EX-1.01 2 exhibit102.htm EXHIBIT 1.01 Exhibit


Exhibit 1.02
Pitney Bowes Inc. Conflict Minerals Report
(as required by Item 1.01 and 1.02 of Form SD)
Pitney Bowes Inc. ("we," "us," "our," or the "Company") submits this report pursuant to Rule 13p-1 and Form SD (the "Rule") promulgated under the Securities Exchange Act of 1934 and adopted by the Securities and Exchange Commission pursuant to Section 1502 of the Dodd-Frank Financial Reform and Consumer Protection Act (the "Act"). This report describes the inquiry the Company undertook to obtain information from internal and external sources to ascertain whether any Pitney Bowes product contains tantalum, tin, tungsten, or gold ("Conflict Minerals" or "3TG") that originated in the Democratic Republic of the Congo or adjoining countries, as defined in the Act (collectively, the "Covered Countries"), and the due diligence Pitney Bowes conducted on the source and chain of custody of such minerals. This report covers parts and products manufactured or contracted to manufacture by the Company in the 2019 calendar year. Based on our inquiry, we have found that Conflict Minerals are necessary to the functionality or production of some of our products manufactured or contracted to manufacture in 2019.
Based on our due diligence for these 2019 products, our suppliers identified a total of 296 potential smelters or refiners in their supply chains that are also identified as smelters or refiners of 3TG in the Smelter Reference List of the Responsible Minerals Initiative's ("RMI") Conflict Minerals Reporting Template ("Template"). For a list of these reported entities, please refer to Appendix A.

•
243 of these 296 smelters, or 82%, are listed as conformant or active with the Responsible Minerals Assurance Process ("RMAP") (as of November 2019) - listed in Appendix A as "Active" or "Conformant"
•
45 of these 296 smelters are engaged in the RMI process but not yet finished - listed in Appendix A as "In Communication" or "Outreach Required"
•
8 of these 296 smelters are listed as "Due Diligence Vetting Process," "Communication Suspended - Not Interested" or "Non-Conformant" in Appendix A

Further investigation performed by a reputable third party on smelters listed as "Communication Suspended - Not
Interested" or "Non-Conformant" revealed that:

•
1 (Morris and Watson) is not certified as conformant to or active with an independent third-party audit program such as RMAP but claims to be a recycler and sourcing gold from New Zealand
•
1 (Abington Reldan Metals, LLC) had its status updated shortly before our follow-up investigation and is listed as a recycler
•
4 are listed as not certified as conformant to an independent third-party audit program such as RMAP, and Pitney Bowes is considering further action

Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry to determine whether any of the necessary conflict minerals in our products originated in the Covered Countries or were from recycled or scrap sources. To make this determination, we focused on engaging our direct suppliers to identify the smelters and refiners of necessary conflict minerals that may have been contained in our products and that are recognized by the RMI to be processors of conflict minerals, and reviewing available information on the sourcing of conflict minerals by these smelters and refiners.

As a downstream company, we are several levels removed from mining minerals. We did not buy any minerals directly from mines, smelters, or refiners for use in these 2019 products. Information regarding the countries from which the identified smelters and refiners may source 3TG was not readily available to us and was not always provided to us by the Surveyed Suppliers (defined below). As part of our efforts to determine the mine or location of origin of 3TG in our products, we searched for publicly available information on the sourcing practices of identified smelters and refiners. In some instances, conflict mineral policies and related resources were available on the RMI website for identified smelters

and refiners that are listed as conformant with RMAP assessment protocols. However, we were unable to locate country of origin information for the Conflict Minerals processed by many of the identified smelters and refiners. In addition, many of the Surveyed Suppliers identified all of the smelters and refiners potentially associated with all of




their product offering and did not always limit the information provided to products supplied to Pitney Bowes. To the extent we located information on the potential origin of 3TG processed by these conformant smelters or refiners, we identify those countries in Appendix B. However, due to limitations discussed above, Pitney Bowes is unable to confirm whether necessary 3TG metals contained in our products in fact originated in any of these countries.

Our due diligence activities are further described in this report.

1.
Pitney Bowes' Design of Due Diligence
A.
Due Diligence Framework
We designed our due diligence to conform, in all material respects, with the framework set out in the "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas" and related Supplements on Tin, Tantalum and Tungsten and on Gold ("OECD Guidance"), published by the Organisation for Economic Cooperation and Development (the "OECD"). Since the Company does not buy Conflict Minerals directly from mines, smelters or refiners, we must rely on our suppliers to provide us with information regarding the source of the Conflict Minerals contained in the products and parts those suppliers provide to us. Our direct suppliers are similarly reliant upon information provided by their suppliers. In this regard, we have designed our due diligence to leverage the due diligence tools developed by RMI, including a supplier survey based on the Template, which is designed to help companies identify the smelters and refiners that process the Conflict Minerals in a company's supply chain. We have incorporated the following five-step, risk-based approach to 3TG due diligence based on OECD Guidance into the design of our Conflict Minerals due diligence program:

•
establish and maintain appropriate internal management systems to identify and manage the 3TG in our global supply chain;

•
identify and assess any risks associated with the use of 3TG in our supply chain by obtaining and evaluating 3TG sourcing information from suppliers;

•
design and implement a strategy to respond to 3TG risks in our supply chain;


•
support independent auditing of smelter and refiner due diligence practices; and


•
report publicly on supply chain due diligence.



B.
Scope of Due Diligence.
In order to determine if products manufactured or contracted to manufacture by Pitney Bowes contain 3TG sourced from Covered Countries, we sought out industry best practices, reviewed current guidance from various associations such as the OECD and the Information Technology Industry Council ("ITI"), and attended industry association meetings to assess how other multinational corporations were approaching Conflict Minerals compliance.
Working with outside consultants, we developed a Conflict Minerals survey based on the Template and guidance from the RMI and ITI. Adapting to the evolution of Pitney Bowes' portfolio of products, we identified the suppliers involved in the supply chain of our Pitney Bowes branded products. We then removed suppliers that either do not contain tin, tantalum, tungsten or gold, or otherwise supplied equipment that is out of scope. Ultimately, we sent the Conflict Minerals survey to

the 51 suppliers who (the "Surveyed Suppliers") are impacted by this rule. We asked the Surveyed Suppliers to respond with certain information, including their Conflict Minerals policies, usage of 3TG, and the smelters and refiners of Conflict Minerals in their supply chains.
The Surveyed Suppliers who completed the survey were asked to attest to the accuracy of their survey responses. The Product Compliance Team (defined below) monitored supplier responses to our surveys and contacted the Surveyed Suppliers who submitted incomplete responses or who failed to respond. We requested updated submittals from the




Surveyed Suppliers that submitted responses with a less than 75% response rate from their supply chain and suppliers that listed smelters with inaccurate information. Data received from Surveyed Suppliers through March 18, 2020 have been included in this report.
We collected and tracked the survey responses in our product compliance database for consolidation, validation, and further analysis. We also generated periodic status reports to track and review our progress in data collection and evaluate which suppliers needed additional help in completing the survey.

A.
Due Diligence Results for Pitney Bowes' 2019 Products
Based on our due diligence, we determined that Conflict Minerals were necessary to the functionality or production of various products from our hardware product offerings list, which includes a varied array of equipment that processes direct mail and/or enables transactional mail management and analytics that we manufactured or contracted to manufacture in 2019.
Some examples of these products include: postage meters, low-/medium-/high-volume mailing systems that can weigh, seal and apply postage to envelopes; inserters; folders; mail openers; tabbers; scales; printers; accessories; and peripherals.

B.
Pitney Bowes' Conflict Minerals Disclosure Posting
We have made public our activities related to Conflict Minerals in our Corporate Responsibility Report and have posted this Conflict Minerals Report to our website (follow this link and click on the Clients and Suppliers tab: Pitney Bowes Corporate Responsibility).1



2.
Pitney Bowes' Due Diligence Measures Undertaken for 2019 Products
In an effort to continue to identify and mitigate any risk that the use of 3TG in our products going forward may benefit armed groups in the Covered Countries, we have incorporated the relevant aspects of the OECD Guidance (as summarized in the sections that follow) into our risk management program for product stewardship requirements (including Conflict Minerals).

A.
Development of an Internal, Strong Management System.
1.
High level management oversight
In order to provide effective management support for, and high level escalation of issues relating to, the Company's overall supply chain due diligence efforts (inclusive of conflict minerals), we formed two cross-functional teams: the Environmental Product Compliance Team (the "Product Compliance Team") and the Environmental Committee (the "Environmental Committee").
The Product Compliance Team is comprised of representatives from Procurement, Supply Chain, Quality, Engineering, Environmental Health and Safety ("EHS"), and Global Product Line Management and other support groups. This team is responsible for assisting the Company in meeting the requirements of global product-compliance regulations.




1 References to our website and information available through this website are not incorporated by reference herein unless otherwise noted.









The Environmental Committee is made up of departmental managers holding senior positions in various departments in the company including: Procurement, Global Supply Chain, Engineering, EHS, Quality, Ethics and Compliance, Legal, Global Product Line Management, Enterprise Risk and Internal Audit and oversees the work of the Product Compliance Team. The Environmental Committee is tasked with providing guidance regarding environmental product compliance, authorizing the financial and human resources needed for product compliance, and enforcing corrective action measures within Company operations and within our supply chain. Members of the Environmental Committee report potential issues and company risks to the Enterprise Risk Management team. The Enterprise Risk Management team, comprised or members of senior management from various functions and business units, reviews the Company's efforts in managing a wide range of risks of the Company.

1.
Pitney Bowes' Conflict Minerals policy and procedures
We established a conflict minerals policy to guide our communications with and expectations for suppliers regarding Conflict Minerals. It is the Company's goal that we will not knowingly manufacture or contract to manufacture products that include Conflict Minerals that originate from the Covered Countries, unless they were processed by smelters and refiners that are certified as responsible or came from recycled or scrap sources. We communicated our expectation that our Surveyed Suppliers source products, parts and components from socially responsible sources and conduct reasonable due diligence on their supply chains in an effort to assure that Conflict Minerals are not knowingly sourced from the Covered Countries unless they were processed by smelters and refiners that are conformant with the RMAP or came from recycled or scrap sources.
We adopted and periodically review certain procedures and maintain the following steps regarding our use of 3TG:
•
Our Supplier Code of Conduct describes our Conflict Minerals and other product compliance requirements;


•
Our engineering standards and specifications include requirements to specify that suppliers must meet Section 1502(4) of the Dodd Frank Act;

•
Our Quality Assurance audit templates include supplier requirements with respect to products containing 3TG;

•
Incorporated consideration of conflict mineral issues within the Pitney Bowes Product Review Process


•
Periodically update and distribute to all suppliers our contractual language regarding certification that 3TG from Covered Countries is conflict free or came from recycled or scrap sources;

•
Annually publish Conflict Minerals information on our website and in our Corporate Responsibility Report;

•
Include Conflict Minerals in Enterprise Risk Management meetings to ensure regular review by our management;

•
Include review of Conflict Minerals supply chain data and related processes to the Company's standardized
environmental compliance reviews of key suppliers;


•
Complete training classes through our learning management system and via video-conference and in person classes in order to educated relevant employees, where necessary;

•
Educate Suppliers and other partners regarding Conflict Minerals during business reviews, where necessary;

•
Continue to require Surveyed Suppliers to complete surveys with the goal of identifying the smelters and refineries used to process Conflict Minerals in their supply chain;

•
Maintain internal policies, written procedures, tools and training to ensure effective implementation of our Conflict Minerals management program;





•
Track and report supplier data in a product compliance information database and


•
Manage a supplier escalation protocol to ensure consistent and thorough management of unresponsive suppliers when needed - this protocol documents our supplier engagement and how we interact with unresponsive suppliers or suppliers who provide incomplete, questionable, or indeterminable information.

2.
Pitney Bowes' system of controls and transparency over the 3TG supply chain
As part of the Company's broader requirement that our suppliers provide us with accurate and complete information relating to the sources of all substances contained in any product, part or component they provide to us, we required that Surveyed Suppliers provide us with information on Conflict Minerals contained in such products, parts, or components.
Surveyed Suppliers who failed to respond to our request for data were subject to additional evaluation to determine whether further engagement or escalation was necessary.

3.
Pitney Bowes' engagement with suppliers
The Company has multiple methods to encourage our suppliers to commit to our policies requiring responsible supplier operations. We have communicated our Conflict Minerals requirements to our Suppliers and other product stewardship requirements, as applicable, to our global supply chain. In connection with our data collection efforts, we have explained to our Suppliers our requirements that they conduct their operations as socially responsible suppliers. In addition, we have revised our supplier form contract wording to include compliance with our Conflict Minerals efforts. Our supplier contracts have long contained provisions giving us the right to conduct unannounced visits to supplier sites and to request documentation to confirm the supplier's compliance with our policies and contractual requirements. Our Surveyed Suppliers have received information regarding Conflict Minerals requirements and completion of our product compliance database.

4.
Pitney Bowes' Company-level grievance mechanism
For many years, Pitney Bowes has maintained an Ethics Help Line which is available toll-free, 24 hours a day, seven days a week. The Ethics Help Line is operated by an outside firm and enables employees, clients and others to make inquiries and report concerns about potential violations of Company policy or the law, in many languages, without fear of retaliation. Anyone can contact the Ethics Help Line to report any concerns about Conflict Minerals that may be contained in our products.

B.
Identification and Assessment of Risk in Our Supply Chain.
The Company continues its program of conducting supply chain due diligence and risk assessment on supplier sources of 3TGs as described above in Section 1.

C.
Strategy for Responding to Identified Risks in Our 3TG Supply Chain.
As described above, the Product Compliance Team monitored supplier responses to our surveys and contacted Surveyed Suppliers who submitted incomplete responses or who failed to respond so that we could understand what was preventing them from submitting a full and final attestation regarding their product line. The Product Compliance Team also reviewed the data from the product compliance database to determine which Surveyed Suppliers had data gaps, had raised questions or had not been responsive. Any Surveyed Suppliers that were considered non-responsive or higher risk were escalated to designated internal teams and management for further evaluation as they were identified.
We also reported the findings and information gathered through our inquiry and due diligence to Pitney Bowes senior management.

D.
Support for Independent Third-party Audits of Supply Chain Due Diligence

Since we do not have direct relationships with smelters or refiners, we did not perform direct audits of these entities' supply




chains of Conflict Minerals. However, we supported the development and implementation of smelter and refinery sourcing audits conducted by independent third parties and industry groups, such as the RMI's RMAP, through our conflict minerals policy and expectations regarding responsible sourcing of minerals from the Covered Countries.

3. Future Actions to Further Minimize Any Risk of Conflict Minerals Benefitting Armed Groups
The Company will continue to request information from our supply chain in order to meet the requirements of the Rule. Where there is reason to believe that a supplier is not adopting a Conflict Minerals policy or providing the necessary data to us, we will work with the supplier to address the issue. In the event of continued supplier deficiencies, we will consider appropriate measures including, if and as appropriate, termination of our relationship with a supplier.































Appendix A

List of Smelters / Refiners Identified by the Surveyed Suppliers

The following list provides the name, location and status of smelters and refiners identified by the Surveyed Suppliers. Pitney Bowes is unable to confirm that any or all smelters and refiners in this list processed the necessary 3TG metals contained in our products, since a number of the Surveyed Suppliers identified all smelters and refiners in their total supply chain and did not limit their responses to the specific products supplied to Pitney Bowes.

Smelter and refiner names and locations were drawn from the Smelter Reference List in the latest version of the Conflict Minerals Reporting Template ("Template"). Smelter and refiner status is based on information available to Pitney Bowes as of November 2019.    "Conformant" means listed by Responsible Minerals Initiative ("RMI") as conformant with Responsible Minerals Assurance Process ("RMAP") assessment protocols; "Active" means listed by RMI as having committed to undergo an audit or as participating in a similar assessment program such as the LBMA Responsible Gold Certification or Responsible Jewelry Council's Chain-of-Custody Certification. Smelters or refiners listed as "In Communication" or "Outreach Required" have begun discussions with or will be encouraged to participate in the RMAP audit.    Smelters and refiners designated by RMI as "Non-Conformant", "Communication Suspended - Not Interested", and "Due Diligence Vetting Process" are not currently conformant with RMAP assessment protocols and/or are not currently progressing toward participation in an audit. Entities that are no longer recognized as smelters or refiners are not included in the reference list below (for example, if they are no longer included in the Smelter Reference List of RMI's Template based on RMI's determination that the entity did not actually engage in smelting or refining activities or if we or RMI believe they are no longer in operation).

Metal
Smelter /Refiner Name
RMI Audit Status
Smelter/Refiner Location
Gold
8853 S.p.A.
Conformant
ITALY
Gold
Abington Reldan Metals, LLC
Non-Conformant
UNITED STATES OF AMERICA
Gold
Advanced Chemical Company
Conformant
UNITED STATES OF AMERICA
Gold
African Gold Refinery
Outreach Required
UGANDA
Gold
Aida Chemical Industries Co., Ltd.
Conformant
JAPAN
Gold
Al Etihad Gold Refinery DMCC
Conformant
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Conformant
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Conformant
UZBEKISTAN
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
Conformant
BRAZIL
Gold
Argor-Heraeus S.A.
Conformant
SWITZERLAND
Gold
Asahi Pretec Corp.
Conformant
JAPAN
Gold
Asahi Refining Canada Ltd.
Conformant
CANADA
Gold
Asahi Refining USA Inc.
Conformant
UNITED STATES OF AMERICA
Gold
Asaka Riken Co., Ltd.
Conformant
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Due Diligence Vetting Process
TURKEY
Gold
AU Traders and Refiners
Conformant
SOUTH AFRICA
Gold
Aurubis AG
Conformant
GERMANY
Gold
Bangalore Refinery
Conformant
INDIA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Conformant
PHILIPPINES
Gold
Boliden AB
Conformant
SWEDEN






Gold
C. Hafner GmbH + Co. KG
Conformant
GERMANY
Gold
Caridad
Communication Suspended - Not Interested
MEXICO
Gold
CCR Refinery - Glencore Canada Corporation
Conformant
CANADA
Gold
Cendres + Metaux S.A.
Conformant
SWITZERLAND
Gold
CGR Metalloys Pvt Ltd.
Outreach Required
INDIA
Gold
Chimet S.p.A.
Conformant
ITALY
Gold
Chugai Mining
Conformant
JAPAN
Gold
Daye Non-Ferrous Metals Mining Ltd.
In Communication
CHINA
Gold
Degussa Sonne / Mond Goldhandel GmbH
Outreach Required
GERMANY
Gold
Dijllah Gold Refinery FZC
In Communication
UNITED ARAB EMIRATES
Gold
DODUCO Contacts and Refining GmbH
Conformant
GERMANY
Gold
Dowa
Conformant
JAPAN
Gold
DS PRETECH Co., Ltd.
Conformant
KOREA, REPUBLIC OF
Gold
DSC (Do Sung Corporation)
Conformant
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd.
Conformant
JAPAN
Gold
Eco-System Recycling Co., Ltd. North Plant
Conformant
JAPAN
Gold
Eco-System Recycling Co., Ltd. West Plant
Conformant
JAPAN
Gold
Emirates Gold DMCC
Conformant
UNITED ARAB EMIRATES
Gold
Fidelity Printers and Refiners Ltd.
Due Diligence Vetting Process
ZIMBABWE
Gold
Fujairah Gold FZC
Outreach Required
UNITED ARAB EMIRATES
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
Outreach Required
INDIA
Gold
Geib Refining Corporation
Conformant
UNITED STATES OF AMERICA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
Conformant
CHINA
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
Outreach Required
CHINA
Gold
Guangdong Jinding Gold Limited
Outreach Required
CHINA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Outreach Required
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
Outreach Required
CHINA
Gold
HeeSung Metal Ltd.
Conformant
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH
Conformant
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
Conformant
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
Conformant
GERMANY
Gold
Hunan Chenzhou Mining Co., Ltd.
Outreach Required
CHINA
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
Outreach Required
CHINA
Gold
Hwasung CJ Co., Ltd.
Communication Suspended - Not Interested
KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Conformant
CHINA
Gold
International Precious Metal Refiners
Outreach Required
UNITED ARAB EMIRATES






Gold
Ishifuku Metal Industry Co., Ltd.
Conformant
JAPAN
Gold
Istanbul Gold Refinery
Conformant
TURKEY
Gold
Italpreziosi
Conformant
ITALY
Gold
Japan Mint
Conformant
JAPAN
Gold
Jiangxi Copper Co., Ltd.
Conformant
CHINA
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Conformant
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
Conformant
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
Conformant
JAPAN
Gold
Kaloti Precious Metals
Outreach Required
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
In Communication
KAZAKHSTAN
Gold
Kazzinc
Conformant
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
Conformant
UNITED STATES OF AMERICA
Gold
KGHM Polska Miedz Spolka Akcyjna
Conformant
POLAND
Gold
Kojima Chemicals Co., Ltd.
Conformant
JAPAN
Gold
Korea Zinc Co., Ltd.
Conformant
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn JSC
Conformant
KYRGYZSTAN
Gold
Kyshtym Copper-Electrolytic Plant ZAO
Outreach Required
RUSSIAN FEDERATION
Gold
L'azurde Company For Jewelry
Outreach Required
SAUDI ARABIA
Gold
Lingbao Gold Co., Ltd.
Outreach Required
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Outreach Required
CHINA
Gold
L'Orfebre S.A.
Conformant
ANDORRA
Gold
LS-NIKKO Copper Inc.
Conformant
KOREA, REPUBLIC OF
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Outreach Required
CHINA
Gold
Marsam Metals
Conformant
BRAZIL
Gold
Materion
Conformant
UNITED STATES OF AMERICA
Gold
Matsuda Sangyo Co., Ltd.
Conformant
JAPAN
Gold
Metalor Technologies (Hong Kong) Ltd.
Conformant
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Conformant
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.
Conformant
CHINA
Gold
Metalor Technologies S.A.
Conformant
SWITZERLAND
Gold
Metalor USA Refining Corporation
Conformant
UNITED STATES OF AMERICA
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
Conformant
MEXICO
Gold
Mitsubishi Materials Corporation
Conformant
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
Conformant
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.
Conformant
INDIA
Gold
Modeltech Sdn Bhd
Active
MALAYSIA
Gold
Morris and Watson
Communication Suspended - Not Interested
NEW ZEALAND
Gold
Moscow Special Alloys Processing Plant
Conformant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
Conformant
TURKEY
Gold
Navoi Mining and Metallurgical Combinat
Outreach Required
UZBEKISTAN






Gold
NH Recytech Company
Active
KOREA, REPUBLIC OF
Gold
Nihon Material Co., Ltd.
Conformant
JAPAN
Gold
Ogussa Osterreichische Gold- und Silber- Scheideanstalt GmbH
Conformant
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.
Conformant
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Conformant
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery
Conformant
RUSSIAN FEDERATION
Gold
PAMP S.A.
Conformant
SWITZERLAND
Gold
Pease & Curren
Outreach Required
UNITED STATES OF AMERICA
Gold
Penglai Penggang Gold Industry Co., Ltd.
Outreach Required
CHINA
Gold
Planta Recuperadora de Metales SpA
Conformant
CHILE
Gold
Prioksky Plant of Non-Ferrous Metals
Conformant
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
Conformant
INDONESIA
Gold
PX Precinox S.A.
Conformant
SWITZERLAND
Gold
QG Refining, LLC
Outreach Required
UNITED STATES OF AMERICA
Gold
Rand Refinery (Pty) Ltd.
Conformant
SOUTH AFRICA
Gold
Refinery of Seemine Gold Co., Ltd.
Outreach Required
CHINA
Gold
REMONDIS PMR B.V.
Conformant
NETHERLANDS
Gold
Royal Canadian Mint
Conformant
CANADA
Gold
SAAMP
Conformant
FRANCE
Gold
Sabin Metal Corp.
Outreach Required
UNITED STATES OF AMERICA
Gold
Safimet S.p.A
Conformant
ITALY
Gold
SAFINA A.S.
Active
CZECH REPUBLIC
Gold
Sai Refinery
Outreach Required
INDIA
Gold
Samduck Precious Metals
Conformant
KOREA, REPUBLIC OF
Gold
Samwon Metals Corp.
Communication Suspended - Not Interested
KOREA, REPUBLIC OF
Gold
SAXONIA Edelmetalle GmbH
Conformant
GERMANY
Gold
SEMPSA Joyeria Plateria S.A.
Conformant
SPAIN
Gold
Shandong Humon Smelting Co., Ltd.
Outreach Required
CHINA
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Outreach Required
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Conformant
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
Conformant
CHINA
Gold
Singway Technology Co., Ltd.
Conformant
TAIWAN, PROVINCE OF CHINA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Conformant
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
Conformant
TAIWAN, PROVINCE OF CHINA
Gold
Sovereign Metals
Outreach Required
INDIA
Gold
State Research Institute Center for Physical Sciences and Technology
Outreach Required
LITHUANIA






Gold
Sudan Gold Refinery
Outreach Required
SUDAN
Gold
Sumitomo Metal Mining Co., Ltd.
Conformant
JAPAN
Gold
SungEel HiMetal Co., Ltd.
Conformant
KOREA, REPUBLIC OF
Gold
T.C.A S.p.A
Conformant
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.
Conformant
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
Conformant
CHINA
Gold
Tokuriki Honten Co., Ltd.
Conformant
JAPAN
Gold
Tongling Nonferrous Metals Group Co., Ltd.
Outreach Required
CHINA
Gold
Tony Goetz NV
Active
BELGIUM
Gold
TOO Tau-Ken-Altyn
In Communication
KAZAKHSTAN
Gold
Torecom
Conformant
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.
Conformant
BRAZIL
Gold
Umicore Precious Metals Thailand
Conformant
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining
Conformant
BELGIUM
Gold
United Precious Metal Refining, Inc.
Conformant
UNITED STATES OF AMERICA
Gold
Valcambi S.A.
Conformant
SWITZERLAND
Gold
Western Australian Mint (T/a The Perth Mint)
Conformant
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
Conformant
GERMANY
Gold
Yamakin Co., Ltd.
Conformant
JAPAN
Gold
Yokohama Metal Co., Ltd.
Conformant
JAPAN
Gold
Yunnan Copper Industry Co., Ltd.
Outreach Required
CHINA
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Conformant
CHINA
Tantalum
Asaka Riken Co., Ltd.
Conformant
JAPAN
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
Conformant
CHINA
Tantalum
CP Metals Inc.
Active
UNITED STATES OF AMERICA
Tantalum
D Block Metals, LLC
Conformant
UNITED STATES OF AMERICA
Tantalum
Exotech Inc.
Conformant
UNITED STATES OF AMERICA
Tantalum
F&X Electro-Materials Ltd.
Conformant
CHINA
Tantalum
FIR Metals & Resource Ltd.
Conformant
CHINA
Tantalum
Global Advanced Metals Aizu
Conformant
JAPAN
Tantalum
Global Advanced Metals Boyertown
Conformant
UNITED STATES OF AMERICA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
Conformant
CHINA
Tantalum
H.C. Starck Co., Ltd.
Conformant
THAILAND
Tantalum
H.C. Starck Hermsdorf GmbH
Conformant
GERMANY
Tantalum
H.C. Starck Inc.
Conformant
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Ltd.
Conformant
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Conformant
GERMANY
Tantalum
H.C. Starck Tantalum and Niobium GmbH
Conformant
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
Conformant
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Conformant
CHINA






Tantalum
Jiangxi Tuohong New Raw Material
Conformant
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Conformant
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
Conformant
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Conformant
CHINA
Tantalum
KEMET Blue Metals
Conformant
MEXICO
Tantalum
KEMET Blue Powder
Conformant
UNITED STATES OF AMERICA
Tantalum
LSM Brasil S.A.
Conformant
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
Conformant
INDIA
Tantalum
Mineracao Taboca S.A.
Conformant
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.
Conformant
JAPAN
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
Conformant
CHINA
Tantalum
NPM Silmet AS
Conformant
ESTONIA
Tantalum
Power Resources Ltd.
Conformant
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Tantalum
QuantumClean
Conformant
UNITED STATES OF AMERICA
Tantalum
Resind Industria e Comercio Ltda.
Conformant
BRAZIL
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
Conformant
CHINA
Tantalum
Solikamsk Magnesium Works OAO
Conformant
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
Conformant
JAPAN
Tantalum
Telex Metals
Conformant
UNITED STATES OF AMERICA
Tantalum
Ulba Metallurgical Plant JSC
Conformant
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
Conformant
CHINA
Tin
Alent plc
Conformant
UNITED STATES
Tin
An Vinh Joint Stock Mineral Processing Company
Outreach Required
VIET NAM
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Conformant
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
Conformant
CHINA
Tin
China Tin Group Co., Ltd.
Conformant
CHINA
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
Active
CHINA
Tin
Dowa
Conformant
JAPAN
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Active
VIET NAM
Tin
EM Vinto
Conformant
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Estanho de Rondonia S.A.
In Communication
BRAZIL
Tin
Fenix Metals
Conformant
POLAND
Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.
Outreach Required
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
Conformant
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
Conformant
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Conformant
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
Conformant
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
Conformant
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
Conformant
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
Conformant
CHINA






Tin
Huichang Jinshunda Tin Co., Ltd.
Conformant
CHINA
Tin
Jiangxi New Nanshan Technology Ltd.
Conformant
CHINA
Tin
Ma'anshan Weitai Tin Co., Ltd.
Conformant
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.
Conformant
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)
Conformant
MALAYSIA
Tin
Melt Metais e Ligas S.A.
Conformant
BRAZIL
Tin
Metallic Resources, Inc.
Conformant
UNITED STATES OF AMERICA
Tin
Metallo Belgium N.V.
Conformant
BELGIUM
Tin
Metallo Spain S.L.U.
Conformant
SPAIN
Tin
Mineracao Taboca S.A.
Conformant
BRAZIL
Tin
Minsur
Conformant
PERU
Tin
Mitsubishi Materials Corporation
Conformant
JAPAN
Tin
Modeltech Sdn Bhd
Conformant
MALAYSIA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Outreach Required
VIET NAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Conformant
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
Conformant
PHILIPPINES
Tin
Operaciones Metalurgicas S.A.
Conformant
BOLIVIA
Tin
Pongpipat Company Limited
Outreach Required
MYANMAR
Tin
Precious Minerals and Smelting Limited
Active
INDIA
Tin
PT Artha Cipta Langgeng
Conformant
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
Conformant
INDONESIA
Tin
PT Mitra Stania Prima
Conformant
INDONESIA
Tin
PT Refined Bangka Tin
Conformant
INDONESIA
Tin
PT Timah Tbk Kundur
Conformant
INDONESIA
Tin
PT Timah Tbk Mentok
Conformant
INDONESIA
Tin
Resind Industria e Comercio Ltda.
Conformant
BRAZIL
Tin
Rui Da Hung
Conformant
TAIWAN, PROVINCE OF CHINA
Tin
Soft Metais Ltda.
Conformant
BRAZIL
Tin
Super Ligas
Outreach Required
BRAZIL
Tin
Super Ligas
Outreach Required
BRAZIL
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
Conformant
VIET NAM
Tin
Thai Solder Industry Corp., Ltd.
Conformant
THAILAND
Tin
Tin Technology & Refining
Conformant
UNITED STATES OF AMERICA
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Outreach Required
VIET NAM
Tin
White Solder Metalurgia e Mineracao Ltda.
Conformant
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Conformant
CHINA
Tin
Yunnan Tin Company Limited
Conformant
CHINA
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
Conformant
CHINA
Tungsten
A.L.M.T. Corp.
Conformant
JAPAN
Tungsten
ACL Metais Eireli
Conformant
BRAZIL
Tungsten
Asia Tungsten Products Vietnam Ltd.
Conformant
VIET NAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
Conformant
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
Conformant
CHINA
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
Outreach Required
CHINA
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
Conformant
CHINA




Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Conformant
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
Conformant
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
Conformant
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Conformant
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
Conformant
CHINA
Tungsten
Global Tungsten & Powders Corp.
Conformant
UNITED STATES OF AMERICA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
Conformant
CHINA
Tungsten
H.C. Starck Smelting GmbH & Co. KG
Conformant
GERMANY
Tungsten
H.C. Starck Tungsten GmbH
Conformant
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
Conformant
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd.
Wuji
Conformant
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
Conformant
CHINA
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
Conformant
CHINA
Tungsten
Hydrometallurg, JSC
Conformant
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.
Conformant
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Conformant
CHINA
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
Active
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
Conformant
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Communication Suspended - Not Interested
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Conformant
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Conformant
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
Conformant
CHINA
Tungsten
Kennametal Fallon
Conformant
UNITED STATES OF AMERICA
Tungsten
Kennametal Huntsville
Conformant
UNITED STATES OF AMERICA
Tungsten
KGETS Co., Ltd.
Conformant
KOREA, REPUBLIC OF
Tungsten
Lianyou Metals Co., Ltd.
Conformant
TAIWAN, PROVINCE OF CHINA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
Conformant
CHINA
Tungsten
Masan Tungsten Chemical LLC (MTC)
Conformant
VIET NAM
Tungsten
Moliren Ltd.
Conformant
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC
Conformant
UNITED STATES OF AMERICA
Tungsten
Philippine Chuangxin Industrial Co., Inc.
Conformant
PHILIPPINES
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Conformant
VIET NAM
Tungsten
Unecha Refractory metals plant
Conformant
RUSSIAN FEDERATION
Tungsten
Wolfram Bergbau und Hutten AG
Conformant
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.
Conformant
KOREA, REPUBLIC OF
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
Conformant
CHINA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
Conformant
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
Conformant
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
Conformant
CHINA





APPENDIX B


Countries of Origin

Potential countries of origin for 3TG processed by conformant smelters or refiners may include (but are not necessarily limited to):


ANDORRA AUSTRALIA AUSTRIA BELGIUM BOLIVIA BRAZIL CANADA CHILE CHINA
CZECH REPUBLIC ESTONIA FRANCE GERMANY HONG KONG INDIA INDONESIA ITALY
JAPAN KAZAKHSTAN KOREA, REPUBLIC OF KYRGYZSTAN LITHUANIA
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF MALAYSIA
MEXICO MYANMAR NETHERLANDS NEW ZEALAND PERU PHILIPPINES POLAND
RUSSIAN FEDERATION RWANDA
SAUDI ARABIA SINGAPORE SOUTH AFRICA SPAIN SUDAN SWEDEN
SWITZERLAND
TAIWAN, PROVINCE OF CHINA THAILAND
TURKEY UGANDA
UNITED ARAB EMIRATES UNITED STATES OF AMERICA UZBEKISTAN
VIET NAM ZAMBIA ZIMBABWE