UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
SPECIALIZED DISCLOSURE REPORT
CIRCOR INTERNATIONAL, INC.

(Exact Name of Registrant as Specified in Charter)


Delaware
001-14962
04-3477276
(State or Other Jurisdiction
(Commission File No.)
(I.R.S. Employer
of Incorporation)
 
Identification Number)
 
 
 
30 Corporate Drive, Suite 200, Burlington, MA
 
01803-4238
(Address of Principal Executive Offices)
 
(Zip Code)
 
 
 
Abhi Khandelwal
 
781-270-1200
(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:

x
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
Based upon its Reasonable Country of Origin Inquiry the registrant has determined that it is necessary to file a Conflict Minerals Report.
Item 1.02
A copy of CIRCOR International, Inc.'s 2019 Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at http://investors.circor.com/investors/conflict-minerals-policy.

Section 2 - Exhibits
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

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.

CIRCOR International, Inc.
(Registrant)

By:
/s/ Abhi Khandelwal
 
 
Senior Vice President, Chief Financial Officer
 
 
 
 
 
June 1, 2020
 








Exhibit


Exhibit 1.01
CIRCOR International, Inc.
Conflict Minerals Report
For The Year Ended December 31, 2019

This report for the year ended December 31, 2019 (the “Reporting Period”) is presented pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”). The Conflict Minerals Rule, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain “conflict minerals” (as defined below) 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, which are currently limited to tantalum, tin and tungsten; 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,” as such term is defined in Form SD (each a “Covered Country, collectively, the “Covered Countries”). Please refer to the Conflict Minerals Rule, Form SD and the 1934 Act Release No. 34-67716 for additional definitions of the terms used in this Report.
1.Overview
This report has been prepared by CIRCOR International, Inc. (herein referred to as “CIRCOR,” the “Company,” “we,” “us,” or “our”). The information in this report includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated. It does not include the activities of variable interest entities that are not required to be consolidated.
Forward-looking statements contained in this report are made based on known events and circumstances at the time of release, and as such, are subject in the future to unforeseen uncertainties and risks. Statements in this report that express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements, including statements related to the Company’s compliance efforts and expected actions identified in this report. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other matters, the Company’s customers’ requirements to use certain suppliers, the Company’s suppliers’ responsiveness and cooperation with the Company’s due diligence efforts, the Company’s ability to implement improvements in its conflict minerals program and the Company’s ability to identify and mitigate related risks in its supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see the Company’s other filings with the Securities and Exchange Commission (“SEC”), including but not limited to its Annual Report on Form 10-K for the year ended December 31, 2019 and subsequent Quarterly Reports on Form 10-Q. The Company makes these statements as of the date of this disclosure, and undertakes no obligation to update them unless otherwise required by law.
2.Product Description    CIRCOR manufactures and contracts to manufacture engineered products and sub-systems used in oil & gas, power generation, aerospace, defense and industrial markets. These products comprise many varieties of valves (ball valves, control valves, check valves, butterfly valves), fluid and gas regulators, pumps, controls, actuation and sub-system components. These products are fabricated from numerous materials procured from the Company’s suppliers through its global supply chains. CIRCOR manufactures and sells products through three major reporting segments: CIRCOR Energy, CIRCOR Aerospace & Defense and CIRCOR Industrial. Each of the four conflict minerals (also collectively referred to herein as "3TG" for the elements tantalum, tin, tungsten and gold) is necessary to the functionality and/or production of our product lines as described.

3.Facilities    During the Reporting Period, CIRCOR processed conflict minerals in its manufacturing facilities located in the United States, Mexico, Western Europe, Morocco, China and India. Our Energy segment operated facilities in Oklahoma City, OK; Spartanburg, SC; Channelview, TX; Houston, TX; and Sandy, UT; Suzhou, PRC; Monterrey, Mexico; Nerviano, Italy; Middlesex and Yorkshire, UK; Cologne and Kornwestheim, Germany; Coimbatore, India; and Bergschenhoek, Netherlands. Our Aerospace & Defense segment operated facilities in Corona, CA; Warren, MA; Hauppauge, NY; Uxbridge, UK; Le Plessis Trévise, France; and Tangier, Morocco. Our Industrial segment operated facilities in Tampa, FL; Columbia, KY; Walden, NY; Monroe, NC; Radolfzell and Bottrop, Germany; Delden, Netherlands; Weihai, China; and Daman, India.

4.Due Diligence on Supply Chains    In designing our conflict minerals compliance program, we referred to the Organisation of Economic Cooperation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). The five basic elements of the OECD guidance are: 1. Establish strong management systems; 2. Identify and assess risks in the supply chain; 3. Design and implement a strategy to respond to identified risks; 4. Carry out independent third-party audit of refiner's due diligence practices; and 5. Report annually on supply chain due diligence. Our program addresses the basic elements of the OECD Guidance as described below.


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4.1Establish Strong Management Systems

Policy
CIRCOR has adopted a Conflict Minerals Policy which is posted on our website at http://investors.circor.com/investors/conflict-minerals-policy. In following its policy, the Company is committed to making continuous improvements toward ensuring that its products do not include 3TG from sources that support the armed conflict in the Covered Countries.
Internal Team
The Company has established a management system for its conflict minerals program. Our management system includes CIRCOR's Senior Vice President - Global Operations, Vice President - Global Supply Chain and Vice President - General Counsel as well as a team of subject matter experts from relevant functions, including Supply Chain, Materials Management, Engineering and the Legal and Accounting functions. The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and is led by our supply chain organization and our legal department. In organizing and conducting our annual survey for the Reporting Period, the Company worked closely with its contracted service provider Source Intelligence. Senior management representatives have been briefed on the results of our due diligence efforts.
Control systems
As the Company does not have direct relationships with smelters and refiners of conflict minerals, it has retained a service provider Source Intelligence for supply chain research, consulting and conflict minerals database management services. Through our service provider, we are able to reference external databases and independent organizations to validate information on source smelters and gold refiners as reported to the Company by its suppliers. Our controls are supported by our Code of Conduct, which outlines expected behaviors for all employees and provides a complaint mechanism that can accommodate anonymous complaints via telephone and email. This mechanism is also available through the Company‘s website.
Strengthen Engagement with Suppliers
The Company has revised many of its contractual relationships with suppliers to include requirements that they cooperate with our efforts to conduct due diligence on our supply chains. The Company requires suppliers to provide written certifications on the country of origin of any conflict minerals contained in the materials they supply to CIRCOR. As we renew or enter into new long term supply agreements, we add clauses requiring suppliers to provide information about their smelters and sources of conflict minerals.
We have also added a Supplier Code of Conduct to our long term agreements with suppliers. The Supplier Code of Conduct restates our commitment to eliminating from our supply chains any conflict mineral that has a connection to armed conflict in a Covered Country, and requires suppliers to cooperate with our due diligence program. The Supplier Code of Conduct includes disclosure requirements to mitigate against the risk of including conflict minerals that finance armed conflict in the Covered Countries, and requires, among other things, that suppliers commit to becoming "conflict free" with respect to the materials they supply to the Company. Additional measures to improve transparency in our supply chains are described below.
4.2
Identify and assess risk in the supply chain

Because of the breadth of our organizational structure, the fact that many of our products are constituted from metals, the complexity of certain products, and the depth and dynamic nature of our supply chain, we have looked across all of our business operations worldwide to organize our assessments of the products we manufacture, our suppliers and their respective upstream sources. We believe that our supply chain professionals and product engineers have identified all direct suppliers of materials that were known to contain or were reasonably believed to contain at least one 3TG ("in-scope suppliers"). These materials are the product of attenuated supply chains. However, we recognize the possibility that some of them might include conflict minerals sourced from mines controlled by persons engaged in human rights abuses in the Covered Countries.
4.3Design and Implement a Strategy to Respond to Risks

The Company’s Conflict Minerals Policy guides its risk management plan and due diligence efforts, through which its compliance program is implemented, managed and monitored. During the 2019 Reporting Period CIRCOR procured materials to manufacture its products from over two thousand four hundred (2,400) suppliers.

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As in prior years, we began our due diligence on our supply chains by reviewing our products to identify all direct suppliers who provided materials which we either knew to contain or believed may contain a conflict mineral. Recognizing that conflict minerals risk is an enterprise-wide issue, we undertook to develop a database of supplier contact and location information from all business units, including email addresses and telephone contact information. The Company has consolidated detailed supplier information into a centrally administered materials management database. We conformed supplier information from across multiple business units, allowing us to consistently and accurately identify suppliers of constituent materials necessary to the functionality or production of CIRCOR finished products. This database has enabled us to elicit and organize more detailed responses from our suppliers and to improve the quantity and quality of supplier responses. Continuing into the current Reporting Period, we continued our program of developing a single master database of product information to assist us in connecting supplier information to our finished products. The Company believes that consolidation of its supplier information will help improve the overall transparency and efficiency of its supply chain management.
CIRCOR included all in-scope suppliers in its Reasonable Country of Origin Inquiry (“RCOI”). To obtain the required information from suppliers, the Company utilized the most current version of the Conflict Minerals Reporting Template ("CMRT") based on the questionnaire form developed and published by the Responsible Minerals Initiative (“RMI”), formerly the Conflict-Free Sourcing Initiative (“CFSI”) originally established by the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative. Each CIRCOR supplier was requested to provide detailed information regarding the supplier's conflict minerals policy, the presence and sources of any conflict minerals contained in materials supplied to CIRCOR, the supplier's engagement with its upstream suppliers, and identification of the smelters from which the supplier had sourced any 3TG materials. We directed suppliers to follow written instructions for completing the form. Suppliers could also link to recorded training that illustrates proper use of the tool. The CMRT can be completed in several non-English languages and is consistent with the template in use by many companies in their due diligence processes relating to conflict minerals. We requested suppliers to submit their responses in an on-line format (rather than uploading their own spreadsheets) and we pre-set the reporting format to elicit product-level responses.

Where suppliers failed to respond to our initial request, reminder emails were sent to them requesting completion of the CMRT. In many cases, this exercise was repeated multiple times. Suppliers who remained non-responsive to our email reminders were contacted directly via telephone and were offered assistance. As our supply chains are global, we utilized service staff members who are fluent in several non-English languages to communicate with suppliers and facilitate their participation in our RCOI program. This assistance included, but was not limited to, providing further information about CIRCOR's conflict minerals compliance program, an explanation of the information sought and why its collection is necessary, a review of how the information would be used and clarification of the instructions for completing the CMRT template. The Company’s supply chain organization also contacted suppliers directly to remind them of CIRCOR’s program and urge their participation. Our survey program has helped to drive greater awareness in our supplier community of the Conflict Minerals Rule and the importance of cooperation with CIRCOR as a regulated customer.

Due Diligence Results: Survey Responses
Information provided by suppliers who responded to the Company's RCOI was aggregated into the Company's online data platform. As was the case last year, our efforts to collect information from our suppliers continued into the current calendar year. We collected over 900 responses from suppliers. This represents an increase over the total of last year’s responses, and a higher percentage of participation in our substantially increased supplier database.
CIRCOR's suppliers vary widely in size and sophistication. The information received also varied in its consistency and accuracy, both internally and when checked against known data from independent sources. For example, although the CMRT template sent to suppliers for completion was pre-set to elicit product-level information, many of our responding suppliers provided data on an enterprise-wide basis, without specifying the products to which their data related. In addition, some suppliers indicated that they were providing information for "all products" without specifying whether this entry described all-products-sold-to-CIRCOR or all-products-produced-by-the-supplier. Because of this ambiguity, we were unable to distinguish whether such a supplier who reported having sourced any 3TG from a Covered Country had in fact incorporated those specific lots of minerals into the specific lot(s) of product(s) it sold to CIRCOR. Based on information available at this time, we are therefore unable to trace certain conflict minerals in the materials supplied to us to a particular source location so as to validate which materials from supplier-identified source smelters, refiners or mines were actually in the supply chain of CIRCOR-manufactured products.
We further examined supplier responses for their plausibility, completeness, internal consistency, accuracy and conformance with other known information. For example, we compared smelter facilities identified as sources by our suppliers to the list of smelters certified as Conflict-Free by the RMI and other certifying bodies. Where information from a supplier contained inconsistent, implausible or apparently erroneous entries, we attempted to make additional contact with the supplier to clarify the information provided. Where clarifying information was obtained, the database was updated or corrected.

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Further ambiguity exists beyond the first tier of CIRCOR’s supply chains. Some suppliers identified source entities as smelters that are not found in the smelter database maintained by the RMI. Other suppliers identified as a source of a particular material a smelter which either could not be confirmed as a smelter at all or could not be confirmed as a processor of the specific material identified by the supplier.
A number of responding suppliers indicated that they sourced 3TG materials from smelters which, based upon supplier information or indicated by independent sources, are believed to have sourced raw materials from at least one mining operation located in a Covered Country. However, the profile information we have for smelters identifies all countries from which materials were sourced by that smelter on an enterprise-wide basis. As a consequence, even where suppliers reported their information on a product-level basis, we believe that our data may contain a number of "false positives" in relation to the risk that our necessary 3TG minerals were sourced from a smelter that in turn sourced them from a Covered Country.
Smelters or Refiners

As noted, CIRCOR has received limited information regarding smelters and/or refiners involved in the Company’s supply chains, as well as the origin of any materials they may potentially process for the Company’s suppliers. This is principally due to the fact that suppliers provided their data at a company or divisional level, and, not specific to the products suppliers produced for CIRCOR.
Appendix A, attached, contains a list of smelters / refiners and countries of origin for the Conflict Minerals that our suppliers identified in their supply chains. We are uncertain of the status of the products that we manufacture that are subject to the reporting obligations of Rule 13p-1, because we have been unable to determine the origin of the Conflict Minerals they contain; whether they came from recycled or scrap sources; the facilities used to process them; their country of origin; or their mine or location of origin. CIRCOR will continue its due diligence efforts going forward.


4.4Independent Third Party Audit of Supply Chain Due Diligence
Because CIRCOR does not have direct relationships with 3TG smelters and refiners, it relies on independent industry resources, such as RMI and other certifying bodies, to provide conflict-free audit certifications and to influence smelters and refiners to participate in audits and achieve conflict-free status. We also rely upon our contracted service provider for additional industry intelligence about smelters and refiners. However, the Company does not possess the level of detailed information necessary to perform effective audits of 3TG suppliers, as much of the information provided from suppliers to date is supplied on an enterprise-wide basis and is not particularized to our products.

4.5Public Report on Supply Chain Due Diligence
This is CIRCOR's seventh public report on its conflict minerals supply chain due diligence. In addition to the strategies, practices and results described in this report, we have, as required by the statute and consistent with the OECD Guidance, published our supply chain due diligence policy as set forth in our Conflict Minerals Policy available on our website at http://investors.circor.com/investors/conflict-minerals-policy.

5.Efforts to determine mine or location of origin

As detailed above, through our establishment of a management structure, assessment of risk, development of a Conflict Minerals Policy, continuous improvement of our supplier database, and the design and implementation of a disciplined due diligence program on our 3TG supply chains, including the direct involvement of our supply chain organization and leveraging of outside resources and databases, we have continued to develop and improve our conflict minerals compliance program. Our work to date has established a foundation of information to support our ongoing efforts to identify the mines or other locations of origin of the necessary 3TG in the products we manufacture and contract to have manufactured.
6.Steps to be taken to mitigate risk

We intend to take the following steps to broaden and deepen supplier participation in our program and improve the due diligence conducted to date to further mitigate the risk that 3TG necessary to the manufacture or functionality of our products could benefit armed groups in the DRC or adjoining countries:
a.
Continue to develop our product database across our business units to drive greater transparency in our supply chains. We are planning to aggregate into our master database information relating to suppliers to our newly-acquired

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businesses and to expand our data collection process by including these suppliers in our follow-up campaign to improve supplier participation in our conflict minerals program.

b.
Renew our RCOI with existing in-scope suppliers and expand it to include new suppliers who we believe may supply materials containing 3TG.

c.
Continue our program of requiring suppliers to subscribe to our Supplier Code of Conduct as described above, which includes conflict minerals disclosure obligations and commitment to transparency and integrity.

d.
Where we identify in our supply chains potential economic links to the armed conflict in the Covered Countries, contact our suppliers to provide additional details with respect to the specific products they supply to CIRCOR, including accurate identification of source smelters.

e.
If any of our suppliers are found to have supplied us with 3TG from sources that support the armed conflict in the Covered Countries, engage with such suppliers to establish an alternate source of 3TG that does not support such conflict.

f.
Work with relevant trade associations to define and improve best practices and build our leverage over the supply chain in accordance with the OECD Guidance.

7.Audit
After performing appropriate due diligence, CIRCOR is unable to determine whether any 3TG necessary to its manufacture of products during the Reporting Period originated in a Covered Country or directly or indirectly financed or benefitted armed groups there. Therefore we are not required to obtain an independent private sector audit of our Conflict Minerals Report.



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APPENDIX A
Metal
Official Smelter Name
RMI Smelter ID
Smelter Country
Gold
8853 S.p.A.
CID002763
Italy
Gold
Abington Reldan Metals, LLC
CID002708
United States
Gold
Advanced Chemical Company
CID000015
United States
Gold
African Gold Refinery
CID003185
Uganda
Gold
Aida Chemical Industries Co., Ltd.
CID000019
Japan
Gold
Al Etihad Gold Refinery DMCC
CID002560
United Arab Emirates
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
Germany
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
Uzbekistan
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
CID000058
Brazil
Gold
Argor-Heraeus S.A.
CID000077
Switzerland
Gold
Asahi Pretec Corp.
CID000082
Japan
Gold
Asahi Refining Canada Ltd.
CID000924
Canada
Gold
Asahi Refining USA Inc.
CID000920
United States
Gold
Asaka Riken Co., Ltd.
CID000090
Japan
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
Turkey
Gold
AU Traders and Refiners
CID002850
South Africa
Gold
Aurubis AG
CID000113
Germany
Gold
Bangalore Refinery
CID002863
India
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
Philippines
Gold
Boliden AB
CID000157
Sweden
Gold
C. Hafner GmbH + Co. KG
CID000176
Germany
Gold
C.I Metales Procesados Industriales SAS
CID003421
Colombia
Gold
Caridad
CID000180
Mexico
Gold
CCR Refinery - Glencore Canada Corporation
CID000185
Canada
Gold
Cendres + Metaux S.A.
CID000189
Switzerland
Gold
CGR Metalloys Pvt Ltd.
CID003382
India
Gold
Chimet S.p.A.
CID000233
Italy
Gold
Chugai Mining
CID000264
Japan
Gold
Daye Non-Ferrous Metals Mining Ltd.
CID000343
China
Gold
Degussa Sonne / Mond Goldhandel GmbH
CID002867
Germany
Gold
Dijllah Gold Refinery FZC
CID003348
United Arab Emirates
Gold
DODUCO Contacts and Refining GmbH
CID000362
Germany
Gold
Dowa
CID000401
Japan
Gold
DS PRETECH Co., Ltd.
CID003195
Korea, Republic of
Gold
DSC (Do Sung Corporation)
CID000359
Korea, Republic of
Gold
Eco-System Recycling Co., Ltd. East Plant
CID000425
Japan
Gold
Eco-System Recycling Co., Ltd. North Plant
CID003424
Japan
Gold
Eco-System Recycling Co., Ltd. West Plant
CID003425
Japan
Gold
Emirates Gold DMCC
CID002561
United Arab Emirates
Gold
Fidelity Printers and Refiners Ltd.
CID002515
Zimbabwe

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Gold
Fujairah Gold FZC
CID002584
United Arab Emirates
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
CID002852
India
Gold
Geib Refining Corporation
CID002459
United States
Gold
Gold Coast Refinery
CID003186
Ghana
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CID002243
China
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CID001909
China
Gold
Guangdong Jinding Gold Limited
CID002312
China
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CID000651
China
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
China
Gold
Heimerle + Meule GmbH
CID000694
Germany
Gold
Heraeus Metals Hong Kong Ltd.
CID000707
China
Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
Germany
Gold
Hunan Chenzhou Mining Co., Ltd.
CID000767
China
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CID000773
China
Gold
HwaSeong CJ CO., LTD.
CID000778
Korea, Republic of
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
China
Gold
International Precious Metal Refiners
CID002562
United Arab Emirates
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
Japan
Gold
Istanbul Gold Refinery
CID000814
Turkey
Gold
Italpreziosi
CID002765
Italy
Gold
JALAN & Company
CID002893
India
Gold
Japan Mint
CID000823
Japan
Gold
Jiangxi Copper Co., Ltd.
CID000855
China
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
Russian Federation
Gold
JSC Uralelectromed
CID000929
Russian Federation
Gold
JX Nippon Mining & Metals Co., Ltd.
CID000937
Japan
Gold
Kaloti Precious Metals
CID002563
United Arab Emirates
Gold
Kazakhmys Smelting LLC
CID000956
Kazakhstan
Gold
Kazzinc
CID000957
Kazakhstan
Gold
Kennecott Utah Copper LLC
CID000969
United States
Gold
KGHM Polska Miedz Spolka Akcyjna
CID002511
Poland
Gold
Kojima Chemicals Co., Ltd.
CID000981
Japan
Gold
Korea Zinc Co., Ltd.
CID002605
Korea, Republic of
Gold
Kyrgyzaltyn JSC
CID001029
Kyrgyzstan
Gold
Kyshtym Copper-Electrolytic Plant ZAO
CID002865
Russian Federation
Gold
L'azurde Company For Jewelry
CID001032
Saudi Arabia
Gold
Lingbao Gold Co., Ltd.
CID001056
China
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
China
Gold
L'Orfebre S.A.
CID002762
Andorra
Gold
LS-NIKKO Copper Inc.
CID001078
Korea, Republic of
Gold
LT Metal Ltd.
CID000689
Korea, Republic of
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
China
Gold
Marsam Metals
CID002606
Brazil

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Gold
Materion
CID001113
United States
Gold
Matsuda Sangyo Co., Ltd.
CID001119
Japan
Gold
Metalor Technologies (Hong Kong) Ltd.
CID001149
China
Gold
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
Singapore
Gold
Metalor Technologies (Suzhou) Ltd.
CID001147
China
Gold
Metalor Technologies S.A.
CID001153
Switzerland
Gold
Metalor USA Refining Corporation
CID001157
United States
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
CID001161
Mexico
Gold
Mitsubishi Materials Corporation
CID001188
Japan
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
Japan
Gold
MMTC-PAMP India Pvt., Ltd.
CID002509
India
Gold
Modeltech Sdn Bhd
CID002857
Malaysia
Gold
Morris and Watson
CID002282
New Zealand
Gold
Moscow Special Alloys Processing Plant
CID001204
Russian Federation
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
CID001220
Turkey
Gold
Navoi Mining and Metallurgical Combinat
CID001236
Uzbekistan
Gold
NH Recytech Company
CID003189
Korea, Republic of
Gold
Nihon Material Co., Ltd.
CID001259
Japan
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
Austria
Gold
Ohura Precious Metal Industry Co., Ltd.
CID001325
Japan
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326
Russian Federation
Gold
OJSC Novosibirsk Refinery
CID000493
Russian Federation
Gold
PAMP S.A.
CID001352
Switzerland
Gold
Pease & Curren
CID002872
United States
Gold
Penglai Penggang Gold Industry Co., Ltd.
CID001362
China
Gold
Planta Recuperadora de Metales SpA
CID002919
Chile
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
Russian Federation
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
Indonesia
Gold
PX Precinox S.A.
CID001498
Switzerland
Gold
QG Refining, LLC
CID003324
United States
Gold
Rand Refinery (Pty) Ltd.
CID001512
South Africa
Gold
Refinery of Seemine Gold Co., Ltd.
CID000522
China
Gold
REMONDIS PMR B.V.
CID002582
Netherlands
Gold
Royal Canadian Mint
CID001534
Canada
Gold
SAAMP
CID002761
France
Gold
Sabin Metal Corp.
CID001546
United States
Gold
Safimet S.p.A
CID002973
Italy
Gold
SAFINA A.S.
CID002290
Czech Republic
Gold
Sai Refinery
CID002853
India
Gold
Samduck Precious Metals
CID001555
Korea, Republic of
Gold
SAMWON METALS Corp.
CID001562
Korea, Republic of
Gold
SAXONIA Edelmetalle GmbH
CID002777
Germany

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Gold
SEMPSA Joyeria Plateria S.A.
CID001585
Spain
Gold
Shandong Humon Smelting Co., Ltd.
CID002525
China
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
China
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
China
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
China
Gold
Singway Technology Co., Ltd.
CID002516
Taiwan
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
Russian Federation
Gold
Solar Applied Materials Technology Corp.
CID001761
Taiwan
Gold
Sovereign Metals
CID003383
India
Gold
State Research Institute Center for Physical Sciences and Technology
CID003153
Lithuania
Gold
Sudan Gold Refinery
CID002567
Sudan
Gold
Sumitomo Metal Mining Co., Ltd.
CID001798
Japan
Gold
SungEel HiMetal Co., Ltd.
CID002918
Korea, Republic of
Gold
T.C.A S.p.A
CID002580
Italy
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
Japan
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
China
Gold
Tokuriki Honten Co., Ltd.
CID001938
Japan
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CID001947
China
Gold
Tony Goetz NV
CID002587
Belgium
Gold
TOO Tau-Ken-Altyn
CID002615
Kazakhstan
Gold
Torecom
CID001955
Korea, Republic of
Gold
Umicore Brasil Ltda.
CID001977
Brazil
Gold
Umicore Precious Metals Thailand
CID002314
Thailand
Gold
Umicore S.A. Business Unit Precious Metals Refining
CID001980
Belgium
Gold
United Precious Metal Refining, Inc.
CID001993
United States
Gold
Valcambi S.A.
CID002003
Switzerland
Gold
Western Australian Mint (T/a The Perth Mint)
CID002030
Australia
Gold
WIELAND Edelmetalle GmbH
CID002778
Germany
Gold
Yamakin Co., Ltd.
CID002100
Japan
Gold
Yokohama Metal Co., Ltd.
CID002129
Japan
Gold
Yunnan Copper Industry Co., Ltd.
CID000197
China
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
China
Tantalum
Asaka Riken Co., Ltd.
CID000092
Japan
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
China
Tantalum
CP Metals Inc.
CID003402
United States
Tantalum
D Block Metals, LLC
CID002504
United States
Tantalum
Exotech Inc.
CID000456
United States
Tantalum
F&X Electro-Materials Ltd.
CID000460
China
Tantalum
FIR Metals & Resource Ltd.
CID002505
China
Tantalum
Global Advanced Metals Aizu
CID002558
Japan
Tantalum
Global Advanced Metals Boyertown
CID002557
United States
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
China
Tantalum
H.C. Starck Co., Ltd.
CID002544
Thailand

9



Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
Germany
Tantalum
H.C. Starck Inc.
CID002548
United States
Tantalum
H.C. Starck Ltd.
CID002549
Japan
Tantalum
H.C. Starck Smelting GmbH & Co. KG
CID002550
Germany
Tantalum
H.C. Starck Tantalum and Niobium GmbH
CID002545
Germany
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
China
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
China
Tantalum
Jiangxi Tuohong New Raw Material
CID002842
China
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
China
Tantalum
Jiujiang Tanbre Co., Ltd.
CID000917
China
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
China
Tantalum
KEMET Blue Metals
CID002539
Mexico
Tantalum
LSM Brasil S.A.
CID001076
Brazil
Tantalum
Metallurgical Products India Pvt., Ltd.
CID001163
India
Tantalum
Mineracao Taboca S.A.
CID001175
Brazil
Tantalum
Mitsui Mining and Smelting Co., Ltd.
CID001192
Japan
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
China
Tantalum
NPM Silmet AS
CID001200
Estonia
Tantalum
PRG Dooel
CID002847
Macedonia, The Former Yugoslav Republic Of
Tantalum
QuantumClean
CID001508
United States
Tantalum
Resind Industria e Comercio Ltda.
CID002707
Brazil
Tantalum
Solikamsk Magnesium Works OAO
CID001769
Russian Federation
Tantalum
Taki Chemical Co., Ltd.
CID001869
Japan
Tantalum
Telex Metals
CID001891
United States
Tantalum
Ulba Metallurgical Plant JSC
CID001969
Kazakhstan
Tantalum
XinXing Haorong Electronic Material Co., Ltd.
CID002508
China
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CID001522
China
Tin
Alpha
CID000292
United States
Tin
An Vinh Joint Stock Mineral Processing Company
CID002703
Viet Nam
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
China
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CID003190
China
Tin
China Tin Group Co., Ltd.
CID001070
China
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CID003356
China
Tin
Dowa
CID000402
Japan
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
CID002572
Viet Nam
Tin
EM Vinto
CID000438
Bolivia
Tin
Estanho de Rondonia S.A.
CID000448
Brazil
Tin
Fenix Metals
CID000468
Poland
Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.
CID003410
China
Tin
Gejiu Kai Meng Industry and Trade LLC
CID000942
China
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
China

10



Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
China
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
China
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CID003116
China
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CID002849
China
Tin
HuiChang Hill Tin Industry Co., Ltd.
CID002844
China
Tin
Huichang Jinshunda Tin Co., Ltd.
CID000760
China
Tin
Jiangxi New Nanshan Technology Ltd.
CID001231
China
Tin
Luna Smelter, Ltd.
CID003387
Rwanda
Tin
Ma'anshan Weitai Tin Co., Ltd.
CID003379
China
Tin
Magnu's Minerais Metais e Ligas Ltda.
CID002468
Brazil
Tin
Malaysia Smelting Corporation (MSC)
CID001105
Malaysia
Tin
Melt Metais e Ligas S.A.
CID002500
Brazil
Tin
Metallic Resources, Inc.
CID001142
United States
Tin
Metallo Belgium N.V.
CID002773
Belgium
Tin
Metallo Spain S.L.U.
CID002774
Spain
Tin
Mineracao Taboca S.A.
CID001173
Brazil
Tin
Minsur
CID001182
Peru
Tin
Mitsubishi Materials Corporation
CID001191
Japan
Tin
Modeltech Sdn Bhd
CID002858
Malaysia
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
Viet Nam
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
Thailand
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
Philippines
Tin
Operaciones Metalurgicas S.A.
CID001337
Bolivia
Tin
Pongpipat Company Limited
CID003208
Myanmar
Tin
Precious Minerals and Smelting Limited
CID003409
India
Tin
PT Artha Cipta Langgeng
CID001399
Indonesia
Tin
PT ATD Makmur Mandiri Jaya
CID002503
Indonesia
Tin
PT Menara Cipta Mulia
CID002835
Indonesia
Tin
PT Mitra Stania Prima
CID001453
Indonesia
Tin
PT Refined Bangka Tin
CID001460
Indonesia
Tin
PT Timah Tbk Kundur
CID001477
Indonesia
Tin
PT Timah Tbk Mentok
CID001482
Indonesia
Tin
Resind Industria e Comercio Ltda.
CID002706
Brazil
Tin
Rui Da Hung
CID001539
Taiwan
Tin
Soft Metais Ltda.
CID001758
Brazil
Tin
Super Ligas
CID002756
Brazil
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
CID002834
Viet Nam
Tin
Thaisarco
CID001898
Thailand
Tin
Tin Technology & Refining
CID003325
United States
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
CID002574
Viet Nam
Tin
White Solder Metalurgia e Mineracao Ltda.
CID002036
Brazil
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
China
Tin
Yunnan Tin Company Limited
CID002180
China

11



Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CID003397
China
Tungsten
A.L.M.T. TUNGSTEN Corp.
CID000004
Japan
Tungsten
ACL Metais Eireli
CID002833
Brazil
Tungsten
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
CID003427
Brazil
Tungsten
Asia Tungsten Products Vietnam Ltd.
CID002502
Viet Nam
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
China
Tungsten
China Molybdenum Co., Ltd.
CID002641
China
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
China
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CID000281
China
Tungsten
CP Metals Inc.
CID003448
United States
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CID003401
China
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
China
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CID002645
China
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
China
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
China
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
China
Tungsten
Global Tungsten & Powders Corp.
CID000568
United States
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
China
Tungsten
H.C. Starck Smelting GmbH & Co. KG
CID002542
Germany
Tungsten
H.C. Starck Tungsten GmbH
CID002541
Germany
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CID000766
China
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
China
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
China
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CID003182
China
Tungsten
Hydrometallurg, JSC
CID002649
Russian Federation
Tungsten
Japan New Metals Co., Ltd.
CID000825
Japan
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
China
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
China
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
China
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
China
Tungsten
Jiangxi Xianglu Tungsten Co., Ltd.
CID002647
China
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
China
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
China
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
CID003408
Russian Federation
Tungsten
Kennametal Fallon
CID000966
United States
Tungsten
Kennametal Huntsville
CID000105
United States
Tungsten
KGETS CO., LTD.
CID003388
Korea, Republic of
Tungsten
Lianyou Metals Co., Ltd.
CID003407
Taiwan
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
China
Tungsten
Masan Tungsten Chemical LLC (MTC)
CID002543
Viet Nam
Tungsten
Moliren Ltd.
CID002845
Russian Federation
Tungsten
Niagara Refining LLC
CID002589
United States
Tungsten
Philippine Chuangxin Industrial Co., Inc.
CID002827
Philippines

12



Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
Viet Nam
Tungsten
Unecha Refractory Metals Plant
CID002724
Russian Federation
Tungsten
Wolfram Bergbau und Hutten AG
CID002044
Austria
Tungsten
Woltech Korea Co., Ltd.
CID002843
Korea, Republic of
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
China
Tungsten
Xiamen Tungsten Co., Ltd.
CID002082
China
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CID002830
China
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
China




















13