UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
AudioCodes Ltd.
(Exact name of registrant as specified in
its charter)
| ISRAEL |
|
0-30070 |
| (State or other jurisdiction of |
|
(Commission file number) |
| incorporation or organization) |
|
|
Hayarden St. 1, Airport City, Lod, Israel
7019900
(Address of principal executive offices)
Lior Aldema, 972-3-9764000
(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,
2014.
Section 1 – Conflict Minerals
Disclosure
This Specialized Disclosure Report on Form
SD (“Form SD”) of AudioCodes Ltd. (“AudioCodes,” “we,” “us,” or “our”)
for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.
Item 1.01. Conflict Minerals Disclosure
and Report
AudioCodes evaluated its current product
lines and determined that certain products we manufacture or contract to manufacture contain tin, tungsten, tantalum and/or gold,
which are defined as “conflict minerals” by the United States Securities and Exchange Commission, that are necessary
to the functionality or production of our products. Accordingly, AudioCodes is filing this disclosure along with a Conflict Minerals
Report to disclose the measures we have taken to determine the origin of the conflict minerals used in our products.
Conflict Minerals Disclosure
We undertook due diligence measures, including
surveying our direct suppliers through an industry-standard survey template for conflict minerals, to try to determine the sources
of these minerals, which we purchase through a complex supply chain. Currently, we do not have sufficient information from our
suppliers or other sources to determine the country of origin of the conflict minerals used in our products or identify the facilities
used to process those conflict minerals. Thus, we have determined that our supply chain is “DRC conflict undeterminable”
(as defined in Form SD).
A copy of our Conflict Minerals Report
is filed as Exhibit 1.01 hereto. Our Conflict Minerals Report, as well as our Conflict Minerals Policy, are publicly available
on our website at http://www.audiocodes.com/sustainability under the heading "About Us-AudioCodes Going Sustainable".
Except as expressly provided herein, the information on, or that can be accessed through, our website is not part of this Form
SD.
Item 1.02 Exhibit
See Item 2.01 below.
Section 2 –
Exhibits
Item 2.01. Exhibits
Exhibit 1.01 - Conflict Minerals Report
as required by Items 1.01 and 1.02 of this Form.
Signatures
Pursuant to the requirements of the Securities
Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
AUDIOCODES LTD.
By: /s/ Lior Aldema
Name: Lior Aldema
Title: Chief Operating Officer and Head
of Global Sales
May 26, 2015
Exhibit 1.01
AudioCodes Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2014
This is the Conflict Minerals Report for AudioCodes
Ltd. (herein referred to as “AudioCodes,” “we,” “us” or “our”) filed with the United
States Securities and Exchange Commission (“SEC”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934,
as amended (the “Rule”) for the reporting period from January 1, 2014 to December 31, 2014. The Rule was adopted by
the SEC to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street
Reform and Consumer Protection Act of 2010. The Rule 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 purpose of this assessment.
If a registrant can establish that the conflict minerals
in its products originated from sources other than the Democratic Republic of the Congo (“DRC”) or an adjoining country
(the “Covered Countries”), or from recycled and scrap sources, the registrant must submit a specialized disclosure
report under Form SD that describes the steps that the registrant took to determine the origin of the conflict minerals in its
products.
If a registrant has reason to believe that any of
the conflict minerals in its supply chain may have originated in a Covered Country, or if the registrant is unable to determine
the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’
source and chain of custody, and the registrant must annually submit a Conflict Minerals Report to the SEC that includes a description
of those due diligence measures.
The report presented herein is not audited by an independent
private sector auditor because the Rule provides that if a registrant’s products are “DRC conflict undeterminable”
in 2013 or 2014, then such audit is not required.
This report has been prepared by AudioCodes. The information
includes the activities of all of our majority-owned subsidiaries that are required to be consolidated.
AudioCodes designs, develops and sells products and
services for voice and data over packet networks. In broad terms, voice over packet, or VoP, networks consist of key network elements
such as software switches, application servers, IP phones, media gateways and session border controllers (“SBC”). Our
products primarily provide the media gateway and SBC element in the network, as well as voice over Internet protocol, or VoIP,
end-points such as IP Phones and VoIP mobile clients.
Our principal hardware product lines are essentially
classified into the following categories: signal processor chips, media gateways, enterprise session border controllers, multi-service
business routers, IP phones and media servers.
Because our supply chain is complex, AudioCodes relies
upon our suppliers to provide information with respect to the origin of the conflict minerals contained in components and materials
supplied to us, including sources of conflict minerals that are supplied to them from sub-tier suppliers. Our suppliers are expected
to provide conflict minerals sourcing information to us pursuant to our Conflict Minerals Policy.
We have performed a comprehensive analysis of the
components used in our products, and the role that suppliers play throughout our manufacturing and product delivery processes.
We defined the scope of our conflict minerals due diligence by identifying and contacting our current suppliers that provide components
or engage in manufacturing activities that are likely to contain conflict minerals. We adopted the standard Conflict Mineral reporting
templates (“CMRT”) established by the Conflict Free Sourcing Initiative (“CFSI”), and sent our conflict
minerals due diligence communication survey to these suppliers.
With respect to the Organization for Economic Cooperation
and Development (“OECD”) requirement to strengthen engagement with suppliers, we have engaged a third party data collection
vendor to conduct, collect and archive suppliers’ responses. Feedback from this engagement has allowed us to render the conclusions
and statements in this report.
| 5. | Reasonable Country of Origin Inquiry (“RCOI”) and RCOI conclusion |
| 5.1 | We conducted an analysis of our products and found that “conflict minerals”, as defined under the Rule (including
tin, tantalum, tungsten and gold) can be found in our products and are necessary to the functionality or production of those products.
Therefore, we are subject to the reporting obligations of the Rule. |
| 5.2 | A list of all the suppliers and manufacturers AudioCodes contracts with to purchase all the
items constructing its products was prepared by the Purchasing Department. The list was then reviewed and non-relevant suppliers
and manufacturers were deleted (suppliers/manufacturers of items which definitely do not contain tin, tantalum, tungsten or gold).
The final list was evaluated by Purchasing Director and Director of Quality Assurance, Environment
& Safety. |
| 5.3 | Due to the breadth and complexity of AudioCodes’ products and supply chain, it will take time for many of our suppliers
to verify the origin of all conflict minerals. Using our supply chain due diligence processes and efforts, we hope to further develop
transparency into our supply chain. |
| 5.4 | Steps conducted this year include: |
| a. | Performed internal applicability assessments of products and suppliers to determine which contain or may contain necessary
conflict minerals. |
| § | Solicitation of survey responses from relevant suppliers. |
| § | Assessment of suppliers responses - identify inconsistent, incomplete,
or inaccurate responses. |
| § | Engaging Purchasing Department to directly contact and push non-responsive
suppliers. |
| § | As part of our validation process, we sent training materials to suppliers,
including an overview of the law and instructions on how to complete the Conflict Minerals Reporting Template, if relevant. |
| 5.5 | Currently, we do not have sufficient information from our suppliers to determine the country of origin of the conflict minerals
used in our products or the facilities used to process those conflict minerals. Therefore, we cannot exclude the possibility that
some of these conflict minerals may have originated in the Democratic Republic of the Congo or an adjoining country and are not
from recycled or scrap sources. Based on this result, AudioCodes conducted due diligence activities and have described these activities
in this Conflict Minerals Report. |
| 6.1 | Our due diligence processes and efforts have been developed in conjunction with the OECD Due Diligence Guidance for Responsible
Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the related Supplements for gold and
for tin, tantalum and tungsten. |
| 7. | Due Diligence Performed |
| 7.1 | Establish Strong Company Management Systems |
| 7.1.1 | Conflict Minerals Policy |
AudioCodes is committed to working with our global
supply chain to ensure compliance with the SEC’s conflict minerals rules. Our conflict minerals policy is publicly available
on our website at http://www.audiocodes.com/sustainability under the heading "Conflict
Minerals”.
AudioCodes has established a task force with representatives
from our Legal, Finance, Purchasing and Quality departments to implement our conflict minerals compliance policy. Senior management
is briefed about the results of our due diligence efforts on a regular basis.
AudioCodes has established our due diligence compliance
process and set forth documentation and record maintenance mechanisms to ensure the retention of relevant documentation in a structured
electronic database. Database content enables real-time identification of all countries of origin of the minerals as well as the
smelters/refiners status. Since our databases are continuously backed up, this data retention assures availability with no time
limitation.
Company level CMRT are amended on a monthly basis,
as our sub-contractor collects new and/or corrected suppliers’ reports. AudioCodes makes its latest company level CMRT available
to its customers upon request.
AudioCodes amended its Requirements from AudioCodes’
Suppliers Process Specification (P-08-03E) to include a paragraph detailing our mandatory requirement to comply with the Rule
and to strictly follow the framework established by the OECD. This Process Specification is referenced in each Purchase Order issued
to our suppliers, and is also available in AudioCodes’ website.
Grievance mechanism & reporting are
defined in the company Policy.
| 7.2 | Identify and Assess Risk in the Supply Chain |
| 7.2.1 | AudioCodes' risk analysis efforts address the information assessed within the risk analysis tool. For example: while trying
to move towards the goal of being a conflict minerals free company, we assessed two primary risks in our supply chain: (1)
the risk of not receiving on time accurate information from the supplier; and (2) the risk of not being able to replace a supplier.
The result was the segmentation of the suppliers into 3 levels of risks: high, medium and low, allowing the Company to focus its
risk mitigation efforts according to the supplier level of risk. |
| 7.3 | Design and Implement Strategy to Respond to Risks |
| 7.3.1 | Suppliers are requested to supply their conflict minerals compliance declarations using the CMRT template. Such declarations
are reviewed by AudioCodes (or its assigned sub-contractor) and verified for completeness and inconsistency. |
| 7.3.2 | Any declaration determined to be inconsistent or missing data is returned to the supplier to correct and complete. |
| 7.3.3 | Under this activity we also track smelters/refiners that have not received a conflict-free designation based on the CFSI/CFSP
or other independent third party validation program, and also compare smelters/refiners identified by the supply chain survey against
the list of facilities that have received a “conflict free” designation. |
| 7.3.4 | Red Flags analysis on the topics listed below were defined to better identify suspicious behavior and activities: |
| b. | Locations of mineral origin |
| c. | Existence of Company Policy |
| 7.4 | Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Point in the Supply Chain |
| 7.4.1 | AudioCodes does not have a direct relationship with smelters and refiners of conflict minerals, nor do we perform direct audits
of these entities that provide our supply chain with conflict minerals. However we do rely upon the industry efforts and tools
(for example, the CFSI Conflict Minerals Reporting Template) in our evaluations. |
| 7.5 | Report Annually on Supply Chain Due Diligence |
| 7.5.1 | AudioCodes’ CMRT is amended on a monthly basis and is available to all requestors. The company’s annual Conflict
Minerals Report is downloadable from AudioCodes’ website, at http://www.audiocodes.com/sustainability under the heading "Conflict
Minerals”, and filed with the SEC on Form SD. |
| 8.1.1 | Because of our size, the breadth and complexity of our products, and constant changes to our supply chain, it is difficult
to identify entities downstream from our direct suppliers. We are relying on our direct suppliers to provide us with information
about the source of conflict minerals contained in the components supplied to us. Our direct suppliers are similarly reliant upon
information provided by their suppliers. |
| 8.1.2 | Despite receiving responses from suppliers listing smelter or refiner names in their supply chain, a few suppliers were unable
to accurately report which specific smelters were part of the supply chain of the components that were sold to AudioCodes in 2014.
Therefore, we are not able to determine the facilities that processed the conflict minerals in such products. |
| 8.1.3 | We received responses from more than 80% of the suppliers surveyed. We reviewed the responses against criteria developed to
determine which required further engagement with our suppliers. These criteria included untimely or incomplete responses, as well
as inconsistencies within the data reported in the Template. We are working directly with these suppliers to have them provide
revised responses. |
| 8.1.4 | Most CMRTs were reported at the company level, see table below. |
| Declaration Scopes of Delivered Consolidated Manufacturers |
| Reported at company level |
85% |
| Reported user defined |
4% |
| Reported product list/product |
11% |
| 8.1.5 | As of today, the 80% responses received from our suppliers can be further categorized as in the table below. CMRTs with major
issues are CMRTs with significant incompleteness, inaccuracy, or contradictory information submitted. For example, tantalum, tin,
gold, or tungsten was declared used but no smelters were entered for these metals. A CMRT which was escalated is a CMRT of manufacturer
with at least one or multiple escalations (no major issues). |
| Consolidated Manufacturers Sub-Collection Status |
| MFRs delivered satisfactory CMRT |
32% |
| MFRs delivered CMRT with major issues |
52% |
| MFRs whose CMRT was escalated* |
11% |
| MFRs still in process |
6% |
| * | MFR with at least one or multiple escalations (no major issues). Escalated by the subcontractor to AudioCodes to supply better/correct
contact information, to contact the manufacturer directly, etc. due to manufacturer’s poor responsiveness. |
| 8.1.6 | The smelters analysis of those 80% responsive manufacturers is given below. The list of smelters is set forth in the attached
Appendix A. The list of mines’ countries of origin is set forth in the attached Appendix B. |
| Smelters Analysis |
| With Certification |
| Certified Smelters - CFSP/RJC/LBMA/DMCC* |
58% |
| Non-Certified Smelters - CFSP/RJC/LBMA/DMCC* |
42% |
| Legitimacy |
| Alleged Smelters - FSI/RJC/LBMA/DMCC/DOC/APPLE/INTEL/GS* |
90% |
| Unknown Smelters |
10% |
| * | Initials of credible sources for conflict minerals information (organizations or company names). |
| 8.1.7 | Based on the information obtained through the due diligence process, AudioCodes does not have sufficient information as yet
to determine the country of origin of all the conflict minerals contained in our products. |
| 8.1.8 | The large majority of the responses received provided data at a company or divisional level or, as described above, were unable
to specify the smelters or refiners used for components supplied to AudioCodes. We are therefore unable to determine whether any
of the conflict minerals reported by the suppliers were contained in components or parts supplied to us or to validate that any
of these smelters or refiners are actually in our supply chain. |
| 8.1.9 | Information gathered from our suppliers is not on a continuous, real-time basis, (since according to the Rule a product would
“not be found to be DRC conflict free” if it does not meet the required standard for even one day of the reporting
year). |
| 8.1.10 | The Company can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the necessary
conflict minerals, since the information comes from: direct and secondary suppliers and independent third party audit programs. |
| 8.2 | Efforts to Determine Country of Origin of Mine or Conflict Minerals |
| 8.2.1 | Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. By adopting
a methodology based on the OECD guidelines and the CFSI template, we have determined that the information we gathered from the
smelters and refiners in our supply chain represents the most reasonable known mine of origin information available to us. |
| 9. | Continuous Improvement Efforts to Mitigate Risks |
| 9.1 | AudioCodes will engage with suppliers who may be sourcing from non-conflict free smelters to move towards using conflict free
smelters within a reasonable time frame. The time frame will be dependent on the criticality of the specific component and the
availability of alternative suppliers. |
| 9.2 | AudioCodes will continue implementing risk mitigation actions such as: follow up letters to high risk non responsive suppliers;
and follow up letters to suppliers with conflict minerals from the Covered Countries from non-certified smelters. |
| 9.3 | AudioCodes will examine the possibility of establishing new terms and conditions in supplier contracts that stipulate responses
to conflict mineral related inquires. |
| 10. | Cautionary Statement Concerning Forward-Looking Statements |
This Report contains “forward-looking statements”
within the meaning of U.S. federal securities laws. These forward-looking statements can generally be identified as such because
the context of the statement will include words such as “may”, “will,” “intends,” “plans,”
“believes,” “anticipates,” “expects,” “estimates,” “predicts,” “potential,”
“continue,” or “opportunity,” the negative of these words or words of similar import. Examples of forward-looking
statements include statements relating to our future plans, and any other statement that does not directly relate to any historical
or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate.
Forward-looking statements are subject to risks, uncertainties and other factors that could cause actual results to differ materially
from those stated in such statements. As a result, these statements speak only as of the date they are made and we undertake no
obligation to update or revise any forward-looking statement, except as required by U.S. federal securities laws.
Appendix A: Smelters list
1. Gold
| Metal |
Smelter Name |
Smelter country |
| Gold |
Aida Chemical Industries Co. Ltd. |
JAPAN |
| Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. |
GERMANY |
| Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
UZBEKISTAN |
| Gold |
AngloGold Ashanti Córrego do Sítio Minerção |
BRAZIL |
| Gold |
Argor-Heraeus SA |
SWITZERLAND |
| Gold |
Asahi Pretec Corp. |
JAPAN |
| Gold |
Asaka Riken Co Ltd |
JAPAN |
| Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
TURKEY |
| Gold |
Aurubis AG |
GERMANY |
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES |
| Gold |
Bauer Walser AG |
GERMANY |
| Gold |
Boliden AB |
SWEDEN |
| Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
| Gold |
Caridad |
MEXICO |
| Gold |
CCR Refinery – Glencore Canada Corporation |
CANADA |
| Gold |
Cendres & Métaux SA |
SWITZERLAND |
| Gold |
Chimet S.p.A. |
ITALY |
| Gold |
China National Gold Group Corporation |
CHINA |
| Gold |
Chugai Mining Co., Ltd |
JAPAN |
| Gold |
Codelco |
CHILE |
| Gold |
Colt Refining |
UNITED STATES |
| Gold |
Daejin Indus Co. Ltd |
KOREA, REPUBLIC OF |
| Gold |
DaeryongENC |
KOREA, REPUBLIC OF |
| Gold |
Daye Non-Ferrous Metals Mining Ltd. |
CHINA |
| Gold |
Do Sung Corporation |
KOREA, REPUBLIC OF |
| Gold |
Doduco |
GERMANY |
| Gold |
Dowa |
JAPAN |
| Gold |
ECHEMEMI ENTERPRISE CORP.(FUTURES EXCHANGE) |
CHINA |
| Gold |
Eco-System Recycling Co., Ltd. |
JAPAN |
| Gold |
FSE Novosibirsk Refinery |
RUSSIAN FEDERATION |
| Gold |
Gansu Seemine Material Hi-Tech Co Ltd |
CHINA |
| Gold |
Gold Bell Group |
CHINA |
| Gold |
Guangdong Jinding Gold Limited |
CHINA |
| Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
CHINA |
| Gold |
Heimerle + Meule GmbH |
GERMANY |
| Gold |
Heraeus Ltd Hong Kong |
HONG KONG |
| Gold |
Heraeus Precious Metals GmbH & Co. KG |
GERMANY |
| Gold |
Heraeus Precious Metals North America |
UNITED STATES |
| Gold |
Hunan Chenzhou Mining Industry Group |
CHINA |
| Gold |
Hwasung CJ Co. Ltd |
KOREA, REPUBLIC OF |
| Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
CHINA |
| Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN |
| Gold |
Istanbul Gold Refinery |
TURKEY |
| Gold |
Japan Mint |
JAPAN |
| Gold |
Jiangxi Copper Company Limited |
CHINA |
| Gold |
Johnson Matthey Inc |
UNITED STATES |
| Gold |
Johnson Matthey Ltd |
CANADA |
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
RUSSIAN FEDERATION |
| Gold |
JSC Uralelectromed |
RUSSIAN FEDERATION |
| Gold |
JX Nippon Mining & Metals Co., Ltd |
JAPAN |
| Gold |
Kazzinc Ltd |
KAZAKHSTAN |
| Gold |
Kennecott Utah Copper LLC |
UNITED STATES |
| Gold |
Kojima Chemicals Co., Ltd |
JAPAN |
| Gold |
Korea Metal 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 |
London Bullion Market Association |
UNITED KINGDOM |
| Gold |
LS-NIKKO Copper Inc. |
KOREA, REPUBLIC OF |
| Gold |
Luoyang Zijin Yinhui Metal Smelt Co Ltd |
CHINA |
| Gold |
Materion |
UNITED STATES |
| Gold |
Matsuda Sangyo Co. Ltd |
JAPAN |
| Gold |
Metalor Technologies (Hong Kong) Ltd |
HONG KONG |
| Gold |
Metalor Technologies (Singapore) Pte. Ltd. |
SINGAPORE |
| Gold |
Metalor Technologies SA |
SWITZERLAND |
| Gold |
Metalor USA Refining Corporation |
UNITED STATES |
| Gold |
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V |
MEXICO |
| Gold |
Met-Mex Peñoles, S.A. |
MEXICO |
| Gold |
Mitsubishi Materials Corporation |
JAPAN |
| Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
| Gold |
Moscow Special Alloys Processing Plant |
RUSSIAN FEDERATION |
| Gold |
Nadir Metal Rafineri San. Ve Tic. A.Ş. |
TURKEY |
| Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN |
| Gold |
Nihon Material Co. LTD |
JAPAN |
| Gold |
Ohio Precious Metals, LLC |
UNITED STATES |
| Gold |
Ohura Precious Metal Industry Co., Ltd |
JAPAN |
| Gold |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) |
RUSSIAN FEDERATION |
| Gold |
OJSC Kolyma Refinery |
RUSSIAN FEDERATION |
| Gold |
PAMP SA |
SWITZERLAND |
| Gold |
Penglai Penggang Gold Industry Co Ltd |
CHINA |
| Gold |
Prioksky Plant of Non-Ferrous Metals |
RUSSIAN FEDERATION |
| Gold |
PT Aneka Tambang (Persero) Tbk |
INDONESIA |
| Gold |
PX Précinox SA |
SWITZERLAND |
| Gold |
Rand Refinery (Pty) Ltd |
SOUTH AFRICA |
| Gold |
Republic Metals Corporation |
UNITED STATES |
| Gold |
Royal Canadian Mint |
CANADA |
| Gold |
Sabin Metal Corp. |
UNITED STATES |
| Gold |
Samduck Precious Metals |
KOREA, REPUBLIC OF |
| Gold |
SAMWON METALS Corp. |
KOREA, REPUBLIC OF |
| Gold |
Schone Edelmetaal |
NETHERLANDS |
| Gold |
SEMPSA Joyería Platería SA |
SPAIN |
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd |
CHINA |
| Gold |
Shanghai Gold Exchange |
CHINA |
| Gold |
Sichuan Tianze Precious Metals Co., Ltd |
CHINA |
| Gold |
Singway Technology Co., Ltd. |
TAIWAN |
| Gold |
So Accurate Group, Inc. |
UNITED STATES |
| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
RUSSIAN FEDERATION |
| Gold |
Solar Applied Materials Technology Corp. |
TAIWAN |
| Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
| Gold |
Suzhou xingrui |
CHINA |
| Gold |
Suzhou Xingrui Noble |
CHINA |
| Gold |
Tanaka Kikinzoku Kogyo K.K. |
JAPAN |
| Gold |
The Great Wall Gold and Silver Refinery of China |
CHINA |
| Gold |
The Refinery of Shandong Gold Mining Co. Ltd |
CHINA |
| Gold |
Tokuriki Honten Co., Ltd |
JAPAN |
| Gold |
Tongling nonferrous Metals Group Co.,Ltd |
CHINA |
| Gold |
Torecom |
KOREA, REPUBLIC OF |
| Gold |
Umicore Brasil Ltda |
BRAZIL |
| Gold |
Umicore Precious Metals Thailand |
THAILAND |
| Gold |
Umicore SA Business Unit Precious Metals Refining |
BELGIUM |
| Gold |
United Precious Metal Refining, Inc. |
UNITED STATES |
| Gold |
Valcambi SA |
SWITZERLAND |
| Gold |
Western Australian Mint trading as The Perth Mint |
AUSTRALIA |
| Gold |
YAMAMOTO PRECIOUS METAL CO., LTD. |
JAPAN |
| Gold |
Yantai Zhaojin Lai Fuk Precious Metals Ltd |
CHINA |
| Gold |
Yokohama Metal Co Ltd |
JAPAN |
| Gold |
Yunnan Copper Industry Co Ltd |
CHINA |
| Gold |
Zhejiang Suijin |
CHINA |
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA |
| Gold |
Zijin Mining Group Co. Ltd |
CHINA |
2. Tantalum
| Metal |
Smelter Name |
Smelter country |
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
CHINA |
| Tantalum |
Conghua Tantalum and Niobium Smeltry |
CHINA |
| Tantalum |
Duoluoshan |
CHINA |
| Tantalum |
Exotech Inc. |
UNITED STATES |
| Tantalum |
F&X Electro-Materials Ltd. |
CHINA |
| Tantalum |
Global Advanced Metals |
UNITED STATES |
| Tantalum |
Global Advanced Metals Aizu |
JAPAN |
| Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES |
| Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. |
CHINA |
| Tantalum |
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch |
CHINA |
| Tantalum |
H.C. Starck Co., Ltd. |
THAILAND |
| Tantalum |
H.C. Starck GmbH Goslar |
GERMANY |
| Tantalum |
H.C. Starck GmbH Laufenburg |
GERMANY |
| Tantalum |
H.C. Starck Group |
GERMANY |
| Tantalum |
H.C. Starck Hermsdorf GmbH |
GERMANY |
| Tantalum |
H.C. Starck Inc. |
UNITED STATES |
| Tantalum |
H.C. Starck Ltd. |
JAPAN |
| Tantalum |
H.C. Starck Smelting GmbH & Co.KG |
GERMANY |
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA |
| Tantalum |
Hi-Temp |
UNITED STATES |
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA |
| Tantalum |
Jiujiang Tanbre Co., Ltd. |
CHINA |
| Tantalum |
KEMET Blue Metals |
MEXICO |
| Tantalum |
KEMET Blue Powder |
UNITED STATES |
| Tantalum |
King-Tan Tantalum Industry Ltd |
CHINA |
| Tantalum |
LSM Brasil S.A. |
BRAZIL |
| Tantalum |
Metallurgical Products India (Pvt.) Ltd. |
INDIA |
| Tantalum |
Mitsui Mining & Smelting |
JAPAN |
| Tantalum |
Molycorp Silmet A.S. |
ESTONIA |
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA |
| Tantalum |
Plansee |
AUSTRIA |
| Tantalum |
Plansee SE Liezen |
AUSTRIA |
| Tantalum |
Plansee SE Reutte |
AUSTRIA |
| Tantalum |
QuantumClean |
UNITED STATES |
| Tantalum |
RFH Tantalum Smeltry Co., Ltd |
CHINA |
| Tantalum |
Shanghai Jiangxi Metals Co. Ltd |
CHINA |
| Tantalum |
Solikamsk Magnesium Works OAO |
RUSSIAN FEDERATION |
| Tantalum |
Solikamsk Metal Works |
RUSSIAN FEDERATION |
| Tantalum |
Taki Chemicals |
JAPAN |
| Tantalum |
Tantalite Resources |
SOUTH AFRICA |
| Tantalum |
Telex |
UNITED STATES |
| Tantalum |
Ulba |
KAZAKHSTAN |
| Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd |
CHINA |
| Tantalum |
Zhuzhou Cement Carbide |
CHINA |
3. Tin
| Metal |
Smelter Name |
Smelter country |
| Tin |
AIM |
CANADA |
| Tin |
Alpha |
UNITED STATES |
| Tin |
American Iron and Metal |
CANADA |
| Tin |
An Xin Xuan Xin Yue You Se Jin Shu Co. Ltd. |
CHINA |
| Tin |
CFC Cooperativa dos Fundidores de Cassiterita da Amazônia Ltda. |
BRAZIL |
| Tin |
China Rare Metal Materials Company |
CHINA |
| Tin |
China Tin Group Co., Ltd. |
CHINA |
| Tin |
China Yunnan Tin Minerals Group Company Ltd. |
CHINA |
| Tin |
CNMC (Guangxi) PGMA Co. Ltd. |
CHINA |
| Tin |
Cookson |
UNITED STATES |
| Tin |
Cooper Santa |
BRAZIL |
| Tin |
COOPERMETAL - Cooperativa Metalúrgica de Rondônia Ltda. |
BRAZIL |
| Tin |
CV Duta Putra Bangka |
INDONESIA |
| Tin |
CV Gita Pesona |
INDONESIA |
| Tin |
CV JusTindo |
INDONESIA |
| Tin |
CV Makmur Jaya |
INDONESIA |
| Tin |
CV Nurjanah |
INDONESIA |
| Tin |
CV Serumpun Sebalai |
INDONESIA |
| Tin |
CV United Smelting |
INDONESIA |
| Tin |
Dowa Metals & Mining Co. Ltd |
JAPAN |
| Tin |
EM Vinto |
BOLIVIA |
| Tin |
Estanho de Rondônia S.A. |
BRAZIL |
| Tin |
Eximetal S.A. |
ARGENTINA |
| Tin |
Feinhütte Halsbrücke GmbH |
GERMANY |
| Tin |
Fenix Metals |
POLAND |
| Tin |
Gejiu Kai Meng Industry and Trade LLC |
CHINA |
| Tin |
Gejiu Non-Ferrous Metal Processing Co. Ltd. |
CHINA |
| Tin |
Gejiu Zi-Li |
CHINA |
| Tin |
Guangxi Huaxi Group Co.,Ltd |
CHINA |
| Tin |
Huaxi Guangxi Group |
CHINA |
| Tin |
Huichang Jinshunda Tin Co. Ltd |
CHINA |
| Tin |
Jean Goldschmidt International |
BELGIUM |
| Tin |
Jiangxi Ketai Advanced Material Co., Ltd. |
CHINA |
| Tin |
Jiangxi Nanshan |
CHINA |
| Tin |
Kai Unita Trade Limited Liability Company |
CHINA |
| Tin |
Kaimeng (Gejiu) Industry and Trade Co., Ltd. |
CHINA |
| Tin |
KOVOHUTĚ PŘÍBRAM NÁSTUPNICKÁ, A.S. |
CZECH REPUBLIC |
| Tin |
Kupol |
RUSSIAN FEDERATION |
| Tin |
Laibin Huaxi Smelterring Co.,Ltd |
CHINA |
| Tin |
Linwu Xianggui Smelter Co |
CHINA |
| Tin |
Liuzhou China Tin |
CHINA |
| Tin |
Magnu's Minerais Metais e Ligas LTDA |
BRAZIL |
| Tin |
MALAYSIA SMEL TING CORPORATION BERHAD |
MALAYSIA |
| Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
| Tin |
Melt Metais e Ligas S/A |
BRAZIL |
| Tin |
Metallic Materials Branch of Guangxi China Tin Group Co.,Ltd. |
CHINA |
| Tin |
Metallic Resources Inc |
UNITED STATES |
| Tin |
Metallo Chimique |
BELGIUM |
| Tin |
Mineração Taboca S.A. |
BRAZIL |
| Tin |
Minmetals Ganzhou Tin Co. Ltd. |
CHINA |
| Tin |
Minsur |
PERU |
| Tin |
Nathan Trotter & Co.,Inc. |
UNITED STATES |
| Tin |
Novosibirsk Integrated Tin Works |
RUSSIAN FEDERATION |
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
| Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
| Tin |
OMSA |
BOLIVIA |
| Tin |
Poongsan Corporation |
KOREA, REPUBLIC OF |
| Tin |
PT Alam Lestari Kencana |
INDONESIA |
| Tin |
PT Artha Cipta Langgeng |
INDONESIA |
| Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
| Tin |
PT Babel Inti Perkasa |
INDONESIA |
| Tin |
PT Babel Surya Alam Lestari |
INDONESIA |
| Tin |
PT Bangka Kudai Tin |
INDONESIA |
| Tin |
PT Bangka Putra Karya |
INDONESIA |
| Tin |
PT Bangka Timah Utama Sejahtera |
INDONESIA |
| Tin |
PT Bangka Tin Industry |
INDONESIA |
| Tin |
PT Belitung Industri Sejahtera |
INDONESIA |
| Tin |
PT BilliTin Makmur Lestari |
INDONESIA |
| Tin |
PT Bukit Timah |
INDONESIA |
| Tin |
PT DS Jaya Abadi |
INDONESIA |
| Tin |
PT Eunindo Usaha Mandiri |
INDONESIA |
| Tin |
PT Fang Di MulTindo |
INDONESIA |
| Tin |
PT HANJAYA PERKASA METALS |
INDONESIA |
| Tin |
PT HP Metals Indonesia |
INDONESIA |
| Tin |
PT Inti Stania Prima |
INDONESIA |
| Tin |
PT Karimun Mining |
INDONESIA |
| Tin |
PT Koba Tin |
INDONESIA |
| Tin |
PT Mitra Stania Prima |
INDONESIA |
| Tin |
PT Panca Mega Persada |
INDONESIA |
| Tin |
PT Pelat Timah Nusantara Tbk |
INDONESIA |
| Tin |
PT Prima Timah Utama |
INDONESIA |
| Tin |
PT REFINED BANGKA TIN |
INDONESIA |
| Tin |
PT Sariwiguna Binasentosa |
INDONESIA |
| Tin |
PT Seirama Tin investment |
INDONESIA |
| Tin |
PT Stanindo Inti Perkasa |
INDONESIA |
| Tin |
PT Sumber Jaya Indah |
INDONESIA |
| Tin |
PT Supra Sukses Trinusa |
INDONESIA |
| Tin |
PT Tambang Timah |
INDONESIA |
| Tin |
PT Timah |
INDONESIA |
| Tin |
PT Timah (Persero), Tbk |
INDONESIA |
| Tin |
PT Tinindo Inter Nusa |
INDONESIA |
| Tin |
PT Tommy Utama |
INDONESIA |
| Tin |
PT Yinchendo Mining Industry |
INDONESIA |
| Tin |
Rui Da Hung |
TAIWAN |
| Tin |
SA Minsur |
PERU |
| Tin |
Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co. Ltd. |
CHINA |
| Tin |
Sizer Metals PTE |
SINGAPORE |
| Tin |
Soft Metais, Ltda. |
BRAZIL |
| Tin |
Thaisarco |
THAILAND |
| Tin |
Tongding Metal Material Co.,Ltd. |
CHINA |
| Tin |
Traxys |
FRANCE |
| Tin |
White Solder Metalurgia e Mineração Ltda. |
BRAZIL |
| Tin |
Wu Xi Shi Yi Zheng Ji Xie She Bei Company |
CHINA |
| Tin |
Yantai Zhaojin Precious Metals Co., Ltd. |
CHINA |
| Tin |
Yifeng Tin Industry (Chenzhou) Co Ltd |
CHINA |
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. |
CHINA |
| Tin |
Yunnan Tin Company Limited |
CHINA |
4. Tungsten
| Metal |
Smelter Name |
Smelter country |
| Tungsten |
A.L.M.T. Corp. |
JAPAN |
| Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. |
CHINA |
| Tungsten |
Chongyi Zhangyuan Tungsten Co Ltd |
CHINA |
| Tungsten |
Dayu Weiliang Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Ganxian Shirui New Material Co., Ltd. |
CHINA |
| Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
CHINA |
| Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA |
| Tungsten |
Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
CHINA |
| Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA |
| Tungsten |
Global Tungsten & Powders Corp. |
UNITED STATES |
| Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Guangdong Xianglu Tungsten Industry Co., Ltd. |
CHINA |
| Tungsten |
H.C. Starck GmbH |
GERMANY |
| Tungsten |
Hunan Chenzhou Mining Group Co |
CHINA |
| Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. |
CHINA |
| Tungsten |
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd. |
CHINA |
| Tungsten |
Japan New Metals Co Ltd |
JAPAN |
| Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Richsea New Materials Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA |
| Tungsten |
Kennametal Fallon |
UNITED STATES |
| Tungsten |
Kennametal Huntsville |
UNITED STATES |
| Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
VIET NAM |
| Tungsten |
Sumitomo |
CHINA |
| Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. |
VIET NAM |
| Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd |
VIET NAM |
| Tungsten |
Wolfram Bergbau und Hütten AG |
AUSTRIA |
| Tungsten |
Wolfram Company CJSC |
RUSSIAN FEDERATION |
| Tungsten |
Xiamen Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Zhuzhou Cemented Carbide Group Co Ltd |
CHINA |
Appendix B: Mines Country of Origin
| Australia |
| Belgium |
| Bolivia |
| Brazil |
| Canada |
| China |
| Ethiopia |
| Germany |
| Hong Kong |
| Indonesia |
| Japan |
| Kazakhstan |
| Korea, Republic of |
| Peru |
| Russia |
| South Africa |
| Switzerland |
| Thailand |
| United States |
| Uzbekistan |
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