EX-1.01 2 formsd123118exhibit101.htm EXHIBIT 1.01 formsd123118exhibit101
Exhibit 1.01 John Bean Technologies Corporation Conflict Minerals Report For The Calendar Year Ended December 31, 2018 This report for the calendar year ended December 31, 2018 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). Unless otherwise specified or indicated by the context, JBT Corporation, JBT, we, us, our and the Company refer to John Bean Technologies Corporation and its subsidiaries. In accordance with the Rule, the information presented in this report does not include products manufactured by businesses acquired after May 1, 2017. JBT has reason to believe that some of the 3TGs (as defined below) present in its supply chain may have originated in the Democratic Republic of the Congo or an adjoining country (collectively referred to as the “Covered Countries”). We are unable to determine the origin of the 3TGs in our products and therefore cannot exclude the possibility that some may have originated in the Covered Countries. For that reason, we are required under the Rule to submit to the Securities and Exchange Commission a Conflict Minerals Report (“CMR”) as an Exhibit to Form SD. In accordance with the instructions to Form SD, this CMR has not been audited by an independent private sector auditor. The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country. Gold, columbite-tantalite (coltan), cassiterite and wolframite, and their derivatives, tin, tungsten and tantalum are hereinafter referred to collectively as “3TGs.” Forward-Looking Statement This report and other materials filed by JBT, as well as information in oral statements or other written statements made or to be made by us, contain statements that are, or may be considered to be, forward-looking statements. All statements that are not historical facts, including statements about our beliefs or expectations, are forward-looking statements. You can identify these forward-looking statements by the use of “seeks”, “approximately”, “predicts”, “intends”, “outlook”, “believes”, “expects”, “potential”, “continues”, “may”, “will”, “should”, “plans”, “estimates”, “anticipates”, “foresees” or the negative version of those words or other comparable words or phrases. Any forward-looking statements contained in this report are based upon our historical performance and on current plans, estimates and expectations. The inclusion of this forward-looking information should not be regarded as a representation by us or any other person that the future plans, estimates or expectations contemplated by us will be achieved. We believe that the factors that could cause our actual results to differ materially from expectations include but are not limited to the factors we described in our Form 10-K under “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations.” If one or more of those or other risks or uncertainties materialize, or if our underlying assumptions prove to be incorrect, actual results may vary materially from what we projected. Consequently, actual events and results may vary significantly from those included in or contemplated or implied by our forward-looking statements. The forward-looking statements included in this report are made only as of the date hereof, and we undertake no obligation to publicly update or revise any forward-looking statement made by us or on our behalf, whether as a result of new information, future developments, subsequent events or changes in circumstances or otherwise. 1. Company Overview We are a leading global technology solutions provider to high-value segments of the food and beverage industry with focus on proteins, liquid foods and automated system solutions. JBT designs, produces and services sophisticated products and systems for multi-national and regional customers through its FoodTech segment. JBT also sells critical equipment and services to domestic and international air transportation customers through its AeroTech segment. The product offerings of our FoodTech businesses include: • Protein. Providing comprehensive solutions to our customers, our Protein technology offerings include chilling, mixing/grinding, injecting, marinating, tumbling, portioning, packaging, coating, frying, freezing, weighing, X-ray food inspection, and packaging systems for poultry, beef, pork and seafood, as well as ready-to-eat meals, fruits, vegetables, dairy, and bakery products. Liquid Foods. Our Liquid Foods portfolio includes fruit and juice solutions that extract, concentrate and aseptically process citrus, tomato and other fruits, vegetables, and juices. It also includes in-container solutions for the filling, closing and preservation of fruits, vegetables, soups, sauces, dairy, and pet food products as well as ready-to-eat meals in a wide


 
variety of modern packages. • Automated Systems. We also provide stand-alone, fully-integrated, and dual-mode robotic automated guided vehicle systems for material movement requirements with a wide variety of applications including manufacturing and warehouse facilities. JBT AeroTech markets its solutions and services to domestic and international airport authorities, passenger airlines, airfreight and ground handling companies, military forces and defense contractors. The product offerings of our AeroTech businesses include: • Mobile Equipment. JBT AeroTech’s portfolio of mobile air transportation equipment includes commercial and military cargo loading, aircraft deicing, aircraft towing, and aircraft ground power and cooling systems. • Fixed Equipment. JBT AeroTech provides gate equipment for passenger boarding. • Airport Services. JBT AeroTech also maintains the maintenance of airport equipment, systems, and facilities. Our products may contain conflict minerals within the following components: • Tantalum, used in capacitors • Tin, used in soldered components • Tungsten, used in coatings, alloys, heating elements and electrodes • Gold, used in circuit boards, electrodes and electronic components Our policy regarding Conflicts Minerals is posted on our website under “Investor Relations” “Corporate Governance” and may be accessed via the following link: https://www.jbtc.com/en/north-america/investors/corporate-governance 2. Description of Reasonable County of Origin Inquiry and Conclusion We engaged Assent Compliance Inc. (“Assent”) to assist in developing our approach to conduct in good faith a reasonable country of origin inquiry (“RCOI”). Assent is a recognized software and consulting provider supporting companies’ regulatory compliance. JBT’s RCOI employed a combination of measures to determine whether the necessary 3TGs in JBT products originated from the Covered Countries. JBT’s primary means of determining country of origin of necessary 3TGs was by conducting a supply chain survey through Assent with direct JBT suppliers using the RBA-GeSI Conflict Minerals Reporting Template (“CMRT”). JBT began its scoping process by compiling a list of direct suppliers of materials for JBT’s businesses that were likely to source materials that might contain 3TGs. This list was then filtered to remove suppliers of direct materials for all business units sourced prior to January 1, 2018. The first two questions in the CMRT used for JBT’s supply chain survey allowed for further scoping as they ask suppliers whether any of the 3TGs are intentionally added and if they are necessary to the functionality or production of their products. Assent conducted additional analysis of the supply chain and, in combination with supplier feedback, discovered that 98% of the suppliers surveyed remained in scope. JBT surveyed its suppliers via the Assent Compliance Manager, a software platform licensed by JBT to log and track supplier communications. This platform also allows suppliers to upload completed CMRTs directly to the platform for assessment and management. In their responses, suppliers specified whether information was being provided at the company level or the product level. Non-responsive suppliers were contacted a minimum of three times by the Assent Compliance Manager and also via one-on-one communications. For the 2018 reporting period, JBT received responses from 42%, of its in-scope suppliers. Of the 861 suppliers that provided a response, approximately 36.7% reported that their products contained 3TGs necessary to the functionality or production of their products. We provided training and education on the completion of the CMRT to assist suppliers in accurately completing the survey questions in the CMRT. All of these communications were monitored and tracked in the Assent Compliance Manager for future reporting and transparency. JBT’s survey process with Assent includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on the construction and relationship of the questions submitted to the suppliers in the CMRT. Suppliers must provide the minimum responses to the CMRT in order to determine the scope of applicability of the remaining CMRT questions - this aligns with the design of the CMRT itself. The remainder of the questions are then automatically assessed for consistency. All submitted forms are accepted and classified as valid or invalid, preserving all of the data submitted for record keeping purposes. Suppliers are contacted in regards to invalid forms and are strongly encouraged to resubmit a valid form. As of May 7th, 2019, there were 46 (2%) invalid supplier submissions. As a result of its assessment, JBT has concluded in good faith that during calendar year 2018:


 
a) JBT has manufactured or contracted to manufacture products as to which 3TGs are necessary to the functionality or production of such products. b) Based on its RCOI, JBT is unable to determine whether a portion of its necessary 3TGs originated or may have originated in the Covered Countries and is unable to determine whether those necessary 3TGs may not be from recycle or scrap sources. 3. Due Diligence Process and Results Our due diligence measures have been designed to conform, in all material respects, with the framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold and for tin, tantalum and tungsten. The 5 steps of due diligence are: 1. Establishing strong company management systems regarding conflict minerals; 2. Identifying and assessing risks in our supply chain; 3. Designing and implementing a strategy to respond to identified risks in our supply chain; 4. Utilizing independent third-party audits of supply chain diligence; and 5. Publicly reporting on our supply chain due diligence We are a downstream supplier, many steps removed from the mining of 3TG. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, JBT does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure. The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us. 3.1. Management Systems Internal Team JBT has established a management system for conflict minerals. Our management system includes a Conflict Minerals team sponsored by JBT’s executive management, as well as engineering and sourcing resources within JBT’s business segments. The Conflict Minerals Team includes subject matter experts from relevant corporate functions such as: • Controller • General Counsel • Global Sourcing The team is responsible for implementing our conflict minerals compliance strategy and is led by the Company’s Executive Vice President and Chief Financial Officer. Control Systems As described above, we have adopted a Conflict Minerals policy which is posted on our website at https://www.jbtc.com/en/north-america/investors/corporate-governance JBT’s standard purchase order form terms and conditions include a requirement that suppliers comply with all local laws including those pertaining to business integrity. As we do not typically have a direct relationship with 3TG smelters and refiners, and due to our position in the supply chain and limited insight into deeper levels of the supply chain, we seek to be engaged and actively cooperate with other major manufacturers in the industry regarding 3TG sourcing matters. Supplier Engagement With respect to the OECD requirement to strengthen engagement with suppliers, we have provided education with respect to conflict


 
minerals regulations as well as our expectations for a continued business relationship, and leveraged the existing communications with our supplier base as is available. We put a strong emphasis on supplier education and training. To accomplish this, we utilized Assent’s learning management system, Assent University, and provided all in-scope suppliers access to their Conflict Minerals training course. All suppliers are encouraged to complete all modules within this course. Grievance Mechanism We have a hotline whereby employees can report violations of JBT’s policies. Employees are encouraged to reports concerns about compliance with policies to their managers, their human resources representative or company counsel unless they prefer to remain anonymous and utilize the hotline. Maintain Records We have adopted a policy to retain relevant documentation. Documentation will be retained for a minimum period of five years based on OECD guidance. 3.2 Identify and Assess Risk in the Supply Chain In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC conflict-free pose a risk to the supply chain. Each facility that meets the Responsible Minerals Initiative (“RMI”) definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the OECD Guidance. There are numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include: • Geographic proximity to the DRC and covered countries; • Known mineral source country of origin; • Responsible Minerals Assurance Process (RMAP) audit status; • Credible evidence of unethical or conflict sourcing; • Peer Assessments conducted by credible third-party sources. As part of our risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. CMRT submissions that include any red flag facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to JBT, and escalating up to removal of these red flag smelters from their supply chain. Consistent with the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain. In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain. If any smelter or refiner is not recognized by the RMI, Assent conducts outreach and research to gain more information about whether they are a smelter or a refiner, sourcing practices, location, and country of origin. Additionally, if any smelter is not certified conflict-free, Assent conducts outreach providing education on the RMAP and encouraging them to join this program. We also calculate supplier risk based on the risk ratings of the smelters declared by that supplier on their CMRT. Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). At this stage, evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on the following CMRT questions: A. Have you established a conflict minerals sourcing policy? E. Have you implemented due diligence measures for conflict-free sourcing? G. Do you review due diligence information received from your suppliers against your company’s expectations? H. Does your review process include corrective action management? When suppliers meet or exceed those criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. 3.3 Design and Implement a Strategy to Respond to Identified Risks In response to this risk assessment, we have a risk management plan, through which the conflict minerals program is implemented,


 
managed and monitored. As part of our risk management plan, to ensure suppliers understand our expectations we have provided both video, recorded training and documented instructions through Assent’s compliance supply chain staff. As the program progresses, contacts via email and phone by our business segments may be utilized to communicate the importance of a response via CMRTs to Assent and the required cooperation for compliance without conflict minerals policies will be emphasized. We expect any of our suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries, to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. During calendar year 2018, we have found no instances where it was necessary to terminate a contract or find a replacement supplier. 3.4 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain We do not have a direct relationship with 3TG smelters and refiners and do not presently perform or direct audits of these entities within our supply chain. JBT depends on audits performed and submitted to the RMI for conflict-free certifications. 3.5 Report Annually on Supply Chain Due Diligence We report annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission. Our Form SD and Conflict Minerals Report can be found on the Investor Relations page of our website https://www.jbtc.com/en/north-america/investors/sec-filings 4. Due Diligence Results Survey Results For the 2018 reporting year, JBT received CMRT from 42% of the suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. 46 suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. We surveyed a total of 2091 in scope suppliers and received 861 CMRT submissions by May 7th, 2019. Certain of the responses provided by the Company’s suppliers to the CMRT included the names of smelters or refiners. See Appendix A - Validated Smelter List. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI, and, if a supplier indicated that the facility was certified as “Conflict-Free”, Assent confirmed that the name was listed as such by RMI. Assent, using the sources above, has validated 322 smelters and refiners (“SORs”) disclosed by the Company’s suppliers on submitted CMRTs. Going forward, Assent is continuing to validate additional SORs from the submitted CMRTs. The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the smelters or refiners identified by our suppliers contained in Appendix A below may include smelters or refiners that processed conflict minerals that our suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the smelters or refiners included in the tables below were used to process the conflict minerals necessary to the functionality or production of our products during calendar year 2018. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed above were the country of origin of conflict minerals in our products during calendar year 2018, and we are therefore also unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the third-party audits conducted on smelters as part of the RMAP and the information that we receive from our suppliers may yield inaccurate or incomplete information. For example, the information received from our suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMAP and, as a result, are not responsible for the quality of these audits or the audit findings. Appendix A to this CMR lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix A also includes an aggregated list of the potential countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by our suppliers and RMI. Many of our surveyed suppliers are still unable to provide the smelters or refiners used for materials they supplied to us. Furthermore, many of the responses provided at the company or division level indicated an “unknown” status in terms of determining the origin of 3TGs. As noted above, the current efforts focus on gathering smelter information via the CMRT and requesting full completion of all necessary smelter identification information which will enable the validation and disclosure of the smelters as well as the tracing of the 3TGs to their location of origin. We believe that the inquiries and assessment processes described above represent a reasonable effort to determine the origin of the 3TGs in our products, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.


 
5. Risk Mitigation and Program Improvement Steps We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the Covered Countries: a. Engage with suppliers and provide training resources to attempt to increase the response rate and improve the content of the supplier survey responses. b. Engage any of our suppliers found to be supplying us with 3TGs from sources that support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict. c. Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers. d. Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts and in the terms and conditions of each purchase order issued to direct suppliers of materials for JBT businesses likely to source materials that might contain 3TGs.


 
Appendix A - Validated Smelter List Metal Standard Smelter Name Smelter Facility Location Smelter ID Gold 8853 S.p.A. ITALY CID002763 Gold Abington Reldan Metals, LLC UNITED STATES CID002708 Gold Advanced Chemical Company UNITED STATES CID000015 Gold African Gold Refinery UGANDA CID003185 Gold Aida Chemical Industries Co., Ltd. JAPAN CID000019 Gold Al Etihad Gold LLC UNITED ARAB EMIRATES CID002560 Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY CID000035 Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN CID000041 Gold AngloGold Ashanti Córrego do Sítio Mineração BRAZIL CID000058 Gold Argor-Heraeus S.A. SWITZERLAND CID000077 Gold Asahi Pretec Corp. JAPAN CID000082 Gold Asahi Refining Canada Ltd. CANADA CID000924 Gold Asahi Refining USA Inc. UNITED STATES CID000920 Gold Asaka Riken Co., Ltd. JAPAN CID000090 Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY CID000103 Gold AU Traders and Refiners SOUTH AFRICA CID002850 Gold Aurubis AG GERMANY CID000113 Gold Bangalore Refinery INDIA CID002863 Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES CID000128 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 S.A. SWITZERLAND CID000189 Gold Chimet S.p.A. ITALY CID000233 Gold Chugai Mining JAPAN CID000264 Gold Daejin Indus Co., Ltd. KOREA, REPUBLIC OF CID000328 Gold Daye Non-Ferrous Metals Mining Ltd. CHINA CID000343 Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY CID002867 Gold Dijllah Gold Refinery FZC UNITED ARAB EMIRATES CID003348 Gold DODUCO Contacts and Refining GmbH GERMANY CID000362 Gold Dowa JAPAN CID000401 Gold DS PRETECH Co., Ltd. KOREA, REPUBLIC OF CID003195 Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF CID000359 Gold Eco-System Recycling Co., Ltd. JAPAN CID000425 Gold Emirates Gold DMCC UNITED ARAB EMIRATES CID002561 Gold Fidelity Printers and Refiners Ltd. ZIMBABWE CID002515 Gold Fujairah Gold FZE UNITED ARAB EMIRATES CID002584 Gold GCC Gujrat Gold Centre Pvt. Ltd. INDIA CID002852 Gold Geib Refining Corporation UNITED STATES CID002459 Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA CID002243 Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA CID001909 Gold Guangdong Jinding Gold Limited CHINA CID002312 Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA CID000651


 
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA CID000671 Gold HeeSung KOREA, REPUBLIC OF CID000689 Gold Heimerle + Meule GmbH GERMANY CID000694 Gold Heraeus Metals Hong Kong Ltd. CHINA CID000707 Gold Heraeus Precious Metals GmbH & Co. KG GERMANY CID000711 Gold Hunan Chenzhou Mining Co., Ltd. CHINA CID000767 Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. CHINA CID000773 Gold Hwasung CJ Co., Ltd. KOREA, REPUBLIC OF CID000778 Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA CID000801 Gold International Precious Metal Refiners UNITED ARAB EMIRATES CID002562 Gold Ishifuku Metal Industry Co., Ltd. JAPAN CID000807 Gold Istanbul Gold Refinery TURKEY CID000814 Gold Italpreziosi ITALY CID002765 Gold Japan Mint JAPAN CID000823 Gold Jiangxi Copper Co., Ltd. CHINA CID000855 Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION CID000927 Gold JSC Uralelectromed RUSSIAN FEDERATION CID000929 Gold JX Nippon Mining & Metals Co., Ltd. JAPAN CID000937 Gold Kaloti Precious Metals UNITED ARAB EMIRATES CID002563 Gold Kazakhmys Smelting LLC KAZAKHSTAN CID000956 Gold Kazzinc KAZAKHSTAN CID000957 Gold Kennecott Utah Copper LLC UNITED STATES CID000969 Gold KGHM Polska Miedz Spolka Akcyjna POLAND CID002511 Gold Kojima Chemicals Co., Ltd. JAPAN CID000981 Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF CID002605 Gold Kyrgyzaltyn JSC KYRGYZSTAN CID001029 Gold Kyshtym Copper-Electrolytic Plant ZAO RUSSIAN FEDERATION CID002865 Gold L'azurde Company For Jewelry SAUDI ARABIA CID001032 Gold Lingbao Gold Co., Ltd. CHINA CID001056 Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA CID001058 Gold L'Orfebre S.A. ANDORRA CID002762 Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF CID001078 Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA CID001093 Gold Marsam Metals BRAZIL CID002606 Gold Materion UNITED STATES CID001113 Gold Matsuda Sangyo Co., Ltd. JAPAN CID001119 Gold Metalor Technologies (Hong Kong) Ltd. CHINA CID001149 Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE CID001152 Gold Metalor Technologies (Suzhou) Ltd. CHINA CID001147 Gold Metalor Technologies S.A. SWITZERLAND CID001153 Gold Metalor USA Refining Corporation UNITED STATES CID001157 Gold Metalúrgica Met-Mex Peñoles S.A. De C.V. MEXICO CID001161 Gold Mitsubishi Materials Corporation JAPAN CID001188 Gold Mitsui Mining and Smelting Co., Ltd. JAPAN CID001193 Gold MMTC-PAMP India Pvt., Ltd. INDIA CID002509 Gold Modeltech Sdn Bhd MALAYSIA CID002857 Gold Morris and Watson NEW ZEALAND CID002282 Gold Morris and Watson Gold Coast AUSTRALIA CID002866 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 NH Recytech Company KOREA, REPUBLIC OF CID003189 Gold Nihon Material Co., Ltd. JAPAN CID001259 Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA CID002779 Gold Ohura Precious Metal Industry Co., Ltd. JAPAN CID001325 OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" Gold (OJSC Krastsvetmet) RUSSIAN FEDERATION CID001326 Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION CID000493 Gold PAMP S.A. SWITZERLAND CID001352 Gold Pease & Curren UNITED STATES CID002872 Gold Penglai Penggang Gold Industry Co., Ltd. CHINA CID001362 Gold Planta Recuperadora de Metales SpA CHILE CID002919 Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION CID001386 Gold PT Aneka Tambang (Persero) Tbk INDONESIA CID001397 Gold PX Précinox S.A. SWITZERLAND CID001498 Gold QG Refining, LLC UNITED STATES OF AMERICA CID003324 Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA CID001512 Gold Refinery of Seemine Gold Co., Ltd. CHINA CID000522 Gold Remondis Argentia B.V. NETHERLANDS CID002582 Gold Republic Metals Corporation UNITED STATES CID002510 Gold Royal Canadian Mint CANADA CID001534 Gold SAAMP FRANCE CID002761 Gold Sabin Metal Corp. UNITED STATES CID001546 Gold Safimet S.p.A Italy CID002973 Gold SAFINA A.S. CZECH REPUBLIC CID002290 Gold Sai Refinery INDIA CID002853 Gold Samduck Precious Metals KOREA, REPUBLIC OF CID001555 Gold SAMWON Metals Corp. KOREA, REPUBLIC OF CID001562 Gold SAXONIA Edelmetalle GmbH GERMANY CID002777 Gold SEMPSA Joyería Platería S.A. SPAIN CID001585 Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA CID001619 Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA CID001622 Gold Shangdong Humon Smelting Co., Ltd. CHINA CID002525 Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA CID001736 Gold Singway Technology Co., Ltd. TAIWAN CID002516 Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION CID001756 Gold Solar Applied Materials Technology Corp. TAIWAN CID001761 State Research Institute Center for Physical Sciences and Gold Technology LITHUANIA CID003153 Gold Sudan Gold Refinery SUDAN CID002567 Gold Sumitomo Metal Mining Co., Ltd. JAPAN CID001798 Gold SungEel HiTech KOREA, REPUBLIC OF CID002918 Gold T.C.A S.p.A ITALY CID002580 Gold Tanaka Kikinzoku Kogyo K.K. JAPAN CID001875 Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA CID001916 Gold Tokuriki Honten Co., Ltd. JAPAN CID001938 Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA CID001947 Gold Tony Goetz NV BELGIUM CID002587 Gold TOO Tau-Ken-Altyn KAZAKHSTAN CID002615 Gold Torecom KOREA, REPUBLIC OF CID001955 Gold Umicore Brasil Ltda. BRAZIL CID001977


 
Gold Umicore Precious Metals Thailand THAILAND CID002314 Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM CID001980 Gold United Precious Metal Refining, Inc. UNITED STATES CID001993 Gold Universal Precious Metals Refining Zambia ZAMBIA CID002854 Gold Valcambi S.A. SWITZERLAND CID002003 Gold Western Australian Mint trading as The Perth Mint AUSTRALIA CID002030 Gold WIELAND Edelmetalle GmbH GERMANY CID002778 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 Tantalum Asaka Riken Co., Ltd. JAPAN CID000092 Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA CID000211 Tantalum D Block Metals, LLC UNITED STATES CID002504 Tantalum Exotech Inc. UNITED STATES CID000456 Tantalum F&X Electro-Materials Ltd. CHINA CID000460 Tantalum FIR Metals & Resource Ltd. CHINA CID002505 Tantalum Global Advanced Metals Aizu JAPAN CID002558 Tantalum Global Advanced Metals Boyertown UNITED STATES CID002557 Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. CHINA CID000291 Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA CID000616 Tantalum H.C. Starck Co., Ltd. THAILAND CID002544 Tantalum H.C. Starck Hermsdorf GmbH GERMANY CID002547 Tantalum H.C. Starck Inc. UNITED STATES CID002548 Tantalum H.C. Starck Ltd. JAPAN CID002549 Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY CID002550 Tantalum H.C. Starck Tantalum and Niobium GmbH GERMANY CID002545 Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA CID002492 Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA CID002512 Tantalum Jiangxi Tuohong New Raw Material CHINA CID002842 Tantalum Jiujiang Janny New Material Co., Ltd. CHINA CID003191 Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA CID000914 Tantalum Jiujiang Tanbre Co., Ltd. CHINA CID000917 Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA CID002506 Tantalum KEMET Blue Metals MEXICO CID002539 Tantalum KEMET Blue Powder UNITED STATES CID002568 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 and Smelting Co., Ltd. JAPAN CID001192 Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA CID001277 Tantalum NPM Silmet AS ESTONIA CID001200 Tantalum Power Resources Ltd. MACEDONIA CID002847 Tantalum QuantumClean UNITED STATES CID001508 Tantalum Resind Industria e Comercio Ltda. BRAZIL CID002707 Tantalum RFH Tantalum Smeltry Co., Ltd. CHINA CID001522 Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION CID001769 Tantalum Taki Chemicals JAPAN CID001869 Tantalum Telex Metals UNITED STATES CID001891 Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN CID001969


 
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA CID002508 Tin Alpha UNITED STATES CID000292 Tin An Vinh Joint Stock Mineral Processing Company VIET NAM CID002703 Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA CID000228 Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA CID003190 Tin China Tin Group Co., Ltd. CHINA CID001070 Tin CV Ayi Jaya INDONESIA CID002570 Tin CV Dua Sekawan INDONESIA CID002592 Tin CV Gita Pesona INDONESIA CID000306 Tin CV Tiga Sekawan INDONESIA CID002593 Tin CV United Smelting INDONESIA CID000315 Tin CV Venus Inti Perkasa INDONESIA CID002455 Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. CHINA CID003356 Tin Dowa JAPAN CID000402 Electro-Mechanical Facility of the Cao Bang Minerals & Tin Metallurgy Joint Stock Company VIET NAM CID002572 Tin EM Vinto BOLIVIA CID000438 Tin Estanho de Rondônia S.A. BRAZIL CID000448 Tin Fenix Metals POLAND CID000468 Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. CHINA CID003410 Tin Gejiu Fengming Metallurgy Chemical Plant CHINA CID002848 Tin Gejiu Kai Meng Industry and Trade LLC CHINA CID000942 Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA CID000538 Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA CID001908 Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA CID000555 Tin Guangdong Hanhe Non-ferrous Metal Limited Company CHINA CID003116 Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA CID002849 Tin HuiChang Hill Tin Industry Co., Ltd. CHINA CID002844 Tin Huichang Jinshunda Tin Co., Ltd. CHINA CID000760 Tin Jiangxi New Nanshan Technology Ltd. CHINA CID001231 Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL CID002468 Tin Malaysia Smelting Corporation (MSC) MALAYSIA CID001105 Tin Melt Metais e Ligas S.A. BRAZIL CID002500 Tin Metallic Resources, Inc. UNITED STATES CID001142 Tin Metallo Belgium N.V. BELGIUM CID002773 Tin Metallo Spain S.L.U. SPAIN CID002774 Tin Mineracao Taboca S.A. BRAZIL CID001173 Tin Minsur PERU CID001182 Tin Mitsubishi Materials Corporation JAPAN CID001191 Tin Modeltech Sdn Bhd MALAYSIA CID002858 Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIET NAM CID002573 Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND CID001314 Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES CID002517 Tin Operaciones Metalurgical S.A. BOLIVIA CID001337 Tin Pongpipat Company Limited MYANMAR CID003208 Tin PT Aries Kencana Sejahtera INDONESIA CID000309 Tin PT Artha Cipta Langgeng INDONESIA CID001399 Tin PT ATD Makmur Mandiri Jaya INDONESIA CID002503 Tin PT Babel Inti Perkasa INDONESIA CID001402 Tin PT Babel Surya Alam Lestari INDONESIA CID001406


 
Tin PT Bangka Prima Tin INDONESIA CID002776 Tin PT Bangka Serumpun INDONESIA CID003205 Tin PT Bangka Tin Industry INDONESIA CID001419 Tin PT Belitung Industri Sejahtera INDONESIA CID001421 Tin PT Bukit Timah INDONESIA CID001428 Tin PT DS Jaya Abadi INDONESIA CID001434 Tin PT Inti Stania Prima INDONESIA CID002530 Tin PT Karimun Mining INDONESIA CID001448 Tin PT Kijang Jaya Mandiri INDONESIA CID002829 Tin PT Menara Cipta Mulia INDONESIA CID002835 Tin PT Mitra Stania Prima INDONESIA CID001453 Tin PT Panca Mega Persada INDONESIA CID001457 Tin PT Premium Tin Indonesia INDONESIA CID000313 Tin PT Prima Timah Utama INDONESIA CID001458 Tin PT Rajawali Rimba Perkasa INDONESIA CID003381 Tin PT Refined Bangka Tin INDONESIA CID001460 Tin PT Sariwiguna Binasentosa INDONESIA CID001463 Tin PT Stanindo Inti Perkasa INDONESIA CID001468 Tin PT Sukses Inti Makmur INDONESIA CID002816 Tin PT Sumber Jaya Indah INDONESIA CID001471 Tin PT Timah (Persero) Tbk Kundur INDONESIA CID001477 Tin PT Timah (Persero) Tbk Mentok INDONESIA CID001482 Tin PT Tinindo Inter Nusa INDONESIA CID001490 Tin PT Tirus Putra Mandiri INDONESIA CID002478 Tin PT Tommy Utama INDONESIA CID001493 Tin Resind Industria e Comercio Ltda. BRAZIL CID002706 Tin Rui Da Hung TAIWAN CID001539 Tin Soft Metais Ltda. BRAZIL CID001758 Tin Super Ligas Brazil CID002756 Tin Thai Nguyen Mining and Metallurgy Co., Ltd. VIET NAM CID002834 Tin Thaisarco THAILAND CID001898 Tin Tin Technology & Refining UNITED STATES OF AMERICA CID003325 Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIET NAM CID002574 Tin White Solder Metalurgia e Mineração Ltda. BRAZIL CID002036 Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA CID002158 Tin Yunnan Tin Company Limited CHINA CID002180 Tungsten A.L.M.T. TUNGSTEN Corp. JAPAN CID000004 Tungsten ACL Metais Eireli BRAZIL CID002833 Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM CID002502 Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA CID002513 Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA CID000258 Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA CID000499 Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA CID002645 Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA CID000875 Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA CID002315 Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA CID002494 Tungsten Ganzhou Yatai Tungsten Co., Ltd. CHINA CID002536 Tungsten Global Tungsten & Powders Corp. UNITED STATES CID000568 Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA CID000218 Tungsten H.C. Starck Smelting GmbH & Co.KG GERMANY CID002542


 
Tungsten H.C. Starck Tungsten GmbH GERMANY CID002541 Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA CID000766 Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA CID002579 Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA CID000769 Tungsten Hunan Litian Tungsten Industry Co., Ltd. CHINA CID003182 Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION CID002649 Tungsten Japan New Metals Co., Ltd. JAPAN CID000825 Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA CID002551 Tungsten Jiangxi Dayu Longxintai Tungsten Co., Ltd. CHINA CID002647 Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA CID002321 Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. CHINA CID002313 Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA CID002318 Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA CID002317 Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA CID002316 Tungsten Kennametal Fallon UNITED STATES CID000966 Tungsten Kennametal Huntsville UNITED STATES CID000105 Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA CID002319 Tungsten Moliren Ltd RUSSIAN FEDERATION CID002845 Tungsten Niagara Refining LLC UNITED STATES CID002589 Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC VIET NAM CID002543 Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES CID002827 Tungsten South-East Nonferrous Metal Company Limited of Hengyang City CHINA CID002815 Tungsten Tejing (Vietnam) Tungsten Co., Ltd. VIET NAM CID001889 Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION CID002724 Tungsten Wolfram Bergbau und Hütten AG AUSTRIA CID002044 Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF CID002843 Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA CID002320 Tungsten Xiamen Tungsten Co., Ltd. CHINA CID002082 Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA CID002830 Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA CID002095 List of Potential Countries of Origin: Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Democratic Republic of the Congo, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe