UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Specialized Disclosure Report
EchoStar Corporation
(Exact name of registrant as specified in its charter)
| Nevada | 001-33807 | 26-1232727 | ||||||||||||
| (State or Other Jurisdiction of Incorporation or Organization) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||||||||||||
| 100 Inverness Terrace East, Englewood, Colorado | 80112-5308 | |||||||
| (Address of Principal Executive Offices) | (Zip Code) | |||||||
Dean A. Manson
Executive Vice President, General Counsel and Secretary
(303) 706-4000
(Name and telephone number, including area code, of person to contact in connection with this report)
Hughes Satellite Systems Corporation
(Exact name of registrant as specified in its charter)
| Colorado | 333-179121 | 45-0897865 | ||||||||||||
| (State or Other Jurisdiction of Incorporation or Organization) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||||||||||||
| 100 Inverness Terrace East, Englewood, Colorado | 80112-5308 | |||||||
| (Address of Principal Executive Offices) | (Zip Code) | |||||||
Dean A. Manson
Executive Vice President, General Counsel and Secretary
(303) 706-4000
(Name and telephone number, including area code, of person to contact in connection with this report)
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020
EXPLANATORY NOTE
EchoStar Corporation (“EchoStar”) and its subsidiary, Hughes Satellite Systems Corporation (“Hughes”), each has prepared this Specialized Disclosure Report on Form SD (“Form SD”) pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period of January 1 to December 31, 2020. Unless the context indicates otherwise, any reference in this Form SD to the “Company,” “we,” “us” and “our” refer to EchoStar, Hughes and their respective subsidiaries through December 31, 2020. Each of EchoStar and Hughes is filing this Form SD and the attached Conflict Minerals Report separately and on its own behalf.
SECTION 1—CONFLICT MINERALS DISCLOSURE
ITEM 1.01. Conflict Minerals Disclosure and Report
Introduction
The Rule requires disclosure of certain information when a registrant manufactures, or contracts to manufacture, products whose manufacture was completed during the relevant reporting period that contain certain minerals that are necessary to the functionality or production of such products (the “Covered Products”). The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”). For the Covered Products, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the Conflict Minerals originated in the Democratic Republic of the Congo or certain adjoining countries (each, a “Covered Country” and collectively, the “Covered Countries”). If, based on such inquiry, a registrant knows or has reason to believe that any of the Conflict Minerals contained in its products originated or may have originated in a Covered Country and that such Conflict Minerals are not or may not be solely from recycled or scrap sources, the registrant must conduct due diligence with respect to the source and chain of custody of the Conflict Minerals to determine the origin of such Conflict Minerals and whether they directly or indirectly financed or benefited armed groups in the Covered Countries.
Conclusion Based on Reasonable Country of Origin Inquiry
In accordance with the Rule, for the reporting period of January 1 to December 31, 2020, the Company:
•Determined that the Company manufactured, or contracted to manufacture, certain Covered Products.
•Conducted a good faith reasonable country of origin inquiry which was reasonably designed to determine whether any of the Conflict Minerals in our Covered Products originated in the Covered Countries and, if so, whether any of such Conflict Minerals were from recycled or scrap sources. Based on that inquiry, the Company has reason to believe that some of the Conflict Minerals in our Covered Products may have originated in one or more of the Covered Countries and that such Conflict Minerals may not have been from recycled or scrap sources.
•Conducted due diligence with respect to the source and chain of custody of such Conflict Minerals.
Based on the information obtained through our reasonable country of origin inquiry and our due diligence efforts, which significantly overlap, the Company has reasonably determined that countries of origin of the Conflict Minerals in the Covered Products, to the extent known, included Central African Republic, the Democratic Republic of the Congo, Rwanda and Tanzania.
Conflict Minerals Disclosure
Based on the results of the procedures described above, the Company has filed this Form SD and the attached Conflict Minerals Report. A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD, and is publicly available on the Company’s website at http://ir.echostar.com/financial-information/sec-filings. Unless otherwise stated in this Form SD and the Conflict Minerals Report filed as Exhibit 1.01 hereto, any documents, third-party materials or references to websites, including the Company’s website, are not incorporated by reference in, or considered to be a part of, this Form SD and the attached Conflict Minerals Report.
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Forward-Looking Statements
This Form SD and the attached Conflict Minerals Report may contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995, Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Exchange Act, including but not limited to statements about our estimates, expectations, future developments, plans, objectives, strategies, and financial condition, expected impact of regulatory developments and legal proceedings, opportunities in our industries and businesses and other trends and projections for the future. All statements, other than statements of historical facts, may be forward-looking statements. Forward-looking statements may also be identified by words such as “anticipate,” “intend,” “plan,” “goal,” “seek,” “believe,” “estimate,” “expect,” “predict,” “project,” “continue,” “future,” “will,” “would,” “could,” “can,” “may” and similar terms. These forward-looking statements are based on information available to us as of the date of this Form SD and the attached Conflict Minerals Report and represent management’s current views and assumptions based on past experience and trends, current economic and industry conditions, expected future developments and other relevant factors. Forward-looking statements are not guarantees of future performance, events or results and involve potential known and unknown risks, uncertainties, including the impact of the coronavirus pandemic (COVID-19), and other factors, many of which may be beyond our control and may pose a risk to our operating and financial condition both the near- and long-term. Accordingly, actual performance, events or results could differ materially from those expressed or implied in the forward-looking statements due to a number of factors. Important factors that could cause actual outcomes to differ materially from those contained in any forward-looking statement include those described in EchoStar’s and Hughes’s respective reports, including EchoStar’s and Hughes’s respective annual reports on Form 10-K for the fiscal year ended December 31, 2020, EchoStar’s and Hughes’s respective quarterly reports on Form 10-Q and other documents that each of EchoStar and Hughes files with or furnishes to the Securities and Exchange Commission from time to time. You should not put undue reliance on any forward-looking statements. Unless we are required to do so under U.S. federal securities laws or other applicable laws, we do not intend to update or revise any forward-looking statements. All cautionary statements made herein should be read as being applicable to all forward-looking statements wherever they appear. Investors should consider the risks and uncertainties described herein and should not place undue reliance on any forward-looking statements. We do not undertake, and specifically disclaim, any obligation to publicly release the results of any revisions that may be made to any forward-looking statements, whether as a result of new information, future events or otherwise, except as required by law.
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 to this Form SD.
SECTION 2—EXHIBITS
ITEM 2.01. Exhibits
The following exhibit is filed as part of this Form SD.
| Exhibit No. | Description | |||||||
| 1.01 | Conflict Minerals Report of EchoStar Corporation and Hughes Satellite Systems Corporation for the reporting period of January 1 to December 31, 2020. | |||||||
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, each registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| ECHOSTAR CORPORATION | ||||||||
| May 27, 2021 | By: | /s/ Dean A. Manson Dean A. Manson Executive Vice President, General Counsel and Secretary | ||||||
| HUGHES SATELLITE SYSTEMS CORPORATION | ||||||||
| May 27, 2021 | By: | /s/ Dean A. Manson Dean A. Manson Executive Vice President, General Counsel and Secretary | ||||||
EXHIBIT INDEX
| Exhibit No. | Description | |||||||
| 1.01 | Conflict Minerals Report of EchoStar Corporation and Hughes Satellite Systems Corporation for the reporting period of January 1 to December 31, 2020. | |||||||
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Exhibit 1.01
ECHOSTAR CORPORATION
HUGHES SATELLITE SYSTEMS CORPORATION
Conflict Minerals Report
For the reporting period from January 1 to December 31, 2020
Introduction and Background
This Conflict Minerals Report (the “Report”) of EchoStar Corporation (“EchoStar”) and Hughes Satellite Systems Corporation (“Hughes” and, together with EchoStar and the respective subsidiaries of EchoStar and Hughes through December 31, 2020, the “Company,” “we,” “our” and/or “us”) has been prepared pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 to December 31, 2020. 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. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”) that originated in the Democratic Republic of the Congo (“DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).
Pursuant to the Rule, the Company has concluded, in good faith, that during the reporting period of January 1 to December 31, 2020:
•the Company manufactured, or contracted to manufacture, certain products whose manufacture was completed in calendar year 2020 as to which Conflict Minerals are necessary to the functionality or production of those products (our “Covered Products”); and
•based on a good faith reasonable country of origin inquiry (“RCOI”) regarding the Conflict Minerals in our Covered Products, the Company had reason to believe that certain of the Conflict Minerals necessary to the functionality or production of our Covered Products may have originated in one or more of the Covered Countries and that such Conflict Minerals may not have been from recycled or scrap sources.
Therefore, the Company performed due diligence on the source and chain of custody of such Conflict Minerals in our Covered Products. The Company is filing this Report with our Specialized Disclosure Report on Form SD (the “Form SD”) to comply with the requirements of the Rule. This Report has not been subject to an independent private sector audit.
PART I. COMPANY OVERVIEW AND DESCRIPTION OF PRODUCTS COVERED BY THIS REPORT
Description of Products
We are a global provider of broadband satellite technologies and broadband internet services to domestic and international consumer customers, which include home and small to medium-sized businesses, and satellite services. We also deliver innovative network technologies, managed services and communications solutions for domestic and international enterprise customers, which include aeronautical and government enterprises.
This Report relates to our Covered Products under our Hughes business segment for the entire reporting period, which consisted of the following:
Broadband Satellite Systems — The Company’s broadband and satellite products included broadband systems and terminals, mobile satellite systems, handheld devices and IP data terminals for mobile satellite operators, all of which support the delivery of a wide range of bandwidth-intensive services as well as privately-branded service offerings, including high-speed internet/intranet access, video conferencing, distance learning, telemedicine, newsgathering, fleet operations and broadband on planes, trains and maritime.
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Certain of our Covered Products were designed, developed, engineered, manufactured, assembled and/or distributed by us; however, we also outsourced a significant portion of these functions to third parties. We worked with third-party vendors for the development and manufacture of components that are integrated into our Covered Products. We developed dual sourcing capabilities for critical parts when practical and we evaluated outsourced subcontract vendors on a periodic basis.
PART II. DESIGN OF OUR DUE DILIGENCE MEASURES
We designed our due diligence measures based on the five-step framework laid out by the Organization for Economic Co-operation and Development in its OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016), including the related supplements on gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”). Summarized below are the components of our due diligence measures as they relate to the five-step framework from the OECD Guidance.
1.Establish Strong Company Management Systems for Conflict Minerals Supply Chain Due Diligence
Designate Internal Corporate Team
The Company has designated an internal team, composed of senior members of the Company’s supply chain and procurement operations and the legal department, which evaluates the Company’s applicable supply chain processes and sourcing procedures and designs and supports the Company’s due diligence efforts. The team meets periodically to develop and refine a due diligence process that:
•is consistent with the OECD Guidance,
•conforms to the requirements of the Rule, and
•is appropriate given the structure and operations of the Company’s supply chain departments.
The Company’s internal audit department monitors the diligence process, provides feedback and reviews the due diligence results. Senior supply chain managers disseminate necessary information and documentation to relevant employees responsible for interfacing directly with suppliers and manufacturers (collectively referred to as “suppliers”).
Commit to a Supply Chain Policy for Minerals from Conflict-Affected and High-Risk Areas
The Company maintains a policy relating to Conflict Minerals (the “Policy”), which generally requires suppliers to:
•have a policy to reasonably assure that the Conflict Minerals in the products they manufacture for or supply to the Company do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Covered Countries;
•exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to the Company upon the Company’s request; and
•be prepared to assist the Company in meeting the Conflict Minerals reporting requirements under the Rule, as well as other national or international mineral reporting regimes that may arise in the future.
The Policy is incorporated into the Company’s supplier code of conduct. All of our suppliers during the reporting period were obligated to comply with the Policy.
Establish a System of Controls and Transparency over the Conflict Minerals Supply Chain
The Company employs a system of controls to promote transparency over our Conflict Minerals supply chain by utilizing the Conflict Minerals Reporting Template version 6.01 (“Conflict Minerals Reporting Template”), which is a standardized supply chain survey designed to facilitate the transfer of information through the supply chain to identify the smelters and refiners that process Conflict Minerals in our Covered Products. The Conflict Minerals Reporting Template was developed by the Responsible Minerals Initiative (“RMI”), a Responsible Business Alliance and Global e-Sustainability Initiative. The Company maintains an automated database of the completed Conflict Minerals Reporting Templates submitted to the Company by our suppliers (the “Conflict Minerals Response Database”), which
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helps us process and analyze the information provided by our suppliers. Once in the Conflict Minerals Response Database, all completed Conflict Mineral Reporting Templates received from suppliers are stored electronically in a central location accessible to authorized employees involved in the due diligence process and are retained in accordance with the Company’s document retention guidelines.
Since 2015, the Company has been a member of RMI, an organization committed to the responsible sourcing of Conflict Minerals that currently has over 400 participating companies and associations from around the world. As a member, the Company has access to a variety of tools and resources to better assess Conflict Minerals in our supply chain, including the Responsible Minerals Assurance Process (“RMAP”), an audit program designed to validate smelters’ and refiners’ sourcing practices.
Strengthen the Company’s Engagement with Suppliers
We generally inform our suppliers of our Policy, our due diligence consistent with OECD Guidance and our compliance with the Rule. Moreover, the Company’s purchase order and contract terms and conditions generally require that suppliers expressly support the supply chain due diligence process employed by the Company.
Establish a Company-Level Grievance Mechanism
The Company maintains a reporting system through which employees and third parties may report concerns about potential or actual violations of the Policy. Concerns may be reported anonymously or for attribution through several channels, including through an employee’s immediate manager or the Company’s legal department.
2.Identify and Assess the Risks in the Company’s Supply Chain
The Company does not purchase Conflict Minerals directly from mines, smelters or refiners and does not have a direct relationship with any mines, smelters or refiners. The Company’s supply chain with respect to our Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacturer of our Covered Products and the original sources of the Conflict Minerals. As a result, we designed our due diligence to conform to the requirements of the Rule and the OECD Guidance as applicable for downstream companies. Because the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, the Company relies on communications with suppliers to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain. In particular, the Company performs the following measures to identify Conflict Minerals in our Covered Products.
Identify Company Suppliers
The Company identifies our first-tier suppliers by generating reports from the Company’s applicable manufacturing and procurement systems of all manufacturers who made, and all vendors who supplied components or products, for our Covered Products. For components delivered to the Company by distributors, the Company adds the distributors to the supplier list. Senior managers in the supply chain organization review and finalize the supplier list (the “Supplier List”) to create a list that includes all relevant suppliers for purposes of the Rule.
Request Conflict Minerals Reporting Templates from Suppliers
The Company uses good faith efforts to identify from the Conflict Minerals Reporting Templates the smelters and refiners used by our suppliers on the Supplier List. Annually, the Company sends a letter and the Conflict Minerals Reporting Template to the suppliers on the Supplier List. The letter (i) reiterates the requirements of the Rule and its applicability to the Company, (ii) requests that each supplier complete the Conflict Minerals Reporting Template for all Covered Products supplied to the Company for the reporting period, and (iii) encourages suppliers to use smelters and refiners which appear on the RMAP’s Conformant Smelter List (as described below). The Company contacts suppliers that do not respond to the Company’s request by a specified date as well as suppliers that submit incomplete or inaccurate requests for follow-on discussions and to request additional information, as applicable.
As set forth in the Conflict Minerals Reporting Template and the OECD Guidance, suppliers make representations or provide information regarding, among other things, (i) the country of origin for the Conflict Minerals contained in components or products provided by the supplier to the Company, (ii) whether such Conflict Minerals are sourced from
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conflict-affected and high -risk areas , (iii) smelters and refiners in the supplier’s supply chain for such Conflict Minerals, (iv) whether such smelters and refiners have been validated in compliance with the RMAP, (v) whether such supplier uses the Conflict Minerals Reporting Template with its own suppliers to gather information, and (vi) whether the supplier has its owns conflict mineral policy that requires its direct suppliers to be conformant.
Analyze Surveys for RMAP Conformant and Active Smelters and Refiners
If correctly and fully completed, each Conflict Minerals Reporting Template identifies the smelters and refiners within the applicable supplier’s supply chain. The Company reviews the information in the completed Conflict Minerals Reporting Templates against the RMAP’s Conformant Smelter List to determine whether the smelters or refiners associated with the applicable supplier qualify as “conformant” or “RMAP Active.” We rely upon third party audits of smelters and refiners as part of the RMI’s RMAP, an audit program designed to validate smelters’ and refiners’ sourcing practices as described below. Smelters and refiners receive a “conformant” designation from RMI if (i) the audited smelter or refiner adheres to the RMAP’s assessment protocols by disclosing to independent auditors the identities and locations of the mines from which it sources Conflict Minerals and (ii) the independent auditor verifies separately that the smelter’s or refiner’s Conflict Minerals originated from conflict-free sources. The RMAP’s Conformant Smelter List includes the names, locations and links to Conflict Minerals policies of all smelters and refiners deemed “conformant” with the RMAP’s assessment protocols. Smelters and refiners labeled as “RMAP Active” have committed to undergo a RMAP audit but have not yet completed their audit or are participating in other cross-recognized certification programs. “RMAP Active” smelters and refiners may be at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase, but may not retain their “active” status if they are unresponsive to requests for re-audit or corrective action past a certain time.
The Company also uses good faith efforts to identify the country of origin information from the smelters and refiners provided by our suppliers on the Supplier List through the Conflict Minerals Reporting Template.
3.Design and Implement Strategies to Respond to Identified Risks
Participate in Existing Industry Conflict Minerals Initiatives; Devise, Adopt and Implement a Risk Management Plan; Monitor Risk Mitigation Efforts
In light of the complexity of the Company’s and our suppliers’ supply chains, the Company is currently unable to assess adequately the risk that Conflict Minerals exist in our Covered Products or whether they finance armed conflict in the DRC. However, the Company engages annually with suppliers to obtain current, accurate and complete information about our supply chains through the use of the Conflict Minerals Reporting Template and to promote “conformant” supply chains through our RMI membership. As a risk mitigation measure, the Company generally requires, through our supplier code of conduct, that suppliers of Covered Products report on Conflict Minerals.
Report Findings to Designated Senior Management and to the Board
The members of the Company’s internal Conflict Minerals team (consisting of senior members of the Company’s supply chain and procurement operations and the legal department) provide a report summarizing the findings from our due diligence efforts to the senior management of the Company and the Audit Committee of EchoStar’s Board of Directors.
4.Carry Out Independent Third-Party Audits of Smelters/Refiners
Due to our downstream position in the supply chain, the Company does not have a direct relationship with smelters and refiners. Further, the complexity of our supply chain and the many third parties involved between the ultimate manufacturer of our Covered Products and the original sources of the Conflict Minerals hinders the Company’s ability to perform direct audits of smelters and refiners in our supply chain. Instead, we rely upon third party audits of smelters and refiners as part of the RMI’s RMAP, an audit program designed to validate smelters’ and refiners’ sourcing practices. The RMAP’s audit process is discussed above in more detail in “Identify and Assess the Risks in the Company’s Supply Chain.”
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Additionally, through our RMI membership, we support the further development and implementation of due diligence practices and tools, such as the Conflict Minerals Reporting Template and the RMAP.
5.Report Annually on Supply Chain Due Diligence
The Company has filed with the Securities and Exchange Commission our Form SD, which includes this Report as Exhibit 1.01, for the reporting period of January 1 to December 31, 2020. In accordance with the OECD Guidance and the Rule, this Report is available on our website at http://ir.echostar.com/financial-information/sec-filings.
PART III. DESCRIPTION OF DUE DILIGENCE MEASURES PERFORMED;
RESULTS OF OUR DUE DILIGENCE MEASURES
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of products which contain Conflict Minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of Conflict Minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of Conflict Minerals. We also rely, to a large extent, on information collected and provided by responsible mineral sourcing validation programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.
Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. The supply chain of commodities such as Conflict Minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers and the entire supply chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce.
Compilation and Analysis of Responses
For the reporting period of January 1 to December 31, 2020, the Company identified approximately 416 relevant suppliers. In the fourth quarter of 2020 and the first quarter of 2021, the Company sent each such supplier on the Supplier List a letter requesting completion of the Conflict Minerals Reporting Template. The Company followed up with suppliers that did not respond to the request by the specified date or that submitted incomplete or inaccurate requests.
The Company received responses from 409, or approximately 99%, of the solicited suppliers, including completed Conflict Minerals Reporting Templates from 338, or approximately 82%, of the solicited suppliers. Through the use of the Conflict Minerals Response Database and access to the RMAP information, we were able to identify the smelters and refiners for the suppliers who submitted completed templates that we believe were used to process the Conflict Minerals contained in our Covered Products as set forth in Annex I attached to this Report, as well as to identify which of those smelters and refiners for the suppliers who submitted completed templates were “RMAP Conformant” or “RMAP Active.”
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Based on the Conflict Minerals Reporting Templates the Company received and information otherwise obtained by the Company during the due diligence process regarding smelters and refiners for the suppliers who submitted such templates, the following table sets forth the number of “RMAP Conformant” and “RMAP Active” smelters and refiners in our supply chain for each of the Conflict Minerals used in our Covered Products:
| Conflict Mineral | RMAP Conformant Smelters or Refiners | RMAP Active Smelters or Refiners | ||||||
| Gold | 108 | 6 | ||||||
| Tantalum | 37 | 0 | ||||||
| Tin | 54 | 12 | ||||||
| Tungsten | 38 | 6 | ||||||
As discussed in “Part II. Design of Our Due Diligence Analysis” above, the Company relies on the completed Conflict Minerals Reporting Templates received from our suppliers as our main source of documentation supporting the representations made by such suppliers regarding the source and chain of custody of relevant Conflict Minerals in our Covered Products during the reporting period. The smelters and refiners identified in Annex I to this Report were identified by such suppliers and the Company cannot be certain that these smelters and refiners were in fact in the Company’s supply chain for our Covered Products.
Country of Origin of the Conflict Minerals in the Covered Products
Based on the Conflict Minerals Reporting Templates the Company received and information otherwise obtained by the Company during the due diligence process regarding smelters and refiners for the suppliers who submitted such templates, the Company does not have sufficient information, with respect to our Covered Products, to determine the country of origin of all of the Conflict Minerals in all of our Covered Products. However, based on the information obtained through our reasonable country of origin inquiry and our due diligence efforts (comprised of the Conflict Minerals Reporting Templates the Company received and information otherwise obtained by the Company during the due diligence process regarding smelters and refiners for the suppliers who submitted such templates), the Company has reasonably determined that countries of origin of the Conflict Minerals in the Covered Products, to the extent known, included Central African Republic, the Democratic Republic of the Congo, Rwanda and Tanzania.
Facilities Used to Process the Conflict Minerals in the Covered Products
Based on the Conflict Minerals Reporting Templates the Company received and information otherwise obtained by the Company during the due diligence process regarding smelters and refiners for the suppliers who submitted such templates, the Company was unable to identify with certainty all of the facilities used to process the Conflict Minerals in our Covered Products. However, based on the information obtained through our reasonable country of origin inquiry and our due diligence efforts (comprised of the Conflict Minerals Reporting Templates the Company received and information otherwise obtained by the Company during the due diligence process regarding smelters and refiners for the suppliers who submitted such templates), the Company has reasonably determined that the facilities that were used to process the Conflict Minerals contained in our Covered Products are believed to include the smelters and refiners listed in Annex I attached to this Report. The smelters and refiners that the Company has been able to determine as “RMAP Conformant” and “RMAP Active” are identified in Annex I. However, as discussed above, the smelters and refiners identified in Annex I to this Report were identified by suppliers and the Company cannot be certain that these smelters and refiners were in fact in the Company’s supply chain for our Covered Products.
PART IV. IMPLEMENTATION OF STRATEGIES TO RESPOND TO IDENTIFIED RISKS AND FUTURE STEPS
Due diligence is an ongoing, proactive and reactive process. The Company engages with our suppliers to obtain current, accurate and complete information about our supply chain. Further, reporting on Conflict Minerals is generally a requirement for our suppliers through our supplier code of conduct. The Company has used our RMI membership to gain a better understanding of the smelters and refiners in our supply chain and their RMAP compliance status, and we intend to continue to take advantage of the resources available to RMI members with regard to conformant sourcing.
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Annex I
LIST OF SMELTERS AND REFINERS REPORTED IN SUPPLY CHAIN IN 2020
| Mineral | Smelter Name | Country of Smelter Facility | ||||||
| Gold | 8853 S.p.A. | Italy* | ||||||
| Gold | Abington Reldan Metals, LLC | United States Of America | ||||||
| Gold | Advanced Chemical Company | United States Of America* | ||||||
| Gold | African Gold Refinery | Uganda | ||||||
| Gold | Aida Chemical Industries Co., Ltd. | Japan* | ||||||
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates* | ||||||
| Gold | Alexy Metals | United States Of America** | ||||||
| Gold | Al Ghaith Gold | United Arab Emirates | ||||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany* | ||||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan* | ||||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil* | ||||||
| Gold | Argor-Heraeus S.A. | Switzerland* | ||||||
| Gold | Asahi Pretec Corp. | Japan* | ||||||
| Gold | Asahi Refining Canada Ltd. | Canada* | ||||||
| Gold | Asahi Refining USA Inc. | United States Of America* | ||||||
| Gold | Asaka Riken Co., Ltd. | Japan* | ||||||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | ||||||
| Gold | Augmont Enterprises Private Limited | India** | ||||||
| Gold | Aurubis AG | Germany* | ||||||
| Gold | AU Traders and Refiners | South Africa* | ||||||
| Gold | Bangalore Refinery | India* | ||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines | Philippines* | ||||||
| Gold | Boliden AB | Sweden* | ||||||
| Gold | Caridad | Mexico | ||||||
| Gold | CCR Refinery - Glencore Canada Corporation | Canada* | ||||||
| Gold | Cendres + Metaux S.A. | Switzerland* | ||||||
| Gold | CGR Metalloys Pvt Ltd. | India | ||||||
| Gold | C. Hafner GmbH + Co. KG | Germany* | ||||||
| Gold | Chimet S.p.A. | Italy* | ||||||
| Gold | Chugai Mining | Japan* | ||||||
| Gold | C.I Metales Procesados Industriales SAS | Colombia** | ||||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | ||||||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | ||||||
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | ||||||
| Gold | DODUCO Contacts and Refining GmbH | Germany* | ||||||
| Gold | Dowa | Japan* | ||||||
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of* | ||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan* | ||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan* | ||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan* | ||||||
| Gold | Emirates Gold DMCC | United Arab Emirates* | ||||||
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | ||||||
* RMAP Conformant
**RMAP Active—in the process of becoming RMAP Conformant.
A-1
| Gold | Fujairah Gold FZC | United Arab Emirates | ||||||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | ||||||
| Gold | Geib Refining Corporation | United States Of America* | ||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China* | ||||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | ||||||
| Gold | Guangdong Jinding Gold Limited | China | ||||||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | ||||||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | ||||||
| Gold | Heimerle + Meule GmbH | Germany* | ||||||
| Gold | Heraeus Germany GmbH Co. KG | Germany** | ||||||
| Gold | Heraeus Metals Hong Kong Ltd. | China* | ||||||
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | ||||||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | ||||||
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | ||||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share | China* | ||||||
| Gold | International Precious Metal Refiners | United Arab Emirates** | ||||||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan* | ||||||
| Gold | Istanbul Gold Refinery | Turkey* | ||||||
| Gold | Italpreziosi | Italy* | ||||||
| Gold | Japan Mint | Japan* | ||||||
| Gold | Jiangxi Copper Co., Ltd. | China* | ||||||
| Gold | Jinlong Copper Co., Ltd. | China | ||||||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | ||||||
| Gold | JSC Novosibirsk Refinery | Russian Federation* | ||||||
| Gold | JSC Uralelectromed | Russian Federation* | ||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan* | ||||||
| Gold | Kaloti Precious Metals | United Arab Emirates | ||||||
| Gold | Kazakhmys Smelting LLC | Kazakhstan | ||||||
| Gold | Kazzinc | Kazakhstan* | ||||||
| Gold | Kennecott Utah Copper LLC | United States Of America* | ||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland* | ||||||
| Gold | Kojima Chemicals Co., Ltd. | Japan* | ||||||
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of* | ||||||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan* | ||||||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | ||||||
| Gold | L'azurde Company For Jewelry | Saudi Arabia | ||||||
| Gold | Lingbao Gold Co., Ltd. | China | ||||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | ||||||
| Gold | L'Orfebre S.A. | Andorra* | ||||||
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of* | ||||||
| Gold | LT Metal Ltd. | Korea, Republic Of* | ||||||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | ||||||
| Gold | Marsam Metals | Brazil* | ||||||
| Gold | Materion | United States Of America* | ||||||
| Gold | Matsuda Sangyo Co., Ltd. | Japan* | ||||||
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa* | ||||||
| Gold | Metallix Refining Inc. | United States Of America** | ||||||
* RMAP Conformant
**RMAP Active—in the process of becoming RMAP Conformant.
A-2
| Gold | Metalor Technologies (Hong Kong) Ltd. | China* | ||||||
| Gold | Metalor Technologies S.A. | Switzerland* | ||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore* | ||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | China* | ||||||
| Gold | Metalor USA Refining Corporation | United States Of America* | ||||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico* | ||||||
| Gold | Mitsubishi Materials Corporation | Japan* | ||||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan* | ||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | India* | ||||||
| Gold | Modeltech Sdn Bhd | Malaysia | ||||||
| Gold | Morris and Watson | New Zealand | ||||||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation* | ||||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey* | ||||||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan* | ||||||
| Gold | NH Recytech Company | Korea, Republic Of | ||||||
| Gold | Nihon Material Co., Ltd. | Japan* | ||||||
| Gold | Nyrstar Metals | United States Of America | ||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstal | Austria* | ||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan* | ||||||
| Gold | OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant | Russian Federation* | ||||||
| Gold | PAMP S.A. | Switzerland* | ||||||
| Gold | Pease & Curren | United States Of America | ||||||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | ||||||
| Gold | Planta Recuperadora de Metales SpA | Chile* | ||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation* | ||||||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia* | ||||||
| Gold | PX Precinox S.A. | Switzerland* | ||||||
| Gold | QG Refining, LLC | United States Of America | ||||||
| Gold | Rand Refinery (Pty) Ltd. | South Africa* | ||||||
| Gold | Refinery of Seemine Gold Co., Ltd. | China | ||||||
| Gold | REMONDIS PMR B.V. | Netherlands* | ||||||
| Gold | Royal Canadian Mint | Canada* | ||||||
| Gold | SAAMP | France* | ||||||
| Gold | Sabin Metal Corp. | United States Of America | ||||||
| Gold | Safimet S.p.A | Italy* | ||||||
| Gold | SAFINA A.S. | Czechia* | ||||||
| Gold | Sai Refinery | India | ||||||
| Gold | Samduck Precious Metals | Korea, Republic Of* | ||||||
| Gold | Samwon Metals Corp. | Korea, Republic Of | ||||||
| Gold | SAXONIA Edelmetalle GmbH | Germany* | ||||||
| Gold | SEMPSA Joyeria Plateria S.A. | Spain* | ||||||
| Gold | Shandong Gold Smelting Co., Ltd. | China* | ||||||
| Gold | Shandong Hengbang Smelter Co., Ltd. | China | ||||||
| Gold | Shandong Humon Smelting Co., Ltd. | China | ||||||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Lt | China | ||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China* | ||||||
* RMAP Conformant
**RMAP Active—in the process of becoming RMAP Conformant.
A-3
| Gold | Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co., Ltd. | China | ||||||
| Gold | Shenzhen Heng Zhong Industry Co., Ltd. | China | ||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China* | ||||||
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China* | ||||||
| Gold | Sino-Platinum Metals Co., Ltd. | China | ||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation* | ||||||
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China* | ||||||
| Gold | Sovereign Metals | India | ||||||
| Gold | State Research Institute Center for Physical Sciences | Lithuania | ||||||
| Gold | Sudan Gold Refinery | Sudan | ||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan* | ||||||
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of* | ||||||
| Gold | Super Dragon Technology Co., Ltd. | China | ||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan* | ||||||
| Gold | T.C.A S.p.A | Italy* | ||||||
| Gold | Tokuriki Honten Co., Ltd. | Japan* | ||||||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | ||||||
| Gold | TOO Tau-Ken-Altyn | Kazakhstan* | ||||||
| Gold | Torecom | Korea, Republic Of* | ||||||
| Gold | TSK Pretech | Korea, Republic Of* | ||||||
| Gold | Umicore Precious Metals Thailand | Thailand* | ||||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium* | ||||||
| Gold | United Precious Metal Refining, Inc. | United States Of America* | ||||||
| Gold | Valcambi S.A. | Switzerland* | ||||||
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia* | ||||||
| Gold | Wieland Edelmetalle GmbH | Germany* | ||||||
| Gold | Wuzhong Group | China | ||||||
| Gold | Yamakin Co., Ltd. | Japan* | ||||||
| Gold | Yokohama Metal Co., Ltd. | Japan* | ||||||
| Gold | Yunnan Copper Industry Co., Ltd. | China | ||||||
| Gold | Yunnan Gold Mining Group Co., Ltd. (YGMG) | China | ||||||
| Gold | Zhe Jiang Guang Yuan Noble Metal Smelting Factory | China | ||||||
| Gold | Zhongkuang Gold Industry Co., Ltd. | China | ||||||
| Gold | Zhongshan Hyper-Toxic Substance Monopolized Co., Ltd. | China | ||||||
| Gold | Zhongshan Poison Material Proprietary Co., Ltd. | China | ||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China* | ||||||
| Gold | Zhuhai Toxic Materials Monopoly Ltd. | China | ||||||
| Gold | Zhuzhou Smelting Group Co., Ltd | China | ||||||
| Tantalum | Asaka Riken Co., Ltd. | Japan* | ||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China* | ||||||
| Tantalum | D Block Metals, LLC | United States Of America* | ||||||
| Tantalum | Exotech Inc. | United States Of America* | ||||||
| Tantalum | FIR Metals & Resource Ltd. | China* | ||||||
* RMAP Conformant
**RMAP Active—in the process of becoming RMAP Conformant.
A-4
| Tantalum | F&X Electro-Materials Ltd. | China* | ||||||
| Tantalum | Global Advanced Metals | United States Of America | ||||||
| Tantalum | Global Advanced Metals Aizu | Japan* | ||||||
| Tantalum | Global Advanced Metals Boyertown | United States Of America* | ||||||
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China* | ||||||
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany* | ||||||
| Tantalum | H.C. Starck Inc. | United States Of America* | ||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China* | ||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China* | ||||||
| Tantalum | Jiangxi Tuohong New Raw Material | China* | ||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China* | ||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | China* | ||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China* | ||||||
| Tantalum | KEMET de Mexico | Mexico* | ||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | India* | ||||||
| Tantalum | Meta Materials | North Macedonia, Republic Of* | ||||||
| Tantalum | Mineracao Taboca S.A. | Brazil* | ||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan* | ||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China* | ||||||
| Tantalum | NPM Silmet AS | Estonia* | ||||||
| Tantalum | QuantumClean | United States Of America* | ||||||
| Tantalum | Resind Industria e Comercio Ltda. | Brazil* | ||||||
| Tantalum | Shanghai Jiangxi Metals Co., Ltd. | China | ||||||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation* | ||||||
| Tantalum | Taki Chemical Co., Ltd. | Japan* | ||||||
| Tantalum | Taniobis Co., Ltd. | Thailand* | ||||||
| Tantalum | Taniobis Gmbh | Germany* | ||||||
| Tantalum | Taniobis Japan Co., Ltd. | Japan* | ||||||
| Tantalum | Taniobis Smelting GmbH & Co. KG | Germany* | ||||||
| Tantalum | Telex Metals | United States Of America* | ||||||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan* | ||||||
| Tantalum | Ximei Resources (Guangdong) Limited | China* | ||||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China* | ||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China* | ||||||
| Tin | Alpha | United States Of America* | ||||||
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | ||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China* | ||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China* | ||||||
| Tin | China Tin Group Co., Ltd. | China* | ||||||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Ele | Brazil** | ||||||
| Tin | CRM Synergies | Spain** | ||||||
| Tin | CV Ayi Jaya | Indonesia** | ||||||
| Tin | CV Venus Inti Perkasa | Indonesia** | ||||||
* RMAP Conformant
**RMAP Active—in the process of becoming RMAP Conformant.
A-5
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | ||||||
| Tin | Dongguan City Xida Soldering Tin Products Co. | China | ||||||
| Tin | Dowa | Japan* | ||||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | ||||||
| Tin | EM Vinto | Bolivia (Plurinational State Of)* | ||||||
| Tin | Estanho de Rondonia S.A. | Brazil** | ||||||
| Tin | Fenix Metals | Poland* | ||||||
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | ||||||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | China* | ||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China* | ||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China* | ||||||
| Tin | Gejiu Yunxi Group Corp. | China | ||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China* | ||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China* | ||||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China* | ||||||
| Tin | Guangxi Hua Tin Gold Minute Fee, Ltd. | China | ||||||
| Tin | Guangxi Nonferrous Metals Group | China | ||||||
| Tin | Guangxi Zhongshan Jin Yi Smelting Co., Ltd. | China | ||||||
| Tin | Hezhou Jinwei Tin Co., Ltd. | China | ||||||
| Tin | Hongqiao Metals (Kunshan) Co., Ltd. | China | ||||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China* | ||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | China* | ||||||
| Tin | Lian Jing | China | ||||||
| Tin | Luna Smelter, Ltd. | Rwanda* | ||||||
| Tin | Ma An Shan Shu Guang Smelter Corp. | China | ||||||
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China* | ||||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil* | ||||||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia* | ||||||
| Tin | Materials Eco-Refining Co., Ltd. | Japan | ||||||
| Tin | Melt Metais e Ligas S.A. | Brazil* | ||||||
| Tin | Metahub Industries Sdn. Bhd. | Malaysia | ||||||
| Tin | Metallic Resources, Inc. | United States Of America* | ||||||
| Tin | Metallo Belgium N.V. | Belgium* | ||||||
| Tin | Metallo Spain S.L.U. | Spain* | ||||||
| Tin | Minchali Metal Industry Co., Ltd. | Taiwan, Province Of China | ||||||
| Tin | Mineracao Taboca S.A. | Brazil* | ||||||
| Tin | Ming Li Jia Smelt Metal Factory | China | ||||||
| Tin | Minsur | Peru* | ||||||
| Tin | Mitsubishi Materials Corporation | Japan* | ||||||
| Tin | Modeltech Sdn Bhd | Malaysia | ||||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | ||||||
| Tin | Novosibirsk Processing Plant Ltd. | Russian Federation** | ||||||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines* | ||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand* | ||||||
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of)* | ||||||
| Tin | Pongpipat Company Limited | Myanmar | ||||||
* RMAP Conformant
**RMAP Active—in the process of becoming RMAP Conformant.
A-6
| Tin | Precious Minerals and Smelting Limited | India | ||||||
| Tin | PT Aries Kencana Sejahtera | Indonesia** | ||||||
| Tin | PT Artha Cipta Langgeng | Indonesia* | ||||||
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia* | ||||||
| Tin | PT Babel Inti Perkasa | Indonesia* | ||||||
| Tin | PT Babel Surya Alam Lestari | Indonesia* | ||||||
| Tin | PT Bangka Serumpun | Indonesia* | ||||||
| Tin | PT Bukit Timah | Indonesia** | ||||||
| Tin | PT Cipta Persada Mulia | Indonesia | ||||||
| Tin | PT Lautan Harmonis Sejahtera | Indonesia** | ||||||
| Tin | PT Menara Cipta Mulia | Indonesia* | ||||||
| Tin | PT Mitra Stania Prima | Indonesia* | ||||||
| Tin | PT Prima Timah Utama | Indonesia* | ||||||
| Tin | PT Rajawali Rimba Perkasa | Indonesia* | ||||||
| Tin | PT Rajehan Ariq | Indonesia* | ||||||
| Tin | PT Refined Bangka Tin | Indonesia* | ||||||
| Tin | PT Stanindo Inti Perkasa | Indonesia* | ||||||
| Tin | PT Sukses Inti Makmur | Indonesia** | ||||||
| Tin | PT Timah Nusantara | Indonesia** | ||||||
| Tin | PT Timah Tbk Kundur | Indonesia* | ||||||
| Tin | PT Timah Tbk Mentok | Indonesia* | ||||||
| Tin | PT Tinindo Inter Nusa | Indonesia* | ||||||
| Tin | Resind Industria e Comercio Ltda. | Brazil* | ||||||
| Tin | Rui Da Hung | Taiwan, Province Of China* | ||||||
| Tin | Soft Metais Ltda. | Brazil* | ||||||
| Tin | Super Ligas | Brazil** | ||||||
| Tin | Suzhou Nuonengda Chemical Co., Ltd. | China | ||||||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam* | ||||||
| Tin | Thaisarco | Thailand* | ||||||
| Tin | Tin Technology & Refining | United States Of America* | ||||||
| Tin | Top-Team Technology (Shenzhen) Ltd. | China | ||||||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | ||||||
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | ||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil* | ||||||
| Tin | Wujiang City Luxe Tin Factory | China | ||||||
| Tin | Yifeng Tin | China | ||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China* | ||||||
| Tin | Yunnan Chengo Electric Smelting Plant | China | ||||||
| Tin | Yunnan Industrial Co., Ltd. | China | ||||||
| Tin | Yunnan Malipo Baiyi Kuangye Co. | China | ||||||
| Tin | Yunnan Tin Company Limited | China* | ||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China* | ||||||
| Tungsten | ACL Metais Eireli | Brazil* | ||||||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil** | ||||||
| Tungsten | A.L.M.T. Corp. | Japan* | ||||||
| Tungsten | Artek LLC | Russian Federation** | ||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam* | ||||||
* RMAP Conformant
**RMAP Active—in the process of becoming RMAP Conformant.
A-7
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China* | ||||||
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China* | ||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China* | ||||||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | ||||||
| Tungsten | Cronimet Brasil Ltda | Brazil** | ||||||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China* | ||||||
| Tungsten | Ganzhou Beseem Ferrotungsten Co., Ltd. | China | ||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China* | ||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China* | ||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China* | ||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China* | ||||||
| Tungsten | GEM Co., Ltd. | China** | ||||||
| Tungsten | Global Tungsten & Powders Corp. | United States Of America* | ||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China* | ||||||
| Tungsten | H.C. Starck Tungsten GmbH | Germany* | ||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China* | ||||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China* | ||||||
| Tungsten | Hydrometallurg, JSC | Russian Federation* | ||||||
| Tungsten | Japan New Metals Co., Ltd. | Japan* | ||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China* | ||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China* | ||||||
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China* | ||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China* | ||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China* | ||||||
| Tungsten | JSC Kirovgrad Hard Alloys Plant | Russian Federation** | ||||||
| Tungsten | Kennametal Fallon | United States Of America* | ||||||
| Tungsten | Kennametal Huntsville | United States Of America* | ||||||
| Tungsten | KGETS Co., Ltd. | Korea, Republic Of* | ||||||
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China* | ||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China* | ||||||
| Tungsten | Masan High-Tech Materials | Viet Nam* | ||||||
| Tungsten | Moliren Ltd. | Russian Federation* | ||||||
| Tungsten | Niagara Refining LLC | United States Of America* | ||||||
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation** | ||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines* | ||||||
| Tungsten | Taniobis Smelting GmbH & Co. KG | Germany* | ||||||
| Tungsten | Tungsten Diversified Industries LLC | United States Of America | ||||||
| Tungsten | Unecha Refractory Metals Plant | Russian Federation* | ||||||
| Tungsten | Wolfram Bergbau und Hutten AG | Austria* | ||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | China* | ||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China* | ||||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China* | ||||||
| Tungsten | Zhangzhou Chuen Bao Apt Smeltery Co., Ltd. | China | ||||||
* RMAP Conformant
**RMAP Active—in the process of becoming RMAP Conformant.
A-8