UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
DORMAN PRODUCTS, INC.
(Exact name of the registrant as specified in its charter)
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Pennsylvania | | 000-18914 | |
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(State or other jurisdiction of incorporation) | | (Commission File Number) | |
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3400 East Walnut Street, Colmar, Pennsylvania | | 18915 |
(Address of principal executive offices) | | (Zip Code) |
Joseph P. Braun
(215) 712-5638
(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:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 230.13q-1) for the fiscal year ended _____.
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of Dorman Products, Inc. (the “Company,” “Dorman,” “we,” “us,” or “our”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023 (the “Reporting Period”).
Through our Reasonable Country of Origin Inquiry, described in our Conflict Minerals Report, some vendors disclosed to us that scrap/recycled sources of Conflict Minerals (as defined in our Conflict Minerals Report) were identified in their supply chains and did not require due diligence. This determination is discussed further in our Conflict Minerals Report.
A copy of the Company’s Conflict Minerals Report for the Reporting Period is filed as Exhibit 1.01 to this Form SD. It is publicly available at www.dormanproducts.com; however, the contents of that site are not incorporated by reference into, and are not otherwise a part of, this Form SD.
Item 1.02 Exhibit
As specified in Section 3, Item 3.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable
Section 3 – Exhibits
Item 3.01 Exhibits
SIGNATURE
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.
DORMAN PRODUCTS, INC.
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| By: |
| /s/ David Hession |
| Date: May 21, 2024 |
| Name: |
| David Hession |
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| Title: |
| Senior Vice President, Chief Financial Officer |
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| and Treasurer |
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DORMAN PRODUCTS, INC.
Conflict Minerals Report
Explanatory Note
This Conflict Minerals Report (the “Report”) of Dorman Products, Inc. (the “Company,” “Dorman,” “we,” “us,” or “our”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023 (the “Reporting Period”).
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which are collectively referred to in this report as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to metallic forms of tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Company and Product Overview
I.Introduction
The Company is one of the leading suppliers of replacement and upgrade parts in the motor vehicle aftermarket industry, serving passenger cars, light-, medium-, and heavy-duty trucks, as well as specialty vehicles, including utility terrain vehicles (UTVs) and all-terrain vehicles (ATVs). During calendar year 2023, many of our products were manufactured in third party vendor facilities (referred to hereafter as “contract manufacturers”) and certain of our products were manufactured or remanufactured by the Company. This Report relates to products (i) for which Conflict Minerals are necessary to the functionality or production of those products, (ii) that were manufactured, remanufactured or contracted for manufacture by Dorman, and (iii) for which the manufacture was completed during calendar year 2023 (the “Covered Products”). We market and sell the Covered Products in three different sectors of the motor vehicle aftermarket industry: light-duty, heavy-duty and powersports (i.e., specialty vehicles).
The Covered Products include products in the following product categories:
•Power-train products, which includes intake and exhaust manifolds, cooling products, harmonic balancers, fluid lines, fluid reservoirs, connectors, four-wheel drive components and axles, drain plugs, and other engine, transmission and axle components.
•Chassis products, which includes control arms, ball joints, tie-rod ends, brake hardware and hydraulics, wheel and axle hardware, suspension arms, knuckles, links, bushings, leaf springs, and other suspension, steering and brake components.
•Motor vehicle body products, which includes door handles and hinges, window lift motors, window regulators, switches and handles, wiper components, lighting, electrical, and other interior and exterior vehicle body components, including windshields for UTVs.
•Hardware products, which includes threaded bolts and auto body fasteners, automotive and home electrical wiring components, and other hardware assortments and merchandise.
Certain products we sell contain parts that can be recycled, or as more commonly referred to in our industry, remanufactured. We refer to the used product that is ultimately remanufactured as core. A used core is remanufactured and sold to the customer as a replacement for a unit on a vehicle. Customers and end-users that purchase a remanufactured part will generally return the used core to us, which we then use in the remanufacturing process to make another finished good. Our core inventory consists of used cores purchased and held in our facilities, used cores that are in the process of being returned from our customers and end-users, and remanufactured cores held in finished goods inventory at our facilities. Our products that utilize cores include electronic control modules, hybrid batteries and complex mechatronics. To the extent such cores contain Conflict Minerals, the Conflict Minerals are from scrap/recycled sources, and therefore, no further due diligence is required. To the extent the various additional components, parts or raw materials used to modify the cores contain Conflict Minerals, we generally rely on our vendors of such additional components, parts or raw materials regarding the origin of the Conflict Minerals that are included in such Covered Products.
We do not purchase Conflict Minerals directly from mines or smelters/refiners. The Company’s supply chain with respect to the Covered Products is complex and, often times, there are many parties in the supply chain between the Company and the original source of the Conflict Minerals. Therefore, the Company must rely on its supply chain to provide information regarding the origin of the Conflict Minerals that are included in such Covered Products. We believe that the smelters/refiners of the Conflict Minerals are best suited to identify the sources of such minerals, and we have requested that our vendors take steps to identify the applicable smelters/refiners of the Conflict Minerals in our supply chain.
II. Reasonable Country of Origin Inquiry
The Company conducted a good faith Reasonable Country of Origin Inquiry (“RCOI”) with respect to the Conflict Minerals included in the Covered Products. Such RCOI was reasonably designed to determine whether any of the Conflict Minerals included in the Covered Products may have originated in the Covered Countries and whether any of the Conflict Minerals may be from scrap or recycled sources.
We began this year’s RCOI by using internal product expertise to update our list of products that we manufacture, remanufacture or contract to manufacture which may contain Conflict Minerals. We then identified the names of our largest seventy-two (72) vendors that accounted for greater than 90% of dollars spent on (i) Covered Products contracted for manufacture by Dorman, and (ii) Conflict Minerals used in the manufacture and remanufacture of Covered Products by Dorman. Once identified, we sent each such vendor a Conflict Minerals reporting template (described below) and a letter with instructions on how to complete the reporting template. We have adopted the Conflict Minerals Reporting Template (the “Template”) developed by the Responsible Minerals Initiative, formerly the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative, as a standard questionnaire for conducting inquiries into our vendors’ sources of metals. This Template was created as a common means for the collection of sourcing information related to Conflict Minerals.
In completing the Template, vendors were asked, among other questions, whether the products or components they supplied to us or manufactured for us contained Conflict Minerals; the origin of such Conflict Minerals; to identify the sources of Conflict Minerals from their lower tier level suppliers; to determine the smelter/refiner or mine origin or whether the Conflict Minerals were sourced from scrap or recycled sources. The vendors were asked to return a copy of the Template once completed. Upon return of the Template, responses from vendors were evaluated for completeness, consistency, plausibility, and gaps in information. We received completed Templates from sixty-nine (69) of the seventy-two (72) vendors solicited, accounting for greater than 90% of dollars spent on (i) Covered Products contracted for manufacture by Dorman, and (ii) Conflict Minerals used in the manufacture and remanufacture of Covered Products by Dorman.
After reviewing the results of our RCOI and comparing the smelters/refiners identified in the supply-chain survey against verified lists produced by the Responsible Minerals Initiative (“RMI”), we determined that we had reason to believe that some of the Conflict Minerals necessary for the functionality of our Covered Products may have originated in a Covered Country. Therefore, we determined that the Rule required that we exercise due diligence on the source and chain of custody of such Conflict Minerals.
III. Design of Due Diligence Framework
We designed our due diligence framework to conform in all material respects with the OECD (2016) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition.
IV. Due Diligence Measures Performed by the Company
Our Vice President, Supply Chain oversaw the due diligence measures that we performed for Covered Products. Those measures included, but were not limited to, the following:
•Communicating our Conflict Minerals Policy Statement (the “Conflict Minerals Policy”) to our vendors. A copy of the Company’s Conflict Minerals Policy is available on the Investor Relations portal of www.dormanproducts.com; however, the contents of that site are not incorporated by reference into, and are not otherwise a part of, this Form SD.
•Including contractual provisions in our standard form of vendor agreements requiring applicable vendors to abide by the terms of the Company’s Conflict Mineral Policy.
•Utilizing a Qualification Review Board (the “QRB”), which is an internal cross-functional team that reviewed supplier information and performance to ascertain whether we are partnering with suppliers that meet our high standards and comply with our policies. The QRB reviewed the results of supplier audits and measurements to assure continued compliance with the Company’s expectations.
•Maintaining a multi-disciplinary internal team to implement our Conflict Minerals due diligence measures. Our Conflict Minerals project team was comprised of members of the global trade compliance, quality, supply chain and legal departments who met and collaborated at various times during the year to discuss the due diligence process and progress.
•Distributing our Templates to our key suppliers, as discussed in greater detail above.
•Storing our Conflict Minerals records, including all returned Templates, in a web-based application.
•Reporting to senior management on vendors’ responses to our Conflict Minerals information requests.
•Using a third-party service to compare smelters/refiners identified by vendors in their Template responses to the RMI lists of validated conflict free facilities.
Appendix A contains a list of known smelters/refiners reported by the Company’s vendors which have been determined to be legitimate mineral processing operations and may have been used to process the Conflict Minerals utilized in the Covered Products. Based on the information obtained pursuant to the due diligence process, the Company does not have sufficient information with respect to products or components supplied to it or manufactured for it to determine the country of origin of the Conflict Minerals in all Covered Products. At the same time, to the extent that vendors supplied information, the Company received no information from its vendors indicating that the Conflict Minerals in the Company’s Covered Products directly or indirectly financed or benefitted armed groups in the Covered Countries. In some cases, information was provided to us for the entire supply chain of a vendor and was not necessarily limited to facilities that have been confirmed to contribute necessary Conflict Minerals to a Covered Product. Accordingly, we have been unable to definitely link the identified smelters/refiners to only those products/materials in our supply chain; therefore, our smelter/refiner list likely contains more processing facilities than are actually in our supply chain or Covered Products. However, based on the information that was obtained, the Company has reasonably determined that countries of origin of the Conflict Minerals may include the countries listed within Appendix A.
We are a downstream purchaser of Conflict Minerals. Accordingly, the efforts we have undertaken to identify the source and chain of custody of the Conflict Minerals in our Covered Products reflect our circumstances and position in the supply chain. As a result, our inquiry can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals necessary to the functionality of the Covered Products. Our process relies on data obtained directly from our vendors who seek similar information within their supply chain to identify the original sources of the necessary Conflict Minerals. Such sources of information may yield inaccurate or incomplete information.
V. Steps to Further Mitigate Risk and Improve Due Diligence in 2024
The Company expects to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Company’s products finance or benefit armed groups in the Covered Countries:
•the Company will continue to engage with vendors in its supply chain to improve the completeness and accuracy of information provided to the Company, including encouraging such vendors to provide product level information to improve the accuracy of information provided to the Company;
•the Company will review changes in vendor circumstances of which it becomes aware that may impact their compliance with the Company’s Conflict Minerals Policy, and in turn may impact the Company’s continued engagement of and relationship with certain vendors;
•the Company will continue to encourage its vendors to take similar measures with their suppliers to ensure alignment with the Company’s sourcing philosophy throughout the supply chain; and
•the Company will continue to encourage its vendors to have only verified “conflict free” sources.
APPENDIX A
SMELTERS/REFINERS
Set forth below are known smelters/refiners reported by the Company’s vendors which may have been used to process the Conflict Minerals utilized in the Covered Products manufactured in calendar year 2023 (“Vendor-Reported Legitimate Facilities”).
Table 1
The following Vendor-Reported Legitimate Facilities achieved during 2023 a Conflict Free designation by the Responsible Minerals Initiative (RMI) or an audit program with which RMI has mutual recognition.
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| Metal | Official Smelter Name |
| Gold | Abington Reldan Metals, LLC |
| Gold | Agosi AG |
| Gold | Aida Chemical Industries Co., Ltd. |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao |
| Gold | Argor-Heraeus S.A. |
| Gold | Asahi Pretec Corp. |
| Gold | Asahi Refining Canada Ltd. |
| Gold | Asahi Refining USA Inc. |
| Gold | Asaka Riken Co., Ltd. |
| Gold | Aurubis AG |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold | Boliden AB |
| Gold | C. Hafner GmbH + Co. KG |
| Gold | CCR Refinery - Glencore Canada Corporation |
| Gold | Chimet S.p.A. |
| Gold | Chugai Mining |
| Gold | Coimpa Industrial LTDA |
| Gold | Dowa |
| Gold | DSC (Do Sung Corporation) |
| Gold | Eco-System Recycling Co., Ltd. East Plant |
| Gold | Eco-System Recycling Co., Ltd. North Plant |
| Gold | Eco-System Recycling Co., Ltd. West Plant |
| Gold | Gold by Gold Colombia |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM |
| Gold | Heimerle + Meule GmbH |
| Gold | Heraeus Germany GmbH Co. KG |
| Gold | Heraeus Metals Hong Kong Ltd. |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Gold | Istanbul Gold Refinery |
| Gold | Italpreziosi |
| Gold | Japan Mint |
| Gold | Jiangxi Copper Co., Ltd. |
| Gold | JX Nippon Mining & Metals Co., Ltd. |
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| Gold | Kazzinc |
| Gold | Kennecott Utah Copper LLC |
| Gold | KGHM Polska Miedz Spolka Akcyjna |
| Gold | Kojima Chemicals Co., Ltd. |
| Gold | Korea Zinc Co., Ltd. |
| Gold | L'Orfebre S.A. |
| Gold | LS-NIKKO Copper Inc. |
| Gold | LT Metal Ltd. |
| Gold | Materion |
| Gold | Matsuda Sangyo Co., Ltd. |
| Gold | Metal Concentrators SA (Pty) Ltd. |
| Gold | Metalor Technologies (Hong Kong) Ltd. |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. |
| Gold | Metalor Technologies (Suzhou) Ltd. |
| Gold | Metalor Technologies S.A. |
| Gold | Metalor USA Refining Corporation |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. |
| Gold | Mitsubishi Materials Corporation |
| Gold | Mitsui Mining and Smelting Co., Ltd. |
| Gold | MKS PAMP SA |
| Gold | MMTC-PAMP India Pvt., Ltd. |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. |
| Gold | Navoi Mining and Metallurgical Combinat |
| Gold | NH Recytech Company |
| Gold | Nihon Material Co., Ltd. |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
| Gold | Ohura Precious Metal Industry Co., Ltd. |
| Gold | Planta Recuperadora de Metales SpA |
| Gold | PT Aneka Tambang (Persero) Tbk |
| Gold | PX Precinox S.A. |
| Gold | Rand Refinery (Pty) Ltd. |
| Gold | REMONDIS PMR B.V. |
| Gold | Royal Canadian Mint |
| Gold | SAFINA A.S. |
| Gold | SEMPSA Joyeria Plateria S.A. |
| Gold | Shandong Gold Smelting Co., Ltd. |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. |
| Gold | Solar Applied Materials Technology Corp. |
| Gold | Sumitomo Metal Mining Co., Ltd. |
| Gold | SungEel HiMetal Co., Ltd. |
| Gold | T.C.A S.p.A |
| Gold | Tanaka Kikinzoku Kogyo K.K. |
| Gold | Tokuriki Honten Co., Ltd. |
| Gold | TOO Tau-Ken-Altyn |
| Gold | Torecom |
| Gold | Umicore S.A. Business Unit Precious Metals Refining |
| Gold | United Precious Metal Refining, Inc. |
| Gold | Valcambi S.A. |
| | | | | |
| Gold | WEEEREFINING |
| Gold | Western Australian Mint (T/a The Perth Mint) |
| Gold | WIELAND Edelmetalle GmbH |
| Gold | Yamakin Co., Ltd. |
| Gold | Yokohama Metal Co., Ltd. |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Tantalum | AMG Brasil |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. |
| Tantalum | D Block Metals, LLC |
| Tantalum | F&X Electro-Materials Ltd. |
| Tantalum | FIR Metals & Resource Ltd. |
| Tantalum | Global Advanced Metals Aizu |
| Tantalum | Global Advanced Metals Boyertown |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| Tantalum | Jiangxi Tuohong New Raw Material |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| Tantalum | Jiujiang Tanbre Co., Ltd. |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| Tantalum | KEMET de Mexico |
| Tantalum | Materion Newton Inc. |
| Tantalum | Metallurgical Products India Pvt., Ltd. |
| Tantalum | Mineracao Taboca S.A. |
| Tantalum | Molycorp Silmet A.S. |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum | QuantumClean |
| Tantalum | Resind Industria e Comercio Ltda. |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. |
| Tantalum | Taki Chemical Co., Ltd. |
| Tantalum | TANIOBIS Co., Ltd. |
| Tantalum | TANIOBIS GmbH |
| Tantalum | TANIOBIS Japan Co., Ltd. |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG |
| Tantalum | Telex Metals |
| Tantalum | Ulba Metallurgical Plant JSC |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED |
| Tantalum | XinXing Haorong Electronic Material Co., Ltd. |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| Tin | Alpha |
| Tin | Aurubis Beerse |
| Tin | Aurubis Berango |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. |
| Tin | China Tin Group Co., Ltd. |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
| Tin | CRM Synergies |
| Tin | CV Ayi Jaya |
| Tin | CV Venus Inti Perkasa |
| | | | | |
| Tin | DS Myanmar |
| Tin | EM Vinto |
| Tin | Estanho de Rondonia S.A. |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. |
| Tin | Fenix Metals |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
| Tin | HuiChang Hill Tin Industry Co., Ltd. |
| Tin | Jiangxi New Nanshan Technology Ltd. |
| Tin | Luna Smelter, Ltd. |
| Tin | Magnu's Minerais Metais e Ligas Ltda. |
| Tin | Malaysia Smelting Corporation (MSC) |
| Tin | Metallic Resources, Inc. |
| Tin | Mining Minerals Resources SARL |
| Tin | Minsur |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin | O.M. Manufacturing Philippines, Inc. |
| Tin | Operaciones Metalurgicas S.A. |
| Tin | PT Aries Kencana Sejahtera |
| Tin | PT Artha Cipta Langgeng |
| Tin | PT ATD Makmur Mandiri Jaya |
| Tin | PT Babel Inti Perkasa |
| Tin | PT Babel Surya Alam Lestari |
| Tin | PT Bangka Prima Tin |
| Tin | PT Bangka Serumpun |
| Tin | PT Belitung Industri Sejahtera |
| Tin | PT Bukit Timah |
| Tin | PT Cipta Persada Mulia |
| Tin | PT Menara Cipta Mulia |
| Tin | PT Mitra Stania Prima |
| Tin | PT Mitra Sukses Globalindo |
| Tin | PT Premium Tin Indonesia |
| Tin | PT Prima Timah Utama |
| Tin | PT Putera Sarana Shakti (PT PSS) |
| Tin | PT Rajawali Rimba Perkasa |
| Tin | PT Rajehan Ariq |
| Tin | PT Refined Bangka Tin |
| Tin | PT Sariwiguna Binasentosa |
| Tin | PT Stanindo Inti Perkasa |
| Tin | PT Sukses Inti Makmur |
| Tin | PT Timah Tbk Kundur |
| Tin | PT Timah Tbk Mentok |
| Tin | PT Tinindo Inter Nusa |
| Tin | PT Tommy Utama |
| Tin | Rui Da Hung |
| Tin | Super Ligas |
| Tin | Thaisarco |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. |
| Tin | Tin Technology & Refining |
| | | | | |
| Tin | White Solder Metalurgia e Mineracao Ltda. |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
| Tungsten | A.L.M.T. TUNGSTEN Corp. |
| Tungsten | Asia Tungsten Products Vietnam Ltd. |
| Tungsten | China Molybdenum Co., Ltd. |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten | Cronimet Brasil Ltda |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten | Global Tungsten & Powders LLC |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten | H.C. Starck Tungsten GmbH |
| Tungsten | Hubei Green Tungsten Co., Ltd. |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
| Tungsten | Japan New Metals Co., Ltd. |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. |
| Tungsten | Kennametal Fallon |
| Tungsten | Kennametal Huntsville |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. |
| Tungsten | Wolfram Bergbau und Hutten AG |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
| Tungsten | Xiamen Tungsten Co., Ltd. |
Table 2 – The following Vendor-Reported Legitimate Facilities were validated as smelters/refiners but were unaudited in 2023 by the RMI (or another similar program).
| | | | | |
| Metal | Official Smelter Name |
| Gold | 8853 S.p.A. |
| Gold | ABC Refinery Pty Ltd. |
| Gold | Advanced Chemical Company |
| Gold | Al Etihad Gold Refinery DMCC |
| Gold | Albino Mountinho Lda. |
| Gold | Alexy Metals |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Gold | AU Traders and Refiners |
| Gold | Augmont Enterprises Private Limited |
| Gold | Bangalore Refinery |
| Gold | Caridad |
| Gold | Cendres + Metaux S.A. |
| Gold | CGR Metalloys Pvt Ltd. |
| Gold | Daye Non-Ferrous Metals Mining Ltd. |
| | | | | |
| Gold | Degussa Sonne / Mond Goldhandel GmbH |
| Gold | Dijllah Gold Refinery FZC |
| Gold | Dongwu Gold Group |
| Gold | Emerald Jewel Industry India Limited (Unit 1) |
| Gold | Emerald Jewel Industry India Limited (Unit 2) |
| Gold | Emerald Jewel Industry India Limited (Unit 3) |
| Gold | Emerald Jewel Industry India Limited (Unit 4) |
| Gold | Emirates Gold DMCC |
| Gold | Fidelity Printers and Refiners Ltd. |
| Gold | Fujairah Gold FZC |
| Gold | Geib Refining Corporation |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. |
| Gold | Gold Coast Refinery |
| Gold | Guangdong Jinding Gold Limited |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold | Hunan Chenzhou Mining Co., Ltd. |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| Gold | HwaSeong CJ CO., LTD. |
| Gold | Industrial Refining Company |
| Gold | International Precious Metal Refiners |
| Gold | JALAN & Company |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| Gold | JSC Novosibirsk Refinery |
| Gold | JSC Uralelectromed |
| Gold | K.A. Rasmussen |
| Gold | Kaloti Precious Metals |
| Gold | Kazakhmys Smelting LLC |
| Gold | Kundan Care Products Ltd. |
| Gold | Kyrgyzaltyn JSC |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO |
| Gold | L'azurde Company For Jewelry |
| Gold | Lingbao Gold Co., Ltd. |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| Gold | Marsam Metals |
| Gold | MD Overseas |
| Gold | Metallix Refining Inc. |
| Gold | Modeltech Sdn Bhd |
| Gold | Morris and Watson |
| Gold | Moscow Special Alloys Processing Plant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
| Gold | Pease & Curren |
| Gold | Penglai Penggang Gold Industry Co., Ltd. |
| Gold | Prioksky Plant of Non-Ferrous Metals |
| Gold | QG Refining, LLC |
| Gold | Refinery of Seemine Gold Co., Ltd. |
| Gold | SAAMP |
| | | | | |
| Gold | Sabin Metal Corp. |
| Gold | Safimet S.p.A |
| Gold | Sai Refinery |
| Gold | Samduck Precious Metals |
| Gold | SAMWON METALS Corp. |
| Gold | Shandong Humon Smelting Co., Ltd. |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| Gold | Shenzhen CuiLu Gold Co., Ltd. |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. |
| Gold | Shirpur Gold Refinery Ltd. |
| Gold | Singway Technology Co., Ltd. |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals |
| Gold | Sovereign Metals |
| Gold | State Research Institute Center for Physical Sciences and Technology |
| Gold | Sudan Gold Refinery |
| Gold | Super Dragon Technology Co., Ltd. |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. |
| Gold | Umicore Precious Metals Thailand |
| Gold | Yunnan Copper Industry Co., Ltd. |
| Tantalum | 5D Production OU |
| Tantalum | Solikamsk Magnesium Works OAO |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. |
| Tin | Gejiu Kai Meng Industry and Trade LLC |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Tin | Ma'anshan Weitai Tin Co., Ltd. |
| Tin | Melt Metais e Ligas S.A. |
| Tin | Precious Minerals and Smelting Limited |
| Tin | PT Bangka Tin Industry |
| Tin | PT Panca Mega Persada |
| Tin | PT Tirus Putra Mandiri |
| Tungsten | ACL Metais Eireli |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. |
| Tungsten | Hunan Jintai New Material Co., Ltd. |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. |
Based on the information that was obtained from our suppliers, the Company has reasonably determined that the countries of origin with respect to the Vendor-Reported Legitimate Facilities listed in each of Table 1 and Table 2 may include the following: Angola, Argentina, Australia, Austria, Bolivia, Brazil, Canada, Central African Republic, Chile, China, Congo (Brazzaville), Czech Republic, Djibouti, DRC- Congo (Kinshasa), Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guinea, Guyana, India, Indonesia, Ireland, Japan, Kazakhstan, Korea, Republic of, Kyrgyzstan, Laos, Madagascar, Malaysia, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Poland, Portugal, Russian Federation, Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa, Spain, Sweden, Switzerland, Taiwan, Turkey, United Kingdom, United States, Uzbekistan, Vietnam, Zambia and Zimbabwe.
Dorman Products (NASDAQ:DORM)
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