EX-1.01 2 a20190531exhibit101.htm EXHIBIT 1.01 Exhibit

Exhibit 1.01
Wabash National Corporation
Conflict Minerals Report
For The Year Ended December 31, 2018

This Conflict Minerals Report (“CMR”) for the year ended December 31, 2018 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants for which conflict minerals are necessary to the functionality or production of products manufactured by the registrant or contracted by the registrant to be manufactured. For the purposes of the Rule, “conflict minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”). These requirements apply to registrants whatever the geographic origin of the 3TG and whether or not they fund armed conflict.
As described in detail below, following a reasonable country of origin inquiry conducted with our supply base into the source and chain of custody of 3TG in our products, we have reason to believe that a portion of the 3TG that is necessary to the functionality or production of products we have manufactured or contracted to be manufactured may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) and may not be from recycled or scrap sources. This CMR is available on our website at https://ir.wabashnational.com/financial-information/sec-filings. This CMR is not subject to an independent private sector audit in accordance with guidance issued by the SEC on April 29, 2014 and updated guidance issued by the SEC on April 7, 2017.
1. Company Overview
This CMR has been prepared by management of Wabash National Corporation (herein referred to as “Wabash,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries that are required to be consolidated. Founded in 1985 and headquartered in Lafayette, Indiana, Wabash National Corporation (NYSE: WNC) is a leading designer, manufacturer and distributor of high-quality, custom-engineered transportation and diversified industrial products and services. Our diverse product portfolio includes dry freight and refrigerated trailers, platform trailers, bulk tank trailers, dry and refrigerated truck bodies, truck-mounted tanks, structural composite panels and products, trailer aerodynamic solutions and specialty food-grade and pharmaceutical equipment. Its innovative products, which could possibly contain 3TGs, are sold under the following brand names: Wabash®, DuraPlate®, DuraPlateHD®, DuraPlate® XD-35®, ArcticLite®, RoadRailer®, Transcraft®, Benson®, Walker Transport, Brenner® Tank, Bulk International, Beall® Trailer, Walker® Engineered Products, Extract Technology®, DuraPlate® AeroSkirt®, AeroSkirt CX™, Ventix DRS™, AeroFin XL®, Kold King®, Inter-City® and Spartan. To learn more, visit www.wabashnational.com.
Supply Chain
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify entities upstream from our suppliers who provide us with products and/or raw materials necessary to the functionality or production of our products (“Direct Suppliers”). As such, we rely heavily on our Direct Suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower-tier suppliers. Current contracts with most of our key Direct Suppliers, which account for the majority of our sourced materials, are in effect for multiple year terms, and as a result, we cannot unilaterally impose new contract terms and flow-down requirements at this time. As we execute new contracts and/or renew contracts, we are requiring affected Direct Suppliers to provide us with geographic origin information concerning 3TG and smelters. Additionally, all new Direct Suppliers receive 3TG reporting requirements as a part of our new supplier information packet. It will take several years to ensure that all of our Direct Suppliers are contractually obligated to report this information to us as part of their normal business interactions with us. In the meantime, as described below, we have established a process to contact affected Direct Suppliers to collect necessary 3TG sourcing information. We have used and will continue to use the data collected through the process described below, and through our contractually obligated disclosures from our Direct Suppliers, to evaluate our supply chain to ensure compliance with the SEC’s current and future conflict minerals rules.

Reasonable Country of Origin Inquiry
Presently, our supply chain consists of over 12,000 suppliers, including many suppliers providing us with services and/or products that are not necessary to the functionality or production of our products and/or products that do not contain 3TG. As such, it was not practicable to conduct a survey of our entire supply base. Instead, we targeted only those Direct Suppliers, approximately 1,050, that we believed, based upon an evaluation of the composition of the product and/or raw material they supplied, could possibly supply us with products containing 3TG. The Company contacted these Direct Suppliers, requesting each to provide 3TG geographic origin data using the Conflict Minerals Reporting Template (“CMRT”) maintained by the Responsible Minerals Initiative (“RMI,” formerly known as the Conflict-Free Sourcing Initiative). Surveys conducted with other manufacturing companies confirmed that our risk-based approach to developing our list of our surveyed Direct Suppliers, as described above, is consistent with how many peer companies are approaching the Rule.


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At this time, having conducted this reasonable country of origin inquiry, we have reason to believe that it is possible that some 3TG necessary to the functionality or production of the products we manufactured or contracted to have manufactured may have originated in the Covered Countries and may not be from recycled or scrap sources. Accordingly, we conducted further due diligence on the source and chain of custody of the 3TG contained in our products.
2. Due Diligence Process
2.1 Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the framework in the Organization for Economic Cooperation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (2016), and the related supplements for each of the 3TG minerals (the “OECD Guidance”).
2.2 Establish Strong Company Management Systems
Conflict Minerals Policy
Wabash is committed to working with our global supply chain to ensure compliance with the SEC’s Rule. We have established a conflict minerals compliance program, as outlined above, that is designed to follow the OECD Guidance. Our enterprise is fully engaged in implementing that program.
For additional information about our commitment to responsible sourcing and other human rights, see our Conflict Minerals Policy Statement and Code of Business Conduct and Ethics, which are both publicly available on our website at www.wabashnational.com.
Internal Team
Our Senior Vice President – General Counsel and our Vice President of Supply Chain Management established a cross-functional team of subject matter experts from relevant functions of finance, legal, and supply chain to create our 3TG compliance program and due diligence efforts necessary to comply with the Rule. As part of this team, our Vice President – Supply Chain Management, Director – Global Strategic Sourcing and a Supply Chain Project Specialist lead our ongoing due diligence efforts with our Direct Suppliers. Senior management and members of the Audit Committee of our Board of Directors (the “Audit Committee”) are briefed about the results of our due diligence efforts at least annually.
Control Systems
As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in the transportation industry and other relevant sectors, as well as our own Direct Suppliers, to encourage the disclosure of the 3TG status of all upstream entities held in common by our various supply chains. Our due diligence process includes utilization of industry-wide initiatives to conduct due diligence on upstream entities in our supply chains, such as the CMRT and the RMI’s list of Responsible Minerals Assurance Process (“RMAP”) Conformant Smelters and Refiners (formerly the Conflict-Free Smelter Program).

Our controls include, but are not limited to, our Code of Business Conduct and Ethics, which outlines expected behaviors for all Wabash employees and suppliers. Going forward, as discussed above, our controls will also include contractual disclosure requirements in our Direct Supplier contracts.
Supplier Engagement
We have invested in tools and developed internal processes and procedures to query and track supplier activity. In addition, we have included 3TG reporting requirements in our new supplier packets and we will continue to request 3TG reporting data as required from all of our Direct Suppliers. We will also utilize key opportunities such as annual executive management reviews with our suppliers to reinforce and review compliance.
Grievance Mechanism
We have multiple mechanisms and processes for employees and suppliers to use to report violations of Wabash’s policies. These are described in our Code of Business Conduct and Ethics, which is publicly available on our website at www.wabashnational.com.
Maintain Records
We have adopted a policy to retain relevant documentation requested from and disclosed by our suppliers.
2.3 Identify and Assess Risk in the Supply Chain
As outlined previously, since we do not typically have a direct relationship with 3TG smelters and refiners, our due diligence efforts undertaken to comply with the Rule rely heavily on our Direct Suppliers providing us with information about the source of 3TG contained in the products and raw materials supplied to us. Our Direct Suppliers are similarly reliant upon information provided by their suppliers.

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Many of our largest suppliers are also SEC registrants and subject to the Rule. However, our ability to comply with the Rule is dependent upon receipt of complete and accurate information from our Direct Suppliers.
2.4 Design and Implement a Strategy to Respond to Risks
In response to this risk assessment, Wabash has an approved risk management plan, through which our 3TG compliance program is implemented, managed and monitored. As part of the risk management efforts undertaken as part of our 3TG compliance program, our Vice President – Supply Chain Management, Director – Global Strategic Sourcing and a Supply Chain Project Specialist regularly review 3TG data provided by our Direct Suppliers. Direct Suppliers who provide incomplete or inconsistent 3TG data are contacted to update and confirm the data provided until Wabash can conclude with a reasonable degree of certainty that the provided data is likely accurate. Updates regarding our due diligence process and this risk assessment are provided regularly to senior management and the Audit Committee.
As described above, we also utilize and participate in several industry-wide initiatives to diligence the 3TG status of upstream entities in our supply chain. We will continue to pursue training and participate in seminars to increase our awareness and further enhance our compliance efforts. As part of our risk management plan, and to ensure our suppliers understand our ongoing expectations to provide accurate and complete 3TG data, we will continue to engage suppliers in various ways such as training sessions, executive management reviews and our annual supplier conference.
2.5 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Since we do not have a direct relationship with 3TG smelters and refiners, we do not perform or direct audits of these upstream entities within our supply chain. We will support audits by our supply base, as necessary, and have augmented our own Direct Supplier audit process with questions and procedures to address compliance by our Direct Suppliers with the Rule.

2.6 Report on Supply Chain Due Diligence
Wabash has filed a Form SD which includes this CMR, and we have made our Form SD and CMR available on our website, demonstrating our progress in implementing our Conflict Minerals Policy Statement.
3. Due Diligence Results
Request Information
As described above, we conducted a survey of certain Direct Suppliers using the CMRT, which was developed to facilitate disclosure and communication of information regarding smelters and refiners that are the source of the 3TG in a company’s supply chain. It includes questions regarding a supplier’s conflict-free policies, engagement with its own direct suppliers, and a listing of the smelters and refiners that the respondent (and its own suppliers) utilizes in its own supply chain. In addition, the CMRT contains questions about the origin of 3TG included in the respondent’s products, as well as the respondent’s own due diligence efforts. Written instructions and recorded training illustrating the use of the tool is available on RMI’s website. The CMRT is being used by many of our peer companies in their due diligence processes related to 3TG.
Survey Responses
We received responses from 38% of the approximately 1,050 Direct Suppliers surveyed, which represents approximately 65% of Wabash’s direct material spend surveyed in 2018. We reviewed the responses provided against criteria developed to determine whether further engagement with our Direct Suppliers was necessary. These criteria included: (1) untimely or incomplete responses, (2) inconsistencies within the data reported in the CMRT or in other provided documentation, or (3) uncertainty in the accuracy of the data reported in light of the product supplied by the Direct Supplier. We conducted further engagement with Direct Suppliers who met one or more of these criteria until we received data sufficient to allow Wabash to conclude with a reasonable degree of certainty that the provided data is likely accurate.
Approximately 87% of our responding Direct Suppliers reported using no 3TG in products sold to Wabash; 8% provided insufficient detail, rendering their responses undeterminable; and 5% reported using 3TG from within the Covered Countries from smelters or refiners not included on the RMI’s list of RMAP Conformant Smelters and Refiners. In all cases where 3TG was reported being used, our suppliers could not determine if 3TG was in the products they sold to Wabash. Of the thousands of lines of smelter data reported to us, we were able to determine 252 smelters and refiners that are potentially in our supply chain, based on the information available through the RMAP. Of these 252 smelters and refiners, 248 were included on the RMAP Conformant Smelters and Refiners list and the remaining four are included on the RMAP Active Smelters and Refiners list, indicating they have committed to undergo an RMAP assessment. As we do not typically have a direct relationship with 3TG smelters and refiners, and thus are unable to directly audit or request documentation from these facilities, Wabash supports the refinement and expansion of the RMAP lists of Active Smelters and Refiners and Conformant Smelters and Refiners.

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Additionally, a large majority of our responding Direct Suppliers provided 3TG data to us at a company or divisional level and did not specify whether the particular products, parts or raw materials specifically supplied to Wabash contained 3TG. These “blanket responses” covering the totality of what these Direct Suppliers sell in aggregate to their customers do not allow us to determine whether any of the 3TG reported by these Direct Suppliers are actually contained in the particular products, parts or raw materials the Direct Supplier sells specifically to Wabash. Therefore, we are also unable to validate whether any of the smelters or refiners who were disclosed by the large majority of our responding Direct Suppliers are actually part of Wabash’s supply chain.
Efforts to Determine Mine or Location of Origin
Through our utilization of RMI resources, the OECD Guidance, and requesting that our Direct Suppliers complete the CMRT, we have determined that seeking information about 3TG smelters and refiners through 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 Direct Suppliers did not provide information on mines of origin for 3TG used in our products manufactured during 2018. Accordingly, we do not have sufficient information to conclusively determine the mines or the locations of origin of the 3TG in our products or whether the 3TG in our products is from recycled or scrap sources.

Smelters or Refiners
•
Based on the Direct Supplier responses we received:
•
87% of responding Direct Suppliers reported using no 3TG in their products and, therefore, utilize no smelters or refiners of concern.
•
The remaining 13% of respondents reported either: (1) no smelter or refiner information available or (2) a list of smelters and refiners utilized in their respective supply chains.
•
When smelter and refiner lists included verified smelter or refiner identification numbers in a response, we were able to confirm the following about those smelters or refiners:
◦
98% are on the RMAP Conformant Smelters and Refiners list
◦
2% are on the Active Conformant Smelters and Refiners list
•
The majority of our responding Direct Suppliers who do utilize 3TG in some or all of the products they sell to their entire customer base: (1) could not represent to us that any smelter or refiner entities they listed as supplying them with 3TG had actually been included in the supply chain for the products, parts and/or raw materials they supplied to Wabash; and/or (2) reported that it was “not known” or “undetermined” if 3TG had been supplied to them by smelters or refiners included in the supply chain for the products, parts and/or raw materials those Direct Suppliers supplied to Wabash.
The statements above are based on the reasonable country of origin inquiry process and due diligence performed in good faith by Wabash. As noted previously, these statements are based solely on the information received from our Direct Suppliers through this process. For a listing of smelters or refiners and their location reported to Wabash by its Direct Suppliers and determined as included on either the RMAP’s list of Conformant Smelters and Refiners or the RMAP’s list of Active Smelters and Refiners, please see Table 1 at the end of this CMR.
4. Steps to Be Taken to Mitigate Risk
We intend to take the following steps to improve the due diligence we conduct, in an effort to further mitigate risk that the 3TG necessary to the functionality or production of the products we manufacture or contract to manufacture could benefit armed groups in the Covered Countries:
•
Inclusion of 3TG flow-down requirements in Wabash’s new or renewed Direct Supplier contracts.
•
Revisit annually the scope of Direct Suppliers requested to supply information as part of our due diligence process.
•
Engage with Direct Suppliers, as deemed necessary, directing them to training resources in an attempt to increase the due diligence response rate and improve the content of the Direct Supplier survey responses.
•
Work with the Organisation for Economic Co-operation and Development and relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance.



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TABLE 1

The following facilities are included on either the RMAP list of Conformant Smelters and Refiners or the RMAP list of Active Smelters and Refiners and were reported by Wabash’s Direct Suppliers as being in Wabash’s supply chain.

Mineral
Smelter Name
Smelter ID
Status
Smelter or Refiner Location
Gold
Advanced Chemical Company
CID000015
Conformant
UNITED STATES OF AMERICA
Gold
Aida Chemical Industries Co., Ltd.
CID000019
Conformant
JAPAN
Gold
Al Etihad Gold Refinery DMCC
CID002560
Conformant
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
Conformant
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
Conformant
UZBEKISTAN
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
CID000058
Conformant
BRAZIL
Gold
Argor-Heraeus S.A.
CID000077
Conformant
SWITZERLAND
Gold
Asahi Pretec Corp.
CID000082
Conformant
JAPAN
Gold
Asahi Refining Canada Ltd.
CID000924
Conformant
CANADA
Gold
Asahi Refining USA Inc.
CID000920
Conformant
UNITED STATES OF AMERICA
Gold
Asaka Riken Co., Ltd.
CID000090
Conformant
JAPAN
Gold
AU Traders and Refiners
CID002850
Conformant
SOUTH AFRICA
Gold
Aurubis AG
CID000113
Conformant
GERMANY
Gold
Bangalore Refinery
CID002863
Active
INDIA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
Conformant
PHILIPPINES
Gold
Boliden AB
CID000157
Conformant
SWEDEN
Gold
C. Hafner GmbH + Co. KG
CID000176
Conformant
GERMANY
Gold
CCR Refinery - Glencore Canada Corporation
CID000185
Conformant
CANADA
Gold
Cendres + Metaux S.A.
CID000189
Conformant
SWITZERLAND
Gold
Chimet S.p.A.
CID000233
Conformant
ITALY
Gold
Chugai Mining
CID000264
Active
JAPAN
Gold
Daejin Indus Co., Ltd.
CID000328
Conformant
KOREA, REPUBLIC OF
Gold
DODUCO Contacts and Refining GmbH
CID000362
Conformant
GERMANY
Gold
Dowa
CID000401
Conformant
JAPAN
Gold
DSC (Do Sung Corporation)
CID000359
Conformant
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd.
CID000425
Conformant
JAPAN
Gold
Emirates Gold DMCC
CID002561
Conformant
UNITED ARAB EMIRATES
Gold
Geib Refining Corporation
CID002459
Conformant
UNITED STATES OF AMERICA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CID002243
Conformant
CHINA
Gold
HeeSung Metal Ltd.
CID000689
Conformant
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH
CID000694
Conformant
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
CID000707
Conformant
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
Conformant
GERMANY
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
Conformant
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
Conformant
JAPAN
Gold
Istanbul Gold Refinery
CID000814
Conformant
TURKEY
Gold
Italpreziosi
CID002765
Conformant
ITALY
Gold
Japan Mint
CID000823
Conformant
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CID000855
Conformant
CHINA
Gold
JSC Uralelectromed
CID000929
Conformant
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
CID000937
Conformant
JAPAN
Gold
Kazzinc
CID000957
Conformant
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
CID000969
Conformant
UNITED STATES OF AMERICA
Gold
KGHM Polska Miedz Spolka Akcyjna
CID002511
Active
POLAND
Gold
Kojima Chemicals Co., Ltd.
CID000981
Conformant
JAPAN
Gold
Korea Zinc Co., Ltd.
CID002605
Conformant
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn JSC
CID001029
Conformant
KYRGYZSTAN
Gold
L'Orfebre S.A.
CID002762
Conformant
ANDORRA
Gold
LS-NIKKO Copper Inc.
CID001078
Conformant
KOREA, REPUBLIC OF
Gold
Marsam Metals
CID002606
Conformant
BRAZIL
Gold
Materion
CID001113
Conformant
UNITED STATES OF AMERICA
Gold
Matsuda Sangyo Co., Ltd.
CID001119
Conformant
JAPAN

A-1

Mineral
Smelter Name
Smelter ID
Status
Smelter or Refiner Location
Gold
Metalor Technologies (Hong Kong) Ltd.
CID001149
Conformant
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
Conformant
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.
CID001147
Conformant
CHINA
Gold
Metalor Technologies S.A.
CID001153
Conformant
SWITZERLAND
Gold
Metalor USA Refining Corporation
CID001157
Conformant
UNITED STATES OF AMERICA
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
CID001161
Conformant
MEXICO
Gold
Mitsubishi Materials Corporation
CID001188
Conformant
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
Conformant
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.
CID002509
Conformant
INDIA
Gold
Moscow Special Alloys Processing Plant
CID001204
Conformant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
CID001220
Conformant
TURKEY
Gold
NH Recytech Company
CID003189
Active
KOREA, REPUBLIC OF
Gold
Nihon Material Co., Ltd.
CID001259
Conformant
JAPAN
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
Conformant
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.
CID001325
Conformant
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326
Conformant
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery
CID000493
Conformant
RUSSIAN FEDERATION
Gold
PAMP S.A.
CID001352
Conformant
SWITZERLAND
Gold
Planta Recuperadora de Metales SpA
CID002919
Conformant
CHILE
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
Conformant
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
Conformant
INDONESIA
Gold
PX Precinox S.A.
CID001498
Conformant
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
CID001512
Conformant
SOUTH AFRICA
Gold
Remondis Argentia B.V.
CID002582
Conformant
NETHERLANDS
Gold
Royal Canadian Mint
CID001534
Conformant
CANADA
Gold
SAAMP
CID002761
Conformant
FRANCE
Gold
Safimet S.p.A
CID002973
Conformant
ITALY
Gold
SAXONIA Edelmetalle GmbH
CID002777
Conformant
GERMANY
Gold
SEMPSA Joyeria Plateria S.A.
CID001585
Conformant
SPAIN
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
Conformant
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
Conformant
CHINA
Gold
Singway Technology Co., Ltd.
CID002516
Conformant
TAIWAN, PROVINCE OF CHINA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
Conformant
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
CID001761
Conformant
TAIWAN, PROVINCE OF CHINA
Gold
Sumitomo Metal Mining Co., Ltd.
CID001798
Conformant
JAPAN
Gold
SungEel HiMetal Co., Ltd.
CID002918
Conformant
KOREA, REPUBLIC OF
Gold
T.C.A S.p.A
CID002580
Conformant
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
Conformant
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
Conformant
CHINA
Gold
Tokuriki Honten Co., Ltd.
CID001938
Conformant
JAPAN
Gold
Torecom
CID001955
Conformant
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.
CID001977
Conformant
BRAZIL
Gold
Umicore Precious Metals Thailand
CID002314
Conformant
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining
CID001980
Conformant
BELGIUM
Gold
United Precious Metal Refining, Inc.
CID001993
Conformant
UNITED STATES OF AMERICA
Gold
Valcambi S.A.
CID002003
Conformant
SWITZERLAND
Gold
Western Australian Mint (T/a The Perth Mint)
CID002030
Conformant
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
CID002778
Conformant
GERMANY
Gold
YAMAKIN CO., LTD.
CID002100
Conformant
JAPAN
Gold
Yokohama Metal Co., Ltd.
CID002129
Conformant
JAPAN
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
Conformant
CHINA
Tantalum
Asaka Riken Co., Ltd.
CID000092
Conformant
JAPAN
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
Conformant
CHINA
Tantalum
D Block Metals, LLC
CID002504
Conformant
UNITED STATES OF AMERICA
Tantalum
Exotech Inc.
CID000456
Conformant
UNITED STATES OF AMERICA
Tantalum
F&X Electro-Materials Ltd.
CID000460
Conformant
CHINA
Tantalum
FIR Metals & Resource Ltd.
CID002505
Conformant
CHINA
Tantalum
Global Advanced Metals Aizu
CID002558
Conformant
JAPAN

A-2

Mineral
Smelter Name
Smelter ID
Status
Smelter or Refiner Location
Tantalum
Global Advanced Metals Boyertown
CID002557
Conformant
UNITED STATES OF AMERICA
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CID000291
Conformant
CHINA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
Conformant
CHINA
Tantalum
H.C. Starck Co., Ltd.
CID002544
Conformant
THAILAND
Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
Conformant
GERMANY
Tantalum
H.C. Starck Inc.
CID002548
Conformant
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Ltd.
CID002549
Conformant
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
CID002550
Conformant
GERMANY
Tantalum
H.C. Starck Tantalum and Niobium GmbH
CID002545
Conformant
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
Conformant
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
Conformant
CHINA
Tantalum
Jiangxi Tuohong New Raw Material
CID002842
Conformant
CHINA
Tantalum
Jiujiang Janny New Material Co., Ltd.
CID003191
Conformant
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
Conformant
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CID000917
Conformant
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
Conformant
CHINA
Tantalum
KEMET Blue Metals
CID002539
Conformant
MEXICO
Tantalum
KEMET Blue Powder
CID002568
Conformant
UNITED STATES OF AMERICA
Tantalum
LSM Brasil S.A.
CID001076
Conformant
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
CID001163
Conformant
INDIA
Tantalum
Mineracao Taboca S.A.
CID001175
Conformant
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.
CID001192
Conformant
JAPAN
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
Conformant
CHINA
Tantalum
NPM Silmet AS
CID001200
Conformant
ESTONIA
Tantalum
Power Resources Ltd.
CID002847
Conformant
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Tantalum
QuantumClean
CID001508
Conformant
UNITED STATES OF AMERICA
Tantalum
Resind Industria e Comercio Ltda.
CID002707
Conformant
BRAZIL
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CID001522
Conformant
CHINA
Tantalum
Solikamsk Magnesium Works OAO
CID001769
Conformant
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
CID001869
Conformant
JAPAN
Tantalum
Telex Metals
CID001891
Conformant
UNITED STATES OF AMERICA
Tantalum
Ulba Metallurgical Plant JSC
CID001969
Conformant
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CID002508
Conformant
CHINA
Tin
Alpha
CID000292
Conformant
UNITED STATES OF AMERICA
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
Conformant
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CID003190
Conformant
CHINA
Tin
China Tin Group Co., Ltd.
CID001070
Conformant
CHINA
Tin
CV Ayi Jaya
CID002570
Conformant
INDONESIA
Tin
CV Dua Sekawan
CID002592
Conformant
INDONESIA
Tin
CV Gita Pesona
CID000306
Conformant
INDONESIA
Tin
CV United Smelting
CID000315
Conformant
INDONESIA
Tin
CV Venus Inti Perkasa
CID002455
Conformant
INDONESIA
Tin
Dowa
CID000402
Conformant
JAPAN
Tin
EM Vinto
CID000438
Conformant
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Fenix Metals
CID000468
Conformant
POLAND
Tin
Gejiu Fengming Metallurgy Chemical Plant
CID002848
Conformant
CHINA
Tin
Gejiu Jinye Mineral Company
CID002859
Conformant
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
CID000942
Conformant
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
Conformant
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
Conformant
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
Conformant
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CID003116
Conformant
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CID002849
Conformant
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CID000760
Conformant
CHINA
Tin
Jiangxi New Nanshan Technology Ltd.
CID001231
Conformant
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.
CID002468
Conformant
BRAZIL

A-3

Mineral
Smelter Name
Smelter ID
Status
Smelter or Refiner Location
Tin
Malaysia Smelting Corporation (MSC)
CID001105
Conformant
MALAYSIA
Tin
Melt Metais e Ligas S.A.
CID002500
Conformant
BRAZIL
Tin
Metallic Resources, Inc.
CID001142
Conformant
UNITED STATES OF AMERICA
Tin
Metallo Belgium N.V.
CID002773
Conformant
BELGIUM
Tin
Metallo Spain S.L.U.
CID002774
Conformant
SPAIN
Tin
Mineracao Taboca S.A.
CID001173
Conformant
BRAZIL
Tin
Minsur
CID001182
Conformant
PERU
Tin
Mitsubishi Materials Corporation
CID001191
Conformant
JAPAN
Tin
Modeltech Sdn Bhd
CID002858
Conformant
MALAYSIA
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
Conformant
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
Conformant
PHILIPPINES
Tin
Operaciones Metalurgical S.A.
CID001337
Conformant
BOLIVIA (PLURINATIONAL STATE OF)
Tin
PT Aries Kencana Sejahtera
CID000309
Conformant
INDONESIA
Tin
PT Artha Cipta Langgeng
CID001399
Conformant
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
CID002503
Conformant
INDONESIA
Tin
PT Babel Inti Perkasa
CID001402
Conformant
INDONESIA
Tin
PT Bangka Prima Tin
CID002776
Conformant
INDONESIA
Tin
PT Bangka Serumpun
CID003205
Conformant
INDONESIA
Tin
PT Bangka Tin Industry
CID001419
Conformant
INDONESIA
Tin
PT Belitung Industri Sejahtera
CID001421
Conformant
INDONESIA
Tin
PT Bukit Timah
CID001428
Conformant
INDONESIA
Tin
PT DS Jaya Abadi
CID001434
Conformant
INDONESIA
Tin
PT Inti Stania Prima
CID002530
Conformant
INDONESIA
Tin
PT Kijang Jaya Mandiri
CID002829
Conformant
INDONESIA
Tin
PT Lautan Harmonis Sejahtera
CID002870
Conformant
INDONESIA
Tin
PT Menara Cipta Mulia
CID002835
Conformant
INDONESIA
Tin
PT Mitra Stania Prima
CID001453
Conformant
INDONESIA
Tin
PT Panca Mega Persada
CID001457
Conformant
INDONESIA
Tin
PT Premium Tin Indonesia
CID000313
Conformant
INDONESIA
Tin
PT Prima Timah Utama
CID001458
Conformant
INDONESIA
Tin
PT Refined Bangka Tin
CID001460
Conformant
INDONESIA
Tin
PT Sariwiguna Binasentosa
CID001463
Conformant
INDONESIA
Tin
PT Stanindo Inti Perkasa
CID001468
Conformant
INDONESIA
Tin
PT Sukses Inti Makmur
CID002816
Conformant
INDONESIA
Tin
PT Sumber Jaya Indah
CID001471
Conformant
INDONESIA
Tin
PT Timah (Persero) Tbk Kundur
CID001477
Conformant
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
CID001482
Conformant
INDONESIA
Tin
PT Tinindo Inter Nusa
CID001490
Conformant
INDONESIA
Tin
PT Tommy Utama
CID001493
Conformant
INDONESIA
Tin
Resind Industria e Comercio Ltda.
CID002706
Conformant
BRAZIL
Tin
Rui Da Hung
CID001539
Conformant
TAIWAN, PROVINCE OF CHINA
Tin
Soft Metais Ltda.
CID001758
Conformant
BRAZIL
Tin
Thaisarco
CID001898
Conformant
THAILAND
Tin
Tin Technology & Refining
CID003325
Conformant
UNITED STATES OF AMERICA
Tin
White Solder Metalurgia e Mineracao Ltda.
CID002036
Conformant
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
Conformant
CHINA
Tin
Yunnan Tin Company Limited
CID002180
Conformant
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.
CID000004
Conformant
JAPAN
Tungsten
ACL Metais Eireli
CID002833
Conformant
BRAZIL
Tungsten
Asia Tungsten Products Vietnam Ltd.
CID002502
Conformant
VIET NAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
Conformant
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
Conformant
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
Conformant
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CID002645
Conformant
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
Conformant
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
Conformant
CHINA
Tungsten
Global Tungsten & Powders Corp.
CID000568
Conformant
UNITED STATES OF AMERICA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
Conformant
CHINA

A-4

Mineral
Smelter Name
Smelter ID
Status
Smelter or Refiner Location
Tungsten
H.C. Starck Smelting GmbH & Co. KG
CID002542
Conformant
GERMANY
Tungsten
H.C. Starck Tungsten GmbH
CID002541
Conformant
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CID000766
Conformant
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
Conformant
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
Conformant
CHINA
Tungsten
Hydrometallurg, JSC
CID002649
Conformant
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.
CID000825
Conformant
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
Conformant
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
Conformant
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
Conformant
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
Conformant
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
Conformant
CHINA
Tungsten
Kennametal Fallon
CID000966
Conformant
UNITED STATES OF AMERICA
Tungsten
Kennametal Huntsville
CID000105
Conformant
UNITED STATES OF AMERICA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
Conformant
CHINA
Tungsten
Moliren Ltd.
CID002845
Conformant
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC
CID002589
Conformant
UNITED STATES OF AMERICA


A-5