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Form SD WABASH NATIONAL CORP

May 27, 2016 8:01 AM EDT

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

Form SD

 

SPECIALIZED DISCLOSURE REPORT

 

 

 

Wabash National Corporation

(Exact Name of Registrant as Specified in Charter)

 

Delaware 1-10883 52-1375208
(State or Other Jurisdiction (Commission File No.) (I.R.S. Employer
of Incorporation)   Identification Number)

 

1000 Sagamore Parkway South, Lafayette, Indiana 47905
(Address of Principal Executive Offices) (Zip Code)

  

765-771-5300

(Registrant’s telephone number, including area code)

 

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:

 

xRule 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

 

Items 1.01 Conflict Minerals Disclosure and Report, Exhibits

 

A copy of Wabash National Corporation’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available on the Company’s website at www.wabashnational.com. A copy of Wabash National Corporation’s Conflict Minerals Policy Statement is also publically available on the Company’s website above or using the direct link at Wabash National's Conflict Minerals Policy.

 

Item 1.02 Exhibit

 

As specified in this Form SD, Wabash National Corporation is hereby filing its Conflict Minerals Report as Exhibit 1.01.

 

Section 2 - Exhibits

 

Exhibits 1.01 - Conflict Minerals Report as required by Item 1.01 of this Form.

 

 

 

 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.

 

  WABASH NATIONAL CORPORATION  
       
Date: May 27, 2016 By: /s/ Jeffery L. Taylor  
    Jeffery L. Taylor  
    Senior Vice President and Chief Financial Officer  

 

 

 

Exhibit 1.01

Wabash National Corporation

Conflict Minerals Report

For The Year Ended December 31, 2015

 

This report for the year ending December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). 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 that 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 (“3TG”). These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.

 

As described in detail below, following reasonable due diligence conducted with our supply base into the source and chain of custody of Conflict Minerals in our products, we are unable with absolute assurance to determine the origin of the Conflict Minerals in our products and therefore cannot exclude the possibility that some may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”), or from recycled and scrap sources. For that reason, we are required under the Rule to submit to the SEC this Conflict Minerals Report (“CMR”) as an Exhibit to Form SD. In accordance with the Organization for Economic Cooperation and Development (the “OECD”) Guidance and the Rule, this report is available on our website at www.wabashnational.com. This CMR is not subject to an independent private sector audit in accordance to guidance issued by the SEC in April of 2014.

 

1. Company Overview

 

This report has been prepared by management of Wabash National Corporation (herein referred to as “Wabash,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries that are required to be consolidated. Headquartered in Lafayette, Indiana, Wabash National Corporation (NYSE: WNC) is a diversified industrial manufacturer and North America’s leading producer of semi-trailers and liquid transportation systems. Established in 1985, the Company manufactures a diverse range of products including: dry freight and refrigerated trailers, platform trailers, bulk tank trailers, dry and refrigerated truck bodies, truck mounted tanks, intermodal equipment, aircraft refueling equipment, structural composite panels and products, trailer aerodynamic solutions, and specialty food grade and pharmaceutical equipment. Its innovative products, which could possibly contain 3TGs, are sold under the following brand names: Wabash National®, Transcraft®, Benson®, DuraPlate®, Walker Transport, Walker Engineered Products, Brenner® Tank, Beall®, Garsite, Progress Tank, Bulk Tank International and Extract Technology®. To learn more, visit www.wabashnational.com

 

Supply chain

Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify entities upstream from our suppliers who provide us with products and/or raw materials necessary to the functionality or production of our products (“Direct Suppliers”). As such, we rely heavily on 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 lower tier suppliers. Current contracts with most of our key Direct Suppliers, which account for the majority of our sourced materials, are in effect for multiple year terms, thus we cannot unilaterally impose new contract terms and flow-down requirements at this time. As we execute new contracts and/or renew contracts, we are requiring affected Direct Suppliers to provide us with geographic origin information concerning Conflict Minerals and smelters. Additionally, all new Direct Suppliers receive Conflict Minerals reporting requirements as a part of our new supplier information packet. It will take several years to ensure that all of our Direct Suppliers are contractually obligated to report this information to us as part of their normal business interactions with us. In the meantime, as described below, we have established a process to contact affected Direct Suppliers to collect necessary Conflict Minerals sourcing information. We have used and will continue to use the data collected through the process described below, and through our contractually obligated disclosures from our Direct Suppliers, to evaluate our supply chain to ensure compliance with the SEC’s Conflict Minerals rules.

 

 

 

 

Presently, our supply chain consists of over 12,000 suppliers, including many suppliers providing us with services and/or products that are not necessary to the functionality or production of our products and/or products that do not contain Conflict Minerals. As such, it was not practicable to conduct a survey of our entire supply base. Instead, we targeted only those Direct Suppliers that we believed, based upon an evaluation of the composition of the product and/or raw material they supplied, could possibly supply us with products containing Conflict Minerals. Upon removal of intracompany-supplied products and retail purchases the population of Direct Suppliers surveyed was set at approximately 1,200. The Company contacted these approximately 1,200 Direct Suppliers, requesting each to provide Conflict Minerals geographic origin data in the Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (“CMRT”). Surveys conducted with other manufacturing companies confirmed that our risk-based approach to developing our list of our surveyed Direct Suppliers, as described above, is consistent with how many peer companies are approaching the Rule.

 

At this time, having conducted this due diligence process, our products that are subject to the reporting obligations of the Rule are “DRC conflict undeterminable,” as we are unable to determine all of the following with regard to all Conflict Minerals present in our supply chain that are necessary to the functionality or production of our products: (1) the origin of the Conflict Minerals and/or the 3TG they contain (or to determine whether they come from recycled or scrap sources) or (2) the location of the facilities used to process them and/or origin mines.

 

Conflict Minerals Policy

Wabash is committed to working with our global supply chain to ensure compliance with the SEC’s Rule. We have established a Conflict Minerals compliance program, as outlined above, that is designed to follow the framework established by the OECD. Our enterprise is fully engaged in implementing that program.

 

For additional information about our commitment to responsible sourcing and other human rights, see our Conflict Minerals Policy and Code of Business Conduct and Ethics, which are both publicly available on our website at www.wabashnational.com.

 

2. Due Diligence Process

 


2.1 Design of Due Diligence

 

Our due diligence measures have been designed to conform, in all material respects, with the framework in The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for Conflict Minerals.

 

2.2 Establish Strong Company Management Systems

 

Internal Team

Our Senior Vice President – General Counsel and our Vice President of Global Strategic Sourcing established a cross-functional team of subject matter experts from relevant functions of finance, legal, and supply chain to create our Conflict Minerals compliance program and due diligence efforts necessary to comply with the Rule. As part of this team, our Global Director of Strategic Sourcing, a Strategic Commodity Manager and a Global Strategic Sourcing Assistant lead our ongoing due diligence efforts with our Direct Suppliers. Senior management and members of our Audit Committee are briefed about the results of our due diligence efforts on a regular basis.

 

Control systems

As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in the transportation industry and other relevant sectors, as well as our own Direct Suppliers to encourage the disclosure of all the conflict mineral status of the upstream entities held in common by our various supply chains. Our due diligence process includes utilization of industry-wide initiatives to disclose upstream entities in the supply chain, such as the CMRT and the CFSI certified smelter list.

 

 

 

 

Our controls include, but are not limited to, our Code of Conduct which outlines expected behaviors for all Wabash National employees and suppliers. Going forward, as discussed above, our controls will also include contractual disclosure requirements in our Direct Supplier contracts.

 

Supplier Engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have invested in tools and developed internal processes and procedures to query and track supplier activity. In addition, we have included Conflict Minerals reporting requirements in our new supplier packets and we will continue to request Conflict Minerals reporting data annually from all of our Direct Suppliers. We will also utilize key opportunities such as annual Executive Management Reviews with our suppliers to reinforce and review compliance.

 

Grievance Mechanism

We have multiple mechanisms and processes for employees and suppliers to use to report violations of Wabash’s policies. These are described in our Code of Business Conduct and Ethics policy, which is publicly available on our website at www.wabashnational.com

 

Maintain records

We have adopted a policy to retain relevant documentation requested from and disclosed by our suppliers.

 

2.3 Identify and assess risk in the supply chain

 

As outlined previously, since we do not typically have a direct relationship with 3TG smelters and refiners, our due diligence efforts undertaken to comply with the Rule rely heavily on our Direct Suppliers providing us with information about the source of Conflict Minerals contained in the products and raw materials supplied to us. Our Direct Suppliers are similarly reliant upon information provided by their suppliers. Many of our largest suppliers are also SEC registrants and subject to the Rule. However, our ability to comply with the Rule is dependent upon receipt of complete and accurate information from our Direct Suppliers.

 

2.4 Design and Implement a Strategy to Respond to Risks

 

In response to this risk assessment, Wabash has an approved risk management plan, through which the Conflict Minerals program is implemented, managed and monitored. As part of the risk management efforts undertaken as part of the Conflict Minerals program, our Global Director of Strategic Sourcing, a Strategic Commodity Manager and a Global Strategic Sourcing Assistant regularly review Conflict Minerals data provided by our Direct Suppliers. Direct Suppliers who provide incomplete or inconsistent Conflict Minerals data are contacted to update and confirm the data provided until Wabash can conclude with a reasonable degree of certainty that the provided data is likely accurate. Updates regarding our due diligence process and this risk assessment are provided regularly to senior management and the Audit Committee.

 

As described above, we also utilize and participate in several industry-wide initiatives to disclose the conflict mineral status of upstream entities in the supply chain. We will continue to pursue training and participate in seminars to increase our awareness and further enhance our compliance. As part of our risk management plan, and to ensure suppliers understand our ongoing expectations to provide accurate and complete Conflict Minerals data, we will continue to engage suppliers in various ways such as training sessions, Executive Management Reviews and our annual supplier conference.

 

2.5 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

 

Since we do not have a direct relationship with 3TG smelters and refiners, we do not perform or direct audits of these upstream entities within our supply chain. We will support audits by our supply base, as necessary, and have augmented our own Direct Supplier audit process with questions and procedures to address compliance by our Direct Suppliers with the Rule.

 

 

 

 

2.6 Report on supply chain due diligence

 

Wabash has filed a Form SD which includes this report and made such information available on our website, demonstrating our progress in implementing our Conflict Minerals Policy.

 

3. Due Diligence Results

 

Request Information

As described above, we conducted a survey of certain Direct Suppliers using the CMRT, which was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a supplier’s conflict-free policies, engagement with its direct suppliers, and a listing of the smelters the suppliers (and its suppliers) utilize in their own supply chain. In addition, the CMRT contains questions about the origin of Conflict Minerals included in suppliers’ products, as well as suppliers’ due diligence efforts. Written instructions and recorded training illustrating the use of the tool is available on CFSI’s website. The CMRT is being used by many of our peer companies in their due diligence processes related to Conflict Minerals.

 

Survey Responses

To date, we’ve received responses from 70% of the approximately 1,200 Direct Suppliers surveyed, which represents approximately 99% of Wabash’s direct material spend surveyed in 2015. We reviewed the responses provided against criteria developed to determine whether further engagement with our Direct Suppliers was necessary. These criteria included: (1) untimely or incomplete responses, (2) inconsistencies within the data reported in the CMRT or in other provided documentation, or (3) uncertainty in the accuracy of the data reported in light of the product supplied by the Direct Supplier. We have worked directly with these Direct Suppliers until we received data sufficient to allow Wabash to conclude with a reasonable degree of certainty that the provided data is likely accurate.

 

Approximately 85% of our responding Direct Suppliers reported using no 3TG in products sold to Wabash; 10% provided insufficient detail rendering their responses undeterminable; 3% reported using 3TG in their products but could not certify the smelters being utilized or their country of origin; and the remaining 2% reported using 3TG from within the Covered Countries from non-certified smelters. In all cases where 3TG was reported being used, it cannot be determined if Conflict Minerals were in the products sold to Wabash. Of the thousands of lines of smelter data reported to us, there were only 318 unique smelter identification numbers reported, of which only 246 smelters were identified, based on the CFSI Conflict-Free Smelter Program Assessment protocol. Of these, 207 were validated as compliant, 35 are active, indicating they have committed to the audit process and 4 tungsten smelters are progressing toward validation. As we do not typically have a direct relationship with 3TG smelters and refiners, and thus are unable to directly audit or request documentation from these facilities, Wabash supports the refinement and expansion of the list of participating smelters through the CFSI program.

 

Additionally, a large majority of our responding Direct Suppliers provided Conflict Minerals data to us at a company or divisional level – and did not specify whether the particular products, parts or raw materials specifically supplied to Wabash: (1) contained Conflict Minerals or (2) originated from a supply chain that included mines, smelters, or refiners containing/using Conflict Minerals. These “blanket responses” covering the totality of what these Direct Suppliers sell in aggregate to their customers, do not allow us to determine whether any of the Conflict Minerals reported by these Direct Suppliers are actually contained in the particular products, parts or raw materials the Direct Supplier sells specifically to Wabash. Therefore, we are also unable to validate whether any of the smelters or refiners (described above) who were disclosed by our Direct Suppliers as being part of the Direct Supplier’s overall supply chain, are actually part of Wabash’s supply chain.

 

Efforts to determine mine or location of origin

Through our utilization of CFSI tools, the OECD implementation guidelines, and requesting our Direct Suppliers to complete the CMRT, we have determined that seeking information about 3TG smelters and refiners through our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.

 

 

 

 

Smelters or Refiners

Based on Direct Supplier responses received to date:

·85% of respondents reported using no 3TG in their products and, therefore, utilize no smelters or refiners of concern.
·The remaining 15% of respondents reported either: (1) no smelter information available or (2) a list of smelters utilized in their respective supply chains.
·When smelter and refiner lists included smelter identification numbers in a response, Wabash was able to verify the following about those smelters:
·65% are conflict –free

·11% are active

·1% are progressing toward validation

·23% are unrecognizable smelter identification numbers

·The majority of our responding Direct Suppliers who do utilize 3TG in some or all of the products they sell to their entire customer base: (1) could not represent to us that any smelter or refiner entities they listed as using Conflict Minerals had actually been included in the supply chain for the products, parts and/or raw materials they supplied to Wabash; and/or (2) reported that it was “not known” or “undetermined” if Conflict Minerals had been utilized by smelters or refiners included in the supply chain for the products, parts and/or raw materials they supplied to Wabash.

 

The statements above are based on the Reasonable Country of Origin Inquiry process and due diligence performed in good faith by Wabash. As noted previously, these statements are based solely on the information received from our Direct Suppliers through this process. For a listing of smelters or refiners and their country of origin, reported to Wabash by its suppliers and determined as either compliant, active, or progressing toward validation when compared to the CFSI list, reference Table 1 at the end of this CMR.

 

4. Steps to be taken to mitigate risk

 

We intend to take the following steps to improve the due diligence we conduct, in an effort to further mitigate risk that the Conflict Minerals necessary to the functionality or production of our products could benefit armed groups in the Covered Countries:

a)Inclusion of Conflict Minerals flow-down requirements in Wabash’s new or renewed Direct Supplier contracts.
b)Revisit annually the scope of Direct Suppliers requested to supply information as part of our due diligence process.
c)Engage with Direct Suppliers, as deemed necessary, directing them to training resources in an attempt to increase the due diligence response rate and improve the content of the Direct Supplier survey responses.
d)Work with the OECD and relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance.

 

 

 

 

  

TABLE 1

The facilities verified by the CFSI as “smelters” or “refiners”, which have been reported by Wabash suppliers as processing conflict minerals, are listed below

 

Mineral Smelter Name Smelter ID Status Country of origin
Gold Advanced Chemical Company CID000015 Active UNITED STATES
Gold Aida Chemical Industries Co., Ltd. CID000019 Compliant JAPAN
Gold Allgemeine Gold-und Silberscheideanstalt A.G. CID000035 Compliant GERMANY
Gold Almalyk Mining and Metallurgical Complex (AMMC) CID000041 Active UZBEKISTAN
Gold AngloGold Ashanti Córrego do Sítio Mineração CID000058 Compliant BRAZIL
Gold Argor-Heraeus S.A. CID000077 Compliant SWITZERLAND
Gold Asahi Pretec Corp. CID000082 Compliant JAPAN
Gold Asaka Riken Co., Ltd. CID000090 Compliant JAPAN
Gold Aurubis AG CID000113 Compliant GERMANY
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) CID000128 Compliant PHILIPPINES
Gold Boliden AB CID000157 Compliant SWEDEN
Gold C. Hafner GmbH + Co. KG CID000176 Compliant GERMANY
Gold CCR Refinery - Glencore Canada Corporation CID000185 Compliant CANADA
Gold Cendres + Métaux S.A. CID000189 Active SWITZERLAND
Gold Chimet S.p.A. CID000233 Compliant ITALY
Gold Daejin Indus Co., Ltd. CID000328 Active KOREA, REPUBLIC OF
Gold DSC (Do Sung Corporation) CID000359 Active KOREA, REPUBLIC OF
Gold DODUCO GmbH CID000362 Compliant GERMANY
Gold Dowa CID000401 Compliant JAPAN
Gold Eco-System Recycling Co., Ltd. CID000425 Compliant JAPAN
Gold OJSC Novosibirsk Refinery CID000493 Compliant RUSSIAN FEDERATION
Gold Heimerle + Meule GmbH CID000694 Compliant GERMANY
Gold Heraeus Precious Metals GmbH & Co. KG CID000711 Compliant GERMANY
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CID000801 Compliant CHINA
Gold Ishifuku Metal Industry Co., Ltd. CID000807 Compliant JAPAN
Gold Istanbul Gold Refinery CID000814 Compliant TURKEY
Gold Japan Mint CID000823 Compliant JAPAN
Gold Jiangxi Copper Co., Ltd. CID000855 Compliant CHINA
Gold Asahi Refining USA Inc. CID000920 Compliant UNITED STATES
Gold Asahi Refining Canada Ltd. CID000924 Compliant CANADA
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant CID000927 Compliant RUSSIAN FEDERATION
Gold JSC Uralelectromed CID000929 Compliant RUSSIAN FEDERATION
Gold JX Nippon Mining & Metals Co., Ltd. CID000937 Compliant JAPAN
Gold Kazzinc CID000957 Compliant KAZAKHSTAN
Gold Kennecott Utah Copper LLC CID000969 Compliant UNITED STATES
Gold Kojima Chemicals Co., Ltd. CID000981 Compliant JAPAN
Gold LS-NIKKO Copper Inc. CID001078 Compliant KOREA, REPUBLIC OF
Gold Materion CID001113 Compliant UNITED STATES
Gold Matsuda Sangyo Co., Ltd. CID001119 Compliant JAPAN

 

 

 

 

Mineral Smelter Name Smelter ID Status Country of origin
Gold Metalor Technologies (Suzhou) Ltd. CID001147 Active CHINA
Gold Metalor Technologies (Hong Kong) Ltd. CID001149 Compliant CHINA
Gold Metalor Technologies (Singapore) Pte., Ltd. CID001152 Compliant SINGAPORE
Gold Metalor Technologies S.A. CID001153 Compliant SWITZERLAND
Gold Metalor USA Refining Corporation CID001157 Compliant UNITED STATES
Gold Metalúrgica Met-Mex Peñoles S.A. De C.V. CID001161 Compliant MEXICO
Gold Mitsubishi Materials Corporation CID001188 Compliant JAPAN
Gold Mitsui Mining and Smelting Co., Ltd. CID001193 Compliant JAPAN
Gold Moscow Special Alloys Processing Plant CID001204 Compliant RUSSIAN FEDERATION
Gold Nadir Metal Rafineri San. Ve Tic. A.Ş. CID001220 Compliant TURKEY
Gold Navoi Mining and Metallurgical Combinat CID001236 Active UZBEKISTAN
Gold Nihon Material Co., Ltd. CID001259 Compliant JAPAN
Gold Elemetal Refining, LLC CID001322 Compliant UNITED STATES
Gold Ohura Precious Metal Industry Co., Ltd. CID001325 Compliant JAPAN
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) CID001326 Compliant RUSSIAN FEDERATION
Gold PAMP S.A. CID001352 Compliant SWITZERLAND
Gold Prioksky Plant of Non-Ferrous Metals CID001386 Compliant RUSSIAN FEDERATION
Gold PT Aneka Tambang (Persero) Tbk CID001397 Compliant INDONESIA
Gold PX Précinox S.A. CID001498 Compliant SWITZERLAND
Gold Rand Refinery (Pty) Ltd. CID001512 Compliant SOUTH AFRICA
Gold Royal Canadian Mint CID001534 Compliant CANADA
Gold Samduck Precious Metals CID001555 Active KOREA, REPUBLIC OF
Gold Schone Edelmetaal B.V. CID001573 Compliant NETHERLANDS
Gold SEMPSA Joyería Platería S.A. CID001585 Compliant SPAIN
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CID001622 Compliant CHINA
Gold Sichuan Tianze Precious Metals Co., Ltd. CID001736 Compliant CHINA
Gold SOE Shyolkovsky Factory of Secondary Precious Metals CID001756 Compliant RUSSIAN FEDERATION
Gold Solar Applied Materials Technology Corp. CID001761 Compliant TAIWAN
Gold Sumitomo Metal Mining Co., Ltd. CID001798 Compliant JAPAN
Gold Tanaka Kikinzoku Kogyo K.K. CID001875 Compliant JAPAN
Gold The Refinery of Shandong Gold Mining Co., Ltd. CID001916 Compliant CHINA
Gold Tokuriki Honten Co., Ltd. CID001938 Compliant JAPAN
Gold Torecom CID001955 Active KOREA, REPUBLIC OF
Gold Umicore Brasil Ltda. CID001977 Compliant BRAZIL
Gold Umicore S.A. Business Unit Precious Metals Refining CID001980 Compliant BELGIUM
Gold United Precious Metal Refining, Inc. CID001993 Compliant UNITED STATES
Gold Valcambi S.A. CID002003 Compliant SWITZERLAND
Gold Western Australian Mint trading as The Perth Mint CID002030 Compliant AUSTRALIA
Gold Yamamoto Precious Metal Co., Ltd. CID002100 Compliant JAPAN
Gold Yokohama Metal Co., Ltd. CID002129 Compliant JAPAN
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CID002224 Compliant CHINA

 

 

 

 

Mineral Smelter Name Smelter ID Status Country of origin
Gold Zijin Mining Group Co., Ltd. Gold Refinery CID002243 Compliant CHINA
Gold Umicore Precious Metals Thailand CID002314 Compliant THAILAND
Gold Faggi Enrico S.p.A. CID002355 Active ITALY
Gold Geib Refining Corporation CID002459 Active UNITED STATES
Gold MMTC-PAMP India Pvt., Ltd. CID002509 Compliant INDIA
Gold Republic Metals Corporation CID002510 Compliant UNITED STATES
Gold KGHM Polska Miedź Spółka Akcyjna CID002511 Active POLAND
Gold Singway Technology Co., Ltd. CID002516 Compliant TAIWAN
Gold Emirates Gold DMCC CID002561 Compliant UNITED ARAB EMIRATES
Gold T.C.A S.p.A CID002580 Compliant ITALY
Gold Korea Zinc Co., Ltd. CID002605 Active KOREA, REPUBLIC OF
Gold SAXONIA Edelmetalle GmbH CID002777 Active GERMANY
Gold WIELAND Edelmetalle GmbH CID002778 Active GERMANY
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH CID002779 Compliant AUSTRIA
Tantalum Changsha South Tantalum Niobium Co., Ltd. CID000211 Compliant CHINA
Tantalum Conghua Tantalum and Niobium Smeltry CID000291 Compliant CHINA
Tantalum Duoluoshan CID000410 Compliant CHINA
Tantalum Exotech Inc. CID000456 Compliant UNITED STATES
Tantalum F&X Electro-Materials Ltd. CID000460 Compliant CHINA
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CID000616 Compliant CHINA
Tantalum Hi-Temp Specialty Metals, Inc. CID000731 Compliant UNITED STATES
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CID000914 Compliant CHINA
Tantalum Jiujiang Tanbre Co., Ltd. CID000917 Compliant CHINA
Tantalum King-Tan Tantalum Industry Ltd. CID000973 Compliant CHINA
Tantalum LSM Brasil S.A. CID001076 Compliant BRAZIL
Tantalum Metallurgical Products India Pvt., Ltd. CID001163 Compliant INDIA
Tantalum Mineração Taboca S.A. CID001175 Compliant BRAZIL
Tantalum Mitsui Mining & Smelting CID001192 Compliant JAPAN
Tantalum Molycorp Silmet A.S. CID001200 Compliant ESTONIA
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CID001277 Compliant CHINA
Tantalum QuantumClean CID001508 Compliant UNITED STATES
Tantalum RFH Tantalum Smeltry Co., Ltd. CID001522 Compliant CHINA
Tantalum Solikamsk Magnesium Works OAO CID001769 Compliant RUSSIAN FEDERATION
Tantalum Taki Chemicals CID001869 Compliant JAPAN
Tantalum Telex Metals CID001891 Compliant UNITED STATES
Tantalum Ulba Metallurgical Plant JSC CID001969 Compliant KAZAKHSTAN
Tantalum Zhuzhou Cemented Carbide CID002232 Compliant CHINA
Tantalum Yichun Jin Yang Rare Metal Co., Ltd. CID002307 Compliant CHINA
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CID002492 Compliant CHINA
Tantalum D Block Metals, LLC CID002504 Compliant UNITED STATES
Tantalum FIR Metals & Resource Ltd. CID002505 Compliant CHINA
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CID002506 Compliant CHINA

 

 

 

 

Mineral Smelter Name Smelter ID Status Country of origin
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CID002508 Compliant CHINA
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CID002512 Compliant CHINA
Tantalum KEMET Blue Metals CID002539 Compliant MEXICO
Tantalum Plansee SE Liezen CID002540 Compliant AUSTRIA
Tantalum H.C. Starck Co., Ltd. CID002544 Compliant THAILAND
Tantalum H.C. Starck GmbH Goslar CID002545 Compliant GERMANY
Tantalum H.C. Starck GmbH Laufenburg CID002546 Compliant GERMANY
Tantalum H.C. Starck Hermsdorf GmbH CID002547 Compliant GERMANY
Tantalum H.C. Starck Inc. CID002548 Compliant UNITED STATES
Tantalum H.C. Starck Ltd. CID002549 Compliant JAPAN
Tantalum Plansee SE Reutte CID002556 Compliant AUSTRIA
Tantalum Global Advanced Metals Boyertown CID002557 Compliant UNITED STATES
Tantalum Global Advanced Metals Aizu CID002558 Compliant JAPAN
Tantalum KEMET Blue Powder CID002568 Compliant UNITED STATES
Tantalum Tranzact, Inc. CID002571 Compliant UNITED STATES
Tantalum Jiangxi Tuohong New Raw Material CID002842 Compliant CHINA
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CID000228 Active CHINA
Tin Jiangxi Ketai Advanced Material Co., Ltd. CID000244 Compliant CHINA
Tin Alpha CID000292 Compliant UNITED STATES
Tin Cooperativa Metalurgica de Rondônia Ltda. CID000295 Compliant BRAZIL
Tin CV Gita Pesona CID000306 Compliant INDONESIA
Tin PT Justindo CID000307 Compliant INDONESIA
Tin PT Aries Kencana Sejahtera CID000309 Compliant INDONESIA
Tin CV Serumpun Sebalai CID000313 Compliant INDONESIA
Tin CV United Smelting CID000315 Compliant INDONESIA
Tin EM Vinto CID000438 Compliant BOLIVIA
Tin Fenix Metals CID000468 Compliant POLAND
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CID000538 Compliant CHINA
Tin Gejiu Kai Meng Industry and Trade LLC CID000942 Active CHINA
Tin China Tin Group Co., Ltd. CID001070 Compliant CHINA
Tin Malaysia Smelting Corporation (MSC) CID001105 Compliant MALAYSIA
Tin Metallic Resources, Inc. CID001142 Compliant UNITED STATES
Tin Mineração Taboca S.A. CID001173 Compliant BRAZIL
Tin Minsur CID001182 Compliant PERU
Tin O.M. Manufacturing (Thailand) Co., Ltd. CID001314 Compliant THAILAND
Tin Operaciones Metalurgical S.A. CID001337 Compliant BOLIVIA
Tin PT Artha Cipta Langgeng CID001399 Compliant INDONESIA
Tin PT Babel Inti Perkasa CID001402 Compliant INDONESIA
Tin PT Bangka Tin Industry CID001419 Compliant INDONESIA
Tin PT Belitung Industri Sejahtera CID001421 Compliant INDONESIA
Tin PT Bukit Timah CID001428 Compliant INDONESIA
Tin PT DS Jaya Abadi CID001434 Compliant INDONESIA

 

 

 

 

Mineral Smelter Name Smelter ID Status Country of origin
Tin PT Eunindo Usaha Mandiri CID001438 Compliant INDONESIA
Tin PT Karimun Mining CID001448 Active INDONESIA
Tin PT Mitra Stania Prima CID001453 Compliant INDONESIA
Tin PT Panca Mega Persada CID001457 Compliant INDONESIA
Tin PT Prima Timah Utama CID001458 Compliant INDONESIA
Tin PT Refined Bangka Tin CID001460 Compliant INDONESIA
Tin PT Sariwiguna Binasentosa CID001463 Compliant INDONESIA
Tin PT Stanindo Inti Perkasa CID001468 Compliant INDONESIA
Tin PT Timah (Persero) Tbk Kundur CID001477 Compliant INDONESIA
Tin PT Timah (Persero) Tbk Mentok CID001482 Compliant INDONESIA
Tin PT Tinindo Inter Nusa CID001490 Compliant INDONESIA
Tin PT Tommy Utama CID001493 Compliant INDONESIA
Tin Rui Da Hung CID001539 Compliant TAIWAN
Tin Soft Metais Ltda. CID001758 Compliant BRAZIL
Tin Thaisarco CID001898 Compliant THAILAND
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CID001908 Active CHINA
Tin VQB Mineral and Trading Group JSC CID002015 Compliant VIET NAM
Tin White Solder Metalurgia e Mineração Ltda. CID002036 Compliant BRAZIL
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CID002158 Active CHINA
Tin Yunnan Tin Company Limited CID002180 Compliant CHINA
Tin CV Venus Inti Perkasa CID002455 Compliant INDONESIA
Tin Magnu's Minerais Metais e Ligas Ltda. CID002468 Compliant BRAZIL
Tin PT Wahana Perkit Jaya CID002479 Compliant INDONESIA
Tin Melt Metais e Ligas S.A. CID002500 Compliant BRAZIL
Tin PT ATD Makmur Mandiri Jaya CID002503 Compliant INDONESIA
Tin Phoenix Metal Ltd. CID002507 Active RWANDA
Tin O.M. Manufacturing Philippines, Inc. CID002517 Compliant PHILIPPINES
Tin PT Inti Stania Prima CID002530 Compliant INDONESIA
Tin CV Ayi Jaya CID002570 Compliant INDONESIA
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company CID002572 Active VIET NAM
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company CID002573 Active VIET NAM
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company CID002574 Active VIET NAM
Tin CV Dua Sekawan CID002592 Active INDONESIA
Tin PT Cipta Persada Mulia CID002696 Compliant INDONESIA
Tin An Vinh Joint Stock Mineral Processing Company CID002703 Active VIET NAM
Tin Resind Indústria e Comércio Ltda. CID002706 Compliant BRAZIL
Tin Metallo-Chimique N.V. CID002773 Compliant BELGIUM
Tin Elmet S.L.U. CID002774 Compliant SPAIN
Tin PT Bangka Prima Tin CID002776 Compliant INDONESIA
Tin PT Sukses Inti Makmur CID002816 Compliant INDONESIA
Tin An Thai Minerals Co., Ltd. CID002825 Active VIET NAM

 

 

 

 

Mineral Smelter Name Smelter ID Status Country of origin
Tin HuiChang Hill Tin Industry Co., Ltd. CID002844 Active CHINA
Tungsten A.L.M.T. TUNGSTEN Corp. CID000004 Compliant JAPAN
Tungsten Kennametal Huntsville CID000105 Compliant UNITED STATES
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CID000218 Compliant CHINA
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CID000258 Compliant CHINA
Tungsten Dayu Weiliang Tungsten Co., Ltd. CID000345 Progressing toward validation CHINA
Tungsten Fujian Jinxin Tungsten Co., Ltd. CID000499 Compliant CHINA
Tungsten Global Tungsten & Powders Corp. CID000568 Compliant UNITED STATES
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CID000769 Compliant CHINA
Tungsten Japan New Metals Co., Ltd. CID000825 Compliant JAPAN
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd. CID000868 Progressing toward validation CHINA
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CID000875 Compliant CHINA
Tungsten Kennametal Fallon CID000966 Active UNITED STATES
Tungsten Tejing (Vietnam) Tungsten Co., Ltd. CID001889 Compliant VIET NAM
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd. CID002011 Compliant VIET NAM
Tungsten Wolfram Bergbau und Hütten AG CID002044 Compliant AUSTRIA
Tungsten Xiamen Tungsten Co., Ltd. CID002082 Compliant CHINA
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CID002095 Compliant CHINA
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CID002315 Compliant CHINA
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CID002316 Active CHINA
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CID002317 Active CHINA
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CID002318 Active CHINA
Tungsten Malipo Haiyu Tungsten Co., Ltd. CID002319 Compliant CHINA
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CID002320 Compliant CHINA
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CID002321 Compliant CHINA
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CID002494 Compliant CHINA
Tungsten Asia Tungsten Products Vietnam Ltd. CID002502 Compliant VIET NAM
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CID002513 Compliant CHINA
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd. CID002518 Progressing toward validation CHINA
Tungsten Pobedit, JSC CID002532 Progressing toward validation RUSSIAN FEDERATION
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CID002535 Compliant CHINA
Tungsten Ganzhou Yatai Tungsten Co., Ltd. CID002536 Compliant CHINA
Tungsten H.C. Starck GmbH CID002541 Compliant GERMANY
Tungsten H.C. Starck Smelting GmbH & Co.KG CID002542 Compliant GERMANY
Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC CID002543 Compliant VIET NAM
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CID002551 Active CHINA
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin CID002578 Active CHINA

 

 

 

 

Mineral Smelter Name Smelter ID Status Country of origin
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CID002579 Compliant CHINA
Tungsten Niagara Refining LLC CID002589 Compliant UNITED STATES
Tungsten Hydrometallurg, JSC CID002649 Compliant RUSSIAN FEDERATION
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CID002830 Active CHINA

 

 

 

 



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