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

FORM SD

SPECIALIZED DISCLOSURE REPORT

TriMas Corporation
(Exact name of registrant as specified in its charter)


 
 
 
 
 
 
 
 
 
 
 
Delaware
(State or other jurisdiction
of incorporation)
 
001-10716
(Commission
File Number)
 
38-2687639
(IRS Employer
Identification No.)

38505 Woodward Avenue, Suite 200 Bloomfield Hills, Michigan
(Address of principal
executive offices)

 
 
 
48304
(Zip Code)

Joshua A. Sherbin, Senior Vice President, General Counsel and Chief Compliance Officer, 248-631-5400
(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

Item 1.01. Conflict Minerals Disclosure and Report.

Introduction
TriMas Corporation ("TriMas" or the "Company"), and its consolidated subsidiaries, is a global manufacturer and distributor of products for commercial, industrial and consumer markets. The Company is principally engaged in the following reportable segments with diverse products and market channels: Packaging, Aerospace and Specialty Products. TriMas is filing this Form SD ("Form SD") pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule") for the reporting period January 1, 2019 to December 31, 2019 (the "Reporting Period").

TriMas manufactures or contracts to manufacture "products" that may contain certain "conflict minerals" (as defined below) that are necessary to the functionality or production of such products. Form SD defines "conflict minerals" as: (i)(a) columbite-tantalite (or coltan, the metal ore from which tantalum is extracted), (b) cassiterite (the metal ore from which tin is extracted), (c) gold and (d) wolframite (the metal ore from which tungsten is extracted), or their derivatives; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (collectively, the "Covered Countries").

Conflict Minerals Disclosures
In accordance with the Rule and Form SD, TriMas has conducted a good faith reasonable country of origin inquiry ("RCOI") regarding the conflict minerals included in its products during the Reporting Period to determine whether any of such conflict minerals originated in the Covered Countries and/or whether any of such conflict minerals may be from recycled or scrap sources.

In accordance with the Rule, TriMas has filed this Form SD and the associated Conflict Minerals Report, each of which are posted to TriMas’ publicly available internet site at www.trimascorp.com.

Item 1.02. Exhibit.

A description of the RCOI and the measures TriMas took to exercise due diligence on the source and chain of custody of certain of its conflict minerals is provided in the Conflict Minerals Report attached hereto as Exhibit 1.01. The content on, or accessible through, any website referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.

Section 2 – Exhibits

Item 2.01. Exhibits.

Exhibit Number
Description
1.01








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.

TriMas Corporation


 
 
 
 
/s/ Joshua A. Sherbin
 
May 29, 2020
Name: Joshua A. Sherbin
 
Date
Title: Senior Vice President, General Counsel, Chief Compliance
     Officer and Corporate Secretary
 
 


Exhibit


Exhibit 1.01

TriMas Corporation
Conflict Minerals Report
For the Reporting Period January 1, 2019 to December 31, 2019

TriMas Corporation (TriMas or the Company) is filing this Conflict Minerals Report (CMR) for the reporting period January 1, 2019 to December 31, 2019 (the Reporting Period) as an exhibit to its Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). TriMas manufactures or contracts to manufacture "products" that may contain conflict minerals, as defined by the Rule, present in its supply chain that may have originated in the Democratic Republic of the Congo or an adjoining country (the Covered Countries) and may not be from recycled or scrap sources. Accordingly, TriMas is filing this CMR as an exhibit to Form SD to describe the due diligence measures taken to determine the source and chain of custody of the conflict minerals used in its products during the Reporting Period.

Reasonable Country of Origin Inquiry

In accordance with the Rule and Form SD, TriMas conducted a good faith reasonable country of origin inquiry (RCOI) regarding the conflict minerals included in its products during the Reporting Period to determine whether any of such conflict minerals originated in the Covered Countries and/or whether any of such conflict minerals may be from recycled or scrap sources.

To determine whether tin, tantalum, tungsten or gold (3TG) necessary to the functionality or production of supplier products originated in Covered Countries, TriMas retained Assent Compliance (Assent), a third-party service provider, to assist in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager (ACM).

To collect data on the materials’ sources of origin procured by the supply chain, TriMas utilized the Conflict Minerals Reporting Template (CMRT) version 5.12 or higher to conduct a survey of all in-scope suppliers.

During the supplier survey, the Company contacted suppliers via the ACM platform, enabling users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the Organization for Economic Cooperation and Development’s (OECD) Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.

Via the ACM and Assent team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the ACM for future reporting and transparency. TriMas directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to Assent.

The Company’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk





assessment, as well as understand the due diligence efforts of tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

All submitted forms are accepted and classified as valid or invalid. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct validation errors in their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, TriMas tracks program gaps to account for future improvement opportunities.

Based on the findings through the RCOI process, the Company determined the countries of origin for a large portion of the 3TGs in its products. TriMas continued to perform further due diligence on the source and chain of custody of the minerals in question.

Due Diligence

Design of Due Diligence

TriMas’ due diligence process is based on OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements. The OECD Guidance applies to both upstream1 and downstream2 companies in the supply chain. As TriMas is a downstream company in the supply chain, TriMas’ tailored its due diligence practices accordingly. Due diligence measures undertaken by TriMas included those described below.

Due Diligence Performed

Establish Strong Company Management Systems

Adopt a Conflict Minerals Policy
TriMas adopted a Responsible Sourcing and Conflict Minerals Policy (Conflict Minerals Policy). This policy is available on the TriMas website at .

Assemble an Internal Team to Support Supply Chain Due Diligence
TriMas senior management identified individuals representing multiple TriMas departments and business units to oversee and drive conflict minerals compliance. Together with Assent, TriMas’ Chief Compliance Officer worked with the Company’s business units to complete tasks associated with the supplier due diligence process. Individual leads within the business units further facilitated the diligence process to collect information regarding the presence and sourcing of conflict minerals in the products supplied to TriMas.
________________
1 Upstream companies refer to those between the mine and smelters or refiners (SOR). As such, the companies typically include miners, local traders, or exporters from the country of mineral origin, international concentrate traders, and SORs.
2 Downstream companies refer to those entities between the SOR and retailer. As such, the companies typically include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers, and retailers.







Establish a System of Controls and Transparency Over The Supply Chain
To provide better transparency within TriMas’ supply chain and to facilitate communication of policies and expectations, TriMas engaged Assent to complement internal management processes. The Assent online system and processes are used to identify suppliers in TriMas’ supply chain and collect, store, and review information on conflict minerals sourcing practices, track information on SORs, and flag risks based on SOR sourcing practices. This system is designed to allow collection and housing of data on supply chain circumstances, which can be updated to reflect changes within the supply chain, such as new customer-supplier relationships and new products.

TriMas mandated compliance in its supply chain with TriMas’ Conflict Minerals Policy through its contractual terms and conditions.

TriMas maintains an ethics hotline accessible at www.trimascorp.com through which a party, including TriMas employees and suppliers, may submit reports or concerns regarding compliance, including with respect to conflict minerals.

Supplier Engagement
TriMas has increased its supply chain transparency by identifying risks within its supply chain. TriMas is committed to conducting business in a socially responsible manner and partnering with suppliers who are similarly committed. TriMas’ supplier compliance process requires that suppliers comply with various contract provisions, legal requirements and industrial standards under local, regional and national laws and regulations of the countries in which the suppliers conduct business. Through this process, TriMas remains engaged with its supply base from a compliance perspective.

During this reporting period, we utilized the CMRT to collect conflict minerals declarations from our tier 1 suppliers. These declarations were uploaded into the ACM web-based reporting platform. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements, and increase the rate of responses we have received from our suppliers to our survey requests. Assent followed-up with suppliers to ensure proper completion of the CMRT, and all communication with suppliers has been documented to reflect the degree of success of these efforts.

TriMas places a strong emphasis on supplier education and training. To accomplish this, we utilize Assent’s Learning Management System, Assent University, and provide all tier 1 suppliers access to a comprehensive conflict minerals training course. This training is tracked and evaluated based on completion of course modules. All tier 1 suppliers are encouraged to complete all relevant modules of the conflict minerals course, which include active learning techniques and testing at the end of each module.

To complete the RCOI, TriMas’ in-scope tier 1 suppliers were requested to provide information regarding the presence and sourcing of conflict minerals used in the products supplied to TriMas. The program utilized the Responsible Minerals Initiative (RMI).
Suppliers were offered two options to submit the required information, either by uploading a completed CMRT or by completing an online survey version of the template directly to a third-party platform operated by Assent.

During the supplier survey, suppliers were contacted via the ACM, operated by Assent, enabling its users to complete and track supplier communications as well as allow suppliers to upload completed CMRT forms directly to the platform for risk assessment and management. In their responses, suppliers specified whether the information provided was at the company level or the product level. Non-responsive suppliers were contacted a minimum of six times by ACM and then were also





managed by the Assent supply chain team in one-on-one communications. This included two follow-ups from the supply chain team. For the 2019 reporting period, TriMas received responses from 554 or 72.4% of its 765 surveyed suppliers. Of the 554 suppliers that provided a response, approximately 38 reported that their products contained 3TG necessary to the functionality or production of their products.

Automated data validation on all submitted CMRTs is included in the program. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. For the 2019 reporting period, TriMas had 5 invalid CMRTs, or .65% of submitted responses.

As mentioned above, the CMRTs received allowed TriMas to collect and compile, via ACM, all answers from the CMRT with respect to smelter information reflected in the CMRTs. With respect to smelter information reflected in the CMRTs, there were suppliers who did not provide smelter lists. Without having full smelter information for TriMas products from all suppliers in scope, TriMas is unable to determine whether there is sourcing from the Covered Countries. In connection with its evaluation of the CMRTs, TriMas and Assent undertook due diligence to validate supplier reports.

Information Cut-Off
The deadline for suppliers to submit RCOI information for the Reporting Period was May 19, 2020.    

Grievance Mechanism
We have established reporting mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Conflict Minerals Policy through the ethics hotline on our website at www.trimascorp.com

Records Maintenance
Under our Records Retention Policy, compliance records are maintained for 10 years.

Identify and Assess Risk in Our Supply Chain

We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. We believe many of our largest suppliers are suppliers to other SEC registrants that are subject to the Rule.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as DRC-conflict free by third-party sources such as RMI or the London Bullion Market Association (LBMA) Responsible Gold Programme, may pose a risk. Where a smelter is not identified as conflict free by such sources, we rate the risk as high, medium or low. This rating is based on various factors, including whether the smelter/refiner has been identified as a valid smelter/refiner and has an associated Smelter Identification Number (under the RMI, this is known as a CID), and the smelter’s geographic location, including proximity to the Covered Countries.

We calculate supplier risk based on the chance that a supplier provides 3TGs that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.

Additionally, each supplier is evaluated on the strength of its conflict minerals program (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of a supplier’s program are:






Do you have a policy in place that includes Covered Countries conflict-free sourcing?
Have you implemented due diligence measures for conflict-free sourcing?
Do you verify due diligence information received from your suppliers?
Does your review process include corrective action management?

The more positive the responses to these questions indicate a stronger conflict sourcing initiative.

As part of our risk management plan and to ensure suppliers understand our expectations, we have, through Assent, provided video and written training on conflict minerals and the CMRT. This includes instructions on completing the form and one-on-one email and phone discussions with supplier personnel.

In accordance with our Conflict Minerals Policy, if a supplier gives us reason to believe that it may be supplying us with 3TG from sources that may support conflict in a Covered Country, we encourage the supplier to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we may initiate steps to find replacement suppliers.

Once surveys were returned, Assent reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the RMI Responsible Minerals Assurance Process (RMAP). If an SOR was not validated by the RMAP, Assent either attempted to contact the SOR to gather more information about its sourcing practices or conducted Internet research to determine whether there are any additional publicly available sources of information regarding the SOR’s sourcing practices.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not certified Covered Country-Conflict Free may pose a risk to the supply chain. 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 OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

Geographic proximity to the Covered Countries;
Known mineral source country of origin;
RMAP audit status;
Credible evidence of unethical or conflict sourcing;
Peer Assessments conducted by credible third-party sources.

As part of our risk management plan under the OECD Guidance, when facilities with red flags are 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 the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to TriMas, and escalating up to removal of these red flag smelters from their supply chain.

As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. In addition, suppliers are guided to the Assent University learning platform for educational materials on mitigating the risk of smelters or refiners on the supply chain.

Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG smelters and refiners in our supply chain represents an appropriate effort to





determine the mines or locations of origin of the 3TGs in our supply chain. This was done by adopting methodology outlined by the RMI’s joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this industry joint effort, we made reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict Free” lists of sourced metals.

Design and Implement a Strategy to Respond to Risks
As part of TriMas’ strategy to mitigate risk and to ensure suppliers understand our expectations, we have provided video, recorded training, and documented instructions through Assent. Responses to the reporting CMRT were reviewed with specific suppliers where clarification was needed. As described in our Conflict Minerals Policy, we intend to engage any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in Covered Countries to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.

Suppliers that may expose the Company to unacceptable risks, either due to unacceptable responses to our inquiries or a refusal to respond, may be evaluated by the Company.

Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
TriMas does not have a direct relationship with conflict minerals smelters or refiners and as a result, TriMas does not perform direct audits of these entities in its supply chain. TriMas relies on the efforts of the industry associations that administer independent third-party smelter and refinery audit programs and encourages suppliers with more direct relationships with smelters to participate in comparable due diligence validation activities.

Assent conducts outreach to all smelters and refineries that are not enrolled in the RMI’s RMAP on behalf of TriMas. The purpose of this outreach is to encourage participation in the RMAP and to inquire about the facility’s sourcing practices and infrastructure.

Report Annually on Supply Chain Due Diligence
TriMas’ Form SD and CMR are publicly available at www.trimascorp.com and meet the OECD recommendation to report annually on supply chain due diligence.







Due Diligence Results

TriMas identified 765 Tier 1 Suppliers for the CMR for the Reporting Period. Approximately 72.4% responded to TriMas’ conflict minerals survey and 38 of the responding suppliers indicated one or more of the regulated conflict minerals metals as necessary to the functionality or production of the products supplied to TriMas. Based on the RCOI and the due diligence measures described in this CMR, specifically that most CMRTs are at the company level and not the product level pertaining to TriMas products, TriMas was unable to validate that any of the SORs identified by suppliers are in its supply chain.

The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the SORs identified by our direct suppliers may contain SORs that processed conflict minerals that our direct suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the SORs were used to process the conflict minerals necessary to the functionality or production of our products during 2019. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin identified were the country of origin of conflict minerals in our products during 2019, and therefore we were also unable to determine the source and chain of custody of those conflict minerals. In addition, the third-party audits conducted by the RMI, the LBMA and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMI RMAP or the LBMA Responsible Gold Programme and, as a result, are not responsible for the quality of these audits or the audit findings.

For all responses that indicated a smelter, Assent compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as “Conflict-Free,” Assent confirmed that the name was listed by RMI as a certified smelter. As of May 25, 2020, we have validated 365 SORs and we are working to validate the additional SOR entries from the submitted CMRTs. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any SORs that we have not been able to validate. Appendix A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and RMI.

In connection with our reasonable country of origin inquiry and due diligence, as applicable, our suppliers identified to us the smelters and refiners listed in Appendix A as potentially having processed the necessary 3TG contained in our products in 2019. All information included in the table is as of May 19, 2020.
Any facility reported by a supplier to us as a smelter was cross-referenced with the RMI Standard Smelter List. There were 307 legitimate smelters identified. Of these, 235 have been certified compliant to RMAP sourcing audit assessment protocol and are considered "conflict-free." An additional 7 facilities are active in the RMAP audit process. The remaining 58 facilities are not currently engaged with the RMAP audit program but have been contacted by Assent on our behalf to encourage them to undertake such an audit.
 
Steps to Improve Due Diligence and Mitigate Risk

TriMas will work to continuously improve its supply chain due diligence efforts through the following measures:






a)
Continue supply chain due diligence efforts and engagement with suppliers to identify sources of conflict minerals;
b)
Continue to clearly communicate expectations with regard to supplier compliance, transparency and sourcing;
c)
Continue to engage with suppliers that provided incomplete or uncertain smelter information or did not respond to our survey request;
d)
Continue to compare RCOI results to information collected via independent conflict free smelter validation programs; and
e)
Contact smelters identified as a result of the RCOI process and request their participation in obtaining a "conflict free" designation from an industry program.






    
Countries of Origin

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

Smelter and Refiner Risk Evaluation

Understanding the risks associated with the smelters and refiners potentially providing material into TriMas’ supply chain is an important part of the due diligence process. Through Assent, comprehensive and ongoing analysis is conducted by Assent’s smelter library manager to assess sourcing risk. This information is used to:
Provide supplier feedback
Determine the health of the Company’s overall program
Conduct outreach to smelters, refiners and their respective associations
Provide detailed analysis in this report.

The following risk categories are used for smelter evaluation and risk determination:
Geo-Risk
Did the mineral originate from or has been transported through a Covered Country?
Audit Status
Has the refiner’s due diligence practices been audited against a standard in conformance with the OECD    Guidance?
        
Assent relies on the RMI audit standard, including cross-recognition of the LBMA Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the    OECD Guidance.
Sourcing Risk

Has evidence of any other red flag that is supported by credible sources been identified?






    







 Forward-Looking Statements

This report may contain forward-looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934 about our financial condition, results of operations and business. These forward-looking statements can be identified by the use of forward-looking words, such as “may,” “could,” “should,” “estimate,” “project,” “forecast,” “intend,” “expect,” “anticipate,” “believe,” “target,” “plan” or other comparable words, or by discussions of strategy that may involve risks and uncertainties.

These forward-looking statements are subject to numerous assumptions, risks and uncertainties which could materially affect our business, financial condition or future results including, but not limited to: the severity and duration of the ongoing corona virus (“COVID-19”) pandemic on our operations, customers and suppliers, as well as related actions taken by governmental authorities and other third parties in response, each of which is uncertain, rapidly changing and difficult to predict; general economic and currency conditions; material and energy costs; risks and uncertainties associated with intangible assets, including goodwill or other intangible asset impairment charges; competitive factors; future trends; our ability to realize our business strategies; our ability to identify attractive acquisition candidates, successfully integrate acquired operations or realize the intended benefits of such acquisitions; information technology and other cyber-related risks; the performance of our subcontractors and suppliers; supply constraints; market demand; intellectual property factors; litigation; government and regulatory actions, including, without limitation, the impact of tariffs, quotas and surcharges; our leverage; liabilities imposed by our debt instruments; labor disputes; changes to fiscal and tax policies; contingent liabilities relating to acquisition activities; the disruption of operations from catastrophic or extraordinary events, including natural disasters or public health crises; the potential impact of Brexit; tax considerations relating to the Cequent spin-off; our future prospects; and other risks that are discussed in Part I, Item 1A, "Risk Factors," in our Annual Report on Form 10-K for the year ended December 31, 2019 and elsewhere in this report. The risks described in our Annual Report on Form 10-K and elsewhere in this report are not the only risks facing our Company. Additional risks and uncertainties not currently known to us or that we currently deemed to be immaterial also may materially adversely affect our business, financial position and results of operations or cash flows.

The cautionary statements set forth above should be considered in connection with any subsequent written or oral forward-looking statements that we or persons acting on our behalf may issue. We caution readers not to place undue reliance on the statements, which speak only as of the date of this report. We do not undertake any obligation to review or confirm analysts' expectations or estimates or to release publicly any revisions to any forward-looking statement to reflect events or circumstances after the date of this report or to reflect the occurrence of unanticipated events, except as required by law.



















APPENDIX A




Standard Smelter Name
Smelter Facility Location
Smelter ID
RMI Audit Status
Gold
8853 S.p.A.
ITALY
CID002763
Conformant
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
CID002708
Non Conformant
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
CID000015
Conformant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Conformant
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
CID002560
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Conformant
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
CID000058
Conformant
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Conformant
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Conformant
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Conformant
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
CID000920
Conformant
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Conformant
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Conformant
Gold
Aurubis AG
GERMANY
CID000113
Conformant
Gold
Bangalore Refinery
INDIA
CID002863
Conformant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Conformant
Gold
Boliden AB
SWEDEN
CID000157
Conformant
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Conformant
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Conformant
Gold
Cendres + Metaux S.A.
SWITZERLAND
CID000189
Conformant
Gold
Chimet S.p.A.
ITALY
CID000233
Conformant
Gold
Chugai Mining
JAPAN
CID000264
Conformant
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Conformant
Gold
Dowa
JAPAN
CID000401
Conformant





Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
CID003195
Conformant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Conformant
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
CID000425
Conformant
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
CID003424
Conformant
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
CID003425
Conformant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Conformant
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
CID002459
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
Conformant
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Conformant
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Conformant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Conformant
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Conformant
Gold
Italpreziosi
ITALY
CID002765
Conformant
Gold
Japan Mint
JAPAN
CID000823
Conformant
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Conformant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Conformant
Gold
Kazzinc
KAZAKHSTAN
CID000957
Conformant
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
CID000969
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002511
Conformant
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Conformant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Conformant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Conformant
Gold
L'Orfebre S.A.
ANDORRA
CID002762
Conformant
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Conformant
Gold
LT Metal Ltd.
KOREA, REPUBLIC OF
CID000689
Conformant
Gold
Marsam Metals
BRAZIL
CID002606
Conformant
Gold
Materion
UNITED STATES OF AMERICA
CID001113
Conformant





Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Conformant
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Conformant
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
CID001157
Conformant
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
CID001161
Conformant
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Conformant
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Non Conformant
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
CID001220
Conformant
Gold
NH Recytech Company
KOREA, REPUBLIC OF
CID003189
Non Conformant
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Conformant
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Conformant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Conformant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Conformant
Gold
PAMP S.A.
SWITZERLAND
CID001352
Conformant
Gold
Planta Recuperadora de Metales SpA
CHILE
CID002919
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Conformant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Conformant
Gold
PX Precinox S.A.
SWITZERLAND
CID001498
Conformant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Conformant
Gold
REMONDIS PMR B.V.
NETHERLANDS
CID002582
Conformant





Gold
Royal Canadian Mint
CANADA
CID001534
Conformant
Gold
SAAMP
FRANCE
CID002761
Conformant
Gold
Safimet S.p.A
ITALY
CID002973
Conformant
Gold
SAFINA A.S.
CZECH REPUBLIC
CID002290
Active
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Conformant
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Conformant
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
CID001585
Conformant
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Conformant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Conformant
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
CID002516
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Conformant
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
CID001761
Conformant
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Conformant
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
CID002918
Conformant
Gold
T.C.A S.p.A
ITALY
CID002580
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Conformant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Conformant
Gold
Tony Goetz NV
BELGIUM
CID002587
Non Conformant
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Conformant
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Conformant
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Conformant
 
 
 
 
 
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Conformant
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
CID001993
Conformant
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Conformant
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
CID002030
Conformant





Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Conformant
Gold
Yamakin Co., Ltd.
JAPAN
CID002100
Conformant
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Conformant
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Conformant
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000092
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Conformant
Tantalum
CP Metals Inc.
UNITED STATES OF AMERICA
CID003402
Conformant
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
CID002504
Conformant
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
CID000456
Conformant
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Conformant
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002505
Conformant
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Conformant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
CID002557
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
Conformant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Conformant
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Conformant
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
CID002548
Conformant
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
Conformant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002512
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID002842
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Conformant





Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002506
Conformant
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Conformant
Tantalum
LSM Brasil S.A.
BRAZIL
CID001076
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Conformant
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001175
Conformant
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001192
Conformant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Conformant
Tantalum
NPM Silmet AS
ESTONIA
CID001200
Conformant
Tantalum
PRG Dooel
NORTH MACEDONIA, REPUBLIC OF
CID002847
Conformant
Tantalum
QuantumClean
UNITED STATES OF AMERICA
CID001508
Conformant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID002707
Conformant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Conformant
Tantalum
Taki Chemical Co., Ltd.
JAPAN
CID001869
Conformant
Tantalum
Telex Metals
UNITED STATES OF AMERICA
CID001891
Conformant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Conformant
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
CID001522
Conformant
Tin
Alpha
UNITED STATES OF AMERICA
CID000292
Conformant
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID003190
Conformant
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Conformant
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
CID003356
Non Conformant
Tin
Dowa
JAPAN
CID000402
Conformant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID002572
Non Conformant





Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
CID000438
Conformant
Tin
Fenix Metals
POLAND
CID000468
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908
Conformant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Conformant
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
CID003116
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Conformant
Tin
Luna Smelter, Ltd.
RWANDA
CID003387
Conformant
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
CID003379
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Conformant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Conformant
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Conformant
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
CID001142
Conformant
Tin
Metallo Belgium N.V.
BELGIUM
CID002773
Conformant
Tin
Metallo Spain S.L.U.
SPAIN
CID002774
Conformant
Tin
Mineracao Taboca S.A.
BRAZIL
CID001173
Conformant
Tin
Minsur
PERU
CID001182
Conformant
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Conformant
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002858
Non Conformant
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Conformant
 
 
 
 
 
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Conformant
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
CID001337
Conformant





Tin
Precious Minerals and Smelting Limited
INDIA
CID003409
Active
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Conformant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Conformant
Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Conformant
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Conformant
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Conformant
Tin
PT Timah Tbk Kundur
INDONESIA
CID001477
Conformant
Tin
PT Timah Tbk Mentok
INDONESIA
CID001482
Conformant
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Conformant
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
CID001539
Conformant
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Conformant
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
CID002834
Conformant
Tin
Thaisarco
THAILAND
CID001898
Conformant
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
CID003325
Conformant
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
CID002036
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Conformant
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Conformant
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
CID003397
Conformant
Tungsten
A.L.M.T. Corp.
JAPAN
CID000004
Conformant
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Conformant
Tungsten
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
CID003427
Active
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Conformant
Tungsten
CP Metals Inc.
UNITED STATES OF AMERICA
CID003448
Active
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
CID003401
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Conformant





Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002645
Conformant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Conformant
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
CID000568
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Conformant
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002542
Conformant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID002541
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Conformant
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID003182
Conformant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Conformant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Conformant
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Conformant
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Conformant
Tungsten
Jiangxi Xianglu Tungsten Co., Ltd.
CHINA
CID002647
Active
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Conformant
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
CID003408
Active
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
CID000966
Conformant
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
CID000105
Conformant
Tungsten
KGETS Co., Ltd.
KOREA, REPUBLIC OF
CID003388
Conformant





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