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)


Delaware001-3259841-1941551
(State or other jurisdiction of (Commission (IRS Employer
incorporation or organization) File Number) Identification No).

129 Concord Road01821
Billerica, Massachusetts(Zip Code)
(Address of principal executive offices)


Gregory B. Graves
Executive Vice President, Chief Financial Officer and Treasurer
(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, 2020 to December 31, 2020.





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, 2020 to December 31, 2020.
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/ Joseph Colella
May 28, 2021
Name: Joseph Colella(Date)
Title: Senior Vice President, General Counsel and Secretary






Document
Exhibit 1.01

Entegris, Inc.
Conflict Minerals Report
For the reporting period from January 1, 2020 to December 31, 2020
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, 2020 to December 31, 2020.
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. 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 its management are intended to identify such forward-looking statements. These statements are not a guarantee 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 supplier of advanced materials and process solutions for the semiconductor and other high-technology industries. Its mission is to help its customers improve their productivity, performance, and technology by providing solutions for the most advanced manufacturing environments. The Company leverages its unique breadth of capabilities to create mission-critical micro contamination control products, specialty chemicals and advanced materials handling solutions that maximize manufacturing yields, reduce manufacturing costs, and enable higher device performance for its customers.
Semiconductors, or integrated circuits, are key components in the electronic devices that have changed the way we live, communicate and work. Products and applications like smartphones, 5G wireless technology, cloud computing, the Internet of Things, machine learning and artificial intelligence, autonomous vehicles and virtual reality will increasingly require faster, more powerful and more energy efficient semiconductors and the Company believes will ultimately drive global chip demand.

To meet the requirements for improved chip performance and density, semiconductor manufacturing processes have rapidly become increasingly complex by moving to smaller geometries, adopting new device architectures, and utilizing new and innovative materials. These complex processes require new materials of ever-increasing purity, quality, and stability to improve and maximize yields. The Company expects to benefit from these two intersecting themes of the growing importance of process materials and materials purity, and the impact they have on semiconductor performance, cost, and reliability. The Company believes these trends are leading to increasing materials content per wafer and filtration opportunity per wafer, which are growth opportunities for the Company.

The Company’s customized materials solutions enable the highest levels of performance essential to the manufacture of semiconductors. As its customers introduce more complex architectures and search for new materials with better electrical and structural properties to improve the performance of their devices, they rely on Entegris as a trusted partner to address these challenges. The Company understands these challenges and has solutions to address them, such as its advanced deposition materials, implant gases, formulated cleaning chemistries and selective etch chemistries. The Company’s customers also require greater end-to-end materials purity and integrity in their manufacturing processes that, when combined with smaller dimensions and more complex architectures, can be challenging to achieve. To enable the use of new metals and the further miniaturization of chips, and to maximize yield and increase long-term device reliability, the Company provides products such as its advanced liquid and gas filtration and purification products that help to selectively remove new classes of contaminants throughout the semiconductor supply chain. In addition, to ensure purity levels are maintained across the entire supply chain, from bulk manufacturing, to transportation to and delivery through a fab, to application onto the wafer, the Company provides high-purity packaging and materials handling products.

The Company’s 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 Micro contamination 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, life sciences and other high-technology industries. While these segments have separate products and technical know-how, they share common business systems and processes, technology centers and strategic and technology roadmaps. With the technology, capabilities, and complementary product portfolios from these three segments, we believe we are uniquely positioned to collaborate across divisions to create new, co-optimized and increasingly integrated solutions for the Company’s customers. For example, the SCEM segment offers a highly selective nitride etch chemistry, the MC segment provides a liquid filter that is specifically matched to that formulation and the AMH segment ensures the integrity of the product as it is moved to and through the fab environment.
3TGs are used in the Company’s business units which utilize the following components: solid deposition chemistries, sensors, monitors, valves, control modules, displays, pressure transducers, flow controllers, printed circuit boards, printed wire boards, 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 and a few specialty chemicals.
In February 2014, the Company adopted a policy relating to Conflict Minerals (the “Conflict Minerals Policy”). This Conflicts Mineral Policy incorporates the standards set forth in the Organization for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Materials from Conflict-Affected and High-Risk Areas, third edition (the “OECD Guidance”). Our Conflict Minerals Policy can be found on our Corporate Social Responsibility website at https://www.entegris.com/en/home/about-us/corporate-social-responsibility/policies.html.
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.
While 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. With the assistance of our third-party compliance partner Assent Compliance Inc. (“Assent”), we contacted all of our suppliers with an automated email describing the compliance requirements and requesting supply chain information be submitted pursuant to version 6.01 or higher of the Responsible Minerals Initiative 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 21, 2021, the Company had an overall response rate from surveyed suppliers of approximately 79%.



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 regarding invalid forms and were encouraged to resubmit a valid form. As of May 21, 2021, we had 64 invalid supplier submissions that were not yet corrected.
Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the RMI and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TGs. Our suppliers identified a total of 333 smelters and refiners that appear on the lists maintained by RMI. Of these, 237 are validated as conflict free by RMI or a cross-recognized initiative, and, based on information provided by RMI, a further 24 have agreed to undergo or are currently undergoing a third-party audit. Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers processed the 3TGs contained in our products.
2.1. Reasonable Country of Origin Inquiry Results
Based on 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
We established a Conflict Minerals compliance program that is designed to conform, in all material respects, to the framework in the OECD Guidance and the related supplements for gold, tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:

1)Establishing strong company management systems regarding Conflict Minerals;
2)Identifying and assessing risks in our supply chain;
3)Designing and implementing a strategy to respond to identified risks in our supply chain;
4)Utilizing independent third-party audits of supply chain diligence; and
5)Publicly reporting on our supply chain due diligence.

We are a downstream supplier, many steps removed from the mining of 3TGs. Many suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, the Company does not purchase raw ore or unrefined Conflict Minerals or make purchases from the Covered Countries. The origin of the Conflict Minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other Conflict Mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.

The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. The OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the Conflict Minerals contained in the components and materials supplied to us.



3.1. Establish Strong Company Management System
3.1.1. Management System 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, with representatives from Environmental, Health and Safety (“EHS”), Procurement, Product Stewardship, Legal and Internal Audit departments. The Product Stewardship team is responsible for implementing our Conflict Minerals compliance strategy and is led by the Vice President of EHS. Senior management is briefed about the results of the Product Stewardship team’s progress and due diligence efforts on a regular basis.
The Company also uses Assent to assist us with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that we will undertake with suppliers regarding Conflict Minerals.
3.1.2. 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 Corporate Social Responsibility website at https://www.entegris.com/en/home/about-us/corporate-social-responsibility/policies.html.
3.1.3. Control Systems
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. In addition, through membership with industry associations like National Association of Environmental Managers (“NAEM”), Semiconductor Equipment and Materials International (“SEMI”) and Responsible Business Alliance (“RBA”), the Company actively monitors best practices used by other manufacturers in the semiconductor and high technology sectors and participates in industry-wide initiatives to control the use of Conflict Minerals. 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. In 2020, the Company continued the engagement with Assent to further implement Conflict Mineral surveys, outreach, and tracking best practices.
3.1.4. 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 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.
3.1.5. 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.



3.1.6. Grievance Mechanism
Our Business Code of Conduct, which is available on our website at https://www.entegris.com/en/home/about-us/corporate-social-responsibility/policies.html 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. Entegris has notified its suppliers of its confidential grievance reporting process, so that suppliers may provide information regarding Conflict Minerals compliance issues.
3.2. 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 1605 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 2020 calendar year.
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 21, 2021, we have validated 333 smelters or refiners and are working to validate the additional smelter/refinery 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. Five factors are used to determine the level of risk that each smelter poses to the supply chain:
1.Geographic proximity to the DRC and covered countries;
2.Known mineral source country of origin;
3.Responsible Minerals Assurance Process (RMAP) audit status;
4.Credible evidence of unethical or conflict sourcing; and
5.Peer Assessments conducted by credible third-party sources.




Based on these 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
Sudan Gold Refinery - CID002567
Fidelity Printers – CID002515
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 process, submissions that include any of the above facilities immediately produce a response 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 action to remove 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 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?

When suppliers meet or exceed those criteria (Yes to at least A, E, G, H on the CMRT 6.01), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
3.3. Design and Implement a Strategy to Respond to Identified Risks
As per the OECD 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 the Company;
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.

3.4. 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.



Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. The Company is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance.
3.5. 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/en/home/about-us/corporate-social-responsibility/policies.html.
4. Due Diligence Results
Attached as Appendix A is a list of all the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Since many of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed on Appendix A processed the 3TGs contained in our products. Therefore, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that processed the Conflict Minerals contained in our products. 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 “RMAP Conformant”, Assent Compliance confirmed that the facility was, in fact, listed as such by RMI.
As of May 21, 2021, we have validated 333 smelters or refiners and are working to validate the additional smelter and refinery entries from the submitted CMRTs. The table set forth on Appendix A 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 237 smelters that are certified “Conflict-Free”, and 24 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 2020 as information on sources remains incomplete at this time.
5. 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 2020. Observations and recommendations have been summarized and integrated in the Conflict Minerals Action Plan for the remainder of the year.



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:
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.
Increase the response rate from our suppliers to 85%.
Engage, as needed, with suppliers and direct them to training resources to increase knowledge, increase response rates, and improve the reliability of responses.
Continue to work with the company supply chain managers to increase their understanding of the program and the need for continuous improvement.
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.
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.
Investigate and act on recommendations from our internal review process.




Appendix A
MetalStandard Smelter NameSmelter Facility LocationSmelter IDRMI Audit Status
Gold8853 S.p.A.ITALYCID002763Conformant
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICACID002708Non-Conformant
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICACID000015Conformant
GoldAfrican Gold RefineryUGANDACID003185Outreach Required
GoldAida Chemical Industries Co., Ltd.JAPANCID000019Conformant
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESCID002560Conformant
GoldAlexy MetalsUNITED STATES OF AMERICACID003500Active
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYCID000035Conformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANCID000041Conformant
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILCID000058Conformant
GoldArgor-Heraeus S.A.SWITZERLANDCID000077Conformant
GoldAsahi Pretec Corp.JAPANCID000082Conformant
GoldAsahi Refining Canada Ltd.CANADACID000924Conformant
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICACID000920Conformant
GoldAsaka Riken Co., Ltd.JAPANCID000090Conformant
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYCID000103Outreach Required
GoldAU Traders and RefinersSOUTH AFRICACID002850Conformant
GoldAugmont Enterprises Private LimitedINDIACID003461Active
GoldAurubis AGGERMANYCID000113Conformant
GoldBangalore RefineryINDIACID002863Conformant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESCID000128Conformant
GoldBoliden ABSWEDENCID000157Conformant
GoldC. Hafner GmbH + Co. KGGERMANYCID000176Conformant
GoldC.I Metales Procesados Industriales SASCOLOMBIACID003421Active
GoldCaridadMEXICOCID000180Outreach Required
GoldCCR Refinery - Glencore Canada CorporationCANADACID000185Conformant
GoldCendres + Metaux S.A.SWITZERLANDCID000189Conformant
GoldCGR Metalloys Pvt Ltd.INDIACID003382Outreach Required
GoldChimet S.p.A.ITALYCID000233Conformant
GoldChugai MiningJAPANCID000264Conformant
GoldDaye Non-Ferrous Metals Mining Ltd.CHINACID000343In Communication
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYCID002867Outreach Required
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATESCID003348Outreach Required
GoldDODUCO Contacts and Refining GmbHGERMANYCID000362Conformant
GoldDowaJAPANCID000401Conformant
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OFCID003195Conformant
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFCID000359Conformant
GoldEco-System Recycling Co., Ltd. East PlantJAPANCID000425Conformant
GoldEco-System Recycling Co., Ltd. North PlantJAPANCID003424Conformant
GoldEco-System Recycling Co., Ltd. West PlantJAPANCID003425Conformant
GoldEmerald Jewel Industry India Limited (Unit 1)INDIACID003487In Communication
GoldEmerald Jewel Industry India Limited (Unit 2)INDIACID003488In Communication
GoldEmerald Jewel Industry India Limited (Unit 3)INDIACID003489In Communication
GoldEmerald Jewel Industry India Limited (Unit 4)INDIACID003490In Communication
GoldEmirates Gold DMCCUNITED ARAB EMIRATESCID002561Conformant



GoldFidelity Printers and Refiners Ltd.ZIMBABWECID002515RMI Due Diligence Review - Unable to Proceed
GoldFujairah Gold FZCUNITED ARAB EMIRATESCID002584Outreach Required
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIACID002852In Communication
GoldGeib Refining CorporationUNITED STATES OF AMERICACID002459Conformant
GoldGold Coast RefineryGHANACID003186Outreach Required
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINACID002243Conformant
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINACID001909Outreach Required
GoldGuangdong Jinding Gold LimitedCHINACID002312Outreach Required
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINACID000651Outreach Required
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINACID000671Outreach Required
GoldHeimerle + Meule GmbHGERMANYCID000694Conformant
GoldHeraeus Metals Hong Kong Ltd.CHINACID000707Conformant
GoldHeraeus Precious Metals GmbH & Co. KGGERMANYCID000711Active
GoldHunan Chenzhou Mining Co., Ltd.CHINACID000767Outreach Required
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINACID000773Outreach Required
GoldHwaSeong CJ CO., LTD.KOREA, REPUBLIC OFCID000778Communication Suspended - Not Interested
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINACID000801Conformant
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATESCID002562Active
GoldIshifuku Metal Industry Co., Ltd.JAPANCID000807Conformant
GoldIstanbul Gold RefineryTURKEYCID000814Conformant
GoldItalpreziosiITALYCID002765Conformant
GoldJALAN & CompanyINDIACID002893Outreach Required
GoldJapan MintJAPANCID000823Conformant
GoldJiangxi Copper Co., Ltd.CHINACID000855Conformant
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATIONCID000927RMI Due Diligence Review - Unable to Proceed
GoldJSC UralelectromedRUSSIAN FEDERATIONCID000929Conformant
GoldJX Nippon Mining & Metals Co., Ltd.JAPANCID000937Conformant
GoldK.A. RasmussenNORWAYCID003497Outreach Required
GoldKaloti Precious MetalsUNITED ARAB EMIRATESCID002563RMI Due Diligence Review - Unable to Proceed
GoldKazakhmys Smelting LLCKAZAKHSTANCID000956In Communication
GoldKazzincKAZAKHSTANCID000957Conformant
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICACID000969Conformant
GoldKGHM Polska Miedz Spolka AkcyjnaPOLANDCID002511Conformant
GoldKojima Chemicals Co., Ltd.JAPANCID000981Conformant
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFCID002605Conformant
GoldKundan Care Products Ltd.INDIACID003463In Communication
GoldKyrgyzaltyn JSCKYRGYZSTANCID001029Conformant
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONCID002865Outreach Required
GoldL'azurde Company For JewelrySAUDI ARABIACID001032RMI Due Diligence Review - Unable to Proceed



GoldLingbao Gold Co., Ltd.CHINACID001056Outreach Required
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINACID001058Outreach Required
GoldL'Orfebre S.A.ANDORRACID002762Conformant
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFCID001078Conformant
GoldLT Metal Ltd.KOREA, REPUBLIC OFCID000689Conformant
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINACID001093Outreach Required
GoldMarsam MetalsBRAZILCID002606Conformant
GoldMaterionUNITED STATES OF AMERICACID001113Conformant
GoldMatsuda Sangyo Co., Ltd.JAPANCID001119Conformant
GoldMD OverseasINDIACID003548In Communication
GoldMetal Concentrators SA (Pty) Ltd.SOUTH AFRICACID003575Conformant
GoldMetallix Refining Inc.UNITED STATES OF AMERICACID003557Active
GoldMetalor Technologies (Hong Kong) Ltd.CHINACID001149Conformant
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORECID001152Conformant
GoldMetalor Technologies (Suzhou) Ltd.CHINACID001147Conformant
GoldMetalor Technologies S.A.SWITZERLANDCID001153Conformant
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICACID001157Conformant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOCID001161Conformant
GoldMitsubishi Materials CorporationJAPANCID001188Conformant
GoldMitsui Mining and Smelting Co., Ltd.JAPANCID001193Conformant
GoldMMTC-PAMP India Pvt., Ltd.INDIACID002509Conformant
GoldModeltech Sdn BhdMALAYSIACID002857Non-Conformant
GoldMorris and WatsonNEW ZEALANDCID002282Communication Suspended - Not Interested
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONCID001204Conformant
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYCID001220Conformant
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANCID001236Conformant
GoldNH Recytech CompanyKOREA, REPUBLIC OFCID003189Non-Conformant
GoldNihon Material Co., Ltd.JAPANCID001259Conformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIACID002779Conformant
GoldOhura Precious Metal Industry Co., Ltd.JAPANCID001325Conformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONCID001326Conformant
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATIONCID000493Conformant
GoldPAMP S.A.SWITZERLANDCID001352Conformant
GoldPease & CurrenUNITED STATES OF AMERICACID002872Outreach Required
GoldPenglai Penggang Gold Industry Co., Ltd.CHINACID001362Outreach Required
GoldPlanta Recuperadora de Metales SpACHILECID002919Conformant
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONCID001386Conformant
GoldPT Aneka Tambang (Persero) TbkINDONESIACID001397Conformant
GoldPX Precinox S.A.SWITZERLANDCID001498Conformant
GoldQG Refining, LLCUNITED STATES OF AMERICACID003324Outreach Required
GoldRand Refinery (Pty) Ltd.SOUTH AFRICACID001512Conformant
GoldRefinery of Seemine Gold Co., Ltd.CHINACID000522Outreach Required
GoldREMONDIS PMR B.V.NETHERLANDSCID002582Conformant
GoldRoyal Canadian MintCANADACID001534Conformant
GoldSAAMPFRANCECID002761Conformant
GoldSabin Metal Corp.UNITED STATES OF AMERICACID001546Outreach Required
GoldSafimet S.p.AITALYCID002973Conformant



GoldSAFINA A.S.CZECH REPUBLICCID002290Conformant
GoldSai RefineryINDIACID002853Outreach Required
GoldSamduck Precious MetalsKOREA, REPUBLIC OFCID001555Conformant
GoldSamwon Metals Corp.KOREA, REPUBLIC OFCID001562Communication Suspended - Not Interested
GoldSancus ZFS (L’Orfebre, SA)COLOMBIACID003529In Communication
GoldSAXONIA Edelmetalle GmbHGERMANYCID002777Conformant
GoldSellem Industries Ltd.MAURITANIACID003540Outreach Required
GoldSEMPSA Joyeria Plateria S.A.SPAINCID001585Conformant
GoldShandong Humon Smelting Co., Ltd.CHINACID002525Outreach Required
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINACID001619Outreach Required
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACID001622Conformant
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CHINACID002527Outreach Required
GoldShirpur Gold Refinery Ltd.INDIACID002588Outreach Required
GoldSichuan Tianze Precious Metals Co., Ltd.CHINACID001736Conformant
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINACID002516Conformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONCID001756Conformant
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINACID001761Conformant
GoldSovereign MetalsINDIACID003383Outreach Required
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIACID003153Outreach Required
GoldSudan Gold RefinerySUDANCID002567Outreach Required
GoldSumitomo Metal Mining Co., Ltd.JAPANCID001798Conformant
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFCID002918Conformant
GoldSuper Dragon Technology Co., LtdTAIWAN, PROVINCE OF CHINACID001810Outreach Required
GoldT.C.A S.p.AITALYCID002580Conformant
GoldTanaka Kikinzoku Kogyo K.K.JAPANCID001875Conformant
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINACID001916Conformant
GoldTokuriki Honten Co., Ltd.JAPANCID001938Conformant
GoldTongling Nonferrous Metals Group Co., Ltd.CHINACID001947Outreach Required
GoldTony Goetz NVBELGIUMCID002587Non-Conformant
GoldTOO Tau-Ken-AltynKAZAKHSTANCID002615Conformant
GoldTorecomKOREA, REPUBLIC OFCID001955Conformant
GoldUmicore Precious Metals ThailandTHAILANDCID002314Conformant
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMCID001980Conformant
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICACID001993Conformant
GoldValcambi S.A.SWITZERLANDCID002003Conformant
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIACID002030Conformant
GoldWIELAND Edelmetalle GmbHGERMANYCID002778Conformant
GoldYamakin Co., Ltd.JAPANCID002100Conformant
GoldYokohama Metal Co., Ltd.JAPANCID002129Conformant
GoldYunnan Copper Industry Co., Ltd.CHINACID000197Outreach Required
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACID002224Conformant
TantalumAsaka Riken Co., Ltd.JAPANCID000092Conformant



TantalumChangsha South Tantalum Niobium Co., Ltd.CHINACID000211Conformant
TantalumD Block Metals, LLCUNITED STATES OF AMERICACID002504Conformant
TantalumExotech Inc.UNITED STATES OF AMERICACID000456Conformant
TantalumF&X Electro-Materials Ltd.CHINACID000460Conformant
TantalumFIR Metals & Resource Ltd.CHINACID002505Conformant
TantalumGlobal Advanced Metals AizuJAPANCID002558Conformant
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICACID002557Conformant
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINACID000616Conformant
TantalumH.C. Starck Co., Ltd.THAILANDCID002544Conformant
TantalumH.C. Starck Hermsdorf GmbHGERMANYCID002547Conformant
TantalumH.C. Starck Inc.UNITED STATES OF AMERICACID002548Conformant
TantalumH.C. Starck Ltd.JAPANCID002549Conformant
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANYCID002550Conformant
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANYCID002545Conformant
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINACID002492Conformant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACID002512Conformant
TantalumJiangxi Tuohong New Raw MaterialCHINACID002842Conformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACID000914Conformant
TantalumJiujiang Tanbre Co., Ltd.CHINACID000917Conformant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACID002506Conformant
TantalumKEMET Blue MetalsMEXICOCID002539Conformant
TantalumLSM Brasil S.A.BRAZILCID001076Conformant
TantalumMetallurgical Products India Pvt., Ltd.INDIACID001163Conformant
TantalumMineracao Taboca S.A.BRAZILCID001175Conformant
TantalumMitsui Mining and Smelting Co., Ltd.JAPANCID001192Conformant
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINACID001277Conformant
TantalumNPM Silmet ASESTONIACID001200Conformant
TantalumPRG DooelNORTH MACEDONIA, REPUBLIC OFCID002847Conformant
TantalumQuantumCleanUNITED STATES OF AMERICACID001508Conformant
TantalumResind Industria e Comercio Ltda.BRAZILCID002707Conformant
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONCID001769Conformant
TantalumTaki Chemical Co., Ltd.JAPANCID001869Conformant
TantalumTelex MetalsUNITED STATES OF AMERICACID001891Conformant
TantalumUlba Metallurgical Plant JSCKAZAKHSTANCID001969Conformant
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINACID002508Conformant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINACID001522Conformant
TinAlphaUNITED STATES OF AMERICACID000292Conformant
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAMCID002703Outreach Required
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINACID000228Conformant
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINACID003190Conformant
TinChina Tin Group Co., Ltd.CHINACID001070Conformant
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBRAZILCID003486Active
TinCRM SynergiesSPAINCID003524Active
TinCV Ayi JayaINDONESIACID002570Active
TinCV Venus Inti PerkasaINDONESIACID002455Active
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINACID003356Non-Conformant
TinDowaJAPANCID000402Conformant



TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAMCID002572Non-Conformant
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)CID000438Conformant
TinEstanho de Rondonia S.A.BRAZILCID000448Active
TinFenix MetalsPOLANDCID000468Conformant
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINACID003410Outreach Required
TinGejiu Fengming Metallurgy Chemical PlantCHINACID002848Conformant
TinGejiu Kai Meng Industry and Trade LLCCHINACID000942Conformant
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINACID000538Conformant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINACID001908Conformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINACID000555Conformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACID003116Conformant
TinHuiChang Hill Tin Industry Co., Ltd.CHINACID002844Conformant
TinJiangxi New Nanshan Technology Ltd.CHINACID001231Conformant
TinLuna Smelter, Ltd.RWANDACID003387Conformant
TinMa'anshan Weitai Tin Co., Ltd.CHINACID003379Conformant
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILCID002468Conformant
TinMalaysia Smelting Corporation (MSC)MALAYSIACID001105Conformant
TinMelt Metais e Ligas S.A.BRAZILCID002500Conformant
TinMetallic Resources, Inc.UNITED STATES OF AMERICACID001142Conformant
TinMetallo Belgium N.V.BELGIUMCID002773Conformant
TinMetallo Spain S.L.U.SPAINCID002774Conformant
TinMineracao Taboca S.A.BRAZILCID001173Conformant
TinMinsurPERUCID001182Conformant
TinMitsubishi Materials CorporationJAPANCID001191Conformant
TinModeltech Sdn BhdMALAYSIACID002858Non-Conformant
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002573Outreach Required
TinNovosibirsk Processing Plant Ltd.RUSSIAN FEDERATIONCID001305Active
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDCID001314Conformant
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESCID002517Conformant
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)CID001337Conformant
TinPongpipat Company LimitedMYANMARCID003208Outreach Required
TinPrecious Minerals and Smelting LimitedINDIACID003409Non-Conformant
TinPT Aries Kencana SejahteraINDONESIACID000309Active
TinPT Artha Cipta LanggengINDONESIACID001399Conformant
TinPT ATD Makmur Mandiri JayaINDONESIACID002503Conformant
TinPT Babel Inti PerkasaINDONESIACID001402Conformant
TinPT Babel Surya Alam LestariINDONESIACID001406Conformant
TinPT Bangka SerumpunINDONESIACID003205Conformant
TinPT Bukit TimahINDONESIACID001428Active
TinPT Cipta Persada MuliaINDONESIACID002696In Communication
TinPT Lautan Harmonis SejahteraINDONESIACID002870Active
TinPT Menara Cipta MuliaINDONESIACID002835Conformant
TinPT Mitra Stania PrimaINDONESIACID001453Conformant
TinPT Mitra Sukses GlobalindoINDONESIACID003449In Communication
TinPT Prima Timah UtamaINDONESIACID001458Conformant
TinPT Rajawali Rimba PerkasaINDONESIACID003381Conformant
TinPT Rajehan AriqINDONESIACID002593Conformant



TinPT Refined Bangka TinINDONESIACID001460Conformant
TinPT Stanindo Inti PerkasaINDONESIACID001468Conformant
TinPT Sukses Inti MakmurINDONESIACID002816Active
TinPT Timah NusantaraINDONESIACID001486Active
TinPT Timah Tbk KundurINDONESIACID001477Conformant
TinPT Timah Tbk MentokINDONESIACID001482Conformant
TinPT Tinindo Inter NusaINDONESIACID001490Conformant
TinResind Industria e Comercio Ltda.BRAZILCID002706Conformant
TinRui Da HungTAIWAN, PROVINCE OF CHINACID001539Conformant
TinSoft Metais Ltda.BRAZILCID001758Conformant
TinSuper LigasBRAZILCID002756Active
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMCID002834Conformant
TinThaisarcoTHAILANDCID001898Conformant
TinTin Technology & RefiningUNITED STATES OF AMERICACID003325Conformant
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002574Outreach Required
TinVQB Mineral and Trading Group JSCVIET NAMCID002015Outreach Required
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILCID002036Conformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACID002158Conformant
TinYunnan Tin Company LimitedCHINACID002180Conformant
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINACID003397Conformant
TungstenA.L.M.T. Corp.JAPANCID000004Conformant
TungstenACL Metais EireliBRAZILCID002833Conformant
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILCID003427Active
TungstenArtek LLCRUSSIAN FEDERATIONCID003553Active
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMCID002502Conformant
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINACID002513Conformant
TungstenChina Molybdenum Co., Ltd.CHINACID002641Conformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINACID000258Conformant
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINACID000281Outreach Required
TungstenCronimet Brasil LtdaBRAZILCID003468Active
TungstenFujian Ganmin RareMetal Co., Ltd.CHINACID003401Conformant
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINACID002645Conformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINACID000875Conformant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINACID002315Conformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINACID002494Conformant
TungstenGEM Co., Ltd.CHINACID003417Active
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICACID000568Conformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINACID000218Conformant
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANYCID002542Conformant
TungstenH.C. Starck Tungsten GmbHGERMANYCID002541Conformant
TungstenHunan Chenzhou Mining Co., Ltd.CHINACID000766Conformant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINACID000769Conformant
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONCID002649Conformant
TungstenJapan New Metals Co., Ltd.JAPANCID000825Conformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINACID002551Conformant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINACID002321Conformant



TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINACID002313Communication Suspended - Not Interested
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINACID002318Conformant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINACID002317Conformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINACID002316Conformant
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONCID003408Active
TungstenKennametal FallonUNITED STATES OF AMERICACID000966Conformant
TungstenKennametal HuntsvilleUNITED STATES OF AMERICACID000105Conformant
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OFCID003388Conformant
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINACID003407Conformant
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINACID002319Conformant
TungstenMasan Tungsten Chemical LLC (MTC)VIET NAMCID002543Conformant
TungstenMoliren Ltd.RUSSIAN FEDERATIONCID002845Conformant
TungstenNiagara Refining LLCUNITED STATES OF AMERICACID002589Conformant
TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATIONCID003416Active
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESCID002827Conformant
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONCID002724Conformant
TungstenWolfram Bergbau und Hutten AGAUSTRIACID002044Conformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINACID002320Conformant
TungstenXiamen Tungsten Co., Ltd.CHINACID002082Conformant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINACID002830Conformant