UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Xylem Inc.
(Exact name of the registrant as specified in its charter)
| Indiana | 001-35229 | 45-2080495 | ||||||||||||
| (State or other jurisdiction | (Commission | (IRS Employer | ||||||||||||
| of incorporation or organization) | File Number) | Identification No.) | ||||||||||||
| 1 International Drive, Rye Brook, New York | 10573 | |||||||
| (Address of principle executive offices) | (Zip code) | |||||||
| Kelly C. O'Shea | 914-323-5783 | |||||||
(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:
| ý | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020. | ||||
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Xylem Inc. (the “Company”) has filed a copy of its Conflict Minerals Report for the calendar year ended December 31, 2020 as Exhibit 1.01 to this Specialized Disclosure Form (Form SD). The Conflict Minerals Report is publicly available on the Company’s website at www.xyleminc.com under “Investors – Access Financial Information – SEC Filings.”
Item 1.02 Exhibit
The Company’s Conflict Minerals Report for calendar year 2020 is filed as Exhibit 1.01 to this Form and is incorporated by reference.
Section 2 - Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| Date: May 27, 2021 | XYLEM INC. | |||||||||||||
| /s/ Kelly C. O'Shea | ||||||||||||||
| VP, Chief Corporate Counsel and Assistant Corporate Secretary | ||||||||||||||
Exhibit 1.01
Xylem Inc.
Conflict Minerals Report
For the Year Ended December 31, 2020
Xylem Inc. (the “Company”) has prepared this Report for the year ended December 31, 2020 to satisfy the requirements of Rule 13p-1 of the Securities Exchange Act of 1934 relating to conflict minerals (the “Rule”). The term "conflict minerals" is defined in the Rule as cassiterite, columbite-tantalite (coltan), wolframite, and their derivatives, tin, tantalum, tungsten, and gold (“conflict minerals” or “3TG”); or any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo ("DRC") or any adjoining country that shares an internationally recognized border with the DRC. For the purpose of this Report, the adjoining countries and the DRC are referred to as the “Covered Countries.”
Company and Product Overview
Xylem is a leading global water technology company. Xylem designs, manufactures and services highly engineered products and solutions across a wide variety of critical applications primarily in the water sector, but also in energy. Our broad portfolio of products, services and solutions addresses customer needs across the water cycle, from the delivery, measurement and use of drinking water, to the collection, testing, analysis and treatment of wastewater, to the return of water to the environment. We sell our products in approximately 150 countries to a diverse customer base through a global distribution network consisting of our direct sales force and independent channel partners.
We have three reportable business segments that are aligned around the critical market applications they provide: Water Infrastructure, Applied Water and Measurement & Control Solutions. Our Water Infrastructure segment primarily supports the process that collects water from a source, treats it and distributes it to users and then treats and returns the wastewater responsibly to the environment through two closely linked applications: Transport and Treatment. Our Water Infrastructure segment offers a range of products including water and wastewater pumps, treatment equipment, and controls and systems. Our Applied Water segment encompasses the uses of water in two primary applications: Building Services and Industrial Water. These applications serve a diverse set of customers in commercial, residential and industrial end markets. Our Applied Water segment’s major products include pumps, valves, heat exchangers, controls and dispensing equipment. Our Measurement & Control Solutions segment develops advanced technology solutions that enable intelligent use and conservation of critical water and energy resources. Our Measurement & Control Solutions segment delivers communications, smart metering, measurement and control technologies, critical infrastructure technologies, analytical instrumentation, software and services including cloud-based analytics, remote monitoring and data management, leak detection, condition assessment, asset management, and pressure monitoring solutions.
We have manufacturing facilities in numerous countries producing thousands of parts. Our facilities procure materials and products globally and regionally, that are then assembled into our products or are resold. There are multiple tiers in our supply chain and we do not have a direct relationship with smelters and refiners. As such, we rely on our direct suppliers to provide information on the existence of, and the origin of, any 3TG contained in components and materials supplied to us, including the sources of any 3TG that are supplied to them from their supply chains. Our direct suppliers similarly rely on information provided by their suppliers.
We have adopted a Conflict Minerals Policy Statement ("Policy") that applies to all of our suppliers. This Policy articulates our conflict minerals supply chain due diligence process and our commitment to our reporting obligations regarding conflict minerals. Our Policy is available on our website at https://www.xylem.com/en-us/about-xylem/conflict-minerals-policy-statement/.
Reasonable Country of Origin Inquiry
We determined that 3TGs were necessary to the functionality and production of some of our products manufactured during the 2020 calendar year. Accordingly, we conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether the 3TGs may have originated in the Covered Countries and whether the minerals may have come from recycled or scrap sources.
We conducted an engineering analysis of the products we manufacture or contract to manufacture to identify products and components used in our manufacturing process that contain, or had a high probability of containing, one or more 3TG. Our engineering departments then worked with sourcing departments across the Company to identify the associated direct suppliers (the “in-scope suppliers”) that provide the Company with those products. We reviewed our supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the conflict minerals survey process, based on the following criteria:
•The supplier supplies packaging only (excluding labels).
•The supplier supplies the Company with items that do not end up in our products (including equipment used to make our products).
•The supplier is a test lab.
•The supplier is a service provider only.
To assist in determining whether necessary 3TG in our products originated in Covered Countries, we retained Assent Compliance (“Assent”), a third-party service provider, to assist us in reviewing our supply chain.
We provided a list of in-scope suppliers to Assent for upload to its Assent Compliance Manager tool (“ACM”). Assent's ACM is a SaaS platform that enables its users to complete and track supplier communications as well as allow suppliers to upload completed Conflict Minerals Reporting Templates ("CMRTs") directly to the platform for assessment and management. Via the ACM, we contacted and conducted a survey of 4,495 in-scope suppliers using version 6.01 of the CMRT maintained by the Responsible Minerals Initiative ("RMI"). Assent requested that all in-scope suppliers complete a CMRT and included training and education resources to guide suppliers on best practices and the use of the CMRT template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. Assent’s program also includes automated data validation on all submitted CMRTs. The goal of data validation was to increase the accuracy of submissions and identify any contradictory answers in the CMRTs.
All submitted CMRTs are accepted and classified as valid or invalid and all data is retained. Suppliers with invalid or incomplete CMRTs were contacted and encouraged to resubmit a valid or complete form. Suppliers were also provided with guidance on how to correct validation errors. As of April 30, 2021, approximately 2.2% of our in-scope suppliers were classified as submitting invalid or incomplete responses. Included in these responses were suppliers who responded to our inquiry with a response that was in a form other than the CMRT. The percentage of invalid or incomplete responses has increased slightly compared to 1.5% in the prior reporting year.
Assent compared the list of smelters and refiners provided in our in-scope suppliers’ CMRT responses to the lists of smelters maintained by the RMI. If a supplier indicated that a facility was certified as conflict-free, Assent confirmed that the facility was listed on RMI’s list of validated conflict-free smelters and refiners of 3TGs. Our in-scope suppliers identified a total of 332 smelters and refiners that appear on the lists maintained by RMI. Of these 332 smelters and refiners, 237 are validated as conflict-free by RMI or a cross-recognized initiative. Furthermore, based on information provided by RMI, 5 smelters or refiners have agreed to undergo, are currently undergoing, or have failed and may be appealing a third-party audit. Most of the CMRTs received were made on a company or division-level basis, which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TGs contained in our products. Based on our RCOI, we exercised further due diligence on the source and chain of custody of the 3TGs contained in components and products provided by our suppliers, as required by the Rule.
Due Diligence
Our conflict minerals supply chain due diligence program is designed to conform, in all material respects, to the framework in The Organisation for Economic Co-operation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and the related Supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”). We integrated the five steps recommended by the OECD Guidance as follows:
Step 1: Establish Strong Management Systems Regarding Conflict Minerals
• | We established a cross-functional team to implement and manage our conflict minerals compliance program. The team, led by our procurement group, includes representatives from our businesses and subject matter experts in the fields of engineering, information technology, legal, operations and procurement. | ||||
• | We adopted a Conflict Minerals Policy Statement that applies to all of our suppliers. Our Conflict Minerals Policy Statement is publicly available on our website at: https://www.xylem.com/en-US/about-xylem/conflict-minerals-policy-statement/ | ||||
• | Our controls include our Code of Conduct and our Supplier Code of Conduct, both publicly available on our website at https://www.xylem.com/en/about-xylem/, which outline expected behaviors for our employees and suppliers. In addition, we added a compliance clause to new and renewed supplier contracts, stating our expectation that suppliers provide the product content information the Company needs to comply with our conflict minerals reporting obligations. | ||||
• | We have a hotline, called Integrity Line, which provides employees and suppliers with a mechanism to report violations or concerns related to our policies, including our Conflict Minerals Policy Statement, our Code of Conduct and our Supplier Code of Conduct. | ||||
• | We engaged Assent Compliance to assist with supplier engagement, evaluating supply chain information regarding 3TGs and to assist with the development and implementation of additional due diligence steps. | ||||
• | To assist in the continuous improvement of the quality of the responses we received from our suppliers, we used Assent’s Learning Management System, Assent University, and provided all in-scope suppliers access to Assent’s Conflict Minerals training course. | ||||
• | Assent retains all conflict minerals related data and documents, including supplier responses to CMRTs. The information and findings from this process are stored in a database that can be audited by internal or external parties. | ||||
Step 2: Identify and Assess Risk in the Supply Chain
We adopted the RMI’s approach, which attempts to trace the origin of the 3TG provided to us by identifying smelters, refiners, recyclers and scrap supplier sources. As discussed above, we surveyed 4,495 in-scope suppliers using the CMRT in an effort to identify the origin, source and chain of custody of 3TGs contained in our products.
We conducted multiple rounds of follow-up with suppliers who were not responsive to our survey. We reviewed the responses we received against red flag indicators and validation criteria to determine which supplier responses required further engagement. Certain risks were identified automatically through Assent's ACM system based on pre-established criteria. These risks were addressed by Assent's supply chain staff as well as members of our internal conflict minerals team to engage the supplier to gather additional pertinent data.
The primary risk we identified related to the nature of the responses received. Many of the responses provided data at a company or divisional level, or suppliers were unable to specify the smelters or refiners used for 3TG in the components supplied to the Company. Additionally, many suppliers indicated that they received information regarding their supply chains from an average of 82% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
We identified and assessed risks associated with conflict minerals in the supply chain in accordance with OECD Guidelines. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared the facilities listed in the CMRT responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met RMI's definition of a 3TG processing facility that was operational during the 2020 calendar year.
In order to assess the risk that any of these smelters and refiners posed to our supply chain, Assent determined if the smelter or refiner had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process ("RMAP"). We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters and refiners that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter or refiner’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.
Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Assent uses the following factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags:
| • | Geographic proximity to the DRC and the Covered Countries; | ||||||||||||||||||||||
| • | Known mineral source country of origin; | ||||||||||||||||||||||
• | RMAP audit status; | ||||||||||||||||||||||
| • | Credible evidence of unethical or conflict sourcing; and | ||||||||||||||||||||||
• | Peer assessments conducted by credible third-party sources. | ||||||||||||||||||||||
As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by one of the in-scope suppliers surveyed, risk mitigation activities are initiated. Through Assent Compliance, submissions that include facilities with red flags are sent a notice 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 the Company, and escalating up to removal of these red flag smelters from their supply chain.
Step 3: Design and Implement a Strategy to Respond to Identified Risks in our Supply Chain
As discussed under Step 2 above, we reviewed CMRT survey responses against risk-assessment criteria, and worked to resolve any red flags or inconsistencies identified. We evaluated risks on a case-by-case basis; this flexible approach enabled us to provide a risk-appropriate response.
Step 4: Independent Third-Party Audits of Supply Chain Due Diligence
We do not have a direct relationship with smelters or refiners and we do not perform or direct audits of smelters or refiners. We have leveraged the due diligence conducted on smelters and refiners through the RMI’s RMAP. The RMAP uses an independent third-party audit to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials.
Step 5: Publicly Report on our Supply Chain Due Diligence
We report annually on our conflict minerals due diligence program in our Form SD filed with the Securities and Exchange Commission ("SEC") and this related Report, which are publicly available on our website at www.xylem.com under “Investors – Access Financial Information – SEC Filings.”
Results of our RCOI and Due Diligence
For the 2020 reporting year, of the 4,495 in-scope suppliers surveyed, approximately 58% responded (as compared to a 55% response rate for the 2019 reporting year). We have a wide supplier base with varying levels of resources and sophistication and many of our suppliers are not subject to the Rule themselves. The majority of the responses we received provided information at the company or division level and/or did not contain conclusive information. There were also suppliers that were unable to provide information on the smelters or refiners they used for materials supplied to us. Some of our in-scope suppliers reported that they had identified scrap or recycled sources of conflict minerals in their supply chains. In addition, due to the recent impacts of the novel coronavirus (COVID-19) pandemic, some suppliers were unable to respond to the survey.
Based on the information obtained through our RCOI and the due diligence processes described above, for the year ended December 31, 2020, we do not have sufficient information to determine the country of origin for all of the 3TGs contained in or used to manufacture our products. We have provided a list of smelters and refiners that may have been used to process minerals in the Company’s supply chain in the Annex to this Report. The list is based on information reported by some of the Company’s in-scope suppliers. While the list is not
comprehensive, it is also over-inclusive, containing some smelters or refiners that are not definitively in the Company’s supply chain due supplier responses at the company level.
Continuous Improvement Efforts to Mitigate Risks
To improve our conflict minerals program and mitigate related risk, we will continue to:
• | Engage with suppliers in an effort to improve the quality of the information we receive and to increase the volume of product-specific responses. | |||||||
• | Work with suppliers who provide incomplete or inconsistent information. | |||||||
• | Refine our scoping approach, so that our efforts will be directed at the most relevant subset of our supply base. | |||||||
• | Communicate to suppliers our expectations regarding compliance with the Company’s Conflict Minerals Policy Statement. | |||||||
• | Conduct due diligence to improve the traceability of the minerals in our products and the overall transparency of our supply chain. | |||||||
Forward-Looking Statements
This Report contains “forward-looking statements”, within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, and the safe harbor provisions of the Private Securities Litigation Act of 1995, that are based on our current expectations and assumptions. Forward-looking statements by their nature address matters that are, to different degrees, uncertain. Forward-looking statements include any statements that are not historical and include the statements made under the heading “Continuous Improvement Efforts to Mitigate Risks”. All forward-looking statements made in this Report are based on information currently available to the Company as of the date of this Report. The Company undertakes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise, except as required by law. In addition, forward-looking statements are subject to certain risks and uncertainties that could cause actual results to differ materially from the Company’s historical experience and its present expectations. Many of these risks and uncertainties are currently amplified by and may continue to be amplified by, or in the future may be amplified by, the novel coronavirus (COVID-19) pandemic or other actual or potential epidemics, pandemics or global health crises. These risks and uncertainties include, but are not limited to, the challenges associated with understanding our entire supply chain to reach the source of conflict minerals; the continued implementation of satisfactory traceability and other compliance measures by the Company and by our direct and indirect suppliers on a timely basis, or at all; the impact of changes in laws and regulations, and the interpretation thereof, and in political conditions; the impact of restructuring activities and the reorganizations of our operations; the impact of acquisitions, divestitures, joint ventures and other transactions; other factors beyond our control; and also include those risks set out under the heading “Item 1A. Risk Factors” in our Annual Report on Form 10-K for the year ended December 31, 2020 and with subsequent filings we make with the SEC.
ANNEX
| Metal | Standard Smelter Name | Smelter Facility Location | ||||||
| Gold | 8853 S.p.A. | ITALY | ||||||
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||||||
| Gold | African Gold Refinery | UGANDA | ||||||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||||||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | Alexy Metals | UNITED STATES OF AMERICA | ||||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||||||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | ||||||
| Gold | Asahi Pretec Corp. | JAPAN | ||||||
| Gold | Asahi Refining Canada Ltd. | CANADA | ||||||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||||||
| Gold | AU Traders and Refiners | SOUTH AFRICA | ||||||
| Gold | Augmont Enterprises Private Limited | INDIA | ||||||
| Gold | Aurubis AG | GERMANY | ||||||
| Gold | Bangalore Refinery | INDIA | ||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||||||
| Gold | Boliden AB | SWEDEN | ||||||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | ||||||
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | ||||||
| Gold | Caridad | MEXICO | ||||||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||||||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | ||||||
| Gold | CGR Metalloys Pvt Ltd. | INDIA | ||||||
| Gold | Chimet S.p.A. | ITALY | ||||||
| Gold | Chugai Mining | JAPAN | ||||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||||||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||||||
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||||||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||||||
| Gold | Dowa | JAPAN | ||||||
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | ||||||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||||||
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | ||||||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||||||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | Gold Coast Refinery | GHANA | ||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||||||
| Gold | Guangdong Jinding Gold Limited | CHINA | ||||||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||||||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||||||
| Gold | Heimerle + Meule GmbH | GERMANY | ||||||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||||||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||||||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | ||||||
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||||||
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | ||||||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold | Istanbul Gold Refinery | TURKEY | ||||||
| Gold | Italpreziosi | ITALY | ||||||
| Gold | JALAN & Company | INDIA | ||||||
| Gold | Japan Mint | JAPAN | ||||||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | ||||||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | ||||||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||||||
| Gold | K.A. Rasmussen | NORWAY | ||||||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||||||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||||||
| Gold | Kazzinc | KAZAKHSTAN | ||||||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||||||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||||||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Kundan Care Products Ltd. | INDIA | ||||||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||||||
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | ||||||
| Gold | Lingbao Gold Co., Ltd. | CHINA | ||||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||||||
| Gold | L'Orfebre S.A. | ANDORRA | ||||||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||||||
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||||||
| Gold | Marsam Metals | BRAZIL | ||||||
| Gold | Materion | UNITED STATES OF AMERICA | ||||||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||||||
| Gold | MD Overseas | INDIA | ||||||
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | ||||||
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||||||
| Gold | Metalor Technologies S.A. | SWITZERLAND | ||||||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||||||
| Gold | Mitsubishi Materials Corporation | JAPAN | ||||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||||||
| Gold | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Gold | Morris and Watson | NEW ZEALAND | ||||||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||||||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||||
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | ||||||
| Gold | Nihon Material Co., Ltd. | JAPAN | ||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||||||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||||||
| Gold | PAMP S.A. | SWITZERLAND | ||||||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | ||||||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||||||
| Gold | Planta Recuperadora de Metales SpA | CHILE | ||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||||||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||||||
| Gold | PX Precinox S.A. | SWITZERLAND | ||||||
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | ||||||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||||||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | ||||||
| Gold | REMONDIS PMR B.V. | NETHERLANDS | ||||||
| Gold | Royal Canadian Mint | CANADA | ||||||
| Gold | SAAMP | FRANCE | ||||||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||||||
| Gold | Safimet S.p.A | ITALY | ||||||
| Gold | SAFINA A.S. | CZECH REPUBLIC | ||||||
| Gold | Sai Refinery | INDIA | ||||||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||||
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||||||
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | ||||||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||||||
| Gold | Sellem Industries Ltd. | MAURITANIA | ||||||
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||||||
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | ||||||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||||||
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | ||||||
| Gold | Shirpur Gold Refinery Ltd. | INDIA | ||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||||||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||||||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold | Sovereign Metals | INDIA | ||||||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||||||
| Gold | Sudan Gold Refinery | SUDAN | ||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||||||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | T.C.A S.p.A | ITALY | ||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||||||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||||||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||||||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||||||
| Gold | Tony Goetz NV | BELGIUM | ||||||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||||||
| Gold | Torecom | KOREA, REPUBLIC OF | ||||||
| Gold | Umicore Precious Metals Thailand | THAILAND | ||||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||||||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Valcambi S.A. | SWITZERLAND | ||||||
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||||||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | ||||||
| Gold | Yamakin Co., Ltd. | JAPAN | ||||||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | ||||||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||||||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | ||||||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | ||||||
| Tantalum | Global Advanced Metals Aizu | JAPAN | ||||||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||||||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||||||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | ||||||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||||||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | H.C. Starck Ltd. | JAPAN | ||||||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||||||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | ||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | ||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | KEMET Blue Metals | MEXICO | ||||||
| Tantalum | LSM Brasil S.A. | BRAZIL | ||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||||||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||||||
| Tantalum | NPM Silmet AS | ESTONIA | ||||||
| Tantalum | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | ||||||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||||||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||||||
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||||||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | ||||||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tin | Alpha | UNITED STATES OF AMERICA | ||||||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||||||
| Tin | China Tin Group Co., Ltd. | CHINA | ||||||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | ||||||
| Tin | CRM Synergies | SPAIN | ||||||
| Tin | CV Ayi Jaya | INDONESIA | ||||||
| Tin | CV Venus Inti Perkasa | INDONESIA | ||||||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||||||
| Tin | Dowa | JAPAN | ||||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||||||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin | Estanho de Rondonia S.A. | BRAZIL | ||||||
| Tin | Fenix Metals | POLAND | ||||||
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||||||
| Tin | Luna Smelter, Ltd. | RWANDA | ||||||
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | ||||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | ||||||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||||||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | ||||||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||||||
| Tin | Metallo Belgium N.V. | BELGIUM | ||||||
| Tin | Metallo Spain S.L.U. | SPAIN | ||||||
| Tin | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tin | Minsur | PERU | ||||||
| Tin | Mitsubishi Materials Corporation | JAPAN | ||||||
| Tin | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | ||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||||||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||||||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin | Pongpipat Company Limited | MYANMAR | ||||||
| Tin | Precious Minerals and Smelting Limited | INDIA | ||||||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | ||||||
| Tin | PT Artha Cipta Langgeng | INDONESIA | ||||||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||||||
| Tin | PT Babel Inti Perkasa | INDONESIA | ||||||
| Tin | PT Babel Surya Alam Lestari | INDONESIA | ||||||
| Tin | PT Bangka Serumpun | INDONESIA | ||||||
| Tin | PT Bukit Timah | INDONESIA | ||||||
| Tin | PT Cipta Persada Mulia | INDONESIA | ||||||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | ||||||
| Tin | PT Menara Cipta Mulia | INDONESIA | ||||||
| Tin | PT Mitra Stania Prima | INDONESIA | ||||||
| Tin | PT Mitra Sukses Globalindo | INDONESIA | ||||||
| Tin | PT Prima Timah Utama | INDONESIA | ||||||
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | ||||||
| Tin | PT Rajehan Ariq | INDONESIA | ||||||
| Tin | PT Refined Bangka Tin | INDONESIA | ||||||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | ||||||
| Tin | PT Sukses Inti Makmur | INDONESIA | ||||||
| Tin | PT Timah Nusantara | INDONESIA | ||||||
| Tin | PT Timah Tbk Kundur | INDONESIA | ||||||
| Tin | PT Timah Tbk Mentok | INDONESIA | ||||||
| Tin | PT Tinindo Inter Nusa | INDONESIA | ||||||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||||||
| Tin | Soft Metais Ltda. | BRAZIL | ||||||
| Tin | Super Ligas | BRAZIL | ||||||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||||||
| Tin | Thaisarco | THAILAND | ||||||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||||||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | ||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tin | Yunnan Tin Company Limited | CHINA | ||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | A.L.M.T. Corp. | JAPAN | ||||||
| Tungsten | ACL Metais Eireli | BRAZIL | ||||||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||||||
| Tungsten | Artek LLC | RUSSIAN FEDERATION | ||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | China Molybdenum Co., Ltd. | CHINA | ||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||||||
| Tungsten | Cronimet Brasil Ltda | BRAZIL | ||||||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||||||
| Tungsten | GEM Co., Ltd. | CHINA | ||||||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||||||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||||||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | ||||||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||||||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||||||
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | ||||||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||||||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||||||
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | ||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||||||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||||||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||||||