EX-1.01 2 exhibit101.htm EXHIBIT 1.01 Exhibit


EXHIBIT 1.01
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CONFLICT MINERALS REPORT OF HP INC.
PURSUANT TO RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934
 
HP Inc. (“HP”) presents this Conflict Minerals Report for the reporting period of January 1, 2016 to December 31, 2016 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission.

HP is a leading global provider of personal computing and other access devices, imaging and printing products, and related technologies, solutions and services. HP sells to individual consumers, small- and medium-sized businesses and large enterprises, including customers in the government, health and education sectors. Unless otherwise specified or unless the context otherwise requires, references to “HP,” “we,” “us” or “our” refer to HP Inc. and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear have the meanings given in Item 1.01 of Form SD.

Overview of our Conflict Minerals Program

As part of our long-standing commitment to sustainability, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner pursuant to HP’s Supply Chain Social and Environmental Responsibility Policy. In 2011, we added to this policy a section on conflict minerals. We engage in ongoing supplier outreach and communications regarding the substance of our conflict minerals policy, our expectations of suppliers with respect to conflict minerals, and our objective of responsible mineral sourcing. The policy is available on our website at http://h20195.www2.hp.com/V2/GetDocument.aspx?docname=c04797682.

HP has been recognized as an industry leader in the conflict minerals domain for the last nine years. HP collaboratively works with other businesses, nongovernmental organizations, government agencies, and our extensive network of direct suppliers to advance the use of responsibly sourced minerals, including from the Democratic Republic of the Congo (“DRC”) and adjoining countries (collectively, the “Covered Countries”). Our work began in 2008, when we helped establish the working group that was the precursor to the Conflict Free Sourcing Initiative (“CFSI”), and we have been instrumental since then in developing and advancing CFSI programs and tools such as the Conflict Free Smelter Program and the Conflict Minerals Reporting Template (the “Template”). HP also held a seat on the Electronics Industry Citizenship Coalition Board of Directors, which provided guidance to and oversight of CFSI. We contributed to the development of the Organisation for Economic Co-operation and Development (“OECD”) due diligence guidance and were a founding member of the Public Private Alliance for Responsible Mineral Trade as well as the Responsible Sourcing Network Multi-Stakeholder Group. We are a member of the European Partnership for Responsible Minerals and the Responsible Raw Materials Initiative. We were one of the first three companies to fund the Initial Audit Fund to offset part of the smelter audit cost. We also supported the initial piloting of the iTSCi traceability scheme for tin, and were a member of the Sustainable Trade Initiative (IDH) Indonesian Tin Working Group. We visited DRC mines and have participated in critical in-region conflict free sourcing projects including Solutions for Hope, Kemet Partnership for Social and Economic Stability, and the former Conflict Free Tin Initiative. For each year since 2014, we have been able to report that all tantalum smelters reported to be in our supply chain were compliant with the Conflict Free Smelter Program.

HP Products

Conflict minerals in the form of gold and the mineral derivatives tin, tantalum, and tungsten (collectively, “3TG”) are necessary to the functionality or production (“necessary conflict minerals”) of certain products. Typically, information technology products like ours contain very small amounts of tin, tantalum, tungsten, and/or gold. For example, the Massachusetts Institute of Technology (MIT) reported in 2014 that a typical laptop might contain 2 grams of tin, 1 gram of tungsten, and less than ¼ of gram of tantalum and gold.1 The products that we manufactured or contracted to manufacture during 2016 were:
____________________
1 Conflict Minerals in the Compute Sector: Estimating Extent of Tin, Tantalum, Tungsten, and Gold Use in ICT Products. Colin Fitzpatrick, Elsa Olivetti, T. Reed Miller, Richard Roth, and Randolph Kirchain. Environmental Science & Technology. December 2014.





•Personal Systems Products. Consumer and commercial personal computers, workstations, thin clients, commercial tablets and mobility devices, retail point-of-sale systems, displays and other related accessories.

•Printing Products. Consumer and commercial printer hardware (including 3D printing hardware), supplies, media, solutions and services, as well as scanning and imaging devices.

Design of Our Due Diligence Measures

We designed our due diligence measures to conform with applicable portions of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition, OECD 2016) and the related Supplements (collectively, the “OECD Guidance”), which is a nationally or internationally recognized due diligence framework. The design of our due diligence measures took into account our individual facts and circumstances, our downstream position in the minerals supply chain, the OECD recommendations for downstream actors that have no direct relationships to smelters or refiners.

Consistent with the OECD Guidance, the design of our due diligence has the following features:

1.Establishment of strong internal company management systems, including a conflict minerals policy; a Conflict Minerals Program team with senior management support; a Supply Chain Transparency System; engagement with 3TG Direct Suppliers3 to communicate and reinforce HP expectations with respect to necessary conflict minerals; and a company level grievance mechanism that is available internally and externally to report concerns, including those related to conflict minerals.

2.Identification and assessment of risks in the supply chain, including through the Supply Chain Transparency System, the mechanism by which risks are identified and assessed in the supply chain. The system is designed to support the Conflict Minerals Program team in systematically surveying, collecting, and analyzing information relating to 3TG facilities’4 use of necessary conflict minerals in the supply chain for our products.

3.Design and implementation of a strategy to respond to such risks as they are identified, including assessment of information on the due diligence practices of 3TG facilities, formulation of a risk management plan, and reporting to senior management.

4.Support of industry organizations to carry out independent third-party audits of facilities’ due diligence practices, including through our membership in CFSI, the industry initiative that conducts audits and assessments of facilities’ due diligence activities.

5.Annual reporting through this Conflict Minerals Report, supplemented with additional information about our Conflict Minerals Program in our annual Sustainability Report.

Description of Due Diligence Measures Performed

We undertook due diligence on the source and chain of custody of necessary conflict minerals from the relevant 3TG facilities (having excluded as a result of our reasonable country of origin inquiry, or “RCOI”, those 3TG facilities that we reasonably believe source conflict minerals exclusively from recycled or scrap sources or from outside of the Covered Countries) and reviewed the results with senior supply chain management, our Chief Supply Chain Officer.

As part of our due diligence measures:

•
we compared the relevant 3TG facilities to the facilities that are listed by CFSI as either compliant or in
____________________
2 The OECD Guidance distinguishes between “upstream” and “downstream” actors. Upstream refers to the minerals supply chain from the mine to the smelter or refiner, and upstream companies include miners, local traders or exporters, international concentrate traders, and mineral re-processors. Downstream refers to the minerals supply chain from smelters and refiners to retailers and includes companies like HP; it also includes metal traders, component manufacturers, product manufacturers, original equipment manufacturers and retailers.
3 3TG Direct Suppliers are HP’s direct suppliers of materials, parts, components or products containing necessary conflict minerals.
4 3TG facilities are those entities reported by our 3TG Direct Suppliers that are also identified by CFSI to be smelters, refiners, recyclers or scrap processors of conflict minerals






process5 with the Conflict Free Smelter Program, which assesses facilities’ systems and processes for traceability of ore and demonstration of conflict free sourcing;

•
we engaged facilities when sourcing was unknown (directly or through a third party) to provide conflict minerals education, collect information on necessary conflict minerals such as country of origin, or encourage participation in the Conflict Free Smelter Program;

•
if any 3TG Direct Supplier reported to us a facility for which we had information that triggered one of our potential risk indicators, then we requested the supplier investigate whether or not that facility contributed 3TG to HP products, and if the supplier reported that it did, we asked that the supplier remove the facility from our supply chain;

•
if we obtained information that indicated there was a potential risk associated with a particular facility, we sought information from industry sources, news and media, stakeholders, and other relevant sources to support our decisions and actions;

•
we reviewed the upstream incident review report produced by CFSI that assessed more than 800 medium or high risk mine-level incidents to assess whether there were incidents associated with facilities’ sourcing that might be linked, directly or indirectly, to supporting armed groups;

•
we supported the Conflict Free Smelter Program (member ID: HPQQ) through membership and participation in the CFSI; and

•
we asked 3TG Direct Suppliers to encourage the facilities in their supply chain to join the Conflict Free Smelter Program.

Results

We set forth below the results of our due diligence as well as our overall progress toward DRC conflict free products. First, we summarize the outcome of due diligence focused on the relevant 3TG facilities (i.e., the facilities that we did not reasonably believe were sourcing conflict minerals exclusively from recycled or scrap sources or from outside the Covered Countries). We then provide a year-over-year view of all of the supplier-reported 3TG facilities. Finally, we provide a snapshot of our overall progress toward DRC conflict free products resulting from our RCOI and due diligence efforts including a chart that highlights our progress by each 3TG metal as well as our total progress toward DRC conflict free products. In 2016, 90% of all 3TG facilities reported to us are compliant, in process to become compliant, and/or are reasonably believed to provide only conflict minerals from recycled or scrap sources or to source conflict minerals from outside the Covered Countries.

Due Diligence Results for Relevant 3TG Facilities

We began our inquiry by focusing on the 311 supplier-reported 3TG facilities. After conducting a RCOI on these 3TG facilities, we reasonably believe 49 of these 3TG facilities exclusively provided conflict minerals from recycled or scrap sources, and 179 sourced conflict minerals from outside of the Covered Countries. Attachment A to this Conflict Minerals Report includes the countries from which the 311 3TG facilities may have sourced necessary conflict minerals.

The remaining 83 3TG facilities underwent further due diligence on the source and chain of custody of conflict minerals as detailed in Chart 1 and below.


____________________
5 Throughout this Conflict Minerals Report, “in process” refers to facilities that are listed by CFSI as currently in the process of becoming Conflict Free Smelter Program compliant.





chart1.jpg

Based on further due diligence of the 83 relevant 3TG facilities, as of March 31, 2017 (the “2017 Cut-Off Date”):

•
52 facilities were listed by CFSI as compliant or in process to become compliant with the Conflict Free Smelter Program.

•
The remaining 31 facilities are not participating and we have limited information about their sourcing and operations. Further, we have not been able to determine if these facilities are processing necessary conflict minerals contained in our products.

HP’s 3TG Direct Suppliers have reported to us more than 95% of the facilities in the world (as recognized by CFSI). We doubt all of these facilities are contributing to the production of HP products. However, the over-reporting of facilities is a function of being several supply chain actors removed from the facilities and sub-tier suppliers refusing to provide customer-specific Templates to our suppliers. Accordingly, our due diligence has continued to be difficult and partially inconclusive.

Status of all Supplier-Reported 3TG Facilities

We also analyze our data set for information on the status of supplier-reported 3TG facilities and evaluate our overall progress by calculating how many of these facilities are listed as participating in or successfully completing an independent assessment program. Our suppliers reported a total of 311 3TG facilities in 2016, of which 260 are compliant with, or in




process to become compliant with, an independent assessment program. Of the remaining 3TG facilities that are not participating, we have reason to believe that 20 facilities are sourcing from outside the Covered Countries (CC) or are exclusively providing conflict minerals from recycled or scrap sources, leaving only the 31 3TG facilities with unknown status discussed above.

Attachment B to this Conflict Minerals Report sets forth the name and status of the 311 supplier-reported 3TG facilities. Chart 2 illustrates our year-over-year progress for all supplier-reported 3TG facilities.

chart2-1.jpg
Overall Progress toward DRC Conflict Free

Based on the RCOI we performed with respect to the 311 3TG facilities our suppliers reported to us and the additional due diligence on relevant 3TG facilities, 90% are now Conflict Free Smelter Program compliant or in process to become compliant, provide only conflict minerals from recycled or scrap sources, and/or are facilities that we reasonably believe source conflict minerals from outside of the Covered Countries. About 10% (31 facilities) have sourcing that is unknown and are not participating in an independent assessment program.

Chart 3 below further expands on our results by providing for each metal the number and percentage (as of the 2017 Cut-off Date) of all supplier-reported 3TG facilities that were either Conflict Free Smelter Program compliant or in process to become compliant, and/or that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries. All of the tantalum smelters reported to be in our supply chain are again compliant with the Conflict Free Smelter Program.





Chart 3: Overall Progress toward DRC Conflict Free by Metal
 
 
 
 
 
Total
Progress toward DRC Conflict Free6
Percentage
Tantalum Facilities
44
44
100%
Tin Facilities
82
75
91%
Tungsten Facilities
46
41
89%
Gold Facilities
139
120
86%
Total
311
280
90%

Efforts to Determine the Mine or Location of Origin with Greatest Possible Specificity

As a downstream actor, we rely upon independent assessment programs to collect and review the majority of the upstream information, such as the mine or location of origin of necessary conflict minerals. Consistent with the key role set forth by the OECD Guidance for downstream actors, our efforts to facilitate upstream mine or location of origin determinations were focused on supporting independent assessment programs such as the Conflict Free Smelter Program.

To determine the mine or location of origin of necessary conflict minerals, or to facilitate such determinations by independent assessment programs, we:

•
surveyed 3TG Direct Suppliers during the reporting period of this Conflict Minerals Report using the Template (which included questions about the mine or location of origin) and required those suppliers to make similar efforts to survey their supply chains using the Template;

•
reviewed the information we obtained on 3TG facilities, and any mine or location of origin information if it was provided; and

•
assessed any information on countries of origin available through our membership in CFSI for 3TG facilities (as part of the Conflict Free Smelter Program audit protocol, the independent auditor makes an examination of the countries of origin as well as the location of the mine, even if the specific mine or location of origin for these minerals within a given country is not provided to CFSI members).

Steps to Further Mitigate Risk and Improve Due Diligence in 2017

We plan to continue the following steps to further mitigate any risk that necessary conflict minerals in our products finance or benefit an armed group:

•
engage with 3TG Direct Suppliers to update information provided to us;

•
repeat our request that 3TG Direct Suppliers encourage facilities they have identified in their supply chains to join the Conflict Free Smelter Program; and

•
support the development of the CFSI’s Conflict Free Smelter Program, including outreach efforts to encourage participation in the program.

____________________
6 This column includes the number of 3TG facilities that (as of the 2017 Cut-Off Date) were either Conflict Free Smelter Program compliant or in process to become compliant, and/or that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries.





Attachment A
Countries of Origin

Based on information available from CSFI as of the 2017 Cut-Off Date and additional research by our external expert consultant, we believe that the countries of origin of the necessary conflict minerals from supplier-reported 3TG facilities may include the following countries.

Covered Countries
Outside Covered Countries
Burundi
Australia
Democratic Republic of the Congo
Austria
Rwanda
Benin
Tanzania
Bolivia
Uganda
Brazil
Zambia
Burkina Faso
 
Cambodia
 
Canada
 
Chile
 
China
 
Colombia
 
Ecuador
 
Eritrea
 
Ethiopia
 
France
 
French Guiana
 
Ghana
 
Guatemala
 
Guinea
 
Guyana
 
Honduras
 
India
 
Indonesia
 
Japan
 
Kazakhstan
 
Kyrgyzstan
 
Laos
 
Madagascar
 
Malaysia
 
Mali
 
Mexico
 
Mongolia
 
Mozambique
 
Myanmar
 
Namibia
 
New Zealand
 
Nicaragua
 
Nigeria
 
Panama
 
Peru




 
Poland
 
Portugal
 
Russia
 
Senegal
 
Sierra Leone
 
South Africa
 
Spain
 
Sudan
 
Tajikistan
 
Thailand
 
Togo
 
Turkey
 
United States of America
 
Uzbekistan
 
Vietnam
 
Zimbabwe





Attachment B

3TG Facility List

This 3TG Facility List sets forth the name, location and status of all of the 311 3TG facilities our suppliers reported to us. It is the result of our review of data from several sources, including information reported to us by 3TG Direct Suppliers, obtained through supplemental engagement with certain 3TG facilities, and from CFSI. In many cases, facility information was provided to us for the entire supply chain of 3TG Direct Suppliers, and did not identify with specificity those 3TG facilities believed to contribute necessary conflict minerals to an HP product.
Metal
Facility Name7
Facility Location8
Status9
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
In process
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Compliant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Compliant
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Compliant
Gold
AngloGold Ashanti Córrego do Sítio Minerção
BRAZIL
Compliant
Gold
Argor-Heraeus S.A.
SWITZERLAND
Compliant
Gold
Asahi Pretec Corp.
JAPAN
Compliant
Gold
Asahi Refining Canada Ltd.
CANADA
Compliant
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Compliant
Gold
Asaka Riken Co., Ltd.
JAPAN
Compliant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Not participating
Gold
AU Traders and Refiners
SOUTH AFRICA
Compliant
Gold
Aurubis AG
GERMANY
Compliant
Gold
Bangalore Refinery
INDIA
In process
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Compliant
Gold
Boliden AB
SWEDEN
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Compliant
Gold
Caridad
MEXICO
Not participating
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Compliant
Gold
Cendres + Métaux S.A.
SWITZERLAND
In process
Gold
Chimet S.p.A.
ITALY
Compliant
Gold
Chugai Mining
JAPAN
Not participating
Gold
Daejin Indus Co., Ltd.
KOREA (REPUBLIC OF)
Compliant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Not participating
____________________
7 Entities that have been reported to us by our 3TG Direct Suppliers as part of their supply chain for conflict minerals and that are recognized by CFSI (as of the 2017 Cut-Off Date) to be smelters, refiners, recyclers or scrap processors of conflict minerals (“3TG facilities”). The facility names are listed as they appear on the CFSI Smelter or Refiner Information Exchange. A company appears more than once if it was reported to us for more than one facility (i.e., smelter, refiner, recycler or scrap processor) that is providing different types of minerals or metals.
8 The facility locations are listed as they appear for each of the 3TG facilities on the CFSI Smelter or Refiner Information Exchange.
9 Compliant refers to 3TG facilities that are listed by CFSI (as of the 2017 Cut-Off Date) as (a) compliant with Conflict Free Smelter Program protocols or (b) certified or accredited by a similar independent assessment program such as the Responsible Jewellery Council’s (RJC) Chain-of-Custody Certification Program, or the London Bullion Market Association’s (LBMA) Responsible Gold Programme. In Process refers to 3TG facilities that are listed by CFSI (as of the 2017 Cut-Off Date) as currently in the process of becoming Conflict Free Smelter Program compliant. Not participating refers to 3TG facilities that are not engaged in an independent assessment program, including the Conflict Free Smelter Program.






Gold
DODUCO GmbH
GERMANY
Compliant
Gold
Dowa
JAPAN
Compliant
Gold
DSC (Do Sung Corporation)
KOREA (REPUBLIC OF)
Compliant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Compliant
Gold
Elemetal Refining, LLC
UNITED STATES OF AMERICA
Compliant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Compliant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Not participating
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Not participating
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Compliant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Not participating
Gold
Guangdong Jinding Gold Limited
CHINA
Not participating
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Not participating
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Not participating
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Not participating
Gold
HeeSung Metal Ltd.
KOREA (REPUBLIC OF)
In process
Gold
Heimerle + Meule GmbH
GERMANY
Compliant
Gold
Heraeus Ltd. Hong Kong
CHINA
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Compliant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Not participating
Gold
HwaSeong CJ Co., Ltd.
KOREA (REPUBLIC OF)
Not participating
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Compliant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
Istanbul Gold Refinery
TURKEY
Compliant
Gold
Japan Mint
JAPAN
Compliant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd
JAPAN
Compliant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Not participating
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Not participating
Gold
Kazzinc
KAZAKHSTAN
Compliant
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Compliant
Gold
KGHM Polska Miedz Spólka Akcyjna
POLAND
In process
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Compliant
Gold
Korea Zinc Co., Ltd.
KOREA (REPUBLIC OF)
Compliant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Compliant
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Not participating
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Not participating
Gold
Lingbao Gold Co., Ltd.
CHINA
Not participating
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Not participating
Gold
LS-NIKKO Copper Inc.
KOREA (REPUBLIC OF)
Compliant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Not participating
Gold
Marsam Metals
BRAZIL
In process
Gold
Materion
UNITED STATES OF AMERICA
Compliant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Compliant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Compliant




Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Compliant
Gold
Metalor Technologies S.A.
SWITZERLAND
Compliant
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Compliant
Gold
Metalurgica Met-Mex Peñoles, S.A. De C.V.
MEXICO
Compliant
Gold
Mitsubishi Materials Corporation
JAPAN
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Compliant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Compliant
Gold
Modeltech Sdn Bhd
MALAYSIA
In process
Gold
Morris and Watson
NEW ZEALAND
Not participating
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Compliant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
In process
Gold
Nihon Material Co., Ltd.
JAPAN
Compliant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Compliant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Compliant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Compliant
Gold
PAMP S.A.
SWITZERLAND
Compliant
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Not participating
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Compliant
Gold
PX Précinox S.A.
SWITZERLAND
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Compliant
Gold
Remondis Argentia B.V.
NETHERLANDS
Not participating
Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
Compliant
Gold
Royal Canadian Mint
CANADA
Compliant
Gold
SAAMP
FRANCE
Not participating
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Not participating
Gold
SAFINA A.S.
CZECH REPUBLIC
Not participating
Gold
Sai Refinery
INDIA
Not participating
Gold
Samduck Precious Metals
KOREA (REPUBLIC OF)
Compliant
Gold
Samwon Metals Corp.
KOREA (REPUBLIC OF)
Not participating
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Compliant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Compliant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
Compliant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Not participating
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Compliant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Compliant
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Compliant
Gold
So Accurate Group, Inc.
UNITED STATES OF AMERICA
Not participating
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Compliant
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Compliant
Gold
State research institute Center for Physical Sciences and Technology
LITHUANIA
Not participating
Gold
Sudan Gold Refinery
SUDAN
Not participating
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Compliant
Gold
T.C.A S.p.A
ITALY
Compliant




Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Compliant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Compliant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Not participating
Gold
Tony Goetz NV
BELGIUM
In process
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Not participating
Gold
Torecom
KOREA (REPUBLIC OF)
Compliant
Gold
Umicore Brasil Ltda.
BRAZIL
Compliant
Gold
Umicore Precious Metals Thailand
THAILAND
Compliant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Compliant
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Compliant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Not participating
Gold
Valcambi S.A.
SWITZERLAND
Compliant
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Compliant
Gold
WIELAND Edelmetalle GmbH
GERMANY
Compliant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Compliant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Compliant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Not participating
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Compliant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd
CHINA
Compliant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Compliant
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Compliant
Tantalum
Duoluoshan
CHINA
Compliant
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Compliant
Tantalum
F&X Electro-Materials Ltd.
CHINA
Compliant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Compliant
Tantalum
Global Advanced Metals Aizu
JAPAN
Compliant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Compliant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Compliant
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Compliant
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Compliant
Tantalum
H.C. Starck Ltd.
JAPAN
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Compliant
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES OF AMERICA
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Nonferrous Metals Smelting Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
KEMET Blue Metals
MEXICO
Compliant
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Compliant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Compliant
Tantalum
LSM Brasil S.A.
BRAZIL
Compliant




Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Compliant
Tantalum
Mineração Taboca S.A.
BRAZIL
Compliant
Tantalum
Mitsui Mining & Smelting Co., Ltd.
JAPAN
Compliant
Tantalum
NPM Silmet AS
ESTONIA
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd
CHINA
Compliant
Tantalum
Power Resources Ltd.
MACEDONIA
Compliant
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Compliant
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Compliant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Compliant
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Compliant
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Compliant
Tantalum
Tranzact, Inc.
UNITED STATES OF AMERICA
Compliant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Compliant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Compliant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Compliant
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
CHINA
Compliant
Tin
Alpha
UNITED STATES OF AMERICA
Compliant
Tin
An Thai Minerals Co., Ltd.
VIET NAM
Not participating
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Not participating
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Compliant
Tin
China Tin Group Co., Ltd.
CHINA
Compliant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Not participating
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Compliant
Tin
CV Ayi Jaya
INDONESIA
Compliant
Tin
CV Dua Sekawan
INDONESIA
Compliant
Tin
CV Gita Pesona
INDONESIA
Compliant
Tin
CV Serumpun Sebalai
INDONESIA
Compliant
Tin
CV Tiga Sekawan
INDONESIA
Compliant
Tin
CV United Smelting
INDONESIA
Compliant
Tin
CV Venus Inti Perkasa
INDONESIA
Compliant
Tin
Dowa
JAPAN
Compliant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
In process
Tin
Elmet S.L.U.
SPAIN
Compliant
Tin
EM Vinto
BOLIVIA
Compliant
Tin
Estanho de Rondônia S.A.
BRAZIL
Not participating
Tin
Fenix Metals
POLAND
Compliant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Compliant
Tin
Gejiu Jinye Mineral Company
CHINA
Compliant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
In process
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Compliant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
In process
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Not participating
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Compliant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Compliant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
In process
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Compliant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Compliant




Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Compliant
Tin
Melt Metais e Ligas S.A.
BRAZIL
Compliant
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Compliant
Tin
Metallo-Chimique N.V.
BELGIUM
Compliant
Tin
Mineração Taboca S.A.
BRAZIL
Compliant
Tin
Minsur
PERU
Compliant
Tin
Mitsubishi Materials Corporation
JAPAN
Compliant
Tin
Modeltech Sdn Bhd
MALAYSIA
In process
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
In process
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Not participating
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Compliant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Compliant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Compliant
Tin
PT Aries Kencana Sejahtera
INDONESIA
Compliant
Tin
PT Artha Cipta Langgeng
INDONESIA
Compliant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Compliant
Tin
PT Babel Inti Perkasa
INDONESIA
Compliant
Tin
PT Bangka Prima Tin
INDONESIA
Compliant
Tin
PT Bangka Tin Industry
INDONESIA
Compliant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Compliant
Tin
PT Bukit Timah
INDONESIA
Compliant
Tin
PT Cipta Persada Mulia
INDONESIA
Compliant
Tin
PT DS Jaya Abadi
INDONESIA
Compliant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Compliant
Tin
PT Inti Stania Prima
INDONESIA
Compliant
Tin
PT Justindo
INDONESIA
Not participating
Tin
PT Karimun Mining
INDONESIA
Compliant
Tin
PT Kijang Jaya Mandiri
INDONESIA
Compliant
Tin
PT Mitra Stania Prima
INDONESIA
Compliant
Tin
PT O.M. Indonesia
INDONESIA
Compliant
Tin
PT Panca Mega Persada
INDONESIA
Compliant
Tin
PT Prima Timah Utama
INDONESIA
Compliant
Tin
PT Refined Bangka Tin
INDONESIA
Compliant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Compliant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Compliant
Tin
PT Sukses Inti Makmur
INDONESIA
Compliant
Tin
PT Sumber Jaya Indah
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Compliant
Tin
PT Tinindo Inter Nusa
INDONESIA
Compliant
Tin
PT Tommy Utama
INDONESIA
Compliant
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Compliant
Tin
Soft Metais Ltda.
BRAZIL
Compliant
Tin
Super Ligas
BRAZIL
Not participating
Tin
Thaisarco
THAILAND
Compliant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Not participating
Tin
VQB Mineral and Trading Group JSC
VIET NAM
Compliant




Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Compliant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
In process
Tin
Yunnan Tin Company Limited
CHINA
Compliant
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Compliant
Tungsten
ACL Metais Eireli
BRAZIL
Not participating
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Not participating
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Not participating
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Not participating
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Compliant
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Compliant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Compliant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Compliant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Not participating
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Not participating
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Compliant
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Compliant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Compliant
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Compliant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Compliant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Compliant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Compliant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Compliant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Compliant
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Compliant
Tungsten
Woltech Korea Co., Ltd.
KOREA (REPUBLIC OF)
Compliant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Compliant




Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Compliant