UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
ReWalk Robotics Ltd.
(Exact name of registrant as specified in its charter)
| State of Israel | 001-36612 | Not applicable | ||
| (State or other jurisdiction of | (Commission | (IRS Employer | ||
| incorporation or organization) | file number) | Identification No.) |
| 3 Hatnufa Street, Floor 6, Yokneam Ilit, Israel | 2069203 | |
| (Address of principal executive offices) | (Zip Code) |
Ori Gon, Chief Financial Officer, telephone: +972.4.6108124
(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, 2018.
Section 1 - Conflict Minerals Disclosures
Item 1.01 – Conflict Minerals Disclosure and Report
Introduction
This Specialized Disclosure Form (“Form SD”) of ReWalk Robotics Ltd. (the “Company,” “we,” or “us”) is filed pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended (the “1934 Act”), for the reporting period from January 1, 2018 to December 31, 2018.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”), that originated in the Democratic Republic of the Congo (“DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).
Per the Rule and the instructions to Form SD, the Company is required to exercise due diligence on the source and chain of custody of such Conflict Minerals if the Company knows or has reason to believe that those Conflict Minerals originated in the DRC or an adjoining country and knows or has reason to believe that they may not be from recycled or scrap sources.
Conclusion Based on Reasonable Country of Origin Inquiry
In accordance with the Rule, the Company has concluded in good faith that during the year ended December 31, 2018:
| ● | Certain of the Company’s operations manufactured, or contracted to manufacture, products (the “Covered Products”) for which the Conflict Minerals are necessary to the functionality or production of those products. | |
| ● | Based on the Company’s good faith reasonable country of origin inquiry regarding the Conflict Minerals, which was designed to determine whether any of the Conflict Minerals contained in the Company’s Covered Products originated in the Covered Countries and whether any of the Conflict Minerals contained in the Covered Products are or may be from recycled or scrap sources, the Company had reason to believe that (i) the Conflict Minerals contained in its Covered Products may have originated in the Covered Countries and (ii) such Conflict Minerals may not be from recycled or scrap sources. |
On the basis of these conclusions, the Company proceeded to exercise due diligence with respect to the source and chain of custody of the Conflict Minerals contained in its Covered Products. The Conflict Minerals Report (the “CMR”) describing the Company’s due diligence efforts is attached as Exhibit 1.01 to this Form SD for the reporting period from January 1, 2018 to December 31, 2018. This CMR has not been subject to an independent private sector audit.
Conflict Minerals Disclosure
A copy of the Company’s CMR is filed as Exhibit 1.01 hereto, and is publicly available on the “Corporate Governance” page in the “Investor Relations” section of the Company’s website at http://ir.rewalk.com/static-files/5963cb2e-049c-4211-9d4d-8c443bd6044b. Information contained on, or that can be accessed through, the Company’s website does not constitute a part of this Form SD or the attached CMR and is not incorporated by reference herein.
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Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its CMR as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01 – Exhibits
| Exhibit 1.01 — | Conflict Minerals Report of ReWalk Robotics Ltd. for the year ended December 31, 2018, as required by Items 1.01 and 1.02 of this Form SD. |
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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.
ReWalk Robotics Ltd.
(Registrant)
| /s/ Ori Gon | May 30, 2019 | |
| Name: Ori Gon | (Date) | |
| Title: Chief Financial Officer |
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Exhibit 1.01
Conflict Minerals Report of
ReWalk Robotics Ltd.
For the year ended December 31, 2018
Introduction
This is the Conflict Minerals Report (the “CMR”) of ReWalk Robotics Ltd. (the “Company,” “we” or “us”) for calendar year 2018 in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “1934 Act”). The Rule requires disclosure of certain information when a registrant manufactures or contracts to manufacture products and when the “Conflict Minerals” specified in the Rule are necessary to the functionality or production of those products (the “Covered Products”).
“Conflict Minerals” are defined as gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. Tantalum, tin, tungsten and gold are collectively referred to as “3TG” for the purposes of this assessment. According to the Rule, if a registrant, based on a good faith reasonable country of origin inquiry regarding the Conflict Minerals, has reason to believe that (i) the Conflict Minerals contained in its Covered Products may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively with the DRC, the “Covered Countries”) or (ii) such Conflict Minerals may not be from recycled or scrap sources, then the registrant must exercise due diligence on the source and chain of custody of the Conflict Minerals, and submit a conflict minerals report describing those due diligence measures.
Reasonable Country of Origin Inquiry
During the year ended December 31, 2018, we conducted a reasonable country of origin inquiry to determine whether any of the necessary 3TG originating in the Covered Countries can be found in our products. We held meetings with management from various departments to discuss the applicable definitions of “manufacturer” and/or “contract to manufacture.” By way of this process, we identified specific types of product parts that are affected by the 3TG and mapped them to their respective suppliers.
We developed a risk-based approach that focuses on our key suppliers involved in the manufacturing the majority of our finished products. We identified 10 relevant suppliers. We requested that all identified suppliers provide information regarding the origin of the Conflict Minerals contained in products supplied using version 5.01, or higher, of the Conflict Minerals Reporting Template (“CMRT”) of the Responsible Business Alliance and created by the Responsible Minerals Initiative (“RMI”).
We reviewed the responses received, checked for inconsistencies, incomplete forms, and inaccurate responses, and sent reminders to suppliers who did not respond to our requests for information. We compared the smelters and refiners identified in the surveys against the lists of facilities that received a conformant or active designation by the RMI’s Responsible Minerals Assurance Process (“RMAP”). In accordance with the Rule, we concluded in good faith that during the year ended December 31, 2018:
| ● | Certain of our operations manufactured, or contracted to manufacture, products for which Conflict Minerals are necessary to the functionality or production of those products. |
| ● | Based on our good faith reasonable country of origin inquiry regarding the Conflict Minerals, which was designed to determine whether any of the Conflict Minerals contained in our Covered Products originated in the Covered Countries and whether any of the Conflict Minerals contained in the Covered Products are or may be from recycled or scrap sources, we had reason to believe that (i) the Conflict Minerals contained in our Covered Products may have originated in the Covered Countries and (ii) such Conflict Minerals may not be from recycled or scrap sources. |
As a result, we exercised due diligence on the Conflict Minerals’ source and chain of custody and are filing this CMR with our Form SD to comply with the requirements of the Rule. This CMR has not been subject to an independent private sector audit. The due diligence measures performed by the Company are discussed below.
Part I. Company Overview and Description of the Company’s Products Covered by This Report
The Company designs, develops and commercializes the ReWalk system, an innovative exoskeleton that allows wheelchair-bound persons with mobility impairments or other medical conditions to stand and walk once again. The ReWalk system consists of a light wearable brace support suit that integrates motors at the joints, rechargeable batteries, an array of sensors and a computer-based control system to power knee and hip movement. There are currently two types of products: ReWalk Personal and ReWalk Rehabilitation. ReWalk Personal is designed for everyday use by individuals at home and in their communities and is custom fitted for each user. ReWalk Rehabilitation is designed for the clinical rehabilitation environment where it provides valuable exercise and therapy. It also enables individuals to evaluate their capacity for using the ReWalk Personal system in the future.
Part II. The Company’s Due Diligence Process
Design of Due Diligence
We have adopted due diligence processes in accordance with Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016), including the related Supplements on Tin, Tantalum and Tungsten and on Gold published by the Organisation for Economic Co-Operation and Development (collectively, the “OECD Guidance”).
The design of our Conflict Minerals program is in conformity with the OECD Guidance, specifically as it relates to our position in the minerals supply chain as a company that is several levels removed from the actual mining of Conflict Minerals (i.e., a “downstream company”). We do not make direct purchases of raw ore or unrefined Conflict Minerals. Summarized below are the design components of our Conflict Minerals program as they relate to the five-step framework set forth in the OECD Guidance:
Due Diligence Performed
Step 1. Establish Strong Company Management Systems
Adopt, communicate and commit to a supply chain policy for minerals from conflict-affected and high-risk areas.
We have adopted our Conflict Minerals Policy (the “Policy”) related to our sourcing of 3TG. Our Policy outlines our commitment to responsible sourcing and the requirements imposed on participants in our supply chain, and is available on the “Corporate Governance” page in the “Investor Relations” section of our website at http://ir.rewalk.com/static-files/6ab6976a-0ab5-4021-b61f-682f26dc74b4. Information contained on, or that can be accessed through, our website does not constitute a part of this CMR and is not incorporated by reference herein.
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Structure internal management systems to support supply chain due diligence.
We provide, from time to time as necessary, training on the relevant Rule and process for relevant employees (e.g., purchasing, legal and finance).
Establish a System of Controls and Transparency over the Conflict Minerals Supply Chain.
We have implemented a supply chain system of controls and transparency through the use of due diligence tools created by the RMI. These tools include, as discussed in “Step 2” below, accepting at a minimum version 5.01, or higher, of the CMRT, which is designed to identify the smelters and refiners that process the necessary Conflict Minerals contained in our products. We have also adopted a process to maintain business records relating to 3TG due diligence, including retention of records of our due diligence processes, findings and resulting decisions for a period of five years.
Strengthen the Company’s Engagement with Suppliers
The Company informs its in-scope manufacturers and suppliers of its disclosure requirements, including its compliance with the OECD Guidance and the Rule.
Establish a Company-level Grievance Mechanism.
Our Policy includes a grievance procedure by which suppliers and other external parties may contact us should they wish to seek guidance or report concerns regarding Conflict Minerals. Concerns or grievances reported through this procedure are reviewed by the relevant staff members and follow-up activities are conducted, as appropriate.
Step 2. Identify and Assess Risks in the Supply Chain
Identify Risks in the Supply Chain by Identifying Company Suppliers.
Identify Company Suppliers.
As explained above, we do not buy raw ore or unrefined Conflict Minerals directly from refiners, smelters or mines. Our supply chain with respect to the Covered Products is complex, with multiple intermediaries and third parties in the supply chain between the manufacturing of the Covered Products and the original sources of the necessary Conflict Minerals. Because we believe that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us.
As discussed above under “Reasonable Country of Origin Inquiry” and “Part I. Company Overview and Description of the Company’s Products Covered by This Report,” we identified our Covered Products falling within the scope of the Rule (i.e., products which were manufactured or contracted to be manufactured by us) during the 2018 calendar year. Based on these Covered Products, we were able to identify the suppliers from which we purchase components or materials for the Covered Products that may include Conflict Minerals. We identified 10 relevant suppliers whose products may contain 3TG.
Request Conflict Minerals Reporting Templates (CMRTs) from suppliers.
We surveyed these 10 suppliers to identify the 3TG contained in the products they supply us with, the smelters and refiners that process the 3TG and the country of origin of such 3TG. The survey was conducted by utilizing version 5.01, or higher, of the CMRT. We utilize this RMI reporting template to collect data and information from our suppliers in order to identify the origins of 3TG in our supply chain. We received responses from 8 suppliers (80%).
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Assess Risks in the Supply Chain.
Analyze surveys for RMAP “conformant” and “active” smelters and refiners.
We compared smelters/refiners identified by the supply chain survey against the RMI’s “conformant” smelter list, which lists all facilities that have received a RMAP “conformant” designation from the RMI. We reviewed all of the responses to determine whether smelters and refiners identified in our supply chain obtained a designation of “conformant” or “active” from the RMI.
Of the CMRT responses we received from suppliers, some included incomplete responses as well as inconsistencies and inaccuracies within the reported data. In such cases, we contacted the suppliers directly in an effort to secure revised responses. Through this process, we have identified, to the best of our efforts, the smelters/refiners in our supply chain and country of origin information for the smelters and refiners identified by the supply chain survey.
Understand and define RMAP “conformant” and “active” statuses.
To compile its list, the RMI employs independent third-party auditors to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters and refiners which agree to undergo an audit. A smelter or refiner receives a RMAP “conformant” designation from the RMI if the smelter or refiner (i) completes an independent third-party audit, (ii) adheres to the RMAP’s assessment protocols by disclosing to auditors the identities and locations of the mines from which it sources Conflict Minerals, (iii) has been found by its independent third-party auditor to possess the systems and processes to support responsible sourcing of Conflict Minerals and can provide evidence to support its sourcing activities and (iv) maintains good standing in the program, through a continual validation process. The RMI’s RMAP “conformant” list provides the names, locations and links to Conflict Minerals policies of all smelters and refiners deemed compliant with the RMAP’s assessment protocols. Smelters and refiners with a “re-audit in progress” are still considered to be RMAP “conformant.”
Smelters and refiners labeled as “active” have committed to undergo an audit, which may be in progress, or are participating in one of the cross-recognized certification programs, namely, the London Bullion Market Association Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. These “active” smelters and refiners may be at various stages of the audit cycle, anywhere from completing the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase. Smelters or refiners may not retain their “active” status if they are unresponsive to requests for re-audit or corrective action past a certain time. Companies that have been determined to be downstream of smelters or refiners may not take part in the RMAP. However, they may participate in the RMI’s Downstream Audit Program, an independent validation of companies’ sourcing practices outside of the RMAP audit process.
Step 3. Design and Implement a Strategy to Respond to Identified Risks
We are working to improve our due diligence processes with respect to 3TG. Our risk mitigation efforts during 2018 included those discussed in this section.
Participate in Existing Industry Conflict Minerals Initiatives.
In light of the complexity of our and our suppliers’ supply chains, we are currently unable to assess adequately all of the risks in our supply chain. However, we continue to engage with suppliers to obtain current, accurate and complete information about our supply chain through the use of version 5.01, or higher, of the CMRT and to improve due diligence efforts to ensure responsible sourcing in compliance with our Policy.
Report Findings to Designated Senior Management.
The Company’s senior management, including our Chief Executive Officer and Chief Financial Officer, is briefed periodically about our supply chain due diligence efforts, risk analysis results and mitigation efforts.
Devise, Adopt and Implement a Risk Management Plan and Monitor Risk Mitigation Efforts.
The Company’s Policy seeks to encourage suppliers to responsibly source Conflict Minerals, but does not necessarily seek to eliminate sourcing from the Covered Countries. We also periodically review our progress, assess identified risks and determine follow-up action, as follows:
| ● | We follow up on inconsistent, incomplete, or inaccurate responses, and send reminders to suppliers who have not responded to our requests for information. |
| ● | Suppliers that source from smelters from the Covered Countries, where such smelters are not certified by the RMAP, are contacted and are asked to submit more information about their sourcing practices, including a corrective action plan. |
Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
Due to our downstream position in the supply chain, we do not have a direct relationship with 3TG smelters and refiners. Therefore, we do not perform direct audits of these entities within our supply chain, but instead rely on the efforts of organizations such as the RMI to influence smelters/refiners to undergo audits and become certified through the RMAP.
Step 5. Report Annually on Supply Chain Due Diligence
Our supply chain due diligence efforts are described in this CMR. We have filed this CMR in accordance with the Rule by submitting to the U.S. Securities and Exchange Commission a Form SD attaching this CMR. This CMR is also available on our website at http://ir.rewalk.com/sec-filings.
Part III. The Company’s Due Diligence Findings and Conclusions
Our Conflict Minerals process, as described above, allowed us to identify in-scope products and the corresponding suppliers. These 10 identified suppliers were surveyed using version 5.01, or higher, of the CMRT. We received survey responses from 80% of our suppliers. The results from the surveys did not allow us to make definitive conclusions as to the source of any potential Conflict Minerals.
Facilities Used to Process the Conflict Minerals in the Covered Products
Based on the information obtained by the Company during the due diligence process, the Company was unable to conclusively determine the origin of all the Conflict Minerals contained in the Covered Products. Based on the information provided by our suppliers as well as by the RMI, as of the date of this CMR, we believe that the facilities that may have been used to process the Conflict Minerals in our products during the reporting period in the 2018 calendar year may include the smelters and refiners listed in Annex I hereto.
Countries of Origin of the Conflict Minerals in the Covered Products
Based on the information provided by our suppliers as well as by RMI, as of the date of this CMR, we believe that the mine countries of origin of the Conflict Minerals contained in our products may include one or more of the countries listed in Annex II hereto.
We can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals in our Covered Products, since the information comes from direct and secondary suppliers and the RMI. Information gathered from our suppliers is not on a continuous, real-time basis. Despite our efforts to follow up with certain suppliers, we did not receive responses from all suppliers, and the suppliers who responded showed varying degrees of cooperation with our inquiries.
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Part IV. Implementation of Strategies to Respond to Identified Risks and Future Steps
We have taken, and intend to continue taking, steps to improve our due diligence processes and to minimize the risk that our necessary Conflict Minerals benefit armed groups. Going forward, we will continue working with our global supply chain to ensure responsible sourcing and assure compliance with applicable regulations through the following steps:
| 1. | Contacting from time to time, as is reasonably required, direct suppliers that do not respond to the supply chain survey by a specified date, requesting their responses. |
| 2. | Comparing, as is reasonably required, applicable smelters and refiners identified by the supply chain survey against the list of facilities that have received a RMAP “conformant” designation from the RMI. |
| 3. | Making a good faith effort to enact terms and conditions related to Conflict Minerals in supplier contracts. |
| 4. | Continuing to implement the Company’s Policy. |
| 5. | Engaging with suppliers to encourage them to provide requested information for 2019. |
Forward-Looking Statements
In addition to historical facts, this CMR contains forward-looking statements within the meaning of Section 27A of the U.S. Securities Act of 1933, as amended, Section 21E of the 1934 Act, and the safe harbor provisions of the U.S. Private Securities Litigation Reform Act of 1995. We have based these forward-looking statements on our current expectations and projections about future events. Forward-looking statements include information regarding further supplier engagement, due diligence and risk mitigation efforts and strategy, and involve certain risks and uncertainties. Actual results could differ materially from the forward-looking statements. Words such as “expects,” “anticipates,” “intends,” variations of these words, and similar expressions are intended to identify such forward looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on our ability to verify the accuracy or completeness of any supply chain information provided by suppliers and other factors discussed under the heading “Risk Factors” in our annual report on Form 10-K for the year ended December 31, 2018, as amended, filed with the U.S. Securities and Exchange Commission and other documents subsequently filed with or furnished to the U.S. Securities and Exchange Commission. Any forward-looking statement made in this CMR speaks only as of the date hereof. Except as otherwise required by law, the Company undertakes no obligation to update publicly the information contained in this CMR, or any forward looking statements, to reflect new information, events or circumstances after the date they were made, or to reflect the occurrence of unanticipated events.
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Annex I
List of Identified Smelters or Refiners
| Metal (*) | Smelter Reference List (*) | Smelter Country (*) | Smelter status by ID | |||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant | |||
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Conformant | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant | |||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant | |||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant | |||
| Gold | Asahi Pretec Corp. | JAPAN | Conformant | |||
| Gold | Asahi Refining Canada Ltd. | CANADA | Conformant | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant | |||
| Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant | |||
| Gold | Aurubis AG | GERMANY | Conformant | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant | |||
| Gold | Boliden AB | SWEDEN | Conformant | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant | |||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
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| Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant | |||
| Gold | Chimet S.p.A. | ITALY | Conformant | |||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant | |||
| Gold | Dowa | JAPAN | Conformant | |||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant | |||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant | |||
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant | |||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant | |||
| Gold | Istanbul Gold Refinery | TURKEY | Conformant | |||
| Gold | Italpreziosi | ITALY | Conformant | |||
| Gold | Japan Mint | JAPAN | Conformant |
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| Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant | |||
| Gold | Kazzinc | KAZAKHSTAN | Conformant | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant | |||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant | |||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Marsam Metals | BRAZIL | Conformant | |||
| Gold | Materion | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant | |||
| Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
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| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant | |||
| Gold | Nihon Material Co., Ltd. | JAPAN | Conformant | |||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Conformant | |||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant | |||
| Gold | PAMP S.A. | SWITZERLAND | Conformant | |||
| Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant | |||
| Gold | PX Precinox S.A. | SWITZERLAND | Conformant | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant | |||
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | Not certified | |||
| Gold | Royal Canadian Mint | CANADA | Conformant | |||
| Gold | SAAMP | FRANCE | Conformant | |||
| Gold | Safimet S.p.A | ITALY | Conformant |
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| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Not certified | |||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant | |||
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant | |||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | T.C.A S.p.A | ITALY | Conformant | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant | |||
| Gold | Torecom | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Umicore Brasil Ltda. | BRAZIL | Conformant | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Conformant | |||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
10
| Gold | Valcambi S.A. | SWITZERLAND | Conformant | |||
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant | |||
| Gold | Yamakin Co., Ltd. | JAPAN | Conformant | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant | |||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant | |||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant |
11
| Tantalum | H.C. Starck Ltd. | JAPAN | Conformant | |||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant | |||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant | |||
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA | Conformant | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | KEMET Blue Metals | MEXICO | Conformant | |||
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Conformant | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant | |||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant | |||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant | |||
| Tantalum | NPM Silmet AS | ESTONIA | Conformant | |||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
12
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant | |||
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant | |||
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant | |||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant | |||
| Tin | Alpha | UNITED STATES OF AMERICA | Conformant | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant | |||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Conformant | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Not certified | |||
| Tin | CV Dua Sekawan | INDONESIA | Conformant | |||
| Tin | CV Gita Pesona | INDONESIA | Conformant | |||
| Tin | CV United Smelting | INDONESIA | Conformant | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Conformant | |||
| Tin | Dowa | JAPAN | Conformant | |||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant | |||
| Tin | Fenix Metals | POLAND | Conformant |
13
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant | |||
| Tin | Gejiu Jinye Mineral Company | CHINA | Conformant | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant | |||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant | |||
| Gold | Caridad | MEXICO | Not certified | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not certified | |||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Conformant | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant | |||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant | |||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant | |||
| Tin | Metallo Belgium N.V. | BELGIUM | Conformant | |||
| Tin | Metallo Spain S.L.U. | SPAIN | Conformant | |||
| Tin | Mineracao Taboca S.A. | BRAZIL | Conformant | |||
| Tin | Minsur | PERU | Conformant |
14
| Tin | Mitsubishi Materials Corporation | JAPAN | Conformant | |||
| Tin | Modeltech Sdn Bhd | MALAYSIA | Conformant | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant | |||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant | |||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Conformant | |||
| Tin | PT Bangka Prima Tin | INDONESIA | Conformant | |||
| Tin | PT Bangka Serumpun | INDONESIA | Conformant | |||
| Tin | PT Bangka Tin Industry | INDONESIA | Conformant | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Conformant | |||
| Tin | PT Bukit Timah | INDONESIA | Conformant | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Conformant | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not certified | |||
| Tin | PT Inti Stania Prima | INDONESIA | Conformant | |||
| Gold | Refinery of Seemine Gold Co., Ltd. | KOREA, REPUBLIC OF | Not certified | |||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Conformant |
15
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Conformant | |||
| Tin | PT Menara Cipta Mulia | INDONESIA | Conformant | |||
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant | |||
| Tin | PT Panca Mega Persada | INDONESIA | Conformant | |||
| Tin | PT Premium Tin Indonesia | INDONESIA | Conformant | |||
| Tin | PT Prima Timah Utama | INDONESIA | Conformant | |||
| Tin | CV Tiga Sekawan | INDONESIA | Conformant | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Conformant | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant | |||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant | |||
| Tin | PT Sukses Inti Makmur | INDONESIA | Conformant | |||
| Tin | PT Sumber Jaya Indah | INDONESIA | Conformant | |||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Conformant | |||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Conformant | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant | |||
| Tin | PT Tommy Utama | INDONESIA | Conformant | |||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant | |||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant | |||
| Tin | Soft Metais Ltda. | BRAZIL | Conformant |
16
| Tin | Thaisarco | THAILAND | Conformant | |||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant | |||
| Tin | Yunnan Tin Company Limited | CHINA | Conformant | |||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Conformant | |||
| Tungsten | ACL Metais Eireli | BRAZIL | Conformant | |||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant | |||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant |
17
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant | |||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Conformant | |||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Conformant | |||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant | |||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Conformant | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Conformant | |||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not certified |
18
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant | |||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Conformant | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not certified | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not certified | |||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | Not certified | |||
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | Not certified | |||
| Gold | Chugai Mining | JAPAN | Active | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CANADA | Not certified | |||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not certified | |||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | Not certified | |||
| Gold | Lingbao Gold Co., Ltd. | CHINA | Not certified | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not certified | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not certified | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Not certified | |||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Conformant |
19
| Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | Not certified | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not certified | |||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Not certified | |||
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | Not certified | |||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Not certified | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not certified | |||
| Gold | So Accurate Group, Inc. | UNITED STATES OF AMERICA | Not certified | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not certified | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not certified | |||
| Gold | Morris and Watson | NEW ZEALAND | Not certified | |||
| Gold | SAFINA A.S. | ITALY | Not certified | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | Not certified | |||
| Gold | Fidelity Printers and Refiners Ltd. | RUSSIAN FEDERATION | Not certified | |||
| Gold | International Precious Metal Refiners | CHINA | Not certified | |||
| Gold | Kaloti Precious Metals | JAPAN | Not certified | |||
| Gold | Sudan Gold Refinery | LITHUANIA | Not certified | |||
| Gold | Fujairah Gold FZC | RUSSIAN FEDERATION | Not certified | |||
| Gold | Tony Goetz NV | CHINA | Not certified | |||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Not certified |
20
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Not certified | |||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Not certified | |||
| Gold | Sai Refinery | INDIA | Not certified | |||
| Gold | Universal Precious Metals Refining Zambia | UNITED STATES OF AMERICA | Not certified | |||
| Gold | Modeltech Sdn Bhd | INDIA | Not certified | |||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Not certified | |||
| Gold | Morris and Watson Gold Coast | AUSTRALIA | Not certified | |||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not certified | |||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | Not certified | |||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Not certified | |||
| Gold | African Gold Refinery | UNITED STATES OF AMERICA | Not certified | |||
| Gold | QG Refining, LLC | SWITZERLAND | Not certified | |||
| Gold | Dijllah Gold Refinery FZC | GERMANY | Not certified | |||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Active | |||
| Gold | Remondis Argentia B.V. | NETHERLANDS | Conformant | |||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Conformant | |||
| Gold | L’Orfebre S.A. | ANDORRA | Conformant | |||
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | Conformant | |||
| Gold | Bangalore Refinery | INDIA | Active |
21
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Active | |||
| Gold | NH Recytech Company | UZBEKISTAN | Active | |||
| Gold | DS PRETECH Co., Ltd. | JAPAN | Conformant | |||
| Tantalum | Duoluoshan | CHINA | Not certified | |||
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Not certified | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Not certified | |||
| Tantalum | Plansee SE Liezen | AUSTRIA | Not certified | |||
| Tin | CV Ayi Jaya | INDONESIA | Not certified | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Not certified | |||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Not certified | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Not certified | |||
| Tin | PT Karimun Mining | INDONESIA | Not certified | |||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not certified | |||
| Tin | Estanho de Rondonia S.A. | BRAZIL | Not certified | |||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Not certified | |||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Not certified | |||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Not certified | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Not certified | |||
| Tin | Super Ligas | BRAZIL | Not certified |
22
| Tin | PT O.M. Indonesia | INDONESIA | Not certified | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Not certified | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | Not certified | |||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Not certified | |||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Not certified | |||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Not certified |
Annex II
List of Countries of Origin of Conflict Minerals*
Based on our due diligence, the above smelters and refiners may process Conflict Minerals from one or more of the following countries of origin:
| Conflict Mineral | Country of origin may include the following | |
Gold |
Andorra, Australia, Austria, Belgium, Brazil, Canada, Chile, China, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Korea (Republic of), Kyrgyzstan, Lithuania, Mexico, Netherlands, New Zealand, Philippines, Poland, Russian Federation, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan (Province of China), Thailand, Turkey, United Arab Emirates, United States of America, Uzbekistan | |
| Tantalum | Austria, Brazil, China, Estonia, Germany, India, Japan, Kazakhstan, Macedonia (the Former Yugoslav Republic of), Mexico, Russian Federation, Thailand, United States of America | |
| Tin | Belgium, Bolivia (Plurinational State of), Brazil, China, Indonesia, Japan, Malaysia, Peru, Philippines, Poland, Spain, Taiwan (Province of China), Thailand, United States of America, Vietnam | |
| Tungsten | Austria, Brazil, China, Germany, Japan, Korea (Republic of), Philippines, Russian Federation, United States of America, Vietnam |
As our suppliers, Smelters or Refiners (“SOR”) did not provide information on the location of mine in their CMRTs, and the Company was not able to establish from the sourcing information on their Conflict Minerals, it has indicated in the countries of origin list the closest indication provided as to the source of Conflict Minerals (i.e. the Smelter Country as reported in the suppliers’ CMRT).
23