EX-1.01 2 donaldson171610_ex1-01.htm CONFLICT MINERALS REPORT

Exhibit 1.01

 

Conflict Minerals Report of Donaldson Company, Inc.

In accord with Rule 13p-1 under the Securities Exchange Act of 1934

 

  1. Introduction and Summary

 

This report for the year ended December 31st 2016 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements pursuant to Section 13(p) of the Securities and Exchange Act of 1934 (“Section 13(p)”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. The term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (“Conflict Minerals”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. These requirements apply to registrants regardless of the geographic origin of the Conflict Minerals or whether they fund armed conflict.

 

Donaldson Company, Inc. (“Donaldson” or “the Company”) determined that Conflict Minerals were necessary to the functionality or production of products that we manufactured or contracted to be manufactured during the 2016 calendar year. Therefore, Donaldson conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the Conflict Minerals in its products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”). Based on its RCOI, Donaldson has concluded that it cannot exclude the possibility that its products contain Conflict Minerals that originated in the Covered Countries and, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the Conflict Minerals in question to determine whether its products are “DRC Conflict Free”. Donaldson designed its due diligence measures to conform, in all material respects, with the nationally recognized due diligence 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, second edition and the related Supplements for gold and for tin, tantalum and tungsten (the “OECD Guidance”). As a result of our due diligence efforts, the Company has concluded some of the Conflict Minerals for the Company’s products originated in, or may have originated in, the Covered Countries and were not from recycled or scrap sources. The Company did not receive responses from all companies in its supply chain and most of the responses were at the company or division level.

 

  2. Company Overview

 

Donaldson was founded in 1915 and organized in its present corporate form under the laws of the State of Delaware in 1936.

 

The Company is a worldwide manufacturer of filtration systems and replacement parts. The Company’s core strengths are leading filtration technology, strong customer relationships and its global presence. Products are manufactured at 44 plants around the world and through three joint ventures.

 

  3. Product Description

 

The Company has two reporting segments: Engine Products and Industrial Products. Products in the Engine Products segment consist of air filtration systems, exhaust and emissions systems, liquid filtration systems including hydraulics, fuel, and lube systems as well as replacement filters. The Engine Products segment sells to original equipment manufacturers (“OEMs”) in the construction, mining, agriculture, aerospace, defense, and truck markets, and to independent distributors, OEM dealer networks, private label accounts, and large equipment fleets. Products in the Industrial Products segment consist of dust, fume, and mist collectors, compressed air purification systems, air filtration systems for gas turbines, polytetrafluoroethylene (PTFE) membrane-based products, and specialized air filtration systems for applications including computer hard disk drives and semi-conductor manufacturing. The Industrial Products segment sells to various industrial dealers, distributors, OEMs of gas-fired turbines, and OEMs and end-users requiring clean air filtration solutions and replacement filters.

 

The Company manufactures and contracts to manufacture products containing Conflict Minerals. Conflict Minerals were identified in products from both of the Company’s reporting segments, Engine Products and Industrial Products.

 

The Company has adopted a Conflict Minerals Policy articulating our conflict minerals supply chain due diligence process and our commitment to our reporting obligations regarding conflict minerals:

 

 

 
 

Conflict Minerals Policy

The ongoing conflict in the Democratic Republic of the Congo (DRC) is fueled in part from trade of “conflict minerals,” which are defined as tantalum, tin, tungsten, and gold or any of their derivatives. Donaldson will work with our supply chain partners to take reasonable steps to assure Conflict Minerals are not sourced by Donaldson or our supply chain partners in a way that would directly or indirectly benefit armed groups responsible for serious human rights abuses in the DRC or adjoining countries. Donaldson expects that our suppliers will comply with our requests to provide statements and perform due diligence about the source of any Conflict Minerals in their products which are provided to us.

 

The Conflict Minerals policy is posted on the Company’s website:

https://secure.ethicspoint.com/domain/media/en/gui/19744/minerals.pdf

 

  4. Reasonable Country of Origin Inquiry

 

The Company developed a supply chain transparency program utilizing internal resources and a third-party vendor to allow for the identification of each Smelter or Refiner (SOR) in the suppliers’ mineral supply chains.

 

Suppliers received an email via the third-party vendor system describing the compliance requirements and requesting Conflict Minerals, SOR information and also included instructions for providing requested supply chain information. Suppliers were requested to provide such SOR information through the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”) Conflict Minerals Reporting Template (“CMRT”), version 4.1 or higher.

 

An escalation process was initiated for suppliers who continued to be non-responsive after the above contacts were made. This process included direct emails to the non-responsive suppliers.

 

Following the suppliers submission of their CMRT, a data validation process was employed to increase the accuracy of submissions and identify contradictory answers in the CMRT. Suppliers were then contacted to address items such as the following:

 

· Incomplete data including missing SORs

 

· Responses that indicated a sourcing location without complete supporting information

 

Certain of the responses provided by suppliers on the CMRT included the names of facilities listed by the suppliers as smelters or refiners. The Company does not typically have a direct relationship with Conflict Minerals smelters and refiners and does not perform or direct audits of these entities within our supply chain. The Company’s third-party vendor compared the facilities listed in the responses to the list of smelters maintained by the Conflict Free Sourcing Initiative (CFSI). If a supplier indicated that the facility was certified as “Conflict-Free,” the third-party vendor confirmed that the name was listed by CFSI. Organizations that were identified by suppliers as SORs, but were invalid or undetermined, were contacted directly to clarify their status as an SOR.

 

Smelters and Refiners

Attached as Appendix A is a list of all of the validated SORs as identified by the Company’s supply chain in their submitted CMRTs that appear on the CFSI list. Because most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which SORs listed on Appendix A actually processed the Conflict Minerals contained in our products. Therefore, our list of processing SORs disclosed in Appendix A may contain more facilities than those that actually processed the Conflict Minerals contained in our products.

 

Country of Origin

Attached as Appendix B is a list of the countries of origin as identified by the CFSI for the SORs included in Appendix A.

 

  5. Due Diligence

 

The Company’s due diligence process is based on the Organization for Economic Cooperation and Development’s (“OECD’s”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, second edition and accompanying Supplements. It is important to note that the OECD Guidance was written for both upstream and downstream companies in the supply chain. Upstream companies refer to those between the mines and SORs. As such, the companies typically include mine operators, local traders, or exporters from the country of mineral origin, international concentrate traders, and SORs. Downstream companies refer to those entities between the SOR and retailer. As such, the companies typically include metal traders and exchanges, component manufacturers, product manufacturers, OEMs, and retailers. As the Company is a downstream company in the supply chain, its due diligence practices were tailored accordingly.

 

 
 

 

A summary of the due diligence measures undertaken by the Company is below:

 

Establish strong company management systems:

 

Internal Team

The Company’s management systems for Conflict Minerals covering the 2016 calendar year were sponsored by a Steering Committee whose members included the Vice President and Chief Financial Officer, Vice President and General Counsel, Vice President Global Operations, Senior Vice President Industrial Products and Senior Vice President Engine Products. Steering Committee members provide reports directly to the Audit Committee of the Board of Directors. The Steering Committee was supported by a Process Development Team consisting of subject matter experts from relevant functions such as Legal, Materials Compliance, Purchasing, Sales, Engineering, and Internal Audit.

 

Conflict Minerals Policy

The Company’s Conflict Minerals policy is publicly available at:

https://secure.ethicspoint.com/domain/media/en/gui/19744/minerals.pdf

 

Control Systems

Since we do not typically have a direct relationship with Conflict Minerals smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our business sector and other sectors, through our own efforts and those organized by trade associations. We also participate in or actively monitor the following industry-wide initiatives to disclose upstream parties in the supply chain: Member of the Electronics Industry Citizenship Coalition-Global e-Sustainability Initiative’s (EICC-GeSI) Conflict Free Sourcing Initiative (CFSI), as well as other manufacturing industry consortiums including the National Association of Manufacturers (NAM), and the Manufacturers Alliance for Productivity and Innovation (MAPI).

 

Controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all Donaldson employees and third parties doing business with Donaldson, and our Policy regarding Conflict Minerals.

 

Supplier Engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 4.1 or higher and a third-party vendor’s web-based reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests. We continue to observe that a great deal of follow-up has been required with suppliers to educate them on the Rule, Donaldson’s Conflict Minerals policy, and our expectations for their supply chain due diligence and reporting.

 

This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized a third party educational tool and provided all in-scope suppliers access to the Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.

 

Grievance Mechanism

The Company continues to maintain a secured, third-party hosted, Company-level grievance mechanism accessible via the Company’s website: https://secure.ethicspoint.com/domain/media/en/gui/19744/index.html

 

Maintain Records

The Company maintained a policy that documentation related to our Conflict Minerals compliance process will be retained for a period of at least five years.

 

Identify and assess risks in the supply chain:

 

The SORs and countries of origin listed by suppliers were matched against a database of verified SORs and associated mines. Verified SORs were matched against available lists of processors that have been certified by CFSI’s internationally-recognized industry validation scheme, the Conflict-Free Smelter Program (CFSP).

 

If the SOR was not certified by the CFSP, research was conducted to gain more information about the SOR’s sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes the SOR had taken to track the chain-of-custody on the source of its mineral ores.

 

Based on the smelter lists provided by suppliers via the CMRTs and the CFSI-provided SOR sourcing information, the Company is aware that, in their supply chain, there are twenty-three identified smelters sourcing from the Covered Countries that are certified conflict-free and a number of other smelters sourcing from other countries that are not disclosed at this time but are also certified conflict-free smelters. Many of the responses provided by suppliers are at the company or division level indicating they are still unable to provide SORs specific to the materials supplied to Donaldson.

 

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 CFSI definition of a smelter or refiner of a Conflict Mineral is assigned a risk of high, medium or low based on three scoring criteria:

 

 
 

 

  • Geographic proximity to the DRC and covered countries;
  • Conflict-Free Smelter Program (CFSP) audit status;
  • Known or plausible evidence of unethical or conflict sourcing.

 

Per these criteria the following facilities have been identified as being of highest concern to the supply chain:

 

  • Tony Goetz NV - CID002587
  • Kaloti Precious Metals - CID002563
  • Phoenix Metals - CID002507 [NOTE: This smelter is no longer operational as of March 2017 per CFSI]
  • Universal Precious Metals Refining Zambia - CID002854
  • Fidelity Printers and Refiners - CID002515
  • Sudan Gold Refinery - CID002567

 

When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our third-party vendor, submissions that include any of the above facilities immediately receive a response instructing the supplier to take their own risk mitigation actions, including submission of product-specific CMRT to better identify the connection to products that they supply to Donaldson.

Additionally, suppliers are evaluated on program strength, which further assists in identifying risk in the supply chain. At this stage in Conflict Minerals compliance it is well-known that many companies are in the middle of the process and do not have many answers beyond “unknown”. It has been decided that penalizing or failing them for working through the process is likely not the best approach as it does not meet the goals or spirit of the Rule; however, evaluating and tracking the strength of the program does meet 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 supplier’s program are:

Does the supplier have a policy in place that includes DRC conflict-free sourcing?
Has the supplier implemented due diligence measures for conflict-free sourcing?
Does the supplier verify due diligence information received from its suppliers?
Does the supplier’s verification process include corrective action management?

 

When a supplier meets these criteria, the supplier is deemed to have a strong program. When a supplier does not meet these criteria, the supplier is deemed to have a weaker program.

We calculate supplier risk based on the chances that a supplier provides Conflict Minerals that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the SORs declared by that supplier on their CMRT.

As part of our risk management plan and to ensure suppliers understand our expectations, we have, through our third party, provided video and written training on Conflict Minerals and the CMRT. This training includes instructions on completing the form and one-on-one email and phone discussions with supplier personnel.

 

 

Design and implement a strategy to respond to identified risks:

 

The Company, in conjunction with a third-party vendor, identified, assessed, and responded to risks in the supply chain. The status of this process is reported on a regular basis to the Company’s senior management.

 

The Company worked with its third-party vendor to help improve the quality of the information provided to the Company by its supply chain and to help strengthen its Conflict Minerals programs through education and direct support. Where SOR risks were identified the actions taken were consistent with the Company’s Conflict Minerals policy.

 

As per 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 goal of progressive elimination of these risks from the supply chain. In addition, suppliers are guided to the educational tools available through our third-party vendor to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

 

Carry out independent third-party audit of smelter/refiners’ due diligence practices:

 

The Company does not have any direct relationship with SORs and does not perform or direct audits on SORs identified by our supply chain. Instead Donaldson relies on third-party audits performed by an internationally-recognized validation organization. Donaldson is a member of CFSI and therefore has access to CFSI’s audit program.

 

 
 

 

Report annually on supply chain due diligence:

 

The Form Specialized Disclosure (“Form SD”) and CMR are contained herein and are publicly available at https://ir.donaldson.com/financial-information/sec-filings/default.aspx

 

The Company believes that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the Conflict Minerals in our Covered Products (the products purchased or manufactured by Donaldson where conflict minerals are necessary to the functionality or production of the product).

 

  6. Steps to Improve Due Diligence

 

The Company will endeavor to improve upon its supply chain due diligence efforts through the following efforts:

 

· Continue to assess the presence of Conflict Minerals in its supply chain;

 

· Communicate expectations with regard to supplier performance, transparency, and sourcing;
   
· Continue to compare RCOI results to the most currently available information collected via independent conflict free smelter validation programs such as the EICC-GeSI Conflict Free Smelter program.

 

 

 
 

Appendix A – Smelter List

Metal  Standard Smelter Name  Smelter Facility Location  Smelter ID  CFSI Audit Status
Gold Abington Reldan Metals, LLC UNITED STATES CID002708 Active
Gold Advanced Chemical Company UNITED STATES CID000015 Compliant
Gold Aida Chemical Industries Co., Ltd. JAPAN CID000019 Compliant
Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES CID002560 Compliant
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY CID000035 Compliant
Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN CID000041 Compliant
Gold AngloGold Ashanti Córrego do Sítio Mineração BRAZIL CID000058 Compliant
Gold Argor-Heraeus S.A. SWITZERLAND CID000077 Compliant
Gold Asahi Pretec Corp. JAPAN CID000082 Compliant
Gold Asahi Refining Canada Ltd. CANADA CID000924 Compliant
Gold Asahi Refining USA Inc. UNITED STATES CID000920 Compliant
Gold Asaka Riken Co., Ltd. JAPAN CID000090 Compliant
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY CID000103 Not Enrolled
Gold AU Traders and Refiners SOUTH AFRICA CID002850 Compliant
Gold AURA-II UNITED STATES CID002851 Not Enrolled
Gold Aurubis AG GERMANY CID000113 Compliant
Gold Bangalore Refinery INDIA CID002863 Active
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES CID000128 Compliant
Gold Boliden AB SWEDEN CID000157 Compliant
Gold C. Hafner GmbH + Co. KG GERMANY CID000176 Compliant
Gold Caridad MEXICO CID000180 Not Enrolled
Gold CCR Refinery - Glencore Canada Corporation CANADA CID000185 Compliant
Gold Cendres + Métaux S.A. SWITZERLAND CID000189 Active
Gold Chimet S.p.A. ITALY CID000233 Compliant
Gold Chugai Mining JAPAN CID000264 Not Enrolled
Gold Daejin Indus Co., Ltd. KOREA, REPUBLIC OF CID000328 Compliant
Gold Daye Non-Ferrous Metals Mining Ltd. CHINA CID000343 Not Enrolled
Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY CID002867 Not Enrolled
Gold DODUCO GmbH GERMANY CID000362 Compliant
Gold Dowa JAPAN CID000401 Compliant
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF CID000359 Compliant
Gold Eco-System Recycling Co., Ltd. JAPAN CID000425 Compliant
Gold Elemetal Refining, LLC UNITED STATES CID001322 Compliant
Gold Emirates Gold DMCC UNITED ARAB EMIRATES CID002561 Compliant
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE CID002515 Not Enrolled
Gold Gansu Seemine Material Hi-Tech Co., Ltd. CHINA CID000522 Not Enrolled
Gold Geib Refining Corporation UNITED STATES CID002459 Active
Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA CID001909 Not Enrolled
Gold Guangdong Jinding Gold Limited CHINA CID002312 Not Enrolled
Gold Gujarat Gold Centre INDIA CID002852 Not Enrolled

 

 
 

 

Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA CID000651 Not Enrolled
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA CID000671 Not Enrolled
Gold Heimerle + Meule GmbH GERMANY CID000694 Compliant
Gold Heraeus Ltd. Hong Kong CHINA CID000707 Compliant
Gold Heraeus Precious Metals GmbH & Co. KG GERMANY CID000711 Compliant
Gold Hunan Chenzhou Mining Co., Ltd. CHINA CID000767 Not Enrolled
Gold Hwasung CJ Co., Ltd. KOREA, REPUBLIC OF CID000778 Not Enrolled
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA CID000801 Compliant
Gold Ishifuku Metal Industry Co., Ltd. JAPAN CID000807 Compliant
Gold Istanbul Gold Refinery TURKEY CID000814 Compliant
Gold Japan Mint JAPAN CID000823 Compliant
Gold Jiangxi Copper Co., Ltd. CHINA CID000855 Compliant
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION CID000927 Compliant
Gold JSC Uralelectromed RUSSIAN FEDERATION CID000929 Compliant
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN CID000937 Compliant
Gold Kaloti Precious Metals UNITED ARAB EMIRATES CID002563 Not Enrolled
Gold Kazakhmys Smelting LLC KAZAKHSTAN CID000956 Not Enrolled
Gold Kazzinc KAZAKHSTAN CID000957 Compliant
Gold Kennecott Utah Copper LLC UNITED STATES CID000969 Compliant
Gold KGHM Polska Miedź Spółka Akcyjna POLAND CID002511 Active
Gold Kojima Chemicals Co., Ltd. JAPAN CID000981 Compliant
Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF CID002605 Compliant
Gold Kyrgyzaltyn JSC KYRGYZSTAN CID001029 Compliant
Gold L’azurde Company For Jewelry SAUDI ARABIA CID001032 Not Enrolled
Gold Lingbao Gold Co., Ltd. CHINA CID001056 Not Enrolled
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA CID001058 Not Enrolled
Gold L’Orfebre S.A. ANDORRA CID002762 Not Enrolled
Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF CID001078 Compliant
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA CID001093 Not Enrolled
Gold Materion UNITED STATES CID001113 Compliant
Gold Matsuda Sangyo Co., Ltd. JAPAN CID001119 Compliant
Gold Metalor Technologies (Hong Kong) Ltd. CHINA CID001149 Compliant
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE CID001152 Compliant
Gold Metalor Technologies (Suzhou) Ltd. CHINA CID001147 Compliant
Gold Metalor Technologies S.A. SWITZERLAND CID001153 Compliant
Gold Metalor USA Refining Corporation UNITED STATES CID001157 Compliant
Gold Metalúrgica Met-Mex Peñoles S.A. De C.V. MEXICO CID001161 Compliant
Gold Mitsubishi Materials Corporation JAPAN CID001188 Compliant
Gold Mitsui Mining and Smelting Co., Ltd. JAPAN CID001193 Compliant
Gold MMTC-PAMP India Pvt., Ltd. INDIA CID002509 Compliant
Gold Modeltech Sdn Bhd MALAYSIA CID002857 Not Enrolled

 

 
 

 

Gold Morris and Watson NEW ZEALAND CID002282 Not Enrolled
Gold Morris and Watson Gold Coast AUSTRALIA CID002866 Not Enrolled
Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION CID001204 Compliant
Gold Nadir Metal Rafineri San. Ve Tic. A.Ş. TURKEY CID001220 Compliant
Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN CID001236 Active
Gold Nihon Material Co., Ltd. JAPAN CID001259 Compliant
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA CID002779 Compliant
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN CID001325 Compliant
Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) RUSSIAN FEDERATION CID001326 Compliant
Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION CID000493 Compliant
Gold PAMP S.A. SWITZERLAND CID001352 Compliant
Gold Pease & Curren UNITED STATES CID002872 Not Enrolled
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA CID001362 Not Enrolled
Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION CID001386 Compliant
Gold PT Aneka Tambang (Persero) Tbk INDONESIA CID001397 Compliant
Gold PX Précinox S.A. SWITZERLAND CID001498 Compliant
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA CID001512 Compliant
Gold Remondis Argentia B.V. NETHERLANDS CID002582 Not Enrolled
Gold Republic Metals Corporation UNITED STATES CID002510 Compliant
Gold Royal Canadian Mint CANADA CID001534 Compliant
Gold SAAMP FRANCE CID002761 Not Enrolled
Gold Sabin Metal Corp. UNITED STATES CID001546 Not Enrolled
Gold SAFINA A.S. CZECH REPUBLIC CID002290 Not Enrolled
Gold Sai Refinery INDIA CID002853 Not Enrolled
Gold Samduck Precious Metals KOREA, REPUBLIC OF CID001555 Compliant
Gold SAMWON Metals Corp. KOREA, REPUBLIC OF CID001562 Not Enrolled
Gold SAXONIA Edelmetalle GmbH GERMANY CID002777 Compliant
Gold Schone Edelmetaal B.V. NETHERLANDS CID001573 Compliant
Gold SEMPSA Joyería Platería S.A. SPAIN CID001585 Compliant
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA CID001619 Not Enrolled
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA CID001622 Compliant
Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA CID001736 Compliant
Gold Singway Technology Co., Ltd. TAIWAN CID002516 Compliant
Gold So Accurate Group, Inc. UNITED STATES CID001754 Not Enrolled
Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION CID001756 Compliant
Gold Solar Applied Materials Technology Corp. TAIWAN CID001761 Compliant
Gold Sudan Gold Refinery SUDAN CID002567 Not Enrolled
Gold Sumitomo Metal Mining Co., Ltd. JAPAN CID001798 Compliant
Gold SungEel HiTech KOREA, REPUBLIC OF CID002918 Active
Gold T.C.A S.p.A ITALY CID002580 Compliant
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN CID001875 Compliant

 

 
 

 

Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA CID001916 Compliant
Gold Tokuriki Honten Co., Ltd. JAPAN CID001938 Compliant
Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA CID001947 Not Enrolled
Gold Tony Goetz NV BELGIUM CID002587 Active
Gold TOO Tau-Ken-Altyn KAZAKHSTAN CID002615 Not Enrolled
Gold Torecom KOREA, REPUBLIC OF CID001955 Compliant
Gold Umicore Brasil Ltda. BRAZIL CID001977 Compliant
Gold Umicore Precious Metals Thailand THAILAND CID002314 Compliant
Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM CID001980 Compliant
Gold United Precious Metal Refining, Inc. UNITED STATES CID001993 Compliant
Gold Universal Precious Metals Refining Zambia ZAMBIA CID002854 Not Enrolled
Gold Valcambi S.A. SWITZERLAND CID002003 Compliant
Gold Western Australian Mint trading as The Perth Mint AUSTRALIA CID002030 Compliant
Gold WIELAND Edelmetalle GmbH GERMANY CID002778 Compliant
Gold Yamamoto Precious Metal Co., Ltd. JAPAN CID002100 Compliant
Gold Yokohama Metal Co., Ltd. JAPAN CID002129 Compliant
Gold Yunnan Copper Industry Co., Ltd. CHINA CID000197 Not Enrolled
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA CID002224 Compliant
Gold Zijin Mining Group Co., Ltd. Gold Refinery CHINA CID002243 Compliant
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA CID000211 Compliant
Tantalum Conghua Tantalum and Niobium Smeltry CHINA CID000291 Compliant
Tantalum D Block Metals, LLC UNITED STATES CID002504 Compliant
Tantalum Duoluoshan CHINA CID000410 Compliant
Tantalum Exotech Inc. UNITED STATES CID000456 Compliant
Tantalum F&X Electro-Materials Ltd. CHINA CID000460 Compliant
Tantalum FIR Metals & Resource Ltd. CHINA CID002505 Compliant
Tantalum Global Advanced Metals Aizu JAPAN CID002558 Compliant
Tantalum Global Advanced Metals Boyertown UNITED STATES CID002557 Compliant
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA CID000616 Compliant
Tantalum H.C. Starck Co., Ltd. THAILAND CID002544 Compliant
Tantalum H.C. Starck GmbH Goslar GERMANY CID002545 Compliant
Tantalum H.C. Starck GmbH Laufenburg GERMANY CID002546 Not Enrolled
Tantalum H.C. Starck Hermsdorf GmbH GERMANY CID002547 Compliant
Tantalum H.C. Starck Inc. UNITED STATES CID002548 Compliant
Tantalum H.C. Starck Ltd. JAPAN CID002549 Compliant
Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY CID002550 Compliant
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA CID002492 Compliant
Tantalum Hi-Temp Specialty Metals, Inc. UNITED STATES CID000731 Compliant
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA CID002512 Compliant
Tantalum Jiangxi Tuohong New Raw Material CHINA CID002842 Compliant
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA CID000914 Compliant
Tantalum Jiujiang Tanbre Co., Ltd. CHINA CID000917 Compliant

 

 
 

 

Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA CID002506 Compliant
Tantalum KEMET Blue Metals MEXICO CID002539 Compliant
Tantalum KEMET Blue Powder UNITED STATES CID002568 Compliant
Tantalum King-Tan Tantalum Industry Ltd. CHINA CID000973 Compliant
Tantalum LSM Brasil S.A. BRAZIL CID001076 Compliant
Tantalum Metallurgical Products India Pvt., Ltd. INDIA CID001163 Compliant
Tantalum Mineração Taboca S.A. BRAZIL CID001175 Compliant
Tantalum Mitsui Mining & Smelting JAPAN CID001192 Compliant
Tantalum Molycorp Silmet A.S. ESTONIA CID001200 Compliant
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA CID001277 Compliant
Tantalum Plansee SE Liezen AUSTRIA CID002540 Not Enrolled
Tantalum Plansee SE Reutte AUSTRIA CID002556 Compliant
Tantalum Power Resources Ltd. MACEDONIA CID002847 Compliant
Tantalum QuantumClean UNITED STATES CID001508 Compliant
Tantalum Resind Indústria e Comércio Ltda. BRAZIL CID002707 Compliant
Tantalum RFH Tantalum Smeltry Co., Ltd. CHINA CID001522 Compliant
Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION CID001769 Compliant
Tantalum Taki Chemicals JAPAN CID001869 Compliant
Tantalum Telex Metals UNITED STATES CID001891 Compliant
Tantalum Tranzact, Inc. UNITED STATES CID002571 Compliant
Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN CID001969 Compliant
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA CID002508 Compliant
Tantalum Yichun Jin Yang Rare Metal Co., Ltd. CHINA CID002307 Compliant
Tantalum Zhuzhou Cemented Carbide Group Co., Ltd. CHINA CID002232 Compliant
Tin Alpha UNITED STATES CID000292 Compliant
Tin An Thai Minerals Co., Ltd. VIET NAM CID002825 Not Enrolled
Tin An Vinh Joint Stock Mineral Processing Company VIET NAM CID002703 Not Enrolled
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA CID000228 Compliant
Tin China Tin Group Co., Ltd. CHINA CID001070 Compliant
Tin CNMC (Guangxi) PGMA Co., Ltd. CHINA CID000278 Not Enrolled
Tin Cooperativa Metalurgica de Rondônia Ltda. BRAZIL CID000295 Compliant
Tin CV Ayi Jaya INDONESIA CID002570 Compliant
Tin CV Dua Sekawan INDONESIA CID002592 Compliant
Tin CV Gita Pesona INDONESIA CID000306 Compliant
Tin CV Serumpun Sebalai INDONESIA CID000313 Compliant
Tin CV Tiga Sekawan INDONESIA CID002593 Compliant
Tin CV United Smelting INDONESIA CID000315 Compliant
Tin CV Venus Inti Perkasa INDONESIA CID002455 Compliant
Tin Dowa JAPAN CID000402 Compliant
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company VIET NAM CID002572 Active
Tin Elmet S.L.U. SPAIN CID002774 Compliant

 

 
 

 

Tin EM Vinto BOLIVIA CID000438 Compliant
Tin Estanho de Rondônia S.A. BRAZIL CID000448 Not Enrolled
Tin Fenix Metals POLAND CID000468 Compliant
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA CID002848 Compliant
Tin Gejiu Jinye Mineral Company CHINA CID002859 Compliant
Tin Gejiu Kai Meng Industry and Trade LLC CHINA CID000942 Active
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA CID000538 Compliant
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA CID001908 Active
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA CID000555 Not Enrolled
Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA CID002849 Compliant
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA CID002844 Compliant
Tin Huichang Jinshunda Tin Co., Ltd. CHINA CID000760 Not Enrolled
Tin Jiangxi Ketai Advanced Material Co., Ltd. CHINA CID000244 Compliant
Tin Magnu’s Minerais Metais e Ligas Ltda. BRAZIL CID002468 Compliant
Tin Malaysia Smelting Corporation (MSC) MALAYSIA CID001105 Compliant
Tin Melt Metais e Ligas S.A. BRAZIL CID002500 Compliant
Tin Metallic Resources, Inc. UNITED STATES CID001142 Compliant
Tin Metallo-Chimique N.V. BELGIUM CID002773 Compliant
Tin Mineração Taboca S.A. BRAZIL CID001173 Compliant
Tin Minsur PERU CID001182 Compliant
Tin Mitsubishi Materials Corporation JAPAN CID001191 Compliant
Tin Modeltech Sdn Bhd MALAYSIA CID002858 Not Enrolled
Tin Nankang Nanshan Tin Manufactory Co., Ltd. CHINA CID001231 Active
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIET NAM CID002573 Not Enrolled
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND CID001314 Compliant
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES CID002517 Compliant
Tin Operaciones Metalurgical S.A. BOLIVIA CID001337 Compliant
Tin Phoenix Metal Ltd. RWANDA CID002507 Not Enrolled
Tin PT Aries Kencana Sejahtera INDONESIA CID000309 Compliant
Tin PT Artha Cipta Langgeng INDONESIA CID001399 Compliant
Tin PT ATD Makmur Mandiri Jaya INDONESIA CID002503 Compliant
Tin PT Babel Inti Perkasa INDONESIA CID001402 Compliant
Tin PT Bangka Prima Tin INDONESIA CID002776 Compliant
Tin PT Bangka Tin Industry INDONESIA CID001419 Compliant
Tin PT Belitung Industri Sejahtera INDONESIA CID001421 Compliant
Tin PT Bukit Timah INDONESIA CID001428 Compliant
Tin PT Cipta Persada Mulia INDONESIA CID002696 Compliant
Tin PT DS Jaya Abadi INDONESIA CID001434 Compliant
Tin PT Eunindo Usaha Mandiri INDONESIA CID001438 Compliant
Tin PT Inti Stania Prima INDONESIA CID002530 Compliant
Tin PT Justindo INDONESIA CID000307 Not Enrolled
Tin PT Karimun Mining INDONESIA CID001448 Compliant

 

 
 

 

Tin PT Kijang Jaya Mandiri INDONESIA CID002829 Compliant
Tin PT Lautan Harmonis Sejahtera INDONESIA CID002870 Compliant
Tin PT Mitra Stania Prima INDONESIA CID001453 Compliant
Tin PT O.M. Indonesia INDONESIA CID002757 Compliant
Tin PT Panca Mega Persada INDONESIA CID001457 Compliant
Tin PT Prima Timah Utama INDONESIA CID001458 Compliant
Tin PT Refined Bangka Tin INDONESIA CID001460 Compliant
Tin PT Sariwiguna Binasentosa INDONESIA CID001463 Compliant
Tin PT Stanindo Inti Perkasa INDONESIA CID001468 Compliant
Tin PT Sukses Inti Makmur INDONESIA CID002816 Compliant
Tin PT Sumber Jaya Indah INDONESIA CID001471 Compliant
Tin PT Timah (Persero) Tbk Kundur INDONESIA CID001477 Compliant
Tin PT Timah (Persero) Tbk Mentok INDONESIA CID001482 Compliant
Tin PT Tinindo Inter Nusa INDONESIA CID001490 Compliant
Tin PT Tommy Utama INDONESIA CID001493 Compliant
Tin PT Wahana Perkit Jaya INDONESIA CID002479 Compliant
Tin Resind Indústria e Comércio Ltda. BRAZIL CID002706 Compliant
Tin Rui Da Hung TAIWAN CID001539 Compliant
Tin Soft Metais Ltda. BRAZIL CID001758 Compliant
Tin Thaisarco THAILAND CID001898 Compliant
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIET NAM CID002574 Not Enrolled
Tin VQB Mineral and Trading Group JSC VIET NAM CID002015 Compliant
Tin White Solder Metalurgia e Mineração Ltda. BRAZIL CID002036 Compliant
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA CID002158 Active
Tin Yunnan Tin Company Limited CHINA CID002180 Compliant
Tungsten A.L.M.T. TUNGSTEN Corp. JAPAN CID000004 Compliant
Tungsten ACL Metais Eireli BRAZIL CID002833 Not Enrolled
Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM CID002502 Compliant
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA CID002513 Compliant
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA CID000258 Compliant
Tungsten Dayu Weiliang Tungsten Co., Ltd. CHINA CID000345 Not Enrolled
Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA CID000499 Compliant
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA CID000875 Compliant
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA CID002315 Compliant
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA CID002494 Compliant
Tungsten Ganzhou Yatai Tungsten Co., Ltd. CHINA CID002536 Not Enrolled
Tungsten Global Tungsten & Powders Corp. UNITED STATES CID000568 Compliant
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA CID000218 Compliant
Tungsten H.C. Starck GmbH GERMANY CID002541 Compliant
Tungsten H.C. Starck Smelting GmbH & Co.KG GERMANY CID002542 Compliant
Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA CID000766 Compliant
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA CID002579 Compliant

 

 
 

 

Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA CID000769 Compliant
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION CID002649 Compliant
Tungsten Japan New Metals Co., Ltd. JAPAN CID000825 Compliant
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA CID002551 Compliant
Tungsten Jiangxi Dayu Longxintai Tungsten Co., Ltd. CHINA CID002647 Not Enrolled
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA CID002321 Compliant
Tungsten Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. CHINA CID002313 Not Enrolled
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA CID002318 Compliant
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA CID002317 Compliant
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CHINA CID002535 Compliant
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA CID002316 Compliant
Tungsten Kennametal Fallon UNITED STATES CID000966 Compliant
Tungsten Kennametal Huntsville UNITED STATES CID000105 Compliant
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA CID002319 Compliant
Tungsten Moliren Ltd RUSSIAN FEDERATION CID002845 Compliant
Tungsten Niagara Refining LLC UNITED STATES CID002589 Compliant
Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC VIET NAM CID002543 Compliant
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES CID002827 Compliant
Tungsten South-East Nonferrous Metal Company Limited of Hengyang City CHINA CID002815 Compliant
Tungsten Tejing (Vietnam) Tungsten Co., Ltd. VIET NAM CID001889 Compliant
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION CID002724 Compliant
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd. VIET NAM CID002011 Compliant
Tungsten Wolfram Bergbau und Hütten AG AUSTRIA CID002044 Compliant
Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF CID002843 Compliant
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA CID002320 Compliant
Tungsten Xiamen Tungsten Co., Ltd. CHINA CID002082 Compliant
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA CID002830 Compliant
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA CID002095 Compliant

 

  

 
 

Appendix B – Countries of Origin

Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chili, China, Colombia, Cote D’lvoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States of America, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.