0001104657-20-000067.txt : 20200529 0001104657-20-000067.hdr.sgml : 20200529 20200529080956 ACCESSION NUMBER: 0001104657-20-000067 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20191231 1.02 20191231 FILED AS OF DATE: 20200529 DATE AS OF CHANGE: 20200529 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MATERION Corp CENTRAL INDEX KEY: 0001104657 STANDARD INDUSTRIAL CLASSIFICATION: METAL FORGING & STAMPINGS [3460] IRS NUMBER: 341919973 STATE OF INCORPORATION: OH FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-15885 FILM NUMBER: 20924081 BUSINESS ADDRESS: STREET 1: 6070 PARKLAND BLVD. CITY: MAYFIELD HTS. STATE: OH ZIP: 44124 BUSINESS PHONE: 2163834931 MAIL ADDRESS: STREET 1: 6070 PARKLAND BLVD. CITY: MAYFIELD HTS. STATE: OH ZIP: 44124 FORMER COMPANY: FORMER CONFORMED NAME: BRUSH ENGINEERED MATERIALS INC DATE OF NAME CHANGE: 20000131 SD 1 sd12-31x19.htm SD Document


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
 
 
 
 
FORM SD
Specialized Disclosure Report

MATERION CORPORATION
(Exact name of registrant as specified in its charter)
 
 
 
 
 
Ohio
001-15885
34-1919973
(State or other jurisdiction of incorporation or organization)
(Commission File Number)
(IRS Employer Identification No.)
 
 
 
 
 
 
6070 Parkland Blvd.
 
 
 
Mayfield Heights, Ohio 44124
 
 
 
(Address of principal executive offices)
(Zip code)
 
 
 
 
 
 
 
 
Gregory R. Chemnitz
 
 
 
Vice President, General Counsel and Secretary
 
 
 
(216) 486-4200
 
 
 
(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:
 
 
 
 
 
ý
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.




Section 1. Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report
Materion's Conflict Minerals Disclosure

Materion Corporation (including its consolidated subsidiaries, the “Company”) is filing this Specialized Disclosure Report on Form SD (“Form SD”) pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934 for the reporting period from January 1, 2019 to December 31, 2019 (the “Reporting Period”).

The Rule, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain “conflict minerals” (as defined below) are necessary to the functionality or production of such products. The Securities and Exchange Commission (“SEC”) defines “conflict minerals” as: (i)(a) columbite-tantalite (or coltan, the metal ore from which tantalum is extracted), (b) cassiterite (the metal ore from which tin is extracted), (c) gold and (d) wolframite (the metal ore from which tungsten is extracted), or their derivatives, which are currently limited to tantalum, tin and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an “adjoining country,” as such term is defined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Covered Countries”).

The Company’s operations may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products (collectively, the “products”). As required by the Rule, the Company has conducted a good faith, reasonable country of origin inquiry (“RCOI”) regarding the conflict minerals included in its products during the Reporting Period to determine whether any such conflict minerals originated in the Covered Countries and/or whether any of the conflict minerals were from recycled or scrap sources. Where applicable, the Company has conducted additional due diligence regarding the sources of the conflict minerals. The results of the Company’s RCOI regarding the conflict minerals, as well as its additional due diligence regarding the sources of such conflict minerals, are contained in the Company’s Conflict Minerals Report, a copy of which is filed as Exhibit 1.01 to this Form SD, and is publicly available at www.materion.com. The content on, or accessible through, any web site referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.

Item 1.02 Exhibit

As specified in Section 2 of Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.

Section 2. Exhibits

Item 2.01 Exhibits
The following exhibit is filed as part of this Form SD.

Exhibit No.        Description
1.01            Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.








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.


MATERION CORPORATION

By: /s/ Gregory R. Chemnitz                    
Gregory R. Chemnitz                                May 29, 2020
Vice President, General Counsel and Secretary



 EX-1.01 2 materion2019conflictminera.htm EXHIBIT 1.01 Exhibit


Exhibit 1.01

Conflict Minerals Report of Materion Corporation
for the Reporting Period from January 1, 2019 to December 31, 2019

Overview
This Conflict Minerals Report (this “Report”) of Materion Corporation (including its consolidated subsidiaries, “we”, “Materion” or the “Company”) has been prepared pursuant to Rule 13p-1 (the “Rule”) as promulgated under the Securities Exchange Act of 1934 for the reporting period from January 1, 2019 to December 31, 2019 (the “Reporting Period”).

Forward-looking statements contained in this Report are made based on known events and circumstances at the time of release, and as such, are subject in the future to unforeseen uncertainties and risks. Statements in this Report which express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements, including statements related to the Company’s compliance efforts and expected actions identified in this Report. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other matters, the Company’s customers' requirements to use certain suppliers, the Company’s suppliers' responsiveness and cooperation with the Company’s due diligence efforts, the Company’s ability to implement improvements in its conflict minerals program and the Company’s ability to identify and mitigate related risks in its supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see the Company’s other filings with the Securities and Exchange Commission (“SEC”), including its Annual Report on Form 10-K for the year ended December 31, 2019 and subsequent Quarterly Reports on Form 10-Q. The Company makes these statements as of the date of this disclosure, and undertakes no obligation to update them unless otherwise required by law.

Rule 13p-1, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain “conflict minerals” (as defined below) are necessary to the functionality or production of such products. The SEC defines “conflict minerals” as: (i)(a) columbite-tantalite (or coltan, the metal ore from which tantalum is extracted), (b) cassiterite (the metal ore from which tin is extracted), (c) gold and (d) wolframite (the metal ore from which tungsten is extracted), or their derivatives, which are currently limited to tantalum, tin and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an “adjoining country,” as such term is defined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (collectively, the “Covered Countries”).

The Company’s operations may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products (collectively, the “products”). As required by the Rule, the Company has conducted a good faith, reasonable country of origin inquiry (“RCOI”) regarding the conflict minerals included in the products during the Reporting Period to determine whether any such conflict minerals originated in the Covered Countries and/or whether any of the conflict minerals were from recycled or scrap sources. Where applicable, the Company has conducted additional due diligence regarding the sources of the conflict minerals. The results of the Company’s RCOI regarding the conflict minerals, as well as the Company’s additional due diligence regarding the sources of such conflict minerals, are contained in this Report, which is publicly available at www.materion.com. The content on, or accessible through, any web site referred to in this Report is not incorporated by reference into this Report unless expressly noted.

Materion, through its wholly owned subsidiaries, is an integrated producer of high-performance advanced engineered materials used in a variety of electrical, electronic, thermal and structural applications. Our products are sold into numerous end markets, including consumer electronics, industrial components, defense, medical, automotive electronics, telecommunications infrastructure, energy, commercial aerospace, science, services, and appliance.

Our businesses are organized under four reportable segments: Performance Alloys and Composites, Advanced Materials, Precision Coatings, and Other. Our Other reportable segment includes unallocated corporate costs.





Performance Alloys and Composites

Performance Alloys and Composites (PAC) provides advanced engineered solutions comprised of beryllium and non-beryllium containing alloy systems and custom engineered parts in strip, bulk, rod, plate, bar, and other customized shapes at manufacturing facilities located throughout the United States and Europe. This segment operates the world's largest bertrandite ore mine and refinery, which is located in Utah, providing feedstock hydroxide for its beryllium businesses and external sales. In addition to the products described below, this segment provides engineering and product development services to help our customers and partners with product design, including delivering prototype parts and other data to demonstrate that the products will perform under the specified design conditions.

Advanced Materials

Advanced Materials produces advanced chemicals, microelectronics packaging, precious metal, non-precious metal and specialty metal products, including vapor deposition targets, frame lid assemblies, clad and precious metal pre-forms, high temperature braze materials, and ultra-pure wire. These products are used in semiconductor logic and memory, medical, energy, lighting, defense, optics and wireless communications applications within the consumer electronics, industrial components, and telecommunications infrastructure end markets. Advanced Materials also has metal recovery operations and in-house refining that allow for the recycling of precious metals.

Precision Coatings

The Precision Coatings segment includes the following reporting units:

Precision Optics produces sputter-coated precision thin film coatings and optical filter materials. Based in Westford, Massachusetts, the group has manufacturing facilities in the United States and China.

Large Area Coatings produces high-performance sputter-coated precision flexible thin film materials. Based in Windsor, Connecticut, the business manufactures and distributes coated and converted thin film material solutions primarily for medical testing and diagnosis applications.

Other

The Other segment is comprised of unallocated corporate costs.

Description of Materion's Reasonable Country of Origin Inquiry

Materion has performed a good faith RCOI regarding the conflict minerals that were in our supply chain between January 1, 2019 and December 31, 2019 to determine whether any of the conflict minerals originated in the Covered Countries and whether any of the conflict minerals may be from recycled or scrap sources in accordance with the Rule and related guidance provided by the SEC.

The Company’s global supply chain is complex. In the course of its business operations, the Company may purchase materials and metals containing conflict minerals. These materials and metals may, in turn, be included in the Company’s products. Because the Company does not normally purchase conflict minerals directly from mines, smelters or refiners, there are many third parties in the supply chain between the Company and the original sources of conflict minerals. As a result, the Company relies on its direct suppliers to provide information regarding the origin of any conflict minerals that are included in its products. In accordance with the framework in the Organization for Economic Co-operation and Development Due Diligence Guidelines for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidelines”), and related guidance provided by the SEC, the Company worked with its direct suppliers to identify, where possible, the smelters and/or refiners and countries of origin of the conflict minerals.





Prior to the Reporting Period, the Company worked to identify direct materials suppliers that it believed could potentially provide materials or metals containing conflict minerals (collectively, the “Identified Suppliers”). The Company then surveyed all the Identified Suppliers to determine whether each such Identified Supplier was supplying materials or metals to the Company that contained conflict minerals and, if so, to determine the source of such conflict minerals. The Company’s surveys required Identified Suppliers to, among other matters, confirm the source of any conflict minerals contained in materials or metals supplied to the Company and to provide any updates regarding such responses.

The Company, with respect to the Reporting Period, reasonably determined that certain of its products described above under “Overview” contain conflict minerals necessary to the functionality or production of such products.

For the Reporting Period, the Company sought and obtained representations from all 60 Identified Suppliers from whom the Company sought such representations. Such representations included, from all Identified Suppliers, Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”) indicating the facility at which the conflict minerals were processed.

Based on the information obtained pursuant to the RCOI process described above, the Company has concluded, in good faith, that it does not have sufficient information with respect to the Reporting Period to determine the country of origin of all of the conflict minerals.

Due Diligence

For the Reporting Period, Materion performed due diligence from September 2019 through April 2020 to determine the source and chain of custody necessary to determine conflict minerals in the Company’s product offerings. Materion designed its due diligence measures to conform in all material respects with the OECD Guidelines. This process included building conflict minerals awareness across the supply base and the survey of all Identified Suppliers that were known to or may have provided products containing metal and /or conflict minerals.

Materion occupies a “downstream” position in the supply chain and followed the principles outlined in the OECD Guidelines for downstream companies with no direct relationships to smelters or refiners. In this context, “downstream” refers to the supply chain from smelters and refiners to retailers and includes companies such as ours, as well as product and component manufacturers and retailers. A summary of Materion’s due diligence activities in line with the OECD Guidelines is outlined below.

Step 1: Establish strong company management systems:
    
•
Materion will be publishing an updated formal Responsible Minerals Sourcing Policy Statement forthwith to address conflict minerals as well as to align with the broader responsible sourcing practices in accordance with RMI’s Responsible Minerals Assurance Process (RMAP) Gold Refiner Standard for RMI certification for conformant smelters/refiners;
    
•
Materion maintains a governance model to oversee the implementation and ongoing management of the Conflict Minerals Compliance Program. The governance model consists of two groups: the Steering Committee and the Core Team, and various work products. The objective is to develop, document and maintain a governance structure that enables sustainable compliance and actively mitigates the risk of not meeting regulatory requirements;
    
•
Materion maintains a process to evaluate raw materials, parts and suppliers in the supply chain for potential conflict minerals risk;
    
•
Materion communicates its policy regarding the responsible sourcing of conflict minerals to all existing and new suppliers including through language incorporated in supplier contracts, agreements, flow down language in all United States Government contracts and the Materion Supplier Code of Conduct. Additionally, wording has been added to supplier contracts and written agreements including the right to conduct unannounced spot-




checks;
    
•
Materion continues to leverage SAP systematic and Quality Management procedural controls to prevent transactions with non-conforming conflict mineral suppliers;
    
•
Materion has established long-term relationships with suppliers and closely manages the pool of suppliers eligible to be utilized; and,
    
•
Materion will refer to RMI’s Grievance Mechanism to collect information on grievances for all interested parties to provide information or voice their concerns regarding its sourcing and use of conflict minerals in its products.

Step 2: Identify and assess risks in the supply chain:
    
•
On an annual basis, Materion evaluates raw materials and parts that are known or are likely to contain conflict minerals using a risk-based approach;
    
•
Each compliance year, Materion requires identified suppliers to provide a CMRT. Materion has a 100% response rate for five consecutive years;
    
•
Materion engages Identified Suppliers in one-on-one individualized capability training in order to build their capabilities and to enable them to improve their understanding of the regulation and their responsibility as a Materion supplier;
    
•
Materion conducts a review of supplier responses to determine that all required questions and sections of the CMRT were completed, followed up with any supplier that did not complete all required questions, and verified the CMRT had an acceptable Effective Date and appropriate CMRT version;
    
•
Materion reviews the survey responses and validates them for completeness and sufficiency;
    
•
Materion reviews aggregated supplier survey responses and reports key metrics as part of the monthly conflict minerals reporting process; and,
    
•
Materion conducts an annual review of summary smelter information to determine if the smelter is certified as conformant or presented a "red flag" as defined by the OECD Guidelines. To make the determination of each smelter's conflict status, Materion relies upon information provided by the RMI. RMI conducts a Responsible Minerals Assurance Process (RMAP), in which it certifies smelters and refiners worldwide as being conformant/conflict free after confirming specific information, including country of origin for conflict minerals that the smelter/refiner may purchase for its operations. RMI makes available to the public the list of smelters/refiners that have been certified by RMI as conformant.

Step 3: Design and implement a strategy to respond to identified risks:
    
•
Annually, Materion completes an OECD Gap Analysis, at the end of each compliance year's due diligence, and provides a summary of the identified risks and gaps to the Steering Committee with recommended action plans to reduce risks and close gaps;
    
•
Materion maintains a risk mitigation strategy with the goal of systematically reducing the extend of exposure to certain risk and the likelihood of its occurrence;
    
•
Materion maintains a risk mitigation plan and monitors execution. New supplier onboarding includes requirements for all suppliers to provide a current CMRT and an agreement to respond to annual conflict minerals surveys;




    
•
Materion continues to systematically and procedurally limit purchasing with suppliers based on their unresponsiveness to conflict minerals inquiries;
    
•
Materion places additional restrictions on smelter sources based on non-conflict mineral related customer requirements; and,
    
•
Additional fact finding, risk assessments and changes in circumstances take place as part of Materion's annual review of its Conflict Minerals Compliance Playbook.

Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices:
    
•
In accordance with the OECD Guidelines, Materion participates and contributes through industry organizations to enhance transparency and traceability in the supply chain and supports independent third-party audits of smelters/refiners; and,
    
•
Materion is not in a position to audit smelter/refiners directly. Materion does, however, reach out to smelters identified by their suppliers to request that they participate in the RMI initiative and become certified as Conformant. In addition, Materion’s gold recycling operation in Buffalo, New York is in the process of completing the Responsible Minerals Assurance Process (RMAP), including having submitted relevant documentation, completed an on-site assessment and addressing findings with expectation of imminent recertification as a RMI conformant smelter/refiner.

Step 5: Report annually on supply chain due diligence:
    
•
Annually, Materion performs due diligence in their conflict minerals supply chain, maintains a process to summarize, review and approve compliance results, complete the Form SD and the Conflict Minerals Report and timely file the Form SD and any Conflict Minerals Report with the SEC.


Continuous Improvement of Supply Chain Due Diligence

The Company expects to continue to maintain its supply chain due diligence efforts including:
    
•
Utilize the RMI Grievance Mechanism for stakeholders to provide information or voice their concerns regarding Materion’s minerals sourcing or due diligence activities;

•
Implement a strategy to support and build supplier capabilities and design improvement plans with suppliers to enhance the Company’s risk mitigation plan;

•
Continue to assess the presence of conflict minerals in its supply chain as part of the its New Product Introduction (NPI) process;
    
•
Continue to require suppliers to identify the conflict minerals contained in the products they supply and when requested on an annual basis, to provide current, accurate and complete information on the smelters/refiners used in the manufacture of materials supplied to Materion;
    
•
Continue to compare RCOI results to information collected via independent conflict free smelter validation programs such as the RMAP;
    
•
Continue to partner with suppliers who are committed to participation in obtaining a "conformant" designation from an industry program such as the RMAP; and,

•
Continue to respond to customer requests to limit smelters active in the supply chain due to non RMI




concerns.

Determination

Based on the process described above, Materion achieved a 100% response rate from the 60 direct material suppliers identified as supplying raw materials or parts containing conflict minerals with 100% of identified smelters reported as conformant for the second year in a row.

Based on the information provided by Materion suppliers utilized during 2019, Materion believes that the facilities that may have been used to process conflict minerals in Materion’s products included the smelters and refiners lists in Appendix I. The suppliers’ responses included exclusively Conformant/Conflict Free smelters.

Based on the due diligence efforts and the absence of full supply chain visibility throughout the supply base, Materion is unable to determine the origin of the conflict minerals and does not have sufficient information to conclusively determine the countries of origin of conflict minerals contained in Materion’s products.












Appendix I: Smelters Identified in the Materion Supply Chain

Metal
Smelter Reference List
Smelter Country
Smelter Identification
RMI STATUS
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
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
Asahi Refining Canada Ltd.
CANADA
CID000924
Conformant
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
CID000920
Conformant
Gold
Aurubis AG
GERMANY
CID000113
Conformant
Gold
Boliden AB
SWEDEN
CID000157
Conformant
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Conformant
Gold
CCR Refinery
CANADA
CID000185
Conformant
Gold
Chimet S.p.A.
ITALY
CID000233
Conformant
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Conformant
Gold
Dowa
JAPAN
CID000401
Conformant
Gold
Geib Refining Corporation
UNITED STATES
CID002459
Conformant
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Conformant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Conformant
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Conformant
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
CID000969
Conformant
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
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 (Hong Kong) Ltd.
CHINA
CID001149
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




Metal
Smelter Reference List
Smelter Country
Smelter Identification
RMI STATUS
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Conformant
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Conformant
Gold
PAMP S.A.
SWITZERLAND
CID001352
Conformant
Gold
Royal Canadian Mint
CANADA
CID001534
Conformant
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Conformant
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Conformant
Gold
Yunan Gejiu Yunxin Electrolyze Limited
CHINA
CID001908
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Conformant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Conformant
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
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
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
CID002030
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Conformant
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
CID002504
Conformant
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
CID000456
Conformant
Tantalum
F & X
CHINA
CID000460
Conformant
Tantalum
Global Advanced Materials Boyertown
UNITED STATES OF AMERICA
CID002557
Conformant
Tantalum
Global Advanced Materials Aizu
JAPAN
CID002558
Conformant
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000291
Conformant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
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
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Conformant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Conformant




Metal
Smelter Reference List
Smelter Country
Smelter Identification
RMI STATUS
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
CID001522
Conformant
Tin
Alpha
UNITED STATES OF AMERICA
CID000292
Conformant
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID003190
Conformant
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Conformant
Tin
CV Ayi Jaya
INDONESIA
CID002570
Conformant
Tin
CV Dua Sekawan
INDONESIA
CID002592
Conformant
Tin
CV Gita Pesona
INDONESIA
CID000306
Conformant
Tin
CV United Smelting
INDONESIA
CID000315
Conformant
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Conformant
Tin
Dowa
JAPAN
CID000402
Conformant
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
CID000438
Conformant
Tin
Fenix Metals
POLAND
CID000468
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Conformant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Conformant
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
CID003116
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Conformant
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
CID003379
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Conformant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Conformant
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Conformant
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
CID001142
Conformant
Tin
Metallo Belgium N.V.
BELGIUM
CID002773
Conformant
Tin
Metallo Spain S.L.U.
SPAIN
CID002774
Conformant
Tin
Mineracao Taboca S.A.
BRAZIL
CID001173
Conformant




Metal
Smelter Reference List
Smelter Country
Smelter Identification
RMI STATUS
Tin
Minsur
PERU
CID001182
Conformant
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Conformant
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Conformant
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
CID001337
Conformant
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Conformant
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Conformant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Conformant
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Conformant
Tin
PT Babel Surya Alam Lestari
INDONESIA
CID001406
Conformant
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Conformant
Tin
PT Bangka Serumpun
INDONESIA
CID003205
Conformant
Tin
PT Bangka Tin Industry
INDONESIA
CID001419
Conformant
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Conformant
Tin
PT Bukit Timah
INDONESIA
CID001428
Conformant
Tin
PT DS Jaya Abadi
INDONESIA
CID001434
Conformant
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Conformant
Tin
PT Karimun Mining
INDONESIA
CID001448
Conformant
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829
Conformant
Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Conformant
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Conformant
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Conformant
Tin
PT Premium Tin Indonesia
INDONESIA
CID000313
Conformant
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Conformant
Tin
PT Rajawali Rimba Perkasa
INDONESIA
CID003381
Conformant
Tin
PT Rajehan Ariq
INDONESIA
CID002593
Conformant
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Conformant
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Conformant
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Conformant
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816
Conformant
Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
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
PT Tirus Putra Mandiri
INDONESIA
CID002478
Conformant
Tin
PT Tommy Utama
INDONESIA
CID001493
Conformant
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Conformant
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
CID001539
Conformant
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002870
Conformant




Metal
Smelter Reference List
Smelter Country
Smelter Identification
RMI STATUS
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Conformant
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
CID002834
Conformant
Tin
Thaisarco
THAILAND
CID001898
Conformant
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
CID003325
Conformant
Tin
White Solder Metalurgica
BRAZIL
CID002036
Conformant
Tin
Yunan Gejiu Yunxin Electrolyze Limited
CHINA
CID001908
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Conformant
Tin
Yunnan Tin Company, Ltd.
CHINA
CID002180
Conformant
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
CID003397
Conformant
Tungsten
A.L.M.T. Corp.
JAPAN
CID000004
Conformant
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Conformant
Tungsten
ATI Metalworking Products
UNITED STATES OF AMERICA
CID000105
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002645
Conformant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Conformant
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
CID000568
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Conformant
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002542
Conformant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID002541
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Conformant
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID003182
Conformant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Conformant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Conformant
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Conformant




Metal
Smelter Reference List
Smelter Country
Smelter Identification
RMI STATUS
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Conformant
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
CID000966
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Conformant
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
CID002543
Conformant
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
CID002845
Conformant
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
CID002589
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Conformant
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Conformant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Conformant
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
CID002044
Conformant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Conformant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095
Conformant