UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
SPX Corporation
(Exact name of registrant as specified in its charter)
Delaware (State or other jurisdiction of incorporation) | 1-6948 (Commission File Number) | 38-1016240 (IRS Employer Identification No.) | ||
13320-A Ballantyne Corporate Place, Charlotte, North Carolina | 28277 | |||
(Address of principal executive offices) | (Zip Code) | |||
John W. Nurkin (980) 474-3804
(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:
ý Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016.
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
SPX Corporation (“SPX” or the “Company”) is filing this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2016 to December 31, 2016 (the “Reporting Period”).
Under Securities and Exchange Commission (“SEC”) regulations, if any “conflict minerals” (as defined below) are necessary to the functionality or production of a product manufactured by the Company or contracted by the Company to be manufactured, the Company must conduct in good faith a reasonable country of origin inquiry (“RCOI”) regarding those “conflict minerals” that is reasonably designed to determine whether any of the “conflict minerals” originated in the Covered Countries (as defined below) or are from recycled or scrap sources. Form SD defines “conflict minerals” as (i) columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are currently limited to tantalum, tin, and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an “adjoining country,” as such term is defined in Form SD, (collectively, the “Covered Countries”).
The Company’s operations may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products. As required by SEC’s conflict minerals rule, the Company has conducted a good faith RCOI regarding conflict minerals included in the Company’s products during the Reporting Period to determine whether any such conflict minerals originated in the Covered Countries and/or whether any of the conflict minerals were from recycled or scrap sources. Where applicable, the Company has conducted additional due diligence within the meaning of the SEC’s conflict minerals rule. The results of SPX’s RCOI, as well as the Company’s additional due diligence regarding the sources of conflict minerals, are contained in the Company’s Conflict Minerals Report, filed herewith as Exhibit 1.01, and publically available on the Company’s website at www.spx.com. The content on, or accessible through, our website or any website referred to in this Form SD is not, and shall not be deemed to be, part of this Form SD or incorporated into this or any other filings SPX makes with the SEC unless expressly noted.
Item 1.02 Exhibit
As specified in Section 2 of Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this Form SD.
Exhibit Number | Description |
1.01 | Conflict Minerals Report of SPX Corporation |
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.
SPX CORPORATION | ||
(Registrant) | ||
By: | /s/ John W. Nurkin | Date: May 25, 2017 |
John W. Nurkin | ||
Vice President, Secretary and General Counsel | ||
EXHIBIT INDEX
Exhibit Number | Description |
1.01 | Conflict Minerals Report of SPX Corporation |
Exhibit 1.01
SPX Corporation
Conflict Minerals Report
Reporting Period: January 1, 2016 – December 31, 2016
This Conflict Minerals Report (this “Report”) of SPX Corporation (“SPX,” “Company,” “we,” “us,” or “our”) for the reporting period from January 1, 2016 to December 31, 2016 (the “Reporting Period”) has been prepared pursuant to Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934, as amended.
Forward-looking statements contained in this Report are made based on events and circumstances known by us at the time of release and, as such, are inherently subject to unforeseen uncertainties and risks. Statements in this Report which express a belief, expectation, or intention, as well as those that are not historical fact, are forward-looking statements, including statements related to the Company’s business, products, compliance efforts, and expected actions identified in this Report. These forward-looking statements are subject to various risks, uncertainties, and assumptions, including, among other matters, our customers’ requirements to use certain suppliers, our suppliers’ responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our conflict minerals program, changes to the sourcing status of smelters and refiners in our supply chain, and our ability to identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see our other filings with the Securities and Exchange Commission (“SEC”), including our Annual Report on Form 10-K for the year ended December 31, 2016. The Company makes these statements as of the date of this disclosure, and undertakes no obligation to update them unless otherwise required by law.
Under SEC regulations, if any “conflict minerals” (as defined below) are necessary to the functionality or production of a product manufactured by the Company or contracted by the Company to be manufactured, the Company must conduct in good faith a reasonable country of origin inquiry (“RCOI”) regarding those “conflict minerals” that is reasonably designed to determine whether any of the “conflict minerals” originated in the Covered Countries (as defined below) or are from recycled or scrap sources. Form SD defines “conflict minerals” as (i) columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are currently limited to tantalum, tin, and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an “adjoining country,” as such term is defined in Form SD, (collectively, the “Covered Countries”).
The Company’s operations may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products. As required by SEC’s conflict minerals rule, the Company has conducted a good faith RCOI regarding conflict minerals included in the Company’s products during the Reporting Period to determine whether any such conflict minerals originated in the Covered Countries and/or whether any of the conflict minerals were from recycled or scrap sources. Where applicable, the Company has conducted additional due diligence within the meaning of the SEC’s conflict minerals rule. The results of SPX’s RCOI, as well as the Company’s additional due diligence regarding the sources of conflict minerals, are contained in this Report.
This Report is publically available on our website at www.spx.com. The content on, or accessible through, our website or any website referred to in this Report is not, and shall not be deemed to be, part of this Report or incorporated into this or any other filings SPX makes with the SEC unless expressly noted.
Company Overview and Product Description
SPX Corporation is a supplier of highly engineered products and technologies, holding leadership positions in the HVAC, detection and measurement, and engineered solutions markets. Based in Charlotte, North Carolina, SPX Corporation had approximately $1.5 billion in annual revenue in 2016 and more than 5,000 employees in about 15 countries.
1
The Company’s operations may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products (collectively, the “products”). Certain of the products contain materials or components that use metallic forms of tin, tantalum, tungsten, and/or gold (“subject minerals”). For the Reporting Period, the Company reasonably determined that the following product groups contain subject minerals:
• | Dry cooling systems; |
• | Evaporative and hybrid cooling systems; |
• | Rotating and stationary heat exchangers; pollution control systems; |
• | Boilers; |
• | Heating and ventilation products; |
• | Power transformers; |
• | Spectrum monitoring and signal monitoring systems; |
• | Specialty lighting; |
• | Fare collection systems; and |
• | Portable cable and pipe locators. |
The due diligence efforts noted below were undertaken on the products manufactured by us in the Reporting Period.
Reasonable Country of Origin Inquiry
SPX conducted a good faith RCOI regarding the potential inclusion of conflict minerals in the products during the Reporting Period. There is significant overlap between the Company’s RCOI efforts and the due diligence measures performed. Although some of our products contain subject minerals, we typically do not purchase raw materials directly from mines, smelters, or refiners and we are many steps removed in the supply chain from the sources of ore from which these metals are produced and the smelters/refiners that process those ores. Accordingly, we rely on direct suppliers in the supply chain between us and the original sources of raw materials to provide information regarding the origin of any conflict minerals that may be included in the products.
We have taken steps to identify the applicable smelters and refiners of such subject minerals metals in our supply chain. However, as a downstream purchaser of components and materials that contain subject minerals, our RCOI and due diligence measures can provide only reasonable - not absolute - assurance regarding the source and chain of custody of the conflict minerals. The Company’s RCOI and due diligence processes are based on the necessity of seeking data from direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the subject minerals contained in components and materials supplied to us. Another complicating factor is the unavailability of country of origin and chain of custody information from direct suppliers on a continuous, real-time basis. The Company’s available sources of information may yield inaccurate or incomplete information and may be subject to fraud.
The Company began its RCOI by identifying product families and commodities that may contain subject minerals. Using information derived from the Company’s procurement systems, supplemented by information supplied by personnel in the Company’s business units supply chain, SPX identified direct suppliers of components and materials that may contain subject minerals. We requested that each of these identified direct suppliers complete a survey utilizing the Electronic Industry Citizenship Coalition-Global e-Sustainability Initiative (EICC-GeSI) Conflict Minerals Common Reporting Template. This survey, among other things, solicited information regarding the location and identity of smelters and refiners. We utilized a database to track survey progress and responses, and from the database we were able to identify direct suppliers that failed to provide the requested information and redistributed surveys to those who did not respond. In addition, we collaborated with our direct suppliers to review responses to the surveys when clarification was warranted.
Using the information collected from the EICC-GeSI surveys completed by these direct suppliers, we determined the products that contained one or more of the subject minerals. Upon conclusion of the RCOI, the origin of these subject minerals could not be definitively determined. As such, we proceeded to exercise due diligence.
2
Due Diligence Framework and Measures
We designed our due diligence framework to conform to applicable portions of the OECD 2013 Guidelines – OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing. http://dx.doi.org/10.1787/9789264185050-en (“OECD Guidelines”).
In accordance with applicable portions of the OECD Guidance for downstream companies such as the Company, the due diligence measures we performed include, but are not limited to, the following:
• | Reporting to senior management and the Board of Directors regarding the structure of our conflict minerals program. |
• | Reporting to senior management on direct suppliers’ responses to our conflict minerals information requests. |
• | Communicating our policy on conflict minerals to direct suppliers. |
• | Communicating the commitments and requirements expected of our direct suppliers, supported by, when appropriate, email and phone dialogues. |
• | Comparing smelters and refiners identified by suppliers to the Conflict Free Sourcing Initiative (“CFSI”) lists of validated conflict free and verified facilities and the U.S. Department of Commerce “Reporting Requirements Under Section 1502(d)(3)(C) of the Dodd-Frank Act World-Wide Conflict Mineral Processing Facilities” (http://www.ita.doc.gov/td/forestprod/DOC-ConflictMineralReport.pdf), and our own independent research. |
• | Including contractual terms and conditions regarding procurement practices that encourage suppliers to purchase raw materials from smelters / refiners which have achieved a compliant designation by the CFSI’s Conflict-Free Smelter Program (“CFSP”) or have an audit program with which CFSI has mutual recognition. |
• | Developing a risk mitigation plan that allows for continued trade with a supplier as appropriate through the supplier’s risk mitigation efforts, and evaluating the business relationship with suppliers that do not address the risks. |
Due Diligence Results
We utilized the Conflict Minerals Reporting Template included in the CFSI to solicit our relevant direct suppliers to gather detailed information regarding the existence of subject minerals in materials or components sold to us, as well as the origin and chain of custody of the subject minerals. To date we have received no information from such direct suppliers indicating that subject minerals in our supply chain directly or indirectly financed or benefitted armed groups in the Covered Countries; even so, based on the information provided by these suppliers and our own due diligence efforts for the Reporting Period, we do not have sufficient information to conclusively determine the countries of origin or chain of custody of subject minerals in the products. Some suppliers disclosed to us that scrap/recycled sources of subject minerals were identified in their supply chains and did not require due diligence.
Based on the information provided by these suppliers and information available from CFSI, SPX believes the smelters and refiners and the countries of origin of subject minerals processed by these smelters and refiners that may have been used to produce subject minerals used in the products include those listed on Annexes A and B.
Additional Due Diligence and Risk Mitigation
SPX intends to continue to evaluate its due diligence program, and, in particular, intends to annually review the criteria used to select suppliers for solicitation. We expect to continue to engage with our direct suppliers so that they more closely comply with SPX’s conflict minerals policy and are able to track the sourcing of conflict minerals with greater precision. To that end, the Company expects to continue outreach efforts among the direct supplier base, particularly with respect to direct suppliers that have not previously conducted business with the Company and with respect to direct suppliers that are unable to provide greater transparency as to their own sourcing practices.
Independent Audit Report
Consistent with Rule 13p-1 and the SEC’s April 29, 2014 statement relating to Rule 13p-1, this Report is not required to be accompanied by an independent private sector audit.
3
Annexes
The information in the below two tables, Annexes A and B, have been gathered and transmitted through multiple levels of our supply chain, and there is a risk that it is not accurate or current. In most cases, direct suppliers provided smelter and/or refiner information and therefore any country of origin data related to such smelter and/or refiner for their entire supply chain without identifying which smelters and/or refiners may have contributed conflict minerals to components and materials actually supplied to us. Accordingly, we cannot verify that any of the smelters and/or refiners or country of origin data shown in these tables actually were part of our supply chain. The presence of a smelter or refiner in this table does not necessarily mean that conflict minerals processed at that smelter or refiner were used in any components and materials supplied to us or in any SPX Corporation products.
Annex A
Below is a list of the smelters / refiners collected as a result of our due diligence activities:
Subject Mineral | Name of Smelter / Refiner† | Status* | ||
Gold | Abington Reldan Metals, LLC | Active | ||
Gold | Advanced Chemical Company | Compliant | ||
Gold | Aida Chemical Industries Co., Ltd. | Compliant | ||
Gold | Al Etihad Gold LLC | Compliant | ||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Compliant | ||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Compliant | ||
Gold | Amax Copper, Inc. | Alleged | ||
Gold | AngloGold Ashanti Córrego do Sítio Mineração | Compliant | ||
Gold | Argor-Heraeus S.A. | Compliant | ||
Gold | Asahi Pretec Corp. | Compliant | ||
Gold | Asahi Refining Canada Ltd. | Compliant | ||
Gold | Asahi Refining USA Inc. | Compliant | ||
Gold | Asaka Riken Co., Ltd. | Compliant | ||
Gold | ASARCO Incorporated | Alleged | ||
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Alleged | ||
Gold | AU Traders and Refiners | Compliant | ||
Gold | AURA-II | Alleged | ||
Gold | Aurubis AG | Compliant | ||
Gold | Baiyin Nonferrous Metals Corporation (BNMC) | Alleged | ||
Gold | Bangalore Refinery | Active | ||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Compliant | ||
Gold | Boliden AB | Compliant | ||
Gold | C. Hafner GmbH + Co. KG | Compliant | ||
Gold | Caridad | Alleged | ||
Gold | CCR Refinery - Glencore Canada Corporation | Compliant | ||
Gold | Cendres + Métaux S.A. | Active | ||
Gold | Changzhou Chemical Research Institute Co. Ltd. | Alleged | ||
Gold | Cheong Hing | Alleged | ||
Gold | Chernan Technology co., ltd | Alleged | ||
Gold | Chimet S.p.A. | Compliant | ||
Gold | Chin-Leep Enterprise Co., Ltd. | Alleged | ||
Gold | Chugai Mining | Alleged | ||
Gold | Compagnie Des Metaux Precieux Paris | Alleged | ||
Gold | Companhia Real de Metais | Alleged | ||
Gold | Comptoir Lyon-Alemand Louyot | Alleged | ||
Gold | CS | Alleged | ||
Gold | Daejin Indus Co., Ltd. | Compliant | ||
Gold | Daye Non-Ferrous Metals Mining Ltd. | Alleged | ||
Gold | DEGUSSA CANADA LTD. | Alleged | ||
Gold | Degussa Sonne / Mond Goldhandel GmbH | Alleged | ||
Gold | DODUCO GmbH | Compliant | ||
Gold | Dong'guan Dong wu Violent-toxic Chemical Products Co., Ltd. | Alleged | ||
Gold | DONGGUAN DONGXU METAL SURFACE HANDLE CO.,LTD | Alleged | ||
Gold | Dongguan Standard Electronic Material.Co.,Ltd | Alleged | ||
Gold | Dongguanshi Sutande Dianzi Cailiao Youxiangongsi | Alleged | ||
Gold | Dong-Wo Co., Ltd. | Alleged | ||
Gold | Dowa | Compliant | ||
Gold | DSC (Do Sung Corporation) | Compliant | ||
Gold | DUOXIN | Alleged | ||
Gold | E-CHEM Enterprise Corp | Alleged | ||
Gold | Eco-System Recycling Co., Ltd. | Compliant | ||
Gold | Elemetal Refining, LLC | Compliant | ||
Gold | Emirates Gold DMCC | Compliant | ||
Gold | Engelhard Australia | Alleged | ||
Gold | Engelhard Corporation (U.S. location) | Alleged | ||
Gold | Engelhard Corporation (Canada location) | Alleged | ||
Gold | ESG Edelmetall-Service | Alleged | ||
Gold | Faggi Enrico S.p.A. | Alleged | ||
Gold | Ferro Corporation | Alleged | ||
Gold | Fidelity Printers and Refiners Ltd. | Alleged | ||
Gold | Foxxconn | Alleged | ||
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | Alleged | ||
Gold | Gansu-based Baiyin Nonferrous Metals Corporation (BNMC) | Alleged | ||
Gold | Geib Refining Corporation | Active | ||
Gold | Gold and Siver Refining Strokes Ltd. | Alleged | ||
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | Alleged | ||
Gold | Guangdong Jinding Gold Limited | Alleged | ||
Gold | Guangdong MingFa Precious Metal Co.,Ltd | Alleged | ||
Gold | GuangZHou Jin Ding | Alleged | ||
Gold | Gujarat Gold Centre | Alleged | ||
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | Alleged | ||
Gold | H.Drijfhout & Zoon's Edelmetaalbedrijven BV | Alleged | ||
Gold | Handy & Harman Refining Group Inc. | Alleged | ||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | Alleged | ||
Gold | Harima Smelter | Alleged | ||
Gold | Heesung Metal Ltd | Alleged | ||
Gold | Heimerle + Meule GmbH | Compliant | ||
A-2
Gold | henan middle plain gold smelt | Alleged | ||
Gold | Henan Sanmenxia Lingbao City Jinyuan Mining Industry Co., Ltd | Alleged | ||
Gold | Henan Yuguang Gold & Lead Co., Ltd. | Alleged | ||
Gold | Heraeus (Zhaoyuan) Precious Metal Materials Co.,Ltd. | Alleged | ||
Gold | Heraeus Incorporated | Alleged | ||
Gold | Heraeus Ltd Hong Kong | Alleged | ||
Gold | Heraeus Metals Hong Kong Ltd. | Compliant | ||
Gold | Heraeus Precious Metals GmbH & Co. KG | Compliant | ||
Gold | Heraeus Precious Metals North America | Alleged | ||
Gold | HMG | Alleged | ||
Gold | Hon Hai Precision Co., Ltd. | Alleged | ||
Gold | Hon Shen Co., Ltd. | Alleged | ||
Gold | Honorable Hardware Craft Product Limited Company | Alleged | ||
Gold | Hunan Chenzhou Mining Co., Ltd. | Alleged | ||
Gold | HwaSeong CJ Co., Ltd. | Alleged | ||
Gold | Hwasung CJ Co., Ltd. | Alleged | ||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | Compliant | ||
Gold | Ishifuku Metal Industry Co., Ltd. | Compliant | ||
Gold | Istanbul Gold Refinery | Compliant | ||
Gold | Japan Mint | Compliant | ||
Gold | Jia Lung Corp | Alleged | ||
Gold | Jiangsu Sue large special chemical reagent Co., LTD | Alleged | ||
Gold | Jiangxi Copper Co., Ltd. | Compliant | ||
Gold | Jie sheng | Alleged | ||
Gold | Jin Dong Heng | Alleged | ||
Gold | Jin Jinyin refining company limited | Alleged | ||
Gold | Jinfeng Gold Mine Smelter | Alleged | ||
Gold | Jinlong Copper Co., Ltd. | Alleged | ||
Gold | Johnson Matthey & Pauwels SA | Alleged | ||
Gold | Johnson Matthey Limited (Australia) | Alleged | ||
Gold | JSC Aurat | Alleged | ||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Compliant | ||
Gold | JSC Urakectrined | Alleged | ||
Gold | JSC Uralelectromed | Compliant | ||
Gold | JX Nippon Mining & Metals Co., Ltd. | Compliant | ||
Gold | Kaloti Precious Metals | Alleged | ||
Gold | Kanfort Industrial (Yantai) | Alleged | ||
Gold | Kazakhmys Smelting LLC | Alleged | ||
Gold | Kazzinc | Compliant | ||
Gold | Kennecott Utah Copper LLC | Compliant | ||
Gold | KGHM Polska Miedź Spółka Akcyjna | Active | ||
Gold | Kojima Chemicals Co., Ltd. | Compliant | ||
Gold | Korea Metal Co., Ltd. | Alleged | ||
Gold | Korea Zinc Co., Ltd. | Compliant | ||
Gold | Kosak Seiren | Alleged | ||
Gold | Kuan Shuo Ind. Co., Ltd. | Alleged | ||
A-3
Gold | Kunshan Jinli chemical industry reagents co.,Ltd. | Alleged | ||
Gold | KYOCERA | Alleged | ||
Gold | Kyrgyzaltyn JSC | Compliant | ||
Gold | L' azurde Company For Jewelry | Alleged | ||
Gold | LBMA | Alleged | ||
Gold | Lian Xing Plating Factory | Alleged | ||
Gold | Lingbao Gold Company Limited | Alleged | ||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | Alleged | ||
Gold | LINXENS | Alleged | ||
Gold | LITTELFUSE | Alleged | ||
Gold | L'Orfebre S.A. | Alleged | ||
Gold | LS-NIKKO Copper Inc. | Compliant | ||
Gold | Luo Yang ZIJIN YINHUI Gold Smelting Co., Ltd | Alleged | ||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | Alleged | ||
Gold | Malaysia Smelting Corporation Berhad | Alleged | ||
Gold | Materion | Compliant | ||
Gold | Matsuda Sangyo Co., Ltd. | Compliant | ||
Gold | Metalli Preziosi S.p.A. | Alleged | ||
Gold | Metallurgie Hoboken Overpelt SA | Alleged | ||
Gold | Metalor Technologies (Hong Kong) Ltd (Hong Kong location) | Alleged | ||
Gold | Metalor Technologies (Hong Kong) Ltd. (China location) | Compliant | ||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Compliant | ||
Gold | Metalor Technologies (Suzhou) Ltd. | Compliant | ||
Gold | Metalor Technologies S.A. | Compliant | ||
Gold | Metalor USA Refining Corporation | Compliant | ||
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | Compliant | ||
Gold | Mitsubishi Materials Corporation | Compliant | ||
Gold | Mitsui | Alleged | ||
Gold | Mitsui Mining and Smelting Co., Ltd. | Compliant | ||
Gold | MMTC-PAMP India Pvt., Ltd. | Compliant | ||
Gold | Modeltech Sdn Bhd | Active | ||
Gold | Morigin Company | Alleged | ||
Gold | Morris and Watson | Alleged | ||
Gold | Morris and Watson Gold Coast | Alleged | ||
Gold | Moscow Special Alloys Processing Plant | Compliant | ||
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Compliant | ||
Gold | Nathan Trotter & Co., Inc | Alleged | ||
Gold | Navoi Mining and Metallurgical Combinat | Active | ||
Gold | Nihon Material Co., Ltd. | Compliant | ||
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Compliant | ||
Gold | Ohura Precious Metal Industry Co., Ltd. | Compliant | ||
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Compliant | ||
Gold | OJSC Kolyma Refinery | Alleged | ||
Gold | OJSC Novosibirsk Refinery | Compliant | ||
Gold | PAMP S.A. | Compliant | ||
A-4
Gold | Pease & Curren | Alleged | ||
Gold | Penglai Penggang Gold Industry Co., Ltd. | Alleged | ||
Gold | PJ-USA | Alleged | ||
Gold | PRECIOUS METAL SALES CORP. | Alleged | ||
Gold | Prioksky Plant of Non-Ferrous Metals | Compliant | ||
Gold | PT Aneka Tambang (Persero) Tbk | Compliant | ||
Gold | PX Précinox S.A. | Compliant | ||
Gold | Rand Refinery (Pty) Ltd. | Compliant | ||
Gold | Reldan Metals, Inc | Alleged | ||
Gold | Remondis Argentia B.V. | Alleged | ||
Gold | Republic Metals Corporation | Compliant | ||
Gold | Rohm & Haas Elec. Mat'ls | Alleged | ||
Gold | Royal Canadian Mint | Compliant | ||
Gold | rui sheng | Alleged | ||
Gold | SAAMP | Alleged | ||
Gold | Sabin Metal Corp. | Alleged | ||
Gold | SAFINA A.S. | Alleged | ||
Gold | Sai Refinery | Alleged | ||
Gold | Samduck Precious Metals | Compliant | ||
Gold | Samwon Metals Corp. | Alleged | ||
Gold | Sanmenxia hang seng science and technology, research and development Co., LTD | Alleged | ||
Gold | SAXONIA Edelmetalle GmbH | Compliant | ||
Gold | Schone Edelmetaal B.V. | Compliant | ||
Gold | SD(Samdok) Metal | Alleged | ||
Gold | SEMPSA Joyería Platería S.A. | Compliant | ||
Gold | Sen Silver | Alleged | ||
Gold | Sendi (Kyocera Corporation) | Alleged | ||
Gold | Senyin | Alleged | ||
Gold | Shan Dong Huangjin | Alleged | ||
Gold | Shandon Jin Jinyin Refining Limited | Alleged | ||
Gold | Shandong Humon Smelting Co., Ltd. | Alleged | ||
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | Alleged | ||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | Compliant | ||
Gold | Sheffield Smelting Co. Ltd. | Alleged | ||
Gold | Shen Zhen Thousand Island Ltd. | Alleged | ||
Gold | Shenzhen Chemicals & light industry co.,ltd | Alleged | ||
Gold | Shenzhen fujun material technology co.,ltd | Alleged | ||
Gold | Shenzhen Heng Zhong Industry Co.,Ltd. | Alleged | ||
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | Alleged | ||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | Compliant | ||
Gold | Singway Technology Co., Ltd. | Compliant | ||
Gold | So Accurate Group, Inc. | Alleged | ||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Compliant | ||
Gold | Sojitz | Alleged | ||
Gold | Solar Applied Materials Technology Corp. | Compliant | ||
A-5
Gold | Solartech | Alleged | ||
Gold | Soochow University's | Alleged | ||
Gold | Standard Bank | Alleged | ||
Gold | Stender Electronic Materials Co., Ltd. | Alleged | ||
Gold | Strain DS Force Shop | Alleged | ||
Gold | Sudan** Gold Refinery | Alleged | ||
Gold | Sumitomo Metal Mining Co., Ltd. | Compliant | ||
Gold | SungEel HiTech | Active | ||
Gold | Super Dragon Technology Co., Ltd. | Alleged | ||
Gold | Suzhou Xingrui Noble | Alleged | ||
Gold | T.C.A S.p.A | Compliant | ||
Gold | Tai zhou chang san Jiao electron Co.,Ltd | Alleged | ||
Gold | Tai'zhou City Yangtze River Delta Electron Ltd. | Alleged | ||
Gold | Tanaka Kikinzoku Kogyo K.K. | Compliant | ||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | Compliant | ||
Gold | Tian Cheng | Alleged | ||
Gold | Tokuriki Honten Co., Ltd. | Compliant | ||
Gold | Tongling Nonferrous Metals Group Co., Ltd. | Alleged | ||
Gold | Tony Goetz NV | Active | ||
Gold | TOO Tau-Ken-Altyn | Alleged | ||
Gold | Torecom | Compliant | ||
Gold | UBS AG | Alleged | ||
Gold | Umicore Brasil Ltda. | Compliant | ||
Gold | Umicore Galvanotechnik GmbH | Alleged | ||
Gold | Umicore Precious Metal Refining | Alleged | ||
Gold | Umicore Precious Metals Thailand | Compliant | ||
Gold | Umicore S.A. Business Unit Precious Metals Refining | Compliant | ||
Gold | Uniforce Metal Industrial Corp | Alleged | ||
Gold | United Precious Metal Refining, Inc. | Compliant | ||
Gold | Universal Precious Metals Refining Zambia | Alleged | ||
Gold | Uyemura | Alleged | ||
Gold | Valcambi S.A. | Compliant | ||
Gold | Western Australian Mint trading as The Perth Mint | Compliant | ||
Gold | WIELAND Edelmetalle GmbH | Compliant | ||
Gold | Williams Gold Refining (U.S. location) | Alleged | ||
Gold | Williams Gold Refining Company (Canada location) | Alleged | ||
Gold | Williams/Williams Brewster | Alleged | ||
Gold | Wuxi City Precious Metal Electronic Material Fty | Alleged | ||
Gold | Yamamoto Precious Metal Co., Ltd. | Compliant | ||
Gold | Yantai Guodasafina High-Tech Environmental Refinery Co. Ltd. | Alleged | ||
Gold | Yantai Zhaojin Lai Fuk Precious Metals Co., Ltd. | Alleged | ||
Gold | Yantai Zhaojin Mai Fu- Precious Metals Limited | Alleged | ||
Gold | Yokohama Metal Co., Ltd. | Compliant | ||
Gold | Yoo Chang Metal Industrial Co., Ltd. | Alleged | ||
Gold | Yueqing Chemical & Light Industry & Building Materials Co., Ltd. | Alleged | ||
Gold | Yunnan Copper Industry Co., Ltd. | Alleged | ||
A-6
Gold | Yunnan Gejiu Zili Metallurgical Group Co., Ltd. | Alleged | ||
Gold | Zhe Jiang Guang Yuan Noble Metal Smelting Factory | Alleged | ||
Gold | Zhejiang suijin | Alleged | ||
Gold | Zhongkuang Gold Industry Co.,LTD | Alleged | ||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Compliant | ||
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | Compliant | ||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | Compliant | ||
Tantalum | Conghua Tantalum and Niobium Smeltry | Compliant | ||
Tantalum | D Block Metals, LLC | Compliant | ||
Tantalum | Duoluoshan | Compliant | ||
Tantalum | E.S.R. Electronics | Alleged | ||
Tantalum | Exotech Inc. | Compliant | ||
Tantalum | F&X Electro-Materials Ltd. | Compliant | ||
Tantalum | FIR Metals & Resource Ltd. | Compliant | ||
Tantalum | Global Advanced Metals Aizu | Compliant | ||
Tantalum | Global Advanced Metals Boyertown | Compliant | ||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | Compliant | ||
Tantalum | H.C. Starck Co., Ltd. | Compliant | ||
Tantalum | H.C. Starck GmbH Laufenburg | Alleged | ||
Tantalum | H.C. Starck Hermsdorf GmbH | Compliant | ||
Tantalum | H.C. Starck Inc. | Compliant | ||
Tantalum | H.C. Starck Ltd. | Compliant | ||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | Compliant | ||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | Compliant | ||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | Compliant | ||
Tantalum | Hi-Temp Specialty Metals, Inc. | Compliant | ||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | Compliant | ||
Tantalum | Jiangxi Tuohong New Raw Material | Compliant | ||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Compliant | ||
Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | Compliant | ||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | Compliant | ||
Tantalum | KEMET Blue Metals | Compliant | ||
Tantalum | KEMET Blue Powder | Compliant | ||
Tantalum | King-Tan Tantalum Industry Ltd. | Compliant | ||
Tantalum | LSM Brasil S.A. | Compliant | ||
Tantalum | Metallurgical Products India Pvt., Ltd. | Compliant | ||
Tantalum | Mineração Taboca S.A. | Compliant | ||
Tantalum | Mitsui Mining and Smelting Co., Ltd. | Compliant | ||
Tantalum | Molycorp Silmet A.S. | Compliant | ||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Compliant | ||
Tantalum | Plansee SE Liezen | Alleged | ||
Tantalum | Plansee SE Reutte | Alleged | ||
Tantalum | Power Resources Ltd. | Compliant | ||
Tantalum | QuantumClean | Compliant | ||
Tantalum | Resind Indústria e Comércio Ltda. | Compliant | ||
Tantalum | Solikamsk Magnesium Works OAO | Compliant | ||
A-7
Tantalum | Taki Chemical Co., Ltd. | Compliant | ||
Tantalum | Telex Metals | Compliant | ||
Tantalum | Tranzact, Inc. | Compliant | ||
Tantalum | Ulba Metallurgical Plant JSC | Compliant | ||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | Compliant | ||
Tantalum | Yanling Jincheng Tantalum Co., Ltd. | Compliant | ||
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | Compliant | ||
Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | Compliant | ||
Tin | A.E.B. International, Inc. | Alleged | ||
Tin | Alpha | Compliant | ||
Tin | Alpha Metals Korea Ltd | Alleged | ||
Tin | An Thai Minerals Co., Ltd. | Alleged | ||
Tin | An Vinh Joint Stock Mineral Processing Company | Active | ||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | Compliant | ||
Tin | China Tin Group Co., Ltd. | Compliant | ||
Tin | CINTAS METALICAS S.A | Alleged | ||
Tin | CNMC (Guangxi) PGMA Co., Ltd. | Alleged | ||
Tin | Cooperativa Metalurgica de Rondônia Ltda. | Compliant | ||
Tin | CV Ayi Jaya | Compliant | ||
Tin | CV Dua Sekawan | Compliant | ||
Tin | CV Gita Pesona | Compliant | ||
Tin | CV Serumpun Sebalai | Compliant | ||
Tin | CV Tiga Sekawan | Compliant | ||
Tin | CV United Smelting | Compliant | ||
Tin | CV Venus Inti Perkasa | Compliant | ||
Tin | Dowa | Compliant | ||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Active | ||
Tin | Elmet S.L.U. | Compliant | ||
Tin | EM Vinto | Compliant | ||
Tin | Empresa Metalúrgica Vinto | Alleged | ||
Tin | Estanho de Rondônia S.A. | Alleged | ||
Tin | Feinhütte Halsbrücke GmbH | Alleged | ||
Tin | Felder GmbH - Löttechnik | Alleged | ||
Tin | Fenix Metals | Compliant | ||
Tin | Galloo N.V. | Alleged | ||
Tin | Gejiu Fengming Metallurgy Chemical Plant | Compliant | ||
Tin | Gejiu Jinye Mineral Company | Compliant | ||
Tin | Gejiu Kai Meng Industry and Trade LLC | Active | ||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | Compliant | ||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | Active | ||
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | Alleged | ||
Tin | Grant Manufacturing and Alloying | Alleged | ||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | Compliant | ||
Tin | Hayes Metals | Alleged | ||
Tin | Hongqiao Metals (Kunshan) Co., Ltd. | Alleged | ||
A-8
Tin | HuiChang Hill Tin Industry Co., Ltd. | Compliant | ||
Tin | Huichang Jinshunda Tin Co., Ltd. | Alleged | ||
Tin | Imperial Zinc, Corp. | Alleged | ||
Tin | International Wire Group, Inc. | Alleged | ||
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | Compliant | ||
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | Alleged | ||
Tin | Magnu's Minerais Metais e Ligas Ltda. | Compliant | ||
Tin | Malaysia Smelting Corporation (MSC) | Compliant | ||
Tin | Melt Metais e Ligas S.A. | Compliant | ||
Tin | Metahub Industries Sdn. Bhd. | Alleged | ||
Tin | Metallic Resources, Inc. | Compliant | ||
Tin | Metallo-Chimique N.V. | Compliant | ||
Tin | Mineração Taboca S.A. | Compliant | ||
Tin | Minmetals ganzhou Tin Co. Ltd. | Alleged | ||
Tin | Minsur | Compliant | ||
Tin | Mitsubishi Materials Corporation | Compliant | ||
Tin | Modeltech Sdn Bhd | Active | ||
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | Active | ||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Alleged | ||
Tin | Novosibirsk Processing Plant Ltd. | Alleged | ||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Compliant | ||
Tin | O.M. Manufacturing Philippines, Inc. | Compliant | ||
Tin | Operaciones Metalurgical S.A. | Compliant | ||
Tin | Persang Alloy Industries | Alleged | ||
Tin | Phoenix Metal Ltd. | Alleged | ||
Tin | Poongsan Corporation | Alleged | ||
Tin | PT Alam Lestari Kencana | Alleged | ||
Tin | PT Aries Kencana Sejahtera | Compliant | ||
Tin | PT Artha Cipta Langgeng | Compliant | ||
Tin | PT ATD Makmur Mandiri Jaya | Compliant | ||
Tin | PT Babel Inti Perkasa | Compliant | ||
Tin | PT Bangka Kudai Tin | Alleged | ||
Tin | PT Bangka Prima Tin | Compliant | ||
Tin | PT Bangka Putra Karya | Alleged | ||
Tin | PT Bangka Timah Utama Sejahtera | Alleged | ||
Tin | PT Bangka Tin Industry | Compliant | ||
Tin | PT Belitung Industri Sejahtera | Compliant | ||
Tin | PT BilliTin Makmur Lestari | Alleged | ||
Tin | PT Bukit Timah | Compliant | ||
Tin | PT Cipta Persada Mulia | Compliant | ||
Tin | PT DS Jaya Abadi | Compliant | ||
Tin | PT Eunindo Usaha Mandiri | Compliant | ||
Tin | PT Fang Di MulTindo | Alleged | ||
Tin | PT Inti Stania Prima | Compliant | ||
Tin | PT Justindo | Alleged | ||
Tin | PT Karimun Mining | Compliant | ||
A-9
Tin | PT Kijang Jaya Mandiri | Compliant | ||
Tin | PT Lautan Harmonis Sejahtera | Compliant | ||
Tin | PT Mitra Stania Prima | Compliant | ||
Tin | PT O.M. Indonesia | Compliant | ||
Tin | PT Panca Mega Persada | Compliant | ||
Tin | PT Pelat Timah Nusantara Tbk | Alleged | ||
Tin | PT Prima Timah Utama | Compliant | ||
Tin | PT Refined Bangka Tin | Compliant | ||
Tin | PT Sariwiguna Binasentosa | Compliant | ||
Tin | PT Seirama Tin Investment | Alleged | ||
Tin | PT Stanindo Inti Perkasa | Compliant | ||
Tin | PT Sukses Inti Makmur | Compliant | ||
Tin | PT Sumber Jaya Indah | Compliant | ||
Tin | PT Timah (Persero) Tbk Kundur | Compliant | ||
Tin | PT Timah (Persero) Tbk Mentok | Compliant | ||
Tin | PT Tinindo Inter Nusa | Compliant | ||
Tin | PT Tirus Putra Mandiri | Alleged | ||
Tin | PT Tommy Utama | Compliant | ||
Tin | PT Wahana Perkit Jaya | Compliant | ||
Tin | Resind Indústria e Comércio Ltda. | Compliant | ||
Tin | Rui Da Hung | Compliant | ||
Tin | Schloetter Co. Ltd | Alleged | ||
Tin | Shaoxing Tianlong Tin Materials Co., Ltd | Alleged | ||
Tin | Sizer Metals PTE | Alleged | ||
Tin | Soft Metais Ltda. | Compliant | ||
Tin | Sumitomo Metal Mining Co. Ltd. | Alleged | ||
Tin | Super Ligas | Alleged | ||
Tin | Taicang City Nancang Metal Meterial Co.,Ltd | Alleged | ||
Tin | Tamura Corporation | Alleged | ||
Tin | Thaisarco | Compliant | ||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Alleged | ||
Tin | UNIFORCE METAL INDUSTRIAL CORP. | Alleged | ||
Tin | VQB Mineral and Trading Group JSC | Compliant | ||
Tin | White Solder Metalurgia e Mineração Ltda. | Compliant | ||
Tin | Xianghualing Tin Industry Co., Ltd. | Alleged | ||
Tin | Xinmao Xiye (Tin Company) | Alleged | ||
Tin | Yifeng Tin | Alleged | ||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | Active | ||
Tin | Yunnan Geiju Zili Metallurgy Co. Ltd. | Alleged | ||
Tin | Yunnan Gejiu Jinye Minerals | Alleged | ||
Tin | Yunnan Tin Company Limited | Compliant | ||
Tin | Zhongshan Jinye Smelting Co., Ltd | Alleged | ||
Tungsten | A.L.M.T. TUNGSTEN Corp. | Compliant | ||
Tungsten | ACL Metais Eireli | Alleged | ||
Tungsten | Asia Tungsten Products Vietnam Ltd. | Compliant | ||
Tungsten | ATC(Asia Tungsten Product Co., Ltd) | Alleged | ||
A-10
Tungsten | Carbografite Equipamentos Industriais Ltda | Alleged | ||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | Compliant | ||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | Compliant | ||
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | Alleged | ||
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | Alleged | ||
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | Compliant | ||
Tungsten | Ganxian Shirui New Material Co., Ltd. | Alleged | ||
Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. | Alleged | ||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | Compliant | ||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | Compliant | ||
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | Alleged | ||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | Compliant | ||
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | Alleged | ||
Tungsten | Global Tungsten & Powders Corp. | Compliant | ||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | Compliant | ||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | Compliant | ||
Tungsten | H.C. Starck Tungsten GmbH | Compliant | ||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | Compliant | ||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | Compliant | ||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | Alleged | ||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | Compliant | ||
Tungsten | Hydrometallurg, JSC | Compliant | ||
Tungsten | Japan New Metals Co., Ltd. | Compliant | ||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Compliant | ||
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | Alleged | ||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | Compliant | ||
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Alleged | ||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Compliant | ||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | Compliant | ||
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | Compliant | ||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | Compliant | ||
Tungsten | Kennametal Fallon | Compliant | ||
Tungsten | Kennametal Huntsville | Compliant | ||
Tungsten | Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd | Alleged | ||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | Compliant | ||
Tungsten | Moliren Ltd | Compliant | ||
Tungsten | Niagara Refining LLC | Compliant | ||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Compliant | ||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | Compliant | ||
Tungsten | Pobedit, JSC | Alleged | ||
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | Alleged | ||
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | Compliant | ||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Compliant | ||
Tungsten | Unecha Refractory metals plant | Compliant | ||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Compliant | ||
Tungsten | Wolfram Bergbau und Hütten AG | Compliant | ||
A-11
Tungsten | Woltech Korea Co., Ltd. | Compliant | ||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | Compliant | ||
Tungsten | Xiamen Tungsten Co., Ltd. | Compliant | ||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | Compliant | ||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | Compliant | ||
† Smelter or refiner names as reported by CFSI as of May 1, 2017.
* Status as defined and reported by CFSI: “Compliant” as a smelter / refiner that is compliant under CFSP; "Active" as a smelter / refiner working toward becoming compliant under CFSP; and “Alleged” as an unconfirmed smelter / refiner.
** We are aware that this country is sanctioned by the U.S. government, restricting trade with U.S. companies. This smelter was identified by our suppliers as possibly being in their supply chain. However, due to the nature of the conflict minerals reporting at the company level - rather than product level - for many tiers in our supply chain, there is uncertainty as to whether this country is actually within our supply chain. We continue to investigate this and seek improved accuracy in reporting from suppliers. Should a sanctioned country actually be in our supply chain, any business dealings would be indirect and several layers down into the supply chain and we would take appropriate steps to assure compliance with all applicable laws.
Annex B
Below is a list of the mineral country of origin information collected as a result of our due diligence activities:
Australia | Bolivia | Brazil | ||
Canada | China | Indonesia | ||
Japan | Malaysia | Peru | ||
Switzerland | Thailand | Unites States | ||
A-12