Document



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

FORM SD
Specialized Disclosure Report

https://cdn.kscope.io/faf5133b167e98a68f0b1b110e557f53-livanova2017conflictm_image1.jpg
LivaNova PLC


 
 
 
 
 
England and Wales 
(State or other jurisdiction of
incorporation or organization)
 
001-37599
(Commission File Number)
 
98-1268150 
(I.R.S. Employer Identification No.)

20 Eastbourne Terrace
London, United Kingdom
W2 6LG
(Address of Principal Executive Offices) (Zip Code)


Catherine Moroz
Company Secretary
+44 (0)203 786 5277

(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, 2017.






INFORMATION TO BE INCLUDED IN THE REPORT

Section 1—Conflict Minerals Disclosure

Item 1.01    Conflict Minerals Disclosure and Report

LivaNova PLC, a public limited company incorporated under the laws of England and Wales (“LivaNova”) was formed for the purpose of facilitating the business combination of Cyberonics, Inc., a Delaware corporation (“Cyberonics”), and Sorin S.p.A., a joint stock company organized under the laws of Italy (“Sorin”). Cyberonics was considered the accounting acquirer and LivaNova PLC (“LivaNova”, “registrant”, “we”, “us”, or “our”) became the successor organization to Cyberonics. This report combines the reporting requirements for legacy Cyberonics and now also includes reporting requirements for those products previously manufactured and distributed by legacy Sorin S.p.A. LivaNova is filing this Specialized Disclosure report on Form SD (this “Form SD”) for LivaNova’s Neuromodulation, Cardiac Rhythm Management, and Cardiac Surgery supply chain operations for the year ended December 31, 2017. This Form SD is presented in compliance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2017 to December 31, 2017.
A copy of our Conflict Minerals Report is filed as a part of this Form SD. In accordance with Rule 12b-12 (17 CFR 240.12b-12), a copy of this Form SD may be found on our website at http://www.livanova.com/investor-relations/sec-filings.
Item 1.02    Exhibits
LivaNova has filed, as an exhibit to this Form SD, the Conflict Minerals Report required by Item 1.01.

Section 2—Exhibits

Item 2.01    Exhibits
The following exhibit is filed as part of this report.
Exhibit
 
Description
 
 
 
1.01
 
Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.


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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.
 
LivaNova PLC
 
 
 
 
Date: May 31, 2018
By:/s/ Catherine Moroz         
 
Name: Catherine Moroz
 
Title: Company Secretary
 
 


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Exhibit

Exhibit 1.01
LivaNova PLC
Conflict Minerals Report
For the Year Ended December 31, 2017

This Conflict Minerals Report of LivaNova PLC (this “Report”) has been prepared for the reporting period from January 1, 2017 to December 31, 2017 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement disclosure and reporting requirements pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). The Act defines conflict minerals as cassiterite (tin), columbite-tanlite (tantalum), gold, wolframite (tungsten), (together, “3TG”) or their derivatives (“Conflict Minerals”). The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. The Rule imposes certain reporting requirements on SEC registrants who manufacture or contract to manufacture products that include Conflict Minerals, if such Conflict Minerals are necessary to the functionality or production of the products.
1.
Company Overview
This Report has been prepared by the management of LivaNova PLC (“LivaNova,” “we,” “us,” “registrant,” or “our”). It does not include the activities of variable interest entities that are not required to be consolidated.
As described in Item 1.01 of the Form SD, LivaNova PLC, a public limited company incorporated under the laws of England and Wales (“LivaNova”) was formed for the purpose of facilitating the business combination of Cyberonics, Inc., a Delaware corporation (“Cyberonics”), and Sorin S.p.A., a joint stock company organized under the laws of Italy (“Sorin”). Cyberonics was considered the accounting acquirer and LivaNova PLC (“LivaNova”, “registrant”, “we”, “us”, or “our”) became the successor organization to Cyberonics. This report combines the reporting requirements for legacy Cyberonics and legacy Sorin S.p.A. This Conflict Minerals Report, reports the results for LivaNova Neuromodulation, Cardiac Rhythm Management, and Cardiac Surgery supply chain operations for the year ended December 31, 2017.
At LivaNova, we understand the importance of bringing both clinical and economic value to our customers. We are a strong, market-leading medical technology and services company, offering a diverse product portfolio and global reach. In fiscal year 2017, LivaNova operated as three business franchises:
Cardiac Surgery: Our Cardiac Surgery Business Franchise is engaged in the development, production and sale of cardiac surgery products, including oxygenators, heart-lung machines, perfusion tubing systems, cannulae and other accessories used for extracorporeal circulation, systems for autologous blood transfusion and blood washing, as well as a complete line of surgical tissue and mechanical heart valve replacements and repair products.
Neuromodulation: Our Neuromodulation Business Franchise designs, develops and markets neuromodulation-based medical devices for the treatment of epilepsy and depression.
Our seminal neuromodulation product, the VNS Therapy® System, is an implantable device authorized for the treatment of drug-resistant epilepsy and treatment-resistant depression (“TRD”). The VNS Therapy System consists of an implantable pulse generator and connective lead that work to stimulate the vagus nerve; surgical equipment to assist with the implant procedure; equipment and instruction manuals enabling a treating physician to set parameters for a patient’s pulse generator; and for epilepsy, magnets to manually



suspend or induce nerve stimulation. The VNS Therapy pulse generator and lead are surgically implanted in a subcutaneous pocket in the upper left chest area, generally during an out-patient procedure; the lead (which does not need to be removed to replace a generator with a depleted battery) is connected to the pulse generator and tunneled under the skin to the vagus nerve in the lower left side of the patient’s neck.
Cardiac Rhythm Management: Until we divested it in the second quarter of 2018, the Cardiac Rhythm Management Business Franchise developed, manufactured, and marketed goods for the diagnosis, treatment, and management of heart rhythm disorders and heart failure. These products included implantable devices, leads and delivery systems and information systems for the management of patients with cardiac rhythm management devices.
Our broad and complex product range may contain conflict minerals within the following components:
Tantalum, used in capacitors;
Tin, used in electrical components, printed circuit board assembly (PCBA), hardware, and equipment;
Tungsten, used in coatings, alloys, heating elements and electrodes; and
Gold, used in circuit boards, electrodes and electronic components.
Additional information on LivaNova is available at www.livanova.com.
2.
General Policy and Team

We strive to conduct our activities in a manner that reflects our mission and Code of Business Conduct and Ethics – which includes being a good corporate citizen, dealing fairly in business, behaving ethically, supporting a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. We are committed to ensuring that our supply chain reflects our values and beliefs, including adherence to principles of responsible sourcing for materials for our products. As part of our commitment, LivaNova supports the goals and objectives of Section 1502 of the Dodd Frank Act that requires public companies to determine the sourcing of conflict minerals used in their products. We expect our suppliers to support our efforts to comply with the Dodd Frank Act and to proactively identify and work towards eliminating the use of any minerals that fund or benefit armed groups from within our supply chain. In addition, we expect our suppliers to conduct business operations in an ethical manner and to comply with our Code of Conduct and all applicable laws related to environmental responsibility, workplace health and safety, and human resources.
We have established a cross-functional team to implement our conflict mineral compliance strategy and policy. This team has executive level involvement and access to various subject matter experts from such areas as sourcing, procurement, legal and finance.

3.
Reasonable Country of Origin Inquiry

In beginning our analysis in conjunction with our partners at Assent Compliance, we first determined which of our products contained 3TGs necessary to the functionality or production of such products. We then conducted a good faith reasonable country of origin inquiry (“RCOI”) with respect to 3TGs contained in our products by assessing our supply chain in accordance with the OECD Guidance (as defined below).


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The RCOI was designed to determine whether any 3TGs contained in our products originated in the Covered Countries. We do not purchase minerals directly from mines, smelters or refiners and therefore must rely on our direct suppliers to provide information on the origin of the minerals contained in components and materials supplied to us or products manufactured for us.

We began our supplier scoping process by:

Determining which of our manufactured products contain one or more of the 3TGs;

Identifying our suppliers that manufactured or contracted to manufacture products containing 3TGs in 2017; and

Identified suppliers that provide product or service that are deemed out of scope (provide material that does not ship with or does not impact functionality of the final product).

The supply chain survey, and the conflict minerals program as a whole, has been developed and implemented in cooperation with Assent Compliance.

Our primary means of determining country of origin information for the necessary 3TGs was by conducting a supply chain survey with direct suppliers using the Conflict Minerals Reporting Template, or CMRT, developed by the Responsible Business Alliance – RBA GeSI. The CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide material to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, engagement with its direct suppliers, and a listing of the smelters and refiners that the direct supplier and its suppliers source from. In addition, the CMRT contains questions about the origin of conflict minerals included in the direct supplier’s products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are available on RBA’s website as well as provided by Assent Compliance. The CMRT version 5.0 or higher was the industry standard template used for conflict minerals data collection for 2017.
We surveyed 419 suppliers based on the scoping process noted above. Responses were tracked and supplier statuses reported regularly by Assent Compliance to LivaNova. As of May 20, 2018, we had received responses from 263 of the suppliers surveyed. Assent Compliance reached out to our suppliers a minimum of three times and then sent at least two escalated campaigns to those suppliers who had still not responded. In addition, LivaNova reached out to the non-responsive suppliers multiple times requesting they fulfill the request.

During the survey, Assent Compliance assessed the supplier list and received information from suppliers in the following groups that could be deemed as out of scope:

Service providers/suppliers
Indirect materials suppliers
Inactive suppliers (minimum 5 years since last purchase)

Once Assent received confirmation from LivaNova on these designations, the suppliers were classified as Out of Scope in the Assent Compliance Manager (“ACM”), which is the software tool used to manage the conflict minerals program. Through this process 4 suppliers were deemed out of scope.

Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions, identify submissions not including smelter lists and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that

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data is still retained. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. As of the 20th of May 2018, we still had 14 invalid supplier submissions that were not yet corrected.

There were some suppliers who were unable to provide smelter or refiner lists and suppliers who could not provide full smelter lists. Accordingly, before conducting an in-depth examination of the smelter information itself, it is important to note that since LivaNova was unable to obtain full smelter information from all in-scope suppliers, LivaNova is unable to confidently state the countries of origin for all 3TGs contained in our products.

4.
Due Diligence

4.1 Design of Due Diligence

LivaNova designed its due diligence process to be in conformity, in all material respects, with the due diligence framework of the Organization of Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively the “OECD Guidance”). LivaNova’s due diligence process is based on multi-industry initiatives with the smelters and refiners who provide conflict minerals within global supply chains.

4.1.1 Establish Strong Company Management and Control Systems

Conflict Minerals Policy

LivaNova has adopted a Conflict Minerals Policy, which is provided in section 2 of this report.

Internal Team and Training

LivaNova has established a management team relating to conflict minerals. Our management team is overseen by the Senior Vice President Global Operations and a team of subject matter experts from relevant functions such as, supply chain, operations, finance and legal. The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and is led by the VP of Global Supply Chain, who acts as the Conflict Minerals Program Manager. Some members of this team have attended external workshops involving this subject matter and have used this information to train those internally responsible for assisting with component review and data collection.

Control Systems

The Company expects its suppliers to have policies and procedures in place to ensure that any 3TGs used in the production of the products sold to LivaNova are DRC conflict-free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. Other controls include, but are not limited to, our Code of Business Conduct and Ethics which outlines certain expected behaviors for all employees. In addition, we rely on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us, including sources of 3TGs that are supplied to them from lower tier suppliers.


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Supplier Engagement

As we do not have a direct relationship with 3TGs smelters and refiners, we are engaged and actively cooperate with other manufacturers in our industry and other sectors. We rely primarily on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us, including sources of 3TGs that are supplied to them from lower tier suppliers.

We have leveraged the existing communications within the Company, specifically through our procurement personnel, to encourage supplier interactions with Assent Compliance as well for them to understand the need for completion of the surveys. Feedback from this process has allowed us to enhance the training, focus it and adapt it to each user’s needs. It has also allowed for our supplier communications to be more focused and ensure expectations are clear.

Grievance Mechanism

We have longstanding grievance mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Code of Business Conduct and Ethics policy.

Records Maintenance

We have retained all relevant documentation from our RCOI and due diligence process.

4.1.2    Identify and Assess Risk in Our Supply Chain

Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult for us to identify actors upstream from our direct suppliers.

As a result of a thorough review of the bill of materials (BOMs) of the products we distributed in 2017 for which we manufactured or contracted out manufacturing, we identified 419 direct suppliers to the company that may provide materials which contain any of the 3TGs. Out of those 419 suppliers, we initially deemed 4 as out of scope based upon the criteria listed above. We then based our RCOI on the remaining 415 suppliers. We rely on suppliers whose materials or components contain 3TGs to provide us with information about the source of 3TGs contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. Many of the largest suppliers either are SEC registrants and subject to the Rule or 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 3TGs in the supply chain. Smelter(s) or refiner(s) (“SORs”) that are not certified as DRC-Conflict Free by third party sources such as the Responsible Minerals Initiative – RMI pose a potential risk. Where a smelter is not identified as Conflict Free, it is assigned a risk rating of High, Medium or Low. This rating is based on various factors, including the SOR’s geographic location, including proximity to the Covered Countries, the SOR’s Responsible Minerals Assurance Process – RMAP audit status, and any known or plausible evidence of unethical or conflicting sourcing.

We calculate supplier risk based on the chances 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. Based on the above criteria, the following facilities have been identified as being of highest concern to the supply chain:

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Tony Goetz NV - CID002587
Kaloti Precious Metals - CID002563
Universal Precious Metals Refining Zambia - CID002854
Fidelity Printers and Refiners - CID002515
Sudan Gold Refinery - CID002567
African Gold Refinery Limited (AGR) - CID003185

When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above 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 the Company, and escalating up to removal of these high-risk smelters from their supply chain.
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.
Additionally, suppliers are evaluated on program strength (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 the supplier’s program are:
Do you have a policy in place that includes DRC conflict-free sourcing?
Have you implemented due diligence measures for conflict-free sourcing?
Do you review due diligence information received from your suppliers against your company’s expectations?
Do you verify due diligence information received from your suppliers?

When suppliers answer yes, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.

The SORs listed by suppliers in their CMRTs were matched against a database of verified SORs. Verified SORs were matched against available lists of processors that have been certified by internationally-recognized industry validation schemes, such as the RMI’s Responsible Minerals Assurance Process – RMAP.

In cases where suppliers and products were associated with certified SORs they were categorized by the Company as “DRC Conflict Free.”

If the SOR was not certified by an internationally-recognized organization, research was conducted to gain more information about the SOR’s sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes the SOR had taken to track the chain-of-custody on the source of its mineral ores.

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 SORs in our supply chain represents the most reasonable effort we can make 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

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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.

4.1.3    Design and Implement a Strategy to Respond to Risks

In designing and implementing our strategy to respond to the supply chain risks that we identified, LivaNova analyzed various industry approaches. LivaNova has established a risk management plan through which the conflict minerals program is implemented, managed and monitored.

As part of our risk management plan, to ensure suppliers understand our expectations, we have provided both video, online training courses and documented instructions through Assent Compliance. We answered all questions or requests for clarification from suppliers, assistance completing the CMRT and one-on-one email or phone discussions with supplier personnel. We then provided each supplier a copy of the CMRT to complete for purposes of conflict minerals tracking. Furthermore, we reviewed responses to the reporting CMRT with specific suppliers where we needed clarification.

4.1.4 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

LivaNova does not have a direct relationship with SORs of 3TGs and as a result, LivaNova does not perform direct audits of these entities in its supply chain. LivaNova relies on the efforts of the industry associations that administer independent third-party SOR audit programs and encourages suppliers with more direct relationships with SORs to participate in comparable due diligence validation activities.

4.1.5
Report on Supply Chain Due Diligence

This Conflict Minerals Report is being filed with the SEC as an exhibit to our specialized disclosure report on Form SD and is available on our website at http://www.livanova.com/investor-relations/sec-filings.
5.
Due Diligence Results

During our due diligence efforts, members of Assent Compliance and/or members of the LivaNova supply chain team made at least three follow-up inquiries to each “non-responsive” supplier who did not respond to our initial survey, by phone or email. Assent Compliance reviewed the responses against criteria developed to determine which required further engagement with our suppliers. These criteria included incomplete responses as well as inconsistencies within the data reported in the CMRT. Assent Compliance worked directly with those suppliers to provide revised responses.

The large majority of the responses received provided data at the supplier company level or a division/segment level relative to the supplier, rather than at a level directly relating to a part number that the supplier supplies to us, or were otherwise unable to specify the SORs used for components supplied to us. We were therefore unable to determine whether any of the 3TGs that these suppliers reported was contained in components or parts supplied to us are actually in our supply chain.


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As noted above, we received 263 responses from our in-scope suppliers as of May 20, 2018. Based on these responses, for all responses that indicated a SOR, our third party consultant compared the facilities listed to the list of SORs maintained by the RMI. If a supplier indicated that the facility was certified as “Conflict-Free,” Assent Compliance confirmed that the name was listed by RMI as a certified SOR. No violations were identified. As of May 20, 2018, we have validated 318 SORs and we are working to validate the additional SOR entries from the submitted CMRTs. Appendix A lists all legitimate smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix B includes an aggregated list of the potential countries of origin from which the reported facilities collectively source conflict minerals, based upon information provided by suppliers and RMI.

Based on the smelter lists provided by suppliers via the CMRTs and publicly available information, we have identified 257 SORs that are certified conflict free smelters by the RMI.

Efforts to Determine Mine or Location of Origin

By requesting our suppliers to complete the CMRT, and, as the program progresses, requiring full completion of all necessary smelter identification information which will enable the validation and disclosure of the SORs as well as the tracing of the 3TGs to their location of origin, we have determined that seeking information about 3TGs SORs in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TGs in our supply chain.

Planned Process Improvements

We intend to take the following steps to improve our conflict minerals program:

Track and add new suppliers as they enter our supply chain to the Company’s Conflict Minerals program.

Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses.

Engage any of our suppliers found to be supplying us with 3TG from sources in the DRC or any adjoining country that they cannot demonstrate are “DRC conflict free” to establish an alternative source of 3TG that they can demonstrate are “DRC conflict free”.


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Appendix A 2017 Smelter or Refiner (SOR) List
The following smelters and refiners were reported by our suppliers as being in their supply chains. Facilities that have been certified as conflict-free by an internationally-recognized validation scheme (RMI) for 3TGs smelters and refiners are identified below.
Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
RMI Audit Status
Gold
Abington Reldan Metals, LLC
UNITED STATES
CID002708
Not Enrolled
Gold
Advanced Chemical Company
UNITED STATES
CID000015
Conformant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Conformant
Gold
Al Etihad Gold LLC
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 Córrego do Sítio Mineração
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
CID000920
Conformant
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Conformant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
Not Enrolled
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Conformant
Gold
Aurubis AG
GERMANY
CID000113
Conformant
Gold
Bangalore Refinery
INDIA
CID002863
Active
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
Caridad
MEXICO
CID000180
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Conformant
Gold
Cendres + Métaux S.A.
SWITZERLAND
CID000189
Conformant

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Gold
Chimet S.p.A.
ITALY
CID000233
Conformant
Gold
Chugai Mining
JAPAN
CID000264
Not Enrolled
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
Conformant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
Not Enrolled
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Conformant
Gold
Dowa
JAPAN
CID000401
Conformant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Conformant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID000425
Conformant
Gold
Elemetal Refining, LLC
UNITED STATES
CID001322
Not Enrolled
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Conformant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
Not Enrolled
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002852
Not Enrolled
Gold
Geib Refining Corporation
UNITED STATES
CID002459
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000651
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
Not Enrolled
Gold
HeeSung
KOREA, REPUBLIC OF
CID000689
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
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
CID000778
Not Enrolled
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

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Gold
Italpreziosi
ITALY
CID002765
Conformant
Gold
Japan Mint
JAPAN
CID000823
Conformant
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Conformant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Conformant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Conformant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
Not Enrolled
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
Not Enrolled
Gold
Kazzinc
KAZAKHSTAN
CID000957
Conformant
Gold
Kennecott Utah Copper LLC
UNITED STATES
CID000969
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002511
Active
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
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID002865
Not Enrolled
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
Not Enrolled
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
Not Enrolled
Gold
L'Orfebre S.A.
ANDORRA
CID002762
Active
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Conformant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Not Enrolled
Gold
Marsam Metals
BRAZIL
CID002606
Conformant
Gold
Materion
UNITED STATES
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

11


Gold
Metalor USA Refining Corporation
UNITED STATES
CID001157
Conformant
Gold
Metalúrgica Met-Mex Peñoles 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
Active
Gold
Morris and Watson
NEW ZEALAND
CID002282
Not Enrolled
Gold
Morris and Watson Gold Coast
AUSTRALIA
CID002866
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
CID001220
Conformant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Not Enrolled
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Conformant
Gold
Ögussa Österreichische 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
Pease & Curren
UNITED STATES
CID002872
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Not Enrolled
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 Précinox S.A.
SWITZERLAND
CID001498
Conformant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Conformant
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID000522
Not Enrolled
Gold
Remondis Argentia B.V.
NETHERLANDS
CID002582
Active
Gold
Republic Metals Corporation
UNITED STATES
CID002510
Conformant
Gold
Royal Canadian Mint
CANADA
CID001534
Conformant

12


Gold
SAAMP
FRANCE
CID002761
Conformant
Gold
Sabin Metal Corp.
UNITED STATES
CID001546
Not Enrolled
Gold
Safimet S.p.A
Italy
CID002973
Conformant
Gold
SAFINA A.S.
CZECH REPUBLIC
CID002290
Active
Gold
Sai Refinery
INDIA
CID002853
Not Enrolled
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Conformant
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
CID001562
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Conformant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
CID001573
Conformant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
CID001585
Conformant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
Not Enrolled
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
CID002516
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Conformant
Gold
Solar Applied Materials Technology Corp.
TAIWAN
CID001761
Conformant
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID003153
Not Enrolled
Gold
Sudan Gold Refinery
SUDAN
CID002567
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Conformant
Gold
SungEel HiTech
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
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Not Enrolled
Gold
Tony Goetz NV
BELGIUM
CID002587
Not Enrolled
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Not Enrolled
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Conformant

13


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
CID001993
Conformant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
CID002854
Not Enrolled
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Conformant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
CID002030
Conformant
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Conformant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
CID002100
Conformant
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Conformant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Not Enrolled
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
D Block Metals, LLC
UNITED STATES
CID002504
Conformant
Tantalum
Duoluoshan
CHINA
CID000410
Not Enrolled
Tantalum
Exotech Inc.
UNITED STATES
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
CID002557
Conformant
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000291
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
CID002548
Conformant
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Conformant

14


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 Janny New Material Co., Ltd.
CHINA
CID003191
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
KEMET Blue Powder
UNITED STATES
CID002568
Conformant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
CID000973
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
Power Resources Ltd.
MACEDONIA
CID002847
Conformant
Tantalum
QuantumClean
UNITED STATES
CID001508
Conformant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID002707
Conformant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
CID001522
Conformant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Conformant
Tantalum
Taki Chemicals
JAPAN
CID001869
Conformant
Tantalum
Telex Metals
UNITED STATES
CID001891
Conformant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Conformant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
CID002307
Conformant
Tin
Alpha
UNITED STATES
CID000292
Conformant

15


Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID003190
Active
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Conformant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
CID000278
Not Enrolled
Tin
CV Ayi Jaya
INDONESIA
CID002570
Conformant
Tin
CV Dua Sekawan
INDONESIA
CID002592
Conformant
Tin
CV Gita Pesona
INDONESIA
CID000306
Conformant
Tin
CV Tiga Sekawan
INDONESIA
CID002593
Conformant
Tin
CV United Smelting
INDONESIA
CID000315
Conformant
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Conformant
Tin
Dowa
JAPAN
CID000402
Conformant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID002572
Not Enrolled
Tin
EM Vinto
BOLIVIA
CID000438
Conformant
Tin
Estanho de Rondônia S.A.
BRAZIL
CID000448
Not Enrolled
Tin
Fenix Metals
POLAND
CID000468
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Conformant
Tin
Gejiu Jinye Mineral Company
CHINA
CID002859
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
Not Enrolled
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
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 Ketai Advanced Material Co., Ltd.
CHINA
CID000244
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Conformant

16


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
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
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Conformant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
CID001337
Conformant
Tin
Pongpipat Company Limited
MYANMAR
CID003208
Not Enrolled
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Conformant
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Conformant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Conformant
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Conformant
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Conformant
Tin
PT Bangka Serumpun
INDONESIA
CID003205
Conformant
Tin
PT Bangka Tin Industry
INDONESIA
CID001419
Conformant
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Conformant
Tin
PT Bukit Timah
INDONESIA
CID001428
Conformant
Tin
PT DS Jaya Abadi
INDONESIA
CID001434
Conformant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
CID001438
Conformant
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Conformant
Tin
PT Karimun Mining
INDONESIA
CID001448
Conformant

17


Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829
Conformant
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002870
Conformant
Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Conformant
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Conformant
Tin
PT O.M. Indonesia
INDONESIA
CID002757
Conformant
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Conformant
Tin
PT Premium Tin Indonesia
INDONESIA
CID000313
Conformant
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Conformant
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Conformant
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Conformant
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Conformant
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816
Conformant
Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
Conformant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
CID001477
Conformant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
CID001482
Conformant
Tin
PT Tinindo Inter Nusa
INDONESIA
CID001490
Conformant
Tin
PT Tommy Utama
INDONESIA
CID001493
Conformant
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Conformant
Tin
Rui Da Hung
TAIWAN
CID001539
Conformant
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Conformant
Tin
Super Ligas
Brazil
CID002756
Not Enrolled
Tin
Thaisarco
THAILAND
CID001898
Conformant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
Not Enrolled
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
CID002036
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Conformant
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Conformant
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
CID000004
Conformant
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Conformant

18


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
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002645
Active
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
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
CID002536
Not Enrolled
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
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 Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002647
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Conformant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313
Not Enrolled
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Conformant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
CID002535
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Conformant
Tungsten
Kennametal Fallon
UNITED STATES
CID000966
Conformant

19


Tungsten
Kennametal Huntsville
UNITED STATES
CID000105
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Conformant
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
CID002845
Conformant
Tungsten
Niagara Refining LLC
UNITED STATES
CID002589
Conformant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
CID002543
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID002815
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Conformant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Conformant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
CID002011
Conformant
Tungsten
Wolfram Bergbau und Hütten 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

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Appendix B 2017 Countries of Origin List
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil,  Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe    



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