Form SD NOVA LTD.

May 25, 2022 7:00 AM EDT

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
FORM SD
SPECIALIZED DISCLOSURE REPORT

Nova Ltd.
(Exact name of registrant as specified in its charter)

 Israel 
   000-30668     
 98-0601172
(State or other jurisdiction of
incorporation or organization)
 (Commission file number)
 (IRS Employer Identification No.)
 
5 David Fikes St., Rehovot 7632805, Israel
 (Address of principal executive offices) (Zip code)

Dror David, +972-73-2295670, +972-8-9407776
 (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:
 
☒   Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
 


SECTION 1 – CONFLICT MINERALS DISCLOSURE

Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

In accordance with Rule 13p-1 of the Securities Exchange Act of 1934, as amended, Nova Ltd. (the “Company”) hereby files this Specialized Disclosure Report on Form SD and the Conflict Minerals Report attached hereto as Exhibit 1.01.  The Specialized Disclosure Report on Form SD and Conflict Minerals Report are also available on the Company’s website at: https://www.novami.com under “Company”—“Corporate Responsibility”—“Conflict Minerals”. The content of any website referred to in this Form SD (including the exhibit hereto) is included for general information only and is not incorporated by reference into this document. 

SECTION 2 – RESOURCE EXTRACTION ISSUER DISCLOSURE

Item 2.01        Resource Extraction Issuer Disclosure and Report

Not applicable.

SECTION 3 – EXHIBITS

Item 3.01 Exhibits


2

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.

 
Nova Ltd.
(Registrant)
 
       
Date: May 25, 2022
By:
/s/ Dror David 
 
    Dror David 
 
    Chief Financial Officer     
 
       

3



 

Exhibit 1.01

Nova Ltd.

Conflict Minerals Report
For the Reporting Period January 1, 2021 to December 31, 2021

Introduction
 
This Conflict Minerals Report of Nova Ltd. (the “Company”, “our Company”, “Nova”, “we”, “us” or “our”) for the reporting period from January 1, 2021 to December 31, 2021 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold (“Conflict Minerals”), and which are necessary to the functionality or production of their products. The Rule requires each of these registrants to conduct a reasonable country of origin inquiry (“RCOI”) with respect to the sourcing of the Conflict Minerals that such company uses in its products and, if it has no reason to believe that the Conflict Minerals originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”), file a description of the inquiry performed and the results of such inquiry on Form SD. If after conducting a RCOI as required by SEC rules a registrant has reason to believe that any of the Conflict Minerals in its supply chain may have originated in the DRC or Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the registrant must exercise due diligence with respect to the source and chain of custody of the Conflict Minerals in order to determine whether or not such Conflict Minerals directly or indirectly financed or benefited armed groups in the DRC or Covered Countries, and describe such due diligence measures in a Conflict Minerals Report that is included as an exhibit to its Form SD.
 
Nova is committed to responsible sourcing of minerals and has taken action to increase transparency in its supply chain and ensure responsible procurement by its suppliers and sub-suppliers. Nova has adopted a policy with respect to the sourcing of Conflict Minerals, which is available on its website at: https://www.novami.com/csr/environment-safety/ under “Environment & Safety” —“Conflict Minerals”. The content of any website referred to in this Conflict Minerals Report is included for general information only and is not incorporated by reference into this document.
 
Consistent with the Rule and the SEC’s statement on April 29, 2014 relating to the Rule, this Conflict Minerals Report has not been audited by an independent private sector auditor.

Company and Products Overview
 
We are a leading innovator and a key provider of metrology solutions for advanced process control used in semiconductor manufacturing. We offer several metrology solutions, mainly by using optical and x-ray technologies, delivering unique measurement solutions to measure the most advanced semiconductor technology nodes. Our metrology systems measure various film thickness and composition properties as well as critical-dimension (CD) variables during various front-end and back-end of line steps in the semiconductor wafer fabrication process, allowing semiconductor manufacturers to improve quality, productivity and yields, lower manufacturing costs and increase profitability. We supply our metrology solutions to major semiconductor manufacturers worldwide and serve customers from offices in Taiwan, the Republic of Korea, China, Japan, the United States and Europe.
 
The scope of this report includes all of our consolidated businesses and subsidiaries for the year 2021, including one manufacturing facility for our Optical CD product lines, which is located in Ness-Ziona, Israel, and one manufacturing facility for our x-ray product line, which is located in Fremont, California, in the United States. This report refers to the purchase of parts and sub-assemblies (“Components”) used for our manufacturing facilities in both Israel and California. During 2021, all such Components were purchased from third parties and were delivered to these facilities, where they were integrated into complete systems that constitute the tools that we sold to others. Following the acquisition of ancosys GmbH in January 2022, we have expanded our technology offering by adding Chemical Analytical methods with applications of Chemical metrology in various steps. In light of the date of the acquisition, ancosys manufacturing is not within the scope of this year’s report.
 
Because metals such as tin, tantalum, tungsten and gold that are included in the definition of Conflict Minerals are generally contained in our Components, we believe that our products contain Conflict Minerals that are necessary for the functionality or production of our products.


 
Reasonable Country of Origin Inquiry (“RCOI”)
 
Because we believe that Conflict Minerals were necessary to the functionality or production of products manufactured, or contracted to be manufactured, by us during 2021, we performed an RCOI to determine whether the Conflict Minerals in such products originated from the DRC or Covered Countries and whether such Conflict Minerals come from recycled or scrap sources.
 
The products that we manufacture, or contract to manufacture, are highly complex, and typically contain thousands of Components from many manufacturers. We have an extensive and varied supply chain and do not have a direct relationship with Conflict Minerals smelters or refiners. In this regard, we do not purchase Conflict Minerals directly from mines, smelters or refiners, and there are many third parties in the supply chain between the original sources of Conflict Minerals and the ultimate manufacture of our products. Accordingly, to gather information from our suppliers, we utilize a standard template for Conflict Minerals reporting designed by the Responsible Business Initiative (“RBI”) known as the Conflict Minerals Reporting Template (the “CMRT”). We relied on our suppliers to complete the CMRT in order to provide information on the origin of the Conflict Minerals contained in Components supplied to us – including information regarding the sources of Conflict Minerals that are supplied to our suppliers from lower tiers in the chain (i.e., sub-suppliers). In addition, with respect to the certification of smelters or refiners as conflict-free, we have relied upon the latest findings of the RBI’s Responsible Minerals Assurance Process (the “RMAP”).
 
The RCOI undertaken by us in 2021 consisted of sending letters and CMRTs to 42 of our largest first-tier suppliers that we concluded were providing us with Components that do, or may, contain Conflict Minerals that are necessary for the functionality or production of our products and that accounted for approximately 90% of all our applicable 2021 product material expenditures. These suppliers include our turnkey suppliers, which means that they are in direct contact with our supply chain management team, and are considered to be our strategic partners, having long-term relationships with our Company. The letters we sent to such suppliers explained the Rule and referred the suppliers to online training materials and instructions, sought their support and cooperation in our efforts in connection with Conflict Minerals, provided a copy of our Conflict Minerals policy, and asked them to complete the CMRT. Working with a third-party service provider to conduct the survey and compile the survey results, we reviewed the responses and followed up as necessary by sending periodic reminders to non-responsive suppliers and following up on responses that appeared to be inconsistent, incomplete or inaccurate.  In the end, the response rate from suppliers asked to participate was 90%.
 
Based on information obtained in the RCOI, and taking into account the complexities of our supply chain, we concluded that we did not have sufficient information to determine the country of origin of the Conflict Minerals in our products and were unable to rule out the possibility that Conflict Minerals used in our products originated, or may have originated, from the DRC or Covered Countries. Therefore, in accordance with the Rule, we undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of our products during 2021. There is significant overlap between our RCOI efforts and our due diligence measures performed.
 
Due Diligence
 
Design of Due Diligence Framework
 
Our due diligence measures have been designed, in all material respects, to conform as far as practicable with the internationally recognized due diligence framework prescribed by the Organization for Economic Co-operation and Development (“OECD”), known as “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas” and related supplements for Conflict Minerals (the “OECD Guidance”).

2

 
Due Diligence Measures Performed
 
In substantial conformance with the OECD Guidance, our due diligence efforts for calendar year 2021 included the following steps:
 
Step 1. Establish Strong Company Management Systems
 

Conflict Minerals steering committee: A cross-functional Conflict Minerals steering committee operates our Conflict Minerals program. The committee consists of representatives from the following areas: operations (purchasing and engineering); and legal and compliance. Regular meetings of our Conflict Minerals steering committee were held, and the committee periodically updated representatives of our senior management on the status of the Conflict Minerals program.

Conflict Minerals Policy: Our Conflict Minerals policy (the “Policy”), adopted in 2015, has been communicated both throughout our Company and to suppliers, and is publicly available on our Company’s website at: https://www.novami.com/csr/environment-safety/ under “Environment & Safety” —“Conflict Minerals”.

Supplier engagement: We sent letters and CMRTs to a substantial portion of our first-tier suppliers identified during an applicability assessment phase as providing Components that do, or may, contain Conflict Minerals that are necessary for the functionality or production of our products. The aforementioned letters advised the suppliers of our commitment to responsible sourcing of minerals and indicated that their cooperation in the due diligence efforts is expected, including by completion of the CMRT.
In addition, we made training materials available to those first-tier suppliers that included an overview of the Rule and instructions on how to complete the CMRT survey.
For each purchase order issued by our computerized purchase order system for purchasing Components, suppliers are required to accept our terms and conditions, which include, among others, that (i) upon request, a supplier shall provide us with information regarding its products that contain Conflict Minerals, and (ii) in certain cases, we reserve the right to immediately terminate the purchase order and cease all procurement activity with the supplier.
 
Step 2. Identify and Assess Risks in the Supply Chain
 
We identified and assessed risk in our supply chain as follows: First, we identified our major first-tier (i.e., direct) suppliers that provide Components that potentially incorporate Conflict Minerals that are necessary to the functionality or production of our products that we manufactured, or contracted to manufacture, in 2021 (and which accounted for a substantial portion of all applicable expenditures on Components by our Company in 2021). We then requested information from relevant suppliers regarding the source and chain of custody of Conflict Minerals in their supply chain. To facilitate the collection of complete, accurate, standardized and verifiable information, we relied primarily on the CMRT, which seeks information regarding country of origin of Conflict Minerals, mine location and smelters or refiners used.
 
We reviewed suppliers’ responses in order to track information regarding smelters or refiners of Conflict Minerals in our supply chain that have not received a conflict-free designation based on the RMAP.
 
Step 3. Design and Implement a Strategy to Respond to Identified Risks
 
We initiated a supply chain survey with selected suppliers using the CMRT in order to identify those smelters or refiners that supplied Conflict Minerals used in our products. We monitored and tracked our performance in this area by reviewing supplier responses. Each CMRT completed by a supplier was entered into a database maintained by a third-party service provider and reviewed.  For suppliers that provided unclear or incomplete responses, an escalation process was used in order to obtain complete and accurate required information, sometimes requiring multiple telephone and/or email contacts to further the data collection process. Our Conflict Minerals steering committee held regular meetings to review progress and assess the risks identified.
 
   In addition, smelters or refiners that were identified in the suppliers’ responses were compared against the list of facilities that have received a conflict-free designation from the RMAP (“conflict-free” meaning generally that they did not directly or indirectly finance or benefit armed groups in the Covered Countries), and country of origin information for the smelters or refiners identified by the supply chain responses were reviewed using RMAP data.  In accordance with our risk management plan, we contacted suppliers that have been identified as having non-certified smelters or refiners within the smelters or refiners list that they have provided to us.

3

 
Finally, representatives of our senior management were briefed about our due diligence efforts and findings on a regular basis.
 
Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
 
We are several steps away in the supply chain from smelters or refiners that process the Conflict Minerals used in our products, do not have any direct relationships with such smelters or refiners and did not obtain from a third party or perform ourselves a direct audit of smelters or refiners within our supply chain. Instead, we relied on conflict-free designations based on the activities of other organizations such as the RBI (through the RMAP).
 
Step 5.  Report Annually on Supply Chain Due Diligence
 
We report annually on our supply chain due diligence, as required by the Rule, and have posted our Form SD and Conflict Minerals Report on our website at: https://www.novami.com/csr/environment-safety/ under “Environment & Safety” —“Conflict Minerals”.
 
Results of Assessment
 
On account of incomplete information, we are unable at this time to determine and describe with complete certainty in this report a complete list of either the facilities used to process the Conflict Minerals used in our products or the countries of origin of those Conflict Minerals. We have, nevertheless, described below the results of our assessment on the source of the Conflict Minerals, to the extent that we received information from our relevant suppliers through our due diligence efforts.
 
As indicated above, the products that we manufacture, or contract to manufacture, are highly complex, and typically contain thousands of Components from many suppliers. Because there are generally multiple tiers between the mines that extract Conflict Minerals and our suppliers, we relied on our suppliers to provide information on the origin of the Conflict Minerals contained in Components supplied to us.
 
In all, we surveyed 42 suppliers to whom we paid approximately 90% of the applicable expenditures by our Company on Component costs for our products in 2021. 90% of the suppliers whom we surveyed provided a complete response.
 
As part of our due diligence efforts and based on the information received from our suppliers, we identified 337 smelters or refiners of Conflict Minerals used generally in their supply chains, of which 72.5% have been certified as conflict free by the RBI’s RMAP, and of which 5% are currently engaged in the RBI audit process. A list of these identified smelters or refiners is provided in Appendix A hereto.
 
Some suppliers were unable to provide a complete list of smelters or refiners. In addition, despite receiving information regarding smelters or refiners used generally by some suppliers in their supply chains, these suppliers were unable to report which smelters or refiners were part of the supply chain applicable to the specific Components that were sold to us. Furthermore, for the significant majority of smelters reported by these suppliers, there is inadequate information available to assess the source of the conflict minerals that they process. As a result, we are unable to identify with complete accuracy the country of origin of the Conflict Minerals used in our products in 2021 and we concluded in good faith that we lack sufficient information to trace the chain of custody of any Conflict Minerals contained in our products in 2021 up through the supply chain to a specific smelter or, in turn, to a country or mine of origin. We have, however, become aware that certain smelters or refiners from Covered Countries that have been identified as part of the supply chain of our suppliers have not been certified as conflict free under the RBI’s RMAP. We have therefore activated our risk management procedures in respect of those smelters or refiners, and have approached the supplier that provided us the relevant Conflict Minerals sourced from those smelters or refiners and have asked for corrective action to be taken.
 
We furthermore note that information is not gathered from our suppliers on a continuous, real-time basis. We can therefore only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals used in our products, since the information comes from direct suppliers, not the underlying smelters or refiners, and is based on independent third-party audit programs, not our own auditing.

4

 
Continuous Efforts to Mitigate Risk
 
We intend to maintain our approach for responsible sourcing of the minerals used in our products and to continue to comply with any applicable regulations related to the sourcing of, and disclosure concerning, the Conflict Minerals that may be contained in our products.
 
Forward Looking Statements
 
Forward looking statements in this Conflict Minerals Report are made pursuant to the safe harbor provisions of Section 21E of the Securities Exchange Act of 1934, as amended, and other federal securities laws. Investors are cautioned that statements in this Conflict Minerals Report that are not strictly historical statements, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts and strategy, constitute forward looking statements that involve risks and uncertainties. Actual results could differ materially from the forward looking statements. Words such as “expects,” “anticipates,” “intends,” variations of these words, and similar expressions, are intended to identify such forward looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others. Except as otherwise required by law, the Company undertakes no obligation to update publicly the information contained in this Conflict Minerals Report, or any forward looking statements, to reflect new information, events or circumstances after the date they were made, or to reflect the occurrence of unanticipated events.
 

5


Appendix A

List of Identified Smelters or Refiners

Smelter Metal
Smelter Look-up (known smelters by RBI)
Smelter Country
Gold
8853 S.p.A.
ITALY
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
African Gold Refinery
UGANDA
Gold
AGR (Perth Mint Australia)
AUSTRALIA
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
AKITA Seiren
JAPAN
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
Amagasaki Factory, Hyogo Prefecture, Japan
JAPAN
Gold
AngloGold Ashanti Brazil
BRAZIL
Gold
Anhui Tongling Nonferrous Metal Mining Co., Ltd.
CHINA
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
ATAkulche
TURKEY
Gold
AU Traders and Refiners
SOUTH AFRICA
Gold
Augmont Enterprises Private Limited
INDIA
Gold
Aurubis AG
GERMANY
Gold
BALORE REFINERSGA
INDIA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Boliden AB
SWEDEN
Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
C.I Metales Procesados Industriales SAS
COLOMBIA
Gold
Caridad
MEXICO
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Cendres + M?taux SA
SWITZERLAND
Gold
CGR Metalloys Pvt Ltd.
INDIA
Gold
CHALCO Yunnan Copper Co. Ltd.
CHINA
Gold
Chimet S.p.A.
ITALY
Gold
China Henan Zhongyuan Gold Smelter
CHINA
Gold
China's Shandong Gold Mining Co., Ltd
CHINA
Gold
Chugai Mining
JAPAN
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
DEGUSSA
GERMANY


6


Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
Gold
Do Sung Corporation
KOREA, REPUBLIC OF
Gold
Doduco
GERMANY
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
Gold
Ekaterinburg
RUSSIAN FEDERATION
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Federal State Unitary Enterprise Moscow Special Processing Plant (FSUE MZSS)
RUSSIAN FEDERATION
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
FSE Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
Fujairah Gold FZC
UNITED ARAB EMIRATES
Gold
Fujian Zijin mining stock company gold smelter
CHINA
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
Gold Coast Refinery
GHANA
Gold
Great Wall Precious Metals Co,. LTD.
CHINA
Gold
Guangdong Gaoyao Co
CHINA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Germany GmbH Co. KG
GERMANY
Gold
Heraeus Ltd. Hong Kong
CHINA
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Gold
Industrial Refining Company
BELGIUM
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Italpreziosi
ITALY
Gold
JALAN & Company
INDIA
Gold
Japan Mint
JAPAN
Gold
JCC
CHINA
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES


7


Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
KGHM Polska Miedz S.A.
POLAND
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
Kundan Care Products Ltd.
INDIA
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Gold
LinBao Gold Mining
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
L'Orfebre S.A.
ANDORRA
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
Marsam Metals
BRAZIL
Gold
Materion
UNITED STATES OF AMERICA
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
MEM(Sumitomo Group)
JAPAN
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalor Technologies S.A.
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Kinzoku Co., Ltd.
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
Modeltech Sdn Bhd
MALAYSIA
Gold
Morris and Watson
NEW ZEALAND
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
PAMP S.A.
SWITZERLAND
Gold
Pease & Curren
UNITED STATES OF AMERICA
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
Planta Recuperadora de Metales SpA
CHILE
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION


8


Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Precinox S.A.
SWITZERLAND
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Gold
Remondis Argentia B.V.
NETHERLANDS
Gold
Royal Canadian Mint
CANADA
Gold
SAAMP
FRANCE
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Gold
Safimet S.p.A
ITALY
Gold
SAFINA A.S.
CZECHIA
Gold
Sai Refinery
INDIA
Gold
Samdok Metal
KOREA, REPUBLIC OF
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Gold
Shandong Tarzan Bio-Gold Industry Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Shenzhen Zhonghenglong Real Industry Co., Ltd.
CHINA
Gold
Shirpur Gold Refinery Ltd.
INDIA
Gold
Shonan Plant Tanaka Kikinzoku
JAPAN
Gold
Shyolkovsky
RUSSIAN FEDERATION
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
Smelter not listed
UNITED STATES OF AMERICA
Gold
Smelter not listed
COLOMBIA
Gold
Smelter not listed
SOUTH AFRICA
Gold
Smelter not listed
INDIA
Gold
Smelter not listed
INDIA
Gold
Smelter not listed
INDIA
Gold
Smelter not listed
INDIA
Gold
Smelter not listed
NORWAY
Gold
Smelter not listed
MAURITANIA
Gold
Smelter not listed
INDIA
Gold
Smelter not listed
UNITED STATES OF AMERICA
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Sovereign Metals
INDIA
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Gold
Sudan Gold Refinery
SUDAN
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
T.C.A S.p.A
ITALY
Gold
Tokuriki Honten Co., Ltd.
JAPAN


9


Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Valcambi S.A.
SWITZERLAND
Gold
Value Trading
Belgium
Gold
WEEEREFINING
FRANCE
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Tantalum
Asaka Riken Co., Ltd.
JAPAN
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
F & X
CHINA
Tantalum
FIR Metals & Resource Ltd.
CHINA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Ltd.
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
LSM Brasil S.A.
BRAZIL
Tantalum
Meta Materials
NORTH MACEDONIA, REPUBLIC OF
Tantalum
Metallurgical Products India Pvt. Ltd. (MPIL)
INDIA
Tantalum
Mineracao Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining & Smelting
JAPAN
Tantalum
Molycorp Silmet A.S.
ESTONIA
Tantalum
Ningxia Non-Ferrous Metal Smeltery
CHINA
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
Resind Ind e Com Ltda.
BRAZIL
Tantalum
RFH
CHINA
Tantalum
Solikamsk
RUSSIAN FEDERATION


10


Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
ULBA
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
Yancheng Jinye New Material Technology Co., Ltd.
China
Tin
Alent plc
UNITED STATES OF AMERICA
Tin
An Vinh Joint Stock Mineral Processing Company
VIETNAM
Tin
Brand RBT
INDONESIA
Tin
Chengfeng Metals Co Pte Ltd
CHINA
Tin
Chenzhou Yun Xiang mining limited liability company
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
China Tin (Hechi)
CHINA
Tin
China Yunnan Tin Co Ltd.
CHINA
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Tiga Sekawan
INDONESIA
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
Tin
Dowa
JAPAN
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIETNAM
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Estanho de Rondonia S.A.
BRAZIL
Tin
Fabrica Auricchio Industria e Comercio Ltda.
BRAZIL
Tin
Fenix Metals
POLAND
Tin
Funsur Smelter
PERU
Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.
CHINA
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
Gejiu Zi-Li
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
INDONESIAN STATE TIN CORPORATION MENTOK SMELTER
INDONESIA
Tin
Jiangxi Nanshan
CHINA
Tin
Kundur Smelter
INDONESIA
Tin
Luna Smelter, Ltd.
RWANDA
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA


11


Tin
Melt Metais e Ligas S.A.
BRAZIL
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
Metallo Belgium N.V.
BELGIUM
Tin
Metallo Spain S.L.U.
SPAIN
Tin
Mineracao Taboca S.A.
BRAZIL
Tin
Mining and processing tin-tungsten ore Giang Son - VQB Co., Ltd.
VIETNAM
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Modeltech Sdn Bhd
MALAYSIA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
OMSA
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Pongpipat Company Limited
MYANMAR
Tin
Precious Minerals and Smelting Limited
INDIA
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
PT Babel Surya Alam Lestari
INDONESIA
Tin
PT Bangka Serumpun
INDONESIA
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Mitra Sukses Globalindo
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Rajawali Rimba Perkasa
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Timah Nusantara
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
Resind Ind e Com Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Smelter not listed
BRAZIL
Tin
Smelter not listed
RUSSIAN FEDERATION
Tin
Smelter not listed
SPAIN
Tin
Soft Metais Ltda.
BRAZIL
Tin
Super Ligas
BRAZIL
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIETNAM
Tin
Thai Solder Industry Corp., Ltd.
THAILAND
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA


12


Tungsten
A.L.M.T. Corp.
JAPAN
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIETNAM
Tungsten
ATI Metalworking Products
UNITED STATES OF AMERICA
Tungsten
Chaozhou Xianglu Tungsten Industry Co., Ltd.
CHINA
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
China Molybdenum Co., Ltd.
CHINA
Tungsten
China National Non Ferrous
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tungsten
Cronimet Brasil Ltda
BRAZIL
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Tungsten
Fujian Xinlu Tungsten
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
GEM Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
Human Chun-Chang non-ferrous Smelting & Concentrating Co., Ltd.
CHINA
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
KGETS Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Masan High-Tech Materials
VIETNAM
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA


13



Tungsten
NPP Tyazhmetprom LLC
RUSSIAN FEDERATION
Tungsten
OOO “Technolom” 1
RUSSIAN FEDERATION
Tungsten
OOO “Technolom” 2
RUSSIAN FEDERATION
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
Smelter not listed
RUSSIAN FEDERATION
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
WBH
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Xiamen H.C.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA

14



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