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.) | ||||||||||||
| 301 Water Street SE, Washington, DC | 20003 | |||||||
| (Address of principle executive offices) | (Zip code) | |||||||
| Kelly C. O'Shea | 914-874-9196 | |||||||
(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, 2023. | ||||
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, 2023 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.xylem.com under “Investors – Access Financial Information – SEC Filings.”
Item 1.02 Exhibit
The Company’s Conflict Minerals Report for calendar year 2023 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 31, 2024 | XYLEM INC. | |||||||||||||
| /s/ Kelly C. O'Shea | ||||||||||||||
| VP, Chief Corporate Counsel and Corporate Secretary | ||||||||||||||
Exhibit 1.01
Xylem Inc.
Conflict Minerals Report
For the Year Ended December 31, 2023
Xylem Inc. (the “Company”) has prepared this Report for the year ended December 31, 2023 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 ( the "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. Our broad portfolio of products, services and solutions addresses customer needs of scarcity, resilience, quality and affordability across the water cycle, from the delivery, treatment, 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 forces and independent channel partners.
Our business has four reportable segments: Water Infrastructure, Applied Water, Measurement and Control Solutions and Water Solutions and Services. The Water Infrastructure segment focuses on the transportation and treatment of water, offering a range of products including water, wastewater and storm water pumps, controls and systems; treatment equipment: filtration and separation, disinfection, wastewater solutions; anodes and electro chlorination technologies for municipal and industrial applications. The Applied Water segment serves many of the primary uses of water and focuses on the residential, commercial and industrial markets. The Applied Water segment's major products include pumps, valves, heat exchangers, controls and dispensing equipment. The Measurement and Control Solutions segment focuses on developing advanced technology solutions that enable intelligent use and conservation of critical water and energy resources as well as analytical instrumentation used in the testing of water. The Measurement and Control Solutions segment's major products include smart metering, networked communications, measurement and control technologies, critical infrastructure technologies, software and services including cloud-based analytics, and remote monitoring and data management. Effective January 1, 2024, we unified our legacy Integrated Solutions and Services segment, the dewatering business within our Water Infrastructure segment and the assessment services business within our Measurement and Control Solutions segment to form a new segment called Water Solutions and Services. The Water Solutions and Services segment provides tailored services and solutions, in collaboration with customers and backed by life‑cycle services, including on‑demand water, outsourced water, recycle / reuse, specialty dewatering and emergency response service alternatives to improve operational reliability, performance and environmental compliance. Key offerings within this segment also include equipment systems for industrial needs (influent water, boiler feed water, ultrahigh purity, process water, wastewater treatment, and recycle / reuse), full-scale outsourcing of operations and maintenance, and municipal services, including odor and corrosion control services, as well as leak detection, condition assessment and asset management and pressure monitoring solutions.
We have manufacturing facilities in numerous countries producing thousands of parts. Our facilities procure parts, 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 of some of our products, components and parts purchased during the 2023 calendar year. We conducted an engineering analysis of the products we
manufacture or contract to manufacture to identify products, components and parts used in our manufacturing process that contain, or had a high probability of containing, one or more 3TG. Our sourcing departments across the Company worked to identify the associated direct suppliers (the “In-scope Suppliers”) that provide the Company with those products, components and parts. We reviewed our supplier list to see that irrelevant (or “out of scope”) suppliers were removed from the conflict minerals survey process, based on the following criteria:
•The supplier supplies components, parts or products that do not contain 3TG.
•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. Assent considered Reasonable Country of Origin (“RCOI”) 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 provided a list of In-scope Suppliers to Assent for upload to its Assent Sustainability Manager tool (“ASM”). Assent's ASM 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 ASM, we contacted and conducted a survey of 3,396 In-scope Suppliers using 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 ASM for future reporting and transparency. Assent’s program also includes 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 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 29, 2024, approximately 1.4% 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 is slightly less than the prior reporting year (which was approximately 1.6%).
Assent compared the list of smelters and refiners provided in our In-scope Suppliers’ CMRT responses to the lists of known smelters and refiners. If a supplier indicated that a facility was certified as conflict-free, Assent confirmed that the facility was an independently validated conflict-free smelter and refiner of 3TGs. Our In-scope Suppliers identified a total of 351 smelters and refiners that appear on the lists of known smelters and refiners. Of these 351 smelters and refiners, 225 are independently validated as conflict-free by RMI or other cross-recognized initiative. Furthermore, based on information provided by RMI, 36 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.
Appendix A includes an aggregated list of countries of origin from which the 351 identified smelters and refiners collectively source 3TGs, based on reasonable identification of country of origin data obtained via Assent’s supply chain database. Overreporting by the In-scope Suppliers could have occurred which could result in Appendix A listing more countries than those strictly relevant to the Company’s products. Responses from In-scope Suppliers may provide more data than can be linked to our products. As a result, Appendix A may contain more countries than those from which 3TGs used in our products are sourced.
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 Supplier Code of Conduct, both publicly available on our website at https://www.xylem.com/en-us/about-xylem/, which outline expected behaviors for our employees and suppliers. In addition, we added a compliance clause to new and renewed supplier contracts and purchase orders, 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, that 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 the development and implementation of additional due diligence steps.
•The Company continues to place a strong emphasis on supplier education and training. To accomplish this, we leveraged Assent’s online resources and all In-scope Suppliers were provided with access to Assent’s library of conflict minerals training and support resources. Also, Assent’s automated feedback process notified suppliers of risks associated with their CMRT submission to educate suppliers of certain conflict minerals risks.
•Assent retains all conflict minerals-related data and documents in accordance with the recommended retention guidelines of five years, 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 market standard approach, which attempts to trace the origin of the 3TGs provided to us by identifying smelters, refiners, recyclers and scrap supplier sources. As discussed above, we surveyed 3,396 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 ASM 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 3TGs in the components supplied to the Company. Additionally, the majority of suppliers indicated to Assent that they received information regarding their supply chain from at least 75% 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 known smelters and refiners to confirm that the facilities met the definition of a 3TG processing facility that was operational during the 2023 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 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. To each smelter that is currently not conformant to RMAP, Assent is sending a smelter outreach letter on behalf of Xylem to encourage participation in cross-recognized industry audit programs. For those smelters for which Assent does not have direct contact information, Assent will also send this outreach letter to smelters’ respective metals associations.
Each facility that meets the 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;
•Relation to sanctioned individuals and entities;
•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
Together with Assent, Xylem has developed processes to assess the risks identified in the supply chain. As discussed under Step 2 above, we reviewed CMRT survey responses against risk-assessment criteria. We evaluated risks on a case-by-case basis; this flexible approach enabled us to provide a risk-appropriate response. As the due diligence process progressed, escalations were sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance with the conflict minerals rules and the Company’s expectations. Feedback on suppliers’ submissions was given directly to suppliers and educational resources were provided to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers were continuously non-responsive or were not committed to corrective action plans, Xylem may assess if replacing that supplier is feasible. The results of the due diligence and risk assessment were shared with the cross-functional conflict minerals team.
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 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. Of the 351 smelters identified by our suppliers, there were 225 that participated in an independent audit program such as RMAP. For those smelters not participating in an independent audit program, we leverage Assent RCOI data collected through smelter and supply chain engagement, for total coverage of 90 out of 351 smelters. Country of origin data collected on smelters and refiners must have a minimum of 10,000 independent source claims before being allowed into the Assent RCOI library. There were 36 out of 351 smelters that did not participate in an independent audit program or meet the minimum criteria of 10,000 data points to validate their RCOI information.
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 2023 reporting year, of the 3,396 In-scope Suppliers surveyed, approximately 55.9% responded (as compared to a 65.5% response rate for the 2022 reporting year). The response rate for 2023 was driven by factors including lower-than-expected responses from suppliers to the businesses comprising Evoqua Water Technologies Corp., which Xylem acquired on May 24, 2023, as well as the fact that 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. In addition, 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.
Based on the information obtained through our RCOI and the due diligence processes described above, for the year ended December 31, 2023, 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 Appendix B 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 to supplier responses at the company or divisional level. We do not have a direct relationship with smelters and refiners listed in Appendix B.
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. 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, including the acquisition of Evoqua Water Technologies Corp. on May 24, 2023, 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, 2023 and with subsequent filings we make with the SEC.
The content of any website referred to in this Report is included for general information only and is not incorporated by reference in this Report.
| APPENDIX A | ||||||||
| Countries of Origin that Company’s declared smelters are known to source from | ||||||||
| Albania | Germany | Norway | ||||||
| Andorra | Ghana | Panama | ||||||
| Angola | Guam | Papua New Guinea | ||||||
| Argentina | Guatemala | Peru | ||||||
| Armenia | Guinea | Philippines | ||||||
| Australia | Guyana | Poland | ||||||
| Austria | Honduras | Portugal | ||||||
| Azerbaijan | Hong Kong | Oman | ||||||
| Belarus | Hungary | Russian Federation | ||||||
| Belgium | India | Rwanda | ||||||
| Benin | Indonesia | Saudi Arabia | ||||||
| Bermuda | Ireland | Senegal | ||||||
| Bolivia (Plurinational State of) | Israel | Serbia | ||||||
| Botswana | Italy | Sierra Leone | ||||||
| Brazil | Ivory Coast | Singapore | ||||||
| Bulgaria | Japan | Slovakia | ||||||
| Burkina Faso | Jersey | Solomon Islands | ||||||
| Burundi | Kazakhstan | South Africa | ||||||
| Cambodia | Kenya | South Sudan | ||||||
| Canada | Korea | Spain | ||||||
| Central African Republic | Kyrgyzstan | Sudan | ||||||
| Chile | Liberia | Suriname | ||||||
| China | Liechtenstein | Sweden | ||||||
| Colombia | Lithuania | Switzerland | ||||||
| Congo | Luxembourg | Taiwan | ||||||
| Cyprus | Madagascar | Tajikistan | ||||||
| Democratic Republic of Congo | Malaysia | Tanzania | ||||||
| Djibouti | Mali | Thailand | ||||||
| Dominica | Mauritania | Togo | ||||||
| Dominican Republic | Mexico | Turkey | ||||||
| Ecuador | Mongolia | Uganda | ||||||
| Egypt | Morocco | United Arab Emirates | ||||||
| El Salvador | Mozambique | United Kingdom | ||||||
| Eritrea | Myanmar | United States | ||||||
| Estonia | Namibia | Uruguay | ||||||
| Ethiopia | Netherlands | Uzbekistan | ||||||
| Fiji | New Zealand | Viet Nam | ||||||
| Finland | Nicaragua | Zambia | ||||||
| France | Niger | |||||||
| Georgia | Nigeria | |||||||
| APPENDIX B | ||||||||
| Metal | Standard Smelter Name | Smelter Facility Location | ||||||
| Gold | Aida Chemical Industries Co., Ltd. | Japan | ||||||
| Gold | Agosi AG | 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 | Asaka Riken Co., Ltd. | Japan | ||||||
| Gold | Aurubis AG | Germany | ||||||
| Gold | Boliden AB | Sweden | ||||||
| Gold | C. Hafner GmbH + Co. KG | Germany | ||||||
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | ||||||
| Gold | Chimet S.p.A. | Italy | ||||||
| Gold | Chugai Mining | Japan | ||||||
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of | ||||||
| Gold | Dowa | Japan | ||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | ||||||
| Gold | LT Metal Ltd. | Korea, Republic Of | ||||||
| Gold | Heimerle + Meule GmbH | Germany | ||||||
| Gold | Heraeus Metals Hong Kong Ltd. | China | ||||||
| Gold | Heraeus Germany GmbH Co. KG | Germany | ||||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | ||||||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | ||||||
| Gold | Istanbul Gold Refinery | Turkey | ||||||
| Gold | Japan Mint | Japan | ||||||
| Gold | Jiangxi Copper Co., Ltd. | China | ||||||
| Gold | Asahi Refining USA Inc. | United States Of America | ||||||
| Gold | Asahi Refining Canada Ltd. | Canada | ||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | ||||||
| Gold | Kazzinc | Kazakhstan | ||||||
| Gold | Kennecott Utah Copper LLC | United States Of America | ||||||
| Gold | Kojima Chemicals Co., Ltd. | Japan | ||||||
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | ||||||
| Gold | Materion | United States Of America | ||||||
| Gold | Matsuda Sangyo Co., Ltd. | Japan | ||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | China | ||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | ||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | ||||||
| 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 | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | ||||||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | ||||||
| Gold | Nihon Material Co., Ltd. | Japan | ||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | ||||||
| Gold | MKS PAMP SA | Switzerland | ||||||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | ||||||
| Gold | PX Precinox S.A. | Switzerland | ||||||
| Gold | Rand Refinery (Pty) Ltd. | South Africa | ||||||
| Gold | Royal Canadian Mint | Canada | ||||||
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | ||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | ||||||
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | ||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | ||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | ||||||
| Gold | Tokuriki Honten Co., Ltd. | Japan | ||||||
| Gold | Torecom | Korea, Republic Of | ||||||
| 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 | Yamakin Co., Ltd. | Japan | ||||||
| Gold | Yokohama Metal Co., Ltd. | Japan | ||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | ||||||
| Gold | SAFINA A.S. | Czechia | ||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | India | ||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | ||||||
| Gold | T.C.A S.p.A | Italy | ||||||
| Gold | REMONDIS PMR B.V. | Netherlands | ||||||
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | ||||||
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | ||||||
| Gold | L'Orfebre S.A. | Andorra | ||||||
| Gold | Italpreziosi | Italy | ||||||
| Gold | WIELAND Edelmetalle GmbH | Germany | ||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | ||||||
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | ||||||
| Gold | Planta Recuperadora de Metales SpA | Chile | ||||||
| Gold | NH Recytech Company | Korea, Republic Of | ||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | ||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | ||||||
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | ||||||
| Gold | Advanced Chemical Company | United States Of America | ||||||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | ||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||||||
| Gold | Caridad | Mexico | ||||||
| Gold | Cendres + Metaux S.A. | Switzerland | ||||||
| Gold | Yunnan Copper Industry Co., Ltd. | China | ||||||
| Gold | Refinery of Seemine Gold Co., Ltd. | China | ||||||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | ||||||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | ||||||
| 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 | Kazakhmys Smelting LLC | Kazakhstan | ||||||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | ||||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | ||||||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | ||||||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | ||||||
| Gold | Sabin Metal Corp. | United States Of America | ||||||
| Gold | Samduck Precious Metals | Korea, Republic Of | ||||||
| Gold | Samwon Metals Corp. | Korea, Republic Of | ||||||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | ||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | ||||||
| Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province Of China | ||||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | ||||||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | ||||||
| Gold | Morris and Watson | New Zealand | ||||||
| Gold | Guangdong Jinding Gold Limited | China | ||||||
| Gold | Umicore Precious Metals Thailand | Thailand | ||||||
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | ||||||
| Gold | Shandong Humon Smelting Co., Ltd. | China | ||||||
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | ||||||
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | ||||||
| Gold | Emirates Gold DMCC | United Arab Emirates | ||||||
| Gold | International Precious Metal Refiners | United Arab Emirates | ||||||
| Gold | Fujairah Gold FZC | United Arab Emirates | ||||||
| Gold | Industrial Refining Company | Belgium | ||||||
| Gold | Shirpur Gold Refinery Ltd. | India | ||||||
| Gold | Marsam Metals | Brazil | ||||||
| Gold | Abington Reldan Metals, LLC | United States Of America | ||||||
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China | ||||||
| Gold | SAAMP | France | ||||||
| Gold | 8853 S.p.A. | Italy | ||||||
| Gold | AU Traders and Refiners | South Africa | ||||||
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India | ||||||
| Gold | Sai Refinery | India | ||||||
| Gold | Modeltech Sdn Bhd | Malaysia | ||||||
| Gold | Bangalore Refinery | India | ||||||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | ||||||
| Gold | Pease & Curren | United States Of America | ||||||
| Gold | JALAN & Company | India | ||||||
| Gold | ABC Refinery Pty Ltd. | Australia | ||||||
| Gold | Safimet S.p.A | Italy | ||||||
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | ||||||
| Gold | Gold Coast Refinery | Ghana | ||||||
| Gold | QG Refining, LLC | United States Of America | ||||||
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | ||||||
| Gold | CGR Metalloys Pvt Ltd. | India | ||||||
| Gold | Sovereign Metals | India | ||||||
| Gold | Augmont Enterprises Private Limited | India | ||||||
| Gold | Kundan Care Products Ltd. | India | ||||||
| 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 | K.A. Rasmussen | Norway | ||||||
| Gold | Alexy Metals | United States Of America | ||||||
| Gold | MD Overseas | India | ||||||
| Gold | Metallix Refining Inc. | United States Of America | ||||||
| Gold | WEEEREFINING | France | ||||||
| Gold | Gold by Gold Colombia | Colombia | ||||||
| Gold | Dongwu Gold Group | China | ||||||
| Gold | Shandong Gold Smelting Co., Ltd. | China | ||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | ||||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | ||||||
| Gold | JSC Novosibirsk Refinery | Russian Federation | ||||||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | ||||||
| Gold | JSC Uralelectromed 1 (see End Notes) | Russian Federation | ||||||
| Gold | L'azurde Company For Jewelry | Saudi Arabia | ||||||
| Gold | Lingbao Gold Co., Ltd. | China | ||||||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||||||
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | ||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | ||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | ||||||
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | ||||||
| Gold | Kaloti Precious Metals | United Arab Emirates | ||||||
| Gold | Sudan Gold Refinery | Sudan | ||||||
| Gold | Albino Mountinho Lda. | Portugal | ||||||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | ||||||
| Gold | African Gold Refinery 2 (see End Notes) | Uganda | ||||||
| Gold | Sam Precious Metals | United Arab Emirates | ||||||
| Gold | Coimpa Industrial LTDA | Brazil | ||||||
| Gold | GG Refinery Ltd. | Tanzania, United Republic Of | ||||||
| Tantalum | F&X Electro-Materials Ltd. | China | ||||||
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | ||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | ||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | ||||||
| Tantalum | AMG Brasil | Brazil | ||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | ||||||
| Tantalum | Mineracao Taboca S.A. | Brazil | ||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | ||||||
| Tantalum | NPM Silmet AS | Estonia | ||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | ||||||
| Tantalum | QuantumClean | United States Of America | ||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | ||||||
| Tantalum | Taki Chemical Co., Ltd. | Japan | ||||||
| Tantalum | Telex Metals | United States Of America | ||||||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | ||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||||||
| Tantalum | D Block Metals, LLC | United States Of America | ||||||
| Tantalum | FIR Metals & Resource Ltd. | China | ||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | ||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | ||||||
| Tantalum | KEMET de Mexico | Mexico | ||||||
| Tantalum | TANIOBIS Co., Ltd. | Thailand | ||||||
| Tantalum | TANIOBIS GmbH | Germany | ||||||
| Tantalum | Materion Newton Inc. | United States Of America | ||||||
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | ||||||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | ||||||
| Tantalum | Global Advanced Metals Boyertown | United States Of America | ||||||
| Tantalum | Global Advanced Metals Aizu | Japan | ||||||
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | ||||||
| Tantalum | Jiangxi Tuohong New Raw Material | China | ||||||
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | ||||||
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | ||||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | ||||||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | ||||||
| Tantalum | 5D Production OU | Estonia | ||||||
| Tantalum | PowerX Ltd. | Rwanda | ||||||
| Tin | EM Vinto | Bolivia (Plurinational State Of) | ||||||
| Tin | Fenix Metals | Poland | ||||||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | ||||||
| Tin | Mineracao Taboca S.A. | Brazil | ||||||
| Tin | Minsur | Peru | ||||||
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | ||||||
| Tin | PT Babel Surya Alam Lestari | Indonesia | ||||||
| Tin | PT Mitra Stania Prima | Indonesia | ||||||
| Tin | PT Refined Bangka Tin | Indonesia | ||||||
| Tin | PT Timah Tbk Mentok | Indonesia | ||||||
| Tin | Thaisarco | Thailand | ||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | ||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | ||||||
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | ||||||
| Tin | CV Venus Inti Perkasa | Indonesia | ||||||
| Tin | CV Ayi Jaya | Indonesia | ||||||
| Tin | Aurubis Beerse | Belgium | ||||||
| Tin | PT Menara Cipta Mulia | Indonesia | ||||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | ||||||
| Tin | PT Rajawali Rimba Perkasa | Indonesia | ||||||
| Tin | PT Mitra Sukses Globalindo | Indonesia | ||||||
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | ||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | ||||||
| Tin | Alpha | United States Of America | ||||||
| Tin | PT Aries Kencana Sejahtera | Indonesia | ||||||
| Tin | Dowa | Japan | ||||||
| Tin | Estanho de Rondonia S.A. | Brazil | ||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | ||||||
| Tin | China Tin Group Co., Ltd. | China | ||||||
| Tin | Metallic Resources, Inc. | United States Of America | ||||||
| Tin | Mitsubishi Materials Corporation | Japan | ||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | China | ||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||||||
| Tin | PT Artha Cipta Langgeng | Indonesia | ||||||
| Tin | PT Babel Inti Perkasa | Indonesia | ||||||
| Tin | PT Bukit Timah | Indonesia | ||||||
| Tin | PT Prima Timah Utama | Indonesia | ||||||
| Tin | PT Sariwiguna Binasentosa | Indonesia | ||||||
| Tin | PT Stanindo Inti Perkasa | Indonesia | ||||||
| Tin | PT Timah Tbk Kundur | Indonesia | ||||||
| Tin | PT Timah Nusantara | Indonesia | ||||||
| Tin | PT Tommy Utama | Indonesia | ||||||
| Tin | Rui Da Hung | Taiwan, Province Of China | ||||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | ||||||
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | ||||||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | ||||||
| Tin | PT Cipta Persada Mulia | Indonesia | ||||||
| Tin | Resind Industria e Comercio Ltda. | Brazil | ||||||
| Tin | Super Ligas | Brazil | ||||||
| Tin | Aurubis Berango | Spain | ||||||
| Tin | PT Sukses Inti Makmur | Indonesia | ||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | ||||||
| Tin | PT Bangka Serumpun | Indonesia | ||||||
| Tin | Tin Technology & Refining | United States Of America | ||||||
| Tin | Luna Smelter, Ltd. | Rwanda | ||||||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | ||||||
| Tin | CRM Synergies | Spain | ||||||
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | ||||||
| Tin | PT Premium Tin Indonesia | Indonesia | ||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | ||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | ||||||
| Tin | PT Belitung Industri Sejahtera | Indonesia | ||||||
| Tin | PT Panca Mega Persada | Indonesia | ||||||
| Tin | PT Tinindo Inter Nusa | Indonesia | ||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | ||||||
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | ||||||
| Tin | PT Tirus Putra Mandiri | Indonesia | ||||||
| Tin | Melt Metais e Ligas S.A. | Brazil | ||||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | ||||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | ||||||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | ||||||
| Tin | PT Rajehan Ariq | Indonesia | ||||||
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | ||||||
| Tin | PT Bangka Prima Tin | Indonesia | ||||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | ||||||
| Tin | Modeltech Sdn Bhd | Malaysia | ||||||
| Tin | Pongpipat Company Limited | Myanmar | ||||||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | ||||||
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China | ||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | ||||||
| Tin | Precious Minerals and Smelting Limited | India | ||||||
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | ||||||
| Tin | Novosibirsk Tin Combine | Russian Federation | ||||||
| Tin | PT Bangka Tin Industry | Indonesia | ||||||
| Tin | DS Myanmar | Myanmar | ||||||
| Tin | Mining Minerals Resources SARL | Congo, Democratic Republic Of The | ||||||
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia | ||||||
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | Japan | ||||||
| Tungsten | A.L.M.T. Corp. | Japan | ||||||
| Tungsten | Kennametal Huntsville | United States Of America | ||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | ||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | ||||||
| Tungsten | Global Tungsten & Powders LLC | United States Of America | ||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | ||||||
| Tungsten | Japan New Metals Co., Ltd. | Japan | ||||||
| Tungsten | Kennametal Fallon | United States Of America | ||||||
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | ||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | China | ||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | ||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | ||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | ||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | ||||||
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | ||||||
| Tungsten | H.C. Starck Tungsten GmbH | Germany | ||||||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | ||||||
| Tungsten | Masan High-Tech Materials | Viet Nam | ||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||||||
| Tungsten | Niagara Refining LLC | United States Of America | ||||||
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China | ||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | ||||||
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | ||||||
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | ||||||
| Tungsten | Cronimet Brasil Ltda | Brazil | ||||||
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | ||||||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | ||||||
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | ||||||
| Tungsten | ACL Metais Eireli | Brazil | ||||||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | ||||||
| Tungsten | Hydrometallurg, JSC | Russian Federation | ||||||
| Tungsten | Unecha Refractory metals plant | Russian Federation | ||||||
| Tungsten | Moliren Ltd. | Russian Federation | ||||||
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | ||||||
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | ||||||
| Tungsten | Artek LLC | Russian Federation | ||||||
| Tungsten | OOO “Technolom” 2 | Russian Federation | ||||||
| Tungsten | OOO “Technolom” 1 | Russian Federation | ||||||
| Tungsten | LLC Vostok | Russian Federation | ||||||
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China | ||||||
| Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic Of | ||||||
| Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam | ||||||
| Tungsten | Nam Viet Cromit Joint Stock Company | Viet Nam | ||||||
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of | ||||||
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | China | ||||||
| Tungsten | Lianyou Resources Co., Ltd. | Taiwan, Province Of China | ||||||
| Tungsten | Kenee Mining Corporation Vietnam | Viet Nam | ||||||
End Notes:
1 JSC Uralelectromed was added to the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) sanctions list on July 20, 2023. Because of the over-reporting nature of the industry CMRT information collection process, and the nature of our supply chains, we are unable to confirm whether this, or any, specific smelter or refiner is or was active in our supply chains, nor are we aware of when or if feedstock from this or any entity may have entered our supply chains. Our policy is that we comply, and that our suppliers should comply, with all applicable sanctions laws. We do not have any direct transactions or contractual relationships with this entity, nor are we, to the best of our knowledge, engaging in indirect transactions, with this entity.
2 African Gold Refinery was added to the U.S. Department of the Treasury's OFAC sanctions list on March 17, 2022. Because of the over-reporting nature of the industry CMRT information collection process, and the nature of our supply chains, we are unable to confirm whether this, or any, specific smelter or refiner is or was active in our supply chains, nor are we aware of when or if feedstock from this or any entity may have entered our supply chains. Our policy is that we comply, and that our suppliers should comply, with all applicable sanctions laws. We do not have any direct transactions or contractual relationships with this entity, nor are we, to the best of our knowledge, engaging in indirect transactions, with this entity.