Form SD BRUKER CORP
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
Specialized Disclosure Report
BRUKER CORPORATION
(Exact name of registrant as specified in its charter)
| DELAWARE | 000-30833 | 04-3110160 | ||
| (State or Other Jurisdiction of Incorporation) |
(Commission File Number) |
(IRS Employer Identification Number) |
40 Manning Road, Billerica, MA 01821
(Address of principal executive offices) (Zip Code)
Gerald N. Herman
(978) 663-3660
(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 January 1 to December 31, 2020. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Pursuant to Rule 13p-1 (“Rule 13p-1”) promulgated under the Securities Exchange Act of 1934, as amended, Bruker Corporation (the “Company”) has filed this Specialized Disclosure Report (“Form SD”) for the reporting period January 1, 2020 to December 31, 2020.
A description of the measures the Company undertook to exercise due diligence on the source and chain of custody of conflict minerals contained in its Products is provided in the Conflict Minerals Report attached hereto as Exhibit 1.01. A copy of the Company’s Conflict Minerals Policy is publicly available at www.bruker.com.
Item 1.02 Exhibits
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit 1.01 — Conflict Minerals Report of Bruker Corporation
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| Bruker Corporation
| ||||||
| By: | /s/ GERALD N. HERMAN |
Date: June 1, 2021 | ||||
| Gerald N. Herman Chief Financial Officer and Executive Vice President (Principal Financial Officer and Principal Accounting Officer) |
||||||
Exhibit Index
| Exhibit No. |
Description | |
| 1.01 | Conflict Minerals Report of Bruker Corporation. | |
Exhibit 1.01
Bruker Corporation
Conflict Minerals Report
For the Reporting Period from January 1, 2020 to December 31, 2020
Introduction
This Conflict Minerals Report (“Report”) of Bruker Corporation and its consolidated subsidiaries for the reporting period from January 1, 2020 to December 31, 2020 (“Reporting Period”) has been prepared pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information by a company that manufactures, or contracts to manufacture, products that contain minerals specified in the Rule as “conflict minerals” that are necessary to the functionality or production of those products. For purposes of the Rule, “conflict minerals” include gold, columbite-tantalite (coltan), cassiterite, and wolframite and their derivatives, which are limited to tantalum, tin and tungsten. During the Reporting Period, we manufactured, or contracted to manufacture, certain products described below for which conflict minerals are necessary to their functionality or production.
We have adopted a Conflict Minerals Policy, which is publicly available at www.bruker.com under “About” in “Investor Relations/Corporate Governance/Governance Documents.” This Report describes our due diligence measures on the source and chain of custody of conflict minerals necessary to the products we manufactured, or contracted to manufacture during the Reporting Period, our efforts to determine the mine or location of origin of the necessary conflict minerals, and, to the extent reasonably known to us, the facilities used to process the conflict minerals.
Forward-Looking Statements
Forward-looking statements, within the meaning of Section 21E of the Securities Exchange Act of 1934, as amended, are made throughout this Report. Any statements contained herein that are not statements of historical fact may be deemed to be forward-looking statements. Without limiting the foregoing, the words “believes,” “anticipates,” “plans,” “expects,” “seeks,” “estimates,” and similar expressions are intended to identify forward-looking statements. While the Company may elect to update forward-looking statements in the future, it specifically disclaims any obligation to do so, even if the Company’s estimates change and readers should not rely on those forward-looking statements as representing the Company’s views as of any date subsequent to the date of the filing of this Report. A number of important factors could cause the results of the Company to differ materially from those indicated by such forward-looking statements, including those detailed under the heading “Future Due Diligence Considerations” in this Report.
Products Covered by this Report
Bruker Corporation, together with its consolidated subsidiaries, develops, manufactures and distributes high-performance scientific instruments and high-value analytical and diagnostic solutions that enable its customers to explore life and materials at microscopic, molecular and cellular levels. Many of the Company’s products are used to detect, measure and visualize structural characteristics of chemical, biological and industrial material samples. The Company’s products address the rapidly evolving needs of a diverse array of customers in life science research, pharmaceuticals, biotechnology, applied markets, cell biology, clinical research, microbiology, in-vitro diagnostics, nanotechnology and materials science research.
These products, which we collectively refer to in this Report as the “Products,” include the following: magnetic resonance systems; mass spectrometry and ion mobility spectrometry, infrared and Raman molecular spectroscopy, radiological/nuclear detectors for Chemical, Biological, Radiological, Nuclear, and Explosive (CBRNE) detection, advanced X-ray instruments; atomic force microscopy instruments, advanced fluorescence optical microscopy instruments, analytical tools for electron microscopes and X-ray metrology; defect–detection equipment; handheld portable and mobile X-ray fluorescence spectrometry, spark optical emission spectroscopy systems; and metallic low temperature superconductors.
Reasonable Country of Origin Inquiry
We conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the conflict minerals necessary to our Products’ functionality or production. As the initial step in our RCOI process, we reviewed parts and materials used in the manufacturing of our products to identify those that may include conflict minerals. Those parts and materials identified that may include conflict minerals necessary to the functionality or production of the relevant product were then linked to the direct supplier, or suppliers, from which we purchased the applicable parts or materials. Our RCOI was reasonably designed to determine whether such conflict minerals originated in the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, or Zambia (collectively, the “Covered Countries”) or came from scrap or recycled sources.
Our supply chain with respect to the Products is complex, and we do not purchase conflict minerals directly from mines, smelters or refiners. We purchase parts and materials directly, or contract with others to manufacture parts, from a large number of suppliers. In most cases, there are multiple layers of third parties in the supply chain between us and the ultimate upstream source of the conflict minerals. Due to the breadth and depth of our supply chain, we focused on engagement with direct suppliers that accounted for approximately 80% of our purchases of parts and materials where conflict minerals may be included. We requested our direct suppliers to provide information regarding the source and chain of custody of conflict minerals included in the Products, including smelter and country of origin information. To provide this information, our direct suppliers inquired with their suppliers to attempt to identify the ultimate source and country of origin of the conflict minerals included in the Products. We received responses from approximately 75% of those direct suppliers from whom we requested information. The percentage of suppliers that completed the requested survey, as compared to some other form of response, was consistent with the 2019 reporting year.
Given the complexity of this multi-tiered process, many of our direct suppliers have been unable to identify, verify, and report to us the origin of conflict minerals contained in the Products in-scope for purposes of our inquiry. Based on our RCOI, we do not have sufficient information to conclusively determine all the countries of origin of the Conflict Minerals in the Products. However, based on the information provided by our suppliers, we had reason to believe that some of the Conflict Minerals contained in the Products may have originated from Covered Countries and may not be from recycled or scrap sources and, accordingly, we performed due diligence measures as described below.
Due Diligence Design and Process
Our due diligence process was designed to materially conform with the Organization for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (“OECD Framework”), an internationally recognized due diligence framework.
Our due diligence process applicable to the Reporting Period included the following:
Step 1 – Establish strong company management systems
| • | We have a Conflict Minerals Policy, which is available on the Company’s website at www.bruker.com under “About” in “Investor Relations/Corporate Governance/Governance Documents.” |
| • | We have an internal team sponsored by our senior management. The internal team includes representation from corporate finance and the Company’s operating divisions on a cross-functional basis, including purchasing, manufacturing, quality management and research and development. The internal team’s responsibilities include developing and executing the Company’s due diligence process. |
| • | We maintained a central electronic repository to store relevant documentation created or obtained during the due diligence process. |
| • | We used an internal process document summarizing our RCOI and due diligence processes as a guide to help in completing our procedures. |
| • | We included a step-by-step process for employees and provided a point of contact for questions or assistance during our process. |
Step 2 – Identify and assess risks in the supply chain
| • | We conducted a survey of suppliers determined to be in-scope for RCOI during the Reporting Period, using the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”). |
| • | We reviewed the surveys, and any other documentation, received from suppliers to validate if parts or materials provided to us include conflict minerals, and if so, to attempt to identify the smelter and country of origin. We reviewed responses for completeness and reliability based on a defined set of red flags criteria developed to help facilitate the review. |
| • | We compared the smelter information provided by suppliers against the standard smelter list in the CMRT. For those smelters included in the CMRT, we reviewed whether such smelters were listed as Responsible Minerals Assurance Process (“RMAP”) Conformant or Active. |
Step 3 – Design and implement a strategy to respond to identified risks
| • | We used escalation procedures in an effort to obtain responses from all suppliers to which a survey was sent. |
| • | We classified red flags identified into categories based on the process document noted above, with follow-up procedures performed based on the red flag category. The follow-up procedures included sending a communication to the supplier to either request additional information or validate certain information provided, or perform additional internal review procedures. |
| • | We held periodic status updates with the internal team to discuss survey response results. |
| • | We briefed senior management on the status of our compliance obligations and due diligence efforts on a periodic basis. |
Step 4 – Carry out independent third-party audit of smelter/refiner’s due diligence practices
| • | We do not have a direct relationship with the smelters and refiners used to process the conflict minerals necessary to the Products and do not perform audits of those smelters and refiners. We rely on industry efforts, such as the RMI, to influence smelters and refineries to become certified as part of RMAP. |
| • | The RMAP independently audits the source, including mines of origin and chain of custody, of the conflict minerals used by smelters and refiners that agree to participate in the RMAP. The smelters and refiners that are found to be RMAP Conformant are those for which the independent audit has verified that the smelter’s or refiner’s conflict minerals originated from conflict free mines. |
Step 5 – Report annually on supply chain due diligence
| • | We have filed publicly a Form SD, which includes, as needed, a Conflict Minerals Report on an annual basis. This Report is available on the Company’s website at www.bruker.com under “About” in “Investor Relations/ Financial Info / SEC Filings.” |
Due Diligence Results
We received responses from approximately 75% of those direct suppliers from whom we requested information. The responses identified potential smelters around the world from which our direct suppliers directly or indirectly source conflict minerals. In the majority of cases, the responses from direct suppliers noted that not all smelters had been identified and did not completely list all the smelters used in their supply chain. In addition, most survey responses were provided on a company-wide basis and did not differentiate as to parts and materials sold to us. Also, we do not believe that all of the smelter facilities included in suppliers’ responses contributed during the Reporting Period to the manufacture our Products. The potential over-reporting of smelter facilities is a function of such Products containing components that are several steps removed from the facilities, as well as the lack of specificity, in certain cases, with respect to the information that respondents provide to us or to our direct suppliers.
Of the smelters provided in the responses that potentially relate to the manufacture of our Products, 337 were included in the standard smelter listing with the CRMT. As of June 1, 2021, 242 of the 337 smelters, or 72%, were verified as RMAP Conformant according to information published by RMI, with an additional 20 verified as an Active smelter. See Exhibit A for a listing of the standard smelters provided from responses received, including smelters verified as RMAP Compliant or Active as of June 1, 2021. We have determined that seeking this information regarding smelters in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the conflict minerals in our supply chain. To date, we only have partial information and we are working to validate the remaining smelter information to accurately determine the mine and location of origin of the conflict minerals contained in our Products.
Future Due Diligence Considerations
We intend to incorporate the following measures, among others, to further develop our due diligence program and to mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the Covered Countries. Development of the due diligence program is expected to include:
| • | Re-examining our scoping approach to ensure we have surveyed a significant amount of our supplier spend where conflict minerals may be included in our Products. |
| • | Continuing to engage with our suppliers to increase the survey response rate and to improve the accuracy and completeness of the information provided to us on the survey responses. |
| • | Encouraging our suppliers to implement responsible sourcing practices and obtain their products from smelters and refiners recognized as Conformant (as determined by RMI). |
Exhibit A – Smelter Listing (1)
| Mineral |
Smelter |
Facility Location | ||
| 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 | Aida Chemical Industries Co., Ltd.* | Japan | ||
| Gold | Al Etihad Gold Refinery DMCC* | United Arab Emirates | ||
| Gold | Alexy Metals** | United States of America | ||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* | Germany | ||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC)* | Uzbekistan | ||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao* | Brazil | ||
| Gold | Argor-Heraeus S.A.* | Switzerland | ||
| Gold | Asahi Pretec Corp.* | Japan | ||
| Gold | Asahi Refining Canada Ltd.* | Canada | ||
| Gold | Asahi Refining USA Inc.* | United States of America | ||
| Gold | Asaka Riken Co., Ltd.* | Japan | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | ||
| Gold | AU Traders and Refiners* | South Africa | ||
| Gold | Augmont Enterprises Private Limited** | India | ||
| Gold | Aurubis AG* | Germany | ||
| Gold | Bangalore Refinery* | 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 + Metaux S.A.* | Switzerland | ||
| Gold | CGR Metalloys Pvt Ltd. | India | ||
| Gold | Chimet S.p.A.* | Italy | ||
| Gold | Chugai Mining* | Japan | ||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | ||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | ||
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | ||
| Gold | DODUCO Contacts and Refining GmbH* | Germany | ||
| Gold | Dowa* | Japan | ||
| Gold | DSC (Do Sung Corporation)* | 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 | Emerald Jewel Industry India Limited (Unit 1) | India | ||
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India |
| Gold |
Emerald Jewel Industry India Limited (Unit 3) |
India | ||
| Gold |
Emerald Jewel Industry India Limited (Unit 4) |
India | ||
| Gold |
Emirates Gold DMCC* |
United Arab Emirates | ||
| Gold |
Fidelity Printers and Refiners Ltd. |
Zimbabwe | ||
| Gold |
Fujairah Gold FZC |
United Arab Emirates | ||
| Gold |
GCC Gujrat Gold Centre Pvt. Ltd. |
India | ||
| Gold |
Geib Refining Corporation* |
United States of America | ||
| Gold |
Gold Coast Refinery |
Ghana | ||
| Gold |
Gold Refinery of Zijin Mining Group Co., Ltd.* |
China | ||
| Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
China | ||
| Gold |
Guangdong Jinding Gold Limited |
China | ||
| Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
China | ||
| Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
China | ||
| Gold |
Heimerle + Meule GmbH* |
Germany | ||
| Gold |
Heraeus Germany GmbH Co. KG** |
Germany | ||
| Gold |
Heraeus Metals Hong Kong Ltd.* |
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 |
Jiangxi Copper Co., Ltd.* |
China | ||
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
Russian Federation | ||
| Gold |
JSC Uralelectromed* |
Russian Federation | ||
| Gold |
JX Nippon Mining & Metals Co., Ltd.* |
Japan | ||
| Gold |
K.A. Rasmussen |
Norway | ||
| Gold |
Kaloti Precious Metals |
United Arab Emirates | ||
| Gold |
Kazakhmys Smelting LLC |
Kazakhstan | ||
| Gold |
Kazzinc* |
Kazakhstan | ||
| Gold |
Kennecott Utah Copper LLC* |
United States of America | ||
| Gold |
KGHM Polska Miedz Spolka Akcyjna* |
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 |
Lingbao Gold Co., Ltd. |
China | ||
| Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
China | ||
| Gold |
L’Orfebre S.A.* |
Andorra | ||
| Gold |
LS-NIKKO Copper Inc.* |
Korea, Republic of | ||
| Gold |
LT Metal Ltd.* |
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 |
MD Overseas |
India | ||
| Gold |
Metal Concentrators SA (Pty) Ltd.* |
South Africa | ||
| Gold |
Metallix Refining Inc.** |
United States of America | ||
| 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 Mining and Smelting Co., Ltd.* |
Japan | ||
| Gold |
MMTC-PAMP India Pvt., Ltd.* |
India | ||
| Gold |
Modeltech Sdn Bhd |
Malaysia | ||
| Gold |
Morris and Watson |
New Zealand | ||
| Gold |
Moscow Special Alloys Processing Plant* |
Russian Federation | ||
| 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 |
OJSC Novosibirsk Refinery |
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 | ||
| 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 PMR 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 |
Samduck Precious Metals* |
Korea, Republic of | ||
| Gold |
Samwon Metals Corp. |
Korea, Republic of | ||
| Gold |
Sancus ZFS (L’Orfebre, SA) |
Colombia | ||
| Gold |
SAXONIA Edelmetalle GmbH* |
Germany | ||
| Gold |
Sellem Industries Ltd. |
Mauritania | ||
| Gold |
SEMPSA Joyeria Plateria S.A.* |
Spain | ||
| Gold |
Shandong Gold Smelting Co., Ltd.* |
China | ||
| Gold |
Shandong Humon Smelting Co., Ltd. |
China | ||
| Gold |
Shandong Tiancheng Biological Gold Industrial 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 |
Sichuan Tianze Precious Metals Co., Ltd.* |
China | ||
| Gold |
Singway Technology Co., Ltd.* |
Taiwan, Province of China | ||
| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals* |
Russian Federation | ||
| 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 |
Sumitomo Metal Mining Co., Ltd.* |
Japan | ||
| Gold |
SungEel HiMetal Co., Ltd.* |
Korea, Republic of | ||
| Gold |
T.C.A S.p.A* |
Italy | ||
| Gold |
Tanaka Kikinzoku Kogyo K.K.* |
Japan | ||
| Gold |
TDK Pretech |
Korea, Republic of | ||
| Gold |
Tokuriki Honten Co., Ltd.* |
Japan | ||
| Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
China | ||
| 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 |
Western Australian Mint (T/a The Perth Mint)* |
Australia | ||
| Gold |
WIELAND Edelmetalle GmbH* |
Germany | ||
| Gold |
Yamakin Co., Ltd.* |
Japan | ||
| Gold |
Yokohama Metal Co., Ltd.* |
Japan | ||
| Gold |
Yunnan Copper Industry Co., Ltd. |
China |
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation* |
China | ||
| Tantalum |
AMG Brasil* |
Brazil | ||
| 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 Electro-Materials Ltd.* |
China | ||
| Tantalum |
FIR Metals & Resource Ltd.* |
China | ||
| Tantalum |
Global Advanced Metals Aizu* |
Japan | ||
| Tantalum |
Global Advanced Metals Boyertown* |
United States of America | ||
| Tantalum |
Guangdong Rising Rare Metals-EO Materials Ltd.* |
China | ||
| Tantalum |
H.C. Starck Hermsdorf GmbH* |
Germany | ||
| Tantalum |
H.C. Starck Inc.* |
United States of America | ||
| 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 de Mexico* |
Mexico | ||
| Tantalum |
LSM Brasil S.A. |
Brazil | ||
| Tantalum |
Meta Materials* |
North Macedonia, Republic of | ||
| Tantalum |
Metallurgical Products India Pvt., Ltd.* |
India | ||
| Tantalum |
Mineracao Taboca S.A.* |
Brazil | ||
| Tantalum |
Mitsui Mining and Smelting Co., Ltd.* |
Japan | ||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd.* |
China | ||
| Tantalum |
NPM Silmet AS* |
Estonia | ||
| Tantalum |
QuantumClean* |
United States of America | ||
| Tantalum |
Resind Industria e Comercio Ltda.* |
Brazil | ||
| Tantalum |
RFH Tantalum Smeltry Co., Ltd. |
China | ||
| Tantalum |
Solikamsk Magnesium Works OAO* |
Russian Federation | ||
| Tantalum |
Taki Chemical Co., Ltd.* |
Japan | ||
| Tantalum |
TANIOBIS Co., Ltd.* |
Thailand | ||
| Tantalum |
TANIOBIS GmbH* |
Germany | ||
| Tantalum |
TANIOBIS Japan Co., Ltd.* |
Japan | ||
| Tantalum |
TANIOBIS Smelting GmbH & Co. KG* |
Germany | ||
| Tantalum |
Telex Metals* |
United States of America | ||
| Tantalum |
ULBA Metallurgical Plant JSC* |
Kazakhstan | ||
| Tantalum |
XIMEI RESOURCES (Guangdong) LIMITED* |
China | ||
| Tantalum |
XinXing HaoRong Electronic Material Co., Ltd.* |
China | ||
| Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd.* |
China | ||
| Tin |
Alpha* |
United States of America | ||
| Tin |
An Vinh Joint Stock Mineral Processing Company |
Viet Nam |
| Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* |
China | ||
| Tin |
Chifeng Dajingzi Tin Industry Co., Ltd.* |
China | ||
| Tin |
China Tin Group Co., Ltd.* |
China | ||
| Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda* |
Brazil | ||
| Tin |
CRM Synergies** |
Spain | ||
| Tin |
CV Ayi Jaya** |
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 |
Viet Nam | ||
| Tin |
EM Vinto* |
Bolivia (Plurinational State of) | ||
| Tin |
Estanho de Rondonia S.A.** |
Brazil | ||
| Tin |
Fenix Metals* |
Poland | ||
| 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 Zili Mining And Metallurgy Co., Ltd.* |
China | ||
| Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* |
China | ||
| Tin |
Guanyang Guida Nonferrous Metal Smelting Plant* |
China | ||
| Tin |
HuiChang Hill Tin Industry Co., Ltd.* |
China | ||
| Tin |
Huichang Jinshunda Tin Co., Ltd.* |
China | ||
| Tin |
Jiangxi New Nanshan Technology Ltd.* |
China | ||
| 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 | ||
| 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 |
Minsur* |
Peru | ||
| Tin |
Mitsubishi Materials Corporation* |
Japan | ||
| Tin |
Modeltech Sdn Bhd |
Malaysia | ||
| Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
Viet Nam | ||
| Tin |
Novosibirsk Processing Plant Ltd.** |
Russian Federation | ||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd.* |
Thailand | ||
| Tin |
O.M. Manufacturing Philippines, Inc.* |
Philippines | ||
| Tin |
Operaciones Metalurgicas S.A.* |
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 Rajehan Ariq* | Indonesia | ||
| Tin | PT Refined Bangka Tin* | Indonesia | ||
| Tin | PT Stanindo Inti Perkasa* | Indonesia | ||
| Tin | PT Sukses Inti Makmur** | Indonesia | ||
| Tin | PT Timah Nusantara** | Indonesia | ||
| Tin | PT Timah Tbk Kundur* | Indonesia | ||
| Tin | PT Timah Tbk Mentok* | Indonesia | ||
| Tin | PT Tinindo Inter Nusa* | Indonesia | ||
| Tin | Resind Industria e Comercio Ltda.* | Brazil | ||
| Tin | Rui Da Hung* | Taiwan, Province of China | ||
| Tin | Soft Metais Ltda.* | Brazil | ||
| Tin | Super Ligas** | Brazil | ||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd.* | Viet Nam | ||
| Tin | Thaisarco* | Thailand | ||
| Tin | Tin Technology & Refining* | United States of America | ||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | ||
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | ||
| Tin | White Solder Metalurgia e Mineracao Ltda.* | Brazil | ||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | China | ||
| Tin | Yunnan Tin Company Limited** | China | ||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd.* | China | ||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | ||
| Tungsten | ACL Metais Eireli* | Brazil | ||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.** | Brazil | ||
| Tungsten | Artek LLC** | Russian Federation | ||
| Tungsten | Asia Tungsten Products Vietnam Ltd.* | Viet Nam | ||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd.* | China | ||
| Tungsten | China Molybdenum Tungsten Co., Ltd.* | 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 | Ganzhou Haichuang Tungsten Co., Ltd.* | China |
| Tungsten | Ganzhou Huaxing Tungsten Products 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 | Guangdong Xianglu Tungsten Co., Ltd.* | China | ||
| Tungsten | H.C. Starck Tungsten GmbH* | Germany | ||
| Tungsten | Hunan Chenzhou Mining Co., Ltd.* | China | ||
| Tungsten | Hunan Chunchang Nonferrous Metals 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-ferris 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 | Kennametal Huntsville* | 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* | Viet Nam | ||
| Tungsten | Moliren Ltd.* | Russian Federation | ||
| Tungsten | Niagara Refining LLC* | United States of America | ||
| Tungsten | NPP Tyazhmetprom LLC** | Russian Federation | ||
| Tungsten | Philippine Chuangxin Industrial Co., Inc.* | Philippines | ||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG* | Germany | ||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* | Viet Nam | ||
| Tungsten | Unecha Refractory metals plant* | Russian Federation | ||
| Tungsten | Wolfram Bergbau und Hutten AG* | Austria | ||
| Tungsten | Woltech Korea Co., Ltd.* | Korea, Republic of | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | China | ||
| Tungsten | Xiamen Tungsten Co., Ltd.* | China | ||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | China |
| (1) | As noted in the Due Diligence Results section of this report, most survey responses from direct suppliers were provided on a company-wide basis and did not differentiate as to parts and materials sold to us. In addition, many of the responses noted that not all smelters had been identified and did not completely list all the smelters used in their supply chain. |
| * | Verified as a Conformant smelter as of June 1, 2021, meaning the smelter is listed as compliant with the RMAP assessment protocols, including through mutual recognition, or is listed as “Re-audit in process” by the RMI. |
| ** | Verified as an Active Smelter as of June 1, 2021, a RMAP designation meaning that the smelter is listed as having submitted a signed Agreement for the Exchange of Confidential Information, Auditee Agreement, and a Due Diligence Checklist. |
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