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)

  

Delaware 001-39218 16-0977505
(State or other jurisdiction of (Commission (I.R.S. Employer
incorporation or organization) File Number) Identification No.)

 

11311 Concept Blvd. Largo FL 33773-4908

(Address of principal executive offices, including zip code)

 

Todd W Garner (727) 214-2975

(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 (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

 

 

 

 

 

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, 2021 to December 31, 2021. Unless the context indicates otherwise, “CONMED,” “we,” “us,” and “our” refer to CONMED Corporation and its consolidated subsidiaries.

 

During 2021, 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 searchable under the SEC Filing section at the following link: http://www.conmed.com/en/about-us/investor-relations ..

 

Item 1.02 Exhibit

 

A copy of CONMED’s Conflict Minerals Report 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 responsive to 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 26, 2022

 

  By:  /s/ Todd W. Garner
  Name:  Todd W. Garner
  Title:  Executive Vice President
    Chief Financial Officer

 

 

 

  

Exhibit Index

  

Exhibit No. Description of Exhibit Page Number
     
Exhibit 1.01 Conflict Minerals Report as responsive to 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, 2021

 

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, 2021.

 

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 2021.

 

This report is available on our website at http://www.conmed.com/en/about-us/investor-relations in the SEC Filings section.

  

2. Company Overview

 

CONMED is a medical technology company that provides devices and equipment for surgical procedures. The Company’s products are used by surgeons and other healthcare professionals in a variety of specialties including orthopedics, general surgery, gynecology, thoracic surgery, and gastroenterology.

 

Products

 

Our product lines consist of orthopedic surgery and general surgery.  Orthopedic surgery consists of sports medicine instrumentation and small bone, large bone, and specialty powered surgical instruments as well as imaging systems for use in minimally invasive surgery procedures and fees related to the sales representation, promotion, and marketing of sports medicine allograft tissue.  General surgery consists of a complete line of endo-mechanical instrumentation for minimally invasive laparoscopic and gastrointestinal procedures, smoke evacuation devices, a line of cardiac monitoring products as well as electrosurgical generators, and related instruments. 3TGs are in a significant portion of CONMED products due to electronics being a vital component to many of our product offerings. All four 3TGs are found within various electrical components that make up CONMED products, such as capacitors, rectifiers, relays, and electrical connectors.

 

Conflict Minerals Policy

 

The Company has actively engaged with our customers and suppliers for several years with respect to the use of conflict minerals. Our actions are a result of the Company’s responsible and inclusive culture and longstanding leadership in corporate responsibility. In addition to the measures described above, we have adopted a conflict minerals supply policy. This policy is available on our website at http://www.conmed.com/en/about-us /investor-relations in the Corporate Governance section.

 

E-1

 

  

3. Reasonable Country of Origin Inquiry

 

Because conflict minerals are necessary to the functionality or production of products that we manufacture, we have conducted 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 Responsible Business Alliance’s Conflict Minerals Reporting Template v6.10 (“CMRT”). This supply chain survey was implemented with the assistance of a third-party service provider, who 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 first-tier suppliers that provided items to CONMED that were used in final products in 2021. This list included many suppliers that did not provide any 3TGs. 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, they were listed as out of scope. The remaining number of suppliers in 2021 was 117.

 

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.

 

This year’s program continues to include 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. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

 

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 1st, 2022, we are left with no invalid supplier submissions.

 

Over 92% of the CONMED suppliers contacted provided a response. Non-responsive suppliers were contacted numerous times by both our third-party consultant and CONMED personnel. The majority of CMRTs provided by CONMED suppliers are at the company level and therefore cannot be definitively linked to any specific CONMED product.

  

Based on 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 Establish Strong Company Management Systems

 

As described above, CONMED has adopted a conflict minerals policy, which is located in the Corporate Governance section of the CONMED Corporation website (http://www.conmed.com/en/about-us /investor-relations).

 

E-2

 

 

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 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.

 

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 well as contractual protections, as described further below; and business relationships with our suppliers.

 

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 the expiration of the contract, we work individually with key selected suppliers to ensure 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.

 

 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 avoidance.

 

We put a strong emphasis on supplier education and training. To accomplish this, we utilized our third-party consultant’s learning management system and provided all in-scope suppliers access to conflict minerals training courses. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within these courses.

 

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 Corporate Governance section of our website at http://www.conmed.com/en/about-us/ investor-relations in the Corporate Governance section.

 

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 Responsible Minerals Initiative (“RMI”) pose a significant risk.

 

E-3

 

 

Where a smelter is not identified as Conflict Free by such sources, we assess them according to red flag indicators defined in the OECD Guidance. This rating is based on various factors, including geographic proximity to the DRC and covered countries; known mineral source country of origin; Responsible Minerals Assurance Process (RMAP) audit status; credible evidence of unethical or conflict sourcing and Peer Assessments conducted by credible third-party sources. 

 

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:

 

·Have you established a conflict minerals sourcing policy?
·Have you implemented due diligence measures for conflict-free sourcing?
·Do you review due diligence information received from your suppliers against your company’s expectations?
·Does your review 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 the methodology outlined by the RMI’s joint industry programs and outreach initiatives and requiring our suppliers to conform to 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 by requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI 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

 

The Company relies on third-party audits of smelters and refiners conducted as part of the Responsible Minerals Assurance Process (RMAP). The RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program. 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

 

CONMED reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC. CONMED’s Form SD and Conflict Minerals Report can be found in the SEC Filings section of the CONMED site at http://www.conmed.com/en/about-us/ investor-relations.

 

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.

 

E-4

 

 

The quality of the responses that we received from our surveyed suppliers also continue to be varied. Many responses provided by suppliers (via the CMRT) included the names of facilities listed by the suppliers as smelters or refiners. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our third-party provider follows up on these, urging suppliers to resubmit with increased smelter information. There are still suppliers 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 Responsible Minerals Initiative. If a supplier indicated that the facility was certified as “Conflict-Free,” our third-party consultant confirmed that the name was listed by RMI as a “Conflict-Free” smelter. As of May 1st, 2022, we have validated 336 legitimate smelters or refiners and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 230 smelters that are deemed “Responsible Minerals Assurance Process (RMAP) Conformant” - this indicates these smelters and refiners are conformant with the RMAP assessment protocols. There are 19 more smelters or refiners that are deemed “RMAP Active” - Smelters and refiners on the Active list have committed to undergo a RMAP audit. In addition, we have identified 17 smelters and refiners that are not conformant with the RMAP assessment protocols. The remaining 70 smelters listed have not yet been confirmed as Conflict-Free. We have assessed these facilities and determined that most of these are of low risk due to their geographic location. 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 RMI.

 

Many 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.

 

We expect any of our suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. During 2021, we have found no instances where it was necessary to terminate a contract or find a replacement supplier. 

 

6. Steps to Improve Future Due Diligence and Supply Chain Risk Mitigation

 

We are taking 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:

 

a.Continue to include a conflict minerals clause in all new or renewed supplier contracts.

 

b.Continue to engage with suppliers and direct them to training resources as mentioned in Section 4.1, Supplier Engagement, 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.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 Management Systems.

 

e.Consider replacing suppliers that remain non-responsive, or that are unable to enact due diligence measures as per the OECD Due Diligence Guidelines.

 

f.Work with suppliers to move to the latest CMRT where new smelter IDs are constantly being added.

 

E-5

 

 

g.Require the use of smelter identification numbers. Supplier responses will not be considered complete without identification numbers.

 

h.Suppliers will also be requested to inform CONMED of the correlation between these smelters and the products and parts they supply to CONMED.

 

i.CONMED, through a compliance partner, has reached out to the 17 non-conformant smelters; 13 are currently in communication with that partner who is providing guidance in addressing concerns.

 

7. Independent Audit

 

In accordance with guidance issued by 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, 2021.

 

E-6

 

 

Attachment A

 

Metal Smelter Name Smelter Facility Location(a)  Smelter ID  RMAP Audit Status
Gold Advanced Chemical Company United States of America CID000015 Conformant
Gold Aida Chemical Industries Co., Ltd. Japan CID000019 Conformant
Gold Allgemeine Gold-und Silberscheideanstalt A.G. Germany CID000035 Conformant
Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan CID000041 Conformant
Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil CID000058 Conformant
Gold Argor-Heraeus S.A. Switzerland CID000077 Conformant
Gold Asahi Pretec Corp. Japan CID000082 Conformant
Gold Asaka Riken Co., Ltd. Japan CID000090 Conformant
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey CID000103 Outreach Required
Gold Aurubis AG Germany CID000113 Conformant
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines CID000128 Conformant
Gold Boliden AB Sweden CID000157 Conformant
Gold C. Hafner GmbH + Co. KG Germany CID000176 Conformant
Gold Caridad Mexico CID000180 Outreach Required
Gold CCR Refinery - Glencore Canada Corporation Canada CID000185 Conformant
Gold Cendres + Metaux S.A. Switzerland CID000189 Conformant
Gold Yunnan Copper Industry Co., Ltd. China CID000197 Outreach Required
Gold Chimet S.p.A. Italy CID000233 Conformant
Gold Chugai Mining Japan CID000264 Conformant
Gold Daye Non-Ferrous Metals Mining Ltd. China CID000343 In Communication
Gold DSC (Do Sung Corporation) Korea, Republic Of CID000359 Conformant
Gold Dowa Japan CID000401 Conformant
Gold Eco-System Recycling Co., Ltd. East Plant Japan CID000425 Conformant
Gold OJSC Novosibirsk Refinery Russian Federation CID000493 Non Conformant
Gold Refinery of Seemine Gold Co., Ltd. China CID000522 Outreach Required
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. China CID000651 Outreach Required
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. China CID000671 Outreach Required
Gold LT Metal Ltd. Korea, Republic Of CID000689 Conformant
Gold Heimerle + Meule GmbH Germany CID000694 Conformant
Gold Heraeus Metals Hong Kong Ltd. China CID000707 Conformant
Gold Heraeus Precious Metals GmbH & Co. KG Germany CID000711 Conformant
Gold Hunan Chenzhou Mining Co., Ltd. China CID000767 Outreach Required
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China CID000773 Outreach Required
Gold HwaSeong CJ CO., LTD. Korea, Republic Of CID000778 Communication Suspended - Not Interested
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China CID000801 Conformant

 

E-7

 

 

Gold Ishifuku Metal Industry Co., Ltd. Japan CID000807 Conformant
Gold Istanbul Gold Refinery Turkey CID000814 Conformant
Gold Japan Mint Japan CID000823 Conformant
Gold Jiangxi Copper Co., Ltd. China CID000855 Conformant
Gold Asahi Refining USA Inc. United States Of America CID000920 Conformant
Gold Asahi Refining Canada Ltd. Canada CID000924 Conformant
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation CID000927 RMI Due Diligence Review - Unable to Proceed
Gold JSC Uralelectromed Russian Federation CID000929 Non Conformant
Gold JX Nippon Mining & Metals Co., Ltd. Japan CID000937 Conformant
Gold Kazakhmys Smelting LLC Kazakhstan CID000956 In Communication
Gold Kazzinc Kazakhstan CID000957 Conformant
Gold Kennecott Utah Copper LLC United States Of America CID000969 Conformant
Gold Kojima Chemicals Co., Ltd. Japan CID000981 Conformant
Gold Kyrgyzaltyn JSC Kyrgyzstan CID001029 Non Conformant
Gold L'azurde Company For Jewelry Saudi Arabia CID001032 RMI Due Diligence Review - Unable to Proceed
Gold Lingbao Gold Co., Ltd. China CID001056 Outreach Required
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. China CID001058 Outreach Required
Gold LS-NIKKO Copper Inc. Korea, Republic Of CID001078 Conformant
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China CID001093 Outreach Required
Gold Materion United States Of America CID001113 Conformant
Gold Matsuda Sangyo Co., Ltd. Japan CID001119 Conformant
Gold Metalor Technologies (Suzhou) Ltd. China CID001147 Conformant
Gold Metalor Technologies (Hong Kong) Ltd. China CID001149 Conformant
Gold Metalor Technologies (Singapore) Pte., Ltd. Singapore CID001152 Conformant
Gold Metalor Technologies S.A. Switzerland CID001153 Conformant
Gold Metalor USA Refining Corporation United States Of America CID001157 Conformant
Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico CID001161 Conformant
Gold Mitsubishi Materials Corporation Japan CID001188 Conformant
Gold Mitsui Mining and Smelting Co., Ltd. Japan CID001193 Conformant
Gold Moscow Special Alloys Processing Plant Russian Federation CID001204 Non Conformant
Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey CID001220 Conformant
Gold Navoi Mining and Metallurgical Combinat Uzbekistan CID001236 Conformant
Gold Nihon Material Co., Ltd. Japan CID001259 Conformant
Gold Ohura Precious Metal Industry Co., Ltd. Japan CID001325 Conformant
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation CID001326 Non Conformant
Gold PAMP S.A. Switzerland CID001352 Conformant
Gold Penglai Penggang Gold Industry Co., Ltd. China CID001362 Outreach Required
Gold Prioksky Plant of Non-Ferrous Metals Russian Federation CID001386 Non Conformant
Gold PT Aneka Tambang (Persero) Tbk Indonesia CID001397 Conformant

 

E-8

 

 

Gold PX Precinox S.A. Switzerland CID001498 Conformant
Gold Rand Refinery (Pty) Ltd. South Africa CID001512 Conformant
Gold Royal Canadian Mint Canada CID001534 Conformant
Gold Sabin Metal Corp. United States Of America CID001546 Communication Suspended - Not Interested
Gold Samduck Precious Metals Korea, Republic Of CID001555 Conformant
Gold Samwon Metals Corp. Korea, Republic Of CID001562 Communication Suspended - Not Interested
Gold SEMPSA Joyeria Plateria S.A. Spain CID001585 Conformant
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China CID001619 Outreach Required
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China CID001622 Conformant
Gold Sichuan Tianze Precious Metals Co., Ltd. China CID001736 Conformant
Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation CID001756 Non Conformant
Gold Solar Applied Materials Technology Corp. Taiwan, Province Of China CID001761 Conformant
Gold Sumitomo Metal Mining Co., Ltd. Japan CID001798 Conformant
Gold Super Dragon Technology Co., Ltd. China CID001810 Outreach Required
Gold Tanaka Kikinzoku Kogyo K.K. Japan CID001875 Conformant
Gold Great Wall Precious Metals Co., Ltd. of CBPM China CID001909 Outreach Required
Gold The Refinery of Shandong Gold Mining Co., Ltd. China CID001916 Conformant
Gold Tokuriki Honten Co., Ltd. Japan CID001938 Conformant
Gold Tongling Nonferrous Metals Group Co., Ltd. China CID001947 Outreach Required
Gold Torecom Korea, Republic Of CID001955 Conformant
Gold Umicore S.A. Business Unit Precious Metals Refining Belgium CID001980 Conformant
Gold United Precious Metal Refining, Inc. United States Of America CID001993 Conformant
Gold Valcambi S.A. Switzerland CID002003 Conformant
Gold Western Australian Mint (T/a The Perth Mint) Australia CID002030 Conformant
Gold Yamakin Co., Ltd. Japan CID002100 Conformant
Gold Yokohama Metal Co., Ltd. Japan CID002129 Conformant
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation China CID002224 Conformant
Gold Gold Refinery of Zijin Mining Group Co., Ltd. China CID002243 Conformant
Gold Morris and Watson New Zealand CID002282 In Communication
Gold SAFINA A.S. Czechia CID002290 Conformant
Gold Guangdong Jinding Gold Limited China CID002312 Outreach Required
Gold Umicore Precious Metals Thailand Thailand CID002314 Conformant
Gold Geib Refining Corporation United States Of America CID002459 Conformant
Gold MMTC-PAMP India Pvt., Ltd. India CID002509 Conformant
Gold KGHM Polska Miedz Spolka Akcyjna Poland CID002511 Conformant
Gold Fidelity Printers and Refiners Ltd. Zimbabwe CID002515 RMI Due Diligence Review - Unable to Proceed
Gold Singway Technology Co., Ltd. Taiwan, Province Of China CID002516 Conformant

 

E-9

 

 

Gold Shandong Humon Smelting Co., Ltd. China CID002525 Outreach Required
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China CID002527 Outreach Required
Gold Al Etihad Gold Refinery DMCC United Arab Emirates CID002560 Conformant
Gold Emirates Gold DMCC United Arab Emirates CID002561 Conformant
Gold International Precious Metal Refiners United Arab Emirates CID002562 In Communication
Gold Kaloti Precious Metals United Arab Emirates CID002563 RMI Due Diligence Review - Unable to Proceed
Gold Sudan Gold Refinery Sudan CID002567 Outreach Required
Gold T.C.A S.p.A Italy CID002580 Conformant
Gold REMONDIS PMR B.V. Netherlands CID002582 Conformant
Gold Fujairah Gold FZC United Arab Emirates CID002584 Outreach Required
Gold Industrial Refining Company Belgium CID002587 Non Conformant
Gold Shirpur Gold Refinery Ltd. India CID002588 Outreach Required
Gold Korea Zinc Co., Ltd. Korea, Republic Of CID002605 Conformant
Gold Marsam Metals Brazil CID002606 Conformant
Gold TOO Tau-Ken-Altyn Kazakhstan CID002615 Conformant
Gold Abington Reldan Metals, LLC United States Of America CID002708 Non Conformant
Gold SAAMP France CID002761 Conformant
Gold L'Orfebre S.A. Andorra CID002762 Conformant
Gold 8853 S.p.A. Italy CID002763 Conformant
Gold Italpreziosi Italy CID002765 Conformant
Gold WIELAND Edelmetalle GmbH Germany CID002778 Conformant
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria CID002779 Conformant
Gold AU Traders and Refiners South Africa CID002850 Non Conformant
Gold GCC Gujrat Gold Centre Pvt. Ltd. India CID002852 Active
Gold Sai Refinery India CID002853 Outreach Required
Gold Modeltech Sdn Bhd Malaysia CID002857 Non Conformant
Gold Bangalore Refinery India CID002863 Conformant
Gold Kyshtym Copper-Electrolytic Plant ZAO Russian Federation CID002865 Outreach Required
Gold Degussa Sonne / Mond Goldhandel GmbH Germany CID002867 Outreach Required
Gold Pease & Curren United States Of America CID002872 Communication Suspended - Not Interested
Gold JALAN & Company India CID002893 Outreach Required
Gold SungEel HiMetal Co., Ltd. Korea, Republic Of CID002918 Conformant
Gold Planta Recuperadora de Metales SpA Chile CID002919 Conformant
Gold Safimet S.p.A Italy CID002973 Conformant
Gold State Research Institute Center for Physical Sciences and Technology Lithuania CID003153 Outreach Required
Gold African Gold Refinery Uganda CID003185 Outreach Required
Gold Gold Coast Refinery Ghana CID003186 Outreach Required

 

E-10

 

 

Gold NH Recytech Company Korea, Republic Of CID003189 Conformant
Gold QG Refining, LLC United States Of America CID003324 Outreach Required
Gold Dijllah Gold Refinery FZC United Arab Emirates CID003348 Outreach Required
Gold CGR Metalloys Pvt Ltd. India CID003382 Outreach Required
Gold Sovereign Metals India CID003383 Outreach Required
Gold C.I Metales Procesados Industriales SAS Colombia CID003421 Active
Gold Eco-System Recycling Co., Ltd. North Plant Japan CID003424 Conformant
Gold Eco-System Recycling Co., Ltd. West Plant Japan CID003425 Conformant
Gold Augmont Enterprises Private Limited India CID003461 Active
Gold Kundan Care Products Ltd. India CID003463 In Communication
Gold Emerald Jewel Industry India Limited (Unit 1) India CID003487 In Communication
Gold Emerald Jewel Industry India Limited (Unit 2) India CID003488 In Communication
Gold Emerald Jewel Industry India Limited (Unit 3) India CID003489 In Communication
Gold Emerald Jewel Industry India Limited (Unit 4) India CID003490 In Communication
Gold K.A. Rasmussen Norway CID003497 Outreach Required
Gold Alexy Metals United States Of America CID003500 Active
Gold Sancus ZFS (L’Orfebre, SA) Colombia CID003529 Active
Gold Sellem Industries Ltd. Mauritania CID003540 Communication Suspended - Not Interested
Gold MD Overseas India CID003548 In Communication
Gold Metallix Refining Inc. United States Of America CID003557 In Communication
Gold Metal Concentrators SA (Pty) Ltd. South Africa CID003575 Conformant
Gold WEEEREFINING France CID003615 Active
Gold Value Trading Belgium CID003617 In Communication
Tantalum Changsha South Tantalum Niobium Co., Ltd. China CID000211 Conformant
Tantalum F&X Electro-Materials Ltd. China CID000460 Conformant
Tantalum Guangdong Zhiyuan New Material Co., Ltd. China CID000616 Conformant
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. China CID000914 Conformant
Tantalum Jiujiang Tanbre Co., Ltd. China CID000917 Conformant
Tantalum LSM Brasil S.A. Brazil CID001076 Conformant
Tantalum Metallurgical Products India Pvt., Ltd. India CID001163 Conformant
Tantalum Mineracao Taboca S.A. Brazil CID001175 Conformant
Tantalum Mitsui Mining and Smelting Co., Ltd. Japan CID001192 Conformant
Tantalum NPM Silmet AS Estonia CID001200 Conformant
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. China CID001277 Conformant

 

E-11

 

 

Tantalum QuantumClean United States Of America CID001508 Conformant
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China CID001522 Conformant
Tantalum Solikamsk Magnesium Works OAO Russian Federation CID001769 Conformant
Tantalum Taki Chemical Co., Ltd. Japan CID001869 Conformant
Tantalum Telex Metals United States Of America CID001891 Conformant
Tantalum Ulba Metallurgical Plant JSC Kazakhstan CID001969 Conformant
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China CID002492 Conformant
Tantalum D Block Metals, LLC United States Of America CID002504 Conformant
Tantalum FIR Metals & Resource Ltd. China CID002505 Conformant
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China CID002506 Conformant
Tantalum XinXing HaoRong Electronic Material Co., Ltd. China CID002508 Conformant
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China CID002512 Conformant
Tantalum KEMET Blue Metals Mexico CID002539 Conformant
Tantalum H.C. Starck Co., Ltd. Thailand CID002544 Conformant
Tantalum H.C. Starck Tantalum and Niobium GmbH Germany CID002545 Conformant
Tantalum H.C. Starck Hermsdorf GmbH Germany CID002547 Conformant
Tantalum H.C. Starck Inc. United States Of America CID002548 Conformant
Tantalum H.C. Starck Ltd. Japan CID002549 Conformant
Tantalum H.C. Starck Smelting GmbH & Co. KG Germany CID002550 Conformant
Tantalum Global Advanced Metals Boyertown United States Of America CID002557 Conformant
Tantalum Global Advanced Metals Aizu Japan CID002558 Conformant
Tantalum Resind Industria e Comercio Ltda. Brazil CID002707 Conformant
Tantalum Jiangxi Tuohong New Raw Material China CID002842 Conformant
Tantalum Yancheng Jinye New Material Technology Co., Ltd. China CID003583 Conformant
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China CID000228 Conformant
Tin Alpha United States Of America CID000292 Conformant
Tin PT Aries Kencana Sejahtera Indonesia CID000309 Active
Tin Dowa Japan CID000402 Conformant

 

E-12

 

 

Tin EM Vinto Bolivia (Plurinational State Of) CID000438 Conformant
Tin Estanho de Rondonia S.A. Brazil CID000448 Conformant
Tin Fenix Metals Poland CID000468 Conformant
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. China CID000538 Conformant
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. China CID000555 Conformant
Tin Gejiu Kai Meng Industry and Trade LLC China CID000942 Non Conformant
Tin China Tin Group Co., Ltd. China CID001070 Conformant
Tin Malaysia Smelting Corporation (MSC) Malaysia CID001105 Conformant
Tin Metallic Resources, Inc. United States Of America CID001142 Conformant
Tin Mineracao Taboca S.A. Brazil CID001173 Conformant
Tin Minsur Peru CID001182 Conformant
Tin Mitsubishi Materials Corporation Japan CID001191 Conformant
Tin Jiangxi New Nanshan Technology Ltd. China CID001231 Conformant
Tin Novosibirsk Processing Plant Ltd. Russian Federation CID001305 Conformant
Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand CID001314 Conformant
Tin Operaciones Metalurgicas S.A. Bolivia (Plurinational State Of) CID001337 Conformant
Tin PT Artha Cipta Langgeng Indonesia CID001399 Conformant
Tin PT Babel Inti Perkasa Indonesia CID001402 Conformant
Tin PT Babel Surya Alam Lestari Indonesia CID001406 Conformant
Tin PT Belitung Industri Sejahtera Indonesia CID001421 Outreach Required
Tin PT Bukit Timah Indonesia CID001428 Active
Tin PT Mitra Stania Prima Indonesia CID001453 Conformant
Tin PT Panca Mega Persada Indonesia CID001457 Outreach Required
Tin PT Prima Timah Utama Indonesia CID001458 Conformant
Tin PT Refined Bangka Tin Indonesia CID001460 Conformant
Tin PT Sariwiguna Binasentosa Indonesia CID001463 Conformant
Tin PT Stanindo Inti Perkasa Indonesia CID001468 Conformant
Tin PT Timah Tbk Kundur Indonesia CID001477 Conformant
Tin PT Timah Tbk Mentok Indonesia CID001482 Conformant
Tin PT Timah Nusantara Indonesia CID001486 Active
Tin PT Tinindo Inter Nusa Indonesia CID001490 Conformant
Tin Rui Da Hung Taiwan, Province Of China CID001539 Conformant
Tin Soft Metais Ltda. Brazil CID001758 Conformant
Tin Thaisarco Thailand CID001898 Conformant
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China CID001908 Conformant
Tin VQB Mineral and Trading Group JSC Vietnam CID002015 Outreach Required
Tin White Solder Metalurgia e Mineracao Ltda. Brazil CID002036 Conformant
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China CID002158 Conformant
Tin Yunnan Tin Company Limited China CID002180 Conformant
Tin CV Venus Inti Perkasa Indonesia CID002455 Active
Tin Magnu's Minerais Metais e Ligas Ltda. Brazil CID002468 Conformant

 

E-13

 

 

Tin PT Tirus Putra Mandiri Indonesia CID002478 Outreach Required
Tin Melt Metais e Ligas S.A. Brazil CID002500 Outreach Required
Tin PT ATD Makmur Mandiri Jaya Indonesia CID002503 Conformant
Tin O.M. Manufacturing Philippines, Inc. Philippines CID002517 Conformant
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Vietnam CID002572 Non Conformant
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company Vietnam CID002573 Outreach Required
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company Vietnam CID002574 Outreach Required
Tin PT Cipta Persada Mulia Indonesia CID002696 Conformant
Tin An Vinh Joint Stock Mineral Processing Company Vietnam CID002703 Outreach Required
Tin Resind Industria e Comercio Ltda. Brazil CID002706 Conformant
Tin Super Ligas Brazil CID002756 Active
Tin Metallo Belgium N.V. Belgium CID002773 Conformant
Tin Metallo Spain S.L.U. Spain CID002774 Conformant
Tin PT Sukses Inti Makmur Indonesia CID002816 Active
Tin Thai Nguyen Mining and Metallurgy Co., Ltd. Vietnam CID002834 Conformant
Tin PT Menara Cipta Mulia Indonesia CID002835 Conformant
Tin Modeltech Sdn Bhd Malaysia CID002858 Non Conformant
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China CID003116 Conformant
Tin Chifeng Dajingzi Tin Industry Co., Ltd. China CID003190 Conformant
Tin PT Bangka Serumpun Indonesia CID003205 Conformant
Tin Pongpipat Company Limited Myanmar CID003208 Outreach Required
Tin Tin Technology & Refining United States Of America CID003325 Conformant
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China CID003356 Non Conformant
Tin Ma'anshan Weitai Tin Co., Ltd. China CID003379 Conformant
Tin PT Masbro Alam Stania Indonesia CID003380 Active
Tin PT Rajawali Rimba Perkasa Indonesia CID003381 Conformant
Tin Luna Smelter, Ltd. Rwanda CID003387 Conformant
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China CID003397 Non Conformant
Tin Precious Minerals and Smelting Limited India CID003409 Non Conformant
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China CID003410 Outreach Required
Tin PT Mitra Sukses Globalindo Indonesia CID003449 Active
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil CID003486 Active
Tin CRM Synergies Spain CID003524 Conformant
Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil CID003582 Conformant
Tin PT Tommy Utama Indonesia CID001493 In Communication
Tungsten A.L.M.T. Corp. Japan CID000004 Conformant
Tungsten Kennametal Huntsville United States Of America CID000105 Conformant
Tungsten Guangdong Xianglu Tungsten Co., Ltd. China CID000218 Conformant
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China CID000258 Conformant
Tungsten CNMC (Guangxi) PGMA Co., Ltd. China CID000281 Outreach Required

 

E-14

 

 

Tungsten Global Tungsten & Powders Corp. United States Of America CID000568 Conformant
Tungsten Hunan Chenzhou Mining Co., Ltd. China CID000766 Conformant
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. China CID000769 Conformant
Tungsten Japan New Metals Co., Ltd. Japan CID000825 Conformant
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. China CID000875 Conformant
Tungsten Kennametal Fallon United States Of America CID000966 Conformant
Tungsten Wolfram Bergbau und Hutten AG Austria CID002044 Conformant
Tungsten Xiamen Tungsten Co., Ltd. China CID002082 Conformant
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China CID002313 Communication Suspended - Not Interested
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China CID002315 Conformant
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China CID002316 Conformant
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China CID002317 Conformant
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China CID002318 Conformant
Tungsten Malipo Haiyu Tungsten Co., Ltd. China CID002319 Conformant
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China CID002320 Conformant
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China CID002321 Conformant
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China CID002494 Conformant
Tungsten Asia Tungsten Products Vietnam Ltd. Vietnam CID002502 Conformant
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. China CID002513 Conformant
Tungsten H.C. Starck Tungsten GmbH Germany CID002541 Conformant
Tungsten H.C. Starck Smelting GmbH & Co. KG Germany CID002542 Conformant
Tungsten Masan Tungsten Chemical LLC (MTC) Vietnam CID002543 Conformant
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China CID002551 Conformant
Tungsten Niagara Refining LLC United States Of America CID002589 Conformant
Tungsten China Molybdenum Co., Ltd. China CID002641 Conformant
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. China CID002645 Conformant
Tungsten Hydrometallurg, JSC Russian Federation CID002649 Conformant
Tungsten Unecha Refractory metals plant Russian Federation CID002724 Conformant
Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines CID002827 Conformant
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. China CID002830 Conformant
Tungsten ACL Metais Eireli Brazil CID002833 Conformant
Tungsten Moliren Ltd. Russian Federation CID002845 Conformant
Tungsten KGETS Co., Ltd. Korea, Republic Of CID003388 Conformant
Tungsten Fujian Ganmin RareMetal Co., Ltd. China CID003401 Conformant
Tungsten Lianyou Metals Co., Ltd. Taiwan, Province Of China CID003407 Conformant
Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation CID003408 Conformant
Tungsten NPP Tyazhmetprom LLC Russian Federation CID003416 Active

 

E-15

 

 

Tungsten GEM Co., Ltd. China CID003417 Conformant
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil CID003427 Active
Tungsten Cronimet Brasil Ltda Brazil CID003468 Conformant
Tungsten Artek LLC Russian Federation CID003553 Outreach Required
Tungsten Fujian Xinlu Tungsten China CID003609 Conformant
Tungsten OOO “Technolom” 2 Russian Federation CID003612 Active
Tungsten OOO “Technolom” 1 Russian Federation CID003614 Active
Tungsten LLC Volstok Russian Federation CID003643 Outreach Required

  

(a) Locations were obtained directly from the individual smelter files. Therefore, the naming convention for the same location may vary across smelters.

 

Appendix B:

 

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

  

Afghanistan, Åland Islands, Albania, American Samoa, Andorra, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia (Plurinational State of), Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo, Czechia, Djibouti, Dominica, Dominican Republic, Democratic Republic of Congo, Ecuador, Egypt, Eritrea, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Kazakhstan, Kenya, Korea, Republic of, Kyrgyzstan, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Norway, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, South Sudan, Spain, Sudan, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States of America, Uzbekistan, Vietnam, Zambia, Zimbabwe

 

E-16