais Ltda. | | BRAZIL | | CID001758 | | Conformant |
| Tin | | Thaisarco | | THAILAND | | CID001898 | | Conformant |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | CHINA | | CID001908 | | Conformant |
| Tin | | White Solder Metalurgia e Mineracao Ltda. | | BRAZIL | | CID002036 | | Conformant |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | CHINA | | CID002158 | | Conformant |
| Tin | | Yunnan Tin Company Limited | | CHINA | | CID002180 | | Conformant |
| Tin | | Magnu's Minerais Metais e Ligas Ltda. | | BRAZIL | | CID002468 | | Conformant |
| Tin | | Melt Metais e Ligas S.A. | | BRAZIL | | CID002500 | | Conformant |
| Tin | | PT ATD Makmur Mandiri Jaya | | INDONESIA | | CID002503 | | Conformant |
| Tin | | O.M. Manufacturing Philippines, Inc. | | PHILIPPINES | | CID002517 | | Conformant |
| Tin | | PT Rajehan Ariq | | INDONESIA | | CID002593 | | Conformant |
| Tin | | Resind Industria e Comercio Ltda. | | BRAZIL | | CID002706 | | Conformant |
| Tin | | Metallo Belgium N.V. | | BELGIUM | | CID002773 | | Conformant |
| Tin | | Metallo Spain S.L.U. | | SPAIN | | CID002774 | | Conformant |
| Tin | | Thai Nguyen Mining and Metallurgy Co., Ltd. | | VIETNAM | | CID002834 | | Conformant |
| Tin | | PT Menara Cipta Mulia | | INDONESIA | | CID002835 | | Conformant |
| Tin | | HuiChang Hill Tin Industry Co., Ltd. | | CHINA | | CID002844 | | Conformant |
| Tin | | Gejiu Fengming Metallurgy Chemical Plant | | CHINA | | CID002848 | | Conformant |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | CHINA | | CID003116 | | Conformant |
| Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | CHINA | | CID003190 | | Conformant |
| Tin | | PT Bangka Serumpun | | INDONESIA | | CID003205 | | Conformant |
| Tin | | Tin Technology & Refining | | UNITED STATES OF AMERICA | | CID003325 | | Conformant |
| Tin | | Ma'anshan Weitai Tin Co., Ltd. | | CHINA | | CID003379 | | Conformant |
| Tin | | PT Rajawali Rimba Perkasa | | INDONESIA | | CID003381 | | Conformant |
| Tin | | Luna Smelter, Ltd. | | RWANDA | | CID003387 | | Conformant |
| Tin | | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | | CHINA | | CID003397 | | Conformant |
| | | | | | | | | | | | | | | | | | | | | | | | | | |
| Tin | | PT Aries Kencana Sejahtera | | INDONESIA | | CID000309 | | Active |
| Tin | | Estanho de Rondonia S.A. | | BRAZIL | | CID000448 | | Active |
| Tin | | Novosibirsk Processing Plant Ltd. | | RUSSIAN FEDERATION | | CID001305 | | Active |
| Tin | | PT Bukit Timah | | INDONESIA | | CID001428 | | Active |
| Tin | | PT Timah Nusantara | | INDONESIA | | CID001486 | | Active |
| Tin | | CV Venus Inti Perkasa | | INDONESIA | | CID002455 | | Active |
| Tin | | CV Ayi Jaya | | INDONESIA | | CID002570 | | Active |
| Tin | | Super Ligas | | BRAZIL | | CID002756 | | Active |
| Tin | | PT Sukses Inti Makmur | | INDONESIA | | CID002816 | | Active |
| Tin | | PT Lautan Harmonis Sejahtera | | INDONESIA | | CID002870 | | Active |
| Tin | | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | | BRAZIL | | CID003486 | | Active |
| Tin | | CRM Synergies | | SPAIN | | CID003524 | | Active |
| Tin | | VQB Mineral and Trading Group JSC | | VIETNAM | | CID002015 | | Not enrolled |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | VIETNAM | | CID002572 | | Not enrolled |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | VIETNAM | | CID002573 | | Not enrolled |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | VIETNAM | | CID002574 | | Not enrolled |
| Tin | | PT Cipta Persada Mulia | | INDONESIA | | CID002696 | | Not enrolled |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | VIETNAM | | CID002703 | | Not enrolled |
| Tin | | Modeltech Sdn Bhd | | MALAYSIA | | CID002858 | | Not enrolled |
| Tin | | Pongpipat Company Limited | | MYANMAR | | CID003208 | | Not enrolled |
| Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | | CHINA | | CID003356 | | Not enrolled |
| Tin | | Precious Minerals and Smelting Limited | | INDIA | | CID003409 | | Not enrolled |
| Tin | | Gejiu City Fuxiang Industry and Trade Co., Ltd. | | CHINA | | CID003410 | | Not enrolled |
| Tin | | PT Mitra Sukses Globalindo | | INDONESIA | | CID003449 | | Not enrolled |
| Tungsten | | A.L.M.T. Corp. | | JAPAN | | CID000004 | | Conformant |
| Tungsten | | Kennametal Huntsville | | UNITED STATES OF AMERICA | | CID000105 | | Conformant |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | CHINA | | CID000218 | | Conformant |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | CHINA | | CID000258 | | Conformant |
| Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES OF AMERICA | | CID000568 | | Conformant |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | CHINA | | CID000766 | | Conformant |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | CHINA | | CID000769 | | Conformant |
| Tungsten | | Japan New Metals Co., Ltd. | | JAPAN | | CID000825 | | Conformant |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA | | CID000875 | | Conformant |
| Tungsten | | Kennametal Fallon | | UNITED STATES OF AMERICA | | CID000966 | | Conformant |
| Tungsten | | Wolfram Bergbau und Hutten AG | | AUSTRIA | | CID002044 | | Conformant |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | CHINA | | CID002082 | | Conformant |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA | | CID002315 | | Conformant |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | CHINA | | CID002316 | | Conformant |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA | | CID002317 | | Conformant |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA | | CID002318 | | Conformant |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA | | CID002319 | | Conformant |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA | | CID002320 | | Conformant |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA | | CID002321 | | Conformant |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA | | CID002494 | | Conformant |
| Tungsten | | Asia Tungsten Products Vietnam Ltd. | | VIETNAM | | CID002502 | | Conformant |
| Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA | | CID002513 | | Conformant |
| Tungsten | | H.C. Starck Tungsten GmbH | | GERMANY | | CID002541 | | Conformant |
| Tungsten | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY | | CID002542 | | Conformant |
| Tungsten | | Masan Tungsten Chemical LLC (MTC) | | VIETNAM | | CID002543 | | Conformant |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | CHINA | | CID002551 | | Conformant |
| Tungsten | | Niagara Refining LLC | | UNITED STATES OF AMERICA | | CID002589 | | Conformant |
| Tungsten | | China Molybdenum Co., Ltd. | | CHINA | | CID002641 | | Conformant |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | CHINA | | CID002645 | | Conformant |
| Tungsten | | Hydrometallurg, JSC | | RUSSIAN FEDERATION | | CID002649 | | Conformant |
| Tungsten | | Unecha Refractory metals plant | | RUSSIAN FEDERATION | | CID002724 | | Conformant |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | PHILIPPINES | | CID002827 | | Conformant |
| | | | | | | | | | | | | | | | | | | | | | | | | | |
| Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA | | CID002830 | | Conformant |
| Tungsten | | ACL Metais Eireli | | BRAZIL | | CID002833 | | Conformant |
| Tungsten | | Moliren Ltd. | | RUSSIAN FEDERATION | | CID002845 | | Conformant |
| Tungsten | | KGETS Co., Ltd. | | KOREA, REPUBLIC OF | | CID003388 | | Conformant |
| Tungsten | | Fujian Ganmin RareMetal Co., Ltd. | | CHINA | | CID003401 | | Conformant |
| Tungsten | | Lianyou Metals Co., Ltd. | | TAIWAN, PROVINCE OF CHINA | | CID003407 | | Conformant |
| Tungsten | | JSC "Kirovgrad Hard Alloys Plant" | | RUSSIAN FEDERATION | | CID003408 | | Active |
| Tungsten | | NPP Tyazhmetprom LLC | | RUSSIAN FEDERATION | | CID003416 | | Active |
| Tungsten | | GEM Co., Ltd. | | CHINA | | CID003417 | | Active |
| Tungsten | | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | | BRAZIL | | CID003427 | | Active |
| Tungsten | | Cronimet Brasil Ltda | | BRAZIL | | CID003468 | | Active |
| Tungsten | | Artek LLC | | RUSSIAN FEDERATION | | CID003553 | | Active |
| Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | | CHINA | | CID000281 | | Not enrolled |
| Tungsten | | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | | CHINA | | CID002313 | | Not enrolled |