UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
Specialized Disclosure Report
Pentair plc
(Exact name of the registrant as specified in its charter)
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| Ireland |
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001-11625 |
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98-1141328 |
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of incorporation or organization) |
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(Commission File
Number) |
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(I.R.S. Employer
Identification No.) |
P.O. Box 471, Sharp Street,
Walkden, Manchester, M28 8BU United Kingdom
(Address of principal executive offices)
Angela D. Lageson
Senior Vice President, General Counsel and Secretary
(763) 545-1730
(Name and
telephone number, including area code, of 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:
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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
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of Pentair plc
(the “Company”) is filed pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2014 to December 31, 2014.
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available at
www.pentair.com/investors/sec-filings.
The Rule imposes reporting obligations on Securities and Exchange Commission registrants whose manufactured
products contain certain minerals that are necessary to the functionality or production of their products. If a registrant determines that any columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to
tantalum, tin and tungsten (the “Subject Minerals”), are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured, the registrant must conduct in good faith
a Reasonable Country of Origin Inquiry (“RCOI”) regarding those Subject Minerals that is reasonably designed to determine whether any of the Subject Minerals originated in the Democratic Republic of the Congo or an adjoining country (the
“Covered Countries”) or are from recycled or scrap sources.
The Company performed a RCOI, in which it surveyed over 4,600 direct suppliers,
spanning over 63 enterprise resource planning systems, regarding whether its necessary Subject Minerals have been sourced from any of the Covered Countries. Most of the responses the Company received indicated that either (1) to the best of
such supplier’s knowledge, the Subject Minerals in the components and materials that it supplied to the Company during 2014 did not originate from a Covered Country or (2) such supplier did not use Subject Minerals in the materials and
components that it supplied to the Company during 2014. Further information regarding the Company’s RCOI is included in Section 2.2 of the Company’s Conflict Minerals Report, which is attached to this specialized disclosure report on
Form SD as Exhibit 1.01. The disclosure set forth in Section 2.2 of the Conflict Minerals Report is incorporated by reference into this Item 1.01.
After reviewing the results of the RCOI, the Company could not conclusively determine that it had no reason to believe that, during 2014, Subject Minerals
necessary for the functionality or production of its products may have originated from a Covered Country and may not be from recycled or scrap sources. The Company conducted its RCOI in good faith, and it believes that such inquiry was reasonable to
allow it to make the determination. Accordingly, the Company proceeded to exercise due diligence on the source and chain of custody of the Subject Minerals in accordance with the framework contained in the Organisation for Economic Co-operation and
Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, including the related supplements on gold, tin, tantalum and tungsten. The Conflict Minerals Report filed as
Exhibit 1.01 to this report includes a discussion of the due diligence procedures performed, the ultimate determination of origin and conflict status reached and other disclosures required by the Rule.
Item 1.02 Exhibit
As specified in Section 2,
Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2—Exhibits
Item 2.01 Exhibits
The following exhibit is filed as
part of this report.
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| Exhibit
No. |
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Description |
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| 1.01 |
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Conflict Minerals Report of Pentair plc |
2
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.
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| Pentair plc |
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| By: |
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/s/ Angela D. Lageson |
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June 1, 2015 |
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Angela D. Lageson Senior Vice President,
General Counsel and Secretary |
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(Date) |
EXHIBIT INDEX
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| Exhibit
No. |
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Description |
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| 1.01 |
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Conflict Minerals Report of Pentair plc |
Exhibit 1.01
Pentair plc
Conflict
Minerals Report
For the reporting period from January 1, 2014 to December 31, 2014
This report for the period from January 1, 2014 to December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of
1934, as amended, and Form SD (the “Rule”). The Rule was adopted to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Rule imposes
reporting obligations on Securities and Exchange Commission registrants whose manufactured products contain certain minerals that are necessary to the functionality or production of their products.
If a registrant determines that any columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and
tungsten (the “Subject Minerals”), are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured, the registrant must conduct in good faith a Reasonable
Country of Origin Inquiry (“RCOI”) regarding those Subject Minerals that is reasonably designed to determine whether any of the Subject Minerals originated in the Democratic Republic of the Congo or an adjoining country (the “Covered
County” or “Covered Countries”) or are from recycled or scrap sources.
If, following the completion of the RCOI, a registrant knows that
any of the necessary Subject Minerals originated in a Covered Country and are not from recycled or scrap sources, or has reason to believe that its necessary Subject Minerals may have originated in the Covered Countries and has reason to believe
that its necessary Subject Minerals did not come from recycled or scrap sources, then the registrant must exercise due diligence on the source and chain of custody of the Subject Minerals that conforms to a nationally or internationally recognized
due diligence framework and describe such due diligence in this separate Conflict Minerals Report.
In accordance with the Organisation for Economic
Co-operation and Development Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, the related supplements on tin, tungsten, tantalum and gold (the “Guidance”) and the Rule, this
report is available on the Company’s website at www.pentair.com/investors/sec-filings.
Consistent with the provisions of the Rule, this Conflict
Minerals Report has not been audited by a third party.
The Company is a focused diversified industrial manufacturing company comprising four
reporting segments, which are classified based primarily on types of products offered and markets served. The Valves & Controls segment designs, manufactures, markets and services valves, fittings, automation and controls and actuators for
the energy and industrial verticals. The Flow & Filtration Solutions segment designs, manufactures, markets and services solutions for the toughest filtration, separation, flow and fluid management challenges in agriculture, food and
beverage processing, water supply and disposal and a variety of industrial applications. The Water Quality Systems segment designs, manufactures, markets and services innovative water system products and solutions to meet filtration and fluid
management challenges in food and beverage, water, swimming pools and aquaculture applications. The Technical
Solutions segment designs, manufactures, markets and services products that guard and protect some of the
world’s most sensitive electronics and electronic equipment, as well as heat management solutions designed to provide thermal protection to temperature sensitive fluid applications.
The Company conducted an analysis of all of its products and its entire supply chain, and, accordingly, the Company did not limit its review to those products
which may have contained Subject Minerals. This Report relates to all products (which are collectively referred to as the “Covered Products”): (i) that were manufactured, or contracted to be manufactured, by the Company; and
(ii) for which the manufacture was completed during calendar year 2014.
The Company has adopted a Conflict Minerals Policy that emphasizes the
Company’s commitment to complying with the Rule and to identifying the source of the Subject Minerals contained in the Company’s products. The Company also indicates in its Global Supplier Guide (the “Supplier Guide”) that it
expects all suppliers doing business with the Company to cooperate with the conflict minerals due diligence process. The Company also has participated in groups and forums focused on responsible sourcing of conflict minerals, including the
Conflict-Free Sourcing Initiative (the “CFSI”) and industry association groups such as the Twin Cities Conflict Minerals Task Force.
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2. |
Conflict Minerals Compliance Process |
The Company’s RCOI was designed to provide a reasonable basis for the Company
to determine whether it sources any Subject Minerals from the Covered Countries. The Company designed its due diligence measures to conform in all material respects to the Guidance.
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2.2 |
Reasonable Country of Origin Inquiry |
The Company designed its RCOI to provide a reasonable basis for it
to determine whether the Company sources Subject Minerals from Covered Countries and whether any of the Subject Minerals may be from recycled or scrap sources. The Company conducted a survey of its suppliers using the template maintained by the
CFSI, known as the Conflict Minerals Reporting Template (the “Template”). The Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It
includes questions regarding a direct supplier’s conflict minerals policy, engagement with its direct suppliers, origin of Subject Minerals included in its products, supplier due diligence and a listing of the smelters the direct supplier and
its suppliers use. Written instructions and recorded training illustrating the use of the tool are available on the CFSI’s website. Many companies are using the Template in their RCOI and due diligence processes related to Subject Minerals.
The Company’s inquiry process included multiple rounds of communication and follow-up including mail, email and telephone calls with over 4,600
direct suppliers, spanning 63 enterprise resource planning systems. The Company received, reviewed and processed responses from over 82% of its suppliers, which represented approximately 92% of calendar year 2014 supplier expenditures. The Company
reviewed the responses against risk-based criteria developed to determine which responses required further engagement with the relevant suppliers. These criteria included inconsistencies within the data reported in the Template and other risk-based
criteria. The Company worked directly with these suppliers to obtain a revised response and/or additional clarity regarding their submission.
2
Most of the responses the Company received indicated that either (1) to the best of such supplier’s
knowledge, the Subject Minerals in the components and materials that it supplied to the Company during 2014 did not originate from a Covered Country or (2) such supplier did not use Subject Minerals in the materials and components that it
supplied to the Company during 2014.
One of the Company’s suppliers indicated that the Subject Minerals in some of its components and materials
supplied to the Company may have originated from a Covered Country and could not demonstrate that such Subject Minerals were “DRC conflict free.” The Company is pursuing recovery measures with this supplier as described in
Section 2.3, below.
After reviewing the results of the RCOI, the Company could not conclusively determine that it had no reason to believe that
Subject Minerals necessary for the functionality or production of its products may have originated from a Covered Country during 2014. The Company conducted its RCOI in good faith, and the Company believes that such inquiry was reasonable to allow
it to make the determination. Accordingly, the Company proceeded to exercise due diligence on the source and chain of custody of the Subject Minerals.
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2.3 |
The Company’s Due Diligence Process |
Design of Due Diligence
The Company exercised due diligence on the source and chain of custody of the Subject Minerals. The Company’s due diligence measures have been designed to
conform to the framework in the Guidance.
Internal Team
The Company (1) developed cross-functional teams to set its conflict minerals strategy and ensure timely implementation and execution of the due diligence
program and (2) tasked each of its global business units with implementing the Company’s conflicts mineral strategy and reporting results and progress to the cross-functional teams. The Company’s Supply Chain Group has primary
responsibility for program execution at the Company level and dedicated conflict mineral compliance teams were put in place at each global business unit. Guidance on the overall strategy and implementation is provided by the Legal Department,
Accounting Department and Internal Audit Department. Senior management is briefed about the results of the due diligence program on a regular basis.
The
Company has developed internal training processes to educate anyone within the Company that is a potential contact point for suppliers or other external parties regarding the Company’s conflict minerals compliance efforts. In addition,
(1) each of the Company’s global business units has developed processes to update and review with its respective employees the latest developments with respect to conflict minerals and the conflict minerals reporting process and
(2) some of the Company’s global business units have developed tailored training programs to train its employees with respect to the potential impact of conflict minerals at the global business unit level.
3
Ethics Hotline
The Company has long-standing grievance mechanisms, including an Ethics Hotline, whereby the Company’s employees can report violations of the
Company’s Code of Conduct, policy or law, including its procedures related to conflict minerals and the conflict minerals reporting process.
Control Systems and Supplier Engagement
Due to its position in the supply chain, the Company does not have a direct relationship with Subject Minerals smelters and refiners. The Company engages with
its suppliers and relies on information provided through the Template to gather information on the source and chain of custody of the Subject Minerals in its products.
In 2014, the Company updated its Supplier Guide to address, among other things, the Subject Minerals and the requirement of its suppliers to provide
information on their use of these minerals. The Company also continues to update its supplier contracts by including a requirement that the supplier comply with the Supplier Guide whenever a new contract is entered into or an outstanding contract is
renewed.
Records Retention
The
Company will retain documentation related to its conflict minerals compliance program according to the Company’s Document Retention Policy.
Risk-Based Due Diligence Process
The
Company’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of the Subject Minerals. In this
regard, the Company does not purchase Subject Minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of Subject Minerals that are included in the Covered
Products.
In conjunction with the Company’s risk assessment process, the Company has developed a risk management plan. Through the Company’s
due diligence process the Company attempts to determine the source and chain of custody of the necessary Subject Minerals the Company knows, or has reason to believe, originated in a Covered Country. The Company generally does not have a direct
relationship with smelters and/or refiners. Most of the work toward this aspect of the Guidance is carried out indirectly through the Company’s suppliers or through the Company’s involvement with industry working groups/coalitions. Due to
its position in the supply chain, the Company largely focuses on the accuracy and quality of the representations the Company’s direct suppliers make regarding the source and chain of custody of their Subject Minerals. The Company evaluates its
direct suppliers’ responses to RCOI and due diligence inquiries based on the risk or likelihood that they are giving an incorrect response or that a non-response may indicate the supplier is purchasing from a known conflict source and does not
wish to disclose this fact.
In evaluating the responses from its suppliers, the Company screens all responses for overall risk factors associated with
the veracity of the information supplied. Suitable, measurable risk mitigation plans are developed as needed on a case-by-case basis. Actions may include (1) the Company’s use of responses to the Template to identify potential high-risk
suppliers on a go-forward basis; and (2) focusing additional due diligence efforts on those high-risk suppliers.
4
Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
The Company does not have a direct relationship with Subject Minerals smelters and refiners and does not perform or direct audits of these entities within
the Company’s supply chain. The Company supports audits by engaging its partners who are closer to the source and, as a member of the Conflict-Free Sourcing Initiative, by promoting the smelter and refiner verification procedures and protocols
of the Conflict-Free Smelter Program.
Due Diligence Results
Based on the information obtained pursuant to the due diligence process, the Company believes that the smelters and refiners listed in Annex I to this Report
may have been used to process the Subject Minerals in the Covered Products. The Company does not have sufficient information, with respect to the Covered Products, to conclusively determine the country of origin of the Subject Minerals in the
Covered Products or to conclusively determine whether the Subject Minerals in the Covered Products are from recycled or scrap sources. However, based on the information provided by the Company’s suppliers, smelters and refiners, as well as from
the CFSI and other sources, the Company believes the countries of origin of the Subject Minerals contained in the Covered Products include the countries listed in Annex II to this Report, as well as recycled and scrap sources.
Of the 277 smelters and refiners of the Subject Minerals in the Covered Products identified for the calendar year 2014, 11 smelters and refiners were
identified as having sourced Subject Minerals from a Covered Country. Of these, 10 were verified as compliant with the CFSI’s Conflict-Free Smelter Program, and one smelter is active but not yet compliant with the Conflict-Free Smelter Program.
Of the 266 remaining smelters and refiners, the Company identified 155 as compliant with the Conflict-Free Smelter Program and 14 as active but not yet compliant with the Conflict-Free Smelter Program. After following up with the relevant suppliers,
to the best of its ability, the Company was unable to determine the status of the remaining 101 smelters and refiners in its supply chain, but the Company found no reasonable basis to conclude these smelters and refiners may have sourced Subject
Minerals that directly or indirectly financed or benefited armed groups.
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3. |
DRC Conflict Undeterminable |
After exercising the due diligence described above, the Company was unable
to determine whether or not each of the Covered Products qualify as “DRC conflict free,” as defined under the Rule. Accordingly, the Company has reasonably determined that each of the Covered Products is “DRC conflict
undeterminable,” as defined in the Rule.
The Company has provided its determination as of the date of this report. Subsequent events, such as the
inability or unwillingness of any supplier, smelter or refiner to comply with the Company’s Conflict Minerals Policy, may affect the Company’s future determinations under Rule 13p-1.
5
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4. |
Due Diligence Improvement Measures |
During calendar year 2014, the Company took the following steps to
improve the quality of its due diligence:
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The Company adopted a company-wide Conflict Minerals Policy, which is publicly available on the Company’s website at http://pentair.com/en/about-us/our-approach/partner-and-supplier-information. |
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The Company undertook greater engagement with its suppliers, improving the response rate and content of supplier responses, with particular emphasis on those suppliers that submitted incomplete or inconsistent responses
to the Template request or that exhibited other high-risk attributes related to the potential use of the Subject Minerals. |
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The Company encouraged suppliers to implement responsible sourcing and had suppliers encourage smelters and refiners to obtain a “conflict-free” designation from an independent, third-party auditor.
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The Company implemented recovery plans with respect to one supplier upon discovering, through the RCOI and the due diligence process, such supplier may have provided the Company with Subject Minerals from a Covered
Country and could not demonstrate such Subject Minerals were “DRC conflict free.” |
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The Company continued to work with its peers, suppliers and industry groups to define and improve best practices in accordance with the Guidance. |
During calendar year 2015, the Company plans to implement the following measures to further improve the quality of its due diligence:
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Implement updated and more robust software systems to support more robust data collection and due diligence. |
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Continue our work with our suppliers to help them understand our expectations regarding the Subject Minerals in our supply chain and our suppliers’ due diligence of their own supply chains, including their ability
to confirm the conflict-free status of identified smelters and refiners. |
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Continue to emphasize to suppliers our expectation that they move toward sourcing exclusively from conflict-free smelters and refiners verified by the Conflict-Free Smelter Program. |
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For suppliers unable to immediately source from conflict-free smelters and refiners verified by the Conflict-Free Smelter Program, request that those suppliers develop, share and implement a mitigation plan to source
exclusively from conflict-free smelters and refiners. |
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Where possible, conduct on-site visits to smelters and refiners, and take an active role in encouraging smelters and refiners to become compliant with the Conflict-Free Smelter Program. |
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Continue our engagement with industry groups, including the CFSI, that support the adoption and improvement of relevant programs, tools and standards. |
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5. |
Forward-Looking Statements |
This Conflict Minerals Report contains forward-looking statements intended
to qualify for the safe harbor from liability established by the Private Securities Litigation Reform Act of 1995. All statements, other than statements of historical fact, included in this Conflict Minerals Report, including, without limitation,
statements regarding our conflict mineral compliance plans, are forward-looking statements. These forward-looking statements generally are identified by the words “targets,” “plans,” “believes,” “expects,”
“intends,” “will,” “likely,” “may,” “anticipates,” “estimates,” “projects,” “should,” “would,” “positioned,” “strategy,” “future”
or phrases or terms of similar substance or the negative thereof or similar terminology generally intended to identify forward-looking statements. These forward-looking statements are not guarantees of future performance and are subject to risks,
uncertainties, assumptions and other factors, some of which are beyond our control. Numerous important factors described in this Conflict Minerals Report, including, among others, our ability to implement new software systems, our suppliers’
willingness and ability to comply with our conflict minerals-related compliance requests, the degree to which we are able to determine our suppliers’ use of conflict-free smelters and refiners, the impact of industry-wide initiatives such as
the Conflict-Free Smelter Program, smelters’ and refiners’ willingness and ability to comply with the Conflict-Free Smelter Program, our effectiveness in managing the conflict minerals RCOI and due diligence processes, and the costs of our
compliance, could affect these statements and could cause actual results to differ materially from our expectations. All forward-looking statements speak only as of the date of this Conflict Minerals Report. We assume no obligation, and disclaim any
duty, to update or revise publicly any forward-looking statements, whether as a result of new information, future events or otherwise.
7
Annex I
List of Smelters and Refiners
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| Mineral |
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Smelter/Refiner |
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Location |
| Gold |
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Advanced Chemical Company |
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United States |
| Gold |
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Aida Chemical Industries Co. Ltd. |
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Japan |
| Gold |
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Aktyubinsk |
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Russian Federation |
| Gold |
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Allgemeine Gold-und Silberscheideanstalt A.G. |
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Germany |
| Gold |
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Almalyk Mining and Metallurgical Complex (AMMC) |
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Uzbekistan |
| Gold |
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AngloGold Ashanti Córrego do Sítio Minerção |
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Brazil |
| Gold |
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Asahi Pretec Corporation |
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Japan |
| Gold |
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Asaka Riken Co Ltd |
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Japan |
| Gold |
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Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
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Turkey |
| Gold |
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Aurubis AG |
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Germany |
| Gold |
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
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Philippines |
| Gold |
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Bauer Walser AG |
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Germany |
| Gold |
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Boliden AB |
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Sweden |
| Gold |
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C. Hafner GmbH + Co. KG |
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Germany |
| Gold |
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Caridad |
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Mexico |
| Gold |
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CCR Refinery – Glencore Canada Corporation |
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Canada |
| Gold |
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Cendres + Métaux SA |
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Switzerland |
| Gold |
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Chimet S.p.A. |
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Italy |
| Gold |
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China National Gold Group Corporation |
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China |
| Gold |
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Chugai Mining |
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Japan |
| Gold |
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Colt Refining |
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United States |
| Gold |
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Daejin Indus Co. Ltd |
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South Korea |
| Gold |
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Daye Non-Ferrous Metals Mining Ltd. |
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China |
| Gold |
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Do Sung Corporation |
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South Korea |
| Gold |
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Doduco |
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Germany |
| Gold |
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Dowa |
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Japan |
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| Mineral |
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Smelter/Refiner |
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Location |
| Gold |
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Eco-System Recycling Co., Ltd. |
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Japan |
| Gold |
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Fidelity Printers and Refiners Ltd. |
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Zimbabwe |
| Gold |
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FSE Novosibirsk Refinery |
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Russian Federation |
| Gold |
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Gansu Seemine Material Hi-Tech Co Ltd |
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China |
| Gold |
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Guangdong Jinding Gold Limited |
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China |
| Gold |
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Hangzhou Fuchunjiang Smelting Co., Ltd. |
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China |
| Gold |
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Heimerle + Meule GmbH |
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Germany |
| Gold |
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Heraeus Ltd. Hong Kong |
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Hong Kong |
| Gold |
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Heraeus Precious Metals GmbH & Co. KG |
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Germany |
| Gold |
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Hunan Chenzhou Mining Group Co., Ltd. |
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China |
| Gold |
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Hwasung CJ Co. Ltd |
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South Korea |
| Gold |
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Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
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China |
| Gold |
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Ishifuku Metal Industry Co., Ltd. |
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Japan |
| Gold |
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Istanbul Gold Refinery |
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Turkey |
| Gold |
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Japan Mint |
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Japan |
| Gold |
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Jiangxi Copper Company Limited |
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China |
| Gold |
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Johnson Matthey Inc |
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United States |
| Gold |
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Johnson Matthey Ltd |
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Canada |
| Gold |
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JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
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Russian Federation |
| Gold |
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JSC Uralelectromed |
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Russian Federation |
| Gold |
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JX Nippon Mining & Metals Co., Ltd. |
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Japan |
| Gold |
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Kazzinc Ltd |
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Kazakhstan |
| Gold |
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Kennecott Utah Copper LLC |
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United States |
| Gold |
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KGHM Polska Miedź Spółka Akcyjna |
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Poland |
| Gold |
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Kojima Chemicals Co., Ltd |
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Japan |
| Gold |
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Korea Metal Co. Ltd |
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South Korea |
| Gold |
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Kyrgyzaltyn JSC |
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Kyrgyzstan |
| Gold |
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L’ azurde Company For Jewelry |
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Saudi Arabia |
9
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| Mineral |
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Smelter/Refiner |
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Location |
| Gold |
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Lingbao Gold Company Limited |
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China |
| Gold |
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Lingbao Jinyuan Tonghui Refinery Co. Ltd. |
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China |
| Gold |
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LS-NIKKO Copper Inc. |
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South Korea |
| Gold |
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Luoyang Zijin Yinhui Metal Smelt Co Ltd |
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China |
| Gold |
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Materion |
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United States |
| Gold |
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Matsuda Sangyo Co., Ltd. |
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Japan |
| Gold |
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Metalor Technologies (Hong Kong) Ltd |
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Hong Kong |
| Gold |
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Metalor Technologies (Singapore) Pte. Ltd. |
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Singapore |
| Gold |
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Metalor Technologies SA |
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Switzerland |
| Gold |
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Metalor USA Refining Corporation |
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United States |
| Gold |
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Met-Mex Peñoles, S.A. |
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Mexico |
| Gold |
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Mitsubishi Materials Corporation |
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Japan |
| Gold |
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Mitsui Mining and Smelting Co., Ltd. |
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Japan |
| Gold |
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MMTC-PAMP India Pvt. Ltd |
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India |
| Gold |
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Moscow Special Alloys Processing Plant |
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Russian Federation |
| Gold |
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Nadir Metal Rafineri San. Ve Tic. A.Ş. |
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Turkey |
| Gold |
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Navoi Mining and Metallurgical Combinat |
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Uzbekistan |
| Gold |
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Nihon Material Co. LTD |
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Japan |
| Gold |
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Ohio Precious Metals, LLC |
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United States |
| Gold |
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Ohura Precious Metal Industry Co., Ltd |
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Japan |
| Gold |
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OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) |
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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 |
10
|
|
|
|
|
| Mineral |
|
Smelter/Refiner |
|
Location |
| Gold |
|
Republic Metals Corporation |
|
United States |
| Gold |
|
Royal Canadian Mint |
|
Canada |
| Gold |
|
Sabin Metal Corp. |
|
United States |
| Gold |
|
Samduck Precious Metals |
|
South Korea |
| Gold |
|
Samwon Metals Corp. |
|
South Korea |
| Gold |
|
Schone Edelmetaal |
|
Netherlands |
| Gold |
|
SEMPSA Joyería Platería SA |
|
Spain |
| Gold |
|
Shandong Zhaojin Gold & Silver Refinery Co. Ltd |
|
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 |
|
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 |
|
South Korea |
| 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 |
|
Yokohama Metal Co Ltd |
|
Japan |
11
|
|
|
|
|
| Mineral |
|
Smelter/Refiner |
|
Location |
| Gold |
|
Yunnan Copper Industry Co Ltd |
|
China |
| Gold |
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
|
China |
| Gold |
|
Zijin Mining Group Co. Ltd |
|
China |
| Tantalum |
|
Changsha South Tantalum Niobium Co., Ltd. |
|
China |
| Tantalum |
|
Conghua Tantalum and Niobium Smeltry |
|
China |
| Tantalum |
|
D Block Metals, LLC |
|
United States |
| Tantalum |
|
Duoluoshan |
|
China |
| Tantalum |
|
Exotech Inc. |
|
United States |
| Tantalum |
|
F&X Electro-Materials Ltd. |
|
China |
| Tantalum |
|
FIR Metals & Resource., Ltd. |
|
China |
| 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 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 |
|
Jiangxi Dinghai Tantalum & Niobium Co., LTD |
|
China |
| Tantalum |
|
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
|
China |
| Tantalum |
|
Jiujiang Tanbre Co., Ltd. |
|
China |
| Tantalum |
|
Jiujiang Zhongao Tantalum & Niobium Co, Ltd |
|
China |
| Tantalum |
|
KEMET Blue Metals |
|
Mexico |
12
|
|
|
|
|
| Mineral |
|
Smelter/Refiner |
|
Location |
| 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 |
|
Mineração Taboca S.A. |
|
Brazil |
| Tantalum |
|
Mitsui Mining & Smelting |
|
Japan |
| Tantalum |
|
Molycorp Silmet A.S. |
|
Estonia |
| Tantalum |
|
Ningxia Orient Tantalum Industry Co., Ltd. |
|
China |
| Tantalum |
|
Phoenix Metal Ltd |
|
Rwanda |
| 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 |
|
Taki Chemicals |
|
Japan |
| Tantalum |
|
Telex |
|
United States |
| Tantalum |
|
Ulba |
|
Kazakhstan |
| Tantalum |
|
XinXing HaoRong Electronic Material CO.,LTD |
|
China |
| Tantalum |
|
Yichun Jin Yang Rare Metal Co., Ltd |
|
China |
| Tantalum |
|
Zhuzhou Cement Carbide |
|
China |
| Tin |
|
Alpha |
|
United States |
| Tin |
|
China Rare Metal Materials Company |
|
China |
| Tin |
|
China Tin Group Co., Ltd. |
|
China |
| Tin |
|
CNMC (Guangxi) PGMA Co. Ltd. |
|
China |
| Tin |
|
Cooper Santa |
|
Brazil |
| Tin |
|
CV Gita Pesona |
|
Indonesia |
| Tin |
|
CV JusTindo |
|
Indonesia |
13
|
|
|
|
|
| Mineral |
|
Smelter/Refiner |
|
Location |
| Tin |
|
CV Makmur Jaya |
|
Indonesia |
| Tin |
|
CV Nurjanah |
|
Indonesia |
| Tin |
|
CV Serumpun Sebalai |
|
Indonesia |
| Tin |
|
CV United Smelting |
|
Indonesia |
| Tin |
|
CV Venus Inti Perkasa |
|
Indonesia |
| Tin |
|
Dowa |
|
Japan |
| Tin |
|
EM Vinto |
|
Bolivia |
| Tin |
|
Estanho de Rondônia S.A. |
|
Brazil |
| 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 |
|
Huichang Jinshunda Tin Co. Ltd |
|
China |
| Tin |
|
Jiangxi Nanshan |
|
China |
| Tin |
|
Linwu Xianggui Smelter Co |
|
China |
| Tin |
|
Magnu’s Minerais Metais e Ligas LTDA |
|
Brazil |
| Tin |
|
Malaysia Smelting Corporation (MSC) |
|
Malaysia |
| Tin |
|
Melt Metais e Ligas S/A |
|
Brazil |
| Tin |
|
Metallo Chimique |
|
Belgium |
| Tin |
|
Mineração Taboca S.A. |
|
Brazil |
| Tin |
|
Minsur |
|
Peru |
| Tin |
|
Mitsubishi Materials Corporation |
|
Japan |
| 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 |
|
PT Alam Lestari Kencana |
|
Indonesia |
| Tin |
|
PT Artha Cipta Langgeng |
|
Indonesia |
14
|
|
|
|
|
| Mineral |
|
Smelter/Refiner |
|
Location |
| 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 Donna Kembara Jaya |
|
Indonesia |
| Tin |
|
PT Eunindo Usaha Mandiri |
|
Indonesia |
| Tin |
|
PT Fang Di MulTindo |
|
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 Rajwa International |
|
Indonesia |
| Tin |
|
PT Refined Bangka Tin |
|
Indonesia |
| Tin |
|
PT Sariwiguna Binasentosa |
|
Indonesia |
| Tin |
|
PT Seirama Tin investment |
|
Indonesia |
| Tin |
|
PT Singkep Times Utama |
|
Indonesia |
| Tin |
|
PT Stanindo Inti Perkasa |
|
Indonesia |
| Tin |
|
PT Sumber Jaya Indah |
|
Indonesia |
15
|
|
|
|
|
| Mineral |
|
Smelter/Refiner |
|
Location |
| Tin |
|
PT Supra Sukses Trinusa |
|
Indonesia |
| Tin |
|
PT Tambang Timah |
|
Indonesia |
| Tin |
|
PT Timah (Persero), Tbk |
|
Indonesia |
| Tin |
|
PT Tinindo Inter Nusa |
|
Indonesia |
| Tin |
|
PT Tirus Putra Mandiri |
|
Indonesia |
| Tin |
|
PT Tommy Utama |
|
Indonesia |
| Tin |
|
PT Wahana Parkit Jaya |
|
Indonesia |
| Tin |
|
PT Yinchendo Mining Industry |
|
Indonesia |
| Tin |
|
PT Hanjaya Perkasa Metals |
|
Indonesia |
| Tin |
|
Rui Da Hung |
|
Taiwan |
| Tin |
|
Soft Metais, Ltda. |
|
Brazil |
| Tin |
|
Thaisarco |
|
Thailand |
| Tin |
|
White Solder Metalurgia e Mineração Ltda. |
|
Brazil |
| Tin |
|
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. |
|
China |
| Tin |
|
Yunnan Tin Company, Ltd. |
|
China |
| Tungsten |
|
A.L.M.T. Corp. |
|
Japan |
| Tungsten |
|
Asia Tungsten Products Vietnam Ltd. |
|
Vietnam |
| Tungsten |
|
Chenzhou Diamond Tungsten Products Co., Ltd. |
|
China |
| Tungsten |
|
Chongyi Zhangyuan Tungsten Co., Ltd. |
|
China |
| Tungsten |
|
Dayu Jincheng Tungsten Industry 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 |
|
Ganzhou Yatai Tungsten Co., Ltd. |
|
China |
16
|
|
|
|
|
| Mineral |
|
Smelter/Refiner |
|
Location |
| Tungsten |
|
Global Tungsten & Powders Corp. |
|
United States |
| Tungsten |
|
Guangdong Xianglu Tungsten Co., Ltd. |
|
China |
| Tungsten |
|
H.C. Starck GmbH |
|
Germany |
| Tungsten |
|
H.C. Starck Smelting GmbH & Co.KG |
|
Germany |
| Tungsten |
|
Hunan Chenzhou Mining Group Co., Ltd. |
|
China |
| Tungsten |
|
Hunan Chunchang Nonferrous Metals 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 |
|
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
|
China |
| Tungsten |
|
Jiangxi Yaosheng Tungsten 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 |
|
Vietnam |
| Tungsten |
|
Sanher Tungsten Vietnam Co., Ltd. |
|
Vietnam |
| Tungsten |
|
Tejing (Vietnam) Tungsten Co., Ltd. |
|
Vietnam |
| Tungsten |
|
Vietnam Youngsun Tungsten Industry Co., Ltd |
|
Vietnam |
| Tungsten |
|
Wolfram Bergbau und Hütten AG |
|
Austria |
| Tungsten |
|
Wolfram Company CJSC |
|
Russian Federation |
| Tungsten |
|
Xiamen Tungsten (H.C.) Co., Ltd. |
|
China |
| Tungsten |
|
Xiamen Tungsten Co., Ltd. |
|
China |
| Tungsten |
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
|
China |
17
Annex II
List of Countries of Origin for Subject Minerals
|
|
|
| Argentina |
|
Mozambique |
| Australia |
|
Myanmar |
| Bolivia |
|
Niger |
| Brazil |
|
Nigeria |
| Burundi |
|
Papua New Guinea |
| Canada |
|
Peru |
| China |
|
Philippines |
| Colombia |
|
Poland |
| Democratic Republic of the Congo |
|
Portugal |
| Estonia |
|
Russia |
| Ethiopia |
|
Rwanda |
| Germany |
|
South Africa |
| Guyana |
|
South Korea |
| India |
|
Spain |
| Indonesia |
|
Suriname |
| Japan |
|
Switzerland |
| Kazakhstan |
|
Taiwan |
| Laos |
|
Thailand |
| Malaysia |
|
United Kingdom |
| Mexico |
|
United States |
| Morocco |
|
Zimbabwe |
18
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