UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
CONMED CORPORATION
(Exact name of registrant as specified in its charter)
| New York | 0-16093 | 16-0977505 |
| (State or other jurisdiction of | (Commission | (I.R.S. Employer |
| incorporation or organization) | File Number) | Identification No.) |
525 French Road
Utica, New York 13502
(Address of principal executive offices, including zip code)
Luke A. Pomilio (315) 797-8375
(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, 2014.
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Specialized Disclosure Report on Form SD of CONMED Corporation is for the period from January 1, 2014 to December 31, 2014. Unless the context indicates otherwise, “CONMED,” “we,” “us,” and “our” refer to CONMED Corporation and its consolidated subsidiaries.
During 2014, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs (as defined below) are necessary to their functionality or production (“Covered Products”). The term “3TGs” refers to columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten. Accordingly, we have conducted a country of origin inquiry (“RCOI”) that was reasonably designed to determine whether any of the 3TGs in the Covered Products originated in the Democratic Republic of the Congo or an adjoining country (the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia or Angola); or were from recycled or scrap sources.
Information about our RCOI, as well as the steps we have taken to exercise due diligence on the source and chain of custody of any 3TGs in the Covered Products, is included in our Conflict Minerals Report, which is included as an exhibit to this Form SD. The Specialized Disclosure Form (“Form SD”) and the associated Conflict Minerals Report is available in our Investor Relations section of the CONMED Corporation website (http://www.conmed.com).
Item 1.02 Exhibit
A copy of CONMED’s Conflict Minerals Report required is filed as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit 1.01 - Conflict Minerals Report as required by Item 1.01 and 1.02 of this Form SD.
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.
May 27, 2015
| By: | /s/ Luke A. Pomilio | ||
| Name: | Luke A. Pomilio | ||
| Title: | Executive Vice President – Finance and Chief Financial Officer |
Exhibit Index
| Exhibit No. | Description of Exhibit | Page Number |
| Exhibit 1.01 | Conflict Minerals Report as required by Item 1.01 and 1.02 of this Form. | E-1 |
Exhibit 1.01
CONMED Corporation
Conflict Minerals Report
For The Year Ended December 31, 2014
We have made statements in this Conflict Minerals Report that may constitute forward-looking statements about our plans to take additional actions or to implement additional procedures with respect to our due diligence efforts to determine the origin of conflict minerals included in our products. There can be no assurance that these future events will occur as anticipated. Forward-looking statements speak only as of the date they were made, and we undertake no obligation to publicly update them. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report.
1. Introduction
CONMED Corporation (“CONMED”, the “Company”, “we”, “our” or “us”) is filing this Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the year ended December 31, 2014.
This Conflict Minerals Report describes our reasonable country of origin inquiry (“RCOI”), the results thereof, and the design of our due diligence measures to determine whether 3TGs in products that CONMED manufactures or contracts to manufacture originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”). The Covered Countries include Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. The term “Conflict Minerals” is defined as: columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten. For purposes of this CMR, tin, tungsten, tantalum and gold will collectively be referred to as the 3TGs. This report also provides an account of how these due diligence measures were implemented in 2014.
This report is available on our website in our Investor Relations section at www.conmed.com.
2. Company Overview
CONMED is a medical technology company that provides surgical devices and equipment for minimally invasive procedures. The Company’s products are used by surgeons and physicians in a variety of specialties including orthopedics, general surgery, gynecology, neurosurgery, and gastroenterology.
Products
Our product lines consist of orthopedic surgery, general surgery and surgical visualization. Orthopedic surgery consists of sports medicine instrumentation and small bone, large bone and specialty powered surgical instruments and service fees related to the promotion and marketing of sports medicine allograft tissue. General surgery consists of a complete line of endomechanical instrumentation for minimally invasive laparoscopic and gastrointestinal procedures, a line of cardiac monitoring products as well as electrosurgical generators and related instruments. Surgical visualization consists of imaging systems for use in minimally invasive orthopedic and general surgery procedures including vision technologies. 3TGs are in a significant portion of CONMED products due to electronics being a vital component to many of our product offerings.
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Supply chain due diligence
We obtain various component products from suppliers that we use in manufacturing our products. Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, among other reasons, it is difficult for us to identify actors upstream from our direct suppliers. As part of our supply chain procedures, we require in our supply contracts that our direct suppliers provide information on the origin of the 3TGs contained in components and materials supplied to us – including sources of 3TGs that are supplied to them from all applicable lower tier suppliers. Contracts with our direct suppliers are frequently multi-year term contracts. In those cases, although we generally are unable to unilaterally impose new contract terms and flow-down requirements prior to expiration of the contract, we work individually with key selected suppliers to insure they provide 3TG sourcing information for all current contracts, and in all new contracts in the future. We have approached existing suppliers to adopt amendments regarding 3TGs, and as we renew contracts or enter into new ones, we will add a clause that requires all applicable suppliers to provide information about the source of 3TGs and information about the smelters from which 3TGs are sourced. In light of existing contract term durations, it will take some time to ensure that all supplier contracts contain what we believe are appropriate “flow-down” clauses. In the meantime and in parallel, all purchase orders for direct materials used in the composition of our products require that suppliers provide CONMED with Conflict Minerals information on the current Conflict Minerals Reporting Template, or CMRT (as described further below), and that components must be free of Conflict Minerals.
Conflict Minerals Policy
In addition to the measures described above, we have adopted a conflict minerals supply policy. This policy is available on our website at www.conmed.com in the Investor Relations section.
3. Reasonable Country of Origin Inquiry
Because conflict minerals are necessary to the functionality or production of products that we manufacture, we are required to conduct in good faith a reasonable country of origin inquiry regarding those conflict minerals. The RCOI is reasonably designed to determine whether any of the conflict minerals originated in the DRC, or the Covered Countries, or are from recycled or scrap sources.
Our RCOI employed a combination of measures to determine whether the 3TGs necessary for the functionality or production of CONMED products originated from the DRC or any of the Covered Countries. The company’s primary means of determining country of origin of the necessary 3TGs was by conducting a supply chain survey with direct suppliers using the Electronic Industry Citizenship Coalition® (“EICC”®) and the Global e-Sustainability Initiative (“GeSI”) Conflict Minerals Reporting Template (“CMRT”). This supply chain survey was implemented with the assistance of a third-party service provider, which is also assisting us with the development and implementation of additional steps that we are undertaking with suppliers in regards to conflict minerals.
As an initial step, we identified all suppliers that provided items to CONMED that were used in final products in 2014. This list included many suppliers that did not provide any 3TGs. After excluding suppliers that did not provide any 3TGs to CONMED, we had a list of 590 suppliers. Any suppliers that appeared on this initial list could be placed out of scope during the supplier survey process. For example, if they were included on the initial list in error and they did not in fact provide components or 3TG components used in our products or, as the CMRT allows, because any 3TGs in those components are unnecessary to the functionality or production of the supplier’s products.
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The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide 3TG materials to a company’s supply chain. It includes questions regarding a supplier’s “conflict-free” policy, engagement with its direct suppliers, and a listing of the smelters used in products provided to CONMED. In addition, the template contains questions about the origin of 3TGs included in the supplier’s products, as well as supplier due diligence. To ensure our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party consultant have provided training to our suppliers through webinars, videos and substantial one-on-one discussions.
A notable addition to our program this year is automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. As of May 11th, 2015, we still had 98 invalid supplier submissions that were not yet corrected.
Over 90% of the CONMED suppliers that we initially contacted provided a response. Non-responsive suppliers were contacted numerous times by both our third party consultant and CONMED personnel. Of the 533 suppliers that provided a response, approximately 33% reported that their products contained 3TGs necessary to the functionality or production of their products. Twenty-four suppliers have indicated to us that the 3TGs used in their products originate from the DRC; however, it was unknown whether they finance conflict.
On the basis of the responses to our RCOI, CONMED is unable to determine that 3TGs necessary to the functionality or production of our products did not originate in the DRC or any of the Covered Countries. Accordingly, CONMED engaged in the due diligence measures on the source and chain of custody of those 3TGs, as described in the next section of this Conflict Minerals Report.
4.0 Design of Due Diligence Measures
Our due diligence measures have been designed to conform, in all material respects, with the framework established in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold, tin, tantalum and tungsten.
4.1 Management Systems
As described above, CONMED has adopted a conflict minerals policy, which is located in the Investor Relations section of the CONMED Corporation website (http://www.conmed.com).
Internal Team
CONMED has established a management system regarding the sourcing of 3TGs. Our management system includes both internal and external resources led by a project manager and subject matter experts at each of our manufacturing locations. This group is responsible for implementing our conflict minerals compliance strategy. Senior management is briefed about the results of our due diligence efforts on a regular basis. We also use a third-party service provider to assist us with evaluating supply chain information regarding 3TGs and in the development and implementation of additional due diligence steps that we will undertake with suppliers in regard to conflict minerals.
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Control systems
As we do not typically have a direct relationship with 3TG smelters and refiners, and due to our position in the supply chain and limited insight into deeper levels of the supply chain, we are engaged and actively cooperate with other major manufacturers in the medical device industry regarding 3TG sourcing matters.
With regards to our suppliers, controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all CONMED employees; our supplier approval and review process as further described below; contractual protections, which are further described above in our Supply Chain section under Company Overview; and business relationships with our suppliers.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we use a Supplier Approval Process that evaluates our suppliers based on their quality systems and their readiness to provide CONMED all of the required services and support documents. In addition, key suppliers are evaluated on the “Supplier Report Card” as to their performance in all aspects of the supply contract. This review includes, but is not limited to: product quality, supplier performance and ensuring conflict mineral compliance.
Grievance Mechanism
Various communication channels exist to serve as grievance mechanisms for early-warning risk awareness. We have multiple longstanding grievance mechanisms whereby employees (internal) and suppliers (external) can report violations of CONMED’s policies. This includes, but is not limited to our whistleblower hotline that is part of our Code of Business Conduct and Ethics policy located in the Investor Relations section of the CONMED Corporation website (http://www.conmed.com).
Maintain records
We have adopted a policy to retain relevant documentation, including the records of our due diligence process for a minimum period of five years.
4.2 Risk Identification, Assessment and Response
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as DRC-Conflict Free by third party sources such as the Conflict-Free Sourcing Initiative (“CFSI”) or the London Bullion Market Association (“LBMA”) Responsible Gold Programme, pose a significant risk. Where a smelter is not identified as Conflict Free by such sources, we rate the risk as High, Medium or Low. This rating is based on various factors, including whether the smelter/refiner has been identified as a valid smelter/refiner and has an associated Smelter Identification Number (under the CFSI, this is known as a CID), and the smelter’s geographic location, including proximity to the Covered Countries.
We calculate supplier risk based on the chances that a supplier provides 3TGs that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that Supplier on their CMRT.
| E-4 |
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:
| · | Do you have a policy in place that includes DRC conflict-free sourcing? |
| · | Have you implemented due diligence measures for conflict-free sourcing? |
| · | Do you verify due diligence information received from your suppliers? |
| · | Does your verification process include corrective action management? |
When suppliers answer yes, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
As part of our risk management plan and to ensure suppliers understand our expectations, we have, through a third party, provided video and written training on conflict minerals and the CMRT. This includes instructions on completing the form, and one-on-one email and phone discussions with supplier personnel.
As described in our Conflict Minerals Policy, we engage any of our suppliers whom we have reason to believe are supplying us with 3TGs from sources that may support conflict in the DRC or any of the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we will then take steps to terminate a contract and find replacement suppliers.
Additionally, in designing and implementing our strategy to respond to the supply chain risks that we identified, CONMED analyzed various industry approaches and consulted with other companies in our industry.
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TGs in our supply chain. This was done by adopting methodology outlined by the CFSI’s joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this industry joint effort, we made reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict Free” lists of sourced metals.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products. This includes: (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding CFSI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
4.3 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
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We support independent third-party audits through our participation in the Conflict Free Smelter Initiative (“CFSI”). We do not typically have a direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain.
4.4 Report annually on supply chain due diligence
Since 2014, CONMED reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC.
5. Due Diligence Results
As described above, as part of our supply chain due diligence process, we identified suppliers likely to utilize 3TGs in the products that they provide to us. We utilized the CMRT to facilitate disclosure and communication of information regarding smelters that provide 3TGs used in products supplied to us by those suppliers for incorporation into our products.
The quality of the responses that we received from our surveyed suppliers were varied. Certain of the responses provided by suppliers to the CMRT included the names of facilities listed by the suppliers as smelters or refiners. Many suppliers, however, were unable to provide the smelters or refiners used for materials supplied to us.
For all responses that indicated a smelter, our third party consultant compared the facilities listed to the list of smelters maintained by the Conflict-Free Sourcing Initiative (“CFSI”), the United States Department of Commerce (“DoC”) and the London Bullion Market Association (“LBMA”). If a supplier indicated that the facility was certified as “Conflict-Free,” our third party consultant confirmed that the name was listed by CFSI. In addition, the same list of smelters, received from our supplier inquiry, was checked against the lists maintained by the DoC and the LBMA to ensure compliance. No violations were identified. As of May 11, 2015, we have validated 287 smelters or refiners and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Attachment A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Attachment A any smelters or refiners that we have not been able to validate. Attachment A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and CFSI. CONMED supports the refinement and expansion of the list of participating smelters through our membership in the CFSI program.
Based on the smelter lists provided by suppliers via the CMRTs and publically available information, we have identified 18 smelters sourcing from the Covered Countries that are certified conflict-free and 132 other smelters of which the source is not disclosed but are certified conflict free smelters.
The large majority of the responses received either provided data at a company or subsidiary level and chose not to provide information at the component level, or did not specify the smelters or refiners used for components supplied to CONMED. Accordingly, we are unable to determine, in those cases, whether any of the 3TGs reported by the suppliers were contained in components or parts supplied to us, or to validate that any of the smelters or refiners identified are actually in our supply chain.
6. Steps to Improve Future Due Diligence and Supply Chain Risk Mitigation
We intend to take the following steps to improve our due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the DRC or Covered Countries:
| E-6 |
| a. | Include a conflict minerals flow-down clause in all new or renewed supplier contracts. |
| b. | Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
| · | All suppliers that were non-responsive will be further contacted to encourage reply. |
| · | All suppliers that did not know the origin of the 3TGs in products will be further encouraged to examine their supply chain and enact due diligence measures as per the OECD Due Diligence Guidelines. |
| c. | Engage any of our suppliers found to be supplying us with 3TGs from sources that support conflict in the DRC or any of the Covered Countries to establish an alternative source of 3TGs that do not support such conflict. |
| d. | Continue our participation in the CFSI. |
| e. | Monitor industry best practices, and continue to work with a third-party service provider to enhance our due diligence and supply chain management process, as appropriate. This includes requesting Conflict Free sourcing by our suppliers as further described in our Conflicts Mineral Policy and in the contractual provisions described above in our Supply Chain section under Company Overview. |
| f. | Consider replacing suppliers that remain non-responsive, or that are unable to enact due diligence measures as per the OECD Due Diligence Guidelines. |
| g. | Working with suppliers to move to the latest CMRT where new smelter IDs are constantly being added. |
| h. | Requiring the use of smelter identification numbers. Supplier responses will not be considered complete without identification numbers. |
| i. | Suppliers will also be requested to inform CONMED of the correlation between these smelters and the products and parts they supply to CONMED. |
7. Independent Audit
In accordance with the requirements of Rule 13p-1 and applicable guidance from the SEC staff, we are not required to obtain an independent private sector audit of this Conflict Minerals Report for the year ended December 31, 2014.
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Attachment A
| Metal | Smelter Name or Refinery | Country |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM |
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | BRAZIL |
| Gold | Umicore Brasil Ltda | BRAZIL |
| Gold | House of Currency of Brazil (Casa da Moeda do Brazil) | BRAZIL |
| Gold | CCR Refinery – Glencore Canada Corporation | CANADA |
| Gold | Johnson Matthey Ltd | CANADA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | China National Gold Group Corporation | CHINA |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Gansu Seemine Material Hi-Tech Co Ltd | CHINA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | Hunan Chenzhou Mining Group Co., Ltd. | CHINA |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
| Gold | Jiangxi Copper Company Limited | CHINA |
| Gold | Lingbao Gold Company Limited | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | CHINA |
| Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | CHINA |
| Gold | Penglai Penggang Gold Industry Co Ltd | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd | CHINA |
| Gold | The Great Wall Gold and Silver Refinery of China | CHINA |
| Gold | The Refinery of Shandong Gold Mining Co. Ltd | CHINA |
| Gold | Tongling nonferrous Metals Group Co.,Ltd | CHINA |
| Gold | Yunnan Copper Industry Co Ltd | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Zijin Mining Group Co. Ltd | CHINA |
| Gold | Zhaoyuan Gold Co. | CHINA |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | Aurubis AG | GERMANY |
| Gold | Bauer Walser AG | GERMANY |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Doduco | GERMANY |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| E-8 |
| Gold | Heraeus Ltd. Hong Kong | HONG KONG |
| Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Aida Chemical Industries Co. Ltd. | JAPAN |
| Gold | Asahi Pretec Corporation | JAPAN |
| Gold | Asaka Riken Co Ltd | JAPAN |
| Gold | Chugai Mining | JAPAN |
| Gold | Dowa | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Japan Mint | JAPAN |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kojima Chemicals Co., Ltd | JAPAN |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | Nihon Material Co. LTD | JAPAN |
| Gold | Ohura Precious Metal Industry Co., Ltd | JAPAN |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | Tokuriki Honten Co., Ltd | JAPAN |
| Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | JAPAN |
| Gold | Yokohama Metal Co Ltd | JAPAN |
| Gold | Kazzinc Ltd | KAZAKHSTAN |
| Gold | Daejin Indus Co. Ltd | KOREA, REPUBLIC OF |
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF |
| Gold | Hwasung CJ Co. Ltd | KOREA, REPUBLIC OF |
| Gold | Korea Metal Co. Ltd | KOREA, REPUBLIC OF |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | Caridad | MEXICO |
| Gold | Met-Mex Peñoles, S.A. | MEXICO |
| Gold | Schone Edelmetaal | NETHERLANDS |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION |
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| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIAN FEDERATION |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Metalor Technologies (Singapore) Pte. Ltd. | SINGAPORE |
| Gold | Rand Refinery (Pty) Ltd | SOUTH AFRICA |
| Gold | SEMPSA Joyería Platería SA | SPAIN |
| Gold | Boliden AB | SWEDEN |
| Gold | Argor-Heraeus SA | SWITZERLAND |
| Gold | Cendres + Métaux SA | SWITZERLAND |
| Gold | Metalor Technologies SA | SWITZERLAND |
| Gold | PAMP SA | SWITZERLAND |
| Gold | PX Précinox SA | SWITZERLAND |
| Gold | Valcambi SA | SWITZERLAND |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| Gold | Advanced Chemical Company | UNITED STATES |
| Gold | Colt Refining | UNITED STATES |
| Gold | Johnson Matthey Inc | UNITED STATES |
| Gold | Kennecott Utah Copper LLC | UNITED STATES |
| Gold | Materion | UNITED STATES |
| Gold | Metalor USA Refining Corporation | UNITED STATES |
| Gold | Ohio Precious Metals, LLC | UNITED STATES |
| Gold | Republic Metals Corporation | UNITED STATES |
| Gold | Sabin Metal Corp. | UNITED STATES |
| Gold | So Accurate Group, Inc. | UNITED STATES |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Tantalum | Plansee SE Liezen | AUSTRIA |
| Tantalum | Plansee SE Reutte | AUSTRIA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| E-10 |
| Tantalum | Mineração Taboca S.A. | BRAZIL |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., LTD | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | King-Tan Tantalum Industry Ltd | CHINA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | RFH Tantalum Smeltry Co., Ltd | CHINA |
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd | CHINA |
| Tantalum | Zhuzhou Cement Carbide | CHINA |
| Tantalum | Molycorp Silmet A.S. | ESTONIA |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tantalum | Metallurgical Products India (Pvt.) Ltd. | INDIA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | H.C. Starck Ltd. | JAPAN |
| Tantalum | Mitsui Mining & Smelting | JAPAN |
| Tantalum | Taki Chemicals | JAPAN |
| Tantalum | Nippon Mining & Metals Co. Ltd. | JAPAN |
| Tantalum | Ulba | KAZAKHSTAN |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | Exotech Inc. | UNITED STATES |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
| Tantalum | H.C. Starck Inc. | UNITED STATES |
| Tantalum | Hi-Temp | UNITED STATES |
| Tantalum | KEMET Blue Powder | UNITED STATES |
| Tantalum | QuantumClean | UNITED STATES |
| Tantalum | Telex | UNITED STATES |
| Tin | Metallo Chimique | BELGIUM |
| E-11 |
| Tin | Jean Goldschmidt International SA | BELGIUM |
| Tin | EM Vinto | BOLIVIA |
| Tin | OMSA | BOLIVIA |
| Tin | Cooper Santa | BRAZIL |
| Tin | Estanho de Rondônia S.A. | BRAZIL |
| Tin | Magnu's Minerais Metais e Ligas LTDA | BRAZIL |
| Tin | Melt Metais e Ligas S/A | BRAZIL |
| Tin | Mineração Taboca S.A. | BRAZIL |
| Tin | Soft Metais, Ltda. | BRAZIL |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| Tin | China Rare Metal Materials Company | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | CHINA |
| Tin | Gejiu Zi-Li | CHINA |
| Tin | Huichang Jinshunda Tin Co. Ltd | CHINA |
| Tin | Jiangxi Nanshan | CHINA |
| Tin | Linwu Xianggui Smelter Co | CHINA |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | CHINA |
| Tin | Yunnan Tin Company, Ltd. | CHINA |
| Tin | KOVOHUTE PRIBRAM NASTUPNICKA, A.S. | CZECH REPUBLIC |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | CV JusTindo | INDONESIA |
| Tin | CV Makmur Jaya | INDONESIA |
| Tin | CV Nurjanah | INDONESIA |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | PT Alam Lestari Kencana | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Bangka Kudai Tin | INDONESIA |
| Tin | PT Bangka Putra Karya | INDONESIA |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT BilliTin Makmur Lestari | INDONESIA |
| E-12 |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT DS Jaya Abadi | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA |
| Tin | PT Fang Di MulTindo | INDONESIA |
| Tin | PT HP Metals Indonesia | INDONESIA |
| Tin | PT Inti Stania Prima | INDONESIA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Koba Tin | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT REFINED BANGKA TIN | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Seirama Tin investment | INDONESIA |
| Tin | PT Singkep Times Utama | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | PT Supra Sukses Trinusa | INDONESIA |
| Tin | PT Tambang Timah | INDONESIA |
| Tin | PT Timah (Persero), Tbk | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | PT WAHANA PERKIT JAYA | INDONESIA |
| Tin | PT Yinchendo Mining Industry | INDONESIA |
| Tin | CV Duta Putra Bangka | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Hyundai-Steel | KOREA, REPUBLIC OF |
| Tin | Poongsan Corporation | KOREA, REPUBLIC OF |
| Tin | POSCO | KOREA, REPUBLIC OF |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Rahman Hydraulic Tin Sdn Bhd | MALAYSIA |
| Tin | Minsur | PERU |
| Tin | Amalgamet Inc. | PERU |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Fenix Metals | POLAND |
| Tin | Pure Technology | RUSSIA |
| Tin | Novosibirsk Integrated Tin Works | RUSSIAN FEDERATION |
| E-13 |
| Tin | CSC Pure Technologies | RUSSIAN FEDERATION |
| Tin | Electroloy Metal Pte | SINGAPORE |
| Tin | Rui Da Hung | TAIWAN |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | Thaisarco | THAILAND |
| Tin | Koki Products Co. Ltd. | THAILAND |
| Tin | Alpha | UNITED STATES |
| Tin | Technic Inc. | UNITED STATES |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | North American Tungsten | CANADA |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangsu Hetian Technological Material Co., Ltd | CHINA |
| Tungsten | Nanchang Cemented Carbide Limited Liability Company | CHINA |
| Tungsten | Xiamen Honglu Tungsten Molybdenum Industry Co. Ltd | CHINA |
| Tungsten | Zhangyuan Tungsten Co., Ltd | CHINA |
| E-14 |
| Tungsten | H.C. Starck GmbH | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Izawa Metal Co., Ltd | JAPAN |
| Tungsten | Saganoseki Smelter & Refinery | JAPAN |
| Tungsten | Tamano Smelter, Hibi Kyodo Smelting Co., Ltd | JAPAN |
| Tungsten | TaeguTec Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Wolfram Company CJSC | RUSSIAN FEDERATION |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
| Tungsten | Kennametal Fallon | UNITED STATES |
| Tungsten | Kennametal Huntsville | UNITED STATES |
| Tungsten | Air Products | UNITED STATES |
| Tungsten | Voss Metals Company, Inc | UNITED STATES |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | VIETNAM |
| E-15 |