UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Powell Industries, Inc.
(Exact name of registrant as specified in its charter)
| Delaware | 001-12488 | 88-0106100 | ||
| (State or other jurisdiction of incorporation or organization) |
(Commission File No.) |
(I.R.S. Employer Identification No.) | ||
| 8550 Mosley Road Houston, Texas |
77075-1180 | |||
| (Address of principal executive offices) | (Zip Code) | |||
Don R. Madison, 713-944-6900
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015. |
| Item 1.01 | Conflict Minerals Disclosure and Report |
Conflict Minerals Disclosure
Powell Industries, Inc. (the “Company”) undertook a reasonable country of origin inquiry with respect to the conflict minerals used in the production of the Company’s custom engineered-to-order electrical equipment and has determined in good faith that for the year ended December 31, 2015:
| a) | The Company has manufactured or contracted to manufacture products as to which certain conflict minerals, gold, tin, tungsten and tantalum (collectively, 3TG) are necessary to the functionality or production of such products. |
| b) | Based on a reasonable country of origin inquiry, the Company believes, or has reason to believe, that a portion of its products that contain the necessary 3TG originated, or may have originated, in the Democratic Republic of the Congo or an adjoining country and knows, or has reason to believe, that those necessary 3TG products may not be from recycle or scrap sources. |
A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 hereto and is publicly available at the Company’s website at www.powellind.com , under the section entitled “Investors.”
| Item 1.02 | Exhibit |
See Item 2.01 of this Specialized Disclosure Report on Form SD.
| Item 2.01 | Exhibits |
| Exhibit No. |
Description | |
| Exhibit 1.01 | Conflict Minerals Report for the calendar year ended December 31, 2015 | |
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the Company has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| POWELL INDUSTRIES, INC. | ||||||
| Date: May 31, 2016 | By: | /s/ DON R. MADISON | ||||
| Don R. Madison | ||||||
| Executive Vice President | ||||||
| Chief Financial and Administrative Officer (Principal Financial Officer) | ||||||
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Exhibit 1.01
Conflict Minerals Report
For the Year Ended December 31, 2015
This is the Conflict Minerals Report (this Report) of Powell Industries, Inc. (Powell, the Company, we, us or our) for calendar year 2015 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the Exchange Act). Please refer to Section 13(p) of the Exchange Act and the general instructions to the Specialized Disclosure Report on Form SD for definitions of certain terms used in this Report, unless otherwise defined herein.
This Report for the year ended December 31, 2015 is presented to comply with Rule 13p-1 under the Exchange Act (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (3TG) for the purposes of this Report. These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.
Company Overview
We are in the business of developing, designing, manufacturing and servicing custom engineered-to-order equipment and systems for the management and control of electrical energy. Certain conflict minerals (as defined in Item 1.01(d)(3) of Form SD), specifically gold, tin, tungsten and tantalum are used in the production of our custom engineered-to-order equipment. Accordingly, pursuant to the Rule, we conducted a reasonable country of origin inquiry (RCOI) regarding such conflict minerals designed to determine whether any of such conflict minerals originated in the Democratic Republic of the Congo (DRC) or an adjoining country (collectively, Covered Countries), or are from recycled or scrap sources.
Product Description
Our broad and complex product range may contain conflict minerals within the following components:
| • | Tantalum, used in capacitors, |
| • | Tin, used in soldered components, |
| • | Tungsten, used in coatings, alloys, heating elements and electrodes, |
| • | Gold, used in circuit boards, electrodes and electronic components. |
Description of RCOI
In conducting the RCOI, Powell engaged Assent Compliance (Assent) to assist with the effectiveness of our conflict minerals program. We identified the scope of our inquiry by first completing a supplier list extraction from our preferred vendor list. This list was then filtered to remove service providers, indirect materials suppliers and inactive suppliers (minimum of one year since last purchase).
This was intended to ensure that all suppliers surveyed provided items to Powell that were used in final products in the year 2015. Once the filtering was completed, we populated the list with contact information. This list, composed of 5,239 suppliers, was then provided to Assent for upload to their Assent Compliance Manager software system (Assent Compliance Manager).
Assent conducted additional analysis of the supply chain that, combined with supplier feedback, resulted in 3,751 suppliers being removed from the scope of the RCOI. The factors considered in Assent’s secondary analysis and the information provided that removed these suppliers from the scope of inquiry included:
| • | Whether the supplied product was merely packaging (labels do not count as packaging); |
| • | Whether the parts a supplier used did not end up in their final product (such as equipment used to make the product, i.e. industrial equipment, computers, etc.); |
| • | Whether a supplier used test labs, for example, to test, the resistance or durability of a product; |
After limiting the scope of inquiry, Assent conducted the supplier survey portion of the RCOI. The supplier survey utilized a template developed by the Electronic Industry Citizenship Coalition® and The Global e-Sustainability Initiative (EICC/GeSI) called the Conflict Mineral Report Template (CMRT). The CMRT was developed to facilitate general disclosures and information regarding smelters that provide materials to the supplier. It includes questions regarding the supplier’s conflict-free minerals policy, the engagement process with its direct suppliers and identification of the smelters used by the supplier.
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Non-responsive suppliers were contacted a minimum of three times by the Assent Compliance Manager and then were also managed by the Assent Compliance Supply Chain team in one-on-one communications. This included two to three follow ups from the supply chain team. After three months of non-responsiveness, suppliers were then contacted via email and phone by Powell procurement team members as an escalation to encourage their response to Assent.
Assent communications included training and education on the completion of the CMRT form as well as access to a Supplier Resource Center designed to alleviate any remaining confusion with suppliers. All communications were monitored and tracked in Assent’s system for future reporting and transparency.
All submitted forms are accepted and classified as valid or invalid in order to retain all data. Suppliers were contacted if they submitted invalid forms and were encouraged to resubmit a valid form. As of May 9, 2015, there were 54 invalid supplier submissions.
Due Diligence Process
Powell’s due diligence measures have been designed to conform, in all material respects, with the framework in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for 3TG (collectively, the “OECD Guidance”). In 2015, the due diligence process was aimed to help Powell assess and respond to risk in its supply chain by investigating the source of its products down the chain to the smelters and refiners and the strength of its suppliers’ conflict minerals programs. The following is a brief summary of certain aspects of our due diligence process.
| A. | Establish Strong Powell Management Systems |
In accordance with our due diligence framework and compliance efforts:
| • | We have communicated to all of our applicable suppliers our efforts to comply with Section 1502 of the Dodd-Frank Act pursuant to a compliance statement and other communications (collectively, the Compliance Statement). We requested that our applicable suppliers provide a comprehensive conflict minerals declaration for all conflict minerals in the form of the CMRT. We provide our Compliance Statement to all new suppliers and plan to provide annual related compliance statement communications to our entire supply base. |
| • | We implemented internal compliance efforts, including internal reporting requirements, to support our supply chain due diligence process. |
| • | We implemented a risk mitigation response plan to address business relationships with suppliers that are DRC conflict undeterminable (as defined in Item 1.01(d)(5) of Form SD), which mitigation may include identifying an alternate supply. Our program includes continuous monitoring to adjust our strategies as sourcing data improves and new information is received. |
Powell has adopted a company policy with respect to conflict minerals which is posted on our website at www.powellind.com.
Internal Team
Powell has established a management system for conflict minerals. Our management system is sponsored by the Chief Financial Officer as well as executive-level representatives and a team of subject matter experts from relevant functions, such as our Strategic Sourcing Manager, Corporate Controller, Vice President of Research and Product Development, and Supply Base Manager.
The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and senior management is briefed about the results of our due diligence efforts.
Control Systems
Controls include, but are not limited to, our code of conduct which outlines expected behaviors for all Powell employees and a conflict minerals policy which can be found on our website at www.powellind.com.
We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers. Contracts with our suppliers are frequently in force for three to five years or more and we cannot unilaterally impose new contract terms and flow-down requirements. As we enter into new
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contracts, or our contracts renew, we are adding a clause to require suppliers to provide information about the source of 3TG and smelters. It will take a number of years to ensure that all our supplier contracts contain appropriate flow-down clauses. In the meantime, as described below, we are working with selected suppliers to ensure they provide the 3TG sourcing information until the contracts can be amended.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have, through Assent, provided education on the conflict minerals regulation. We have leveraged the existing communications within the Company, specifically the procurement department, to encourage supplier interactions with Assent as well as to help suppliers understand the requirement for completion of their supplier surveys. Feedback from this engagement has allowed us to enhance the training and focus and adapt it to each user’s needs. It has also allowed for our supplier communications to be more focused and to clarify expectations.
Grievance Mechanisms
We have multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Powell’s policies.
Maintain Records
We have also adopted a policy to retain relevant documentation. Such documentation will be retained for minimum of five years.
| B. | Identify and Assess Risks in Our Supply Chain |
We identified direct material suppliers to capture possible 3TG risk suppliers. As we progress, we expect that transparency in our supply chain will increase to allow for better risk assessment at more detailed levels of our supply chain. We intend to continue communicating with our suppliers regarding conflict minerals.
Based on assessed risks, our RCOI covered applicable suppliers.
| C. | Design and Implement a Strategy to Respond to Identified Risks |
We believe that our RCOI was reasonably designed and executed in good faith to determine the existence and source of conflict minerals in our supply chain, including from recycled or scrap sources (as defined in Item 1.01(d)(6) of Form SD). We utilized the CMRT template for our RCOI. We conducted our effort to send surveys in good faith, utilizing up to three rounds of communications with our suppliers. We evaluated survey responses to identify: (i) the use and source of conflict minerals; and (ii) any warning signs indicating that conflict minerals may have come from a Covered Country. We intend to make additional inquiries on a case-by-case basis during 2016 to clarify or obtain more information as necessary. We tracked results of our supply chain diligence process and periodically reported the results to our executive leadership team.
Because of Powell’s size, the complexity of its products, and the depth, breadth, and constant evolution of its supply chain, it is difficult to identify parties upstream from its direct suppliers. Powell continues to work with suppliers to identify the upstream sources of its conflict minerals through the CMRTs, follow up on invalid responses on the CMRTs, use of a risk-based assessment of identified smelters and assessment of the conflict minerals programs of its suppliers, as described below in this Report. Information and findings from this process are stored in a database that can be tracked and audited.
Certain of the responses to the surveys included the names of facilities listed by the suppliers as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. We and our consultant compared these facilities listed in the responses to the list of smelters maintained by the Conflict-Free Sourcing Initiative (CFSI) and, if a supplier indicated that the facility was certified as “Conflict-Free,” we confirmed that the name was listed by CFSI.
In accordance with OECD Guidance, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free pose a significant risk to the supply chain. In the Assent Compliance Manager, risk is classified as High, Medium and Low; this risk rating is generated based on 3 scoring criteria:
| 1) | Regulated Body: this assesses whether the smelter is a member and has an associated regulated body number (Smelter CID Number is the primary method). |
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| 2) | Proximity: Level 1 Country: Countries with known active ore production for tin or tantalum that are not identified as conflict regions or plausible countries that smuggle or export materials containing tin or tantalum. Examples include countries located in North or South America, Australia or Europe that are G8 Level Countries who are known to meet OECD standards in other sectors. Level 2 Country: Known or plausible countries that smuggle or export materials containing tin or tantalum out of Level 3 countries, or that have transit of materials containing tin or tantalum. This currently includes Kenya, Mozambique, and South Africa. Level 3 Country: The DRC and its nine adjoining countries as outlined in Section 1502 of the Dodd Frank Act. These include Angola, Burundi, Central African Republic, DRC, Rwanda, South Sudan, Tanzania, Uganda and Zambia. |
| 3) | Likelihood: We also calculate supplier risk based on the chances that the supplier provides 3TG that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT. |
Powell does not have a direct relationship with conflict minerals smelters and refiners and, as a result, does not perform or direct audits of these entities within its supply chain. Powell captured smelter and refiner information as part of the CMRT, as some suppliers provided the names of facilities it used as smelters or refiners. Assent compared the facilities identified by the suppliers to the list of smelters maintained by the CFSI.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). At this stage in conflict minerals compliance it is well-known that many companies are in the middle of the process and do not have many answers beyond “unknown”. The criteria used to evaluate the strength of the program are:
A. Do you have a policy in place that includes DRC conflict-free sourcing?
E. Have you implemented due diligence measures for conflict-free sourcing?
H. Do you verify due diligence information received from your suppliers?
I. Does your verification process include corrective action management?
When suppliers meet or exceed those criteria (Yes to at least A, E, H, I) they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TG in our applicable products, including (1) seeking information about 3TG smelters and refiners in our supply chain by requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding CFSI lists, (3) conducting the due diligence review and (4) obtaining additional documentation and verification, as applicable. Our existing policy related to relevant documentation of our conflict mineral compliance process requires that documentation will be retained for a period of at least five years.
| D. | Implement Targeted Independent Third-Party Due Diligence |
We engaged Assent to assist in the RCOI, data collection and survey process. Assent supports industry associations that administer independent third-party smelter and refinery audit programs and encourages targeted suppliers and/or facilities to participate in comparable due diligence validation activities.
| E. | Report on Supply Chain Due Diligence |
We have responded to various customer requests for information regarding our conflict minerals determination.
Powell reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC. We also disclose our company policy with respect to conflict minerals on our website at www.powellind.com.
Due Diligence Results
While due diligence is ongoing and the information received continues to improve in quantity and quality, the majority of the responses received provided data at a company or divisional level or did not specify the smelters or refiners used for materials supplied to us. We have decided to disclose validated smelters provided to us by our supply chain. However, we cannot definitively determine whether any of the 3TG reported by the suppliers were contained in materials supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. As a result, we are unable to identify all smelters and refiners as well as all the countries of origin of the 3TG that are contained in the applicable products
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As of May 9th 2016, Powell validated 320 smelters or refiners identified within its supply chain. If a supplier indicated that the facility was certified as “conflict-free,” such status was confirmed by Assent if the facility was listed by the CFSI as certified.
Many suppliers within Powell’s supply chain are still unable to provide the smelters or refiners used for products supplied. Furthermore, many of the suppliers provided responses at the company or division level and indicated an “unknown” status in terms of determining the origin of conflict minerals. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our third party provider follows up on these, urging suppliers to resubmit with increased smelter information. There are still suppliers unable to provide the smelters or refiners used for materials supplied to us.
Appendix I lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix I any smelters or refiners that we have not been able to validate. Appendix I also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and CFSI. Powell supports the refinement and expansion of the list of participating smelters through our membership in the CFSI program.
The large majority of the responses received either provided data at a company or subsidiary level and chose not to provide information at the component level, or did not specify the smelters or refiners used for components supplied to Powell. Accordingly, we are unable to determine, in those cases, whether any of the 3TGs reported by the suppliers were contained in components or parts supplied to us, or to validate that any of the smelters or refiners identified are actually in our supply chain.
Steps to Improve Future Due Diligence and Supply Chain Risk Mitigation
Powell intends to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in its products could benefit armed groups in the Covered Countries:
| • | Include a conflict minerals flow-down clause in new or renewed supplier contracts. |
| • | Continue engagement with suppliers and direct them to training resources to increase the response rate and improve the content of the supplier survey responses. |
| • | Engage any suppliers found to be supplying Powell with conflict minerals to establish an alternative source of conflict minerals that does not support the conflict in the Covered Countries. |
| • | Define and improve best practices and build leverage over its supply chain in accordance with the OECD Guidance. |
Based on its due diligence process as of the date of this Report, Powell has found no instances where it was necessary to terminate a supplier contract or to find a replacement supply of any conflict minerals.
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|
Appendix I |
| Metal |
Smelter or Refiner Name |
Smelter Facility Location |
Conflict Free? | |||
| Gold | Advanced Chemical Company | UNITED STATES | ||||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Yes | |||
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | ||||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Yes | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Yes | |||
| Gold | Argor-Heraeus SA | SWITZERLAND | Yes | |||
| Gold | Asahi Pretec Corporation | JAPAN | Yes | |||
| Gold | Asahi Refining Canada Limited | CANADA | Yes | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES | Yes | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Yes | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||||
| Gold | Aurubis AG | GERMANY | Yes | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes | |||
| Gold | Bauer Walser AG | GERMANY | ||||
| Gold | Boliden AB | SWEDEN | Yes | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Yes | |||
| Gold | Caridad | MEXICO | ||||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Yes | |||
| Gold | Cendres + Métaux SA | SWITZERLAND | ||||
| Gold | Chimet S.p.A. | ITALY | Yes | |||
| Gold | Chugai Mining | JAPAN | ||||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||||
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF | ||||
| Gold | DODUCO GmbH | GERMANY | Yes | |||
| Gold | Dowa | JAPAN | Yes | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Yes | |||
| Gold | Elemetal Refining, LLC | UNITED STATES | Yes | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Yes | |||
| Gold | Faggi Enrico S.p.A. | ITALY | ||||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||||
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | ||||
| Gold | Geib Refining Corporation | UNITED STATES | ||||
| 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 | Yes | |||
| Gold | Heraeus Ltd. Hong Kong | CHINA | Yes | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Yes | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Yes | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Yes | |||
| Gold | Istanbul Gold Refinery | TURKEY | Yes | |||
| Gold | Japan Mint | JAPAN | Yes | |||
| Gold | Jiangxi Copper Company Limited | CHINA | Yes | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Yes | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Yes | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Yes | |||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||||
| Gold | Kazzinc | KAZAKHSTAN | Yes | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Yes | |||
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
|
|
Appendix I |
| Metal |
Smelter or Refiner Name |
Smelter Facility Location |
Conflict Free? | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes | |||
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA | ||||
| Gold | Lingbao Gold Company Limited | CHINA | ||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Yes | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||||
| Gold | Materion | UNITED STATES | Yes | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes | |||
| Gold | Metahub Industries Sdn. Bhd. | MALAYSIA | ||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Yes | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||||
| Gold | Metalor Technologies SA | SWITZERLAND | Yes | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES | Yes | |||
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Yes | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Yes | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Yes | |||
| Gold | Morris and Watson | NEW ZEALAND | ||||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Yes | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Yes | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||
| Gold | Nihon Material Co., Ltd. | JAPAN | Yes | |||
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Yes | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Yes | |||
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Yes | |||
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | ||||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Yes | |||
| Gold | PAMP SA | SWITZERLAND | Yes | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Yes | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes | |||
| Gold | PX Précinox SA | SWITZERLAND | Yes | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Yes | |||
| Gold | Republic Metals Corporation | UNITED STATES | Yes | |||
| Gold | Royal Canadian Mint | CANADA | Yes | |||
| Gold | SAAMP | FRANCE | ||||
| Gold | Sabin Metal Corp. | UNITED STATES | ||||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | ||||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Yes | |||
| Gold | SEMPSA Joyería Platería SA | SPAIN | Yes | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Yes | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Yes | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN | Yes | |||
| Gold | So Accurate Group, Inc. | UNITED STATES | ||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Yes | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes | |||
| Gold | Sudan Gold Refinery | SUDAN | ||||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Yes |
|
|
Appendix I |
| Metal |
Smelter or Refiner Name |
Smelter Facility Location |
Conflict Free? | |||
| Gold | T.C.A S.p.A | ITALY | Yes | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Yes | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Yes | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Yes | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||||
| Gold | Tony Goetz NV | BELGIUM | ||||
| Gold | Torecom | KOREA, REPUBLIC OF | ||||
| Gold | Umicore Brasil Ltda. | BRAZIL | Yes | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Yes | |||
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Yes | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes | |||
| Gold | Valcambi SA | SWITZERLAND | Yes | |||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | ||||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes | |||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Yes | |||
| Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM | ||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Yes | |||
| Tantalum | D Block Metals, LLC | UNITED STATES | Yes | |||
| Tantalum | Duoluoshan | CHINA | Yes | |||
| Tantalum | E.S.R. Electronics | UNITED STATES | ||||
| Tantalum | Exotech Inc. | UNITED STATES | Yes | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Yes | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Yes | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Yes | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Yes | |||
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | ||||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Yes | |||
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Yes | |||
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Yes | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Yes | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES | Yes | |||
| Tantalum | H.C. Starck Ltd. | JAPAN | Yes | |||
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Yes | |||
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Yes | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Yes | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | KEMET Blue Metals | MEXICO | Yes | |||
| Tantalum | KEMET Blue Powder | UNITED STATES | Yes | |||
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Yes | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Yes | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes | |||
| Tantalum | Mineração Taboca S.A. | BRAZIL | Yes | |||
| Tantalum | Mitsui Mining & Smelting | JAPAN | Yes | |||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Yes | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes |
|
|
Appendix I |
| Metal |
Smelter or Refiner Name |
Smelter Facility Location |
Conflict Free? | |||
| Tantalum | Plansee SE Liezen | AUSTRIA | Yes | |||
| Tantalum | Plansee SE Reutte | AUSTRIA | Yes | |||
| Tantalum | QuantumClean | UNITED STATES | Yes | |||
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Yes | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Yes | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Yes | |||
| Tantalum | Taki Chemicals | JAPAN | Yes | |||
| Tantalum | Telex Metals | UNITED STATES | Yes | |||
| Tantalum | Tranzact, Inc. | UNITED STATES | Yes | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Yes | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Yes | |||
| Tantalum | Zhuzhou Cemented Carbide | CHINA | Yes | |||
| Tin | Alpha | UNITED STATES | Yes | |||
| Tin | An Thai Minerals Company Limited | VIET NAM | ||||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||||
| Tin | Chenzhou Yun Xiang mining limited liability company | CHINA | ||||
| Tin | China Tin Group Co., Ltd. | CHINA | Yes | |||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Yes | |||
| Tin | CV Ayi Jaya | INDONESIA | Yes | |||
| Tin | CV Dua Sekawan | INDONESIA | ||||
| Tin | CV Gita Pesona | INDONESIA | Yes | |||
| Tin | CV Serumpun Sebalai | INDONESIA | Yes | |||
| Tin | CV Tiga Sekawan | INDONESIA | ||||
| Tin | CV United Smelting | INDONESIA | Yes | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Yes | |||
| Tin | Dowa | JAPAN | Yes | |||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||||
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Yes | |||
| Tin | EM Vinto | BOLIVIA | Yes | |||
| Tin | Estanho de Rondônia S.A. | BRAZIL | ||||
| Tin | Feinhütte Halsbrücke GmbH | GERMANY | ||||
| Tin | Fenix Metals | POLAND | Yes | |||
| Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | ||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Yes | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Yes | |||
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | ||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Yes | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes | |||
| Tin | Melt Metais e Ligas S/A | BRAZIL | Yes | |||
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA | ||||
| Tin | Metallic Resources, Inc. | UNITED STATES | Yes | |||
| Tin | Metallo-Chimique N.V. | BELGIUM | Yes | |||
| Tin | Mineração Taboca S.A. | BRAZIL | Yes | |||
| Tin | Minsur | PERU | Yes | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Yes | |||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | ||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
|
|
Appendix I |
| Metal |
Smelter or Refiner Name |
Smelter Facility Location |
Conflict Free? | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Yes | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Yes | |||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Yes | |||
| Tin | Phoenix Metal Ltd. | RWANDA | ||||
| Tin | PT Alam Lestari Kencana | INDONESIA | ||||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Yes | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Yes | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Yes | |||
| Tin | PT Bangka Kudai Tin | INDONESIA | ||||
| Tin | PT Bangka Prima Tin | INDONESIA | Yes | |||
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | ||||
| Tin | PT Bangka Tin Industry | INDONESIA | Yes | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Yes | |||
| Tin | PT BilliTin Makmur Lestari | INDONESIA | Yes | |||
| Tin | PT Bukit Timah | INDONESIA | Yes | |||
| Tin | PT Cipta Persada Mulia | INDONESIA | Yes | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Yes | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Yes | |||
| Tin | PT Fang Di MulTindo | INDONESIA | ||||
| Tin | PT Inti Stania Prima | INDONESIA | Yes | |||
| Tin | PT Justindo | INDONESIA | Yes | |||
| Tin | PT Karimun Mining | INDONESIA | ||||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | ||||
| Tin | PT Mitra Stania Prima | INDONESIA | Yes | |||
| Tin | PT Panca Mega Persada | INDONESIA | Yes | |||
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | ||||
| Tin | PT Prima Timah Utama | INDONESIA | Yes | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Yes | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Yes | |||
| Tin | PT Seirama Tin Investment | INDONESIA | ||||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Yes | |||
| Tin | PT Sukses Inti Makmur | INDONESIA | Yes | |||
| Tin | PT Sumber Jaya Indah | INDONESIA | Yes | |||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Yes | |||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Yes | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Yes | |||
| Tin | PT Tirus Putra Mandiri | INDONESIA | ||||
| Tin | PT Tommy Utama | INDONESIA | Yes | |||
| Tin | PT Wahana Perkit Jaya | INDONESIA | Yes | |||
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Yes | |||
| Tin | Rui Da Hung | TAIWAN | Yes | |||
| Tin | Soft Metais Ltda. | BRAZIL | Yes | |||
| Tin | Thaisarco | THAILAND | Yes | |||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Yes | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Yes | |||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes | |||
| Tungsten | ACL Metais Eireli | BRAZIL | ||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Yes | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Yes | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
|
|
Appendix I |
| Metal |
Smelter or Refiner Name |
Smelter Facility Location |
Conflict Free? | |||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | ||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | ||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | ||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | H.C. Starck GmbH | GERMANY | Yes | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Yes | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Yes | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA | ||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Yes | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Yes | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | ||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Yes | |||
| 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 Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||||
| Tungsten | Kennametal Fallon | UNITED STATES | ||||
| Tungsten | Kennametal Huntsville | UNITED STATES | Yes | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | ||||
| Tungsten | Niagara Refining LLC | UNITED STATES | Yes | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Yes | |||
| Tungsten | Philippine Chuangin Industrial Co., Inc. | PHILIPPINES | Yes | |||
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | ||||
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM | ||||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Yes | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Yes | |||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes | |||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |