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May 31, 2017 3:38 PM EDT







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




FORM SD

SPECIALIZED DISCLOSURE REPORT


__________________________________________

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



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

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

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

[ X ]
Rule 13p-1 under the Securities Exchange Act (17CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016.




Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report
As provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report is provided as an Exhibit to this Form SD and is available on our website at www.itw.com.

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

Item 2.01    Exhibits
1.01    Conflict Minerals Report for the calendar year ended December 31, 2016.





SIGNATURES



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



 
ILLINOIS TOOL WORKS INC.
 
 
 
 
Dated: May 31, 2017
By: /s/ CHRISTOPHER A. O'HERLIHY
 
Christopher A. O’Herlihy
 
Vice Chairman





    





EXHIBIT INDEX

Exhibit
 
Description
1.01
 
Conflict Minerals Report for the calendar year ended December 31, 2016.



Exhibit 1.01

Conflict Minerals Report
I.
Introduction

A.    Our Business

Illinois Tool Works Inc. is a global manufacturer of a diversified range of industrial products and equipment with 85 divisions in 57 countries, and has prepared this Conflict Minerals Report for calendar year 2016 as provided for in Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended, and Form SD (together referred to as the "Conflict Minerals Rule"). Unless the context indicates otherwise, the terms “Company,” “ITW,” “we,” “its,” “us” and “our” refer to Illinois Tool Works Inc. and its consolidated subsidiaries. “Conflict minerals” or “3TG” as used in this report, refers to cassiterite, columbite-tantalite, gold, wolframite and their derivatives, tin, tantalum, tungsten and/or gold, without regard to their location of origin.

The Company’s operations are reported as the following segments: Automotive OEM; Food Equipment; Test & Measurement and Electronics; Welding; Polymers & Fluids; Construction Products; and Specialty Products. Each of our segments manufactures certain products that contain 3TG that are necessary to the functionality or production of the products (which we sometimes refer to herein as "in-scope" products). ITW’s in-scope products collectively contain all four 3TGs.

B.    Reasonable Country of Origin Inquiry and Due Diligence Overview

As provided for in the Conflict Minerals Rule, we conducted a "reasonable country of origin inquiry" ("RCOI"), designed in good faith to determine the origin of the 3TG that are contained in our in-scope products. See Section II. Reasonable Country of Origin Inquiry for a description of our RCOI process for 2016.

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

C.    ITW’s Position in the Supply Chain

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

D.    Responsible Sourcing Commitment

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

1


E.    Smelter and Refiner and Country of Origin Information

The Company’s in-scope products that contain 3TG are described in Section IV. Product Information. Information about SORs relating to the Company’s in-scope products is described in Section V. Identified Smelters and Refiners and on Annex A. We have not found for 2016 that any of the necessary 3TG contained in our in-scope products directly or indirectly financed or benefited armed groups in a Covered Country. However, we have not declared that any of our products are “DRC conflict free.” The terms "adjoining country," "armed group," and "DRC conflict free" have the meanings contained in the Conflict Minerals Rule.

F.    2016 Program Enhancements

For 2016, we took the following actions to enhance our RCOI and conflict minerals due diligence and mitigate sourcing risk:

Enhanced Identification of In-Scope Products and Suppliers

•
We used internal spend data cross-checked against products that typically contain 3TG to help ensure identification of all in-scope products and suppliers;
•
We refined and updated our internal product lists for our businesses and suppliers to reference;
•
We enhanced training and materials for our internal conflict minerals contacts;

Enhanced Supplier Outreach

•
In order to better communicate with our suppliers, we translated our supplier invitation letters into 8 languages;
•
In order to better communicate our Conflict Minerals Policy globally, we translated it into 7 languages, all of which available on our website;

Enhanced Smelter Outreach

•
We continued our participation in the AIAG Conflict Minerals Working Group and in the CFSI’s plenary and due diligence practices team;
•
We participate in the CFSI’s Multi-Stakeholder Call and Smelter Engagement Team;
•
We added links on our website to the CFSI smelter outreach letters that encourage SORs to become certified as Compliant (as later defined in Section III.B., and which we also sometimes refer to herein as “certified” or “conflict-free”) with the CFSP protocols;
•
We sent letters to SORs identified by our suppliers and classified by the CFSI as requiring outreach to encourage them to become certified as Compliant;

General Process Enhancements

•
Additional data was made available to our internal sourcing team showing the progress of each of our locations in the RCOI process;
•
We increased the level of assistance and support for our conflict minerals team across the enterprise;
•
We continued to revise and simplify our written communications and instructions to our businesses regarding Supplier red flag follow-up to enhance program effectiveness; and
•
We continued providing information and assistance at enterprise-wide strategic sourcing conferences.

II.    Reasonable Country of Origin Inquiry

Our RCOI utilized management systems recommended by the first step of the Organisation for Economic Co-operation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (the “OECD Guidance”), and was conducted in accordance with the second step of the OECD Guidance. Selected

2


elements of our program design and RCOI process are discussed below. However, these are not all of the discrete elements of the program that we have put in place in accordance with these steps of the OECD Guidance to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the first and second steps.

A.
Establish Strong Management Systems

1.    ITW Policies

ITW has adopted a company-wide Conflict Minerals Policy Statement (the "Conflict Minerals Policy"), which has been approved by ITW’s Chief Executive Officer and is available in seven languages on our website at http://www.itw.com/about-itw/suppliers/page/en/conflict-minerals-policy-statement/. Our Conflict Minerals Policy states that we do not knowingly procure 3TG that originate from the Covered Countries unless they originate from mines or SORs that are certified as having followed established protocols to allow them to be considered “conflict free.” We ask our suppliers to undertake reasonable due diligence with their supply chains to determine whether products containing 3TG used in the manufacture of our products originate from a Covered Country and, if they do originate from a Covered Country, that the SORs be certified as Compliant. The Conflict Minerals Policy encourages our suppliers to continue to support Compliant SORs in the Covered Countries and to make similar requests of their sub-suppliers. If we discover that any 3TG procured by us are produced in a Covered Country from facilities that are not certified as Compliant, we will request that our supplier ask the facility to become certified or use our best efforts to transition the product to be from Compliant sources.

ITW’s Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) sets forth expectations for all ITW suppliers to adhere to the highest ethical standards in the conduct of their business. It also requires suppliers to adhere to specific standards and specifically prohibits certain behaviors associated with conflict minerals, including use of child or forced labor, unsafe working conditions and bribery. The Code of Conduct also requires that, upon request, our suppliers determine whether any products provided by them contain 3TG and to take such actions as necessary to provide the information requested by ITW to conduct its RCOI, as described below under B. Identify and Assess Risk in the Supply Chain.

We do not support a general embargo of sourcing from the Covered Countries, and our Conflict Minerals Policy encourages our suppliers to continue to source from responsible sources in those countries.

2.    Cross Functional Committee

ITW has a cross-functional conflict minerals committee (the “Committee”). The Committee is headed by ITW’s Vice President of Strategic Sourcing, who reports to ITW’s Vice Chairman, and includes dedicated employees and representatives from strategic sourcing, legal, internal audit, IT, and selected personnel from various operations. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets as needed to discuss the conflict minerals compliance process and developments. Senior management is briefed on the results of our due diligence efforts on a regular basis.

3.    Internal Training

We maintain an intranet conflict minerals website which contains resources, instructions and guidance on the RCOI and due diligence processes to be followed by our businesses that have or may have in-scope products. The site also contains step-by-step instructions for making supplier inquiries, including training videos regarding our RCOI and due diligence process, and can be accessed by all ITW businesses for reference. Our businesses are instructed to view at least one of the training sessions.


3


4.    Supplier Engagement and Training

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

Our supplier invitation letters are translated into eight languages. ITW educates key suppliers through presentations regarding our conflict minerals compliance program during supplier meetings and other interactions. The training is intended to help ensure the quality and completeness of the Conflict Minerals Reporting Templates (“CMRTs”) received from suppliers. We also post information and guidance for suppliers on our Company website and encourage our businesses to share relevant information with suppliers on the process for responding to our RCOI requests for information. See http://www.itw.com/about-itw/suppliers/.

5.    Records Retention

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

6.    Grievance Mechanism

ITW maintains a web- and telephone-based reporting system (“Helpline”), providing employees with a confidential reporting mechanism by which they can communicate issues and concerns associated with violations of ITW’s Principles of Conduct, which requires all employees to comply with all applicable laws and Company policies, including the Conflict Minerals Policy.
A link to the Helpline is included in our Conflict Minerals Policy on our website to provide convenient access to external stakeholders, suppliers and other third parties to communicate issues and concerns regarding ITW’s supply chain. The contact information for our Helpline is http://www.itwhelpline.ethicspoint.com.

B.    Identify and Assess Risk in the Supply Chain

Our RCOI process was used to survey our potential in-scope suppliers to identify and assess conflict mineral sourcing risk in our supply chain for the 2016 reporting cycle.

Prior to conducting our supplier survey, we made internal inquiries of our businesses to identify the in-scope products of each of our segments. All businesses were given information and guidance to assist in determining which products are in-scope. In addition, we reviewed our 2016 spend data for commodities likely to contain 3TG and notified businesses of potentially relevant suppliers that did not receive a request for conflict minerals information during the prior collection cycle.

We then surveyed all potentially in-scope suppliers to determine whether 3TG in those products originated or may have originated from a Covered Country and were not from recycled or scrap sources. Businesses with potential in-scope products were instructed to survey their suppliers regarding the origin of the 3TG contained in those products using the then latest version of the CFSI’s CMRT. The CMRT requests information regarding 3TG included in the suppliers’ products, SOR identity and location, the supplier’s RCOI process and other information about the suppliers’ conflict minerals policies and practices. Our outreach included all suppliers that we identified as having provided us with components, parts or products that contain 3TG or that we identified as potentially containing 3TG (the "Suppliers"), in an effort to comprehensively include all sources of 3TG.

ITW has an established protocol for its supplier inquiry process and uses a third party software vendor to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and suppliers through use of a cloud-based 3TG tracking tool (the “CM System”).


4


We sent 4,113 requests to Suppliers to provide us with a completed CMRT. A number of our businesses source different products from the same Supplier. Since each business sent inquiries to all of its suppliers of potentially in-scope products, the total number of unique suppliers is less than the number of Suppliers queried. We received 1,768 CMRTs from the Suppliers surveyed, as compared to 1,636 received for calendar year 2015.

The CM System issued automatic weekly follow-up reminders to non-responding Suppliers, and our businesses were given instructions regarding follow-up actions beyond the automatic reminders and in response to receipt of incomplete or incorrect CMRTs.

Our protocol also includes a follow-up process to investigate any CMRTs received that raised “red flags”. See Section III. Due Diligence for a description of the follow-up process.

Our Supplier responses identified 242 SORs certified by the CFSI as Compliant. We determined that 201 of these Compliant SORs sourced exclusively from outside the Covered Countries, including in whole or in part from recycled or scrap sources. Our determination was based on country of origin information CFSI has obtained through their smelter audit process that is made available to CFSI members.

Our Supplier responses identified an additional 18 SORs that were listed as “Active” (as later defined in Section III.B.) by the CFSI, 8 that were in communication with the CFSI and 40 that were on the CFSI’s Smelter Reference List but were not Compliant, Active or in communication.

A member of our conflict minerals team joined CFSI’s Smelter Engagement Team, and we reached out directly to the 40 SORs that were not listed as Compliant, Active or in communication with the CFSI and either asked them to become certified by the CFSI or instructed our businesses to request that their suppliers remove them from their supply chains.

Based on the results of our RCOI, we were required to conduct due diligence, as described below.

III.    Due Diligence

A.
Design Framework

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

B.
Due Diligence Activities

Selected elements of our program design and implementation in furtherance of the third, fourth and fifth steps of the OECD Guidance are discussed below. However, these are not all of the discrete elements of the program that we have put in place pursuant to these steps to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the third, fourth and fifth steps. The actions taken by the Company to address the first and second steps of the OECD Guidance are described in Section II. Reasonable Country of Origin Inquiry. See also our 2016 program enhancements discussed in Section I. Introduction.

Design and implement a strategy to respond to identified risks

The SOR information provided by Suppliers in response to the Company’s supplier survey described in Section II.B. was reviewed against the Smelter Reference List in the CMRT. SOR information also was reviewed against the lists of Compliant, Active and “in communication” SORs and country-of-origin information published by the CFSI and contained in the CM System. “Compliant” SORs have been audited and found compliant with the relevant CFSP protocol. “Active” SORs are those that are taking action to become Compliant. “In communication” SORs are those that are not yet Active but in communication with CFSP and/or a CFSI member.

CMRTs received from our Suppliers that indicated 3TG from a source within a Covered Country or that contained inconsistent smelter information triggered a “red flag” in the CM System, and communications with the flagged Suppliers

5


were escalated. Suppliers indicating 3TG from a source within a Covered Country were asked to complete a series of additional questions, and our businesses were given written guidance and instructions for these communications. These escalated Supplier situations were reviewed on a case-by-case basis. Suppliers with CMRTs containing inconsistent smelter information were asked to revisit their submission and resubmit a corrected CMRT.

In addition, we reached out directly to the SORs that were not listed as Compliant, Active or in communication by the CFSI and either asked them to become certified by the CFSI or instructed our businesses to request that their suppliers remove them from their supply chains. Smelters that were categorized by the CFSI as “not applicable” were not addressed in our outreach efforts, as we did not consider them to be operating smelters. To the extent that identified SORs are not Compliant, we also seek to exercise leverage over these SORs to become Compliant through our participation in and support of the CFSI and its Smelter Engagement Team. We also utilize information provided by the CFSI to its members to monitor smelter and refiner improvement.

In 2016, we continued to revise and simplify our written communications and instructions to our businesses regarding Supplier red flag follow-up to enhance program effectiveness.

Our conflict minerals compliance team reported the findings from its RCOI and due diligence process to our Vice President of Strategic Sourcing, and these results were in turn discussed with senior management.

Carry out independent third party audit of supply chain diligence at identified points in the supply chain

The Company continued its membership in the CFSI for 2016 and joined its Multi-Stakeholder call and Smelter Engagement Team. Due to our location in the mineral supply chain, which is discussed earlier in this Conflict Minerals Report, we support and utilize the CFSI’s CFSP to perform third-party audits of SORs.

Report annually on supply chain due diligence

We describe our supply chain due diligence efforts in our Conflict Minerals Report. We prepare this report annually, post it on our website and file it with the SEC as an exhibit to our annual Form SD. Once filed, the Form SD and Conflict Minerals Report become available on our website. We also disclosed our efforts in the area of conflict minerals in our annual Corporate Social Responsibility Report, which is available on our website at
http://www.itw.com/wp-content/uploads/2017/03/ITW_2016CorporateSocialResponsibilityReport_FINAL-min.pdf.


6


IV.    Product Information

For 2016, our in-scope products included products in each of the categories below:
Arc welding and cutting equipment and consumables
Industrial ovens
Automotive components
Industrial warewashers
Catalysts
Inspection equipment
Commercial food equipment
LEDs, LCDs
Commercial cooking equipment
Marking and coding equipment
Commercial refrigerators
Mixers
Cutting equipment
Printers and dispensers
Electronic components
Production equipment
Electrical devices
Sealants
Electronic equipment
Sealing equipment
Fasteners
Soldering equipment
Fastening tools
Switches, capacitors and electronics
Filtration
Testing equipment
Flow control meters
Warehouse equipment
Hot stamp machines
Welding hardware
Industrial equipment
 

V.    Identified Smelters and Refiners

Our Supplier responses identified 242 SORs that were on the CFSI Compliant list, 18 that were listed as Active, 8 listed as in communication with the CFSI and 40 that were on the Smelter Reference List but not Compliant, Active or in communication with the CFSI. These facilities are listed on Annex A. The information in Annex A includes only the information and entities identified by our Suppliers as SORs that were on the Smelter Reference List contained in the CM System as of February 24, 2017, which are those entities identified to us that we were able to determine were SORs. Entities identified by our Suppliers that are not on Annex A have been submitted to the CFSI to support their ongoing effort to identify and audit all 3TG SORs.

Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our Suppliers for accurate SOR information, and our RCOI and due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products. The information that we received from most of our Suppliers was made at a company or user defined level, rather than at a product level, meaning that such Suppliers provided information on all of their products that contained 3TG, not just the products that were sold to us. Therefore, our list of SORs disclosed in Annex A may contain facilities that did not process the 3TG contained in our products. In addition, the identified SORs may not include all SORs present in our in-scope product supply chain, since some Suppliers were unable to identify all of the SORs in their supply chain.

Annex A includes information concerning the smelter locations of the SORs listed. We applied the information made available to CFSI members regarding the countries of origin of these smelters and have not found for 2016 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country. However, we have not declared that any of our products are “DRC conflict free.”

VI.    Additional Risk Mitigation

In addition to the actions described elsewhere in this Conflict Minerals Report, we intend to take or continue the following steps in respect of our 2017 compliance to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:

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

7


•
Analyze spend data against supplier response data to identify inconsistencies and areas of potential enhanced focus for supplier outreach efforts.
Engage with Suppliers that provided incomplete responses or that did not provide responses for 2016 to help ensure that they will provide requested information for 2017.
•
Continue to enhance supplier communication and training to improve RCOI and due diligence data accuracy and completion.
•
Through our direct suppliers, continue to seek to influence uncertified SORs in our supply chain to obtain a Compliant certification by engaging with Suppliers who identified uncertified SORs that are not actively pursuing certification to encourage them to pursue certification.
•
Continue our membership in the CFSI and participation in its Multi-Stakeholder, Due Diligence and Smelter Engagement Teams and support the CFSI’s certification of SORs.
•
Continue to submit to the CFSI facilities identified by our Suppliers that are not on the Smelter Reference List, to support the CFSI's ongoing effort to identify and audit all 3TG SORs.

VII.    Forward Looking Statements

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





8


Annex A to Exhibit 1.01
CFSI Smelters or Refiners
 
 
 
 
Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner Status
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Compliant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Compliant
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Compliant
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Compliant
Gold
Argor-Heraeus S.A.
SWITZERLAND
Compliant
Gold
Asahi Pretec Corp.
JAPAN
Compliant
Gold
Asahi Refining Canada Ltd.
CANADA
Compliant
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Compliant
Gold
Asaka Riken Co., Ltd.
JAPAN
Compliant
Gold
AU Traders and Refiners
SOUTH AFRICA
Compliant
Gold
Aurubis AG
GERMANY
Compliant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Compliant
Gold
Boliden AB
SWEDEN
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Compliant
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Compliant
Gold
Chimet S.p.A.
ITALY
Compliant
Gold
Daejin Indus Co., Ltd.
KOREA (REPUBLIC OF)
Compliant
Gold
DODUCO GmbH
GERMANY
Compliant
Gold
Dowa
JAPAN
Compliant
Gold
DSC (Do Sung Corporation)
KOREA (REPUBLIC OF)
Compliant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Compliant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Compliant
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Compliant
Gold
Heimerle + Meule GmbH
GERMANY
Compliant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Compliant
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Compliant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
Istanbul Gold Refinery
TURKEY
Compliant
Gold
Japan Mint
JAPAN
Compliant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Compliant

9


Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Compliant
Gold
Kazzinc
KAZAKHSTAN
Compliant
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Compliant
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Compliant
Gold
Korea Zinc Co., Ltd.
KOREA (REPUBLIC OF)
Compliant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Compliant
Gold
LS-NIKKO Copper Inc.
KOREA (REPUBLIC OF)
Compliant
Gold
Materion
UNITED STATES OF AMERICA
Compliant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Compliant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Compliant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Compliant
Gold
Metalor Technologies S.A.
SWITZERLAND
Compliant
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Compliant
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Compliant
Gold
Mitsubishi Materials Corporation
JAPAN
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Compliant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Compliant
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Compliant
Gold
Nihon Material Co., Ltd.
JAPAN
Compliant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Compliant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Compliant
Gold
PAMP S.A.
SWITZERLAND
Compliant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Compliant
Gold
PX Precinox S.A.
SWITZERLAND
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Compliant
Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
Compliant
Gold
Royal Canadian Mint
CANADA
Compliant
Gold
Samduck Precious Metals
KOREA (REPUBLIC OF)
Compliant
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Compliant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Compliant
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Compliant
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Compliant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Compliant

10


Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Compliant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Compliant
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Compliant
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Compliant
Gold
T.C.A S.p.A
ITALY
Compliant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Compliant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Compliant
Gold
Torecom
KOREA (REPUBLIC OF)
Compliant
Gold
Umicore Brasil Ltda.
BRAZIL
Compliant
Gold
Umicore Precious Metals Thailand
THAILAND
Compliant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Compliant
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Compliant
Gold
Valcambi S.A.
SWITZERLAND
Compliant
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Compliant
Gold
WIELAND Edelmetalle GmbH
GERMANY
Compliant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Compliant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Compliant
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Compliant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Compliant
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Compliant
Gold
Bangalore Refinery
INDIA
Active
Gold
Cendres + Metaux S.A.
SWITZERLAND
Active
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Active
Gold
Marsam Metals
BRAZIL
Active
Gold
Modeltech Sdn Bhd
MALAYSIA
Active
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Active
Gold
Tony Goetz NV
BELGIUM
Active
Gold
HeeSung Metal Ltd.
KOREA (REPUBLIC OF)
Active
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Active
Gold
Caridad
MEXICO
On Smelter Reference List
Gold
HwaSeong CJ CO., LTD.
KOREA (REPUBLIC OF)
On Smelter Reference List
Gold
Morris and Watson
NEW ZEALAND
On Smelter Reference List
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
On Smelter Reference List
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
On Smelter Reference List

11


Gold
L'azurde Company For Jewelry
SAUDI ARABIA
On Smelter Reference List
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
On Smelter Reference List
Gold
Sudan Gold Refinery
SUDAN
On Smelter Reference List
Gold
Chugai Mining
JAPAN
In Communication
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
In Communication
Gold
Remondis Argentia B.V.
NETHERLANDS
In Communication
Gold
SAAMP
FRANCE
In Communication
Gold
SAFINA A.S.
CZECH REPUBLIC
In Communication
Gold
Samwon Metals Corp.
KOREA (REPUBLIC OF)
In Communication
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
In Communication
Gold
Elemetal Refining, LLC
UNITED STATES OF AMERICA
On Smelter Reference List
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
On Smelter Reference List
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
On Smelter Reference List
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
On Smelter Reference List
Gold
Guangdong Jinding Gold Limited
CHINA
On Smelter Reference List
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
On Smelter Reference List
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
On Smelter Reference List
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
On Smelter Reference List
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
On Smelter Reference List
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
On Smelter Reference List
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
On Smelter Reference List
Gold
Lingbao Gold Co., Ltd.
CHINA
On Smelter Reference List
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
On Smelter Reference List
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
On Smelter Reference List
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
On Smelter Reference List
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
On Smelter Reference List
Gold
Sai Refinery
INDIA
On Smelter Reference List
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
On Smelter Reference List

12


Gold
So Accurate Group, Inc.
UNITED STATES OF AMERICA
On Smelter Reference List
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
On Smelter Reference List
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
On Smelter Reference List
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Compliant
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Compliant
Tantalum
Duoluoshan
CHINA
Compliant
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Compliant
Tantalum
F&X Electro-Materials Ltd.
CHINA
Compliant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Compliant
Tantalum
Global Advanced Metals Aizu
JAPAN
Compliant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Compliant
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Compliant
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Compliant
Tantalum
H.C. Starck Ltd.
JAPAN
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Compliant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Compliant
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES OF AMERICA
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Nonferrous Metals Smelting Company Limited
CHINA
Compliant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
KEMET Blue Metals
MEXICO
Compliant
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Compliant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Compliant
Tantalum
LSM Brasil S.A.
BRAZIL
Compliant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Compliant
Tantalum
Mineracao Taboca S.A.
BRAZIL
Compliant
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Compliant
Tantalum
NPM Silmet AS
ESTONIA
Compliant

13


Tantalum
Power Resources Ltd.
MACEDONIA (THE FORMER YUGOSLAV REPUBLIC OF)
Compliant
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Compliant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Compliant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Compliant
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Compliant
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Compliant
Tantalum
Tranzact, Inc.
UNITED STATES OF AMERICA
Compliant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Compliant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Compliant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Compliant
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
CHINA
Compliant
Tin
Alpha
UNITED STATES OF AMERICA
Compliant
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Compliant
Tin
China Tin Group Co., Ltd.
CHINA
Compliant
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Compliant
Tin
CV Ayi Jaya
INDONESIA
Compliant
Tin
CV Dua Sekawan
INDONESIA
Compliant
Tin
CV Gita Pesona
INDONESIA
Compliant
Tin
CV Serumpun Sebalai
INDONESIA
Compliant
Tin
CV Tiga Sekawan
INDONESIA
Compliant
Tin
CV United Smelting
INDONESIA
Compliant
Tin
CV Venus Inti Perkasa
INDONESIA
Compliant
Tin
Dowa
JAPAN
Compliant
Tin
Elmet S.L.U.
SPAIN
Compliant
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Compliant
Tin
Fenix Metals
POLAND
Compliant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Compliant
Tin
Gejiu Jinye Mineral Company
CHINA
Compliant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Compliant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Compliant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Compliant
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Compliant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Compliant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Compliant
Tin
Melt Metais e Ligas S.A.
BRAZIL
Compliant
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Compliant

14


Tin
Metallo-Chimique N.V.
BELGIUM
Compliant
Tin
Mineracao Taboca S.A.
BRAZIL
Compliant
Tin
Minsur
PERU
Compliant
Tin
Mitsubishi Materials Corporation
JAPAN
Compliant
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Compliant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Compliant
Tin
Operaciones Metalurgical S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Compliant
Tin
PT Aries Kencana Sejahtera
INDONESIA
Compliant
Tin
PT Artha Cipta Langgeng
INDONESIA
Compliant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Compliant
Tin
PT Babel Inti Perkasa
INDONESIA
Compliant
Tin
PT Bangka Prima Tin
INDONESIA
Compliant
Tin
PT Bangka Tin Industry
INDONESIA
Compliant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Compliant
Tin
PT Bukit Timah
INDONESIA
Compliant
Tin
PT DS Jaya Abadi
INDONESIA
Compliant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Compliant
Tin
PT Inti Stania Prima
INDONESIA
Compliant
Tin
PT Karimun Mining
INDONESIA
Compliant
Tin
PT Kijang Jaya Mandiri
INDONESIA
Compliant
Tin
PT Mitra Stania Prima
INDONESIA
Compliant
Tin
PT O.M. Indonesia
INDONESIA
Compliant
Tin
PT Panca Mega Persada
INDONESIA
Compliant
Tin
PT Prima Timah Utama
INDONESIA
Compliant
Tin
PT Refined Bangka Tin
INDONESIA
Compliant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Compliant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Compliant
Tin
PT Sukses Inti Makmur
INDONESIA
Compliant
Tin
PT Sumber Jaya Indah
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Compliant
Tin
PT Tinindo Inter Nusa
INDONESIA
Compliant
Tin
PT Tommy Utama
INDONESIA
Compliant
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Compliant
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Compliant
Tin
Soft Metais Ltda.
BRAZIL
Compliant
Tin
Thaisarco
THAILAND
Compliant
Tin
VQB Mineral and Trading Group JSC
VIET NAM
Compliant
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Compliant
Tin
Yunnan Tin Company Limited
CHINA
Compliant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Active

15


Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Active
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Active
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Active
Tin
Modeltech Sdn Bhd
MALAYSIA
Active
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Active
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Active
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
In Communication
Tin
An Thai Minerals Co., Ltd.
VIET NAM
On Smelter Reference List
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
On Smelter Reference List
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
On Smelter Reference List
Tin
Estanho de Rondonia S.A.
BRAZIL
On Smelter Reference List
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
On Smelter Reference List
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
On Smelter Reference List
Tin
Super Ligas
BRAZIL
On Smelter Reference List
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Compliant
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Compliant
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Compliant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Compliant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Compliant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Compliant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Compliant

16


Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Compliant
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Compliant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Compliant
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Compliant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Compliant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Compliant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Compliant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Compliant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Compliant
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Compliant
Tungsten
Woltech Korea Co., Ltd.
KOREA (REPUBLIC OF)
Compliant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Compliant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Haichuang Tungsten Industry Co., Ltd.
CHINA
Active
Tungsten
ACL Metais Eireli
BRAZIL
Active
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
On Smelter Reference List
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
On Smelter Reference List
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
On Smelter Reference List
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
On Smelter Reference List

Country of Origin Information

The countries of origin of the 3TG processed by the Compliant SORs listed above may have included minerals from the respective countries listed below. The listed countries of origin are derived from information made available by the CFSI to its members. Except for the DRC, the CFSI does not indicate individual countries of origin of the 3TG processed by Compliant SORs. Instead, the CFSI indicates country of origin by category. Compliant SORs listed above sourced minerals directly and/or indirectly (second tier smelter) from one or more of the following categories: L1, countries not identified as conflict regions or plausible areas of smuggling or export of 3TG from the DRC and its nine adjoining countries; L2, countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG; L3, which includes the DRC and its nine adjoining countries; and/or The Democratic Republic of Congo (DRC).

L1: Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Ecuador, Eritrea, Ethiopia, France, Guinea, Ghana, Guatemala, Guinea, Guyana,

17


Honduras, India, Indonesia, Japan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russia, Senegal, Sierra Leone, Spain, Thailand, Togo, the United States of America, Uzbekistan, Vietnam, Zimbabwe

L2: Mozambique, South Africa

L3: Burundi, Rwanda Uganda

The Democratic Republic of Congo (DRC)

In addition, according to information made available by the CFSI to its members, some of the listed SORs processed 3TG originating solely from recycled or scrap sources and others processed both recycled and scrap content and newly mined content from one or more of the regions indicated above.

Because the CFSI generally does not indicate individual countries of origin of the 3TG processed by Compliant SORs, we were not able to determine the countries of origin of the 3TG processed by the listed Compliant SORs with greater specificity. In addition, for some of the listed Compliant SORs, origin information is not disclosed. We did not determine the countries of origin of the 3TG processed by other SORs listed on this Annex A.

18


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