Conflict Minerals Report
2017-09-15
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EXHIBIT 1.01 CONFLICT MINERALS REPORT OF PLEXUS CORP. IN ACCORDANCE WITH RULE 13p-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934 FOR THE REPORTING PERIOD FROM JANUARY 1 TO DECEMBER 31, 2016 Introduction This Conflict Minerals Report (the “Report”) of Plexus Corp. (“Plexus,” the “Company,” “we,” “us,” or “our”) has been prepared for calendar year 2016 under the Securities Exchange Act of 1934 (the “Act”). The term “conflict mineral” is defined as (A) columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”). Numerous terms in this Report are defined in Rule 13p1 of the Act and Form SD (collectively, the “Conflict Minerals Rule”) and the reader is referred to those sources, and also to Securities and Exchange Commission (“SEC”) Release No. 3467716 (August 22, 2012) under the Act for such definitions. For the purpose of this report, tin, tungsten, tantalum, and gold will collectively be referred to as the 3TGs. In accordance with the Conflict Minerals Rule, we undertook efforts to determine whether the 3TGs necessary to the functionality or production of products that we manufacture, or contract to manufacture, were sourced from the Covered Countries, or are from recycled or scrap sources. The Company designed its due diligence efforts to conform, in all material respects, with the framework presented by the Organisation for Economic Co-operation and Development (the “OECD”) in the publication Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related supplements for each of the conflict minerals (collectively, the “OECD Guidance”). The statements below are based on the due diligence activities performed to date and on the information available at the time of this filing. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or a lack of available smelter data, errors or omissions by suppliers or smelters, evolving confirmation of smelters, incomplete information from industry or other third-party sources, and other issues. 1 About Plexus Plexus participates in the Electronic Manufacturing Services (“EMS”) industry. We deliver optimized solutions to our customers through our unique Product Realization Value Stream. Our customer-focused solutions model seamlessly integrates innovative product conceptualization, design, commercialization, manufacturing, fulfillment and sustaining solutions. Plexus delivers comprehensive end-to-end solutions for customers in the Americas, Europe, Middle East, and Africa and Asia-Pacific regions. Plexus is the industry leader in servicing mid-to-low volume, higher complexity customer programs characterized by unique flexibility, technology, quality and regulatory requirements. Plexus provides award-winning customer service to more than 140 branded product companies in the Healthcare/Life Sciences, Industrial/Commercial, Communications, and Defense/Security/Aerospace market sectors. The Company's customers have stringent quality, reliability and regulatory requirements, requiring exceptional production and supply chain agility. Their products require complex configuration management, direct order fulfillment (to end customers) and global logistics management and Aftermarket Services. To service the complexities that the Company's customers' products demand, Plexus utilizes its Product Realization Value Stream, addressing its customers' products from concept to end of life. Description of Products Plexus does not sell “Plexus-branded” products. Plexus provides services for original equipment manufacturers (“OEMs”) with a focus on supporting mid-to-low volume, higher complexity customer programs characterized by unique flexibility, technology, quality and regulatory requirements. The products falling within the scope of this Report include the assemblies and products that we manufactured or contracted to manufacture for customers in the aforementioned market sectors during calendar year 2016. As an EMS company, it’s highly likely that most/all products assembled contain tin, tungsten, tantalum and/or gold. Although Plexus did not find any evidence that the required 3TGs contained in these assemblies or products directly or indirectly benefited armed groups in the Covered Countries, we were unable to conclude that any of these assemblies and products were definitively “DRC conflict free.” Conflict Minerals Policy Plexus is committed to ensuring ethical sourcing and has made significant progress in developing supply chain transparency. We have a Conflict Minerals Policy Statement (the “Conflict Minerals Policy”), which is posted on our website at the following link: http://www.plexus.com/sites/default/files/resources/plexus_conflict_minerals_policy_statement. pdf. 2 Reasonable Country of Origin Inquiry (“RCOI”) Plexus conducted a good faith RCOI regarding the 3TGs in the materials, components and finished goods supplied to the Company. We utilized a third-party service provider (the “Provider”) to assist in supplier outreach and our due diligence procedures. Plexus reviewed the assemblies and products that it manufactured or contracted to manufacture for customers during calendar year 2016 and identified suppliers that supply components or products, or engage in manufacturing activities, that are likely to contain one or more of the 3TGs. We removed from the list of suppliers all service providers, indirect materials suppliers, and inactive suppliers that did not supply goods to Plexus. We focused our RCOI efforts on suppliers comprising approximately the top 90% of the Company’s spend with suppliers. The Provider conducted the supplier survey portion of the RCOI. Suppliers received a communication describing the compliance requirements and requesting information on the 3TGs in their products and the smelters or refiners of those minerals. The Provider, on behalf of the Company, utilized version 4.10 or higher of the Conflict-Free Sourcing Initiative’s (the “CFSI”) Conflict Minerals Reporting Template (“CMRT”). The Provider, on behalf of Plexus, engaged 1,427 suppliers determined to be in scope for purposes of our RCOI efforts to collect information regarding the presence and sourcing of 3TGs in the products supplied to the Company. The Provider followed up with all unresponsive suppliers through a defined process. The Provider utilized both automated and direct email communications. The communications offered assistance and further information to suppliers about the requirements of the Conflict Minerals Rule and the Company’s compliance program. A minimum of three attempts were made to contact unresponsive suppliers. Additionally, our program continues to include automated data validation on all submitted CMRTs. Suppliers were contacted to address incomplete data, missing smelters or refiners, and invalid submissions and they were encouraged to re-submit a valid CMRT. The goal of this process is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. The Provider monitored and tracked all invalid or incomplete supplier submissions. Although we requested information at a product level, the majority of suppliers provided CMRT responses at a company or division level that included information on all products sold by the supplier to its customers, even though Plexus may have purchased only a limited subset of components or products from the supplier. Therefore, the information provided by these suppliers was not necessarily limited to smelters or refiners that were potentially part of the Company’s supply chain. 3 Based on the responses gathered during our RCOI, the Company was unable to determine that the conflict minerals necessary to the functionality or production of our products did not originate in the Covered Countries. As a result, and in accordance with the Conflict Minerals Rule, Plexus undertook the due diligence measures described below on the source and chain of custody of the conflict minerals in its supply chain. Design of Due Diligence As previously disclosed, the Company’s due diligence measures were designed to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the OECD Guidance. The design of the Company’s due diligence measures considered the OECD’s recommendations for “downstream” actors with no direct relationships with smelters or refiners. “Downstream” refers to the supply chain from smelters or refiners to retailers and manufacturers, whereas “upstream” refers to the supply chain from the mines to the smelters or refiners. Plexus does not have a direct relationship with any smelters or refiners and therefore, does not perform direct audits of the due diligence practices of these entities. The Company instead relies on internationally-recognized validation schemes that facilitate independent third-party audits of smelters or refiners and validate that smelters or refiners have met the requirements of the OECD Guidance, such as the CFSI Conflict-Free Smelter Program. Plexus supports this program through membership and participation in the CFSI as a member of the Electronics Industry Citizenship Coalition (“EICC”). Due Diligence Measures Performed Plexus’ overall conflict minerals program is based on the five-step framework of the OECD Guidance. Plexus followed the five-step framework established by the OECD Guidance while performing our due diligence measures for calendar year 2016, which consisted of the following steps: Step 1: Maintain strong company management systems Step 2: Identify and assess risks in the supply chain Step 3: Design and implement a strategy to respond to identified risks Step 4: Carry out independent third-party audit of smelters’ and refiners’ due diligence practices when required Step 5: Report annually on supply chain due diligence 4 Step 1: Maintain strong company management systems Internal Team: Plexus has established an internal management system reporting through the Corporate Compliance Officer designed to assist with complying with the Conflict Minerals Rule. As previously discussed, we also retained the services of the Provider to assist with our efforts. Through use of the Provider’s web-based reporting tool we are able to collect and store supplier data and CMRTs, communicate with suppliers and monitor risks in our supply chain. The use of this tool and our other management systems has provided an opportunity for the Company to assist our suppliers in understanding our expectations and requirements and to increase the rate of responses received from our suppliers. Control Systems: The Company’s Conflict Minerals Policy outlines the expectation that all Plexus suppliers abide by the requirements of the Plexus Supplier Code of Conduct, which prohibits human rights abuses and unethical practices. The Conflict Minerals Policy also requires all suppliers to comply with applicable legal standards and requirements and provide us with completed conflict minerals declarations annually. We periodically review our Conflict Minerals Policy and will make updates as necessary and appropriate. If a supplier fails to comply with our Conflict Minerals Policy, we may reconsider our willingness to continue to partner with that supplier. Supplier Engagement: In an effort to strengthen engagement with suppliers, Plexus utilized version 4.10 or higher of the CMRT and the Provider’s web-based reporting tool for collecting CMRTs from our supplier base. The use of these tools and our other engagement efforts, have allowed us to assist our suppliers in understanding our expectations. This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized our third-party vendor’s learning management system and provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course. In addition to this, we invited certain suppliers who listed high risk smelters or refiners in the 2015 reporting year, to attend a customized webinar. This webinar training session was meant to educate suppliers on smelters and refiners, how to identify risks, and describe recommended risk mitigation activities. 5 Company Level Grievance Mechanism: As an additional means of communication regarding conflict minerals, Plexus employees and other stakeholders can communicate directly and confidentially with the Company’s Corporate Compliance Officer and executive management by using the Plexus Ethics Hotline, as outlined in the Plexus Code of Conduct and Business Ethics, which is available at https://www.plexus.com/en-US/plexus-code-of-conduct Document Retention: Plexus is retaining documentation regarding its conflict minerals program for calendar year 2016 in accordance with its record retention guidelines. Step 2: Identify and assess risks in the supply chain Plexus performed multiple steps in an effort to ensure that risks were identified and assessed during the execution of its conflict minerals program. This included risks associated with smelters or refiners, supplier responses, and with suppliers’ internal policies and programs. The Provider verified whether the metals processors identified by each supplier on its CMRT are actually smelters, refiners, or recyclers of conflict minerals (“verified smelters or refiners”) by comparing the facilities reported by suppliers to the CFSI's Standard Smelter List, the data gathered by the U.S. Department of Commerce, and by conducting its own independent research. The Provider also researched and reviewed mine information for all verified smelters or refiners in an effort to determine the country of origin of the minerals processed. The Provider attempted to match each identified smelter or refiner to available lists of smelters and refiners that have been certified by internationally-recognized validation schemes, such as the CFSI Conflict-Free Smelter Program. If a smelter or refiner was not certified by an internationally-recognized scheme, the Provider attempted to contact the entity to gather more information about its sourcing practices. In addition, the Provider also performed research using publicly available sources of information regarding the smelter’s or refiner’s sourcing practices. The Company sought to understand the risk levels associated with conflict minerals in the supply chain. A smelter’s or refiner’s overall risk is based on various factors, including whether the smelter has been identified as “valid” and has an associated Smelter Identification Number (under the CFSI, this is known as a CID), as well as the smelter’s geographic location, including its proximity to the Covered Countries. The Provider assessed supplier risk based on its determination of the likelihood that a supplier provided conflict minerals to the Company that may have originated from sources that are not conflict free, considering the smelters or refiners declared by that supplier on its CMRT. Additionally, we evaluated suppliers based on the strength of their conflict minerals programs. The criteria used to evaluate the strength of a supplier’s program consisted of the following: 6 • • • • Does the supplier have a policy in place that includes DRC conflict-free sourcing? Has the supplier implemented due diligence measures for conflict-free sourcing? Does the supplier verify due diligence information received from suppliers? Does the supplier’s verification process include corrective action management? The Company has, through the Provider, provided training to suppliers on conflict minerals, the Conflict Minerals Rule and the CMRT. This includes instructions on completing the CMRT, guidance for identifying risks, and discussions with supplier personnel. Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in the supply chain. Plexus has determined that seeking information about conflict minerals smelters and refiners in the supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the conflict minerals in the supply chain. This was done by adopting the methodology outlined by the OECD Guidance and by requiring suppliers to conform with the same standards to meet the OECD Guidance, and report to Plexus using the CMRT. Through this process, we believe we have made reasonable efforts to determine the mines or locations of origin of the conflict minerals in our supply chain. Step 3: Design and implement a strategy to respond to identified risks Following the assessment of supplier risk discussed above, Plexus followed up with suppliers whom we had reason to believe may be sourcing conflict minerals originating from a smelter or refiner in the Covered Countries. We also followed up with any supplier that did not submit a valid response to the CMRT and encouraged them to provide complete and accurate data via the CMRT. As stated in our Conflict Minerals Policy, Plexus requires all in-scope suppliers to provide completed conflict minerals declarations using the CMRT. Plexus may reconsider its willingness to partner with suppliers that fail to comply with our Conflict Minerals Policy. Based on the smelter or refiner risk criteria noted above, the following facilities have been identified as being of highest concern to the supply chain: Tony Goetz NV - CID002587 Kaloti Precious Metals - CID002563 Phoenix Metals - CID002507 Universal Precious Metals Refining Zambia - CID002854 Fidelity Printers and Refiners - CID002515 Sudan Gold Refinery - CID002567 When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through the Provider, submissions that include any of the above facilities 7 immediately produce a receipt instructing the supplier to take their own risk mitigation actions. The mitigation actions may include the submission of a product specific CMRT to better identify the connection to products that they supply to Plexus, escalating up to removal of these high risk smelters from their supply chain. In addition to this, we conducted a direct email campaign to all suppliers who indicated one or more smelter of concern in an effort to educate them on the level of risk and suggested next steps. The Company plans to assess all suppliers who indicated smelters of high concern in multiple reporting years and to escalate these concerns internally. As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain. Furthermore, suppliers are guided to our third-party vendor’s learning management system to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain. Step 4: Carry out independent third-party audit of smelter/refiner due diligence practices Plexus relies on multi-stakeholder initiatives that provide verification processes for smelters or refiners who provide conflict minerals to companies in its supply chain. Plexus, as a purchaser of component parts, is many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals and we do not conduct purchasing activities directly in the Covered Countries. In addition, we do not perform or direct audits of the smelters or refiners listed by our suppliers as being potentially a part of our supply chain. Step 5: Report annually on supply chain due diligence This Report (and the related Form SD) was filed with the SEC and is available on the Plexus website at: https://plexuscdn.s3.amazonaws.com/plexus/media/english-media/resources/socialimpact/conflict-minerals-report.pdf Due Diligence Results Using the processes outlined above, Plexus surveyed the in-scope suppliers for calendar year 2016 and reviewed the responses received. As previously noted, the Company, along with the Provider, followed up with suppliers who did not respond or who provided incomplete responses, or whose responses contained inconsistencies, in an effort to secure valid and complete responses. We received CMRTs from approximately 75% of our in-scope suppliers for the 2016 Reporting Year. 8 Based on the due diligence measures discussed in this Report, Plexus does not have sufficient information from our suppliers or otherwise to conclusively determine the country of origin of the 3TGs in the products we manufactured, or were contracted to manufacture, in calendar year 2016 or whether the 3TGs were from recycled or scrap sources. As a result of these due diligence measures, Plexus has identified the 317 smelters and refiners listed in Annex A to this Report as potentially processing the 3TGs provided by its suppliers. Based on information provided by Plexus’ suppliers, CFSI’s country of origin data and the research provided by the Provider, the smelters or refiners listed in Annex A are believed to have provided 3TGs to Plexus’ supply chain. Of the 317 smelters and refiners, 246 were identified as CFSI compliant with an additional 13 pursuing their CFSI certification, leaving a total of 58 smelters that are not currently enrolled in the CFSI’s Conflict Free Sourcing Program (“CFSP”). Each of those 58 smelters will receive a letter to educate them on the CFSI process as well as encouraging them to join the CFSP and become a CFSI compliant smelter. As previously disclosed, Plexus does not do business directly with any of the smelters or refiners listed. The list was generated based on information received from the Company’s suppliers. Plexus continues to conduct independent research on smelters and refiners and will work with suppliers throughout our supply chain to help improve and refine reported information in future years. Plexus will continue to communicate expectations and information requirements to our direct suppliers. We will continue to make inquiries to direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. Although we requested information at a product level, as previously disclosed, a majority of suppliers returned information at a company or division level, not at a product level. Therefore, the information provided was not necessarily limited to smelters or refiners confirmed to be in the Company’s supply chain. From the responses that we received, we identified 6 smelters that potentially posed a risk. These concerns stem from location of the facilities and claims that fall outside of the scope of the conflict minerals Rule. We will continue to work with our suppliers to determine if these smelters can be directly linked to the actual parts or products sold to Plexus. Due to the submission of company level responses, we cannot make this determination at this time. In addition, various supplier responses were incomplete, as all supply chain participants continue to map their upstream supply chains. As a result, Plexus is unable to definitively validate whether the facilities listed in Annex A actually processed the minerals contained in our products. Steps to Continuously Improve Due Diligence In addition to the initiatives outlined above, Plexus plans to take the following steps during the next compliance period to improve the due diligence conducted and to further mitigate the risk that these conflict minerals benefit armed groups: 9 Actively participate in and support industry trade groups to help improve communication throughout the supply chain. Plexus is an active member of the EICC, and will continue its membership activity through the coming year. Continue to partner with certain customers to help educate suppliers on our ongoing expectations supporting responsible sourcing decisions. Continue to expand and improve supplier engagement. With the goal of increasing the response rate and quality of survey responses, Plexus will continue to reach out to suppliers, support education and training, and seek to integrate expectations into new supplier contracts. Evaluate ongoing supplier relationships with those suppliers that do not comply with our Conflict Minerals Policy. We plan to assess year-over-year supplier submissions to identify suppliers who have not made improvements to their CM programs in an attempt to reduce their risk. Comparisons between 2015 and 2016 submissions are currently underway. An educational outreach program will be offered for those suppliers failing to provide a CMRT for both years through the Provider. Evaluate the suppliers that have provided smelters or refiners on the previously mentioned 6 risky smelters and require smelter diligence training for those suppliers. Continue to enhance and refine due diligence measures. Based on an evaluation of the 2016 supplier survey process, Plexus will continue to work with third-party service providers to enhance its supplier survey and due diligence processes. In the 2017 reporting year, Plexus will be shifting the scoping effort defined by spend to an effort that identifies parts that contain 3TG or do not contain 3TG regardless of spend. 10 Annex A List of Identified Smelters/Refiners for 2016 Conflict Free? CID002708 Unknown Unknown CID000015 Yes Unknown JAPAN UNITED ARAB EMIRATES CID000019 Yes No CID002560 Yes Unknown GERMANY CID000035 Yes Unknown Gold Allgemeine Gold-und Silberscheideanstalt A.G. Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN CID000041 Yes Unknown Gold AngloGold Ashanti Córrego do Sítio Mineração CID000058 Yes Unknown Gold Argor-Heraeus S.A. BRAZIL SWITZERLAN D CID000077 Yes Unknown Gold Asahi Pretec Corp. JAPAN CID000082 Yes No Gold Asahi Refining Canada Ltd. CID000924 Yes Unknown Gold Asahi Refining USA Inc. CANADA UNITED STATES CID000920 Yes Unknown Gold Asaka Riken Co., Ltd. JAPAN CID000090 Yes No Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. CID000103 Unknown Unknown Gold AU Traders and Refiners CID002850 Yes Unknown Gold AURA-II TURKEY SOUTH AFRICA UNITED STATES CID002851 Unknown Unknown Gold Aurubis AG GERMANY CID000113 Yes Unknown Gold INDIA CID002863 Unknown Unknown Gold Bangalore Refinery Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES CID000128 Yes Unknown Gold Boliden AB SWEDEN CID000157 Yes Unknown Gold C. Hafner GmbH + Co. KG GERMANY CID000176 Yes Unknown Gold Caridad MEXICO CID000180 Unknown Unknown Gold CCR Refinery - Glencore Canada Corporation CID000185 Yes Unknown Gold Cendres + Métaux S.A. CANADA SWITZERLAN D CID000189 Unknown Unknown Gold Chimet S.p.A. ITALY CID000233 Yes Unknown Gold Chugai Mining CID000264 Unknown Unknown Gold Daejin Indus Co., Ltd. JAPAN KOREA, REPUBLIC OF CID000328 Yes Unknown Gold Daye Non-Ferrous Metals Mining Ltd. CHINA CID000343 Yes Unknown Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY CID002867 Unknown Unknown Gold DODUCO GmbH GERMANY CID000362 Yes No Gold Dowa JAPAN CID000401 Yes No Standard Smelter Name Gold Abington Reldan Metals, LLC Gold Advanced Chemical Company Gold Aida Chemical Industries Co., Ltd. Gold Al Etihad Gold Refinery DMCC Gold Smelter Facility Location Source from DRC? Smelter ID Metal UNITED STATES UNITED STATES 11 Gold DSC (Do Sung Corporation) Gold Eco-System Recycling Co., Ltd. Gold Elemetal Refining, LLC Gold KOREA, REPUBLIC OF CID000359 Yes Unknown CID000425 Yes No CID001322 Yes No Emirates Gold DMCC JAPAN UNITED STATES UNITED ARAB EMIRATES CID002561 Yes Unknown Gold Fidelity Printers and Refiners Ltd. ZIMBABWE CID002515 Unknown Unknown Gold Gansu Seemine Material Hi-Tech Co., Ltd. CID000522 Unknown Unknown Gold Geib Refining Corporation CHINA UNITED STATES CID002459 Unknown Unknown Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA CID001909 Unknown Unknown Gold Guangdong Jinding Gold Limited CHINA CID002312 Unknown Unknown Gold INDIA CID002852 Unknown Unknown Gold Gujarat Gold Centre Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA CID000651 Unknown Unknown Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA CID000671 Unknown Unknown Gold Heimerle + Meule GmbH GERMANY CID000694 Yes No Gold Heraeus Ltd. Hong Kong CHINA CID000707 Yes Unknown Gold Heraeus Precious Metals GmbH & Co. KG GERMANY CID000711 Yes Unknown Gold Hunan Chenzhou Mining Co., Ltd. CID000767 Unknown Unknown Gold CID000778 Unknown Unknown Gold Hwasung CJ Co., Ltd. Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA KOREA, REPUBLIC OF CHINA CID000801 Yes Unknown Gold Ishifuku Metal Industry Co., Ltd. JAPAN CID000807 Yes Unknown Gold Istanbul Gold Refinery TURKEY CID000814 Yes Unknown Gold Japan Mint JAPAN CID000823 Yes Unknown Gold Yes Unknown CID000927 Yes Unknown Gold JSC Uralelectromed CHINA RUSSIAN FEDERATION RUSSIAN FEDERATION CID000855 Gold Jiangxi Copper Co., Ltd. JSC Ekaterinburg Non-Ferrous Metal Processing Plant CID000929 Yes Unknown Gold JX Nippon Mining & Metals Co., Ltd. CID000937 Yes Unknown Gold Kaloti Precious Metals JAPAN UNITED ARAB EMIRATES CID002563 Unknown Unknown Gold Kazakhmys Smelting LLC KAZAKHSTAN CID000956 Unknown Unknown Gold Kazzinc CID000957 Yes Unknown Gold Kennecott Utah Copper LLC KAZAKHSTAN UNITED STATES CID000969 Yes Unknown Gold KGHM Polska Miedź Spółka Akcyjna POLAND CID002511 Unknown Unknown Gold Kojima Chemicals Co., Ltd. CID000981 Yes No Gold Korea Zinc Co., Ltd. JAPAN KOREA, REPUBLIC OF CID002605 Yes Unknown Gold Kyrgyzaltyn JSC CID001029 Yes Unknown Gold L'azurde Company For Jewelry KYRGYZSTAN SAUDI ARABIA CID001032 Unknown Unknown 12 Gold Lingbao Gold Co., Ltd. CHINA CID001056 Unknown Unknown Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA CID001058 Unknown Unknown Gold L'Orfebre S.A. CID002762 Unknown Unknown Gold LS-NIKKO Copper Inc. ANDORRA KOREA, REPUBLIC OF CID001078 Yes Unknown Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CID001093 Unknown Unknown Gold Materion CHINA UNITED STATES CID001113 Yes No Gold Matsuda Sangyo Co., Ltd. JAPAN CID001119 Yes Unknown Gold Metalor Technologies (Hong Kong) Ltd. CHINA CID001149 Yes Unknown Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE CID001152 Yes Unknown Gold Metalor Technologies (Suzhou) Ltd. CID001147 Yes Unknown Gold Metalor Technologies S.A. CID001153 Yes Unknown Gold Metalor USA Refining Corporation CHINA SWITZERLAN D UNITED STATES CID001157 Yes Unknown Gold Metalúrgica Met-Mex Peñoles S.A. De C.V. MEXICO CID001161 Yes Unknown Gold Mitsubishi Materials Corporation JAPAN CID001188 Yes Unknown Gold Mitsui Mining and Smelting Co., Ltd. JAPAN CID001193 Yes Unknown Gold MMTC-PAMP India Pvt., Ltd. INDIA CID002509 Yes Unknown Gold Modeltech Sdn Bhd CID002857 Unknown Unknown Gold Morris and Watson MALAYSIA NEW ZEALAND CID002282 Unknown Unknown Gold Morris and Watson Gold Coast CID002866 Unknown Unknown Gold Moscow Special Alloys Processing Plant AUSTRALIA RUSSIAN FEDERATION CID001204 Yes Unknown Gold Nadir Metal Rafineri San. Ve Tic. A.Ş. TURKEY CID001220 Yes Unknown Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN CID001236 Unknown Unknown Gold Nihon Material Co., Ltd. Ögussa Österreichische Gold- und SilberScheideanstalt GmbH JAPAN CID001259 Yes Unknown AUSTRIA CID002779 Yes Unknown Yes No CID001326 Yes Unknown Gold OJSC Novosibirsk Refinery CID000493 Yes Unknown Gold PAMP S.A. CID001352 Yes Unknown Gold Pease & Curren JAPAN RUSSIAN FEDERATION RUSSIAN FEDERATION SWITZERLAN D UNITED STATES CID001325 Gold Ohura Precious Metal Industry Co., Ltd. OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) CID002872 Unknown Unknown Gold Penglai Penggang Gold Industry Co., Ltd. CID001362 Unknown Unknown Gold Prioksky Plant of Non-Ferrous Metals CHINA RUSSIAN FEDERATION CID001386 Yes Unknown Gold PT Aneka Tambang (Persero) Tbk CID001397 Yes Unknown Gold PX Précinox S.A. INDONESIA SWITZERLAN D CID001498 Yes Unknown Gold Rand Refinery (Pty) Ltd. SOUTH CID001512 Yes Unknown Gold Gold 13 AFRICA Gold Remondis Argentia B.V. Gold Republic Metals Corporation NETHERLAND S UNITED STATES Gold Royal Canadian Mint Gold SAAMP Gold Sabin Metal Corp. Gold SAFINA A.S. Gold Sai Refinery Gold Samduck Precious Metals Gold SAMWON Metals Corp. Gold SAXONIA Edelmetalle GmbH Gold Schone Edelmetaal B.V. Gold CID002582 Unknown Unknown CID002510 Yes Unknown CANADA CID001534 Yes Unknown FRANCE UNITED STATES CZECH REPUBLIC CID002761 Unknown Unknown CID001546 Unknown Unknown CID002290 Unknown Unknown INDIA KOREA, REPUBLIC OF KOREA, REPUBLIC OF CID002853 Unknown Unknown CID001555 Yes Unknown CID001562 Unknown Unknown GERMANY NETHERLAND S CID002777 Yes Unknown CID001573 Yes Unknown SPAIN CID001585 Yes Unknown Gold SEMPSA Joyería Platería S.A. Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA CID001619 Unknown Unknown Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA CID001622 Yes Unknown Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA CID001736 Yes Unknown Gold Singway Technology Co., Ltd. CID002516 Yes No Gold CID001754 Unknown Unknown Gold So Accurate Group, Inc. SOE Shyolkovsky Factory of Secondary Precious Metals TAIWAN UNITED STATES RUSSIAN FEDERATION CID001756 Yes Unknown Gold Solar Applied Materials Technology Corp. TAIWAN CID001761 Yes No Gold Sudan Gold Refinery SUDAN CID002567 Unknown Unknown Gold Sumitomo Metal Mining Co., Ltd. CID001798 Yes Unknown Gold SungEel HiTech JAPAN KOREA, REPUBLIC OF CID002918 Unknown Unknown Gold T.C.A S.p.A ITALY CID002580 Yes Unknown Gold Tanaka Kikinzoku Kogyo K.K. JAPAN CID001875 Yes Unknown Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA CID001916 Yes Unknown Gold Tokuriki Honten Co., Ltd. JAPAN CID001938 Yes Unknown Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA CID001947 Unknown Unknown Gold Tony Goetz NV BELGIUM CID002587 Unknown Unknown Gold TOO Tau-Ken-Altyn CID002615 Unknown Unknown Gold Torecom KAZAKHSTAN KOREA, REPUBLIC OF CID001955 Yes Unknown Gold Umicore Brasil Ltda. BRAZIL CID001977 Yes Unknown Gold Umicore Precious Metals Thailand Umicore S.A. Business Unit Precious Metals Refining THAILAND CID002314 Yes Unknown BELGIUM CID001980 Yes Unknown Gold 14 Gold United Precious Metal Refining, Inc. Gold Universal Precious Metals Refining Zambia Gold UNITED STATES CID001993 Yes No CID002854 Unknown Unknown Valcambi S.A. ZAMBIA SWITZERLAN D CID002003 Yes Unknown Gold Western Australian Mint trading as The Perth Mint AUSTRALIA CID002030 Yes Unknown Gold WIELAND Edelmetalle GmbH GERMANY CID002778 Yes Unknown Gold Yamamoto Precious Metal Co., Ltd. JAPAN CID002100 Yes No Gold Yokohama Metal Co., Ltd. JAPAN CID002129 Yes No Gold CHINA CID000197 Unknown Unknown Gold Yunnan Copper Industry Co., Ltd. Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA CID002224 Yes Unknown Gold Zijin Mining Group Co., Ltd. Gold Refinery CHINA CID002243 Yes Unknown Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA CID000211 Yes No Tantalum Conghua Tantalum and Niobium Smeltry CID000291 Yes Yes Tantalum D Block Metals, LLC CHINA UNITED STATES CID002504 Yes No Tantalum Duoluoshan CID000410 Yes Yes Tantalum Exotech Inc. CHINA UNITED STATES CID000456 Yes No Tantalum F&X Electro-Materials Ltd. CHINA CID000460 Yes Yes Tantalum FIR Metals & Resource Ltd. CHINA CID002505 Yes No Tantalum Global Advanced Metals Aizu CID002558 Yes Yes Tantalum Global Advanced Metals Boyertown JAPAN UNITED STATES CID002557 Yes Yes Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA CID000616 Yes No Tantalum H.C. Starck Co., Ltd. THAILAND CID002544 Yes Yes Tantalum H.C. Starck GmbH Goslar GERMANY CID002545 Yes Yes Tantalum H.C. Starck GmbH Laufenburg GERMANY CID002546 Yes Yes Tantalum H.C. Starck Hermsdorf GmbH CID002547 Yes No Tantalum H.C. Starck Inc. GERMANY UNITED STATES CID002548 Yes No Tantalum H.C. Starck Ltd. JAPAN CID002549 Yes No Tantalum GERMANY CID002550 Yes Yes Tantalum H.C. Starck Smelting GmbH & Co. KG Hengyang King Xing Lifeng New Materials Co., Ltd. CID002492 Yes No Tantalum Hi-Temp Specialty Metals, Inc. CHINA UNITED STATES CID000731 Yes No Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA CID002512 Yes No Tantalum Jiangxi Tuohong New Raw Material CHINA CID002842 Yes Unknown Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA CID000914 Yes Yes Tantalum Jiujiang Tanbre Co., Ltd. CHINA CID000917 Yes Yes Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA CID002506 Yes No 15 Tantalum KEMET Blue Metals CID002539 Yes Yes KEMET Blue Powder MEXICO UNITED STATES Tantalum CID002568 Yes No Tantalum King-Tan Tantalum Industry Ltd. CHINA CID000973 Yes No Tantalum LSM Brasil S.A. BRAZIL CID001076 Yes No Tantalum Metallurgical Products India Pvt., Ltd. INDIA CID001163 Yes No Tantalum Mineração Taboca S.A. BRAZIL CID001175 Yes No Tantalum Mitsui Mining & Smelting JAPAN CID001192 Yes Yes Tantalum Molycorp Silmet A.S. ESTONIA CID001200 Yes No Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA CID001277 Yes Yes Tantalum Plansee SE Liezen AUSTRIA CID002540 Yes No Tantalum Plansee SE Reutte AUSTRIA CID002556 Yes No Tantalum Power Resources Ltd. CID002847 Yes Unknown Tantalum QuantumClean MACEDONIA UNITED STATES CID001508 Yes No Tantalum Resind Indústria e Comércio Ltda. BRAZIL CID002707 Yes No Tantalum RFH Tantalum Smeltry Co., Ltd. CID001522 Yes No Tantalum Solikamsk Magnesium Works OAO CHINA RUSSIAN FEDERATION CID001769 Yes No Tantalum Taki Chemicals CID001869 Yes Yes Tantalum Telex Metals CID001891 Yes No Tantalum Tranzact, Inc. JAPAN UNITED STATES UNITED STATES CID002571 Yes No Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN CID001969 Yes Yes Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA CID002508 Yes No Tantalum Yichun Jin Yang Rare Metal Co., Ltd. CHINA CID002307 Yes No Tantalum Zhuzhou Cemented Carbide Group Co., Ltd. CID002232 Yes Yes Tin Alpha CHINA UNITED STATES CID000292 Yes No Tin An Thai Minerals Co., Ltd. VIET NAM CID002825 Unknown Unknown Tin VIET NAM CID002703 Unknown Unknown Tin An Vinh Joint Stock Mineral Processing Company Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA CID000228 Yes Unknown Tin China Tin Group Co., Ltd. CHINA CID001070 Yes No Tin CNMC (Guangxi) PGMA Co., Ltd. CHINA CID000278 Unknown Unknown Tin Cooperativa Metalurgica de Rondônia Ltda. BRAZIL CID000295 Yes No Tin CV Ayi Jaya INDONESIA CID002570 Yes No Tin CV Dua Sekawan INDONESIA CID002592 Yes Unknown Tin CV Gita Pesona INDONESIA CID000306 Yes No Tin CV Serumpun Sebalai INDONESIA CID000313 Yes No 16 Tin CV Tiga Sekawan INDONESIA CID002593 Yes Unknown Tin CV United Smelting INDONESIA CID000315 Yes No Tin CV Venus Inti Perkasa INDONESIA CID002455 Yes No Tin JAPAN CID000402 Yes No Tin Dowa Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company VIET NAM CID002572 Unknown Unknown Tin Elmet S.L.U. SPAIN CID002774 Yes No Tin EM Vinto BOLIVIA CID000438 Yes No Tin Estanho de Rondônia S.A. BRAZIL CID000448 Unknown Unknown Tin Fenix Metals POLAND CID000468 Yes No Tin Gejiu Fengming Metallurgy Chemical Plant CHINA CID002848 Yes Unknown Tin Gejiu Jinye Mineral Company CHINA CID002859 Yes Unknown Tin Gejiu Kai Meng Industry and Trade LLC CHINA CID000942 Unknown Unknown Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA CID000538 Yes No Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA CID001908 Unknown Unknown Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA CID000555 Unknown Unknown Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA CID002849 Yes Unknown Tin HuiChang Hill Tin Industry Co., Ltd. CHINA CID002844 Yes Unknown Tin Huichang Jinshunda Tin Co., Ltd. CHINA CID000760 Unknown Unknown Tin Jiangxi Ketai Advanced Material Co., Ltd. CHINA CID000244 Yes No Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL CID002468 Yes No Tin Malaysia Smelting Corporation (MSC) MALAYSIA CID001105 Yes Yes Tin Melt Metais e Ligas S.A. CID002500 Yes No Tin Metallic Resources, Inc. BRAZIL UNITED STATES CID001142 Yes No Tin Metallo-Chimique N.V. BELGIUM CID002773 Yes No Tin Mineração Taboca S.A. BRAZIL CID001173 Yes No Tin Minsur PERU CID001182 Yes No Tin Mitsubishi Materials Corporation JAPAN CID001191 Yes No Tin Modeltech Sdn Bhd MALAYSIA CID002858 Unknown Unknown Tin CHINA CID001231 Unknown Unknown Tin Nankang Nanshan Tin Manufactory Co., Ltd. Nghe Tinh Non-Ferrous Metals Joint Stock Company VIET NAM CID002573 Unknown Unknown Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND CID001314 Yes No Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES CID002517 Yes No Tin Operaciones Metalurgical S.A. BOLIVIA CID001337 Yes No Tin Phoenix Metal Ltd. RWANDA CID002507 Unknown Unknown Tin PT Aries Kencana Sejahtera INDONESIA CID000309 Yes No 17 Tin PT Artha Cipta Langgeng INDONESIA CID001399 Yes No Tin PT ATD Makmur Mandiri Jaya INDONESIA CID002503 Yes No Tin PT Babel Inti Perkasa INDONESIA CID001402 Yes No Tin PT Bangka Prima Tin INDONESIA CID002776 Yes No Tin PT Bangka Tin Industry INDONESIA CID001419 Yes No Tin PT Belitung Industri Sejahtera INDONESIA CID001421 Yes No Tin PT Bukit Timah INDONESIA CID001428 Yes No Tin PT Cipta Persada Mulia INDONESIA CID002696 Yes No Tin PT DS Jaya Abadi INDONESIA CID001434 Yes No Tin PT Eunindo Usaha Mandiri INDONESIA CID001438 Yes No Tin PT Inti Stania Prima INDONESIA CID002530 Yes No Tin PT Justindo INDONESIA CID000307 Yes No Tin PT Karimun Mining INDONESIA CID001448 Yes Unknown Tin PT Kijang Jaya Mandiri INDONESIA CID002829 Yes Unknown Tin PT Lautan Harmonis Sejahtera INDONESIA CID002870 Yes Unknown Tin PT Mitra Stania Prima INDONESIA CID001453 Yes No Tin PT O.M. Indonesia INDONESIA CID002757 Yes Unknown Tin PT Panca Mega Persada INDONESIA CID001457 Yes No Tin PT Prima Timah Utama INDONESIA CID001458 Yes No Tin PT Refined Bangka Tin INDONESIA CID001460 Yes No Tin PT Sariwiguna Binasentosa INDONESIA CID001463 Yes No Tin PT Stanindo Inti Perkasa INDONESIA CID001468 Yes No Tin PT Sukses Inti Makmur INDONESIA CID002816 Yes No Tin PT Sumber Jaya Indah INDONESIA CID001471 Yes No Tin PT Timah (Persero) Tbk Kundur INDONESIA CID001477 Yes No Tin PT Timah (Persero) Tbk Mentok INDONESIA CID001482 Yes No Tin PT Tinindo Inter Nusa INDONESIA CID001490 Yes No Tin PT Tommy Utama INDONESIA CID001493 Yes Unknown Tin PT Wahana Perkit Jaya INDONESIA CID002479 Yes No Tin Resind Indústria e Comércio Ltda. BRAZIL CID002706 Yes No Tin Rui Da Hung TAIWAN CID001539 Yes No Tin Soft Metais Ltda. BRAZIL CID001758 Yes No Tin THAILAND CID001898 Yes Yes Tin Thaisarco Tuyen Quang Non-Ferrous Metals Joint Stock Company VIET NAM CID002574 Unknown Unknown Tin VQB Mineral and Trading Group JSC VIET NAM CID002015 Yes No 18 Tin White Solder Metalurgia e Mineração Ltda. BRAZIL CID002036 Yes No Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA CID002158 Unknown Unknown Tin Yunnan Tin Company Limited CHINA CID002180 Yes No Tungsten A.L.M.T. TUNGSTEN Corp. JAPAN CID000004 Yes No Tungsten ACL Metais Eireli BRAZIL CID002833 Unknown Unknown Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM CID002502 Yes Yes Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA CID002513 Yes No Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA CID000258 Yes No Tungsten Dayu Weiliang Tungsten Co., Ltd. CHINA CID000345 Unknown Unknown Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA CID000499 Yes No Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA CID000875 Yes No Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA CID002315 Yes No Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA CID002494 Yes No Tungsten Ganzhou Yatai Tungsten Co., Ltd. CID002536 Unknown Unknown Tungsten Global Tungsten & Powders Corp. CHINA UNITED STATES CID000568 Yes No Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA CID000218 Yes No Tungsten H.C. Starck GmbH GERMANY CID002541 Yes No Tungsten H.C. Starck Smelting GmbH & Co.KG GERMANY CID002542 Yes No Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA CID000766 Yes No Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA CID002579 Yes Unknown Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CID000769 Yes No Tungsten Hydrometallurg, JSC CHINA RUSSIAN FEDERATION CID002649 Yes No Tungsten Japan New Metals Co., Ltd. JAPAN CID000825 Yes No Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA CID002551 Yes No Tungsten Jiangxi Dayu Longxintai Tungsten Co., Ltd. CHINA CID002647 Unknown Unknown Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA CID002321 Yes No CHINA CID002313 Unknown Unknown CHINA CID002318 Yes No CHINA CID002317 Yes No Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CHINA CID002535 Yes No Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CID002316 Yes Unknown Tungsten Kennametal Fallon CID000966 Yes No Tungsten Kennametal Huntsville CHINA UNITED STATES UNITED STATES CID000105 Yes No Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA CID002319 Yes No Tungsten Tungsten Tungsten 19 Tungsten Moliren Ltd Tungsten Niagara Refining LLC Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC RUSSIAN FEDERATION UNITED STATES CID002845 Yes Unknown CID002589 Yes No VIET NAM CID002543 Yes No PHILIPPINES CID002827 Yes Unknown Tungsten Philippine Chuangxin Industrial Co., Inc. South-East Nonferrous Metal Company Limited of Hengyang City CHINA CID002815 Yes Unknown Tungsten Tejing (Vietnam) Tungsten Co., Ltd. CID001889 Yes No Tungsten Unecha Refractory metals plant VIET NAM RUSSIAN FEDERATION CID002724 Yes Unknown Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd. VIET NAM CID002011 Yes Yes Tungsten Wolfram Bergbau und Hütten AG CID002044 Yes Yes Tungsten Woltech Korea Co., Ltd. AUSTRIA KOREA, REPUBLIC OF CID002843 Yes Unknown Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA CID002320 Yes Yes Tungsten CHINA CID002082 Yes No Tungsten Xiamen Tungsten Co., Ltd. Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA CID002830 Yes Unknown Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA CID002095 Yes No Tungsten Tungsten 20