Document



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, 2017.
 
 
 
____________________________________________________________________________________________________________




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, 2017.
For the year 2017, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs, as defined below, are necessary to their functionality or production (“Covered Products”). Conflict minerals are defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (together with gold collectively referred to as 3TGs), or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo ("DRC") or any adjoining country that shares an internationally recognized border with the DRC. Accordingly, we have conducted a reasonable country of origin inquiry that was designed to determine whether any of the 3TGs in our Covered Products originated in the DRC or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia), or were from recycled 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
 
 






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.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Date: May 30, 2018
 
 
By:
/s/ DON R. MADISON
 
 
 
 
Don R. Madison
Executive Vice President
 
 
 
 
Chief Financial and Administrative Officer
(Principal Financial Officer)


Exhibit

Exhibit 1.01
Conflict Minerals Report
For the Year Ended December 31, 2017

This is the Conflict Minerals Report (this Report) of Powell Industries, Inc. (referred to herein as Powell, the Company, we, us or our) for calendar year 2017 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, 2017 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. For the purposes of this Report, tin, tantalum, tungsten and gold shall be collectively referred to as the 3TGs. These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.

Company Overview
We develop design, manufacture and service custom-engineered equipment and systems for the distribution, control and monitoring of electrical energy designed to (1) distribute, control and monitor the flow of electrical energy and (2) provide protection to motors, transformers and other electrically powered equipment. Our principal products include integrated power control room substations (PCRs®), custom-engineered modules, electrical houses (E-Houses), traditional and arc-resistant distribution switchgear and control gear, medium-voltage circuit breakers, monitoring and control communications systems, motor control centers and bus duct systems. These products are designed for application voltages ranging from 480 volts to 38,000 volts and are used in oil and gas refining, offshore oil and gas production, petrochemical, pipeline, terminal, mining and metals, light rail traction power, electric utility, pulp and paper and other heavy industrial markets. Our product scope includes designs tested to meet both U.S. standards (ANSI) and international standards (IEC). We assist customers by providing value-added services such as spare parts, field service inspection, installation, commissioning, modification and repair, retrofit and retrofill components for existing systems and replacement circuit breakers for switchgear that is obsolete or that is no longer produced by the original manufacturer. We seek to establish long-term relationships with the end users of our systems as well as the design and construction engineering firms contracted by those end users.

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 2017. Once the filtering was completed, we populated the list with contact information. This list, composed of 896 suppliers, was then provided to Assent for upload to their Assent Compliance Manager software system (the Assent Compliance Manager).
Assent conducted the supplier survey portion of the RCOI. The supplier survey utilized a template developed by the Responsible Business Alliance® and The Global e-Sustainability Initiative (RBA/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.



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 with Powell procurement team members copied, 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 an Assent’s learning management system, Assent University. All in-scope suppliers were provided access to the Conflict Minerals Training course and this training was monitored and tracked in Assent's system for future reporting and transparency.
Due Diligence Process
Powell’s due diligence measures have been designed to conform, in all material respects, with the framework in the Organization 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 2017, 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 in-scope suppliers our efforts to comply with Section 1502 of the Dodd-Frank Act pursuant to a compliance statement and other communications (together, the “Compliance Statement”). We requested that our in-scope suppliers provide a comprehensive conflict minerals declaration for all conflict minerals in the form of the CMRT v.5.01 or higher. 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). 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. Select the section entitled “Our Company”, then “Supply Chain.”
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 Supply Chain Director, Corporate Controller, Vice President of Research and Product Development, and Category 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 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 CMRTs. 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. Our emergency contact number can be found at www.powellind.com under the section entitled “Contact Us.”
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.

Each facility that meets the Responsible Minerals Initiative (RMI) definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidances: Assent uses 3 factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags.
1.
Geographic proximity to the DRC and other Covered Countries;
2.
Responsible Minerals Assurance Process (RMAP) audit status;
3.
Credible evidence of unethical or conflict sourcing.

Based on this criteria the following facilities have been identified as being of highest concern to the supply chain:
Tony Goetz NV - CID002587
Kaloti Precious Metals - CID002563
African Gold Refinery Limited (AGR) - CID003185
Universal Precious Metals Refining Zambia - CID002854
Fidelity Printers and Refiners - CID002515
Sudan Gold Refinery - CID002567
As part of our risk management plan under the OECD Guidance, when a facility is reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, submissions that include any reported facilities produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Powell. As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context.

In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
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 the 3TGs 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 v5.01 or higher 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 the 3TGs; and (ii) any warning signs indicating that conflict minerals may have come from one of the Covered Countries. We intend to make additional inquiries on a case-by-case basis during 2018 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 the 3TGs 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 the Assent Compliance Manager, 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 Responsible Minerals Initiative (RMI) and, if a supplier indicated that the facility was certified as “Conflict-Free,” we confirmed that the name was listed by RMI.
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 based on the three scoring criteria that we outlined in the previous section.
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. Have you established a conflict minerals sourcing policy?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Do you review due diligence information received from your suppliers against your company’s expectations?
H. Does your review process include corrective action management?
When suppliers meet or exceed those criteria (Yes to at least A, E, G, H) 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 3TGs 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 RMI lists, (3) conducting the due diligence review and (4) obtaining additional documentation and verification, as applicable. As mentioned above, 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. Select the section entitled “Our Company”, then “Supply Chain.”
Due Diligence Results    
For the 2017 reporting year, Powell received CMRT forms from 70% of the suppliers surveyed. All submitted forms were 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 16, 2018, there were 15 invalid supplier submissions.

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 specifically 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 3TGs 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 3TGs that are contained in the applicable products

As of May 16, 2018, Powell validated 321 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 RMI 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 the 3TGs. 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 Assent 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.

In cases where any red-flagged smelters were reported on a CMRT by a supplier, risk mitigation activities were initiated. Through Assent, the suppliers were asked to submit a product-level CMRT to better identify the connection between the smelters or refiners they listed and the products they provide to us. Suppliers were also guided to Assent University where they were provided with educational materials on mitigating the risk of smelters or refiners in the supply chain.

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 II 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 RMI. Powell supports the refinement and expansion of the list of participating smelters through our membership in the RMI 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 our due diligence process as of the date of this Report, we have found no instances where it was necessary to terminate a supplier contract or to find a replacement supply of any conflict minerals.
















Appendix I
Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Gold
Abington Reldan Metals, LLC
UNITED STATES
CID002708
Gold
Advanced Chemical Company
UNITED STATES
CID000015
Gold
African Gold Refinery
UGANDA
CID003185
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
CID002560
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
CID000058
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Gold
Asahi Refining USA Inc.
UNITED STATES
CID000920
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Gold
Aurubis AG
GERMANY
CID000113
Gold
Bangalore Refinery
INDIA
CID002863
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Gold
Boliden AB
SWEDEN
CID000157
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Gold
Caridad
MEXICO
CID000180
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Gold
Cendres + Métaux S.A.
SWITZERLAND
CID000189
Gold
Chimet S.p.A.
ITALY
CID000233
Gold
Chugai Mining
JAPAN
CID000264
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Gold
Dowa
JAPAN
CID000401
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
CID003195
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID000425
Gold
Elemetal Refining, LLC
UNITED STATES
CID001322
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002852
Gold
Geib Refining Corporation
UNITED STATES
CID002459
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909



Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000651
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
Gold
HeeSung
KOREA, REPUBLIC OF
CID000689
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
CID000778
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Gold
Italpreziosi
ITALY
CID002765
Gold
Japan Mint
JAPAN
CID000823
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
Gold
Kazzinc
KAZAKHSTAN
CID000957
Gold
Kennecott Utah Copper LLC
UNITED STATES
CID000969
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002511
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID002865
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
Gold
L'Orfebre S.A.
ANDORRA
CID002762
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Gold
Marsam Metals
BRAZIL
CID002606
Gold
Materion
UNITED STATES
CID001113
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Gold
Metalor USA Refining Corporation
UNITED STATES
CID001157



Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
CID001161
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Gold
Morris and Watson
NEW ZEALAND
CID002282
Gold
Morris and Watson Gold Coast
AUSTRALIA
CID002866
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
CID001220
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Gold
NH Recytech Company
KOREA, REPUBLIC OF
CID003189
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Gold
PAMP S.A.
SWITZERLAND
CID001352
Gold
Pease & Curren
UNITED STATES
CID002872
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Gold
Planta Recuperadora de Metales SpA
CHILE
CID002919
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Gold
PX Précinox S.A.
SWITZERLAND
CID001498
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID000522
Gold
Remondis Argentia B.V.
NETHERLANDS
CID002582
Gold
Republic Metals Corporation
UNITED STATES
CID002510
Gold
Royal Canadian Mint
CANADA
CID001534
Gold
SAAMP
FRANCE
CID002761
Gold
Sabin Metal Corp.
UNITED STATES
CID001546
Gold
Safimet S.p.A
Italy
CID002973
Gold
SAFINA A.S.
CZECH REPUBLIC
CID002290
Gold
Sai Refinery
INDIA
CID002853
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
CID001562
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Gold
Schone Edelmetaal B.V.
NETHERLANDS
CID001573
Gold
SEMPSA Joyería Platería S.A.
SPAIN
CID001585
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Gold
Singway Technology Co., Ltd.
TAIWAN
CID002516



Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Gold
Solar Applied Materials Technology Corp.
TAIWAN
CID001761
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID003153
Gold
Sudan Gold Refinery
SUDAN
CID002567
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Gold
SungEel HiTech
KOREA, REPUBLIC OF
CID002918
Gold
T.C.A S.p.A
ITALY
CID002580
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Gold
Tony Goetz NV
BELGIUM
CID002587
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Gold
United Precious Metal Refining, Inc.
UNITED STATES
CID001993
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
CID002854
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
CID002030
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
CID002100
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000092
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Tantalum
D Block Metals, LLC
UNITED STATES
CID002504
Tantalum
Duoluoshan
CHINA
CID000410
Tantalum
Exotech Inc.
UNITED STATES
CID000456
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002505
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
CID002557
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000291
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Tantalum
H.C. Starck Inc.
UNITED STATES
CID002548
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002512



Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID002842
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
CID003191
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002506
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Tantalum
KEMET Blue Powder
UNITED STATES
CID002568
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
CID000973
Tantalum
LSM Brasil S.A.
BRAZIL
CID001076
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001175
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001192
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Tantalum
NPM Silmet AS
ESTONIA
CID001200
Tantalum
Power Resources Ltd.
MACEDONIA
CID002847
Tantalum
QuantumClean
UNITED STATES
CID001508
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID002707
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
CID001522
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Tantalum
Taki Chemicals
JAPAN
CID001869
Tantalum
Telex Metals
UNITED STATES
CID001891
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
CID002307
Tin
Alpha
UNITED STATES
CID000292
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID003190
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
CID000278
Tin
CV Ayi Jaya
INDONESIA
CID002570
Tin
CV Dua Sekawan
INDONESIA
CID002592
Tin
CV Gita Pesona
INDONESIA
CID000306
Tin
CV Tiga Sekawan
INDONESIA
CID002593
Tin
CV United Smelting
INDONESIA
CID000315
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Tin
Dowa
JAPAN
CID000402
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID002572
Tin
EM Vinto
BOLIVIA
CID000438
Tin
Estanho de Rondônia S.A.
BRAZIL
CID000448
Tin
Fenix Metals
POLAND
CID000468
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Tin
Gejiu Jinye Mineral Company
CHINA
CID002859
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908



Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CHINA
CID003116
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
CID000244
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Tin
Metallic Resources, Inc.
UNITED STATES
CID001142
Tin
Metallo Belgium N.V.
BELGIUM
CID002773
Tin
Metallo Spain S.L.U.
SPAIN
CID002774
Tin
Mineracao Taboca S.A.
BRAZIL
CID001173
Tin
Minsur
PERU
CID001182
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002858
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Tin
Operaciones Metalurgical S.A.
BOLIVIA
CID001337
Tin
Pongpipat Company Limited
MYANMAR
CID003208
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Tin
PT Bangka Serumpun
INDONESIA
CID003205
Tin
PT Bangka Tin Industry
INDONESIA
CID001419
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Tin
PT Bukit Timah
INDONESIA
CID001428
Tin
PT DS Jaya Abadi
INDONESIA
CID001434
Tin
PT Eunindo Usaha Mandiri
INDONESIA
CID001438
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Tin
PT Karimun Mining
INDONESIA
CID001448
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002870
Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Tin
PT O.M. Indonesia
INDONESIA
CID002757
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Tin
PT Premium Tin Indonesia
INDONESIA
CID000313
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816



Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
CID001477
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
CID001482
Tin
PT Tinindo Inter Nusa
INDONESIA
CID001490
Tin
PT Tommy Utama
INDONESIA
CID001493
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Tin
Rui Da Hung
TAIWAN
CID001539
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Tin
Super Ligas
Brazil
CID002756
Tin
Thaisarco
THAILAND
CID001898
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
CID002036
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
CID000004
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002645
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
CID002536
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
CID000568
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
CID002542
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID002541
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID003182
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002647
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
CID002535
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Tungsten
Kennametal Fallon
UNITED STATES
CID000966
Tungsten
Kennametal Huntsville
UNITED STATES
CID000105
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319



Tungsten
Moliren Ltd
RUSSIAN FEDERATION
CID002845
Tungsten
Niagara Refining LLC
UNITED STATES
CID002589
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
CID002543
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID002815
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
CID002011
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
CID002044
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095









































Appendix II

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil,  Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zimbabwe