0000072333-19-000125.txt : 20190531 0000072333-19-000125.hdr.sgml : 20190531 20190531163453 ACCESSION NUMBER: 0000072333-19-000125 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20181231 1.02 20181231 FILED AS OF DATE: 20190531 DATE AS OF CHANGE: 20190531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NORDSTROM INC CENTRAL INDEX KEY: 0000072333 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-FAMILY CLOTHING STORES [5651] IRS NUMBER: 910515058 STATE OF INCORPORATION: WA FISCAL YEAR END: 0201 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-15059 FILM NUMBER: 19870937 BUSINESS ADDRESS: STREET 1: 1617 SIXTH AVENUE CITY: SEATTLE STATE: WA ZIP: 98101-4407 BUSINESS PHONE: 2066282111 MAIL ADDRESS: STREET 1: 1617 SIXTH AVENUE CITY: SEATTLE STATE: WA ZIP: 98101 FORMER COMPANY: FORMER CONFORMED NAME: NORDSTROM BEST INC DATE OF NAME CHANGE: 19730611 SD 1 jwn-05312019xsd.htm FORM SD Document


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
NORDSTROM, INC.
(Exact name of registrant as specified in its charter)
Washington
 
001-15059
 
91-0515058
(State or other jurisdiction
of incorporation or organization)
 
(Commission
File Number)
 
(IRS Employer
Identification No.)
1617 Sixth Avenue, Seattle, Washington
 
98101
(Address of principal executive offices)
 
(Zip Code)
Sheryl Garland
Vice President,
Corporate Secretary and Interim General Counsel
(206) 628-2111
(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
þ
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.






ITEM 1.01 Conflict Minerals Disclosure and Report
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1"), Nordstrom Inc. has filed this Specialized Disclosure Form ("Form SD") and Conflict Minerals Report for calendar year ended December 31, 2018, filed herewith as Exhibit 1.01 and made publicly available at investor.nordstrom.com under the SEC Filings section.
The information contained on our website is not incorporated by reference into this Form SD or our Conflict Minerals Report and should not be considered part of this Form SD or the Conflict Minerals Report.
ITEM 1.02 Exhibit
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
ITEM 2.01 Exhibits
 
Conflict Minerals Report for the calendar year ended December 31, 2018.
EXHIBIT INDEX
 
 
 
EXHIBIT
 
 
NUMBER
 
DESCRIPTION
 
 
 
 
Conflict Minerals Report for the calendar year ended December 31, 2018.
 
 
 
 
 
 
 
 
 
 
 
 





SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
 
NORDSTROM, INC.
(Registrant)
 
 
/s/ Sheryl Garland
Sheryl Garland
Vice President,
Corporate Secretary and Interim General Counsel
 


Date: May 31, 2019



EX-1.01 2 jwn-05312019xex101.htm CONFLICT MINERALS REPORT Exhibit
        

Exhibit 1.01

Conflict Minerals Report
This is the Conflict Minerals Report ("CMR") of Nordstrom, Inc. for calendar year 2018 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1"). Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products that contain gold, columbite-tantalite (tantalum), cassiterite (tin) or wolframite (tungsten) (collectively, "3TG" or "Conflict Minerals"). Unless the context indicates otherwise, the terms “Nordstrom,” “Company,” “we,” “us,” and “our” refer to Nordstrom, Inc. and its consolidated subsidiaries.
For the January 1, 2018 to December 31, 2018, reporting period, we surveyed 287 suppliers of our private label business line, Nordstrom Product Group ("NPG"). NPG products within the scope of this report have been categorized as: apparel, footwear, jewelry, accessories and home goods (the “Covered Products”). This CMR relates to the process undertaken by Nordstrom to determine the source of 3TG potentially contained in products deemed to be manufactured or contracted to be manufactured by NPG.
Forward-Looking Statements
Forward-looking statements in this Report are made pursuant to the safe harbor provisions of Section 21E of the Exchange Act and other federal securities laws. You are cautioned that statements in this Report that are not strictly historical statements, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts, strategy, and future reporting constitute forward-looking statements that involve risks and uncertainties. Actual results could differ materially from the forward-looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities); inadequate supplier education and knowledge; whether smelters and refiners and other market participants responsibly source Conflict Minerals; political developments in Covered Countries, the United States, or elsewhere; limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers, third-party audit programs or others as well as the possibility of future statutory and regulatory changes. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this document or to reflect the occurrence of unanticipated events.
Introduction
Nordstrom, Inc. is a leading fashion retailer based in the U.S. Founded in 1901 as a shoe store in Seattle, today Nordstrom operates 380 stores in 40 states, including 119 full-line stores in the United States, Canada and Puerto Rico; 247 Nordstrom Rack stores; three Jeffrey boutiques; two clearance stores; six Trunk Club clubhouses; and three Nordstrom Local service concepts. Additionally, customers are served online through Nordstrom.com, Nordstromrack.com, HauteLook and TrunkClub.com. Nordstrom, Inc.’s common stock is publicly traded on the NYSE under the symbol JWN.
Nordstrom looks to work with vendors that share its commitment to quality products and see ethical business practices as an important factor in their business approach. Consistent with this commitment, Nordstrom has adopted a Conflict Minerals Policy, which is set forth in its entirety in Part II, section B, below. In accordance with and since the inception of this policy, Nordstrom has conducted both a good faith "reasonable country of origin inquiry" ("RCOI") and subsequent due diligence of its direct NPG suppliers ("Tier 1 Suppliers"). Through the Company's RCOI and due diligence processes, this year Nordstrom concluded that NPG contracted to manufacture a small number of products that contain 3TG necessary to a product's functionality or production.
The RCOI consisted principally of identifying the Tier 1 Suppliers of the Covered Products and circulating to these Tier 1 Suppliers the Conflict Minerals Reporting Template from the Responsible Minerals Initiative. Among the purposes of this supplier survey was to identify, if possible, the supply chain, including smelters or refiners (“SORs”) that contribute refined Conflict Minerals to the Covered Products, and to request information regarding whether any of the necessary Conflict Minerals in the Covered Products originated from the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, with DRC, the "Covered Countries") and whether the Conflict Minerals come from recycled or scrap sources. Based on the results of that RCOI, Nordstrom has reason to believe that some of the Conflict Minerals contained in the Covered Products may have originated in one or more of the Covered Countries. Accordingly, Nordstrom, conducted due diligence on the source and chain of custody of those Conflict Minerals.
Nordstrom’s supply chain with respect to the Covered Products is complex, and Nordstrom, as a purchaser, is many steps removed from the mining and smelting or refining of the Conflict Minerals. Nordstrom does not purchase raw ore or unrefined Conflict Minerals. Because






the SORs are consolidating points for raw ore, Nordstrom believes the SORs are in the best position in the supply chain to determine the origin of the ores. As a result, tracing these minerals to their sources is a challenge that requires Nordstrom to enlist its Tier 1 Suppliers in its efforts to achieve supply chain transparency, including its effort to obtain information regarding the origin of the Conflict Minerals. The information provided by Tier 1 Suppliers may be inaccurate or incomplete or subject to other irregularities. Because of Nordstrom’s relative location within the supply chain in relation to the actual extraction, transport, smelting and refinement of Conflict Minerals, its ability to verify the accuracy of information reported by Tier 1 Suppliers is limited.
Part I. Nordstrom's Conflict Minerals Program
A.
Summary of Findings
Throughout the reporting period ("RY") 2018, Nordstrom continued to deploy its efforts to determine the sourcing mines or location of origin for 3TG contained in its NPG products with the greatest possible specificity. Nordstrom received responses from its survey requests from all its Tier 1 Suppliers contacted, except one supplier that had closed its business and did not respond.
The Company's due diligence efforts indicate that for RY 2018, 95.1% of Tier 1 Suppliers produced products that do not contain 3TG deemed necessary to the functionality or production of the product and 4.9% of Tier 1 Suppliers produced products that do contain 3TG deemed necessary to the functionality or production of the product. Of the 4.9% of Tier 1 Suppliers whose products contain 3TG, all the suppliers that reported they use SORs that source from the Covered Countries indicated that those SORs were determined to be “DRC conflict free” based on the internationally accepted audit standards of the Responsible Minerals Assurance Process (“RMAP”), the London Bullion Market Association Good Delivery Program or the Responsible Jewelry Council Chain of Custody Certification.
Nordstrom was unable to determine the countries of origin for the 3TG contained in the Covered Products produced by two Tier 1 Suppliers. Seventy-one percent of the SORs used by those two suppliers were determined to be “DRC conflict free” based on the audit standards described above. However, 29% of the SORs used by those two suppliers were not certified “DRC conflict free” by the above-referenced organizations.
Finally, eleven Tier 1 Suppliers provided information regarding SORs that was incomplete or inconsistent and therefore Nordstrom was not able to make a determination about the source of any Conflict Minerals in the Covered Products produced by those suppliers.
B.
Continual Improvement
In RY 2019, Nordstrom intends to continue to monitor its internal Conflict Minerals Rule compliance program with the objective of again receiving Conflict Minerals Survey responses from 100% of its suppliers and encouraging suppliers to source from SORs that are known to be conflict free. Nordstrom’s ultimate objective is to develop a supply chain that does not indirectly or directly provide revenue to militia groups in the Covered Countries.
Part II. Due Diligence and Risk Mitigation
Nordstrom's due diligence process is designed to conform, in all material respects, with the nationally and internationally recognized due diligence framework identified by the U.S. Securities and Exchange Commission ("SEC"): OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements ("OECD Guidance"), consistent with Nordstrom’s position as a downstream purchaser.
A.
Design of Due Diligence Framework
With respect to Conflict Minerals, Nordstrom's due diligence framework includes the following key elements:
Establish Strong Company Management Systems
Identify and Assess Risks in the Supply Chain
Design and Implement a Strategy to Respond to Identified Risks
Review Independent Third-Party Audit of Supply Chain
Report Annually on Supply Chain Due Diligence
B.
Due Diligence Measures Performed
1.
Establish Strong Company Management Systems






Nordstrom's management system is a framework of policies, procedures, processes and organizational structure designed to enable the Company to complete all tasks necessary to achieve its objectives. Our system incorporates the following steps:
a.
Adoption of our Conflict Minerals Policy
To help ensure consistent and clear communication of our commitment to responsible Conflict Minerals sourcing, Nordstrom has adopted and periodically reviews a Conflict Minerals policy, which is publicly available at https://shop.nordstrom.com/content/nordstrom-cares-partnership-guidelines?breadcrumb=Home%2FNordstrom+Cares%2FPartnership+Guidelines and provides:
Nordstrom, Inc. ("Nordstrom") is working to ensure that metals and other minerals contained in our Nordstrom private label products are obtained, produced and used in an environmentally and socially responsible manner. In particular, by partnering with our agents and direct suppliers, we will strive to source in ways that do not contribute to human rights abuses.
Under the "conflict minerals" provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, many publicly traded companies, including Nordstrom, are required to better understand how they use four metals: gold, columbite-tantalite (tantalum), cassiterite (tin) and wolframite (tungsten) (collectively, the "Conflict Minerals") and whether those Conflict Minerals originated in the Democratic Republic of Congo ("DRC") or adjoining countries (collectively, the "Covered Countries"). The intent of this regulation is to end the violent conflict in a region that has been financed, in part, by the exploitation and trade of Conflict Minerals originating in the Covered Countries.
We intend to conduct an annual good faith inquiry into the origin of Conflict Minerals that are necessary to the functionality or production of our Nordstrom private label products. This includes requesting certain information from our Nordstrom private label agents and direct suppliers and reporting on these inquiries and due diligence to the U.S. Securities and Exchange Commission ("SEC"). As these inquiries will be reasonably designed to determine whether any such minerals originated in the Covered Countries or are from recycled or scrap sources, we expect our agents and suppliers to participate fully, including by providing complete and timely responses to surveys and other inquiries.
In the event Nordstrom has a reason to believe that Conflict Minerals may have originated in the Covered Countries, Nordstrom will perform due diligence on its supply chain in a manner consistent with the guidance issued by the Organization for Economic Cooperation and Development ("OECD").
All reports we file with the SEC in compliance with the Conflict Minerals law requirements will be available to the public through our website.
Nordstrom partners with companies who share our commitment to making a positive difference. In furtherance of that commitment, we expect all agents and suppliers of our Nordstrom private label products to comply with this Policy.
b.
Internal support for NPG supply chain due diligence
Nordstrom's internal support for Conflict Minerals supply chain due diligence is led by NPG, with support from the Legal Department.
c.
Strengthen engagement with Tier 1 Suppliers
Nordstrom makes suppliers aware of and periodically trains suppliers on its Conflict Minerals Policy and its desire to develop a supply chain that does not indirectly or directly provide revenue to militia groups in the Covered Countries. To further support communication of policies and expectations, NPG again engaged a third-party consultant to engage with suppliers and review and validate the NPG Supplier Conflict Minerals Survey responses.
d.
System of controls and transparency over the NPG supply chain
Nordstrom maintains an internal management system that encompasses a range of processes, activities, and operating procedures to guide the Company’s due diligence efforts. These procedures establish a process to be followed to generate and maintain the information needed to comply with Rule 13p-1.






e.
Mechanisms for reporting Conflict Minerals Policy violations
In the Company's internal and external training communications, parties are informed that concerns or reports of possible violations of Nordstrom's Conflict Minerals Policy can be reported by:
Raising concerns through the Nordstrom Supplier website
Calling Nordstrom's anonymous anticorruption and fraud hotline
In addition, suppliers and other parties are encouraged to contact the Company directly if they seek guidance on the application of this approach or if they wish to report suspected violations.
2.
Identify and Assess Risks in the Supply Chain
The steps outlined below, consistent with the OECD Guidance as applied to downstream companies, were applied by NPG to support the identification and assessment of Conflict Minerals risks in its supply chain.
a.
Identify the SORs in the supply chain
As an initial step to identifying SORs, Nordstrom reviewed its supply chain for products applicable to Rule 13p-1 and determined that NPG "contracts to manufacture" products that may contain 3TG, including, footwear, apparel, jewelry, accessories and home goods. As these materials might be necessary to the functionality of a product, the Company traced the origin of these metals in support of its commitment to sourcing in socially responsible ways that do not contribute to human rights abuses in the Covered Countries. Nordstrom's RCOI process included a combination of measures to determine whether applicable 3TG in the Covered Products originated from Covered Countries.
1)
Identifying Products in Scope
Nordstrom conducted a risk assessment of NPG product categories, including footwear, apparel, jewelry, accessories and home goods. All Tier 1 Suppliers of these products whose manufacture was completed and the goods shipped to Nordstrom between January 1, 2018 and December 31, 2018 were identified. Next, these suppliers were surveyed in an effort to determine whether products provided to NPG contained 3TG, and, if so, the country of origin for the 3TG.
2)
Supplier Engagement
To perform the supplier engagement necessary as part of the RCOI, NPG required its Tier 1 Suppliers to complete the Responsible Minerals Initiative’s Conflict Minerals Reporting Template questionnaire ("NPG Supplier Conflict Minerals Survey"). Nordstrom engaged a third-party consultant to assist with processing the NPG Supplier Conflict Minerals Surveys. The consultant validated the information collected from the Tier 1 Suppliers, including tracking information on SORs and flagging risks based on supplier SOR sourcing practices.
The Company's RCOI efforts resulted in responses from 100% of NPG's Tier 1 Suppliers, with the exception of one Tier 1 Supplier that did not respond due to the closure of its business. A small number of these responses indicated that 3TG was necessary to the functionality or production of products supplied to NPG. Once the Company's RCOI process was complete, the Company, in partnership with its third-party vendor, designed and implemented a supplier due diligence process.
b.
Assessment of risk that SORs have funded conflict in the Covered Countries
To assess the risk that the sourcing practices of its suppliers were funding conflict in the Covered Countries, Nordstrom engaged its third-party consultant to verify whether any known SORs were identified on available lists of SORs that have been certified by internationally recognized industry validation schemes, such as the RMAP, the London Bullion Market Association Good Delivery Program, or the Responsible Jewelry Council Chain-of-Custody Certification. Suppliers associated with certified SORs were recognized as meeting the OECD Guidance due diligence. SORs that satisfy these audit standards are generally considered to source conflict free minerals.
If the SOR was not certified by an internationally-recognized scheme, the SOR was contacted by the third-party consultant in an attempt to gain more information about its sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes the SORs take to track the chain-of-custody on the source of its mineral ores. The relevant information requested included whether the SOR had a documented, effective and communicated conflict-free policy, an accounting system to support a mass balance of materials processed, and traceability documentation.






3.
Design and Implement a Strategy to Respond to Identified Risks
Utilizing the OECD's Red Flag criteria (i.e., Level 2 or 3 Country sourcing or sourcing from unknown reserves), NPG reviewed its supply chain to identify any high risk or potentially high risk SORs and implemented the following measures to address them:
a.
Report findings to senior management
Senior management is briefed periodically on the Company's conflict minerals rule compliance.
b.
Devise and adopt a risk management plan
Nordstrom's Conflict Minerals risk management plan includes processes for internal and external training and communications on its Conflict Minerals Rule compliance policy and practices, transparency throughout the NPG supplier on boarding and review process, reporting to senior management on the key risks associated with Conflict Minerals rule compliance and routine monitoring and reviewing of the effectiveness of Nordstrom's existing processes.
c.
Implement the risk management plan, monitor and track risk mitigation, report to senior management and evaluate supplier relationships
To improve its due diligence process, improve its supply chain transparency, and to further mitigate the risk that its necessary Conflict Minerals finance or benefit armed groups in the Covered Countries, Nordstrom makes suppliers aware of and periodically trains suppliers on its Conflict Minerals Policy and its desire to develop a supply chain that does not indirectly or directly provide revenue to militia groups in the Covered Countries.
With regard to the two Tier 1 Suppliers that provided products from SORs that used 3TG from undetermined sources and the eleven Tier 1 Suppliers who provided inconsistent or incomplete information, Nordstrom is currently reevaluating its relationship with those suppliers and considering whether to locate alternate suppliers. NPG stakeholders have been briefed on these suppliers’ responses to the NPG Supplier Conflict Minerals Survey and enhancements to the Company’s processes to promote sourcing in ways that do not fund the conflict in the Covered Countries are being explored.
4.
Review Independent Third-Party Audit of Supply Chain
Nordstrom does not have any direct relationships with smelters or refiners that process Conflict Minerals, and it does not perform or direct audits of these entities within its supply chain. As an alternative, the Company has considered information collected and provided by independent third-party audit programs, such as the RMAP.
5.
Report Annually on Supply Chain Due Diligence
The Form SD and CMR contained herein and publicly available at investor.nordstrom.com in the SEC Filings section meet the OECD recommendation to report annually on supply chain due diligence.
Part III. Determination
Applying the due diligence process outlined in the above, including information provided by NPG's suppliers, Nordstrom believes that for the reporting period January 1, 2018 to December 31, 2018, NPG products containing Conflict Minerals might have been processed by the smelters and refiners listed in Annex I and sourced from the countries of origin listed in Annex II below. However, in most cases, the information provided by suppliers was provided on a company-wide basis, not on a product-level basis. That is, the information was not specific enough to identify the SORs that processed the Conflict Minerals or the countries of origin of those Conflict Minerals that were used in the specific products provided by the supplier to Nordstrom, but instead included information regarding the SORs that processed Conflict Minerals and the countries of origin of those Conflict Minerals used by the responding supplier only on a company-wide or general product basis. As a result, in those cases, Nordstrom has not been able to reasonably or reliably determine whether the identified SORs have been used to process Conflict Minerals used in the Covered Products actually furnished to Nordstrom or whether the identified countries of origin were countries of origin of Conflict Minerals used in the Covered Products actually furnished to Nordstrom.
Based on the information provided through NPG's Conflict Minerals compliance program, two Tier 1 Suppliers engaged SORs that used 3TG from undetermined sources and eleven Tier 1 Suppliers provided inconsistent or incomplete information regarding the SORs they used such that Nordstrom cannot the countries of origin for all their products.






ANNEX I
Metal
Official Smelter Name
Tungsten
A.L.M.T. TUNGSTEN Corp.
Gold
Abington Reldan Metals, LLC
Tungsten
ACL Metais Eireli
Gold
Advanced Chemical Company
Gold
African Gold Refinery
Gold
Aida Chemical Industries Co., Ltd.
Gold
Al Etihad Gold Refinery DMCC
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Tin
Alpha
Tin
An Vinh Joint Stock Mineral Processing Company
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
Gold
Argor-Heraeus S.A.
Gold
Asahi Pretec Corp.
Gold
Asahi Refining Canada Ltd.
Gold
Asahi Refining USA Inc.
Gold
Asaka Riken Co., Ltd.
Tantalum
Asaka Riken Co., Ltd.
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold
AU Traders and Refiners
Gold
Aurubis AG
Gold
Bangalore Refinery
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold
Boliden AB
Gold
C. Hafner GmbH + Co. KG
Gold
Caridad
Gold
CCR Refinery - Glencore Canada Corporation
 
Metal
Official Smelter Name
Gold
Cendres + Metaux S.A.
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
Gold
Chimet S.p.A.
Tin
China Tin Group Co., Ltd.
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
Gold
Chugai Mining
Tin
CV Ayi Jaya
Tin
CV Dua Sekawan
Tin
CV Gita Pesona
Tin
CV United Smelting
Tin
CV Venus Inti Perkasa
Tantalum
D Block Metals, LLC
Gold
Daejin Indus Co., Ltd.
Gold
Daye Non-Ferrous Metals Mining Ltd.
Gold
Degussa Sonne / Mond Goldhandel GmbH
Gold
DODUCO Contacts and Refining GmbH
Gold
Dowa
Tin
Dowa
Gold
DS PRETECH Co., Ltd.
Gold
DSC (Do Sung Corporation)
Gold
Eco-System Recycling Co., Ltd.
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin
EM Vinto
Gold
Emirates Gold DMCC






Metal
Official Smelter Name
Tin
Estanho de Rondonia S.A.
Tantalum
Exotech Inc.
Tantalum
F&X Electro-Materials Ltd.
Tin
Fenix Metals
Gold
Fidelity Printers and Refiners Ltd.
Tantalum
FIR Metals & Resource Ltd.
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
Gold
Geib Refining Corporation
Tin
Gejiu Fengming Metallurgy Chemical Plant
Tin
Gejiu Jinye Mineral Company
Tin
Gejiu Kai Meng Industry and Trade LLC
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
Tantalum
Global Advanced Metals Aizu
Tantalum
Global Advanced Metals Boyertown
Tungsten
Global Tungsten & Powders Corp.
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
Gold
Guangdong Jinding Gold Limited
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
 
Metal
Official Smelter Name
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Tantalum
H.C. Starck Co., Ltd.
Tantalum
H.C. Starck Hermsdorf GmbH
Tantalum
H.C. Starck Inc.
Tantalum
H.C. Starck Ltd.
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Tungsten
H.C. Starck Smelting GmbH & Co. KG
Tantalum
H.C. Starck Tantalum and Niobium GmbH
Tungsten
H.C. Starck Tungsten GmbH
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold
HeeSung Metal Ltd.
Gold
Heimerle + Meule GmbH
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
Gold
Heraeus Metals Hong Kong Ltd.
Gold
Heraeus Precious Metals GmbH & Co. KG
Tin
HuiChang Hill Tin Industry Co., Ltd.
Tin
Huichang Jinshunda Tin Co., Ltd.
Gold
Hunan Chenzhou Mining Co., Ltd.
Tungsten
Hunan Chenzhou Mining Co., Ltd.
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
Gold
HwaSeong CJ CO., LTD.
Tungsten
Hydrometallurg, JSC
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold
Ishifuku Metal Industry Co., Ltd.






Metal
Official Smelter Name
Gold
Istanbul Gold Refinery
Gold
Italpreziosi
Gold
Japan Mint
Tungsten
Japan New Metals Co., Ltd.
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Gold
Jiangxi Copper Co., Ltd.
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tin
Jiangxi New Nanshan Technology Ltd.
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tantalum
Jiangxi Tuohong New Raw Material
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
Tantalum
Jiujiang Janny New Material Co., Ltd.
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum
Jiujiang Tanbre Co., Ltd.
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold
JSC Uralelectromed
Gold
JX Nippon Mining & Metals Co., Ltd.
Gold
Kaloti Precious Metals
Gold
Kazakhmys Smelting LLC
Gold
Kazzinc
Tantalum
KEMET Blue Metals
Tantalum
Kemet Blue Powder
Tungsten
Kennametal Fallon
 
Metal
Official Smelter Name
Tungsten
Kennametal Huntsville
Gold
Kennecott Utah Copper LLC
Gold
KGHM Polska Miedz Spolka Akcyjna
Gold
Kojima Chemicals Co., Ltd.
Gold
Korea Zinc Co., Ltd.
Gold
Kyrgyzaltyn JSC
Gold
Kyshtym Copper-Electrolytic Plant ZAO
Gold
L'azurde Company For Jewelry
Gold
Lingbao Gold Co., Ltd.
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold
L'Orfebre S.A.
Tantalum
LSM Brasil S.A.
Gold
LS-NIKKO Copper Inc.
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Tin
Magnu's Minerais Metais e Ligas Ltda.
Tin
Malaysia Smelting Corporation (MSC)
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
Gold
Marsam Metals
Tungsten
Masan Tungsten Chemical LLC (MTC)
Gold
Materion
Gold
Matsuda Sangyo Co., Ltd.
Tin
Melt Metais e Ligas S.A.
Tin
Metallic Resources, Inc.
Tin
Metallo Belgium N.V.
Tin
Metallo Spain S.L.U.
Tantalum
Metallurgical Products India Pvt., Ltd.
Gold
Metalor Technologies (Hong Kong) Ltd.
Gold
Metalor Technologies (Singapore) Pte., Ltd.






Metal
Official Smelter Name
Gold
Metalor Technologies (Suzhou) Ltd.
Gold
Metalor Technologies S.A.
Gold
Metalor USA Refining Corporation
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
Tantalum
Mineracao Taboca S.A.
Tin
Mineracao Taboca S.A.
Tin
Minsur
Gold
Mitsubishi Materials Corporation
Tin
Mitsubishi Materials Corporation
Gold
Mitsui Mining and Smelting Co., Ltd.
Tantalum
Mitsui Mining and Smelting Co., Ltd.
Gold
MMTC-PAMP India Pvt., Ltd.
Gold
Modeltech Sdn Bhd
Tin
Modeltech Sdn Bhd
Tungsten
Moliren Ltd.
Gold
Morris and Watson
Gold
Morris and Watson Gold Coast
Gold
Moscow Special Alloys Processing Plant
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
Gold
Navoi Mining and Metallurgical Combinat
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Gold
NH Recytech Company
Tungsten
Niagara Refining LLC
Gold
Nihon Material Co., Ltd.
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum
NPM Silmet AS
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Tin
O.M. Manufacturing Philippines, Inc.
 
Metal
Official Smelter Name
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Gold
Ohura Precious Metal Industry Co., Ltd.
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Gold
OJSC Novosibirsk Refinery
Tin
Operaciones Metalurgical S.A.
Gold
PAMP S.A.
Gold
Pease & Curren
Gold
Penglai Penggang Gold Industry Co., Ltd.
Tungsten
Philippine Chuangxin Industrial Co., Inc.
Gold
Planta Recuperadora de Metales SpA
Tin
Pongpipat Company Limited
Tantalum
Power Resources Ltd.
Gold
Prioksky Plant of Non-Ferrous Metals
Gold
PT Aneka Tambang (Persero) Tbk
Tin
PT Aries Kencana Sejahtera
Tin
PT Artha Cipta Langgeng
Tin
PT ATD Makmur Mandiri Jaya
Tin
PT Babel Inti Perkasa
Tin
PT Bangka Prima Tin
Tin
PT Bangka Serumpun
Tin
PT Bangka Tin Industry
Tin
PT Belitung Industri Sejahtera
Tin
PT Bukit Timah
Tin
PT DS Jaya Abadi
Tin
PT Inti Stania Prima
Tin
PT Karimun Mining
Tin
PT Kijang Jaya Mandiri
Tin
PT Menara Cipta Mulia






Metal
Official Smelter Name
Tin
PT Mitra Stania Prima
Tin
PT Panca Mega Persada
Tin
PT Premium Tin Indonesia
Tin
PT Prima Timah Utama
Tin
PT Rajehan Ariq
Tin
PT Refined Bangka Tin
Tin
PT Sariwiguna Binasentosa
Tin
PT Stanindo Inti Perkasa
Tin
PT Sukses Inti Makmur
Tin
PT Sumber Jaya Indah
Tin
PT Timah (Persero) Tbk Kundur
Tin
PT Timah (Persero) Tbk Mentok
Tin
PT Tinindo Inter Nusa
Tin
PT Tommy Utama
Gold
PX Precinox S.A.
Tantalum
QuantumClean
Gold
Rand Refinery (Pty) Ltd.
Gold
Refinery of Seemine Gold Co., Ltd.
Gold
REMONDIS PMR B.V.
Tantalum
Resind Industria e Comercio Ltda.
Tin
Resind Industria e Comercio Ltda.
Gold
Royal Canadian Mint
Tin
Rui Da Hung
Gold
SAAMP
Gold
Sabin Metal Corp.
Gold
Safimet S.p.A
Gold
SAFINA A.S.
Gold
Sai Refinery
 
Metal
Official Smelter Name
Gold
Samduck Precious Metals
Gold
SAMWON METALS Corp.
Gold
SAXONIA Edelmetalle GmbH
Gold
SEMPSA Joyeria Plateria S.A.
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold
Sichuan Tianze Precious Metals Co., Ltd.
Gold
Singway Technology Co., Ltd.
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Tin
Soft Metais Ltda.
Gold
Solar Applied Materials Technology Corp.
Tantalum
Solikamsk Magnesium Works OAO
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
Gold
State Research Institute Center for Physical Sciences and Technology
Gold
Sudan Gold Refinery
Gold
Sumitomo Metal Mining Co., Ltd.
Gold
SungEel HiMetal Co., Ltd.
Tin
Super Ligas
Gold
T.C.A S.p.A
Tantalum
Taki Chemical Co., Ltd.
Gold
Tanaka Kikinzoku Kogyo K.K.
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Tantalum
Telex Metals
Tin
Thaisarco
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
Gold
Tokuriki Honten Co., Ltd.
Gold
Tongling Nonferrous Metals Group Co., Ltd.
Gold
Tony Goetz NV






Metal
Official Smelter Name
Gold
TOO Tau-Ken-Altyn
Gold
Torecom
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tantalum
Ulba Metallurgical Plant JSC
Gold
Umicore Brasil Ltda.
Gold
Umicore Precious Metals Thailand
Gold
Umicore S.A. Business Unit Precious Metals Refining
Tungsten
Unecha Refractory Metals Plant
Gold
United Precious Metal Refining, Inc.
Gold
Universal Precious Metals Refining Zambia
Gold
Valcambi S.A.
Gold
Western Australian Mint (T/a The Perth Mint)
Tin
White Solder Metalurgia e Mineracao Ltda.
Gold
WIELAND Edelmetalle GmbH
Tungsten
Wolfram Bergbau und Hutten AG
Tungsten
Woltech Korea Co., Ltd.
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten
Xiamen Tungsten Co., Ltd.
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
Tantalum
XinXing Haorong Electronic Material Co., Ltd.
Gold
Yamakin Co., Ltd.
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
Gold
Yokohama Metal Co., Ltd.
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Gold
Yunnan Copper Industry Co., Ltd.
Tin
Yunnan Tin Company Limited
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
 







ANNEX II
Angola
Laos
Argentina
Luxembourg
Armenia
Madagascar
Australia
Malaysia
Austria
Mali
Belarus
Mexico
Belgium
Mongolia
Bermuda
Morocco
Bolivia
Mozambique
Brazil
Myanmar
Burundi
Namibia
Cambodia
Netherlands
Canada
New Zealand
Central African Republic
Niger
Chile
Nigeria
China
Papua New Guinea
Colombia
Peru
Congo (Brazzaville)
Philippines
Czech Republic
Poland
Djibouti
Portugal
DRC- Congo (Kinshasa)
Russian Federation
Ecuador
Rwanda
Egypt
Saudi Arabia
Estonia
Sierra Leone
Ethiopia
Singapore
Finland
Slovakia
France
South Africa
Germany
South Sudan
Ghana
Spain
Guinea
Suriname
Guyana
Sweden
Hong Kong
Switzerland
Hungary
Taiwan
India
Tajikistan
Indonesia
Tanzania
Ireland
Thailand
Israel
Turkey
Italy
Uganda
Ivory Coast
United Arab Emirates
Japan
United Kingdom
Jersey
United States
Kazakhstan
Uzbekistan
Kenya
Viet Nam
Korea, Republic of
Zambia
Kyrgyzstan
Zimbabwe