0001178913-20-001510.txt : 20200518 0001178913-20-001510.hdr.sgml : 20200518 20200518060343 ACCESSION NUMBER: 0001178913-20-001510 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20191231 1.02 20191231 FILED AS OF DATE: 20200518 DATE AS OF CHANGE: 20200518 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SILICOM LTD. CENTRAL INDEX KEY: 0000916793 STANDARD INDUSTRIAL CLASSIFICATION: COMPUTER COMMUNICATIONS EQUIPMENT [3576] IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-23288 FILM NUMBER: 20887953 BUSINESS ADDRESS: STREET 1: 14 ATIR YEDA ST. CITY: KFAR-SAVA STATE: L3 ZIP: 4464323 BUSINESS PHONE: 97297644555 MAIL ADDRESS: STREET 1: 14 ATIR YEDA ST. CITY: KFAR-SAVA STATE: L3 ZIP: 4464323 FORMER COMPANY: FORMER CONFORMED NAME: SILICOM LTD DATE OF NAME CHANGE: 19940103 SD 1 zk2024424.htm SD

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
FORM SD
Specialized Disclosure Report

SILICOM LTD.
(Exact name of registrant as specified in its charter)
 
                       
ISRAEL 
000-23288 N/A
(State or other jurisdiction
(Commission
(IRS Employer
of incorporation or organization)
File Number)
Identification No.)
 
14 Atir Yeda Street, Kfar Sava, Israel
4464323
(Address of principal executive offices) (Zip Code)

Eran Gilad
Telephone: +972-9-764-4555
(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
 
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.
Introduction

This Specialized Disclosure Report on Form SD ("Form SD") of Silicom Ltd. ("Silicom" or "we") for the year ended December 31, 2019 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended ("Rule"). 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 ("Dodd-Frank Act"). Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. The Rule imposes certain reporting obligations on SEC registrants whose products contain conflict minerals that are necessary to the functionality or production of their products (such minerals are referred to as "necessary conflict minerals"). For products which contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo ("DRC") or an adjoining country, collectively defined as the "Covered Countries." If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals contained in its products originated or may have originated in a Covered Country and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources, the registrant must conduct due diligence on the necessary conflict minerals’ source and chain of custody as a method to conclude if the necessary conflict minerals contained in those products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries. Products which do not contain necessary conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries are considered "DRC conflict free". In addition, conflict minerals that a registrant obtains from recycled or scrap sources are also considered "DRC conflict free."
 
We use the term "conflict free" in this Form SD in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the Covered Countries.
 
Company Overview
 
Silicom Ltd. is an industry-leading provider of high-performance networking and data infrastructure solutions. Designed primarily to improve performance and efficiency in Cloud and Data Center environments, Silicom’s solutions increase throughput, decrease latency and boost the performance of servers and networking appliances, the infrastructure backbone that enables advanced Cloud architectures and leading technologies like NFV, SD-WAN and Cyber Security. Our innovative solutions for high-density networking, high-speed fabric switching, offloading and acceleration, which utilize a range of cutting-edge silicon technologies as well as FPGA-based solutions, are ideal for scaling-up and scaling-out cloud infrastructures.
 
Silicom products are used by major Cloud players, service providers, Telcos and OEMs as components of their infrastructure offerings, including both add-on adapters in the Data Center and stand-alone virtualized/universal CPE devices at the edge.
 
Silicom’s long-term, trusted relationships with more than 170 customers throughout the world, its more than 400 active Design Wins and more than 300 product SKUs have made Silicom a "go-to" connectivity/performance partner of choice for technology leaders around the globe.
 
For more information, please visit: www.silicom.co.il
 
Products
 
Our products are comprised of:
 
(A)
Server network interface cards (Server Adapters);
(B)
Smart Cards: Intelligent and/or programmable cards, with features such as encryption, acceleration, data compression, redirection and switching, packet processing, time stamping, packet capture solutions, ultra-low latency solutions, other offloading features; and
(C)
 
Stand-alone Products: Customer-Premises Equipment, including virtualized Customer-Premises Equipment (vCPE) and universal Customer-Premises Equipment (uCPE) (together, "CPE"), edge devices for SD-WAN and NFV deployments (together with the CPE, "EDGE"), Networking Targeted Appliances, Bypass Switches and Intelligent Bypass Switches.
The products detailed above constitute all products and product lines that we manufactured or sub-contracted to manufacture in the 2019 calendar year. Accordingly, we determined that none of our products qualified as DRC conflict free in the 2019 calendar year.
 
Overview of Silicom's Conflict Minerals Program
 
As a product manufacturer, we are knowledgeable about the design of our products, including the materials needed to construct them. We design the manufacturing processes to build those products and in some cases, design the detailed materials to manufacture those products. As a result, we know that conflict minerals (tantalum, tin, tungsten and gold, also referred to as "3TG") are necessary to the functionality or production of all of our products. Conflict minerals are obtained, via our direct suppliers, from sources worldwide, and our desire is not to eliminate those originating in the Covered Countries but rather to obtain conflict minerals from sources that do not directly or indirectly finance or benefit armed groups in the Covered Countries.
 
Conflict Minerals Sourcing Policy
 
Silicom's policy with respect to the sourcing of conflict minerals is as follows: Silicom expects its suppliers to have in place policies and due diligence measures that will enable it to reasonably assure that products and components supplied to it containing conflict minerals are DRC conflict free. Silicom expects its suppliers to comply with the Global e-Sustainability Initiative and with the Responsible Minerals Initiative ("RMI") (formerly the Conflict Free Sourcing Initiative, or CFSI) and conduct their business in alignment with Silicom's supply chain responsibility expectations.
 
In support of this policy, Silicom will:
•
exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and will encourage our suppliers to do likewise with their suppliers.
•
provide, and expect its suppliers to cooperate in providing, due diligence information to confirm the 3TG in its supply-chain is DRC conflict free.
•
collaborate with its suppliers and others on industry-wide solutions to encourage the manufacturing of products that are DRC conflict free.
•
commit to transparency in the implementation of this policy by making available reports on its progress to relevant stakeholders and the public.
The full text of Silicom's Conflict Minerals Sourcing Policy is available at http://www.silicom-usa.com/conflict-minerals/. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
 
Supply Chain Description
 
Although Silicom's hardware products contain conflict minerals, Silicom does not purchase any conflict minerals directly from mines and is many steps removed in the supply chain from the mining of the conflict minerals. Silicom purchases materials used in its products from its suppliers and some of those materials contribute necessary conflict minerals to its products and/or production process. The origin of conflict minerals cannot be determined with any certainty once the ores are smelted, refined and converted to ingots, bullion or other conflict minerals containing derivatives. The smelters and refiners (sometimes referred to as "facilities") are consolidating points for ore and are in the best position in the total supply chain to know the origin of the ores. Silicom relies on its direct suppliers to assist with its reasonable country of origin inquiry and due diligence efforts, including the identification of smelters and refiners, for the conflict minerals contained in the materials which they supply.
 
During the past several years, we have asked our potential suppliers to provide evidence of being conflict-free, and the presentation of such evidence has become a major consideration in our engagement process with new suppliers.
Silicom has well established and structured the process of new supplier approval, when information about conflict minerals is necessary for supplier approval.
 
SECTION 1 – CONFLICT MINERALS DISCLOSURE
 
Item 1.01          Conflict Minerals Disclosure and Report
 
Description of Reasonable Country of Origin Inquiry ("RCOI") Efforts
 
Below is a description of Silicom's efforts to determine whether any of the necessary conflict minerals in its products originated in the Covered Countries during 2019.
 
Silicom conducted an analysis of its products and the production process thereof and found that 3TG are used in all of its products.
 
For 2019, Silicom conducted a supply chain survey with all the suppliers and manufacturers from whom it purchases components used in its products in order to obtain country of origin information for the necessary conflict minerals in its products using the Conflict Minerals Reporting Template ("CMRT"), an industry standard template for conflict minerals reporting designed by the RMI. However, as a result of the complexity of Silicom's products and the constant evolution of its supply chain, it is difficult to identify sub-tier suppliers downstream from the direct suppliers and manufacturers from whom Silicom purchases components used in its products ("Suppliers").
 
Suppliers who are relevant for the survey were thoroughly chosen using following process:
 
1.
A list of all suppliers and manufacturers from whom Silicom purchases its products was generated from Silicom's ERP system. The total number of Suppliers was 888.
2.
Irrelevant suppliers and manufacturers were then eliminated from the list mentioned above. Irrelevant suppliers and manufacturers are defined as those who (a) do not provide goods, but rather provide services, office supplies, infrastructure services, etc.; (b) do not provide goods that are part of Silicom's products (i.e. packaging); (c) supply components or materials that do not, by their nature, contain 3TG materials (i.e. paper labels, glue, etc.); and (d) inactive suppliers and manufacturers (i.e. suppliers and manufacturers from whom Silicom did not purchase any products in 2019). After such elimination Silicom remained with 202 suppliers and manufacturers.
3.
Silicom sent requests to such 202 suppliers and manufacturers that were active suppliers and manufacturers during 2019.
Silicom requested such suppliers and manufacturers to complete a conflict minerals survey, based on the CMRT.
 
All received CMRTs were checked and verified against a list of active and complaint smelters published by the RMI. In the case of non-conformance in the answers delivered by the suppliers and manufacturers in the CMRTs, Silicom contacted suppliers and manufacturers in order to receive updated valid CMRTs.
 
The supply chain survey requested information from the direct suppliers and manufacturers in order to identify the smelters and refiners and countries of origin of the conflict minerals in products they supply to Silicom. Silicom received responses from its suppliers and manufacturers, representing over 99.9% of its total direct spend with its suppliers and manufacturers during 2019. Silicom compared the smelters and refiners identified in the surveys against the lists of facilities that have received a "conflict free" designation by the RMI. Those designations provide country of origin information on the conflict minerals sourced by such facilities (such as third party software providers' databases).
 
In the case of non-responsive suppliers and manufacturers, Silicom, through its Sustainability Team, attempted to contact such suppliers and manufacturers by email and telephone at least three times.
 
Suppliers' and manufacturers' responses were examined and the quality and relevance of their answers were verified when required, including by validation of all CMRTs that were provided to Silicom. The goal of data validation was to increase the accuracy of the responses that were provided to Silicom and identify any discrepancies and contradictory answers in the CMRTs.
 
When a smelter or refiner in Silicom's supply chain was not listed as having received a "conflict free" designation, Silicom asked its suppliers and manufacturers to proactively contact such facility and requested country of origin information for the necessary conflict minerals that it processed. In addition, Silicom is taking all measures that it deems fit in order to replace such suppliers and manufacturers with others who are declared as conflict-free. Silicom documented country of origin information for the smelters and refiners identified by the supply-chain survey.
There is a significant overlap between Silicom's RCOI efforts and its due diligence measures performed. Silicom's due diligence measures performed were based on the findings of RCOI and are discussed further in the Conflict Minerals Report filed as Exhibit 1.02 hereto.
 
Conflict Minerals Disclosure
 
This Form SD and the Conflict Minerals Report, filed as Exhibit 1.02 hereto, are publicly available at http://www.silicom-usa.com/conflict-minerals/ as well as the SEC’s EDGAR database at www.sec.gov.
 
Item 1.02          Exhibits 
 
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.02 to this Form SD.
 
SECTION 2 – EXHIBITS
 
Item 2.01          Exhibits
 
SIGNATURES
 
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
 
Silicom Ltd.
(Registrant)
 
/s/ Daniel Cohen
May 18, 2020
By: Daniel Cohen, VP Operations
 (Date)
     
EX-1.01 2 exhibit_1-02.htm EXHIBIT 1.02
Exhibit 1.02
 
Silicom Ltd.
 
Conflict Minerals Report
 
For the Year Ended December 31, 2019
 
This report for the year ended December 31, 2019 is presented to comply with Section 13(p) of the Securities Exchange Act of 1934 and Rule 13p-1 (the "Rule") and Form SD thereunder. 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 ("Dodd-Frank Act"). These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict. 
 
Design of Conflict Minerals Due Diligence Program
 
The design of our conflict minerals due diligence program is in conformity with the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, "OECD Guidance"), specifically as it relates to our position in the minerals supply chain as a "downstream" purchaser. We designed our due diligence program, management and measures to conform in all material respects with the framework OECD Guidance.  
 
Description of Performed Conflict Minerals Due Diligence Program
(i)
Maintaining of Strong Company Management Systems
 
  a.
Silicom has adopted and committed to a Conflict Minerals policy for minerals originating from conflict-affected and high-risk areas. More information about Silicom's Conflict Minerals policy can be found in the RCOI section above. Our management system includes a Conflict Minerals Qualification Team overseen by the Chief Financial Officer of the Company and run under the supervision of the Company's QA & EMS Director, and includes a team of subject matter experts from relevant functions including Operations and Purchasing. Senior management is briefed about the results of our due diligence efforts on a regular basis.

 
  b.
During the last year Silicom became a member of the Responsible Minerals Initiative ("RMI") (formerly the Conflict Free Sourcing Initiative, or CFSI), as a member we participate in all RMI activities such as smelters audits and other activities.

 
  c.
Silicom has implemented a supply chain system of controls and transparency through the use of due diligence software provided by third party software supplier.

 
  d.
In the process of engaging with new manufacturers and suppliers, Silicom requests that such suppliers provide it with complete and valid CMRTs as a condition for Silicom's engagement with such manufacturers and suppliers.

 
  e.
Silicom conducts trainings to suppliers and manufacturers from whom it purchases components used in its products, assists suppliers and manufacturers in educating their own suppliers, by informing them on the Rule, referring suppliers and manufacturers to the RMI website and online training materials and providing Silicom's Conflict Minerals policy and due diligence procedures.

 
  f.
Silicom documents and maintains a record maintenance mechanism to ensure the retaining of relevant documentation in an electronic database for at least 5 years.

 
  g.
Silicom encourages employees, suppliers and manufacturers and stakeholders to report any concerns relating to its conflict minerals program by contacting Silicom on its Conflict Minerals page: http://www.silicom-usa.com/conflict-minerals/.

(ii)
Identification and Assessment of Risk in the Supply Chain
Suppliers and manufacturers (including smelters and refiners) of products which include Conflict Minerals which are "necessary to the functionality of the products" were identified through our CMRT analysis.

We identified two primary risks in our supply chain: (1) not receiving on time and accurate information from the suppliers and manufacturers; and (2) reliance on suppliers and manufacturers who are not conflict-free while pursuing our goal of becoming a conflict free company. This assessment assisted us to segment our suppliers and manufacturers into three risk levels (high, medium and low), on which we based our risk strategy.

We conducted a survey of our active suppliers and manufacturers using the template developed by RMI, known as the Conflict Minerals Reporting Template ("CMRT"). Suppliers and manufacturers were requested to use version 5.12 of the CMRT, or newer versions.

(iii)
Design and Implementation of a Strategy to Respond to Identified Risks
 
  a.
We performed reviews of suppliers and manufacturers, smelters, and refiners that could be sourcing or processing Conflict Minerals from the Covered Countries, which could not be from recycled or scrap sources.

 
  b.
As part of our risk based approach, we decided to focus our risk management actions on suppliers and manufacturers with a spending volume of over US$ 1,000 in 2019. We requested smelter information from all of our direct suppliers and manufacturers, and prioritized suppliers and manufacturers with a spending volume of over US$ 1,000. In cases where sure prioritized suppliers and manufacturers did not respond to our initial requests, we attempted to contact them several additional times in order to obtain the necessary information from them.

 
  c.
We monitored and tracked suppliers and manufacturers (as described in RCOI section above), smelters and/or refiners identified as not meeting the requirements (or that defined themselves as "Unknown" or "Undeterminable" or "Sourced from DRC") set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements.

 
  d.
New suppliers and manufacturers were required to complete RMI declarations in order to qualify as approved suppliers and manufacturers by us.

 
  e.
We provided periodic progress reports to our senior management relating to our risk mitigation efforts.

 
  f.
In general, supply chain Due Diligence is a dynamic process and requires on-going risk monitoring. This process is performed twice a year and an updated CMRT is released after completion of each Due Diligence cycle.

 
  g.
Follow up letters were sent to high and medium risk suppliers and manufacturers who were identified as having non-compliant smelters in their supply chain. Non-responsive suppliers and manufacturers were reminded to send their responses several times by e-mails and, if they remained non-responsive thereafter, such suppliers and manufacturers were personally approached by our Sustainability Team or by our Purchasing Team and warned that if they remain non-responsive despite our continued attempts to receive their responses, they will be removed from our approved suppliers and manufacturers list. In cases where such suppliers and manufacturers remained non-responsive nonetheless, we removed them from our approved suppliers and manufacturers list.

(iv)   Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
         We encourage our suppliers and manufacturers to purchase from RMI Compliant Smelters, and we rely on the RMI compliant and active smelters list, which is available on the RMI website.

(v)
Report on Supply Chain Due Diligence

This Report is available on our website at http://www.silicom-usa.com/conflict-minerals/. This Report is being filed to the SEC and is also available on the SEC's EDGAR database at www.sec.gov.
Results of our Assessment
 
As a downstream purchaser of conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and manufacturers and those suppliers and manufacturers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also gather required CMRT information from websites of suppliers and manufacturers where conflict minerals reports were available. We also rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud because the information gathered from our suppliers and manufacturers is not on a continuous, real-time basis.
 
Supplier Chain Survey Responses
 
Silicom contacted 202 suppliers and manufacturers, and the response rate achieved was over 99.9% in cost of purchased goods.
 
The Sustainability Team directly contacted Silicom's suppliers and manufacturers in order to collect CMRTs. Following the efforts of the Sustainability Team, 192 suppliers and manufacturers delivered satisfactory CMRTs. For the purposes hereof, Silicom considers CMRTs to be satisfactory if they do not include any deficiencies or discrepancies and comply, in form and in substance, with the terms governing the RMI, such as blank rows, scope not matching PN list, inclusion of irrelevant information, etc.
 
4 of the 202 suppliers and manufacturers delivered CMRTs with invalid supplier submissions, like incorrect smelter names or invalid CID identification numbers. Following our requests for improved CMRTs, we received satisfactory CMRTs submissions from all such suppliers and manufacturers.
 
63 suppliers and manufacturers were classified as "Not from DRC" – suppliers and manufacturers who reported that they were sourcing minerals from countries other than the Covered Countries.
 
66 suppliers and manufacturers were classified as "DRC conflict free" – suppliers and manufacturers who reported that the 3TG minerals used in the products provided to Silicom originate from Covered Countries but the smelters are approved by the RMI
 
18 suppliers and manufacturers were classified as "DRC not conflict free" – suppliers and manufacturers who reported that the 3TG minerals used in the products provided to Silicom originate from Covered Countries and the smelters are not approved by the RMI.
 
27 suppliers and manufacturers were classified as "Free no 3TG" – suppliers and manufacturers who reported that 3TG minerals are not necessary for the functionality or production of the products provided to Silicom.
 
9 suppliers and manufacturers were classified as "Undetermined not from DRC" – suppliers and manufacturers who reported that the 3TG used in the products supplied to Silicom do not originate from Covered Countries but since they have not yet concluded their due diligence process, their determination and responses are not yet final and may vary. Consequently, our due diligence for these suppliers and manufacturers is still ongoing.
 
9 suppliers and manufacturers were classified as "Undetermined from DRC" – suppliers and manufacturers who reported that the 3TG used in the products supplied to Silicom originate from Covered Countries and the smelters are approved by the RMI program, but they have not yet concluded their due diligence process so their determination and responses are not yet final and may vary. Consequently, our due diligence for these suppliers and manufacturers is still ongoing.
 
Of the 192 suppliers and manufacturers that delivered satisfactory CMRTs:
 
112 suppliers and manufacturers provided data at a "Company" level;
 
52 suppliers and manufacturers provided data at a "User defined" level; and
 
28 suppliers and manufacturers provided data at a "Product" level.
 
As we are attentive to market requests, we asked several of these suppliers and manufacturers to provide data at a "Company" level as well as at a "Product" level, and such suppliers and manufacturers provided the data at both levels.
 
Below is a summary of the country of origin information collected as a result of our RCOI efforts.
 
Conflict Mineral
Countries of origin and other sources may include the following
Gold
Australia, Austria, Andorra, Belgium, Brazil, Canada, Chile, China,
Czech Republic, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Republic of Korea, Kyrgyzstan, Lithuania, Malaysia, Mexico, Netherlands, New Zealand, Philippines, Poland, Russian, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, United Arab Emirates, Russian Federation, Uganda, United States, Uzbekistan.
Tantalum
Brazil, China, Estonia, Germany, India, Japan, Kazakhstan, Macedonia, Mexico, Russian Federation, Thailand, United States.
Tungsten
Austria, Brazil, China, Germany, Japan, Republic of Korea, Philippines, Russian Federation, Taiwan, United States, Vietnam.
Tin
Belgium, Bolivia, Brazil, China, India, Indonesia, Japan, Malaysia, Myanmar, Peru, Philippines, Poland, Spain, Taiwan, Thailand, United States, Vietnam.

Smelters and refiners verified as conflict free (compliant) or in the audit process:
 
Tin
86 of 91 (94%)
Tantalum
41 of 41 (100%)
Tungsten
46 of 47 (98%)
Gold
146 of 154 (95%)
Total
319 of 333 (96%)

A number of the smelters and refiners detailed above provided more than one necessary conflict mineral.
 
List of the facilities which, to the extent known, processed the necessary conflict minerals used in our products can be found in Appendix 1.
 
Continuous Improvement Efforts to Mitigate Risks
 
During the reporting period for the calendar year ending December 31, 2020, we are continuing to engage in the diligence process described above.
 
We intend to follow up with high risk non-responsive or non-compliant suppliers and manufacturers, work with suppliers and manufacturers to educate them on conflict minerals sourcing, contact selected smelters and refiners that have not received a "conflict free" designation and more. In the event that any of our suppliers and manufacturers do not cooperate with us and do not respond to our efforts in a satisfactory manner, we will disqualify them and remove them from our approved suppliers and manufacturers list.
In the event that we continue to engage with suppliers and manufacturers who have not completed their RCOI process, we will ask such suppliers and manufacturers to complete the process and become conflict free at a company or product level as a condition to our continued engagement with them.
 
In addition, being attentive to the market and to our customers, we are currently in the process of qualifying our line of products as "conflict free" by, among other things, requesting from all of our direct suppliers and manufacturers to qualify the goods supplied by them to Silicom as "Conflict Free", replacing, where possible and appropriate, non-compliant suppliers and manufacturers with compliant ones and removal of non-compliant vendors from our approved vendors list.
 
Appendix 1
 
List of smelters used in Silicom's products:
 
Smelter identification
RMI METAL
Smelter or Refiner Facility Name
RMI COUNTRY
CID000711
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000707
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID001622
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001916
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001761
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
CID001875
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID000015
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
CID001477
Tin
PT Timah Tbk Kundur
INDONESIA
CID001482
Tin
PT Timah Tbk Mentok
INDONESIA
CID001453
Tin
PT Mitra Stania Prima
INDONESIA
CID000292
Tin
Alpha
UNITED STATES OF AMERICA
CID000082
Gold
Asahi Pretec Corp.
JAPAN
CID000425
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
CID000807
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000937
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID001119
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001188
Gold
Mitsubishi Materials Corporation
JAPAN
CID001193
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001259
Gold
Nihon Material Co., Ltd.
JAPAN
CID001798
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001938
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID000077
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000401
Gold
Dowa
JAPAN
CID000981
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID001105
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID000438
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
CID000538
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA

CID002773
Tin
Metallo Belgium N.V.
BELGIUM
CID001173
Tin
Mineracao Taboca S.A.
BRAZIL
CID001182
Tin
Minsur
PERU
CID001191
Tin
Mitsubishi Materials Corporation
JAPAN
CID001460
Tin
PT Refined Bangka Tin
INDONESIA
CID001898
Tin
Thaisarco
THAILAND
CID002082
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002317
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000258
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID002494
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID000769
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000460
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID002320
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002557
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
CID002544
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002548
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
CID002549
Tantalum
H.C. Starck Ltd.
JAPAN
CID002550
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002545
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID001277
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001969
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001337
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
CID000019
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000035
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000041
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000058
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
CID000924
Gold
Asahi Refining Canada Ltd.
CANADA
CID000920
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
CID000090
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000113
Gold
Aurubis AG
GERMANY
CID000157
Gold
Boliden AB
SWEDEN
CID000176
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000185
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000233
Gold
Chimet S.p.A.
ITALY
CID000328
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000362
Gold
DODUCO Contacts and Refining GmbH
GERMANY

CID000359
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID002561
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002459
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
CID002243
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID000689
Gold
LT Metal Ltd.
KOREA, REPUBLIC OF
CID000694
Gold
Heimerle + Meule GmbH
GERMANY
CID000801
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000814
Gold
Istanbul Gold Refinery
TURKEY
CID002765
Gold
Italpreziosi
ITALY
CID000823
Gold
Japan Mint
JAPAN
CID000855
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000929
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000957
Gold
Kazzinc
KAZAKHSTAN
CID000969
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
CID002605
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID001029
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID002762
Gold
L'Orfebre S.A.
ANDORRA
CID001078
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID002606
Gold
Marsam Metals
BRAZIL
CID001113
Gold
Materion
UNITED STATES OF AMERICA
CID001149
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001152
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001147
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001153
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001157
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
CID001161
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
CID002509
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID001204
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001220
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
CID001325
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001326
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID000493
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID001352
Gold
PAMP S.A.
SWITZERLAND
CID002919
Gold
Planta Recuperadora de Metales SpA
CHILE
CID001386
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION

CID001397
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001498
Gold
PX Precinox S.A.
SWITZERLAND
CID001512
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID002582
Gold
REMONDIS PMR B.V.
NETHERLANDS
CID001534
Gold
Royal Canadian Mint
CANADA
CID002777
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID001585
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
CID001736
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID002516
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
CID001756
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID002918
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
CID002580
Gold
T.C.A S.p.A
ITALY
CID001955
Gold
Torecom
KOREA, REPUBLIC OF
CID001977
Gold
Umicore Brasil Ltda.
BRAZIL
CID001980
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001993
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
CID002003
Gold
Valcambi S.A.
SWITZERLAND
CID002030
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
CID002778
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002100
Gold
Yamakin Co., Ltd.
JAPAN
CID002129
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002224
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID001070
Tin
China Tin Group Co., Ltd.
CHINA
CID002158
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002763
Gold
8853 S.p.A.
ITALY
CID002560
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
CID002850
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002863
Gold
Bangalore Refinery
INDIA
CID000128
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000189
Gold
Cendres + Metaux S.A.
SWITZERLAND
CID003195
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
CID002511
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002779
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002761
Gold
SAAMP
FRANCE

CID002973
Gold
Safimet S.p.A
ITALY
CID002314
Gold
Umicore Precious Metals Thailand
THAILAND
CID000092
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000211
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID002504
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
CID000456
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
CID002505
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002558
Tantalum
Global Advanced Metals Aizu
JAPAN
CID000291
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000616
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID002547
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002492
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002512
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002842
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID000914
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000917
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID002506
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002539
Tantalum
KEMET Blue Metals
MEXICO
CID002568
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
CID001076
Tantalum
LSM Brasil S.A.
BRAZIL
CID001163
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001175
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001192
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001200
Tantalum
NPM Silmet AS
ESTONIA
CID002847
Tantalum
PRG Dooel
NORTH MACEDONIA, REPUBLIC OF
CID001508
Tantalum
QuantumClean
UNITED STATES OF AMERICA
CID002707
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID001769
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001869
Tantalum
Taki Chemical Co., Ltd.
JAPAN
CID001891
Tantalum
Telex Metals
UNITED STATES OF AMERICA
CID002508
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID001522
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
CID000228
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID003190
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA

CID000402
Tin
Dowa
JAPAN
CID000468
Tin
Fenix Metals
POLAND
CID002848
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID000942
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID001908
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID000555
Tin
Gejiu Zili Mining and Metallurgy Co., Ltd.
CHINA
CID003116
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
CID002849
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002844
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID000760
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID001231
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID002468
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002500
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID001142
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
CID002774
Tin
Metallo Spain S.L.U.
SPAIN
CID001314
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID002517
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002706
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID001539
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
CID001758
Tin
Soft Metais Ltda.
BRAZIL
CID002834
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
CID003325
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
CID002036
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
CID002180
Tin
Yunnan Tin Company Limited
CHINA
CID000004
Tungsten
A.L.M.T. Corp.
JAPAN
CID002833
Tungsten
ACL Metais Eireli
BRAZIL
CID002502
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002513
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID000499
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID002645
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002315
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID000568
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
CID000218
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID002542
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002541
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID000766
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID002579
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA

CID002649
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID000825
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID002551
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002321
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002318
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002316
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID000966
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
CID000105
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
CID003388
Tungsten
KGETS Co., Ltd.
KOREA, REPUBLIC OF
CID002319
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002543
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
CID002845
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
CID002589
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
CID002827
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID001889
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID002724
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002044
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
CID002843
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002830
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002095
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID000315
Tin
CV United Smelting
INDONESIA
CID001399
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001421
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001428
Tin
PT Bukit Timah
INDONESIA
CID001468
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001490
Tin
PT Tinindo Inter Nusa
INDONESIA
CID002455
Tin
CV Venus Inti Perkasa
INDONESIA
CID002503
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002592
Tin
CV Dua Sekawan
INDONESIA
CID002816
Tin
PT Sukses Inti Makmur
INDONESIA
CID002829
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID000306
Tin
CV Gita Pesona
INDONESIA
CID000309
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000313
Tin
PT Premium Tin Indonesia
INDONESIA
CID001402
Tin
PT Babel Inti Perkasa
INDONESIA
CID001419
Tin
PT Bangka Tin Industry
INDONESIA
CID001434
Tin
PT DS Jaya Abadi
INDONESIA

CID001448
Tin
PT Karimun Mining
INDONESIA
CID001457
Tin
PT Panca Mega Persada
INDONESIA
CID001458
Tin
PT Prima Timah Utama
INDONESIA
CID001463
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001471
Tin
PT Sumber Jaya Indah
INDONESIA
CID001493
Tin
PT Tommy Utama
INDONESIA
CID002530
Tin
PT Inti Stania Prima
INDONESIA
CID002593
Tin
PT Rajehan Ariq
INDONESIA
CID002776
Tin
PT Bangka Prima Tin
INDONESIA
CID002835
Tin
PT Menara Cipta Mulia
INDONESIA
CID003205
Tin
PT Bangka Serumpun
INDONESIA
CID001555
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID002858
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002570
Tin
CV Ayi Jaya
INDONESIA
CID000264
Gold
Chugai Mining
JAPAN
CID000343
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000671
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000767
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000778
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
CID000956
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID001032
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001056
Gold
LinBao Gold Mining
CHINA
CID001058
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID002615
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID000103
Gold
ATAkulche
TURKEY
CID000180
Gold
Caridad
MEXICO
CID000197
Gold
CHALCO Yunnan Copper Co. Ltd.
CHINA
CID002865
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID001093
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID002282
Gold
Morris and Watson
NEW ZEALAND
CID001236
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID003189
Gold
NH Recytech Company
KOREA, REPUBLIC OF
CID002872
Gold
Pease & Curren
UNITED STATES OF AMERICA
CID001362
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID003324
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
CID000522
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID001546
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
CID002853
Gold
Sai Refinery
INDIA
CID001562
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF

CID001619
Gold
Shandong Tarzan Bio-Gold Industry Co., Ltd.
CHINA
CID003153
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID001947
Gold
Anhui Tongling Nonferrous Metal Mining Co., Ltd.
CHINA
CID001909
Gold
Great Wall Precious Metals Co,. LTD.
CHINA
CID002312
Gold
Guangdong Gaoyao Co
CHINA
CID002852
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002867
Gold
DEGUSSA
GERMANY
CID003348
Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
CID000773
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
CID002562
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
CID002525
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
CID002563
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002587
Gold
Tony Goetz NV
BELGIUM
CID002708
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
CID003185
Gold
African Gold Refinery
UGANDA
CID002857
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002584
Gold
Fujairah Gold FZC
UNITED ARAB EMIRATES
CID003383
Gold
Sovereign Metals
INDIA
CID003382
Gold
CGR Metalloys Pvt Ltd.
INDIA
CID003402
Tantalum
CP Metals Inc.
UNITED STATES OF AMERICA
CID000448
Tin
Estanho de Rondonia S.A.
BRAZIL
CID002573
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002703
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002756
Tin
Super Ligas
BRAZIL
CID003208
Tin
Pongpipat Company Limited
MYANMAR
CID002572
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID003356
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
CID003397
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
CID003379
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
CID002647
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002313
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID003182
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID000281
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA

CID000927
Gold
Ekaterinburg
RUSSIAN FEDERATION
CID001406
Tin
PT Babel Surya Alam Lestari
INDONESIA
CID002478
Tin
PT Tirus Putra Mandiri
INDONESIA
CID003381
Tin
PT Rajawali Rimba Perkasa
INDONESIA
CID000538
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID001191
Tin
Mitsubishi Materials Corporation
JAPAN
CID001482
Tin
INDONESIAN STATE TIN CORPORATION MENTOK SMELTER
INDONESIA
CID000651
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID003191
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
CID002870
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002290
Gold
SAFINA A.S.
CZECH REPUBLIC
CID003409
Tin
Precious Minerals and Smelting Limited
INDIA
CID003401
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
CID003408
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
CID003407
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
CID003424
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
CID003425
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
CID001322
Gold
NA
UNITED STATES OF AMERICA
CID000278
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA