Document


        



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

FORM SD

SPECIALIZED DISCLOSURE REPORT


Entegris, Inc.
(Exact name of the registrant as specified in its charter)


Delaware
001-32598
41-1941551
(State or other jurisdiction of
(Commission
(IRS Employer
incorporation or organization)
File Number)
Identification No).

129 Concord Road
 
01821
Billerica, Massachusetts
 
(Zip Code)
(Address of principal executive offices)
 
 


Sue Lee
Senior Vice President, General Counsel and Secretary
(978) 436-6500
(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, 2017 to December 31, 2017.







Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of Entegris, Inc. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2017 to December 31, 2017.
A copy of Conflict Minerals Report is provided as Exhibit 1.01 and is publicly available at https://www.entegris.com/content/dam/web/about-us/corporate-overview/documents/report-conflict-minerals.pdf
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 of this report.
Section 2 - Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report.
Exhibit No.
Description
1.01







SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

ENTEGRIS, INC.
By: /s/ Gregory B. Graves
 
May 31, 2018
Name: Gregory B. Graves
 
(Date)
Title: Executive Vice President and Chief Financial Officer
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 








EXHIBIT INDEX
Exhibit No.
Description
1.01






Exhibit


Exhibit 1.01
Entegris, Inc.
Conflict Minerals Report
For the reporting period from January 1, 2017 to December 31, 2017
1. Introduction
This Conflict Minerals Report (this “Report”) of Entegris, Inc. (herein referred to as the “Company”, “we”, “us”, or “our”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period from January 1, 2017 to December 31, 2017.
The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. “Conflict Minerals” are defined as cassiterite, columbite-tantalite (coltan), wolframite, gold and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”). These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict. The “Covered Countries” for the purposes of the Rule and this Report 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.
If any 3TGs are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured and are required to be reported in the calendar year covered by the Specialized Disclosure Report on Form SD (the “Form SD”), the registrant must conduct in good faith a reasonable country of origin inquiry (“RCOI”) regarding those 3TGs that is reasonably designed to determine whether any of the 3TGs originated in the Covered Countries or are from recycled or scrap sources.
Based on its RCOI, if the registrant knows that any of its necessary 3TGs originated in the Covered Countries and are not from recycled or scrap sources, or has reason to believe that its necessary 3TGs may have originated in the Covered Countries and has reason to believe that they may not be from recycled or scrap sources, the registrant must exercise due diligence on the source and chain of custody of its 3TGs that conforms to a nationally or internationally recognized due diligence framework. If, as a result of that due diligence, the registrant is unable to determine that its 3TGs did not originate in the Covered Countries or the registrant determines that its 3TGs did come from recycled or scrap sources, the registrant must annually file a Report as an exhibit to its Form SD that includes a description of its due diligence measures on the source and chain of custody of those 3TGs.
This Report has not been audited.
Certain information contained in this Report may constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. These forward-looking statements are based on current management expectations only as of the date of the Form SD to which this Report is an Exhibit, and involve substantial risks and uncertainties that could cause actual results to differ materially from the results expressed in, or implied by, these forward-looking statements. Statements that include such words as “anticipate,” “believe,” “estimate,” “expect,” “forecast,” “may,” “will,” “should” or the





negative thereof and similar expressions as they relate to the Company or our management are intended to identify such forward-looking statements. These statements are not guarantees of future performance and involve risks, uncertainties and assumptions that are difficult to predict. These risks include but are not limited to, our ability to successfully implement the steps indicated in the “Additional Risk Mitigation Steps” section of this Report, our ability to implement such steps in the anticipated timeframe, and other factors. Except as required under the federal securities laws and the rules and regulations of the SEC, we undertake no obligation to update publicly any forward-looking statements contained herein.
1.1 Company Overview
The Company is a leading global developer, manufacturer and supplier of microcontamination control products, specialty chemicals and advanced materials handling solutions for manufacturing processes in the semiconductor and other high-technology industries. Our mission is to leverage our unique breadth of capabilities to create value for our customers by developing mission-critical solutions to maximize manufacturing yields, reduce manufacturing costs and enable higher device performance.
Semiconductors, or integrated circuits, are key components in modern electronic devices. Smartphones, cloud computing, the Internet of Things, artificial intelligence and other applications require faster, more powerful and more energy efficient semiconductors. In response to these requirements and the growing demand from these applications, semiconductor makers have been adding more capacity and semiconductor manufacturing technology has rapidly been moving to smaller dimensions, adopting new device architectures, such as FinFET transistors and 3D-NAND, and utilizing new and innovative manufacturing materials to increase transistor and bit density. As the technology node becomes increasingly complex, to enable improvements and to maximize yields, manufacturers require the effective development and application of new materials, a reliable and consistent supply of high-value materials, and contamination-free transportation, storage and delivery of these materials, seamlessly integrated into the semiconductor manufacturing process, at ever-increasing levels of purity and contaminant control. Additionally, the effective management and maintenance of the entire materials handling system, from initial production of process chemistry, to transportation and dispensing onto the wafer, has grown in importance to enhanced device yield.
The Company is uniquely positioned to rapidly respond to these challenges. We deliver advanced materials and high-purity chemistries, free from contamination, with optimized packaging and delivery solutions and in-process filtration and purification solutions that ensure high-value liquid chemistries and gases are free from contaminants before reaching the wafer. Our technology portfolio includes approximately 20,000 standard and customized products and solutions to achieve the highest levels of purity and performance that are essential to the manufacture of semiconductors, flat panel displays, light emitting diodes, or LEDs, high-purity chemicals, solar cells, gas lasers, optical and magnetic storage devices, and critical components for aerospace, glass manufacturing and biomedical applications. The majority of our products are consumed at various times throughout the manufacturing process, with demand driven in part by the level of semiconductor and other manufacturing activity.
Our business is organized and operated in three operating segments which align with the key elements of the advanced semiconductor manufacturing ecosystem. The Specialty Chemicals and Engineered Materials, or SCEM, segment provides high-performance and high-purity process chemistries, gases, and materials, and safe and efficient delivery systems to support semiconductor and other advanced manufacturing processes. The Microcontamination Control, or MC, segment offers solutions to filter and purify critical liquid chemistries and gases used in semiconductor manufacturing processes and other high-technology industries. The Advanced Materials Handling, or AMH, segment develops solutions to monitor, protect, transport, and deliver critical liquid chemistries, wafers and other substrates for a broad set of applications in the semiconductor industry and other high-technology industries. While these





segments have separate products and technical know-how, they share a global generalist sales force, common business systems and processes, technology centers, and strategic and technology roadmaps. We leverage our expertise from these three segments to create new and increasingly integrated solutions for our customers.
3TGs are used in the Company’s business units which utilize the following components: sensors, monitors, valves, control modules, displays, pressure transducers, flow controllers, printed circuit boards, printed wire board, and cables. Tin (primarily in tin-based solder) and gold (in electronic components) are the predominant materials in use, while tantalum is reported on a minimal level, and tungsten is mainly found in tungsten impregnated graphite.
In February 2014, the Company adopted a policy relating to Conflict Minerals (the “Conflict Minerals Policy”) incorporating the standards set forth in the then-current version of the Organization for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Materials from Conflict-Affected and High Risk Areas and the related Supplements for 3TG, second edition (the “OECD Guidance”). Our Conflict Minerals Policy can be found on our website at https://www.entegris.com/content/dam/web/about-us/corporate-overview/documents/policies/policy-conflict-minerals.pdf
1.2 Supply Chain
As a developer, manufacturer and supplier of products and materials to semiconductor and other high-technology industries, the Company is several levels removed from the mining and refining of 3TGs.
The Company does not make purchases of raw ore or unrefined 3TGs and makes no direct purchases in the Covered Countries. As a result, we rely on our suppliers to provide information on the origin of 3TGs that may be contained in components and materials supplied to us.
In the course of negotiating new supply agreements or renewals of existing supply agreements, members of our procurement organization provide the requirements of the Rule and Conflict Minerals disclosure process to suppliers to increase awareness and educate our suppliers on the Rule’s requirement for cooperation and reporting from sub-suppliers.
We are committed to compliance with the Rule and working toward avoiding the use of 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. If we become aware of a supplier whose supply chain includes minerals that are not conflict free, we will take appropriates steps to address the situation in a timely manner, including reassessment of the supplier relationship. We expect our suppliers to take similar measures with their sub-suppliers.
2. Reasonable Country of Origin Inquiry Program
The Company conducted a RCOI regarding the 3TGs in materials, components and finished goods supplied to the Company, including the steps detailed below.
The conflict minerals team risk-stratified the Company’s list of suppliers that supply products potentially containing 3TGs to identify the suppliers that constitute the top 80% of total spend with suppliers of in-scope products and focused direct Company engagement efforts toward suppliers within this group. The Company identified 979 suppliers that supply products potentially containing 3TGs and engaged with such suppliers to collect information regarding the presence and sourcing of 3TGs in its products.
The Company, with the assistance of our third-party compliance partner Assent Compliance Inc. (“Assent”), contacted all our suppliers with an automated email describing the compliance requirements and requesting supply chain information be submitted pursuant to version 5.01 or higher of the





Responsible Minerals Initiative’s Conflict Minerals Reporting Template (“CMRT”). Additionally, if a response was not received from the initial contact, follow-up emails were sent to suppliers offering assistance and further information about the requirements of the Rule and its requirements. If, after these outreach efforts, a supplier still did not respond to the survey, the Company’s relevant supplier relationship managers were instructed to contact those suppliers directly for a response. As of May 24, 2018, the Company had an overall response rate from surveyed suppliers of 69%.
The Company utilized a software platform which validated the information submitted on CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that, in either event, data is retained. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. As of May 24, 2018, we still had 7 invalid supplier submissions that were not yet corrected.
Based on the responses received from the Company’s RCOI, a list was compiled of 321 verified unique smelters and refiners (the “unique smelter list”), including information regarding associated countries of origin.
2.1 Reasonable Country of Origin Inquiry Results
On the basis of the responses to our RCOI, the Company is unable to determine that 3TGs necessary to the functionality or production of our products did not originate in the Covered Countries or were not exclusively from recycled or scrap sources. Accordingly, the Company undertook the measures described below to assess the due diligence practices of the smelters and refiners listed on its unique smelter list that were known or reasonably believed to have sourced from the DRC or that had unknown sourcing.
3. Due Diligence
3.1 Design of Due Diligence
We established a Conflict Minerals compliance program that is designed to conform, in all material respects, to the framework in the OECD Guidance.
3.1.1 Establish Strong Company Management System Internal Team
Internal Team
The Company has established a management system with respect to the Rule and the obligations thereof. Our management system includes a cross-functional team, the conflict minerals team, which is sponsored by the Chief Financial Officer. Members of the conflict minerals team include representatives from Environmental, Health and Safety (“EHS”), Procurement, Product Stewardship, Finance, Law and Internal Audit departments. The conflict minerals team is responsible for implementing our conflict minerals compliance strategy and is led by the Global Director of EHS who acts as the conflict minerals coordinator. Senior management is briefed about the results of the conflict minerals team’s progress and due diligence efforts on a regular basis.
Conflict Mineral Policy
As described above, in February 2014, the Company adopted the Conflict Minerals Policy incorporating the standards set forth in the then-current version of the OECD Guidance. Our Conflict Minerals Policy can be found on our website at https://www.entegris.com/content/dam/web/about-us/corporate-overview/documents/policies/policy-conflict-minerals.pdf
Control Systems





While a portion of our direct suppliers are also Exchange Act registered companies which are subject to and knowledgeable about the Rule, we also have many other suppliers and distributors that are not registered companies that require additional training to understand the requirements of the Rule.
We do not typically have direct relationships with 3TG smelters and refiners. However, through associations like National Association of Environmental Managers (“NAEM”), Semiconductor Equipment and Materials International (“SEMI”) and Responsible Business Alliance (“RBI”), we attempt to mitigate the risk of using 3TGs that benefit armed groups in our supply chain by actively monitoring best practices used by other manufacturers in the semiconductor and high technology sectors and participating in a number of industry-wide initiatives. Additionally, in 2017, the Company engaged Assent to further implement Conflict Mineral surveys, outreach, and tracking best practices.
Internal controls include our on-going initiative of integrating Conflict Minerals related provisions in our supply agreements that require disclosure of 3TGs and Conflict Minerals.
Supplier Engagement
In accordance with the OECD requirement to strengthen engagement with suppliers, we have made reasonable inquiries to direct suppliers to obtain 3TG data, provided them with requirements of our Conflict Minerals Policy and informed them as to where they may find additional information on the requirements relating to conflict minerals disclosure.
The Company has provided education and training relating to the Rule and to Conflict Minerals to all in-scope suppliers by providing such suppliers with access to Assent’s Learning Management System training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
Additionally, as identified earlier, our procurement organization continues to integrate Conflict Minerals related requirements language into new supply agreements or renewals of existing supply agreements during the course of negotiations. Accordingly, we are continuing our attempts to identify risks before entering into such agreements, so that steps can be taken to confirm suppliers have implemented processes to identify the origin of 3TGs.
Maintain Records
As part of our EHS Management System, we have developed a record retention requirement for information relating to the management of our Conflict Minerals compliance process. All relevant records will be retained for a period of 5 years.
Grievance Mechanism
Our Code of Business Ethics, which is available on our website at http://investor.entegris.com/governance.cfm, provides details about our grievance mechanisms, such as the details of our dedicated mailbox and hotline, whereby violations of our policies, including our Conflict Minerals Policy, may be reported.
In addition, the Company has established a monitored email account, with the address of supplier.whistleblowing@Entegris.com, and has notified its suppliers of such email address, so that suppliers may provide information regarding Conflict Minerals compliance issues.
3.1.2 Identify and Assess Risk in the 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. We have





determined that seeking information about 3TG smelters and refiners 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 a reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the lists of sourced metals certified by third party sources as “Known” and “Conflict Free”.
We have identified 979 direct 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 Exchange Act registrants and subject to the Rule or are suppliers to other Exchange Act registrants that are subject to the Rule.
In accordance with OECD Guidelines, it is important to identify and assess risks associated with conflict minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the 2017 calendar year.

In order to assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.

As of May 24, 2018, we have validated 321 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primarily supplier-level CMRTs, we cannot definitely determine their connection to the Covered Products.

Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Three factors are used to determine the level of risk that each smelter poses to the supply chain:
Geographic proximity to the DRC and covered countries;
Responsible Minerals Assurance Process (RMAP) audit status;
Credible evidence of unethical or conflict sourcing.

Based on this criteria the following facilities have been identified with red-flag risks in their supply chain:
Tony Goetz NV - CID002587
African Gold Refinery Limited (AGR) - CID003185
Kaloti Precious Metals - CID002563
Universal Precious Metals Refining Zambia - CID002854
Sudan Gold Refinery - CID002567
As part of our risk management plan under the OECD Guidance, when these facilities were reported on a





CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our 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 red flag smelters from their supply chain.

As per the OECD 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 red flags from the supply chain.  
Suppliers are also evaluated on their Conflict Minerals program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of such Conflict Minerals program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s Conflict Minerals program are:
Does the supplier have a Conflict Minerals policy in place that prohibits the procurement of 3TGs from sources that directly or indirectly finance or benefit armed groups in the Covered Countries?
Has the supplier implemented due diligence measures to implement such policy?
Does the supplier verify due diligence information received from its suppliers?
Does the supplier’s verification process include corrective action management?
Based on a supplier’s answer to the above criteria, the supplier’s Conflict Minerals program will be ranked as either strong or weak.
3.1.3 Design and Implement a Strategy to Respond to Risks
As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific role in the supply chain. When a high-risk smelting facility is reported on a CMRT by a supplier surveyed, risk mitigation will include:
Requesting the supplier to submit product specific CMRT to better identify the connection to products that they supply to Entegris;
Guiding suppliers to the Assent University learning platform to access educational materials on mitigating the risk of smelters or refiners on the supply chain; and
If necessary, requesting all of our suppliers whom we have reason to believe are supplying us with 3TGs from sources that may directly or indirectly finance or benefit armed groups in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. To date, we have found no instances where it was necessary to terminate a contract or find a replacement material or supplier for issues relating to Conflict Minerals.
3.1.4 Third-Party Audit of Supply Chain Due Diligence
As a downstream purchaser of 3TGs, our due diligence process is based on the necessity of relying on data obtained from our direct suppliers. We also rely on information collected and provided by other external audit programs. As such, we have not conducted third-party audits of any smelters or refiners.
3.1.5 Report on Supply Chain Due Diligence
This Conflict Minerals Report is on file with the SEC and is publicly available on our web site at https://www.entegris.com/content/dam/web/about-us/corporate-overview/documents/report-conflict-minerals.pdf





3.2 Due Diligence Results
The large majority of the responses we received from the supplier survey provided data at a company or divisional level or were unable to specify the smelters or refiners used for components supplied to us. We are therefore unable to determine whether the 3TGs reported by the suppliers were contained in components or parts supplied to us. Therefore, we were unable to validate that any of these smelters or refiners are actually in our supply chain.
The current efforts focus on gathering smelter information via 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 smelters as well as the tracing of 3TGs to their location of origin. Seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of 3TGs in our supply chain.
Certain of the responses provided by suppliers to the CMRT did include the names of facilities listed by the suppliers as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Assent Compliance, our third-party compliance partner, compared these facilities listed in the responses to the list of smelters maintained by the RMI and, if a supplier indicated that the facility was certified as “Conflict-Free”, Assent Compliance confirmed that the facility was, in fact, listed as such by RMI.
As of May 24, 2018, we have validated 321 smelters or refiners and are working to validate the additional smelter and refiner entries from the submitted CMRTs. The table set forth on Schedule 1 to this CMR lists the valid smelters identified by suppliers we surveyed. Not all of these facilities have necessarily processed 3TGs contained in our products covered by this Conflict Minerals Report. This is because our suppliers generally provided information via the CMRT at the company or divisional level, and generally did not limit their CMRT responses to information relating to 3TGs in specific products supplied to us.
Based on the information provided by our suppliers in their CMRT’s, we are aware that there are 257 smelters that are certified “Conflict-Free”, and 11 smelters are active in the RMAP third-party audit process. Many suppliers are still unable to provide the smelters or refiners used for materials supplied to us. Furthermore, many of the responses provided at the company or division level indicated an “unknown” status in terms of determining the origin of 3TGs.
Based on our due diligence, the products that we manufacture or contract to manufacture which contain 3TGs are classified as “DRC conflict undeterminable” in 2017 as information on sources remains incomplete at this time.
4. Additional Risk Mitigation Steps
In keeping with our commitment to continual improvement, our Product Stewardship Team performed a review of our internal program in the first quarter of 2018. Observations and recommendations have been summarized and integrated the Conflict Minerals Action Plan for 2018.
The Company intends to take the following steps to improve the RCOI and due diligence conducted to further identify and mitigate the risk that our products contain Conflict Minerals from sources that support conflict in the Covered Countries:
a)
Further collaboration with our third-party compliance partner, Assent, to raise supplier survey response rates, as well as implement best practice supplier education and engagement initiatives.
b)
Increase the response rate from our suppliers to 75%.
c)
Include Conflict Minerals flow-down clauses in new or renewed supplier contracts.





d)
Engage, as needed, with suppliers and direct them to training resources to increase knowledge, increase response rates, and improve the reliability of responses.
e)
Continue to work with the company supply chain managers to increase their understanding of the program and the need for continuous improvement.
f)
If applicable, upon learning of a supplier found to be supplying 3TGs from sources that support conflict in the Covered Countries, establish an alternative source that does not support such conflict.
g)
Continue to monitor the OECD and relevant trade associations to incorporate best practices to improve our processes and leverage our supply chain in accordance with OECD Guidance.
h)
Investigate and act on recommendations from our internal review process.







Schedule 1
Metal
 Standard Smelter Name
Smelter ID
RMI Audit Status
Gold
Abington Reldan Metals, LLC
CID002708
Not Enrolled
Gold
Advanced Chemical Company
CID000015
Conformant
Gold
African Gold Refinery
CID003185
Not Enrolled
Gold
Aida Chemical Industries Co., Ltd.
CID000019
Conformant
Gold
Al Etihad Gold LLC
CID002560
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
Conformant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
Conformant
Gold
Argor-Heraeus S.A.
CID000077
Conformant
Gold
Asahi Pretec Corp.
CID000082
Conformant
Gold
Asahi Refining Canada Ltd.
CID000924
Conformant
Gold
Asahi Refining USA Inc.
CID000920
Conformant
Gold
Asaka Riken Co., Ltd.
CID000090
Conformant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
Not Enrolled
Gold
AU Traders and Refiners
CID002850
Conformant
Gold
Aurubis AG
CID000113
Conformant
Gold
Bangalore Refinery
CID002863
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
Conformant
Gold
Boliden AB
CID000157
Conformant
Gold
C. Hafner GmbH + Co. KG
CID000176
Conformant
Gold
Caridad
CID000180
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CID000185
Conformant
Gold
Cendres + Métaux S.A.
CID000189
Conformant
Gold
Chimet S.p.A.
CID000233
Conformant
Gold
Chugai Mining
CID000264
Not Enrolled
Gold
Daejin Indus Co., Ltd.
CID000328
Conformant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CID000343
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
CID002867
Not Enrolled
Gold
DODUCO Contacts and Refining GmbH
CID000362
Conformant
Gold
Dowa
CID000401
Conformant
Gold
DS PRETECH Co., Ltd.
CID003195
Active
Gold
DSC (Do Sung Corporation)
CID000359
Conformant
Gold
Eco-System Recycling Co., Ltd.
CID000425
Conformant
Gold
Elemetal Refining, LLC
CID001322
Not Enrolled
Gold
Emirates Gold DMCC
CID002561
Conformant
Gold
Fidelity Printers and Refiners Ltd.
CID002515
Not Enrolled
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
CID002852
Not Enrolled
Gold
Geib Refining Corporation
CID002459
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CID002243
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CID001909
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CID002312
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CID000651
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
Not Enrolled





Gold
HeeSung
CID000689
Conformant
Gold
Heimerle + Meule GmbH
CID000694
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CID000707
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
Conformant
Gold
Hunan Chenzhou Mining Co., Ltd.
CID000767
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
CID000778
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
Conformant
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
Conformant
Gold
Istanbul Gold Refinery
CID000814
Conformant
Gold
Italpreziosi
CID002765
Conformant
Gold
Japan Mint
CID000823
Conformant
Gold
Jiangxi Copper Co., Ltd.
CID000855
Conformant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
Conformant
Gold
JSC Uralelectromed
CID000929
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
CID000937
Conformant
Gold
Kaloti Precious Metals
CID002563
Not Enrolled
Gold
Kazakhmys Smelting LLC
CID000956
Not Enrolled
Gold
Kazzinc
CID000957
Conformant
Gold
Kennecott Utah Copper LLC
CID000969
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
CID002511
Active
Gold
Kojima Chemicals Co., Ltd.
CID000981
Conformant
Gold
Korea Zinc Co., Ltd.
CID002605
Conformant
Gold
Kyrgyzaltyn JSC
CID001029
Conformant
Gold
Kyshtym Copper-Electrolytic Plant ZAO
CID002865
Not Enrolled
Gold
L'azurde Company For Jewelry
CID001032
Not Enrolled
Gold
Lingbao Gold Co., Ltd.
CID001056
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
Not Enrolled
Gold
L'Orfebre S.A.
CID002762
Active
Gold
LS-NIKKO Copper Inc.
CID001078
Conformant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
Not Enrolled
Gold
Marsam Metals
CID002606
Conformant
Gold
Materion
CID001113
Conformant
Gold
Matsuda Sangyo Co., Ltd.
CID001119
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
CID001149
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
CID001147
Conformant
Gold
Metalor Technologies S.A.
CID001153
Conformant
Gold
Metalor USA Refining Corporation
CID001157
Conformant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
CID001161
Conformant
Gold
Mitsubishi Materials Corporation
CID001188
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
CID002509
Conformant
Gold
Modeltech Sdn Bhd
CID002857
Active
Gold
Morris and Watson
CID002282
Not Enrolled
Gold
Morris and Watson Gold Coast
CID002866
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
CID001204
Conformant





Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.
CID001220
Conformant
Gold
Navoi Mining and Metallurgical Combinat
CID001236
Not Enrolled
Gold
NH Recytech Company
CID003189
Active
Gold
Nihon Material Co., Ltd.
CID001259
Conformant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
Conformant
Gold
Ohura Precious Metal Industry Co., Ltd.
CID001325
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326
Conformant
Gold
OJSC Novosibirsk Refinery
CID000493
Conformant
Gold
PAMP S.A.
CID001352
Conformant
Gold
Pease & Curren
CID002872
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CID001362
Not Enrolled
Gold
Planta Recuperadora de Metales SpA
CID002919
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
Conformant
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
Conformant
Gold
PX Précinox S.A.
CID001498
Conformant
Gold
Rand Refinery (Pty) Ltd.
CID001512
Conformant
Gold
Refinery of Seemine Gold Co., Ltd.
CID000522
Not Enrolled
Gold
Remondis Argentia B.V.
CID002582
Active
Gold
Republic Metals Corporation
CID002510
Conformant
Gold
Royal Canadian Mint
CID001534
Conformant
Gold
SAAMP
CID002761
Conformant
Gold
Sabin Metal Corp.
CID001546
Not Enrolled
Gold
Safimet S.p.A
CID002973
Conformant
Gold
SAFINA A.S.
CID002290
Active
Gold
Sai Refinery
CID002853
Not Enrolled
Gold
Samduck Precious Metals
CID001555
Conformant
Gold
SAMWON Metals Corp.
CID001562
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
CID002777
Conformant
Gold
Schone Edelmetaal B.V.
CID001573
Conformant
Gold
SEMPSA Joyería Platería S.A.
CID001585
Conformant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
Not Enrolled
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
Conformant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
Conformant
Gold
Singway Technology Co., Ltd.
CID002516
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
Conformant
Gold
Solar Applied Materials Technology Corp.
CID001761
Conformant
Gold
State Research Institute Center for Physical Sciences and Technology
CID003153
Not Enrolled
Gold
Sudan Gold Refinery
CID002567
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
CID001798
Conformant
Gold
SungEel HiTech
CID002918
Conformant
Gold
T.C.A S.p.A
CID002580
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
Conformant
Gold
Tokuriki Honten Co., Ltd.
CID001938
Conformant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CID001947
Not Enrolled





Gold
Tony Goetz NV
CID002587
Not Enrolled
Gold
TOO Tau-Ken-Altyn
CID002615
Not Enrolled
Gold
Torecom
CID001955
Conformant
Gold
Umicore Brasil Ltda.
CID001977
Conformant
Gold
Umicore Precious Metals Thailand
CID002314
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
CID001980
Conformant
Gold
United Precious Metal Refining, Inc.
CID001993
Conformant
Gold
Universal Precious Metals Refining Zambia
CID002854
Not Enrolled
Gold
Valcambi S.A.
CID002003
Conformant
Gold
Western Australian Mint trading as The Perth Mint
CID002030
Conformant
Gold
WIELAND Edelmetalle GmbH
CID002778
Conformant
Gold
Yamamoto Precious Metal Co., Ltd.
CID002100
Conformant
Gold
Yokohama Metal Co., Ltd.
CID002129
Conformant
Gold
Yunnan Copper Industry Co., Ltd.
CID000197
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
Conformant
Tantalum
Asaka Riken Co., Ltd.
CID000092
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
Conformant
Tantalum
D Block Metals, LLC
CID002504
Conformant
Tantalum
Duoluoshan
CID000410
Not Enrolled
Tantalum
Exotech Inc.
CID000456
Conformant
Tantalum
F&X Electro-Materials Ltd.
CID000460
Conformant
Tantalum
FIR Metals & Resource Ltd.
CID002505
Conformant
Tantalum
Global Advanced Metals Aizu
CID002558
Conformant
Tantalum
Global Advanced Metals Boyertown
CID002557
Conformant
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CID000291
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
Conformant
Tantalum
H.C. Starck Co., Ltd.
CID002544
Conformant
Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
Conformant
Tantalum
H.C. Starck Inc.
CID002548
Conformant
Tantalum
H.C. Starck Ltd.
CID002549
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
CID002550
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
CID002545
Conformant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
CID002842
Conformant
Tantalum
Jiujiang Janny New Material Co., Ltd.
CID003191
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CID000917
Conformant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
Conformant
Tantalum
KEMET Blue Metals
CID002539
Conformant
Tantalum
KEMET Blue Powder
CID002568
Conformant
Tantalum
King-Tan Tantalum Industry Ltd.
CID000973
Conformant
Tantalum
LSM Brasil S.A.
CID001076
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
CID001163
Conformant
Tantalum
Mineracao Taboca S.A.
CID001175
Conformant
Tantalum
Mitsui Mining and Smelting Co., Ltd.
CID001192
Conformant





Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
Conformant
Tantalum
NPM Silmet AS
CID001200
Conformant
Tantalum
Power Resources Ltd.
CID002847
Conformant
Tantalum
QuantumClean
CID001508
Conformant
Tantalum
Resind Industria e Comercio Ltda.
CID002707
Conformant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CID001522
Conformant
Tantalum
Solikamsk Magnesium Works OAO
CID001769
Conformant
Tantalum
Taki Chemicals
CID001869
Conformant
Tantalum
Telex Metals
CID001891
Conformant
Tantalum
Ulba Metallurgical Plant JSC
CID001969
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CID002508
Conformant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CID002307
Conformant
Tin
Alpha
CID000292
Conformant
Tin
An Vinh Joint Stock Mineral Processing Company
CID002703
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CID003190
Active
Tin
China Tin Group Co., Ltd.
CID001070
Conformant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CID000278
Not Enrolled
Tin
CV Ayi Jaya
CID002570
Conformant
Tin
CV Dua Sekawan
CID002592
Conformant
Tin
CV Gita Pesona
CID000306
Conformant
Tin
CV Tiga Sekawan
CID002593
Conformant
Tin
CV United Smelting
CID000315
Conformant
Tin
CV Venus Inti Perkasa
CID002455
Conformant
Tin
Dowa
CID000402
Conformant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
CID002572
Not Enrolled
Tin
EM Vinto
CID000438
Conformant
Tin
Estanho de Rondônia S.A.
CID000448
Not Enrolled
Tin
Fenix Metals
CID000468
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CID002848
Conformant
Tin
Gejiu Jinye Mineral Company
CID002859
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
CID000942
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
Conformant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
Not Enrolled
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CID003116
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CID002849
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CID002844
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CID000760
Conformant
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CID000244
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CID001231
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
CID002468
Conformant
Tin
Malaysia Smelting Corporation (MSC)
CID001105
Conformant
Tin
Melt Metais e Ligas S.A.
CID002500
Conformant
Tin
Metallic Resources, Inc.
CID001142
Conformant
Tin
Metallo Belgium N.V.
CID002773
Conformant





Tin
Metallo Spain S.L.U.
CID002774
Conformant
Tin
Mineracao Taboca S.A.
CID001173
Conformant
Tin
Minsur
CID001182
Conformant
Tin
Mitsubishi Materials Corporation
CID001191
Conformant
Tin
Modeltech Sdn Bhd
CID002858
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
Conformant
Tin
Operaciones Metalurgical S.A.
CID001337
Conformant
Tin
Pongpipat Company Limited
CID003208
Not Enrolled
Tin
PT Aries Kencana Sejahtera
CID000309
Conformant
Tin
PT Artha Cipta Langgeng
CID001399
Conformant
Tin
PT ATD Makmur Mandiri Jaya
CID002503
Conformant
Tin
PT Babel Inti Perkasa
CID001402
Conformant
Tin
PT Bangka Prima Tin
CID002776
Conformant
Tin
PT Bangka Serumpun
CID003205
Conformant
Tin
PT Bangka Tin Industry
CID001419
Conformant
Tin
PT Belitung Industri Sejahtera
CID001421
Conformant
Tin
PT Bukit Timah
CID001428
Conformant
Tin
PT DS Jaya Abadi
CID001434
Conformant
Tin
PT Eunindo Usaha Mandiri
CID001438
Conformant
Tin
PT Inti Stania Prima
CID002530
Conformant
Tin
PT Karimun Mining
CID001448
Conformant
Tin
PT Kijang Jaya Mandiri
CID002829
Conformant
Tin
PT Lautan Harmonis Sejahtera
CID002870
Conformant
Tin
PT Menara Cipta Mulia
CID002835
Conformant
Tin
PT Mitra Stania Prima
CID001453
Conformant
Tin
PT O.M. Indonesia
CID002757
Conformant
Tin
PT Panca Mega Persada
CID001457
Conformant
Tin
PT Premium Tin Indonesia
CID000313
Conformant
Tin
PT Prima Timah Utama
CID001458
Conformant
Tin
PT Refined Bangka Tin
CID001460
Conformant
Tin
PT Sariwiguna Binasentosa
CID001463
Conformant
Tin
PT Stanindo Inti Perkasa
CID001468
Conformant
Tin
PT Sukses Inti Makmur
CID002816
Conformant
Tin
PT Sumber Jaya Indah
CID001471
Conformant
Tin
PT Timah (Persero) Tbk Kundur
CID001477
Conformant
Tin
PT Timah (Persero) Tbk Mentok
CID001482
Conformant
Tin
PT Tinindo Inter Nusa
CID001490
Conformant
Tin
PT Tommy Utama
CID001493
Conformant
Tin
Resind Industria e Comercio Ltda.
CID002706
Conformant
Tin
Rui Da Hung
CID001539
Conformant
Tin
Soft Metais Ltda.
CID001758
Conformant
Tin
Super Ligas
CID002756
Not Enrolled
Tin
Thaisarco
CID001898
Conformant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
CID002574
Not Enrolled





Tin
White Solder Metalurgia e Mineração Ltda.
CID002036
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
Conformant
Tin
Yunnan Tin Company Limited
CID002180
Conformant
Tungsten
A.L.M.T. TUNGSTEN Corp.
CID000004
Conformant
Tungsten
ACL Metais Eireli
CID002833
Conformant
Tungsten
Asia Tungsten Products Vietnam Ltd.
CID002502
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CID002645
Active
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
Conformant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CID002536
Not Enrolled
Tungsten
Global Tungsten & Powders Corp.
CID000568
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
Conformant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
CID002542
Conformant
Tungsten
H.C. Starck Tungsten GmbH
CID002541
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CID000766
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
Conformant
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CID003182
Conformant
Tungsten
Hydrometallurg, JSC
CID002649
Conformant
Tungsten
Japan New Metals Co., Ltd.
CID000825
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
Conformant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CID002647
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
Conformant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
Not Enrolled
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
Conformant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CID002535
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
Conformant
Tungsten
Kennametal Fallon
CID000966
Conformant
Tungsten
Kennametal Huntsville
CID000105
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
Conformant
Tungsten
Moliren Ltd
CID002845
Conformant
Tungsten
Niagara Refining LLC
CID002589
Conformant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
CID002827
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CID002815
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
Conformant
Tungsten
Unecha Refractory metals plant
CID002724
Conformant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
CID002011
Conformant
Tungsten
Wolfram Bergbau und Hütten AG
CID002044
Conformant
Tungsten
Woltech Korea Co., Ltd.
CID002843
Conformant





Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
CID002082
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CID002830
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
Conformant






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