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


FORM SD
Specialized Disclosure Report


DXP ENTERPRISES INC.
(Exact name of registrant as specified in its charter)
Texas000-2151376-0509661
(State or other jurisdiction(Commission File Number)(IRS Employer Identification No.)
of incorporation or organization)
5301 Hollister Drive, Houston, Texas77040
(Address of principal executive officers)(Zip Code)


Kent Yee
Senior Vice President & Chief Financial Officer
713-996-4736
(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:

[ü] 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

DXP Enterprises, Inc. is submitting this Specialized Disclosure Report on Form SD and the related Conflict Minerals Report (“Report”) filed herewith for the calendar year ended December 31, 2019, as required by Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule”). All terms used but not defined in this Report shall have the meanings ascribed to them in the Rule or Form SD, as adopted by the Securities and Exchange Commission (“SEC”) pursuant to the Rule. Unless the context otherwise indicates, “DXP”, “Company”, “we”, “us” and “our” refer to DXP Enterprises, Inc. and its majority owned subsidiaries and any entities that are required to be consolidated.

During calendar year 2019 the Company believes that Conflict Minerals (as defined herein) may be necessary to the functionality or production of one or more products manufactured or contracted to be manufactured by DXP (“Covered Products”). In addition, DXP has reason to believe that some of its necessary Conflict Minerals may have originated from the Democratic Republic of the Congo (“DRC”) or any country that shares an internationally recognized boarder with the DRC and DXP has reason to believe that those Conflict Minerals may not be from recycled or scrap sources. Accordingly, we are filing the attached Report describing the reasonable country of origin inquiry and additional due diligence steps taken for the 2019 reporting period. The results of our investigation regarding the origin of necessary Conflict Minerals in our supply chain is described in the Report attached hereto as Exhibit 1.01 and in the Company’s website at www.dxpe.com.

Item 1.01 Conflict Minerals Disclosure and Report

In accordance with the Rule, the Company is filing the Report attached hereto as Exhibit 1.01. A copy of this Form SD and the related Report are publicly available on our website at: www.dxpe.com within the “Investors” section under “Investor Relations” > “Financial Information” > “SEC Filings”.


Item 1.02 Exhibit

DXP’s Report, as required by Items 1.01 and 1.02, is filed as Exhibit 1.01 to this Form SD.


SECTION 2 - EXHIBIT

Item 2.01 Exhibit

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


SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this Report to be signed on its behalf by the duly authorized undersigned.
DXP Enterprises, Inc.
(Registrant)
Date: May 29, 2020
/s/ Kent Yee
By: Kent Yee
Senior Vice President & Chief Financial Officer




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Document

EXHIBIT 1.01

DXP Enterprises, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2019

Introduction

This Conflict Minerals Report (“Report”) has been prepared by management of DXP for the period from January 1, 2019 to December 31, 2019 (“Reporting Period”). Unless the context otherwise indicates, "DXP", “Company”, "we", "us", and "our" means DXP Enterprises, Inc. and its majority owned subsidiaries and any entities that are required to be consolidated.

This Report is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule”). The Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing Conflict Minerals (as hereinafter defined) that are necessary to the functionality or production of their products. The term Conflict Minerals is defined to mean: (A) cassiterite, columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are currently limited to tin, tantalum, tungsten and gold (collectively the “3TGs”); 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 country that shares an internationally recognized border with the DRC (collectively “Covered Countries”).

DXP has reason to believe that some of the 3TGs may be present in its supply chain that may have originated in any of the Covered Countries. Therefore, we performed a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the 3TGs in our products originated from any Covered Countries. This Report describes the measures the Company took to exercise due diligence on the source and chain of custody of the Conflict Minerals, the Company products that may contain 3TGs and are therefore in the scope of the Company’s Conflict Minerals program, the facilities that may have processed the 3TGs that may be necessary to the functionality or production of one or more products, and the efforts the Company took to determine the mine or location of origin of those 3TGs. Although we are unable to determine the origins of all 3TGs in our products, only some of our products fall within the scope of the Rule because they may contain one or more of the 3TGs.

Company and Product Overview

Our business

DXP Enterprises, Inc. is headquartered in Houston Texas and is a diversified company that conducts business in the markets set out below. DXP is engaged in the business of distributing maintenance, repair, and operating products, equipment and services to energy and industrial customers. DXP is organized into three business segments: Service Centers, Innovative Pumping Solutions and Supply Chain Services. The Service Centers offer a wide range of MRO products, equipment and integrated services, including technical expertise and logistics capabilities, to energy and industrial customers. The Service Centers segment also provides services such as field safety supervision, in-house and field repair and predictive maintenance. Service Centers provide a wide range of MRO products in the rotating equipment, bearing, power transmission, hose, fluid power, metal working, industrial supply, safety product and safety service categories. The Innovative Pumping Solutions segment provides integrated, custom pump skid packages, pump remanufacturing and branded private label pumps it manufactures. The Supply Chain Services segment manages all or part of a customer’s supply chains, including procurement and inventory management.

Our Covered Products

For the purposes of this Report, we reviewed our supply base in order to determine the suppliers of materials/components that may possibly contain some 3TGs. Some of our suppliers have reported to us that some of our products that may be necessary to the functionality or production of products that we manufactured or contracted to manufacture during the 2019 Reporting Period may contain 3TGs. DXP is unsure of the presence of 3TGs in our products, however, based on the Conflict Minerals Reporting Template (“CMRT”) we received from suppliers, the presence of 3TGs may be in some of their products. Many of our suppliers completed their CMRTs at the company,
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business unit or entity level basis. Due to this we are unable to definitively conclude which 3TGs, if any, are present in any products that were supplied to us.

Reasonable Country of Origin Inquiry

To determine whether necessary 3TGs in our products originated in Covered Countries, we retained Assent Compliance (“Assent”), our third-party service provider, to assist us in reviewing our supply chain and in identifying risks. We provided Assent with a list of our suppliers associated with Covered Products that may be within the scope of the Rule for upload to the Assent Compliance Manager tool (“ACM”). We could not determine definitively the presence or absence of Conflict Minerals in all parts and products supplied to us for our products.

DXP utilized the CMRT version 5.12 or higher, as designed by the Responsible Business Alliance and the Global e-Sustainability Initiative to conduct a survey of all our in-scope suppliers. We surveyed our in-scope suppliers through the ACM, a software-as-a-service platform that allows users to complete and track supplier communications as well as allows suppliers to upload competed CMRTs directly to the platform for validation, assessment and management. The use of CMRTs allowed for some elimination of irrelevant suppliers.

Assent requested that all our suppliers complete a CMRT and Assent included training and education to guide suppliers on best practices and the use of the CMRT. Assent monitored and tracked all communications in the ACM for future reporting and transparency. In order to increase the response level, Assent provided our suppliers with a stated deadline and followed up with both “reminder” and “late” notices. In addition, Assent developed a list of criteria to identify supplier responses that warranted further inquiry.

Our Conflict Minerals program continues to include automated validation of all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify contradictory answers to the CMRT.

All submitted CMRTs are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regards to invalid CMRTs and are encouraged to submit a valid CMRT. Suppliers are also provided with guidance on how to correct these validation errors. There are 13 invalid supplier submissions that could not be corrected.

Assent compared the list of smelters and refiners provided in our suppliers’ responses to the list of smelters maintained by the Responsible Minerals Initiative (“RMI”) and, if a supplier indicated that a facility was certified as conflict free, confirmed the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TGs. Our suppliers identified a total 307 smelters and refiners that appear on the list maintained by RMI. Of those 307 smelters and refiners, 235 are validated as conflict free by RMI or a cross recognized initiative, and, based on information provided by RMI, a further 7 agreed to undergo a third party audit. Most of the CMRT’s we received were made on a company, business unit or division level basis, which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TGs contained in our products.

Due Diligence

Design of due diligence

With the assistance of Assent we have designed our due diligence measures to conform, in all material respects, with the due diligence framework presented by the Organization for Economic Co-operation and Development (“OECD”) in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“Guidance”).

DXP’s Conflict Minerals due diligence process includes the following five steps recommended by the Guidance: 1) establishing company management systems; 2) identifying and assessing risks in our supply chain; 3) designing and implementing a strategy to respond to identified risks; 4) utilizing independent third-party audits; and 5) reporting on our supply chain due diligence. A summary of the due diligence measures undertaken by the Company is outlined below.

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We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of our suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. The origin of Conflict Minerals cannot be determined with any certainty once the raw ores are smelted and refined.

The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OCED Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with the supply chain complexities, the OCED Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of any Conflict Minerals contained in any components or materials supplied to us.

Due Diligence Performed

Establishing Company Management Systems

Internal Team

We have a Conflict Minerals group comprised of individuals in management positions across legal, finance, and procurement. This group leads our Conflict Minerals compliance effort.

We also use Assent to assist us with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of any addition due diligence steps that we may undertake with suppliers in regard to Conflict Minerals.
        
Control Systems

DXP expects all of its suppliers to have policies and procedures in place to ensure that any 3TGs used in the products sold to us are free of Conflict Minerals. This means that these products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. We rely upon our direct suppliers to provide information on the origin of any 3TGs contained in components and materials supplied to us, including sources of 3TGs that were supplied to us and that were supplied to them from lower tier suppliers.

Our Code of Conduct applies to our direct suppliers. We also established a Conflict Minerals policy related to our sourcing of 3TGs as described in full in our “Conflict Minerals Policy” posted on our website at www.dxpe.com within the “Investors” section under “Investor Relations” > “Corporate Governance” > “Governance Documents”.

Supplier Engagement

DXP engages with suppliers to request they complete a valid CMRT for the products they supply to us. With respect to the OECD requirement to engagement with suppliers, we have worked with Assent to develop steps of supplier engagement regarding corrective actions. We have utilized Assent’s online resources and provided suppliers, through Assent, access to Conflict Minerals training and support resources.

We believe our Conflict Minerals Policy and Assent’s engagement with our suppliers for Conflict Minerals training and other requests constitutes a viable program when it comes to supplier engagement.

Grievance Mechanisms

DXP has established grievance mechanisms whereby employees and suppliers can report violations of DXP’s policies, including with respect to Conflict Minerals. Suppliers may contact us anonymously via a dedicated email address that is published in our Conflicts Minerals Policy and in our Code of Conduct. In addition, our employees may anonymously report suspected violations using the same dedicated email address, dxpe.ethicspoint.com, or our anonymous third party conduct help line at (888) 307-4308, as published in our Conflicts Minerals Policy and in our Code of Conduct.
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Maintain Records

We have adopted a policy to retain relevant documents with Assent for 5 years. We implemented this policy through Assent to retain Conflict Minerals related documents, including responses to CMRTs. We also have engaged Assent to store all of the information and findings from this process in a database that can be audited by internal and external parties.

Identifying and Assessing Risks in our Supply Chain

Due to our size, the complexity of our products, and the depth, breadth and constant evolution of our supply chain it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in the ACM tool based on criteria established for supplier responses in the ACM. These risks are addressed by the Assent Compliance Supply Chain staff who contact the supplier, gather pertinent data and perform an assessment of the supplier’s Conflict Minerals status.

We identified a risk related to the nature of the responses received. Many of the responses received provided data at a company, business unit or division level basis or were unable to specify the smelter or refiner used for the 3TGs in the components supplied to us. Additionally, some suppliers indicated they could not provide a comprehensive list of smelter or refiners in their supply chain.

In accordance with OECD Guidance, it is important to identify and assess risks associated with Conflict Minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed minerals processing facilities on their CMRT declarations. Assent compared the facilities listed in the response to the list of smelters and refiners maintained by the Responsible Minerals Initiative (“RMI”) to ensure that these facilities met the RMI definition of a 3TGs processing facility that was operation during the 2019 calendar year.

In order to assess the risk that any of the smelters or refiners posed to our supply chain, Assent determined if the smelter or refiner had been audited against a standard of conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RAMP”). We do not typically have a direct relationship with 3TGs smelters and refiners and do not perform direct audits of these entities. Smelters that have completed a RMAP audit are considered to be DRC Conflict Free. In cases where the smelters due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists. Due to the provision of primary supplier level CMRTs, we cannot definitely determine their connection to the Covered Products.

Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the OED Guidance. Assent uses numerous factors to determine the level of risk that each smelter or refiner poses to the supply chain by identifying red flags. These factors include, but are not limited to:

1.Geographic proximity to the Covered Countries;
2.RMAP audit status;
3.Credible evidence of unethical or conflict sourcing;
4.Known mineral source of origin; and
5.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, submissions that include any red flag facilities immediately produce a receipt instructing such suppliers to take their own risk mitigation actions, including the submission of a product specific CMRT to better identify the connection to products that they supply to us and escalating up to removal of these red flag smelters from their supply chain.

As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable time frames with the ultimate goal of progressive elimination of the red flags from the supply chain. In addition, the suppliers are guided to the Assent University learning platform to engage in educational materials on the mitigation risk of smelters or refiners in the supply chain.
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Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:

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 the above criteria, by answering yes to all four questions, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. At this time 140 of our responsive suppliers have been identified as having a weak program.

Designing and Implementing a Strategy to Respond to Identified Risks

Together with Assent, we developed processes to access and respond to the risks identified in our supply chain. In response to this risk assessment, we have a risk management plan, through which our Conflict Minerals program is implemented, managed and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the Conflict Minerals rules.

We will 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 3TGs that does not support such conflict, as provided in the OECD Guidance.

Utilizing Independent Third Party Audits

We do not have a direct relationship with any 3TG smelters and refiners of Conflict Minerals and do not perform or direct audits of these entities within our supply chain. Instead, we rely upon Assent to provide us with 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.

Report on Supply Chain Due Diligence

We have published our Form SD for the year ended December 31, 2019. Form SD and this Report is available on our website at www.dxpe.com within the “Investors” section under “Investor Relations” > “Financial Information “ > “SEC Filings”. Information found on or accessed through our website is not consider part of this Report and is not incorporated herein by reference. We have also filed our Form SD and this Report with the SEC.

Results of Due Diligence

Survey results

For the 2019 reporting year Assent received CMRTs from 695 suppliers. All final CMRT submissions were reviewed and validated by Assent to ensure no inaccuracies or gaps in data were found. There were 13 suppliers that were unable to correct their CMRT and as such, are listed as invalid submissions.





5



Smelters and Refiners

Attached as Appendix A is a table that lists all the smelters and refiners identified by our responsive direct suppliers that may have been used to process the Conflict Minerals necessary to the functionality or production of our Covered Products during the 2019 calendar year. This list may contain more facilities than are actually linked to the Company’s Covered Products. Alternatively, this list may not include all applicable facilities as not all of our suppliers were able to provide the required information at this time. Those that have been validated as compliant under RAMP by the RMI, have been noted as such in the final column on the right in Appendix A. From the responses received, Assent identified 307 smelters that potentially posed a risk due to the presence of some red flag indicators.

Countries of Origin

Attached as Appendix B is an aggregated list of countries of origin which is populated based on publicly available information, our RCOI and due diligence. It is important to note many responses were provided at the company, business unit or division level basis, therefore it is not certain which of these countries of origin can be linked to our products.

Steps to be Taken To Mitigate Risk

We are committed to complying with the provisions of the Rule and Form SD and we expect to continue our efforts to improve our Conflict Minerals program and related due diligence. As we further develop our program and procedures, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to the following:

Engage with suppliers and direct them to Assent’s training resources in an attempt to increase our response rate and improve the content of responses to assist in our RCOI process and our efforts to determine the country of origin of our 3TGs;
Engage suppliers and encourage them to provide responses at the product level;
Continue to invest in Assent’s Conflict Minerals due diligence tools; and
Continue to respond to industry trends and legal requirements to further improve the traceability of 3TGs in our supply chain.


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Appendix A Refiners and Smelters List:



MetalStandard Smelter NameSmelter Facility LocationSmelter ID
Gold8853 S.p.A.ITALYCID002763
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICACID002708
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICACID000015
GoldAfrican Gold RefineryUGANDACID003185
GoldAida Chemical Industries Co., Ltd.JAPANCID000019
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESCID002560
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYCID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILCID000058
GoldArgor-Heraeus S.A.SWITZERLANDCID000077
GoldAsahi Pretec Corp.JAPANCID000082
GoldAsahi Refining Canada Ltd.CANADACID000924
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICACID000920
GoldAsaka Riken Co., Ltd.JAPANCID000090
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYCID000103
GoldAU Traders and RefinersSOUTH AFRICACID002850
GoldAurubis AGGERMANYCID000113
GoldBangalore RefineryINDIACID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESCID000128
GoldBoliden ABSWEDENCID000157
GoldC. Hafner GmbH + Co. KGGERMANYCID000176
GoldC.I Metales Procesados Industriales SASCOLOMBIACID003421
GoldCaridadMEXICOCID000180
GoldCCR Refinery - Glencore Canada CorporationCANADACID000185
GoldCendres + Metaux S.A.SWITZERLANDCID000189
GoldCGR Metalloys Pvt Ltd.INDIACID003382
GoldChimet S.p.A.ITALYCID000233
GoldChugai MiningJAPANCID000264
GoldDaye Non-Ferrous Metals Mining Ltd.CHINACID000343
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYCID002867
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATESCID003348
GoldDODUCO Contacts and Refining GmbHGERMANYCID000362
GoldDowaJAPANCID000401
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OFCID003195
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFCID000359
GoldEco-System Recycling Co., Ltd. East PlantJAPANCID000425
GoldEco-System Recycling Co., Ltd. North PlantJAPANCID003424
GoldEco-System Recycling Co., Ltd. West PlantJAPANCID003425
GoldEmirates Gold DMCCUNITED ARAB EMIRATESCID002561
GoldFidelity Printers and Refiners Ltd.ZIMBABWECID002515
GoldFujairah Gold FZCUNITED ARAB EMIRATESCID002584
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIACID002852
GoldGeib Refining CorporationUNITED STATES OF AMERICACID002459
GoldGold Coast RefineryGHANACID003186
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GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINACID002243
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINACID001909
GoldGuangdong Jinding Gold LimitedCHINACID002312
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINACID000651
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINACID000671
GoldHeimerle + Meule GmbHGERMANYCID000694
GoldHeraeus Metals Hong Kong Ltd.CHINACID000707
GoldHeraeus Precious Metals GmbH & Co. KGGERMANYCID000711
GoldHunan Chenzhou Mining Co., Ltd.CHINACID000767
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINACID000773
GoldHwaSeong CJ CO., LTD.KOREA, REPUBLIC OFCID000778
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINACID000801
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATESCID002562
GoldIshifuku Metal Industry Co., Ltd.JAPANCID000807
GoldIstanbul Gold RefineryTURKEYCID000814
GoldItalpreziosiITALYCID002765
GoldJALAN & CompanyINDIACID002893
GoldJapan MintJAPANCID000823
GoldJiangxi Copper Co., Ltd.CHINACID000855
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATIONCID000927
GoldJSC UralelectromedRUSSIAN FEDERATIONCID000929
GoldJX Nippon Mining & Metals Co., Ltd.JAPANCID000937
GoldKaloti Precious MetalsUNITED ARAB EMIRATESCID002563
GoldKazakhmys Smelting LLCKAZAKHSTANCID000956
GoldKazzincKAZAKHSTANCID000957
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICACID000969
GoldKGHM Polska Miedz Spolka AkcyjnaPOLANDCID002511
GoldKojima Chemicals Co., Ltd.JAPANCID000981
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFCID002605
GoldKundan Care Products Ltd.INDIACID003463
GoldKyrgyzaltyn JSCKYRGYZSTANCID001029
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONCID002865
GoldL'azurde Company For JewelrySAUDI ARABIACID001032
GoldLingbao Gold Co., Ltd.CHINACID001056
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINACID001058
GoldL'Orfebre S.A.ANDORRACID002762
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFCID001078
GoldLT Metal Ltd.KOREA, REPUBLIC OFCID000689
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINACID001093
GoldMarsam MetalsBRAZILCID002606
GoldMaterionUNITED STATES OF AMERICACID001113
GoldMatsuda Sangyo Co., Ltd.JAPANCID001119
GoldMetalor Technologies (Hong Kong) Ltd.CHINACID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORECID001152
GoldMetalor Technologies (Suzhou) Ltd.CHINACID001147
GoldMetalor Technologies S.A.SWITZERLANDCID001153
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICACID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOCID001161
GoldMitsubishi Materials CorporationJAPANCID001188
8



GoldMitsui Mining and Smelting Co., Ltd.JAPANCID001193
GoldMMTC-PAMP India Pvt., Ltd.INDIACID002509
GoldModeltech Sdn BhdMALAYSIACID002857
GoldMorris and WatsonNEW ZEALANDCID002282
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYCID001220
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANCID001236
GoldNH Recytech CompanyKOREA, REPUBLIC OFCID003189
GoldNihon Material Co., Ltd.JAPANCID001259
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIACID002779
GoldOhura Precious Metal Industry Co., Ltd.JAPANCID001325
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONCID001326
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATIONCID000493
GoldPAMP S.A.SWITZERLANDCID001352
GoldPease & CurrenUNITED STATES OF AMERICACID002872
GoldPenglai Penggang Gold Industry Co., Ltd.CHINACID001362
GoldPlanta Recuperadora de Metales SpACHILECID002919
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONCID001386
GoldPT Aneka Tambang (Persero) TbkINDONESIACID001397
GoldPX Precinox S.A.SWITZERLANDCID001498
GoldQG Refining, LLCUNITED STATES OF AMERICACID003324
GoldRand Refinery (Pty) Ltd.SOUTH AFRICACID001512
GoldRefinery of Seemine Gold Co., Ltd.CHINACID000522
GoldREMONDIS PMR B.V.NETHERLANDSCID002582
GoldRoyal Canadian MintCANADACID001534
GoldSAAMPFRANCECID002761
GoldSabin Metal Corp.UNITED STATES OF AMERICACID001546
GoldSafimet S.p.AITALYCID002973
GoldSAFINA A.S.CZECH REPUBLICCID002290
GoldSai RefineryINDIACID002853
GoldSamduck Precious MetalsKOREA, REPUBLIC OFCID001555
GoldSamwon Metals Corp.KOREA, REPUBLIC OFCID001562
GoldSAXONIA Edelmetalle GmbHGERMANYCID002777
GoldSEMPSA Joyeria Plateria S.A.SPAINCID001585
GoldShandong Humon Smelting Co., Ltd.CHINACID002525
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINACID001619
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACID001622
GoldShirpur Gold Refinery Ltd.INDIACID002588
GoldSichuan Tianze Precious Metals Co., Ltd.CHINACID001736
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINACID002516
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONCID001756
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINACID001761
GoldSovereign MetalsINDIACID003383
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIACID003153
GoldSudan Gold RefinerySUDANCID002567
GoldSumitomo Metal Mining Co., Ltd.JAPANCID001798
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFCID002918
GoldT.C.A S.p.AITALYCID002580
GoldTanaka Kikinzoku Kogyo K.K.JAPANCID001875
9



GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINACID001916
GoldTokuriki Honten Co., Ltd.JAPANCID001938
GoldTongling Nonferrous Metals Group Co., Ltd.CHINACID001947
GoldTony Goetz NVBELGIUMCID002587
GoldTOO Tau-Ken-AltynKAZAKHSTANCID002615
GoldTorecomKOREA, REPUBLIC OFCID001955
GoldUmicore Brasil Ltda.BRAZILCID001977
GoldUmicore Precious Metals ThailandTHAILANDCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMCID001980
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICACID001993
GoldValcambi S.A.SWITZERLANDCID002003
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIACID002030
GoldWIELAND Edelmetalle GmbHGERMANYCID002778
GoldYamakin Co., Ltd.JAPANCID002100
GoldYokohama Metal Co., Ltd.JAPANCID002129
GoldYunnan Copper Industry Co., Ltd.CHINACID000197
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACID002224
TantalumAsaka Riken Co., Ltd.JAPANCID000092
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINACID000211
TantalumCP Metals Inc.UNITED STATES OF AMERICACID003402
TantalumD Block Metals, LLCUNITED STATES OF AMERICACID002504
TantalumExotech Inc.UNITED STATES OF AMERICACID000456
TantalumF&X Electro-Materials Ltd.CHINACID000460
TantalumFIR Metals & Resource Ltd.CHINACID002505
TantalumGlobal Advanced Metals AizuJAPANCID002558
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICACID002557
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINACID000616
TantalumH.C. Starck Co., Ltd.THAILANDCID002544
TantalumH.C. Starck Hermsdorf GmbHGERMANYCID002547
TantalumH.C. Starck Inc.UNITED STATES OF AMERICACID002548
TantalumH.C. Starck Ltd.JAPANCID002549
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANYCID002550
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANYCID002545
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINACID002492
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACID002512
TantalumJiangxi Tuohong New Raw MaterialCHINACID002842
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACID000914
TantalumJiujiang Tanbre Co., Ltd.CHINACID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACID002506
TantalumKEMET Blue MetalsMEXICOCID002539
TantalumLSM Brasil S.A.BRAZILCID001076
TantalumMetallurgical Products India Pvt., Ltd.INDIACID001163
TantalumMineracao Taboca S.A.BRAZILCID001175
TantalumMitsui Mining and Smelting Co., Ltd.JAPANCID001192
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINACID001277
TantalumNPM Silmet ASESTONIACID001200
TantalumPRG DooelNORTH MACEDONIA, REPUBLIC OFCID002847
TantalumQuantumCleanUNITED STATES OF AMERICACID001508
TantalumResind Industria e Comercio Ltda.BRAZILCID002707
10



TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONCID001769
TantalumTaki Chemical Co., Ltd.JAPANCID001869
TantalumTelex MetalsUNITED STATES OF AMERICACID001891
TantalumUlba Metallurgical Plant JSCKAZAKHSTANCID001969
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINACID002508
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINACID001522
TinAlphaUNITED STATES OF AMERICACID000292
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAMCID002703
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINACID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINACID003190
TinChina Tin Group Co., Ltd.CHINACID001070
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINACID003356
TinDowaJAPANCID000402
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAMCID002572
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)CID000438
TinEstanho de Rondonia S.A.BRAZILCID000448
TinFenix MetalsPOLANDCID000468
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINACID003410
TinGejiu Kai Meng Industry and Trade LLCCHINACID000942
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINACID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINACID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINACID000555
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACID003116
TinGuanyang Guida Nonferrous Metal Smelting PlantCHINACID002849
TinHuiChang Hill Tin Industry Co., Ltd.CHINACID002844
TinHuichang Jinshunda Tin Co., Ltd.CHINACID000760
TinJiangxi New Nanshan Technology Ltd.CHINACID001231
TinLuna Smelter, Ltd.RWANDACID003387
TinMa'anshan Weitai Tin Co., Ltd.CHINACID003379
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILCID002468
TinMalaysia Smelting Corporation (MSC)MALAYSIACID001105
TinMelt Metais e Ligas S.A.BRAZILCID002500
TinMetallic Resources, Inc.UNITED STATES OF AMERICACID001142
TinMetallo Belgium N.V.BELGIUMCID002773
TinMetallo Spain S.L.U.SPAINCID002774
TinMineracao Taboca S.A.BRAZILCID001173
TinMinsurPERUCID001182
TinMitsubishi Materials CorporationJAPANCID001191
TinModeltech Sdn BhdMALAYSIACID002858
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002573
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDCID001314
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESCID002517
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)CID001337
TinPongpipat Company LimitedMYANMARCID003208
TinPrecious Minerals and Smelting LimitedINDIACID003409
TinPT Artha Cipta LanggengINDONESIACID001399
TinPT ATD Makmur Mandiri JayaINDONESIACID002503
TinPT Menara Cipta MuliaINDONESIACID002835
TinPT Mitra Stania PrimaINDONESIACID001453
11



TinPT Refined Bangka TinINDONESIACID001460
TinPT Timah Tbk KundurINDONESIACID001477
TinPT Timah Tbk MentokINDONESIACID001482
TinResind Industria e Comercio Ltda.BRAZILCID002706
TinRui Da HungTAIWAN, PROVINCE OF CHINACID001539
TinSoft Metais Ltda.BRAZILCID001758
TinSuper LigasBRAZILCID002756
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMCID002834
TinThaisarcoTHAILANDCID001898
TinTin Technology & RefiningUNITED STATES OF AMERICACID003325
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002574
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACID002158
TinYunnan Tin Company LimitedCHINACID002180
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINACID003397
TungstenA.L.M.T. Corp.JAPANCID000004
TungstenACL Metais EireliBRAZILCID002833
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILCID003427
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMCID002502
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINACID002513
TungstenChina Molybdenum Co., Ltd.CHINACID002641
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINACID000258
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINACID000281
TungstenCP Metals Inc.UNITED STATES OF AMERICACID003448
TungstenFujian Ganmin RareMetal Co., Ltd.CHINACID003401
TungstenFujian Jinxin Tungsten Co., Ltd.CHINACID000499
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINACID002645
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINACID000875
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINACID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINACID002494
TungstenGEM Co., Ltd.CHINACID003417
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICACID000568
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINACID000218
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANYCID002542
TungstenH.C. Starck Tungsten GmbHGERMANYCID002541
TungstenHunan Chenzhou Mining Co., Ltd.CHINACID000766
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiCHINACID002579
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINACID000769
TungstenHunan Litian Tungsten Industry Co., Ltd.CHINACID003182
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONCID002649
TungstenJapan New Metals Co., Ltd.JAPANCID000825
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINACID002551
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINACID002321
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINACID002313
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINACID002318
TungstenJiangxi Xianglu Tungsten Co., Ltd.CHINACID002647
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINACID002317
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINACID002316
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONCID003408
12



TungstenKennametal FallonUNITED STATES OF AMERICACID000966
TungstenKennametal HuntsvilleUNITED STATES OF AMERICACID000105
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OFCID003388
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINACID003407
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINACID002319
TungstenMasan Tungsten Chemical LLC (MTC)VIET NAMCID002543
TungstenMoliren Ltd.RUSSIAN FEDERATIONCID002845
TungstenNiagara Refining LLCUNITED STATES OF AMERICACID002589
TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATIONCID003416
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESCID002827
TungstenTejing (Vietnam) Tungsten Co., Ltd.VIET NAMCID001889
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONCID002724
TungstenWolfram Bergbau und Hutten AGAUSTRIACID002044
TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OFCID002843
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINACID002320
TungstenXiamen Tungsten Co., Ltd.CHINACID002082
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINACID002830
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.CHINACID002095























13



Appendix B Country of Origin List:
Country List
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
14



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 Of Korea
Russia
Rwanda
Saudi Arabia
Sierra Leone
Singapore
Slovakia
Slovenia
15



South Africa
Spain
Sudan
Suri
Suriname
Sweden
Switzerland
Tanzania
Thailand
Turkey
Uganda
United Arab Emirates
United Kingdom
USA
Uzbekistan
Vietnam
Zambia
Zimbabwe


16