EX-1.01 2 exhibit1012023.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 84 divisions in 51 countries and has prepared this Conflict Minerals Report for calendar year 2022 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, wolframite and their derivatives, tin, tantalum and 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 2022.

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 linked or referred to in 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”), which provides companies with tools and resources to make sourcing decisions that improve regulatory compliance and support responsible sourcing of minerals from conflict-affected and high-risk areas (“CAHRAs”). 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 https://www.itw.com/suppliers/) mandates humane treatment and compliance with all laws, and
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in particular, prohibits use of child or forced labor and discrimination, and mandates compliance with safety regulations, wage and hour laws, international trade 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 2022, 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” within the meaning of the Conflict Minerals Rule. 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.

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.

A. Establish Strong Management Systems

1. ITW Policies

ITW has adopted a company-wide Responsible Materials Policy, which addresses 3TG, has been approved by ITW’s Chairman and Chief Executive Officer and is available in seven languages on our website at https://www.itw.com/suppliers/. We also provide a copy of ITW’s Responsible Materials Policy to potential suppliers participating in our online bid portal process whose products contain or may contain 3TG.

Our Responsible Materials Policy states that:

We do not knowingly procure 3TG that originates from 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 products 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 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, including responsible sourcing of materials
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and an expectation of the same commitment from their suppliers, 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, Strategic Sourcing and Environmental Health & Safety, who reports to ITW’s Chief Financial Officer, and includes dedicated strategic sourcing, environmental, legal, internal audit, IT, trade compliance and corporate communications members. 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, supplier risk, supplier diversity 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.

4. Supplier Engagement and Training

In addition to our Responsible Materials Policy and Supplier Code of Conduct, ITW’s standard “Terms and Conditions” obligate 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 seven 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 Code of Conduct, which requires all employees to comply with all applicable laws and Company policies, including the Responsible Materials 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 Responsible Materials 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.

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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 2022 reporting cycle.

For 2022, 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 2022 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.

We sent 1,686 requests in seven languages to the Suppliers to provide us with a completed CMRT, as compared to 1,674 requests sent for 2021. 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 1,273 completed CMRTs from the Suppliers surveyed, compared to 1,295 received for 2021. From 2014 to 2021, our supplier response rate improved steadily each year, but the response rate has leveled off, reaching 76% in 2022 versus 77% in 2021.

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 228 SORs verified by the RMI as Conformant. We determined that 39 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 9 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.

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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.

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 2022 compliance, we continued to review past data to improve our written communications and to follow up with our businesses regarding supplier red flags.

In addition, we reached out directly to some of 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 help us 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 for 2022, we have thus far identified a number of 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, Strategic Sourcing and Environmental Health & Safety, and these results were in turn discussed with senior management.

Smelter Engagement

We continued our membership in the RMI and active participation in its Plenary, Multi-Stakeholder, Due Diligence and Smelter Engagement Teams;

We continue to support the RMAP by leading an RMI sub-team responsible for researching newly identified potential SORs; and

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

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 2022. 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
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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 SORs 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 3TG and further efforts to source our minerals responsibly in our 2022 Sustainability Report, which is available on our website at https://www.itw.com/sustainability/itw-sustainability/.

IV.Product Information

For 2022, 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:

AerosolFoam
Air delivery equipmentIndustrial cleaners
AppliancesIndustrial equipment
Automotive componentsIndustrial ovens
Automotive fuel systemsIndustrial warewashers
Commercial cooking equipmentInspection equipment
Commercial food equipmentLED lamps and displays
Commercial refrigeratorsMachines
ConstructionMeasuring equipment
Electrical enclosuresPrinters & dispensers
Electrical componentsSealing equipment
Electronic equipmentSolder products
Electronic safety productSwitches
Fastening toolsTesting equipment
Flow control metersWeighing platform

V. Identified Smelters and Refiners

As stated above, our Supplier responses identified 228 SORs that were on the RMI Conformant lists, 9 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 April 7, 2023. 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
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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 2022 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country. However, we did not conclude that any of our products are “DRC conflict free” within the meaning of the Conflict Minerals Rule.

V.Additional Risk Mitigation

In addition to the actions described elsewhere in this Conflict Minerals Report, we intend to take the following steps in 2023 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 and Smelter Engagement Teams and support the RMAP;

Continue our membership and active participation in the AIAG Responsible Materials Working Group and its subteams;

Continue our membership in Drive+, a service to automotive tier 1 suppliers and supplier associations offered by Drive Sustainability, providing opportunity to learn, collaborate and share with OEMs and peer companies;

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 SORs 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 the collection of their supplier assessments.

VI.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 improve or revise 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 or other third-party sources, continuing guidance regarding the Conflict Minerals Rule and the enactment of laws and rules in other jurisdictions, 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
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICAConformant
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICAConformant
GoldAgosi AGGERMANYConformant
GoldAida Chemical Industries Co., Ltd.JAPANConformant
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESConformant
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
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
GoldChimet S.p.A.ITALYConformant
GoldChugai MiningJAPANConformant
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 by Gold ColombiaCOLOMBIAConformant
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINAConformant
GoldHeimerle + Meule GmbHGERMANYConformant
GoldHeraeus Germany GmbH Co. KGGERMANYConformant
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
GoldJapan MintJAPANConformant
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MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
GoldJiangxi Copper Co., Ltd.CHINAConformant
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
GoldL'Orfebre S.A.ANDORRAConformant
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFConformant
GoldLT Metal Ltd.KOREA, REPUBLIC OFConformant
GoldMaterionUNITED STATES OF AMERICAConformant
GoldMatsuda Sangyo Co., Ltd.JAPANConformant
GoldMetal Concentrators SA (Pty) Ltd.SOUTH AFRICAConformant
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
GoldMKS PAMP SASWITZERLANDConformant
GoldMMTC-PAMP India Pvt., Ltd.INDIAConformant
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYConformant
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANConformant
GoldNH Recytech CompanyKOREA, REPUBLIC OFConformant
GoldNihon Material Co., Ltd.JAPANConformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIAConformant
GoldOhura Precious Metal Industry Co., Ltd.JAPANConformant
GoldPlanta Recuperadora de Metales SpACHILEConformant
GoldPT Aneka Tambang (Persero) TbkINDONESIAConformant
GoldPX Precinox S.A.SWITZERLANDConformant
GoldRand Refinery (Pty) Ltd.SOUTH AFRICAConformant
GoldREMONDIS PMR B.V.NETHERLANDSConformant
GoldRoyal Canadian MintCANADAConformant
GoldSAAMPFRANCEConformant
GoldSAFINA A.S.CZECHIAConformant
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
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MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
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
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
Gold8853 S.p.A.ITALYOn Smelter Look-up List
GoldABC Refinery Pty Ltd.AUSTRALIAOn Smelter Look-up List
GoldAfrican Gold RefineryUGANDAOn Smelter Look-up List
GoldAlbino Mountinho Lda.PORTUGALOn Smelter Look-up List
GoldAlexy MetalsUNITED STATES OF AMERICAOn Smelter Look-up List
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYOn Smelter Look-up List
GoldAU Traders and RefinersSOUTH AFRICAOn Smelter Look-up List
GoldAugmont Enterprises Private LimitedINDIAOn Smelter Look-up List
GoldC.I Metales Procesados Industriales SASCOLOMBIAOn Smelter Look-up List
GoldCaridadMEXICOOn Smelter Look-up List
GoldCendres + Metaux S.A.SWITZERLANDOn Smelter Look-up List
GoldCGR Metalloys Pvt Ltd.INDIAOn 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
GoldDongwu Gold GroupCHINAOn 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
GoldGGC 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
10



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
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
GoldIndustrial Refining CompanyBELGIUMOn 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 Processing PlantRUSSIAN FEDERATIONOn Smelter Look-up List
GoldJSC Novosibirsk RefineryRUSSIAN FEDERATIONOn Smelter Look-up List
GoldJSC UralelectromedRUSSIAN 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
GoldKyrgyzaltyn JSCKYRGYZSTANOn 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
GoldMarsam MetalsBRAZILOn 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
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONOn Smelter Look-up List
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONOn Smelter Look-up List
GoldPease & CurrenUNITED STATES OF AMERICAOn Smelter Look-up List
GoldPenglai Penggang Gold Industry Co., Ltd.CHINAOn Smelter Look-up List
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONOn Smelter Look-up List
GoldQG Refining, LLCUNITED STATES OF AMERICAOn Smelter Look-up List
GoldRefinery of Seemine Gold Co., Ltd.CHINAOn Smelter Look-up List
GoldSabin Metal Corp.UNITED STATES OF AMERICAOn Smelter Look-up List
GoldSafimet S.p.AITALYOn Smelter Look-up List
GoldSai RefineryINDIAOn Smelter Look-up List
GoldSamduck Precious MetalsKOREA, REPUBLIC OFOn Smelter Look-up List
GoldSamwon Metals Corp.KOREA, REPUBLIC OFOn Smelter Look-up List
11



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
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 CuiLu Gold 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
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINAOn Smelter Look-up List
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONOn 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
GoldSuper Dragon Technology Co., Ltd.TAIWAN, PROVINCE OF CHINAOn Smelter Look-up List
GoldTongling Nonferrous Metals Group Co., Ltd.CHINAOn Smelter Look-up List
GoldUmicore Precious Metals ThailandTHAILANDOn Smelter Look-up List
GoldWEEEREFININGFRANCEOn Smelter Look-up List
GoldYunnan Copper Industry Co., Ltd.CHINAOn Smelter Look-up List
TantalumAMG BrasilBRAZILConformant
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINAConformant
TantalumD Block Metals, LLCUNITED 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
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
TantalumMaterion Newton Inc.UNITED STATES OF AMERICAConformant
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
TantalumQSIL Metals Hermsdorf GmbHGERMANYConformant
12



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
TantalumQuantumCleanUNITED STATES OF AMERICAConformant
TantalumResind Industria e Comercio Ltda.BRAZILConformant
TantalumRFH Yancheng Jinye New Material Technology Co., Ltd.CHINAConformant
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
Tantalum5D Production OUESTONIAOn Smelter Look-up List
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONOn Smelter Look-up List
TinAlphaUNITED STATES OF AMERICAConformant
TinAurubis BeerseBELGIUMConformant
TinAurubis BerangoSPAINConformant
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINAConformant
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINAConformant
TinChina Tin Group Co., Ltd.CHINAConformant
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBRAZILConformant
TinCRM SynergiesSPAINConformant
TinCV Ayi JayaINDONESIAConformant
TinCV Venus Inti PerkasaINDONESIAConformant
TinDowaJAPANConformant
TinDS MyanmarMYANMARConformant
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)Conformant
TinEstanho de Rondonia S.A.BRAZILConformant
TinFabrica Auricchio Industria e Comercio Ltda.BRAZILConformant
TinFenix MetalsPOLANDConformant
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINAConformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINAConformant
TinHuiChang Hill Tin Industry 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
13



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
TinMetallic Resources, Inc.UNITED STATES OF AMERICAConformant
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 Aries Kencana SejahteraINDONESIAConformant
TinPT Artha Cipta LanggengINDONESIAConformant
TinPT ATD Makmur Mandiri JayaINDONESIAConformant
TinPT Babel Inti PerkasaINDONESIAConformant
TinPT Babel Surya Alam LestariINDONESIAConformant
TinPT Bangka Prima TinINDONESIAConformant
TinPT Bangka SerumpunINDONESIAConformant
TinPT Bukit TimahINDONESIAConformant
TinPT Cipta Persada MuliaINDONESIAConformant
TinPT Menara Cipta MuliaINDONESIAConformant
TinPT Mitra Stania PrimaINDONESIAConformant
TinPT Mitra Sukses GlobalindoINDONESIAConformant
TinPT Premium Tin IndonesiaINDONESIAConformant
TinPT Prima Timah UtamaINDONESIAConformant
TinPT Putera Sarana Shakti (PT PSS)INDONESIAConformant
TinPT Rajawali Rimba PerkasaINDONESIAConformant
TinPT Rajehan AriqINDONESIAConformant
TinPT Refined Bangka TinINDONESIAConformant
TinPT Sariwiguna BinasentosaINDONESIAConformant
TinPT Stanindo Inti PerkasaINDONESIAConformant
TinPT Sukses Inti MakmurINDONESIAConformant
TinPT Timah Tbk KundurINDONESIAConformant
TinPT Timah Tbk MentokINDONESIAConformant
TinPT Tommy UtamaINDONESIAConformant
TinResind Industria e Comercio Ltda.BRAZILConformant
TinRui Da HungTAIWAN, PROVINCE OF CHINAConformant
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIETNAMConformant
TinThaisarcoTHAILANDConformant
TinTin Smelting Branch of Yunnan Tin Co., Ltd.CHINAConformant
TinTin Technology & RefiningUNITED STATES OF AMERICAConformant
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILConformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINAConformant
TinAn Vinh Joint Stock Mineral Processing CompanyVIETNAMOn Smelter Look-up List
14



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINAOn Smelter Look-up List
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIETNAMOn Smelter Look-up List
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINAOn Smelter Look-up List
TinGejiu Kai Meng Industry and Trade LLCCHINAOn Smelter Look-up List
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINAOn Smelter Look-up List
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINAOn Smelter Look-up List
TinMelt Metais e Ligas S.A.BRAZILOn Smelter Look-up List
TinModeltech Sdn BhdMALAYSIAOn Smelter Look-up List
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIETNAMOn Smelter Look-up List
TinNovosibirsk Tin CombineRUSSIAN FEDERATIONOn Smelter Look-up List
TinPongpipat Company LimitedMYANMAROn Smelter Look-up List
TinPrecious Minerals and Smelting LimitedINDIAOn Smelter Look-up List
TinPT Bangka Tin IndustryINDONESIAOn Smelter Look-up List
TinPT Belitung Industri SejahteraINDONESIAOn Smelter Look-up List
TinPT Panca Mega PersadaINDONESIAOn Smelter Look-up List
TinPT Timah NusantaraINDONESIAOn Smelter Look-up List
TinPT Tinindo Inter NusaINDONESIAOn Smelter Look-up List
TinPT Tirus Putra MandiriINDONESIAOn Smelter Look-up List
TinSuper LigasBRAZILOn Smelter Look-up List
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIETNAMOn Smelter Look-up List
TinVQB Mineral and Trading Group JSCVIETNAMOn Smelter Look-up List
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINAOn Smelter Look-up List
TungstenA.L.M.T. Corp.JAPANConformant
TungstenAsia Tungsten Products Vietnam Ltd.VIETNAMConformant
TungstenChina Molybdenum Tungsten Co., Ltd.CHINAConformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINAConformant
TungstenCronimet Brasil LtdaBRAZILConformant
TungstenFujian Ganmin RareMetal Co., Ltd.CHINAConformant
TungstenFujian Xinlu Tungsten 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
TungstenHubei Green Tungsten Co., Ltd.CHINAConformant
TungstenHunan Chenzhou Mining Co., Ltd.CHINAConformant
TungstenHunan Jintai New Material Co., Ltd.CHINAConformant
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchCHINAConformant
TungstenJapan New Metals Co., Ltd.JAPANConformant
15



MineralSmelter or Refiner NameSmelter or Refiner CountrySmelter or Refiner
Status
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 High-Tech MaterialsVIETNAMConformant
TungstenNiagara Refining LLCUNITED STATES OF AMERICAConformant
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESConformant
TungstenTANIOBIS Smelting GmbH & Co. KGGERMANYConformant
TungstenWolfram Bergbau und Hutten AGAUSTRIAConformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINAConformant
TungstenXiamen Tungsten Co., Ltd.CHINAConformant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINAConformant
TungstenACL Metais EireliBRAZILOn Smelter Look-up List
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILOn Smelter Look-up List
TungstenArtek LLCRUSSIAN FEDERATIONOn Smelter Look-up List
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINAOn Smelter Look-up List
TungstenDONGKUK INDUSTRIES CO., LTD.KOREA, REPUBLIC OFOn Smelter Look-up List
TungstenHANNAE FOR T Co., Ltd.KOREA, REPUBLIC OFOn Smelter Look-up List
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONOn Smelter Look-up List
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINAOn Smelter Look-up List
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONOn Smelter Look-up List
TungstenLLC VostokRUSSIAN FEDERATIONOn Smelter Look-up List
TungstenMoliren Ltd.RUSSIAN FEDERATIONOn Smelter Look-up List
TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATIONOn Smelter Look-up List
TungstenOOO “Technolom” 1RUSSIAN FEDERATIONOn Smelter Look-up List
TungstenOOO “Technolom” 2RUSSIAN FEDERATIONOn Smelter Look-up List
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONOn Smelter Look-up List
TungstenYUDU ANSHENG TUNGSTEN CO., LTD.CHINAOn Smelter Look-up List


16



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
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
17



GambiaNew CaledoniaUganda*
GeorgiaNew ZealandUnited States of America
GermanyNicaraguaUruguay
GhanaNigerUzbekistan
GreeceNigeriaVietnam
GuatemalaNorwayZambia*
GuineaPakistanZimbabwe
GuyanaPanama
HondurasPapua New Guinea

* Covered Country.








18