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May 26, 2017 3:11 PM EDT





UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C.  20549
 mtwlogo.jpg
FORM SD
Specialized Disclosure Report
 

The Manitowoc Company, Inc.
(Exact name of registrant as specified in its charter)
 
Wisconsin
 
1-11978
 
39-0448110
(State or other jurisdiction
 of incorporation or organization)
 
(Commission File
 Number)
 
(I.R.S. Employer
 Identification No.)


2400 South 44th Street, Manitowoc, Wisconsin 54220
(Address of principal executive offices) (Zip Code)
Louis F. Raymond
Vice President, General Counsel and Secretary
(920) 684-4410
(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, 2016.










Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

A copy of The Manitowoc Company, Inc.’s (the “Company”) Conflict Minerals Report for the reporting period from January 1 to December 31, 2016, is provided as Exhibit 1.01 hereto and is publicly available on the Company’s website (www.manitowoc.com) under Investor Relations–Corporate Governance–Governance Highlights–Other Governance Documents.


Item 1.02    Exhibit

See Item 2.01 of this Form.

Section 2 – Exhibits
Item 2.01    Exhibits
Exhibit 1.01 – Conflict Minerals Report of The Manitowoc Company, Inc., as required by Items 1.01 and 1.02 of this Form.





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.

THE MANITOWOC COMPANY, INC.
(Registrant)


By: /s/ Louis F. Raymond
May 26, 2017
Louis F. Raymond
(Date)
Vice President, General Counsel and Secretary
    





Exhibit 1.01

The Manitowoc Company, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2016

Part I.    Introduction
This is the Conflict Minerals Report (the “Report”) of The Manitowoc Company, Inc. (the “Company,” “we,” “us” or “our”) for calendar year 2016 in accordance with Rule 13p-1 under the Securities and Exchange Act of 1934 (“the Rule”). This Report discusses the Company’s efforts to determine whether any of the products it manufactures or contracts to be manufactured contain columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin, and tungsten (collectively, “3TGs”), that are necessary to the functionality or production of such products that may have originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”) or are from recycled or scrap sources.
Part II.    Company and Product Overview
Founded in 1902, the Company is a leading global manufacturer of cranes and lift solutions. The Company is recognized as one of the premier innovators and providers of lattice boom crawler cranes, tower cranes, mobile telescopic cranes, and boom trucks for the global construction industry (collectively referred to herein as “Products”), which are complemented by a slate of industry-leading aftermarket product support services. Our Products are principally marketed under the Manitowoc, Grove, Potain, and National Crane brand names. We serve a wide variety of customers, including dealers, rental companies, contractors and government entities, across the petrochemical, industrial, commercial, power and utilities, infrastructure and residential end markets.
Our Conflict Minerals Steering Committee (the “Committee”) conducted an analysis of our manufacturing operations and supply chain (the “applicability assessment”) and identified 3TGs that are necessary to the functionality or production of the Products we manufactured or contracted to be manufactured during calendar year 2016. Our Products generally contain (in varying degrees and amounts) some 3TGs necessary to their functionality or production.
Part III.     Reasonable Country of Origin Inquiry (“RCOI”)     
We began our scoping process identifying a list of our Products that may contain 3TG and then we extracted a list of our suppliers who provide us with products that may contain one or more of the 3TGs. Once the filtering was completed, we populated the supplier list with contact information and provided the list to our third-party service provider. We also included a list of associated parts for these suppliers to ensure that suppliers have the option of completing their CMRT (as defined below) on the product or company level. This supplier list was then uploaded to our third-party provider’s software platform that allows us to store and manage supplier requests and documentation.
From there, we defined our scoping process even further by removing service providers, indirect materials suppliers, and inactive suppliers. This ensures that all suppliers surveyed provided items to the Company that were used in final Products in the year 2016. Through this process, we determined that 1018 suppliers were in scope for the 2016 reporting period. The number of in-scope suppliers increased significantly since last reporting year due to the inclusion of our after-market Crane Care parts direct material suppliers in order to obtain more comprehensive data. The Company took a more proactive approach to scoping compared to the last reporting year, and initially included suppliers who had been previously excluded due to these suppliers’ posing minimal risk to the supply chain. The Company then re-evaluated many of these after-market Crane Care suppliers for scope; in particular, those suppliers who remained non-responsive after multiple inquiries. Of that group, we then removed from scope any suppliers who provided a very low number of parts, having determined that the risk they pose to Manitowoc’s supply chain was minimal. After this process, the total number of in-scope suppliers for the 2016 reporting period was 748 suppliers.
Our service provider then conducted the supplier survey portion of the RCOI. Utilizing the Conflict Minerals Reporting Template (the “CMRT”), version 4.10 or higher, developed by the Electronic Industry Citizenship Coalition® and The Global e-Sustainability Initiative, the suppliers identified through the procedures described above were surveyed on their sourcing of the 3TGs that we identified in our Products. The CMRT includes questions regarding a direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain, such as the names and locations of smelters and refiners as well as the origin of 3TGs used by those facilities.

1


During the supplier survey, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in our third-party provider’s software platform. Non-responsive suppliers were contacted a minimum of three times by our service provider’s Supply Chain Team as well as by Manitowoc personnel in one-on-one communications. This included four follow-ups by the Company to encourage their response via the CMRT.
To ensure that our suppliers understood our expectations regarding the sourcing of 3TGs, we provided training through webinars, videos, documentation, and one-on-one discussions. This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized a Learning Management System, Assent University, and provided all in-scope suppliers access to Assent’s Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation was to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms were accepted and classified as valid or invalid so that data was retained. All suppliers who submitted CMRTs that were flagged as “invalid” were contacted at least twice to address items such as incomplete data, missing smelter information, or inconsistent answers. These communications were monitored and tracked in our service provider’s system for future reporting and transparency. As of May 24, 2017, we had received responses from 98% of the suppliers surveyed (there were 62 invalid submissions that were not corrected by suppliers).
Based on the RCOI, we determined that we may have some suppliers who sourced 3TGs from the Covered Countries. Therefore, in an effort to identify mines with the greatest possible specificity, we conducted due diligence on our supplier base, as described below.
Part IV. Due Diligence
In accordance with Securities and Exchange Commission (“SEC”) rules, the Company undertook due diligence efforts to determine whether the 3TGs in the Products it manufactures, or contracts to manufacture, that are necessary to the functionality or production of its Products originated in the Covered Countries or are from recycled or scrap sources. The Company designed its due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related supplements for each of the Conflict Minerals (the “OECD Guidance”).
Our due diligence process for 2016 included the steps described below:
Step 1: Establish strong Company management systems
We are committed to the responsible sourcing of our Products and we expect the same from our suppliers, including ensuring that the products or components supplied to us do not directly or indirectly finance or benefit armed groups in the Covered Countries. Our suppliers are required to support our efforts to comply with the Rule. We have developed a Conflict Minerals Policy, which is available on our website (www.manitowoc.com) under Investor Relations-Corporate Governance-Governance Highlights-Other Governance Documents. In addition, our standard supplier terms and conditions address our expectations related to any 3TGs supplied to us. We also have a Company-level mechanism to enable the reporting of grievances.
We established a grievance mechanism whereby employees and suppliers can report violations of the Company’s policies, including with respect to conflict minerals. Suppliers and others outside the Company may contact our conflict minerals team to communicate with us, including to report grievances, via a dedicated email address that is published in our conflict minerals policy and in other communications with our suppliers. In addition, our employees may anonymously report suspected violations using Manitowoc’s Corporate Governance/Whistleblower Hotline, available 24 hours a day, seven days a week. The Company’s Corporate Governance/Whistleblower Hotline is staffed by non-Manitowoc personnel, who share any information reported with our General Counsel and Corporate Governance Committee.
Our Conflict Minerals steering committee (the “Committee”), which includes representatives from supply chain management, procurement, engineering, operational excellence, information systems, legal and internal audit, and reports to the Company’s senior leadership, oversees supplier due diligence regarding Conflict Minerals. The Committee is also responsible for educating procurement and supply chain employees, revising supplier terms and conditions to include our Conflict Minerals expectations, and overseeing the preparation of the Form SD and this Report. The Committee also has the authority to engage consultants and advisors to assist with its efforts.

2


Building on the process the Committee implemented in previous years, in 2016 the Committee analyzed the Company’s manufacturing operations and supply chain to identify the Products that we manufacture or contract to manufacture that might contain 3TGs. Based on that process, the Committee worked with the Company’s engineering, manufacturing, and supply chain management teams as well as our service provider to identify, engage with, and make appropriate inquiries of our suppliers to determine, based on a RCOI, whether the Company may be sourcing 3TGs from the Covered Countries. We also sought to strengthen engagement with suppliers by developing an internal procedure that includes steps for supplier engagement escalations, including direct follow ups from Company personnel and our third-party service provider.
The Company retained information regarding its due diligence efforts for 2016 in accordance with its existing record retention policies and procedures.
Step 2: Identify and assess risk in the supply chain
Our due diligence efforts were based on a survey process in which we requested certain information from selected suppliers who we believed may be providing parts or components containing 3TGs by using the CMRT, as previously discussed. More specifically, the Committee oversaw the following:
•
A supply chain survey of those direct suppliers identified during the applicability assessment and ROCI who the Company believed represented the highest risk of supplying parts or components that may contain 3TGs from the Covered Countries.
•
Automated data validation on all submitted CMRT responses. All invalid responses were flagged and the applicable suppliers were contacted at least twice to correct their CMRT.
•
A comparison of the smelters and refiners that were identified by the Company’s suppliers against published lists to assist in the supplier risk assessment.
•
Periodic reporting to senior management regarding the results of the survey and related risk assessment.

Certain of the responses to the CMRT included the names of facilities listed by the suppliers as smelters or refiners of 3TGs. As a downstream consumer of 3TGs, we do not have direct relationships with smelters and refiners of 3TGs and do not perform or direct audits of these entities. Our service provider compared the facilities listed by our suppliers to the list of smelters and refiners maintained by the Conflict-Free Sourcing Initiative (“CFSI”). If a supplier indicated that the facility was certified as “Conflict-Free,” our service provider first confirmed that the name of the smelter or refiner was included on the published list as an active facility. As of May 24, 2017, we had validated 316 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primarily company or divisional level CMRTs by our suppliers, as opposed to product-level CMRTs, we cannot definitively determine the connection of their 3TGs (if any) to our Products.
Any supplier who claimed that the products they provided to the Company contained 3TGs was asked to include smelter or refiner information on the smelter tab of the CMRT. In these cases, if the supplier did not provide smelter or refiner information, the CMRT was flagged as invalid and a follow-up message was sent.
Each facility that meets the CFSI definition of a smelter or refiner of a 3TGs mineral is assigned a risk of high, medium, or low based on the following three scoring criteria:

•
Geographic proximity to the DRC and covered countries;
•
Conflict-Free Smelter Program (CFSP) audit status; and
•
Known or plausible evidence of unethical or conflict sourcing.

We also calculated supplier risk based on the chance that the supplier provides 3TGs that may originate from non-conflict-free sources. The value of this risk was calculated based on the risk ratings of the smelters/refiners listed by the supplier on the CMRT.
Additionally, suppliers were evaluated on the strength of their sourcing program, which further assisted in identifying risk in the supply chain and in making key risk mitigation decisions. The following criteria were used to evaluate the strength of each supplier’s program:
•
Do you have a policy in place that includes DRC conflict-free sourcing?
•
Have you implemented due diligence measures for conflict-free sourcing?
•
Do you verify due diligence information received from your suppliers?
•
Does your verification process include corrective action management?


3


If a supplier answered “yes” to all of the questions above, it was deemed to have a strong 3TGs program. When a supplier did not meet any of those criteria, it was deemed to have a weak 3TGs program.
Any supplier who is flagged as having a weak program will be contacted to encourage it to increase the strength of its program.
We believe that the inquiries and investigations described above, which included (1) seeking information about 3TGs smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT; (2) verifying those smelters and refiners with the expanding published lists; (3) conducting the due diligence review; and (4) obtaining additional documentation and verification, as applicable, represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Products.
Step 3: Design and implement a strategy to respond to identified risks
We completed a management reporting dashboard on a periodic basis summarizing the results of the risk assessment process. Other elements of the Company’s due diligence process designed to respond to identified risks included the following:
•
Suppliers who did not respond to the Company’s initial survey request were sent at least three escalation communications requesting that they provide the information requested.
•
Suppliers who provided incomplete or inconsistent responses were sent follow-up communications, as previously discussed. Based on the type of risk identified during a review of supplier responses, suppliers were sent a corrective action communication.

Based on the smelter or refiner risk criteria noted above, the following facilities have been identified as being of highest concern to the supply chain:

•
Tony Goetz NV - CID002587
•
Kaloti Precious Metals - CID002563
•
Phoenix Metals - CID002507
•
Universal Precious Metals Refining Zambia - CID002854
•
Fidelity Printers and Refiners - CID002515
•
Sudan Gold Refinery - CID002567

When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our third-party vendor, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take its own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Manitowoc, and escalating up to removal of these high-risk smelters from their supply chain. As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context.
If a supplier was unable to confirm that 3TGs supplied to us were sourced from a smelter or refiner that has been audited and certified as conflict-free, we requested that the supplier find alternative sources for 3TGs.
In addition, if, through our due diligence process, we became aware that one of our suppliers was sourcing 3TGs from the Covered Countries or was unable to determine the origin of the 3TGs supplied to us, our practice was to take the following steps:
•
Determine whether the smelter or refiner that processed the 3TGs supplied by that supplier had been audited and certified as conflict-free by a reputable independent third party;
•
Notify the supplier of our Conflict Minerals Policy and expectations; and
•
Inform the supplier that if the supplier does not begin using conflict-free sources within a reasonable period, we may take appropriate steps including, but not limited to, replacing the supplier.

Step 4: Third-party audit of smelters’/refiners’ due diligence practices
As a downstream consumer of 3TGs, the Company must rely on its direct suppliers to gather information about smelters and refiners in the supply chain. The Company does not purchase any 3TGs in their raw material form and, to the best of its knowledge, does not directly purchase any products or components directly from any of the Covered Countries. As a result, the Company does not perform or direct audits of smelters and refiners.
Step 5: Report annually on supply chain due diligence

4


This Report and the related Form SD were publicly filed with the SEC and are available on our website (www.manitowoc.com) under Investor Relations-Corporate Governance-Governance Highlights-Other Governance Documents.
Part V.    Due Diligence Results
Most of the supplier responses we received provided data at a company or divisional level. Therefore, based on our due diligence efforts, we are unable to determine whether the 3TGs reported by the suppliers were contained in the actual components or parts supplied to the Company. Therefore, our list of processing smelters or refiners may contain more facilities than those that actually processed the 3TGs contained in our Products.
The quality of the responses that we received from our surveyed suppliers continues to be varied. Many responses provided by suppliers (via the CMRT) included the names of facilities listed by the suppliers as smelters or refiners. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TGs claimed on the CMRT are considered invalid and our third-party provider continues to follow up with these suppliers. In addition, there are still suppliers unable to provide the smelters or refiners used for 3TGs supplied to us.
For all responses that indicated a smelter, our third-party provider compared the facilities listed to the list of smelters maintained by the CFSI. If a supplier indicated that the facility was certified as “Conflict-Free,” our provider confirmed that the name was listed by CFSI as a certified smelter. No violations were identified. As of May 24, 2017, we had validated 316 smelters or refiners and we are working to validate the additional smelter or refiner entries from the submitted CMRTs.
Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 246 smelters and refiners that are deemed CFSP Compliant - this indicates these smelters or refiners follow the Conflict Free Smelter Program assessment protocols. There are 12 more smelters or refiners that have been deemed CFSP Active, meaning that they have committed to undergo a CFSP audit or are currently participating in one of the cross-recognized certification programs such as the LBMA Responsible Gold Certification or the Responsible Jewelry Program Chain-of-Custody Certification. The remaining 58 smelters and refiners have not yet been confirmed as conflict-free. We have assessed these facilities and determined that most of them are low risk due to their geographic location. As mentioned above, there are six smelters or refiners that are considered high risk and the below six appear in the CMRTs submitted to Manitowoc by our suppliers:
•
Tony Goetz NV - CID002587
•
Kaloti Precious Metals - CID002563
•
Phoenix Metals - CID002507
•
Universal Precious Metals Refining Zambia - CID002854
•
Fidelity Printers and Refiners - CID002515
•
Sudan Gold Refinery - CID002567

Appendix A to this Report lists the legitimate smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate and the fact that the smelter or refiner is listed on Appendix A does not definitively indicate that 3TGs processed by such smelter or refiner were included in the Company’s Products. Appendix B to this Report includes an aggregated list of potential countries of origin from which the reported facilities collectively source 3TGs, based on information provided by our suppliers and the CFSI; the fact that a country is listed on Appendix B does not definitively indicate that 3TGs in the Company’s Products were sourced from that country.
Part VI.    Steps to Improve Due Diligence
In addition to the measures described above, the Company intends to take the following steps during the next compliance period to improve the due diligence conducted and to further mitigate the risk that the 3TGs necessary to support our operations benefit armed groups, including:
•
Informing and encouraging suppliers to transition to smelters identified as conflict-free by an independent audit program such as the CFSI;
•
Actively participating in and supporting industry trade groups to help improve communication throughout the supply chain;
•
Working with certain suppliers to help educate them on our ongoing expectations supporting responsible sourcing decisions;
•
Reconsidering our willingness to continue to partner with suppliers who do not comply with our Conflict Minerals Policy;

5


•
Contacting suppliers that have been flagged for additional follow-up and clarification; and/or
•
Increasing education to suppliers regarding the Conflict Minerals Rule, smelters and refiners, and proper use of the CMRT.

Forward-Looking Statements
The Report contains forward-looking statements, which express a belief, expectation or intention, as well as those that are historical fact, including statements relating to our compliance efforts and expected actions. The words “expects,” “intends,” “plans,” “believes,” and “anticipates” and similar expressions are used to identify these forward-looking statements. These statements are not guarantees of future actions or performance and are subject to various risks, uncertainties and assumptions. Undue reliance should be not be placed on these statements, which are only effective as of the date of this Report, and the Company undertakes no obligation to publicly update or revise any forward-looking statement.




6


Appendix A
List of Potential Smelters/Refiners

Metal
 Standard Smelter Name
 Smelter Facility Location
 Smelter ID
 CFSI Audit Status
Gold
Abington Reldan Metals, LLC
UNITED STATES
CID002708
Active
Gold
Advanced Chemical Company
UNITED STATES
CID000015
Compliant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Compliant
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
CID002560
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Compliant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
CID000058
Compliant
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Compliant
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Compliant
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Compliant
Gold
Asahi Refining USA Inc.
UNITED STATES
CID000920
Compliant
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Compliant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
Not Enrolled
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Compliant
Gold
AURA-II
UNITED STATES
CID002851
Not Enrolled
Gold
Aurubis AG
GERMANY
CID000113
Compliant
Gold
Bangalore Refinery
INDIA
CID002863
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Compliant
Gold
Boliden AB
SWEDEN
CID000157
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Compliant
Gold
Caridad
MEXICO
CID000180
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Compliant
Gold
Cendres + Métaux S.A.
SWITZERLAND
CID000189
Active
Gold
Chimet S.p.A.
ITALY
CID000233
Compliant
Gold
Chugai Mining
JAPAN
CID000264
Not Enrolled
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
Compliant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
Not Enrolled
Gold
DODUCO GmbH
GERMANY
CID000362
Compliant
Gold
Dowa
JAPAN
CID000401
Compliant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Compliant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID000425
Compliant
Gold
Elemetal Refining, LLC
UNITED STATES
CID001322
Compliant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Compliant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
Not Enrolled
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
CID000522
Not Enrolled
Gold
Geib Refining Corporation
UNITED STATES
CID002459
Active
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
Not Enrolled
Gold
Gujarat Gold Centre
INDIA
CID002852
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000651
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
Not Enrolled

7


Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Compliant
Gold
Heraeus Ltd. Hong Kong
CHINA
CID000707
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Compliant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
CID000778
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Compliant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Compliant
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Compliant
Gold
Japan Mint
JAPAN
CID000823
Compliant
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Compliant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
Not Enrolled
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
Not Enrolled
Gold
Kazzinc
KAZAKHSTAN
CID000957
Compliant
Gold
Kennecott Utah Copper LLC
UNITED STATES
CID000969
Compliant
Gold
KGHM Polska MiedŸ Spó³ka Akcyjna
POLAND
CID002511
Active
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Compliant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Compliant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Compliant
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
Not Enrolled
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
Not Enrolled
Gold
L'Orfebre S.A.
ANDORRA
CID002762
Not Enrolled
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Compliant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Not Enrolled
Gold
Materion
UNITED STATES
CID001113
Compliant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Compliant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Compliant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Compliant
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Compliant
Gold
Metalor USA Refining Corporation
UNITED STATES
CID001157
Compliant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
CID001161
Compliant
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Compliant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Compliant
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Not Enrolled
Gold
Morris and Watson
NEW ZEALAND
CID002282
Not Enrolled
Gold
Morris and Watson Gold Coast
AUSTRALIA
CID002866
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.
TURKEY
CID001220
Compliant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Active
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Compliant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Compliant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Compliant

8


Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Compliant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Compliant
Gold
PAMP S.A.
SWITZERLAND
CID001352
Compliant
Gold
Pease & Curren
UNITED STATES
CID002872
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Not Enrolled
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Compliant
Gold
PX Précinox S.A.
SWITZERLAND
CID001498
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Compliant
Gold
Remondis Argentia B.V.
NETHERLANDS
CID002582
Not Enrolled
Gold
Republic Metals Corporation
UNITED STATES
CID002510
Compliant
Gold
Royal Canadian Mint
CANADA
CID001534
Compliant
Gold
SAAMP
FRANCE
CID002761
Not Enrolled
Gold
Sabin Metal Corp.
UNITED STATES
CID001546
Not Enrolled
Gold
SAFINA A.S.
CZECH REPUBLIC
CID002290
Not Enrolled
Gold
Sai Refinery
INDIA
CID002853
Not Enrolled
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Compliant
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
CID001562
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Compliant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
CID001573
Compliant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
CID001585
Compliant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
Not Enrolled
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Compliant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Compliant
Gold
Singway Technology Co., Ltd.
TAIWAN
CID002516
Compliant
Gold
So Accurate Group, Inc.
UNITED STATES
CID001754
Not Enrolled
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Compliant
Gold
Solar Applied Materials Technology Corp.
TAIWAN
CID001761
Compliant
Gold
Sudan Gold Refinery
SUDAN
CID002567
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Compliant
Gold
T.C.A S.p.A
ITALY
CID002580
Compliant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Compliant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Compliant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Not Enrolled
Gold
Tony Goetz NV
BELGIUM
CID002587
Active
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Not Enrolled
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Compliant
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Compliant
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Compliant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Compliant
Gold
United Precious Metal Refining, Inc.
UNITED STATES
CID001993
Compliant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
CID002854
Not Enrolled
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Compliant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
CID002030
Compliant
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Compliant

9


Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
CID002100
Compliant
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Compliant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Compliant
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
CID002243
Compliant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
CID000291
Compliant
Tantalum
D Block Metals, LLC
UNITED STATES
CID002504
Compliant
Tantalum
Duoluoshan
CHINA
CID000410
Compliant
Tantalum
Exotech Inc.
UNITED STATES
CID000456
Compliant
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Compliant
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002505
Compliant
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Compliant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
CID002557
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Compliant
Tantalum
H.C. Starck GmbH Goslar
GERMANY
CID002545
Compliant
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
CID002546
Not Enrolled
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Compliant
Tantalum
H.C. Starck Inc.
UNITED STATES
CID002548
Compliant
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492
Compliant
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
CID000731
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002512
Compliant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID002842
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Compliant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Compliant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002506
Compliant
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Compliant
Tantalum
KEMET Blue Powder
UNITED STATES
CID002568
Compliant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
CID000973
Compliant
Tantalum
LSM Brasil S.A.
BRAZIL
CID001076
Compliant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Compliant
Tantalum
Mineração Taboca S.A.
BRAZIL
CID001175
Compliant
Tantalum
Mitsui Mining & Smelting
JAPAN
CID001192
Compliant
Tantalum
Molycorp Silmet A.S.
ESTONIA
CID001200
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Compliant
Tantalum
Plansee SE Liezen
AUSTRIA
CID002540
Not Enrolled
Tantalum
Plansee SE Reutte
AUSTRIA
CID002556
Compliant
Tantalum
Power Resources Ltd.
MACEDONIA
CID002847
Compliant
Tantalum
QuantumClean
UNITED STATES
CID001508
Compliant
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
CID002707
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
CID001522
Compliant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Compliant
Tantalum
Taki Chemicals
JAPAN
CID001869
Compliant
Tantalum
Telex Metals
UNITED STATES
CID001891
Compliant
Tantalum
Tranzact, Inc.
UNITED STATES
CID002571
Compliant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Compliant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Compliant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
CID002307
Compliant
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
CHINA
CID002232
Compliant

10


Tin
Alpha
UNITED STATES
CID000292
Compliant
Tin
An Thai Minerals Co., Ltd.
VIET NAM
CID002825
Not Enrolled
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Compliant
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Compliant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
CID000278
Not Enrolled
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
CID000295
Compliant
Tin
CV Ayi Jaya
INDONESIA
CID002570
Compliant
Tin
CV Dua Sekawan
INDONESIA
CID002592
Compliant
Tin
CV Gita Pesona
INDONESIA
CID000306
Compliant
Tin
CV Serumpun Sebalai
INDONESIA
CID000313
Compliant
Tin
CV Tiga Sekawan
INDONESIA
CID002593
Compliant
Tin
CV United Smelting
INDONESIA
CID000315
Compliant
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Compliant
Tin
Dowa
JAPAN
CID000402
Compliant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID002572
Active
Tin
Elmet S.L.U.
SPAIN
CID002774
Compliant
Tin
EM Vinto
BOLIVIA
CID000438
Compliant
Tin
Estanho de Rondônia S.A.
BRAZIL
CID000448
Not Enrolled
Tin
Fenix Metals
POLAND
CID000468
Compliant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Compliant
Tin
Gejiu Jinye Mineral Company
CHINA
CID002859
Compliant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Active
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Compliant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908
Active
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Not Enrolled
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Compliant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Compliant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Not Enrolled
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
CID000244
Compliant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Compliant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Compliant
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Compliant
Tin
Metallic Resources, Inc.
UNITED STATES
CID001142
Compliant
Tin
Metallo-Chimique N.V.
BELGIUM
CID002773
Compliant
Tin
Mineração Taboca S.A.
BRAZIL
CID001173
Compliant
Tin
Minsur
PERU
CID001182
Compliant
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Compliant
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002858
Not Enrolled
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
CID001231
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Compliant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Compliant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
CID001337
Compliant
Tin
Phoenix Metal Ltd.
RWANDA
CID002507
Not Enrolled
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Compliant
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Compliant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Compliant
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Compliant
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Compliant

11


Tin
PT Bangka Tin Industry
INDONESIA
CID001419
Compliant
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Compliant
Tin
PT Bukit Timah
INDONESIA
CID001428
Compliant
Tin
PT Cipta Persada Mulia
INDONESIA
CID002696
Compliant
Tin
PT DS Jaya Abadi
INDONESIA
CID001434
Compliant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
CID001438
Compliant
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Compliant
Tin
PT Justindo
INDONESIA
CID000307
Not Enrolled
Tin
PT Karimun Mining
INDONESIA
CID001448
Compliant
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829
Compliant
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002870
Compliant
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Compliant
Tin
PT O.M. Indonesia
INDONESIA
CID002757
Compliant
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Compliant
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Compliant
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Compliant
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Compliant
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Compliant
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816
Compliant
Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
Compliant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
CID001477
Compliant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
CID001482
Compliant
Tin
PT Tinindo Inter Nusa
INDONESIA
CID001490
Compliant
Tin
PT Tommy Utama
INDONESIA
CID001493
Compliant
Tin
PT Wahana Perkit Jaya
INDONESIA
CID002479
Compliant
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
CID002706
Compliant
Tin
Rui Da Hung
TAIWAN
CID001539
Compliant
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Compliant
Tin
Thaisarco
THAILAND
CID001898
Compliant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
Not Enrolled
Tin
VQB Mineral and Trading Group JSC
VIET NAM
CID002015
Compliant
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
CID002036
Compliant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Active
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Compliant
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
CID000004
Compliant
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Not Enrolled
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Compliant
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
CID000345
Not Enrolled
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Compliant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Compliant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
CID002536
Not Enrolled
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
CID000568
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Compliant
Tungsten
H.C. Starck GmbH
GERMANY
CID002541
Compliant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
CID002542
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Compliant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Compliant

12


Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Compliant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Compliant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Compliant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002647
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Compliant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313
Not Enrolled
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Compliant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Compliant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
CID002535
Compliant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Compliant
Tungsten
Kennametal Fallon
UNITED STATES
CID000966
Compliant
Tungsten
Kennametal Huntsville
UNITED STATES
CID000105
Compliant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Compliant
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
CID002845
Compliant
Tungsten
Niagara Refining LLC
UNITED STATES
CID002589
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
CID002543
Compliant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Compliant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID002815
Compliant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Compliant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Compliant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
CID002011
Compliant
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
CID002044
Compliant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Compliant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Compliant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Compliant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095
Compliant


13


Appendix B
Potential Countries of Origin

The list below sets forth the potential countries of origin of 3TGs used in the manufacture of the Products disclosed in the Report. The list is based on publicly available information, our RCOI, and other due diligence efforts. However, for the reasons described in the Report, these possible countries of origin cannot be linked to our Products with reasonable certainty.
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Columbia, Cote D’Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia



14

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