ILLINOIS TOOL WORKS INC filed this SD on 05/31/2016

Document







UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549




FORM SD

SPECIALIZED DISCLOSURE REPORT


__________________________________________

ILLINOIS TOOL WORKS INC.
(Exact name of registrant as specified in its charter)
__________________________________________



Delaware
1-4797
36-1258310
(State or other jurisdiction of incorporation or organization)
(Commission File Number)
(I.R.S. Employer Identification No.)
 
 
 
155 Harlem Avenue, Glenview, IL
 
60025
(Address of principal executive offices)
 
(Zip Code)

Janet O. Love (224-661-7778)
Name and telephone number, including area code, of the person to contact in connection with this report

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

[ X ]
Rule 13p-1 under the Securities Exchange Act (17CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.

 
 
 







Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report
As required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report is provided as an Exhibit to this Form SD and is available on our website at http://investor.itw.com/investor-information/sec-filings.

Item 1.02 Exhibits
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 - Exhibits

Item 2.01    Exhibits
1.01    Conflict Minerals Report for the calendar year ended December 31, 2015.

 
 
 
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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.



 
ILLINOIS TOOL WORKS INC.
 
 
 
 
Dated: May 31, 2016
By: /s/ DAVID C. PARRY
 
David C. Parry
 
Vice Chairman





    


 
 
 
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EXHIBIT INDEX

Exhibit
 
Description
1.01
 
Conflict Minerals Report for the calendar year ended December 31, 2015.


 
 
 
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Exhibit

Exhibit 1.01
Conflict Minerals Report
I.
Introduction

A.
Our Business
Illinois Tool Works Inc. is a global manufacturer of a diversified range of industrial products and equipment with 84 divisions in 57 countries, and has prepared this Conflict Minerals Report for calendar year 2015 in accordance with the requirements of Rule 13p-1 (“Rule 13p-1”) and Form SD (together referred to as the "Conflict Minerals Rule") of the United States Securities and Exchange Commission (“SEC”). Unless the context indicates otherwise, the terms “Company,” “ITW,” “we,” “its,” “us” and “our” refer to Illinois Tool Works Inc. and its consolidated subsidiaries. “Conflict minerals” or “3TG” as used in this report, refers to cassiterite, columbite-tantalite, gold, wolframite and their derivatives, tin, tantalum, tungsten and/or gold, without regard to their location of origin.
The Company’s operations are reported to senior management as the following segments: Automotive OEM; Test & Measurement and Electronics; Food Equipment; Polymers & Fluids; Welding; Construction Products; and Specialty Products. Each of our segments manufactures certain products that contain some amount of 3TG that are necessary to the functionality or production of the products (which we sometimes refer to herein as "in-scope" products). ITW’s in-scope products taken together as a whole contain all four 3TGs, although each product does not contain all four 3TGs.

B.Reasonable Country of Origin Inquiry and Due Diligence Overview

As required by the Conflict Minerals Rule, we conducted a "reasonable country of origin inquiry" ("RCOI"), designed in good faith to determine the origin of the 3TG that are contained in our in-scope products. See Section II. Reasonable Country of Origin Inquiry for a description of our RCOI process for 2015.

If the Company has reason to believe that any of the 3TG in our supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”), or we are unable to determine the country of origin of the 3TG, we are required to exercise due diligence on the source and chain of custody of the 3TG and include a description of our due diligence measures in this Conflict Minerals Report. On the basis of our RCOI, we have determined that some of the 3TG contained in our products originated from a Covered Country, and we are therefore submitting this Conflict Minerals Report, which describes the due diligence we have performed pursuant to the Conflict Minerals Rule and our related processes and procedures. See Section III. Due Diligence. This report is filed as an exhibit to our Form SD and is available on our website at http://investor.itw.com/investor-information/sec-filings. Information contained on our website or otherwise actively linked to this Conflict Minerals Report is not part of or incorporated by reference into this Conflict Minerals Report or our Form SD.







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C.
ITW’s Position in the Supply Chain
Most of our businesses are many levels removed from 3TG mining, smelting and processing facilities, and we have no relationships with mines. We therefore require the cooperation of our supply chain to provide information on smelters and refiners (“SORs”) as well as the origin of 3TG contained in our products, and we rely on the Conflict Free Sourcing Initiative (“CFSI”) and the Conflict Free Smelter Program managed by the CFSI to conduct and recognize independent, third-party audits of SORs.

D.
Responsible Sourcing Commitment
Through the efforts described in this Conflict Minerals Report, we seek to ensure that our suppliers responsibly source 3TG. Our responsible sourcing goes beyond compliance with the Conflict Minerals Rule, however, and our Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) mandates compliance with all laws, and in particular prohibits use of child labor, forced labor, and discrimination, and mandates compliance with safety rules, wage and hour laws, and anti-bribery laws.

E.
Smelter and Refiner and Country of Origin Information

The Company’s in-scope products that contain 3TG and that are required to be described in this CMR are described in Section IV. Product Information. Information about SORs relating to the Company’s in-scope products is described in Section V. Identified Smelters and Refiners and on Annex A. We have not found for 2015 that any of the necessary 3TG contained in our in-scope products directly or indirectly financed or benefited armed groups in a Covered Country. However, we have not declared that any of our products are “DRC conflict free.” The terms "adjoining country," "armed group," and "DRC conflict free" have the meanings contained in the Conflict Minerals Rule.

F.
2015 Program Improvements
For 2015, we continued our participation in the AIAG Conflict Minerals Working Group and in the CFSI’s plenary and due diligence practices team. We also took the following actions to improve our RCOI and conflict minerals due diligence and mitigate sourcing risk:
Completed an external readiness assessment of our conflict minerals process with a professional assurance firm to evaluate the alignment of our process with the due diligence guidance of the Organisation for Economic Co-operation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Second Edition 2013) (“OECD Guidance”);
Completed an internal assessment of our conflict minerals due diligence process to better understand how we can assist our business divisions in the process of inquiring and reporting of information from their suppliers. As a result of this assessment, we took certain actions, including:
Offered conflict minerals information and assistance at enterprise-wide strategic sourcing conferences; and
Revised our communications with our businesses to be simpler and easier to follow.

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Revised ITW’s Conflict Minerals Policy Statement (which can be found at http://www.itw.com/about-itw/suppliers/page/en/conflict-minerals-policy-statement/) to clearly encourage our suppliers’ support of verified SORs in the Covered Countries;
Incorporated conflict mineral screening questions into incoming supplier bids;
Created a link to ITW’s Helpline in our Conflict Minerals Policy Statement that is included on our website to enable third parties and shareholders, as well as suppliers, to report grievances; and
Participated in the Caterpillar Cross-Industry Collaboration Group calls.

II.
Reasonable Country of Origin Inquiry
Our RCOI utilized management systems recommended by the first step of the OECD Guidance and was conducted in accordance with the second step of the OECD Guidance. Selected elements of our program design and RCOI process are discussed below. However, these are not all of the discrete elements of the program that we have put in place in accordance with these steps of the OECD Guidance to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the first and second steps.
A.    Establish Strong Management Systems
1.    ITW Policies
ITW has adopted a company-wide Conflict Minerals Policy Statement (the "Policy"), which has been approved by ITW’s Chief Executive Officer and is available on our website at http://www.itw.com/about-itw/suppliers/page/en/conflict-minerals-policy-statement/. Our Policy states that we do not knowingly procure 3TG that originate from the Covered Countries unless they originate from mines or SORs that are certified as having followed established protocols to allow them to be considered “conflict free.” We ask our suppliers to undertake reasonable due diligence with their supply chains to determine whether products containing 3TG used in the manufacture of our products originate from a Covered Country and, if they do originate from a Covered Country, that the SORs be certified as compliant by an independent third party. The Policy encourages our suppliers to continue to support compliant SORs in the Covered Countries and to make similar requests of their sub-suppliers. If we discover that any 3TG procured by us are produced in a Covered Country from facilities that are not certified as compliant, we will request that our supplier ask the facility to become certified or use our best efforts to transition the product to be from compliant sources.
ITW’s Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) sets forth expectations for all ITW suppliers to adhere to the highest ethical standards in the conduct of their business. It also requires suppliers to adhere to specific standards and specifically prohibits certain behaviors associated with conflict minerals, including use of child or forced labor, unsafe working conditions and bribery. The Code of Conduct also requires that, upon request, our suppliers determine whether any products provided by them contain 3TG and to take such actions as necessary to provide the information requested by ITW to conduct its RCOI, as described below under B. Identify and Assess Risk in the Supply Chain.

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We do not support a general embargo of sourcing from the Covered Countries, and clarified our Conflict Minerals Policy to encourage our suppliers to continue to source from responsible sources in those countries.
2.    Cross Functional Committee
ITW has a cross-functional conflict minerals committee (the “Committee”). The Committee is headed by ITW’s Vice President of Strategic Sourcing, who reports to one of ITW’s Vice Chairmen, and includes dedicated employees and representatives from strategic sourcing, legal, environmental and chemical compliance, sustainability, internal audit, IT, and selected personnel from various operations. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets as needed to discuss the conflict minerals compliance process and developments. Senior management is briefed on the results of our due diligence efforts on a regular basis.
3.    Internal Training
We maintain an intranet conflict minerals website which contains resources, instructions and guidance on the RCOI and due diligence processes to be followed by our businesses that have or may have in-scope products. The site also contains step-by-step instructions for making supplier inquiries, including a training video regarding our RCOI and due diligence process, and can be accessed by all ITW businesses for reference.

4.    Supplier Engagement and Training
In addition to our Conflict Minerals Policy Statement and Supplier Code of Conduct, ITW’s standard “Terms and Conditions” with its suppliers obligates suppliers to take such actions as requested by ITW to enable us to comply with our conflict minerals disclosure requirements. We also include conflict minerals screening questions into incoming supplier bids.

ITW educates key suppliers through presentations regarding our conflict minerals compliance program during supplier meetings and other interactions. We also post information and guidance for suppliers on our Company website and encourage our businesses to share relevant information with suppliers on the process for responding to our RCOI requests for information.

5.    Records Retention
ITW retains its conflict minerals related records for at least five years. These records generally are maintained in an electronic format.

6.    Grievance Mechanism
ITW maintains a web- and telephone-based reporting system (“Helpline”), providing employees with a confidential reporting mechanism by which they can communicate issues and concerns associated with violations of ITW’s Principles of Conduct, which requires all employees to comply with all applicable laws and Company policies, including the Policy.


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A link to the Helpline is included in our Conflict Minerals Policy Statement on our website to provide convenient access to external stakeholders, suppliers and other third parties to communicate issues and concerns regarding ITW’s supply chain. The contact information for our Helpline is http://www.itwhelpline.ethicspoint.com.

B.    Identify and Assess Risk in the Supply Chain
Our RCOI process was used to survey our potential in-scope suppliers to identify and assess conflict mineral sourcing risk in our supply chain for the 2015 reporting cycle.
Prior to conducting our supplier survey, we made internal inquiries of all of our businesses to identify the in-scope products of each of our segments. All businesses were given information and guidance to assist in determining which products are in-scope.
We then surveyed all potential in-scope suppliers to determine whether 3TG in those products originated or may have originated from a Covered Country and were not from recycled or scrap sources. Businesses with potentially in-scope products were instructed to survey their suppliers regarding the origin of the 3TG contained in those products using the CFSI’s Conflict Minerals Reporting Template (“CMRT”). The CMRT requests information regarding 3TG included in the suppliers’ products, SOR identity and location, the supplier’s RCOI process and other information about the suppliers’ conflict minerals policies and practices. Our outreach included all suppliers that we identified as having provided us with components, parts or products that contain 3TG or that we believed may have contained 3TG (the "Suppliers").
ITW has an established protocol for its Supplier inquiry process and uses a third party software vendor to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and Suppliers through use of a cloud-based 3TG tracking tool (the “CM System”).
We sent 4,280 requests to Suppliers to provide us with a completed CMRT. A number of our businesses source different products from the same supplier, and each business sent inquiries to all suppliers of potentially in-scope products; accordingly, the total number of unique suppliers is less than the number of Suppliers queried. We received 1,636 CMRTs from the Suppliers surveyed.
The CM System issued automatic weekly follow-up reminders to non-responding suppliers, and our businesses were given instructions regarding follow-up actions beyond the automatic reminders and in response to receipt of incomplete or incorrect CMRTs.
Our protocol also includes a follow-up process to investigate any CMRTs received that raise red flags. See Section III. Due Diligence for a description of the follow-up process.
Our Supplier responses identified 215 SORs certified by the CFSI as compliant. We determined that 192 of these compliant SORs sourced exclusively from outside the Covered Countries, including in whole or in part from recycled or scrap sources. Our determination was based on country of origin information made available by the CFSI to its members. Our Supplier responses identified an additional 35 SORs that were listed as active by the CFSI and 65 that were on the CFSI’s Smelter Reference List but were not certified or active. Based on the results of our RCOI, we were required to conduct due diligence, as described below.

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III.
Due Diligence

A.
Design Framework
ITW´s conflict minerals due diligence process is designed in conformance with the related third, fourth and fifth steps of the OECD Guidance.

B.
Due Diligence Activities
Selected elements of our program design and implementation in furtherance of the third, fourth and fifth steps of the OECD Guidance are discussed below. However, these are not all of the discrete elements of the program that we have put in place pursuant to these steps to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the third, fourth and fifth steps. The actions taken by the Company to address the first and second steps of the OECD Guidance are described in Section II. Reasonable Country of Origin Inquiry. See also our 2015 program improvements discussed in Section I. Introduction.

Design and implement a strategy to respond to identified risks

The SOR information provided by suppliers in response to the Company’s supplier survey described in Section II.B. was reviewed against the Smelter Reference List in the CMRT. SOR information also was reviewed against the lists of "compliant" and "active" SORs and country-of-origin information published by the CFSI and contained in the CM System. Active SORs are those that are taking action to become certified as conflict free.
CMRTs that indicated 3TG from a source within a Covered Country, or that contained inconsistent smelter information, triggered a red flag in the CM System. If an individual business received a response from a supplier indicating the presence of 3TG from a Covered Country that is sourced from an SOR that is not compliant or that did not identify an SOR, communications with that Supplier were escalated. These Suppliers were asked to complete a series of additional questions, and our businesses were given written guidance and instructions for these communications. These escalated Supplier situations were reviewed on a case-by-case basis, and the communications took place outside of the CM System.
Our red flag process did not result in the need to require corrective action on the part of our Suppliers.
In 2015, we continued to revise and simplify our written communications and instructions to our businesses regarding Supplier red flag follow-up to enhance program effectiveness.
Our conflict minerals compliance team reported the findings from its RCOI and due diligence process to our Vice President of Strategic Sourcing, and these results were in turn discussed with senior management.
Carry out independent third party audit of supply chain diligence at identified points in the supply chain

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The Company continued its membership in the CFSI for 2015. Due to our location in the mineral supply chain, which is discussed earlier in this Conflict Minerals Report, we support and utilize the CFSI’s Conflict-Free Smelter Program to perform third-party audits of SORs.
Report annually on supply chain due diligence
We describe our supply chain due diligence efforts in our Conflict Minerals Report. We are required to prepare this report annually, post it on our website and file it with the SEC as an exhibit to our annual Form SD. Once filed, the Form SD and Conflict Minerals Report become available on our website. We also include a discussion of our efforts in the area of conflict minerals in our annual Corporate Social Responsibility Report, which is also available on our website (see http://workingtogether.itw-csr.com/our-world/conflict-minerals).

IV.
Product Information
For 2015, our in-scope products required to be described in this Conflict Minerals Report included products in each of the categories below:

Arc welding and cutting equipment and consumables
Industrial ovens
Automotive components
Industrial warewashers
Catalysts
Inspection equipment
Commercial cooking equipment
LEDs, LCDs
Commercial refrigerators
Marking and coding equipment
Cutting Equipment
Mixers
Electrical devices
Printers and dispensers
Electronic equipment
Sealing equipment
Fastening tools
Switches, capacitors and electronics
Flow control meters
Testing equipment
Hot stamp machines
Warehouse equipment
Industrial equipment
 
V.    Identified Smelters and Refiners
Our Supplier responses identified 215 SORs that were on the CFSI compliant list, 35 that were listed as active and 65 that were on the Smelter Reference List but not compliant or active. These facilities are listed on Annex A. The information in Annex A includes only the information and entities identified by our Suppliers as SORs that were on the Smelter Reference List contained in the CM System as of May 11, 2016, which are those entities identified to us that we were able to determine were SORs. Entities identified by our Suppliers that are not on Annex A have been submitted to the CFSI to support their ongoing effort to identify and audit all 3TG SORs.
Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our Suppliers for accurate SOR information, and our RCOI and due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope

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products. The information that we received from most of our Suppliers was made at a company or user defined level, rather than at a product level, meaning that such Suppliers provided information on all of their products that contained 3TG, not just the products that were sold to us. Therefore, our list of SORs disclosed in Annex A may contain facilities that did not process the 3TG contained in our products. In addition, the identified SORs may not include all SORs present in our in-scope product supply chain, since some Suppliers were unable to identify all of the SORs in their supply chain.

Annex A also includes information concerning the identified countries of origin of the SORs listed. We have not found for 2015 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country. However, we have not declared that any of our products are “DRC conflict free.” An "armed group" under the Conflict Minerals Rule is an armed group that is identified as a perpetrator of serious human rights abuses in annual Country Reports on Human Rights Practices under sections 116(d) and 502B(b) of the Foreign Assistance Act of 1961 relating to a Covered Country.
We endeavored to determine the mine or location of origin of the 3TG contained in our in-scope products by requesting that the Suppliers provide us with a completed CMRT and through the other actions described in this Conflict Minerals Report.

VI.
Additional Risk Mitigation
In addition to the actions described elsewhere in this Conflict Minerals Report, we intend to take the following steps in respect of our 2016 compliance to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:

Continue to analyze and review our current processes to improve their effectiveness and efficiency.

Analyze spend data against supplier response data to identify inconsistencies and areas of potential enhanced focus for supplier outreach efforts.

Engage with suppliers that provided incomplete responses or that did not provide responses for 2015 to help ensure that they will provide requested information for 2016.

Continue to enhance supplier communication and training to improve RCOI and due diligence data accuracy and completion.

Through our direct suppliers, continue to seek to influence uncertified SORs in our supply chain to obtain a compliant certification by engaging with suppliers who identified uncertified SORs that are not actively pursuing certification to encourage them to pursue certification.

Continue our membership in the CFSI and support the CFSI’s certification of SORs.

Continue to submit to the CFSI facilities identified by our Suppliers that are not on the Smelter Reference List, to support the CFSI's ongoing effort to identify and audit all 3TG SORs.

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VII.
Forward Looking Statements

This report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements include expectations concerning the Company’s future actions to identify improvements to our due diligence processes, to engage with our suppliers, and to take other actions regarding our product sourcing. These statements are subject to certain risks, uncertainties and other factors, including but not limited to, decisions to make changes to our continual improvement efforts and delays or difficulties in engaging suppliers and/or transitioning sources of product containing 3TG.





































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Annex A to Exhibit 1.01
CFSI Smelters or Refiners
 
 
 
 
Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner Status
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Compliant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Compliant
Gold
Argor-Heraeus SA
SWITZERLAND
Compliant
Gold
Asahi Pretec Corporation
JAPAN
Compliant
Gold
Asahi Refining Canada Limited
CANADA
Compliant
Gold
Asahi Refining USA Inc.
UNITED STATES
Compliant
Gold
Asaka Riken Co., Ltd.
JAPAN
Compliant
Gold
Aurubis AG
GERMANY
Compliant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Compliant
Gold
Boliden AB
SWEDEN
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Compliant
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Compliant
Gold
Chimet S.p.A.
ITALY
Compliant
Gold
DODUCO GmbH
GERMANY
Compliant
Gold
Dowa
JAPAN
Compliant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Compliant
Gold
Elemetal Refining, LLC
UNITED STATES
Compliant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Compliant
Gold
Heimerle + Meule GmbH
GERMANY
Compliant
Gold
Heraeus Ltd. Hong Kong
CHINA
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Compliant
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
CHINA
Compliant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
Istanbul Gold Refinery
TURKEY
Compliant
Gold
Japan Mint
JAPAN
Compliant
Gold
Jiangxi Copper Company Limited
CHINA
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Compliant
Gold
Kazzinc
KAZAKHSTAN
Compliant

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Gold
Kennecott Utah Copper LLC
UNITED STATES
Compliant
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Compliant
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Compliant
Gold
Materion
UNITED STATES
Compliant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Compliant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Compliant
Gold
Metalor Technologies SA
SWITZERLAND
Compliant
Gold
Metalor USA Refining Corporation
UNITED STATES
Compliant
Gold
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
MEXICO
Compliant
Gold
Mitsubishi Materials Corporation
JAPAN
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Compliant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Compliant
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Compliant
Gold
Nihon Material Co., Ltd.
JAPAN
Compliant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Compliant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Compliant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Compliant
Gold
PAMP SA
SWITZERLAND
Compliant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Compliant
Gold
PX Précinox SA
SWITZERLAND
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Compliant
Gold
Republic Metals Corporation
UNITED STATES
Compliant
Gold
Royal Canadian Mint
CANADA
Compliant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Compliant
Gold
SEMPSA Joyería Platería SA
SPAIN
Compliant
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Compliant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Compliant
Gold
Singway Technology Co., Ltd.
TAIWAN
Compliant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Compliant

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Gold
Solar Applied Materials Technology Corp.
TAIWAN
Compliant
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Compliant
Gold
T.C.A S.p.A
ITALY
Compliant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Compliant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Compliant
Gold
Umicore Brasil Ltda.
BRAZIL
Compliant
Gold
Umicore Precious Metals Thailand
THAILAND
Compliant
Gold
Umicore SA Business Unit Precious Metals Refining
BELGIUM
Compliant
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Compliant
Gold
Valcambi SA
SWITZERLAND
Compliant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Compliant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Compliant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Compliant
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Compliant
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
Compliant
Gold
Advanced Chemical Company
UNITED STATES
Active
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Active
Gold
Cendres + Métaux SA
SWITZERLAND
Active
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Active
Gold
Do Sung Corporation
KOREA, REPUBLIC OF
Active
Gold
Faggi Enrico S.p.A.
ITALY
Active
Gold
Geib Refining Corporation
UNITED STATES
Active
Gold
KGHM Polska Miedź Spółka Akcyjna
POLAND
Active
Gold
Korea Zinc Co. Ltd.
KOREA, REPUBLIC OF
Active
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Active
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Active
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Active
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Active
Gold
Torecom
KOREA, REPUBLIC OF
Active
Gold
WIELAND Edelmetalle GmbH
GERMANY
Active
Gold
Aktyubinsk Copper Company TOO
KAZAKHSTAN
On Smelter Reference List
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
On Smelter Reference List
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
On Smelter Reference List

12



Gold
Bauer Walser AG
GERMANY
On Smelter Reference List
Gold
Caridad
MEXICO
On Smelter Reference List
Gold
Chugai Mining
JAPAN
On Smelter Reference List
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
On Smelter Reference List
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
On Smelter Reference List
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
On Smelter Reference List
Gold
Guangdong Jinding Gold Limited
CHINA
On Smelter Reference List
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
On Smelter Reference List
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
On Smelter Reference List
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
On Smelter Reference List
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
On Smelter Reference List
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
On Smelter Reference List
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
On Smelter Reference List
Gold
Korea Metal Co., Ltd.
KOREA, REPUBLIC OF
On Smelter Reference List
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
On Smelter Reference List
Gold
Lingbao Gold Company Limited
CHINA
On Smelter Reference List
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
On Smelter Reference List
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
On Smelter Reference List
Gold
Metahub Industries Sdn. Bhd.
MALAYSIA
On Smelter Reference List
Gold
Morris and Watson
NEW ZEALAND
On Smelter Reference List
Gold
OJSC Kolyma Refinery
KOREA, REPUBLIC OF
On Smelter Reference List
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
On Smelter Reference List
Gold
Sabin Metal Corp.
UNITED STATES
On Smelter Reference List
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
On Smelter Reference List
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
On Smelter Reference List
Gold
So Accurate Group, Inc.
UNITED STATES
On Smelter Reference List
Gold
The Great Wall Gold and Silver Refinery of China
China
On Smelter Reference List
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
On Smelter Reference List
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
On Smelter Reference List
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Compliant
Tantalum
D Block Metals, LLC
UNITED STATES
Compliant
Tantalum
Duoluoshan
CHINA
Compliant
Tantalum
Exotech Inc.
UNITED STATES
Compliant

13



Tantalum
F&X Electro-Materials Ltd.
CHINA
Compliant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Compliant
Tantalum
Global Advanced Metals Aizu
JAPAN
Compliant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Compliant
Tantalum
H.C. Starck GmbH Goslar
GERMANY
Compliant
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
Compliant
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Compliant
Tantalum
H.C. Starck Inc.
UNITED STATES
Compliant
Tantalum
H.C. Starck Ltd.
JAPAN
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Compliant
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
KEMET Blue Metals
MEXICO
Compliant
Tantalum
KEMET Blue Powder
UNITED STATES
Compliant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Compliant
Tantalum
LSM Brasil S.A.
BRAZIL
Compliant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Compliant
Tantalum
Mineração Taboca S.A.
BRAZIL
Compliant
Tantalum
Mitsui Mining & Smelting
JAPAN
Compliant
Tantalum
Molycorp Silmet A.S.
ESTONIA
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Compliant
Tantalum
Plansee SE Liezen
AUSTRIA
Compliant
Tantalum
Plansee SE Reutte
AUSTRIA
Compliant
Tantalum
QuantumClean
UNITED STATES
Compliant
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Compliant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Compliant
Tantalum
Taki Chemicals
JAPAN
Compliant
Tantalum
Telex Metals
UNITED STATES
Compliant

14



Tantalum
Tranzact, Inc.
UNITED STATES
Compliant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Compliant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Compliant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Compliant
Tantalum
Zhuzhou Cemented Carbide
CHINA
Compliant
Tantalum
Avon Specialty Metals Ltd
UNITED KINGDOM
On Smelter Reference List
Tin
Alpha
UNITED STATES
Compliant
Tin
China Tin Group Co., Ltd.
CHINA
Compliant
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Compliant
Tin
CV Ayi Jaya
INDONESIA
Compliant
Tin
CV Gita Pesona
INDONESIA
Compliant
Tin
CV Serumpun Sebalai
INDONESIA
Compliant
Tin
CV United Smelting
INDONESIA
Compliant
Tin
CV Venus Inti Perkasa
INDONESIA
Compliant
Tin
Dowa
JAPAN
Compliant
Tin
Elmet S.L.U. (Metallo Group)
SPAIN
Compliant
Tin
EM Vinto
BOLIVIA
Compliant
Tin
Fenix Metals
POLAND
Compliant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Compliant
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Compliant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Compliant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Compliant
Tin
Melt Metais e Ligas S/A
BRAZIL
Compliant
Tin
Metallic Resources, Inc.
UNITED STATES
Compliant
Tin
Metallo-Chimique N.V.
BELGIUM
Compliant
Tin
Mineração Taboca S.A.
BRAZIL
Compliant
Tin
Minsur
PERU
Compliant
Tin
Mitsubishi Materials Corporation
JAPAN
Compliant
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Compliant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Compliant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Compliant
Tin
PT Aries Kencana Sejahtera
INDONESIA
Compliant
Tin
PT Artha Cipta Langgeng
INDONESIA
Compliant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Compliant
Tin
PT Babel Inti Perkasa
INDONESIA
Compliant
Tin
PT Bangka Prima Tin
INDONESIA
Compliant
Tin
PT Bangka Tin Industry
INDONESIA
Compliant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Compliant
Tin
PT BilliTin Makmur Lestari
INDONESIA
Compliant
Tin
PT Bukit Timah
INDONESIA
Compliant

15



Tin
PT Cipta Persada Mulia
INDONESIA
Compliant
Tin
PT DS Jaya Abadi
INDONESIA
Compliant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Compliant
Tin
PT Inti Stania Prima
INDONESIA
Compliant
Tin
PT Justindo
INDONESIA
Compliant
Tin
PT Mitra Stania Prima
INDONESIA
Compliant
Tin
PT Panca Mega Persada
INDONESIA
Compliant
Tin
PT Prima Timah Utama
INDONESIA
Compliant
Tin
PT Refined Bangka Tin
INDONESIA
Compliant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Compliant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Compliant
Tin
PT Sukses Inti Makmur
INDONESIA
Compliant
Tin
PT Sumber Jaya Indah
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Compliant
Tin
PT Tinindo Inter Nusa
INDONESIA
Compliant
Tin
PT Tommy Utama
INDONESIA
Compliant
Tin
PT Wahana Perkit Jaya
INDONESIA
Compliant
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tin
Rui Da Hung
TAIWAN
Compliant
Tin
Soft Metais Ltda.
BRAZIL
Compliant
Tin
Thaisarco
THAILAND
Compliant
Tin
VQB Mineral and Trading Group JSC
VIETNAM
Compliant
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Compliant
Tin
Yunnan Tin Group (Holding) Company Limited
CHINA
Compliant
Tin
An Thai Minerals Company Limited
VIETNAM
Active
Tin
An Vinh Joint Stock Mineral Processing Company
VIETNAM
Active
Tin
Chenzhou Yunxiang Mining and Metallurgy Company Limited
CHINA
Active
Tin
CV Dua Sekawan
INDONESIA
Active
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIETNAM
Active
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Active
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Active
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIETNAM
Active
Tin
Phoenix Metal Ltd.
RWANDA
Active
Tin
PT Karimun Mining
INDONESIA
Active
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIETNAM
Active
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Active
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
On Smelter Reference List
Tin
CV Makmur Jaya
INDONESIA
On Smelter Reference List

16



Tin
Estanho de Rondônia S.A.
BRAZIL
On Smelter Reference List
Tin
Feinhütte Halsbrücke GmbH
GERMANY
On Smelter Reference List
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
On Smelter Reference List
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
On Smelter Reference List
Tin
Linwu Xianggui Ore Smelting Co., Ltd.
CHINA
On Smelter Reference List
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
On Smelter Reference List
Tin
Novosibirsk Processing Plant Ltd.
RUSSIAN FEDERATION
On Smelter Reference List
Tin
PT Alam Lestari Kencana
INDONESIA
On Smelter Reference List
Tin
PT Babel Surya Alam Lestari
INDONESIA
On Smelter Reference List
Tin
PT Bangka Kudai Tin
INDONESIA
On Smelter Reference List
Tin
PT Bangka Timah Utama Sejahtera
INDONESIA
On Smelter Reference List
Tin
PT Donna Kembara Jaya
INDONESIA
On Smelter Reference List
Tin
PT Fang Di MulTindo
INDONESIA
On Smelter Reference List
Tin
PT Koba Tin
INDONESIA
On Smelter Reference List
Tin
PT Pelat Timah Nusantara Tbk
INDONESIA
On Smelter Reference List
Tin
PT Rajwa International
INDONESIA
On Smelter Reference List
Tin
PT Seirama Tin Investment
INDONESIA
On Smelter Reference List
Tin
PT Singkep Times Utama
INDONESIA
On Smelter Reference List
Tin
PT Supra Sukses Trinusa
INDONESIA
On Smelter Reference List
Tin
PT Tirus Putra Mandiri
INDONESIA
On Smelter Reference List
Tin
PT Yinchendo Mining Industry
INDONESIA
On Smelter Reference List
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Compliant
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIETNAM
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
H.C. Starck GmbH
GERMANY
Compliant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Compliant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Compliant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Compliant
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Compliant

17



Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Kennametal Huntsville
UNITED STATES
Compliant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Niagara Refining LLC
UNITED STATES
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIETNAM
Compliant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIETNAM
Compliant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIETNAM
Compliant
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Compliant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Compliant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Active
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Active
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Active
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Active
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Active
Tungsten
Kennametal Fallon
UNITED STATES
Active
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Active
Tungsten
Dayu Jincheng Tungsten Industry Co., Ltd.
CHINA
On Smelter Reference List
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
On Smelter Reference List
Tungsten
Ganxian Shirui New Material Co., Ltd.
CHINA
On Smelter Reference List
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
CHINA
On Smelter Reference List
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin
CHINA
On Smelter Reference List
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
On Smelter Reference List
Tungsten
Jiangxi Richsea New Materials Co., Ltd.
CHINA
On Smelter Reference List
Tungsten
Pobedit, JSC
RUSSIAN FEDERATION
On Smelter Reference List
Tungsten
Sanher Tungsten Vietnam Co., Ltd.
VIETNAM
On Smelter Reference List
Country of Origin Information
The countries of origin of the 3TG processed by the Compliant SORs listed above may have included the countries listed below. The listed countries of origin are derived from information made available by the CFSI to its members. Except for the DRC, the CFSI does not indicate individual countries of origin of the 3TG processed by Compliant SORs. Instead, the CFSI indicates country of origin by category. Compliant SORs listed above were in each of the categories below:

18



L1 – Countries that are not identified as conflict regions or plausible areas of smuggling or export of 3TG from the DRC and its nine adjoining countries: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Cote d’Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam and Zimbabwe.
L2 – Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Kenya, Mozambique and South Africa.
L3 – The DRC and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.
DRC – The Democratic Republic of the Congo.
In addition, according to information made available by the CFSI to its members, some of the listed SORs processed 3TG originating solely from recycled or scrap sources and others processed both recycled and scrap content and newly mined content from one or more of the regions indicated above.
Because the CFSI generally does not indicate individual countries of origin of the 3TG processed by Compliant SORs, we were not able to determine the countries of origin of the 3TG processed by the listed Compliant SORs with greater specificity. In addition, for some of the listed Compliant SORs, origin information is not disclosed. We did not determine the countries of origin of the 3TG processed by other SORs listed on this Annex A.




19