Form SD TRIMBLE INC.
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
TRIMBLE INC.
(Exact name of registrant as specified in its charter)
Delaware | 001-14845 | 94-2802192 | ||
(State or other jurisdiction of incorporation) |
(Commission File Number) |
(IRS. Employer Identification No.) |
935 Stewart Drive
Sunnyvale, CA 94085
(Address of principal executive offices)
James A. Kirkland
Senior Vice President, General Counsel and Secretary
(408) 481-8000
(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, 2017. |
Section 1 - Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit
A copy of Trimble Inc.s Conflict Minerals Report is provided as Exhibit 1.01 to this Report and is available at the following address:
http://www.trimble.com/Corporate/Compliance/compliance_resources.aspx
Section 2 - Exhibits
Item 2.01 | Exhibits |
Exhibit No. |
Description | |
1.01 | Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form. |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
TRIMBLE INC. | ||
/s/ James A. Kirkland | ||
By: | James A. Kirkland, Senior Vice President, General Counsel and Secretary | |
Date: | May 31, 2018 |
Exhibit 1.01
Trimble Inc.
Conflict Minerals Report For The Year Ended December 31, 2017
The following conflict minerals report contains forward-looking statements about our plans to take additional actions or to implement additional policies or procedures with respect to our due diligence efforts to determine the origin of conflict minerals contained in our products. We undertake no obligation to publically update or revise any forward-looking statement, whether as a result of new information, future events or otherwise. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report.
This is the Conflict Minerals Report of Trimble Inc. for the 2017 calendar year in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.
Rule 13p-1 requires that all public companies report annually on the presence of certain minerals, characterized as conflict minerals, including tin, tantalum, tungsten or gold (3TG or conflict minerals), in the products that they manufacture or contract to manufacture, and demonstrate the proper level of due diligence in determining whether these minerals originated from the Democratic Republic of the Congo or an adjoining country (collectively, Covered Countries) or from scrap or recycled sources and whether they directly or indirectly finance or benefit armed groups in the Covered Countries.
Introduction
Trimble provides technology solutions that enable professionals and field mobile workers to improve or transform their work processes. Our solutions, which can include a combination of hardware, software and services, are used across a range of industries including agriculture, architecture, civil engineering, survey and land administration, construction, geospatial, government, natural resources, transportation and utilities. Representative Trimble customers include engineering and construction firms, contractors, surveying companies, farmers and agricultural companies, enterprise firms with large-scale fleets, energy, mining and utility companies, and state, federal and municipal governments.
We design and manufacture, or have manufactured on our behalf, thousands of different hardware products ranging across multiple business divisions within our key business segments of Buildings and Infrastructure, Geospatial, Resources and Utilities, and Transportation. Many of these hardware products, which are typically based upon positioning or location technologies, including Global Navigation Satellite Systems (GNSS), lasers and optics, are built by our contract manufacturing partners.
Our contract manufacturing partners are responsible for significant material procurement, assembly, and testing. We generally manage product design and are involved in qualifying suppliers and key components used in our products. We are many levels removed from the mining or processing of minerals in our supply chain, however, and we do not directly source, or manage the sourcing of, raw materials, including conflict minerals.
Many of our hardware products are designed with printed circuit boards, connectors, sheet metal and other electrical mechanical assemblies that may contain conflict minerals. The components used in our products that contain these metals are required for the functionality of our products.
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Trimbles Conflict Minerals Program
Trimble is committed to sourcing components and materials from companies that share our values concerning human rights, ethics and environmental responsibility. Our Conflict Minerals Policy Statement, as well as all of our Conflict Minerals Reports, are published on our public website and available at:
http://www.trimble.com/Corporate/Compliance/compliance_resources.aspx.
We focus our due diligence efforts on determining the source and chain of custody of conflict minerals in the components and materials that are supplied to us. Tracing conflict minerals back to their country of origin, though, is a complex task that requires, among other things, screening for the possible presence of 3TG in parts or materials provided by our contract manufacturers and direct suppliers (which we refer to as in-scope suppliers), and then surveying such in-scope suppliers to understand what programs they have in place for tracing the source of minerals included in products or components supplied to us. Suppliers are deemed out-of-scope and not surveyed if they only provide software, plastic, packaging materials or other items that do not contain 3TG.
Trimble uses as its standard reporting template, and requires its in-scope suppliers to use, the Responsible Minerals Initiatives (RMI) (formerly known as the Conflict-Free Sourcing Initiative) Conflict Minerals Reporting Template (CMRT) to identify whether in-source suppliers source 3TG from the Covered Countries or from recycled or scrap sources. The CMRT is a key part of our due diligence efforts and is used to determine the source and chain of custody of 3TG in the components and materials that are supplied to us. We rely on the information provided through the CMRT by our supply chain, as well as smelter information provided by the RMI and other industry organizations, to complete our Conflict Minerals Report.
As part of our supplier risk assessment, we require new suppliers to go through a screening and approval process so we can assess their use of 3TG and determine whether they are in-scope suppliers. We provide an initial survey to assess their use of 3TG and to understand their business processes. We also inform new suppliers of our Supplier Requirements for the Sourcing of Conflict Minerals, which further describe our Conflict Minerals Program goals and expectations. Additionally, we have established a Supplier Code of Conduct, which is based upon the Responsible Business Alliances Code of Conduct.
Trimble requires in-scope suppliers to source from smelters that are either conformant with the Responsible Minerals Assurance Process (RMAP) (formerly, the Conflict-Free Smelter Program or CFSP), have undergone another recognized third-party audit program or are in the process of achieving audit compliance. In the event of non-compliance by an in-scope supplier, we require the supplier to pursue corrective actions, and, in the event of continued non-compliance, we may consider termination of the supplier.
Reasonable Country of Origin Inquiry (RCOI)
Since conflict minerals are necessary to the functionality of many of our hardware products, we conducted an RCOI to determine the origin of the 3TG present in our products delivered to customers. Given the complex nature of our supply chain and our extensive parts inventory, we assess our in-scope suppliers in three separate phases: (i) we first assess suppliers of parts containing 3TG that are used in the bill of materials for products that we are actively producing; (ii) we then review those suppliers that manufacture and sell to us their parts and components; and (iii) finally, we review suppliers of the companies and businesses that we acquire.
After our three phase assessment, we requested that in-scope suppliers provide us with information using the CMRT. We received a 96% response rate, which was the same rate as the prior year. Based on the CMRT responses from our in-scope suppliers and a review and analysis of the responses against RMIs
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RMAP Conformant Smelter & Refiner list, which provides sourcing information and audit status for certified smelters, we concluded that, of the identified smelters:
63% sourced minerals from conflict free regions;
8% sourced from Covered Countries but were compliant; and
29% did not disclose their sourcing information.
Based on our internal assessment of in-scope suppliers and the CMRT information we received back from our in-scope suppliers, we determined that it was necessary to exercise due diligence to determine the source and chain of custody of the conflict minerals contained in our products.
Trimble Due Diligence
We have designed our due diligence program to conform, in all material respects, with the framework in the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition), and the related supplements, published by the Organisation for Economic Co-operation and Development. The following describes Trimbles due diligence activities for the 2017 reporting year.
Step 1: | Establish Strong Company Management Systems |
| We have made our Conflict Minerals Policy, described above, publicly available on our website. |
| We have established a team that is responsible for administering our Conflict Minerals Program. Our team is supported by, and works closely with, our third-party vendor, MetricStream. Our team consists of personnel from our corporate operations group, including representatives from our quality, internal audit and global commodity management departments, and works closely with our specific business area buyers and product managers to address supplier risks and disclosure issues. |
| If suppliers are unresponsive or do not provide the requested information, we have a process for escalating the matter to increasingly senior levels of management and considering corrective actions for suppliers that do not meet our stated expectations. |
| We have established Supplier Requirements for the Sourcing of Conflict Minerals, which we communicate to our suppliers and require them to follow. We also engage suppliers by providing conflict mineral training and orientation materials to assist our suppliers in completing the CMRTs, and provide support to answer suppliers questions. We maintain a conflict minerals resource page with links to resources about the conflict minerals law, the CMRT and our contact information for conflict minerals related inquiries: http://www.trimble.com/Corporate/Compliance/compliance_resources.aspx. |
| Our template terms of purchase require suppliers to assist us in complying with applicable provisions of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act such as notifying us of their use of conflict minerals. |
| We report on the status and progress of our Conflict Minerals Program during our operation groups quarterly business and executive-level review meetings. |
| Our Conflict Minerals Program, as an established internal process, is subject to oversight by our internal audit group. |
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Step 2: | Identify and Assess Risk in the Supply Chain |
| We requested each in-scope supplier to complete and return a CMRT so that we could survey our supply chain and obtain information about the smelters and refiners (which we collectively refer to as smelters throughout this report), and mines or locations of origin, of the 3TG used in our products. We identified the CMRT, the standardized reporting template developed by RMI as the best method for collecting information about Trimbles suppliers in order to identify and assess risks. |
| We tracked responses from in-scope suppliers and initially categorized suppliers according to whether they provided in their CMRT responses: (i) legitimate smelter information, or (ii) inconsistent or incomplete information about smelters that required further investigation. |
| We use RMIs smelters and refiners database to obtain conflict minerals sourcing information for the smelters identified on the CMRTs from our in-scope suppliers. |
| We have a defined process for reviewing and evaluating CMRT responses, including procedures to address incomplete or vague answers and to follow up with suppliers, as necessary. |
| We identify any high risk suppliers that require additional attention by focusing on suppliers that: (i) list smelters that are in the Covered Countries and are not found on the RMAP Conformant Smelters & Refiners list (ii) list smelters that have been found to be non-conformant with the RMAP or similar third-party audit programs (iii) list unresponsive smelters that are unwilling to undertake compliance with the RMAP or another third-party audit program; or (iv) identify smelters through our trade compliance screening that may be financed by a U.S.-embargoed or - sanctioned country, or that are identified as potentially supporting armed conflict or human rights violations. |
Step 3: | Design and Implement a Strategy to Respond to Identified Risks |
| We obtained updated smelter status data from RMIs smelters and refiners database and compared supplier provided information against such data. Smelters found not in conformance with the RMAP or other independent third-party audit programs (such as the Tin Supply Chain Initiative List and the London Bullion Market Good Delivery Lists) were flagged for further due diligence. |
| Any supplier that Trimble identified as high risk underwent further investigation, and was subject to additional risk mitigation requests by Trimble. |
| We informed our in-scope suppliers of identified high risk smelters and requested our suppliers to conduct further due diligence and to work with their supply chains to ensure compliance, such as by requesting impacted suppliers to utilize RMIs smelter outreach letter in reaching out to non-certified smelters and press them for compliance, or to find substitute smelters. |
| We require high risk suppliers to commit to and implement a corrective action plan within a reasonable time frame, and if such plan is deemed ineffective or there is no progress made, at the discretion of management, the supplier is subject to suspension or termination. |
| We participate in and support RMIs working groups on smelter due diligence practices for risk mitigation. |
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Step 4: | Carry Out Independent Third-party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
| We are a member of RMI and rely on RMIs data to validate the audit status and sourcing information of smelters. |
| We conduct our own due diligence through publicly available information regarding identified high risk smelters to validate the existence and assess the conflict status of smelters. |
| We address conflict minerals in our general supplier audits, focusing on supplier CMRT responses and due diligence programs. |
Step 5: | Report on supply chain due diligence |
| Our annual Conflict Minerals Reports are publicly accessible on our website. |
| We highlight selected accomplishments and attributes of our Conflict Minerals Program in our Responsible Corporate Citizenship Report, publicly available through our website: https://www.trimble.com/corporate/pdf/Trimble_RCC_Final.pdf. |
| We remind high risk suppliers of our expectations for the upcoming 2018 conflict minerals reporting period and emphasize our requirements and goals. |
Results of Due Diligence
Based on the responses received from suppliers, we identified a total of 311 smelters within our supply chain that were potential sources of 3TG for our suppliers.
We utilized RMIs smelter database to obtain recent smelter audit status as of April 5, 2018. The table below summarizes the status of smelters that were identified through the information provided by our in-scope suppliers. Trimble has adopted the same audit status designations utilized by RMI to categorize audit compliance status. Compliant smelters are those that have completed an audit and conform with RMAP or other third party programs. Active smelters are those that are engaging with RMAP or other third party auditors to achieve compliance. In Communication refers to smelters that are not certified, but which demonstrate interest in participating in an audit program. Alleged are alleged smelters that are not certified and have not even been verified yet to be a true smelter or still in business. Non-Conformant are those smelters that have been identified as having non-conformant audit results.
Schedule A lists all the verified smelters reported by our in-scope suppliers that we believe processed 3TG which may have been used in Trimble products during the 2017 reporting period.
2017 Trimble Smelters Audit Status in reference to RMIs Smelter Database (as of April 5, 2018) |
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Smelter Audit Status |
Compliant Smelters: | Active Smelters: | In Communication: | Alleged: | Non- Conformant: |
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Gold |
101 | 6 | 27 | 8 | 2 | |||||||||||||||
Tantalum |
41 | | | | | |||||||||||||||
Tin |
71 | 2 | 5 | 1 | 1 | |||||||||||||||
Tungsten |
41 | 1 | 2 | | 2 | |||||||||||||||
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Total: |
254 | 9 | 34 | 9 | 5 | |||||||||||||||
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Of the total number of smelters identified, 180 smelters had associated mine disclosure information that was provided to us by RMI. From this information, we determined that 160 of those smelters did not source 3TG from the Covered Countries. We also determined that 2 smelters that sourced 3TG from Covered Countries were certified as conflict-free by RMI.
We conducted additional diligence and assessed the remaining 18 high risk smelters as follows:
| 2 may have been misidentified as non-conformant due to mistranslations and were in fact determined to be part of valid smelter audit programs; |
| 3 smelters were determined to either not be true smelters or were no longer in business; |
| 7 smelters could not be validated as true 3TG smelters or there was a lack of evidence showing that the smelters sourced from Covered Countries; and |
| 6 smelters were of unknown status due to either RMI being unable to verify status or because of lack of participation in any audit program. |
Trimble issued corrective actions to all 95 in-scope suppliers that listed at least one of these 18 smelters. Of those, 77 suppliers have responded with remedial action plans. The remaining 18 suppliers have acknowledged Trimbles requests for corrective actions but have not yet provided remedial plans. Trimble continues to closely monitor the progress of these suppliers and will consider additional corrective action if warranted.
Determination
Based on the measures we have taken, as described above, we do not have sufficient information to determine the country of origin of all of the 3TG contained in our products. Not all of the RMAP compliant smelters disclosed the origin of their minerals. In addition, the information provided by some suppliers was incomplete and unverifiable, and certain smelters identified by suppliers were not recognized by RMI or were unknown to us so we were unable to determine the origin of minerals processed by such smelters.
However, based on the information provided by our suppliers, as well as information from RMI and other third party sources, we believe the origin of 3TG processed by smelters known to us and contained in our products include the countries listed in Schedule B. As discussed above, the known smelters for which we had mine disclosure information, and that we believe processed 3TG originating from the Covered Countries, were all certified conflict-free by RMI. In addition, we are not aware of any instance where 3TG sourced from the Covered Countries directly or indirectly financed or benefited armed groups.
Future Due Diligence Measures
We intend to take the following measures in 2018 to further mitigate the risk that conflict minerals in our products could directly or indirectly finance or benefit armed groups in the Covered Countries:
| Push our suppliers to reach out to those smelters with the status of In Communication to pressure those smelters to attain compliance with a third-party smelter audit program; |
| Actively monitor the progress of those suppliers with high risk smelters identified within their supply chains; |
| Continue to communicate with our suppliers regarding Trimbles Conflict Mineral Policy and Supplier Requirements to ensure that suppliers appropriately assess their supply chains, in keeping with the principles of responsible sourcing and corporate social responsibility underlying Trimbles Conflict Minerals Program; |
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| Require our suppliers to source from smelters that are certified as conflict-free or that are currently undergoing, or willing to undergo, an audit through the RMAP or another third party; |
| Provide conflict minerals training to Trimbles new suppliers and other suppliers that appear to need assistance; |
| Review our supplier risk mitigation process to assess remedial and corrective actions that we may take to address situations where suppliers are unresponsive, provide incomplete information or continue to source from unknown smelters; and |
| Continue monitoring our supply chain activities, keep current with changes or updates in relevant laws and guidance, and update our related policies and procedures as appropriate. |
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Schedule A
Smelters and Refiners
Metal |
Smelter Name |
Country | ||
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||
Gold | PAMP S.A. | SWITZERLAND | ||
Gold | Nihon Material Co., Ltd. | JAPAN | ||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
Gold | Mitsubishi Materials Corporation | JAPAN | ||
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||
Gold | Metalor Technologies S.A. | SWITZERLAND | ||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||
Gold | Asahi Refining Canada Ltd. | CANADA | ||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||
Gold | Dowa | JAPAN | ||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||
Gold | Asaka Riken Co., Ltd. | JAPAN | ||
Gold | Asahi Pretec Corp. | JAPAN | ||
Gold | Argor-Heraeus S.A. | SWITZERLAND | ||
Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | ||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||
Gold | Valcambi S.A. | SWITZERLAND | ||
Gold | Umicore Brasil Ltda. | BRAZIL | ||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||
Gold | Royal Canadian Mint | CANADA | ||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||
Gold | Materion | UNITED STATES OF AMERICA | ||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
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Gold | Jiangxi Copper Co., Ltd. | CHINA | ||
Gold | Heimerle + Meule GmbH | GERMANY | ||
Gold | Eco-System Recycling Co., Ltd. | JAPAN | ||
Gold | Chimet S.p.A. | ITALY | ||
Gold | Aurubis AG | GERMANY | ||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||
Gold | Yamakin Co., Ltd. | JAPAN | ||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||
Gold | PX Precinox S.A. | SWITZERLAND | ||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||
Gold | Torecom | KOREA, REPUBLIC OF | ||
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | ||
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||
Gold | Cendres + Metaux S.A. | SWITZERLAND | ||
Gold | C. Hafner GmbH + Co. KG | GERMANY | ||
Gold | Boliden AB | SWEDEN | ||
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||
Gold | SAFINA A.S. | CZECH REPUBLIC | ||
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||
Gold | Schone Edelmetaal B.V. | NETHERLANDS | ||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||
Gold | AU Traders and Refiners | SOUTH AFRICA | ||
Gold | Remondis Argentia B.V. | NETHERLANDS | ||
Gold | WIELAND Edelmetalle GmbH | GERMANY | ||
Gold | SAAMP | FRANCE | ||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||
Gold | Istanbul Gold Refinery | TURKEY | ||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | ||
Gold | Sudan Gold Refinery | SUDAN | ||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||
Gold | Lingbao Gold Co., Ltd. | CHINA | ||
Gold | Lazurde Company For Jewelry | SAUDI ARABIA | ||
Gold | Tony Goetz NV | BELGIUM | ||
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||
Gold | Sai Refinery | INDIA | ||
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
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Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||
Gold | Universal Precious Metals Refining Zambia | ZAMBIA | ||
Gold | Guangdong Jinding Gold Limited | CHINA | ||
Gold | Morris and Watson | NEW ZEALAND | ||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | T.C.A S.p.A | ITALY | ||
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | ||
Gold | Japan Mint | JAPAN | ||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||
Gold | Umicore Precious Metals Thailand | THAILAND | ||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||
Gold | Yokohama Metal Co., Ltd. | JAPAN | ||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||
Gold | OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||
Gold | Kazzinc | KAZAKHSTAN | ||
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||
Gold | Pease & Curren | UNITED STATES OF AMERICA | ||
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||
Gold | Morris and Watson Gold Coast | AUSTRALIA | ||
Gold | Bangalore Refinery | INDIA | ||
Gold | Modeltech Sdn Bhd | MALAYSIA | ||
Gold | Italpreziosi | ITALY | ||
Gold | Marsam Metals | BRAZIL | ||
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||
Gold | Safimet S.p.A | ITALY | ||
Gold | Planta Recuperadora de Metales SpA | CHILE | ||
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | ||
Gold | LOrfebre S.A. | ANDORRA | ||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
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Tantalum | F&X Electro-Materials Ltd. | CHINA | ||
Tantalum | Global Advanced Metals Aizu | JAPAN | ||
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
Tantalum | H.C. Starck Ltd. | JAPAN | ||
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | ||
Tantalum | H.C. Starck Co., Ltd. | THAILAND | ||
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||
Tantalum | NPM Silmet AS | ESTONIA | ||
Tantalum | LSM Brasil S.A. | BRAZIL | ||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | ||
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | ||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||
Tantalum | Mineracao Taboca S.A. | BRAZIL | ||
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||
Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | ||
Tantalum | KEMET Blue Metals | MEXICO | ||
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||
Tantalum | FIR Metals & Resource Ltd. | CHINA | ||
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||
Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | ||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | ||
Tantalum | Telex Metals | UNITED STATES OF AMERICA | ||
Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | ||
Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||
Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||
Tin | Mitsubishi Materials Corporation | JAPAN | ||
Tin | Minsur | PERU | ||
Tin | Mineracao Taboca S.A. | BRAZIL | ||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||
Tin | China Tin Group Co., Ltd. | CHINA | ||
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
4
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||
Tin | Fenix Metals | POLAND | ||
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||
Tin | Dowa | JAPAN | ||
Tin | CV United Smelting | INDONESIA | ||
Tin | Gejiu Jinye Mineral Company | CHINA | ||
Tin | Modeltech Sdn Bhd | MALAYSIA | ||
Tin | PT Bangka Prima Tin | INDONESIA | ||
Tin | Metallo Belgium N.V. | BELGIUM | ||
Tin | PT Rajehan Ariq | INDONESIA | ||
Tin | PT Inti Stania Prima | INDONESIA | ||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||
Tin | CV Venus Inti Perkasa | INDONESIA | ||
Tin | Yunnan Tin Company Limited | CHINA | ||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||
Tin | Thaisarco | THAILAND | ||
Tin | PT Tinindo Inter Nusa | INDONESIA | ||
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | ||
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | ||
Tin | PT Stanindo Inti Perkasa | INDONESIA | ||
Tin | PT Sariwiguna Binasentosa | INDONESIA | ||
Tin | PT Refined Bangka Tin | INDONESIA | ||
Tin | PT Prima Timah Utama | INDONESIA | ||
Tin | PT Mitra Stania Prima | INDONESIA | ||
Tin | PT Eunindo Usaha Mandiri | INDONESIA | ||
Tin | PT DS Jaya Abadi | INDONESIA | ||
Tin | PT Bukit Timah | INDONESIA | ||
Tin | PT Belitung Industri Sejahtera | INDONESIA | ||
Tin | PT Bangka Tin Industry | INDONESIA | ||
Tin | PT Babel Inti Perkasa | INDONESIA | ||
Tin | PT Artha Cipta Langgeng | INDONESIA | ||
Tin | Soft Metais Ltda. | BRAZIL | ||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||
Tin | PT Panca Mega Persada | INDONESIA | ||
Tin | PT Premium Tin Indonesia | INDONESIA | ||
Tin | PT Aries Kencana Sejahtera | INDONESIA | ||
Tin | Alpha | UNITED STATES OF AMERICA | ||
Tin | PT Sukses Inti Makmur | INDONESIA | ||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||
Tin | Melt Metais e Ligas S.A. | BRAZIL | ||
Tin | Magnus Minerais Metais e Ligas Ltda. | BRAZIL | ||
Tin | CV Ayi Jaya | INDONESIA | ||
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||
Tin | PT Sumber Jaya Indah | INDONESIA | ||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||
Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||
Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
5
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | ||
Tin | Metallo Spain S.L.U. | SPAIN | ||
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||
Tin | PT Tommy Utama | INDONESIA | ||
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||
Tin | Super Ligas | BRAZIL | ||
Tin | Estanho de Rondonia S.A. | BRAZIL | ||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company* | VIET NAM | ||
Tin | PT Karimun Mining | INDONESIA | ||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||
Tin | PT Menara Cipta Mulia | INDONESIA | ||
Tin | PT Kijang Jaya Mandiri | INDONESIA | ||
Tin | CV Dua Sekawan | INDONESIA | ||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||
Tin | CV Gita Pesona | INDONESIA | ||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||
Tin | PT O.M. Indonesia | INDONESIA | ||
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||
Tin | PT Babel Surya Alam Lestari | INDONESIA | ||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||
Tungsten | ACL Metais Eireli | BRAZIL | ||
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | ||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | ||
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | ||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
6
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | ||
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | ||
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd. | CHINA | ||
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | ||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | ||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
7
Schedule B
Countries of Origin List
ANDORRA | SAUDI ARABIA | |
AUSTRALIA | SINGAPORE | |
AUSTRIA | SOUTH AFRICA | |
BELGIUM | SPAIN | |
BOLIVIA (PLURINATIONAL STATE OF) | SUDAN | |
BRAZIL | SWEDEN | |
CANADA | SWITZERLAND | |
CHILE | TAIWAN, PROVINCE OF CHINA | |
CHINA | THAILAND | |
CZECH REPUBLIC | TURKEY | |
ESTONIA | UNITED ARAB EMIRATES | |
FRANCE | UNITED STATES OF AMERICA | |
GERMANY | UZBEKISTAN | |
INDIA | VIETNAM | |
INDONESIA | ZAMBIA | |
ITALY | MALAYSIA | |
JAPAN | MEXICO | |
KAZAKHSTAN | NETHERLANDS | |
KOREA, REPUBLIC OF | NEW ZEALAND | |
KYRGYZSTAN | PERU | |
LITHUANIA | PHILIPPINES | |
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | POLAND | |
RUSSIAN FEDERATION |
1