Form SD TRIMAS CORP

May 26, 2022 5:30 PM EDT

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

FORM SD

SPECIALIZED DISCLOSURE REPORT

TriMas Corporation
(Exact name of registrant as specified in its charter)


Delaware
(State or other jurisdiction
of incorporation)
001-10716
(Commission
File Number)
38-2687639
(IRS Employer
Identification No.)

38505 Woodward Avenue, Suite 200 Bloomfield Hills, Michigan
(Address of principal
executive offices)

48304
(Zip Code)

Jodi Robin, General Counsel and Secretary, 248-631-5400
(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.
 ___
Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended December 31, 2021.









Section 1 – Conflict Minerals Disclosure

Item 1.01. Conflict Minerals Disclosure and Report.

Introduction
TriMas Corporation ("TriMas" or the "Company"), and its consolidated subsidiaries, designs, engineers and manufactures innovative products under leading brand names for customers in the consumer products, aerospace & defense and industrial markets. The Company is principally engaged in the following reportable segments with diverse products and market channels: Packaging, Aerospace and Specialty Products. TriMas is filing this Form SD ("Form SD") pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule") for the reporting period January 1, 2021 to December 31, 2021 (the "Reporting Period").

TriMas manufactures or contracts to manufacture "products" that may contain certain "conflict minerals" (as defined below) that are necessary to the functionality or production of such products. Form SD defines "conflict minerals" as: (i)(a) columbite-tantalite (or coltan, the metal ore from which tantalum is extracted), (b) cassiterite (the metal ore from which tin is extracted), (c) gold and (d) wolframite (the metal ore from which tungsten is extracted), or their derivatives; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (collectively, the "Covered Countries").

Conflict Minerals Disclosures
In accordance with the Rule and Form SD, TriMas has conducted a good faith reasonable country of origin inquiry ("RCOI") regarding the conflict minerals included in its products during the Reporting Period to determine whether any of such conflict minerals originated in the Covered Countries and/or whether any of such conflict minerals may be from recycled or scrap sources.

In accordance with the Rule, TriMas has filed this Form SD and the associated Conflict Minerals Report, each of which are posted to TriMas’ publicly available internet site at www.trimascorp.com. The content on any website referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.

Item 1.02. Exhibit.

A description of the RCOI and the measures TriMas took to exercise due diligence on the source and chain of custody of certain of its conflict minerals is provided in the Conflict Minerals Report attached hereto as Exhibit 1.01. The content on, or accessible through, any website referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.

Section 3 – Exhibits

Item 3.01. Exhibits.








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.



TRIMAS CORPORATION
   /s/ Scott Mell May 27, 2022
Name: Scott Mell
Date
Title: Chief Financial Officer



Exhibit 1.01

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

TriMas Corporation (TriMas or the Company) is filing this Conflict Minerals Report (CMR) for the reporting period January 1, 2021 to December 31, 2021 (the Reporting Period) as an exhibit to its Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). TriMas manufactures or contracts to manufacture "products" that may contain conflict minerals, as defined by the Rule, present in its supply chain that may have originated in the Democratic Republic of the Congo or an adjoining country (the Covered Countries) and may not be from recycled or scrap sources. Accordingly, TriMas is filing this CMR as an exhibit to Form SD to describe the due diligence measures taken to determine the source and chain of custody of the conflict minerals used in its products during the Reporting Period.

Reasonable Country of Origin Inquiry

In accordance with the Rule and Form SD, TriMas conducted a good faith reasonable country of origin inquiry (RCOI) regarding the conflict minerals included in its products during the Reporting Period to determine whether any of such conflict minerals originated in the Covered Countries and/or whether any of such conflict minerals may be from recycled or scrap sources.

To determine whether tin, tantalum, tungsten or gold (3TG) necessary to the functionality or production of supplier products originated in Covered Countries, TriMas retained ComplianceXL, a third-party service provider, to assist in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers and parts associated with the in-scope products to ComplianceXL for upload to the SustainHub (SH) platform provided by iPoint.

To collect data on the materials’ sources of origin procured by the supply chain, TriMas utilized the Conflict Minerals Reporting Template (CMRT) version 6.1 or higher to conduct a survey of all in-scope suppliers.

During the supplier survey, the Company contacted suppliers via the SH platform, enabling users to complete and track supplier communications, and allowing suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. SH also provides functionality that meets the Organization for Economic Cooperation and Development’s (OECD) Guidance process expectations by evaluating the quality of each supplier response. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.

Via SH and the ComplianceXL team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. ComplianceXL monitored and tracked all communications in SH for future reporting and transparency. TriMas directly contacted suppliers that were unresponsive to ComplianceXL’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to ComplianceXL.

The Company’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further



classification or risk assessment, as well as understand the due diligence efforts of tier 1 suppliers. The results of this data validation are shared with the suppliers to ensure they understand areas that require clarification or improvement.

All submitted forms are accepted and classified as valid or invalid. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct validation errors in their CMRT submission and direct engagement help through ComplianceXL. Since some suppliers may remain unresponsive to feedback, TriMas tracks program gaps to account for future improvement opportunities. TriMas also continued to perform further due diligence on the source and chain of custody of the minerals in question.

Due Diligence

Design of Due Diligence

TriMas’ due diligence process is based on OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements. The OECD Guidance applies to both upstream1 and downstream2 companies in the supply chain. As TriMas is a downstream company in the supply chain, TriMas’ tailored its due diligence practices accordingly. Due diligence measures undertaken by TriMas included those described below.

Due Diligence Performed

Establish Strong Company Management Systems

Adopt a Conflict Minerals Policy
TriMas adopted a Responsible Sourcing and Conflict Minerals Policy (Conflict Minerals Policy). This policy is available on the TriMas website at www.trimascorp.com. The content on any website referred to in this CMR is not incorporated by reference into this CMR unless expressly noted.

Assemble an Internal Team to Support Supply Chain Due Diligence
TriMas' senior management identified individuals representing multiple TriMas departments and business units to oversee and drive conflict minerals compliance. Together with ComplianceXL, TriMas’ General Counsel and Secretary worked with the Company’s business units to complete tasks associated with the supplier due diligence process. Individual leads within the business units further facilitated the diligence process to collect information regarding the presence and sourcing of conflict minerals in the products supplied to TriMas.
________________
1 Upstream companies refer to those between the mine and smelters or refiners (SOR). As such, the companies typically include miners, local traders, or exporters from the country of mineral origin, international concentrate traders, and SORs.
2 Downstream companies refer to those entities between the SOR and retailer. As such, the companies typically include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers, and retailers.





Establish a System of Controls and Transparency Over The Supply Chain
To provide better transparency within TriMas’ supply chain and to facilitate communication of policies and expectations, TriMas engaged ComplianceXL to complement internal management processes. The ComplianceXL and SH online system and processes are used to identify suppliers in TriMas’ supply chain and to collect, store, and review information on conflict minerals sourcing practices, track information on SORs, and flag risks based on SOR sourcing practices. This system is designed to allow collection and housing of data on supply chain circumstances, which can be updated to reflect changes within the supply chain, such as new customer-supplier relationships and new products.

TriMas mandated compliance in its supply chain with TriMas’ Conflict Minerals Policy through its contractual terms and conditions.

TriMas maintains an ethics hotline accessible at www.trimascorp.com through which a party, including TriMas employees and suppliers, may submit reports or concerns regarding compliance, including with respect to conflict minerals.

Supplier Engagement
TriMas has increased its supply chain transparency by identifying risks within its supply chain. TriMas is committed to conducting business in a socially responsible manner and partnering with suppliers who are similarly committed. TriMas’ supplier compliance process requires that suppliers comply with various contract provisions, legal requirements and industrial standards under local, regional and national laws and regulations of the countries in which the suppliers conduct business. Through this process, TriMas remains engaged with its supply base from a compliance perspective.

During this reporting period, we utilized the CMRT to collect conflict minerals declarations from our tier 1 suppliers. These declarations were uploaded into the SH web-based reporting platform. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements, and increase the rate of responses we have received from our suppliers to our survey requests. ComplianceXL followed-up with suppliers to ensure proper completion of the CMRT, and all communication with suppliers has been documented to reflect the degree of success of these efforts.

To complete the RCOI, TriMas’ in-scope tier 1 suppliers were requested to provide information regarding the presence and sourcing of conflict minerals used in the products supplied to TriMas. The program utilized the CMRT version 6.1 or higher to conduct a survey of all in-scope suppliers.
Suppliers were offered two options to submit the required information, either by uploading a completed CMRT or through direct submission to ComplianceXL.

During the supplier survey, suppliers were contacted via the SH platform, operated by ComplianceXL, enabling its users to complete and track supplier communications as well as allowing suppliers to upload completed CMRT forms directly to the platform for risk assessment and management. In their responses, suppliers specified whether the information provided was at the company level or the product level. Non-responsive suppliers were contacted a minimum of 15 times by ComplianceXL. For the 2021 reporting period, TriMas received responses from 794 or 67.2% of its 1182 surveyed suppliers. Of the 794 suppliers that provided a response, approximately 109 reported that their products contained 3TG necessary to the functionality or production of their products.





Automated data validation on all submitted CMRTs is included in the program. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. For the 2021 reporting period, TriMas had 27 invalid CMRTs.

As mentioned above, the CMRTs received allowed TriMas to collect and compile, via SH, all answers from the CMRT with respect to smelter information reflected in the CMRTs. With respect to smelter information reflected in the CMRTs, there were suppliers who did not provide smelter lists. Without having full smelter information for TriMas products from all suppliers in scope, TriMas is unable to determine whether there is sourcing from the Covered Countries. In connection with its evaluation of the CMRTs, TriMas and ComplianceXL undertook due diligence to validate supplier reports.

Information Cut-Off
The deadline for suppliers to submit RCOI information for the Reporting Period was May 20, 2022.    

Grievance Mechanism
We have established reporting mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Conflict Minerals Policy through the ethics hotline on our website at www.trimascorp.com

Records Maintenance
Under our Records Retention Policy, compliance records are maintained for 10 years.

Identify and Assess Risk in Our Supply Chain

We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. We believe many of our largest suppliers are suppliers to other SEC registrants that are subject to the Rule.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as DRC-conflict free by third-party sources such as Responsible Minerals Initiative (RMI) or the London Bullion Market Association (LBMA) Responsible Gold Programme, may pose a risk. Where a smelter is not identified as conflict free by such sources, we rate the risk as high, medium or low. This rating is based on various factors, including whether the smelter/refiner has been identified as a valid smelter/refiner and has an associated Smelter Identification Number (under the RMI, this is known as a CID), and the smelter’s geographic location, including proximity to the Covered Countries.

We calculate supplier risk based on the chance that a supplier provides 3TGs that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.

Additionally, each supplier is evaluated on the strength of its conflict minerals program (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of a supplier’s program are:

Do you have a policy in place that includes Covered Countries 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 review process include corrective action management?

The more positive the responses to these questions indicate a stronger conflict sourcing initiative.

As part of our risk management plan and to ensure suppliers understand our expectations, we have, through ComplianceXL, written training on conflict minerals and the CMRT. This includes instructions on completing the form and one-on-one email and phone discussions with supplier personnel.

In accordance with our Conflict Minerals Policy, if a supplier gives us reason to believe that it may be supplying us with 3TG from sources that may support conflict in a Covered Country, we encourage the supplier to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we may initiate steps to find replacement suppliers.

Once surveys were returned, ComplianceXL reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the RMI Responsible Minerals Assurance Process (RMAP). If an SOR was not validated by the RMAP, ComplianceXL attempted to contact the SOR to gather more information about its sourcing practices.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not certified Covered Country-Conflict Free may pose a risk to the supply chain. Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the OECD Guidance.

As part of our risk management plan under the OECD Guidance, when facilities with red flags are reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through ComplianceXL, submissions that include any red flag facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to TriMas, and escalating up to removal of these red flag smelters from their supply chain.

As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context.

Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG smelters and refiners in our supply chain represents an appropriate effort to determine the mines or locations of origin of the 3TGs in our supply chain. This was done by adopting methodology outlined by the RMI’s joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this industry joint effort, we made a reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict Free” lists of sourced metals.

Design and Implement a Strategy to Respond to Risks
As part of TriMas’ strategy to mitigate risk and to ensure suppliers understand our expectations, we have provided documented instructions through ComplianceXL. Responses to the reporting CMRT were reviewed with specific suppliers where clarification was needed. As described in our Conflict Minerals Policy, we intend to engage any of our



suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in Covered Countries to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.

Suppliers that may expose the Company to unacceptable risks, either due to unacceptable responses to our inquiries or a refusal to respond, may be evaluated by the Company.

Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
TriMas does not have a direct relationship with conflict minerals smelters or refiners and as a result, TriMas does not perform direct audits of these entities in its supply chain. TriMas relies on the efforts of the industry associations that administer independent third-party smelter and refinery audit programs and encourages suppliers with more direct relationships with smelters to participate in comparable due diligence validation activities.

ComplianceXL conducts outreach to all smelters and refineries that are not enrolled in the RMI’s RMAP on behalf of TriMas. The purpose of this outreach is to encourage participation in the RMAP and to inquire about the facility’s sourcing practices and infrastructure.

Report Annually on Supply Chain Due Diligence
TriMas’ Form SD and CMR are publicly available at www.trimascorp.com and meet the OECD recommendation to report annually on supply chain due diligence.





Due Diligence Results

For the 2021 reporting period, TriMas received responses from 794 or 67.2% of its 1182 surveyed suppliers. Of the 794 suppliers that provided a response, approximately 109 reported that their products contained 3TG necessary to the functionality or production of their products. Based on the RCOI and the due diligence measures described in this CMR, specifically that most CMRTs are at the company level and not the product level pertaining to TriMas products, TriMas was unable to determine if any of the specific SORs identified by suppliers are in its supply chain.

The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the SORs identified by our direct suppliers may contain SORs that processed conflict minerals that our direct suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the SORs were used to process the conflict minerals necessary to the functionality or production of our products during 2021. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin identified were the country of origin of conflict minerals in our products during 2021, and therefore we were also unable to determine the source and chain of custody of those conflict minerals. In addition, the third-party audits conducted by the RMI, the LBMA and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMI RMAP or the LBMA Responsible Gold Programme and, as a result, are not responsible for the quality of these audits or the audit findings.

In connection with our reasonable country of origin inquiry and due diligence, as applicable, our suppliers identified to us certain smelters and refiners as potentially having processed the necessary 3TG contained in our products in 2021. For all responses that indicated a smelter, ComplianceXL compared the facilities listed to the list of smelters maintained by the RMI. As of May 23, 2022, we have validated 275 SORs. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any SORs that we have not been able to validate. If a supplier indicated that the facility was certified as "Conflict-Free," ComplianceXL confirmed that the name was listed by RMI as a certified smelter.

Steps to Improve Due Diligence and Mitigate Risk

TriMas will work to continuously improve its supply chain due diligence efforts through the following measures:

a)
Continue supply chain due diligence efforts and engagement with suppliers to identify sources of conflict minerals;
b)
Continue to clearly communicate expectations with regard to supplier compliance, transparency and sourcing;
c)
Continue to engage with suppliers that provided incomplete or uncertain smelter information or did not respond to our survey request;
d)
Continue to compare RCOI results to information collected via independent conflict free smelter validation programs; and
e)
Contact smelters identified as a result of the RCOI process and request their participation in obtaining a "conflict free" designation from an industry program.




Smelters and Refiners

Appendix A includes an aggregated list of smelters and refiners that our suppliers identified to us as potentially having processed the necessary 3TG contained in our products in 2021 based on information provided through the CMRT data collection process. As mentioned previously, it is understood that many supplier responses may provide more data than can be directly linked to products sold by TriMas, therefore, Appendix A may contain more smelters and refiners than those that the Company’s products are being sourced from.

Smelter and Refiner Risk Evaluation

Understanding the risks associated with the smelters and refiners potentially providing material into TriMas’ supply chain is an important part of the due diligence process.

The following risk categories are used for smelter evaluation and risk determination:
Geo-Risk
Did the mineral originate from or has been transported through a Covered Country?
Audit Status
Has the refiner’s due diligence practices been audited against a standard in conformance with the OECD    Guidance?
ComplianceXL relies on the RMI audit standard, including cross-recognition of the LBMA Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance.
Sourcing Risk
Has evidence of any other red flag that is supported by credible sources been identified?

    





 Forward-Looking Statements

This report may contain forward-looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934, including statements related to our compliance efforts. These forward-looking statements can be identified by the use of forward-looking words, such as “may,” “could,” “should,” “estimate,” “project,” “forecast,” “intend,” “expect,” “anticipate,” “believe,” “target,” “plan” or other comparable words, or by discussions of strategy that may involve risks and uncertainties.

These forward-looking statements are subject to various risks, uncertainties, and assumptions, including, among other matters, our customers’ requirements to use certain suppliers, our suppliers’ responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our conflict minerals program and our ability to identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed in or implied by the forward-looking statements. For a more complete discussion of these and other risk factors, see our other filings with the Securities and Exchange Commission (SEC), including our Annual Report on Form 10-K for the year ended December 31, 2021. We caution you not to place undue reliance on these forward-looking statements, which speak only as of the date of this report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.

The cautionary statements set forth above should be considered in connection with any subsequent written or oral forward-looking statements that we or persons acting on our behalf may issue. We caution readers not to place undue reliance on the statements, which speak only as of the date of this report. We do not undertake any obligation to review or confirm analysts' expectations or estimates or to release publicly any revisions to any forward-looking statement to reflect events or circumstances after the date of this report or to reflect the occurrence of unanticipated events, except as required by law.














APPENDIX A



MetalStandard Smelter NameSmelter ID
Smelter Country
RMI Audit Status
Gold8853 S.p.A.CID002763ITALYConformant
GoldAbington Reldan Metals, LLCCID002708UNITED STATES OF AMERICANon Conformant
GoldAdvanced Chemical CompanyCID000015UNITED STATES OF AMERICAConformant
GoldAida Chemical Industries Co., Ltd.CID000019JAPANConformant
GoldAl Etihad Gold Refinery DMCCCID002560UNITED ARAB EMIRATESConformant
GoldAlexy MetalsCID003500UNITED STATES OF AMERICAActive
GoldAllgemeine Gold-und Silberscheideanstalt A.G.CID000035GERMANYConformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)CID000041UZBEKISTANConformant
GoldAngloGold Ashanti Corrego do Sitio MineracaoCID000058BRAZILConformant
GoldArgor-Heraeus S.A.CID000077SWITZERLANDConformant
GoldAsahi Pretec Corp.CID000082JAPANConformant
GoldAsahi Refining Canada Ltd.CID000924CANADAConformant
GoldAsahi Refining USA Inc.CID000920UNITED STATES OF AMERICAConformant
GoldAsaka Riken Co., Ltd.CID000090JAPANConformant
GoldAU Traders and RefinersCID002850SOUTH AFRICANon Conformant
GoldAugmont Enterprises Private LimitedCID003461INDIAActive
GoldAurubis AGCID000113GERMANYConformant
GoldBangalore RefineryCID002863INDIAConformant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)CID000128PHILIPPINESConformant
GoldBoliden ABCID000157SWEDENConformant
GoldC. Hafner GmbH + Co. KGCID000176GERMANYConformant
GoldC.I Metales Procesados Industriales SASCID003421COLOMBIAActive
GoldCCR Refinery - Glencore Canada CorporationCID000185CANADAConformant
GoldCendres + Metaux S.A.CID000189SWITZERLANDConformant
GoldChimet S.p.A.CID000233ITALYConformant
GoldChugai MiningCID000264JAPANConformant
GoldDODUCO Contacts and Refining GmbHCID000362GERMANYConformant
GoldDowaCID000401JAPANConformant
GoldDSC (Do Sung Corporation)CID000359KOREA, REPUBLIC OFConformant
GoldEco-System Recycling Co., Ltd. East PlantCID000425JAPANConformant
GoldEco-System Recycling Co., Ltd. North PlantCID003424JAPANConformant
GoldEco-System Recycling Co., Ltd. West PlantCID003425JAPANConformant
GoldEmirates Gold DMCCCID002561UNITED ARAB EMIRATESConformant



GoldGCC Gujrat Gold Centre Pvt. Ltd.CID002852INDIAActive
GoldGeib Refining CorporationCID002459UNITED STATES OF AMERICAConformant
GoldGold Refinery of Zijin Mining Group Co., Ltd.CID002243CHINAConformant
GoldHeimerle + Meule GmbHCID000694GERMANYConformant
GoldHeraeus Germany GmbH Co. KGCID000711GERMANYConformant
GoldHeraeus Metals Hong Kong Ltd.CID000707CHINAConformant
GoldIndustrial Refining CompanyCID002587BELGIUMNon Conformant
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CID000801CHINAConformant
GoldIshifuku Metal Industry Co., Ltd.CID000807JAPANConformant
GoldIstanbul Gold RefineryCID000814TURKEYConformant
GoldItalpreziosiCID002765ITALYConformant
GoldJapan MintCID000823JAPANConformant
GoldJiangxi Copper Co., Ltd.CID000855CHINAConformant
GoldJSC Novosibirsk RefineryCID000493RUSSIAN FEDERATIONConformant
GoldJSC UralelectromedCID000929RUSSIAN FEDERATIONConformant
GoldJX Nippon Mining & Metals Co., Ltd.CID000937JAPANConformant
GoldKazzincCID000957KAZAKHSTANConformant
GoldKennecott Utah Copper LLCCID000969UNITED STATES OF AMERICAConformant
GoldKGHM Polska Miedz Spolka AkcyjnaCID002511POLANDConformant
GoldKojima Chemicals Co., Ltd.CID000981JAPANConformant
GoldKorea Zinc Co., Ltd.CID002605KOREA, REPUBLIC OFConformant
GoldKyrgyzaltyn JSCCID001029KYRGYZSTANNon Conformant
GoldL'Orfebre S.A.CID002762ANDORRAConformant
GoldLS-NIKKO Copper Inc.CID001078KOREA, REPUBLIC OFConformant
GoldLT Metal Ltd.CID000689KOREA, REPUBLIC OFConformant
GoldMarsam MetalsCID002606BRAZILConformant
GoldMaterionCID001113UNITED STATES OF AMERICAConformant
GoldMatsuda Sangyo Co., Ltd.CID001119JAPANConformant
GoldMetal Concentrators SA (Pty) Ltd.CID003575SOUTH AFRICAConformant
GoldMetalor Technologies (Hong Kong) Ltd.CID001149CHINAConformant
GoldMetalor Technologies (Singapore) Pte., Ltd.CID001152SINGAPOREConformant
GoldMetalor Technologies (Suzhou) Ltd.CID001147CHINAConformant
GoldMetalor Technologies S.A.CID001153SWITZERLANDConformant
GoldMetalor USA Refining CorporationCID001157UNITED STATES OF AMERICAConformant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.CID001161MEXICOConformant
GoldMitsubishi Materials CorporationCID001188JAPANConformant



GoldMitsui Mining and Smelting Co., Ltd.CID001193JAPANConformant
GoldMMTC-PAMP India Pvt., Ltd.CID002509INDIAConformant
GoldModeltech Sdn BhdCID002857MALAYSIANon Conformant
GoldMoscow Special Alloys Processing PlantCID001204RUSSIAN FEDERATIONConformant
GoldNadir Metal Rafineri San. Ve Tic. A.S.CID001220TURKEYConformant
GoldNavoi Mining and Metallurgical CombinatCID001236UZBEKISTANConformant
GoldNH Recytech CompanyCID003189KOREA, REPUBLIC OFConformant
GoldNihon Material Co., Ltd.CID001259JAPANConformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHCID002779AUSTRIAConformant
GoldOhura Precious Metal Industry Co., Ltd.CID001325JAPANConformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)CID001326RUSSIAN FEDERATIONConformant
GoldPAMP S.A.CID001352SWITZERLANDConformant
GoldPlanta Recuperadora de
Metales SpA
CID002919CHILEConformant
GoldPrioksky Plant of Non-Ferrous MetalsCID001386RUSSIAN FEDERATIONConformant
GoldPT Aneka Tambang (Persero) TbkCID001397INDONESIAConformant
GoldPX Precinox S.A.CID001498SWITZERLANDConformant
GoldRand Refinery (Pty) Ltd.CID001512SOUTH AFRICAConformant
GoldREMONDIS PMR B.V.CID002582NETHERLANDSConformant
GoldRoyal Canadian MintCID001534CANADAConformant
GoldSAAMPCID002761FRANCEConformant
GoldSafimet S.p.ACID002973ITALYConformant
GoldSAFINA A.S.CID002290CZECHIAConformant
GoldSamduck Precious MetalsCID001555KOREA, REPUBLIC OFConformant
GoldSancus ZFS (L’Orfebre, SA)CID003529COLOMBIAActive
GoldSAXONIA Edelmetalle GmbHCID002777GERMANYConformant
GoldSEMPSA Joyeria Plateria S.A.CID001585SPAINConformant
GoldShandong Gold Smelting Co., Ltd.CID001916CHINAConformant
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CID001622CHINAConformant
GoldSichuan Tianze Precious Metals Co., Ltd.CID001736CHINAConformant
GoldSingway Technology Co., Ltd.CID002516TAIWAN, PROVINCE OF CHINAConformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsCID001756RUSSIAN FEDERATIONConformant
GoldSolar Applied Materials Technology Corp.CID001761TAIWAN, PROVINCE OF CHINAConformant
GoldSumitomo Metal Mining Co., Ltd.CID001798JAPANConformant
GoldSungEel HiMetal Co., Ltd.CID002918KOREA, REPUBLIC OFConformant
GoldT.C.A S.p.ACID002580ITALYConformant



GoldTanaka Kikinzoku Kogyo K.K.CID001875JAPANConformant
GoldTokuriki Honten Co., Ltd.CID001938JAPANConformant
GoldTOO Tau-Ken-AltynCID002615KAZAKHSTANConformant
GoldTorecomCID001955KOREA, REPUBLIC OFConformant
GoldUmicore Precious Metals ThailandCID002314THAILANDConformant
GoldUmicore S.A. Business Unit Precious Metals RefiningCID001980BELGIUMConformant
GoldUnited Precious Metal Refining, Inc.CID001993UNITED STATES OF AMERICAConformant
GoldValcambi S.A.CID002003SWITZERLANDConformant
GoldWEEEREFININGCID003615FRANCEActive
GoldWestern Australian Mint (T/a The Perth Mint)CID002030AUSTRALIAConformant
GoldWIELAND Edelmetalle GmbHCID002778GERMANYConformant
GoldYamakin Co., Ltd.CID002100JAPANConformant
GoldYokohama Metal Co., Ltd.CID002129JAPANConformant
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCID002224CHINAConformant
TantalumAsaka Riken Co., Ltd.CID000092JAPANConformant
TantalumChangsha South Tantalum Niobium Co., Ltd.CID000211CHINAConformant
TantalumD Block Metals, LLCCID002504UNITED STATES OF AMERICAConformant
TantalumExotech Inc.CID000456UNITED STATES OF AMERICAConformant
TantalumF&X Electro-Materials Ltd.CID000460CHINAConformant
TantalumFIR Metals & Resource Ltd.CID002505CHINAConformant
TantalumGlobal Advanced Metals AizuCID002558JAPANConformant
TantalumGlobal Advanced Metals BoyertownCID002557UNITED STATES OF AMERICAConformant
TantalumGuangdong Rising Rare Metals-EO Materials Ltd.CID000291CHINAConformant
TantalumH.C. Starck Hermsdorf GmbHCID002547GERMANYConformant
TantalumH.C. Starck Inc.CID002548UNITED STATES OF AMERICAConformant
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CID002492CHINAConformant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CID002512CHINAConformant
TantalumJiangxi Tuohong New Raw MaterialCID002842CHINAConformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CID000914CHINAConformant
TantalumJiujiang Tanbre Co., Ltd.CID000917CHINAConformant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CID002506CHINAConformant
TantalumKEMET de MexicoCID002539MEXICOConformant
TantalumLSM Brasil S.A.CID001076BRAZILConformant
TantalumMeta MaterialsCID002847NORTH MACEDONIA, REPUBLIC OFConformant
TantalumMetallurgical Products India Pvt., Ltd.CID001163INDIAConformant
TantalumMineracao Taboca S.A.CID001175BRAZILConformant
TantalumMitsui Mining and Smelting Co., Ltd.CID001192JAPANConformant



TantalumNingxia Orient Tantalum Industry Co., Ltd.CID001277CHINAConformant
TantalumNPM Silmet ASCID001200ESTONIAConformant
TantalumQuantumCleanCID001508UNITED STATES OF AMERICAConformant
TantalumResind Industria e Comercio Ltda.CID002707BRAZILConformant
TantalumSolikamsk Magnesium Works OAOCID001769RUSSIAN FEDERATIONConformant
TantalumTaki Chemical Co., Ltd.CID001869JAPANConformant
TantalumTANIOBIS Co., Ltd.CID002544THAILANDConformant
TantalumTANIOBIS GmbHCID002545GERMANYConformant
TantalumTANIOBIS Japan Co., Ltd.CID002549JAPANConformant
TantalumTANIOBIS Smelting GmbH & Co. KGCID002550GERMANYConformant
TantalumTelex MetalsCID001891UNITED STATES OF AMERICAConformant
TantalumUlba Metallurgical Plant JSCCID001969KAZAKHSTANConformant
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDCID000616CHINAConformant
TantalumXinXing HaoRong Electronic Material Co., Ltd.CID002508CHINAConformant
TantalumYancheng Jinye New Material Technology Co., Ltd.CID003583CHINAConformant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CID001522CHINAConformant
TinAlphaCID000292UNITED STATES OF AMERICAConformant
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CID000228CHINAConformant
TinChifeng Dajingzi Tin Industry Co., Ltd.CID003190CHINAConformant
TinChina Tin Group Co., Ltd.CID001070CHINAConformant
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaCID003486BRAZILActive
TinCRM SynergiesCID003524SPAINConformant
TinCV Venus Inti PerkasaCID002455INDONESIAActive
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CID003356CHINANon Conformant
TinDowaCID000402JAPANConformant
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyCID002572VIET NAMNon Conformant
TinEM VintoCID000438BOLIVIA (PLURINATIONAL STATE OF)Conformant
TinEstanho de Rondonia S.A.CID000448BRAZILActive
TinFabrica Auricchio Industria e Comercio Ltda.CID003582BRAZILConformant
TinFenix MetalsCID000468POLANDConformant
TinGejiu Kai Meng Industry and Trade LLCCID000942CHINANon Conformant
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CID000538CHINAConformant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CID001908CHINAConformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.CID000555CHINAConformant



TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CID003116CHINAConformant
TinHuiChang Hill Tin Industry Co., Ltd.CID002844CHINAConformant
TinJiangxi New Nanshan Technology Ltd.CID001231CHINAConformant
TinLuna Smelter, Ltd.CID003387RWANDAConformant
TinMa'anshan Weitai Tin Co., Ltd.CID003379CHINAConformant
TinMagnu's Minerais Metais e Ligas Ltda.CID002468BRAZILConformant
TinMalaysia Smelting Corporation (MSC)CID001105MALAYSIAConformant
TinMelt Metais e Ligas S.A.CID002500BRAZILConformant
TinMetallic Resources, Inc.CID001142UNITED STATES OF AMERICAConformant
TinMetallo Belgium N.V.CID002773BELGIUMConformant
TinMetallo Spain S.L.U.CID002774SPAINConformant
TinMineracao Taboca S.A.CID001173BRAZILConformant
TinMinsurCID001182PERUConformant
TinMitsubishi Materials CorporationCID001191JAPANConformant
TinModeltech Sdn BhdCID002858MALAYSIANon Conformant
TinNovosibirsk Processing Plant Ltd.CID001305RUSSIAN FEDERATIONActive
TinO.M. Manufacturing (Thailand) Co., Ltd.CID001314THAILANDConformant
TinO.M. Manufacturing Philippines, Inc.CID002517PHILIPPINESConformant
TinOperaciones Metalurgicas S.A.CID001337BOLIVIA (PLURINATIONAL STATE OF)Conformant
TinPrecious Minerals and Smelting LimitedCID003409INDIANon Conformant
TinPT Artha Cipta LanggengCID001399INDONESIAConformant
TinPT ATD Makmur Mandiri JayaCID002503INDONESIAConformant
TinPT Babel Inti PerkasaCID001402INDONESIAConformant
TinPT Babel Surya Alam LestariCID001406INDONESIAConformant
TinPT Bangka SerumpunCID003205INDONESIAConformant
TinPT Bukit TimahCID001428INDONESIAActive
TinPT Cipta Persada MuliaCID002696INDONESIAConformant
TinPT Masbro Alam StaniaCID003380INDONESIAActive
TinPT Menara Cipta MuliaCID002835INDONESIAConformant
TinPT Mitra Stania PrimaCID001453INDONESIAConformant
TinPT Mitra Sukses GlobalindoCID003449INDONESIAActive
TinPT Prima Timah UtamaCID001458INDONESIAConformant
TinPT Rajawali Rimba PerkasaCID003381INDONESIAConformant
TinPT Rajehan AriqCID002593INDONESIAConformant
TinPT Refined Bangka TinCID001460INDONESIAConformant
TinPT Sariwiguna BinasentosaCID001463INDONESIAConformant
TinPT Stanindo Inti PerkasaCID001468INDONESIAConformant
TinPT Sukses Inti MakmurCID002816INDONESIAActive
TinPT Timah NusantaraCID001486INDONESIAActive
TinPT Timah Tbk KundurCID001477INDONESIAConformant
TinPT Timah Tbk MentokCID001482INDONESIAConformant



TinPT Tinindo Inter NusaCID001490INDONESIAConformant
TinResind Industria e Comercio Ltda.CID002706BRAZILConformant
TinRui Da HungCID001539TAIWAN, PROVINCE OF CHINAConformant
TinSoft Metais Ltda.CID001758BRAZILConformant
TinSuper LigasCID002756BRAZILActive
TinThai Nguyen Mining and Metallurgy Co., Ltd.CID002834VIET NAMConformant
TinThaisarcoCID001898THAILANDConformant
TinTin Technology & RefiningCID003325UNITED STATES OF AMERICAConformant
TinWhite Solder Metalurgia e Mineracao Ltda.CID002036BRAZILConformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CID002158CHINAConformant
TinYunnan Tin Company LimitedCID002180CHINAActive
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CID003397CHINANon Conformant
TungstenA.L.M.T. Corp.CID000004JAPANConformant
TungstenACL Metais EireliCID002833BRAZILConformant
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.CID003427BRAZILActive
TungstenAsia Tungsten Products Vietnam Ltd.CID002502VIET NAMConformant
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CID002513CHINAConformant
TungstenChina Molybdenum Tungsten Co., Ltd.CID002641CHINAConformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CID000258CHINAConformant
TungstenCronimet Brasil LtdaCID003468BRAZILConformant
TungstenFujian Ganmin RareMetal Co., Ltd.CID003401CHINAConformant
TungstenFujian Xinlu TungstenCID003609CHINAConformant
TungstenGanzhou Haichuang Tungsten Co., Ltd.CID002645CHINAConformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CID000875CHINAConformant
TungstenGanzhou Jiangwu
Ferrotungsten Co., Ltd.
CID002315CHINAConformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.CID002494CHINAConformant
TungstenGEM Co., Ltd.CID003417CHINAActive
TungstenGlobal Tungsten & Powders Corp.CID000568UNITED STATES OF AMERICAConformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.CID000218CHINAConformant
TungstenH.C. Starck Tungsten GmbHCID002541GERMANYConformant
TungstenHunan Chenzhou Mining Co., Ltd.CID000766CHINAConformant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CID000769CHINAConformant
TungstenHydrometallurg, JSCCID002649RUSSIAN FEDERATIONConformant
TungstenJapan New Metals Co., Ltd.CID000825JAPANConformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CID002551CHINAConformant



TungstenJiangxi Gan Bei Tungsten Co., Ltd.CID002321CHINAConformant
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CID002318CHINAConformant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CID002317CHINAConformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CID002316CHINAConformant
TungstenJSC "Kirovgrad Hard Alloys Plant"CID003408RUSSIAN FEDERATIONConformant
TungstenKennametal FallonCID000966UNITED STATES OF AMERICAConformant
TungstenKennametal HuntsvilleCID000105UNITED STATES OF AMERICAConformant
TungstenKGETS Co., Ltd.CID003388KOREA, REPUBLIC OFConformant
TungstenLianyou Metals Co., Ltd.CID003407TAIWAN, PROVINCE OF CHINAConformant
TungstenMalipo Haiyu Tungsten Co., Ltd.CID002319CHINAConformant
TungstenMasan High-Tech MaterialsCID002543VIET NAMConformant
TungstenMoliren Ltd.CID002845RUSSIAN FEDERATIONConformant
TungstenNiagara Refining LLCCID002589UNITED STATES OF AMERICAConformant
TungstenNPP Tyazhmetprom LLCCID003416RUSSIAN FEDERATIONActive
TungstenOOO “Technolom” 1CID003614RUSSIAN FEDERATIONActive
TungstenOOO “Technolom” 2CID003612RUSSIAN FEDERATIONActive
TungstenPhilippine Chuangxin Industrial Co., Inc.CID002827PHILIPPINESConformant
TungstenTANIOBIS Smelting GmbH & Co. KGCID002542GERMANYConformant
TungstenUnecha Refractory metals plantCID002724RUSSIAN FEDERATIONConformant
TungstenWolfram Bergbau und Hutten AGCID002044AUSTRIAConformant
TungstenWoltech Korea Co., Ltd.CID002843KOREA, REPUBLIC OFConformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.CID002320CHINAConformant
TungstenXiamen Tungsten Co., Ltd.CID002082CHINAConformant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CID002830CHINAConformant



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