EX-1.01 2 cslformsd052517ex101.htm EXHIBIT 1.01 Exhibit


Exhibit 1.01
 
Carlisle Companies Incorporated
Conflict Minerals Report
For the Year Ended December 31, 2016
 
This Conflict Minerals Report (the “Report”) of Carlisle Companies Inc. (“Carlisle,” “The Company,” “we,” “us,” or “our”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the year ended December 31, 2016.  The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“the Act”).

The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products.  For purposes of this assessment, conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“Conflict Minerals” or “3TG”) and originated from the Democratic Republic of the Congo or an adjoining country (“Covered Countries”).  These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.  Please refer to the Rule for definitions of the terms used in this Report, unless otherwise defined herein.  Please also note that the report presented herein is not audited.

 Company Overview
 
Carlisle is a multi‑national company that designs, manufactures and sells a wide range of products principally throughout North America, Western Europe, and the Asia Pacific region via the following segments:

Carlisle Construction Materials (“CCM” or “Construction Materials”);
Carlisle Interconnect Technologies (“CIT” or “Interconnect Technologies”);
Carlisle Fluid Technologies (“CFT” or “Fluid Technologies”);
Carlisle Brake & Friction (“CBF” or “Brake & Friction”); and
Carlisle FoodService Products (“CFS” or “FoodService Products”).

 Products Overview
 
CCM manufactures and sells rubber ("EPDM"), thermoplastic polyolefin ("TPO"), and polyvinyl chloride membrane ("PVC") roofing systems. CCM also manufactures and distributes energy-efficient rigid foam insulation panels for substantially all roofing applications. Through its coatings and waterproofing operation, CCM manufactures and sells liquid and spray-applied waterproofing membranes, vapor and air barriers, and HVAC duct sealants and hardware for the commercial and residential construction markets.  Raw materials for this segment include EPDM polymer, TPO polymer, carbon black, processing oils, solvents, asphalt, methylene diphenyldiisocyanate, polyol, polyester fabric, black facer paper, oriented strand board, clay, and various packaging materials.
 
CIT designs and manufactures high-performance wire, cable, connectors, contacts, and cable assemblies for the transfer of power and data primarily for the aerospace, medical, defense electronics, test and measurement equipment, and select industrial markets. Raw materials for this segment include gold, copper conductors that are plated with tin, nickel, or silver, polyimide tapes, polytetrafluoroethylene (“PTFE”) tapes, PTFE fine powder resin, thermoplastic resins, stainless steel, beryllium copper rod, machined metals, plastic parts, and various marking and identification materials. Key raw materials are typically sourced worldwide.    

CFS manufactures and distributes various commercial and institutional foodservice products and industrial brooms, brushes, and mops.  Raw materials used by the FoodService Products segment include polymer resins, stainless steel, and aluminum. Key raw materials are sourced from suppliers within the United States.
 
CFT designs, manufactures, and sells highly-engineered liquid and powder finishing equipment and system components primarily in the automotive, automotive refinishing, aerospace, agriculture, construction, marine, and rail industries.  Key raw materials used by CFT include carbon and various grades of stainless steel, brass, aluminum, copper, machined metals, carbide, machined plastic parts, and PTFE.  Raw materials are typically sourced worldwide.
 

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CBF manufactures off-highway braking systems and friction products for off-highway, on-highway, aircraft, and other industrial applications. CBF also includes the performance racing group which markets and sells high-performance motorsport braking products. The brake manufacturing operations require the use of various metal products such as castings, pistons, springs, and bearings. Raw materials used by CBF include fiberglass, phenolic resin, metallic chips, copper and iron powders, steel, custom-fabricated cellulose sheet, and various other organic materials. Raw materials are sourced worldwide.
  
Based on a review of the raw materials used by the segments and discussions with key operations personnel across all segments, the Company determined that all four Conflict Minerals are present and that the CIT segment has the highest utilization of 3TG.  It has been determined that CFT, CBF, and CFS have significantly less utilization of 3TG than CIT, and that CCM does not use materials in the manufacturing process that contain conflict minerals.    For the year ended December 31, 2016, the Company’s reasonable country of origin (“RCOI”) and due diligence inquiries focused primarily on CIT, CFT, and CBF. 
 
Conflict Minerals Policy
 
The Company has adopted a conflict minerals policy, which is publicly available on our website at www.carlisle.com under “Corporate Responsibility”.
 
Reasonable Country of Origin Inquiries
 
A detailed scoping exercise, led by key operating and purchasing personnel, included reviewing all purchases over a twelve month period to identify any 3TG and corresponding suppliers. The suppliers were sorted according to their likelihood of supplying components or materials containing Conflict Minerals. Those that were known to or could potentially supply components or materials containing Conflict Minerals with whom annual spend exceeded a specified threshold were considered to be in scope for supplier inquiries.

As a result of this scoping process, 1328 different suppliers were identified for RCOI outreach.

We conducted a RCOI reasonably designed to determine whether the 3TG in our products in the 2016 Report Year originated from the Covered Countries or are from recycled or scrap sources in accordance with the requirements of the Rule. The Covered Countries are the Democratic Republic of Congo and its adjoining countries (Angola, Burundi, Republic of the Congo, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda and Zambia). As part of its RCOI, and with the assistance of a third-party consultant, Assent Compliance, Inc. (“Assent”), the Company engaged its potential 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products. Suppliers were asked to complete and submit, within a certain time frame, the joint Electronic Industry Citizen Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”) EICC-GeSI Conflict Minerals Reporting Template v. 4.1 or higher (“CMRT”). The CMRT is a standardized reporting template developed by the Conflict-Free Sourcing Initiative (“CFSI”) that requests, among other things, information regarding country of origin of 3TG supplied to the Company and the smelters or refiners ("SOR") in the supply chain. Assent followed up with all unresponsive suppliers through a defined process through both automated emails and one-on-one emails, including offering assistance and further information to suppliers about the requirements of the Rule and the Company’s expectations.

Because of the size, complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is challenging to identify providers upstream from our direct suppliers. There are potentially many tiers of suppliers and sub-suppliers between the Company and the SORs that process the 3TG that is contained in each product manufactured or contracted to be manufactured by Carlisle. Therefore, it is inherently difficult to determine the ultimate source of 3TGs in our products.
 
Based on the responses received thus far from direct suppliers, there is reason to believe that some of the necessary Conflict Minerals used in our products may have originated from the Covered Countries, but no instances were identified in which this sourcing, directly or indirectly, financed or benefited armed groups from the Covered Countries.  However, since not all supplier responses have been received and not all additional inquiries have been completed, we are unable to determine the country of origin of some conflict minerals or whether they originated from recycled or scrap sources.  We continue to reach out to unresponsive suppliers and perform additional inquiries until such time we have 100% response rate.


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As a result of the above conclusion and pursuant to the Rule, we undertook due diligence measures on the source and chain of custody of the necessary conflict minerals in our products which we had reason to believe may have originated from Covered Countries and which may not have come from recycled scrap or scrap sources. There is significant overlap between our RCOI efforts and our due diligence measures performed.
 
Due Diligence Performed
 
Carlisle undertook systematic due diligence to determine the status of the Conflict Minerals used in its businesses.  Due diligence efforts have been designed to conform, in all material respects, with the framework presented by The Organisation for Economic Co-operation and Development (“OECD”) in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing and the related Supplements for gold and for tin, tantalum and tungsten, an internationally recognized due diligence framework.  The OECD Due Diligence Guidance includes the following five-step program:
 
Step 1: Establish and maintain strong company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Support independent third party audits of supply chain
Step 5: Report annually on supply chain due diligence
 
Establish and Maintain Strong Company Management Systems
 
Conflict Minerals Policy: As noted above, the Company has adopted and maintains a conflict minerals policy related to our sourcing of 3TG.  The policy has been provided to our suppliers and is publicly available on our company website.

Internal Team and Training: The Conflict Minerals team responsible for overseeing Carlisle’s compliance is comprised of our Assistant General Counsel and CIT Director of Supplier Development along with designated representatives within the supply chain organizations at each segment.  Additionally, a professional services firm was engaged to augment the internal management group responsible for the design and implementation of our planned due diligence. 

Control Systems: A management system has been established to support supply chain due diligence related to 3TG.  We employ a supply chain system of controls and transparency through the use of due diligence tools, such as the CMRT used to identify the smelters and refiners that process the necessary conflict minerals contained in a company's products and the country of origin of those conflict minerals.

Supplier Engagement: We have feature requirements related to conflict minerals in our standard template for supplier contracts and specifications so that current and future suppliers are obligated to comply with our policies on conflict minerals, including participation in a supply chain survey and related due diligence activities.

Grievance Mechanism: In the event of an actual or possible violation of our policies, including the Company’s Conflict Minerals Policy, employees (internal) and suppliers (external) can report violations as part of the Company’s AlertLine protocol for reporting suspected violations of the Carlisle Business Code of Ethics. The Company’s Business Code of Ethics is available at http://www.carlisle.com/about-carlisle/corporate-governance/Business-Code-of-Ethics/.

Records Maintenance: We employ a database to assess due diligence information and maintain records related to our conflict mineral program, in accordance with our record retention policies.
 
Identify and Assess Risks in the Supply Chain
 
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG SORs in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.

Our primary means of determining origin of our 3TG for the 2016 Report Year was by conducting a supply chain survey with direct suppliers using the CMRT. This supply chain survey, and Carlisle’s Conflict Minerals program as a whole, has been developed and implemented in cooperation with Assent.

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Assent provided each supplier a copy of the CMRT to complete for purposes of Conflict Minerals tracking. Assent made at least three follow-up inquiries to each supplier that did not respond to our initial survey, by either phone or email or both. The software platform automatically reviewed the responses against criteria developed to determine which required further engagement with our suppliers. These criteria included incomplete responses as well as inconsistencies within the data reported in the CMRT. Assent worked directly with those suppliers to provide revised responses.

Once surveys were returned, Assent reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the CFSI Conflict-Free Smelter Program. If a SOR was not validated by the CFSI’s Conflict-Free Smelter Program (CFSP), Assent either attempted to contact the SOR to gather more information about its sourcing practices or conducted research to determine whether there are any additional publicly available sources of information regarding the SORs' sourcing practices.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free pose a significant risk to the Supply Chain. Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on three scoring criteria:

Geographic proximity to the DRC and covered countries;
Conflict-Free Smelter Program (CFSP) audit status;
Known or plausible evidence of unethical or conflict sourcing.

If a risk is identified, risk mitigation activities are initiated. As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the goal of progressive elimination of these risks from the supply chain.

In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

Design and Implement a Strategy to Respond to Identified Risks
 
The Company maintains a risk management plan to respond to risks identified in the above-described risk assessment. The Company’s Conflict Minerals program is implemented, managed and monitored in accordance with this risk management plan.

The Company’s Conflict Minerals team provides updates to senior management of the Company in connection with the Conflict Minerals Program, including with regard to risk assessment and results of the annual due diligence process.

As described in our Conflict Minerals policy, we expect our suppliers to fully support our compliance efforts, including in connection with our due diligence efforts to trace the source and chain of custody of our 3TG. As part of our risk management plan, to ensure suppliers understand our expectations, we worked with Assent to provide both video recorded training and documented instructions to suppliers and answered all inquiries that needed further clarification. We will continue improving our conflict minerals process to obtain complete and accurate information about SORs.
 
Support Independent Third Party Audits of Supply Chain
 
The Company does not typically have a direct relationship with 3TG smelters and refiners, therefore we rely on the CFSI’s Conflict-Free Smelter Program to manage and report results of the independent third-party audits of smelters and the related certification.
 
Report Annually on Supply Chain Due Diligence
 
This Conflict Minerals Report constitutes the Company’s annual report on our 3TG due diligence, is available on our website at www.carlisle.com, and is an Exhibit to this Form SD.  The content of any website referred to in the Form SD or this Exhibit is included for general information only and is not incorporated by reference into the Form SD or this Exhibit filed with the SEC.

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Results of Due Diligence
 
As a result of the due diligence efforts described above, we received responses from 64.2%, or 853, of our direct suppliers for the year ended December 31, 2016. Of these, 775 were completed and validated CMRTs. From these responses, a list was compiled of the smelters and refiners that may have been used to process 3TGs necessary to the functionality or production of our products. For all smelters identified, Assent confirmed that the name was listed on the CFSI’s Standard Smelter List. We have validated 317 smelters to date and continue to work on validating the additional entries from submitted CMRTs. Based on the smelter lists provided by suppliers via the CMRTs and publicly available information regarding the results of sourcing audits by the CFSI, we have identified 246 Conflict-Free SORs, with an additional 13 that are active in the audit process.

The information that we received from a majority of our direct suppliers was at a company-wide level. Therefore, the smelters identified by our direct suppliers may include facilities that processed 3TGs that our direct suppliers supplied to their other customers rather than to us. Thus, we are unable to conclusively determine whether these smelters were used to process the 3TGs necessary to the functionality or production of our products during 2016. Because of this uncertainty, we are also unable to conclusively determine the country of origin of 3TGs in our products during 2016, and therefore, are unable to conclusively determine the source and chain of custody of those 3TGs. In addition, the third-party audits conducted by the CFSI, and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete Conflict Minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the CFSI Conflict-Free Smelter Program and, as a result, are not responsible for the quality of these audits or the audit findings.
 
Due Diligence Procedures to be Performed
 
Carlisle will continue to implement steps to improve the information gathered from its due diligence to further mitigate the risk that its necessary conflict minerals benefit armed groups.  We will continue to work to increase the response rate of suppliers and will continue to evaluate responses to the surveys with the expectation that the third-party developed software will continue to help increase efficiency and identify any necessary follow-up procedures.  This includes executives and supply chain management teams completing a supplier scoping exercise, sending CMRTs to any supplier selling goods to Carlisle that may contain 3TG minerals, detailed analysis of all survey responses, and additional inquiries as necessary. 


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Appendix A

Summary of Smelter and Refiner Status

The table below details, as of May 1, 2017, the status of operational smelter and refiner facilities, identified by the surveyed suppliers, and the results of our smelter and refiner due diligence activities. The table indicates the number of such smelters and refiner facilities that:
have received a "conflict-free" designation from an independent third party audit program (referred to as "Compliant"),
have begun participating in an independent third party audit program (referred to as "Active"), or
have not begun participating in an independent third party audit program (referred to as "Not Enrolled").
Metal
 Standard Smelter or Refiner Name
Facility Location
CFSI Audit Status
Gold
Abington Reldan Metals, LLC
UNITED STATES
Active
Gold
Advanced Chemical Company
UNITED STATES
Compliant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Compliant
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Compliant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Compliant
Gold
Argor-Heraeus S.A.
SWITZERLAND
Compliant
Gold
Asahi Pretec Corp.
JAPAN
Compliant
Gold
Asahi Refining Canada Ltd.
CANADA
Compliant
Gold
Asahi Refining USA Inc.
UNITED STATES
Compliant
Gold
Asaka Riken Co., Ltd.
JAPAN
Compliant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Not Enrolled
Gold
AU Traders and Refiners
SOUTH AFRICA
Compliant
Gold
AURA-II
UNITED STATES
Not Enrolled
Gold
Aurubis AG
GERMANY
Compliant
Gold
Bangalore Refinery
INDIA
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Compliant
Gold
Boliden AB
SWEDEN
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Compliant
Gold
Caridad
MEXICO
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Compliant
Gold
Cendres + Métaux S.A.
SWITZERLAND
Active
Gold
Chimet S.p.A.
ITALY
Compliant
Gold
Chugai Mining
JAPAN
Not Enrolled
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Compliant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Not Enrolled
Gold
DODUCO GmbH
GERMANY
Compliant
Gold
Dowa
JAPAN
Compliant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Compliant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Compliant
Gold
Elemetal Refining, LLC
UNITED STATES
Compliant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Compliant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Not Enrolled

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Metal
 Standard Smelter or Refiner Name
Facility Location
CFSI Audit Status
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Not Enrolled
Gold
Geib Refining Corporation
UNITED STATES
Active
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CHINA
Not Enrolled
Gold
Gujarat Gold Centre
INDIA
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Not Enrolled
Gold
Heimerle + Meule GmbH
GERMANY
Compliant
Gold
Heraeus Ltd. Hong Kong
CHINA
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Compliant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Compliant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
Istanbul Gold Refinery
TURKEY
Compliant
Gold
Japan Mint
JAPAN
Compliant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Compliant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Not Enrolled
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Not Enrolled
Gold
Kazzinc
KAZAKHSTAN
Compliant
Gold
Kennecott Utah Copper LLC
UNITED STATES
Compliant
Gold
KGHM Polska MiedŸ Spó³ka Akcyjna
POLAND
Active
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Compliant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Compliant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Compliant
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Not Enrolled
Gold
Lingbao Gold Co., Ltd.
CHINA
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
L'Orfebre S.A.
ANDORRA
Not Enrolled
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Compliant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
Materion
UNITED STATES
Compliant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Compliant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Compliant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Compliant
Gold
Metalor Technologies S.A.
SWITZERLAND
Compliant
Gold
Metalor USA Refining Corporation
UNITED STATES
Compliant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
Compliant
Gold
Mitsubishi Materials Corporation
JAPAN
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Compliant

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Metal
 Standard Smelter or Refiner Name
Facility Location
CFSI Audit Status
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Compliant
Gold
Modeltech Sdn Bhd
MALAYSIA
Not Enrolled
Gold
Morris and Watson
NEW ZEALAND
Not Enrolled
Gold
Morris and Watson Gold Coast
AUSTRALIA
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.
TURKEY
Compliant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Active
Gold
Nihon Material Co., Ltd.
JAPAN
Compliant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Compliant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Compliant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Compliant
Gold
PAMP S.A.
SWITZERLAND
Compliant
Gold
Pease & Curren
UNITED STATES
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Not Enrolled
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Compliant
Gold
PX Précinox S.A.
SWITZERLAND
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Compliant
Gold
Remondis Argentia B.V.
NETHERLANDS
Not Enrolled
Gold
Republic Metals Corporation
UNITED STATES
Compliant
Gold
Royal Canadian Mint
CANADA
Compliant
Gold
SAAMP
FRANCE
Not Enrolled
Gold
Sabin Metal Corp.
UNITED STATES
Not Enrolled
Gold
SAFINA A.S.
CZECH REPUBLIC
Not Enrolled
Gold
Sai Refinery
INDIA
Not Enrolled
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Compliant
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Compliant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Compliant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
Compliant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Not Enrolled
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Compliant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Compliant
Gold
Singway Technology Co., Ltd.
TAIWAN
Compliant
Gold
So Accurate Group, Inc.
UNITED STATES
Not Enrolled
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Compliant
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Compliant
Gold
Sudan Gold Refinery
SUDAN
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Compliant
Gold
SungEel HiTech
KOREA, REPUBLIC OF
Active
Gold
T.C.A S.p.A
ITALY
Compliant

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Metal
 Standard Smelter or Refiner Name
Facility Location
CFSI Audit Status
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Compliant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Compliant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Not Enrolled
Gold
Tony Goetz NV
BELGIUM
Active
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Not Enrolled
Gold
Torecom
KOREA, REPUBLIC OF
Compliant
Gold
Umicore Brasil Ltda.
BRAZIL
Compliant
Gold
Umicore Precious Metals Thailand
THAILAND
Compliant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Compliant
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Compliant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Not Enrolled
Gold
Valcambi S.A.
SWITZERLAND
Compliant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Compliant
Gold
WIELAND Edelmetalle GmbH
GERMANY
Compliant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Compliant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Compliant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Compliant
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
Compliant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Compliant
Tantalum
D Block Metals, LLC
UNITED STATES
Compliant
Tantalum
Duoluoshan
CHINA
Compliant
Tantalum
Exotech Inc.
UNITED STATES
Compliant
Tantalum
F&X Electro-Materials Ltd.
CHINA
Compliant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Compliant
Tantalum
Global Advanced Metals Aizu
JAPAN
Compliant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Compliant
Tantalum
H.C. Starck GmbH Goslar
GERMANY
Compliant
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
Not Enrolled
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Compliant
Tantalum
H.C. Starck Inc.
UNITED STATES
Compliant
Tantalum
H.C. Starck Ltd.
JAPAN
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Compliant
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
KEMET Blue Metals
MEXICO
Compliant
Tantalum
KEMET Blue Powder
UNITED STATES
Compliant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Compliant

9



Metal
 Standard Smelter or Refiner Name
Facility Location
CFSI Audit Status
Tantalum
LSM Brasil S.A.
BRAZIL
Compliant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Compliant
Tantalum
Mineração Taboca S.A.
BRAZIL
Compliant
Tantalum
Mitsui Mining & Smelting
JAPAN
Compliant
Tantalum
Molycorp Silmet A.S.
ESTONIA
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Compliant
Tantalum
Plansee SE Liezen
AUSTRIA
Not Enrolled
Tantalum
Plansee SE Reutte
AUSTRIA
Compliant
Tantalum
Power Resources Ltd.
MACEDONIA
Compliant
Tantalum
QuantumClean
UNITED STATES
Compliant
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Compliant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Compliant
Tantalum
Taki Chemicals
JAPAN
Compliant
Tantalum
Telex Metals
UNITED STATES
Compliant
Tantalum
Tranzact, Inc.
UNITED STATES
Compliant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Compliant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Compliant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Compliant
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
CHINA
Compliant
Tin
Alpha
UNITED STATES
Compliant
Tin
An Thai Minerals Co., Ltd.
VIET NAM
Not Enrolled
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Compliant
Tin
China Tin Group Co., Ltd.
CHINA
Compliant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Not Enrolled
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Compliant
Tin
CV Ayi Jaya
INDONESIA
Compliant
Tin
CV Dua Sekawan
INDONESIA
Compliant
Tin
CV Gita Pesona
INDONESIA
Compliant
Tin
CV Serumpun Sebalai
INDONESIA
Compliant
Tin
CV Tiga Sekawan
INDONESIA
Compliant
Tin
CV United Smelting
INDONESIA
Compliant
Tin
CV Venus Inti Perkasa
INDONESIA
Compliant
Tin
Dowa
JAPAN
Compliant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Active
Tin
Elmet S.L.U.
SPAIN
Compliant
Tin
EM Vinto
BOLIVIA
Compliant
Tin
Estanho de Rondônia S.A.
BRAZIL
Not Enrolled
Tin
Fenix Metals
POLAND
Compliant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Compliant
Tin
Gejiu Jinye Mineral Company
CHINA
Compliant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Active
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Compliant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Active
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Not Enrolled
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Compliant

10



Metal
 Standard Smelter or Refiner Name
Facility Location
CFSI Audit Status
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Compliant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Not Enrolled
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Compliant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Compliant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Compliant
Tin
Melt Metais e Ligas S.A.
BRAZIL
Compliant
Tin
Metallic Resources, Inc.
UNITED STATES
Compliant
Tin
Metallo-Chimique N.V.
BELGIUM
Compliant
Tin
Mineração Taboca S.A.
BRAZIL
Compliant
Tin
Minsur
PERU
Compliant
Tin
Mitsubishi Materials Corporation
JAPAN
Compliant
Tin
Modeltech Sdn Bhd
MALAYSIA
Not Enrolled
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Compliant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Compliant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Compliant
Tin
Phoenix Metal Ltd.
RWANDA
Not Enrolled
Tin
PT Aries Kencana Sejahtera
INDONESIA
Compliant
Tin
PT Artha Cipta Langgeng
INDONESIA
Compliant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Compliant
Tin
PT Babel Inti Perkasa
INDONESIA
Compliant
Tin
PT Bangka Prima Tin
INDONESIA
Compliant
Tin
PT Bangka Tin Industry
INDONESIA
Compliant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Compliant
Tin
PT Bukit Timah
INDONESIA
Compliant
Tin
PT Cipta Persada Mulia
INDONESIA
Compliant
Tin
PT DS Jaya Abadi
INDONESIA
Compliant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Compliant
Tin
PT Inti Stania Prima
INDONESIA
Compliant
Tin
PT Justindo
INDONESIA
Not Enrolled
Tin
PT Karimun Mining
INDONESIA
Compliant
Tin
PT Kijang Jaya Mandiri
INDONESIA
Compliant
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Compliant
Tin
PT Mitra Stania Prima
INDONESIA
Compliant
Tin
PT O.M. Indonesia
INDONESIA
Compliant
Tin
PT Panca Mega Persada
INDONESIA
Compliant
Tin
PT Prima Timah Utama
INDONESIA
Compliant
Tin
PT Refined Bangka Tin
INDONESIA
Compliant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Compliant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Compliant
Tin
PT Sukses Inti Makmur
INDONESIA
Compliant
Tin
PT Sumber Jaya Indah
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Compliant
Tin
PT Tinindo Inter Nusa
INDONESIA
Compliant
Tin
PT Tommy Utama
INDONESIA
Compliant
Tin
PT Wahana Perkit Jaya
INDONESIA
Compliant

11



Metal
 Standard Smelter or Refiner Name
Facility Location
CFSI Audit Status
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tin
Rui Da Hung
TAIWAN
Compliant
Tin
Soft Metais Ltda.
BRAZIL
Compliant
Tin
Thaisarco
THAILAND
Compliant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Not Enrolled
Tin
VQB Mineral and Trading Group JSC
VIET NAM
Compliant
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Compliant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Active
Tin
Yunnan Tin Company Limited
CHINA
Compliant
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Compliant
Tungsten
ACL Metais Eireli
BRAZIL
Not Enrolled
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Not Enrolled
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Not Enrolled
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
H.C. Starck GmbH
GERMANY
Compliant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Compliant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Compliant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Compliant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Not Enrolled
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Kennametal Fallon
UNITED STATES
Compliant
Tungsten
Kennametal Huntsville
UNITED STATES
Compliant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
Compliant
Tungsten
Niagara Refining LLC
UNITED STATES
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Compliant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Compliant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Compliant

12



Metal
 Standard Smelter or Refiner Name
Facility Location
CFSI Audit Status
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Compliant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Compliant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Compliant
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Compliant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Compliant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Compliant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Compliant


13