UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM SD

 

 

SPECIALIZED DISCLOSURE REPORT

 

 

 

IMAX Corporation

(Exact name of the registrant as specified in its charter)

 

 

 

Canada   001-35066   98-0140269

(State or other jurisdiction of

incorporation or organization)

 

(Commission

File Number)

 

(IRS Employer

Identification No.)

 

2525 Speakman Drive,   902 Broadway, Floor 20
Mississauga, ON, Canada L5K 1B1   New York, New York, USA 10010

(Address of principal executive offices) (Zip code)

Robert D. Lister, Chief Legal Officer and Senior Executive Vice President

212-821-0100

(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

Items 1.01 and 1.02            Conflict Minerals Disclosures and Report, Exhibit

IMAX Corporation (the “Company” or “IMAX”) has filed a Conflict Minerals Report which is provided as Exhibit 1.01 hereto and is also available on the Governance page of the Company’s Investor Relations website at http://www.imax.com/content/investor-relations.1

Section 2 – Exhibits

 

Item 2.01

Exhibits

The following exhibit is filed as part of this report.

Exhibit 1.01 – Conflict Minerals Report for the year ended December 31, 2019

Cautionary Note Regarding Forward-Looking Statements

This Specialized Disclosure Report on Form SD, including the Conflict Minerals Report exhibit, contains forward-looking statements that are based upon management’s expectations and beliefs concerning future events. Certain matters contained herein concerning the future, including risk mitigation steps, constitute forward-looking statements and are based upon management’s expectations and beliefs concerning future events impacting the Company’s efforts to improve its due diligence and risk mitigation strategies relating to any conflict minerals used in the Company’s manufacture or contract to manufacture activities. There can be no assurance that these future events will occur as anticipated. Forward-looking statements speak only as of the date they were made, and the Company undertakes no obligation to publicly update them. For a description of certain factors that could cause the Company’s future results to differ materially from those expressed in any forward-looking statement, see Item 1A of the Company’s Annual Report on Form 10-K for the year ended December 31, 2019 entitled “Risk Factors.”

 

 

 

1 

The reference to the Company’s Investor Relations website is provided for convenience only, and its contents are not incorporated by reference into this Form SD or the Conflict Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.


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.

 

    IMAX CORPORATION
    (Registrant)
Date: May 29, 2020     By:   /s/ Robert D. Lister
      Robert D. Lister
      Chief Legal Officer & Senior Executive Vice President
Date: May 29, 2020     By:   /s/ Kenneth Weissman
      Kenneth Weissman
      Senior Vice President, Legal Affairs and Corporate Secretary

 

EX-1.01

Exhibit 1.01

IMAX CORPORATION

Conflict Minerals Report

For the Year Ended December 31, 2019

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 (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of such products. The term “conflict mineral” is defined in Form SD under the SEC’s conflict mineral rules 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 which are limited to tantalum, tin, and tungsten, unless the Secretary of State determines that additional derivatives are financing conflict in the Democratic Republic of the Congo or an adjoining country 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 (the “DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The adjoining countries include: the Republic of the Congo, the Central African Republic, South Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania and Angola.

Tin, tungsten, tantalum and gold will herein be referred to as the “3TGs”.

Pursuant to the Rule, IMAX Corporation (herein referred to as “IMAX” or the “Company”) has undertaken a reasonable country of origin inquiry (“RCOI”) for products manufactured or contracted to be manufactured by IMAX during calendar year 2019. In response to representations from certain of its suppliers obtained in the course of the RCOI, IMAX has conducted due diligence on the source and chain of custody of the necessary 3TGs in its products that it had reason to believe could have originated from the DRC or an adjoining country (collectively, the “Covered Countries”). For that reason, IMAX is required under the Rule to undertake due diligence and to submit to the SEC a Conflict Minerals Report as an Exhibit to Form SD.

This report has been prepared by management of IMAX. The information includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated. It does not include the activities of variable interest entities that are not required to be consolidated.

References herein to the Company’s Investor Relations website are provided for convenience only, and its contents are not incorporated by reference into this Conflict Minerals Report nor deemed filed with the SEC.

 

1.

Company Overview

IMAX is one of the world’s leading entertainment technology companies, specializing in technological innovations powering the presentation of some of today’s most immersive entertainment experiences. The Company leverages its innovative technology and engineering in all aspects of its business, which principally consists of (1) the digital remastering of films and other presentations into the IMAX format by enhancing their image resolution and sound quality for exhibition in the IMAX network; and (2) the sale or lease of premium IMAX theater systems (“IMAX theater systems”) to exhibitor customers. The IMAX theater systems contain many electronic components, which in turn contain 3TGs that are necessary to their functionality or production.

 

2.

Supply Chain

IMAX develops and designs all of the key elements of the proprietary technology involved in IMAX theater systems. Fabrication of a majority of parts and sub-assemblies, however, is subcontracted to a group of third-party suppliers. IMAX is therefore a purchaser of parts, components and manufactured products that are many steps downstream in the minerals supply chain. As a result, IMAX’s due diligence measures can provide only reasonable and not absolute assurance regarding the source and chain of custody of the necessary 3TGs. IMAX’s due diligence processes are based on the necessity of seeking data from its direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary 3TGs.


3.

Product Description

IMAX theater systems may contain conflict minerals within the following components:

 

   

Tantalum, primarily used in capacitors;

 

   

Tin, used in soldered components;

 

   

Tungsten, used in lamp electrodes (solely for non-laser based IMAX theater systems); and

 

   

Gold, used in circuit boards, electrodes, connectors and electronic components.

 

4.

Reasonable Country of Origin Inquiry

IMAX has engaged a third-party service provider, Assent Compliance (“Assent”), to assist with its conflict minerals program. For 2019, IMAX began its RCOI by compiling a list of suppliers, which was extracted from the Company’s vendor list. The list was then filtered to ensure that all suppliers surveyed by the Company actually provided items that were used in final products in 2019. Specifically, the list was filtered to remove:

 

   

Service providers/suppliers;

 

   

Indirect materials suppliers; and

 

   

Inactive suppliers (minimum 1 year since last purchase).

The filtered list was composed of 432 suppliers, which was provided to Assent and uploaded to Assent’s Compliance Manager software system (“Assent Compliance Manager”). The Assent Compliance Manager is a SaaS platform provided by Assent that enables its users to complete and track supplier communications as well as allow in-scope suppliers to upload completed Conflict Mineral Report Templates (“CMRTs”) directly to the platform for validation, assessment and management. The Assent Compliance Manager also provides functionality that meets the OECD Guidance (as defined below) process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement.

Assent conducted additional analysis of the supply chain which, combined with supplier feedback, resulted in 7 additional suppliers being removed from the scope of the conflict minerals inquiry. These suppliers were removed based on the following factors, which were provided either directly by the suppliers or through Assent’s secondary analysis:

 

   

Whether a supplied product was merely packaging (labels do not count as packaging);

 

   

Whether the parts a supplier used did not end up in the final product (e.g., such as equipment used to make the product, including industrial equipment, computers, etc.);

 

   

Whether a supplier used test labs to determine, for example, the resistance or durability of a product;

 

   

Whether a supplier was solely a service provider; and

 

   

Whether a supplier supplied anything to IMAX in the last year.

After limiting the scope of inquiry, Assent conducted the supplier survey portion of the RCOI. The supplier survey utilized a template developed by the Responsible Minerals Initiative (“RMI”) called the CMRT. The CMRT was developed to facilitate general disclosures and information regarding smelters or refiners that provide materials to the supplier. It includes questions regarding the supplier’s conflict minerals policy, the engagement process with its direct suppliers and identification of the smelters or refiners used by the supplier. Suppliers were contacted a minimum of three times by the Assent Compliance Manager. Non-responsive suppliers were also contacted by Assent on a one-on-one basis, with two follow-ups. Communications from Assent also included training and education on completion of the CMRT, as well as access to a resource center for suppliers designed to answer questions. All communications with suppliers were monitored and tracked in Assent’s system for future reporting and transparency.

For calendar year 2019, IMAX’s program continued to include automated data validation on all submitted CMRTs. The goal of automated data validation is to increase the accuracy of submissions and to identify any contradictory answers provided in a CMRT. All submitted forms are accepted so that data is retained and classified as valid or invalid. Suppliers who submit invalid forms are contacted and are encouraged to resubmit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help.


After completing the RCOI, IMAX then implemented due diligence measures on the source and chain of custody of such conflict minerals, as further described below.

 

5.

Due Diligence

As a result of the RCOI, IMAX has reason to believe that some of the 3TG minerals included in IMAX theater systems may have originated in the Covered Countries. Therefore, IMAX conducted supply chain due diligence on the source and chain of custody of the minerals, in a manner consistent with the framework promulgated by the Organisation for Economic Co-operation and Development (“OECD”) and its Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas, including the related supplements on gold, tin, tantalum and tungsten (“OECD Guidance”), an internationally recognized due diligence framework. The OECD Guidance identifies five steps for due diligence that should be implemented and provides guidance on how to achieve each step. IMAX developed a due diligence process to address each of these five steps, namely:

 

  1.

Establishing strong company management systems regarding conflict minerals;

 

  2.

Identifying and assessing risks in our supply chain;

 

  3.

Designing and implementing a strategy to respond to identified risks in our supply chain;

 

  4.

Utilizing independent third-party audits of supply chain diligence; and

 

  5.

Publicly reporting on our supply chain due diligence

 

5.1

Establish Strong Company Management Systems

 

5.1.1

Conflict Minerals Policy

IMAX first adopted a Conflict Minerals Policy in 2014 committed to addressing the concern that certain minerals that are contained in IMAX theater systems may contribute to the funding of military conflict and human rights violations in the Covered Countries. The policy is reviewed and updated on a periodic basis and was most recently revised in September 2019. Through this policy, IMAX has encouraged its suppliers and sub-suppliers to responsibly source 3TGs. This policy is available publicly on the Governance page of the Company’s Investor Relations website at http://www.imax.com/content/investor-relations.

 

5.1.2

Internal Team and Third-Party Service Provider

To ensure compliance with the Conflict Minerals Policy, IMAX established an internal management system to support the conflict minerals team, which includes representatives from IMAX’s technology, supply chain management and legal teams. The conflict minerals team is responsible for implementing IMAX’s conflict minerals program. Management, including senior members of the technology and procurement groups, are briefed about issues arising under the Company’s conflict minerals compliance program.

The Company also used Assent, a third-party service provider, to assist with evaluating supply chain information regarding 3TGs and identifying potential risks, as well as to assist in the development and implementation of additional due diligence steps for the Company to undertake with suppliers regarding conflict minerals.

 

5.1.3

Control Systems

Controls adopted include, but are not limited to, IMAX’s Code of Business Conduct and Ethics, which outlines expected behaviors for all IMAX employees, IMAX’s Conflicts Minerals Policy, the IMAX Supplier Compliance Document, and supplier conflict minerals contract clauses as further described below.

A number of parts contained in IMAX’s products are commercial, off-the-shelf (“COTS”) components. Each new purchase order for COTS components requires that the supplier assist the Company in implementing its Conflict Minerals Policy, such as by completing the CMRT. IMAX further compiles a list of all unique COTS items contained in IMAX products and contacts the manufacturers of each COTS items to request completion of the CMRT.


IMAX also contracts with various suppliers for fabricated assemblies. Based on drawings provided by IMAX, suppliers fabricate a portion of these assemblies from various materials, such as metal for enclosures. All metal fabrication drawings generated by IMAX specifically state the materials used are to be conflict-free. These fabricated assemblies are in turn used by IMAX in the assembly of its products. All new purchase agreements for the manufacturing of assemblies incorporated into IMAX products contain clauses that require suppliers to assist IMAX in implementing its Conflict Minerals Policy, such as by completing the CMRT. However, contracts with the Company’s direct suppliers are frequently multi-year term contracts. In the case of existing contracts, the Company generally is unable to unilaterally impose new contract terms prior to expiration of the contract. However, IMAX works individually with key selected suppliers to ensure they provide 3TG sourcing information for current contracts. As the Company renews contracts or enters into new ones, it intends to add a clause that requires all applicable suppliers assist IMAX in implementing its Conflict Minerals Policy.

 

5.1.4

Supplier Engagement

With respect to the OECD Guidance requirement to strengthen engagement with suppliers, IMAX has, through Assent, provided education on conflict minerals regulation as well as communicated IMAX’s expectations of the parties’ continued business relationship through video, recorded training and documented instructions. IMAX utilizes Assent’s learning management system, Assent University, and provides all of its in-scope suppliers with access to conflict minerals training courses available through such program. Feedback from engagement with suppliers has further allowed IMAX to enhance the supplier training, and to ensure that communications with the Company’s suppliers are focused and adapted appropriately to each supplier. The Company has also leveraged processes and educational opportunities available through Assent in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support and other multilingual resources.

 

5.1.5

Grievance Mechanism

In the event of an actual or possible violation of the Company’s policies, including the Company’s Conflict Minerals Policy, employees (internal) and suppliers (external) can report violations as part of the Company’s whistleblower protocol for reporting suspected violations of the IMAX Code of Business Conduct and Ethics. The Company’s Code of Business Conduct and Ethics provides the method by which such reports can be made and is available on the Governance page of the Company’s Investor Relations website at http://www.imax.com/content/investor-relations.

 

5.1.6

Maintain Records

Assent has implemented a document retention policy and maintains all relevant documentation in a database that can be audited by internal or external parties for a minimum of five years, as per the OECD Guidance.

 

5.2

Identify and Assess Risk in the Supply Chain

Because of IMAX’s size, the complexity of its products, and the depth, breadth and constant evolution of its supply chain, it is difficult to identify actors upstream from the Company’s direct suppliers. The majority of IMAX’s direct suppliers who were asked to submit a CMRT and who provided a CMRT identified their components and products as containing 3TGs. These suppliers are relied upon to provide IMAX with information about the source of 3TGs contained in the components and products supplied to us.

Risks are identified based on criteria established for supplier responses in IMAX’s conflict minerals compliance system. Specifically, with assistance from Assent, supplier risk is classified as high, medium or low based on various scoring criteria, including: (1) whether there is known or plausible evidence of unethical or conflict sourcing by the smelter or refiner; (2) an analysis of the smelter or refiner country and its proximity to Covered Countries; (3) the smelter or refiner’s audit status with the RMI’s Responsible Minerals Assurance Process (“RMAP”); (4) known mineral source country of origin; and (5) whether peer assessments were conducted by credible third-party sources. Where a smelter or refiner is claimed to be “conflict-free”, the facility is cross-referenced against the lists maintained by the RMI. In cases where IMAX identifies supplier risk, IMAX will contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.

If any of IMAX’s direct suppliers report a high-risk smelter on its CMRT, Assent will request that the supplier in question provide a product-level and/or user-defined CMRT. This helps to enable IMAX to determine if there is any connection between IMAX theater systems and the high-risk smelters reported. The results of IMAX’s smelter and refiner data analysis are described in Section 6 below.

The Company believes that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in its products, including (1) seeking information about 3TG smelters and refiners in the supply chain through requesting that 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.

 

5.3

Design and Implement a Strategy to Respond to Risks

As described in IMAX’s Conflict Minerals Policy, IMAX will engage with any suppliers whom it has reason to believe may be supplying the Company with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that do 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. At present, the Company has found no instances where it was necessary to terminate a contract or find a replacement supplier.


5.4

Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

The Company does not typically have a direct relationship with 3TG smelters and refiners and does not perform or direct audits of these entities within its supply chain.

Instead, the Company relies on third-party audits of smelters and refiners conducted as part of the 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.

Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facility’s sourcing practices on behalf of its compliance partners.

 

5.5

Report Annually on Supply Chain Due Diligence

The Company reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC. The Company’s Form SD and Conflict Minerals Report can be found on the Governance page of the Company’s Investor Relations website http://www.imax.com/content/investor-relations.

 

6.

Due Diligence Results

The large majority of the responses received provided data at a company or divisional level meaning that the 3TG may or may not actually be present in the components or parts actually supplied to IMAX. In many other cases, the suppliers were unable to specify the smelters or refiners used for components supplied to IMAX. Furthermore, suppliers did not always provide smelter or refiner lists nor were the smelter or refiner lists they did supply consistently completed with smelter or refiner identification numbers. In addition, many of the responses provided at the company or division level indicated an “unknown” status in terms of determining the origin of 3TGs. Therefore, IMAX was unable to validate that any of these smelters or refiners are actually in its supply chain.

As of May 20, 2020, IMAX had received 337 CMRTs from suppliers for an overall response rate of 78%. Of the responses received, 13 suppliers claimed that they source 3TGs from the Covered Countries. There were 6 invalid supplier submissions. Many suppliers were unable to provide all of the smelters or refiners used for materials supplied to IMAX, and some responses indicated an “unknown” status with respect to the origin of their materials.

As of May 20, 2020, IMAX had validated 307 legitimate smelters or refiners and continues to work to validate the additional smelter and refiner entries from the submitted CMRTs. IMAX has included the current list of valid smelters and refiners disclosed to it by suppliers in Annex 1 to this report.

Based on the smelter and refiner lists provided by suppliers via the CMRTs, which were in turn validated against the RMI as described above, the Company is aware of (i) 235 conflict-free smelters or refiners and (ii) 7 smelters or refiners that have begun the process to be validated as conflict-free, and which are active in the RMAP but have not yet been validated as conflict-free. Annex 2 includes an aggregate country list of known smelter or refiner sourcing countries.

 

7.

Steps to Be Taken to Mitigate Risk

Going forward, IMAX intends to take the following steps to further improve its due diligence and to further mitigate any risk that the necessary 3TGs in IMAX products could benefit armed groups in the Covered Countries:

 

   

Periodically reevaluate and enhance clauses in new purchase orders and supplier contracts to assist in implementing the Company’s conflict minerals program;

 

   

Pursue strategies to increase the number of suppliers providing information while working with suppliers to move to the latest version of the CMRT;

 

   

Engage any suppliers found to be supplying the Company with 3TG from sources that support conflict in the Covered Countries and encourage them to establish an alternative source of 3TG that does not support such conflict; and

 

   

Continue to emphasize clean and validated smelter or refiner information from the supply chain as the list of conflict-free smelters and refiners grows and more smelters declare their intent to enroll in the program.

All suppliers who do not know the origin of the 3TGs in their products will be further encouraged to examine their supply chain and enact due diligence measures as per the OECD Guidance. The goal for these suppliers is to determine origin of their 3TGs and, if not from recycled or scrap resources, then to ensure a conflict-free origin. Should suppliers of parts that are at a high risk of containing 3TGs remain unresponsive or if suppliers are unable to definitively determine origin and to take necessary subsequent steps to ensure that their products are conflict-free, IMAX will consider replacing such suppliers.


Annex 1

 

Metal Name

 

Standard SOR Name

 

SOR Facility Location

Gold

  8853 S.p.A.   ITALY

Gold

  Abington Reldan Metals, LLC   UNITED STATES

Gold

  Advanced Chemical Company   UNITED STATES

Gold

  African Gold Refinery   UGANDA

Gold

  Aida Chemical Industries Co., Ltd.   JAPAN

Gold

  Al Etihad Gold Refinery DMCC   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

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

  C.I Metales Procesados Industriales SAS   COLOMBIA

Gold

  Caridad   MEXICO

Gold

  CCR Refinery – Glencore Canada Corporation   CANADA

Gold

  Cendres + Metaux S.A.   SWITZERLAND

Gold

  CGR Metalloys Pvt Ltd.   INDIA

Gold

  Chimet S.p.A.   ITALY

Gold

  Chugai Mining   JAPAN

Gold

  Daye Non-Ferrous Metals Mining Ltd.   CHINA

Gold

  Degussa Sonne / Mond Goldhandel GmbH   GERMANY

Gold

  Dijllah Gold Refinery FZC   UNITED ARAB EMIRATES

Gold

  DODUCO Contacts and Refining GmbH   GERMANY

Gold

  Dowa   JAPAN

Gold

  DS PRETECH Co., Ltd.   KOREA, REPUBLIC OF

Gold

  DSC (Do Sung Corporation)   KOREA, REPUBLIC OF


Gold

  Eco-System Recycling Co., Ltd. East Plant   JAPAN

Gold

  Eco-System Recycling Co., Ltd. North Plant   JAPAN

Gold

  Eco-System Recycling Co., Ltd. West Plant   JAPAN

Gold

  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

Gold

  Gold Coast Refinery   GHANA

Gold

  Gold Refinery of Zijin Mining Group Co., Ltd.   CHINA

Gold

  Great Wall Precious Metals Co., Ltd. of CBPM   CHINA

Gold

  Guangdong Jinding Gold Limited   CHINA

Gold

  Guoda Safina High-Tech Environmental Refinery Co., Ltd.   CHINA

Gold

  Hangzhou Fuchunjiang Smelting Co., Ltd.   CHINA

Gold

  Heimerle + Meule GmbH   GERMANY

Gold

  Heraeus 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

  JALAN & Company   INDIA

Gold

  Japan Mint   JAPAN

Gold

  Jiangxi Copper Co., Ltd.   CHINA

Gold

  JSC Ekaterinburg Non-Ferrous Metal Processing Plant   RUSSIAN FEDERATION

Gold

  JSC Uralelectromed   RUSSIAN FEDERATION

Gold

  JX Nippon Mining & Metals Co., Ltd.   JAPAN

Gold

  Kaloti Precious Metals   UNITED ARAB EMIRATES

Gold

  Kazakhmys Smelting LLC   KAZAKHSTAN

Gold

  Kazzinc   KAZAKHSTAN

Gold

  Kennecott Utah Copper LLC   UNITED STATES

Gold

  KGHM Polska Miedz Spolka Akcyjna   POLAND


Gold

  Kojima Chemicals Co., Ltd.   JAPAN

Gold

  Korea Zinc Co., Ltd.   KOREA, REPUBLIC OF

Gold

  Kundan Care Products Ltd.   INDIA

Gold

  Kyrgyzaltyn JSC   KYRGYZSTAN

Gold

  Kyshtym Copper-Electrolytic Plant ZAO   RUSSIAN FEDERATION

Gold

  L’azurde Company For Jewelry   SAUDI ARABIA

Gold

  Lingbao Gold Co., Ltd.   CHINA

Gold

  Lingbao Jinyuan Tonghui Refinery Co., Ltd.   CHINA

Gold

  L’Orfebre S.A.   ANDORRA

Gold

  LS-NIKKO Copper Inc.   KOREA, REPUBLIC OF

Gold

  LT Metal Ltd.   KOREA, REPUBLIC OF

Gold

  Luoyang Zijin Yinhui Gold Refinery Co., Ltd.   CHINA

Gold

  Marsam Metals   BRAZIL

Gold

  Materion   UNITED STATES

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

Gold

  Metalurgica Met-Mex Penoles S.A. De C.V.   MEXICO

Gold

  Mitsubishi Materials Corporation   JAPAN

Gold

  Mitsui Mining and Smelting Co., Ltd.   JAPAN

Gold

  MMTC-PAMP India Pvt., Ltd.   INDIA

Gold

  Modeltech Sdn Bhd   MALAYSIA

Gold

  Morris and Watson   NEW ZEALAND

Gold

  Moscow Special Alloys Processing Plant   RUSSIAN FEDERATION

Gold

  Nadir Metal Rafineri San. Ve Tic. A.S.   TURKEY

Gold

  Navoi Mining and Metallurgical Combinat   UZBEKISTAN

Gold

  NH Recytech Company   KOREA, REPUBLIC OF

Gold

  Nihon Material Co., Ltd.   JAPAN

Gold

  Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH   AUSTRIA

Gold

  Ohura Precious Metal Industry Co., Ltd.   JAPAN

Gold

  OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)   RUSSIAN FEDERATION

Gold

  OJSC Novosibirsk Refinery   RUSSIAN FEDERATION


Gold

  PAMP S.A.   SWITZERLAND

Gold

  Pease & Curren   UNITED STATES

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

Gold

  Rand Refinery (Pty) Ltd.   SOUTH AFRICA

Gold

  Refinery of Seemine Gold Co., Ltd.   CHINA

Gold

  REMONDIS PMR B.V.   NETHERLANDS

Gold

  Royal Canadian Mint   CANADA

Gold

  SAAMP   FRANCE

Gold

  Sabin Metal Corp.   UNITED STATES

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

  Shirpur Gold Refinery Ltd.   INDIA

Gold

  Sichuan Tianze Precious Metals Co., Ltd.   CHINA

Gold

  Singway Technology Co., Ltd.   TAIWAN

Gold

  SOE Shyolkovsky Factory of Secondary Precious Metals   RUSSIAN FEDERATION

Gold

  Solar Applied Materials Technology Corp.   TAIWAN

Gold

  Sovereign Metals   INDIA

Gold

  State Research Institute Center for Physical Sciences and Technology   LITHUANIA

Gold

  Sudan Gold Refinery   SUDAN

Gold

  Sumitomo Metal Mining Co., Ltd.   JAPAN

Gold

  SungEel HiMetal Co., Ltd.   KOREA, REPUBLIC OF

Gold

  T.C.A S.p.A   ITALY


Gold

  Tanaka Kikinzoku Kogyo K.K.   JAPAN

Gold

  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

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

Tantalum

  D Block Metals, LLC   UNITED STATES

Tantalum

  Exotech Inc.   UNITED STATES

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

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

Tantalum

  H.C. Starck Ltd.   JAPAN

Tantalum

  H.C. Starck Smelting GmbH & Co. KG   GERMANY

Tantalum

  H.C. Starck Tantalum and Niobium GmbH   GERMANY

Tantalum

  Hengyang King Xing Lifeng New Materials Co., Ltd.   CHINA

Tantalum

  Jiangxi Dinghai Tantalum & Niobium Co., Ltd.   CHINA


Tantalum

  Jiangxi Tuohong New Raw Material   CHINA

Tantalum

  JiuJiang JinXin Nonferrous Metals Co., Ltd.   CHINA

Tantalum

  Jiujiang Tanbre Co., Ltd.   CHINA

Tantalum

  Jiujiang Zhongao Tantalum & Niobium Co., Ltd.   CHINA

Tantalum

  KEMET Blue Metals   MEXICO

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

  PRG Dooel   NORTH MACEDONIA, REPUBLIC OF

Tantalum

  QuantumClean   UNITED STATES

Tantalum

  Resind Industria e Comercio Ltda.   BRAZIL

Tantalum

  Solikamsk Magnesium Works OAO   RUSSIAN FEDERATION

Tantalum

  Taki Chemical Co., Ltd.   JAPAN

Tantalum

  Telex Metals   UNITED STATES

Tantalum

  Ulba Metallurgical Plant JSC   KAZAKHSTAN

Tantalum

  XinXing HaoRong Electronic Material Co., Ltd.   CHINA

Tantalum

  Yanling Jincheng Tantalum & Niobium Co., Ltd.   CHINA

Tin

  Alpha   UNITED STATES

Tin

  An Vinh Joint Stock Mineral Processing Company   VIET NAM

Tin

  Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.   CHINA

Tin

  Chifeng Dajingzi Tin Industry Co., Ltd.   CHINA

Tin

  China Tin Group Co., Ltd.   CHINA

Tin

  Dongguan CiEXPO Environmental Engineering Co., Ltd.   CHINA

Tin

  Dowa   JAPAN

Tin

  Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company   VIET NAM

Tin

  EM Vinto   BOLIVIA (PLURINATIONAL STATE OF)

Tin

  Estanho de Rondonia S.A.   BRAZIL

Tin

  Fenix Metals   POLAND

Tin

  Gejiu City Fuxiang Industry and Trade Co., Ltd.   CHINA

Tin

  Gejiu Kai Meng Industry and Trade LLC   CHINA

Tin

  Gejiu Non-Ferrous Metal Processing Co., Ltd.   CHINA

Tin

  Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.   CHINA


Tin

  Gejiu Zili Mining And Metallurgy Co., Ltd.   CHINA

Tin

  Guangdong Hanhe Non-Ferrous Metal Co., Ltd.   CHINA

Tin

  Guanyang Guida Nonferrous Metal Smelting Plant   CHINA

Tin

  HuiChang Hill Tin Industry Co., Ltd.   CHINA

Tin

  Huichang Jinshunda Tin Co., Ltd.   CHINA

Tin

  Jiangxi New Nanshan Technology Ltd.   CHINA

Tin

  Luna Smelter, Ltd.   RWANDA

Tin

  Ma’anshan Weitai Tin Co., Ltd.   CHINA

Tin

  Magnu’s Minerais Metais e Ligas Ltda.   BRAZIL

Tin

  Malaysia Smelting Corporation (MSC)   MALAYSIA

Tin

  Melt Metais e Ligas S.A.   BRAZIL

Tin

  Metallic Resources, Inc.   UNITED STATES

Tin

  Metallo Belgium N.V.   BELGIUM

Tin

  Metallo Spain S.L.U.   SPAIN

Tin

  Mineracao Taboca S.A.   BRAZIL

Tin

  Minsur   PERU

Tin

  Mitsubishi Materials Corporation   JAPAN

Tin

  Modeltech Sdn Bhd   MALAYSIA

Tin

  Nghe Tinh Non-Ferrous Metals Joint Stock Company   VIET NAM

Tin

  O.M. Manufacturing (Thailand) Co., Ltd.   THAILAND

Tin

  O.M. Manufacturing Philippines, Inc.   PHILIPPINES

Tin

  Operaciones Metalurgicas S.A.   BOLIVIA (PLURINATIONAL STATE OF)

Tin

  Pongpipat Company Limited   MYANMAR

Tin

  Precious Minerals and Smelting Limited   INDIA

Tin

  PT Artha Cipta Langgeng   INDONESIA

Tin

  PT ATD Makmur Mandiri Jaya   INDONESIA

Tin

  PT Menara Cipta Mulia   INDONESIA

Tin

  PT Mitra Stania Prima   INDONESIA

Tin

  PT Refined Bangka Tin   INDONESIA

Tin

  PT Timah Tbk Kundur   INDONESIA

Tin

  PT Timah Tbk Mentok   INDONESIA

Tin

  Resind Industria e Comercio Ltda.   BRAZIL

Tin

  Rui Da Hung   TAIWAN

Tin

  Soft Metais Ltda.   BRAZIL

Tin

  Super Ligas   BRAZIL


Tin

  Thai Nguyen Mining and Metallurgy Co., Ltd.   VIET NAM

Tin

  Thaisarco   THAILAND

Tin

  Tin Technology & Refining   UNITED STATES

Tin

  Tuyen Quang Non-Ferrous Metals Joint Stock Company   VIET NAM

Tin

  White Solder Metalurgia e Mineracao Ltda.   BRAZIL

Tin

  Yunnan Chengfeng Non-ferrous Metals Co., Ltd.   CHINA

Tin

  Yunnan Tin Company Limited   CHINA

Tin

  Yunnan Yunfan Non-ferrous Metals Co., Ltd.   CHINA

Tungsten

  A.L.M.T. Corp.   JAPAN

Tungsten

  ACL Metais Eireli   BRAZIL

Tungsten

  Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.   BRAZIL

Tungsten

  Asia Tungsten Products Vietnam Ltd.   VIET NAM

Tungsten

  Chenzhou Diamond Tungsten Products Co., Ltd.   CHINA

Tungsten

  China Molybdenum Co., Ltd.   CHINA

Tungsten

  Chongyi Zhangyuan Tungsten Co., Ltd.   CHINA

Tungsten

  CNMC (Guangxi) PGMA Co., Ltd.   CHINA

Tungsten

  CP Metals Inc.   UNITED STATES

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

  GEM Co., Ltd.   CHINA

Tungsten

  Global Tungsten & Powders Corp.   UNITED STATES

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 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 Xianglu Tungsten 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

Tungsten

  Kennametal Huntsville   UNITED STATES

Tungsten

  KGETS Co., Ltd.   KOREA, REPUBLIC OF

Tungsten

  Lianyou Metals Co., Ltd.   TAIWAN

Tungsten

  Malipo Haiyu Tungsten Co., Ltd.   CHINA

Tungsten

  Masan Tungsten Chemical LLC (MTC)   VIET NAM

Tungsten

  Moliren Ltd.   RUSSIAN FEDERATION

Tungsten

  Niagara Refining LLC   UNITED STATES

Tungsten

  NPP Tyazhmetprom LLC   RUSSIAN FEDERATION

Tungsten

  Philippine Chuangxin Industrial Co., Inc.   PHILIPPINES

Tungsten

  Tejing (Vietnam) Tungsten Co., Ltd.   VIET NAM

Tungsten

  Unecha Refractory metals plant   RUSSIAN FEDERATION

Tungsten

  Wolfram Bergbau und Hutten AG   AUSTRIA

Tungsten

  Woltech Korea Co., Ltd.   KOREA, REPUBLIC OF

Tungsten

  Xiamen Tungsten (H.C.) Co., Ltd.   CHINA

Tungsten

  Xiamen Tungsten Co., Ltd.   CHINA

Tungsten

  Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.   CHINA

Tungsten

  Xinhai Rendan Shaoguan Tungsten Co., Ltd.   CHINA


Annex 2

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore it is not certain which of these countries of origin can be linked to our products.

 

AFGHANISTAN    GUINEA    PHILIPPINES
ALBANIA    GUYANA    POLAND
ANGOLA    HUNGARY    PORTUGAL
ARGENTINA    INDIA    REPUBLIC OF KOREA
ARMENIA    INDONESIA    RUSSIA
AUSTRALIA    IRELAND    RWANDA
AUSTRIA    ISRAEL    SAUDI ARABIA
BELARUS    ITALY    SIERRA LEONE
BELGIUM    IVORY COAST    SINGAPORE
BERMUDA    JAPAN    SLOVAKIA
BOLIVIA    KAZAKHSTAN    SLOVENIA
BRAZIL    KENYA    SOUTH AFRICA
BULGARIA    KYRGYZSTAN    SPAIN
BURUNDI    LAOS    SUDAN
CAMBODIA    LIBERIA    SURINAME
CANADA    LITHUANIA    SWEDEN
CENTRAL AFRICAN REPUBLIC    LUXEMBOURG    SWITZERLAND
CHILE    MADAGASCAR    TANZANIA
CHINA    MALAYSIA    THAILAND
COLOMBIA    MALI    TURKEY
CZECH REPUBLIC    MAURITANIA    UGANDA
DJIBOUTI    MEXICO    UNITED ARAB EMIRATES
DOMINICAN REPUBLIC    MONGOLIA    UNITED KINGDOM
DRC OR AN ADJOINING COUNTRY (COVERED COUNTRIES)    MOROCCO    UNITED STATES
ECUADOR    MOZAMBIQUE    UZBEKISTAN
EGYPT    MYANMAR    VIETNAM
ENGLAND    NAMIBIA    ZAMBIA
ESTONIA    NETHERLANDS    ZIMBABWE
ETHIOPIA    NEW ZEALAND   
FINLAND    NIGER   
FRANCE    NIGERIA   
GERMANY    PAPUA NEW GUINEA   
GHANA    PERU