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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
INTERNATIONAL BUSINESS MACHINES CORPORATION
(Exact name of registrant as specified in its charter)
|
NEW YORK |
|
1-2360 |
|
13-0871985 |
|
(State or other jurisdiction of |
|
(Commission File Number) |
|
(IRS Employer |
|
ARMONK, NEW YORK |
|
10504 |
|
(Address of principal executive offices) |
|
(Zip Code) |
CHRISTINA M. MONTGOMERY
VICE PRESIDENT, ASSISTANT GENERAL COUNSEL AND SECRETARY
(914) 499-1900
(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
This Form SD of International Business Machines Corporation (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2015 to December 31, 2015.
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD and is publicly available at www.ibm.com/conflictminerals.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 — Exhibits
Item 2.01 Exhibit
The following exhibit is filed as part of this report.
|
Exhibit Number |
|
Description |
|
Exhibit 1.01 |
|
Conflict Minerals Report of International Business Machines Corporation |
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.
INTERNATIONAL BUSINESS MACHINES CORPORATION
|
/s/ Thomas W. Rosamilia |
|
May 27, 2016 |
|
Name: Thomas W. Rosamilia |
|
Date |
|
Title: Senior Vice President, IBM Systems |
|
|
Exhibit 1.01
INTERNATIONAL BUSINESS MACHINES CORPORATION
Conflict Minerals Report
For the reporting period from January 1, 2015 to December 31, 2015
This Conflict Minerals Report (Report) of International Business Machines Corporation (IBM) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the Rule) promulgated under the Securities Exchange Act of 1934, as amended, for the period from January 1, 2015 through December 31, 2015 (Reporting Period).
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products, and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, Conflict Minerals). The specified countries for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (collectively, Covered Countries). As described in this Report, Conflict Minerals are necessary to the functionality or production of certain products that IBM manufactures or contracts to manufacture.
Design of IBM’s Conflict Minerals Program
IBM’s Conflict Minerals Program is run by a full-time, dedicated team of experienced supply chain professionals within IBM’s Global Procurement organization. The Conflict Minerals Program team members report to IBM’s Vice President and Chief Procurement Officer, who has responsibility for IBM’s external supply base for IBM’s products. IBM’s Conflict Minerals team gathers information on the sources of Conflict Minerals in IBM’s supply chain and drives in-scope suppliers to source Conflict Minerals from conflict-free sources.
Description of IBM’s Products
This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by IBM; and (iii) for which the manufacture was completed during the Reporting Period (Covered Products). The Covered Products include the following product categories that were manufactured or contracted to be manufactured by IBM in 2015:
(1) Servers: a range of high-performing systems designed to address capacity, security, speed, and compute power needs for businesses, organizations and technical computing applications. The portfolio includes z Systems, a trusted enterprise platform for integrating data, transactions and insight, and Power Systems, a system designed from the ground up for big data, optimized for scale-out cloud and Linux, and delivering open innovation with OpenPOWER.
(2) Storage: data storage products and solutions that allow clients to retain and manage rapidly growing, complex volumes of digital information. These solutions address critical client requirements for information retention and archiving, security, compliance and storage optimization, including data deduplication, availability and virtualization. The portfolio consists of a broad range of software-defined storage solutions, flash storage, disk and tape storage solutions.
(3) Microelectronics: in 2014, IBM announced a definitive agreement to divest its Microelectronics business and manufacturing operations. This transaction closed in 2015. Because IBM manufactured semiconductors for a portion of the Reporting Period prior to the divestiture, the supply chain supporting the Microelectronics business is included in this Report. Prior to the closing of the transaction, Microelectronics included semiconductor design and manufacturing primarily for use in IBM’s systems and storage products, as well as delivering semiconductors and related services to external clients.
Reasonable Country of Origin Inquiry
IBM conducted a good faith reasonable country of origin inquiry (RCOI) regarding the Conflict Minerals. This good faith RCOI was designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources.
IBM’s Conflict Minerals Due Diligence Design
IBM’s due diligence measures for Conflict Minerals conform to the framework set forth in the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas, including the related supplements pertaining to downstream companies.
Since IBM is not a direct purchaser of ore or unrefined minerals, it is several tiers “downstream” from the smelters or refiners (SORs) of such minerals. SORs are at the point in the supply chain where ore, concentrates and/or scrap material are converted to a metal. IBM, like many downstream companies, does not have direct business relationships with SORs or visibility to the extraction and movement of Conflict Minerals between SORs and upstream entities. This position increases the difficulty of determining the origin of the Conflict Minerals in the Covered Products and, as a result, IBM relies on industry processes and information from its in-scope direct suppliers.
Description of Due Diligence Measures Performed
IBM’s due diligence reflects the principles of IBM’s Conflict Minerals Standard and IBM’s position in the supply chain as a downstream company, as defined by OECD guidance. IBM’s RCOI and due diligence process utilized the Conflict Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Template (CMRT), including the CFSI’s Conflict-Free Smelter Program (CFSP), and the London Bullion Market Association (LBMA). The CFSP and the LBMA use independent third-party audits to identify SORs that have systems in place to assure sourcing of only conflict-free materials.
Below is a description of the measures performed by IBM for the Reporting Period.
1. Maintained a strong company management system.
· Employed the IBM Conflict Minerals team within IBM’s Global Procurement organization to implement IBM’s Conflict Minerals Program.
· Posted IBM’s Conflict Minerals Standard on IBM’s Conflict Minerals-dedicated public website, www.ibm.com/conflictminerals.
· Conveyed Conflict Minerals information to in-scope direct suppliers from the IBM Global Procurement and CFSI websites.
· Provided an online grievance mechanism for internal and external parties to confidentially report concerns regarding Conflict Minerals to IBM’s Ombudsman.
· Retained records related to Conflict Minerals in conformance with IBM’s records retention policy.
· Used revised purchasing contract template requiring suppliers’ products to contain conflict-free sources for any Conflict Minerals.
2. Continued to identify and assess risks in the supply chain.
· Requested IBM’s in-scope direct suppliers to identify SORs and related Conflict Minerals information through the use of the CMRT.
· Gathered CMRTs from in-scope direct suppliers and reviewed the information provided in the CMRTs against IBM’s validation criteria.
· Managed collection of CMRTs and tracked status of supplier responses.
· Analyzed the CMRTs for completeness and accuracy, and, when appropriate, communicated errors and actions required to suppliers.
· Used CFSI Compliant Smelter Sourcing Information and third-party research to ascertain whether any Conflict Minerals in the Covered Products may have originated in the Covered Countries.
· Compared SORs identified by the in-scope direct suppliers against CFSI information to determine valid SORs and their CFSP status; also checked LBMA status.
· Engaged a third-party consultant to research SORs sourcing Conflict Minerals from Covered Countries.
· Worked with CFSI to gather additional facts regarding these SORs’ sources and to help drive the SORs into the CFSP.
3. Designed and implemented a strategy to respond to identified risks.
· Reported to IBM’s Global Procurement management on topics such as progress of CMRT collection, in-scope direct supplier conflict-free action plans, smelter risk mitigation, and progress of driving identified SORs toward CFSP listing.
· Identified SORs of concern and undertook mitigation actions.
· Stayed informed of macro Conflict Minerals issues and developments through participation in the CFSI.
· Participated in 12 SOR site visits to China, Indonesia and the US with other CFSI members to discuss matters regarding CFSP, such as participation and smelter operations.
· Presented material on the CFSP, including the benefits of CFSP participation, at the 2015 China Gold Forum in Shandong, China.
· Contacted select SORs without a conflict-free designation to encourage their participation in CFSP or other independent third-party audit program.
4. Supported the implementation of independent third-party audits of supply chain due diligence.
· Supported CFSI initiatives through participation in CFSI workgroups.
· Worked in concert with CFSI to enhance SOR outreach to drive CFSP participation.
5. Reported on supply chain due diligence.
· Pursuant to the Rule, filed Form SD and IBM’s 2014 Conflict Minerals Report.
· Published the 2014 Conflict Minerals Report on IBM’s Conflict Minerals-dedicated public website, www.ibm.com/conflictminerals.
· Included Conflict Minerals information in IBM’s annual Corporate Responsibility Report.
Reporting Period Determination and Findings
Based on the information that was provided by IBM’s in-scope direct suppliers, and otherwise obtained through the due diligence process described herein, IBM believes that the SORs that may be used to process the Conflict Minerals contained in the Covered Products are listed in Appendix A. Further, as listed in Appendix B, IBM has reasonably determined, from information provided by the CFSP and otherwise obtained through due diligence, the potential countries of origin of the Conflict Minerals in the Covered Products.
For calendar year 2015, IBM requested CMRTs from 205 in-scope direct suppliers and have received responses from 100% of those suppliers. To provide a measure of overall progress of the program, the following table illustrates the change in the percentage of 2015 SORs in the upstream IBM supply chain assessed as conflict free using the CFSP and LBMA status (as of April 15, 2016).
|
Conflict |
|
2014 |
|
2014 |
|
2015 |
|
2015 |
|
2015 SORs |
|
2015 SORs |
|
|
Tantalum |
|
43 of 45 |
|
96 |
% |
45 of 45 |
|
100 |
% |
45 of 45 |
|
100 |
% |
|
Tin |
|
22 of 68 |
|
32 |
% |
59 of 81 |
|
73 |
% |
71 of 81 |
|
88 |
% |
|
Tungsten |
|
9 of 39 |
|
23 |
% |
29 of 43 |
|
67 |
% |
41 of 43 |
|
95 |
% |
|
Gold |
|
56 of 112 |
|
50 |
% |
83 of 126 |
|
66 |
% |
98 of 126 |
|
78 |
% |
|
Total |
|
130 of 264 |
|
49 |
% |
216 of 295 |
|
73 |
% |
255 of 295 |
|
86 |
% |
Conflict-Free Action Plans
In 2015, IBM launched an initiative to have all in-scope direct suppliers document their plans to achieve a conflict-free supply chain. In-scope direct suppliers with CMRTs containing smelters that were not progressing toward or not already conflict free were required to create conflict-free action plans addressing the critical steps to become conflict free and remain conflict free. Supplier action plans are reviewed by IBM and accepted or returned to suppliers for rework.
IBM’s Next Steps to Mitigate Conflict Minerals Risk
IBM expects to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Covered Products finance or benefit armed groups in the Covered Countries:
· By participating in the CFSI, contribute to the continued development of collaborative tools and resources for companies to use to help assess their supply chains and avoid inclusion of Conflict Minerals in the extended supply chain.
· Remain aware of developments in Conflict Minerals due diligence processes by participation in the CFSI and apply that knowledge to IBM’s Conflict Minerals risk assessment and mitigation actions.
· Work in concert with CFSI members and in-scope direct suppliers to contact SORs to better understand their sourcing circumstances and gain their commitment to a CFSP assessment or another recognized validation scheme.
· Seek resolution for the identified SORs in IBM’s supply chain that are not currently on CFSI’s list of recognized SORs and drive additional identified SORs in IBM’s supply chain into the CFSP.
· Improve CMRT response completeness from in-scope direct suppliers through IBM’s review and feedback to suppliers using the most current smelter information.
· Drive in-scope direct suppliers to provide product-specific CMRTs instead of company-level CMRTs, as company-level CMRTs may include SORs not used in the supply chain for Covered Products; use of product-specific CMRTs by in-scope direct suppliers will enable IBM to have a more precise list of SORs used in the Covered Products.
· Continue to influence upstream sourcing practices to require the usage of CFSP-compliant SORs, including the use of conflict-free contract clauses.
IBM’s Support of CFSI
As outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the internationally recognized standard on which IBM’s due diligence is based, we support an industry initiative that audits the due diligence activities of SORs. That industry initiative is the Electronic Industry Citizenship Coalition and GeSI’s Conflict-Free Sourcing Initiative. The RCOI data on which we relied for certain statements in this Report was obtained through our membership in the CFSI. IBM is an active contributor to CFSI through our participation in various working groups. IBM’s member ID: MIBM.
Appendix A
Smelters or Refiners (SORs) that may be used to process the Conflict Minerals contained in the Covered Products.
SOR Status: “CFSP Listed” or “LBMA Listed” indicates that the SOR is publically listed on the CFSP or LBMA web sites and considered conflict-free for 2015. “Active” indicates that the SOR is in process for CFSP or LBMA assessment. “Unknown” indicates that the SOR is not a current participant in either process.
|
Metal |
|
Name of SOR |
|
Country Location |
|
SOR Status |
|
Gold |
|
Advanced Chemical Company |
|
United States |
|
Active |
|
Gold |
|
Aida Chemical Industries Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Al Etihad Gold Refinery DMCC |
|
United Arab Emirates |
|
Unknown |
|
Gold |
|
Allgemeine Gold-und Silberscheideanstalt A.G. |
|
Germany |
|
CFSP Listed |
|
Gold |
|
Almalyk Mining and Metallurgical Complex (AMMC) |
|
Uzbekistan |
|
LBMA Listed |
|
Gold |
|
AngloGold Ashanti Córrego do Sítio Mineração |
|
Brazil |
|
CFSP Listed |
|
Gold |
|
Argor-Heraeus SA |
|
Switzerland |
|
CFSP Listed |
|
Gold |
|
Asahi Pretec Corporation |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Asahi Refining Canada Limited |
|
Canada |
|
CFSP Listed |
|
Gold |
|
Asahi Refining USA Inc. |
|
United States |
|
CFSP Listed |
|
Gold |
|
Asaka Riken Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
|
Turkey |
|
Unknown |
|
Gold |
|
AURA-II |
|
United States |
|
Unknown |
|
Gold |
|
Aurubis AG |
|
Germany |
|
CFSP Listed |
|
Gold |
|
Bangalore Refinery |
|
India |
|
Unknown |
|
Gold |
|
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
|
Philippines |
|
CFSP Listed |
|
Gold |
|
Boliden AB |
|
Sweden |
|
CFSP Listed |
|
Gold |
|
C. Hafner GmbH + Co. KG |
|
Germany |
|
CFSP Listed |
|
Gold |
|
Caridad |
|
Mexico |
|
Unknown |
|
Gold |
|
CCR Refinery - Glencore Canada Corporation |
|
Canada |
|
CFSP Listed |
|
Gold |
|
Cendres + Métaux SA |
|
Switzerland |
|
Active |
|
Gold |
|
Chimet S.p.A. |
|
Italy |
|
CFSP Listed |
|
Gold |
|
Chugai Mining |
|
Japan |
|
Unknown |
|
Gold |
|
Daejin Indus Co., Ltd. |
|
Korea, Republic Of |
|
Active |
|
Gold |
|
Daye Non-Ferrous Metals Mining Ltd. |
|
China |
|
LBMA Listed |
|
Gold |
|
DODUCO GmbH |
|
Germany |
|
CFSP Listed |
|
Gold |
|
Dowa |
|
Japan |
|
CFSP Listed |
|
Gold |
|
DSC (Do Sung Corporation) |
|
Korea, Republic Of |
|
Active |
|
Gold |
|
Eco-System Recycling Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Elemetal Refining, LLC |
|
United States |
|
CFSP Listed |
|
Gold |
|
Emirates Gold DMCC |
|
United Arab Emirates |
|
CFSP Listed |
|
Gold |
|
Faggi Enrico S.p.A. |
|
Italy |
|
Active |
|
Gold |
|
Gansu Seemine Material Hi-Tech Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
Geib Refining Corporation |
|
United States |
|
Active |
|
Gold |
|
Great Wall Precious Metals Co., Ltd. of CBPM |
|
China |
|
Active |
|
Gold |
|
Guangdong Jinding Gold Limited |
|
China |
|
Unknown |
|
Gold |
|
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
Hangzhou Fuchunjiang Smelting Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
Heimerle + Meule GmbH |
|
Germany |
|
CFSP Listed |
|
Gold |
|
Heraeus Ltd. Hong Kong |
|
China |
|
CFSP Listed |
|
Gold |
|
Heraeus Precious Metals GmbH & Co. KG |
|
Germany |
|
CFSP Listed |
|
Gold |
|
Hunan Chenzhou Mining Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
Hwasung CJ Co., Ltd. |
|
Korea, Republic Of |
|
Unknown |
|
Gold |
|
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
|
China |
|
LBMA Listed |
|
Gold |
|
Ishifuku Metal Industry Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Istanbul Gold Refinery |
|
Turkey |
|
CFSP Listed |
|
Gold |
|
Japan Mint |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Jiangxi Copper Company Limited |
|
China |
|
CFSP Listed |
|
Gold |
|
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
|
Russian Federation |
|
CFSP Listed |
|
Gold |
|
JSC Uralelectromed |
|
Russian Federation |
|
CFSP Listed |
|
Gold |
|
JX Nippon Mining & Metals Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Kazakhmys Smelting LLC |
|
Kazakhstan |
|
Unknown |
|
Gold |
|
Kazzinc |
|
Kazakhstan |
|
CFSP Listed |
|
Gold |
|
Kennecott Utah Copper LLC |
|
United States |
|
CFSP Listed |
|
Gold |
|
KGHM Polska Miedź Spółka Akcyjna |
|
Poland |
|
Active |
|
Gold |
|
Kojima Chemicals Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Korea Metal Co., Ltd.* |
|
Korea, Republic Of |
|
Unknown |
|
Gold |
|
Korea Zinc Co. Ltd. |
|
Korea, Republic Of |
|
Active |
|
Gold |
|
Kyrgyzaltyn JSC |
|
Kyrgyzstan |
|
Active |
|
Gold |
|
L’ azurde Company For Jewelry |
|
Saudi Arabia |
|
Unknown |
|
Gold |
|
Lingbao Gold Company Limited |
|
China |
|
Unknown |
|
Gold |
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
LS-NIKKO Copper Inc. |
|
Korea, Republic Of |
|
CFSP Listed |
|
Gold |
|
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
Materion |
|
United States |
|
CFSP Listed |
|
Gold |
|
Matsuda Sangyo Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Metalor Technologies (Hong Kong) Ltd. |
|
China |
|
CFSP Listed |
|
Gold |
|
Metalor Technologies (Singapore) Pte., Ltd. |
|
Singapore |
|
CFSP Listed |
|
Gold |
|
Metalor Technologies (Suzhou) Ltd. |
|
China |
|
Active |
|
Gold |
|
Metalor Technologies SA |
|
Switzerland |
|
CFSP Listed |
|
Gold |
|
Metalor USA Refining Corporation |
|
United States |
|
CFSP Listed |
|
Gold |
|
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V |
|
Mexico |
|
CFSP Listed |
|
Gold |
|
Mitsubishi Materials Corporation |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Mitsui Mining and Smelting Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
MMTC-PAMP India Pvt., Ltd. |
|
India |
|
CFSP Listed |
|
Gold |
|
Morris and Watson |
|
New Zealand |
|
Unknown |
|
Gold |
|
Moscow Special Alloys Processing Plant |
|
Russian Federation |
|
CFSP Listed |
|
Gold |
|
Nadir Metal Rafineri San. Ve Tic. A.Ş. |
|
Turkey |
|
CFSP Listed |
|
Gold |
|
Navoi Mining and Metallurgical Combinat |
|
Uzbekistan |
|
LBMA Listed |
|
Gold |
|
Nihon Material Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
|
Austria |
|
CFSP Listed |
|
Gold |
|
Ohura Precious Metal Industry Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
|
Russian Federation |
|
CFSP Listed |
|
Gold |
|
OJSC Kolyma Refinery* |
|
Russian Federation |
|
Unknown |
|
Gold |
|
OJSC Novosibirsk Refinery |
|
Russian Federation |
|
CFSP Listed |
|
Gold |
|
PAMP SA |
|
Switzerland |
|
CFSP Listed |
|
Gold |
|
Penglai Penggang Gold Industry Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
Prioksky Plant of Non-Ferrous Metals |
|
Russian Federation |
|
CFSP Listed |
|
Gold |
|
PT Aneka Tambang (Persero) Tbk |
|
Indonesia |
|
CFSP Listed |
|
Gold |
|
PX Précinox SA |
|
Switzerland |
|
CFSP Listed |
|
Gold |
|
Rand Refinery (Pty) Ltd. |
|
South Africa |
|
CFSP Listed |
|
Gold |
|
Remondis Argentia B.V. |
|
Netherlands |
|
Unknown |
|
Gold |
|
Republic Metals Corporation |
|
United States |
|
CFSP Listed |
|
Gold |
|
Royal Canadian Mint |
|
Canada |
|
CFSP Listed |
|
Gold |
|
Sabin Metal Corp. |
|
United States |
|
Unknown |
|
Gold |
|
Samduck Precious Metals |
|
Korea, Republic Of |
|
Active |
|
Gold |
|
SAMWON Metals Corp. |
|
Korea, Republic Of |
|
Unknown |
|
Gold |
|
SAXONIA Edelmetalle GmbH |
|
Germany |
|
Active |
|
Gold |
|
Schone Edelmetaal B.V. |
|
Netherlands |
|
CFSP Listed |
|
Gold |
|
SEMPSA Joyería Platería SA |
|
Spain |
|
CFSP Listed |
|
Gold |
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
|
China |
|
CFSP Listed |
|
Gold |
|
Sichuan Tianze Precious Metals Co., Ltd. |
|
China |
|
CFSP Listed |
|
Gold |
|
Singway Technology Co., Ltd. |
|
Taiwan |
|
CFSP Listed |
|
Gold |
|
So Accurate Group, Inc. |
|
United States |
|
Unknown |
|
Gold |
|
SOE Shyolkovsky Factory of Secondary Precious Metals |
|
Russian Federation |
|
CFSP Listed |
|
Gold |
|
Solar Applied Materials Technology Corp. |
|
Taiwan |
|
CFSP Listed |
|
Gold |
|
Sumitomo Metal Mining Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
T.C.A S.p.A |
|
Italy |
|
CFSP Listed |
|
Gold |
|
Tanaka Kikinzoku Kogyo K.K. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
The Refinery of Shandong Gold Mining Co., Ltd. |
|
China |
|
CFSP Listed |
|
Gold |
|
Tokuriki Honten Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Tongling Nonferrous Metals Group Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
Torecom |
|
Korea, Republic Of |
|
Active |
|
Gold |
|
Umicore Brasil Ltda. |
|
Brazil |
|
CFSP Listed |
|
Gold |
|
Umicore Precious Metals Thailand |
|
Thailand |
|
CFSP Listed |
|
Gold |
|
Umicore SA Business Unit Precious Metals Refining |
|
Belgium |
|
CFSP Listed |
|
Gold |
|
United Precious Metal Refining, Inc. |
|
United States |
|
CFSP Listed |
|
Gold |
|
Valcambi SA |
|
Switzerland |
|
CFSP Listed |
|
Gold |
|
Western Australian Mint trading as The Perth Mint |
|
Australia |
|
CFSP Listed |
|
Gold |
|
WIELAND Edelmetalle GmbH |
|
Germany |
|
Active |
|
Gold |
|
Yamamoto Precious Metal Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Yokohama Metal Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Gold |
|
Yunnan Copper Industry Co., Ltd. |
|
China |
|
Unknown |
|
Gold |
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
|
China |
|
CFSP Listed |
|
Gold |
|
Zijin Mining Group Co., Ltd. Gold Refinery |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Changsha South Tantalum Niobium Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Conghua Tantalum and Niobium Smeltry |
|
China |
|
CFSP Listed |
|
Tantalum |
|
D Block Metals, LLC |
|
United States |
|
CFSP Listed |
|
Tantalum |
|
Duoluoshan |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Exotech Inc. |
|
United States |
|
CFSP Listed |
|
Tantalum |
|
F&X Electro-Materials Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
FIR Metals & Resource Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Global Advanced Metals Aizu |
|
Japan |
|
CFSP Listed |
|
Tantalum |
|
Global Advanced Metals Boyertown |
|
United States |
|
CFSP Listed |
|
Tantalum |
|
Guangdong Zhiyuan New Material Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
H.C. Starck Co., Ltd. |
|
Thailand |
|
CFSP Listed |
|
Tantalum |
|
H.C. Starck GmbH Goslar |
|
Germany |
|
CFSP Listed |
|
Tantalum |
|
H.C. Starck GmbH Laufenburg |
|
Germany |
|
CFSP Listed |
|
Tantalum |
|
H.C. Starck Hermsdorf GmbH |
|
Germany |
|
CFSP Listed |
|
Tantalum |
|
H.C. Starck Inc. |
|
United States |
|
CFSP Listed |
|
Tantalum |
|
H.C. Starck Ltd. |
|
Japan |
|
CFSP Listed |
|
Tantalum |
|
H.C. Starck Smelting GmbH & Co.KG |
|
Germany |
|
CFSP Listed |
|
Tantalum |
|
Hengyang King Xing Lifeng New Materials Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Hi-Temp Specialty Metals, Inc. |
|
United States |
|
CFSP Listed |
|
Tantalum |
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Jiujiang Tanbre Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
KEMET Blue Metals |
|
Mexico |
|
CFSP Listed |
|
Tantalum |
|
KEMET Blue Powder |
|
United States |
|
CFSP Listed |
|
Tantalum |
|
King-Tan Tantalum Industry Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
LSM Brasil S.A. |
|
Brazil |
|
CFSP Listed |
|
Tantalum |
|
Metallurgical Products India Pvt., Ltd. |
|
India |
|
CFSP Listed |
|
Tantalum |
|
Mineração Taboca S.A. |
|
Brazil |
|
CFSP Listed |
|
Tantalum |
|
Mitsui Mining & Smelting |
|
Japan |
|
CFSP Listed |
|
Tantalum |
|
Molycorp Silmet A.S. |
|
Estonia |
|
CFSP Listed |
|
Tantalum |
|
Ningxia Orient Tantalum Industry Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Plansee SE Liezen |
|
Austria |
|
CFSP Listed |
|
Tantalum |
|
Plansee SE Reutte |
|
Austria |
|
CFSP Listed |
|
Tantalum |
|
QuantumClean |
|
United States |
|
CFSP Listed |
|
Tantalum |
|
Resind Indústria e Comércio Ltda. |
|
Brazil |
|
CFSP Listed |
|
Tantalum |
|
RFH Tantalum Smeltry Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Solikamsk Magnesium Works OAO |
|
Russian Federation |
|
CFSP Listed |
|
Tantalum |
|
Taki Chemicals |
|
Japan |
|
CFSP Listed |
|
Tantalum |
|
Telex Metals |
|
United States |
|
CFSP Listed |
|
Tantalum |
|
Tranzact, Inc. |
|
United States |
|
CFSP Listed |
|
Tantalum |
|
Ulba Metallurgical Plant JSC |
|
Kazakhstan |
|
CFSP Listed |
|
Tantalum |
|
XinXing HaoRong Electronic Material Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Yichun Jin Yang Rare Metal Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tantalum |
|
Zhuzhou Cemented Carbide |
|
China |
|
CFSP Listed |
|
Tin |
|
Alpha |
|
United States |
|
CFSP Listed |
|
Tin |
|
An Thai Minerals Company Limited |
|
Vietnam |
|
Active |
|
Tin |
|
An Vinh Joint Stock Mineral Processing Company |
|
Vietnam |
|
Active |
|
Tin |
|
China Tin Group Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tin |
|
CNMC (Guangxi) PGMA Co., Ltd. |
|
China |
|
Unknown |
|
Tin |
|
Cooperativa Metalurgica de Rondônia Ltda. |
|
Brazil |
|
CFSP Listed |
|
Tin |
|
CV Ayi Jaya |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
CV Dua Sekawan |
|
Indonesia |
|
Active |
|
Tin |
|
CV Gita Pesona |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
CV Serumpun Sebalai |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
CV United Smelting |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
CV Venus Inti Perkasa |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
Dowa |
|
Japan |
|
CFSP Listed |
|
Tin |
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
|
Vietnam |
|
Active |
|
Tin |
|
Elmet S.L.U. (Metallo Group) |
|
Spain |
|
CFSP Listed |
|
Tin |
|
EM Vinto |
|
Bolivia |
|
CFSP Listed |
|
Tin |
|
Estanho de Rondônia S.A. |
|
Brazil |
|
Unknown |
|
Tin |
|
Feinhütte Halsbrücke GmbH |
|
Germany |
|
Active |
|
Tin |
|
Fenix Metals |
|
Poland |
|
CFSP Listed |
|
Tin |
|
Gejiu Jinye Mineral Company |
|
China |
|
Active |
|
Tin |
|
Gejiu Kai Meng Industry and Trade LLC |
|
China |
|
Active |
|
Tin |
|
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tin |
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
|
China |
|
Unknown |
|
Tin |
|
Gejiu Zili Mining And Metallurgy Co., Ltd. |
|
China |
|
Unknown |
|
Tin |
|
Huichang Jinshunda Tin Co., Ltd. |
|
China |
|
Unknown |
|
Tin |
|
Jiangxi Ketai Advanced Material Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tin |
|
Linwu Xianggui Ore Smelting Co., Ltd. |
|
China |
|
Unknown |
|
Tin |
|
Magnu’s Minerais Metais e Ligas Ltda. |
|
Brazil |
|
CFSP Listed |
|
Tin |
|
Malaysia Smelting Corporation (MSC) |
|
Malaysia |
|
CFSP Listed |
|
Tin |
|
Melt Metais e Ligas S/A |
|
Brazil |
|
CFSP Listed |
|
Tin |
|
Metallic Resources, Inc. |
|
United States |
|
CFSP Listed |
|
Tin |
|
Metallo-Chimique N.V. |
|
Belgium |
|
CFSP Listed |
|
Tin |
|
Mineração Taboca S.A. |
|
Brazil |
|
CFSP Listed |
|
Tin |
|
Minsur |
|
Peru |
|
CFSP Listed |
|
Tin |
|
Mitsubishi Materials Corporation |
|
Japan |
|
CFSP Listed |
|
Tin |
|
Nankang Nanshan Tin Manufactory Co., Ltd. |
|
China |
|
Unknown |
|
Tin |
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
|
Vietnam |
|
Active |
|
Tin |
|
O.M. Manufacturing (Thailand) Co., Ltd. |
|
Thailand |
|
CFSP Listed |
|
Tin |
|
O.M. Manufacturing Philippines, Inc. |
|
Philippines |
|
CFSP Listed |
|
Tin |
|
Operaciones Metalurgical S.A. |
|
Bolivia |
|
CFSP Listed |
|
Tin |
|
Phoenix Metal Ltd.* |
|
Rwanda |
|
Active |
|
Tin |
|
PT Aries Kencana Sejahtera |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Artha Cipta Langgeng |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT ATD Makmur Mandiri Jaya |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Babel Inti Perkasa |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Bangka Prima Tin |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Bangka Putra Karya* |
|
Indonesia |
|
Unknown |
|
Tin |
|
PT Bangka Tin Industry |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Belitung Industri Sejahtera |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT BilliTin Makmur Lestari |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Bukit Timah |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Cipta Persada Mulia |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT DS Jaya Abadi |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Eunindo Usaha Mandiri |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Inti Stania Prima |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Justindo |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Karimun Mining |
|
Indonesia |
|
Active |
|
Tin |
|
PT Mitra Stania Prima |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Panca Mega Persada |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Prima Timah Utama |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Refined Bangka Tin |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Sariwiguna Binasentosa |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Seirama Tin Investment* |
|
Indonesia |
|
Unknown |
|
Tin |
|
PT Stanindo Inti Perkasa |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Sukses Inti Makmur |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Sumber Jaya Indah |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Timah (Persero) Tbk Kundur |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Timah (Persero) Tbk Mentok |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Tinindo Inter Nusa |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Tirus Putra Mandiri |
|
Indonesia |
|
Unknown |
|
Tin |
|
PT Tommy Utama |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
PT Wahana Perkit Jaya |
|
Indonesia |
|
CFSP Listed |
|
Tin |
|
Resind Indústria e Comércio Ltda. |
|
Brazil |
|
CFSP Listed |
|
Tin |
|
Rui Da Hung |
|
Taiwan |
|
CFSP Listed |
|
Tin |
|
Soft Metais Ltda. |
|
Brazil |
|
CFSP Listed |
|
Tin |
|
Thaisarco |
|
Thailand |
|
CFSP Listed |
|
Tin |
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
|
Vietnam |
|
Active |
|
Tin |
|
VQB Mineral and Trading Group JSC |
|
Vietnam |
|
CFSP Listed |
|
Tin |
|
White Solder Metalurgia e Mineração Ltda. |
|
Brazil |
|
CFSP Listed |
|
Tin |
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
|
China |
|
Active |
|
Tin |
|
Yunnan Tin Group (Holding) Company Limited |
|
China |
|
CFSP Listed |
|
Tungsten |
|
A.L.M.T. TUNGSTEN Corp. |
|
Japan |
|
CFSP Listed |
|
Tungsten |
|
Asia Tungsten Products Vietnam Ltd. |
|
Vietnam |
|
CFSP Listed |
|
Tungsten |
|
Chenzhou Diamond Tungsten Products Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Chongyi Zhangyuan Tungsten Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Dayu Jincheng Tungsten Industry Co., Ltd. |
|
China |
|
Active |
|
Tungsten |
|
Dayu Weiliang Tungsten Co., Ltd. |
|
China |
|
Active |
|
Tungsten |
|
Fujian Jinxin Tungsten Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Ganxian Shirui New Material Co., Ltd. |
|
China |
|
Unknown |
|
Tungsten |
|
Ganzhou Huaxing Tungsten Products Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
|
China |
|
Active |
|
Tungsten |
|
Ganzhou Seadragon W & Mo Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Ganzhou Yatai Tungsten Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Global Tungsten & Powders Corp. |
|
United States |
|
CFSP Listed |
|
Tungsten |
|
Guangdong Xianglu Tungsten Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
H.C. Starck GmbH |
|
Germany |
|
CFSP Listed |
|
Tungsten |
|
H.C. Starck Smelting GmbH & Co.KG |
|
Germany |
|
CFSP Listed |
|
Tungsten |
|
Hunan Chenzhou Mining Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
|
China |
|
Active |
|
Tungsten |
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin |
|
China |
|
Active |
|
Tungsten |
|
Hunan Chunchang Nonferrous Metals Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Hydrometallurg, JSC |
|
Russian Federation |
|
CFSP Listed |
|
Tungsten |
|
Japan New Metals Co., Ltd. |
|
Japan |
|
CFSP Listed |
|
Tungsten |
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
|
China |
|
Active |
|
Tungsten |
|
Jiangxi Gan Bei Tungsten Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
|
China |
|
Unknown |
|
Tungsten |
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
|
China |
|
Active |
|
Tungsten |
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
|
China |
|
Active |
|
Tungsten |
|
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Jiangxi Yaosheng Tungsten Co., Ltd. |
|
China |
|
Active |
|
Tungsten |
|
Kennametal Fallon |
|
United States |
|
Active |
|
Tungsten |
|
Kennametal Huntsville |
|
United States |
|
CFSP Listed |
|
Tungsten |
|
Malipo Haiyu Tungsten Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Niagara Refining LLC |
|
United States |
|
CFSP Listed |
|
Tungsten |
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
|
Vietnam |
|
CFSP Listed |
|
Tungsten |
|
Pobedit, JSC |
|
Russian Federation |
|
Active |
|
Tungsten |
|
Sanher Tungsten Vietnam Co., Ltd. |
|
Vietnam |
|
Active |
|
Tungsten |
|
Tejing (Vietnam) Tungsten Co., Ltd. |
|
Vietnam |
|
CFSP Listed |
|
Tungsten |
|
Vietnam Youngsun Tungsten Industry Co., Ltd. |
|
Vietnam |
|
CFSP Listed |
|
Tungsten |
|
Wolfram Bergbau und Hütten AG |
|
Austria |
|
CFSP Listed |
|
Tungsten |
|
Xiamen Tungsten (H.C.) Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Xiamen Tungsten Co., Ltd. |
|
China |
|
CFSP Listed |
|
Tungsten |
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
|
China |
|
CFSP Listed |
*IBM believes the SOR is no longer in operation as of December 31, 2015; for purposes of calendar year 2015 reporting the SOR is included in this appendix.
Appendix B
Countries of Origin for Conflict Minerals potentially associated with the SORs listed in Appendix A.
|
Angola |
|
Madagascar |
|
Australia |
|
Malaysia |
|
Austria |
|
Mongolia |
|
Belgium |
|
Mozambique |
|
Bolivia |
|
Myanmar |
|
Brazil |
|
Namibia |
|
Burundi |
|
Netherlands |
|
Cambodia |
|
New Zealand |
|
Canada |
|
Nigeria |
|
Central African Republic |
|
Peru |
|
Chile |
|
Poland |
|
China |
|
Portugal |
|
Colombia |
|
Republic of Congo |
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Côte D’Ivoire |
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Russia |
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Czech Republic |
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Rwanda |
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Djibouti |
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Sierra Leone |
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Egypt |
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Singapore |
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Estonia |
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Slovakia |
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Ethiopia |
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South Africa |
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France |
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South Korea |
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Germany |
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Spain |
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Ghana |
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Suriname |
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Guyana |
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Switzerland |
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Hungary |
|
Taiwan |
|
India |
|
Tanzania |
|
Indonesia |
|
Thailand |
|
Ireland |
|
Uganda |
|
Israel |
|
United Kingdom |
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Japan |
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United States of America |
|
Kazakhstan |
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Uzbekistan |
|
Kenya |
|
Vietnam |
|
Kyrgyz Republic |
|
Zambia |
|
Laos |
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Zimbabwe |
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Luxembourg |
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