0001104657-22-000093.txt : 20220531 0001104657-22-000093.hdr.sgml : 20220531 20220531093906 ACCESSION NUMBER: 0001104657-22-000093 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20211231 1.02 20211231 FILED AS OF DATE: 20220531 DATE AS OF CHANGE: 20220531 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: 22980952 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 sd12-31x21.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)
Ohio001-1588534-1919973
(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:
ýRule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.






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, 2021 to December 31, 2021 (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 3 of Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.

Section 3. Exhibits

Item 3.01 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 31, 2022
Vice President, General Counsel and Secretary


EX-1.01 2 materion2021conflictminera.htm EX-1.01 Document

Exhibit 1.01

Conflict Minerals Report of Materion Corporation
for the Reporting Period from January 1, 2021 to December 31, 2021

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 “Rules”) as promulgated under the Securities Exchange Act of 1934 for the reporting period from January 1, 2021 to December 31, 2021 (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, 2021 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 semiconductor, consumer electronics, industrial components, defense, automotive electronics, telecommunications infrastructure, energy, and commercial aerospace.




Our businesses are organized under four reportable segments: Performance Materials, Electronic Materials, Precision Optics, and Other. Our Other reportable segment includes unallocated corporate costs.

Performance Materials

Performance Materials 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.

Electronic Materials

Electronic 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. Electronic Materials also has metal recovery operations and in-house refining that allow for the recycling of precious metals.

The Company completed the acquisition of HCS Electronic Materials on November 1, 2021. As permitted by SEC guidance, the scope of our evaluation of internal control over financial reporting and over the RMI conformant status as of December 31, 2021 did not include HCS Electronic Materials.

Precision Optics

Precision Optics provides custom made, precision optical filter products spanning a broad range of the electromagnetic spectrum (from UV to LWIR) and offers assembly capabilities at manufacturing facilities located in the United States, Europe, and Asia.

Precision Optics possesses broad and in-depth knowhow in optical thin-film coating processes, complemented by sophisticated patterning, glass bonding and sealing, and further processing capabilities necessary for producing optical thin film coated components up to optical subassemblies. Highly experienced and skilled development and engineering teams collaborate closely with customers to develop innovative solutions meeting their specific requirements. The combination of these capabilities and skills places Precision Optics at the forefront of markets in the photonics industry such as semiconductor, industrial, aerospace and defense, consumer electronics, and automotive.

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, 2021 and December 31, 2021 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: Third 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 and during the Reporting Period, the Company worked to identify current and new direct materials suppliers that it believed provided 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 68 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 2021 through March 2022 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 and the Responsible Business Alliance’s Responsible Minerals Assurance Process ("RMAP"). 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 has published an updated formal Responsible Minerals Sourcing Policy to address conflict minerals sourcing in the Covered Countries expanding the scope to include conflict-affected and high-risk areas ("CAHRAs") in accordance with UN resolutions with a pledge to purchase materials only from sources that are not involved in or contributing to illegal armed groups, human rights violators, or financial wrongdoings;
    
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 regulatory non-compliance;
    
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 and other enterprise risk management ("ERP") systems 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 continue to 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 seven 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 requires all Suppliers provide their CMRT aggregating all the smelters/refiners in their Supply Chain including the mineral name and address of the smelter or refiner and CID number;

Materion conducts a review of supplier responses to determine that all required questions and sections of the CMRT were completed, follows up with any supplier that did not complete all required questions, and verifies 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 or Active (in the process of a RMAP assessment and previously Conformant) 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 or Active. Additionally, Materion is in the process of joining RMI in order to obtain additional information such as country of origin and risk management assessment tools not available to non-members.

Step 3: Design and implement a strategy to respond to identified risks:
    
Annually, Materion completes the RMAP Downstream Assessment, the RMI and OECD Due Diligence Guidance Expectations for Downstream companies, at the conclusion of its due diligence and provides a



summary of the identified risks and gaps to senior management with recommended action plans to reduce risks and close gaps;
    
Materion maintains a risk mitigation strategy with the goal of systematically reducing 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 or use of non-Conformant Smelters and Refiners;
    
Materion places additional restrictions on smelter sources based on non-conflict mineral related customer requirements; and
    
Materion reports new identified risk to The Steering Committee and in coordination with the Core Team implements strategies to mitigate current risks and prevent reoccurring risks; 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, including membership in RMI, to enhance transparency and traceability in the supply chain and supports independent third-party audits of smelters/refiners including recommendations for improvements in smelter due diligence practices, building capacity, mitigating risk and improving due diligence performance; and
    
Materion is not in a position to audit smelter/refiners directly but as a member of RMI is contributing to on-going smelter audits. Additionally, Materion reaches out to smelters identified by their suppliers to request that they participate in the RMI RMAP initiative and become certified as Conformant. Furthermore, Materion’s gold recycling operation in Buffalo, New York is in the process of its annual RMAP review to maintain its RMI Conformant Gold Refiner status, including having completed an annual on-site assessment and is addressing relevant findings.

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; and

Annually upon request, Materion provides downstream partners a Company or Product level CMRT including smelters used in the production of parts and materials purchased from Materion.


Continuous Improvement of Supply Chain Due Diligence

The Company expects to continue to maintain its supply chain due diligence efforts including:

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 the 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 manufacturing 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 source responsibility and limit smelters active in the supply chain in CAHRAs, for minerals other than 3TG or due to non-conflict minerals sourcing concerns such as embargos or sanctioned countries.

Determination

Based on the process described above, Materion achieved a 100% response rate from the 68 direct material suppliers identified as supplying raw materials or parts containing conflict minerals and 100% of the 207 identified smelters or refiners were Conformant or Active.

Based on the information provided by Materion suppliers utilized during 2021, 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 include Conformant and Active smelters, where Active smelters are in the process of recertification of their conformant status.

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 ID
Smelter Reference List
Smelter Country
RMI
Gold
CID002763
8853 S.p.A.
ITALY
Conformant
Gold
CID000015
Advanced Chemical Company
UNITED STATES OF AMERICA
Conformant
Gold
CID000019
Aida Chemical Industries Co., Ltd.
JAPAN
Conformant
Gold
CID002560
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Conformant
Gold
CID000035
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Conformant
Gold
CID000041
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Conformant
Gold
CID000058
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Conformant
Gold
CID000077
Argor-Heraeus S.A.
SWITZERLAND
Conformant
Gold
CID000082
Asahi Pretec Corp.
JAPAN
Conformant
Gold
CID000924
Asahi Refining Canada Ltd.
CANADA
Conformant
Gold
CID000920
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Conformant
Gold
CID000090
Asaka Riken Co., Ltd.
JAPAN
Conformant
Gold
CID000113
Aurubis AG
GERMANY
Conformant
Gold
CID002863
Bangalore Refinery
INDIA
Conformant
Gold
CID000128
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Conformant
Gold
CID000157
Boliden AB
SWEDEN
Conformant
Gold
CID000176
C. Hafner GmbH + Co. KG
GERMANY
Conformant
Gold
CID000185
CCR Refinery - Glencore Canada Corporation
CANADA
Conformant
Gold
CID000189
Cendres + Metaux S.A.
SWITZERLAND
Conformant
Gold
CID000233
Chimet S.p.A.
ITALY
Conformant
Gold
CID000264
Chugai Mining
JAPAN
Conformant
Gold
CID000362
Doduco
GERMANY
Conformant
Gold
CID000362
DODUCO Contacts and Refining GmbH
GERMANY
Conformant
Gold
CID000401
Dowa
JAPAN
Conformant
Gold
CID000359
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Conformant
Gold
CID000425
Eco-System Recycling Co., Ltd. East Plant
JAPAN
Conformant
Gold
CID002561
Emirates Gold DMCC
UNITED ARAB EMIRATES
Conformant
Gold
CID002459
Geib Refining Corporation
UNITED STATES OF AMERICA
Conformant
Gold
CID002243
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Conformant
Gold
CID000694
Heimerle + Meule GmbH
GERMANY
Conformant
Gold
CID000707
Heraeus Metals Hong Kong Ltd.
CHINA
Conformant
Gold
CID000711
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Conformant
Gold
CID000801
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Conformant
Gold
CID000807
Ishifuku Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
CID000814
Istanbul Gold Refinery
TURKEY
Conformant
Gold
CID002765
Italpreziosi
ITALY
Conformant



Gold
CID000823
Japan Mint
JAPAN
Conformant
Gold
CID000855
Jiangxi Copper Co., Ltd.
CHINA
Conformant
Gold
CID000920
Johnson Matthey Inc. (USA)
UNITED STATES OF AMERICA
Conformant
Gold
CID000493
JSC Novosibirsk Refinery
RUSSIAN FEDERATION
Conformant
Gold
CID000929
JSC Uralelectromed
RUSSIAN FEDERATION
Conformant
Gold
CID000937
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Conformant
Gold
CID000957
Kazzinc
KAZAKHSTAN
Conformant
Gold
CID000969
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Conformant
Gold
CID002511
KGHM Polska Miedz Spolka Akcyjna
POLAND
Conformant
Gold
CID000981
Kojima Chemicals Co., Ltd.
JAPAN
Conformant
Gold
CID002605
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
CID002762
L'Orfebre S.A.
ANDORRA
Conformant
Gold
CID001078
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Conformant
Gold
CID000689
LT Metal Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
CID002606
Marsam Metals
BRAZIL
Conformant
Gold
CID001113
Materion
UNITED STATES OF AMERICA
Conformant
Gold
CID001119
Matsuda Sangyo Co., Ltd.
JAPAN
Conformant
Gold
CID001149
Metalor Technologies (Hong Kong) Ltd.
CHINA
Conformant
Gold
CID001152
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Conformant
Gold
CID001147
Metalor Technologies (Suzhou) Ltd.
CHINA
Conformant
Gold
CID001153
Metalor Technologies S.A.
SWITZERLAND
Conformant
Gold
CID001157
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Conformant
Gold
CID001161
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Conformant
Gold
CID001188
Mitsubishi Materials Corporation
JAPAN
Conformant
Gold
CID001193
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
Gold
CID002509
MMTC-PAMP India Pvt., Ltd.
INDIA
Conformant
Gold
CID001204
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Conformant
Gold
CID001220
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Conformant
Gold
CID001259
Nihon Material Co., Ltd.
JAPAN
Conformant
Gold
CID002779
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Conformant
Gold
CID001325
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
CID001326
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Conformant
Gold
CID001352
PAMP S.A.
SWITZERLAND
Conformant
Gold
CID002919
Planta Recuperadora de Metales SpA
CHILE
Conformant
Gold
CID001386
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Conformant
Gold
CID001397
PT Aneka Tambang (Persero) Tbk
INDONESIA
Conformant
Gold
CID001498
PX Precinox S.A.
SWITZERLAND
Conformant
Gold
CID001512
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Conformant
Gold
CID002582
REMONDIS PMR B.V.
NETHERLANDS
Conformant



Gold
CID001534
Royal Canadian Mint
CANADA
Conformant
Gold
CID002761
SAAMP
FRANCE
Conformant
Gold
CID002973
Safimet S.p.A
ITALY
Conformant
Gold
CID001555
Samduck Precious Metals
KOREA, REPUBLIC OF
Conformant
Gold
CID002777
SAXONIA Edelmetalle GmbH
GERMANY
Conformant
Gold
CID001585
SEMPSA Joyeria Plateria S.A.
SPAIN
Conformant
Gold
CID001916
Shandong Gold Smelting Co., Ltd.
CHINA
Conformant
Gold
CID001622
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Conformant
Gold
CID001736
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Conformant
Gold
CID002516
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Conformant
Gold
CID001756
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Conformant
Gold
CID001761
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Conformant
Gold
CID001798
Sumitomo Metal Mining Co., Ltd.
JAPAN
Conformant
Gold
CID002918
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
CID002580
T.C.A S.p.A
ITALY
Conformant
Gold
CID001875
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Conformant
Gold
CID001938
Tokuriki Honten Co., Ltd.
JAPAN
Conformant
Gold
CID001955
Torecom
KOREA, REPUBLIC OF
Conformant
Gold
CID002314
Umicore Precious Metals Thailand
THAILAND
Conformant
Gold
CID001980
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Conformant
Gold
CID001993
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Conformant
Gold
CID002003
Valcambi S.A.
SWITZERLAND
Conformant
Gold
CID002030
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Conformant
Gold
CID002778
WIELAND Edelmetalle GmbH
GERMANY
Conformant
Gold
CID002100
Yamakin Co., Ltd.
JAPAN
Conformant
Gold
CID002129
Yokohama Metal Co., Ltd.
JAPAN
Conformant
Tantalum
CID000211
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Conformant
Tantalum
CID002504
D Block Metals, LLC
UNITED STATES OF AMERICA
Conformant
Tantalum
CID000456
Exotech Inc.
UNITED STATES OF AMERICA
Conformant
Tantalum
CID000460
F&X Electro-Materials Ltd.
CHINA
Conformant
Tantalum
CID002558
Global Advanced Metals Aizu
JAPAN
Conformant
Tantalum
CID002557
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Conformant
Tantalum
CID000616
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Conformant
Tantalum
CID002547
H.C. Starck Hermsdorf GmbH
GERMANY
Conformant
Tantalum
CID002548
H.C. Starck Inc.
UNITED STATES OF AMERICA
Conformant
Tantalum
CID002492
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Conformant
Tantalum
CID002842
Jiangxi Tuohong New Raw Material
CHINA
Conformant
Tantalum
CID000914
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tantalum
CID000917
Jiujiang Tanbre Co., Ltd.
CHINA
Conformant



Tantalum
CID002506
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
CID002539
KEMET de Mexico
MEXICO
Conformant
Tantalum
CID001163
Metallurgical Products India Pvt., Ltd.
INDIA
Conformant
Tantalum
CID001277
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Conformant
Tantalum
CID001200
NPM Silmet AS
ESTONIA
Conformant
Tantalum
CID002544
TANIOBIS Co., Ltd.
THAILAND
Conformant
Tantalum
CID002545
TANIOBIS GmbH
GERMANY
Conformant
Tantalum
CID002549
TANIOBIS Japan Co., Ltd.
JAPAN
Conformant
Tantalum
CID002550
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Conformant
Tantalum
CID001891
Telex Metals
UNITED STATES OF AMERICA
Conformant
Tantalum
CID001969
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Conformant
Tantalum
CID000616
XIMEI RESOURCES (GUANGDONG) LIMITED
CHINA
Conformant
Tantalum
CID002508
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Conformant
Tantalum
CID001522
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tin
CID000292
Alpha
UNITED STATES OF AMERICA
Conformant
Tin
CID000228
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Conformant
Tin
CID003190
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Conformant
Tin
CID001070
China Tin Group Co., Ltd.
CHINA
Conformant
Tin
CID002455
CV Venus Inti Perkasa
INDONESIA
Active
Tin
CID000402
Dowa
JAPAN
Conformant
Tin
CID000438
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
Tin
CID000448
Estanho de Rondonia S.A.
Brazil
Active
Tin
CID000468
Fenix Metals
POLAND
Conformant
Tin
CID000538
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Conformant
Tin
CID001908
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Conformant
Tin
CID000555
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Conformant
Tin
CID003116
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Conformant
Tin
CID002844
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Conformant
Tin
CID001482
INDONESIAN STATE TIN CORPORATION MENTOK SMELTER
INDONESIA
Conformant
Tin
CID001231
Jiangxi New Nanshan Technology Ltd.
CHINA
Conformant
Tin
CID003387
Luna Smelter, Ltd.
RWANDA
Conformant
Tin
CID003379
Ma'anshan Weitai Tin Co., Ltd.
CHINA
Conformant
Tin
CID002468
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Conformant
Tin
CID001105
Malaysia Smelting Corporation (MSC)
MALAYSIA
Conformant
Tin
CID002500
Melt Metais e Ligas S.A.
BRAZIL
Conformant
Tin
CID001142
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Conformant
Tin
CID002773
Metallo Belgium N.V.
BELGIUM
Conformant
Tin
CID002774
Metallo Spain S.L.U.
SPAIN
Conformant
Tin
CID001173
Mineração Taboca S.A.
BRAZIL
Conformant



Tin
CID001182
Minsur
PERU
Conformant
Tin
CID001191
Mitsubishi Materials Corporation
JAPAN
Conformant
Tin
CID001314
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Conformant
Tin
CID002517
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Conformant
Tin
CID001337
Operaciones Metalúrgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
Tin
CID000309
PT Aries Kencana Sejahtera
INDONESIA
Active
Tin
CID001399
PT Artha Cipta Langgeng
INDONESIA
Conformant
Tin
CID002503
PT ATD Makmur Mandiri Jaya
INDONESIA
Conformant
Tin
CID001406
PT Babel Surya Alam Lestari
INDONESIA
Conformant
Tin
CID003205
PT Bangka Serumpun
INDONESIA
Conformant
Tin
CID002835
PT Menara Cipta Mulia
INDONESIA
Conformant
Tin
CID001453
PT Mitra Stania Prima
INDONESIA
Conformant
Tin
CID003449
PT Mitra Sukses Globalindo
INDONESIA
Active
Tin
CID001458
PT Prima Timah Utama
INDONESIA
Conformant
Tin
CID003381
PT Rajawali Rimba Perkasa
INDONESIA
Conformant
Tin
CID001460
PT Refined Bangka Tin
INDONESIA
Conformant
Tin
CID001468
PT Stanindo Inti Perkasa
INDONESIA
Conformant
Tin
CID001477
PT Timah (Persero) Tbk Kundur
INDONESIA
Conformant
Tin
CID001486
PT Timah Nusantara
INDONESIA
Active
Tin
CID001490
PT Tinindo Inter Nusa
INDONESIA
Conformant
Tin
CID002706
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
Tin
CID001539
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Conformant
Tin
CID001758
Soft Metais Ltda.
BRAZIL
Conformant
Tin
CID002834
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
Conformant
Tin
CID001898
Thailand Smelting & Refining Co Ltd
THAILAND
Conformant
Tin
CID003325
Tin Technology & Refining
UNITED STATES OF AMERICA
Conformant
Tin
CID002036
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Conformant
Tin
CID002158
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Conformant
Tin
CID002180
Yunnan Tin Company Limited
CHINA
Active
Tungsten
CID000004
A.L.M.T. Corp.
JAPAN
Conformant
Tungsten
CID002513
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
CID000258
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
CID002645
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
CID000875
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
CID002315
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Conformant
Tungsten
CID002494
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Conformant
Tungsten
CID000568
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Conformant
Tungsten
CID000218
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
CID002541
H.C. Starck Tungsten GmbH
GERMANY
Conformant



Tungsten
CID000769
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tungsten
CID002649
Hydrometallurg, JSC
RUSSIAN FEDERATION
Conformant
Tungsten
CID002551
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
CID002321
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
CID002316
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
CID000966
Kennametal Fallon
UNITED STATES OF AMERICA
Conformant
Tungsten
CID000105
Kennametal Huntsville
UNITED STATES OF AMERICA
Conformant
Tungsten
CID002543
Masan Tungsten Chemical LLC (MTC)
VIET NAM
Conformant
Tungsten
CID002589
Niagara Refining LLC
UNITED STATES OF AMERICA
Conformant
Tungsten
CID002827
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Conformant
Tungsten
CID002542
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Conformant
Tungsten
CID002044
Wolfram Bergbau und Hutten AG
AUSTRIA
Conformant
Tungsten
CID002320
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Conformant
Tungsten
CID002082
Xiamen Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
CID002830
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Conformant