UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
__________________________________________
ILLINOIS TOOL WORKS INC.
(Exact name of registrant as specified in its charter)
__________________________________________
| | | | | | | | |
| Delaware | | 1-4797 |
| (State or other jurisdiction of incorporation or organization) | | (Commission File Number) |
| | |
| 155 Harlem Avenue, Glenview, IL | | 60025 |
| (Address of principal executive offices) | | (Zip Code) |
Todd Pankey
Vice President, Strategic Sourcing and Environmental Health & Safety
847-724-7500
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:
| | | | | |
| [ X ] | Rule 13p-1 under the Securities Exchange Act (17CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
| [ ] | Rule 13q-1 under the Securities Exchange Act (17CFR 240.13q-1) for the fiscal year ended . |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
As provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report is provided as an Exhibit to this Form SD and is available on the Company’s website at www.itw.com/about-itw/suppliers. Information contained on the Company’s website is not part of, or incorporated by reference into, this Form SD or the Conflict Minerals Report.
Item 1.02 Exhibits
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable.
Section 3 - Exhibits
Item 3.01 Exhibits
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
Illinois Tool Works Inc.
By: /s/ Michael M. Larsen Dated: May 31, 2024
Michael M. Larsen
Senior Vice President and CFO
Exhibit 1.01
Conflict Minerals Report
I.Introduction
A.Our Business
Illinois Tool Works Inc. is a global manufacturer of a diversified range of industrial products and equipment with 84 divisions in 51 countries and has prepared this Conflict Minerals Report for calendar year 2023 as provided for in Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended, and Form SD (together referred to as the “Conflict Minerals Rule”). Unless the context indicates otherwise, the terms “Company,” “ITW,” “we,” “us” and “our” refer to Illinois Tool Works Inc. and its consolidated subsidiaries. “Conflict minerals” or “3TG” as used in this report, refers to cassiterite, columbite-tantalite, wolframite and their derivatives, tin, tantalum and tungsten, and/or gold, without regard to their location of origin.
The Company’s operations are reported as the following segments: Automotive OEM; Food Equipment; Test & Measurement and Electronics; Welding; Polymers & Fluids; Construction Products; and Specialty Products. Each of our segments manufactures certain products that contain 3TG that are necessary to the functionality or production of the products (which we sometimes refer to herein as “in-scope” products). ITW’s in-scope products collectively contain all four 3TGs.
B.Reasonable Country of Origin Inquiry and Due Diligence Overview
As provided for in the Conflict Minerals Rule, we conducted a “reasonable country of origin inquiry” (“RCOI”), designed in good faith to determine the origin of the 3TG that are contained in our in-scope products. See Section II. Reasonable Country of Origin Inquiry for a description of our RCOI process for 2023.
If the Company has reason to believe that any of the 3TG in our supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (with the DRC, the “Covered Countries”), or we are unable to determine the country of origin of the 3TG, we exercise due diligence on the source and chain of custody of the 3TG. We have included a description of our due diligence measures in this Conflict Minerals Report. On the basis of our RCOI, we have determined that some of the 3TG contained in our in-scope products may have originated from a Covered Country, and we are therefore submitting this Conflict Minerals Report, which describes the due diligence we have performed pursuant to the Conflict Minerals Rule and our related processes and procedures. This report is filed as an exhibit to our Form SD and is available on our website at http://www.itw.com/about-itw/suppliers/. Information contained on our website or otherwise actively linked to this Conflict Minerals Report is not part of or incorporated by reference into this Conflict Minerals Report or our Form SD.
C.ITW’s Position in the Supply Chain
ITW is a “downstream company” as defined by the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition) (the “OECD Guidance”). Most of our businesses are many levels removed from 3TG mining, smelting and processing facilities, and we have no relationships with mines. We source materials and components from suppliers who in turn source their materials and components from sub-tier suppliers and, therefore, we require the cooperation of our supply chain to provide information on smelters and refiners (collectively, “SORs”) as well as the origin of 3TG contained in our products. Due to our position in the supply chain, we utilize 3TG source
information provided by the Responsible Minerals Initiative (the “RMI”), which provides companies with tools and resources to make sourcing decisions that improve regulatory compliance and support responsible sourcing of minerals from conflict-affected and high-risk areas (“CAHRAs”). RMI also manages the Responsible Minerals Assurance Process (the “RMAP”), which implements a risk-based audit program for SORs. We are a member of the RMI (member identifier = ITWI) and actively participate in its initiatives, as discussed later in this Conflict Minerals Report.
D.Responsible Sourcing Commitment
Through the efforts described in this Conflict Minerals Report, we seek to ensure that our suppliers responsibly source 3TG. Our responsible sourcing goes beyond compliance with the Conflict Minerals Rule, however, and our Supplier Code of Conduct (which can be found at https://www.itw.com/suppliers/) mandates humane treatment and compliance with all laws, and in particular, prohibits use of child or forced labor and discrimination, and mandates compliance with safety regulations, wage and hour laws, international trade laws and anti-bribery laws.
E.Smelter and Refiner and Country of Origin Information
The Company’s in-scope products that contain 3TG that originated or might have originated from a Covered Country are described in Section IV. Product Information. For 2023, we have not found that any of the 3TG contained in our in-scope products directly or indirectly financed or benefited armed groups in a Covered Country. However, we have not concluded that any of our products are “DRC conflict free” within the meaning of the Conflict Minerals Rule. Information about SORs relating to our in-scope products containing 3TG is described in Section V. Identified Smelters and Refiners and on Annex A.
The terms “adjoining country,” “armed group,” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.
II.Reasonable Country of Origin Inquiry
Our RCOI utilized management systems recommended by the first step of the OECD Guidance, and was conducted in accordance with the second step of the OECD Guidance. Selected elements of our program design and RCOI process are discussed below. However, these are not all of the discrete elements of the program that we have put in place in accordance with the steps of the OECD Guidance to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the first and second steps.
A. Establish Strong Management Systems
1. ITW Policies
ITW has adopted a company-wide Responsible Materials Policy, which addresses 3TG, has been approved by ITW’s Chairman and Chief Executive Officer and is available in seven languages on our website at https://www.itw.com/suppliers/.
Our Responsible Materials Policy states that:
•We do not knowingly procure 3TG that originates from a CAHRA unless processed by SORs that are verified or in the process of becoming verified as “conflict free.”
•Our due diligence processes and efforts conform to the relevant portions of the OECD Guidance.
•Our due diligence requests to our suppliers are supported by our Supplier Code of Conduct, which is described further below, and our Terms and Conditions of Purchase found at https://www.itw.com/suppliers/.
•If we discover that products procured by us contain 3TG from CAHRAs that are processed by facilities that are not conflict free or in the process of becoming conflict free, we will take steps to transition the products to conflict free sources.
•We do not seek to embargo responsibly sourced 3TG from CAHRAs as doing so could be detrimental to the legitimate economies and communities of those areas, and our suppliers are encouraged to continue support of conflict free SORs in CAHRAs and to take similar measures with their supply chains.
•The information provided by our suppliers is used to conduct our due diligence and to inform our risk assessments and risk mitigation activities and in the development of our Conflict Minerals Report and Form SD.
ITW’s Supplier Code of Conduct sets forth expectations for all ITW suppliers to adhere to the highest ethical standards in the conduct of their business. It also requires suppliers to adhere to specific standards, including responsible sourcing of materials and an expectation of the same commitment from their suppliers, and specifically prohibits certain behaviors and conditions associated with 3TG mining and processing, including use of child or forced labor, unsafe working conditions, corruption and bribery. The Supplier Code of Conduct also requires that, upon request, our suppliers determine whether any products provided by them contain 3TG and to take such actions as necessary to provide the information requested by ITW to conduct its RCOI, as described below in Section II.B. (Identify and Assess Risk in the Supply Chain).
2. Cross-Functional Committee
ITW has a cross-functional responsible sourcing committee (the “Committee”). The Committee is headed by ITW’s Vice President, Strategic Sourcing and Environmental Health & Safety, who reports to ITW’s Chief Financial Officer, and includes dedicated strategic sourcing, environmental, legal, internal audit, IT, trade compliance and corporate communications members. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets regularly to discuss the 3TG compliance process, minerals beyond the 3TG compliance process, modern slavery, restricted party screening, supplier risk, supplier diversity and other responsible supply chain developments. Senior management is briefed on the results of our RCOI and due diligence efforts on a regular basis.
3. Internal Training
We maintain an internal responsible sourcing webpage, which contains resources, instructions, and guidance on the RCOI and due diligence processes to be followed by our businesses that have or may have in-scope products. The
site also contains step-by-step instructions for making supplier inquiries, including training videos regarding our RCOI and due diligence process, and is accessible by all ITW businesses at any time. We encourage our businesses to review the training videos prior to sending RCOI requests to suppliers.
4. Supplier Engagement and Training
In addition to our Responsible Materials Policy and Supplier Code of Conduct, ITW’s standard “Terms and Conditions” obligate our suppliers to take such actions as requested by ITW to enable us to comply with our conflict minerals disclosure requirements.
ITW has an established protocol for its supplier inquiry process and uses a third-party software vendor whose role is to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and in-scope suppliers through use of a cloud-based 3TG tracking tool (the “CM System”).
Our supplier invitation letters are translated into seven languages. We encourage our businesses’ use of RMI’s eLearning Academy for supplier training, post information and guidance for suppliers on our Company website and encourage our businesses to share relevant information with suppliers on the process for responding to our RCOI requests for information.
5. Records Retention
ITW retains its conflict minerals-related records for at least five years. These records generally are maintained in an electronic format.
6. Grievance Mechanism
ITW maintains a web- and telephone-based reporting system (“Helpline”), providing employees with a confidential reporting mechanism by which they can communicate issues and concerns associated with violations of ITW’s Code of Conduct, which requires all employees to comply with all applicable laws and Company policies, including the Responsible Materials Policy. Web-based reporting is offered in 16 languages and telephone-based reporting is offered in more than 200 languages, both available 24 hours a day, seven days a week. A link to the Helpline is included in our Responsible Materials Policy and our Supplier Code of Conduct on our website to provide convenient access to external stakeholders, suppliers and other third parties to communicate issues and concerns regarding ITW’s supply chain. The contact information for our Helpline is http://www.itwhelpline.ethicspoint.com.
As an RMI member, we also support the use of the RMI’s grievance mechanism for reporting grievances relating to SORs and the RMAP.
B. Identify and Assess Risk in the Supply Chain
Our RCOI process was used to survey our potential in-scope suppliers to identify and assess 3TG sourcing risk in our supply chain for the 2023 reporting cycle.
For 2023, our 3TG working team, together with various members of our sourcing department, compiled a list of the Company’s “80” suppliers by segment (i.e., the most significant suppliers) that have or are likely to have 3TG in their products, and distributed the list to our businesses with products containing or likely to contain 3TG. Those businesses were asked to further refine the list by identifying their own “80” suppliers and were instructed to survey those suppliers (we refer to the surveyed suppliers for 2023 as the “Suppliers”). We asked our businesses to
concentrate their outreach on their “80” suppliers because these suppliers are the most likely to be recurring suppliers and responsible for a significant portion of the 3TG in our products.
The purpose of the Supplier survey was to determine whether 3TG in the components, parts or products from the Suppliers originated or may have originated from a CAHRA and were not from recycled or scrap sources. Businesses were instructed to survey the Suppliers using the then latest version of the CMRT. The CMRT requests information regarding 3TG included in suppliers’ products, SOR identity and location, suppliers’ RCOI processes and other information about the suppliers’ 3TG policies and practices.
As mentioned above, ITW uses the CM System for its supplier inquiry process. We sent 1,785 requests in seven languages to the Suppliers to provide us with a completed CMRT, as compared to 1,686 requests sent for 2022. Several of our businesses source different products from the same Supplier, which means the total number of unique Suppliers is less than the number of Suppliers queried. We received 1,493 completed CMRTs from the Suppliers surveyed, compared to 1,273 received for 2022. From 2014 to 2023, our supplier response rate has improved steadily each year other than 2022, reaching approximately 84% in 2023 versus 76% in 2022 and 77% in 2021.
The CM System issued automatic weekly follow-up reminders to non-responding Suppliers, and our businesses were given instructions regarding follow-up actions beyond the automatic reminders and in response to receipt of incomplete or incorrect CMRTs.
Our protocol also includes a follow-up process to investigate any CMRTs received that raised “red flags.” See Section III. Due Diligence for a description of the follow-up process.
Our Supplier responses identified 234 SORs verified by the RMI as Conformant. We determined that 38 of these Conformant SORs sourced in whole or in part from within the Covered Countries. Our determination was based on country-of-origin information the RMI has obtained through the RMAP that is made available to RMI members.
Our Supplier responses also identified an additional 8 SORs that were listed as “Active” (as later defined in Section III.B. Due Diligence Activities) by the RMI and 176 that were listed on the Smelter Look-up tab of the CMRT but were not Conformant or Active.
Based on the results of our RCOI, we were required to conduct due diligence, as described below.
III.Due Diligence
A.Design Framework
ITW’s conflict minerals due diligence process is designed in conformance with the steps of the OECD Guidance.
B.Due Diligence Activities
Selected elements of our program design and implementation in furtherance of the third, fourth and fifth steps of the OECD Guidance are discussed below. However, these are not all of the discrete elements of the program that we have put in place pursuant to these steps to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the third, fourth and fifth steps. The actions taken by the Company to address the first and second steps of the OECD Guidance are described in Section II. Reasonable Country of Origin Inquiry.
Design and implement a strategy to respond to identified risks
The SOR information provided by Suppliers in response to the Company’s supplier survey described in Section II.B. was reviewed against the Smelter list in the CMRT. SOR information also was reviewed against the lists of Conformant, Active, and other SORs not listed as Conformant or Active and country-of-origin information provided by the RMI and contained in the CM System. “Conformant” SORs have been audited and are conformant with the RMAP assessment protocols, including those listed as “re-audit in progress.” “Active” SORs are those that have committed to undergo an RMAP assessment, completed the relevant documents and scheduled the on-site assessment. These may be in the pre-assessment, assessment or corrective-action phases of the assessment.
CMRTs received from our Suppliers that indicated 3TG from a source within a Covered Country triggered a “red flag” in the CM System, and communications with the flagged Suppliers were escalated. Businesses and their respective flagged Suppliers indicating 3TG from a source within a Covered Country were asked to provide additional information, and our businesses were given written guidance and instructions for these Supplier communications. The escalated Supplier responses were evaluated on a case-by-case basis. For our 2023 compliance, we continued to review past data to improve our written communications and to follow up with our businesses regarding supplier red flags.
In addition, we reached out directly to some of the SORs that were not listed as Conformant or Active by the RMI and asked them to become Conformant. Entities that the RMI has determined are either not SORs or not in operation were not addressed in our outreach efforts. We seek to exercise leverage over SORs that are neither Conformant nor Active through our participation in and support of the RMI and its Smelter Engagement Team, and we utilize information provided by the RMI to its members to help us monitor SOR improvement. Finally, we screen identified SORs with a restricted party screening software to alert us if the SORs are sanctioned or on various government watchlists. As a result of our ongoing due diligence activities for 2023, we have thus far identified a number of SORs that are neither Conformant nor Active or that otherwise fail to meet our supplier requirements and intend to take steps to remove these SORs from our supply chain.
Our 3TG working team reported the findings from its RCOI and due diligence process to our Vice President, Strategic Sourcing and Environmental Health & Safety, and these results were in turn discussed with senior management.
Smelter Engagement
•We continued our membership in the RMI and active participation in its Plenary, Due Diligence and Smelter Engagement Teams; and
•We continued our active participation in and leadership of the Responsible Materials Working Group of the Automotive Industry Action Group (“AIAG”), contributing Tier 1 perspective and insight.
Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
The Company continued its membership in the RMI for 2023. Due to our location in the mineral supply chain, which is discussed earlier in this Conflict Minerals Report, we support and utilize the RMI’s RMAP to perform third-party audits of SORs, as well as the London Bullion Market Association (“LBMA”) and Responsible Jewellery Council (“RJC”) gold audit standards, which RMI cross-recognizes. Additionally, we continued our voluntary contribution to RMI’s Initial Audit Fund, managed by RMI, meant to encourage RMAP-eligible SORs to undergo an
independent third-party assessment and participate in its annual review process by fully paying for the costs of the SOR initial audit.
Report annually on supply chain due diligence
We describe our supply chain due diligence efforts in this annual Conflict Minerals Report. We post this report on our website and file it with the SEC as an exhibit to our annual Form SD. Once filed, the Form SD and Conflict Minerals Report become available on our website at https://www.itw.com/suppliers. We also refer to our efforts relating to 3TG and further efforts to source our minerals responsibly in our 2023 Sustainability Report, which is available on our website at https://www.itw.com/sustainability/itw-sustainability/.
IV.Product Information
For 2023, our in-scope products that contain 3TG that originated or might have originated from a Covered Country included products in each of the categories below:
| | | | | |
| Aerosol | Industrial warewashers |
| Air delivery equipment | LED lamps and displays |
| Appliance components | Measuring equipment |
| Automotive components | Printers & dispensers |
| Commercial dishwashers | Refrigerator components |
| Commercial food equipment | Refrigerators |
| Commercial refrigerators | Sawing machines |
| Electrical enclosures | Scales |
| Electronic components | Sealing equipment |
| Electronic equipment | Solder products |
| Fasteners | Static neutralizing equipment |
| Flow control meters | Switches |
| Industrial cleaners | Testing equipment |
| Industrial ovens | Welding hardware |
| Industrial stencil printers | Welding machines |
V. Identified Smelters and Refiners
As stated above, our Supplier responses identified 234 SORs that were on the RMI Conformant lists, 8 that were listed as Active with the RMI and 176 that were on the Smelter list of the CMRT but not listed as Conformant or Active by the RMI. Those facilities are listed on Annex A. The information on Annex A includes only information regarding the SORs identified by our Suppliers that were on the Smelter list contained in the CM System as of April 12, 2024. Entities identified by our Suppliers that are not on Annex A have been submitted to the RMI to support their ongoing effort to identify and audit all 3TG SORs.
Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our Suppliers for accurate SOR information, and our RCOI and due diligence measures cannot provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products. The
information that we received from most of our Suppliers was made at a “company” or “user defined” level, rather than at a “product” level, meaning that such Suppliers provided information on all of their products that contained 3TG, not just the products that were sold to us. Therefore, our list of SORs disclosed on Annex A may be “over-inclusive” in that it may contain facilities that did not process the 3TG contained in our products. In addition, the identified SORs may not include all SORs present in our in-scope product supply chain, because we did not obtain a response from all Suppliers surveyed, some Suppliers were unable to identify all of the SORs in their supply chain, and we surveyed only the larger suppliers of products containing or potentially containing 3TG.
Annex A includes information concerning the locations of the SORs listed. We utilized the information made available to RMI members regarding the potential countries of origin of the 3TG processed by these SORs and did not find for 2023 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country. However, we did not conclude that any of our products are “DRC conflict free” within the meaning of the Conflict Minerals Rule.
VI.Additional Risk Mitigation
In addition to the actions described elsewhere in this Conflict Minerals Report, we intend to take the following steps in 2024 to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:
•Continue to analyze and review our current processes to improve their effectiveness and efficiency;
•Continue to enhance supplier and internal communications and training to improve RCOI and due diligence data accuracy and completeness;
•Continue to seek to influence non-Conformant SORs in our supply chain to obtain a Conformant designation;
•Continue our membership in the RMI and active participation in its Plenary, Due Diligence and Smelter Engagement Teams and support the RMAP;
•Continue our membership and active participation in the AIAG Responsible Materials Working Group and its subteams;
•Continue to submit to the RMI facilities identified by our suppliers that have not yet been identified by the RMI as SORs, to support the RMI’s ongoing effort to identify and audit all 3TG SORs;
•Continue to send tailored communications to SORs believed to be in our supply chain who are either scheduled to undergo RMI re-audit or are not fulfilling RMI audit requirements, encouraging them to go through the re-audit process or to continue fulfilling their audit requirements; and
•Continuous evaluation of supplier CMRT response failures to assist our businesses in the collection of their supplier assessments.
VII.Forward-Looking Statements
This report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements include expectations concerning the Company’s future actions to improve or revise our due diligence processes, to engage with our suppliers, and to take other actions regarding our product
sourcing. These statements are subject to certain risks, uncertainties and other factors, including, but not limited to, incomplete information from industry or other third-party sources, continuing guidance regarding the Conflict Minerals Rule and the enactment of laws and rules in other jurisdictions, changes to our continual improvement efforts and delays or difficulties in engaging suppliers and/or transitioning sources of product containing 3TG.
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| Annex A to Exhibit 1.01 |
| RMI Smelters and Refiners |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Conformant |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant |
| Gold | Agosi AG | GERMANY | Conformant |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | 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 | Aurubis AG | GERMANY | Conformant |
| Gold | Bangalore Refinery | INDIA | Conformant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
| Gold | Boliden Ronnskar | SWEDEN | Conformant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
| Gold | Chimet S.p.A. | ITALY | Conformant |
| Gold | Chugai Mining | JAPAN | Conformant |
| Gold | Coimpa Industrial LTDA | BRAZIL | Conformant |
| Gold | Dowa | JAPAN | Conformant |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | Conformant |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | Conformant |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | Conformant |
| Gold | Gold by Gold Colombia | COLOMBIA | Conformant |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | 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 |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
| Gold | Kazzinc | KAZAKHSTAN | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Conformant |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
| Gold | L'Orfebre S.A. | ANDORRA | Conformant |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF | Conformant |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Materion | UNITED STATES OF AMERICA | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | 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 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Gold | MKS PAMP SA | SWITZERLAND | Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | 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 | Planta Recuperadora de Metales SpA | CHILE | 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 | REMONDIS PMR B.V. | NETHERLANDS | Conformant |
| Gold | Royal Canadian Mint | CANADA | Conformant |
| Gold | SAFINA A.S. | CZECHIA | Conformant |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | Conformant |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | 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 | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant |
| Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | Valcambi S.A. | SWITZERLAND | Conformant |
| Gold | WEEEREFINING | FRANCE | 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 |
| Gold | 8853 S.p.A. | ITALY | On Smelter Look-up List |
| Gold | ABC Refinery Pty Ltd. | AUSTRALIA | On Smelter Look-up List |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | Albino Mountinho Lda. | PORTUGAL | On Smelter Look-up List |
| Gold | Alexy Metals | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | On Smelter Look-up List |
| Gold | AU Traders and Refiners | SOUTH AFRICA | On Smelter Look-up List |
| Gold | Augmont Enterprises Private Limited | INDIA | On Smelter Look-up List |
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | On Smelter Look-up List |
| Gold | Caridad | MEXICO | On Smelter Look-up List |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | On Smelter Look-up List |
| Gold | CGR Metalloys Pvt Ltd. | INDIA | On Smelter Look-up List |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | On Smelter Look-up List |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | On Smelter Look-up List |
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | On Smelter Look-up List |
| Gold | Dongwu Gold Group | CHINA | On Smelter Look-up List |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | On Smelter Look-up List |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | On Smelter Look-up List |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | On Smelter Look-up List |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | On Smelter Look-up List |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | On Smelter Look-up List |
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | On Smelter Look-up List |
| Gold | Gold Coast Refinery | GHANA | On Smelter Look-up List |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | On Smelter Look-up List |
| Gold | Guangdong Jinding Gold Limited | CHINA | On Smelter Look-up List |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | On Smelter Look-up List |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Gold | Industrial Refining Company | BELGIUM | On Smelter Look-up List |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | JALAN & Company | INDIA | On Smelter Look-up List |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | K.A. Rasmussen | NORWAY | On Smelter Look-up List |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | On Smelter Look-up List |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Gold | Kundan Care Products Ltd. | INDIA | On Smelter Look-up List |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | On Smelter Look-up List |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | On Smelter Look-up List |
| Gold | Lingbao Gold Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Marsam Metals | BRAZIL | On Smelter Look-up List |
| Gold | MD Overseas | INDIA | On Smelter Look-up List |
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Modeltech Sdn Bhd | MALAYSIA | On Smelter Look-up List |
| Gold | Morris and Watson | NEW ZEALAND | On Smelter Look-up List |
| Gold | Morris and Watson Gold Coast | AUSTRALIA | On Smelter Look-up List |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | Pease & Curren | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | SAAMP | FRANCE | On Smelter Look-up List |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Safimet S.p.A | ITALY | On Smelter Look-up List |
| Gold | Sai Refinery | INDIA | On Smelter Look-up List |
| Gold | Sam Precious Metals | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | On Smelter Look-up List |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | On Smelter Look-up List |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | On Smelter Look-up List |
| Gold | Sellem Industries Ltd. | MAURITANIA | On Smelter Look-up List |
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Shirpur Gold Refinery Ltd. | INDIA | On Smelter Look-up List |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | On Smelter Look-up List |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | Sovereign Metals | INDIA | On Smelter Look-up List |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | On Smelter Look-up List |
| Gold | Sudan Gold Refinery | SUDAN | On Smelter Look-up List |
| Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | On Smelter Look-up List |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | TSK Pretech | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Gold | Umicore Brasil Ltda. | BRAZIL | On Smelter Look-up List |
| Gold | Umicore Precious Metals Thailand | THAILAND | On Smelter Look-up List |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | On Smelter Look-up List |
| Gold | Value Trading | BELGIUM | On Smelter Look-up List |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | On Smelter Look-up List |
| Tantalum | AMG Brasil | BRAZIL | Conformant |
| Tantalum | Avon Specialty Metals Ltd. | UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND | Conformant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | CMT Rare Metal Advanced Materials (Hunan) Co., Ltd. | CHINA | Conformant |
| Tantalum | D Block Metals, LLC | 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 | 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 Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| 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 | Plansee SE Reutte | AUSTRIA | Conformant |
| Tantalum | PowerX Ltd. | RWANDA | Conformant |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tantalum | RFH Recycling Metals Co., Ltd. | CHINA | Conformant |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | Conformant |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | Conformant |
| Tantalum | TANIOBIS GmbH | GERMANY | Conformant |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | Conformant |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
| Tantalum | V&D New Materials (Jiangsu) Co., Ltd. | CHINA | Conformant |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | Conformant |
| Tantalum | XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD. | CHINA | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | Conformant |
| Tantalum | 5D Production OU | ESTONIA | On Smelter Look-up List |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | On Smelter Look-up List |
| Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | On Smelter Look-up List |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Tantalum | KEMET de Mexico | MEXICO | On Smelter Look-up List |
| Tantalum | Meta Materials | NORTH MACEDONIA, REPUBLIC OF | On Smelter Look-up List |
| Tantalum | QSIL Metals Hermsdorf GmbH | GERMANY | On Smelter Look-up List |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tantalum | Taike Technology (Suzhou) Co.,Ltd. | CHINA | On Smelter Look-up List |
| Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
| Tin | Aurubis Beerse | BELGIUM | Conformant |
| Tin | Aurubis Berango | SPAIN | 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 |
| | | |
| | | | | | | | | | | |
| | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | Conformant |
| Tin | CRM Synergies | SPAIN | Conformant |
| Tin | CV Ayi Jaya | INDONESIA | Conformant |
| Tin | Dowa | JAPAN | Conformant |
| Tin | DS Myanmar | MYANMAR | Conformant |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | Estanho de Rondonia S.A. | BRAZIL | Conformant |
| Tin | Feinhutte Halsbrucke GmbH | GERMANY | Conformant |
| Tin | Fenix Metals | POLAND | Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
| Tin | Luna Smelter, Ltd. | RWANDA | Conformant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA | Conformant |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
| Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE | Conformant |
| Tin | Minsur | PERU | Conformant |
| Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | Precious Minerals and Smelting Limited | INDIA | 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 Babel Surya Alam Lestari | INDONESIA | Conformant |
| Tin | PT Bangka Prima Tin | INDONESIA | Conformant |
| Tin | PT Bangka Serumpun | INDONESIA | Conformant |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Conformant |
| Tin | PT Bukit Timah | INDONESIA | Conformant |
| Tin | PT Cipta Persada Mulia | INDONESIA | Conformant |
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | Conformant |
| Tin | PT Panca Mega Persada | INDONESIA | Conformant |
| Tin | PT Premium Tin Indonesia | INDONESIA | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| Tin | PT Prima Timah Utama | INDONESIA | Conformant |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | Conformant |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | Conformant |
| Tin | PT Rajehan Ariq | 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 (SIM) | INDONESIA | Conformant |
| Tin | PT Timah Nusantara | INDONESIA | Conformant |
| Tin | PT Timah Tbk Kundur | INDONESIA | Conformant |
| Tin | PT Timah 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 | Rian Resources SDN. BHD. | MALAYSIA | Conformant |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tin | Soft Metais Ltda. | BRAZIL | Conformant |
| Tin | Super Ligas | BRAZIL | Conformant |
| Tin | Thaisarco | THAILAND | Conformant |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | Conformant |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | On Smelter Look-up List |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | CV Dua Sekawan | INDONESIA | On Smelter Look-up List |
| Tin | CV Gita Pesona | INDONESIA | On Smelter Look-up List |
| Tin | CV United Smelting | INDONESIA | On Smelter Look-up List |
| Tin | CV Venus Inti Perkasa | INDONESIA | On Smelter Look-up List |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Dragon Silver Holdings Limited | CHINA | On Smelter Look-up List |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | On Smelter Look-up List |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | On Smelter Look-up List |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | On Smelter Look-up List |
| Tin | Gejiu Jinye Mineral Company | CHINA | On Smelter Look-up List |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | On Smelter Look-up List |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | On Smelter Look-up List |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | On Smelter Look-up List |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | On Smelter Look-up List |
| Tin | Modeltech Sdn Bhd | MALAYSIA | On Smelter Look-up List |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | On Smelter Look-up List |
| Tin | Novosibirsk Tin Combine | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tin | Pongpipat Company Limited | MYANMAR | On Smelter Look-up List |
| Tin | PT Bangka Tin Industry | INDONESIA | On Smelter Look-up List |
| Tin | PT DS Jaya Abadi | INDONESIA | On Smelter Look-up List |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | On Smelter Look-up List |
| Tin | PT Inti Stania Prima | INDONESIA | On Smelter Look-up List |
| Tin | PT Karimun Mining | INDONESIA | On Smelter Look-up List |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | On Smelter Look-up List |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | On Smelter Look-up List |
| Tin | PT Masbro Alam Stania | INDONESIA | On Smelter Look-up List |
| Tin | PT Menara Cipta Mulia | INDONESIA | On Smelter Look-up List |
| Tin | PT Sumber Jaya Indah | INDONESIA | On Smelter Look-up List |
| Tin | PT Tirus Putra Mandiri | INDONESIA | On Smelter Look-up List |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | On Smelter Look-up List |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | On Smelter Look-up List |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | On Smelter Look-up List |
| Tungsten | A.L.M.T. Corp. | JAPAN | Conformant |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
| Tungsten | Avon Specialty Metals Ltd | UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND | Conformant |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | Conformant |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | KOREA, REPUBLIC OF | Conformant |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Sunny Non-Ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | 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 |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| 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 | Kenee Mining Corporation Vietnam | VIET NAM | Conformant |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tungsten | Lianyou Resources Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Masan High-Tech Materials | VIET NAM | Conformant |
| Tungsten | Nam Viet Cromit Joint Stock Company | VIET NAM | Conformant |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
| Tungsten | Plansee Composite Materials GmbH | GERMANY | Conformant |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CHINA | Conformant |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM | Conformant |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | ACL Metais Eireli | BRAZIL | On Smelter Look-up List |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | On Smelter Look-up List |
| Tungsten | Artek LLC | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | CP Metals Inc. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | On Smelter Look-up List |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Tungsten | LLC Vostok | RUSSIAN FEDERATION | On Smelter Look-up List |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | On Smelter Look-up List |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | On Smelter Look-up List |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | On Smelter Look-up List |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CHINA | On Smelter Look-up List |
Country of Origin Information
The countries of origin of the newly-mined 3TG processed by the Conformant SORs listed above may have included the countries listed below, as well as possibly other countries. We did not determine the possible countries of origin of the 3TG processed by any other SORs listed on this Annex A. The listed countries of origin are derived from information made available by the RMI to its members, which includes LBMA Good Delivery List and RJC Chain of Custody Certification information. Because the RMI generally does not indicate individual countries of origin of the 3TG processed by Conformant SORs, we were not able to determine the countries of origin of the newly-mined 3TG processed by the listed Conformant SORs with greater specificity. According to information made available by the RMI to its members, some of the listed SORs processed 3TG originating solely from recycled or scrap sources and others processed both recycled and scrap content and newly-mined content from one or more of the countries indicated below.
| | | | | | | | | | | |
| Argentina | Ethiopia | Mali | Saudi Arabia |
| Australia | Fiji | Mauritania | Senegal |
| Austria | Finland | Mexico | Serbia |
| Azerbaijan | France | Mongolia | Sierra Leone |
| Benin | Georgia | Morocco | South Africa |
| Bolivia | Ghana | Mozambique | Spain |
| Botswana | Guatemala | Myanmar | Sudan |
| Brazil | Guinea | Namibia | Suriname |
| Burkina Faso | Guyana | New Zealand | Sweden |
| Burundi* | Honduras | Nicaragua | Tanzania* |
| Cambodia | Indonesia | Niger | Thailand |
| Canada | Japan | Nigeria | Turkey |
| Chile | Kazakhstan | Oman | Uganda* |
| China | Kenya | Panama | United Kingdom |
| Colombia | Korea, Republic of | Papua New Guinea | United States of America |
| Côte d'Ivoire | Kyrgyzstan | Peru | Uzbekistan |
| Democratic Republic of the Congo* | Laos | Philippines | Vietnam |
| Dominican Republic | Liberia | Portugal | Zambia* |
| Ecuador | Madagascar | Russia | Zimbabwe |
| Egypt | Malaysia | Rwanda* | |
* Covered Country.
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