EX-1.01 2 exhibit1012021.htm EX-1.01 Document


Exhibit 1.01

Conflict Minerals Report

I.Introduction

A.Our Business

Illinois Tool Works Inc. is a global manufacturer of a diversified range of industrial products and equipment with 83 divisions in 52 countries and has prepared this Conflict Minerals Report for calendar year 2020 as provided for in Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended, and Form SD (together referred to as the “Conflict Minerals Rule”). Unless the context indicates otherwise, the terms “Company,” “ITW,” “we,” “us” and “our” refer to Illinois Tool Works Inc. and its consolidated subsidiaries. “Conflict minerals” or “3TG” as used in this report, refers to cassiterite, columbite-tantalite, gold, wolframite and their derivatives, tin, tantalum, tungsten and/or gold, without regard to their location of origin.

The Company’s operations are reported as the following segments: Automotive OEM; Food Equipment; Test & Measurement and Electronics; Welding; Polymers & Fluids; Construction Products; and Specialty Products. Each of our segments manufactures certain products that contain 3TG that are necessary to the functionality or production of the products (which we sometimes refer to herein as “in-scope” products). ITW’s in-scope products collectively contain all four 3TGs.

B.Reasonable Country of Origin Inquiry and Due Diligence Overview

As provided for in the Conflict Minerals Rule, we conducted a “reasonable country of origin inquiry” (“RCOI”), designed in good faith to determine the origin of the 3TG that are contained in our in-scope products. See Section II. Reasonable Country of Origin Inquiry for a description of our RCOI process for 2020.

If the Company has reason to believe that any of the 3TG in our supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (with the DRC, the “Covered Countries”), or we are unable to determine the country of origin of the 3TG, we exercise due diligence on the source and chain of custody of the 3TG. We have included a description of our due diligence measures in this Conflict Minerals Report. On the basis of our RCOI, we have determined that some of the 3TG contained in our in-scope products may have originated from a Covered Country, and we are therefore submitting this Conflict Minerals Report, which describes the due diligence we have performed pursuant to the Conflict Minerals Rule and our related processes and procedures. This report is filed as an exhibit to our Form SD and is available on our website at http://www.itw.com/about-itw/suppliers/. Information contained on our website or otherwise actively linked to this Conflict Minerals Report is not part of or incorporated by reference into this Conflict Minerals Report or our Form SD.

C.ITW’s Position in the Supply Chain

ITW is a “downstream company” as defined by the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition) (the “OECD Guidance”). Most of our businesses are many levels removed from 3TG mining, smelting and processing facilities, and we have no relationships with mines. We source materials and components from suppliers who in turn source their materials and components from sub-tier suppliers, and therefore, we require the cooperation of our supply chain to provide information on smelters and refiners (“SORs”) as well as the origin of 3TG contained in our products. Due to our position in the supply chain, we utilize 3TG source information provided by the Responsible Minerals Initiative (the “RMI”), whose stated mission is to provide companies with tools and resources to help members make sourcing decisions that improve regulatory compliance and support responsible sourcing from conflict-affected and high-risk areas. RMI also manages the Responsible Minerals Assurance Process (the “RMAP”), which implements a risk-based audit program for SORs. We are a member of the RMI (member identifier = ITWI) and actively participate in its initiatives, as discussed later in this Conflict Minerals Report.

D.Responsible Sourcing Commitment

Through the efforts described in this Conflict Minerals Report, we seek to ensure that our suppliers responsibly source 3TG. Our responsible sourcing goes beyond compliance with the Conflict Minerals Rule, however, and our Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) mandates humane
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treatment and compliance with all laws, and in particular prohibits use of child labor, forced labor, and discrimination, and mandates compliance with safety rules, wage and hour laws, and anti-bribery laws.

E.Smelter and Refiner and Country of Origin Information

The Company’s in-scope products that contain 3TG that originated or might have originated from a Covered Country are described in Section IV. Product Information. For 2020, we have not found that any of the 3TG contained in our in-scope products directly or indirectly financed or benefited armed groups in a Covered Country. However, we have not concluded that any of our products are “DRC conflict free.” Information about SORs relating to our in-scope products containing 3TG is described in Section V. Identified Smelters and Refiners and on Annex A.

The terms “adjoining country,” “armed group,” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.

F.2020 Program Enhancements

For 2020, we took the following actions to enhance our RCOI and 3TG due diligence and mitigate sourcing risk. In accordance with our practice of continuous improvement, these actions build on our insights and efforts in prior years.

Enhanced Smelter Engagement

We increased our participation in the RMI’s Mineral Reporting Template (“MRT”) and smelter engagement teams and continued our active participation in the RMI’s due diligence practices, multi-stakeholder and plenary calls, contributing perspective and recommendations we believe to be of benefit to RMI members; and

We continued our active participation in the Automotive Industry Action Group’s (“AIAG”) Responsible Materials Working Group on their smelter engagement and industry best practices subteams, and joined their global requirements and minerals sensing sub-team, contributing Tier 1 perspective and insight.

General Process Enhancements

We continued to strengthen, revise and simplify our written communications, reminders and instructions to our businesses regarding supplier selection and supplier red flag follow-up to enhance the effectiveness of our 3TG compliance program; in particular, we believe that our enhancements in 2020 contributed to an improvement in our supplier response rate, which increased by 9% from our rate in 2019.

In addition, we have taken the following actions to continuously improve our sourcing processes beyond our 3TG RCOI and due diligence.

Further Continuous Improvement

We updated our Conflict Minerals Policy, as further discussed below; and

We continued to update and enhance our internal responsible sourcing webpage, which is used to inform our businesses as to recent responsible sourcing developments, including relating to cobalt, mica and RMI resources available to our businesses as part of our RMI membership.

II.     Reasonable Country of Origin Inquiry

Our RCOI utilized management systems recommended by the first step of the OECD Guidance, and was conducted in accordance with the second step of the OECD Guidance. Selected elements of our program design and RCOI process are discussed below. However, these are not all of the discrete elements of the program that we have put in place in accordance with the steps of the OECD Guidance to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the first and second steps.



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A. Establish Strong Management Systems

1. ITW Policies
ITW has adopted a company-wide Conflict Minerals Policy Statement (the “Conflict Minerals Policy”), which has been approved by ITW’s Chairman and Chief Executive Officer and is available in seven languages on our website at http://www.itw.com/about-itw/suppliers/page/en/conflict-minerals-policy-statement/. We also provide a copy of ITW’s Conflict Minerals Policy to potential suppliers participating in our online bid portal process whose products contain or may contain 3TG.

Our Conflict Minerals Policy, which was most recently updated in July 2020, states that:

We do not knowingly procure 3TG that originates from a conflict-affected or high-risk area (a “CAHRA”) unless processed by SORs that are verified or in the process of becoming verified as “conflict free.”

Our due diligence processes and efforts conform to the relevant portions of the OECD Guidance.

Our due diligence requests to our suppliers are supported by our Supplier Code of Conduct, which is described below, and our Terms and Conditions of Purchase.

If we discover that products procured by us contain 3TG from CAHRAs that are processed by facilities that are not conflict free or in the process of becoming conflict free, we will take steps to transition the product to conflict free sources.

We do not seek to embargo responsibly sourced 3TG from CAHRAs as doing so could be detrimental to the legitimate economies and communities of those areas, and our suppliers are encouraged to continue support of conflict free SORs in CAHRAs and to take similar measures with their supply chains.

The information provided by our suppliers is used to conduct our due diligence and to inform our risk assessments and risk mitigation activities and in the development of our Conflict Minerals Report and Form SD.

ITW’s Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) sets forth expectations for all ITW suppliers to adhere to the highest ethical standards in the conduct of their business. It also requires suppliers to adhere to specific standards and specifically prohibits certain behaviors and conditions associated with 3TG mining and processing, including use of child or forced labor, unsafe working conditions, corruption and bribery. The Supplier Code of Conduct also requires that, upon request, our suppliers determine whether any products provided by them contain 3TG and to take such actions as necessary to provide the information requested by ITW to conduct its RCOI, as described below under B. Identify and Assess Risk in the Supply Chain.

2. Cross Functional Committee

ITW has a cross-functional responsible sourcing committee (the “Committee”). The Committee is headed by ITW’s Vice President of Global Strategic Sourcing & Environmental Health and Safety, who reports to ITW’s Vice Chairman, and includes dedicated strategic sourcing, sourcing risk, environmental, legal, internal audit, IT, trade compliance and corporate communications. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets quarterly to discuss the 3TG compliance process, minerals beyond the 3TG compliance process, modern slavery, restricted party screening and other responsible supply chain developments. Senior management is briefed on the results of our RCOI and due diligence efforts on a regular basis.

3. Internal Training

We maintain an internal responsible sourcing webpage, which contains resources, instructions, and guidance on the RCOI and due diligence processes to be followed by our businesses that have or may have in-scope products. The site also contains step-by-step instructions for making supplier inquiries, including training videos regarding our RCOI and due diligence process, and is accessible by all ITW businesses at any time. We continually encourage our businesses to review the training videos prior to sending RCOI requests to suppliers.


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4. Supplier Engagement and Training

In addition to our Conflict Minerals Policy and Supplier Code of Conduct, ITW’s standard “Terms and Conditions” obligates our suppliers to take such actions as requested by ITW to enable us to comply with our conflict minerals disclosure requirements. We also include conflict minerals screening questions into incoming supplier bids.

ITW has an established protocol for its supplier inquiry process and uses a third-party software vendor whose role is to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and in-scope suppliers through use of a cloud-based 3TG tracking tool (the “CM System”).

Our supplier invitation letters are translated into eight languages. We encourage our businesses’ use of RMI’s eLearning Academy for supplier training, post information and guidance for suppliers on our Company website and encourage our businesses to share relevant information with suppliers on the process for responding to our RCOI requests for information.

5. Records Retention

ITW retains its conflict minerals related records for at least five years. These records generally are maintained in an electronic format.

6. Grievance Mechanism

ITW maintains a web- and telephone-based reporting system (“Helpline”), providing employees with a confidential reporting mechanism by which they can communicate issues and concerns associated with violations of ITW’s Principles of Conduct, which requires all employees to comply with all applicable laws and Company policies, including the Conflict Minerals Policy. Web-based reporting is offered in 16 languages and telephone-based reporting is offered in more than 200 languages, both available 24 hours a day, seven days a week. A link to the Helpline is included in our Conflict Minerals Policy and our Supplier Code of Conduct on our website to provide convenient access to external stakeholders, suppliers and other third parties to communicate issues and concerns regarding ITW’s supply chain. The contact information for our Helpline is http://www.itwhelpline.ethicspoint.com.

As an RMI member, we also support the use of the RMI’s grievance mechanism for reporting grievances relating to SORs and the RMAP.

B.    Identify and Assess Risk in the Supply Chain

Our RCOI process was used to survey our potential in-scope suppliers to identify and assess 3TG sourcing risk in our supply chain for the 2020 reporting cycle.

For 2020, our 3TG working team, together with various members of our sourcing department, compiled a list of the Company’s “80” suppliers by segment (i.e., the most significant suppliers) that have or are likely to have 3TG in their products, and distributed the list to our businesses with products containing or likely to contain 3TG. Those businesses were asked to further refine the list by identifying their own “80” suppliers and were instructed to survey those suppliers (we refer to the surveyed suppliers for 2020 as the “Suppliers”). We asked our businesses to concentrate their outreach on their “80” suppliers because these suppliers are the most likely to be recurring suppliers and responsible for a significant portion of the 3TG in our products.

The purpose of the Supplier survey was to determine whether 3TG in the components, parts or products from the Suppliers originated or may have originated from a CAHRA and were not from recycled or scrap sources. Businesses were instructed to survey the Suppliers using the then latest version of the CMRT. The CMRT requests information regarding 3TG included in suppliers’ products, SOR identity and location, suppliers’ RCOI processes and other information about the suppliers’ 3TG policies and practices.

ITW has an established protocol for its supplier inquiry process and uses the CM System, a third-party software vendor whose role is to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and in-scope suppliers through use of a cloud-based 3TG tracking tool.

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We sent 1,872 requests in eight languages to the Suppliers to provide us with a completed CMRT, as compared to 2,654 requests sent for 2019. The number of queried Suppliers decreased year-over-year due to further enhanced internal scoping. A number of our businesses source different products from the same Supplier, which means the total number of unique Suppliers is less than the number of Suppliers queried. We received 1,334 completed CMRTs from the Suppliers surveyed, compared to 1,639 received for 2019. Since our earliest report in 2014, our supplier response rate has improved steadily year-over-year, and increased from 62% in 2019 to 71% in 2020.

The CM System issued automatic weekly follow-up reminders to non-responding Suppliers, and our businesses were given instructions regarding follow-up actions beyond the automatic reminders and in response to receipt of incomplete or incorrect CMRTs.
Our protocol also includes a follow-up process to investigate any CMRTs received that raised “red flags.” See Section III. Due Diligence for a description of the follow-up process.

Our Supplier responses identified 241 SORs verified by the RMI as Conformant. We determined that 46 of these Conformant SORs sourced in whole or in part from within the Covered Countries. Our determination was based on country of origin information the RMI has obtained through the RMAP that is made available to RMI members.

Our Supplier responses also identified an additional 18 SORs that were listed as “Active” (as later defined in Section III.B.) by the RMI and 113 that were listed on the Smelter Look-up tab of the CMRT but were not Conformant or Active.

Based on the results of our RCOI, we were required to conduct due diligence, as described below.

III.    Due Diligence

A.Design Framework

ITW’s conflict minerals due diligence process is designed in conformance with the steps of the OECD Guidance.

B.     Due Diligence Activities
Selected elements of our program design and implementation in furtherance of the third, fourth and fifth steps of the OECD Guidance are discussed below. However, these are not all of the discrete elements of the program that we have put in place pursuant to these steps to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the third, fourth and fifth steps. The actions taken by the Company to address the first and second steps of the OECD Guidance are described in Section II. Reasonable Country of Origin Inquiry. See also our 2020 program enhancements discussed in Section I. Introduction.

Design and implement a strategy to respond to identified risks

The SOR information provided by Suppliers in response to the Company’s supplier survey described in Section II.B. was reviewed against the Smelter list in the CMRT. SOR information also was reviewed against the lists of Conformant, Active, and other SORs not listed as Conformant or Active and country-of-origin information provided by the RMI and contained in the CM System. “Conformant” SORs have been audited and are conformant with the RMAP assessment protocols, including those listed as “re-audit in progress.” “Active” SORs are those that have committed to undergo an RMAP assessment, completed the relevant documents and scheduled the on-site assessment. These may be in the pre-assessment, assessment or corrective-action phases of the assessment.

CMRTs received from our Suppliers that indicated 3TG from a source within a Covered Country triggered a “red flag” in the CM System, and communications with the flagged Suppliers were escalated. Businesses and their respective flagged Suppliers indicating 3TG from a source within a Covered Country were asked to provide additional information, and our businesses were given written guidance and instructions for these Supplier communications. The escalated Supplier responses were evaluated on a case-by-case basis. For our 2020 compliance, we continued to revise and simplify our written communications and instructions to our businesses regarding supplier red flag follow-up to enhance program effectiveness.

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In addition, we reached out directly to the SORs that were not listed as Conformant or Active by the RMI and asked them to become Conformant. Entities that the RMI has determined are either not SORs or not in operation were not addressed in our outreach efforts. We seek to exercise leverage over SORs that are neither Conformant nor Active through our participation in and support of the RMI and its Smelter Engagement Team, and we utilize information provided by the RMI to its members to monitor SOR improvement. Finally, we screen our smelters with a restricted party screening software to alert us if our SORs are sanctioned or on various government watchlists. As a result of our ongoing due diligence activities in 2020, we have thus far identified approximately 12 SORs that are neither Conformant nor Active or that otherwise fail to meet our supplier requirements and intend to take steps to remove these smelters from our supply chain.

Our 3TG working team reported the findings from its RCOI and due diligence process to our Vice President of Global Strategic Sourcing, and these results were in turn discussed with senior management.

Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain

The Company continued its membership in the RMI for 2020. Due to our location in the mineral supply chain, which is discussed earlier in this Conflict Minerals Report, we support and utilize the RMI’s RMAP to perform third-party audits of SORs, as well as the London Bullion Market Association (“LBMA”) and Responsible Jewellery Council (“RJC”) gold audit standards, which RMI cross-recognizes. Additionally, we continued our voluntary contribution to RMI’s Initial Audit Fund, managed by RMI, meant to encourage RMAP-eligible smelters to undergo an independent third-party assessment and participate in its annual review process by fully paying for the costs of the SOR initial audit.

Report annually on supply chain due diligence

We describe our supply chain due diligence efforts in this annual Conflict Minerals Report. We post this report on our website and file it with the SEC as an exhibit to our annual Form SD. Once filed, the Form SD and Conflict Minerals Report become available on our website at https://www.itw.com/suppliers. We also refer to our efforts relating to conflict minerals and further efforts to source our minerals responsibly in our annual Corporate Social Responsibility Report, which is available on our website at https://itw-csr.com/.

IV.     Product Information

For 2020, our in-scope products that contain 3TG that originated or might have originated from a Covered Country included products in each of the categories below:

Air delivery equipmentIndustrial equipment
Automotive componentsIndustrial ovens
Commercial cooking equipmentIndustrial warewashers
Commercial food equipmentInspection equipment
Commercial refrigeratorsLED lamps & displays
Drills & drill accessoriesMeasuring equipment
Electrical enclosuresPower sources
Electronic components & devicesPrinters & dispensers
Electronic equipmentProduction equipment
Electronic safety productSealing equipment
Fastening toolsSolder products
Flow control metersSwitches
FoamTesting equipment
Ground support equipmentWelding hardware
Industrial cleaners & cleaning equipment



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V.    Identified Smelters and Refiners

As stated above, our Supplier responses identified 241 SORs that were on the RMI Conformant lists, 18 that were listed as Active with the RMI and 113 that were on the Smelter list of the CMRT but not listed as Conformant or Active by the RMI. Those facilities are listed on Annex A. The information on Annex A includes only information regarding the SORs identified by our Suppliers that were on the Smelter list contained in the CM System as of February 12, 2021. Entities identified by our Suppliers that are not on Annex A have been submitted to the RMI to support their ongoing effort to identify and audit all 3TG SORs.

Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our Suppliers for accurate SOR information, and our RCOI and due diligence measures cannot provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products. The information that we received from most of our Suppliers was made at a “company” or “user defined” level, rather than at a “product” level, meaning that such Suppliers provided information on all of their products that contained 3TG, not just the products that were sold to us. Therefore, our list of SORs disclosed on Annex A may contain facilities that did not process the 3TG contained in our products. In addition, the identified SORs may not include all SORs present in our in-scope product supply chain, because we did not obtain a response from all Suppliers surveyed, some Suppliers were unable to identify all of the SORs in their supply chain, and we surveyed only the larger suppliers of products containing or potentially containing 3TG.

Annex A includes information concerning the locations of the SORs listed. We utilized the information made available to RMI members regarding the potential countries of origin of the 3TG processed by these SORs and did not find for 2020 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country.

VI.Additional Risk Mitigation

In addition to the actions described elsewhere in this Conflict Minerals Report, we intend to take or continue the following steps in respect of our 2021 compliance to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:

Continue to analyze and review our current processes to improve their effectiveness and efficiency;

Continue to enhance supplier and internal communications and training to improve RCOI and due diligence data accuracy and completeness;

Continue to seek to influence non-Conformant SORs in our supply chain to obtain a Conformant designation;

Continue our membership in the RMI and active participation in its Plenary, Multi-Stakeholder, Due Diligence, Smelter Engagement and MRT Teams and support the RMAP;

Continue our membership and active participation in the AIAG Responsible Materials Working Group and its global requirements and minerals sensing, industry best practices and smelter engagement subteams;

Continue to submit to the RMI facilities identified by our suppliers that have not yet been identified by the RMI as SORs, to support the RMI’s ongoing effort to identify and audit all 3TG SORs;

Continue to send tailored communications to smelters believed to be in our supply chain who are either scheduled to undergo RMI re-audit or are not fulfilling RMI audit requirements, encouraging them to go through the re-audit process or to continue fulfilling their audit requirements; and

Continuous evaluation of supplier CMRT response failures to assist our businesses in their supplier assessments.

VII.Forward Looking Statements

This report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements include expectations concerning the Company’s future actions to identify improvements to our due diligence processes, to engage with our suppliers, and to take other actions regarding our product sourcing. These statements are subject to certain risks, uncertainties and other factors, including, but not limited to, incomplete information from industry
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or other third-party sources, continuing guidance regarding the Conflict Minerals Rule and the enactment of laws and rules in other jurisdictions, decisions to make changes to our continual improvement efforts and delays or difficulties in engaging suppliers and/or transitioning sources of product containing 3TG.

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Annex A to Exhibit 1.01
RMI Smelters and Refiners
MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
Gold8853 S.p.A.ITALYConformant
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICAConformant
GoldAida Chemical Industries Co., Ltd.JAPANConformant
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESConformant
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYConformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANConformant
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILConformant
GoldArgor-Heraeus S.A.SWITZERLANDConformant
GoldAsahi Pretec Corp.JAPANConformant
GoldAsahi Refining Canada Ltd.CANADAConformant
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICAConformant
GoldAsaka Riken Co., Ltd.JAPANConformant
GoldAU Traders and RefinersSOUTH AFRICAConformant
GoldAurubis AGGERMANYConformant
GoldBangalore RefineryINDIAConformant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESConformant
GoldBoliden ABSWEDENConformant
GoldC. Hafner GmbH + Co. KGGERMANYConformant
GoldCCR Refinery - Glencore Canada CorporationCANADAConformant
GoldCendres + Metaux S.A.SWITZERLANDConformant
GoldChimet S.p.A.ITALYConformant
GoldChugai MiningJAPANConformant
GoldDODUCO Contacts and Refining GmbHGERMANYConformant
GoldDowaJAPANConformant
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFConformant
GoldEco-System Recycling Co., Ltd. East PlantJAPANConformant
GoldEco-System Recycling Co., Ltd. North PlantJAPANConformant
GoldEco-System Recycling Co., Ltd. West PlantJAPANConformant
GoldEmirates Gold DMCCUNITED ARAB EMIRATESConformant
GoldGeib Refining CorporationUNITED STATES OF AMERICAConformant
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINAConformant
GoldHeimerle + Meule GmbHGERMANYConformant
GoldHeraeus Metals Hong Kong Ltd.CHINAConformant
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINAConformant
GoldIshifuku Metal Industry Co., Ltd.JAPANConformant
GoldIstanbul Gold RefineryTURKEYConformant
GoldItalpreziosiITALYConformant
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MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
GoldJapan MintJAPANConformant
GoldJiangxi Copper Co., Ltd.CHINAConformant
GoldJSC Novosibirsk RefineryRUSSIAN FEDERATIONConformant
GoldJSC UralelectromedRUSSIAN FEDERATIONConformant
GoldJX Nippon Mining & Metals Co., Ltd.JAPANConformant
GoldKazzincKAZAKHSTANConformant
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICAConformant
GoldKGHM Polska Miedz Spolka AkcyjnaPOLANDConformant
GoldKojima Chemicals Co., Ltd.JAPANConformant
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFConformant
GoldKyrgyzaltyn JSCKYRGYZSTANConformant
GoldL'Orfebre S.A.ANDORRAConformant
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFConformant
GoldLT Metal Ltd.KOREA, REPUBLIC OFConformant
GoldMarsam MetalsBRAZILConformant
GoldMaterionUNITED STATES OF AMERICAConformant
GoldMetal Concentrators SA (Pty) Ltd.SOUTH AFRICAConformant
GoldMatsuda Sangyo Co., Ltd.JAPANConformant
GoldMetalor Technologies (Hong Kong) Ltd.CHINAConformant
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPOREConformant
GoldMetalor Technologies (Suzhou) Ltd.CHINAConformant
GoldMetalor Technologies S.A.SWITZERLANDConformant
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICAConformant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOConformant
GoldMitsubishi Materials CorporationJAPANConformant
GoldMitsui Mining and Smelting Co., Ltd.JAPANConformant
GoldMMTC-PAMP India Pvt., Ltd.INDIAConformant
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONConformant
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYConformant
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANConformant
GoldNihon Material Co., Ltd.JAPANConformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIAConformant
GoldOhura Precious Metal Industry Co., Ltd.JAPANConformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONConformant
GoldPAMP S.A.SWITZERLANDConformant
GoldPlanta Recuperadora de Metales SpACHILEConformant
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONConformant
GoldPT Aneka Tambang (Persero) TbkINDONESIAConformant
GoldPX Precinox S.A.SWITZERLANDConformant
GoldRand Refinery (Pty) Ltd.SOUTH AFRICAConformant
GoldREMONDIS PMR B.V.NETHERLANDSConformant
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MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
GoldRoyal Canadian MintCANADAConformant
GoldSAAMPFRANCEConformant
GoldSafimet S.p.AITALYConformant
GoldSAFINA A.S.CZECHIAConformant
GoldSamduck Precious MetalsKOREA, REPUBLIC OFConformant
GoldSAXONIA Edelmetalle GmbHGERMANYConformant
GoldSEMPSA Joyeria Plateria S.A.SPAINConformant
GoldShandong Gold Smelting Co., Ltd.CHINAConformant
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINAConformant
GoldSichuan Tianze Precious Metals Co., Ltd.CHINAConformant
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINAConformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONConformant
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINAConformant
GoldSumitomo Metal Mining Co., Ltd.JAPANConformant
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFConformant
GoldT.C.A S.p.AITALYConformant
GoldTanaka Kikinzoku Kogyo K.K.JAPANConformant
GoldTokuriki Honten Co., Ltd.JAPANConformant
GoldTOO Tau Ken AltynKAZAKHSTANConformant
GoldTorecomKOREA, REPUBLIC OFConformant
GoldTSK PretechKOREA, REPUBLIC OFConformant
GoldUmicore Precious Metals ThailandTHAILANDConformant
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMConformant
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICAConformant
GoldValcambi S.A.SWITZERLANDConformant
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIAConformant
GoldWIELAND Edelmetalle GmbHGERMANYConformant
GoldYamakin Co., Ltd.JAPANConformant
GoldYokohama Metal Co., Ltd.JAPANConformant
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINAConformant
GoldAlexy MetalsUNITED STATES OF AMERICAActive
GoldAugmont Enterprises Private LimitedINDIAActive
GoldC.I Metales Procesados Industriales SASCOLOMBIAActive
GoldHeraeus Germany GmbH Co. KGGERMANYActive
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICAOn Smelter Look-up List
GoldAfrican Gold RefineryUGANDAOn Smelter Look-up List
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYOn Smelter Look-Up List
GoldCaridadMEXICOOn Smelter Look-Up List
11



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
GoldCGR Metalloys Pvt Ltd.INDIAOn Smelter Look-up List
GoldDaejin Indus Co., Ltd.KOREA, REPUBLIC OFOn Smelter Look-up List
GoldDaye Non-Ferrous Metals Mining Ltd.CHINAOn Smelter Look-up List
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYOn Smelter Look-up List
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATESOn Smelter Look-up List
GoldEmerald Jewel Industry India Limited (Unit 1)INDIAOn Smelter Look-up List
GoldEmerald Jewel Industry India Limited (Unit 2)INDIAOn Smelter Look-up List
GoldEmerald Jewel Industry India Limited (Unit 3)INDIAOn Smelter Look-up List
GoldEmerald Jewel Industry India Limited (Unit 4)INDIAOn Smelter Look-up List
GoldFidelity Printers and Refiners Ltd.ZIMBABWEOn Smelter Look-up List
GoldFujairah Gold FZCUNITED ARAB EMIRATESOn Smelter Look-up List
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIAOn Smelter Look-up List
GoldGold Coast RefineryGHANAOn Smelter Look-up List
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINAOn Smelter Look-up List
GoldGuangdong Jinding Gold LimitedCHINAOn Smelter Look-up List
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINAOn Smelter Look-up List
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINAOn Smelter Look-up List
GoldHunan Chenzhou Mining Co., Ltd.CHINAOn Smelter Look-up List
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINAOn Smelter Look-up List
GoldHwaSeong CJ CO., LTD.KOREA, REPUBLIC OFOn Smelter Look-up List
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATESOn Smelter Look-up List
GoldJALAN & CompanyINDIAOn Smelter Look-up List
GoldJSC Ekaterinburg Non-Ferrous Metal RefinersRUSSIAN FEDERATIONOn Smelter Look-up List
GoldK.A. RasmussenNORWAYOn Smelter Look-up List
GoldKaloti Precious MetalsUNITED ARAB EMIRATESOn Smelter Look-up List
GoldKazakhmys Smelting LLCKAZAKHSTANOn Smelter Look-up List
GoldKundan Care Products Ltd.INDIAOn Smelter Look-up List
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONOn Smelter Look-up List
GoldL’azurde Company For JewelrySAUDI ARABIAOn Smelter Look-up List
GoldLingbao Gold Co., Ltd.CHINAOn Smelter Look-up List
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINAOn Smelter Look-up List
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINAOn Smelter Look-up List
GoldMD OverseasINDIAOn Smelter Look-up List
GoldMetallix Refining Inc.UNITED STATES OF AMERICAOn Smelter Look-up List
GoldModeltech Sdn BhdMALAYSIAOn Smelter Look-up List
GoldMorris and WatsonNEW ZEALANDOn Smelter Look-up List
GoldMorris and Watson Gold CoastAUSTRALIAOn Smelter Look-up List
GoldNH Recytech CompanyKOREA, REPUBLIC OFOn Smelter Look-up List
GoldPease & CurrenUNITED STATES OF AMERICAOn Smelter Look-up List
GoldPenglai Penggang Gold Industry Co., Ltd.CHINAOn Smelter Look-up List
GoldQG Refining, LLCUNITED STATES OF AMERICAOn Smelter Look-up List
12



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
GoldRefinery of Seemine Gold Co., Ltd.CHINAOn Smelter Look-up List
GoldRepublic Metals CorporationUNITED STATES OF AMERICAOn Smelter Look-up List
GoldSabin Metal Corp.UNITED STATES OF AMERICAOn Smelter Look-up List
GoldSai RefineryINDIAOn Smelter Look-up List
GoldSamwon Metals Corp.KOREA, REPUBLIC OFOn Smelter Look-up List
GoldSancus ZFS (L'Orfebre, SA)COLOMBIAOn Smelter Look-up List
GoldSellem Industries Ltd.MAURITANIAOn Smelter Look-up List
GoldShandong Humon Smelting Co., Ltd.CHINAOn Smelter Look-up List
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINAOn Smelter Look-up List
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CHINAOn Smelter Look-up List
GoldShirpur Gold Refinery Ltd.INDIAOn Smelter Look-up List
GoldSovereign MetalsINDIAOn Smelter Look-up List
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIAOn Smelter Look-up List
GoldSudan Gold RefinerySUDANOn Smelter Look-up List
GoldTongling Nonferrous Metals Group Co., Ltd.CHINAOn Smelter Look-up List
GoldUmicore Brasil Ltda.BRAZILOn Smelter Look-up List
GoldUniversal Precious Metals Refining ZambiaZAMBIAOn Smelter Look-up List
GoldValue TradingBELGIUMOn Smelter Look-up List
GoldYunnan Copper Industry Co., Ltd.CHINAOn Smelter Look-up List
TantalumAsaka Riken Co., Ltd.JAPANConformant
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINAConformant
TantalumD Block Metals, LLCUNITED STATES OF AMERICAConformant
TantalumExotech Inc.UNITED STATES OF AMERICAConformant
TantalumF&X Electro-Materials Ltd.CHINAConformant
TantalumFIR Metals & Resource Ltd.CHINAConformant
TantalumGlobal Advanced Metals AizuJAPANConformant
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICAConformant
TantalumGuangdong Rising Rare Metals-EO Materials Ltd.CHINAConformant
TantalumH.C. Starck Hermsdorf GmbHGERMANYConformant
TantalumH.C. Starck Inc.UNITED STATES OF AMERICAConformant
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINAConformant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumJiangxi Tuohong New Raw MaterialCHINAConformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINAConformant
TantalumJiujiang Tanbre Co., Ltd.CHINAConformant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumKEMET de MexicoMEXICOConformant
TantalumLSM Brasil S.A.BRAZILConformant
13



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
TantalumMeta MaterialsNORTH MACEDONIA, REPUBLIC OFConformant
TantalumMetallurgical Products India Pvt., Ltd.INDIAConformant
TantalumMineracao Taboca S.A.BRAZILConformant
TantalumMitsui Mining and Smelting Co., Ltd.JAPANConformant
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINAConformant
TantalumNPM Silmet ASESTONIAConformant
TantalumQuantumCleanUNITED STATES OF AMERICAConformant
TantalumResind Industria e Comercio Ltda.BRAZILConformant
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONConformant
TantalumTaki Chemical Co., Ltd.JAPANConformant
TantalumTANIOBIS Co., Ltd.THAILANDConformant
TantalumTANIOBIS GmbHGERMANYConformant
TantalumTANIOBIS Japan Co., Ltd.JAPANConformant
TantalumTANIOBIS Smelting GmbH & Co. KGGERMANYConformant
TantalumTelex MetalsUNITED STATES OF AMERICAConformant
TantalumUlba Metallurgical Plant JSCKAZAKHSTANConformant
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDCHINAConformant
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINAConformant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumCP Metals Inc.UNITED STATES OF AMERICAOn Smelter Look-up List
TantalumJiujiang Janny New Material Co., Ltd.CHINAOn Smelter Look-up List
TantalumKEMET Blue PowderUNITED STATES OF AMERICAOn Smelter Look-up List
TinAlphaUNITED STATES OF AMERICAConformant
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINAConformant
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINAConformant
TinChina Tin Group Co., Ltd.CHINAConformant
TinDowaJAPANConformant
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)Conformant
TinFenix MetalsPOLANDConformant
TinGejiu Fengming Metallurgy Chemical PlantCHINAConformant
TinGejiu Kai Meng Industry and Trade LLCCHINAConformant
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINAConformant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINAConformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINAConformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINAConformant
TinGuanyang Guida Nonferrous Metal Smelting PlantCHINAConformant
TinHuiChang Hill Tin Industry Co., Ltd.CHINAConformant
14



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
TinHuichang Jinshunda Tin Co., Ltd.CHINAConformant
TinJiangxi New Nanshan Technology Ltd.CHINAConformant
TinLuna Smelter, Ltd.RWANDAConformant
TinMa'anshan Weitai Tin Co., Ltd.CHINAConformant
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILConformant
TinMalaysia Smelting Corporation (MSC)MALAYSIAConformant
TinMelt Metais e Ligas S.A.BRAZILConformant
TinMetallic Resources, Inc.UNITED STATES OF AMERICAConformant
TinMetallo Belgium N.V.BELGIUMConformant
TinMetallo Spain S.L.U.SPAINConformant
TinMineracao Taboca S.A.BRAZILConformant
TinMinsurPERUConformant
TinMitsubishi Materials CorporationJAPANConformant
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDConformant
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESConformant
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)Conformant
TinPT Artha Cipta LanggengINDONESIAConformant
TinPT ATD Makmur Mandiri JayaINDONESIAConformant
TinPT Babel Surya Alam LestariINDONESIAConformant
TinPT Bangka SerumpunINDONESIAConformant
TinPT Menara Cipta MuliaINDONESIAConformant
TinPT Mitra Stania PrimaINDONESIAConformant
TinPT Prima Timah UtamaINDONESIAConformant
TinPT Rajawali Rimba PerkasaINDONESIAConformant
TinPT Rajehan AriqINDONESIAConformant
TinPT Refined Bangka TinINDONESIAConformant
TinPT Stanindo Inti PerkasaINDONESIAConformant
TinPT Timah Tbk KundurINDONESIAConformant
TinPT Timah Tbk MentokINDONESIAConformant
TinResind Industria e Comercio Ltda.BRAZILConformant
TinRui Da HungTAIWAN, PROVINCE OF CHINAConformant
TinSoft Metais Ltda.BRAZILConformant
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMConformant
TinThaisarcoTHAILANDConformant
TinTin Technology & RefiningUNITED STATES OF AMERICAConformant
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILConformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINAConformant
TinYunnan Tin Company LimitedCHINAConformant
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINAConformant
15



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBRAZILActive
TinCRM SynergiesSPAINActive
TinCV Venus Inti PerkasaINDONESIAActive
TinEstanho de Rondonia S.A.BRAZILActive
TinNovosibirsk Processing Plant Ltd.RUSSIAN FEDERATIONActive
TinPT Aries Kencana SejahteraINDONESIAActive
TinPT Lautan Harmonis SejahteraINDONESIAActive
TinPT Tinindo Inter NusaINDONESIAActive
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAMOn Smelter Look-up List
TinCNMC (Guangxi) PGMA Co., Ltd.CHINAOn Smelter Look-up List
TinCV Ayi JayaINDONESIAOn Smelter Look-up List
TinCV Dua SekawanINDONESIAOn Smelter Look-up List
TinCV Gita PesonaINDONESIAOn Smelter Look-up List
TinCV United SmeltingINDONESIAOn Smelter Look-up List
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINAOn Smelter Look-up List
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAMOn Smelter Look-up List
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINAOn Smelter Look-up List
TinGejiu Jinye Mineral CompanyCHINAOn Smelter Look-up List
TinJiangxi Ketai Advanced Material Co., Ltd.CHINAOn Smelter Look-up List
TinModeltech Sdn BhdMALAYSIAOn Smelter Look-up List
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAMOn Smelter Look-up List
TinPongpipat Company LimitedMYANMAROn Smelter Look-up List
TinPrecious Minerals and Smelting LimitedINDIAOn Smelter Look-up List
TinPT Babel Inti PerkasaINDONESIAOn Smelter Look-up List
TinPT Bangka Prima TinINDONESIAOn Smelter Look-up List
TinPT Bangka Tin IndustryINDONESIAOn Smelter Look-up List
TinPT Belitung Industri SejahteraINDONESIAOn Smelter Look-up List
TinPT Bukit TimahINDONESIAOn Smelter Look-up List
TinPT DS Jaya AbadiINDONESIAOn Smelter Look-up List
TinPT Eunindo Usaha MandiriINDONESIAOn Smelter Look-up List
TinPT Inti Stania PrimaINDONESIAOn Smelter Look-up List
TinPT Karimun MiningINDONESIAOn Smelter Look-up List
TinPT Kijang Jaya MandiriINDONESIAOn Smelter Look-up List
TinPT Mitra Sukses GlobalindoINDONESIAOn Smelter Look-up List
TinPT Panca Mega PersadaINDONESIAOn Smelter Look-up List
TinPT Premium Tin IndonesiaINDONESIAOn Smelter Look-up List
TinPT Sariwiguna BinasentosaINDONESIAOn Smelter Look-up List
TinPT Sukses Inti MakmurINDONESIAOn Smelter Look-up List
TinPT Sumber Jaya IndahINDONESIAOn Smelter Look-up List
TinPT Timah NusantaraINDONESIAOn Smelter Look-up List
TinPT Tirus Putra MandiriINDONESIAOn Smelter Look-up List
16



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
TinPT Tommy UtamaINDONESIAOn Smelter Look-up List
TinSuper LigasBRAZILOn Smelter Look-up List
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAMConformant
TungstenA.L.M.T. Corp.JAPANConformant
TungstenACL Metais EireliBRAZILConformant
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMConformant
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINAConformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINAConformant
TungstenFujian Ganmin RareMetal Co., Ltd.CHINAConformant
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINAConformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINAConformant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINAConformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINAConformant
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICAConformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINAConformant
TungstenH.C. Starck Tungsten GmbHGERMANYConformant
TungstenHunan Chenzhou Mining Co., Ltd.CHINAConformant
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiCHINAConformant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINAConformant
TungstenHunan Litian Tungsten Industry Co., Ltd.CHINAConformant
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONConformant
TungstenJapan New Metals Co., Ltd.JAPANConformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINAConformant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINAConformant
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINAConformant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINAConformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINAConformant
TungstenKennametal FallonUNITED STATES OF AMERICAConformant
TungstenKennametal HuntsvilleUNITED STATES OF AMERICAConformant
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OFConformant
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINAConformant
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINAConformant
TungstenMasan Tungsten Chemical LLC (MTC)VIET NAMConformant
TungstenMoliren Ltd.RUSSIAN FEDERATIONConformant
TungstenNiagara Refining LLCUNITED STATES OF AMERICAConformant
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESConformant
TungstenTANIOBIS Smelting GmbH & Co. KGGERMANYConformant
TungstenTejing (Vietnam) Tungsten Co., Ltd.VIET NAMConformant
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONConformant
17



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
TungstenWolfram Bergbau und Hutten AGAUSTRIAConformant
TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OFConformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINAConformant
TungstenXiamen Tungsten Co., Ltd.CHINAConformant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINAConformant
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILActive
TungstenArtek LLCRUSSIAN FEDERATIONActive
TungstenChina Molybdenum Tungsten Co., Ltd.CHINAActive
TungstenCronimet Brasil LtdaBRAZILActive
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONActive
TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATIONActive
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINAOn Smelter Look-up List
TungstenCP Metals Inc.UNITED STATES OF AMERICAOn Smelter Look-up List
TungstenFujian Jinxin Tungsten Co., Ltd.CHINAOn Smelter Look-up List
TungstenGanzhou Yatai Tungsten Co., Ltd.CHINAOn Smelter Look-up List
TungstenGEM Co., Ltd.CHINAOn Smelter Look-up List
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINAOn Smelter Look-up List
TungstenJiangxi Xianglu Tungsten Co., Ltd.CHINAOn Smelter Look-up List
TungstenSouth-East Nonferrous Metal Company Limited of Hengyang CityCHINAOn Smelter Look-up List
TungstenVietnam Youngsun Tungsten Industry Co., Ltd.VIET NAMOn Smelter Look-up List
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.CHINAOn Smelter Look-up List

Country of Origin Information

The countries of origin of the newly-mined 3TG processed by the Conformant SORs listed above may have included the countries listed below, as well as possibly other countries. We did not determine the possible countries of origin of the 3TG processed by any other SORs listed on this Annex A. The listed countries of origin are derived from information made available by the RMI to its members, which includes LBMA Good Delivery List and RJC Chain of Custody Certification information. Because the RMI generally does not indicate individual countries of origin of the 3TG processed by Conformant SORs, we were not able to determine the countries of origin of the newly-mined 3TG processed by the listed Conformant SORs with greater specificity. According to information made available by the RMI to its members, some of the listed SORs processed 3TG originating solely from recycled or scrap sources and others processed both recycled and scrap content and newly-mined content from one or more of the countries indicated below.

ArgentinaHungaryParaguay
ArmeniaIcelandPeru
AustraliaIndiaPhilippines
AustriaIndonesiaPoland
AzerbaijanIrelandPortugal
BelgiumIsraelRomania
BeninItalyRussian Federation
Bolivia (Plurinational State of)Ivory CoastRwanda*
BotswanaJapanSan Marino
18



BrazilJordanSaudi Arabia
BruneiRepublic of KoreaSenegal
BulgariaKazakhstanSerbia
Burkina FasoKenyaSierra Leone
Burundi*KuwaitSingapore
CambodiaKyrgyzstanSlovakia
CameroonLaosSlovenia
CanadaLatviaSolomon Islands
ChileLebanonSomaliland
ChinaLiberiaSouth Africa
ColombiaLiechtensteinSpain
CroatiaLithuaniaSudan
CubaLuxembourgSuriname
CyprusMacauSwaziland
Czech RepublicMadagascarSweden
Democratic Republic of the Congo*MalaysiaSwitzerland
DenmarkMaliTaiwan
Dominican RepublicMaltaTanzania*
EcuadorMauritaniaTajikistan
EgyptMauritiusThailand
El SalvadorMexicoTogo
EritreaMongoliaTrinidad and Tobago
EstoniaMoroccoTunisia
EthiopiaMozambiqueTurkey
FijiMyanmarUkraine
FinlandNamibiaUnited Arab Emirates
FranceNetherlandsUnited Kingdom of Great Britain and Northern Ireland
GambiaNew CaledoniaUganda*
GeorgiaNew ZealandUnited States of America
GermanyNicaraguaUruguay
GhanaNigerUzbekistan
GreeceNigeriaVietnam
GuatemalaNorwayZambia*
GuineaPakistanZimbabwe
GuyanaPanama
HondurasPapua New Guinea
* Covered Country.
19