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May 24, 2019 1:27 PM EDT
 
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

_________________________
FORM SD
_________________________

Specialized Disclosure Report

_________________________
Pitney Bowes Inc.
(Exact name of registrant as specified in its charter)

 _________________________

Delaware
 
1-3579
 
06-0495050
(State or other jurisdiction of incorporation or organization)
 
(Commission File Number)
 
(IRS Employer Identification No.)
World Headquarters
3001 Summer Street
Stamford, Connecticut 06926-0700
(Address of principal executive offices) (Zip Code)
Allison Bresloff, Director, Global Environment, Health and Safety
(203) 922-4421
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
x     Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.




Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
In accordance with Section 1502 of the Dodd-Frank Financial Reform and Consumer Protection Act (the “Act”) and Rule 13p-1 under the Securities and Exchange Act of 1934 (the “Rule”), Pitney Bowes Inc. (the “Company”) has determined that it is subject to the reporting requirements under the Act and the Rule and that certain products that Pitney Bowes contracted to manufacture during calendar year 2018 contain “conflict minerals” as defined in the Rule (in the form of gold and the derivatives tantalum, tin and tungsten) necessary to the functionality of those products. The Company has undertaken a reasonable inquiry into the country of origin of the conflict minerals in our products to assess whether any of those conflict minerals originated in the Democratic Republic of Congo or an “adjoining country” as defined in the Rule or were “conflict minerals from recycled or scrap sources” as defined in the Rule. To maximize efficiency, we combined our inquiry with our due diligence activities. Our inquiry and due diligence activities are described in the Conflict Minerals Report attached hereto as Exhibit 1.02.

Conflict Minerals Disclosure
A copy of Pitney Bowes Inc.’s Conflict Minerals Report filed for the calendar year ended December 31, 2018 is publicly available at http://www.pitneybowes.com/us/our-company/corporate-responsibility.

Item 1.02 Exhibit
Pitney Bowes Inc.’s Conflict Minerals Report for the calendar year ended December 31, 2018 is filed as Exhibit 1.02 hereto.

Section 2 - Exhibits
Item 2.01 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 undersigned hereunto duly authorized.

 
    Pitney Bowes Inc. (Registrant)
 
 
 
 
 
/s/ Daniel J. Goldstein
 
 
Daniel J. Goldstein
 
 
Executive Vice President,
Chief Legal Officer and Corporate Secretary

Dated: May 23, 2019



3


Exhibit 1.02
Pitney Bowes Inc. Conflict Minerals Report
(as required by Item 1.01 and 1.02 of Form SD)

Pitney Bowes Inc. (“we,” “us,” “our,” or the “Company”) submits this report pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934 and adopted by the Securities and Exchange Commission pursuant to Section 1502 of the Dodd-Frank Financial Reform and Consumer Protection Act (the “Act”). This report describes the inquiry the Company undertook to obtain information from internal and external sources to ascertain whether any Pitney Bowes product contains tantalum, tin, tungsten, or gold (“Conflict Minerals” or “3TG”) that originated in the Democratic Republic of the Congo or adjoining countries, as defined in the Act (collectively, the “Covered Countries”), and the due diligence Pitney Bowes conducted on the source and chain of custody of such minerals. This report covers parts and products manufactured or contracted to manufacture by the Company in the 2018 calendar year. Based on our inquiry, we have found that Conflict Minerals are necessary to the functionality or production of some of our products manufactured or contracted to manufacture in 2018.
Based on our due diligence for these 2018 products, our suppliers identified a total of 536 potential smelters or refiners of 3TG in their supply chains. However, 238 of these smelters or refiners are no longer included in the Smelter Reference List of RMI’s Conflict Minerals Reporting Template based on RMI’s determination that these entities did not actually engage in smelting or refining activities, are no longer in operation, or were duplicative of other recognized smelters or refiners. Of the 298 remaining smelters or refiners, 253, or 85% were listed by RMI as conformant or active with the Responsible Minerals Assurance Process as of November 2018. One smelter, Abington Reldan Metals, LLC, has been listed as non-conformant for the past two years. However, due diligence performed by a reputable third party has indicated that this smelter is a scrap metal recycler and the following detail is provided on their web site: “We do not intentionally purchase materials that we know contain conflict minerals, except as permitted for recycling, and we require our customers and suppliers to certify that they are not knowingly supplying us with materials that contain conflict minerals that were not sourced responsibly.” The remaining 44 smelters or refiners identified are not currently participating in an auditing program; however, we have insufficient information to confirm whether these smelters or refiners sourced 3TG from the Covered Countries. For a list of the reported entities identified by our suppliers that are also identified as smelters or refiners of 3TG in RMI’s Smelter Reference List, please refer to Appendix A.

Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry to determine whether any of the necessary conflict minerals in our products originated in the Covered Countries or were from recycled or scrap sources. To make this determination, we focused on engaging our direct suppliers to identify the smelters and refiners of necessary conflict minerals that may have been contained in our products and that are recognized by the RMI to be processors of conflict minerals, and reviewing available information on the sourcing of conflict minerals by these smelters and refiners.

As a downstream company, we are several levels removed from mining minerals. We did not buy any minerals directly from mines, smelters, or refiners for use in these 2018 products. Information regarding the countries from which the identified smelters and refiners may source 3TG was not readily available to us and was not always provided to us by the Surveyed Suppliers (defined below). As part of our efforts to determine the mine or location of origin of 3TG in our products, we searched for publicly available information on the sourcing practices of identified smelters and refiners. In some instances, conflict mineral policies and related resources were available on the RMI website for identified smelters and refiners that are listed as conformant with Responsible Minerals Assurance Process assessment protocols. However, we were unable to locate country of origin information for the Conflict Minerals processed by many of the identified smelters and refiners. In addition, many of the Surveyed Suppliers identified all of the smelters and refiners potentially associated with all of their product offering and did not always limit the information provided to products supplied to Pitney Bowes. To the extent we located information on the potential origin of 3TG processed by these conformant smelters or refiners, we identify those countries in Appendix B. However, due to limitations discussed above, Pitney Bowes is unable to confirm whether necessary 3TG metals contained in our products in fact originated in any of these countries.

Our due diligence activities are further described in this report.




1. Pitney Bowes’ Design of Due Diligence
A. Due Diligence Framework
We designed our due diligence to conform, in all material respects, with the framework set out in the “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” and related Supplements on Tin, Tantalum and Tungsten and on Gold (“OECD Guidance”), published by the Organisation for Economic Cooperation and Development (the “OECD”). Since the Company does not buy Conflict Minerals directly from mines, smelters or refiners, we must rely on our suppliers to provide us with information regarding the source of the Conflict Minerals contained in the products and parts those suppliers provide to us. Our direct suppliers are similarly reliant upon information provided by their suppliers. In this regard, we have designed our due diligence to leverage the due diligence tools developed by RMI, including a supplier survey based on the Template, which is designed to help companies identify the smelters and refiners that process the Conflict Minerals in a company’s supply chain. We have incorporated the following five-step, risk-based approach to 3TG due diligence based on OECD Guidance into the design of our Conflict Minerals due diligence program:
•
establish and maintain appropriate internal management systems to identify and manage the 3TG in our global supply chain;
 
 
•
identify and assess any risks associated with the use of 3TG in our supply chain by obtaining and evaluating 3TG sourcing information from suppliers;
 
 
•
design and implement a strategy to respond to 3TG risks in our supply chain;
 
 
•
support independent auditing of smelter and refiner due diligence practices; and
 
 
•
report publicly on supply chain due diligence.

B. Scope of Due Diligence.
In order to determine if products manufactured or contracted to manufacture by Pitney Bowes contain 3TG sourced from Covered Countries, we sought out industry best practices, reviewed current guidance from various associations such as the OECD and the Information Technology Industry Council (“ITIC”), and attended industry association meetings to assess how other multinational corporations were approaching Conflict Minerals compliance.
Working with outside consultants, we developed a Conflict Minerals survey based on the Template and guidance from the RMI and ITIC. We began with a list of the top 100 suppliers who provide nearly 95% of the total dollar spend for Pitney Bowes. Ultimately we sent the Conflict Minerals survey to the 66 suppliers who (the “Surveyed Suppliers”) are impacted by this rule, eliminating suppliers that provide Pitney Bowes with products that either do not contain tin, tantalum, tungsten or gold, or otherwise supplied equipment that is out of scope. We asked the Surveyed Suppliers to respond with certain information, including their Conflict Minerals policies, usage of 3TG, and the smelters and refiners of Conflict Minerals in their supply chains.
The Surveyed Suppliers who completed the survey were asked to attest to the accuracy of their survey responses. The Product Compliance Team (defined below) monitored supplier responses to our surveys and contacted the Surveyed Suppliers who submitted incomplete responses or who failed to respond. We requested updated submittals from the Surveyed Suppliers that submitted responses with a less than 75% response rate from their supply chain and suppliers that listed smelters with inaccurate information. Data received from Surveyed Suppliers through January 22, 2019 have been included in this report.
We collected and tracked the survey responses in our product compliance database for consolidation, validation, and further analysis. We also generated periodic status reports to track and review our progress in data collection and evaluate which suppliers needed additional help in completing the survey.
C. Due Diligence Results for Pitney Bowes’ 2018 Products    
Based on our due diligence, we determined that Conflict Minerals were necessary to the functionality or production of various products from our hardware product offerings list, which includes a varied array of equipment that processes direct mail and/or enables transactional mail management and analytics that we manufactured or contracted to manufacture in 2018.




Some examples of these products include: postage meters, low-/medium-/high-volume mailing systems that can weigh, seal and apply postage to envelopes; inserters; sorters; folders; mail openers; tabbers; scales; mail kiosks; monitors; printers; accessories; and peripherals.
D. Pitney Bowes’ Conflict Minerals Disclosure Posting
We have made public our activities related to Conflict Minerals in our Corporate Responsibility Report and have posted this Conflict Minerals Report to our website (follow this link and click on the Clients and Suppliers tab: https://www.pitneybowes.com/us/our-company/corporate-responsibility.htm).
2. Pitney Bowes’ Due Diligence Measures Undertaken for 2018 Products
In an effort to continue to identify and mitigate any risk that the use of 3TG in our products going forward may benefit armed groups in the Covered Countries, we have incorporated the relevant aspects of the OECD Guidance (as summarized in the sections that follow) into our risk management program for product stewardship requirements (including Conflict Minerals).
A. Development of an Internal, Strong Management System.
1. High level management oversight
In order to provide effective management support for, and high level escalation of issues relating to, the Company’s overall supply chain due diligence efforts (inclusive of conflict minerals), we formed two cross-functional teams: the Environmental Product Compliance Team (the “Product Compliance Team”) and the Environmental Committee (the “Environmental Committee”).
The Product Compliance Team is comprised of representatives from Procurement, Supply Chain, Quality, Engineering, Environmental Health and Safety (“EHS”), Finance and Global Product Line Management and other support groups. This team is responsible for assisting the Company in meeting the requirements of global product-compliance regulations.
The Environmental Committee is made up of departmental managers holding senior positions in various departments in the company including: Procurement, Global Supply Chain, Engineering, EHS, Quality, Ethics and Compliance, Legal, Finance, Business Continuity, Global Product Line Management, Enterprise Risk and Internal Audit and oversees the work of the Product Compliance Team. The Environmental Committee is tasked with providing guidance regarding environmental product compliance, authorizing the financial and human resources needed for product compliance, and enforcing corrective action measures within Company operations and within our supply chain. Members of the Environmental Committee report potential issues and company risks to the Enterprise Risk Management team. The Enterprise Risk Management team, comprised or members of senior management from various functions and business units, reviews the Company’s efforts in managing a wide range of risks of the Company.
2. Pitney Bowes’ Conflict Minerals policy and procedures
We established a conflict minerals policy to guide our communications with and expectations for suppliers regarding Conflict Minerals. It is the Company’s goal that we will not knowingly manufacture or contract to manufacture products that include Conflict Minerals that originate from the Covered Countries, unless they were processed by smelters and refiners that are certified as “conflict free” or came from recycled or scrap sources. We communicated our expectation that our Surveyed Suppliers source products, parts and components from socially responsible sources and conduct reasonable due diligence on their supply chains in an effort to assure that Conflict Minerals are not knowingly sourced from the Covered Countries unless they were processed by smelters and refiners that are conformant with the Responsible Minerals Assurance Process or came from recycled or scrap sources.
    
We adopted and periodically review certain procedures and maintain the following steps regarding our use of 3TG:




 
 
•
Our Supplier Code of Conduct describes our Conflict Minerals and other product compliance requirements;
 
 
•
Our engineering standards and specifications include requirements to specify that suppliers must meet Section 1502(4) of the Dodd Frank Act;
 
 
•
Our Quality Assurance audit templates include supplier requirements with respect to products containing 3TG;
 
 
•
Periodically update and distribute to all suppliers our contractual language regarding certification that 3TG from Covered Countries is conflict free or came from recycled or scrap sources;
 
 
 
•
Annually publish Conflict Minerals information on our website and in our Corporate Responsibility Report;
 
 
•
Include Conflict Minerals in Enterprise Risk Management meetings to ensure regular review by our management;
 
 
•
Complete training classes through our learning management system and via webex and in person classes in order to educated relevant employees;

 
 
•
Educate Suppliers and other partners regarding Conflict Minerals during business reviews;
•
Maintain internal policies, written procedures, tools and training to ensure effective implementation of our Conflict Minerals management program;
 
 
 
 
•
Manage a supplier escalation protocol to ensure consistent and thorough management of unresponsive suppliers when needed – this protocol documents our supplier engagement and how we interact with unresponsive suppliers or suppliers who provide incomplete, questionable, or indeterminable information.

 
 

3. Pitney Bowes’ system of controls and transparency over the 3TG supply chain
As part of the Company’s broader requirement that our suppliers provide us with accurate and complete information relating to the sources of all substances contained in any product, part or component they provide to us, we required that Surveyed Suppliers provide us with information on Conflict Minerals contained in such products, parts, or components.
Surveyed Suppliers who failed to respond to our request for data were subject to additional evaluation to determine whether further engagement or escalation was necessary.
4. Pitney Bowes’ engagement with suppliers
The Company has multiple methods to encourage our suppliers to commit to our policies requiring responsible supplier operations. We have communicated our Conflict Minerals requirements to our Suppliers and other product stewardship requirements, as applicable, to our global supply chain. In connection with our data collection efforts, we have explained to our Suppliers our requirements that they conduct their operations as socially responsible suppliers. In addition, we have revised our supplier form contract wording to include compliance with our Conflict Minerals efforts. Our supplier contracts have long contained provisions giving us the right to conduct unannounced visits to supplier sites and to request documentation to confirm the supplier’s compliance with our policies and contractual requirements. Our Surveyed Suppliers have received training regarding Conflict Minerals requirements and completion of our product compliance database.
5. Pitney Bowes’ Company-level grievance mechanism
For many years, Pitney Bowes has maintained an Ethics Help Line which is available toll-free, 24 hours a day, seven days a week. The Ethics Help Line is operated by an outside firm and enables employees, clients and others to make inquiries and report concerns about potential violations of Company policy or the law, in many languages, without fear of retaliation. Anyone can contact the Ethics Help Line to report any concerns about Conflict Minerals that may be contained in our products.
B. Identification and Assessment of Risk in Our Supply Chain.
The Company continues its program of conducting supply chain due diligence and risk assessment on supplier sources of 3TGs as described above in Section 1.






C. Strategy for Responding to Identified Risks in Our 3TG Supply Chain.
As described above, the Product Compliance Team monitored supplier responses to our surveys and contacted Surveyed Suppliers who submitted incomplete responses or who failed to respond so that we could understand what was preventing them from submitting a full and final attestation regarding their product line. The Product Compliance Team also reviewed the data from the product compliance database to determine which Surveyed Suppliers had data gaps, had raised questions or had not been responsive. Any Surveyed Suppliers that were considered non-responsive or higher risk were escalated to designated internal teams and management for further evaluation as they were identified.
We also reported the findings and information gathered through our inquiry and due diligence to Pitney Bowes senior management.
D. Support for Independent Third-party Audits of Supply Chain Due Diligence

Since we do not have direct relationships with smelters or refiners, we did not perform direct audits of these entities’ supply chains of Conflict Minerals. However, we supported the development and implementation of smelter and refinery sourcing audits conducted by independent third parties and industry groups, such as the RMI’s Responsible Minerals Assurance Process, through our conflict minerals policy and expectations regarding conflict-free sourcing of minerals from the Covered Countries.
3. Future Actions to Further Minimize Any Risk of Conflict Minerals Benefitting Armed Groups
The Company will continue to request information from our supply chain in order to meet the requirements of the Rule. Where there is reason to believe that a supplier is not adopting a Conflict Minerals policy or providing the necessary data to us, we will work with the supplier to address the issue. In the event of continued supplier deficiencies, we will consider appropriate measures including, if and as appropriate, termination of our relationship with a supplier.





Appendix A

List of Smelters / Refiners Identified by the Surveyed Suppliers

The following list provides the name, location and status of smelters and refiners identified by the Surveyed Suppliers. Pitney Bowes is unable to confirm that any or all smelters and refiners in this list processed the necessary 3TG metals contained in our products, since a number of the Surveyed Suppliers identified all smelters and refiners in their total supply chain and did not limit their responses to the specific products supplied to Pitney Bowes.

Smelter and refiner names and locations were drawn from the Smelter Reference List in the latest version of the Template. Smelter and refiner status is based on information available to Pitney Bowes as of November 2018. “Conformant” means listed by RMI as conformant with Responsible Minerals Assurance Process assessment protocols; “Active” means listed by RMI as having committed to undergo an audit or as participating in a similar assessment program such as the LBMA Responsible Gold Certification or Responsible Jewelry Council’s Chain-of-Custody Certification. Smelters or refiners listed as “In Communication” or “Outreach Required” have begun discussions with or will be encouraged to participate in the RMAP audit. Smelters and refiners designated by RMI as “Non-Conformant”, “Communication Suspended – Not Interested”, and “Due Diligence Vetting Process” are not currently conformant with Responsible Minerals Assurance Process assessment protocols and/or are not currently progressing toward participation in an audit. Entities that are no longer recognized as smelters or refiners are not included in the reference list below (for example, if they are no longer included in the Smelter Reference List of the Template based on RMI’s determination that the entity did not actually engage in smelting or refining activities or if we or RMI believe they are no longer in operation).



Metal
Smelter /Refiner Name
Smelter/Refiner Location
RMI Audit Status

Gold
Abington Reldan Metals, LLC
UNITED STATES
Non-Conformant
Gold
Advanced Chemical Company
UNITED STATES
Conformant
Gold
AGR Mathey
AUSTRALIA
Conformant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Conformant
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Conformant
Gold
Amagasaki Factory, Hyogo Prefecture, Japan
JAPAN
Conformant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Conformant
Gold
Anhui Tongling Nonferrous Metal Mining Co., Ltd.
CHINA
Outreach Required
Gold
Argor-Heraeus S.A.
SWITZERLAND
Conformant
Gold
Asahi Pretec Corp.
JAPAN
Conformant
Gold
Asahi Refining Canada Ltd.
CANADA
Conformant
Gold
Asahi Refining USA Inc.
UNITED STATES
Conformant
Gold
Asaka Riken Co., Ltd.
JAPAN
Conformant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Due Diligence Vetting Process
Gold
AU Traders and Refiners
SOUTH AFRICA
Conformant
Gold
Aurubis AG
GERMANY
Conformant
Gold
Bangalore Refinery
INDIA
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Conformant
Gold
Boliden AB
SWEDEN
Conformant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Conformant
Gold
Caridad
MEXICO
Communication Suspended - Not Interested
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Conformant
Gold
Cendres + Métaux S.A.
SWITZERLAND
Conformant
Gold
Chimet S.p.A.
ITALY
Conformant




Gold
Chugai Mining
JAPAN
Active
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
In Communication
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Outreach Required
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Conformant
Gold
Dowa
JAPAN
Conformant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Conformant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Conformant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Conformant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Due Diligence Vetting Process
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Outreach Required
Gold
Geib Refining Corporation
UNITED STATES
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Outreach Required
Gold
Guangdong Jinding Gold Limited
CHINA
Outreach Required
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Outreach Required
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Outreach Required
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Heimerle + Meule GmbH
GERMANY
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Conformant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Outreach Required
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Communication Suspended - Not Interested
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Conformant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
Istanbul Gold Refinery
TURKEY
Conformant
Gold
Italpreziosi
ITALY
Conformant
Gold
Japan Mint
JAPAN
Conformant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Conformant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Conformant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Conformant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Outreach Required
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
In Communication
Gold
Kazzinc
KAZAKHSTAN
Conformant
Gold
Kennecott Utah Copper LLC
UNITED STATES
Conformant
Gold
KGHM Polska Miedź Spółka Akcyjna
POLAND
Active
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Conformant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Conformant
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Outreach Required
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Outreach Required
Gold
Lingbao Gold Co., Ltd.
CHINA
Outreach Required
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Outreach Required
Gold
L'Orfebre S.A.
ANDORRA
Conformant
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Conformant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Outreach Required




Gold
Marsam Metals
BRAZIL
Conformant
Gold
Materion
UNITED STATES
Conformant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Conformant
Gold
Metalor Technologies S.A.
SWITZERLAND
Conformant
Gold
Metalor USA Refining Corporation
UNITED STATES
Conformant
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Conformant
Gold
Mitsubishi Materials Corporation
JAPAN
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Conformant
Gold
Modeltech Sdn Bhd
MALAYSIA
Active
Gold
Morris and Watson
NEW ZEALAND
Communication Suspended - Not Interested
Gold
Morris and Watson Gold Coast
AUSTRALIA
Communication Suspended - Not Interested
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Conformant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Outreach Required
Gold
Nihon Material Co., Ltd.
JAPAN
Conformant
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Conformant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Conformant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Conformant
Gold
PAMP S.A.
SWITZERLAND
Conformant
Gold
Pease & Curren
UNITED STATES
Outreach Required
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Outreach Required
Gold
Planta Recuperadora de Metales SpA
CHILE
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Conformant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Conformant
Gold
PX Precinox S.A.
SWITZERLAND
Conformant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Conformant
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Outreach Required
Gold
Remondis Argentia B.V.
NETHERLANDS
Conformant
Gold
Royal Canadian Mint
CANADA
Conformant
Gold
SAAMP
FRANCE
Conformant
Gold
Sabin Metal Corp.
UNITED STATES
Outreach Required
Gold
SAFINA A.S.
CZECH REPUBLIC
Active
Gold
Sai Refinery
INDIA
Outreach Required
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Conformant
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Communication Suspended - Not Interested
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Conformant
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Conformant
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Outreach Required
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Outreach Required
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Conformant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Conformant
Gold
Singway Technology Co., Ltd.
TAIWAN
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Conformant




Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Conformant
Gold
State research institute Center for Physical Sciences and Technology
LITHUANIA
Outreach Required
Gold
Sudan Gold Refinery
SUDAN
Outreach Required
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Conformant
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
T.C.A S.p.A
ITALY
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Conformant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Conformant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Outreach Required
Gold
Tony Goetz NV
BELGIUM
Active
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
In Communication
Gold
Torecom
KOREA, REPUBLIC OF
Conformant
Gold
Umicore Brasil Ltda.
BRAZIL
Conformant
Gold
Umicore Precious Metals Thailand
THAILAND
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Conformant
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Conformant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Communication Suspended - Not Interested
Gold
Valcambi S.A.
SWITZERLAND
Conformant
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Conformant
Gold
WIELAND Edelmetalle GmbH
GERMANY
Conformant
Gold
Yamakin Co., Ltd.
JAPAN
Conformant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Conformant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Outreach Required
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Conformant
Tantalum
D Block Metals, LLC
UNITED STATES
Conformant
Tantalum
Exotech Inc.
UNITED STATES
Conformant
Tantalum
F&X Electro-Materials Ltd.
CHINA
Conformant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Conformant
Tantalum
Global Advanced Metals Aizu
JAPAN
Conformant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Conformant
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Conformant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Conformant
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Conformant
Tantalum
H.C. Starck Inc.
UNITED STATES
Conformant
Tantalum
H.C. Starck Ltd.
JAPAN
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Conformant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Conformant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
KEMET Blue Metals
MEXICO
Conformant
Tantalum
KEMET Blue Powder
UNITED STATES
Conformant
Tantalum
LSM Brasil S.A.
BRAZIL
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Conformant
Tantalum
Mineracao Taboca S.A.
BRAZIL
Conformant
Tantalum
Mitsui Mining & Smelting Co. Ltd.
JAPAN
Conformant




Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Conformant
Tantalum
NPM Silmet AS
ESTONIA
Conformant
Tantalum
Power Resources Ltd.
MACEDONIA
Conformant
Tantalum
QuantumClean
UNITED STATES
Conformant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Conformant
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Conformant
Tantalum
Telex Metals
UNITED STATES
Conformant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Conformant
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tin
Alpha
UNITED STATES
Conformant
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Outreach Required
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Conformant
Tin
China Tin Group Co., Ltd.
CHINA
Conformant
Tin
CV Ayi Jaya
INDONESIA
Conformant
Tin
CV Dua Sekawan
INDONESIA
Conformant
Tin
CV Gita Pesona
INDONESIA
Conformant
Tin
CV United Smelting
INDONESIA
Conformant
Tin
CV Venus Inti Perkasa
INDONESIA
Conformant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Active
Tin
EM Vinto
BOLIVIA
Conformant
Tin
Estanho de Rondonia S.A.
BRAZIL
Outreach Required
Tin
Fenix Metals
POLAND
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Conformant
Tin
Gejiu Jinye Mineral Company
CHINA
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Conformant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Active
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Conformant
Tin
Jiangxi New Nanshan Technology, Ltd.
CHINA
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Conformant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Conformant
Tin
Melt Metais e Ligas S.A.
BRAZIL
Conformant
Tin
Metallic Resources, Inc.
UNITED STATES
Conformant
Tin
Metallo Belgium N.V.
BELGIUM
Conformant
Tin
Metallo Spain S.L.U.
SPAIN
Conformant
Tin
Mineracao Taboca S.A.
BRAZIL
Conformant
Tin
Minsur
PERU
Conformant
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Outreach Required
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Conformant
Tin
Operaciones Metalurgicas S.A.
BOLIVIA
Conformant
Tin
PT Aries Kencana Sejahtera
INDONESIA
Conformant
Tin
PT Artha Cipta Langgeng
INDONESIA
Conformant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Conformant
Tin
PT Babel Inti Perkasa
INDONESIA
Conformant
Tin
PT Babel Surya Alam Lestari
INDONESIA
Conformant
Tin
PT Bangka Prima Tin
INDONESIA
Conformant
Tin
PT Bangka Tin Industry
INDONESIA
Conformant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Conformant
Tin
PT Bukit Timah
INDONESIA
Conformant




Tin
PT DS Jaya Abadi
INDONESIA
Conformant
Tin
PT Karimun Mining
INDONESIA
Conformant
Tin
PT Kijang Jaya Mandiri
INDONESIA
Conformant
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Conformant
Tin
PT Menara Cipta Mulia
INDONESIA
Conformant
Tin
PT Mitra Stania Prima
INDONESIA
Conformant
Tin
PT Panca Mega Persada
INDONESIA
Conformant
Tin
PT Prima Timah Utama
INDONESIA
Conformant
Tin
PT Premium Tin Indonesia
INDONESIA
Conformant
Tin
PT Rajehan Ariq
INDONESIA
Conformant
Tin
PT Refined Bangka Tin
INDONESIA
Conformant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Conformant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Conformant
Tin
PT Sukses Inti Makmur
INDONESIA
Conformant
Tin
PT Sumber Jaya Indah
INDONESIA
Conformant
Tin
PT Timah Tbk Kundur
INDONESIA
Conformant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Conformant
Tin
PT Tinindo Inter Nusa
INDONESIA
Conformant
Tin
PT Tirus Putra Mandiri
INDONESIA
Active
Tin
PT Tommy Utama
INDONESIA
Conformant
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Conformant
Tin
Soft Metais Ltda.
BRAZIL
Conformant
Tin
Super Ligas
BRAZIL
Outreach Required
Tin
Thaisarco
THAILAND
Conformant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Outreach Required
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Conformant
Tin
Yunnan Geiju Zili Mining and Metallurgy Co. Ltd.
CHINA
Active
Tin
Yunnan Tin Company Limited
CHINA
Conformant
Tungsten
A.L.M.T. Corp.
JAPAN
Conformant
Tungsten
ACL Metais Eireli
BRAZIL
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
China National Non Ferrous
CHINA
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
H.C. Starck GmbH
GERMANY
Conformant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
Active
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Outreach Required
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Communication Suspended - Not Interested
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Conformant




Tungsten
Kennametal Fallon
UNITED STATES
Conformant
Tungsten
Kennametal Huntsville
UNITED STATES
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Conformant
Tungsten
Niagara Refining LLC
UNITED STATES
Conformant
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Conformant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Conformant
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Conformant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Conformant









































APPENDIX B


Countries of Origin

Potential countries of origin for 3TG processed by conformant smelters or refiners may include (but are not necessarily limited to):

ALGERIA
AMERICAN SAMOA
ANDORRA
ARGENTINA
AUSTRALIA
AUSTRIA
BELGIUM
BOLIVIA
BRAZIL
CANADA
CHILE
CHINA
CZECH REPUBLIC
ENGLAND
ESTONIA
ETHIOPIA
FRANCE
GERMANY
HONG KONG
INDIA
INDONESIA
ITALY
JAPAN
KAZAKHSTAN
KOREA (REPUBLIC OF)
KYRGYZSTAN
LITHUANIA
LUXEMBOURG
MACEDONIA, REPUBLIC OF
MALAYSIA
MEXICO
MOZAMBIQUE
NETHERLANDS
NEW ZEALAND
NORWAY
PANAMA
PERU
PHILIPPINES
POLAND
REPUBLIC OF KOREA
RUSSIAN FEDERATION
RWANDA




SAUDI ARABIA
SINGAPORE
SLOVAKIA
SOUTH AFRICA
SPAIN
SUDAN
SWAZILAND
SWEDEN
SWITZERLAND
TAIWAN
THAILAND
TURKEY
UNITED ARAB EMIRATES
UNITED KINGDOM
UNITED STATES OF AMERICA
URUGUAY
UZBEKISTAN
VIET NAM
ZAMBIA
ZIMBABWE




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