EX-1.01 2 tm2514859d1_ex1-01.htm EXHIBIT 1.01

 

Exhibit 1.01

 

Allegion plc

 

Conflict Minerals Report

for the reporting period January 1 to December 31, 2024

 

Background

 

This Conflict Minerals Report on Form SD of Allegion plc (“Allegion,” “we,” “us” or the “Company”) for the year ended December 31, 2024, was prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”).

 

The Rule requires disclosure of certain information when a public company manufactures or contracts to manufacture products that contain “conflict minerals” (as defined in the Rule) that may have originated in the Democratic Republic of the Congo (“DRC”) and its adjoining countries (the “Covered Countries”). As defined by the Rule, and for the purposes of this report, the conflict minerals are columbite-tantalite (coltan), cassiterite, gold and wolframite, including their derivatives, which are currently limited to tantalum, tin and tungsten (collectively, “conflict minerals” or “3TGs”).

 

Web links in this report are provided for convenience only. Content on, or that may be accessed through, the referenced websites is not incorporated by reference into and is not part of this filing.

 

Forward-Looking Statements

 

Certain statements in this report are “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. These statements are based on the Company’s currently available information and our current assumptions, expectations and projections about future events. They are subject to future events, risks and uncertainties - many of which are beyond the Company’s control - as well as potentially inaccurate assumptions, that could cause actual results to differ materially from those in the forward-looking statements. Further information on these factors and other risks that may affect the Company’s business is included in filings it makes with the SEC from time to time, including under the headings “Item 1A. Risk Factors” and “Item 7. Management’s Discussion and Analysis of Financial Conditions and Results of Operations” in its Annual Report filed on Form 10-K for the year ended December 31, 2024, and any Quarterly Report filed on Form 10-Q, Current Report on Form 8-K, or other SEC filing that contains updates thereto. Forward-looking statements included herein are made only as of the date hereof and the Company undertakes no obligation to update these forward-looking statements, whether as a result of new information, future events or otherwise, except as required by law.

 

Company Overview

 

Allegion is a leading global provider of security products and solutions that keep people and their assets safe and secure in the places they live, learn, work and connect. We pioneer safety and security to create a safer and more accessible world. Central to our work is partnering and developing ecosystems to create flawless, seamless access experiences and enable an uninterrupted and secure flow of people and assets. We offer an extensive and versatile portfolio of security and access control products and solutions across a range of market-leading brands. Our experts across the globe deliver high-quality hardware, software, services and systems, and we use our deep expertise to serve as trusted partners to end-users who seek customized solutions to their security needs.

 

1 

 

 

Product Description

 

The following categories of electronic and other products we manufacture or contract to manufacture may contain conflict minerals that are necessary to the functionality or production of such products:

 

·Door controls, door control systems and exit devices
·Doors, glass and door systems and accessories
·Electronic security products and access control systems, including time, attendance and workforce productivity
·Locks, locksets, portable locks and key systems
·Services and software

 

For further information about our products, please refer to “Item 1. Business — Products and Services” of our Annual Report on Form 10-K for the year ended December 31, 2024, which is incorporated herein by reference.

 

Conflict Minerals Program Overview

 

Allegion is many layers removed from the mining of conflict minerals, and we do not directly purchase raw ore or unrefined conflict minerals. We rely on collaboration with our supplier base by building awareness through training and provide support to identify the upstream supply chain and the originating smelter(s)/refiner(s) for the conflict minerals that ultimately are found in our products.

 

This effort is both challenging and demanding, as many of our suppliers are private entities that are not directly affected by the Rule, and many times do not have the financial and human resources to comply with the requests. Furthermore, our suppliers have their own supply chains and need to collaborate with their own upstream suppliers in order provide transparency of the end-to-end supply chain and to identify the smelter(s)/refiner(s).

 

Reasonable Country of Origin Inquiry

 

We conducted a reasonable country of origin inquiry (“RCOI”) regarding the conflict minerals by utilizing the conflict minerals reporting template (“CMRT”) provided by the Responsible Business Alliance (“RBA”) through its Responsible Minerals Initiative (“RMI”). Our RCOI was designed to determine whether any of the conflict minerals in the products we manufacture or contract to manufacture originated in the Covered Countries or were from recycled or scrap sources by asking our suppliers to identify the smelters and refiners of the conflict minerals contained in the products or raw materials that they supply to us. We reviewed the information our suppliers provided and compared it to publicly available information about such smelters and refiners.

 

2 

 

 

OECD Due Diligence Framework in Practice

 

We designed our due diligence measures to conform, in all material respects, with the framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition) and the related supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”). The OECD Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely: (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.

 

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 strategic, direct suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.

 

STEP 1: Establish Strong Company Management Systems

 

Company Conflict Minerals Policy

 

Our policy is to support the legitimate businesses within the Covered Countries, and we expect our suppliers to source conflict minerals responsibly by establishing conflict minerals compliance policies and a due diligence process to support their conflict minerals data collection efforts.

 

Our Conflict Minerals Policy is available at: https://www.allegion.com/corp/en/about/ESG/environmental/conflict-minerals.html.

 

Internal Team

 

Our conflict minerals program is designed to conform to the internationally recognized due diligence framework of the OECD. The framework includes standard operating procedures, supplier risk segmentation, established processes for RCOI, due diligence and escalation, training and communication, as well as a website containing our Conflict Minerals Policy with information about the regulation, contact information and the latest Form SD filing.

 

3 

 

 

We have a global supply chain compliance team that reports up to the Vice President - Global Supply Chain & Operations Support. This team focuses on driving the compliance efforts of the conflict minerals program, executing the procedures, working closely with a third-party regulatory compliance consulting firm to advance the maturity and sophistication of the program, and further strengthening the conformance with the OECD Guidance and standards. Our continued conflict minerals program maturity progress can be attributed to several successfully executed initiatives:

 

·Attendance at virtual conferences that include topics related to conflict minerals
·Advancing internal knowledge through continuing education
·Monitoring for any updates to relevant regulations (such as following news releases, webinars, industry initiatives)
·Leveraging third-party software solution and consulting services to:

oRetain related legacy documents and records
oOffer training and updates for suppliers
oUtilize their resources for tracking supplier CMRT response rates and best practices

 

We collaborate closely with our suppliers by developing long-lasting relationships. Our supplier development team has the responsibility to qualify and develop our suppliers. This team conducts periodic reviews of our Global Supplier Requirements Manual, which lays out the Company’s expectations of suppliers with respect to compliance with local, state and national regulations, including conflict mineral requirements.

 

Further, we have a dedicated commodity management team responsible for maintaining relationships with suppliers within their assigned commodities. This team also monitors supplier performance and selectively manages strategic relationships with preferred suppliers to help preserve the stability and longevity of the supplier relationships. Our supplier contracts contain a regulatory clause that explicitly lays out the expectations with the suppliers to comply with laws, including the Rule, and allows our company to audit and inspect data, records and other materials to evidence conflict minerals use and controls.

 

Per the OECD Guidance, we retain and maintain our records for a period of five years on an internal Company network. These records are also stored in our third-party software system, and we will continue to leverage this system for record keeping purposes.

 

Reporting Mechanism

 

As part of our continuing efforts to ensure lawful and ethical behavior, the Allegion Code of Conduct (the “Code”), applicable to all officers, directors and employees of Allegion, and the Allegion Business Partner Code of Conduct (the “Business Partner Code”), applicable to Allegion’s agents, distributors, dealers, contractors, suppliers, vendors, service providers, intermediaries, joint venture partners and other business partners, provide guidance on reporting legal and ethical questions or concerns.

 

The Code and the Business Partner Code are available at: https://www.allegion.com/corp/en/about/ESG/governance/ethics-and-compliance-program.html.

 

A variety of options are available for employees and business partners to ask questions, or report concerns regarding ethics and compliance.

 

4 

 

 

Employees

 

As set forth in the Code, employees may contact their manager, local management, their local Human Resources partner, the Allegion Legal Department, the Chief Compliance Officer or the Ethics HelpLine (“HelpLine”). Specific instructions for contacting these resources are provided in the Code. Employees contacting the HelpLine may choose to remain anonymous if consistent with applicable local law. The HelpLine is available 24/7 and is staffed by an independent organization. The Code also prohibits retaliation against individuals asking questions or raising concerns.

 

Business Partners

 

The Business Partner Code states business partners who wish to seek guidance or report concerns in the ethics and compliance area may send an email to Allegion, submit a report to Allegion via the Internet, send a letter to Allegion by mail or contact the HelpLine. Specific instructions and information (such as email, internet and mailing addresses, and U.S. and international HelpLine phone numbers) on reporting using each of these resources is provided in the Business Partner Code.

 

STEP 2: Identify and Assess Risks in Our Supply Chain

 

Scope Identification

 

Due to our size, the complexity of our products, and the depth, breadth and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified by Assent Compliance (“Assent”), our third-party service provider, and members of our internal conflict minerals team who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.

 

Ongoing concerns are related to gaps in information from CMRT responses which did not provide product specific CMRT information (instead providing company-wide or divisional level information that is not directly relevant to products manufactured by Allegion) or were unable to specify the smelters or refiners used for 3TGs in the components supplied to Allegion. Additionally, for our suppliers who indicated they received 50% or less of their suppliers’ CMRTs, their corresponding list of smelters or refiners was not comprehensive.

 

Based on historical supply chain information, we performed a risk-based approach in our due diligence that included:

 

·Risk Identification through a commodity segmentation across the company for components (including electronic products) or products previously identified as containing, or were suspected of containing, conflict mineral(s).

 

5 

 

 

·Risk Assessment and prioritization based on information about purchased components or products from engineering, catalogs, sourcing managers and commodity-taxonomy definition. Our categories were as follows:

 

High Concern: ·  Electronic products and components
  ·  Materials and mechanical components containing 3TG’s
Low Concern: · Mechanical products, molded components, finishing, powered coats
No Concern/ · Plastics extrusions and foam/insulation
Out of Scope: · Packaging, paper, wood, chemicals, service providers, etc.

 

·Risk Monitoring of new suppliers and additional information, including changes in regulatory landscape. When new suppliers are identified, we conduct a risk assessment of the anticipated purchases to determine the concern level. Based on this assessment, we engage with all relevant suppliers and request that they complete and return the CMRT.

 

Following our risk-based approach, we do not prioritize outreach to suppliers in the No Concern/Out of Scope category who consistently stated they did not use conflict minerals in products furnished to Allegion and instead focus our efforts on suppliers more likely to have conflict minerals in their products.

 

Execution

 

We retained Assent to oversee our 2024 CMRT campaign. Assent initiated the campaign with a communication to our supply base authorizing Assent to solicit information from our suppliers. Next, Assent distributed a “campaign kick-off” letter in multiple languages that laid out the timing of the campaign, the process and expectations. Following the campaign kick-off, Assent provided each supplier with: Allegion’s Conflict Minerals Policy; information about the conflict minerals regulations; training materials for the program and CMRT form (version 6.4); Allegion contact information and conflict minerals website; and the CMRT response deadline. Assent also assisted us with the smelter review and country-of-origin determination for the data we collected during our due diligence and supplier campaign.

 

We followed this pre-established process for all selected suppliers with reminders to complete and return the CMRT and validated the CMRT responses for completion and accuracy. In addition, we followed an escalation process for all suppliers who failed to timely complete and return the CMRT or who provided incomplete or inconsistent responses which included alternative communication medium (e.g., phone calls or emails from private accounts as opposed to company accounts), leveraging the commodity managers (including local commodity managers in other regions of the world) who had established relationships with the suppliers and online research of the suppliers to see if they provided any public information regarding conflict minerals (e.g., policy or Form SD filing).

 

Assent validated the smelter information provided by the suppliers using the most recent smelter and refinery validation list from the Responsible Minerals Initiative (RMI). Before the validation, the lists were reviewed and scrubbed for errors.

 

6 

 

 

Assent reviewed the list to identify smelters/refiners that were participating in the Responsible Minerals Assurance Process (“RMAP”), while a risk-based assessment was also performed on the remaining smelters/refiners to determine which suppliers posed increased risks in the supply chain.

 

Assent used numerous factors to determine the level of risk that each smelter/refiner posed to the supply chain by identifying red flags. These factors include:

 

·Geographic proximity to Conflict-Affected and High-Risk Areas
·Known mineral source country of origin
·RMAP audit status
·Credible evidence of unethical or conflict sourcing
·Peer assessments conducted by credible third-party sources
·Sanctions risks

 

Based on these criteria, Assent identified certain third-party facilities in the received CMRT responses as smelters or refiners of Interest, including the following that are not identified as “Conformant” or “Active” by RMI:

 

·21 gold refiners from Belgium, China, India, Republic of Korea, Russia, South Africa, Sudan, Uganda, United Arab Emirates and Zimbabwe
·1 tantalum smelters from Russia
·6 tin smelters from Russia
·10 tungsten smelters from China and Russia

 

Through Assent, submissions that included any of the above facilities immediately produced a response instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to components or products that they supply to us, if any, and escalating up to removal of these smelters of interest from their supply chain. Information about these smelters/refiners lacked a chain of custody and therefore were insufficient to tie 3TGs from one or more of these smelters directly to products supplied to Allegion.

 

Additionally, suppliers were evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Guidance and can assist in making key risk mitigation decisions as the program progresses.

 

The criteria used to evaluate the strength of the program were based on these four questions in the CMRT:

 

·Have you established a responsible minerals sourcing policy?
·Have you implemented due diligence measures for responsible sourcing?
·Do you review due diligence information received from your suppliers against your company’s expectations?
·Does your review process include corrective action management?

 

7 

 

 

When suppliers met or exceeded those criteria (by responding “Yes” to each of the above questions), they were deemed to have a strong program. When suppliers did not meet those criteria, they were deemed to have a weak program. As of April 4, 2025, 23.61% of our responsive suppliers were identified as having a “strong” program and 7.87% were identified as having a “weak” program. The remaining suppliers claimed no 3TGs.

 

STEP 3: Design and Implement a Strategy to Respond to Identified Risks

 

We provide periodic reports on the progress of our campaign process to our internal leadership. On an annual basis, we provide an update to the Executive Leadership Team about our conflict minerals program and have a separate meeting with senior leadership where we review the process, efforts, challenges, milestones and results before the final Form SD report is filed with the SEC.

 

We have also established a supplier risk management process that evaluates many factors and determines the next steps for concerning suppliers (including any need for renegotiation of supplier terms, termination of supplier relationships, creation of a remediation plan, etc.). Declarations (CMRTs) look retrospectively at materials procured throughout the calendar year and at the time a CMRT is provided, material from smelters may already be part of the Company’s supply chain and products. Requests for immediate removal of a smelter of concern from the CMRT and supply chain may not be practical but may inform future purchases. The CMRT must accurately reflect past sourcing in order to support appropriate, ongoing due diligence and monitor changes over time.

 

As minerals and metals are durable goods, production may include feedstock purchased several months prior. As a result, high-risk or inoperative smelters may continue to appear on downstream CMRTs even if upstream suppliers no longer engage in business with these smelters. In many cases, this accurately reflects the continued downstream use of metal originally processed by these smelters in the past, either before smelter risks were identified or before smelter operations ceased. We are working with Assent and our suppliers to identify these situations and work to ensure that our suppliers cease doing business with high-risk smelters/refiners or encourage such smelters/refiners to participate in RMI and undergo an RMAP assessment and audit.

 

STEP 4: Utilize Independent Third-Party Audits of Supply Chain Diligence Practices

 

While we do not have a team of resources to independently audit the smelters/refiners within our supply chain, we have partnered with Assent, a third-party software and regulatory consulting company, who performs verification activities of smelters/refiners across the globe as part of their business services for Allegion. We also rely on RMAP, which performs third-party audits of smelters/refiners and certifies their status.

 

8 

 

 

STEP 5: Publicly Report on Supply Chain Due Diligence

 

We have made continual progress in our risk assessment and due diligence related to conflict minerals. While progress has been made, we were unable to determine with certainty that all the conflict minerals contained in our products are from conflict-free sources due to, among other things, the following:

 

·Several of our suppliers identified smelters/refiners that do not participate in the RMAP or a similar program, and other suppliers failed to identify any smelters/refiners in their responses to us. Furthermore, we were unable to obtain responses from all our suppliers, and some suppliers provided incomplete or inconsistent data.

 

·Many of our suppliers submitted responses that were declared on a company-wide basis (i.e., representing the smelters and refiners associated with all product offerings of the supplier that contained conflict minerals) and not specific to the materials supplied to Allegion. Therefore, in combination with multiple layers in our supply chain, we believe these declarations might include smelters and refiners that do not provide the conflict minerals that are in our products.

 

As a result, we do not have sufficient information to conclusively determine the country-of-origin of all the conflict minerals in our products and, if such conflict minerals did originate in the Covered Countries, whether such conflict minerals were from recycled or scrap sources or were from other conflict-free sources.

 

2024 Results

 

For 2024, we received responses representing approximately 85% of the supplier spend surveyed. We received 314 CMRTs. Of those received, 310 were validated as complete and provide the basis for our list of Reported Entities. Based on the due diligence process described herein and the information provided by our suppliers, we believe, to the extent reasonably determinable by us, that the facilities used to process the conflict minerals in our products or the other sources of the conflict minerals in our products consist of the following 343 entities (listed in the Reported Entities section), and that we have categorized as follows:

 

·212 smelters were classified as “RMAP Conformant”
·94 smelters had a status of “Not Enrolled”
·5 smelters are “RMAP Active”
·32 smelters are “Non-Conformant”

 

Smelters and Refiners Gold Tantalum Tin Tungsten Total
Overall Number of Smelters 181 36 71 55 343
Number of RMAP Conformant 92 33 52 35 212
% of RMAP Conformant 51% 92% 73% 64% 62%

 

“RMAP Conformant” means the smelter has successfully completed a RMAP audit and maintains good standing in the program, through a continual validation process. These smelters or refiners have the systems and processes in place to support responsible sourcing of raw materials and can provide evidence to support their sourcing activities.

 

9 

 

 

Due Diligence Determination

 

For the reasons stated in this report, we do not have sufficient information to conclusively determine the country-of-origin of all the conflict minerals in our products and, if such conflict minerals did originate in the Covered Countries, whether such conflict minerals were from recycled or scrap sources or were from other conflict-free sources.

 

We have provided this information as of the date of this report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to provide us with complete information, may affect our future determinations under the Rule.

 

Independent Private Sector Audit

 

As permitted by the Rule and the SEC’s guidance with respect thereto, we did not obtain an independent private-sector audit of this Conflict Minerals Report.

 

Future Initiatives

 

We continue to execute several initiatives to enhance our conflict minerals program, such as:

 

·Continued education and training both for our Company and our supply chain
·Continued partnerships with industry groups and subject matter experts to define and improve best practices and build leverage over our supply chain
·Continued engagement with our suppliers to obtain current, accurate and complete information from them and their upstream supply chain, and encourage suppliers to discontinue use of high-risk smelters/refiners or encourage such smelters/refiners to participate in RMI and undergo an RMAP assessment and audit
·Continued engagement with our third-party software solution and consulting company who are working on independently verifying smelters outside of the RMI smelter certification program

 

10 

 

 

Reported Entities

 

The below table contains a list of confirmed smelters and refiners included in the CMRTs submitted by our suppliers.

 

Metal Smelter Name Smelter Country Smelter ID
Gold 8853 S.p.A. Italy CID002763
Gold ABC Refinery Pty Ltd. Australia CID002920
Gold Abington Reldan Metals, LLC USA CID002708
Gold Advanced Chemical Company USA CID000015
Gold African Gold Refinery Uganda CID003185
Gold Agosi AG Germany CID000035
Gold Aida Chemical Industries Co., Ltd. Japan CID000019
Gold Al Etihad Gold Refinery DMCC United Arab Emirates CID002560
Gold Albino Mountinho Lda. Portugal CID002760
Gold Alexy Metals USA CID003500
Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan CID000041
Gold AngloGold Ashanti Corrego do Sitio Mineracao 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. USA CID000920
Gold Asaka Riken Co., Ltd. Japan CID000090
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey CID000103
Gold Attero Recycling Pvt Ltd India CID004697
Gold AU Traders and Refiners South Africa CID002850
Gold Augmont Enterprises Private Limited India CID003461
Gold Aurubis AG Germany CID000113
Gold Bangalore Refinery India CID002863
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines CID000128
Gold Boliden Ronnskar Sweden CID000157
Gold C. Hafner GmbH + Co. KG Germany CID000176
Gold Caridad Mexico CID000180
Gold CCR Refinery - Glencore Canada Corporation Canada CID000185
Gold Cendres + Metaux S.A. Switzerland CID000189
Gold CGR Metalloys Pvt Ltd. India CID003382
Gold Chimet S.p.A. Italy CID000233

 

11 

 

 

Metal Smelter Name Smelter Country Smelter ID
Gold Chugai Mining Japan CID000264
Gold Coimpa Industrial LTDA Brazil CID004010
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 Dongwu Gold Group China CID003663
Gold Dowa Japan CID000401
Gold DSC (Do Sung Corporation) Republic of Korea CID000359
Gold Eco-System Recycling Co., Ltd. East Plant Japan CID000425
Gold Eco-System Recycling Co., Ltd. North Plant Japan CID003424
Gold Eco-System Recycling Co., Ltd. West Plant Japan CID003425
Gold Elite Industech Co., Ltd. Taiwan CID004755
Gold Emerald Jewel Industry India Limited (Unit 1) India CID003487
Gold Emerald Jewel Industry India Limited (Unit 2) India CID003488
Gold Emerald Jewel Industry India Limited (Unit 3) India CID003489
Gold Emerald Jewel Industry India Limited (Unit 4) India CID003490
Gold Emirates Gold DMCC United Arab Emirates CID002561
Gold Fidelity Printers and Refiners Ltd. Zimbabwe CID002515
Gold Fujairah Gold FZC United Arab Emirates CID002584
Gold GG Refinery Ltd. Tanzania CID004506
Gold GGC Gujrat Gold Centre Pvt. Ltd. India CID002852
Gold Gold by Gold Colombia Colombia CID003641
Gold Gold Coast Refinery Ghana CID003186
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 Heimerle + Meule GmbH Germany CID000694
Gold Heraeus Germany GmbH Co. KG Germany CID000711
Gold Heraeus Metals Hong Kong Ltd. China CID000707
Gold Hunan Chenzhou Mining Co., Ltd. China CID000767
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China CID000773
Gold HwaSeong CJ CO., LTD. Republic of Korea CID000778

 

12 

 

 

Metal Smelter Name Smelter Country Smelter ID
Gold Impala Platinum - Platinum Metals Refinery (PMR) South Africa CID004714
Gold Impala Refineries – Base Metals Refinery (BMR) South Africa CID004604
Gold Impala Rustenburg South Africa CID004610
Gold Industrial Refining Company Belgium CID002587
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 JALAN & Company India CID002893
Gold Japan Mint Japan CID000823
Gold Jiangxi Copper Co., Ltd. China CID000855
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russia CID000927
Gold JSC Novosibirsk Refinery Russia CID000493
Gold JSC Uralelectromed Russia CID000929
Gold JX Nippon Mining & Metals Co., Ltd. Japan CID000937
Gold K.A. Rasmussen Norway CID003497
Gold Kaloti Precious Metals United Arab Emirates CID002563
Gold Kazakhmys Smelting LLC Kazakhstan CID000956
Gold Kazzinc Kazakhstan CID000957
Gold Kennecott Utah Copper LLC USA CID000969
Gold KGHM Polska Miedz Spolka Akcyjna Poland CID002511
Gold Kojima Chemicals Co., Ltd. Japan CID000981
Gold Korea Zinc Co., Ltd. Republic of Korea CID002605
Gold Kundan Care Products Ltd. India CID003463
Gold Kyrgyzaltyn JSC Kyrgyzstan CID001029
Gold Kyshtym Copper-Electrolytic Plant ZAO Russia 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 MnM Inc. Republic of Korea CID001078
Gold LT Metal Ltd. Republic of Korea CID000689

 

13 

 

 

Metal Smelter Name Smelter Country Smelter ID
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China CID001093
Gold Marsam Metals Brazil CID002606
Gold Materion USA CID001113
Gold Matsuda Sangyo Co., Ltd. Japan CID001119
Gold MD Overseas India CID003548
Gold Metal Concentrators SA (Pty) Ltd. South Africa CID003575
Gold Metallix Refining Inc. USA CID003557
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 USA CID001157
Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico CID001161
Gold Mitsubishi Materials Corporation Japan CID001188
Gold Mitsui Mining and Smelting Co., Ltd. Japan CID001193
Gold MKS PAMP SA Switzerland CID001352
Gold MMTC-PAMP India Pvt., Ltd. India CID002509
Gold Modeltech Sdn Bhd Malaysia CID002857
Gold Morris and Watson New Zealand CID002282
Gold Moscow Special Alloys Processing Plant Russia CID001204
Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey CID001220
Gold Navoi Mining and Metallurgical Combinat Uzbekistan CID001236
Gold NH Recytech Company Republic of Korea CID003189
Gold Nihon Material Co., Ltd. Japan CID001259
Gold NOBLE METAL SERVICES USA CID003690
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria CID002779
Gold Ohura Precious Metal Industry Co., Ltd. Japan CID001325
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russia CID001326
Gold Pease & Curren USA 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 Russia CID001386
Gold PT Aneka Tambang (Persero) Tbk Indonesia CID001397
Gold PX Precinox S.A. Switzerland CID001498
Gold QG Refining, LLC USA CID003324

 

14 

 

 

Metal Smelter Name Smelter Country Smelter ID
Gold Rand Refinery (Pty) Ltd. South Africa CID001512
Gold Refinery of Seemine Gold Co., Ltd. China CID000522
Gold REMONDIS PMR B.V. Netherlands CID002582
Gold Royal Canadian Mint Canada CID001534
Gold SAAMP France CID002761
Gold Sabin Metal Corp. USA CID001546
Gold Safimet S.p.A Italy CID002973
Gold SAFINA A.S. Czechia CID002290
Gold Sai Refinery India CID002853
Gold Sam Precious Metals United Arab Emirates CID003666
Gold Samduck Precious Metals Republic of Korea CID001555
Gold Samwon Metals Corp. Republic of Korea CID001562
Gold SEMPSA Joyeria Plateria S.A. Spain CID001585
Gold Shandong Gold Smelting Co., Ltd. China CID001916
Gold Shandong Humon Smelting Co., Ltd. China CID002525
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China CID001619
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China CID001622
Gold Shenzhen CuiLu Gold Co., Ltd. China CID002750
Gold SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. China CID004435
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China CID002527
Gold Shirpur Gold Refinery Ltd. India CID002588
Gold Sichuan Tianze Precious Metals Co., Ltd. China CID001736
Gold Singway Technology Co., Ltd. Taiwan CID002516
Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russia CID001756
Gold Solar Applied Materials Technology Corp. Taiwan CID001761
Gold Sovereign Metals India CID003383
Gold State Research Institute Center for Physical Sciences and Technology Lithuania CID003153
Gold Sudan Gold Refinery Sudan CID002567
Gold Sumitomo Metal Mining Co., Ltd. Japan CID001798
Gold SungEel HiMetal Co., Ltd. Republic of Korea CID002918
Gold Super Dragon Technology Co., Ltd. Taiwan CID001810

 

15 

 

 

Metal Smelter Name Smelter Country Smelter ID
Gold T.C.A S.p.A Italy CID002580
Gold Tanaka Kikinzoku Kogyo K.K. Japan CID001875
Gold Tokuriki Honten Co., Ltd. Japan CID001938
Gold Tongling Nonferrous Metals Group Co., Ltd. China CID001947
Gold TOO Tau-Ken-Altyn Kazakhstan CID002615
Gold Torecom Republic of Korea CID001955
Gold Umicore Precious Metals Thailand Thailand CID002314
Gold Umicore S.A. Business Unit Precious Metals Refining Belgium CID001980
Gold United Precious Metal Refining, Inc. USA CID001993
Gold Valcambi S.A. Switzerland CID002003
Gold WEEEREFINING France CID003615
Gold Western Australian Mint (T/a The Perth Mint) Australia CID002030
Gold WIELAND Edelmetalle GmbH Germany CID002778
Gold Yamakin 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 5D Production OU Estonia CID003926
Tantalum AMG Brasil Brazil CID001076
Tantalum D Block Metals, LLC USA CID002504
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 USA CID002557
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. China CID000291
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China CID002492
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China CID002512
Tantalum Jiangxi Sanshi Nonferrous Metals Co., Ltd China CID004813
Tantalum Jiangxi Tuohong New Raw Material China CID002842
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

 

16 

 

 

Metal Smelter Name Smelter Country Smelter ID
Tantalum KEMET de Mexico Mexico CID002539
Tantalum Materion Newton Inc. USA CID002548
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 PowerX Ltd. Rwanda CID004054
Tantalum QuantumClean USA CID001508
Tantalum Resind Industria e Comercio Ltda. Brazil CID002707
Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. China CID003583
Tantalum Solikamsk Magnesium Works OAO Russia CID001769
Tantalum Taki Chemical Co., Ltd. Japan CID001869
Tantalum TANIOBIS Co., Ltd. Thailand CID002544
Tantalum TANIOBIS GmbH Germany CID002545
Tantalum TANIOBIS Japan Co., Ltd. Japan CID002549
Tantalum TANIOBIS Smelting GmbH & Co. KG Germany CID002550
Tantalum Telex Metals USA CID001891
Tantalum Ulba Metallurgical Plant JSC Kazakhstan CID001969
Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED China CID000616
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China CID001522
Tin Alpha USA CID000292
Tin An Vinh Joint Stock Mineral Processing Company Vietnam CID002703
Tin Aurubis Beerse Belgium CID002773
Tin Aurubis Berango Spain CID002774
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 CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil CID003486
Tin CRM Synergies Spain CID003524
Tin CV Ayi Jaya Indonesia CID002570
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China CID003356

 

17 

 

 

Metal Smelter Name Smelter Country Smelter ID
Tin Dowa Japan CID000402
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Vietnam CID002572
Tin EM Vinto Bolivia CID000438
Tin Estanho de Rondonia S.A. Brazil CID000448
Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil CID003582
Tin Fenix Metals Poland CID000468
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China CID003410
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 Global Advanced Metals Greenbushes Pty Ltd. Australia CID004754
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China CID003116
Tin HuiChang Hill Tin Industry Co., Ltd. China CID002844
Tin Jiangxi New Nanshan Technology Ltd. China CID001231
Tin Longnan Chuangyue Environmental Protection Technology Development Co., Ltd China CID004796
Tin Luna Smelter, Ltd. Rwanda CID003387
Tin Ma'anshan Weitai Tin Co., Ltd. China CID003379
Tin Magnu's Minerais Metais e Ligas Ltda. Brazil CID002468
Tin Malaysia Smelting Corporation (MSC) Malaysia CID001105
Tin Malaysia Smelting Corporation Berhad (Port Klang) Malaysia CID004434
Tin Melt Metais e Ligas S.A. Brazil CID002500
Tin Metallic Resources, Inc. USA CID001142
Tin Mineracao Taboca S.A. Brazil CID001173
Tin Mining Minerals Resources SARL DRC CID004065
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 Vietnam CID002573
Tin Novosibirsk Tin Combine Russia CID001305
Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand CID001314
Tin O.M. Manufacturing Philippines, Inc. Philippines CID002517

 

18 

 

 

Metal Smelter Name Smelter Country Smelter ID
Tin Operaciones Metalurgicas S.A. Bolivia CID001337
Tin Pongpipat Company Limited Myanmar CID003208
Tin Precious Minerals and Smelting Limited India CID003409
Tin PT ATD Makmur Mandiri Jaya Indonesia CID002503
Tin PT Bangka Prima Tin Indonesia CID002776
Tin PT Cipta Persada Mulia Indonesia CID002696
Tin PT Mitra Stania Prima Indonesia CID001453
Tin PT Mitra Sukses Globalindo Indonesia CID003449
Tin PT Premium Tin Indonesia Indonesia CID000313
Tin PT Prima Timah Utama Indonesia CID001458
Tin PT Putera Sarana Shakti (PT PSS) Indonesia CID003868
Tin PT Rajehan Ariq Indonesia CID002593
Tin PT Timah Tbk Kundur Indonesia CID001477
Tin PT Timah Tbk Mentok Indonesia CID001482
Tin Resind Industria e Comercio Ltda. Brazil CID002706
Tin RIKAYAA GREENTECH PRIVATE LIMITED India CID004692
Tin Rui Da Hung Taiwan CID001539
Tin Super Ligas Brazil CID002756
Tin Takehara PVD Materials Plant/PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. Japan CID004403
Tin Thaisarco Thailand CID001898
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. China CID002180
Tin Tin Technology & Refining USA CID003325
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company Vietnam CID002574
Tin VQB Mineral and Trading Group JSC Vietnam CID002015
Tin White Solder Metalurgia e Mineracao Ltda. Brazil CID002036
Tin Woodcross Smelting Company Limited Uganda CID004724
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China CID002158
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China CID003397
Tungsten A.L.M.T. Corp. Japan CID000004
Tungsten ACL Metais Eireli Brazil CID002833
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil CID003427
Tungsten Artek LLC Russia CID003553

 

19 

 

 

Metal Smelter Name Smelter Country Smelter ID
Tungsten Asia Tungsten Products Vietnam Ltd. Vietnam CID002502
Tungsten China Molybdenum Tungsten Co., Ltd. China CID002641
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China CID000258
Tungsten CNMC (Guangxi) PGMA Co., Ltd. China CID000281
Tungsten Cronimet Brasil Ltda Brazil CID003468
Tungsten DONGKUK INDUSTRIES CO., LTD. Republic of Korea CID004060
Tungsten Fujian Xinlu Tungsten Co., Ltd. China CID003609
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China CID002315
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China CID002494
Tungsten Global Tungsten & Powders LLC USA CID000568
Tungsten Guangdong Xianglu Tungsten Co., Ltd. China CID000218
Tungsten H.C. Starck Tungsten GmbH Germany CID002541
Tungsten HANNAE FOR T Co., Ltd. Republic of Korea CID003978
Tungsten Hubei Green Tungsten Co., Ltd. China CID003417
Tungsten Hunan Jintai New Material Co., Ltd. China CID000769
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch China CID002513
Tungsten Hydrometallurg, JSC Russia CID002649
Tungsten Japan New Metals Co., Ltd. Japan CID000825
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China CID002551
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 JSC "Kirovgrad Hard Alloys Plant" Russia CID003408
Tungsten Kenee Mining Corporation Vietnam Vietnam CID004619
Tungsten Kennametal Fallon USA CID000966
Tungsten Kennametal Huntsville USA CID000105
Tungsten Lianyou Metals Co., Ltd. Taiwan CID003407
Tungsten Lianyou Resources Co., Ltd. Taiwan CID004397
Tungsten LLC Vostok Russia CID003643
Tungsten MALAMET SMELTING SDN. BHD. Malaysia CID004056
Tungsten Malipo Haiyu Tungsten Co., Ltd. China CID002319

 

20 

 

 

Metal Smelter Name Smelter Country Smelter ID
Tungsten Masan High-Tech Materials Vietnam CID002543
Tungsten Moliren Ltd. Russia CID002845
Tungsten Nam Viet Cromit Joint Stock Company Vietnam CID004034
Tungsten Niagara Refining LLC USA CID002589
Tungsten NPP Tyazhmetprom LLC Russia CID003416
Tungsten OOO “Technolom” 1 Russia CID003614
Tungsten OOO “Technolom” 2 Russia CID003612
Tungsten Philippine Bonway Manufacturing Industrial Corporation Philippines CID004797
Tungsten Philippine Carreytech Metal Corp. Philippines CID004438
Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines CID002827
Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. China CID004430
Tungsten TANIOBIS Smelting GmbH & Co. KG Germany CID002542
Tungsten Tungsten Vietnam Joint Stock Company Vietnam CID003993
Tungsten Unecha Refractory metals plant Russia CID002724
Tungsten Wolfram Bergbau und Hutten AG Austria CID002044
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China CID002320
Tungsten Xiamen Tungsten Co., Ltd. China CID002082
Tungsten YUDU ANSHENG TUNGSTEN CO., LTD. China CID003662

 

21