EX-1.01 2 mtw-ex101_14.htm EX-1.01 mtw-ex101_14.htm

 

Exhibit 1.01

The Manitowoc Company, Inc.

Conflict Minerals Report

For the Year Ended December 31, 2017

Part I.Introduction

This is the Conflict Minerals Report (the “Report”) of The Manitowoc Company, Inc. (the “Company,” “we,” “us” or “our”) for calendar year 2017 in accordance with Rule 13p-1 under the Securities and Exchange Act of 1934 (“the Rule”).  This Report discusses the Company’s efforts to determine whether any of the products it manufactures or contracts to be manufactured contain columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin, and tungsten (collectively, “3TGs”), that are necessary to the functionality or production of such products that may have originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”) or are from recycled or scrap sources.

Part II.Company and Product Overview

Founded in 1902, The Manitowoc Company, Inc. is a leading global manufacturer of cranes and lifting solutions with manufacturing, distribution, and service facilities in 20 countries. Manitowoc is recognized as one of the premier innovators and providers of crawler cranes, tower cranes, and mobile cranes for the heavy construction industry, which are complemented by a slate of industry-leading aftermarket product support services. In 2017, Manitowoc’s net sales totaled $1.58 billion, with over half generated outside the United States.  Additionally, our Manitowoc Crane Care offering leverages Manitowoc’s installed base of approximately 143,000 cranes to provide aftermarket parts and services to enable our customers to manage their fleets more effectively and improve their return on investment.  Due to the ongoing and predictable maintenance needed by cranes, as well as the high cost of crane downtime, Crane Care provides us with a consistent stream of recurring aftermarket revenue.

Our Conflict Minerals Steering Committee, which includes members of Strategic Purchasing and Corporate Legal (the “Committee”), conducted an analysis of our manufacturing operations and supply chain (the “applicability assessment”) and identified 3TGs that are necessary to the functionality or production of the Products we manufactured or contracted to be manufactured during calendar year 2017.  Our Products generally contain (in varying degrees and amounts) some 3TGs necessary to their functionality or production.

Part III.Reasonable Country of Origin Inquiry (“RCOI”)

We began our scoping process identifying a list of our Products that may contain 3TG and then we extracted a list of our suppliers who provide us with products that may contain one or more of the 3TGs. Once the filtering was completed, we populated the supplier list with contact information and provided the list to our third-party service provider. We also included a list of associated parts for these suppliers to ensure that suppliers have the option of completing their CMRT (as defined below) on the product or company level. This supplier list was then uploaded to our third-party provider’s software platform that allows us to store and manage supplier requests and documentation.

From there, we defined our scoping process even further by removing service providers, indirect materials suppliers, and inactive suppliers. This ensures that all suppliers surveyed provided items to the Company that were used in final Products in the year 2017. Through this process, we determined that 381 suppliers were in scope for the 2017 reporting period.

Our service provider then conducted the supplier survey portion of the RCOI. Utilizing the Conflict Minerals Reporting Template (the “CMRT”), version 5.01 or higher, developed by the Responsible Business Alliance (“RBA”) and The Global e-Sustainability Initiative (“GeSI”), the suppliers identified through the procedures

 

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described above were surveyed on their sourcing of the 3TGs that we identified in our Products. The CMRT includes questions regarding a direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain, such as the names and locations of smelters and refiners as well as the origin of 3TGs used by those facilities.

During the supplier survey, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in our third-party provider’s software platform. Non-responsive suppliers were contacted a minimum of three times by our service provider’s Supply Chain Team as well as by Manitowoc personnel in one-on-one communications. This included four follow-ups to encourage their response via the CMRT.

To ensure that our suppliers understood our expectations regarding the sourcing of 3TGs, we provided training through webinars, videos, documentation, and one-on-one discussions. We continued to put a strong emphasis on supplier education and training. To accomplish this, we utilized a Learning Management System, Assent University, and provided all in-scope suppliers access to Assent’s Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.

The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation was to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms were accepted and classified as valid or invalid so that data was retained. All suppliers who submitted CMRTs that were flagged as “invalid” were contacted at least twice to address items such as incomplete data, missing smelter information, or inconsistent answers. These communications were monitored and tracked in our service provider’s system for future reporting and transparency. As of May 1, 2018, we had received responses from 77.5% of the suppliers surveyed (there were 11 invalid submissions that were not corrected by suppliers).

Based on the RCOI, we determined that we may have some suppliers who sourced 3TGs from the Covered Countries. Therefore, in an effort to identify mines with the greatest possible specificity, we conducted due diligence on our supplier base, as described below.

Part IV.Due Diligence

In accordance with Securities and Exchange Commission (“SEC”) rules, the Company undertook due diligence efforts to determine whether the 3TGs in the Products it manufactures, or contracts to manufacture, that are necessary to the functionality or production of its Products originated in the Covered Countries or are from recycled or scrap sources.  The Company designed its due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework set forth in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related supplements for each of the Conflict Minerals (the “OECD Guidance”).

Our due diligence process for 2017 included the steps described below:

Step 1:  Establish strong Company management systems

We are committed to the responsible sourcing of our Products and we expect the same from our suppliers, including ensuring that the products or components supplied to us do not directly or indirectly finance or benefit armed groups in the Covered Countries.  Our suppliers are required to support our efforts to comply with the Rule.  We have developed a Conflict Minerals Policy, which is available on our website (www.manitowoc.com) under Investor Relations–Corporate Governance–Governance Highlights–Other Governance Documents (http://ir.manitowoc.com/investor-relations/corporate-governance/governance-documents/default.aspx). In addition, our standard supplier terms and conditions address our expectations related to any 3TGs supplied to us.  We also have a Company-level mechanism to enable the reporting of grievances.

 

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We established a grievance mechanism whereby employees and suppliers can report violations of the Company’s policies, including with respect to conflict minerals. Suppliers and others outside the Company may contact our conflict minerals team to communicate with us, including to report grievances, via a dedicated email address that is published in our conflict minerals policy and in other communications with our suppliers. In addition, our employees may anonymously report suspected violations using Manitowoc’s Corporate Governance/Whistleblower Hotline, available 24 hours a day, seven days a week. The Company’s Corporate Governance/Whistleblower Hotline is staffed by non-Manitowoc personnel, who share any information reported with our General Counsel and our Audit Committee.

The Committee, which includes multiple internal stakeholder representatives and reports to the Company’s senior leadership, oversees supplier due diligence regarding Conflict Minerals.  The Committee is also responsible for educating procurement and supply chain employees, revising supplier terms and conditions to include our Conflict Minerals expectations, and overseeing the preparation of the Form SD and this Report. The Committee also has the authority to engage consultants and advisors to assist with its efforts.

Building on the process the Committee implemented in previous years, in 2017 the Committee analyzed the Company’s manufacturing operations and supply chain to identify the Products that we manufacture or contract to manufacture that might contain 3TGs.  Based on that process, the Committee worked with the Company’s engineering, manufacturing, and supply chain management teams as well as our service provider to identify, engage with, and make appropriate inquiries of our suppliers to determine, based on a RCOI, whether the Company may be sourcing 3TGs from the Covered Countries. We also sought to strengthen engagement with suppliers by developing an internal procedure that includes steps for supplier engagement escalations, including direct follow ups from Company personnel and our third-party service provider.

The Company retained information regarding its due diligence efforts for 2017 in accordance with its existing record retention policies and procedures.  

Step 2:  Identify and assess risk in the supply chain

Our due diligence efforts were based on a survey process in which we requested certain information from selected suppliers who we believed may be providing parts or components containing 3TGs by using the CMRT, as previously discussed.  More specifically, the Committee oversaw the following:

 

A supply chain survey of those direct suppliers identified during the applicability assessment and ROCI who the Company believed represented the highest risk of supplying parts or components that may contain 3TGs from the Covered Countries.

 

Automated data validation on all submitted CMRT responses. All invalid responses were flagged and the applicable suppliers were contacted at least twice to correct their CMRT.

 

A comparison of the smelters and refiners that were identified by the Company’s suppliers against the list maintained by the Responsible Minerals Initiative (“RMI”) to assist in the supplier risk assessment.

 

Periodic reporting to senior management regarding the results of the survey and related risk assessment.

Certain of the responses to the CMRT included the names of facilities listed by the suppliers as smelters or refiners of 3TGs.  As a downstream consumer of 3TGs, we do not have direct relationships with smelters and refiners of 3TGs and do not perform or direct audits of these entities. Our service provider compared the facilities listed by our suppliers to the list of smelters and refiners maintained by the RMI. If a supplier indicated that the facility was identified as “conformant,” our service provider first confirmed that the name of the smelter or refiner was included on the published list as an active facility. As of May 1, 2018, we had validated 321 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs.

 

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In order to assess the risk that any of these smelters or refiners posed to our supply chain, we determined if the smelter or refiner had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). In cases where the smelter’s due diligence practices have not been audited against the standard, a potential risk exists. Of the valid facilities identified, 257 have been identified as conformant by the RMAP standard and an additional 11 have committed to or are currently undergoing an audit through the RMAP. Due to the provision of primarily company or divisional level CMRTs by our suppliers, as opposed to product-level CMRTs, we cannot definitively determine the connection of their 3TGs (if any) to our Products.

Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the OECD Guidance. Our third-party service provider utilizes the following three scoring criteria to determine the level of risk that each smelter or refiner poses to the supply chain by identifying red flags:

 

Geographic proximity to the DRC and covered countries;

 

RMAP audit status; and

 

Credible evidence of unethical or conflict sourcing.

Additionally, suppliers were evaluated on the strength of their sourcing program, which further assisted in identifying risk in the supply chain and in making key risk mitigation decisions. The following questions from the CMRT were used to evaluate the strength of each supplier’s program:

 

Have you established a conflict minerals sourcing policy?

 

Have you implemented due diligence measures for conflict-free sourcing?

 

Do you review due diligence information received from your suppliers against your company’s expectations?

 

Does your review process include corrective action management?

If a supplier answered “yes” to all of the questions above, it was deemed to have a strong 3TGs program. When a supplier did not meet any of those criteria, it was deemed to have a weak 3TGs program. Any supplier who is flagged as having a weak program will be contacted to encourage it to increase the strength of its program.

We believe that the inquiries and investigations described above, which included (1) seeking information about 3TGs smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT; (2) verifying those smelters and refiners with the expanding published lists; (3) conducting the due diligence review; and (4) obtaining additional documentation and verification, as applicable, represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Products.

Step 3:  Design and implement a strategy to respond to identified risks

We completed a management reporting dashboard on a periodic basis summarizing the results of the risk assessment process.  Other elements of the Company’s due diligence process designed to respond to identified risks included the following:

 

Suppliers who did not respond to the Company’s initial survey request were sent at least three escalation communications requesting that they provide the information requested.

 

Suppliers who provided incomplete or inconsistent responses were sent follow-up communications, as previously discussed.  Based on the type of risk identified during a review of supplier responses, suppliers were sent a corrective action communication.

 

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Based on the smelter or refiner risk criteria noted above, the following facilities have been identified with red-flag risks in their supply chain:

 

Tony Goetz NV - CID002587

 

African Gold Refinery Limited (AGR) – CID003185

 

Kaloti Precious Metals - CID002563

 

Universal Precious Metals Refining Zambia - CID002854

 

Fidelity Printers and Refiners - CID002515

 

Sudan Gold Refinery - CID002567

As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our third-party vendor, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take its own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Manitowoc, and escalating up to removal of these high-risk smelters from their supply chain. As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context.

If a supplier was unable to confirm that 3TGs supplied to us were sourced from a smelter or refiner that has been audited and certified as conflict-free, we requested that the supplier find alternative sources for 3TGs.

In addition, if, through our due diligence process, we became aware that one of our suppliers was sourcing 3TGs from the Covered Countries or was unable to determine the origin of the 3TGs supplied to us, our practice was to take the following steps:

 

Determine whether the smelter or refiner that processed the 3TGs supplied by that supplier had been audited and certified as conflict-free by a reputable independent third party such as the RMI;

 

Notify the supplier of our Conflict Minerals Policy and expectations; and

 

Inform the supplier that if the supplier does not begin using conflict-free sources within a reasonable period, we may take appropriate steps including, but not limited to, replacing the supplier.

Step 4:  Third-party audit of smelters’/refiners’ due diligence practices

As a downstream consumer of 3TGs, the Company must rely on its direct suppliers to gather information about smelters and refiners in the supply chain.  The Company does not purchase any 3TGs in their raw material form and, to the best of its knowledge, does not directly purchase any products or components directly from any of the Covered Countries.  As a result, the Company does not perform or direct audits of smelters and refiners. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the minerals used by smelters and refiners that agree to participate in the program.

Step 5:  Report annually on supply chain due diligence

This Report and the related Form SD were publicly filed with the SEC and are available on our website (www.manitowoc.com) under Investor Relations–Corporate Governance–Governance Highlights–Other Governance Documents (http://ir.manitowoc.com/investor-relations/corporate-governance/governance-documents/default.aspx).

 

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Part V.Due Diligence Results

Most of the supplier responses we received provided data at a company or divisional level.  Therefore, based on our due diligence efforts, we are unable to determine whether the 3TGs reported by the suppliers were contained in the actual components or parts supplied to the Company. Due to this, our list of processing smelters or refiners may contain more facilities than those that actually processed the 3TGs contained in our Products.

The quality of the responses that we received from our surveyed suppliers continues to be varied. Many responses provided by suppliers (via the CMRT) included the names of facilities listed by the suppliers as smelters or refiners. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TGs claimed on the CMRT are considered invalid and our third-party provider continues to follow up with these suppliers. In addition, there are still suppliers unable to provide the smelters or refiners used for 3TGs supplied to us.

For all responses that indicated a smelter, our third-party provider compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was identified as “DRC Conflict-Free,” our provider confirmed that the name was listed by RMI as a conformant smelter. No violations were identified. As of May 1, 2018, we had validated 321 smelters or refiners and we are working to validate the additional smelter or refiner entries from the submitted CMRTs.

Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 257 smelters and refiners that are deemed RMAP Conformant – this indicates these smelters or refiners follow the RMAP audit protocols. There are 11 more smelters or refiners that have been deemed Active, meaning that they have committed to undergo a RMAP audit or are currently participating in one of the cross-recognized certification programs such as the LBMA Responsible Gold Certification or the Responsible Jewelry Program Chain-of-Custody Certification. The remaining 53 smelters and refiners have not yet been confirmed as conflict-free.

Appendix A to this Report lists the legitimate smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate as a legitimate smelter or refiner of 3TGs. The fact that the smelter or refiner is listed on Appendix A does not definitively indicate that 3TGs processed by such smelter or refiner were included in the Company’s Products. Appendix B to this Report includes an aggregated list of potential countries of origin from which the reported facilities collectively source 3TGs, based on information provided by our suppliers and the RMI; the fact that a country is listed on Appendix B does not definitively indicate that 3TGs in the Company’s Products were sourced from that country.


 

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Part VI.Steps to Improve Due Diligence

In addition to the measures described above, the Company intends to take the following steps during the next compliance period to improve the due diligence conducted and to further mitigate the risk that the 3TGs necessary to support our operations benefit armed groups, including:

 

Informing and encouraging suppliers to transition to smelters identified as conflict-free by an independent audit program such as the RMAP;

 

Actively participating in and supporting industry trade groups to help improve communication throughout the supply chain;

 

Working with certain suppliers to help educate them on our ongoing expectations supporting responsible sourcing decisions;

 

Reconsidering our willingness to continue to partner with suppliers who do not comply with our Conflict Minerals Policy and who do not meet our expectations;

 

Contacting suppliers that have been flagged for additional follow-up and clarification; and/or

 

Increasing education to suppliers regarding the Conflict Minerals Rule, smelters and refiners, and proper use of the CMRT.

Forward-Looking Statements

The Report contains forward-looking statements, which express a belief, expectation or intention, as well as those that are historical fact, including statements relating to our compliance efforts and expected actions.  The words “expects,” “intends,” “plans,” “believes,” and “anticipates” and similar expressions are used to identify these forward-looking statements. These statements are not guarantees of future actions or performance and are subject to various risks, uncertainties and assumptions. Undue reliance should be not be placed on these statements, which are only effective as of the date of this Report, and the Company undertakes no obligation to publicly update or revise any forward-looking statement.

 

 

 

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Appendix A

List of Potential Smelters/Refiners

 

Metal

Standard Smelter Name

Smelter Facility Location

Smelter ID

RMI Audit Status

Gold

Abington Reldan Metals, LLC

UNITED STATES

CID002708

Not Enrolled

Gold

Advanced Chemical Company

UNITED STATES

CID000015

Conformant

Gold

African Gold Refinery

UGANDA

CID003185

Not Enrolled

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

CID000019

Conformant

Gold

Al Etihad Gold LLC

UNITED ARAB EMIRATES

CID002560

Conformant

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

CID000035

Conformant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

CID000041

Conformant

Gold

AngloGold Ashanti Córrego do Sítio Mineração

BRAZIL

CID000058

Conformant

Gold

Argor-Heraeus S.A.

SWITZERLAND

CID000077

Conformant

Gold

Asahi Pretec Corp.

JAPAN

CID000082

Conformant

Gold

Asahi Refining Canada Ltd.

CANADA

CID000924

Conformant

Gold

Asahi Refining USA Inc.

UNITED STATES

CID000920

Conformant

Gold

Asaka Riken Co., Ltd.

JAPAN

CID000090

Conformant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

CID000103

Not Enrolled

Gold

AU Traders and Refiners

SOUTH AFRICA

CID002850

Conformant

Gold

Aurubis AG

GERMANY

CID000113

Conformant

Gold

Bangalore Refinery

INDIA

CID002863

Active

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

CID000128

Conformant

Gold

Boliden AB

SWEDEN

CID000157

Conformant

Gold

C. Hafner GmbH + Co. KG

GERMANY

CID000176

Conformant

Gold

Caridad

MEXICO

CID000180

Not Enrolled

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

CID000185

Conformant

Gold

Cendres + Métaux S.A.

SWITZERLAND

CID000189

Conformant

Gold

Chimet S.p.A.

ITALY

CID000233

Conformant

Gold

Chugai Mining

JAPAN

CID000264

Not Enrolled

Gold

Daejin Indus Co., Ltd.

KOREA, REPUBLIC OF

CID000328

Conformant

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

CID000343

Not Enrolled

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

CID002867

Not Enrolled

Gold

DODUCO Contacts and Refining GmbH

GERMANY

CID000362

Conformant

Gold

Dowa

JAPAN

CID000401

Conformant

 

Page 1 of 10


 

Gold

DS PRETECH Co., Ltd.

KOREA, REPUBLIC OF

CID003195

Active

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

CID000359

Conformant

Gold

Eco-System Recycling Co., Ltd.

JAPAN

CID000425

Conformant

Gold

Elemetal Refining, LLC

UNITED STATES

CID001322

Not Enrolled

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

CID002561

Conformant

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

CID002515

Not Enrolled

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

CID002852

Not Enrolled

Gold

Geib Refining Corporation

UNITED STATES

CID002459

Conformant

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

CID002243

Conformant

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

CID001909

Not Enrolled

Gold

Guangdong Jinding Gold Limited

CHINA

CID002312

Not Enrolled

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

CID000651

Not Enrolled

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

CID000671

Not Enrolled

Gold

HeeSung

KOREA, REPUBLIC OF

CID000689

Conformant

Gold

Heimerle + Meule GmbH

GERMANY

CID000694

Conformant

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

CID000707

Conformant

Gold

Heraeus Precious Metals GmbH & Co. KG

GERMANY

CID000711

Conformant

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000767

Not Enrolled

Gold

Hwasung CJ Co., Ltd.

KOREA, REPUBLIC OF

CID000778

Not Enrolled

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

CID000801

Conformant

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

CID000807

Conformant

Gold

Istanbul Gold Refinery

TURKEY

CID000814

Conformant

Gold

Italpreziosi

ITALY

CID002765

Conformant

Gold

Japan Mint

JAPAN

CID000823

Conformant

Gold

Jiangxi Copper Co., Ltd.

CHINA

CID000855

Conformant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

CID000927

Conformant

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

CID000929

Conformant

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

CID000937

Conformant

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

CID002563

Not Enrolled

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

CID000956

Not Enrolled

Gold

Kazzinc

KAZAKHSTAN

CID000957

Conformant

Gold

Kennecott Utah Copper LLC

UNITED STATES

CID000969

Conformant

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

CID002511

Active

Gold

Kojima Chemicals Co., Ltd.

JAPAN

CID000981

Conformant

 

Page 2 of 10


 

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

CID002605

Conformant

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

CID001029

Conformant

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

CID002865

Not Enrolled

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

CID001032

Not Enrolled

Gold

Lingbao Gold Co., Ltd.

CHINA

CID001056

Not Enrolled

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

CID001058

Not Enrolled

Gold

L'Orfebre S.A.

ANDORRA

CID002762

Active

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

CID001078

Conformant

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

CID001093

Not Enrolled

Gold

Marsam Metals

BRAZIL

CID002606

Conformant

Gold

Materion

UNITED STATES

CID001113

Conformant

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

CID001119

Conformant

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

CID001149

Conformant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

CID001152

Conformant

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

CID001147

Conformant

Gold

Metalor Technologies S.A.

SWITZERLAND

CID001153

Conformant

Gold

Metalor USA Refining Corporation

UNITED STATES

CID001157

Conformant

Gold

Metalúrgica Met-Mex Peñoles S.A. De C.V.

MEXICO

CID001161

Conformant

Gold

Mitsubishi Materials Corporation

JAPAN

CID001188

Conformant

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001193

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

CID002509

Conformant

Gold

Modeltech Sdn Bhd

MALAYSIA

CID002857

Active

Gold

Morris and Watson

NEW ZEALAND

CID002282

Not Enrolled

Gold

Morris and Watson Gold Coast

AUSTRALIA

CID002866

Not Enrolled

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

CID001204

Conformant

Gold

Nadir Metal Rafineri San. Ve Tic. A.Ş.

TURKEY

CID001220

Conformant

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

CID001236

Not Enrolled

Gold

NH Recytech Company

KOREA, REPUBLIC OF

CID003189

Active

Gold

Nihon Material Co., Ltd.

JAPAN

CID001259

Conformant

Gold

Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

CID002779

Conformant

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

CID001325

Conformant

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

RUSSIAN FEDERATION

CID001326

Conformant

Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

CID000493

Conformant

Gold

PAMP S.A.

SWITZERLAND

CID001352

Conformant

Gold

Pease & Curren

UNITED STATES

CID002872

Not Enrolled

 

Page 3 of 10


 

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

CID001362

Not Enrolled

Gold

Planta Recuperadora de Metales SpA

CHILE

CID002919

Conformant

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

CID001386

Conformant

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

CID001397

Conformant

Gold

PX Précinox S.A.

SWITZERLAND

CID001498

Conformant

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

CID001512

Conformant

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

CID000522

Not Enrolled

Gold

Remondis Argentia B.V.

NETHERLANDS

CID002582

Active

Gold

Republic Metals Corporation

UNITED STATES

CID002510

Conformant

Gold

Royal Canadian Mint

CANADA

CID001534

Conformant

Gold

SAAMP

FRANCE

CID002761

Conformant

Gold

Sabin Metal Corp.

UNITED STATES

CID001546

Not Enrolled

Gold

Safimet S.p.A

Italy

CID002973

Conformant

Gold

SAFINA A.S.

CZECH REPUBLIC

CID002290

Active

Gold

Sai Refinery

INDIA

CID002853

Not Enrolled

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

CID001555

Conformant

Gold

SAMWON Metals Corp.

KOREA, REPUBLIC OF

CID001562

Not Enrolled

Gold

SAXONIA Edelmetalle GmbH

GERMANY

CID002777

Conformant

Gold

Schone Edelmetaal B.V.

NETHERLANDS

CID001573

Conformant

Gold

SEMPSA Joyería Platería S.A.

SPAIN

CID001585

Conformant

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

CID001619

Not Enrolled

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

CID001622

Conformant

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

CID001736

Conformant

Gold

Singway Technology Co., Ltd.

TAIWAN

CID002516

Conformant

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

CID001756

Conformant

Gold

Solar Applied Materials Technology Corp.

TAIWAN

CID001761

Conformant

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

CID003153

Not Enrolled

Gold

Sudan Gold Refinery

SUDAN

CID002567

Not Enrolled

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

CID001798

Conformant

Gold

SungEel HiTech

KOREA, REPUBLIC OF

CID002918

Conformant

Gold

T.C.A S.p.A

ITALY

CID002580

Conformant

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

CID001875

Conformant

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

CID001916

Conformant

Gold

Tokuriki Honten Co., Ltd.

JAPAN

CID001938

Conformant

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

CID001947

Not Enrolled

 

Page 4 of 10


 

Gold

Tony Goetz NV

BELGIUM

CID002587

Not Enrolled

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

CID002615

Not Enrolled

Gold

Torecom

KOREA, REPUBLIC OF

CID001955

Conformant

Gold

Umicore Brasil Ltda.

BRAZIL

CID001977

Conformant

Gold

Umicore Precious Metals Thailand

THAILAND

CID002314

Conformant

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

CID001980

Conformant

Gold

United Precious Metal Refining, Inc.

UNITED STATES

CID001993

Conformant

Gold

Universal Precious Metals Refining Zambia

ZAMBIA

CID002854

Not Enrolled

Gold

Valcambi S.A.

SWITZERLAND

CID002003

Conformant

Gold

Western Australian Mint trading as The Perth Mint

AUSTRALIA

CID002030

Conformant

Gold

WIELAND Edelmetalle GmbH

GERMANY

CID002778

Conformant

Gold

Yamamoto Precious Metal Co., Ltd.

JAPAN

CID002100

Conformant

Gold

Yokohama Metal Co., Ltd.

JAPAN

CID002129

Conformant

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

CID000197

Not Enrolled

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

CID002224

Conformant

Tantalum

Asaka Riken Co., Ltd.

JAPAN

CID000092

Conformant

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

CID000211

Conformant

Tantalum

D Block Metals, LLC

UNITED STATES

CID002504

Conformant

Tantalum

Duoluoshan

CHINA

CID000410

Not Enrolled

Tantalum

Exotech Inc.

UNITED STATES

CID000456

Conformant

Tantalum

F&X Electro-Materials Ltd.

CHINA

CID000460

Conformant

Tantalum

FIR Metals & Resource Ltd.

CHINA

CID002505

Conformant

Tantalum

Global Advanced Metals Aizu

JAPAN

CID002558

Conformant

Tantalum

Global Advanced Metals Boyertown

UNITED STATES

CID002557

Conformant

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

CHINA

CID000291

Conformant

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

CID000616

Conformant

Tantalum

H.C. Starck Co., Ltd.

THAILAND

CID002544

Conformant

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

CID002547

Conformant

Tantalum

H.C. Starck Inc.

UNITED STATES

CID002548

Conformant

Tantalum

H.C. Starck Ltd.

JAPAN

CID002549

Conformant

Tantalum

H.C. Starck Smelting GmbH & Co. KG

GERMANY

CID002550

Conformant

Tantalum

H.C. Starck Tantalum and Niobium GmbH

GERMANY

CID002545

Conformant

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

CID002492

Conformant

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

CID002512

Conformant

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

CID002842

Conformant

 

Page 5 of 10


 

Tantalum

Jiujiang Janny New Material Co., Ltd.

CHINA

CID003191

Conformant

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

CID000914

Conformant

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

CID000917

Conformant

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002506

Conformant

Tantalum

KEMET Blue Metals

MEXICO

CID002539

Conformant

Tantalum

KEMET Blue Powder

UNITED STATES

CID002568

Conformant

Tantalum

King-Tan Tantalum Industry Ltd.

CHINA

CID000973

Conformant

Tantalum

LSM Brasil S.A.

BRAZIL

CID001076

Conformant

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

CID001163

Conformant

Tantalum

Mineracao Taboca S.A.

BRAZIL

CID001175

Conformant

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001192

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

CID001277

Conformant

Tantalum

NPM Silmet AS

ESTONIA

CID001200

Conformant

Tantalum

Power Resources Ltd.

MACEDONIA

CID002847

Conformant

Tantalum

QuantumClean

UNITED STATES

CID001508

Conformant

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

CID002707

Conformant

Tantalum

RFH Tantalum Smeltry Co., Ltd.

CHINA

CID001522

Conformant

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

CID001769

Conformant

Tantalum

Taki Chemicals

JAPAN

CID001869

Conformant

Tantalum

Telex Metals

UNITED STATES

CID001891

Conformant

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

CID001969

Conformant

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

CID002508

Conformant

Tantalum

Yichun Jin Yang Rare Metal Co., Ltd.

CHINA

CID002307

Conformant

Tin

Alpha

UNITED STATES

CID000292

Conformant

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

CID002703

Not Enrolled

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

CID000228

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

CID003190

Active

Tin

China Tin Group Co., Ltd.

CHINA

CID001070

Conformant

Tin

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

CID000278

Not Enrolled

Tin

CV Ayi Jaya

INDONESIA

CID002570

Conformant

Tin

CV Dua Sekawan

INDONESIA

CID002592

Conformant

Tin

CV Gita Pesona

INDONESIA

CID000306

Conformant

Tin

CV Tiga Sekawan

INDONESIA

CID002593

Conformant

Tin

CV United Smelting

INDONESIA

CID000315

Conformant

Tin

CV Venus Inti Perkasa

INDONESIA

CID002455

Conformant

 

Page 6 of 10


 

Tin

Dowa

JAPAN

CID000402

Conformant

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

VIET NAM

CID002572

Not Enrolled

Tin

EM Vinto

BOLIVIA

CID000438

Conformant

Tin

Estanho de Rondônia S.A.

BRAZIL

CID000448

Not Enrolled

Tin

Fenix Metals

POLAND

CID000468

Conformant

Tin

Gejiu Fengming Metallurgy Chemical Plant

CHINA

CID002848

Conformant

Tin

Gejiu Jinye Mineral Company

CHINA

CID002859

Conformant

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

CID000942

Conformant

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

CID000538

Conformant

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

CID001908

Conformant

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

CID000555

Not Enrolled

Tin

Guangdong Hanhe Non-ferrous Metal Limited Company

CHINA

CID003116

Conformant

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

CHINA

CID002849

Conformant

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

CID002844

Conformant

Tin

Huichang Jinshunda Tin Co., Ltd.

CHINA

CID000760

Conformant

Tin

Jiangxi Ketai Advanced Material Co., Ltd.

CHINA

CID000244

Conformant

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

CID001231

Conformant

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

CID002468

Conformant

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

CID001105

Conformant

Tin

Melt Metais e Ligas S.A.

BRAZIL

CID002500

Conformant

Tin

Metallic Resources, Inc.

UNITED STATES

CID001142

Conformant

Tin

Metallo Belgium N.V.

BELGIUM

CID002773

Conformant

Tin

Metallo Spain S.L.U.

SPAIN

CID002774

Conformant

Tin

Mineracao Taboca S.A.

BRAZIL

CID001173

Conformant

Tin

Minsur

PERU

CID001182

Conformant

Tin

Mitsubishi Materials Corporation

JAPAN

CID001191

Conformant

Tin

Modeltech Sdn Bhd

MALAYSIA

CID002858

Active

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002573

Not Enrolled

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

CID001314

Conformant

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID002517

Conformant

Tin

Operaciones Metalurgical S.A.

BOLIVIA

CID001337

Conformant

Tin

Pongpipat Company Limited

MYANMAR

CID003208

Not Enrolled

Tin

PT Aries Kencana Sejahtera

INDONESIA

CID000309

Conformant

Tin

PT Artha Cipta Langgeng

INDONESIA

CID001399

Conformant

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

CID002503

Conformant

 

Page 7 of 10


 

Tin

PT Babel Inti Perkasa

INDONESIA

CID001402

Conformant

Tin

PT Bangka Prima Tin

INDONESIA

CID002776

Conformant

Tin

PT Bangka Serumpun

INDONESIA

CID003205

Conformant

Tin

PT Bangka Tin Industry

INDONESIA

CID001419

Conformant

Tin

PT Belitung Industri Sejahtera

INDONESIA

CID001421

Conformant

Tin

PT Bukit Timah

INDONESIA

CID001428

Conformant

Tin

PT DS Jaya Abadi

INDONESIA

CID001434

Conformant

Tin

PT Eunindo Usaha Mandiri

INDONESIA

CID001438

Conformant

Tin

PT Inti Stania Prima

INDONESIA

CID002530

Conformant

Tin

PT Karimun Mining

INDONESIA

CID001448

Conformant

Tin

PT Kijang Jaya Mandiri

INDONESIA

CID002829

Conformant

Tin

PT Lautan Harmonis Sejahtera

INDONESIA

CID002870

Conformant

Tin

PT Menara Cipta Mulia

INDONESIA

CID002835

Conformant

Tin

PT Mitra Stania Prima

INDONESIA

CID001453

Conformant

Tin

PT O.M. Indonesia

INDONESIA

CID002757

Conformant

Tin

PT Panca Mega Persada

INDONESIA

CID001457

Conformant

Tin

PT Premium Tin Indonesia

INDONESIA

CID000313

Conformant

Tin

PT Prima Timah Utama

INDONESIA

CID001458

Conformant

Tin

PT Refined Bangka Tin

INDONESIA

CID001460

Conformant

Tin

PT Sariwiguna Binasentosa

INDONESIA

CID001463

Conformant

Tin

PT Stanindo Inti Perkasa

INDONESIA

CID001468

Conformant

Tin

PT Sukses Inti Makmur

INDONESIA

CID002816

Conformant

Tin

PT Sumber Jaya Indah

INDONESIA

CID001471

Conformant

Tin

PT Timah (Persero) Tbk Kundur

INDONESIA

CID001477

Conformant

Tin

PT Timah (Persero) Tbk Mentok

INDONESIA

CID001482

Conformant

Tin

PT Tinindo Inter Nusa

INDONESIA

CID001490

Conformant

Tin

PT Tommy Utama

INDONESIA

CID001493

Conformant

Tin

Resind Industria e Comercio Ltda.

BRAZIL

CID002706

Conformant

Tin

Rui Da Hung

TAIWAN

CID001539

Conformant

Tin

Soft Metais Ltda.

BRAZIL

CID001758

Conformant

Tin

Super Ligas

Brazil

CID002756

Not Enrolled

Tin

Thaisarco

THAILAND

CID001898

Conformant

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002574

Not Enrolled

Tin

White Solder Metalurgia e Mineração Ltda.

BRAZIL

CID002036

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

CID002158

Conformant

 

Page 8 of 10


 

Tin

Yunnan Tin Company Limited

CHINA

CID002180

Conformant

Tungsten

A.L.M.T. TUNGSTEN Corp.

JAPAN

CID000004

Conformant

Tungsten

ACL Metais Eireli

BRAZIL

CID002833

Conformant

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIET NAM

CID002502

Conformant

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

CID002513

Conformant

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID000258

Conformant

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

CHINA

CID000499

Conformant

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

CID002645

Active

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

CID000875

Conformant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

CID002315

Conformant

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

CID002494

Conformant

Tungsten

Ganzhou Yatai Tungsten Co., Ltd.

CHINA

CID002536

Not Enrolled

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES

CID000568

Conformant

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

CID000218

Conformant

Tungsten

H.C. Starck Smelting GmbH & Co.KG

GERMANY

CID002542

Conformant

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

CID002541

Conformant

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000766

Conformant

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CHINA

CID002579

Conformant

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

CID000769

Conformant

Tungsten

Hunan Litian Tungsten Industry Co., Ltd.

CHINA

CID003182

Conformant

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

CID002649

Conformant

Tungsten

Japan New Metals Co., Ltd.

JAPAN

CID000825

Conformant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

CID002551

Conformant

Tungsten

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

CHINA

CID002647

Not Enrolled

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

CID002321

Conformant

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

CID002313

Not Enrolled

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

CID002318

Conformant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

CID002317

Conformant

Tungsten

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

CHINA

CID002535

Conformant

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

CID002316

Conformant

Tungsten

Kennametal Fallon

UNITED STATES

CID000966

Conformant

Tungsten

Kennametal Huntsville

UNITED STATES

CID000105

Conformant

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002319

Conformant

Tungsten

Moliren Ltd

RUSSIAN FEDERATION

CID002845

Conformant

Tungsten

Niagara Refining LLC

UNITED STATES

CID002589

Conformant

 

Page 9 of 10


 

Tungsten

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

VIET NAM

CID002543

Conformant

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

CID002827

Conformant

Tungsten

South-East Nonferrous Metal Company Limited of Hengyang City

CHINA

CID002815

Conformant

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

VIET NAM

CID001889

Conformant

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

CID002724

Conformant

Tungsten

Vietnam Youngsun Tungsten Industry Co., Ltd.

VIET NAM

CID002011

Conformant

Tungsten

Wolfram Bergbau und Hütten AG

AUSTRIA

CID002044

Conformant

Tungsten

Woltech Korea Co., Ltd.

KOREA, REPUBLIC OF

CID002843

Conformant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

CID002320

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

CID002082

Conformant

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CHINA

CID002830

Conformant

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CHINA

CID002095

Conformant

 

 

 

Page 10 of 10


 

Appendix B

Potential Countries of Origin

The list below sets forth the potential countries of origin of 3TGs used in the manufacture of the Products disclosed in the Report. The list is based on publicly available information, our RCOI, and other due diligence efforts. However, for the reasons described in the Report, these possible countries of origin cannot be linked to our Products with reasonable certainty.

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