Document

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)
Pennsylvania000-1043625-1324733
(State or other jurisdiction of incorporation)(Commission File Number)(I.R.S. Employer Identification No.)
415 Holiday Drive, Suite 100, Pittsburgh, Pennsylvania15220
(Address of principal executive offices)(Zip Code)
Sean M. Reilly, (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, 2021




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, 2021 to December 31, 2021 is provided as Exhibit 1.01 hereto and is publicly available on our corporate website, https://www.lbfoster.com as well as the Securities and Exchange Commission’s EDGAR database at https://www.sec.gov.

Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit NumberDescription
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 27, 2022 /s/ Sean M. Reilly
Sean M. Reilly
Corporate Controller and Principal Accounting Officer


Document
Exhibit 1.01
L.B. FOSTER COMPANY

Conflict Minerals Report
For the reporting period from January 1, 2021 to December 31, 2021
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 from January 1, 2021 to December 31, 2021.

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), 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 https://www.lbfoster.com/en/about/corporate-responsibility/conflict-mineral.

1.1 Company Overview
L.B. Foster Company provides products and services for the rail industry and solutions to support critical infrastructure projects. The Company’s innovative engineering and product development solutions inspire the safety, reliability, and performance of its customers’ challenging requirements. The Company maintains locations in North America, South America, Europe, and Asia. The Company is organized and operates in three business segments: Rail, Technologies, and Services (“Rail”), Precast Concrete Products (“Precast”), and Steel Products and Measurement. The Rail segment is comprised of several manufacturing, distribution, and service businesses that provide a variety of products, solutions, and services for freight and passenger railroads and other industrial companies throughout the world. The Precast segment manufactures precast concrete products for the North American civil infrastructure market. The Steel Products and Measurement segment provides custom engineered solutions and services that help build and maintain critical civil and energy infrastructure throughout North and South America, Central America, and the Caribbean.

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 2021.

The 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 6.1 or higher of the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”), the Company engaged its 678 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 assessment and management. Non-responsive suppliers were contacted a minimum of three times and were also subject to one on one communications by the Vendor, including offering assistance and further information to suppliers about the requirements of the Rule and the Program.
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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 April 29, 2022, five 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 335 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
The Company designed its due diligence process to be in conformity, in all material respects, with the due diligence framework in the Organization 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 https://www.lbfoster.com/en/about/corporate-responsibility/conflict-mineral.

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.

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.

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.
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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 678 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 for the year ended December 31, 2021 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.

When high-risk smelters 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 high-risk smelters 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.

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.

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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 to establish an alternative source of 3TGs that do not support conflict in the Covered Countries, as provided in the OECD guidance, when we have reason to believe those suppliers may be supplying us with 3TGs from sources that may support conflict in the Covered Countries. 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 https://www.lbfoster.com.

4. Due Diligence Results
For the 2021 reporting year, the Company received complete and valid CMRTs from approximately 50% of its 678 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.

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
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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 April 29, 2022, we have determined that 335 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 230 smelters that are certified “conflict-free.” In addition, 19 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 86 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 2022, 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;
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.
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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 2021. 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 2021, 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.
MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
GoldAdvanced Chemical CompanyUnited States Of AmericaCID000015
GoldAida Chemical Industries Co., Ltd.JapanCID000019
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GermanyCID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UzbekistanCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazilCID000058
GoldArgor-Heraeus S.A.SwitzerlandCID000077
GoldAsahi Pretec Corp.JapanCID000082
GoldAsaka Riken Co., Ltd.JapanCID000090
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TurkeyCID000103
GoldAurubis AGGermanyCID000113
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PhilippinesCID000128
GoldBoliden ABSwedenCID000157
GoldC. Hafner GmbH + Co. KGGermanyCID000176
GoldCaridadMexicoCID000180
GoldCCR Refinery - Glencore Canada CorporationCanadaCID000185
GoldCendres + Metaux S.A.SwitzerlandCID000189
GoldYunnan Copper Industry Co., Ltd.ChinaCID000197
GoldChimet S.p.A.ItalyCID000233
GoldChugai MiningJapanCID000264
GoldDaye Non-Ferrous Metals Mining Ltd.ChinaCID000343
GoldDSC (Do Sung Corporation)Korea, Republic OfCID000359
GoldDowaJapanCID000401
GoldEco-System Recycling Co., Ltd. East PlantJapanCID000425
GoldOJSC Novosibirsk RefineryRussian FederationCID000493
GoldRefinery of Seemine Gold Co., Ltd.ChinaCID000522
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.ChinaCID000651
GoldHangzhou Fuchunjiang Smelting Co., Ltd.ChinaCID000671
GoldLT Metal Ltd.Korea, Republic OfCID000689
GoldHeimerle + Meule GmbHGermanyCID000694
GoldHeraeus Metals Hong Kong Ltd.ChinaCID000707
GoldHeraeus Precious Metals GmbH & Co. KGGermanyCID000711



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
GoldHunan Chenzhou Mining Co., Ltd.ChinaCID000767
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.ChinaCID000773
GoldHwaSeong CJ CO., LTD.Korea, Republic OfCID000778
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.ChinaCID000801
GoldIshifuku Metal Industry Co., Ltd.JapanCID000807
GoldIstanbul Gold RefineryTurkeyCID000814
GoldJapan MintJapanCID000823
GoldJiangxi Copper Co., Ltd.ChinaCID000855
GoldAsahi Refining USA Inc.United States Of AmericaCID000920
GoldAsahi Refining Canada Ltd.CanadaCID000924
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRussian FederationCID000927
GoldJSC UralelectromedRussian FederationCID000929
GoldJX Nippon Mining & Metals Co., Ltd.JapanCID000937
GoldKazakhmys Smelting LLCKazakhstanCID000956
GoldKazzincKazakhstanCID000957
GoldKennecott Utah Copper LLCUnited States Of AmericaCID000969
GoldKojima Chemicals Co., Ltd.JapanCID000981
GoldKyrgyzaltyn JSCKyrgyzstanCID001029
GoldL'azurde Company For JewelrySaudi ArabiaCID001032
GoldLingbao Gold Co., Ltd.ChinaCID001056
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.ChinaCID001058
GoldLS-NIKKO Copper Inc.Korea, Republic OfCID001078
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.ChinaCID001093
GoldMaterionUnited States Of AmericaCID001113
GoldMatsuda Sangyo Co., Ltd.JapanCID001119
GoldMetalor Technologies (Suzhou) Ltd.ChinaCID001147
GoldMetalor Technologies (Hong Kong) Ltd.ChinaCID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeCID001152
GoldMetalor Technologies S.A.SwitzerlandCID001153
GoldMetalor USA Refining CorporationUnited States Of AmericaCID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MexicoCID001161
GoldMitsubishi Materials CorporationJapanCID001188
GoldMitsui Mining and Smelting Co., Ltd.JapanCID001193
GoldMoscow Special Alloys Processing PlantRussian FederationCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.S.TurkeyCID001220
GoldNavoi Mining and Metallurgical CombinatUzbekistanCID001236
GoldNihon Material Co., Ltd.JapanCID001259
GoldOhura Precious Metal Industry Co., Ltd.JapanCID001325
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)Russian FederationCID001326
GoldPAMP S.A.SwitzerlandCID001352
GoldPenglai Penggang Gold Industry Co., Ltd.ChinaCID001362
GoldPrioksky Plant of Non-Ferrous MetalsRussian FederationCID001386



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
GoldPT Aneka Tambang (Persero) TbkIndonesiaCID001397
GoldPX Precinox S.A.SwitzerlandCID001498
GoldRand Refinery (Pty) Ltd.South AfricaCID001512
GoldRoyal Canadian MintCanadaCID001534
GoldSabin Metal Corp.United States Of AmericaCID001546
GoldSamduck Precious MetalsKorea, Republic OfCID001555
GoldSamwon Metals Corp.Korea, Republic OfCID001562
GoldSEMPSA Joyeria Plateria S.A.SpainCID001585
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.ChinaCID001619
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaCID001622
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaCID001736
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian FederationCID001756
GoldSolar Applied Materials Technology Corp.Taiwan, Province Of ChinaCID001761
GoldSumitomo Metal Mining Co., Ltd.JapanCID001798
GoldSuper Dragon Technology Co., Ltd.ChinaCID001810
GoldTanaka Kikinzoku Kogyo K.K.JapanCID001875
GoldGreat Wall Precious Metals Co., Ltd. of CBPMChinaCID001909
GoldThe Refinery of Shandong Gold Mining Co., Ltd.ChinaCID001916
GoldTokuriki Honten Co., Ltd.JapanCID001938
GoldTongling Nonferrous Metals Group Co., Ltd.ChinaCID001947
GoldTorecomKorea, Republic OfCID001955
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgiumCID001980
GoldUnited Precious Metal Refining, Inc.United States Of AmericaCID001993
GoldValcambi S.A.SwitzerlandCID002003
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaCID002030
GoldYamakin Co., Ltd.JapanCID002100
GoldYokohama Metal Co., Ltd.JapanCID002129
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaCID002224
GoldGold Refinery of Zijin Mining Group Co., Ltd.ChinaCID002243
GoldMorris and WatsonNew ZealandCID002282
GoldSAFINA A.S.CzechiaCID002290
GoldGuangdong Jinding Gold LimitedChinaCID002312
GoldUmicore Precious Metals ThailandThailandCID002314
GoldGeib Refining CorporationUnited States Of AmericaCID002459
GoldMMTC-PAMP India Pvt., Ltd.IndiaCID002509
GoldKGHM Polska Miedz Spolka AkcyjnaPolandCID002511
GoldFidelity Printers and Refiners Ltd.ZimbabweCID002515
GoldSingway Technology Co., Ltd.Taiwan, Province Of ChinaCID002516
GoldShandong Humon Smelting Co., Ltd.ChinaCID002525
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.ChinaCID002527
GoldAl Etihad Gold Refinery DMCCUnited Arab EmiratesCID002560
GoldEmirates Gold DMCCUnited Arab EmiratesCID002561



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
GoldInternational Precious Metal RefinersUnited Arab EmiratesCID002562
GoldKaloti Precious MetalsUnited Arab EmiratesCID002563
GoldSudan Gold RefinerySudanCID002567
GoldT.C.A S.p.AItalyCID002580
GoldREMONDIS PMR B.V.NetherlandsCID002582
GoldFujairah Gold FZCUnited Arab EmiratesCID002584
GoldIndustrial Refining CompanyBelgiumCID002587
GoldShirpur Gold Refinery Ltd.IndiaCID002588
GoldKorea Zinc Co., Ltd.Korea, Republic OfCID002605
GoldMarsam MetalsBrazilCID002606
GoldTOO Tau-Ken-AltynKazakhstanCID002615
GoldAbington Reldan Metals, LLCUnited States Of AmericaCID002708
GoldSAAMPFranceCID002761
GoldL'Orfebre S.A.AndorraCID002762
Gold8853 S.p.A.ItalyCID002763
GoldItalpreziosiItalyCID002765
GoldWIELAND Edelmetalle GmbHGermanyCID002778
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustriaCID002779
GoldAU Traders and RefinersSouth AfricaCID002850
GoldGCC Gujrat Gold Centre Pvt. Ltd.IndiaCID002852
GoldSai RefineryIndiaCID002853
GoldModeltech Sdn BhdMalaysiaCID002857
GoldBangalore RefineryIndiaCID002863
GoldKyshtym Copper-Electrolytic Plant ZAORussian FederationCID002865
GoldDegussa Sonne / Mond Goldhandel GmbHGermanyCID002867
GoldPease & CurrenUnited States Of AmericaCID002872
GoldJALAN & CompanyIndiaCID002893
GoldSungEel HiMetal Co., Ltd.Korea, Republic OfCID002918
GoldPlanta Recuperadora de Metales SpAChileCID002919
GoldSafimet S.p.AItalyCID002973
GoldState Research Institute Center for Physical Sciences and TechnologyLithuaniaCID003153
GoldAfrican Gold RefineryUgandaCID003185
GoldGold Coast RefineryGhanaCID003186
GoldNH Recytech CompanyKorea, Republic OfCID003189
GoldQG Refining, LLCUnited States Of AmericaCID003324
GoldDijllah Gold Refinery FZCUnited Arab EmiratesCID003348
GoldCGR Metalloys Pvt Ltd.IndiaCID003382
GoldSovereign MetalsIndiaCID003383
GoldC.I Metales Procesados Industriales SASColombiaCID003421
GoldEco-System Recycling Co., Ltd. North PlantJapanCID003424
GoldEco-System Recycling Co., Ltd. West PlantJapanCID003425
GoldAugmont Enterprises Private LimitedIndiaCID003461



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
GoldKundan Care Products Ltd.IndiaCID003463
GoldEmerald Jewel Industry India Limited (Unit 1)IndiaCID003487
GoldEmerald Jewel Industry India Limited (Unit 2)IndiaCID003488
GoldEmerald Jewel Industry India Limited (Unit 3)IndiaCID003489
GoldEmerald Jewel Industry India Limited (Unit 4)IndiaCID003490
GoldK.A. RasmussenNorwayCID003497
GoldAlexy MetalsUnited States Of AmericaCID003500
GoldSancus ZFS (L’Orfebre, SA)ColombiaCID003529
GoldSellem Industries Ltd.MauritaniaCID003540
GoldMD OverseasIndiaCID003548
GoldMetallix Refining Inc.United States Of AmericaCID003557
GoldMetal Concentrators SA (Pty) Ltd.South AfricaCID003575
GoldWEEEREFININGFranceCID003615
GoldValue TradingBelgiumCID003617
TantalumChangsha South Tantalum Niobium Co., Ltd.ChinaCID000211
TantalumF&X Electro-Materials Ltd.ChinaCID000460
TantalumGuangdong Zhiyuan New Material Co., Ltd.ChinaCID000616
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaCID000914
TantalumJiujiang Tanbre Co., Ltd.ChinaCID000917
TantalumLSM Brasil S.A.BrazilCID001076
TantalumMetallurgical Products India Pvt., Ltd.IndiaCID001163
TantalumMineracao Taboca S.A.BrazilCID001175
TantalumMitsui Mining and Smelting Co., Ltd.JapanCID001192
TantalumNPM Silmet ASEstoniaCID001200
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaCID001277
TantalumQuantumCleanUnited States Of AmericaCID001508
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaCID001522
TantalumSolikamsk Magnesium Works OAORussian FederationCID001769
TantalumTaki Chemical Co., Ltd.JapanCID001869
TantalumTelex MetalsUnited States Of AmericaCID001891
TantalumUlba Metallurgical Plant JSCKazakhstanCID001969
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaCID002492
TantalumD Block Metals, LLCUnited States Of AmericaCID002504
TantalumFIR Metals & Resource Ltd.ChinaCID002505
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaCID002506
TantalumXinXing HaoRong Electronic Material Co., Ltd.ChinaCID002508
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.ChinaCID002512
TantalumKEMET Blue MetalsMexicoCID002539
TantalumH.C. Starck Co., Ltd.ThailandCID002544
TantalumH.C. Starck Tantalum and Niobium GmbHGermanyCID002545
TantalumH.C. Starck Hermsdorf GmbHGermanyCID002547



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
TantalumH.C. Starck Inc.United States Of AmericaCID002548
TantalumH.C. Starck Ltd.JapanCID002549
TantalumH.C. Starck Smelting GmbH & Co. KGGermanyCID002550
TantalumGlobal Advanced Metals BoyertownUnited States Of AmericaCID002557
TantalumGlobal Advanced Metals AizuJapanCID002558
TantalumResind Industria e Comercio Ltda.BrazilCID002707
TantalumJiangxi Tuohong New Raw MaterialChinaCID002842
TantalumYancheng Jinye New Material Technology Co., Ltd.ChinaCID003583
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaCID000228
TinAlphaUnited States Of AmericaCID000292
TinDowaJapanCID000402
TinEM VintoBolivia (Plurinational State Of)CID000438
TinEstanho de Rondonia S.A.BrazilCID000448
TinFenix MetalsPolandCID000468
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaCID000538
TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaCID000555
TinGejiu Kai Meng Industry and Trade LLCChinaCID000942
TinChina Tin Group Co., Ltd.ChinaCID001070
TinMalaysia Smelting Corporation (MSC)MalaysiaCID001105
TinMetallic Resources, Inc.United States Of AmericaCID001142
TinMineracao Taboca S.A.BrazilCID001173
TinMinsurPeruCID001182
TinMitsubishi Materials CorporationJapanCID001191
TinJiangxi New Nanshan Technology Ltd.ChinaCID001231
TinNovosibirsk Processing Plant Ltd.Russian FederationCID001305
TinO.M. Manufacturing (Thailand) Co., Ltd.ThailandCID001314
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)CID001337
TinPT Artha Cipta LanggengIndonesiaCID001399
TinPT Babel Inti PerkasaIndonesiaCID001402
TinPT Babel Surya Alam LestariIndonesiaCID001406
TinPT Bukit TimahIndonesiaCID001428
TinPT Mitra Stania PrimaIndonesiaCID001453
TinPT Prima Timah UtamaIndonesiaCID001458
TinPT Refined Bangka TinIndonesiaCID001460
TinPT Sariwiguna BinasentosaIndonesiaCID001463
TinPT Stanindo Inti PerkasaIndonesiaCID001468
TinPT Timah Tbk KundurIndonesiaCID001477
TinPT Timah Tbk MentokIndonesiaCID001482
TinPT Timah NusantaraIndonesiaCID001486
TinPT Tinindo Inter NusaIndonesiaCID001490



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
TinRui Da HungTaiwan, Province Of ChinaCID001539
TinSoft Metais Ltda.BrazilCID001758
TinThaisarcoThailandCID001898
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.ChinaCID001908
TinVQB Mineral and Trading Group JSCViet NamCID002015
TinWhite Solder Metalurgia e Mineracao Ltda.BrazilCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaCID002158
TinYunnan Tin Company LimitedChinaCID002180
TinCV Venus Inti PerkasaIndonesiaCID002455
TinMagnu's Minerais Metais e Ligas Ltda.BrazilCID002468
TinMelt Metais e Ligas S.A.BrazilCID002500
TinPT ATD Makmur Mandiri JayaIndonesiaCID002503
TinO.M. Manufacturing Philippines, Inc.PhilippinesCID002517
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyViet NamCID002572
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyViet NamCID002573
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyViet NamCID002574
TinPT Cipta Persada MuliaIndonesiaCID002696
TinAn Vinh Joint Stock Mineral Processing CompanyViet NamCID002703
TinResind Industria e Comercio Ltda.BrazilCID002706
TinSuper LigasBrazilCID002756
TinMetallo Belgium N.V.BelgiumCID002773
TinMetallo Spain S.L.U.SpainCID002774
TinPT Sukses Inti MakmurIndonesiaCID002816
TinThai Nguyen Mining and Metallurgy Co., Ltd.Viet NamCID002834
TinPT Menara Cipta MuliaIndonesiaCID002835
TinModeltech Sdn BhdMalaysiaCID002858
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaCID003116
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaCID003190
TinPT Bangka SerumpunIndonesiaCID003205
TinPongpipat Company LimitedMyanmarCID003208
TinTin Technology & RefiningUnited States Of AmericaCID003325
TinDongguan CiEXPO Environmental Engineering Co., Ltd.ChinaCID003356
TinMa'anshan Weitai Tin Co., Ltd.ChinaCID003379
TinPT Masbro Alam StaniaIndonesiaCID003380
TinPT Rajawali Rimba PerkasaIndonesiaCID003381
TinLuna Smelter, Ltd.RwandaCID003387
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.ChinaCID003397
TinPrecious Minerals and Smelting LimitedIndiaCID003409
TinGejiu City Fuxiang Industry and Trade Co., Ltd.ChinaCID003410
TinPT Mitra Sukses GlobalindoIndonesiaCID003449
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBrazilCID003486
TinCRM SynergiesSpainCID003524



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
TinPT Aries Kencana SejahteraIndonesiaCID000309
TinFabrica Auricchio Industria e Comercio Ltda.BrazilCID003582
TinPT Belitung Industri SejahteraIndonesiaCID001421
TinPT Panca Mega PersadaIndonesiaCID001457
TinPT Tommy UtamaIndonesiaCID001493
TinPT Tirus Putra MandiriIndonesiaCID002478
TungstenA.L.M.T. Corp.JapanCID000004
TungstenKennametal HuntsvilleUnited States Of AmericaCID000105
TungstenGuangdong Xianglu Tungsten Co., Ltd.ChinaCID000218
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaCID000258
TungstenCNMC (Guangxi) PGMA Co., Ltd.ChinaCID000281
TungstenGlobal Tungsten & Powders Corp.United States Of AmericaCID000568
TungstenHunan Chenzhou Mining Co., Ltd.ChinaCID000766
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.ChinaCID000769
TungstenJapan New Metals Co., Ltd.JapanCID000825
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.ChinaCID000875
TungstenKennametal FallonUnited States Of AmericaCID000966
TungstenWolfram Bergbau und Hutten AGAustriaCID002044
TungstenXiamen Tungsten Co., Ltd.ChinaCID002082
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.ChinaCID002313
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.ChinaCID002315
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaCID002316
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.ChinaCID002317
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.ChinaCID002318
TungstenMalipo Haiyu Tungsten Co., Ltd.ChinaCID002319
TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaCID002320
TungstenJiangxi Gan Bei Tungsten Co., Ltd.ChinaCID002321
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaCID002494
TungstenAsia Tungsten Products Vietnam Ltd.Viet NamCID002502
TungstenChenzhou Diamond Tungsten Products Co., Ltd.ChinaCID002513
TungstenH.C. Starck Tungsten GmbHGermanyCID002541
TungstenH.C. Starck Smelting GmbH & Co. KGGermanyCID002542
TungstenMasan Tungsten Chemical LLC (MTC)Viet NamCID002543
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.ChinaCID002551
TungstenNiagara Refining LLCUnited States Of AmericaCID002589
TungstenChina Molybdenum Co., Ltd.ChinaCID002641
TungstenGanzhou Haichuang Tungsten Co., Ltd.ChinaCID002645
TungstenHydrometallurg, JSCRussian FederationCID002649
TungstenUnecha Refractory metals plantRussian FederationCID002724
TungstenPhilippine Chuangxin Industrial Co., Inc.PhilippinesCID002827
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.ChinaCID002830
TungstenACL Metais EireliBrazilCID002833



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
TungstenMoliren Ltd.Russian FederationCID002845
TungstenKGETS Co., Ltd.Korea, Republic OfCID003388
TungstenFujian Ganmin RareMetal Co., Ltd.ChinaCID003401
TungstenLianyou Metals Co., Ltd.Taiwan, Province Of ChinaCID003407
TungstenJSC "Kirovgrad Hard Alloys Plant"Russian FederationCID003408
TungstenNPP Tyazhmetprom LLCRussian FederationCID003416
TungstenGEM Co., Ltd.ChinaCID003417
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BrazilCID003427
TungstenCronimet Brasil LtdaBrazilCID003468
TungstenArtek LLCRussian FederationCID003553
TungstenFujian Xinlu TungstenChinaCID003609
TungstenOOO “Technolom” 2Russian FederationCID003612
TungstenOOO “Technolom” 1Russian FederationCID003614