UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM SD

 

 

Specialized Disclosure Report

 

 

LG Display Co., Ltd.

(Exact name of registrant as specified in its charter)

 

 

 

The Republic of Korea		1-32238		Not applicable
(State or other jurisdiction of incorporation)		(Commission File Number)		(I.R.S. Employer Identification No.)
LG Twin Towers 128 Yeoui-daero, Yeongdeungpo-gu Seoul 07336, The Republic of Korea				Seoul 07336
(Address of principal executive offices)				(Zip Code)

MyoungWoon Ahn

LG Display Co., Ltd. Investor Relations Team

+82-2-3777-1010

(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 and 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

A company is required to file Form SD pursuant to Rule 13p-1 promulgated under the Exchange Act if it manufactures, or contracts to manufacture, products for which certain specified minerals are necessary to the functionality or production of the products. These minerals consist of columbite-tantalite (also referred to as “coltan”), cassiterite and wolframite (and their derivatives tantalum, tin, and tungsten), and gold and are referred to as “conflict minerals” (also referred to herein as “3TG minerals”) regardless of the geographic origin of the minerals and whether or not they fund armed conflict.

LG Display Co., Ltd. (together with its consolidated subsidiaries, also referred to herein as “we” or “our”) manufactures display panels and OLED light panels for which we have determined that 3TG minerals are necessary to the functionality or production of those products. Accordingly, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) with respect to 3TG minerals contained in those products manufactured in 2019. We believe our RCOI was reasonably designed to determine whether any 3TG minerals contained in our products originated in the Democratic Republic of the Congo or an adjoining country (together, the “Covered Countries”), or are from recycled or scrap sources.

We have prepared a Conflict Minerals Report, which is attached as an exhibit hereto and also publicly available on our website at www.lgdisplay.com.

 

Item 1.02:

Exhibit

A Conflict Minerals Report is attached as Exhibit 1.01 to this report.

SECTION 2 – EXHIBITS

 

Item 2.01:

Exhibits

 

Exhibit No.		Description
1.01		Conflict Minerals Report for the reporting period from January 1, 2019 to December 31, 2019

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.

 

LG Display Co., Ltd. (Registrant)
By:		/s/ YungKeun Choi				Date: May 29, 2020
		YungKeun Choi
		Head of Purchasing Group

EXHIBIT INDEX

 

Exhibit No.		Description
1.01		Conflict Minerals Report

Exhibit 1.01

CONFLICT MINERALS REPORT OF LG DISPLAY CO., LTD.

FOR THE YEAR ENDED DECEMBER 31, 2019

This is the Conflict Minerals Report of LG Display Co., Ltd. for the year ended December 31, 2019 (this “Report”). In this Report, the terms “we,” “us” and “our” refer to LG Display Co., Ltd. and its consolidated subsidiaries. Capitalized terms in this Report that have not been expressly defined herein have the meanings assigned to them in Rule 13p-1 (“Rule 13p-1”) under the Exchange Act of 1934, as amended (the “Exchange Act”), and Form SD.

A company is required to file Form SD with the U.S. Securities and Exchange Commission (“SEC”) pursuant to Rule 13p-1 if it manufactures, or contracts to manufacture, products for which certain specified minerals are necessary to the functionality or production of the products. These minerals consist of columbite-tantalite (also referred to as “coltan”), cassiterite and wolframite (and their derivatives tantalum, tin, and tungsten), and gold and are referred to as “conflict minerals” (also referred to as “3TG minerals” in this Report) regardless of the geographic origin of the minerals and whether or not they fund armed conflict.

This Report is also publicly available on our website at: www.lgdisplay.com/eng/sustainability/safetyEnvironment/conflictMinerals/certification

This document includes forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995, including (but not limited to) statements about expected future supplier diligence and engagement efforts, development of our systems supporting those efforts and participation in industry supply chain efforts. Many of the forward-looking statements contained in this document may be identified by the use of words such as “believe,” “expect,” “anticipate,” “should,” “planned,” “estimate” and “potential,” among others. These forward-looking statements are based on our expectations and beliefs concerning future events and involve risks and uncertainties that may cause actual results to differ materially from current expectations. These risks and uncertainties are difficult to predict accurately and may be beyond our control, and may include (but are not limited to) the following: regulatory changes and judicial developments relating to conflict minerals disclosure; changes in or developments related to our products or our supply chain; industry developments relating to supply chain diligence, disclosure and other practices; and cost considerations. Other risks and uncertainties relevant to our forward-looking statements are discussed in greater detail in our reports filed with the SEC. Forward-looking statements in this document speak only as of the date made, and we disclaim any obligation to update or revise these statements as a result of new developments or otherwise.

Company and Product Overview

We are a leading innovator of thin-film transistor liquid crystal display (“TFT-LCD”) technology, organic light-emitting diode (“OLED”) technology and other display panel technologies. We manufacture and sell display panels in a broad range of sizes and specifications primarily to end-brand customers who incorporate our display panels as component parts in the manufacture and assembly of televisions, notebook computers, desktop monitors, tablet computers and mobile and other application products. We also manufacture and sell OLED light panels. 3TG minerals are commonly used in electronic products in general, and we have determined that they are necessary to the functionality of our display panels and light panels, which consist of thousands of component parts and raw materials, including circuit components such as chips, wires and electrodes that are coated using 3TG minerals, and transparent electrodes for which 3TG minerals are a key material.

 

1

For additional information about our business in general, please refer to our most recent annual report on Form 20-F for the year ended 2019 filed with the SEC on April 29, 2020.

Conflict Minerals Policy

As a responsible corporate citizen, we believe in ethical sourcing and have formulated and announced a conflict minerals policy (our “Policy”), which is to eliminate from our products the use of 3TG minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together, the “Covered Countries”). Our current Policy is publicly available on our website at www.lgdisplay.com/eng/sustainability/safetyEnvironment/conflictMinerals/policy and serves as a common reference point for all our suppliers and us internally.

Results of Reasonable Country of Origin Inquiry

As required under Rule 13p-1, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) with respect to 3TG minerals contained in our products manufactured in 2019. We believe our RCOI was reasonably designed to determine whether any 3TG minerals contained in our products originated in the Covered Countries or were from recycled or scrap sources.

Based on our RCOI, and as described further below, although we did not find any indication that the 3TG minerals necessary to the functionality of our products originated from a Covered Country, we concluded that we had insufficient information to determine that there was no reason to believe that the 3TG minerals necessary to the functionality of our products may have originated from a Covered Country or were not from recycled or scrap sources.

Source and Chain of Custody Due Diligence

Given the results of our RCOI, we engaged in additional due diligence on the source and chain of custody of the 3TG minerals necessary to the functionality of our products. As further described below, our due diligence conformed in all material respects to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Second Edition) and related Supplements (“OECD Guidance”) for downstream companies.

 

2

As an integral part of our source and chain of custody due diligence, we have conducted supply chain surveys by requesting that our suppliers of component parts and raw materials used in our products (the “Covered Suppliers”) fill out the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”), which is an initiative founded by members of the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative and was formerly named the Conflict-Free Sourcing Initiative. Responsible Minerals Assurance Process (“RMAP”), which was formerly called the Conflict-Free Smelter Program, of the RMI uses an independent third-party audit to identify smelters and refiners that have systems in place to assure sourcing of only minerals not benefitting armed groups in the Covered Countries. Further, we have requested certifications from each Covered Supplier regarding the truthfulness of its CMRT responses.

Company Management System

Our senior management established a 3TG minerals task force consisting of managerial level employees from our Purchasing Planning Team, Legal Department and Investor Relations Team along with outside consultants (the “Task Force”) to take the lead in formulating our Policy, implementing our Policy with our suppliers and us internally and conducting due diligence on our supply chain based on the OECD Guidance. The Task Force assigned roles and responsibilities to relevant internal teams and departments to implement our Policy and established a process for monitoring 3TG minerals in our supply chain.

Further to our efforts to more accurately identify the use of 3TG minerals in our supply chain, we implemented a conflict minerals management system (our “System”) for the overall management and coordination of our processes related to 3TG minerals, including verification of supplier data, immediate risk assessments and analyses of 3TG minerals usage statistics. The implementation of our System has enabled us to categorize and monitor our 3TG minerals usage by buyer and model, on a real-time basis, and to track 3TG minerals throughout our supply chain.

In 2014, the continuing roles and responsibilities of the Task Force were transferred to the Purchasing Group. Within the Purchasing Group, the Purchasing Planning Team sets overall strategy and response processes, and the frontline purchasing teams obtain and verify data from our suppliers. Our chief production officer and the head of the Purchasing Group review monthly status reports and remain highly involved in the management of our System, as does our chief executive officer who is briefed with status updates periodically.

In 2013 and 2014, we engaged with senior management and working level personnel of our direct Covered Suppliers as well as second- and third-tier suppliers to raise awareness of regulations applicable to the sourcing of 3TG minerals and to educate them on our Policy, as well as to share policy guidelines and updates on conflict minerals management in an effort to facilitate compliance on their part. Since 2015, we have conducted additional supplier education outreach to suppliers for whom we deemed such additional outreach was necessary.

The implementation of our System and our supplier education efforts have also contributed to the reliability and accuracy of the information we are able to garner from and about our supply chain. In 2019, as a result of verification efforts by us and our suppliers, including direct communications with listed entities and requests for product-by-product level CMRT responses from our suppliers, we were able to identify 258 smelters and refiners that we believed were operational and still in our supply chain as of December 31, 2019.

 

3

We have continued in our efforts to identify and monitor smelters and refiners and encourage them to receive verification as independently audited under the RMAP of the RMI. We have also established an action plan to address unaudited smelters and refiners; to improve the integrity and accuracy of the information in our 3TG minerals database; and to hedge our exposure to operational risks associated with 3TG minerals.

In furtherance of our Policy, we require all of our suppliers to agree to terms that reflect our Policy. In the case of Covered Suppliers who responded that they do not use 3TG minerals or that they source from smelters or refiners that have been verified as conformant with the RMAP’s assessment protocols (“RMAP-conformant”), we require that they covenant not to use 3TG minerals that directly or indirectly finance or benefit armed groups in the Covered Countries. We have also developed a supplier code of conduct and we encourage our suppliers to formulate their own 3TG policies and identify all smelters and refiners that supply 3TG minerals in their supply chains. To encourage compliance with our Policy, we have also made the reporting center, including the cyber reporting center, of our Administrative Office of Ethics available to our employees, suppliers and other stakeholders to report any alleged violations of our Policy on a confidential basis. In addition, with a view to efficiently and practically address applicable regulations, we continue to attend governmental and non-governmental forums and conferences, and actively participate in a consultation committee with our affiliates, LG Electronics, LG Chem and LG Innotek.

Supply Chain Risk Identification and Assessment

In their CMRT responses, our Covered Suppliers identified smelters and refiners that they listed as sources for the 3TG minerals contained in the component parts and raw materials they supply. We further checked whether any of these smelters or refiners were located in or near Covered Countries or areas suspected of transporting or sourcing 3TG minerals from Covered Countries. We utilized our System to perform immediate risk assessments on our Covered Suppliers’ 3TG mineral information and informed our Covered Suppliers of applicable risks. We continue to monitor the risk hedging activities of our Covered Suppliers.

Based on their CMRT responses, we assessed the risk associated with the Covered Suppliers, smelters and refiners and categorized each Covered Supplier into one of the following three categories:

 

•

No Risk: Supplier either (i) reported no 3TG minerals are contained in component parts or raw materials it supplies or (ii) reported it sources 3TG minerals only from RMAP-conformant smelters and refiners, and confirmed such 3TG minerals do not directly or indirectly finance or benefit armed groups in the Covered Countries.

 

•

Low Risk: Supplier reported it sources 3TG minerals only from RMAP-conformant smelters but did not provide separate confirmation that such 3TG minerals do not directly or indirectly finance or benefit armed groups in the Covered Countries.

 

•

High Risk: Supplier reported it sources 3TG minerals from smelters and refiners that were not independently audited under the RMAP.

 

4

Response Strategy to Identified Risk

To address the identified risks, we established a risk hedging plan with respect to suppliers in the High Risk category. Pursuant to the risk hedging plan, we instructed suppliers within the High Risk category to adhere to the following alternatives:

 

•

Require the non-conformant smelter or refiner to be independently audited under the RMAP;

 

•

Reroute sourcing of 3TG minerals to RMAP-conformant smelters and refiners;

 

•

Eliminate from their supply chain smelters or refiners that were not RMAP-conformant; or

 

•

Reroute sourcing to up-stream suppliers that source only from RMAP-conformant smelters and refiners.

We have historically selected suppliers which were in the High Risk category for additional due diligence. The selection criteria for these suppliers also included whether the supplier had a 3TG minerals policy of its own, the importance of the supplier to our production process (in terms of proportion of purchases), the extent to which the supplier sourced 3TG minerals from smelters and refiners that were not independently audited under the RMAP, the geographic location of the supplier and the geographic location of the smelters and refiners identified by the supplier. We have conducted on-site due diligence of these selected suppliers and examined their 3TG minerals management levels by reviewing the CMRT responses, 3TG minerals policies and internal processes of their up-stream suppliers. We have engaged in additional training and education with these selected suppliers on applicable regulations and how to improve their 3TG minerals management and we have assessed their improvements and grievances.

Third-party Independent Audit of Supply Chain

As a downstream company, there are many steps in the supply chain separating us from the mines, smelters and refiners that source the 3TG minerals contained in our products. With respect to smelters and refiners known to be in our supply chain, we make reference to independent third-party audits used by the RMAP to identify smelters and refiners that have systems in place to assure sourcing of only minerals not benefitting armed groups in the Covered Countries. We have not obtained an independent third-party audit of our own supply chain.

We will continue to support private and public efforts to encourage sourcing of 3TG minerals not benefitting armed groups in the Covered Countries.

Results of Source and Chain of Custody Due Diligence

We obtained CMRT responses from 100% of our Covered Suppliers, excluding suppliers no longer in our supply chain, as of December 31, 2019. We assessed the conformity and reliability of these CMRT responses, conducted risk analyses and compliance improvement activities, and provided regular progress updates to our chief executive officer and other relevant members of management. In addition, we implemented strict limitations on authorizing transactions with new suppliers where risks materialized. We believe that these efforts have driven the following results.

 

5

Based on the CMRT responses provided by our Covered Suppliers and our further due diligence to confirm the usage of 3TG minerals within our supply chain, we identified a total of 258 entities as smelters or refiners from which 3TG minerals were sourced. All of the 258 smelters and refiners we identified in 2019 were independently audited under the RMAP and designated as “conformant,” and there were no smelters or refiners that were (x) progressing towards completion of an independent audit under the RMAP and designated as “active” or (y) not independently audited under the RMAP (“non-participating”).

As a result of our source and chain of custody due diligence for the year ended December 31, 2019, we were able to confirm that 100% of the tantalum, tin, tungsten and gold smelters known to be in our supply chain as of December 31, 2019 were RMAP-conformant. We therefore found no reasonable basis for concluding that our sourcing of 3TG minerals necessary to the functionality of our products directly or indirectly financed or benefitted armed groups in the Covered Countries.

The following table sets forth the number of smelters and refiners in our supply chain by RMAP status and type of mineral.

 

Status of identified smelters and refiners		Tantalum				Tin				Tungsten				Gold				Total
Conformant			40				73				40				105				258
Active			—				—				—				—				—
Non-participating			—				—				—				—				—
Total			40				73				40				105				258
Total conformant ratio (%)			100	%			100	%			100	%			100	%			100	%

Based on the information provided by our suppliers and our own due diligence efforts with known smelters and refiners through December 31, 2019, we believe that the facilities that may have been used to process the 3TG minerals in our products include the smelters and refiners listed in Annex I below.

Future Measures

We will continue to seek to source all 3TG minerals in our supply chain from smelters and refiners that are RMAP-conformant or that have otherwise been verified under an independent third-party audit as sourcing only minerals not benefitting armed groups in the Covered Countries, and we intend to do so through the following measures:

 

•

Continue conducting due diligence of our supply chain and educating and training our Covered Suppliers in order to drive proactive measures by such suppliers;

 

6

•

Pursue voluntary participation in the RMAP by more smelters and refiners;

 

•

Continue information sharing and collaborative efforts with governmental and non-governmental entities and academia; and

 

•

Aim to eliminate from our supply chain and products the use of not only 3TG minerals that directly or indirectly finance or benefit armed groups in the Covered Countries, but also minerals from unethical sources that would cause human rights violations or environmental destruction.

 

7

Annex I

Conformant Smelters and Refiners

 

Mineral		Smelter or Refiner Name		Country
Tantalum		Asaka Riken Co., Ltd.		Japan
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		China
Tantalum		Conghua Tantalum and Niobium Smeltry		China
Tantalum		Exotech Inc.		United States of America
Tantalum		F&X Electro-Materials Ltd.		China
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		China
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		China
Tantalum		Jiujiang Tanbre Co., Ltd.		China
Tantalum		LSM Brasil S.A.		Brazil
Tantalum		Metallurgical Products India Pvt., Ltd.		India
Tantalum		Mineração Taboca S.A.		Brazil
Tantalum		Mitsui Mining & Smelting		Japan
Tantalum		Molycorp Silmet A.S.		Estonia
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		China
Tantalum		QuantumClean		United States of America
Tantalum		RFH Tantalum Smeltry Co., Ltd.		China
Tantalum		Solikamsk Magnesium Works OAO		Russia
Tantalum		Taki Chemicals		Japan
Tantalum		Telex Metals		United States of America
Tantalum		Ulba Metallurgical Plant JSC		Kazakhstan
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		China
Tantalum		D Block Metals, LLC		United States of America
Tantalum		FIR Metals & Resource Ltd.		China
Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		China
Tantalum		XinXing HaoRong Electronic Material Co., Ltd.		China
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		China
Tantalum		KEMET Blue Metals		Mexico
Tantalum		H.C. Starck Co., Ltd.		Thailand
Tantalum		H.C. Starck GmbH Goslar		Germany
Tantalum		H.C. Starck Hermsdorf GmbH		Germany
Tantalum		H.C. Starck Inc.		United States of America
Tantalum		H.C. Starck Ltd.		Japan
Tantalum		H.C. Starck Smelting GmbH & Co.KG		Germany
Tantalum		Global Advanced Metals Boyertown		United States of America
Tantalum		Global Advanced Metals Aizu		Japan
Tantalum		KEMET Blue Powder		United States of America
Tantalum		Resind Indústria e Comércio Ltda		Brazil
Tantalum		Jiangxi Tuohong New Raw Material		China
Tantalum		Power Resources Ltd		Macedonia
Tantalum		Jiujiang Janny New Material Co., Ltd.		China
Tin		Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.		China
Tin		Alpha		United States of America
Tin		CV Gita Pesona		Indonesia
Tin		PT Aries Kencana Sejahtera		Indonesia
Tin		CV Serumpun Sebalai		Indonesia
Tin		CV United Smelting		Indonesia
Tin		Dowa		Japan
Tin		EM Vinto		Bolivia
Tin		Fenix Metals		Poland
Tin		Gejiu Non-Ferrous Metal Processing Co., Ltd.		China
Tin		Gejiu Zili Mining And Metallurgy Co., Ltd.		China
Tin		Huichang Jinshunda Tin Co., Ltd.		China
Tin		Gejiu Kai Meng Industry and Trade LLC		China
Tin		China Tin Group Co., Ltd.		China
Tin		Malaysia Smelting Corporation (MSC)		Malaysia

 

A-1

Tin		Metallic Resources, Inc.		United States of America
Tin		Mineração Taboca S.A.		Brazil
Tin		Minsur		Peru
Tin		Mitsubishi Materials Corporation		Japan
Tin		Nankang Nanshan Tin Manufactory Co., Ltd.		China
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		Thailand
Tin		Operaciones Metalurgical S.A.		Bolivia
Tin		PT Artha Cipta Langgeng		Indonesia
Tin		PT Babel Inti Perkasa		Indonesia
Tin		PT Bangka Tin Industry		Indonesia
Tin		PT Belitung Industri Sejahtera		Indonesia
Tin		PT Bukit Timah		Indonesia
Tin		PT DS Jaya Abadi		Indonesia
Tin		PT Karimun Mining		Indonesia
Tin		PT Mitra Stania Prima		Indonesia
Tin		PT Panca Mega Persada		Indonesia
Tin		PT Prima Timah Utama		Indonesia
Tin		PT REFINED BANGKA TIN		Indonesia
Tin		PT Sariwiguna Binasentosa		Indonesia
Tin		PT Stanindo Inti Perkasa		Indonesia
Tin		PT Sumber Jaya Indah		Indonesia
Tin		PT Timah (Persero) Tbk Kundur		Indonesia
Tin		PT Timah (Persero) Tbk Mentok		Indonesia
Tin		PT Tinindo Inter Nusa		Indonesia
Tin		PT Tommy Utama		Indonesia
Tin		Rui Da Hung		Taiwan
Tin		Soft Metais Ltda.		Brazil
Tin		Thaisarco		Thailand
Tin		Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.		China
Tin		White Solder Metalurgia e Mineração Ltda.		Brazil
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		China
Tin		Yunnan Tin Group (Holding) Company Limited		China
Tin		CV Venus Inti Perkasa		Indonesia
Tin		Magnu’s Minerais Metais e Ligas Ltda.		Brazil
Tin		PT Tirus Putra Mandiri		Indonesia
Tin		Melt Metais e Ligas S/A		Brazil
Tin		PT ATD Makmur Mandiri Jaya		Indonesia
Tin		O.M. Manufacturing Philippines, Inc.		Philippines
Tin		PT Inti Stania Prima		Indonesia
Tin		CV Ayi Jaya		Indonesia
Tin		CV Dua Sekawan		Indonesia
Tin		CV Tiga Sekawan		Indonesia
Tin		Resind Indústria e Comércio Ltda		Brazil
Tin		Metallo-Chimique N.V.		Belgium
Tin		Elmet S.L.U. (Metallo Group)		Spain
Tin		PT Bangka Prima Tin		Indonesia
Tin		PT Sukses Inti Makmur		Indonesia
Tin		PT Kijang Jaya Mandiri		Indonesia
Tin		Thai Nguyen Mining and Metallurgy Co., Ltd.		Vietnam
Tin		PT Menara Cipta Mulia		Indonesia
Tin		HuiChang Hill Tin Industry Co., Ltd.		China
Tin		Gejiu Fengming Metallurgy Chemical Plant		China
Tin		Guanyang Guida Nonferrous Metal Smelting Plant		China
Tin		PT Lautan Harmonis Sejahtera		Indonesia
Tin		Guangdong Hanhe Non-ferrous Metal Limited Company		China
Tin		Chifeng Dajingzi Tin Industry Co., Ltd.		China
Tin		PT Bangka Serumpun		Indonesia

 

A-2

Tin		Tin Technology & Refining		United States of America
Tungsten		A.L.M.T. TUNGSTEN Corp.		Japan
Tungsten		Kennametal Huntsville		United States of America
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		China
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		China
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		China
Tungsten		Global Tungsten & Powders Corp.		United States of America
Tungsten		Hunan Chenzhou Mining Group Co., Ltd.		China
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		China
Tungsten		Japan New Metals Co., Ltd.		Japan
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		China
Tungsten		Kennametal Fallon		United States of America
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		Vietnam
Tungsten		Wolfram Bergbau und Hütten AG		Austria
Tungsten		Xiamen Tungsten Co., Ltd.		China
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		China
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		China
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		China
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		China
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		China
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		China
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		China
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		China
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		China
Tungsten		Asia Tungsten Products Vietnam Ltd.		Vietnam
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		China
Tungsten		H.C. Starck GmbH		Germany
Tungsten		H.C. Starck Smelting GmbH & Co.KG		Germany
Tungsten		Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC		Vietnam
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		China
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		China
Tungsten		Niagara Refining LLC		United States of America
Tungsten		Ganzhou Haichuang Tungsten Co., Ltd.		China
Tungsten		Hydrometallurg, JSC		Russia
Tungsten		Unecha Refractory metals plant		Russia
Tungsten		Philippine Chuangxin Industrial Co., Inc.		Philippines
Tungsten		Xinfeng Huarui Tungsten & Molbdenum New Material Co., Ltd.		China
Tungsten		ACL Metais Eireli		Brazil
Tungsten		Woltech Korea Co., Ltd.		Republic of Korea
Tungsten		Moliren Ltd		Russia
Tungsten		KGETS CO., LTD.		Republic of Korea
Gold		Advanced Chemical Company		United States of America
Gold		Aida Chemical Industries Co., Ltd.		Japan
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		Germany
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		Uzbekistan
Gold		AngloGold Ashanti Córrego do Sítio Mineração		Brazil
Gold		Argor-Heraeus SA		Switzerland
Gold		Asahi Pretec Corporation		Japan

 

A-3

Gold		Asaka Riken Co., Ltd.		Japan
Gold		Aurubis AG		Germany
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		Philippines
Gold		Boliden AB		Sweden
Gold		C. Hafner GmbH + Co. KG		Germany
Gold		CCR Refinery – Glencore Canada Corporation		Canada
Gold		Cendres + Métaux SA		Switzerland
Gold		Chimet S.p.A.		Italy
Gold		Chugai Mining		Japan
Gold		Daejin Indus Co., Ltd.		Republic of Korea
Gold		Do Sung Corporation		Republic of Korea
Gold		Doduco		Germany
Gold		Dowa		Japan
Gold		Eco-System Recycling Co., Ltd.		Japan
Gold		OJSC Novosibirsk Refinery		Russia
Gold		HeeSung Metal Ltd.		Republic of Korea
Gold		Heimerle + Meule GmbH		Germany
Gold		Heraeus Ltd. Hong Kong		China
Gold		Heraeus Precious Metals GmbH & Co. KG		Germany
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Company		China
Gold		Ishifuku Metal Industry Co., Ltd.		Japan
Gold		Istanbul Gold Refinery		Turkey
Gold		Japan Mint		Japan
Gold		Jiangxi Copper Company Limited		China
Gold		Johnson Matthey Inc.		United States of America
Gold		Johnson Matthey Limited		Canada
Gold		JSC Uralelectromed		Russia
Gold		JX Nippon Mining & Metals Co., Ltd.		Japan
Gold		Kazzinc		Kazakhstan
Gold		Kennecott Utah Copper LLC		United States of America
Gold		Kojima Chemicals Co., Ltd.		Japan
Gold		Kyrgyzaltyn JSC		Kyrgyzstan
Gold		LS-NIKKO Copper Inc.		Republic of Korea
Gold		Materion		United States of America
Gold		Matsuda Sangyo Co., Ltd.		Japan
Gold		Metalor Technologies (Suzhou) Ltd.		China
Gold		Metalor Technologies (Hong Kong) Ltd.		China
Gold		Metalor Technologies (Singapore) Pte., Ltd.		Singapore
Gold		Metalor Technologies SA		Switzerland
Gold		Metalor USA Refining Corporation		United States of America
Gold		METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V		Mexico
Gold		Mitsubishi Materials Corporation		Japan
Gold		Mitsui Mining and Smelting Co., Ltd.		Japan
Gold		Moscow Special Alloys Processing Plant		Russia
Gold		Nadir Metal Rafineri San. Ve Tic. A.Ş.		Turkey
Gold		Nihon Material Co., Ltd.		Japan
Gold		Ohura Precious Metal Industry Co., Ltd.		Japan
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant”		Russia
Gold		PAMP SA		Switzerland
Gold		Prioksky Plant of Non-Ferrous Metals		Russia
Gold		PT Aneka Tambang (Persero) Tbk		Indonesia
Gold		PX Précinox SA		Switzerland
Gold		Rand Refinery (Pty) Ltd.		South Africa
Gold		Royal Canadian Mint		Canada
Gold		Samduck Precious Metals		Republic of Korea
Gold		SEMPSA Joyería Platería SA		Spain
Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.		China

 

A-4

Gold		Sichuan Tianze Precious Metals Co., Ltd.		China
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		Russia
Gold		Solar Applied Materials Technology Corp.		Taiwan
Gold		Sumitomo Metal Mining Co., Ltd.		Japan
Gold		Tanaka Kikinzoku Kogyo K.K.		Japan
Gold		The Refinery of Shandong Gold Mining Co., Ltd.		China
Gold		Tokuriki Honten Co., Ltd.		Japan
Gold		Torecom		Republic of Korea
Gold		Umicore Brasil Ltda.		Brazil
Gold		Umicore SA Business Unit Precious Metals Refining		Belgium
Gold		United Precious Metal Refining, Inc.		United States of America
Gold		Valcambi SA		Switzerland
Gold		Western Australian Mint trading as The Perth Mint		Australia
Gold		YAMAMOTO PRECIOUS METAL CO., LTD.		Japan
Gold		Yokohama Metal Co., Ltd.		Japan
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		China
Gold		Zijin Mining Group Co., Ltd. Gold Refinery		China
Gold		Umicore Precious Metals Thailand		Thailand
Gold		Geib Refining Corporation		United States of America
Gold		MMTC-PAMP India Pvt., Ltd.		India
Gold		KGHM Polska Miedź Spółka Akcyjna		Poland
Gold		Singway Technology Co., Ltd.		Taiwan
Gold		Al Etihad Gold Refinery DMCC		United Arab Emirates
Gold		Emirates Gold DMCC		United Arab Emirates
Gold		T.C.A S.p.A		Italy
Gold		Remondis Argentia B.V.		Netherlands
Gold		Korea Zinc Co. Ltd.		Republic of Korea
Gold		Marsam Metals		Brazil
Gold		SAAMP		France
Gold		L’Orfebre S.A.		Andorra
Gold		8853 S.p.A		Italy
Gold		Italpreziosi		Italy
Gold		SAXONIA Edelmetalle GmbH		Germany
Gold		WIELAND Edelmetalle GmbH		Germany
Gold		Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH		Austria
Gold		AU Traders and Refiners		South Africa
Gold		Bangalore Refinery		India
Gold		SungEel HiMetal Co., Ltd.		Republic of Korea
Gold		Planta Recuperadora de Metales SpA		Chile
Gold		Safimet S.p.A		Italy
Gold		DS PRETECH Co., Ltd.		Republic of Korea

 

A-5