UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
TriMas Corporation
(Exact name of registrant as specified in its charter)
Delaware (State or other jurisdiction of incorporation) | 001-10716 (Commission File Number) | 38-2687639 (IRS Employer Identification No.) | ||
38505 Woodward Avenue, Suite 200 Bloomfield Hills, Michigan (Address of principal executive offices) | 48304 (Zip Code) | |||
Joshua A. Sherbin, Senior Vice President, General Counsel and Chief Compliance Officer, 248-631-5400
(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:
ü | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017. |
Section 1 – Conflict Minerals Disclosure
Item 1.01. Conflict Minerals Disclosure and Report.
Introduction
TriMas Corporation ("TriMas" or the "Company"), and its consolidated subsidiaries, is a global manufacturer and distributor of products for commercial, industrial and consumer markets. The Company is principally engaged in the following reportable segments with diverse products and market channels: Packaging, Aerospace and Specialty Products. TriMas is filing this Form SD ("Form SD") pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule") for the reporting period January 1, 2017 to December 31, 2017 (the "Reporting Period").
TriMas manufactures or contracts to manufacture "products" that may contain certain "conflict minerals" (as defined below) that are necessary to the functionality or production of such products. Form SD defines "conflict minerals" as: (i)(a) columbite-tantalite (or coltan, the metal ore from which tantalum is extracted), (b) cassiterite (the metal ore from which tin is extracted), (c) gold and (d) wolframite (the metal ore from which tungsten is extracted), or their derivatives; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (collectively, the "Covered Countries").
Conflict Minerals Disclosures
In accordance with the Rule and Form SD, TriMas has conducted a good faith reasonable country of origin inquiry ("RCOI") regarding the conflict minerals included in its products during the Reporting Period to determine whether any of such conflict minerals originated in the Covered Countries and/or whether any of such conflict minerals may be from recycled or scrap sources.
In accordance with the Rule, TriMas has filed this Form SD and the associated Conflict Minerals Report, each of which are posted to TriMas’ publicly available internet site at www.trimascorp.com.
Item 1.02. Exhibit.
A description of the RCOI and the measures TriMas took to exercise due diligence on the source and chain of custody of certain of its conflict minerals is provided in the Conflict Minerals Report attached hereto as Exhibit 1.01. The content on, or accessible through, any website referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.
Section 2 – Exhibits
Item 2.01. Exhibits.
Exhibit Number | Description |
1.01 | |
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.
TriMas Corporation
/s/ Joshua A. Sherbin | May 31, 2018 | |
Name: Joshua A. Sherbin | Date | |
Title: Senior Vice President, General Counsel, Chief Compliance Officer and Corporate Secretary | ||
Exhibit 1.01
TriMas Corporation
Conflict Minerals Report
For the Reporting Period January 1, 2017 to December 31, 2017
TriMas Corporation ("TriMas" or the "Company") is filing this Conflict Minerals Report ("CMR") for the reporting period January 1, 2017 to December 31, 2017 (the "Reporting Period") as an exhibit to its Form SD ("Form SD") pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). TriMas manufactures or contracts to manufacture "products" that may contain conflict minerals, as defined by the Rule, present in its supply chain that may have originated in the Democratic Republic of the Congo or an adjoining country (the "Covered Countries") and may not be from recycled or scrap sources. Accordingly, TriMas is filing this CMR as an exhibit to Form SD to describe the due diligence measures taken to determine the source and chain of custody of the conflict minerals used in its products during the Reporting Period.
1) Reasonable Country of Origin Inquiry
In accordance with the Rule and Form SD, TriMas conducted a good faith reasonable country of origin inquiry ("RCOI") regarding the conflict minerals included in its products during the Reporting Period to determine whether any of such conflict minerals originated in the Covered Countries and/or whether any of such conflict minerals may be from recycled or scrap sources.
a) | Supplier Engagement |
To complete the RCOI, TriMas’ in-scope tier 1 suppliers ("Tier 1 Suppliers") were requested to provide information regarding the presence and sourcing of conflict minerals used in the products supplied to TriMas. The program utilized the Responsible Minerals Initiative - RMI.
Suppliers were offered two options to submit the required information, either by uploading a completed Conflict Minerals Reporting Template ("CMRT," also referred to as "surveys" or "declarations") or by completing an online survey version of the template directly to a third-party platform operated by Assent Compliance, a vendor retained by TriMas.
During the supplier survey, suppliers were contacted via Assent Compliance Manager, a SaaS platform, operated by Assent Compliance, that enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRT forms directly to the platform for risk assessment and management. In their responses, suppliers specified whether information was being provided at the company level or the product level. Non-responsive suppliers were contacted a minimum of three times by Assent Compliance Manager and then were also managed by the Assent Compliance supply chain team in one-on-one communications. This included two follow-ups from the supply chain team. For the 2017 reporting period, TriMas received responses from 371 or 85% of its 437 surveyed suppliers. Of the 371 suppliers that provided a response, approximately 287 reported that their products contained either tin, tantalum, tungsten or gold ("3TG") necessary to the functionality or production of their products.
Automated data validation on all submitted CMRTs is included in the program. 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. For the 2017 reporting period, TriMas had 17 invalid CMRTs, or 4% of submitted responses.
As mentioned above, the CMRTs received allowed TriMas to collect and compile, via Assent Compliance Manager, all answers from the CMRT with respect to smelter information reflected in the CMRTs. With respect to smelter information reflected in the CMRTs, there were suppliers who did not provide smelter lists. Without having full smelter information for TriMas products from all suppliers in scope, TriMas is unable to determine whether there is sourcing from the Covered Countries. In connection with its evaluation of the CMRTs, TriMas and Assent undertook due diligence to validate supplier reports.
b) Information Cut-Off
The deadline for suppliers to submit RCOI information for the Reporting Period was May 15, 2018.
2) Due Diligence Process
Based on the information obtained pursuant to the RCOI process described above, the Company conducted additional due diligence to determine the source and chain of custody of the conflict minerals used in its products during the Reporting Period.
TriMas’ due diligence process is based on the Organization for Economic Cooperation and Development’s ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements. The OECD Guidance was written for both upstream1 and downstream2 companies in the supply chain. As TriMas is a downstream company in the supply chain, TriMas’ due diligence practices were tailored accordingly. Due diligence measures undertaken by TriMas included the following:
a)Establish Strong Company Management Systems
Adopt A Conflict Minerals Policy
TriMas adopted a Responsible Sourcing and Conflict Minerals Policy ("Conflict Minerals Policy"). This policy is available on TriMas’ website at www.trimascorp.com/supplier.htm.
Assemble An Internal Team To Support Supply Chain Due Diligence
TriMas’ Senior Management Compliance Committee (the "SMCC") identified individuals representing multiple TriMas departments and business units to oversee and drive conflict minerals compliance. Together with Assent Compliance, TriMas’ Chief Compliance Officer worked with the Company’s business units to complete tasks associated with the supplier due diligence process. Individual leads within the business units further facilitated the diligence process to collect information regarding the presence and sourcing of conflict minerals in the products supplied to TriMas.
Establish A System Of Controls And Transparency Over The Supply Chain
To provide better transparency within TriMas’ supply chain and to facilitate communication of policies and expectations, TriMas engaged a third-party information management service provider (Assent Compliance) to complement internal management processes. The Assent Compliance online system and processes are used to identify suppliers in TriMas’ supply chain and collect, store, and review information on conflict minerals sourcing practices, track information on SORs, and flag risks based on SOR sourcing practices. This system is designed to allow collection and housing of data on supply chain circumstances, which can be updated to reflect changes within the supply chain, such as new customer-supplier relationships and new products.
TriMas mandated compliance in its supply chain with TriMas’ Conflict Minerals Policy through its contractual terms and conditions.
TriMas maintains an ethics hotline accessible at www.trimascorp.com through which a party, including TriMas employees and suppliers, may submit reports or concerns regarding compliance, including with respect to conflict minerals.
________________
1 Upstream companies refer to those between the mine and smelters or refiners ("SOR"). As such, the companies typically include miners, local traders, or exporters from the country of mineral origin, international concentrate traders, and SORs.
2 Downstream companies refer to those entities between the SOR and retailer. As such, the companies typically include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers, and retailers.
Implement Internal Measures Taken To Strengthen Company Engagement With Suppliers
TriMas has increased its supply chain transparency by identifying risks within its supply chain. TriMas is committed to conducting business in a socially responsible manner and partnering with suppliers who are similarly committed. TriMas’ supplier compliance process requires that suppliers comply with various contract provisions, legal requirements and industrial standards under local, regional and national laws and regulations of the countries in which the suppliers conduct business. Through this process, TriMas remains engaged with its supply base from a compliance perspective.
During this reporting period, we utilized the Conflict Minerals Reporting Template (CMRT) version 5.01 or higher to collect conflict minerals declarations from our Tier 1 Suppliers. These declarations were uploaded into the Assent Compliance Manager web-based reporting platform. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements, and increase the rate of responses we have received from our suppliers to our survey requests. Assent followed-up with suppliers to ensure proper completion of the CMRT, and all communication with suppliers has been documented to reflect the degree of success of these efforts.
This reporting year, TriMas placed a strong emphasis on supplier education and training. To accomplish this, we utilized Assent’s Learning Management System, Assent University, and provided all Tier 1 Suppliers access to a comprehensive Conflict Minerals training course. This training is tracked and evaluated based on completion of course modules. All Tier 1 Suppliers are encouraged to complete all relevant modules of the conflict minerals course, which include active learning techniques and testing at the end of each module.
Reporting Mechanism
We have established reporting mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Conflict Minerals Policy.
b) | Identify and Assess Risk in Our Supply Chain |
TriMas identified 437 Tier 1 Suppliers. We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. We believe many of our largest suppliers are suppliers to other SEC registrants that are subject to the Rule.
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 or the London Bullion Market Association ("LBMA") Responsible Gold Programme, may 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 RMI, 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 chance 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.
Additionally, each supplier is evaluated on the strength of its conflict minerals program (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 a 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 review process include corrective action management?
The more positive the responses to these questions indicate a stronger conflict sourcing initiative.
As part of our risk management plan and to ensure suppliers understand our expectations, we have, through Assent Compliance, 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.
In accordance with our Conflict Minerals Policy, if a supplier we have engaged gives us reason to believe that it may be supplying us with 3TG from sources that may support conflict in a Covered Country, we encourage the supplier to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we may initiate steps to find replacement suppliers.
Once surveys were returned, Assent reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the RMI Responsible Minerals Assurance Process - RMAP. If an SOR was not validated by the RMAP, Assent either attempted to contact the SOR to gather more information about its sourcing practices or conducted Internet research to determine whether there are any additional publicly available sources of information regarding the SOR’s sourcing practices.
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free may pose a significant risk to the supply chain. Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
•Geographic proximity to the DRC and covered countries;
•Responsible Minerals Assurance Process - RMAP audit status; and
•Known or plausible evidence of unethical or conflict sourcing.
Per these criteria, the following facilities have been identified as being of highest concern:
• | Tony Goetz NV - CID002587 |
• | Kaloti Precious Metals - CID002563 |
• | African Gold Refinery Limited (AGR) - CID003185 |
• | Universal Precious Metals Refining Zambia - CID002854 |
• | Fidelity Printers and Refiners - CID002515 |
• | Sudan Gold Refinery - CID002567 |
When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to TriMas, up to removal of these red flag smelters from their supply chain.
As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
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 an appropriate effort to determine the mines or locations of origin of the 3TGs in our supply chain. This was done by adopting methodology outlined by the RMI’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.
c) | Design and Implement a Strategy to Respond to Risks |
As part of TriMas’ strategy to mitigate risk and to ensure suppliers understand our expectations, we have provided video, recorded training, and documented instructions through Assent Compliance. Responses to the reporting CMRT were reviewed with specific suppliers where clarification was needed. As described in our Conflict Minerals Policy, we intend to engage any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in the DRC or any adjoining country to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.
Suppliers that may expose the Company to unacceptable risks, either due to unacceptable responses to our inquiries or a refusal to respond, may be evaluated by the SMCC.
d) | Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
TriMas does not have a direct relationship with conflict minerals smelters or refiners and as a result, TriMas does not perform direct audits of these entities in its supply chain. TriMas relies on the efforts of the industry associations that administer independent third-party smelter and refinery audit programs and encourages suppliers with more direct relationships with smelters to participate in comparable due diligence validation activities.
Assent Compliance conducts outreach to all smelters and refineries that are not enrolled in the RMI’s Responsible Minerals Assurance Process - RMAP on behalf of TriMas. The purpose of this outreach is to encourage participation in the RMAP and to inquire about the facility’s sourcing practices and infrastructure.
e) | Report Annually on Supply Chain Due Diligence |
TriMas’ Form SD and CMR are publicly available at www.trimascorp.com and meet the OECD recommendation to report annually on supply chain due diligence.
3) Diligence Results
TriMas identified 437 Tier 1 Suppliers for the CMR for the Reporting Period. Approximately 85% of the Tier 1 suppliers responded to TriMas’ conflict minerals survey and 287 of the responding suppliers indicated one or more of the regulated conflict minerals metals as necessary to the functionality or production of the products supplied to TriMas. Based on the RCOI and the due diligence measures described in this CMR, specifically the fact that most CMRTs are at the company level and not the product level specifically pertaining to TriMas products, TriMas was unable to validate that any of the SORs identified by suppliers are in its supply chain.
The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the SORs identified by our direct suppliers may contain SORs that processed conflict minerals that our direct suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the SORs were used to process the conflict minerals necessary to the functionality or production of our products during 2017. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin identified were the country of origin of conflict minerals in our products during 2017, and therefore also unable to determine the source and chain of custody of those conflict minerals. In addition, the third-party audits conducted by the RMI, the LBMA and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMI Responsible Minerals Assurance Process - RMAP or the LBMA Responsible Gold Programme and, as a result, are not responsible for the quality of these audits or the audit findings.
For all responses that indicated a smelter, Assent Compliance compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as “Conflict-Free,” Assent confirmed that the name was
listed by RMI as a certified smelter. As of May 23, 2018, we have validated 314 SORs and we are working to validate the additional SOR entries from the submitted CMRTs. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any SORs that we have not been able to validate. Appendix 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.
4) Steps to Improve Due Diligence and Mitigate Risk
TriMas will work to continuously improve its supply chain due diligence efforts through the following measures:
a) | Continue supply chain due diligence efforts and engagement with suppliers to identify sources of conflict minerals; |
b) | Continue to clearly communicate expectations with regard to supplier compliance, transparency and sourcing; |
c) | Continue to engage with suppliers that provided incomplete or uncertain smelter information or did not respond to our survey request; |
d) | Continue to compare RCOI results to information collected via independent conflict free smelter validation programs; and |
e) | Contact smelters identified as a result of the RCOI process and request their participation in obtaining a "conflict free" designation from an industry program. |
Forward-Looking Statements
Any "forward-looking" statements, within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934, contained herein, including those relating to the Company's business, financial condition or future results, involve risks and uncertainties with respect to, including, but not limited to: general economic and currency conditions; material and energy costs; risks and uncertainties associated with intangible assets, including goodwill or other intangible asset impairment charges; competitive factors; future trends; the Company's ability to realize its business strategies; the Company's ability to identify attractive acquisition candidates, successfully integrate acquired operations or realize the intended benefits of such acquisitions; the performance of subcontractors and suppliers; supply constraints; market demand; technology factors; intellectual property factors; litigation; government and regulatory actions; the Company's leverage; liabilities imposed by debt instruments; labor disputes; changes to fiscal and tax policies; contingent liabilities relating to acquisition activities; information technology factors; the disruption of operations from catastrophic or extraordinary events, including natural disasters; the potential impact of Brexit; tax considerations relating to the Cequent spin-off; the Company's future prospects; and other risks that are detailed in the Company's Annual Report on Form 10-K for the fiscal year ended December 31, 2017. These risks and uncertainties may cause actual results to differ materially from those indicated by the forward-looking statements. All forward-looking statements made herein are based on information currently available, and the Company assumes no obligation to update any forward-looking statements.
APPENDIX A
In connection with our reasonable country of origin inquiry and due diligence, as applicable, our suppliers identified to us the smelters and refiners listed below as potentially having processed the necessary 3TG contained in our products in 2017. All information included in the table is as of May 23, 2018.
Any facility reported by a supplier to us as a smelter was cross-referenced with the RMI Standard Smelter List that accompanied version 5.01 of the CMRT. There were 314 legitimate smelters identified. Of these, 255 have been certified compliant to RMAP sourcing audit assessment protocol and are considered "conflict-free." An additional 8 facilities are active in the RMAP audit process. The remaining 51 facilities are not currently engaged with the RMAP audit program but have been contacted by Assent on our behalf to encourage them to undertake such an audit.
The large majority of the responses we received from the supplier survey provided data at a company or divisional level or were unable to specify the smelters or refiners used for components supplied to us. We are therefore unable to determine whether the 3TG’s reported by the suppliers were contained in components or parts supplied to us. Therefore, we were unable to validate that any of these smelters or refiners listed here are actually in our supply chain.
Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Gold | Abington Reldan Metals, LLC | UNITED STATES | Not Enrolled |
Gold | Advanced Chemical Company | UNITED STATES | Conformant |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Conformant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Conformant |
Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
Gold | Asahi Pretec Corp. | JAPAN | Conformant |
Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
Gold | Asahi Refining USA Inc. | UNITED STATES | Conformant |
Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Not Enrolled |
Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant |
Gold | Aurubis AG | GERMANY | Conformant |
Gold | Bangalore Refinery | INDIA | Active |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
Gold | Boliden AB | SWEDEN | Conformant |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
Gold | Caridad | MEXICO | Not Enrolled |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
Gold | Cendres + Métaux S.A. | SWITZERLAND | Conformant |
Gold | Chimet S.p.A. | ITALY | Conformant |
Gold | Chugai Mining | JAPAN | Not Enrolled |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not Enrolled |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not Enrolled |
Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant |
Gold | Dowa | JAPAN | Conformant |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant |
Gold | Elemetal Refining, LLC | UNITED STATES | Not Enrolled |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Not Enrolled |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Not Enrolled |
Gold | Geib Refining Corporation | UNITED STATES | Conformant |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not Enrolled |
Gold | Guangdong Jinding Gold Limited | CHINA | Not Enrolled |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not Enrolled |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not Enrolled |
Gold | HeeSung | KOREA, REPUBLIC OF | Conformant |
Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not Enrolled |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Not Enrolled |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
Gold | Istanbul Gold Refinery | TURKEY | Conformant |
Gold | Italpreziosi | ITALY | Conformant |
Gold | Japan Mint | JAPAN | Conformant |
Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Conformant |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Not Enrolled |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not Enrolled |
Gold | Kazzinc | KAZAKHSTAN | Conformant |
Gold | Kennecott Utah Copper LLC | UNITED STATES | Conformant |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Active |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Not Enrolled |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Not Enrolled |
Gold | Lingbao Gold Co., Ltd. | CHINA | Not Enrolled |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not Enrolled |
Gold | L'Orfebre S.A. | ANDORRA | Active |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not Enrolled |
Gold | Marsam Metals | BRAZIL | Conformant |
Gold | Materion | UNITED STATES | Conformant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
Gold | Metalor USA Refining Corporation | UNITED STATES | Conformant |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Conformant |
Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
Gold | Modeltech Sdn Bhd | MALAYSIA | Active |
Gold | Morris and Watson | NEW ZEALAND | Not Enrolled |
Gold | Morris and Watson Gold Coast | AUSTRALIA | Not Enrolled |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | TURKEY | Conformant |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Not Enrolled |
Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Conformant |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant |
Gold | PAMP S.A. | SWITZERLAND | Conformant |
Gold | Pease & Curren | UNITED STATES | Not Enrolled |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not Enrolled |
Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
Gold | PX Précinox S.A. | SWITZERLAND | Conformant |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Not Enrolled |
Gold | Remondis Argentia B.V. | NETHERLANDS | Active |
Gold | Republic Metals Corporation | UNITED STATES | Conformant |
Gold | Royal Canadian Mint | CANADA | Conformant |
Gold | SAAMP | FRANCE | Conformant |
Gold | Sabin Metal Corp. | UNITED STATES | Not Enrolled |
Gold | Safimet S.p.A | Italy | Conformant |
Gold | SAFINA A.S. | CZECH REPUBLIC | Active |
Gold | Sai Refinery | INDIA | Not Enrolled |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Not Enrolled |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant |
Gold | Schone Edelmetaal B.V. | NETHERLANDS | Conformant |
Gold | SEMPSA Joyería Platería S.A. | SPAIN | Conformant |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not Enrolled |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
Gold | Singway Technology Co., Ltd. | TAIWAN | Conformant |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant |
Gold | Solar Applied Materials Technology Corp. | TAIWAN | Conformant |
Gold | State Research Institute Center for Physical Sciences & Technology | LITHUANIA | Not Enrolled |
Gold | Sudan Gold Refinery | SUDAN | Not Enrolled |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
Gold | SungEel HiTech | KOREA, REPUBLIC OF | Conformant |
Gold | T.C.A S.p.A | ITALY | Conformant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not Enrolled |
Gold | Tony Goetz NV | BELGIUM | Not Enrolled |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Not Enrolled |
Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
Gold | Umicore Brasil Ltda. | BRAZIL | Conformant |
Gold | Umicore Precious Metals Thailand | THAILAND | Conformant |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
Gold | United Precious Metal Refining, Inc. | UNITED STATES | Conformant |
Gold | Universal Precious Metals Refining Zambia | ZAMBIA | Not Enrolled |
Gold | Valcambi S.A. | SWITZERLAND | Conformant |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Conformant |
Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Conformant |
Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not Enrolled |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | D Block Metals, LLC | UNITED STATES | Conformant |
Tantalum | Duoluoshan | CHINA | Not Enrolled |
Tantalum | Exotech Inc. | UNITED STATES | Conformant |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Conformant |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
Tantalum | H.C. Starck Inc. | UNITED STATES | Conformant |
Tantalum | H.C. Starck Ltd. | JAPAN | Conformant |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | KEMET Blue Metals | MEXICO | Conformant |
Tantalum | KEMET Blue Powder | UNITED STATES | Conformant |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Conformant |
Tantalum | LSM Brasil S.A. | BRAZIL | Conformant |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
Tantalum | NPM Silmet AS | ESTONIA | Conformant |
Tantalum | Power Resources Ltd. | MACEDONIA | Conformant |
Tantalum | QuantumClean | UNITED STATES | Conformant |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Conformant |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant |
Tantalum | Taki Chemicals | JAPAN | Conformant |
Tantalum | Telex Metals | UNITED STATES | Conformant |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Conformant |
Tin | Alpha | UNITED STATES | Conformant |
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM | Not Enrolled |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not Enrolled |
Tin | CV Ayi Jaya | INDONESIA | Conformant |
Tin | CV Dua Sekawan | INDONESIA | Conformant |
Tin | CV Gita Pesona | INDONESIA | Conformant |
Tin | CV Tiga Sekawan | INDONESIA | Conformant |
Tin | CV United Smelting | INDONESIA | Conformant |
Tin | CV Venus Inti Perkasa | INDONESIA | Conformant |
Tin | Dowa | JAPAN | Conformant |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM | Not Enrolled |
Tin | EM Vinto | BOLIVIA | Conformant |
Tin | Estanho de Rondônia S.A. | BRAZIL | Not Enrolled |
Tin | Fenix Metals | POLAND | Conformant |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant |
Tin | Gejiu Jinye Mineral Company | CHINA | Conformant |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Not Enrolled |
Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | CHINA | Conformant |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Conformant |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant |
Tin | Metallic Resources, Inc. | UNITED STATES | Conformant |
Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
Tin | Metallo Spain S.L.U. | SPAIN | Conformant |
Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
Tin | Minsur | PERU | Conformant |
Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
Tin | Modeltech Sdn Bhd | MALAYSIA | Active |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM | Not Enrolled |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
Tin | Operaciones Metalurgical S.A. | BOLIVIA | Conformant |
Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant |
Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
Tin | PT Babel Inti Perkasa | INDONESIA | Conformant |
Tin | PT Bangka Prima Tin | INDONESIA | Conformant |
Tin | PT Bangka Tin Industry | INDONESIA | Conformant |
Tin | PT Belitung Industri Sejahtera | INDONESIA | Conformant |
Tin | PT Bukit Timah | INDONESIA | Conformant |
Tin | PT DS Jaya Abadi | INDONESIA | Conformant |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Conformant |
Tin | PT Inti Stania Prima | INDONESIA | Conformant |
Tin | PT Karimun Mining | INDONESIA | Conformant |
Tin | PT Kijang Jaya Mandiri | INDONESIA | Conformant |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Conformant |
Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
Tin | PT O.M. Indonesia | INDONESIA | Conformant |
Tin | PT Panca Mega Persada | INDONESIA | Conformant |
Tin | PT Premium Tin Indonesia | INDONESIA | Conformant |
Tin | PT Prima Timah Utama | INDONESIA | Conformant |
Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
Tin | PT Sukses Inti Makmur | INDONESIA | Conformant |
Tin | PT Sumber Jaya Indah | INDONESIA | Conformant |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Conformant |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Conformant |
Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant |
Tin | PT Tommy Utama | INDONESIA | Conformant |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
Tin | Rui Da Hung | TAIWAN | Conformant |
Tin | Soft Metais Ltda. | BRAZIL | Conformant |
Tin | Super Ligas | Brazil | Not Enrolled |
Tin | Thaisarco | THAILAND | Conformant |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM | Not Enrolled |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Conformant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
Tin | Yunnan Tin Company Limited | CHINA | Conformant |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Conformant |
Tungsten | ACL Metais Eireli | BRAZIL | Conformant |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | Conformant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Active |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Not Enrolled |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Conformant |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Conformant |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Conformant |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Not Enrolled |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not Enrolled |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Kennametal Fallon | UNITED STATES | Conformant |
Tungsten | Kennametal Huntsville | UNITED STATES | Conformant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Conformant |
Tungsten | Niagara Refining LLC | UNITED STATES | Conformant |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM | Conformant |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Conformant |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | Conformant |
Tungsten | Unecha Refractory Metals Plant | RUSSIAN FEDERATION | Conformant |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | Conformant |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Conformant |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Conformant |
Appendix A - Countries of Origin
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.
Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe