Form SD ALERE INC.
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
ALERE INC.
(Exact Name of Registrant as Specified in its Charter)
Delaware | 1-16789 | 04-3565120 | ||
(State or Other Jurisdiction of Incorporation or Organization) |
(Commission File Number) |
(I.R.S. Employer Identification No.) |
51 Sawyer Road, Suite 200, Waltham, Massachusetts 02459
(Address of Principal Executive Offices) (Zip Code)
Douglas Barry, Associate General Counsel, (781) 647-3900
(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 (17 CFR 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 |
Conflict Minerals Disclosure
Alere Inc. has filed a Conflict Minerals Report as an exhibit to this Specialized Disclosure Report and posted a copy of the Conflict Minerals Report on its publicly available Internet website at http://www.alere.com/en/home/about/our-vision/corporate-responsibility/conflict-minerals.html.
Item 1.02 | Exhibit |
Alere Inc. has filed its Conflict Minerals Report as Exhibit 1.01 to this Specialized Disclosure Report.
Section 2 Exhibits
Item 2.01 | Exhibits |
Exhibit 1.01 Conflicts Minerals Report as required by Items 1.01 and 1.02 of this Form.
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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.
ALERE INC. | ||||||
Date: May 31, 2016 | By: | /s/ Ellen Chiniara | ||||
Ellen Chiniara | ||||||
Senior Vice President, General Counsel, Chief Ethics and Compliance Officer, and Secretary |
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Exhibit 1.01
Alere Inc.
Conflict Minerals Report
For The Year Ended December 31, 2015
This Conflict Minerals Report of Alere Inc., including its consolidated subsidiaries (herein referred to as Alere, the Company, we, us, or our), for the year ended December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the 1934 Act). The Rule was adopted by the Securities and Exchange Commission (the SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold (the Conflict Minerals). These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
If a registrant can establish that the relevant Conflict Minerals for the reporting year originated from sources other than the Democratic Republic of the Congo or an adjoining country (the Covered Countries), or from recycled and scrap sources, it must submit a Form SD for that year which describes its reasonable country of origin inquiry (RCOI).
If a registrant knows or has reason to believe that any of the relevant Conflict Minerals for the reporting year may have originated in the Covered Countries, then it must exercise due diligence on the Conflict Minerals source and chain of custody. The registrant must also submit a Conflict Minerals Report (CMR) for that year to the SEC that includes a description of its due diligence measures.
1. | Company and Products Overview |
We deliver reliable and actionable health information through rapid diagnostic tests, resulting in better clinical and economic healthcare outcomes globally. Our high-performance diagnostics for infectious disease, cardiometabolic disease and toxicology are designed to meet the growing global demand for accurate, easy-to-use and cost-effective near-patient tests. Our goal is to make Alere products accessible to more people around the world, even those located in remote and resource-limited areas, by making them affordable and usable in any setting. By making critical clinical diagnostic information available to doctors and patients in an actionable timeframe, Alere products help streamline healthcare delivery and improve patient outcomes. Our principal executive offices are located at 51 Sawyer Road, Suite 200, Waltham, MA 02453.
Our products for which Conflict Minerals are necessary to their functionality or production (Covered Products) consist of the following:
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| Infectious disease diagnostic products, including Alere Determine HIV-1/2 Ag/Ab Combo, used to identify HIV, Alere CD4 Analyzer, used to stage the progression of HIV, and Alere I, a rapid, instrument-based, isothermal system for the qualitative detection of infectious diseases; |
| Cardiometabolic products, such as our various Alere Triage cardiovascular tests, used in the diagnosis and assessment of cardiovascular disease, our epoc® Blood Analysis System, the first wireless point of care solution for testing blood gas, electrolytes and metabolites at the bedside, and our Afinion Test System, which aids in the early detection of kidney disease often present in diabetic patients; and |
| Toxicology or drugs of abuse tests, such as our Alere Triage TOX Drug Screen panel and our Alere Triage MeterPro system used to detect the presence of many of illicit and prescription drugs. |
Our exposure to Conflict Minerals arises primarily because most of the Covered Products contain electronic components, which can contain one or more Conflict Minerals.
2. | Supply Chain Overview |
We rely upon our direct suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us, including sources of Conflict Minerals that are supplied to them from their own upstream suppliers. We have adopted a Policy on Conflict Minerals, which is described below. Under that policy, we expressly state our expectation that our suppliers will perform similar due diligence on their own supply chains and provide their Conflict Minerals sourcing information to us. We have analyzed both our product components and the role that suppliers play throughout our manufacturing and product delivery processes. We defined the scope of our RCOI and Conflict Minerals due diligence by identifying and reaching out to our suppliers that provide components or engage in manufacturing activities that are reasonably likely to contain Conflict Minerals.
3. | Reasonable Country of Origin Inquiry |
We conducted an analysis of our products by analyzing the materials lists of our operations to determine materials or components reasonably likely to contain Conflict Minerals and concluded that Conflict Minerals may be necessary to the functionality or production of the Covered Products. We then conducted our RCOI with respect to the suppliers of such materials through the use of the standard Conflict Minerals reporting templates developed jointly by the Electronic Industry Citizenship Coalition® (EICC®) and The Global e-Sustainability Initiative (GeSI), known as the Conflict-Free Sourcing Initiative (CSFI) or CFSI Reporting Template (the Template), and launched our RCOI survey to the pertinent suppliers beginning in March 2016. The Template was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide material to a companys supply chain. It includes questions regarding a companys conflict-free policy, engagement with its direct suppliers and a listing of the smelters and refiners the company and its suppliers use. In addition, the Template contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence.
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For 2015, we engaged the services of a consulting firm with supply chain expertise, including expertise in determining the sourcing of conflict minerals, to assist us with our RCOI.
We identified 60 suppliers for inclusion in our RCOI for 2015. We and our consulting firm contacted each supplier initially through e-mail and, for suppliers that either did not respond or that provided incomplete, inconsistent or unclear responses, through an escalating series of contacts, including additional e-mail messages and telephone calls. We received responses from 70% of our suppliers, a substantial improvement from the 45% response rate that we reported for 2014.
We also performed certain quality assurance procedures with respect to the data we received. Working with our consulting firm, we evaluated supplier responses for plausibility, consistence and gaps. If the consulting firm identified any of the following quality concerns, it automatically contacted the supplier for supplemental information:
| one or more smelter or refiners were listed for an unused metal; |
| no smelter or refiner information was provided for a used metal, or an identified smelter or refiner was not a verified metal processor; |
| the supplier confirmed sourcing from the Covered Countries, but the smelters and refiners listed are not known to source from the region; |
| the supplier indicated that it had not received conflict minerals data for each metal from all relevant suppliers; |
| the supplier indicated it had not identified all of the smelters and refiners used for the products included in the declaration scope; |
| the supplier indicated it had not provided all applicable smelter and refiner information received; or |
| the supplier indicated that 100% of the Conflict Minerals for products covered by the declaration originated from recycled or scrap sources, but one or more smelters or refiners listed are not known to be exclusive recyclers. |
Of the responding suppliers, 76% indicated that one or more Conflict Minerals was necessary to the functionality or production of the products supplied to us. The responding suppliers provided us with information regarding 321 known and active smelters and refiners that they had identified as part of our supply chain for those Conflict Minerals. The responding suppliers also identified an additional 36 potential smelters and refiners that have not been verified, including certain companies believed to be inactive.
Based on the information we obtained through our RCOI, we concluded that we had reason to believe that some of the Conflict Minerals in our supply chain for 2015 were or may have been sourced from the Covered Countries. Accordingly, under Rule 13p-1 of the 1934 Act, we were required to perform due diligence on the source and chain of custody of such Conflict Minerals and prepare this Conflict Minerals Report to disclose the results of our efforts.
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4. | Design of Our Due Diligence Process |
Our due diligence processes and efforts have been designed to conform with the five-step framework recommended by the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten.
5. | Due Diligence Measures Performed |
Step 1. Establishment of Strong Management Systems
Our Conflict Minerals due diligence process includes: the development of a Policy on Conflict Minerals, which is posted on our website at www.alere.com under Corporate Responsibility (http://www.alere.com/en/home/about/our-vision/corporate-responsibility/conflict-minerals.html), the establishment of governance structures with cross-functional team members and senior executives, communication to, and engagement of, suppliers, due diligence compliance process and measurement, record keeping and escalation procedures.
Conflict Minerals Policy
Alere Inc. has adopted the following policy on Conflict Minerals:
ALERE INC.
POLICY ON CONFLICT MINERALS
In August 2012, Section 1502 of the Dodd-Frank Act was finalized with specific language relating to conflict minerals, which include tin, tantalum, tungsten, and gold derived in The Democratic Republic of Congo (DRC) or surrounding countries. Some of the mining operations in the DRC are controlled by warring militias who are believed to finance armed conflict with profits from the sale of these minerals. This on-going conflict has been linked to human rights violations, labor abuses, and environmental destruction.
Alere is committed to the responsible sourcing of materials through compliance with the conflict mineral disclosure requirements. The new rules require companies with securities registered in the US that use conflict minerals in their products to determine whether those minerals originated in the DRC or surrounding countries, and disclose this annually on Form SD filed with the Securities and Exchange Commission.
While our supply chain is complex and tracing the source of minerals used in our products is a challenge, we are committed to complying with the new
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reporting requirements and we have implemented appropriate compliance measures. These include reasonable country of origin inquiries and additional supply chain due diligence that follows the framework of the Organisation for Economic Co-operation and Development. We expect our suppliers to perform similar due diligence on their own supply chains and to otherwise cooperate with us as necessary to support these efforts.
Conflict Minerals Compliance Team
Alere has established a system for complying with the applicable rules. We developed a Conflict Minerals Compliance Team, currently comprised of our Senior Vice President, Global Operations, our Vice President, Global Shared Service, our Group Operations Director and our Associate General Counsel. The Conflict Minerals Compliance Team reports directly to our Chief Financial Officer and Executive Vice President. The team established a worldwide compliance process consistent with the OECD due diligence framework and put into place an appropriate process to facilitate future compliance.
System of Controls and Transparency over Supply Chain
We have worked to identify upstream actors in our supply chain through the utilization of the Template. The Template facilitates the transfer of information through the supply chain regarding Conflict Mineral country of origin and smelters and refiners being utilized. The Template also identifies new smelters and refiners.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have trained our relevant worldwide purchasing agents regarding conflict mineral reporting, and established a system to analyze and follow-up on supplier responses to our RCOI. These efforts, along with the work performed by our consultant, have allowed us to render the conclusions and statement annotated in this report.
We also introduced our relevant suppliers to our consulting firms Conflict Minerals Supplier Resources Center, an online educational tool designed to facilitate a deeper understanding of our Conflict Minerals compliance program and educate suppliers regarding the reasons for requesting information regarding Conflict Minerals.
Grievance Mechanism
Alere has established a Policy on Conflict Minerals, which is posted on our website. Alere also provides an ethics hotline to report any concerns about violations of Aleres Code of Conduct and provides a mechanism for escalating any issues and concerns.
Maintenance of Records
Alere has established a documentation and record maintenance mechanism to ensure the retention of relevant documentation in a structured electronic database in accordance with our record retention policy.
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Step 2. Assessment of Risk in the Supply Chain
We compared the smelters and refiners identified by our suppliers against the list of facilities that have received a DRC conflict free designation from any of three internationally recognized certification programs: the CFSI Conflict-Free Smelter Program, the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain-of-Custody Certification program.
Our consulting firm also conducted additional research, including consultation with industry and government associations and direct outreach to smelters and refiners to verify information provided by suppliers. We then identified a list of smelters and refiners for which there was reason to believe that they may be sourcing from the Covered Countries.
Step 3. Implementation of Strategies to Respond to Identified Risks
Alere has a risk management plan, through which the Conflict Minerals program is implemented, managed and monitored. As part of this years due diligence efforts, our consulting firm contacted smelters and refiners that have not been certified as DRC conflict free in order to assess their sourcing practices, including countries of origin and transfer, and due diligence or chain-of-custody procedures. This review included an evaluation of whether the identified smelters and refiners had documented, effective and communicated conflict-free policies in place, relevant accounting systems and traceability documentation.
In addition, as described above, we participate in the EICC-GeSI CFSI industry-wide initiative to disclose upstream actors in the supply chain. In addition, to ensure suppliers understand our expectations, we have posted our Policy on Conflict Minerals on our website. Alere will work with suppliers who are sourcing from non-conflict-free smelters to move towards using conflict-free smelters within a reasonable time frame. The time frame will be dependent on the criticality of the specific part and the availability of alternative suppliers.
Step 4. Independent Third-Party Audit
We do not have a direct relationship with Conflict Minerals smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain with Conflict Minerals. We rely upon the industry (for example, EICC and CFSI) efforts to influence smelters and refiners to get audited and certified through CFSIs Conflict-Free Smelter (CFS) program.
Step 5. Reporting on Due Diligence
Through the preparation and filing of this report, Alere has made a public report regarding its Conflict Minerals compliance program. This report is also available on our corporate website at http://www.alere.com/en/home/about/our-vision/corporate-responsibility/conflict-minerals.html. Alere will report annually on its Conflict Minerals compliance efforts as and to the extent required by Rule 13p-1 of the 1934 Act.
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5. | Due Diligence Results |
To the extent reasonably determinable through our due diligence process as described above, we believe that the smelters and refiners that were used to process the Conflict Minerals for the Covered Products for 2015 included the 321 known and active smelters and refiners listed in Annex A, and potentially one or more of the 36 additional companies identified by our suppliers, which are listed in Annex B, but which we could not identify as known and active smelters or refiners and for which we have no additional sourcing information. Of the 321 known and active smelters and refiners identified by our suppliers, 223, or approximately 69%, have been certified as DRC conflict free by one or more of three internationally recognized programs: the CFSI Conflict-Free Smelter Program, the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain-of-Custody Certification program. Twenty-eight of the 223 DRC conflict free smelters and refiners disclosed that their sources of Conflict Minerals included one or more of the Covered Countries. Of the 98 smelters and refiners not certified as DRC conflict free by one of these three internationally recognized programs, we were able to obtain country of origin information (including recycled or scrap sources) for the Conflict Minerals processed by 55 of them. Of those 55 smelters and refiners, only two indicated that they sourced from a list of counties that included the Covered Countries. For these two smelters and refiners, we did not receive any more detailed information about the source or chain of custody of the Conflict Minerals they obtained from the Covered Countries.
Accordingly, based on our due diligence process, we believe that, of the 321 known and active smelters and refiners in our Conflict Minerals supply chain for 2015, 276, or 86%, were either certified to be DRC conflict free by one or more internationally recognized certification programs or sourced their Conflict Minerals from countries other than the Covered Countries or from recycled or scrap materials. Further, of the 30 smelters and refiners that disclosed that they sourced Conflict Minerals from the Covered Countries, 28, or 93%, were certified to be DRC conflict free by one or more internationally recognized certification programs.
We believe that the countries of origin of the Conflict Minerals contained in the Covered Products for 2015 include the countries listed in Annex C. At this time, we are unable to form the basis for a reasonable belief as to which of the smelters and refiners named by our suppliers processed the specific Conflict Minerals that were necessary to the functionality or production of the Covered Products.
6. | Anticipated Future Actions |
We intend to take the following steps to continue to improve our due diligence and further mitigate the risk that the necessary Conflict Minerals in our products could benefit armed groups in the DRC or adjoining countries:
| Enhance supplier communication and training to improve due diligence data accuracy and completion. |
| Continue to influence additional smelters to obtain CFS status through our supply chain, where possible. |
| Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
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| Engage any of our suppliers found to be supplying us with Conflict Minerals from sources that support conflict in the Covered Countries to establish an alternative source of Conflict Minerals that does not support such conflict. |
We plan to report on our progress with these efforts in any Forms SD or Conflict Minerals Reports that we may file in the future.
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Annex A
Metal |
Official Smelter Name |
Smelter Country |
Certified Smelter | |||
Gold | Advanced Chemical Company | United States | NO | |||
Gold | Aida Chemical Industries Co., Ltd. | Japan | YES | |||
Gold | Aktyubinsk Copper Company TOO | Kazakhstan | NO | |||
Gold | Al Etihad Gold | United Arab Emirates | NO | |||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | YES | |||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | YES | |||
Gold | AngloGold Ashanti Córrego do Sítio Mineração | Brazil | YES | |||
Gold | Argor-Heraeus SA | Switzerland | YES | |||
Gold | Asahi Pretec Corporation | Japan | YES | |||
Gold | Asahi Refining Canada Limited | Canada | YES | |||
Gold | Asahi Refining USA Inc. | United States | YES | |||
Gold | Asaka Riken Co., Ltd. | Japan | YES | |||
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | NO | |||
Gold | Aurubis AG | Germany | YES | |||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | YES | |||
Gold | Bauer Walser AG | Germany | NO | |||
Gold | Boliden AB | Sweden | YES | |||
Gold | C. Hafner GmbH + Co. KG | Germany | YES | |||
Gold | Caridad | Mexico | NO | |||
Gold | CCR Refinery - Glencore Canada Corporation | Canada | YES | |||
Gold | Cendres + Métaux SA | Switzerland | NO | |||
Gold | Chimet S.p.A. | Italy | YES | |||
Gold | Chugai Mining | Japan | NO | |||
Gold | Codelco | Chile | NO | |||
Gold | Daejin Indus Co., Ltd. | South Korea | NO | |||
Gold | Daye Non-Ferrous Metals Mining Ltd. | China | NO | |||
Gold | DODUCO GmbH | Germany | YES | |||
Gold | Dowa | Japan | NO | |||
Gold | DSC (Do Sung Corporation) | South Korea | NO | |||
Gold | Eco-System Recycling Co., Ltd. | Japan | YES | |||
Gold | Elemetal Refining, LLC | United States | YES | |||
Gold | Emirates Gold DMCC | United Arab Emirates | NO | |||
Gold | Faggi Enrico S.p.A. | Italy | NO | |||
Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | NO | |||
Gold | Gansu Seemine Material Hi-Tech Co Ltd | China | NO | |||
Gold | Geib Refining Corporation | United States | NO | |||
Gold | Guangdong Jinding Gold Limited | China | NO | |||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | NO | |||
Gold | Heimerle + Meule GmbH | Germany | YES | |||
Gold | Heraeus Ltd. Hong Kong | China | YES | |||
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | YES | |||
Gold | Hunan Chenzhou Mining Co., Ltd. | China | NO | |||
Gold | Hwasung CJ Co. Ltd | South Korea | NO |
Annex A
Metal |
Official Smelter Name |
Smelter Country |
Certified Smelter | |||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | China | YES | |||
Gold | Ishifuku Metal Industry Co., Ltd. | Japan | YES | |||
Gold | Istanbul Gold Refinery | Turkey | YES | |||
Gold | Japan Mint | Japan | YES | |||
Gold | Jiangxi Copper Company Limited | China | YES | |||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russia | YES | |||
Gold | JSC Uralelectromed | Russia | YES | |||
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | YES | |||
Gold | Kaloti Precious Metals | United Arab Emirates | NO | |||
Gold | Kazakhmys plc | Kazakhstan | NO | |||
Gold | Kazzinc | Kazakhstan | YES | |||
Gold | Kennecott Utah Copper LLC | United States | YES | |||
Gold | KGHM Polska Miedź Spółka Akcyjna | Poland | NO | |||
Gold | Kojima Chemicals Co., Ltd. | Japan | YES | |||
Gold | Korea Metal Co. Ltd | South Korea | NO | |||
Gold | Korea Zinc Co. Ltd. | South Korea | NO | |||
Gold | Kyrgyzaltyn JSC | Kyrgyzstan | YES | |||
Gold | L azurde Company For Jewelry | Saudi Arabia | NO | |||
Gold | Lingbao Gold Company Ltd. | China | NO | |||
Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | China | NO | |||
Gold | LS-NIKKO Copper Inc. | South Korea | YES | |||
Gold | Luo yang Zijin Yinhui Metal Smelt Co Ltd | China | NO | |||
Gold | Materion | United States | YES | |||
Gold | Matsuda Sangyo Co., Ltd. | Japan | YES | |||
Gold | Metahub Industries Sdn. Bhd. | Malaysia | NO | |||
Gold | Metalor Technologies (Hong Kong) Ltd. | China | YES | |||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | YES | |||
Gold | Metalor Technologies (Suzhou) Co Ltd | China | NO | |||
Gold | Metalor Technologies SA | Switzerland | YES | |||
Gold | Metalor USA Refining Corporation | United States | YES | |||
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | Mexico | YES | |||
Gold | Mitsubishi Materials Corporation | Japan | YES | |||
Gold | Mitsui Mining & Smelting | Japan | YES | |||
Gold | MMTC-PAMP India Pvt., Ltd. | India | YES | |||
Gold | Morris and Watson | New Zealand | NO | |||
Gold | Moscow Special Alloys Processing Plant | Russia | YES | |||
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey | YES | |||
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | YES | |||
Gold | Nihon Material Co., Ltd. | Japan | YES | |||
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Austria | YES | |||
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | YES | |||
Gold | OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) | Russia | YES | |||
Gold | OJSC Kolyma Refinery | Russia | NO | |||
Gold | OJSC Novosibirsk Refinery | Russia | YES | |||
Gold | PAMP SA | Switzerland | YES | |||
Gold | Penglai Penggang Gold Industry Co Ltd | China | NO | |||
Gold | Prioksky Plant of Non-Ferrous Metals | Russia | YES |
Annex A
Metal |
Official Smelter Name |
Smelter Country |
Certified Smelter | |||
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | YES | |||
Gold | PX Prcinox SA | Switzerland | YES | |||
Gold | Rand Refinery (Pty) Ltd. | South Africa | YES | |||
Gold | Republic Metals Corporation | United States | YES | |||
Gold | Royal Canadian Mint | Canada | YES | |||
Gold | Sabin Metal Corp. | United States | NO | |||
Gold | Samduck Precious Metals | South Korea | NO | |||
Gold | SAMWON METALS Corp. | South Korea | NO | |||
Gold | SAXONIA Edelmetalle GmbH | Germany | NO | |||
Gold | Schone Edelmetaal B.V. | Netherlands | YES | |||
Gold | SEMPSA Joyería Platería SA | Spain | YES | |||
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | NO | |||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | YES | |||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | YES | |||
Gold | Singway Technology Co., Ltd. | Taiwan | YES | |||
Gold | So Accurate Group, Inc. | United States | NO | |||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russia | YES | |||
Gold | Solar Applied Materials Technology Corp. | Taiwan | YES | |||
Gold | Sudan Gold Refinery | Sudan | NO | |||
Gold | Sumitomo Metal Mining Co., Ltd. | Japan | YES | |||
Gold | T.C.A S.p.A | Italy | YES | |||
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | YES | |||
Gold | The Great Wall Gold and Silver Refinery of China | China | YES | |||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | YES | |||
Gold | Tokuriki Honten Co., Ltd. | Japan | YES | |||
Gold | TongLing Nonferrous Metals Group Holdings Co., Ltd. | China | NO | |||
Gold | Torecom | South Korea | NO | |||
Gold | Umicore Brasil Ltda. | Brazil | YES | |||
Gold | Umicore Precious Metals Thailand | Thailand | YES | |||
Gold | Umicore SA Business Unit Precious Metals Refining | Belgium | YES | |||
Gold | United Precious Metal Refining, Inc. | United States | YES | |||
Gold | Valcambi SA | Switzerland | YES | |||
Gold | Western Australian Mint trading as The Perth Mint | Australia | YES | |||
Gold | WIELAND Edelmetalle GmbH | Germany | NO | |||
Gold | Yamamoto Precious Metal Co., Ltd. | Japan | YES | |||
Gold | Yantai Guodasafina High-tech Environmental Refinery CO., Ltd. | China | NO | |||
Gold | Yokohama Metal Co., Ltd. | Japan | YES | |||
Gold | Yunnan Copper Industry Co Ltd | China | NO | |||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | YES | |||
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | China | YES | |||
Tantalum | Avon Specialty Metals Ltd | United Kingdom | NO | |||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | YES | |||
Tantalum | Conghua Tantalum and Niobium Smeltry | China | YES | |||
Tantalum | D Block Metals, LLC | United States | YES | |||
Tantalum | Duoluoshan | China | YES | |||
Tantalum | E.S.R. Electronics | United States | NO | |||
Tantalum | Exotech Inc. | United States | YES |
Annex A
Metal |
Official Smelter Name |
Smelter Country |
Certified Smelter | |||
Tantalum | F&X Electro-Materials Ltd. | China | YES | |||
Tantalum | FIR Metals & Resource Ltd. | China | YES | |||
Tantalum | Global Advanced Metals Aizu | Japan | YES | |||
Tantalum | Global Advanced Metals Boyertown | United States | YES | |||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | YES | |||
Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | China | NO | |||
Tantalum | H.C. Starck Co., Ltd. | Thailand | YES | |||
Tantalum | H.C. Starck GmbH Goslar | Germany | YES | |||
Tantalum | H.C. Starck GmbH Laufenburg | Germany | YES | |||
Tantalum | H.C. Starck Hermsdorf GmbH | Germany | YES | |||
Tantalum | H.C. Starck Inc. | United States | YES | |||
Tantalum | H.C. Starck Ltd. | Japan | YES | |||
Tantalum | H.C. Starck Smelting GmbH & Co.KG | Germany | YES | |||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | YES | |||
Tantalum | Hi-Temp Specialty Metals, Inc. | United States | YES | |||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd | China | YES | |||
Tantalum | Jiangxi Tuohong New Raw Material | China | NO | |||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | YES | |||
Tantalum | Jiujiang Tanbre Co., Ltd. | China | YES | |||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | YES | |||
Tantalum | KEMET Blue Metals | United States | YES | |||
Tantalum | Kemet Blue Powder | United States | YES | |||
Tantalum | King-Tan Tantalum Industry Ltd. | China | YES | |||
Tantalum | LSM Brasil S.A. | Brazil | YES | |||
Tantalum | Metallurgical Products India Pvt., Ltd. | India | YES | |||
Tantalum | Mineração Taboca S.A. | Brazil | NO | |||
Tantalum | Mitsui Mining & Smelting | Japan | YES | |||
Tantalum | Molycorp Silmet A.S. | Estonia | YES | |||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | YES | |||
Tantalum | Plansee SE Liezen | Austria | YES | |||
Tantalum | Plansee SE Reutte | Austria | YES | |||
Tantalum | QuantumClean | United States | YES | |||
Tantalum | Resind Indústria e Comércio Ltda. | Brazil | NO | |||
Tantalum | RFH Tantalum Smeltry Co., Ltd. | China | YES | |||
Tantalum | Solikamsk Magnesium Works OAO | Russia | YES | |||
Tantalum | Taki Chemicals | Japan | YES | |||
Tantalum | Telex Metals | United States | YES | |||
Tantalum | Tranzact, Inc. | United States | YES | |||
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | YES | |||
Tantalum | XinXing Haorong Electronic Material Co., Ltd. | China | YES | |||
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China | YES | |||
Tantalum | Zhuzhou Cemented Carbide | China | YES | |||
Tin | Alpha | United States | YES | |||
Tin | An Thai Minerals Company Limited | Vietnam | YES | |||
Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam | NO | |||
Tin | Best Metais e Soldas SA | Brazil | NO | |||
Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | China | NO |
Annex A
Metal |
Official Smelter Name |
Smelter Country |
Certified Smelter | |||
Tin | China Tin Group Co., Ltd. | China | YES | |||
Tin | CNMC (Guangxi) PGMA Co. Ltd. | China | NO | |||
Tin | Cooperativa Metalurgica de Rondônia Ltda. | Brazil | YES | |||
Tin | CV Ayi Jaya | Indonesia | YES | |||
Tin | CV Dua Sekawan | Indonesia | NO | |||
Tin | CV Duta Putra Bangka | Indonesia | NO | |||
Tin | CV Gita Pesona | Indonesia | YES | |||
Tin | CV Serumpun Sebalai | Indonesia | YES | |||
Tin | CV Tiga Sekawan | Indonesia | NO | |||
Tin | CV United Smelting | Indonesia | YES | |||
Tin | CV Venus Inti Perkasa | Indonesia | YES | |||
Tin | Dowa | Japan | NO | |||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam | NO | |||
Tin | Elmet S.L.U. (Metallo Group) | Spain | YES | |||
Tin | EM Vinto | Bolivia | YES | |||
Tin | Estanho de Rondônia S.A. | Brazil | NO | |||
Tin | Feinhutte Halsbrucke GmbH | Germany | NO | |||
Tin | Fenix Metals | Poland | YES | |||
Tin | Gejiu Fengming Metalurgy Chemical Plant | China | NO | |||
Tin | Gejiu Kai Meng Industry and Trade LLC | China | YES | |||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | YES | |||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | NO | |||
Tin | Gejiu Zi-Li | China | NO | |||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China | NO | |||
Tin | HuiChang Hill Tin Industry Co., Ltd. | China | NO | |||
Tin | Huichang Jinshunda Tin Co. Ltd | China | NO | |||
Tin | Jean Goldschmidt International SA | Belgium | NO | |||
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China | YES | |||
Tin | Linwu Xianggui Smelter Co | China | NO | |||
Tin | Magnus Minerais Metais e Ligas Ltda. | Brazil | YES | |||
Tin | Malaysia Smelting Corporation (MSC) | Malaysia | YES | |||
Tin | Melt Metais e Ligas S/A | Brazil | YES | |||
Tin | Metahub Industries Sdn. Bhd. | Malaysia | NO | |||
Tin | Metallic Resources, Inc. | United States | YES | |||
Tin | Metallo-Chimique N.V. | Belgium | YES | |||
Tin | Mineração Taboca S.A. | Brazil | NO | |||
Tin | Minsur | Peru | YES | |||
Tin | Mitsubishi Materials Corporation | Japan | YES | |||
Tin | Nankang Nanshan Tin Co., Ltd. | China | NO | |||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam | NO | |||
Tin | Novosibirsk Integrated Tin Works | Russia | NO | |||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | YES | |||
Tin | O.M. Manufacturing Philippines, Inc. | Philippines | YES | |||
Tin | Operaciones Metalurgical S.A. | Bolivia | YES | |||
Tin | Phoenix Metal Ltd | Rwanda | NO | |||
Tin | PT Alam Lestari Kencana | Indonesia | NO | |||
Tin | PT Aries Kencana Sejahtera | Indonesia | YES |
Annex A
Metal |
Official Smelter Name |
Smelter Country |
Certified Smelter | |||
Tin | PT Artha Cipta Langgeng | Indonesia | YES | |||
Tin | PT ATD Makmur Mandiri Jaya | Indonesia | YES | |||
Tin | PT Babel Inti Perkasa | Indonesia | YES | |||
Tin | PT Bangka Kudai Tin | Indonesia | NO | |||
Tin | PT Bangka Prima Tin | Indonesia | YES | |||
Tin | PT Bangka Timah Utama Sejahtera | Indonesia | NO | |||
Tin | PT Bangka Tin Industry | Indonesia | YES | |||
Tin | PT Belitung Industri Sejahtera | Indonesia | YES | |||
Tin | PT BilliTin Makmur Lestari | Indonesia | YES | |||
Tin | PT Bukit Timah | Indonesia | YES | |||
Tin | PT Cipta Persada Mulia | Indonesia | YES | |||
Tin | PT DS Jaya Abadi | Indonesia | YES | |||
Tin | PT Eunindo Usaha Mandiri | Indonesia | YES | |||
Tin | PT Fang Di MulTindo | Indonesia | NO | |||
Tin | PT Inti Stania Prima | Indonesia | YES | |||
Tin | PT Justindo | Indonesia | YES | |||
Tin | PT Karimun Mining | Indonesia | NO | |||
Tin | PT Kijang Jaya Mandiri | Indonesia | NO | |||
Tin | PT Mitra Stania Prima | Indonesia | YES | |||
Tin | PT Panca Mega Persada | Indonesia | YES | |||
Tin | PT Pelat Timah Nusantara Tbk | Indonesia | NO | |||
Tin | PT Prima Timah Utama | Indonesia | YES | |||
Tin | PT Refined Bangka Tin | Indonesia | YES | |||
Tin | PT Sariwiguna Binasentosa | Indonesia | YES | |||
Tin | PT Seirama Tin investment | Indonesia | NO | |||
Tin | PT Stanindo Inti Perkasa | Indonesia | YES | |||
Tin | PT Sukses Inti Makmur | Indonesia | YES | |||
Tin | PT Sumber Jaya Indah | Indonesia | YES | |||
Tin | PT Timah (Persero) Tbk Kundur | Indonesia | YES | |||
Tin | PT Timah (Persero) Tbk Mentok | Indonesia | YES | |||
Tin | PT Tinindo Inter Nusa | Indonesia | YES | |||
Tin | PT Tirus Putra Mandiri | Indonesia | NO | |||
Tin | PT Tommy Utama | Indonesia | YES | |||
Tin | PT WAHANA PERKIT JAYA | Indonesia | YES | |||
Tin | Resind Indústria e Comércio Ltda. | Brazil | NO | |||
Tin | Rui Da Hung | Taiwan | YES | |||
Tin | Soft Metais Ltda. | Brazil | YES | |||
Tin | Thaisarco | Thailand | YES | |||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam | NO | |||
Tin | VQB Mineral and Trading Group JSC | Vietnam | YES | |||
Tin | White Solder Metalurgia e Mineração Ltda. | Brazil | YES | |||
Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | China | YES | |||
Tin | Yunnan Tin Group (Holding) Company Limited | China | YES | |||
Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | YES | |||
Tungsten | ACL Metais Eireli | Brazil | NO | |||
Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam | YES | |||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | YES |
Annex A
Metal |
Official Smelter Name |
Smelter Country |
Certified Smelter | |||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | YES | |||
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | China | YES | |||
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China | YES | |||
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | YES | |||
Tungsten | Ganxian Shirui New Material Co., Ltd. | China | NO | |||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | YES | |||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | YES | |||
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | China | YES | |||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | YES | |||
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China | YES | |||
Tungsten | Global Tungsten & Powders Corp. | United States | YES | |||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | YES | |||
Tungsten | H.C. Starck GmbH | Germany | YES | |||
Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany | YES | |||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | NO | |||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China | YES | |||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | China | YES | |||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | YES | |||
Tungsten | Hydrometallurg, JSC | Russia | YES | |||
Tungsten | Japan New Metals Co., Ltd. | Japan | YES | |||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | YES | |||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | YES | |||
Tungsten | Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd. | China | NO | |||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | YES | |||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | YES | |||
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China | YES | |||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | YES | |||
Tungsten | Kennametal Fallon | United States | YES | |||
Tungsten | Kennametal Huntsville | United States | YES | |||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | YES | |||
Tungsten | Niagara Refining LLC | United States | YES | |||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam | YES | |||
Tungsten | Pobedit, JSC | Russia | YES | |||
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | Vietnam | YES | |||
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China | NO | |||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam | YES | |||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam | YES | |||
Tungsten | Wolfram Bergbau und Hütten AG | Austria | YES | |||
Tungsten | Woltech Korea Co., Ltd. | South Korea | NO | |||
Tungsten | Xiamen Tungsten Co., Ltd. | China | YES | |||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | NO | |||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | YES | |||
Tungsten | Zhuzhou Cemented Carbide | China | NO |
Annex B
Additional Unverified Smelters
| Brinkmann Chemie GmbH |
| CFC Cooperativa dos Fundidores de Cassiterita da Amazonia Ltda. |
| China Gold Deal Investment Co., Ltd. |
| China Minmetals Corporation |
| China National Gold Group Corporation |
| Colt Refining |
| CV Makmur Jaya |
| Ganzhou Hongfei Tungsten & Molybdenum Materials Co., Ltd. |
| Global Advanced Metals |
| Gold Bell Group |
| H.C. Starck/H.C. Starck Group |
| Huanggang Tongding Metal Material Co., Ltd. |
| Japanese House Manufacturing |
| Jiangxi Richsea New Materials Co., Ltd. |
| JingDong chemical Material |
| Kunshan Jinli Chemical Industry Reagents Co Ltd. |
| Leqing Zongli Non-ferrous metal material Corporation |
| Minmetals Ganzhou Tin Co. Ltd. |
| Nathan Trotter |
| Norddeutshe Affinerie |
| Novosibirsk Processing Plant Ltd. |
| Plansee |
| PT Babel Surya Alam Lestari |
| PT Bangka Putra Karya |
| PT Hanjaya Perkasa Metals |
| PT HP Metals Indonesia |
| PT Koba Tin |
| PT Tambang Timah |
| PT Yinchendo Mining Industry |
| Remondis Argentia B.V. |
| Samwha Group |
| Sanmenxia Hengsheng Science and Technology R&D Co. Ltd. |
| Shandong Gold&Silver Refinery Co. |
| Shanghai Jiangxi Metals Co., Ltd. |
| Tantalite Resources |
| Wolfram Company CJSC |
Annex C
Countries of Origin
| Argentina |
| Armenia |
| Australia |
| Austria |
| Belarus |
| Belgium |
| Bolivia |
| Brazil |
| Burundi |
| Canada |
| Chile |
| China |
| DRC- Congo (Kinshasa) |
| Estonia |
| Ethiopia |
| France |
| Germany |
| Ghana |
| Guinea |
| Guyana |
| Hong Kong |
| India |
| Indonesia |
| Italy |
| Japan |
| Kazakhstan |
| Kyrgyzstan |
| Laos |
| Malaysia |
| Mali |
| Mexico |
| Mongolia |
| Morocco |
| Mozambique |
| Myanmar |
| Namibia |
| Netherlands |
| Niger |
| Nigeria |
| Papua New Guinea |
Annex C
| Peru |
| Philippines |
| Poland |
| Portugal |
| Russia |
| Rwanda |
| Saudi Arabia |
| Sierra Leone |
| Singapore |
| South Africa |
| Spain |
| Suriname |
| Sweden |
| Switzerland |
| Taiwan |
| Tajikistan |
| Tanzania |
| Thailand |
| Turkey |
| United Arab Emirates |
| United Kingdom |
| United States |
| Uzbekistan |
| Vietnam |
| Zambia |
| Zimbabwe |
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