EX-1.01 2 exhibit1012014conflictmine.htm EXHIBIT 1.01 2014 CONFLICT MINERALS REPORT Exhibit 1.01 2014 Conflict Minerals


Exhibit 1.01


Nortek, Inc.
Conflict Minerals Report
For the Reporting Period Ended December 31, 2014

This Conflict Minerals Report for the calendar-year reporting period beginning January 1, 2014 and ending December 31, 2014 (the “reporting period”, has been prepared and filed with the Securities and Exchange Commission (“SEC” or “Commission”) under cover of Form SD by Nortek, Inc. (together with all consolidated subsidiaries, “Nortek,” “Company,” “we” or “us”) to comply with Section 13(p) of the Securities Exchange Act of 1934 (“Exchange Act Section 13(p)”) and associated SEC Rule 13p-1 (17 CFR 240.13p-1) and Form SD (17 CFR 249b.400) (together, the “Rule”). The term “conflict minerals” is defined by Section 13(p) and the Rule to mean tin, tantalum, tungsten and gold, commonly referred to as the “3TG,” without regard to their country or countries of origin.

As certain of the Company’s businesses manufactured, or contracted to manufacture, products during the reporting period that contain conflict minerals that are necessary to the functionality or production of these products (“necessary conflict minerals”), we have prepared this particular Conflict Minerals Report (“CMR”). After conducting our good-faith, reasonable country of origin inquiry (“RCOI”) for the reporting period, we know or have reason to believe that some of our necessary conflict minerals originated or may have originated in the Democratic Republic of the Congo or an adjoining country (together, “Covered Countries”), and know or have reason to believe that such necessary conflict minerals may not be derived solely from recycled or scrap sources. Accordingly, we performed due diligence pursuant to a process designed to conform to the framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High- Risk Areas: Second Edition: 2013, including the supplements thereto for gold, tin, tantalum and tungsten (together, “OECD Due Diligence Guidance”).
     
Company Overview and Description of Nortek Products Covered by this CMR

We are a global, diversified company whose many market-leading brands deliver broad capabilities and a wide array of innovative, technology-driven products and solutions for lifestyle improvement at home and at work. A description of our reporting segments and their products is set forth below.

the Air Quality & Home Solutions ("AQH") segment primarily manufactures and distributes room and whole house ventilation products for the professional remodeling and replacement markets, residential new construction market, and do-it-yourself market. The principal products of the segment are kitchen range hoods, exhaust fans (such as bath fans and fan, heater and light combination units), and indoor air quality products (such as air exchangers and heat or energy recovery ventilators).
the Security & Control Solutions ("SCS”) segment manufactures and distributes a broad array of products designed to provide convenience and security primarily for residential applications. The principal product categories in this segment include security, automation and access control equipment and systems.
the Ergonomic & Productivity Solutions ("ERG") segment manufactures and distributes a broad array of innovative products designed with ergonomic features including wall mounts, carts, arms, desk mounts, workstations, and stands that attach to or support a variety of display devices such as notebook computers, computer monitors, and flat panel displays.
the Residential & Commercial HVAC ("RCH") segment principally manufactures and sells split-system and packaged air conditioners and heat pumps, furnaces, air handlers and parts for the residential replacement and new construction markets. In addition, this segment produces unit heaters, radiant heaters and rooftop HVAC products primarily for industrial and commercial applications.
the Custom & Commercial Air Solutions ("CAS") segment manufactures and sells custom-designed and engineered HVAC products and systems, primarily in North America, for non-residential applications that include healthcare and educational facilities, commercial buildings, manufacturing facilities, clean rooms, data centers,

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and government buildings. The principal products sold by this segment are air handlers and large custom rooftop cooling and heating products.
the Audio, Video & Control Solutions (“AVC”) segments manufacture and distribute a broad array of products primarily for the residential audio/video and professional video signal management markets. The principal product categories in these segments include residential audio/video equipment (including architectural speakers and power conditioners, among other products), home control equipment, and professional video signal management solutions.

Through these segments, we manufacture and sell primarily in the United States, Canada, and Europe, with additional manufacturing in China and Mexico a wide variety of products principally for the remodeling and replacement markets, the residential and commercial new construction markets, and the personal and enterprise computer markets. Some of these products contain necessary conflict minerals (“Covered Products”), as discussed further below.

The manufacture of products during any specified time period likely includes raw materials sourced before, as well as during, the reporting period. In particular, some 3TGs used during the current reporting period may have been smelted, refined and/or manufactured by a supplier (pursuant to a contract with us to manufacture) prior to January 1, 2014. However, the RCOI and supply chain due diligence we conducted for this reporting cycle did not exclude such materials. Accordingly, our due diligence and this CMR may include products containing necessary conflict minerals whose manufacture (and/or smelting/refining in the case of unprocessed materials) may have occurred prior to January 1, 2014 (the beginning of the reporting period) even though the Rule requires only that we report on such products whose manufacture was completed in 2014.

Nortek’s Supply Chain

We are dependent upon raw materials and components, and in some cases finished products, purchased from other manufacturers or suppliers. These materials and components include, among others, steel, electronics, motors, plastics, compressors, printed circuit boards, electrical components, microprocessors, batteries, and paint, as well as standard nuts, bolts and fasteners, all of which we purchase from third parties and some of which may contain one or more 3TGs. As a result, we have a large supply base, with many suppliers unique to each of our individual business segment’s requirements. Due to the complex nature of our business, our segments may manufacture in-house or contract with third parties to manufacture specific components that we then incorporate into our end products. Because of our size, the complexity of our products, and the depth and breadth of our supply chain, it has been difficult to identify the smelters/refiners and other potential sourcing beyond our immediate, direct suppliers. As a downstream purchaser of conflict minerals and/or components containing such conflict minerals, we are many steps removed from the smelters or refiners (“SOR”) that originally processed the ores or other materials containing the 3TGs ultimately included in our final products.


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1.    Due Diligence (DD) Process

1.1    Design of Due Diligence

We have designed our due diligence framework -- which we refer to in this Report as our CM Program framework -- to conform to the criteria set forth in the “OECD Due Diligence Guidance”, as applicable to downstream companies.

Summarized below are the design components of our conflicts mineral program as it relates to the five-step framework reflected in the OECD Due Diligence Guidance:

Establish strong company management systems:

Our Conflict Mineral Policy (“CM Policy”), which is publicly available on our website at www.nortek.com under “Corporate Governance” on the “Investors” portion of our website.
Operate an internal Conflict Minerals Steering Committee consisting of executive-level representatives who report directly to the Chief Executive Officer (“Steering Committee”), as well as a select group of Nortek employees which includes representatives from procurement, risk management, legal, and finance. This team is tasked to ensure that there is a clear understanding on the part of all responsible personnel with respect to the background and policy underpinnings of the Rule, provide the group with an understanding of the requirements of the Rule, and set the foundation to enable us to manage the complexities of compliance with the Rule on an ongoing basis.
Use the Conflict Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (“CMRT”), which was developed under the OECD Due Diligence Guidance, to request from selected suppliers relevant source information (i.e., 3TG content, country of origin, and SOR facilities) regarding products (including components) or materials purchased by Nortek that may contain necessary conflict minerals.
Incorporate requirements related to conflict minerals in our standard supplier agreement to ensure that our suppliers (and sub-tier suppliers) comply with our conflict mineral requirements and participate in the annual survey process.
Maintain records pertaining to the conflict minerals program to support audit compliance for a minimum of a five year period.
Provide suppliers access to the established grievance mechanism at: ethics@nortek.com or our hotline at 888-475-6620. Our employees may report concerns directly to nortek.silentwhistle.com.

Identify & Assess Risk in the Supply Chain

Conduct a supply chain survey of those suppliers identified in the 2014 Supplier Population (as this term is defined in Section 1.2, below) using the CMRT.
Follow up with direct suppliers that did not respond to the survey request to obtain sourcing and smelter information for Nortek’s products, as part of our risk management plan.
Compare SORs identified in supplier responses against the list of facilities that are participating in the Conflict Free Smelter Program (“CFSP”), and check whether other SORs that do not appear on this list are identified by other reputable sources such as the U.S. Department of Commerce.


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Design & Implement a Strategy to Respond to Risks

Implement the risk mitigation process defined in our CM Program framework to identify and follow up with direct suppliers that are not meeting the CM Policy, as discussed further below in Section 1.2 of this CMR.
Provide metrics to the Steering Committee summarizing our program’s progress and risk mitigation efforts on a quarterly basis.
Negotiate supply agreements with our suppliers to ensure alignment with our CM Policy. In addition, contracts up for renewal or amendment were modified to include the requirements relating to the conflict minerals program.

Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices

Rely on the publicly-available results of the CFSP third-party audits to validate the responsible sourcing practices of processing facilities in our supply chain.

Report on Supply Chain Due Diligence

Post our CM Policy on our company website at www.nortek.com under “Corporate Governance” on the “Investors” portion of our website
Publicly report on our due diligence efforts in the annual SEC filing of our Form SD and CMR. Post the Form SD and Conflict Minerals Report on our website.

1.2 Due Diligence Measures Performed and Results

Request Information from a Representative Sample of Direct Suppliers in 2014

During this second year of compliance with the Rule, we continued to target the “highest-risk” areas of our supply chain which we could reasonably expect to include conflict minerals. The following measures were performed during the reporting period to satisfy both our RCOI and due diligence obligations relating to the source and chain of custody of the necessary conflict minerals contained in our products, in an effort to determine whether they may have originated from the Covered Countries and did not come from recycled or scrap sources:

Surveyed 111 direct suppliers within the “highest risk” areas of our supply chain, as noted above, which we defined as Nortek’s “2014 Supplier Population” for survey purposes. Fifty- six of the direct suppliers represented approximately 49% of spend across the organization. We also covered based on three specific customers’ requests, all the in-scope suppliers who provided parts, components or products with necessary conflict minerals for the following product lines: Ceiling Grid Systems, Air Handlers, Fan Filter Units, Blank Cans, and Face Screens; Notebook Display Stands and Charging Carts; Monitor Stands, All-in-One Stands and Mobile Computing Carts, which resulted in an additional fifty-five suppliers being surveyed.
Used an Excel macro tool developed by a third-party vendor to review the responses against red flag criteria established within the macro, in order to identify areas of heightened risk of noncompliance. These criteria included incomplete responses as well as inconsistencies within the data reported in the Template.
Followed up with the direct suppliers who either did not respond to our survey request or, based upon the results identified in the macro tool, provided incomplete or potentially inaccurate information to seek additional clarifying information.
Compared smelters and refiners identified in the supplier survey responses against the list of facilities that have received a “Compliant” or “Active” designation from the CFSP or other independent third-party audit program.
Implemented a risk mitigation response plan to monitor and track suppliers that actually or potentially did not meet the requirements set forth in our CM Policy or contractual requirements.

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2.     Supply Chain Survey Responses

We received some level of response from approximately 75% of the Supplier Population surveyed for calendar year 2014, which represents a decrease of two percentage points from the prior year’s response rate of approximately 77%. This drop may be partially due to the fact that we surveyed smaller suppliers and/or suppliers outside the United States who are not subject to the Rule and its obligations. There were 21 suppliers who did not respond, even after multiple email reminders from us that their survey response was required. There were 12 suppliers who did respond but provided either incomplete information or their response contained one or more red flags. We followed up with a majority of these suppliers if we believed that they may have provided a specific response in error, requesting that they provide revised responses. If the supplier had additional information or was able to correct discrepancies, it provided updated information. As this is only the second year of compliance with the Rule, many of our suppliers, who are not themselves subject to the “Rule”, have indicated via their CMRT declaration that they are still in process of establishing their own due diligence procedures and gathering SOR and other information. In fact, several suppliers have indicated they are less than 25% complete in their surveying of their own suppliers, which may suggest that many of Nortek’s upstream suppliers are facing the same challenges as Nortek. The results information presented below represents the information provided by our suppliers as of April 1, 2015.

Based on our direct suppliers’ responses to our survey and follow-up inquiries, we have reason to believe that some of the necessary conflict minerals used in our products may have originated in the covered countries, but we have not identified any instances in which our sourcing of necessary conflict minerals directly or indirectly financed or benefitted armed groups in the covered countries.

Some of the necessary conflict minerals contained in our Covered Products could be traced to various smelters and refineries designated as “Compliant” or “Active” by well-respected industry groups whose lists were compiled on the basis of their application of a third-party supply chain audit process developed under the auspices of the OECD Due Diligence Guidance. These lists are maintained and published on the Conflict-Free Sourcing Initiative (“CFSI”) website: http://www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists/; with oversight by the CFSI.

The table below provides a summary of the smelters/refiners disclosed by our suppliers. We are listing those processing facilities in the tables at the end of this Report (in Appendix 1) that have been included in the CFSI list.

For a list of smelters or refineries, reference Appendix 1.

Supplier Survey Smelter/Refiner Results
Metal
Identified by Suppliers
Listed by CFSI as “Compliant”*
Listed by CFSI as Active*+
Tin
49
29
8
Tantalum
30
28
0
Tungsten
22
7
0
Gold
104
63
7

*
The Compliant and Active Smelters and Refiners as identified per the CFSI website http://www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists/ as of April 13, 2015.
+
Active Smelters & Refiners have committed to undergo a CFSP audit. Smelters and refiners are identified as Active in the Conflict-Free Smelter Program once they submit signed Agreement for the Exchange of Confidential Information (AECI) and Auditee Agreement contracts. This is the first step of the audit process. The number of smelters identified above is only based on the CFSI standard smelter list.


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3.     Risk Mitigation - Efforts to Improve Due Diligence for 2015 and Beyond

We intend to continue taking the following steps in 2015 (and beyond, as necessary or appropriate) to improve upon and enhance the due diligence conducted for 2014, to further mitigate any risk that the necessary conflict minerals in our Covered Products could benefit armed groups in the Covered Countries:

Continue to include a conflict minerals flow-down requirement in all new or renewed supplier agreements, which our direct suppliers must push down to their sub-suppliers via insertion in their agreements.
Continue to expand our supplier population surveyed to increase our response rate and gather more smelter and refinery data.
With respect to the OECD Due Diligence Guidance requirement to strengthen engagement with suppliers, we have developed a specific conflict minerals supplier training package that will provide our suppliers with an overview of our conflict minerals program and outline the requirements, commitment and expectations they must satisfy to help us meet our due diligence obligations under the Rule.
Provide training resources to our suppliers to support a higher response rate with improved content, as well as encourage their sourcing from conflict-free smelters or refiners.
Engage trade associations and other conflict free initiatives to define and incorporate best practices into our conflict minerals program.
Operationalize a Nortek conflict minerals compliance playbook for appropriate personnel which (a) provides an overview of the Dodd-Frank Wall Street Reform Act Section 1502 and SEC requirements; (b) outlines Nortek’s compliance requirements; and (c) ensures that Nortek has a consistent approach across all business segments/units and training throughout Nortek’s businesses.
In 2015, our online supplier portal will be available to push out requests to Nortek suppliers and collect their conflict mineral surveys resulting in a more efficient collection of data.
As part of our CM Program framework, we will follow our “potential escalation procedures” framework to determine, based on severity of action (i.e., no response, incomplete response, poor due diligence and not found to be DRC conflict free), what escalation procedure is required with respect to a particular supplier. Escalation procedures range from email to supplier point of contact to reduction in spend and selecting an alternative source, depending on the type/severity of the problem(s) detected and priority-level of supplier (depending for example, on the amount of products purchased, etc.).    

Forward-Looking Disclosure

This Conflict Minerals Report contains forward-looking statements regarding our business, products and conflict minerals efforts, including steps we intend to take to mitigate the risk that conflict minerals in our products benefit armed groups, and our industry’s conflict minerals efforts. Words such as “expects,” “anticipates,” “intends,” “believes” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this Report. Additionally, statements concerning future matters that are not historical are forward-looking statements.


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APPENDIX 1

Some of our direct supplier responses represented their supply chain at a company-level rather than being product-specific. As such, our list of processing facilities disclosed in this Report may contain more facilities than those that actually process the necessary conflict minerals contained in our Covered Products.

We requested country of origin information (if known) from each of our direct suppliers, most of which do not source directly from processing facilities, for the purposes of determining the source and chain of custody of the necessary conflict minerals in our supply chain.

At this time, we are listing only those processing facilities in the tables at the end of this Report that have been included in publicly available lists prepared by the CFSI (“CFSI-Listed Facilities”). Although some suppliers in our 2014 Supplier Population who responded to our survey identified what they designated smelters or refiners that did not appear among the CFSI Listed Facilities, we were unable to confirm independently (e.g., through the Department of Commerce supplier list and other third-party information sources) that these entities in fact were operating conflict free minerals processing facilities during calendar year 2014. Accordingly, there is no reasonable basis in our view for concluding that these additional entities are “known” within the meaning of the Rule, and therefore subject to identification in this Report. For the same reasons, we believe that identification of these entities as smelters or refiners would be materially misleading to investors.

Those rows identified with a * below reflect Compliant Smelters and Refiners identified on the CFSI website as of April 13, 2015; respectively, the rows identified with a + below reflect smelters and refiners which have committed to undergo an audit sponsored by CFSI, and are listed by CFSI as “Active”.

Gold
Aida Chemical Industries Co. Ltd.*
JAPAN
CID000019
Gold
Allgemeine Gold- und Silberscheideanstalt A.G.*
GERMANY
CID000035
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Gold
AngloGold Ashanti Mineração Ltda*
BRAZIL
CID000058
Gold
Argor-Heraeus SA*
SWITZERLAND
CID000077
Gold
Asahi Pretec Corporation*
JAPAN
CID000082
Gold
Asaka Riken Co Ltd*
JAPAN
CID000090
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.*
TURKEY
CID000103
Gold
Aurubis AG*
GERMANY
CID000113
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Gold
Bauer Walser AG
GERMANY
CID000141
Gold
Boliden AB*
SWEDEN
CID000157
Gold
C. Hafner GmbH + Co. KG*
GERMANY
CID000176
Gold
Caridad
MEXICO
CID000180
Gold
CCR Refinery – Glencore Canada Corporation*
CANADA
CID000185
Gold
Cendres & Métaux SA+
SWITZERLAND
CID000189
Gold
Chimet S.p.A.*
ITALY
CID000233
Gold
China National Gold Group Corporation
CHINA
CID000242
Gold
Chugai Mining
JAPAN
CID000264
Gold
Colt Refining
UNITED STATES
CID000288
Gold
Daejin Indus Co. Ltd
KOREA, REPUBLIC OF
CID000328
Gold
Daeryoung ENC
KOREA, REPUBLIC OF
CID000333
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Gold
Do Sung Corporation
KOREA, REPUBLIC OF
CID000359
Gold
Doduco+
GERMANY
CID000362

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Gold
Dowa*
JAPAN
CID000401
Gold
Eco-System Recycling Co., Ltd.*
JAPAN
CID000425
Gold
FSE Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Gold
Gansu Seemine Material Hi-Tech Co Ltd
CHINA
CID000522
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
Gold
Heimerle + Meule GmbH*
GERMANY
CID000694
Gold
Heraeus Ltd. Hong Kong*
HONG KONG
CID000707
Gold
Heraeus Precious Metals GmbH & Co. KG*
GERMANY
CID000711
Gold
Hunan Chenzhou Mining Industry Group
CHINA
CID000767
Gold
Hwasung CJ Co. Ltd
KOREA, REPUBLIC OF
CID000778
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
CHINA
CID000801
Gold
Ishifuku Metal Industry Co., Ltd.*
JAPAN
CID000807
Gold
Istanbul Gold Refinery*
TURKEY
CID000814
Gold
Japan Mint*
JAPAN
CID000823
Gold
Jiangxi Copper Company Limited
CHINA
CID000855
Gold
Johnson Matthey Inc*
UNITED STATES
CID000920
Gold
Johnson Matthey Limited*
CANADA
CID000924
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
RUSSIAN FEDERATION
CID000927
Gold
JSC Uralectromed*
RUSSIAN FEDERATION
CID000929
Gold
JX Nippon Mining & Metals Co., Ltd*
JAPAN
CID000937
Gold
Kazzinc Ltd*
KAZAKHSTAN
CID000957
Gold
Kennecott Utah Copper LLC*
UNITED STATES
CID000969
Gold
Kojima Chemicals Co. Ltd*
JAPAN
CID000981
Gold
Korea Metal Co. Ltd
KOREA, REPUBLIC OF
CID000988
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Gold
L' azurde Company For Jewelry*
SAUDI ARABIA
CID001032
Gold
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
CHINA
CID001058
Gold
LS-NIKKO Copper Inc.*
KOREA, REPUBLIC OF
CID001078
Gold
Luoyang Zijin Yinhui Metal Smelt Co Ltd
CHINA
CID001093
Gold
Materion Advanced Metals*
UNITED STATES
CID001113
Gold
Matsuda Sangyo Co., Ltd.*
JAPAN
CID001119
Gold
Metalor Technologies (Hong Kong) Ltd.*
HONG KONG
CID001149
Gold
Metalor Technologies (Singapore) Pte. Ltd.*
SINGAPORE
CID001152
Gold
Metalor Technologies Switzerland SA*
SWITZERLAND
CID001153
Gold
Metalor USA Refining Corporation*
UNITED STATES
CID001157
Gold
Met-Mex Peñoles, S.A.*
MEXICO
CID001161
Gold
Mitsubishi Materials Corporation*
JAPAN
CID001188
Gold
Mitsui Mining and Smelting Co., Ltd.*
JAPAN
CID001193
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.*
TURKEY
CID001220
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Gold
Nihon Material Co. LTD*
JAPAN
CID001259
Gold
Ohio Precious Metals LLC.*
UNITED STATES
CID001322
Gold
Ohura Precious Metal Industry Co., Ltd*
JAPAN
CID001325
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
RUSSIAN FEDERATION
CID001326

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Gold
OJSC Kolyma Refinery
RUSSIAN FEDERATION
CID001328
Gold
PAMP SA*
SWITZERLAND
CID001352
Gold
Penglai Penggang Gold Industry Co Ltd
CHINA
CID001362
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Gold
PT Aneka Tambang (Persero) Tbk*
INDONESIA
CID001397
Gold
PX Précinox SA*
SWITZERLAND
CID001498
Gold
Rand Refinery (Pty) Ltd*
SOUTH AFRICA
CID001512
Gold
Royal Canadian Mint*
CANADA
CID001534
Gold
Sabin Metal Corp.+
UNITED STATES
CID001546
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
CID001562
Gold
Schone Edelmetaal*
NETHERLANDS
CID001573
Gold
SEMPSA Joyeria Plateria SA*
SPAIN
CID001585
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd*
CHINA
CID001622
Gold
So Accurate Group, Inc.
UNITED STATES
CID001754
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals+
RUSSIAN FEDERATION
CID001756
Gold
Solar Applied Materials Technology Corp.*
TAIWAN
CID001761
Gold
Sumitomo
CHINA
CID001798
Gold
Sumitomo Metal Mining Co., Ltd.*
JAPAN
CID001798
Gold
Tanaka Kikinnzoku Kogyo K.K.*
JAPAN
CID001875
Gold
The Great Wall Gold and Silver Refinery of China
CHINA
CID001909
Gold
The Perth Mint
AUSTRALIA
CID002030
Gold
The Refinery of Shandong Gold Mining Co. Ltd*
CHINA
CID001916
Gold
Tokuriki Honten Co., Ltd*
JAPAN
CID001938
Gold
TongLing Nonferrous Metals Group Holdings Co;Ltd
CHINA
CID001947
Gold
Torecom+
KOREA, REPUBLIC OF
CID001955
Gold
Umicore Brasil Ltda*
BRAZIL
CID001977
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Gold
Umicore SA Business Unit Precious Metals Refining*
BELGIUM
CID001980
Gold
United Precious Metal Refining Inc.*
UNITED STATES
CID001993
Gold
Valcambi SA*
SWITZERLAND
CID002003
Gold
Western Australian Mint trading as The Perth Mint*
AUSTRALIA
CID002030
Gold
Yamamoto Precious Metal Co., Ltd.+
JAPAN
CID002100
Gold
Yokohama Metal Co Ltd+
JAPAN
CID002129
Gold
Yunnan Copper Industry Co Ltd
CHINA
CID000197
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
CHINA
CID002224
Gold
Zijin Mining Group Co. Ltd*
CHINA
CID002243
Tantalum
Changsha South Tantalum Niobium Co., Ltd.*
CHINA
CID000211
Tantalum
Conghua Tantalum and Niobium Smeltry*
CHINA
CID000291
Tantalum
Duoluoshan*
CHINA
CID000410
Tantalum
Exotech Inc.*
UNITED STATES
CID000456
Tantalum
F&X Electro-Materials Ltd.*
CHINA
CID000460
Tantalum
Global Advanced Metals (Cabot)
UNITED STATES
CID000564
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
CHINA
CID000616
Tantalum
H.C. Starck Group*
GERMANY
CID000654
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
CHINA
CID000616
Tantalum
Hi-Temp*
UNITED STATES
CID000731

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Tantalum
JiuJiang JinXin Nonferrous Metals Co. Ltd.*
CHINA
CID000914
Tantalum
JiuJiang Tanbre Co. Ltd.*
CHINA
CID000917
Tantalum
Kemet Blue Powder*
UNITED STATES
CID000963
Tantalum
King-Tan Tantalum Industry Ltd*
CHINA
CID000973
Tantalum
LSM Brasil S.A.*
BRAZIL
CID001076
Tantalum
Metallurgical Products India (Pvt.) Ltd.*
INDIA
CID001163
Tantalum
Mineracao Taboca S.A.*
BRAZIL
CID001175
Tantalum
Mitsui Mining & Smelting*
JAPAN
CID001192
Tantalum
Molycorp Silmet A.S.*
ESTONIA
CID001200
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.*
CHINA
CID001277
Tantalum
Plansee*
AUSTRIA
CID001368
Tantalum
QuantumClean*
UNITED STATES
CID001508
Tantalum
RFH Tantalum Smeltry Co., Ltd*
CHINA
CID001522
Tantalum
Shanghai Jiangxi Metals Co. Ltd
CHINA
CID001634
Tantalum
Solikamsk Metal Works*
RUSSIAN FEDERATION
CID001769
Tantalum
Taki Chemical*
JAPAN
CID001869
Tantalum
Tantalite Resources*
SOUTH AFRICA
CID001879
Tantalum
Telex*
UNITED STATES
CID001891
Tantalum
Ulba*
KAZAKHSTAN
CID001969
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd*
CHINA
CID002037
Tantalum
Zhuzhou Cement Carbide*
CHINA
CID002232
Tantalum
Alpha*
UNITED STATES
CID000292
Tin
China Rare Metal Materials Company
CHINA
CID000244
Tin
China Tin Group Co., Ltd+
CHINA
CID001070
Tin
CNMC (Guangxi) PGMA Co. Ltd.
CHINA
CID000278
Tin
Cooper Santa
BRAZIL
CID000295
Tin
CV Serumpun Sebalai
INDONESIA
CID000313
Tin
CV United Smelting
INDONESIA
CID000315
Tin
EM Vinto*
BOLIVIA
CID000438
Tin
Estanho de Rondonia S.A.
BRAZIL
CID000448
Tin
Fenix Metals+
POLAND
CID000468
Tin
Gejiu Non-Ferrous Metal Processing Co. Ltd.*
CHINA
CID000538
Tin
Gejiu Zi-Li
CHINA
CID000555
Tin
Huichang Jinshunda Tin Co. Ltd
CHINA
CID000760
Tin
Jiangxi Nanshan
CHINA
CID000864
Tin
Kai Unita Trade Limited Liability Company
CHINA
CID000942
Tin
Linwu Xianggui Smelter Co
CHINA
CID001063
Tin
Magnu's Minerals Metais e Ligas LTDA*
BRAZIL
CID002468
Tin
Malaysia Smelting Corporation (MSC)*
MALAYSIA
CID001105
Tin
Melt Metais e Ligas S/A*
BRAZIL
CID002500
Tin
Metallo Chimique*
BELGIUM
CID001143
Tin
Mineração Taboca S.A.*
BRAZIL
CID001173
Tin
Minmetals Ganzhou Tin Co. Ltd.
CHINA
CID001179
Tin
Minsur*
PERU
CID001182
Tin
Mitsubishi Materials Corporation*
JAPAN
CID001191
Tin
NGHE Tin Nonferrous Metal+
VIETNAM
CID002573

Page 10



Tin
Novosibirsk Integrated Tin Works
RUSSIAN FEDERATION
CID001305
Tin
O.M. Manufacturing (Thailand) Co., Ltd.+
Thailand
CID001314
Tin
OMSA
BOLIVIA
CID001337
Tin
PT Artha Cipta Langgeng+
INDONESIA
CID001399
Tin
PT Babel Inti Perkasa*
INDONESIA
CID001402
Tin
PT Bangka Putra Karya*
INDONESIA
CID001412
Tin
PT Bangka Tin Industry*
INDONESIA
CID001419
Tin
PT Belitung Industri Sejahtera*
INDONESIA
CID001421
Tin
PT BilliTin Makmur Lestari+
INDONESIA
CID001424
Tin
PT Bukit Timah*
INDONESIA
CID001428
Tin
PT DS Jaya Abadi*
INDONESIA
CID001434
Tin
PT Eunindo Usaha Mandiri*
INDONESIA
CID001438
Tin
PT Karimun Mining+
INDONESIA
CID001448
Tin
PT Mitra Stania Prima*
INDONESIA
CID001453
Tin
PT Prima Timah Utama*
INDONESIA
CID001458
Tin
PT Refined Banka Tin*
INDONESIA
CID001460
Tin
PT Sariwiguna Binasentosa*
INDONESIA
CID001463
Tin
PT Stanindo Inti Perkasa*
INDONESIA
CID001468
Tin
PT Sumber Jaya Indah+
INDONESIA
CID001471
Tin
PT Tambang Timah
INDONESIA
CID001477
Tin
PT Timah (Persero), Tbk*
INDONESIA
CID001482
Tin
PT Tinindo Inter Nusa*
INDONESIA
CID001490
Tin
Rui Da Hung+
TAIWAN
CID001539
Tin
Soft Metals Ltda+
BRAZIL
CID001758
Tin
Thaisarco*
THAILAND
CID001898
Tin
White Solder Metalurgia e Mineracao Ltda*
BRAZIL
CID002036
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd+
CHINA
CID002158
Tin
Yunnan Tin Company, Ltd*
CHINA
CID002180
Tin
ALMT*
CHINA
CID000004
Tin
China Minmetals Nonferrous Metals Co Ltd*
China
CID002513
Tungsten
China National Nonferrous Metals Imp. & Exp. Jiangxi Corporation Ltd.
CHINA
CID002317
Tungsten
Chongyi Zhangyuan Tungsten Co Ltd*
CHINA
CID000258
Tungsten
Dayu Welliang Tungsten Co., Ltd.*
CHINA
CID000345
Tungsten
Fujian Jinxin Tungsten Co. Ltd*
CHINA
CID000499
Tungsten
Ganzhou Grand Sea W & Mo Group Co Ltd
CHINA
CID002494
Tungsten
Ganzhou Hongfei Tungsten & Molybdenum Materials Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Huaxing Tungsten*
CHINA
CID000875
Tungsten
Ganzhou Nonferrous Metals smelting Co Ltd.*
CHINA
CID000868
Tungsten
Ganzhou Seadragon W&Mo Co Ltd*
CHINA
CID002494
Tungsten
Global Tungsten & Powders Corp*
UNITED STATES
CID000568
Tungsten
HC Starck GmbH*
GERMANY
CID000693
Tungsten
Hunan Chenzhou Mining Group Co*
CHINA
CID000766
Tungsten
Hunan Chun-chang Non-ferrous Smelting & Concentrating Co., Ltd.*
CHINA
CID000769
Tungsten
Japan New Metals Company*
JAPAN
CID000825
Tungsten
Jiangxi Tungsten Industry Co Ltd
CHINA
CID002317
Tungsten
Kennametal Inc.*
UNITED STATES
CID000966

Page 11



Tungsten
Tejing (Vietnam) Tungsten Co Ltd*
VIET NAM
CID001889
Tungsten
Wolfram Bergbau und Hütten AG*
AUSTRIA
CID002044
Tungsten
Wolfram Company CJSC*
RUSSIAN FEDERATION
CID002047
Tungsten
Xiamen Tungsten Co Ltd*
CHINA
CID002320
Tungsten
Zhuzhou Cemented Carbide Group Co Ltd
CHINA
CID002236


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