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


FORM SD
SPECIALIZED DISCLOSURE REPORT




UNISYS CORPORATION
(Exact Name of Registrant as Specified in its Charter)

Delaware
 
1-8729
 
38-0387840
(State or Other Jurisdiction of Incorporation)
 
(Commission File Number)
 
(IRS Employer Identification No.)


801 Lakeview Drive, Suite 100
 
 
Blue Bell, Pennsylvania
 
19422
(Address of Principal Executive Offices)
 
(Zip Code)

Gerald P. Kenney: (267) 462-3600
(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:
ý Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.





SECTION 1 - CONFLICT MINERALS DISCLOSURE

ITEM 1.01 CONFLICT MINERALS DISCLOSURE AND REPORT

This Form SD of Unisys Corporation (the "Company") is filed pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 through December 31, 2019.

A copy of the Company's Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD and is also available at the Company’s website, attached as an exhibit to the Company’s most recent Form SD, at https://www.unisys.com/investor-relations/financials-filings/sec-filings.
    
ITEM 1.02 EXHIBIT

The Company's Conflict Minerals report is filed as Exhibit 1.01 to this Form SD.


SECTION 2 - EXHIBITS

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.





SIGNATURE
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.
 
 
 
 
 
UNISYS CORPORATION
 
 
 
Date: May 27, 2020
By:
/s/ Gerald P. Kenney
 
 
Gerald P. Kenney
 
 
Senior Vice President, General Counsel
 
 
and Secretary
 
 
 



Exhibit
Exhibit 1.01

Unisys Corporation
                
Conflict Minerals Report
Reporting Year: 2019
Introduction                                 

Unisys Corporation (“Unisys”) has prepared this Conflict Minerals Report in accordance with Rule 13p-1 of the Securities Exchange Act, as amended to reflect the requirements of Dodd-Frank Wall Street and Consumer Protection Reform Act of 2010. The scope of this document covers the reporting period from January 1 through December 31, 2019.

“Conflict Materials” are defined by the U.S. Securities and Exchange Commission (the “SEC”) as gold, columbite-tantalite, cassiterite, wolframite, and their derivatives - tin, tantalum, and tungsten (collectively referred to as “3TGs”). Rule 13p-1 requires the annual disclosure of certain information when the 3TGs used in the manufacture of a company’s products are known (or are suspected) to originate from certain conflict regions - specifically from the countries of Angola, Burundi, Central African Republic, Democratic Republic of the Congo, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (collectively referred to as “DRC Covered Countries”).

Company & Supply Chain Overview

Unisys is a global information technology (“IT”) company that provides a portfolio of IT services, software, and technology. Unisys operates in two business segments - Services and Technology. In its Technology segment, Unisys develops software and designs systems using commodity servers and server related products.

Many Unisys hardware products require the use of one or more 3TG metals (as detailed in Exhibit A below). These Conflict Minerals are introduced into Unisys products through parts obtained from suppliers, either contract manufacturers or original equipment manufacturers (“OEM”), or from utilization of Conflict Minerals in manufacturing processes employed by Unisys suppliers. Supplier parts obtained by Unisys are utilized in the assembly of Unisys enterprise servers and other electronic equipment. Unisys is not a vertically integrated manufacturer and instead focuses on systems integration through the purchase of higher level assemblies and OEM products. Unisys is therefore several levels removed from the actual mining of Conflict Minerals. Unisys does not make purchases of raw ore or unrefined Conflict Minerals and makes no direct purchases from DRC Covered Countries. In addition, Unisys does not procure directly from smelters or refiners (“SORs”). Unisys does, however, actively support a conflict-free minerals trade policy with DRC Covered Countries from its suppliers. Unisys works with its suppliers to either pursue the development or elimination of SORs that have not achieved RMAP conformance (as defined herein), or are not recognized by RMI as actively working toward compliance.

A copy of Unisys’ Conflict Minerals Policy Statement may be found at the following Unisys website: https://www.unisys.com/about-us/environmental-social-and-governance/conflict-minerals. A copy of the latest Conflict Minerals Report, attached as an exhibit to Unisys’ most recent Form SD, may be found at http://www.unisys.com/investor-relations/financials-filings/sec-filings.
 

1


Due Diligence Process Design

Unisys designed its due diligence process to conform with the framework established for Downstream Supply Chains, as provided by The Organization for Economic Co-operation and Development (“OECD”) “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”. As a downstream company, Unisys does not have direct business relationships with SORs or visibility into the movement of Conflict Minerals between mine locations, SORs, or upstream companies. As such, Unisys relies to a large extent on information obtained from industry sources, as well as information obtained from its in-scope direct suppliers.

Unisys supports and leverages the efforts of the Responsible Business Alliance - Responsible Minerals Initiative (“RMI”), Responsible Minerals Assurance Process (“RMAP”), and Conflict Minerals Reporting Template (“CMRT”), as well as industry sponsored third party audits and independent audits performed by the London Bullion Market Association (“LBMA”) and the Responsible Jewellery Council Chain of Custody Standard (“RJC CoC”), in the analysis of SORs for in scope suppliers utilized by Unisys.

2019 Due Diligence Measures Performed

Following is a summary of the 2019 due diligence measures performed by Unisys - per the 5 Step OECD Due Diligence Guidelines.

Step 1: Establish Strong Company Management Systems

Maintain a Supply Chain Policy for Conflict Minerals Originating from Identified Conflict Regions

A copy of Unisys’ Conflict Minerals Policy is posted at the Unisys Social Responsibility web site (see link above). Implementation of this policy is accomplished via Unisys’ internal ISO9001:2015 Quality Management system within procedures adopted by Unisys’ Global Procurement and Supply Chain Operations groups.

Maintain an Internal Conflict Minerals Team

Unisys maintains an internal Conflict Minerals team, facilitated by a management representative of the U.S. Engineering Resources and Operations organization, and composed of team members representing Commodity Management, Supplier Quality Assurance, and Compliance and Supply Chain Engineering groups. The team is responsible for coordinating and implementing all aspects of the Unisys’ Conflict Minerals program, and for communicating results to Unisys senior management.

Communicate Unisys Conflict Minerals Requirements to Suppliers

Unisys includes in its purchase order standard terms and conditions a clause that states Unisys Conflict Minerals policy and that requires suppliers to disclose to Unisys the existence and origin of any Conflict Minerals in products supplied to Unisys. As an additional measure, Unisys has added a similar clause to its agreement templates for incorporation into applicable new agreements. Unisys agreements continue to be reviewed as they approach renewal, and a similar clause is added as appropriate. Unisys also

2


provides additional written notifications to all in scope suppliers reiterating the Unisys Conflict Minerals Policy and outlining the subject years reporting requirements. For suppliers that have not met previous required reporting obligations, Unisys communicates specifically on required reporting improvements, or alternatively, may choose to eliminate the supplier from the Unisys supply chain.

Provide an On-Line Grievance Mechanism for Conflict Minerals Concerns

Unisys’ Social Responsibility web site contains a link that may be used by concerned parties to communicate Conflict Minerals information to Unisys and/or to report to Unisys corporate management any perceived Conflict Minerals issues.

Retain Records Relating to Supplier Conflict Minerals Performance

Unisys maintains records of relevant supplier correspondence relating to Unisys’ Conflict Minerals program - including supplier provided CMRTs, relevant e-mails, and Unisys Supplier Assessments - per Unisys records retention policies.

Step 2: Identify and Assess Risk in the Supply Chain

Obtain Conflict Minerals Information from In-Scope Unisys Suppliers

Unisys maintains direct contact with each of its in-scope suppliers and requires them to provide information on a minimum annual basis regarding (1) the specific Conflict Minerals contained in parts supplied to Unisys, and (2) the potential source of the Conflict Minerals, including smelter/refinery information. Each supplier is required to submit a completed CMRT covering the most recent reporting period.

Analyze Supplier CMRTs for Accuracy/Completeness, and Communicate Any Issues with Suppliers

Each supplier CMRT is reviewed to determine the completeness, timeliness, and, to the extent possible, the accuracy of its data. For each CMRT, Unisys assesses whether the 3TGs identified are consistent with the technology and complexity of the supplied part(s), and whether the supplier’s responses demonstrate sufficient commitment to conflict-free sourcing principles. Supplier responses judged to be insufficient, questionable, or dated (i.e., > 6 month CMRT date stamp) are followed-up with the supplier, and updated information obtained, as applicable. Any supplier deemed to be non-responsive after one or more follow-up attempts is flagged as a problem supplier that requires either additional training/development, or creation of a plan to remove the subject supplier from the Unisys supply chain.

Develop a Unisys CMRT

A Unisys CMRT, comprised of a roll-up of all supplier provided CMRT data, is developed using a commercially available software package from a major Conflict Minerals service provider. The software package is further used to scrub and refine the smelter data so as to eliminate invalid, erroneous, or duplicate smelter entries, and to identify a final Unisys smelter list.




3


Perform a Reasonable Country of Origin (RCOI) Analysis to Assess the Source of 3TGs

A Reasonable Country of Origin Inquiry (“RCOI”) is performed on the Unisys smelter list to determine, to the extent possible, the mine locations from which each smelter’s ore originates, and whether any of these locations are within DRC Covered Countries. The source of this information is a combination of data obtained from supplier provided CMRTs, as well as data published at smelter web sites, RMI RMAP conformant / RMAP active smelter data, and to a lesser degree, data from third party sources. As a result of Unisys’ RCOI analysis, each SOR is tagged as to whether their 3TG sourcing “Excludes Covered Countries”, “Includes Covered Countries”, is “Unknown”, or is from “100% Scrap/Recycle” sources.

Perform Further Due Diligence on SORs Sourcing from DRC Region

SORs whose RCOI analysis either “Includes Covered Countries” or is “Unknown” are considered candidates for further Unisys due diligence measures. A significant distinction is made by Unisys between SORs who have successfully completed the RMI - RMAP or are actively pursuing RMAP conformance, versus SORs who have chosen not to participate in the program, with the former (RMAP) groups believed to represent a low risk of supporting armed conflict. Unisys due diligence efforts are therefore focused on those SORs who are not currently RMAP conformant or actively working to achieve RMAP conformance, and are therefore considered to be of higher risk.

Unisys due diligence efforts for higher risk smelters involve a thorough review of publically available SOR information, with an emphasis on evidence of support for armed conflict or a history of questionable or unethical business behavior or human rights abuse.

Step 3: Respond to Identified Risks

Identify “At Risk” Smelters and Undertake Mitigation Actions

SORs who are identified to be “at risk” for support of armed conflict or unethical business behavior are brought to the attention of the specific Unisys supplier whose CMRT reported that smelter, and a plan is requested for risk mitigation. The goal of this effort is to either validate the smelter’s intention to pursue RMAP conformance within a prescribed period of time, or alternatively, to eliminate the SOR from potential use in Unisys products.

Report Conflict Minerals Status and Risks to Unisys Supply Chain Management

Unisys due diligence efforts and risk mitigation plans are reviewed with Unisys’ U.S. Engineering Resources and Operations VP and his staff during the course of regularly scheduled compliance review meetings.

Maintain Awareness of Potential Problematic SORs as Reported by Non-Governmental Organizations (“NGOs”) or Third Party Conflict Minerals Service Providers

Unisys’ Conflict Minerals team works to maintain awareness of potentially problematic SORs, as reported by various NGOs or third party Conflict Minerals service providers, and strives to avoid use of these SORs in the Unisys supply chain.


4


Step 4: Carry Out Independent Third Party Audit of Supply Chain Due Diligence

As a downstream supply chain company, Unisys has no direct business relationship with SORs, and relies heavily on independent third party audits performed by RMI’s RMAP, as well as similar third party gold audits performed by the LBMA and the RJC CoC, all of which employ the OECD Due Diligence Guidance process.

Step 5: Report Annually on Supply Chain Due Diligence

In accordance with Rule 13p-1 of the Securities Exchange Act, each year Unisys files with the SEC a Specialized Disclosure Form (“Form SD”) together with an accompanying Conflict Minerals Report (“CMR”). A copy of Unisys’ Conflict Minerals Policy Statement is published on the Unisys Environmental Social and Governance website (see link above).

2019 Due Diligence Findings/Results

For calendar year 2019, Unisys identified a total of 16 in-scope suppliers who provided purchased parts containing one or more Conflict Minerals that were used in the manufacture of Unisys products. Latest revision CMRTs were requested from each of these suppliers, from which Unisys received a total of 16 completed responses (i.e., 100% supplier response rate), covering 100% of Unisys 2019 3TG purchases.

From the 16 CMRTs received, Unisys identified a total of 335 operational SORs that may have processed Conflict Minerals contained in Unisys products. As of April 1, 2020, of the 335 SORs - 264 (79%) were RMAP conformant, 9 (2.7%) were actively pursuing RMAP conformance through participation in either RMI or LBMA Audit processes, while 62 SORs (18.5%) were identified as currently “Non-Participating” in an OECD Guidance based audit program.

A summary of Unisys’ progress in achieving conflict-free SOR status is shown in Table 1 below for the 2016 thru 2019 reporting periods. During the past year, the overall percentage of conflict-free SORs for tin, tantalum and tungsten showed incremental improvements of one to seven percent, due in part to the efforts of Unisys suppliers in eliminating problematic smelters from their supply chains, as well as through Unisys re-sourcing of several key purchased parts from older to newer technologies. However, these gains were offset by an increase in the number of reported new gold smelters, many of which were found to be non-participating in a Conflict Free SOR program. The addition of these new smelters was primarily the result of two suppliers new to Unisys in 2019, for which Unisys had no prior procurement history. The net result was a near-flat 81% total Conflict Free SOR participation rate for 2019 vs the 2018 time period.


5


Unisys remains committed to working with its suppliers to achieve continuous improvement in supply chain performance, especially as new products are introduced, and continues to strive to maximize the percentage of SORs actively participating in the RMI conflict-free program.

Conflict Mineral
Conflict Free SORs vs Total SORs
2016
2017
2018
2019
(Qty)
(%)
(Qty)
(%)
(Qty)
(%)
(Qty)
(%)
Tantalum
47 of 48
98%
41 of 43
95%
41 of 43
95%
41 of 41
100%
Tin
67 of 84
80%
71 of 80
89%
75 of 84
89%
79 of 87
91%
Tungsten
40 of 46
87%
41 of 46
87%
40 of 46
87%
46 of 49
94%
Gold
94 of 136
69%
101 of 147
69%
106 of 149
71%
107 of 158
68%
Total
248 of 314
79%
254 of 316
80%
262 of 322
81%
273 of 335
81%
Table 1 - 2016 through 2019 Conflict-Free & Actively Participating SORs, for Unisys 3TG metals

Unisys RCOI and due diligence investigations for the 62 SORs not currently participating in an OECD Guidance based audit program found no evidence of sourcing from DRC Covered Countries for 56 of the SORs, and confirmed and/or determined that it was likely that the six remaining SORs sourced from DRC Covered Countries. All six of the SORs were additionally identified as higher risk due to prior reported incidences of questionable or unethical business behavior or lax procurement practices, and Unisys is now working to validate that these higher risk suppliers are not in use on Unisys purchased products.

A summary of Unisys progress in eliminating high risk SORs that may have been used in parts supplied to Unisys is shown in Table 2. The total number of identified high risk SORs increased from four to six from during 2019, while the total number of Unisys suppliers reporting the use of these high risk SORs increased from two to three. The cause of these increases was solely due to the addition of two new suppliers to the Unisys supply chain, for which Unisys had no previous procurement experience. The impact of these two new suppliers notwithstanding, the total number of high risk SORs employed by returning Unisys suppliers decreased from four to three during 2019, while the total number of suppliers reporting the use of these high risk SORs decreased from two to one. Unisys is committed to working with its two new suppliers, as well as with the one returning supplier with reported usage of a high risk SOR, to eliminate these problematic smelters from their respective supply chains.

Conflict Mineral
High Risk SORs
Suppliers with High Risk SORs
2018
2019
2015
2016
2017
2018
2019
Tantalum
0
0
0
0
0
0
0
Tin
0
0
10
0
0
0
0
Tungsten
0
0
0
0
0
0
0
Gold
4
6
8
5
3
2
3
Total
4
6
10
5
3
2
3
Table 2 - Number of High Risk SORs & Suppliers employing High Risk SORs, for Unisys products, for reporting periods 2015 through 2019.

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A listing of country of origin information, as collected by Unisys during the 2019 RCOI process, is found in the following Table 3
Argentina
Ecuador
Kyrgyzstan
Nigeria
Sudan
Australia
Ethiopia
Liberia
Panama
Sweden
Austria
France
Madagascar
Peru
Switzerland
Bolivia
Ghana
Malaysia
Philippines
Tanzania
Brazil
Guatemala
Mexico
Poland
Thailand
Burundi
Guinea
Mongolia
Portugal
Turkey
Cambodia
Guyana
Morocco
Republic of Korea
Uganda
Canada
Honduras
Mozambique
Russian Federation
United States
Chile
India
Myanmar
Rwanda
Uzbekistan
China
Indonesia
Namibia
Sierra Leone
Vietnam
Columbia
Japan
New Zealand
South Africa
Zambia
DRC
Kazakhstan
Nicaragua
Spain
Zimbabwe
Table 3 - Potential Countries of Origin for Conflict Minerals used by SORs listed in Exhibit B.

Risk Mitigation - Improvement Program

Following is a list of steps that Unisys has taken or is taking to mitigate the risk that Unisys Conflict Minerals might benefit or finance armed groups:

1.
After review of the High Risk SORs identified during the 2019 due diligence process, it was determined that three Unisys suppliers sourced 3TGs from one or more of the six high risk SORs. Unisys is currently working with these suppliers to better understand the actions being taken relative to the subject high risk SORs, and in parallel to determine if the high risk SORs are used in the creation of Unisys purchased product. The goal of this effort is to either validate the intention of these SORs to achieve RMAP conformance within a prescribed period of time or, alternatively, to eliminate the use of these smelters by the relevant suppliers in the production of product being purchased by Unisys;

2.
Unisys continues to work with its suppliers to maximize the use of conflict-free SORs in the manufacture of Unisys purchased parts, with emphasis on parts used in new Unisys products;

3.
Unisys will continue to maintain awareness of latest industry developments and trends in Conflict Minerals due diligence processes and implement these into the Unisys risk assessment process, as applicable;

4.
Unisys will again request information and supporting data from each supplier providing parts to Unisys that are subject to 2020 reporting requirements by utilizing the CMRT and will pursue completed template responses that identify material down to the smelter and mine;

5.
Unisys will again follow its due diligence process to review and validate supplier responses that

7


are obtained in support of Unisys 2020 Conflict Minerals reporting;

6.
Unisys will continue to provide its Conflict Minerals Policy to suppliers as part of its reporting template-based supplier inquiry process for 2020; and

7.
Unisys will continue to include within its purchase order standard terms and conditions a clause requiring suppliers to disclose to Unisys the existence and origin of any Conflict Minerals in any products supplied to Unisys. A similar clause is being added into new agreements and will be added to agreement renewals as appropriate.

2019 Conflict Minerals Reporting Summary

Although Unisys’ due diligence efforts determined that 329 of 335 SORs that were reported to Unisys from its in scope suppliers for 2019 were either not sourcing Conflict Minerals from DRC Covered Countries or were not supporting armed conflict in the DRC, Unisys was unable to precisely determine the status of the six remaining smelters. Because of concerns around these six remaining SORs, Unisys is taking action to work with these suppliers to identify their plan to eliminate the six SORs from their reported SORs for 2020. Alternatively, if any of the subject 6 smelters will remain in 2020 reporting, Unisys will look to validate that they are not used in the creation of products provided to Unisys.

Product Description and List of Facilities

A list of parts used in Unisys enterprise servers and other electronic equipment for which Unisys solicited supplier information regarding Conflict Mineral content or Conflict Mineral use in production is included in Exhibit A. A list of smelter facilities that, to the extent known, processed Conflict Minerals in Unisys products is included in Exhibit B.




8


CONFLICT MINERALS REPORT
EXHIBIT A
DESCRIPTION OF UNISYS CORPORATION’S 2019 PRODUCTS (PARTS/SUPPLIES)

Product Description (conflict mineral)
Cables & Harnesses * (tin, gold)
Computer Cabinets & Accessories (none)
Computer Products - Servers, Storage, Input/Output & other Peripherals * (tin, tantalum, tungsten, gold)
Displays / Monitors * (tin, tantalum, tungsten, gold)
Fasteners (none)
Flex Circuits * (tin, gold)
Keyboards * (tin, tantalum, tungsten, gold)
Labels (none)
Memory - Modules, * (tin, tantalum, tungsten, gold)
Molded Plastic Parts (none)
Network Switches *(tin, tantalum, tungsten, gold)
Power Strips * (tin, tantalum, tungsten, gold)
Power Supplies * (tin, tantalum, gold)
Printed Circuit Assemblies * (tin, tantalum, tungsten, gold)
Sheet Metal (none)
Electro-mechanical Assemblies * (tin, tantalum, tungsten, gold)
Solder * (tin)
Thermal Transfer Products (none)
Universal Serial Port (USB) Security Devices, Flash cards * (tin, gold)

* Denotes Unisys Products known to contain Conflict Minerals - tin, tantalum, tungsten, or gold




9


CONFLICT MINERALS REPORT
EXHIBIT B
FACILITIES THAT, TO THE EXTENT KNOWN, PROCESSED CONFLICT MINERALS IN UNISYS PRODUCTS
Metal
Facility Name
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 LLC
UNITED ARAB EMIRATES
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
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
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
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
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

10


Metal
Facility Name
Facility Location
Gold
Dowa
JAPAN
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
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 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
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
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
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
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 as
NORWAY
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN

11


Metal
Facility Name
Facility Location
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
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
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
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
Morris and Watson Gold Coast
AUSTRALIA
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

12


Metal
Facility Name
Facility Location
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 Argentia B.V.
NETHERLANDS
Gold
Royal Canadian Mint
CANADA
Gold
SAAMP
FRANCE
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Gold
Safimet S.p.A
ITALY
Gold
SAFINA A.S.
CZECH REPUBLIC
Gold
Sai Refinery
INDIA
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
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

13


Metal
Facility Name
Facility Location
Gold
Tanaka Kikinzoku Kogyo K.K
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
Tony Goetz NV
BELGIUM
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.
BRAZIL
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
Universal Precious Metals Refining Zambia
ZAMBIA
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
Asaka Riken Co., Ltd.
JAPAN
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
CP Metals Inc.
UNITED STATES OF AMERICA
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
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Ltd.
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY

14


Metal
Facility Name
Facility Location
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 Janny New Material Co., Ltd.
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Nonferrous Metals Smelting Company Limited
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Tantalum
LSM Brasil S.A.
BRAZIL
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
Power Resources Ltd.
MACEDONIA
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tin
Alpha
UNITED STATES OF AMERICA
Tin
An Vinh Joint Stock Mineral Processing Company
VIETNAM
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
CV Ayi Jaya
INDONESIA
Tin
CV Dua Sekawan
INDONESIA
Tin
CV Gita Pesona
INDONESIA
Tin
CV Serumpun Sebalai
INDONESIA
Tin
CV Tiga Sekawan
INDONESIA
Tin
CV United Smelting
INDONESIA

15


Metal
Facility Name
Facility Location
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
Tin
Dowa
JAPAN
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIETNAM
Tin
EM Vinto
BOLIVIA
Tin
Estanho de Rondonia S.A.
BRAZIL
Tin
Fenix Metals
POLAND
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
Kundur Smelter
INDONESIA
Tin
Luna Smelter, Ltd.
RWANDA
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
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
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Tin
Pongpipat Company Limited
MYANMAR
Tin
Precious Minerals and Smelting Limited
INDIA

16


Metal
Facility Name
Facility Location
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
PT Babel Inti Perkasa
INDONESIA
Tin
PT Babel Surya Alam Lestari
INDONESIA
Tin
PT Bangka Prima Tin
INDONESIA
Tin
PT Bangka Serumpun
INDONESIA
Tin
PT Bangka Tin Industry
INDONESIA
Tin
PT Belitung Industri Sejahtera
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT DS Jaya Abadi
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA
Tin
PT Karimun Mining
INDONESIA
Tin
PT Kijang Jaya Mandiri
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Rajawali Rimba Perkasa
INDONESIA
Tin
PT Refined Bangka Tin
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
PT Sumber Jaya Indah
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
PT Tirus Putra Mandiri
INDONESIA
Tin
PT Tommy Utama
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.
VIETNAM
Tin
Thaisarco
THAILAND
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA

17


Metal
Facility Name
Facility Location
Tin
Yunnan Tin Company, Ltd.
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
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tungsten
CP Metals Inc.
UNITED STATES OF AMERICA
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten 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
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
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 Dayu Longxintai Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA

18


Metal
Facility Name
Facility Location
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
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIETNAM
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIETNAM
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
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA



19