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, 2019. |
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, 2019 to December 31, 2019 (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 29, 2020 | |
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, 2019 to December 31, 2019
TriMas Corporation (TriMas or the Company) is filing this Conflict Minerals Report (CMR) for the reporting period January 1, 2019 to December 31, 2019 (the Reporting Period) as an exhibit to its 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.
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.
To determine whether tin, tantalum, tungsten or gold (3TG) necessary to the functionality or production of supplier products originated in Covered Countries, TriMas retained Assent Compliance (Assent), a third-party service provider, to assist in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager (ACM).
To collect data on the materials’ sources of origin procured by the supply chain, TriMas utilized the Conflict Minerals Reporting Template (CMRT) version 5.12 or higher to conduct a survey of all in-scope suppliers.
During the supplier survey, the Company contacted suppliers via the ACM platform, enabling users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the Organization for Economic Cooperation and Development’s (OECD) Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.
Via the ACM and Assent team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the ACM for future reporting and transparency. TriMas directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to Assent.
The Company’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. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk
assessment, as well as understand the due diligence efforts of tier 1 suppliers. 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. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct validation errors in their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, TriMas tracks program gaps to account for future improvement opportunities.
Based on the findings through the RCOI process, the Company determined the countries of origin for a large portion of the 3TGs in its products. TriMas continued to perform further due diligence on the source and chain of custody of the minerals in question.
Due Diligence
Design of Due Diligence
TriMas’ due diligence process is based on OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements. The OECD Guidance applies to both upstream1 and downstream2 companies in the supply chain. As TriMas is a downstream company in the supply chain, TriMas’ tailored its due diligence practices accordingly. Due diligence measures undertaken by TriMas included those described below.
Due Diligence Performed
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 the TriMas website at .
Assemble an Internal Team to Support Supply Chain Due Diligence
TriMas senior management identified individuals representing multiple TriMas departments and business units to oversee and drive conflict minerals compliance. Together with Assent, 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.
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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.
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 Assent to complement internal management processes. The Assent 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.
Supplier Engagement
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 CMRT to collect conflict minerals declarations from our tier 1 suppliers. These declarations were uploaded into the ACM 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.
TriMas places a strong emphasis on supplier education and training. To accomplish this, we utilize Assent’s Learning Management System, Assent University, and provide 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.
To complete the RCOI, TriMas’ in-scope 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 CMRT or by completing an online survey version of the template directly to a third-party platform operated by Assent.
During the supplier survey, suppliers were contacted via the ACM, operated by Assent, enabling 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 the information provided was at the company level or the product level. Non-responsive suppliers were contacted a minimum of six times by ACM and then were also
managed by the Assent supply chain team in one-on-one communications. This included two follow-ups from the supply chain team. For the 2019 reporting period, TriMas received responses from 554 or 72.4% of its 765 surveyed suppliers. Of the 554 suppliers that provided a response, approximately 38 reported that their products contained 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. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. For the 2019 reporting period, TriMas had 5 invalid CMRTs, or .65% of submitted responses.
As mentioned above, the CMRTs received allowed TriMas to collect and compile, via ACM, 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.
Information Cut-Off
The deadline for suppliers to submit RCOI information for the Reporting Period was May 19, 2020.
Grievance Mechanism
We have established reporting mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Conflict Minerals Policy through the ethics hotline on our website at www.trimascorp.com
Records Maintenance
Under our Records Retention Policy, compliance records are maintained for 10 years.
Identify and Assess Risk in Our Supply Chain
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 RMI or the London Bullion Market Association (LBMA) Responsible Gold Programme, may pose a 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 Covered Countries 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, 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 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 certified Covered Country-Conflict Free may pose a risk to the supply chain. Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
• | Geographic proximity to the Covered Countries; |
• | Known mineral source country of origin; |
• | RMAP audit status; |
• | Credible evidence of unethical or conflict sourcing; |
• | Peer Assessments conducted by credible third-party sources. |
As part of our risk management plan under the OECD Guidance, when facilities with red flags are reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent, submissions that include any red flag 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, and escalating 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 for 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.
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. 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 Covered Countries 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 Company.
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 conducts outreach to all smelters and refineries that are not enrolled in the RMI’s 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.
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.
Due Diligence Results
TriMas identified 765 Tier 1 Suppliers for the CMR for the Reporting Period. Approximately 72.4% responded to TriMas’ conflict minerals survey and 38 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 that most CMRTs are at the company level and not the product level 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 2019. 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 2019, and therefore we were 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 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 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 25, 2020, we have validated 365 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.
In connection with our reasonable country of origin inquiry and due diligence, as applicable, our suppliers identified to us the smelters and refiners listed in Appendix A as potentially having processed the necessary 3TG contained in our products in 2019. All information included in the table is as of May 19, 2020.
Any facility reported by a supplier to us as a smelter was cross-referenced with the RMI Standard Smelter List. There were 307 legitimate smelters identified. Of these, 235 have been certified compliant to RMAP sourcing audit assessment protocol and are considered "conflict-free." An additional 7 facilities are active in the RMAP audit process. The remaining 58 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.
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. |
Countries of Origin
Appendix A includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. As mentioned previously, it is understood that many responses may provide more data than can be directly linked to products sold by TriMas, therefore, Appendix A may contain more countries than those that the Company’s products are being sourced from.
Smelter and Refiner Risk Evaluation
Understanding the risks associated with the smelters and refiners potentially providing material into TriMas’ supply chain is an important part of the due diligence process. Through Assent, comprehensive and ongoing analysis is conducted by Assent’s smelter library manager to assess sourcing risk. This information is used to:
• | Provide supplier feedback |
• | Determine the health of the Company’s overall program |
• | Conduct outreach to smelters, refiners and their respective associations |
• | Provide detailed analysis in this report. |
The following risk categories are used for smelter evaluation and risk determination:
▪ | Geo-Risk |
◦ | Did the mineral originate from or has been transported through a Covered Country? |
• | Audit Status |
◦ | Has the refiner’s due diligence practices been audited against a standard in conformance with the OECD Guidance? |
◦ | Assent relies on the RMI audit standard, including cross-recognition of the LBMA Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance. |
• | Sourcing Risk |
◦ | Has evidence of any other red flag that is supported by credible sources been identified? |
Forward-Looking Statements
This report may contain 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 about our financial condition, results of operations and business. These forward-looking statements can be identified by the use of forward-looking words, such as “may,” “could,” “should,” “estimate,” “project,” “forecast,” “intend,” “expect,” “anticipate,” “believe,” “target,” “plan” or other comparable words, or by discussions of strategy that may involve risks and uncertainties.
These forward-looking statements are subject to numerous assumptions, risks and uncertainties which could materially affect our business, financial condition or future results including, but not limited to: the severity and duration of the ongoing corona virus (“COVID-19”) pandemic on our operations, customers and suppliers, as well as related actions taken by governmental authorities and other third parties in response, each of which is uncertain, rapidly changing and difficult to predict; 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; our ability to realize our business strategies; our ability to identify attractive acquisition candidates, successfully integrate acquired operations or realize the intended benefits of such acquisitions; information technology and other cyber-related risks; the performance of our subcontractors and suppliers; supply constraints; market demand; intellectual property factors; litigation; government and regulatory actions, including, without limitation, the impact of tariffs, quotas and surcharges; our leverage; liabilities imposed by our debt instruments; labor disputes; changes to fiscal and tax policies; contingent liabilities relating to acquisition activities; the disruption of operations from catastrophic or extraordinary events, including natural disasters or public health crises; the potential impact of Brexit; tax considerations relating to the Cequent spin-off; our future prospects; and other risks that are discussed in Part I, Item 1A, "Risk Factors," in our Annual Report on Form 10-K for the year ended December 31, 2019 and elsewhere in this report. The risks described in our Annual Report on Form 10-K and elsewhere in this report are not the only risks facing our Company. Additional risks and uncertainties not currently known to us or that we currently deemed to be immaterial also may materially adversely affect our business, financial position and results of operations or cash flows.
The cautionary statements set forth above should be considered in connection with any subsequent written or oral forward-looking statements that we or persons acting on our behalf may issue. We caution readers not to place undue reliance on the statements, which speak only as of the date of this report. We do not undertake any obligation to review or confirm analysts' expectations or estimates or to release publicly any revisions to any forward-looking statement to reflect events or circumstances after the date of this report or to reflect the occurrence of unanticipated events, except as required by law.
APPENDIX A
Standard Smelter Name | Smelter Facility Location | Smelter ID | RMI Audit Status | |
Gold | 8853 S.p.A. | ITALY | CID002763 | Conformant |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 | Non Conformant |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 | Conformant |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 | Conformant |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 | 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 | Asahi Refining Canada Ltd. | CANADA | CID000924 | Conformant |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 | Conformant |
Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 | Conformant |
Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 | Conformant |
Gold | Aurubis AG | GERMANY | CID000113 | Conformant |
Gold | Bangalore Refinery | INDIA | CID002863 | 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 | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 | Conformant |
Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 | Conformant |
Gold | Chimet S.p.A. | ITALY | CID000233 | Conformant |
Gold | Chugai Mining | JAPAN | CID000264 | Conformant |
Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 | Conformant |
Gold | Dowa | JAPAN | CID000401 | Conformant |
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | CID003195 | Conformant |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 | Conformant |
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 | Conformant |
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 | Conformant |
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 | Conformant |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | Conformant |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 | Conformant |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 | 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 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | Conformant |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | Conformant |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 | Conformant |
Gold | Italpreziosi | ITALY | CID002765 | Conformant |
Gold | Japan Mint | JAPAN | CID000823 | Conformant |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | Conformant |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | Conformant |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | Conformant |
Gold | Kazzinc | KAZAKHSTAN | CID000957 | Conformant |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 | Conformant |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 | Conformant |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 | Conformant |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 | Conformant |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | Conformant |
Gold | L'Orfebre S.A. | ANDORRA | CID002762 | Conformant |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | Conformant |
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 | Conformant |
Gold | Marsam Metals | BRAZIL | CID002606 | Conformant |
Gold | Materion | UNITED STATES OF AMERICA | CID001113 | Conformant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | Conformant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | Conformant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | Conformant |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | 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 | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | Conformant |
Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 | Non Conformant |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | Conformant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 | Conformant |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 | Non Conformant |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | Conformant |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | 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 | Conformant |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | Conformant |
Gold | PAMP S.A. | SWITZERLAND | CID001352 | Conformant |
Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 | Conformant |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | Conformant |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | Conformant |
Gold | PX Precinox S.A. | SWITZERLAND | CID001498 | Conformant |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | Conformant |
Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 | Conformant |
Gold | Royal Canadian Mint | CANADA | CID001534 | Conformant |
Gold | SAAMP | FRANCE | CID002761 | Conformant |
Gold | Safimet S.p.A | ITALY | CID002973 | Conformant |
Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 | Active |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | Conformant |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 | Conformant |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 | Conformant |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | Conformant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | Conformant |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 | Conformant |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | Conformant |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 | Conformant |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | Conformant |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 | Conformant |
Gold | T.C.A S.p.A | ITALY | CID002580 | Conformant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | Conformant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | Conformant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | Conformant |
Gold | Tony Goetz NV | BELGIUM | CID002587 | Non Conformant |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | Conformant |
Gold | Torecom | KOREA, REPUBLIC OF | CID001955 | Conformant |
Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 | Conformant |
Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | 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 | WIELAND Edelmetalle GmbH | GERMANY | CID002778 | 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 |
Tantalum | Asaka Riken Co., Ltd. | JAPAN | CID000092 | Conformant |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 | Conformant |
Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA | CID003402 | Conformant |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 | Conformant |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | CID000456 | Conformant |
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | Conformant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | Conformant |
Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | Conformant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 | Conformant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | Conformant |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | 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 | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 | Conformant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | Conformant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | Conformant |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | Conformant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | Conformant |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | Conformant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 | Conformant |
Tantalum | KEMET Blue Metals | MEXICO | CID002539 | 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 | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | Conformant |
Tantalum | NPM Silmet AS | ESTONIA | CID001200 | Conformant |
Tantalum | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | CID002847 | Conformant |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 | Conformant |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 | 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 | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 | Conformant |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 | Conformant |
Tin | Alpha | UNITED STATES OF AMERICA | CID000292 | Conformant |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 | Conformant |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 | Conformant |
Tin | China Tin Group Co., Ltd. | CHINA | CID001070 | Conformant |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | CID003356 | Non Conformant |
Tin | Dowa | JAPAN | CID000402 | Conformant |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 | Non Conformant |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 | Conformant |
Tin | Fenix Metals | POLAND | CID000468 | Conformant |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | Conformant |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | Conformant |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 | Conformant |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | Conformant |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 | Conformant |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 | Conformant |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 | Conformant |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 | Conformant |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 | Conformant |
Tin | Luna Smelter, Ltd. | RWANDA | CID003387 | Conformant |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | CID003379 | Conformant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | Conformant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | Conformant |
Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 | Conformant |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 | Conformant |
Tin | Metallo Belgium N.V. | BELGIUM | CID002773 | Conformant |
Tin | Metallo Spain S.L.U. | SPAIN | CID002774 | Conformant |
Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 | Conformant |
Tin | Minsur | PERU | CID001182 | Conformant |
Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 | Conformant |
Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 | Non Conformant |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 | Conformant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | Conformant |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 | Conformant |
Tin | Precious Minerals and Smelting Limited | INDIA | CID003409 | Active |
Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 | Conformant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | Conformant |
Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 | Conformant |
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 | Conformant |
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 | Conformant |
Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 | Conformant |
Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 | Conformant |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 | Conformant |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 | Conformant |
Tin | Soft Metais Ltda. | BRAZIL | CID001758 | Conformant |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | CID002834 | Conformant |
Tin | Thaisarco | THAILAND | CID001898 | Conformant |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 | Conformant |
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 | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 | Conformant |
Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 | Conformant |
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 | Conformant |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 | Active |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | Conformant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 | Conformant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | Conformant |
Tungsten | CP Metals Inc. | UNITED STATES OF AMERICA | CID003448 | Active |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | CID003401 | Conformant |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 | Conformant |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 | Conformant |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 | Conformant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 | Conformant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | Conformant |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 | Conformant |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | Conformant |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 | Conformant |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 | Conformant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | Conformant |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 | Conformant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 | Conformant |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | CID003182 | Conformant |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 | Conformant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | Conformant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 | Conformant |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | Conformant |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 | Conformant |
Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | CID002647 | Active |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 | Conformant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | Conformant |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | CID003408 | Active |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 | Conformant |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 | Conformant |
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | CID003388 | Conformant |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 | Conformant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 | Conformant |
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | CID002543 | Conformant |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 | Conformant |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 | Conformant |
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | CID003416 | Active |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 | Conformant |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 | Conformant |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 | Conformant |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 | Conformant |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 | Conformant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | Conformant |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | Conformant |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 | Conformant |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 | Conformant |