UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM SD

Specialized Disclosure Report

 

 

Manitex International, Inc.

(Exact name of registrant as specified in its charter)

 

 

 

Michigan		001-32401		42-1628978
(State or other jurisdiction of incorporation or organization)		(Commission File No.)		(I.R.S. Employer Identification No.)

9725 Industrial Drive

Bridgeview, IL 60455

(Address of principal executive offices)(zipcode)

 

 

Laura Yu 708-237-2066

(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, 2019.

 

 

 

SECTION 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

Manitex International, Inc. (the “Company”) undertook a reasonable country of origin inquiry with respect to the conflict minerals used in the production of the Company’s products and has determined in good faith that for the year ended December 31, 2019:

 

a)

The Company has manufactured or contracted to manufacture products as to which tin, tungsten, tantalum and/or gold (herein referred to as 3TGs, for “conflict minerals”1– see footnote) are necessary to the functionality or production of such products.

 

b)

Based on a “reasonable country of origin inquiry” and additional due diligence measures, the Company has reason to believe that a portion of its necessary 3TGs originated or may have originated in the Democratic Republic of the Congo or an adjoining country (collectively, sometimes referred to as the “Covered Countries”) and has reason to believe that those necessary 3TGs may not be from recycled or scrap sources.

The Company’s reasonable country of origin inquiry (RCOI) employed a combination of measures to determine whether the necessary 3TGs in the Company’s products originated from the Covered Countries. The Company’s primary means of determining country of origin of necessary 3TGs was by conducting a supply chain survey with direct suppliers using the RBA-GeSI (Responsible Business Alliance – Global E-Sustainability Initiative) conflict minerals reporting template (“CMRT”), version 5.12 or higher.

In accordance with Rule 13p-1 under the Securities and Exchange Act of 1934 (“Rule 13p-1”), the Company has filed this Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report and both reports are posted to a publicly available Internet site at http://www.manitexinternational.com/secfilings.aspx.

Item 1.02 Exhibit

The Company has included its Conflict Minerals Report as Exhibit 1.01 to this Form SD.

Section 2 Exhibits

Item 2.01 Exhibits

Exhibit 1.01 Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD

 

 

1

The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.

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.

 

Manitex International, Inc. (Registrant)
/s/ Laura Yu
By Laura Yu Senior Vice President Finance and Chief Financial Officer (Principal Financial and Accounting Officer)				May 28, 2020

 

Exhibit 1.01

Manitex International, Inc.

Conflict Minerals Report

For The Year Ended December 31, 2019

Introduction and Summary

This report for the year ended December 31, 2019 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). The Rule was adopted by the Securities and Exchange Commission (“SEC”) and imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. The term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (“3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC (collectively referred to as the “Covered Countries”). Manitex International has reason to believe that some of the 3TGs present in their supply chain may have originated in the Covered Countries. We are unable with absolute assurance to determine the origin of the 3TG in our products and therefore cannot exclude the possibility that some may have originated in the Covered Countries. For that reason, we are required under the Rule to submit to the SEC a Conflict Minerals Report (CMR) as an Exhibit to Form SD.

Manitex International is committed to complying with the requirements of the Rule and upholding responsible sourcing practices. As such, the Company has put into place a robust due diligence program to ensure its contributions to upholding human rights and responsible practices across the supply chain.

Caution Concerning Forward-Looking Statements

Certain statements in this report may be “forward-looking” within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “expects,” “intends,” “plans,” “projects,” “believes,” and “estimates,” “targets,” “anticipates,” and similar expressions are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.

1. Company & Product Overview

The Company is a leading provider of engineered lifting solutions. The Company reports in a single business segment and has five operating segments. The Company designs, manufactures and distributes a diverse group of products that serve different functions and are used in a variety of industries.

Manitex, Inc. (“Manitex”) markets a comprehensive line of boom trucks, truck cranes and sign cranes. Manitex’s boom trucks and crane products are primarily used for industrial projects, energy exploration and infrastructure development, including roads, bridges and commercial construction.

Badger Equipment Company (“Badger”) is a manufacturer of specialized rough terrain cranes and material handling products. Badger primarily serves the needs of the construction, municipality and railroad industries.

PM Oil and Steel S.p.A. (“PM” or “PM Group”), formerly known as PM Group S.p.A., is a leading Italian manufacturer of truck- mounted hydraulic knuckle boom cranes with a 50-year history of technology and innovation, and a product range spanning more than 50 models.

Manitex Valla S.r.L. (“Valla”) produces a full range of precision pick and carry industrial cranes using electric, diesel, and hybrid power options. Its cranes offer wheeled or tracked, and fixed or swing boom configurations, with special applications designed specifically to meet the needs of its customers. These products are sold internationally through dealers and into the rental distribution channel.

Manitex Sabre, Inc. (“Sabre”) manufactures a comprehensive line of specialized mobile tanks for liquid and solid storage and containment solutions with capacities from 8,000 to 21,000 gallons. Its mobile tanks are sold to specialized independent tank rental companies and through the Company’s existing dealer network. The tanks are used in a variety of end markets such as petrochemical, waste management and oil and gas drilling. On March 4, 2020, the Company’s Board of Directors approved the exploration by management of various strategic alternatives for Sabre, including the possibility of a transaction involving the sale of all or part of Sabre’s business and assets, to determine whether such a transaction would provide value to shareholders. The criterion of asset held for sale has been met and Sabre will be reported as discontinued operations in the Company’s financial statements. The Company at this time cannot be sure that any such transaction will occur, and if so, what impact such a transaction would have on the Company’s financial statements.

Crane and Machinery, Inc. (“C&M”) is a distributor of the Company’s products as well as Terex Corporation’s (“Terex”) rough terrain and truck cranes. Crane and Machinery Leasing, Inc. (“C&M Leasing”) rents equipment manufactured by the Company as well as a limited amount of equipment manufactured by third parties. Although C&M is a distributor of Terex rough terrain and truck cranes, C&M’s primary business is the distribution of products manufactured by the Company.

This report has been prepared by management of Manitex International, Inc. (herein referred to as “Manitex International,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries, except as may be noted above.

Our Conflict Minerals Policy can be found on the Manitex International website (http://www.manitexinternational.com/indexm.aspx) under the Investor Relations heading “Code of Ethics” and at: https://www.manitexinternational.com/codeofethics.aspx.

2. Description of RCOI

Manitex International’s reasonable country of origin inquiry (RCOI) employed a combination of measures to determine whether the necessary 3TGs in Manitex International’s products originated from the Covered Countries. Manitex International’s primary means of determining country of origin of necessary 3TGs was by conducting a supply chain survey with direct in-scope suppliers using the RBA-GeSI conflict minerals reporting template (“CMRT”), version 5.12 or higher.

Manitex International, Inc. designs, manufactures and markets a portfolio of highly engineered and customizable lifting equipment, spanning boom truck, telescopic, rough terrain and industrial cranes, and mobile liquid and solid containment solutions, including parts support for all products. C&M is a distributor of Terex rough terrain and truck cranes as well as Manitex’s own products. C&M offers equipment repair services in the Chicago area and supplies repair parts for a wide variety of medium to heavy duty construction equipment both domestically and internationally. C&M Leasing rents equipment manufactured by the Company as well as equipment manufactured by third parties.

To compile a list of suppliers to be contacted for our conflict minerals survey process, in 2013, Manitex International identified well over two thousand potential suppliers supporting our various segments and providing thousands of parts from fully assembled flatbed trucks, which we build our cranes on, to prefabricated steel booms and components as well as hundreds of other parts such as electronic components, electrical wiring, lighting, computers, and other smaller parts which may be integral to the operation and functioning of our completed products. As it is expected that some of our components could contain one or more of the 3TG minerals, it was decided to conduct a survey of all our production related suppliers.

In 2019, Manitex International continued their scoping process of the listing of suppliers from each of its subsidiaries. This list was filtered to remove service providers and any non-product related suppliers.

This process allowed Manitex International to compile a list of 743 suppliers across our various different divisions. The process helped to ensure that all suppliers surveyed provided items to Manitex International that were used in final products in the year 2019. Once the filtering was completed, Manitex International populated the list with contact information and then provided to Assent Compliance for upload to their Assent Compliance Manager SaaS (Software as a Solution) system.

It was deemed appropriate to not further filter this list based on the necessity of the presence of 3TGs in the product as Manitex International could not definitively determine the presence or absence of 3TGs in all parts supplied to them for their products. As part of the CMRT, question 1 allows for further analysis of the supplier, as it asks suppliers whether any of the 3TGs are necessary to the functionality or production of their products. Assent conducts additional analysis of the supply chain and, combined with supplier feedback, suppliers provided a response that allowed Assent and Manitex International to remove these suppliers from the scope of the conflict minerals analysis. The factors considered in Assent’s secondary analysis and the information provided that removed these suppliers from scope include:

 

•

The product they supply is packaging. (Labels do not count as packaging)

 

•

Parts that do not end up in the final product. (This includes equipment used to make the product but is not a part of the actual product itself. i.e. Industrial equipment, computers etc.)

 

•

Test Labs (i.e. Providers that test the resistance or durability of a product).

 

•

Service Providers (i.e. any supplier that provides a service but not an actual physical part).

 

•

Any supplier who has not supplied anything to Manitex International in the last 2 years.

During the supplier survey, suppliers were contacted via the Assent Compliance Manager, a SaaS platform that enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRTs directly to the platform for risk assessment and management. Non-responsive suppliers were contacted a minimum of 3 times by the Assent Compliance Manager and then were also managed by the Assent Compliance Support team in one on one communications.

Assent communications includes training and education on the completion of the CMRT to alleviate any confusion with suppliers. As an improvement to our program, for 2019 we continued to utilize Assent’s Learning Management System, Assent University, and provided all in-scope suppliers access to their Conflict Minerals training course. All suppliers are encouraged to complete all modules within this course. All communications were monitored and tracked in Assent’s system for future reporting and transparency.

Using Assent, we maintained our automated data validation practices on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on:

 

•

Questions 1 and 2 are minimum requirements for the CMRT

 

•

If suppliers state (via Q1 and Q2) that their products do not contain 3TGs necessary to the function or production of said products then no further information is required and no further data validation is completed.

 

•

Question 3 – Do any of your 3TGs originate from the covered countries?

 

•

Any supplier that has any 3TGs from the covered countries, even 1 positive response from their supply chain must answer yes.

 

•

Question 4 – is 100% of the 3TG in question from a recycled source?

 

•

Question 5 – Have you received info from all relevant 3TG Suppliers?

 

•

If you are not at 100%, then you can’t make definitive statements for Questions 3, 4 and 6

 

•

Question 6 – Have you identified all your Smelters?

 

•

If the answer here is yes, then question 5 must be yes. This also impacts question 3.

All submitted forms are accepted and classified as valid or invalid (incorrect) so that data is still retained. Suppliers are contacted in regards to invalid forms and are encouraged to resubmit a valid (corrected) form. As of May 3^rd, 2020, there was 1 invalid supplier submission.

Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the conflict minerals in question.

3. Due Diligence Process

Design of Due Diligence

Our due diligence measures have been designed to conform, in all material respects, with the framework in The Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps.

Due diligence requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot fully be owned by the Company. However, through continued outreach and process validation, this aligns with industry standards and market expectations for downstream companies’ due diligence.

Step 1: Establish Strong Company Management Systems

As described above, Manitex International, Inc. has adopted a company policy which is posted on our website at https://www.manitexinternational.com/codeofethics.aspx

Internal Compliance Team

Manitex International has established a management system for conflict minerals. Our management system includes a steering committee consisting of our Principal Financial Officer and our project leader (our Vice President of Financial Reporting). The project sponsor is our Principal Financial Officer and our team consists of Purchasing and Production Managers from each of our subsidiaries and is supplemented by Assent Compliance. The team is responsible for implementing our conflict minerals compliance strategy and is led by our Vice President of Financial Reporting who acts as the executive conflict minerals program manager. Senior management is briefed about the results of our due diligence efforts periodically.

Control Systems

Controls include, but are not limited to, our Code of Ethics which outlines expected behaviors for all Manitex International’s employees and suppliers. A supplier conflict minerals contract clause is included in our Code of Ethics. We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers.

Supplier Engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have, through Assent, provided education on the Conflict Minerals regulation as well as the expectations of the law and for a continued business relationship, leveraged the existing communications within the company, specifically procurement to encourage their interactions with Assent as well as understand the requirement for completion. Manitex International has leveraged processes in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, obtain help desk support and utilize other multilingual resources. Manitex International’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly file a CMRT. Suppliers receive guidance in their native language, if needed. In addition, our procurement Purchase Order terms and conditions include Conflict Minerals compliance requirements. Feedback from this engagement has allowed us to enhance the training, focus and adapt it to each user’s needs. It has also allowed for our supplier communications to be more focused and ensure expectations are clear.

Grievance Mechanisms

We have multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Manitex International’s policies. Manitex International is committed to supporting responsible sourcing of conflict minerals. As an international company it is our responsibility to create a framework within our corporate structure as to comply with Conflict Minerals reporting rules of section 1502 of the Dodd-Frank Act.

Any Covered Person (any employee of Manitex International and its operating subsidiaries) who becomes aware of a violation or potential violation of the Company’s conflict minerals policy must promptly report that information to a supervisor, to a Board member or via our AlertLine communication system. AlertLine can be accessed on the Internet at http://manitexinternational.alertline.com or by calling 1-877-874-8416 (toll free).

Maintain Records

We have adopted a policy to retain relevant documentation. Documentation will be retained for a period of 5 years. Our Service Provider (Assent Compliance) retains conflict minerals related documents, including supplier responses to CMRTs. This information is stored in a database hosted by our Service Provider.

Step 2: Identifying and Assessing Risks in Our Supply Chain.

In accordance with OECD Guidance, it is important to understand risk levels associated with conflict minerals in the supply chain. Risks are identified automatically in the Assent Compliance Manager system based on criteria established for supplier responses in the system. These risks are addressed by Assent Compliance Supply Chain staff and members of our Conflict Minerals team internally, who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.

The primary risk we identified with respect to the reporting period ended December 31^st, 2019 related to the nature of the responses received. Many the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG in the components supplied to the Company.

Smelters not being certified DRC-Conflict Free pose a significant risk to the supply chain. Certain of the responses provided by suppliers to the CMRT included the names of facilities listed by the suppliers as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the Responsible Minerals Initiative (“RMI”) and, if a supplier indicated that the facility was certified as “Conflict-Free,” confirmed that the name was listed by RMI. As of May 3^rd , 2020, we have validated 307 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primarily supplier-level CMRTs, we cannot definitively determine their connection to the Covered Products.

In the Assent Compliance Manager (the software used in conjunction with the services of our third party service provider), each facility that meets the RMI definition of a smelter or refiner of a 3TG is assigned a risk of High, Medium and Low; this Risk rating is generated based on 5 scoring criteria:

 

•

Responsible Minerals Assurance Process (RMAP) audit status

 

•

Geographic proximity to the DRC and covered countries

 

•

Known or plausible evidence of unethical or conflict sourcing

 

•

Credible evidence of unethical or conflict sourcing;

 

•

Peer Assessments conducted by credible third-party sources.

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

Additionally, suppliers are evaluated on program strength, further assisting in identifying risk in the supply chain. At this stage in Conflict Minerals compliance it is well-known that many companies are in the middle of the process and do not have many answers beyond “unknown”. It has been decided that penalizing or failing them for working through the process is likely not the best approach for the initial years of compliance, it does not meet the goals or spirit of the Rule, however evaluating and tracking the strength of the program does meet the OECD expectation.

Due Diligence Guidelines can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the programs are:

A. Have you established a conflict minerals sourcing policy?

E. Have you implemented due diligence measures for conflict-free sourcing?

G. Do you review due diligence information received from your suppliers against your company’s expectations?

H. Does your review process include corrective action management?

When suppliers meet or exceed these criteria (Yes to at least A, E, G and H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. This program categorization can be used in conjunction with other risk assessment factors to enable Manitex International to properly assess supplier relationships as needed to ensure compliance and risk mitigation. As of May 3^rd, 2020, 100 suppliers were identified as having a weak program.

We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.

Step 3: Design and Implement a Strategy to Respond to Risks

Together with Assent, we developed processes to assess and respond to the risks identified in our supply chain. In response to this risk assessment, the Company has a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to nonresponsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the Conflict Minerals rules. We engage any of our suppliers whom we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD Guidance. Assent also communicates directly with smelters that have not yet been determined to be conformant with the RMAP in order to request sourcing information and encourage their involvement with the RMI program.

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

We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.

Step 5: Publicly Report on Supply Chain Due Diligence

We have published our Form SD for the year ended December 31, 2019 and this report on our website at https://www.manitexinternational.com/sec_filings.aspx

4. Due Diligence Results

Survey Results

For the 2019 Reporting Year, 47% of Manitex International’s suppliers have responded to the supply chain survey via the CMRT, version 5.12 or higher. Of the received CMRTs, 47.3% were considered valid and 0.13% of received CMRTs were considered invalid. Manitex International continues to review its vendor lists and is working with the suppliers to increase the valid response rates.

Metrics are summarized in the table below in order to assess progress over time:

Calendar Year		Suppliers in Scope				% Responded				% Invalid
RY 2019			743				47	%			0.13	%
RY 2018			289				56	%			1.38	%
RY 2017			340				56	%			3.82	%

The large majority of the responses received provided data at a company or divisional level or, as described above, were unable to specify the smelters or refiners used for components supplied to Manitex International. We are therefore unable to determine whether the 3TGs reported by the suppliers were contained in components or parts supplied to us. Furthermore, suppliers did not always provide smelter lists nor were the smelter lists consistently completed with smelter identification numbers and therefore we were unable to validate that any of these smelters or refiners are actually in our supply chain.

Smelters and Refiners

Certain responses provided by suppliers on the CMRT included the names of facilities listed by the suppliers as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Assent compared these facilities listed in the responses to the list of smelters maintained by the Responsible Minerals Initiative (“RMI”) and, if a supplier indicated that the facility was certified as “Conflict-Free,” confirmed that the name was listed by RMI. Of the 307 validated smelters or refiners, 235 are certified to be compliant to RMAP conflict-free protocols. Attached at Appendix A, is a full list of all legitimate smelters or refiners that have been declared by our suppliers. Due to the submission of mostly company-level responses, we are not able to determine if all facilities listed can actually be linked to any Manitex products.

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. As mentioned in the above section, it is understood that many responses may provide more data than can be directly linked to products sold by Manitex International, therefore, Appendix B may contain more countries than those that the Company’s products are being sourced from.

As noted above, the current efforts focus on gathering smelter information via the CMRT and, as the program progresses, requiring full completion of all necessary smelter identification information which will enable the validation and disclosure of the smelters as well as the tracing of the 3TGs to their location of origin. Seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.

5. Steps to be taken to mitigate risk

Our conflict minerals program will continue to focus on vetting smelter and refiner data including:

 

•

Requiring the use of the smelter identification numbers. Supplier responses will not be considered complete without identification numbers.

 

•

Suppliers will also be requested to inform Manitex, through Assent, of the correlation between these smelters or refiners and the products and parts they supply to Manitex International and its in-scope divisions.

 

•

A comparison of the facilities identified to the RMI list of smelters.

 

•

Efforts to determine mine or location of origin.

We also intend to take the following steps to enhance the due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the Covered Countries:

 

•

Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts. We will reemphasize this requirement with our Purchasing Agents.

 

•

Continue to engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses.

 

•

Engage any of our suppliers found to be supplying us with 3TGs from sources that directly or indirectly finance armed conflict in the Covered Countries to determine if an alternative source of 3TGs can be found that do not support such armed conflict.

APPENDIX A: SMELTER LIST

Includes: Mineral, smelter/refinery name, location.

This list includes all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Since most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed below actually processed the 3TGs contained in our products. Therefore, our list of processing smelters and refiners disclosed here may contain more facilities than those that actually processed the conflict minerals contained in our products.

 

Metal		Standard Smelter Name		Smelter Facility Location		Smelter ID
Gold		8853 S.p.A.		ITALY		CID002763
Gold		Abington Reldan Metals, LLC		UNITED STATES OF AMERICA		CID002708
Gold		Advanced Chemical Company		UNITED STATES OF AMERICA		CID000015
Gold		African Gold Refinery		UGANDA		CID003185
Gold		Aida Chemical Industries Co., Ltd.		JAPAN		CID000019
Gold		Al Etihad Gold Refinery DMCC		UNITED ARAB EMIRATES		CID002560
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		GERMANY		CID000035
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		UZBEKISTAN		CID000041
Gold		AngloGold Ashanti Corrego do Sitio Mineracao		BRAZIL		CID000058
Gold		Argor-Heraeus S.A.		SWITZERLAND		CID000077
Gold		Asahi Pretec Corp.		JAPAN		CID000082
Gold		Asahi Refining Canada Ltd.		CANADA		CID000924
Gold		Asahi Refining USA Inc.		UNITED STATES OF AMERICA		CID000920
Gold		Asaka Riken Co., Ltd.		JAPAN		CID000090
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		TURKEY		CID000103
Gold		AU Traders and Refiners		SOUTH AFRICA		CID002850
Gold		Aurubis AG		GERMANY		CID000113
Gold		Bangalore Refinery		INDIA		CID002863
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		PHILIPPINES		CID000128
Gold		Boliden AB		SWEDEN		CID000157
Gold		C. Hafner GmbH + Co. KG		GERMANY		CID000176
Gold		C.I Metales Procesados Industriales SAS		COLOMBIA		CID003421
Gold		Caridad		MEXICO		CID000180
Gold		CCR Refinery - Glencore Canada Corporation		CANADA		CID000185
Gold		Cendres + Metaux S.A.		SWITZERLAND		CID000189
Gold		CGR Metalloys Pvt Ltd.		INDIA		CID003382
Gold		Chimet S.p.A.		ITALY		CID000233
Gold		Chugai Mining		JAPAN		CID000264

Gold		Daye Non-Ferrous Metals Mining Ltd.		CHINA		CID000343
Gold		Degussa Sonne / Mond Goldhandel GmbH		GERMANY		CID002867
Gold		Dijllah Gold Refinery FZC		UNITED ARAB EMIRATES		CID003348
Gold		DODUCO Contacts and Refining GmbH		GERMANY		CID000362
Gold		Dowa		JAPAN		CID000401
Gold		DS PRETECH Co., Ltd.		KOREA, REPUBLIC OF		CID003195
Gold		DSC (Do Sung Corporation)		KOREA, REPUBLIC OF		CID000359
Gold		Eco-System Recycling Co., Ltd. East Plant		JAPAN		CID000425
Gold		Eco-System Recycling Co., Ltd. North Plant		JAPAN		CID003424
Gold		Eco-System Recycling Co., Ltd. West Plant		JAPAN		CID003425
Gold		Emirates Gold DMCC		UNITED ARAB EMIRATES		CID002561
Gold		Fidelity Printers and Refiners Ltd.		ZIMBABWE		CID002515
Gold		Fujairah Gold FZC		UNITED ARAB EMIRATES		CID002584
Gold		GCC Gujrat Gold Centre Pvt. Ltd.		INDIA		CID002852
Gold		Geib Refining Corporation		UNITED STATES OF AMERICA		CID002459
Gold		Gold Coast Refinery		GHANA		CID003186
Gold		Gold Refinery of Zijin Mining Group Co., Ltd.		CHINA		CID002243
Gold		Great Wall Precious Metals Co., Ltd. of CBPM		CHINA		CID001909
Gold		Guangdong Jinding Gold Limited		CHINA		CID002312
Gold		Guoda Safina High-Tech Environmental Refinery Co., Ltd.		CHINA		CID000651
Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.		CHINA		CID000671
Gold		Heimerle + Meule GmbH		GERMANY		CID000694
Gold		Heraeus Metals Hong Kong Ltd.		CHINA		CID000707
Gold		Heraeus Precious Metals GmbH & Co. KG		GERMANY		CID000711
Gold		Hunan Chenzhou Mining Co., Ltd.		CHINA		CID000767
Gold		Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.		CHINA		CID000773
Gold		HwaSeong CJ CO., LTD.		KOREA, REPUBLIC OF		CID000778
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.		CHINA		CID000801
Gold		International Precious Metal Refiners		UNITED ARAB EMIRATES		CID002562
Gold		Ishifuku Metal Industry Co., Ltd.		JAPAN		CID000807
Gold		Istanbul Gold Refinery		TURKEY		CID000814
Gold		Italpreziosi		ITALY		CID002765
Gold		JALAN & Company		INDIA		CID002893
Gold		Japan Mint		JAPAN		CID000823
Gold		Jiangxi Copper Co., Ltd.		CHINA		CID000855

Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		RUSSIAN FEDERATION		CID000927
Gold		JSC Uralelectromed		RUSSIAN FEDERATION		CID000929
Gold		JX Nippon Mining & Metals Co., Ltd.		JAPAN		CID000937
Gold		Kaloti Precious Metals		UNITED ARAB EMIRATES		CID002563
Gold		Kazakhmys Smelting LLC		KAZAKHSTAN		CID000956
Gold		Kazzinc		KAZAKHSTAN		CID000957
Gold		Kennecott Utah Copper LLC		UNITED STATES OF AMERICA		CID000969
Gold		KGHM Polska Miedz Spolka Akcyjna		POLAND		CID002511
Gold		Kojima Chemicals Co., Ltd.		JAPAN		CID000981
Gold		Korea Zinc Co., Ltd.		KOREA, REPUBLIC OF		CID002605
Gold		Kundan Care Products Ltd.		INDIA		CID003463
Gold		Kyrgyzaltyn JSC		KYRGYZSTAN		CID001029
Gold		Kyshtym Copper-Electrolytic Plant ZAO		RUSSIAN FEDERATION		CID002865
Gold		L’azurde Company For Jewelry		SAUDI ARABIA		CID001032
Gold		Lingbao Gold Co., Ltd.		CHINA		CID001056
Gold		Lingbao Jinyuan Tonghui Refinery Co., Ltd.		CHINA		CID001058
Gold		L’Orfebre S.A.		ANDORRA		CID002762
Gold		LS-NIKKO Copper Inc.		KOREA, REPUBLIC OF		CID001078
Gold		LT Metal Ltd.		KOREA, REPUBLIC OF		CID000689
Gold		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.		CHINA		CID001093
Gold		Marsam Metals		BRAZIL		CID002606
Gold		Materion		UNITED STATES OF AMERICA		CID001113
Gold		Matsuda Sangyo Co., Ltd.		JAPAN		CID001119
Gold		Metalor Technologies (Hong Kong) Ltd.		CHINA		CID001149
Gold		Metalor Technologies (Singapore) Pte., Ltd.		SINGAPORE		CID001152
Gold		Metalor Technologies (Suzhou) Ltd.		CHINA		CID001147
Gold		Metalor Technologies S.A.		SWITZERLAND		CID001153
Gold		Metalor USA Refining Corporation		UNITED STATES OF AMERICA		CID001157
Gold		Metalurgica Met-Mex Penoles S.A. De C.V.		MEXICO		CID001161
Gold		Mitsubishi Materials Corporation		JAPAN		CID001188
Gold		Mitsui Mining and Smelting Co., Ltd.		JAPAN		CID001193
Gold		MMTC-PAMP India Pvt., Ltd.		INDIA		CID002509
Gold		Modeltech Sdn Bhd		MALAYSIA		CID002857

Gold		Morris and Watson		NEW ZEALAND		CID002282
Gold		Moscow Special Alloys Processing Plant		RUSSIAN FEDERATION		CID001204
Gold		Nadir Metal Rafineri San. Ve Tic. A.S.		TURKEY		CID001220
Gold		Navoi Mining and Metallurgical Combinat		UZBEKISTAN		CID001236
Gold		NH Recytech Company		KOREA, REPUBLIC OF		CID003189
Gold		Nihon Material Co., Ltd.		JAPAN		CID001259
Gold		Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH		AUSTRIA		CID002779
Gold		Ohura Precious Metal Industry Co., Ltd.		JAPAN		CID001325
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)		RUSSIAN FEDERATION		CID001326
Gold		OJSC Novosibirsk Refinery		RUSSIAN FEDERATION		CID000493
Gold		PAMP S.A.		SWITZERLAND		CID001352
Gold		Pease & Curren		UNITED STATES OF AMERICA		CID002872
Gold		Penglai Penggang Gold Industry Co., Ltd.		CHINA		CID001362
Gold		Planta Recuperadora de Metales SpA		CHILE		CID002919
Gold		Prioksky Plant of Non-Ferrous Metals		RUSSIAN FEDERATION		CID001386
Gold		PT Aneka Tambang (Persero) Tbk		INDONESIA		CID001397
Gold		PX Precinox S.A.		SWITZERLAND		CID001498
Gold		QG Refining, LLC		UNITED STATES OF AMERICA		CID003324
Gold		Rand Refinery (Pty) Ltd.		SOUTH AFRICA		CID001512
Gold		Refinery of Seemine Gold Co., Ltd.		CHINA		CID000522
Gold		REMONDIS PMR B.V.		NETHERLANDS		CID002582
Gold		Royal Canadian Mint		CANADA		CID001534
Gold		SAAMP		FRANCE		CID002761
Gold		Sabin Metal Corp.		UNITED STATES OF AMERICA		CID001546
Gold		Safimet S.p.A		ITALY		CID002973
Gold		SAFINA A.S.		CZECH REPUBLIC		CID002290
Gold		Sai Refinery		INDIA		CID002853
Gold		Samduck Precious Metals		KOREA, REPUBLIC OF		CID001555
Gold		Samwon Metals Corp.		KOREA, REPUBLIC OF		CID001562
Gold		SAXONIA Edelmetalle GmbH		GERMANY		CID002777
Gold		SEMPSA Joyeria Plateria S.A.		SPAIN		CID001585
Gold		Shandong Humon Smelting Co., Ltd.		CHINA		CID002525
Gold		Shandong Tiancheng Biological Gold Industrial Co., Ltd.		CHINA		CID001619

Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.		CHINA		CID001622
Gold		Shirpur Gold Refinery Ltd.		INDIA		CID002588
Gold		Sichuan Tianze Precious Metals Co., Ltd.		CHINA		CID001736
Gold		Singway Technology Co., Ltd.		TAIWAN, PROVINCE OF CHINA		CID002516
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		RUSSIAN FEDERATION		CID001756
Gold		Solar Applied Materials Technology Corp.		TAIWAN, PROVINCE OF CHINA		CID001761
Gold		Sovereign Metals		INDIA		CID003383
Gold		State Research Institute Center for Physical Sciences and Technology		LITHUANIA		CID003153
Gold		Sudan Gold Refinery		SUDAN		CID002567
Gold		Sumitomo Metal Mining Co., Ltd.		JAPAN		CID001798
Gold		SungEel HiMetal Co., Ltd.		KOREA, REPUBLIC OF		CID002918
Gold		T.C.A S.p.A		ITALY		CID002580
Gold		Tanaka Kikinzoku Kogyo K.K.		JAPAN		CID001875
Gold		The Refinery of Shandong Gold Mining Co., Ltd.		CHINA		CID001916
Gold		Tokuriki Honten Co., Ltd.		JAPAN		CID001938
Gold		Tongling Nonferrous Metals Group Co., Ltd.		CHINA		CID001947
Gold		Tony Goetz NV		BELGIUM		CID002587
Gold		TOO Tau-Ken-Altyn		KAZAKHSTAN		CID002615
Gold		Torecom		KOREA, REPUBLIC OF		CID001955
Gold		Umicore Brasil Ltda.		BRAZIL		CID001977
Gold		Umicore Precious Metals Thailand		THAILAND		CID002314
Gold		Umicore S.A. Business Unit Precious Metals Refining		BELGIUM		CID001980
Gold		United Precious Metal Refining, Inc.		UNITED STATES OF AMERICA		CID001993
Gold		Valcambi S.A.		SWITZERLAND		CID002003
Gold		Western Australian Mint (T/a The Perth Mint)		AUSTRALIA		CID002030
Gold		WIELAND Edelmetalle GmbH		GERMANY		CID002778
Gold		Yamakin Co., Ltd.		JAPAN		CID002100
Gold		Yokohama Metal Co., Ltd.		JAPAN		CID002129
Gold		Yunnan Copper Industry Co., Ltd.		CHINA		CID000197
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		CHINA		CID002224
Tantalum		Asaka Riken Co., Ltd.		JAPAN		CID000092
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		CHINA		CID000211
Tantalum		CP Metals Inc.		UNITED STATES OF AMERICA		CID003402

Tantalum		D Block Metals, LLC		UNITED STATES OF AMERICA		CID002504
Tantalum		Exotech Inc.		UNITED STATES OF AMERICA		CID000456
Tantalum		F&X Electro-Materials Ltd.		CHINA		CID000460
Tantalum		FIR Metals & Resource Ltd.		CHINA		CID002505
Tantalum		Global Advanced Metals Aizu		JAPAN		CID002558
Tantalum		Global Advanced Metals Boyertown		UNITED STATES OF AMERICA		CID002557
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		CHINA		CID000616
Tantalum		H.C. Starck Co., Ltd.		THAILAND		CID002544
Tantalum		H.C. Starck Hermsdorf GmbH		GERMANY		CID002547
Tantalum		H.C. Starck Inc.		UNITED STATES OF AMERICA		CID002548
Tantalum		H.C. Starck Ltd.		JAPAN		CID002549
Tantalum		H.C. Starck Smelting GmbH & Co. KG		GERMANY		CID002550
Tantalum		H.C. Starck Tantalum and Niobium GmbH		GERMANY		CID002545
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		CHINA		CID002492
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		CHINA		CID002512
Tantalum		Jiangxi Tuohong New Raw Material		CHINA		CID002842
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		CHINA		CID000914
Tantalum		Jiujiang Tanbre Co., Ltd.		CHINA		CID000917
Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		CHINA		CID002506
Tantalum		KEMET Blue Metals		MEXICO		CID002539
Tantalum		LSM Brasil S.A.		BRAZIL		CID001076
Tantalum		Metallurgical Products India Pvt., Ltd.		INDIA		CID001163
Tantalum		Mineracao Taboca S.A.		BRAZIL		CID001175
Tantalum		Mitsui Mining and Smelting Co., Ltd.		JAPAN		CID001192
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		CHINA		CID001277
Tantalum		NPM Silmet AS		ESTONIA		CID001200
Tantalum		PRG Dooel		NORTH MACEDONIA, REPUBLIC OF		CID002847
Tantalum		QuantumClean		UNITED STATES OF AMERICA		CID001508
Tantalum		Resind Industria e Comercio Ltda.		BRAZIL		CID002707
Tantalum		Solikamsk Magnesium Works OAO		RUSSIAN FEDERATION		CID001769
Tantalum		Taki Chemical Co., Ltd.		JAPAN		CID001869

Tantalum		Telex Metals		UNITED STATES OF AMERICA		CID001891
Tantalum		Ulba Metallurgical Plant JSC		KAZAKHSTAN		CID001969
Tantalum		XinXing HaoRong Electronic Material Co., Ltd.		CHINA		CID002508
Tantalum		Yanling Jincheng Tantalum & Niobium Co., Ltd.		CHINA		CID001522
Tin		Alpha		UNITED STATES OF AMERICA		CID000292
Tin		An Vinh Joint Stock Mineral Processing Company		VIET NAM		CID002703
Tin		Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.		CHINA		CID000228
Tin		Chifeng Dajingzi Tin Industry Co., Ltd.		CHINA		CID003190
Tin		China Tin Group Co., Ltd.		CHINA		CID001070
Tin		Dongguan CiEXPO Environmental Engineering Co., Ltd.		CHINA		CID003356
Tin		Dowa		JAPAN		CID000402
Tin		Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company		VIET NAM		CID002572
Tin		EM Vinto		BOLIVIA (PLURINATIONAL STATE OF)		CID000438
Tin		Estanho de Rondonia S.A.		BRAZIL		CID000448
Tin		Fenix Metals		POLAND		CID000468
Tin		Gejiu City Fuxiang Industry and Trade Co., Ltd.		CHINA		CID003410
Tin		Gejiu Kai Meng Industry and Trade LLC		CHINA		CID000942
Tin		Gejiu Non-Ferrous Metal Processing Co., Ltd.		CHINA		CID000538
Tin		Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.		CHINA		CID001908
Tin		Gejiu Zili Mining And Metallurgy Co., Ltd.		CHINA		CID000555
Tin		Guangdong Hanhe Non-Ferrous Metal Co., Ltd.		CHINA		CID003116
Tin		Guanyang Guida Nonferrous Metal Smelting Plant		CHINA		CID002849
Tin		HuiChang Hill Tin Industry Co., Ltd.		CHINA		CID002844
Tin		Huichang Jinshunda Tin Co., Ltd.		CHINA		CID000760
Tin		Jiangxi New Nanshan Technology Ltd.		CHINA		CID001231
Tin		Luna Smelter, Ltd.		RWANDA		CID003387
Tin		Ma’anshan Weitai Tin Co., Ltd.		CHINA		CID003379
Tin		Magnu’s Minerais Metais e Ligas Ltda.		BRAZIL		CID002468
Tin		Malaysia Smelting Corporation (MSC)		MALAYSIA		CID001105
Tin		Melt Metais e Ligas S.A.		BRAZIL		CID002500
Tin		Metallic Resources, Inc.		UNITED STATES OF AMERICA		CID001142
Tin		Metallo Belgium N.V.		BELGIUM		CID002773

Tin		Metallo Spain S.L.U.		SPAIN		CID002774
Tin		Mineracao Taboca S.A.		BRAZIL		CID001173
Tin		Minsur		PERU		CID001182
Tin		Mitsubishi Materials Corporation		JAPAN		CID001191
Tin		Modeltech Sdn Bhd		MALAYSIA		CID002858
Tin		Nghe Tinh Non-Ferrous Metals Joint Stock Company		VIET NAM		CID002573
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		THAILAND		CID001314
Tin		O.M. Manufacturing Philippines, Inc.		PHILIPPINES		CID002517
Tin		Operaciones Metalurgicas S.A.		BOLIVIA (PLURINATIONAL STATE OF)		CID001337
Tin		Pongpipat Company Limited		MYANMAR		CID003208
Tin		Precious Minerals and Smelting Limited		INDIA		CID003409
Tin		PT Artha Cipta Langgeng		INDONESIA		CID001399
Tin		PT ATD Makmur Mandiri Jaya		INDONESIA		CID002503
Tin		PT Menara Cipta Mulia		INDONESIA		CID002835
Tin		PT Mitra Stania Prima		INDONESIA		CID001453
Tin		PT Refined Bangka Tin		INDONESIA		CID001460
Tin		PT Timah Tbk Kundur		INDONESIA		CID001477
Tin		PT Timah Tbk Mentok		INDONESIA		CID001482
Tin		Resind Industria e Comercio Ltda.		BRAZIL		CID002706
Tin		Rui Da Hung		TAIWAN, PROVINCE OF CHINA		CID001539
Tin		Soft Metais Ltda.		BRAZIL		CID001758
Tin		Super Ligas		BRAZIL		CID002756
Tin		Thai Nguyen Mining and Metallurgy Co., Ltd.		VIET NAM		CID002834
Tin		Thaisarco		THAILAND		CID001898
Tin		Tin Technology & Refining		UNITED STATES OF AMERICA		CID003325
Tin		Tuyen Quang Non-Ferrous Metals Joint Stock Company		VIET NAM		CID002574
Tin		White Solder Metalurgia e Mineracao Ltda.		BRAZIL		CID002036
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		CHINA		CID002158
Tin		Yunnan Tin Company Limited		CHINA		CID002180
Tin		Yunnan Yunfan Non-ferrous Metals Co., Ltd.		CHINA		CID003397
Tungsten		A.L.M.T. Corp.		JAPAN		CID000004
Tungsten		ACL Metais Eireli		BRAZIL		CID002833
Tungsten		Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.		BRAZIL		CID003427

Tungsten		Asia Tungsten Products Vietnam Ltd.		VIET NAM		CID002502
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		CHINA		CID002513
Tungsten		China Molybdenum Co., Ltd.		CHINA		CID002641
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		CHINA		CID000258
Tungsten		CNMC (Guangxi) PGMA Co., Ltd.		CHINA		CID000281
Tungsten		CP Metals Inc.		UNITED STATES OF AMERICA		CID003448
Tungsten		Fujian Ganmin RareMetal Co., Ltd.		CHINA		CID003401
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		CHINA		CID000499
Tungsten		Ganzhou Haichuang Tungsten Co., Ltd.		CHINA		CID002645
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		CHINA		CID000875
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		CHINA		CID002315
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		CHINA		CID002494
Tungsten		GEM Co., Ltd.		CHINA		CID003417
Tungsten		Global Tungsten & Powders Corp.		UNITED STATES OF AMERICA		CID000568
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		CHINA		CID000218
Tungsten		H.C. Starck Smelting GmbH & Co. KG		GERMANY		CID002542
Tungsten		H.C. Starck Tungsten GmbH		GERMANY		CID002541
Tungsten		Hunan Chenzhou Mining Co., Ltd.		CHINA		CID000766
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		CHINA		CID002579
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		CHINA		CID000769
Tungsten		Hunan Litian Tungsten Industry Co., Ltd.		CHINA		CID003182
Tungsten		Hydrometallurg, JSC		RUSSIAN FEDERATION		CID002649
Tungsten		Japan New Metals Co., Ltd.		JAPAN		CID000825
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		CHINA		CID002551
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		CHINA		CID002321
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		CHINA		CID002313
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		CHINA		CID002318
Tungsten		Jiangxi Xianglu Tungsten Co., Ltd.		CHINA		CID002647
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		CHINA		CID002317
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		CHINA		CID002316
Tungsten		JSC “Kirovgrad Hard Alloys Plant”		RUSSIAN FEDERATION		CID003408
Tungsten		Kennametal Fallon		UNITED STATES OF AMERICA		CID000966
Tungsten		Kennametal Huntsville		UNITED STATES OF AMERICA		CID000105

Tungsten		KGETS Co., Ltd.		KOREA, REPUBLIC OF		CID003388
Tungsten		Lianyou Metals Co., Ltd.		TAIWAN, PROVINCE OF CHINA		CID003407
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		CHINA		CID002319
Tungsten		Masan Tungsten Chemical LLC (MTC)		VIET NAM		CID002543
Tungsten		Moliren Ltd.		RUSSIAN FEDERATION		CID002845
Tungsten		Niagara Refining LLC		UNITED STATES OF AMERICA		CID002589
Tungsten		NPP Tyazhmetprom LLC		RUSSIAN FEDERATION		CID003416
Tungsten		Philippine Chuangxin Industrial Co., Inc.		PHILIPPINES		CID002827
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		VIET NAM		CID001889
Tungsten		Unecha Refractory metals plant		RUSSIAN FEDERATION		CID002724
Tungsten		Wolfram Bergbau und Hutten AG		AUSTRIA		CID002044
Tungsten		Woltech Korea Co., Ltd.		KOREA, REPUBLIC OF		CID002843
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		CHINA		CID002320
Tungsten		Xiamen Tungsten Co., Ltd.		CHINA		CID002082
Tungsten		Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.		CHINA		CID002830
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		CHINA		CID002095

APPENDIX B: COUNTRIES OF ORIGIN

Includes: List of countries that declared smelters are known to source from.

Afghanistan

Albania

Angola

Argentina

Armenia

Australia

Austria

Belarus

Belgium

Bermuda

Bolivia

Brazil

Bulgaria

Burundi

Cambodia

Canada

Central African Republic

Chile

China

Colombia

Czech Republic

Djibouti

Dominican Republic

DRC or an adjoining country (Covered Countries)

Ecuador

Egypt

England

Estonia

Ethiopia

Finland

France

Germany

Ghana

Guinea

Guyana

Hungary

India

Indonesia

Ireland

Israel

Italy

Ivory Coast

Japan

Kazakhstan

Kenya

Kyrgyzstan

Laos

Liberia

Lithuania

Luxembourg

Madagascar

Malaysia

Mali

Mauritania

Mexico

Mongolia

Morocco

Mozambique

Myanmar

Namibia

Netherlands

New Zealand

Niger

Nigeria

Papua New Guinea

Peru

Philippines

Poland

Portugal

Republic

Republic Of Korea

Russia

Rwanda

Saudi Arabia

Sierra Leone

Singapore

Slovakia

Slovenia

South Africa

Spain

Sudan

Suri

Suriname

Sweden

Switzerland

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