UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
L.B. Foster Company | ||||
(Exact name of registrant as specified in its charter) | ||||
Pennsylvania | 000-10436 | 25-1324733 | ||
(State or other jurisdiction of incorporation) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||
415 Holiday Drive, Pittsburgh, Pennsylvania | 15220 | |||
(Address of principal executive offices) | (Zip Code) | |||
Todd M. James, (412) 928-3400 | ||||
(Name and telephone number, including area code, of the person to contact in connection with this report) | ||||
Check the appropriate box below to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies: | ||||
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017 | ||||
Section 1 – Conflict Minerals Disclosure
Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
Conflict Minerals Disclosure
A copy of L.B. Foster’s Conflict Minerals Report for the reporting period January 1, 2017 to December 31, 2017 is provided as Exhibit 1.01 hereto and is publicly available on our corporate website, http://www.lbfoster.com as well as the Securities and Exchange Commission’s EDGAR database at http://www.sec.gov.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit Number | Description |
1.01 | |
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 undersigned hereunto duly authorized.
L.B. FOSTER COMPANY | |||
(Registrant) | |||
Date: | May 25, 2018 | /s/ Todd M. James | |
Todd M. James | |||
Controller and Principal Accounting Officer | |||
Exhibit 1.01
L.B. FOSTER COMPANY
Conflict Minerals Report
For the reporting period from January 1, 2017 to December 31, 2017
1. Introduction
This Conflict Minerals Report (the “Report”) of L.B. Foster Company (the “Company” or “we”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2017 to December 31, 2017.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The term "conflict minerals" is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (collectively “3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (the “DRC”) or any adjoining country that shares an internationally recognized border with the DRC (collectively the “Covered Countries”).
As further described in this Report, the Company has determined that certain of its operations manufacture or contract to manufacture products that may contain 3TGs that are necessary to the functionality or production of such products.
L.B. Foster Company’s policy relating to 3TGs (the “Conflict Minerals Policy”) can be viewed on the Company’s website at http://www.lbfoster.com/corporate/conflict_minerals.asp.
1.1 Company Overview
L.B. Foster Company is a leading manufacturer and distributor of products and services for transportation and energy infrastructure with locations in North America and Europe. The Company’s Rail Products and Services (“Rail”) segment provides a full line of new and used rail, trackwork, and accessories to railroads, mines, and other customers in the rail industry. The Rail segment also designs and produces insulated rail joints, power rail, track fasteners, concrete railroad ties, coverboards, and special accessories for mass transit and other rail systems. In addition, the Rail segment engineers, manufactures, and assembles friction management products and railway wayside data collection and management systems. The Company’s Construction Products (“Construction”) segment sells and rents steel sheet piling, H-bearing pile, and other piling products for foundation and earth retention requirements. The Construction segment also sells bridge decking, bridge railing, structural steel fabrications, expansion joints, bridge forms, and other products for highway construction and repair. Also, as part of the Construction segment, concrete products businesses produce precast concrete buildings and a variety of specialty precast concrete products. The Company’s Tubular and Energy Services segment provides pipe coatings for natural gas pipelines and utilities, upstream test and inspection services, and precision measurement systems for the oil and gas market, and produces threaded pipe products for the oil and gas markets as well as industrial water well and irrigation markets.
1.2 Product Overview
This Report relates to the Company’s products (i) for which 3TGs are necessary to the functionality or production of that product; (ii) that were manufactured or contracted to be manufactured by the Company; and (iii) for which the manufacture was completed during calendar year 2017.
L.B. Foster Company does not directly purchase 3TGs, but it purchases components that it uses in the products it manufactures. The Company identified certain products it sells as possibly containing 3TGs that are necessary to the functionality or production of the products. These products include, but are not limited to, power rail, coverboards, mass transit and rail system accessories, certain friction management products, railway wayside data collection and management systems, expansion joints, precast concrete buildings, and precision measurement systems.
2. Reasonable Country of Origin Inquiry (“RCOI”)
The Company conducted a good faith RCOI regarding the 3TG in materials, components, and finished goods supplied to the Company, including the following steps (collectively, the “Program”):
Utilizing version 5.0 or higher of the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”), the Company engaged its 1,088 potential 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products.
The Company retained a third party vendor (“Vendor”) to conduct supplier surveying via its platform that enables users to complete and track supplier communications. It also allows suppliers to upload completed CMRTs directly to the platform for
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assessment and management. Non-responsive suppliers were contacted a minimum of three times by the Vendor and then were also managed by the Vendor supply chain team in 1:1 communications, including offering assistance and further information to suppliers about the requirements of the Rule and the Program.
The Program continues to include automated data validation on all submitted CMRTs via the Vendor’s software. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers were contacted with regard to invalid forms and were encouraged to resubmit a valid form. As of May 20, 2018, 17 invalid supplier submissions were not yet corrected.
Of the suppliers who responded that they provide 3TG to the Company, many did not include the name of any verified Smelters or Refiners (together, “SOR” or “Smelters”). Based on the responses received from the Company’s RCOI, which included thousands of alleged SOR names, a list was compiled of 321 verified, unique SORs, including information regarding associated countries of origin (the “Unique Smelter List”). The Company performed due diligence on the SORs which appeared on the Unique Smelter List that were known or reasonably believed to have sourced from the Covered Countries or that had unknown sourcing.
Based on the responses to our RCOI, the Company is unable to determine that 3TGs necessary to the functionality or production of our products did not originate in the Covered Countries. Accordingly, the Company undertook the below Due Diligence measures to assess the practices of the SORs listed on its Unique Smelter List that were known or reasonably believed to have been sourced from the Covered Countries or that had unknown sourcing.
3. Due Diligence
3.1 Design of Due Diligence
L.B. Foster Company designed its due diligence process to be in conformity, in all material respects, with the due diligence framework in the Organisation of Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition and related Supplements on tin, tantalum, and tungsten and on gold (collectively, the “OECD Guidance”). The OECD Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We have developed our due diligence process to address each of these five steps.
3.1.1 Establish Strong Company Management Systems
Conflict Minerals Policy
As described above, we maintain a Conflict Minerals Policy, which is posted on our website at http://www.lbfoster.com/corporate/conflict_minerals.asp.
Internal Team and Training
The Company has established a management team responsible for the oversight of its conflict mineral assessment. The management team is overseen by the Principal Accounting Officer and a team of subject matter experts from relevant functions such as quality, supply chain, operations, finance, and legal. Senior management is briefed about the results of our due diligence efforts.
We, in cooperation with our Vendor, have developed internal training programs to educate persons within the Company who may potentially have contact with suppliers or other external parties regarding the Company’s conflict minerals compliance efforts. We review our training programs at least annually to make sure they are continuously aligned with current regulations, our initiatives, and the tools we use.
Control Systems
As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other manufacturers in our industry and other sectors.
Our controls include our Legal and Ethical Conduct Policy, which outlines expected behaviors for all our employees.
Supplier Engagement
We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us, including sources of 3TG that are supplied to them from lower tier suppliers.
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In accordance with the OECD requirement to strengthen engagement with suppliers, we have, in cooperation with our Vendor, provided education to suppliers on the conflict minerals regulations as well as the expectations of the law. We continue to utilize our Vendor’s Learning Management System to provide all in-scope suppliers access to their Conflict Minerals Training Course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
In addition, we have leveraged the existing communications within the Company, specifically through our procurement personnel, to encourage supplier interactions with our Vendor as well for them to understand the need to complete the surveys. Feedback from this process has allowed us to enhance the training, to focus and adapt it to each user’s needs, and refine and clarify our supplier communications to ensure that our expectations are clear.
Grievance Mechanism
We have longstanding grievance mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Conflict Minerals Policy.
Records Maintenance
We have retained all relevant documentation from our RCOI and due diligence. Our existing policy related to relevant documentation of our conflict mineral compliance process requires that documentation be retained for a period of at least five years.
3.1.2 Identify and Assess Risk in Our Supply Chain
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult for us to identify all vendors upstream from our direct suppliers.
We have identified 1,088 direct suppliers related to our in-scope products. We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. Many of the largest suppliers either are Securities and Exchange Commission (“SEC”) registrants and subject to the Rule or are suppliers to other SEC registrants who are subject to the Rule.
Risks are identified automatically in the reporting system based on criteria established for supplier responses. The primary risk we identified with respect to the reporting period ended December 31, 2017 related to the nature of the responses received. Many of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG in the components supplied to the Company. Additionally, many suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as “conflict-free” by third party sources such as the Responsible Minerals Assurance Process (“RMAP”) pose a significant risk. Where a smelter is not identified as “conflict-free” by such sources, we rate the risk as high, medium, or low. This rating is based on various factors, including whether the SOR has been identified as a valid SOR and has an associated Smelter Identification Number (under the RMI, this is known as a Country Identification Number, or “CID”), whether there is known or plausible evidence of unethical or conflict sourcing, and the smelter’s geographic location, including proximity to the Covered Countries.
Based on these criteria the following facilities have been identified as being of highest concern to the supply chain:
• | Tony Goetz NV - CID002587 |
• | Kaloti Precious Metals - CID002563 |
• | African Gold Refinery Limited (AGR) - CID003185 |
• | Universal Precious Metals Refining Zambia - CID002854 |
• | Fidelity Printers and Refiners - CID002515 |
• | Sudan Gold Refinery - CID002567 |
When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our Vendor, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product CMRT to better identify the connection to products that they supply to the Company, and escalating up to removal of these high-risk smelters from their supply chain.
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Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:
• | Existence of a policy in place that includes “conflict-free” sourcing; |
• | Implementation of due diligence measures for “conflict-free” sourcing; |
• | Whether the supplier reviews due diligence information received from their suppliers against your company’s expectations; |
• | Whether the verification process includes corrective action management. |
Based on how each supplier’s program meets these criteria, its program strength is identified as either strong or weak.
As part of our risk management plan and to ensure suppliers understand our expectations, we have, through our Vendor, provided video and written training on conflict minerals and the CMRT. This includes instructions on completing the form, and one-on-one email and phone discussions with supplier personnel.
In accordance with our Conflict Minerals Policy, we engage suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we may then take steps to terminate a contract and find replacement suppliers.
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TGs in our supply chain. This was done by adopting the methodology outlined by the RMI’s joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this industry joint effort, we made a reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict-Free” lists of sourced metals.
3.1.3 Design and Implement a Strategy to Respond to Risks
In response to this risk assessment, the Company has an approved risk management plan through which the conflict minerals program is implemented, managed, and monitored. Updates to this risk assessment are provided to senior management.
As part of our risk management plan, to ensure suppliers understand our expectations, we have provided both video, recorded training, and documented instructions through our Vendor and responded to questions of suppliers requiring further clarification. We then provided each supplier a copy of the Responsible Business Alliance (“RBA”) reporting CMRT to complete for purposes of conflict minerals tracking. Furthermore, we reviewed responses to the reporting CMRT with suppliers where we needed clarification. As described in our Conflict Minerals Policy, we intend to engage any of our suppliers that we have reason to believe are supplying us with 3TG from sources that may support conflict in the Covered Countries to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. We do not seek to embargo responsible sourcing of 3TGs from the DRC region or condone a general embargo on sourcing from the region.
3.1.4 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chains
The Company does not have a direct relationship with conflict minerals smelters or refiners and thus, the Company does not perform direct audits of these entities in its supply chain. The Company relies on the efforts of the industry associations that administer independent third-party smelter and refinery audit programs and encourages suppliers with more direct relationships with smelters to participate in comparable due diligence validation activities.
3.1.5 Report on Supply Chain Due Diligence
This conflict minerals report is being filed with the SEC as an exhibit to our specialized disclosure report on Form SD and is available on our website at http://www.lbfoster.com.
4. Due Diligence Results
For the 2017 reporting year, the Company received CMRTs from approximately 44% of its 1,088 suppliers surveyed. Most supplier responses received provided information at a company-wide level. We reviewed the responses against criteria we developed to determine which responses might require further engagement with our suppliers. Such criteria included untimely or incomplete responses as well as inconsistencies with the data reported. We have sent and continue to send additional requests to seek clarifications from suppliers to validate such data and obtain more complete and accurate responses.
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4.1 Efforts to Determine Mine or Location of Origin
Due to our position in the supply chain, it is difficult for us to identify suppliers upstream from our direct suppliers and it is increasingly difficult to track 3TGs down to the mine or smelter level. Through continual follow-up, the Company requests additional status reports from direct suppliers. We work to validate the data obtained from suppliers by utilizing claims made by referenced refiners or smelters on their websites. For our position in the supply chain, we have determined to use this risk based approach to determine the origin of 3TGs in purchased products/materials.
4.2 Country of Origin
Based on the nature of information we received from our suppliers, we are unable to determine the country of origin of 3TG’s in our products.
4.3 Smelters or Refiners
For all responses that indicated a smelter, our Vendor compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as “conflict-free,” our Vendor confirmed that the name was listed by RMI as a certified smelter. As of May 20, 2018, we have determined that 321 smelters or refiners are listed as certified smelters/refiners by RMI and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Schedule A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Schedule A any smelters or refiners that we have not been able to validate.
Based on the smelter lists provided by suppliers via the CMRTs and publicly available information, we have identified 257 smelters that are certified “conflict-free.” In addition, 11 smelters are active in the Responsible Minerals Assurance Process and are or have committed to undergoing an audit.
From the responses that we received, we identified 53 smelters that potentially posed a risk. These concerns stem from the location of the facilities and claims that fall outside of the scope of the conflict minerals law. For suppliers that identified these smelters of concern on their CMRT, we created an escalation plan. These suppliers were contacted by our Vendor and the Company to evaluate whether these smelters could be connected to the Company’s products. The suppliers were asked to complete a product-level CMRT, rather than a company-level CMRT, to better identify the connection to products that they supply to the Company. Other suppliers were evaluated internally to determine if they were in fact still active suppliers. If not, they were taken out of scope.
5. Steps Taken to Mitigate Risk
In 2018, we have taken, or plan to take, the following steps to mitigate the risk that our necessary 3TGs benefit armed groups:
• | Continue to deploy our supply chain policy in accordance with OECD recommendations; |
• | Enhance management processes to ensure risks related to the acquisition of components containing 3TGs are adequately managed; |
• | Structure internal systems to support supply chain due diligence, including through the assignment of responsibility to senior staff to oversee the process and ensure availability of resources and implementation of “up the chain” communication processes; |
• | Further augment our reasonable country of origin and due diligence process with our vendors; |
• | Increase our supplier response rate while increasing the validation of Smelter information by substituting suppliers that do not use 3TGs from suppliers that use 3TGs from the Covered Countries; and |
• | Raise the awareness of suppliers to their use of “conflict-free” minerals and alert them to a potential request for an audit to prove that they are “conflict-free.” |
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Cautionary Statement on Forward-Looking Statements
This Report contains “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, and such forward-looking statements involve risks and uncertainties. These forward-looking statements are subject to various risks, uncertainties and other factors, including, among other matters, the Company’s suppliers’ responsiveness and cooperation with the Company’s due diligence efforts, the Company’s ability to identify and mitigate risks in its supply chain, whether smelters and refiners and other market participants responsibly source conflict minerals, and political and regulatory developments, whether in the Covered Countries, the United States, or elsewhere. The Company’s forward-looking statements in this Report are based on management’s current views, beliefs, and assumptions regarding future events. The Company undertakes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise, except as required by the federal securities laws.
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Schedule A
The following lists the smelters/refiners identified by our suppliers as sources for their products that are certified by the “Responsible Minerals Assurance Process .”
The information that we received from much of our direct suppliers was at their company-wide level. Thus, the smelters or refiners identified by our direct suppliers contained in the tables below may include smelters or refiners that processed minerals that our direct suppliers supplied to their other customers, but not to us. We are unable to conclusively determine whether the smelters or refiners included in the tables below were used to process the 3TGs necessary to the functionality or production of our products during 2017. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed below were the country of origin of minerals in our products during 2017, and therefore we are unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the information that we received from our direct suppliers may yield inaccurate or incomplete information. For example, the information we received from our direct suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMI Responsible Minerals Assurance Process – RMAP and, thus, are not responsible for the quality of these audits or the audit findings.
Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Gold | Abington Reldan Metals, LLC | UNITED STATES | Not Enrolled |
Gold | Advanced Chemical Company | UNITED STATES | Conformant |
Gold | African Gold Refinery | UGANDA | Not Enrolled |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Conformant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Conformant |
Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
Gold | Asahi Pretec Corp. | JAPAN | Conformant |
Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
Gold | Asahi Refining USA Inc. | UNITED STATES | Conformant |
Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Not Enrolled |
Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant |
Gold | Aurubis AG | GERMANY | Conformant |
Gold | Bangalore Refinery | INDIA | Active |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
Gold | Boliden AB | SWEDEN | Conformant |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
Gold | Caridad | MEXICO | Not Enrolled |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
Gold | Cendres + Métaux S.A. | SWITZERLAND | Conformant |
Gold | Chimet S.p.A. | ITALY | Conformant |
Gold | Chugai Mining | JAPAN | Not Enrolled |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not Enrolled |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not Enrolled |
Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant |
Gold | Dowa | JAPAN | Conformant |
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | Active |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant |
Gold | Elemetal Refining, LLC | UNITED STATES | Not Enrolled |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Not Enrolled |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Not Enrolled |
Gold | Geib Refining Corporation | UNITED STATES | Conformant |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not Enrolled |
Gold | Guangdong Jinding Gold Limited | CHINA | Not Enrolled |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not Enrolled |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not Enrolled |
Gold | HeeSung | KOREA, REPUBLIC OF | Conformant |
Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not Enrolled |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Not Enrolled |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
Gold | Istanbul Gold Refinery | TURKEY | Conformant |
Gold | Italpreziosi | ITALY | Conformant |
Gold | Japan Mint | JAPAN | Conformant |
Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Conformant |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Not Enrolled |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not Enrolled |
Gold | Kazzinc | KAZAKHSTAN | Conformant |
Gold | Kennecott Utah Copper LLC | UNITED STATES | Conformant |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Active |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Not Enrolled |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Not Enrolled |
Gold | Lingbao Gold Co., Ltd. | CHINA | Not Enrolled |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not Enrolled |
Gold | L'Orfebre S.A. | ANDORRA | Active |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not Enrolled |
Gold | Marsam Metals | BRAZIL | Conformant |
Gold | Materion | UNITED STATES | Conformant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
Gold | Metalor USA Refining Corporation | UNITED STATES | Conformant |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Conformant |
Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
Gold | Modeltech Sdn Bhd | MALAYSIA | Active |
Gold | Morris and Watson | NEW ZEALAND | Not Enrolled |
Gold | Morris and Watson Gold Coast | AUSTRALIA | Not Enrolled |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | TURKEY | Conformant |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Not Enrolled |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | Active |
Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Conformant |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant |
Gold | PAMP S.A. | SWITZERLAND | Conformant |
Gold | Pease & Curren | UNITED STATES | Not Enrolled |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not Enrolled |
Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
Gold | PX Précinox S.A. | SWITZERLAND | Conformant |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Not Enrolled |
Gold | Remondis Argentia B.V. | NETHERLANDS | Active |
Gold | Republic Metals Corporation | UNITED STATES | Conformant |
Gold | Royal Canadian Mint | CANADA | Conformant |
Gold | SAAMP | FRANCE | Conformant |
Gold | Sabin Metal Corp. | UNITED STATES | Not Enrolled |
Gold | Safimet S.p.A | Italy | Conformant |
Gold | SAFINA A.S. | CZECH REPUBLIC | Active |
Gold | Sai Refinery | INDIA | Not Enrolled |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Not Enrolled |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant |
Gold | Schone Edelmetaal B.V. | NETHERLANDS | Conformant |
Gold | SEMPSA Joyería Platería S.A. | SPAIN | Conformant |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not Enrolled |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
Gold | Singway Technology Co., Ltd. | TAIWAN | Conformant |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant |
Gold | Solar Applied Materials Technology Corp. | TAIWAN | Conformant |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Not Enrolled |
Gold | Sudan Gold Refinery | SUDAN | Not Enrolled |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
Gold | SungEel HiTech | KOREA, REPUBLIC OF | Conformant |
Gold | T.C.A S.p.A | ITALY | Conformant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not Enrolled |
Gold | Tony Goetz NV | BELGIUM | Not Enrolled |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Not Enrolled |
Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
Gold | Umicore Brasil Ltda. | BRAZIL | Conformant |
Gold | Umicore Precious Metals Thailand | THAILAND | Conformant |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
Gold | United Precious Metal Refining, Inc. | UNITED STATES | Conformant |
Gold | Universal Precious Metals Refining Zambia | ZAMBIA | Not Enrolled |
Gold | Valcambi S.A. | SWITZERLAND | Conformant |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Conformant |
Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Conformant |
Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not Enrolled |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | D Block Metals, LLC | UNITED STATES | Conformant |
Tantalum | Duoluoshan | CHINA | Not Enrolled |
Tantalum | Exotech Inc. | UNITED STATES | Conformant |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Conformant |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
Tantalum | H.C. Starck Inc. | UNITED STATES | Conformant |
Tantalum | H.C. Starck Ltd. | JAPAN | Conformant |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA | Conformant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | KEMET Blue Metals | MEXICO | Conformant |
Tantalum | KEMET Blue Powder | UNITED STATES | Conformant |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Conformant |
Tantalum | LSM Brasil S.A. | BRAZIL | Conformant |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
Tantalum | NPM Silmet AS | ESTONIA | Conformant |
Tantalum | Power Resources Ltd. | MACEDONIA | Conformant |
Tantalum | QuantumClean | UNITED STATES | Conformant |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Conformant |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant |
Tantalum | Taki Chemicals | JAPAN | Conformant |
Tantalum | Telex Metals | UNITED STATES | Conformant |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Conformant |
Tin | Alpha | UNITED STATES | Conformant |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Not Enrolled |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Active |
Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not Enrolled |
Tin | CV Ayi Jaya | INDONESIA | Conformant |
Tin | CV Dua Sekawan | INDONESIA | Conformant |
Tin | CV Gita Pesona | INDONESIA | Conformant |
Tin | CV Tiga Sekawan | INDONESIA | Conformant |
Tin | CV United Smelting | INDONESIA | Conformant |
Tin | CV Venus Inti Perkasa | INDONESIA | Conformant |
Tin | Dowa | JAPAN | Conformant |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Not Enrolled |
Tin | EM Vinto | BOLIVIA | Conformant |
Tin | Estanho de Rondônia S.A. | BRAZIL | Not Enrolled |
Tin | Fenix Metals | POLAND | Conformant |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant |
Tin | Gejiu Jinye Mineral Company | CHINA | Conformant |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Not Enrolled |
Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | CHINA | Conformant |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Conformant |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant |
Tin | Metallic Resources, Inc. | UNITED STATES | Conformant |
Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
Tin | Metallo Spain S.L.U. | SPAIN | Conformant |
Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
Tin | Minsur | PERU | Conformant |
Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
Tin | Modeltech Sdn Bhd | MALAYSIA | Active |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Not Enrolled |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
Tin | Operaciones Metalurgical S.A. | BOLIVIA | Conformant |
Tin | Pongpipat Company Limited | MYANMAR | Not Enrolled |
Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant |
Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
Tin | PT Babel Inti Perkasa | INDONESIA | Conformant |
Tin | PT Bangka Prima Tin | INDONESIA | Conformant |
Tin | PT Bangka Serumpun | INDONESIA | Conformant |
Tin | PT Bangka Tin Industry | INDONESIA | Conformant |
Tin | PT Belitung Industri Sejahtera | INDONESIA | Conformant |
Tin | PT Bukit Timah | INDONESIA | Conformant |
Tin | PT DS Jaya Abadi | INDONESIA | Conformant |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Conformant |
Tin | PT Inti Stania Prima | INDONESIA | Conformant |
Tin | PT Karimun Mining | INDONESIA | Conformant |
Tin | PT Kijang Jaya Mandiri | INDONESIA | Conformant |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Conformant |
Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
Tin | PT O.M. Indonesia | INDONESIA | Conformant |
Tin | PT Panca Mega Persada | INDONESIA | Conformant |
Tin | PT Premium Tin Indonesia | INDONESIA | Conformant |
Tin | PT Prima Timah Utama | INDONESIA | Conformant |
Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
Tin | PT Sukses Inti Makmur | INDONESIA | Conformant |
Tin | PT Sumber Jaya Indah | INDONESIA | Conformant |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Conformant |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Conformant |
Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant |
Tin | PT Tommy Utama | INDONESIA | Conformant |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
Tin | Rui Da Hung | TAIWAN | Conformant |
Tin | Soft Metais Ltda. | BRAZIL | Conformant |
Tin | Super Ligas | Brazil | Not Enrolled |
Tin | Thaisarco | THAILAND | Conformant |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Not Enrolled |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Conformant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
Tin | Yunnan Tin Company Limited | CHINA | Conformant |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Conformant |
Tungsten | ACL Metais Eireli | BRAZIL | Conformant |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Active |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Not Enrolled |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Conformant |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Conformant |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Conformant |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Not Enrolled |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not Enrolled |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Kennametal Fallon | UNITED STATES | Conformant |
Tungsten | Kennametal Huntsville | UNITED STATES | Conformant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Conformant |
Tungsten | Niagara Refining LLC | UNITED STATES | Conformant |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Conformant |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Conformant |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Conformant |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Conformant |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Conformant |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Conformant |