UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
______________________
FORM SD
Specialized Disclosure Report
______________________
STEELCASE INC.
(Exact name of registrant as specified in its charter)
| | | | | | | | |
| Michigan | 1-13873 | 38-0819050 |
| (State or other jurisdiction of incorporation or organization) | (Commission File Number) | (IRS employer identification number) |
| | |
| 901 44th Street SE | | |
| Grand Rapids, Michigan | | 49508 |
| (Address of principal executive offices) | | (Zip code) |
| | |
| Liesl A. Maloney (616) 247-2710 |
| (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, 2023.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Form SD of Steelcase Inc. is filed in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1, 2023 to December 31, 2023. As used in this Form SD, unless otherwise expressly stated or the context otherwise requires, all references to “Steelcase,” “we,” “our,” “Company” and similar references are to Steelcase Inc. and its consolidated subsidiaries.
Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in Rule 13p-1 are necessary to the production or functionality of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“Conflict Minerals”). The “Covered Countries” for the purposes of Rule 13p-1 are the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.
Certain of our operations manufacture or contract to manufacture products for which Conflict Minerals are necessary to the production or functionality of those products. We conducted a reasonable country of origin inquiry regarding such Conflict Minerals, which was designed to determine whether any of the Conflict Minerals originated in the Covered Countries or were from recycled or scrap sources. For those Conflict Minerals which we believe may have originated in the Covered Countries and which we were unable to conclude were from scrap or recycled sources, we exercised due diligence on the source and chain of custody of those Conflict Minerals. Our reasonable country of origin inquiry and due diligence processes are described in our Conflict Minerals Report, which is filed as Exhibit 1.01 to this Form SD, and is publicly available at ir.steelcase.com/financial-information/sec-filings/default.aspx.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01, Steelcase Inc. 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.
| | | | | |
Exhibit Number | Description |
| 1.01 | Conflict Minerals Report of Steelcase Inc. |
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.
| | | | | |
| By: | /s/ Lizbeth S. O'Shaughnessy |
| Lizbeth S. O'Shaughnessy
Senior Vice President, Chief Administrative Officer,
General Counsel and Secretary |
Date: May 22, 2024
Exhibit 1.01
STEELCASE INC.
Conflict Minerals Report
For the reporting period from January 1, 2023 to December 31, 2023
Introduction
This Conflict Minerals Report (“Report”) of Steelcase Inc. has been prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period January 1, 2023 to December 31, 2023. As used in this Report and unless otherwise expressly stated or the context otherwise requires, all references to “Steelcase,” “we,” “our,” “Company” and similar references are references to Steelcase Inc. and its consolidated subsidiaries.
Rule 13p-1 was adopted by the Securities and Exchange Commission (“SEC”) to implement certain disclosure requirements related to minerals specified in the rule. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“Conflict Minerals”). Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which Conflict Minerals are necessary to the production or functionality of those products (such minerals are referred to herein as “Necessary Conflict Minerals”).
Company Overview
We offer a comprehensive portfolio of furniture and architectural products and services designed to help customers create workplaces that help people reach their full potential at work, wherever work happens.
Conflict Minerals Policy and Supplier Code of Conduct
Our Conflict Minerals Policy states our intent to refrain from purchasing products, components or materials containing any Necessary Conflict Minerals from the Covered Countries that directly or indirectly finance or benefit armed groups and are not otherwise from recycled or scrap sources. The policy also expresses our expectation that our suppliers follow this same practice, establish appropriate due diligence programs and provide us with information, upon our request, regarding the source and chain of custody of any Necessary Conflict Minerals in the products, components or materials they sell to us. In addition, our Supplier Code of Conduct includes a Fair Operating Practices section regarding “Responsible Sourcing of Minerals and Other Materials” which is consistent with our Conflict Minerals Policy. Our policy and our Supplier Code of Conduct are publicly available on our website at www.steelcase.com/about/steelcase/suppliers/.
Reasonable Country of Origin Inquiry
Pursuant to Rule 13p-1, we conducted a Reasonable Country of Origin Inquiry (“RCOI”). Our RCOI began with an evaluation of our global suppliers who provided materials, components or products that became part of products we manufactured or contracted to be manufactured in 2023 which contained or were likely to contain Necessary Conflict Minerals. This evaluation consisted of examining internal records such as bills of materials or other product specifications and performing a qualitative review of purchasing records and/or information provided by the supplier.
Based on our evaluation, we surveyed a total of 199 suppliers that provided materials, components or products which we concluded contained or were likely to contain Necessary Conflict Minerals. The suppliers were asked to report on the presence of any Necessary Conflict Minerals in the goods sold to us. We achieved a greater than 89% response rate from the surveyed suppliers (measured by spend
during the reporting period) with Conflict Minerals Reporting Templates (“CMRTs”) completed at either the company or product level.
Due Diligence
Design of Due Diligence
We designed our due diligence measures to conform to the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on tin, tantalum, tungsten, and gold (collectively, the “OECD Guidance”).
Due Diligence Measures Performed
Pursuant to Rule 13p-1, we undertook due diligence measures on the source and chain of custody of the Necessary Conflict Minerals in our products which we had reason to believe may have originated from the Democratic Republic of the Congo or an adjoining country (collectively, the "Covered Countries") and which may not have come from recycled or scrap sources. Following is a summary of the due diligence actions we performed with regard to the reporting period:
1. Establish strong company management systems
•As referenced previously, we have a Conflict Minerals Policy which is shared with our supply chain and publicly available on our website.
•We have an established project team from our Sustainability department which leads the RCOI, due diligence and reporting processes. Our Conflict Minerals Governance Committee provides oversight for the project team and is comprised of senior management from our legal, compliance and internal audit functions.
•We are a “downstream company” in our supply chain, meaning we are generally several tiers removed from the smelters and refiners which process the Necessary Conflict Minerals present in some of our products. Accordingly, we rely on communication with and through our immediate suppliers to provide us with information relating to the presence and sourcing of the Necessary Conflict Minerals present in our products.
•We intend to maintain our records relating to Conflict Minerals reporting for a minimum of five years after each applicable reporting period, in accordance with the OECD Guidance and our own Records Retention Policy.
•Our Supplier Code of Conduct includes language that reinforces our Conflict Minerals Policy, and we have included Conflict Minerals reporting requirements in our purchasing contract templates.
•We have implemented Conflict Minerals checkpoints into both our supplier qualification and product development processes to begin engaging new suppliers and suppliers of new materials early in the process.
•We have continued to educate our suppliers and employees about Conflict Minerals and the related reporting requirements in each of the regions in which we operate: the Americas, Europe, Middle East and Africa, and Asia Pacific.
•We have continued to provide a grievance mechanism channel through our international integrity helpline to both employees and non-employees for reporting ethics and compliance issues, including those related to Conflict Minerals. Information about contacting the helpline can be found at integrity.steelcase.com.
2. Identify and assess risks in the supply chain
•We surveyed suppliers we either knew or had reason to believe may have provided materials, components or products which may contain Necessary Conflict Minerals, using the due diligence tool created by the Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“GESI”)’s Responsible Minerals Initiative (“RMI”)’s CMRT, which is a survey designed to identify the smelters and refiners that process, and the country of origin of, Conflict Minerals contained in the products supplied by the applicable supplier.
•We selected a subset of suppliers among all surveyed suppliers to be targeted for prioritized follow up. We referred to this subset as “prioritized suppliers.” Prioritized suppliers were selected for additional follow up to capture the greatest risk in our supply chain. The criteria used to select prioritized suppliers included: material composition, previously submitted smelter and refiner information, geographic region, spend, type of supplier and quantity of parts purchased.
•We followed up with prioritized suppliers that did not respond to our survey request or that we identified as providing incomplete or potentially inaccurate information to seek additional clarification or remediation and to bring them into conformity with our Conflict Minerals Policy and contractual agreements.
•We cross-referenced smelters and refiners identified in the CMRTs submitted by our suppliers against the list of facilities that have received a “conformant” designation from the Responsible Minerals Assurance Process ("RMAP") and its cross-recognized programs (e.g. the Responsible Jewellery Council and the London Bullion Market Association, otherwise known as “RJC” and “LBMA,” respectfully), whose designations provide country of origin and additional due diligence information on the Conflict Minerals sourced by such facilities.
•We continued to encourage the participation of smelters and refiners in the RMAP, through our continued membership and active participation in the RMI and related working groups, and by conducting outreach to those smelters and refiners identified by our supply chain which are not yet participating in the RMAP or require additional assistance with the process.
3. Design and implement a strategy to respond to identified risks
•The status and findings of our RCOI and due diligence efforts were reported to our Conflict Minerals Governance Committee during regular updates between the months of December 2023 and May 2024.
•We intend to follow a risk mitigation plan that is consistent with our Conflict Minerals Policy. If a smelter or refiner in our supply chain were known to be sourcing from a mine within a Covered Country which directly or indirectly finances or benefits armed groups, we would consider all available options, including, but not limited to, making changes to our sourcing of those items.
4. Independent third-party audit of smelter or refiner’s due diligence practices
•As a downstream company and an active member of the RMI, we support the independent third-party audits of smelters and refiners performed by the RMAP and other cross-recognized programs (e.g. RJC and LBMA) to audit the conformant status of smelters and refiners.
5. Report annually on supply chain due diligence
•We plan to report annually to the SEC by filing a Form SD and Conflict Minerals Report as required by applicable law.
Results of Due Diligence Measures Performed
Inherent Limitations of Due Diligence Measures
As a downstream company in a complex supply chain, our due diligence measures can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Necessary Conflict Minerals contained in our products. Our due diligence processes rely on obtaining data from our tier one suppliers and those suppliers seeking similar information from their supply chains to identify the original sources of the Necessary Conflict Minerals. We also rely on information collected and provided by independent third party audit programs. Such sources of information may yield inaccurate or incomplete information.
Product Description
For the reporting period, we identified the following types of products which we either manufactured or contracted with others to manufacture that contained Necessary Conflict Minerals which may have originated in the Covered Countries but for which we could not confirm the countries of origin of all the Necessary Conflict Minerals:
Some of our desking products, wall systems, doors, tiles, panels, lighting, and other office furniture products which contain one or more of the following: electronic and electrical components, including lighting, and glass panels.
Determination
Based on the information provided by our suppliers, the facilities that may have been used to process the Necessary Conflict Minerals used in our products may include the smelters and refiners listed in Annex I.
Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of all the Necessary Conflict Minerals in the products described above in the “Product Description” section of this report or whether the Necessary Conflict Minerals were from recycled or scrap sources. However, based on the information provided by our suppliers and available from the RMI, the countries of origin of the Necessary Conflict Minerals contained in the products described above may include, but may not be limited to, the countries listed in Annex II, in addition to recycled or scrap sources.
Smelter and Refiner Summary
In response to our survey, our suppliers identified 317 smelter and refiner facilities which may have processed the Necessary Conflict Minerals contained in the materials provided to us. Of those facilities, as of May 22, 2024:
•215 have received a “conformant” designation from the RMAP;
•4 have not yet received a “conformant” designation but are considered “active” in the RMAP or are "in communication" with the RMAP or other cross-recognized programs; and
•the remaining facilities are not currently actively participating in the RMAP.
Under the RMAP’s standards, “conformant” means a facility has been audited and found to be conformant with the relevant RMAP protocol or cross-recognized program, and “active” means a facility that is engaged in the RMAP program but has not yet been found to be "conformant." Facilities characterized as "in communication" are not yet "active" but are in communication with the RMAP or cross-recognized program.
Each of the facilities which we believe may source Conflict Minerals from the Covered Countries has received a “conformant” designation from the RMAP.
To our knowledge, none of the Necessary Conflict Minerals contained in the products we manufactured or contracted to be manufactured during the reporting period directly or indirectly financed or benefitted armed groups in the Covered Countries.
Risk Mitigation
We remain committed to familiarizing our supply chain with our compliance process and enhancing our internal systems of controls, and we expect to continue improving upon the steps outlined below. These are the steps we took for our 2023 reporting cycle to mitigate the risk that the Necessary Conflict Minerals contained in the products we manufacture or contract to be manufactured may have benefited armed groups:
•further educated our supply chain and employees about Conflict Minerals reporting requirements;
•continued pursuing Conflict Minerals identification during our supplier qualification and product development processes;
•continued including our Conflict Minerals clause in purchasing contracts, either upon establishment or during the renewal process;
•performed additional material research and further identified where Necessary Conflict Minerals are present in our existing products and likely to be present in future products, especially with regard to recent acquisitions that will impact future reporting;
•surveyed suppliers and collected responses for the respective reporting period;
•prioritized supplier follow up by using criteria which captured the greatest risk and leverage in our supply chain;
•continued to encourage our suppliers to obtain current, accurate and complete smelter and refiner information that is specific to the products they sell to us;
•compared and validated supplier-identified smelters and refiners to information collected via independent smelter and refiner audit programs such as the RMAP; and
•maintained our membership and active participation in the RMI and related working groups.
Conclusion Statement
We have provided the information in this Report as of the date of filing with the SEC.
Annex I
| | | | | | | | |
| Metal | Facility Name | Facility Location |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
| Gold | Chugai Mining | Japan |
| Gold | Dowa | Japan |
| Gold | LS-NIKKO Copper Inc. | Republic of Korea |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Gold | Asahi Pretec Corp. | Japan |
| Gold | Solar Applied Materials Technology Corp. | Taiwan |
| Gold | Metalor USA Refining Corporation | United States Of America |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | Asahi Refining USA Inc. | United States Of America |
| Gold | Asahi Refining Canada Ltd. | Canada |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Caridad | Mexico |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold | Materion | United States Of America |
| Gold | Kazzinc | Kazakhstan |
| Gold | Royal Canadian Mint | Canada |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
| Gold | Metalor Technologies S.A. | Switzerland |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russia |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russia |
| | | | | | | | |
| Metal | Facility Name | Facility Location |
| Gold | PAMP S.A. | Switzerland |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russia |
| Gold | Torecom | Republic of Korea |
| Gold | United Precious Metal Refining, Inc. | United States Of America |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | Advanced Chemical Company | United States Of America |
| Gold | Aurubis AG | Germany |
| Gold | JSC Uralelectromed | Russia |
| Gold | Refinery of Seemine Gold Co., Ltd. | China |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | PX Precinox S.A. | Switzerland |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russia |
| Gold | Yamakin Co., Ltd. | Japan |
| Gold | Shirpur Gold Refinery Ltd. | India |
| Gold | Korea Zinc Co., Ltd. | Republic of Korea |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Chimet S.p.A. | Italy |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Samduck Precious Metals | Republic of Korea |
| Gold | Samwon Metals Corp. | Republic of Korea |
| Gold | MMTC-PAMP India Pvt., Ltd. | India |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | DSC (Do Sung Corporation) | Republic of Korea |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | LT Metal Ltd. | Republic of Korea |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | Valcambi S.A. | Switzerland |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | Guangdong Jinding Gold Limited | China |
| | | | | | | | |
| Metal | Facility Name | Facility Location |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
| Gold | Japan Mint | Japan |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | Sudan Gold Refinery | Sudan |
| Gold | NH Recytech Company | Republic of Korea |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | International Precious Metal Refiners | United Arab Emirates |
| Gold | T.C.A S.p.A | Italy |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland |
| Gold | Singway Technology Co., Ltd. | Taiwan |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Gold | Shandong Humon Smelting Co., Ltd. | China |
| Gold | African Gold Refinery | Uganda |
| Gold | Gold Coast Refinery | Ghana |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | OJSC Novosibirsk Refinery | Russia |
| Gold | HwaSeong CJ CO., LTD. | Republic of Korea |
| Gold | Kennecott Utah Copper LLC | United States Of America |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | REMONDIS PMR B.V. | Netherlands |
| Gold | Fujairah Gold FZC | United Arab Emirates |
| Gold | Tony Goetz NV | Belgium |
| Gold | Marsam Metals | Brazil |
| Gold | CGR Metalloys Pvt Ltd. | India |
| Gold | Sovereign Metals | India |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | Sabin Metal Corp. | United States Of America |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
| Gold | Abington Reldan Metals, LLC | United States Of America |
| | | | | | | | |
| Metal | Facility Name | Facility Location |
| Gold | 8853 S.p.A. | Italy |
| Gold | L'Orfebre S.A. | Andorra |
| Gold | SAAMP | France |
| Gold | Italpreziosi | Italy |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | Boliden AB | Sweden |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | Metalor Technologies (Suzhou) Ltd. | China |
| Gold | Moscow Special Alloys Processing Plant | Russia |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | Morris and Watson | New Zealand |
| Gold | SAFINA A.S. | Czechia |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
| Gold | Pease & Curren | United States Of America |
| Gold | Safimet S.p.A | Italy |
| Gold | Kaloti Precious Metals | United Arab Emirates |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Sai Refinery | India |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russia |
| Gold | Modeltech Sdn Bhd | Malaysia |
| Gold | Planta Recuperadora de Metales SpA | Chile |
| Gold | SungEel HiMetal Co., Ltd. | Republic of Korea |
| Gold | QG Refining, LLC | United States Of America |
| Gold | JALAN & Company | India |
| Gold | AU Traders and Refiners | South Africa |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
| Gold | Augmont Enterprises Private Limited | India |
| Gold | Bangalore Refinery | India |
| Gold | Kundan Care Products Ltd. | India |
| Gold | K.A.Rasmussen as | Norway |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China |
| Tantalum | Exotech Inc. | United States Of America |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | Solikamsk Magnesium Works OAO | Russia |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | China |
| Tantalum | Telex Metals | United States Of America |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| | | | | | | | |
| Metal | Facility Name | Facility Location |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tantalum | KEMET Blue Metals | Mexico |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | QuantumClean | United States Of America |
| Tantalum | H.C. Starck Co., Ltd. | Thailand |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany |
| Tantalum | H.C. Starck Inc. | United States Of America |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
| Tantalum | LSM Brasil S.A. | Brazil |
| Tantalum | D Block Metals, LLC | United States Of America |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Mineracao Taboca S.A. | Brazil |
| Tantalum | NPM Silmet AS | Estonia |
| Tantalum | H.C. Starck Ltd. | Japan |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tantalum | Global Advanced Metals Boyertown | United States Of America |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | China |
| Tantalum | Plansee SE Reutte | Austria |
| Tin | Minsur | Peru |
| Tin | PT Tinindo Inter Nusa | Indonesia |
| Tin | PT Bukit Timah | Indonesia |
| Tin | PT Aries Kencana Sejahtera | Indonesia |
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia |
| Tin | Mineracao Taboca S.A. | Brazil |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | PT Belitung Industri Sejahtera | Indonesia |
| Tin | PT Sariwiguna Binasentosa | Indonesia |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | Operaciones Metalurgical S.A. | Bolivia |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| | | | | | | | |
| Metal | Facility Name | Facility Location |
| Tin | PT Prima Timah Utama | Indonesia |
| Tin | China Tin Group Co., Ltd. | China |
| Tin | Alpha | United States Of America |
| Tin | EM Vinto | Bolivia |
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| Tin | CV Serumpun Sebalai | Indonesia |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | China |
| Tin | Metallo-Chimique N.V. | Belgium |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
| Tin | PT Bangka Serumpun | Indonesia |
| Tin | Pongpipat Company Limited | Myanmar |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China |
| Tin | Precious Minerals and Smelting Limited | India |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Thaisarco | Thailand |
| Tin | Resind Industria e Comercio Ltda. | Brazil |
| Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam |
| Tin | Mitsubishi Materials Corporation | Japan |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | Estanho de Rondonia S.A. | Brazil |
| Tin | Fenix Metals | Poland |
| Tin | Rui Da Hung | Taiwan |
| Tin | Luna Smelter, Ltd. | Rwanda |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | Yunnan Tin Company Limited | China |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| | | | | | | | |
| Metal | Facility Name | Facility Location |
| Tin | Metallo Spain S.L.U. | Spain |
| Tin | Super Ligas | Brazil |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
| Tin | Dowa | Japan |
| Tin | Metallic Resources, Inc. | United States Of America |
| Tin | Modeltech Sdn Bhd | Malaysia |
| Tin | Tin Technology & Refining | United States Of America |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
| Tin | PT Mitra Sukses Globalindo | Indonesia |
| Tin | PT Rajawali Rimba Perkasa | Indonesia |
| Tin | PT Menara Cipta Mulia | Indonesia |
| Tin | PT Rajehan Ariq | Indonesia |
| Tin | PT Babel Surya Alam Lestari | Indonesia |
| Tin | Novosibirsk Processing Plant Ltd. | Russia |
| Tin | CV Venus Inti Perkasa | Indonesia |
| Tin | CV Ayi Jaya | Indonesia |
| Tin | PT Sukses Inti Makmur | Indonesia |
| Tin | PT Bangka Prima Tin | Indonesia |
| Tin | PT Bangka Tin Industry | Indonesia |
| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Babel Inti Perkasa | Indonesia |
| Tin | PT Tommy Utama | Indonesia |
| Tin | PT Tirus Putra Mandiri | Indonesia |
| Tin | Feinhütte Halsbrücke GmbH | Germany |
| Tin | PT Cipta Persada Mulia | Indonesia |
| Tin | VQB Mineral and Trading Group JSC | Vietnam |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | Kennametal Huntsville | United States Of America |
| Tungsten | Global Tungsten & Powders Corp. | United States Of America |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| Tungsten | A.L.M.T. Corp. | Japan |
| Tungsten | China Molybdenum Co., Ltd. | China |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tungsten | Moliren Ltd. | Russia |
| Tungsten | Hydrometallurg, JSC | Russia |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russia |
| | | | | | | | |
| Metal | Facility Name | Facility Location |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten | H.C. Starck Tungsten GmbH | Germany |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | Vietnam |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Niagara Refining LLC | United States Of America |
| Tungsten | Kennametal Fallon | United States Of America |
| Tungsten | NPP Tyazhmetprom LLC | Russia |
| Tungsten | GEM Co., Ltd. | China |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam |
| Tungsten | Unecha Refractory metals plant | Russia |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tungsten | Cronimet Brasil Ltda | Brazil |
| Tungsten | Artek LLC | Russia |
Annex II
| | | | | | | | |
| |
| Metal | Countries |
| Gold | | |
| Algeria | Guinea |
| Andorra | Guyana |
| Argentina | Honduras |
| Australia | Hong Kong |
| Austria | Hungary |
| Azerbaijan | Iceland |
| Bangladesh | India |
| Belarus | Indonesia |
| Belgium | Ireland |
| Benin | Israel |
| Bolivia | Italy |
| Bosnia and Herzegovina | Jamaica |
| Botswana | Japan |
| Brazil | Jordan |
| Bulgaria | Kazakhstan |
| Burkina Faso | Kenya |
| Cambodia | Kyrgyzstan |
| Canada | Laos |
| Chile | Latvia |
| China | Lebanon |
| Chinese Taipei | Liberia |
| Colombia | Liechtenstein |
| Côte d'Ivoire | Lithuania |
| Croatia | Luxembourg |
| Cyprus | Macao |
| Czech Republic | Malaysia |
| Democratic Republic of Congo | Mali |
| Denmark | Malta |
| Dominican Republic | Mauritania |
| Ecuador | Mauritius |
| Egypt | Mexico |
| Estonia | Monaco |
| Fiji | Mongolia |
| Finland | Morocco |
| France | Mozambique |
| French Guiana | Namibia |
| Georgia | Netherlands |
| Germany | New Zealand |
| Ghana | Nicaragua |
| Greece | Niger |
| Guatemala | Nigeria |
| | | | | | | | |
| |
| Norway | Sudan |
| Oman | Suriname |
| Pakistan | Sweden |
| Panama | Switzerland |
| Papua New Guinea | Tajikistan |
| Peru | Tanzania |
| Philippines | Thailand |
| Poland | Trinidad and Tobago |
| Portugal | Tunisia |
| Puerto Rico | Turkey |
| Republic of Korea | Ukraine |
| Romania | United Arab Emirates |
| Russia | United Kingdom |
| Saudi Arabia | United States of America |
| Senegal | Uruguay |
| Serbia | Uzbekistan |
| Singapore | Vietnam |
| Slovakia | Zambia |
| Slovenia | Zimbabwe |
| South Africa | |
| Spain | |
| Tantalum | | |
| Australia | Madagascar |
| Brazil | Mozambique |
| Burundi | Nigeria |
| China | Rwanda |
| Democratic Republic of Congo | Sierra Leone |
| Ethiopia | Spain |
| France | |
| Tin | | |
| Australia | Russia |
| Bolivia | Rwanda |
| Brazil | Spain |
| Burundi | Tanzania |
| China | Thailand |
| Democratic Republic of Congo | United Kingdom |
| Indonesia | Vietnam |
| Laos | |
| Malaysia | |
| Mongolia | |
| Myanmar | |
| Nigeria | |
| Peru | |
| Tungsten | | |
| Australia | Portugal |
| | | | | | | | |
| |
| Austria | Russia |
| Bolivia | Rwanda |
| Brazil | Spain |
| Burundi | Tanzania |
| China | Thailand |
| Democratic Republic of Congo | Uganda |
| Kazakhstan | United Kingdom |
| Malaysia | United States of America |
| Mexico | Vietnam |
| Mongolia | |
| Myanmar | |
| Nigeria | |
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