UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM SD
Specialized Disclosure Report

 

 

 

ALTRA INDUSTRIAL MOTION CORP.

(Exact name of registrant as specified in its charter)

 

 

 

 

 

 

 

 

Delaware

 

001-33209

 

61-1478870

(State or other Jurisdiction

of Incorporation)

 

(Commission

File Number)

 

(IRS Employer

Identification No.)

 

 

 

 

300 Granite Street, Suite 201

Braintree, Massachusetts

 

02184

(Address of Principal Executive Offices)

 

(Zip Code)

 

Glenn Deegan (781) 917-5517
(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:

 

 Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

 

 

 

Section 1 – Conflict Minerals Disclosure.

Item 1.01 Conflict Minerals Disclosure and Report.

 

Altra Industrial Motion Corp. and its subsidiaries (collectively, “Altra”) manufacture and supply electromechanical power transmission, motion control and automation products. Altra evaluated its current product lines and determined that columbite-tantalite ("tantalum"), cassiterite ("tin"), wolframite ("tungsten") and/or gold (collectively, “3TG”) are contained in, and necessary to the functionality or production of, certain products manufactured, or contracted to be manufactured by Altra, and for which the manufacture was completed during the calendar year covered by this Specialized Disclosure Report. Accordingly, Altra conducted in good faith a reasonable country of origin inquiry regarding the 3TG in Altra’s products that was reasonably designed to determine whether any such 3TG originated in the Democratic Republic of the Congo or an adjoining country, or were from recycled or scrap sources.

 

In accordance with Rule 13p-1, under the Securities Exchange Act of 1934, Altra has filed this Specialized Disclosure Form and the associated Conflict Minerals Report as Exhibit 1.01 hereto. A copy of Altra’s Conflict Minerals Report is publicly available in the “Governance” section of Altra’s website located at: https://ir.altramotion.com/governance/governance-documents/.

Item 1.02 Exhibit.

See Exhibit 1.01 attached hereto.

Section 2 – Exhibits.

Item 2.01. Exhibits.

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and Item 1.02 of this Form SD.

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 undersigned hereunto duly authorized.

 

 

 

 

ALTRA INDUSTRIAL MOTION CORP.

 

/s/ Glenn Deegan

Name:

 

Glenn Deegan

Title:

 

Chief Legal and Human Resources Officer

 

Date: May 26, 2022

EX-1.01

EXHIBIT 1.01

Altra Industrial Motion Corp.
Conflict Minerals Report
For The Year Ended December 31, 2021

This is the Conflict Minerals Report of Altra Industrial Motion Corp. for calendar year 2021, in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“1934 Act”). Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-677161 for definitions to the terms used in this Conflict Minerals Report (this “Report”), unless otherwise defined herein.

Overview

Rule 13p-1 of the 1934 Act (the “Conflict Minerals Rule”) requires disclosure of certain information when a company manufactures or contracts to manufacture products, and the “conflict minerals” specified in the Conflict Minerals Rule are necessary to the functionality or production of those products. For purposes of the Conflict Minerals Rule, “conflict minerals” include: columbite-tantalite ("tantalum"), cassiterite ("tin"), wolframite ("tungsten"), and gold (collectively referred to in this Report as “3TG”).

This Report has been prepared by Altra Industrial Motion Corp. (herein referred to as “Altra”, “we”, “us” or “our”). The information in this Report includes the activities of all subsidiaries owned or controlled by Altra that are required to be consolidated for purposes of this Report. This Report covers products (i) for which 3TG are necessary to the functionality or production of those products; (ii) that were manufactured, or contracted to be manufactured, by Altra; and (iii) for which the manufacture was completed during the reporting period from January 1, 2021 to December 31, 2021 (the “Reporting Period”). These products are collectively referred to in this Report as the “Covered Products”.

Our Products

Altra is a premier industrial, global manufacturer and supplier of electromechanical power transmission, motion control and automation products, including highly engineered power transmission, motion control and engine braking systems and components. As of May 31, 2022, Altra’s portfolio consists of 26 well-respected brands including Bauer Gear Motor, Boston Gear, Kollmorgen, Portescap, Stromag, Svendborg Brakes, TB Wood’s, Thomson and Warner Electric. Altra acquired Nook Industries, LLC (“Nook”) on December 31, 2021, and, as permitted by the instructions to Form SD, we have not included Nook in this Report.

1 Final Rule: Conflict Minerals, Release No. 34-67716 (August 22, 2012), available at http://www.sec.gov/rules/final/2012/34-67716.pdf.

Compliance with the Conflict Minerals Rule

Altra is fully committed to complying with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which aims to prevent the use of 3TG that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or adjoining countries (including Angola, Burundi, The Central African Republic, The Republic of Congo, Uganda, Rwanda, South Sudan, Tanzania, and Zambia) (collectively, the "Covered Countries").

In accordance with the Conflict Minerals Rule, Altra undertook measures reasonably designed to (i) identify whether there are any 3TG included in, and necessary to the functionality or production of, products manufactured, or contracted to be manufactured, by Altra, and for which the manufacture was completed during the Reporting Period, and if so, (ii) determine whether any of the 3TG originated in the Covered Countries or are from recycled or scrap sources. Altra’s processes are described in detail below.

While Altra takes compliance with the Conflict Minerals Rule very seriously, as a company engaged in the manufacture and supply of electromechanical power transmission, motion control and automation products, Altra’s global supply chain is complex, and Altra is several levels removed from the actual mining of any potential 3TG that may be contained in its final products. Furthermore, Altra does not purchase raw ore or unrefined 3TG, or make purchases from the Covered Countries. Altra must therefore rely on its suppliers to provide information regarding the origin of 3TG that are included in the Covered Products. Moreover, Altra believes that the smelters and refiners in Altra's supply chain -- who Altra typically does not know due to being so far removed from them in the supply chain -- are in the best position to know the origin of the 3TG, and therefore Altra has structured its RCOI and due diligence processes to ultimately identify the applicable smelters of 3TG in Altra’s supply chain.

Reasonable Country of Origin Inquiry

In order to comply with the Conflict Minerals Rule during the Reporting Period, Altra continued to utilize its Conflict Minerals compliance team, led by a member of Altra’s senior management. Each of Altra’s business units conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding 3TG in its supply chain. In accordance with the Conflict Minerals Rule and related guidance provided by the SEC, this RCOI was reasonably designed to determine whether any of the 3TG included in Altra’s products originated in the Conflict Region and/or whether any of those 3TG may be from recycled or scrap sources. Due to the overlap between the supplier/smelter RCOI and the supplier/smelter due diligence processes, the supplier/smelter RCOI processes are summarized in the Due Diligence section of this Report.

Due Diligence

Altra designed its due diligence process to conform in all material respects with the Organization for Economic Cooperation and Development’s (“OECD’s”) Due Diligence Guidance for

Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, an internationally recognized due diligence framework (the “OECD Framework”). In accordance with the OECD Framework, during the Reporting Period Altra has maintained a Conflict Minerals compliance and due diligence program that includes (i) the establishment of strong company management systems, (ii) procedures for identifying and assessing risk in Altra’s supply chain, (iii) a strategy to respond to identified risks, and (iv) public reporting on supply chain due diligence. The following is a summary of Altra’s efforts to comply with the OECD’s Five-Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain.

1.
Company Management Systems. Altra has established strong management systems in accordance with Step 1 of the OECD Framework. These systems include the following:

 

a.
Altra has adopted and implemented a Policy Statement on Conflict Minerals which is publicly available in the “Governance” section of Altra’s website located at: https://ir.altramotion.com/governance/governance-documents/.
b.
Altra has implemented an internal management structure to support supply chain due diligence. Altra’s management structure consists of (i) a member of Altra’s senior management with overall responsibility for the RCOI and due diligence processes, (ii) members of Altra’s Corporate Supply Chain Department with dedicated responsibility for the design of the RCOI and due diligence processes, and (iii) at least one employee at each of Altra’s business units who are responsible for executing the RCOI and due diligence processes at the business unit level. The business unit-level compliance teams are comprised of subject matter experts from relevant functions such as purchasing, quality assurance and engineering.
c.
Altra continues to utilize a process to collect required supplier and smelter RCOI and due diligence data, as described below. In addition, Altra continues to require its suppliers to support its Conflict Minerals compliance efforts through contractual methods. For example, Altra has incorporated terms and conditions in its procurement documents which require the supplier to certify that its product is "conflict free."
d.
Altra continues to engage with suppliers by communicating with and educating them as necessary with respect to the Conflict Minerals Rule.
e.
Altra’s Code of Business Conduct includes a mechanism for employees to escalate issues and concerns regarding any compliance matter, including issues regarding compliance with the Conflict Minerals Rule. In addition, Altra’s Conflict Minerals business unit-level compliance teams routinely follow up with the management-level compliance team, including Altra’s Corporate Supply Chain and Legal
Departments, to identify and escalate any identified issues associated with non-responsive or problematic responses to Altra’s RCOI survey. Altra believes that this system is conducive to identifying and addressing risks as early as possible.

 

2.
Identify and Assess Risks in the Supply Chain. Altra has continued its efforts to increase its supply chain transparency and to identify and assess risks in its supply chain. As noted above, Altra designed its due diligence process to identify the smelters in Altra’s supply chain in accordance with Step 2 of the OECD Framework. In particular, Altra’s supplier due diligence process included the following:

 

•
Due to the wide variety and high mix of products manufactured and sold by Altra, Altra conducted a risk-based approach to its RCOI and due diligence processes, with all of Altra’s businesses targeting suppliers that, in the aggregate, were responsible for the top 80% of the businesses’ total annual spending on materials, parts and components (each such supplier, an “In-Scope Supplier”).
•
Altra sent each In-Scope Supplier a copy of Altra’s Policy Statement on Conflict Minerals.
•
Altra requested that each In-Scope Supplier complete a survey regarding the presence and origin of 3TG contained within the components, parts and materials supplied to Altra during the Reporting Period.
•
As necessary, Altra educated In-Scope Suppliers regarding the reasons for requesting the 3TG data and answered supplier questions related thereto.
•
Altra followed up with In-Scope Suppliers that did not respond to Altra’s initial outreach, and also followed up with In-Scope Suppliers who submitted data that appeared to be incomplete or incorrect.
•
Altra amalgamated supplier-provided smelters into a single unique list of smelters.

Altra has relied on the responses of these In-Scope Suppliers to provide information about the source of 3TG contained within the parts, components and materials supplied to Altra. Some of Altra’s In-Scope Suppliers were unable to identify the smelters or countries of origin in their supply chain, some In-Scope Suppliers responded by providing information related to all of the items the In-Scope Supplier produces without identifying smelters specific to the items purchased by Altra, and some In-Scope Suppliers included names of smelters that we believe may have been misidentified as smelters or that are not operational. As noted above, Altra made every reasonable effort to follow up with

In-Scope Suppliers that (i) did not respond to Altra’s initial outreach or (ii) submitted data that appeared to be incomplete or incorrect.

3.
Design and Implement a Strategy to Respond to Risks. Altra has continued to develop and execute measures to respond to identified risks in accordance Step 3 of the OECD Framework. In particular, Altra’s strategy includes the following:

 

•
With respect to each smelter identified by Altra’s supply chain that declared directly or through their relevant industry association that they did not source from the Covered Countries and were not recognized as conflict free by the RMI’s Responsible Minerals Assurance Process (“RMAP”), Altra, with the assistance of an outside consultant, reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration.
•
With respect to each smelter identified by Altra’s supply chain that is sourcing from, or as to which there is reason to believe may be sourcing from, the Covered Countries, Altra did not audit such smelters but instead relied on the RMAP, and if the smelter has not been audited and recognized as conflict free by the RMAP, Altra conducted risk mitigation in accordance with the OECD Framework.
•
Altra’s compliance team consolidated the data provided by Altra’s In-Scope Suppliers, as well as the findings from Altra’s outside consultant, for periodic reporting to Altra’s senior management as needed, consistent with the OECD Framework.
•
Throughout the due diligence process, Altra identified the applicable risks associated with its supply chain for mitigation as discussed below under “Risk Mitigation Efforts”.
•
Altra communicates with and educates suppliers on compliance with the Conflict Minerals Rule as needed.
•
Altra communicates to its suppliers that they will be evaluated and reviewed on an ongoing basis for compliance with the Conflict Minerals Rule and that Altra reserves the right at any time to take appropriate actions with respect to non-compliant suppliers, up to and including discontinuing purchases from the supplier.

 

4.
Independent Third Party Audit of Supply Chain Due Diligence. It is important to note that the OECD Framework was written for both upstream and downstream companies in the supply chain. With respect to Step 4 of the OECD Framework, as noted above, Altra is a
downstream consumer of 3TG and is many steps removed from smelters and refiners who provide minerals and ore. Altra does not purchase raw or unrefined 3TG and does not, to the best of its knowledge, directly purchase these minerals from any of the Covered Countries. Therefore, Altra does not perform or direct audits of smelters and refiners within its supply chain. Altra relies on industry resources, such as the Conflict Free Smelters Initiative, RMAP and other certifying bodies, to provide certifications and to influence smelters and refiners to participate in audits and achieve conflict-free certifications.

 

5.
Public Report on Supply Chain Due Diligence. Altra complies with Step 5 of the OECD Framework by making this Report and its Policy Statement on Conflict Minerals publicly available in the “Governance” section of Altra’s website located at: https://ir.altramotion.com/governance/governance-documents/.

 

 

Results of Our RCOI and Due Diligence Processes

Altra’s efforts to collect information from In-Scope Suppliers continued into the current calendar year. Despite Altra’s diligent efforts in repeatedly contacting non-responsive suppliers, as of the date of this filing, Altra has yet to receive responses to its 3TG survey from a number of its In-Scope Suppliers. In addition, In-Scope Suppliers who have responded to Altra’s 3TG survey have showed varying degrees of cooperation. Some of the challenges Altra has faced with respect to obtaining and analyzing supplier responses include the following: (i) Altra is dependent on information received from its direct suppliers, who are dependent upon information received from their lower level suppliers, to determine (x) the country of origin of 3TG contained in the components and materials supplied to Altra and (y) which specific smelters are providing the source metals that eventually become incorporated into Altra’s products; (ii) Altra has a varied supplier base with differing levels of resources and sophistication, many of whom are not themselves subject to Rule 13p-1 of the Exchange Act; (iii) some of Altra’s In-Scope Suppliers provided incomplete or unclear responses that required significant follow-up; (iv) some of Altra’s In-Scope Suppliers were unable or unwilling to specify the country of origin of, or the smelters or refiners used for, materials and components supplied to Altra; and (v) the majority of Altra’s In-Scope Suppliers who did identify smelters or refiners in their supply chain responded to Altra’s 3TG survey at a company or divisional level and, therefore, Altra cannot definitively determine whether (x) any of the 3TG reported by these In-Scope Suppliers are actually contained in the products or components supplied to us or (y) whether the identified smelters or refiners are actually in our supply chain.

The responses provided by Altra’s In-Scope Suppliers resulted in the identification of 334 unique smelters that may have been the source of 3TG in products Altra manufactured or contracted to manufacture during the Reporting Period. These smelters are identified in Schedule A attached to this Report. With the assistance of its outside consultant, Altra determined that certain of these identified smelters source, or there is reason to believe may source, from the Covered Countries. Altra compared these smelters to the list of smelters that have been audited and recognized as conflict free by the RMAP and, for those smelters that have not been recognized as conflict free by the RMAP, Altra worked with its outside consultant to conduct risk mitigation in accordance with Step 3 of the OECD Framework, including performing additional due diligence to determine (i) whether the products supplied to Altra during the Reporting Period contain the particular 3TG sourced from such smelters, (ii) whether such smelters are part of Altra’s supply chain, and (iii) if there is any reason to believe such smelters directly or indirectly finance or benefit armed groups in the Covered Countries.

Notwithstanding the foregoing steps, due to the lack of product-level detail provided by Altra’s In-Scope Suppliers, Altra was unable to confirm that the necessary 3TG in its products were processed by any particular smelter or smelters and is, therefore, unable to identify the processing facilities, country of origin or mine or location of origin of such 3TG.

Risk Mitigation Efforts

In the next compliance period, Altra intends to continue to make efforts to improve its RCOI and due diligence processes, in order to further mitigate any risk that the necessary 3TG in Altra's products could benefit armed groups in the Covered Countries. These efforts include:

•
Continue to leverage the activities of the OECD and relevant trade associations to identify and improve best practices for RCOI and due diligence processes;
•
Continue to educate members of our management and business unit-level conflict minerals compliance teams as well as other employees who are involved with 3TG on both the supplier and customer sides of Altra’s business;
•
Continue to engage with suppliers to improve the accuracy and completeness of the information provided to Altra about Altra’s supply chain;
•
Continue to move towards purchasing only from suppliers who are sourcing from certified, conflict-free smelters;
•
Continue to compare the list of smelters identified as a result of Altra’s RCOI and due diligence processes to the evolving list of smelters who have been designated as “conflict free” through independent “conflict free” smelter validation programs; and
•
Continue to seek to include in supplier contracts a commitment by the supplier to take steps necessary to enable Altra to comply with the Conflict Minerals Rule.

In order to improve the transparency throughout its supply chain, Altra will routinely (i) monitor these risk mitigation efforts, (ii) report to senior management on the effectiveness of these efforts and (iii) make any adjustments to this strategy as may be necessary from time to time.

Independent Audit

In accordance with the Conflict Minerals Rule and related SEC guidance, an independent private sector audit of this Report is not required.

 

SCHEDULE A

The following smelters have been identified by Altra’s suppliers as having potentially processed necessary 3TG in certain of Altra’s products manufactured during the Reporting Period:

CID

Metal

Smelter Name

Country

CID002763

Gold

8853 S.p.A.

ITALY

CID002708

Gold

Abington Reldan Metals, LLC

UNITED STATES OF AMERICA

CID000015

Gold

Advanced Chemical Company

UNITED STATES OF AMERICA

CID003185

Gold

African Gold Refinery

UGANDA

CID000019

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

CID002560

Gold

Al Etihad Gold Refinery DMCC

UNITED ARAB EMIRATES

CID003500

Gold

Alexy Metals

UNITED STATES OF AMERICA

CID000035

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

CID000041

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

CID000058

Gold

AngloGold Ashanti Córrego do Sítio Mineração

BRAZIL

CID000077

Gold

Argor-Heraeus S.A.

SWITZERLAND

CID000082

Gold

Asahi Pretec Corp.

JAPAN

CID000924

Gold

Asahi Refining Canada Ltd.

CANADA

CID000920

Gold

Asahi Refining USA Inc.

UNITED STATES OF AMERICA

CID000090

Gold

Asaka Riken Co., Ltd.

JAPAN

CID000103

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

CID002850

Gold

AU Traders and Refiners

SOUTH AFRICA

CID003461

Gold

Augmont Enterprises Private Limited

INDIA

CID000113

Gold

Aurubis AG

GERMANY

CID002863

Gold

Bangalore Refinery

INDIA

CID000128

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

CID000157

Gold

Boliden AB

SWEDEN

CID000176

Gold

C. Hafner GmbH + Co. KG

GERMANY

CID003421

Gold

C.I Metales Procesados Industriales SAS

COLOMBIA

CID000180

Gold

Caridad

MEXICO

CID000185

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

 

CID

Metal

Smelter Name

Country

CID000189

Gold

Cendres + Métaux S.A.

SWITZERLAND

CID003382

Gold

CGR Metalloys Pvt Ltd.

INDIA

CID000233

Gold

Chimet S.p.A.

ITALY

CID000264

Gold

Chugai Mining

JAPAN

CID000343

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

CID002867

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

CID003348

Gold

Dijllah Gold Refinery FZC

UNITED ARAB EMIRATES

CID000362

Gold

DODUCO Contacts and Refining GmbH

GERMANY

CID000359

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

CID000425

Gold

Eco-System Recycling Co., Ltd. East Plant

JAPAN

CID003424

Gold

Eco-System Recycling Co., Ltd. North Plant

JAPAN

CID003425

Gold

Eco-System Recycling Co., Ltd. West Plant

JAPAN

CID003487

Gold

Emerald Jewel Industry India Limited (Unit 1)

INDIA

CID003488

Gold

Emerald Jewel Industry India Limited (Unit 2)

INDIA

CID003489

Gold

Emerald Jewel Industry India Limited (Unit 3)

INDIA

CID003490

Gold

Emerald Jewel Industry India Limited (Unit 4)

INDIA

CID002561

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

CID002515

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

CID002584

Gold

Fujairah Gold FZC

UNITED ARAB EMIRATES

CID002852

Gold

GGC Gujrat Gold Centre Pvt. Ltd.

INDIA

CID002459

Gold

Geib Refining Corporation

UNITED STATES OF AMERICA

CID003186

Gold

Gold Coast Refinery

GHANA

CID002243

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

CID001909

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

CID002312

Gold

Guangdong Jinding Gold Limited

CHINA

CID000651

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

CID000671

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

 

CID

Metal

Smelter Name

Country

CID000694

Gold

Heimerle + Meule GmbH

GERMANY

CID000711

Gold

Heraeus Germany GmbH Co. KG

GERMANY

CID000707

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

CID000767

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000773

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

CHINA

CID000778

Gold

HwaSeong CJ Co., Ltd.

KOREA, REPUBLIC OF

CID002587

Gold

Industrial Refining Company

BELGIUM

CID000801

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

CID002562

Gold

International Precious Metal Refiners

UNITED ARAB EMIRATES

CID000807

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

CID000814

Gold

Istanbul Gold Refinery

TURKEY

CID002765

Gold

Italpreziosi

ITALY

CID002893

Gold

JALAN & Company

INDIA

CID000823

Gold

Japan Mint

JAPAN

CID000855

Gold

Jiangxi Copper Co., Ltd.

CHINA

CID000927

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

CID000493

Gold

JSC Novosibirsk Refinery

RUSSIAN FEDERATION

CID000929

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

CID000937

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

CID003497

Gold

K.A. Rasmussen

NORWAY

CID002563

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

CID000956

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

CID000957

Gold

Kazzinc

KAZAKHSTAN

CID000969

Gold

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

CID002511

Gold

KGHM Polska Miedź Spółka Akcyjna

POLAND

CID000981

Gold

Kojima Chemicals Co., Ltd.

JAPAN

CID002605

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

CID003463

Gold

Kundan Care Products Ltd.

INDIA

CID001029

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

CID002865

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

CID001032

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

CID002762

Gold

L'Orfebre S.A.

ANDORRA

CID001056

Gold

Lingbao Gold Co., Ltd.

CHINA

CID001058

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

CID001078

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

CID000689

Gold

LT Metal Ltd.

KOREA, REPUBLIC OF

 

CID

Metal

Smelter Name

Country

CID001093

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

CID002606

Gold

Marsam Metals

BRAZIL

CID001113

Gold

Materion

UNITED STATES OF AMERICA

CID001119

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

CID003548

Gold

MD Overseas

INDIA

CID003575

Gold

Metal Concentrators SA (Pty) Ltd.

SOUTH AFRICA

CID003557

Gold

Metallix Refining Inc.

UNITED STATES OF AMERICA

CID001149

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

CID001152

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

CID001147

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

CID001153

Gold

Metalor Technologies S.A.

SWITZERLAND

CID001157

Gold

Metalor USA Refining Corporation

UNITED STATES OF AMERICA

CID001161

Gold

Metalúrgica Met-Mex Peñoles S.A. De C.V.

MEXICO

CID001188

Gold

Mitsubishi Materials Corporation

JAPAN

CID001193

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID002509

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

CID002857

Gold

Modeltech Sdn Bhd

MALAYSIA

CID002282

Gold

Morris and Watson

NEW ZEALAND

CID001204

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

CID001220

Gold

Nadir Metal Rafineri San. Ve Tic. A.Ş.

TURKEY

CID001236

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

CID003189

Gold

NH Recytech Company

KOREA, REPUBLIC OF

CID001259

Gold

Nihon Material Co., Ltd.

JAPAN

CID002779

Gold

Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

CID001325

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

CID001326

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

RUSSIAN FEDERATION

CID001352

Gold

PAMP S.A.

SWITZERLAND

CID002872

Gold

Pease & Curren

UNITED STATES OF AMERICA

 

CID

Metal

Smelter Name

Country

CID001362

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

CID002919

Gold

Planta Recuperadora de Metales SpA

CHILE

CID001386

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

CID001397

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

CID001498

Gold

PX Précinox S.A.

SWITZERLAND

CID003324

Gold

QG Refining, LLC

UNITED STATES OF AMERICA

CID001512

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

CID000522

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

CID002582

Gold

REMONDIS PMR B.V.

NETHERLANDS

CID001534

Gold

Royal Canadian Mint

CANADA

CID002761

Gold

SAAMP

FRANCE

CID001546

Gold

Sabin Metal Corp.

UNITED STATES OF AMERICA

CID002973

Gold

Safimet S.p.A

ITALY

CID002290

Gold

SAFINA A.S.

CZECHIA

CID002853

Gold

Sai Refinery

INDIA

CID001555

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

CID001562

Gold

SAMWON Metals Corp.

KOREA, REPUBLIC OF

CID003529

Gold

Sancus ZFS (L’Orfebre, SA)

COLOMBIA

CID002777

Gold

SAXONIA Edelmetalle GmbH

GERMANY

CID003540

Gold

Sellem Industries Ltd.

MAURITANIA

CID001585

Gold

SEMPSA Joyería Platería S.A.

SPAIN

CID001916

Gold

Shandong Gold Smelting Co., Ltd.

CHINA

CID002525

Gold

Shandong Humon Smelting Co., Ltd.

CHINA

CID001619

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

CID001622

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

CID002527

Gold

Shenzhen Zhonghenglong Real Industry Co., Ltd.

CHINA

CID002588

Gold

Shirpur Gold Refinery Ltd.

INDIA

CID001736

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

CID002516

Gold

Singway Technology Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID001756

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

CID001761

Gold

Solar Applied Materials Technology Corp.

TAIWAN, PROVINCE OF CHINA

CID003383

Gold

Sovereign Metals

INDIA

 

CID

Metal

Smelter Name

Country

CID003153

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

CID002567

Gold

Sudan Gold Refinery

SUDAN

CID001798

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

CID002918

Gold

SungEel HiMetal Co., Ltd.

KOREA, REPUBLIC OF

CID001810

Gold

Super Dragon Technology Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID002580

Gold

T.C.A S.p.A

ITALY

CID001875

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

CID001938

Gold

Tokuriki Honten Co., Ltd.

JAPAN

CID001947

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

CID002615

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

CID001955

Gold

Torecom

KOREA, REPUBLIC OF

CID002314

Gold

Umicore Precious Metals Thailand

THAILAND

CID001980

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

CID001993

Gold

United Precious Metal Refining, Inc.

UNITED STATES OF AMERICA

CID002003

Gold

Valcambi S.A.

SWITZERLAND

CID003617

Gold

Value Trading

BELGIUM

CID003615

Gold

WEEEREFINING

FRANCE

CID002030

Gold

Western Australian Mint (T/a The Perth Mint)

AUSTRALIA

CID002778

Gold

WIELAND Edelmetalle GmbH

GERMANY

CID002100

Gold

Yamakin Co., Ltd.

JAPAN

CID002129

Gold

Yokohama Metal Co., Ltd.

JAPAN

CID000197

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

CID002224

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

CID000211

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

CID002504

Tantalum

D Block Metals, LLC

UNITED STATES OF AMERICA

CID000456

Tantalum

Exotech Inc.

UNITED STATES OF AMERICA

CID000460

Tantalum

F&X Electro-Materials Ltd.

CHINA

CID002505

Tantalum

FIR Metals & Resource Ltd.

CHINA

CID002558

Tantalum

Global Advanced Metals Aizu

JAPAN

CID002557

Tantalum

Global Advanced Metals Boyertown

UNITED STATES OF AMERICA

CID002547

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

 

 

 

 

 

CID

Metal

Smelter Name

Country

CID002548

Tantalum

H.C. Starck Inc.

UNITED STATES OF AMERICA

CID002492

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

CID002512

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

CID002842

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

CID000914

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

CID000917

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

CID002506

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002539

Tantalum

KEMET de Mexico

MEXICO

CID001076

Tantalum

LSM Brasil S.A.

BRAZIL

CID001163

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

CID001175

Tantalum

Mineração Taboca S.A.

BRAZIL

CID001192

Tantalum

Mitsui Mining & Smelting

JAPAN

CID001200

Tantalum

NPM Silmet AS

ESTONIA

CID001508

Tantalum

QuantumClean

UNITED STATES OF AMERICA

CID002707

Tantalum

Resind Indústria e Comércio Ltda.

BRAZIL

CID001769

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

CID001869

Tantalum

Taki Chemical Co., Ltd.

JAPAN

CID002544

Tantalum

TANIOBIS Co., Ltd.

THAILAND

CID002545

Tantalum

TANIOBIS GmbH

GERMANY

CID002549

Tantalum

TANIOBIS Japan Co., Ltd.

JAPAN

CID002550

Tantalum

TANIOBIS Smelting GmbH & Co. KG

GERMANY

CID001891

Tantalum

Telex Metals

UNITED STATES OF AMERICA

CID001969

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

CID000616

Tantalum

XIMEI RESOURCES (GUANGDONG) LIMITED

CHINA

CID002508

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

CID003583

Tantalum

Yancheng Jinye New Material Technology Co., Ltd.

CHINA

CID001522

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

CHINA

CID000292

Tin

Alpha

UNITED STATES OF AMERICA

CID002703

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

CID000228

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

 

CID

Metal

Smelter Name

Country

CID003190

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

CID001070

Tin

China Tin Group Co., Ltd.

CHINA

CID003486

Tin

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

BRAZIL

CID003524

Tin

CRM Synergies

SPAIN

CID002455

Tin

CV Venus Inti Perkasa

INDONESIA

CID003356

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

CHINA

CID000402

Tin

Dowa

JAPAN

CID002572

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

VIET NAM

CID000438

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

CID000448

Tin

Estanho de Rondônia S.A.

BRAZIL

CID003582

Tin

Fabrica Auricchio Industria e Comercio Ltda.

BRAZIL

CID000468

Tin

Fenix Metals

POLAND

CID003410

Tin

Gejiu City Fuxiang Industry and Trade Co., Ltd.

CHINA

CID000942

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

CID000538

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

CID001908

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

CID000555

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

CID003116

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

CHINA

CID002844

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

CID001231

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

CID003387

Tin

Luna Smelter, Ltd.

RWANDA

CID003379

Tin

Ma'anshan Weitai Tin Co., Ltd.

CHINA

CID002468

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

CID001105

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

CID002500

Tin

Melt Metais e Ligas S.A.

BRAZIL

CID001142

Tin

Metallic Resources, Inc.

UNITED STATES OF AMERICA

CID002773

Tin

Metallo Belgium N.V.

BELGIUM

CID002774

Tin

Metallo Spain S.L.U.

SPAIN

 

CID

Metal

Smelter Name

Country

CID001173

Tin

Mineração Taboca S.A.

BRAZIL

CID001182

Tin

Minsur

PERU

CID001191

Tin

Mitsubishi Materials Corporation

JAPAN

CID002858

Tin

Modeltech Sdn Bhd

MALAYSIA

CID002573

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

CID001305

Tin

Novosibirsk Processing Plant Ltd.

RUSSIAN FEDERATION

CID001314

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

CID002517

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID001337

Tin

Operaciones Metalúrgicas S.A.

BOLIVIA (PLURINATIONAL STATE OF)

CID003208

Tin

Pongpipat Company Limited

MYANMAR

CID003409

Tin

Precious Minerals and Smelting Limited

INDIA

CID000309

Tin

PT Aries Kencana Sejahtera

INDONESIA

CID001399

Tin

PT Artha Cipta Langgeng

INDONESIA

CID002503

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

CID001402

Tin

PT Babel Inti Perkasa

INDONESIA

CID001406

Tin

PT Babel Surya Alam Lestari

INDONESIA

CID003205

Tin

PT Bangka Serumpun

INDONESIA

CID001421

Tin

PT Belitung Industri Sejahtera

INDONESIA

CID001428

Tin

PT Bukit Timah

INDONESIA

CID002696

Tin

PT Cipta Persada Mulia

INDONESIA

CID003380

Tin

PT Masbro Alam Stania

INDONESIA

CID002835

Tin

PT Menara Cipta Mulia

INDONESIA

CID001453

Tin

PT Mitra Stania Prima

INDONESIA

CID003449

Tin

PT Mitra Sukses Globalindo

INDONESIA

CID001457

Tin

PT Panca Mega Persada

INDONESIA

CID001458

Tin

PT Prima Timah Utama

INDONESIA

CID003381

Tin

PT Rajawali Rimba Perkasa

INDONESIA

CID001460

Tin

PT Refined Bangka Tin

INDONESIA

CID001463

Tin

PT Sariwiguna Binasentosa

INDONESIA

CID001468

Tin

PT Stanindo Inti Perkasa

INDONESIA

CID002816

Tin

PT Sukses Inti Makmur

INDONESIA

CID001486

Tin

PT Timah Nusantara

INDONESIA

CID001477

Tin

PT Timah Tbk Kundur

INDONESIA

CID001482

Tin

PT Timah Tbk Mentok

INDONESIA

CID001490

Tin

PT Tinindo Inter Nusa

INDONESIA

CID002706

Tin

Resind Indústria e Comércio Ltda.

BRAZIL

CID001539

Tin

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

CID001758

Tin

Soft Metais Ltda.

BRAZIL

 

CID

Metal

Smelter Name

Country

CID002756

Tin

Super Ligas

BRAZIL

CID002834

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

VIET NAM

CID001898

Tin

Thaisarco

THAILAND

CID003325

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

CID002574

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002036

Tin

White Solder Metalurgia e Mineração Ltda.

BRAZIL

CID002158

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

CID002180

Tin

Yunnan Tin Company Limited

CHINA

CID003397

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

CHINA

CID000004

Tungsten

A.L.M.T. Corp.

JAPAN

CID002833

Tungsten

ACL Metais Eireli

BRAZIL

CID003427

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

BRAZIL

CID003553

Tungsten

Artek LLC

RUSSIAN FEDERATION

CID002502

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIET NAM

CID002513

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

CID002641

Tungsten

China Molybdenum Co., Ltd.

CHINA

CID000258

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID000281

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

CID003468

Tungsten

Cronimet Brasil Ltda

BRAZIL

CID003401

Tungsten

Fujian Ganmin RareMetal Co., Ltd.

CHINA

CID003609

Tungsten

Fujian Xinlu Tungsten

CHINA

CID002645

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

CID000875

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

CID002315

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

CID002494

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

CID003417

Tungsten

GEM Co., Ltd.

CHINA

CID000568

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES OF AMERICA

CID000218

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

 

CID

Metal

Smelter Name

Country

CID002541

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

CID000766

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000769

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

CID002649

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

CID000825

Tungsten

Japan New Metals Co., Ltd.

JAPAN

CID002551

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

CID002321

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

CID002313

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

CID002318

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

CID002317

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

CID002316

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

CID003408

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

RUSSIAN FEDERATION

CID000966

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

CID000105

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

CID003388

Tungsten

KGETS Co., Ltd.

KOREA, REPUBLIC OF

CID003407

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID002319

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002543

Tungsten

Masan High-Tech Materials

VIET NAM

CID002845

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

CID002589

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

CID003416

Tungsten

NPP Tyazhmetprom LLC

RUSSIAN FEDERATION

CID003614

Tungsten

OOO “Technolom” 1

RUSSIAN FEDERATION

CID003612

Tungsten

OOO “Technolom” 2

RUSSIAN FEDERATION

CID002827

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

CID002542

Tungsten

TANIOBIS Smelting GmbH & Co. KG

GERMANY

CID002724

Tungsten

Unecha Refractory Metals Plant

RUSSIAN FEDERATION

CID002044

Tungsten

Wolfram Bergbau und Hütten AG

AUSTRIA

CID002320

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

CID002082

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

CID002830

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CHINA