UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
ABAXIS, INC.
(Exact name of registrant as specified in its charter)
California
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000-19720
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77-0213001
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(State or other Jurisdiction of Incorporation)
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(Commission File Number)
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(I.R.S. Employer Identification No.)
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3240 Whipple Road
Union City, CA 94587
(Address of principal executive offices, including zip code)
Donald P. Wood, (510) 675-6500
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Form SD of Abaxis, Inc. is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934 for the reporting period January 1, 2014 to December 31, 2014. A copy of Abaxis’ Conflict Minerals Report is filed as Exhibit 1.01 hereto and is publicly available in the Investor Relations section of the Company’s website at http://www.abaxis.com.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, Abaxis is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
ABAXIS, INC.
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By:
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/s/ Donald P. Wood
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Date: June 1, 2015
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Donald P. Wood
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Chief Operating Officer
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EXHIBIT INDEX
Exhibit No.
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Description
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Conflict Minerals Report of Abaxis, Inc.
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Exhibit 1.01
Abaxis, Inc.
Conflict Minerals Report
For The Year Ended December 31, 2014
This report for the period from January 1, 2014 through December 31, 2014 (the “Reporting Period”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to their functionality or production. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (“3TG” or “Conflict Minerals”). The intent of these requirements is to further the goal of ending violent conflict in the Democratic Republic of Congo and in adjoining countries (the “Covered Countries”), which conflict has been financed, in part, by the exploitation and trade of conflict minerals. These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
If a registrant can establish that the Conflict Minerals originated from sources other than the Covered Countries, or from recycled or scrap sources, it must submit a Form SD that describes the Reasonable Country of Origin Inquiry (“RCOI”) completed.
If a registrant has reason to believe that any of the Conflict Minerals in its supply chain may have originated in the Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the registrant must conduct due diligence on the conflict minerals’ source and chain of custody. The registrant must annually submit a Conflict Minerals Report (“CMR”), to the SEC that includes a description of those due diligence measures. Abaxis is filing this CMR because, based on its RCOI, the Company was unable to determine the country of origin of all Conflict Minerals in its supply chain.
Covered Products
Abaxis, Inc. (“Abaxis” or the “Company”), incorporated in California in 1989, develops, manufactures and markets portable blood analysis systems that are used in a broad range of medical specialties in human or veterinary patient care to provide clinicians with rapid blood constituent measurements.
Our medical devices are manufactured using parts and components that are several levels removed from the actual mining of conflict minerals. The blood chemistry analyzers that we manufacture employ a variety of components designed or specified by us that contain Conflict Minerals that are necessary to their functionality or production (the “Covered Products”). The components are manufactured by several third-party suppliers that have been qualified and approved by us and then assembled by our contract manufacturers.
The Company’s Reasonable Country-of-Origin Inquiry and Due Diligence Process
The Company’s supply chain with respect to the Covered Products is complex, and its manufacturing process is significantly removed from the mining, smelting and refining of Conflict Minerals. In this regard, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of Conflict Minerals. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and, therefore, has taken steps to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain. However, tracing these minerals to their sources is a challenge that requires the Company to rely on its suppliers in its efforts to achieve supply chain transparency, including obtaining information regarding the origin of the Conflict Minerals. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. Moreover, because of the Company’s relative location within the supply chain in relation to the actual extraction and transport of Conflict Minerals, its ability to verify the accuracy of information reported by suppliers is limited. Accordingly, the Company can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals in the Covered Products.
As described below, for Covered Products the manufacture of which was completed during the Reporting Period, Abaxis has undertaken a RCOI and due diligence on the source and chain of custody of the Conflict Minerals that were included in those products. To perform its RCOI and supply chain due diligence, the Company surveyed its suppliers using the Conflict Minerals Reporting Template (the “Template”) developed by the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative (“EICC-GeSI”) available through the Conflict-Free Sourcing Initiative (“CFSI”). The Template facilitates the transfer of information through the supply chain regarding country of origin and smelters and refiners, including suppliers’ conflict-free policies and information regarding their engagement with lower-tier suppliers.
Reasonable Country-of-Origin Inquiry
The Company has conducted a good faith RCOI that was reasonably designed to determine whether any of the Conflict Minerals in the Covered Products originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources. Using the Template, Abaxis conducted a survey of all suppliers that provided components or parts the Company reasonably believed were likely to contain 3TG. Because, as a result of its RCOI, the Company was unable to determine the country of origin of all Conflict Minerals in its supply chain, the Company also performed due diligence on the source and chain of custody to determine whether the Conflict Minerals directly or indirectly financed or benefitted armed groups in the Covered Countries.
Design of Due Diligence
The Company’s due diligence process has been designed to conform to the framework developed by 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, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”), consistent with the Company’s position as a downstream company.
Description of Due Diligence Measures
The Company’s due diligence on the source and chain of custody of the Conflict Minerals contained in the Covered Products included the following measures:
Establish Strong Management Systems
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Conflict Minerals Policy. The Company has adopted a conflict minerals policy (the “Company Policy”), which provides in part as follows: |
We support the objectives underlying Section 1502 and the efforts being made to reduce the risk that trade in conflict minerals contributes to this humanitarian crisis. We have initiated a process to comply with the SEC rules. In particular, we are taking steps to (1) conduct due diligence regarding the origin of any conflict minerals in our supply chain and enhance our supply chain internal controls; (2) strive to eliminate conflict minerals that may be supporting the conflict in the DRC; and (3) notify our suppliers of our policy on conflict minerals and encourage them to make similar commitments and take similar measures. We are in the process of determining the exposure of our supply chain to conflict minerals mined in conditions of armed conflict and human rights abuses and following an internationally recognized due diligence framework to understand and minimize our risk. However, the global supply chain for these minerals is complex, and tracing these minerals to their sources is a challenge. To meet that challenge, we must rely on the cooperation of our suppliers. To help us adhere to our policy, implement the tracking process and meet our SEC reporting obligations, we expect our suppliers to respond to our queries about purchased components on a timely basis, including assistance in reaching out to their suppliers when necessary to trace the source of minerals and regular communications with us about supplier’s conflict minerals tracking and tracing efforts. In addition, we are taking steps to encourage our suppliers to commit to responsible “conflict-free” sourcing to prevent directly or indirectly contributing to armed conflicts and human rights abuses. If conflict minerals are identified in our supply chain, we plan to work with our suppliers to determine if practical conflict-free sources certified under the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative (EICC/GeSI) Conflict-Free Smelter Program, are available and work to qualify those sources.
This policy will be regularly reviewed and updated as needed. The Company has posted the Company Policy on its website (http://www.abaxis.com/investor_relations/supply-chain-policy-and-supplier-guidelines.html). The Company has also advised its suppliers about the Company Policy and has encouraged them to adopt similar policies.
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Conflict Minerals Team. Abaxis has identified an internal Conflict Minerals Rule compliance team consisting of a cross-functional group that includes representatives from manufacturing/engineering, purchasing/procurement and finance. The compliance team is responsible for developing and implementing the Company’s compliance program. |
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Strengthen Engagement with Suppliers. The Company enhanced its engagement with its suppliers principally by communicating to suppliers, information and guidance regarding the Company’s requirements under the SEC’s Conflict Minerals rules, as well as the standards and expectations set forth in the Company Policy. |
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Grievance Mechanism. The Company’s Corporate Governance policies include a whistleblower hotline for reporting any grievances, including issues concerning the Company’s Conflict Minerals compliance. |
Identify and Assess Risks in the Supply Chain
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Identification of Supply Chain Risk. To identify the risk in the supply chain, consistent with the approach taken for the RCOI, the Company reviewed the Templates and other information provided by the suppliers that responded to the survey. All suppliers surveyed responded to the Company’s inquiry. However, the responses contained varying degrees of information regarding the names and locations of 3TG smelters or refiners in the suppliers’ respective supply chains. The Company assessed the reasonableness of the representations made, reviewing the responses against criteria it developed to determine which responses required further engagement with suppliers. These criteria included untimely or incomplete responses as well as inconsistencies or other apparent inaccuracies within the data reported. Where necessary, the Company contacted suppliers for follow-up, clarification or additional information. |
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Risk Assessment. To the extent that suppliers identified smelters and refiners in the supply chain, the Company took steps to assess the risk that the Conflict Minerals directly or indirectly financed or benefitted armed groups in the Covered Countries. To that end, the Company evaluated suppliers’ stated responses regarding the locations of origin of the Conflict Minerals as well as the mine locations. In particular, the Company compared the smelters and refiners identified by its surveyed suppliers against currently available independently verified lists of compliant smelters or refiners such as the CFSI’s Conflict-Free Smelter Program (“CFSP”) – Compliant Refiners/Smelters, the Responsible Jewellery Council (RJC) – Chain of Custody Certified Entities and the London Bullion Market Association (LBMA) – Good Delivery List. Generally, these programs identify smelters and refiners that an independent third-party audit has confirmed have systems in place designed to assure sourcing of only conflict-free minerals. |
Carry Out Independent Third-Party Audit of Supply Chain
The Company does not have any direct relationships with smelters or refiners that process Conflict Minerals, and it does not perform or direct audits of these entities within its supply chain. As an alternative, the Company has relied on audit results and information collected and provided by independent third-party audit programs, such as the CFSP.
Report Annually on Supply Chain Due Diligence
The Company expects to report annually, as required by the Rule, and has posted this Report on its website.
Risk Mitigation and Future Due Diligence Measures
As noted above, Abaxis adopted the Company Policy and strives to take steps to ensure that Conflict Minerals contained in its products are sourced with due respect for human rights, avoid contributing to conflict, and support development through responsible supply chain practices.
The Company takes the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the Conflict Minerals contained in the Company’s products benefit armed groups in the Covered Countries:
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Enhancing supply chain transparency by continuing to engage with suppliers to obtain current, accurate and complete information about the supply chain; and |
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Encouraging suppliers to implement responsible sourcing and to request that they encourage smelters and refiners to obtain a “conflict-free” designation from a recognized third-party auditor through a program such as the CFSP and other industry-sponsored programs. |
Results of Due Diligence
Although some suppliers were unable to identify the smelters or refiners or the mine locations, the suppliers who were able to identify the smelters and refiners in their supply chains provided lists of smelters or refiners at product-level. For the calendar year 2014, the Company’s suppliers identified 605 3TG smelters or refiners at product-level. Of these, 304 facilities were not confirmed to be actual smelters or refiners, based on the list of “all known conflict mineral processing facilities worldwide” developed by the U.S. Department of Commerce. Of the 301 facilities the Company believes were actual smelters or refiners, 161 or 53% were identified by one of the programs above as certified conflict-free based on currently available independently verified lists of compliant smelters or refiners.
Identified Smelters and Refiners
As noted above, not all of the Company’s suppliers were able to identify smelters and refiners either at company-level or product-level. Moreover, there were facilities identified by suppliers that were not identified as actual smelters or refiners on the list developed by the U.S. Department of Commerce. As a result, at this point, the Company does not believe that it can reliably identify all smelters and/or refiners in its supply chain and, therefore, has presented in Table I of this CMR, only the 301 facilities believed to be actual smelters or refiners and that were identified by suppliers that provided product-level information.
Identified Countries of Origin
Based on the above-described due diligence process, the Company does not have sufficient information to conclusively determine the countries of origin of the 3TG in each of the Covered Products or whether the 3TG were from scrap or recycled sources. However, based on the information provided by the suppliers, as well as from other sources such as CFSI, RJC and LBMA, the Company believes that the countries of origin of the 3TG contained in the Covered Products include the countries listed in Table II of this this CMR. In compiling this list, the Company included all of the countries of origin identified by suppliers that provided product-level information, consistent with the Company’s approach with respect to smelters and refiners.
Efforts to Determine Mine or Location of Origin
To determine the mines or location of origin of the Conflict Minerals with the greatest possible specificity, the Company performed the due diligence measures described above.
Cautionary Note on Forward-Looking Statements
Forward-looking statements in this CMR are made pursuant to the safe harbor provisions of Section 21E of the Securities Exchange Act of 1934, as amended, and other federal securities laws. Investors are cautioned that statements in this CMR that are not strictly historical statements, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, due diligence, and risk mitigation efforts and strategy, constitute forward-looking statements that involve risks and uncertainties. Words such as “expects,” “anticipates,” “goals,” “strives,” “intends,” “plans,” “believes,” “seeks,” variations of these words, and similar expressions are intended to identify such forward-looking statements. Actual results could differ materially from the forward-looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others.
Table I. Names of Smelters or Refiners are believed to include:
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Mineral
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Smelter or Refiner Name
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Smelter or Refiner Country Location
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Gold
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Aida Chemical Industries Co. Ltd.
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JAPAN
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Gold
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Allgemeine Gold-und Silberscheideanstalt A.G.
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GERMANY
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Gold
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Almalyk Mining and Metallurgical Complex (AMMC)
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UZBEKISTAN
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Gold
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AngloGold Ashanti Córrego do Sítio Minerção
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BRAZIL
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Gold
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Argor-Heraeus SA
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SWITZERLAND
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Gold
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Asahi Pretec Corporation
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JAPAN
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Gold
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Asaka Riken Co Ltd
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JAPAN
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Gold
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Asarco
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UNITED STATES
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Gold
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Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
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TURKEY
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Gold
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Aurubis AG
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GERMANY
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Gold
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
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PHILIPPINES
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Gold
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Bauer Walser AG
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GERMANY
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Gold
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Boliden AB
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SWEDEN
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Gold
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C. Hafner GmbH + Co. KG
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GERMANY
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Gold
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Caridad
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MEXICO
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Gold
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CCR Refinery – Glencore Canada Corporation / Xstrata Canada Corportion
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CANADA
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Gold
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Cendres + Métaux SA
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SWITZERLAND
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Gold
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Chimet S.p.A.
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ITALY
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Gold
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China National Gold Group Corporation
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CHINA
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Gold
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Chugai Mining
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JAPAN
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Gold
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Codelco
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CHILE
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Gold
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Colt Refining
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UNITED STATES
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Gold
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Daejin Indus Co. Ltd
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REPUBLIC OF KOREA
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Gold
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Daye Non-Ferrous Metals Mining Ltd.
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CHINA
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Gold
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Do Sung Corporation
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REPUBLIC OF KOREA
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Gold
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Doduco
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GERMANY
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Gold
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Dowa
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JAPAN
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Gold
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Eco-System Recycling Co., Ltd.
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JAPAN
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Gold
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FSE Novosibirsk Refinery
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RUSSIAN FEDERATION
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Gold
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Gansu Seemine Material Hi-Tech Co Ltd
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CHINA
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Gold
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Guangdong Jinding Gold Limited
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CHINA
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Gold
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Hangzhou Fuchunjiang Smelting Co., Ltd.
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CHINA
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Gold
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Heimerle + Meule GmbH
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GERMANY
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Gold
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Heraeus Ltd. Hong Kong
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HONG KONG
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Gold
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Heraeus Precious Metals GmbH & Co. KG
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GERMANY
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Gold
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Hunan Chenzhou Mining Group Co., Ltd.
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CHINA
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Gold
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Hwasung CJ Co. Ltd
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REPUBLIC OF KOREA
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Gold
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Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
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CHINA
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Gold
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Ishifuku Metal Industry Co., Ltd.
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JAPAN
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Gold
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Istanbul Gold Refinery
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TURKEY
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Gold
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Japan Mint
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JAPAN
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Gold
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Jiangxi Copper Company Limited
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CHINA
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Gold
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Johnson Matthey Inc
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UNITED STATES
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Gold
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Johnson Matthey Ltd
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CANADA
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Gold
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JSC Ekaterinburg Non-Ferrous Metal Processing Plant
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RUSSIAN FEDERATION
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Table I. Names of Smelters or Refiners are believed to include:
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Mineral
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Smelter or Refiner Name
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Smelter or Refiner Country Location
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Gold
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JSC Uralelectromed
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RUSSIAN FEDERATION
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Gold
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JX Nippon Mining & Metals Co., Ltd.
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JAPAN
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Gold
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Kazzinc Ltd
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KAZAKHSTAN
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Gold
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Kennecott Utah Copper LLC
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UNITED STATES
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Gold
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Kojima Chemicals Co., Ltd
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JAPAN
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Gold
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Korea Metal Co. Ltd
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REPUBLIC OF KOREA
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Gold
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Kyrgyzaltyn JSC
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KYRGYZSTAN
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Gold
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L' azurde Company For Jewelry
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SAUDI ARABIA
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Gold
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Lingbao Gold Company Limited
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CHINA
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Gold
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Lingbao Jinyuan Tonghui Refinery Co. Ltd.
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CHINA
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Gold
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LS-NIKKO Copper Inc.
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REPUBLIC OF KOREA
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Gold
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Luoyang Zijin Yinhui Metal Smelt Co Ltd
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CHINA
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Gold
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Materion
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UNITED STATES
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Gold
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Matsuda Sangyo Co., Ltd.
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JAPAN
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Gold
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Metalor Technologies (Hong Kong) Ltd
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HONG KONG
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Gold
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Metalor Technologies (Singapore) Pte. Ltd.
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SINGAPORE
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Gold
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Metalor Technologies (Suzhou) Ltd.
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CHINA
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Gold
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Metalor Technologies SA
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SWITZERLAND
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Gold
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Metalor USA Refining Corporation
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UNITED STATES
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Gold
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Met-Mex Peñoles, S.A.
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MEXICO
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Gold
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Mitsubishi Materials Corporation
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JAPAN
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Gold
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Mitsui Mining and Smelting Co., Ltd.
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JAPAN
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Gold
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Moscow Special Alloys Processing Plant
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RUSSIAN FEDERATION
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Gold
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Nadir Metal Rafineri San. Ve Tic. A.Ş.
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TURKEY
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Gold
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Navoi Mining and Metallurgical Combinat
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UZBEKISTAN
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Gold
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Nihon Material Co. LTD
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JAPAN
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Gold
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Ohio Precious Metals, LLC
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UNITED STATES
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Gold
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Ohura Precious Metal Industry Co., Ltd
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JAPAN
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Gold
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OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
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RUSSIAN FEDERATION
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Gold
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OJSC Kolyma Refinery
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RUSSIAN FEDERATION
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Gold
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PAMP SA
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SWITZERLAND
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Gold
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Penglai Penggang Gold Industry Co Ltd
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CHINA
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Gold
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Prioksky Plant of Non-Ferrous Metals
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RUSSIAN FEDERATION
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Gold
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PT Aneka Tambang (Persero) Tbk
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INDONESIA
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Gold
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PX Précinox SA
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SWITZERLAND
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Gold
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Rand Refinery (Pty) Ltd
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SOUTH AFRICA
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Gold
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Royal Canadian Mint
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CANADA
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Gold
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Sabin Metal Corp.
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UNITED STATES
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Gold
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Samduck Precious Metals
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REPUBLIC OF KOREA
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Gold
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SAMWON METALS Corp.
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REPUBLIC OF KOREA
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Gold
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Schone Edelmetaal
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NETHERLANDS
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Gold
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SEMPSA Joyería Platería SA / Cookson
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SPAIN
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Gold
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Shandong Zhaojin Gold & Silver Refinery Co. Ltd
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CHINA
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Gold
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So Accurate Group, Inc.
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UNITED STATES
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Gold
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SOE Shyolkovsky Factory of Secondary Precious Metals
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RUSSIAN FEDERATION
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Table I. Names of Smelters or Refiners are believed to include:
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Mineral
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Smelter or Refiner Name
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Smelter or Refiner Country Location
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Gold
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Solar Applied Materials Technology Corp.
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TAIWAN
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Gold
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Sumitomo Metal Mining Co., Ltd. / Niihama Nickel Refinery
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JAPAN
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Gold
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Tanaka Kikinzoku Kogyo K.K.
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JAPAN
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Gold
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The Great Wall Gold and Silver Refinery of China
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CHINA
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Gold
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The Refinery of Shandong Gold Mining Co. Ltd
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CHINA
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Gold
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Tokuriki Honten Co., Ltd
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JAPAN
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Gold
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Tongling nonferrous Metals Group Co.,Ltd
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CHINA
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Gold
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Torecom
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REPUBLIC OF KOREA
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Gold
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Umicore Brasil Ltda
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BRAZIL
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Gold
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Umicore Precious Metals Thailand
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THAILAND
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Gold
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Umicore SA Business Unit Precious Metals Refining
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BELGIUM
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Gold
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United Precious Metal Refining, Inc.
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UNITED STATES
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Gold
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Valcambi SA
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SWITZERLAND
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Gold
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Western Australian Mint trading as The Perth Mint
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AUSTRALIA
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Gold
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YAMAMOTO PRECIOUS METAL CO., LTD.
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JAPAN
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Gold
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Yokohama Metal Co Ltd
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JAPAN
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Gold
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Yunnan Copper Industry Co Ltd
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CHINA
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Gold
|
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
|
CHINA
|
Gold
|
|
Zijin Mining Group Co. Ltd
|
|
CHINA
|
Tantalum
|
|
Changsha South Tantalum Niobium Co., Ltd.
|
|
CHINA
|
Tantalum
|
|
Conghua Tantalum and Niobium Smeltry
|
|
CHINA
|
Tantalum
|
|
Duoluoshan
|
|
CHINA
|
Tantalum
|
|
Exotech Inc.
|
|
UNITED STATES
|
Tantalum
|
|
F&X Electro-Materials Ltd.
|
|
CHINA
|
Tantalum
|
|
Gannon & Scott
|
|
UNITED STATES
|
Tantalum
|
|
Global Advanced Metals Aizu
|
|
JAPAN
|
Tantalum
|
|
Global Advanced Metals Boyertown
|
|
UNITED STATES
|
Tantalum
|
|
Guangdong Zhiyuan New Material Co., Ltd.
|
|
CHINA
|
Tantalum
|
|
H.C. Starck Co., Ltd.
|
|
THAILAND
|
Tantalum
|
|
H.C. Starck GmbH Goslar
|
|
GERMANY
|
Tantalum
|
|
H.C. Starck GmbH Laufenburg
|
|
GERMANY
|
Tantalum
|
|
H.C. Starck Hermsdorf GmbH
|
|
GERMANY
|
Tantalum
|
|
H.C. Starck Inc.
|
|
UNITED STATES
|
Tantalum
|
|
H.C. Starck Ltd.
|
|
JAPAN
|
Tantalum
|
|
H.C. Starck Smelting GmbH & Co.KG
|
|
GERMANY
|
Tantalum
|
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
|
CHINA
|
Tantalum
|
|
Hi-Temp
|
|
UNITED STATES
|
Tantalum
|
|
Jiangxi Dinghai Tantalum & Niobium Co., LTD
|
|
CHINA
|
Tantalum
|
|
JiuJiang JinXin Nonferrous Metals Co., Ltd.
|
|
CHINA
|
Tantalum
|
|
Jiujiang Tanbre Co., Ltd.
|
|
CHINA
|
Tantalum
|
|
Jiujiang Zhongao Tantalum & Niobium Co, Ltd
|
|
CHINA
|
Tantalum
|
|
KEMET Blue Metals
|
|
MEXICO
|
Tantalum
|
|
KEMET Blue Powder
|
|
UNITED STATES
|
Tantalum
|
|
King-Tan Tantalum Industry Ltd
|
|
CHINA
|
Tantalum
|
|
LSM Brasil S.A.
|
|
BRAZIL
|
Table I. Names of Smelters or Refiners are believed to include:
|
|
|
|
|
|
|
|
Mineral
|
|
Smelter or Refiner Name
|
|
Smelter or Refiner Country Location
|
Tantalum
|
|
Metallurgical Products India (Pvt.) Ltd.
|
|
INDIA
|
Tantalum
|
|
Mineração Taboca S.A.
|
|
BRAZIL
|
Tantalum
|
|
Mitsui Mining & Smelting
|
|
JAPAN
|
Tantalum
|
|
Molycorp Silmet A.S.
|
|
ESTONIA
|
Tantalum
|
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
|
CHINA
|
Tantalum
|
|
Plansee SE Liezen
|
|
AUSTRIA
|
Tantalum
|
|
Plansee SE Reutte
|
|
AUSTRIA
|
Tantalum
|
|
QuantumClean
|
|
UNITED STATES
|
Tantalum
|
|
RFH Tantalum Smeltry Co., Ltd
|
|
CHINA
|
Tantalum
|
|
Shanghai Jiangxi Metals Co. Ltd
|
|
CHINA
|
Tantalum
|
|
Solikamsk Magnesium Works OAO
|
|
RUSSIAN FEDERATION
|
Tantalum
|
|
Taki Chemicals
|
|
JAPAN
|
Tantalum
|
|
Tantalite Resources
|
|
SOUTH AFRICA
|
Tantalum
|
|
Telex
|
|
UNITED STATES
|
Tantalum
|
|
Ulba
|
|
KAZAKHSTAN
|
Tantalum
|
|
Yichun Jin Yang Rare Metal Co., Ltd
|
|
CHINA
|
Tantalum
|
|
Zhuzhou Cement Carbide
|
|
CHINA
|
Tin
|
|
Alpha / Cookson
|
|
UNITED STATES
|
Tin
|
|
Amalgamated Metal Corporation PLC
|
|
INDONESIA
|
Tin
|
|
Amalgamet Inc
|
|
PERU
|
Tin
|
|
China Rare Metal Materials Company
|
|
CHINA
|
Tin
|
|
China Tin Group Co., Ltd. / Liuzhou China Tin
|
|
CHINA
|
Tin
|
|
CNMC (Guangxi) PGMA Co. Ltd.
|
|
CHINA
|
Tin
|
|
Cooper Santa
|
|
BRAZIL
|
Tin
|
|
CV Duta Putra Bangka
|
|
INDONESIA
|
Tin
|
|
CV JusTindo
|
|
INDONESIA
|
Tin
|
|
CV Makmur Jaya
|
|
INDONESIA
|
Tin
|
|
CV Nurjanah
|
|
INDONESIA
|
Tin
|
|
CV Serumpun Sebalai
|
|
INDONESIA
|
Tin
|
|
CV United Smelting
|
|
INDONESIA
|
Tin
|
|
Dowa
|
|
JAPAN
|
Tin
|
|
Electroloy Metal Pte.
|
|
SINGAPORE
|
Tin
|
|
EM Vinto
|
|
BOLIVIA
|
Tin
|
|
Estanho de Rondônia S.A.
|
|
BRAZIL
|
Tin
|
|
Fenix Metals
|
|
POLAND
|
Tin
|
|
FSE Novosibirsk Refinery
|
|
RUSSIAN FEDERATION
|
Tin
|
|
Gejiu Kai Meng Industry and Trade LLC
|
|
CHINA
|
Tin
|
|
Gejiu Non-Ferrous Metal Processing Co. Ltd.
|
|
CHINA
|
Tin
|
|
Gejiu Zi-Li
|
|
CHINA
|
Tin
|
|
Guangxi China Tin Group Co., Ltd
|
|
CHINA
|
Tin
|
|
Guangxi Pinggui PGMA Co. Ltd.
|
|
CHINA
|
Tin
|
|
Heraeus Materials Singapore Pte. Ltd.
|
|
SINGAPORE
|
Tin
|
|
Huichang Jinshunda Tin Co. Ltd
|
|
CHINA
|
Tin
|
|
Hyundai-Steel
|
|
REPUBLIC OF KOREA
|
Tin
|
|
Jean Goldschmidt International
|
|
BELGIUM
|
Table I. Names of Smelters or Refiners are believed to include:
|
|
|
|
|
|
|
|
Mineral
|
|
Smelter or Refiner Name
|
|
Smelter or Refiner Country Location
|
Tin
|
|
Jiangxi Nanshan
|
|
CHINA
|
Tin
|
|
Kovohute Pribram Nastupnicka, A.S.
|
|
CZECH REPUBLIC
|
Tin
|
|
Lai'bin China Tin Smelting Ltd.
|
|
CHINA
|
Tin
|
|
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
|
|
CHINA
|
Tin
|
|
Linwu Xianggui Smelter Co
|
|
CHINA
|
Tin
|
|
Magnu's Minerais Metais e Ligas LTDA
|
|
BRAZIL
|
Tin
|
|
Malaysia Smelting Corporation (MSC)
|
|
MALAYSIA
|
Tin
|
|
Melt Metais e Ligas S/A
|
|
BRAZIL
|
Tin
|
|
Metallo Chimique
|
|
BELGIUM
|
Tin
|
|
Mineração Taboca S.A.
|
|
BRAZIL
|
Tin
|
|
Minsur
|
|
PERU
|
Tin
|
|
Mitsubishi Materials Corporation
|
|
JAPAN
|
Tin
|
|
Novosibirsk Integrated Tin Works
|
|
RUSSIAN FEDERATION
|
Tin
|
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
|
THAILAND
|
Tin
|
|
O.M. Manufacturing Philippines, Inc.
|
|
PHILIPPINES
|
Tin
|
|
Ohio Precious Metals, LLC
|
|
UNITED STATES
|
Tin
|
|
OMSA
|
|
BOLIVIA
|
Tin
|
|
Poongsan Corporation
|
|
REPUBLIC OF KOREA
|
Tin
|
|
Posco
|
|
REPUBLIC OF KOREA
|
Tin
|
|
PT Alam Lestari Kencana
|
|
INDONESIA
|
Tin
|
|
PT Artha Cipta Langgeng
|
|
INDONESIA
|
Tin
|
|
PT Babel Inti Perkasa
|
|
INDONESIA
|
Tin
|
|
PT Babel Surya Alam Lestari
|
|
INDONESIA
|
Tin
|
|
PT Bangka Kudai Tin
|
|
INDONESIA
|
Tin
|
|
PT Bangka Putra Karya
|
|
INDONESIA
|
Tin
|
|
PT Bangka Timah Utama Sejahtera
|
|
INDONESIA
|
Tin
|
|
PT Bangka Tin Industry
|
|
INDONESIA
|
Tin
|
|
PT Belitung Industri Sejahtera
|
|
INDONESIA
|
Tin
|
|
PT BilliTin Makmur Lestari
|
|
INDONESIA
|
Tin
|
|
PT Bukit Timah
|
|
INDONESIA
|
Tin
|
|
PT DS Jaya Abadi
|
|
INDONESIA
|
Tin
|
|
PT Eunindo Usaha Mandiri
|
|
INDONESIA
|
Tin
|
|
PT Fang Di MulTindo
|
|
INDONESIA
|
Tin
|
|
PT HP Metals Indonesia
|
|
INDONESIA
|
Tin
|
|
PT Karimun Mining
|
|
INDONESIA
|
Tin
|
|
PT Koba Tin
|
|
INDONESIA
|
Tin
|
|
PT Mitra Stania Prima
|
|
INDONESIA
|
Tin
|
|
PT Panca Mega Persada
|
|
INDONESIA
|
Tin
|
|
PT Pelat Timah Nusantara Tbk
|
|
INDONESIA
|
Tin
|
|
PT Prima Timah Utama
|
|
INDONESIA
|
Tin
|
|
PT REFINED BANGKA TIN
|
|
INDONESIA
|
Tin
|
|
PT Sariwiguna Binasentosa
|
|
INDONESIA
|
Tin
|
|
PT Seirama Tin investment
|
|
INDONESIA
|
Tin
|
|
PT Stanindo Inti Perkasa
|
|
INDONESIA
|
Tin
|
|
PT Sumber Jaya Indah
|
|
INDONESIA
|
Table I. Names of Smelters or Refiners are believed to include:
|
|
|
|
|
|
|
|
Mineral
|
|
Smelter or Refiner Name
|
|
Smelter or Refiner Country Location
|
Tin
|
|
PT Supra Sukses Trinusa
|
|
INDONESIA
|
Tin
|
|
PT Tambang Timah
|
|
INDONESIA
|
Tin
|
|
PT Timah (Persero), Tbk
|
|
INDONESIA
|
Tin
|
|
PT Tinindo Inter Nusa
|
|
INDONESIA
|
Tin
|
|
PT Yinchendo Mining Industry
|
|
INDONESIA
|
Tin
|
|
Pure Technology
|
|
RUSSIAN FEDERATION
|
Tin
|
|
Rahman Hydrulic Tin Sdn Bhd
|
|
MALAYSIA
|
Tin
|
|
Rui Da Hung
|
|
TAIWAN
|
Tin
|
|
Senju Metal Industry Co. (SMIC)
|
|
JAPAN
|
Tin
|
|
Shao Xing Tian Long Tin Materials Co. Ltd
|
|
CHINA
|
Tin
|
|
SMIC Senju Malysia
|
|
MALAYSIA
|
Tin
|
|
Soft Metais, Ltda.
|
|
BRAZIL
|
Tin
|
|
Technic Inc.
|
|
UNITED STATES
|
Tin
|
|
Thaisarco
|
|
THAILAND
|
Tin
|
|
Umicore Haboken
|
|
BELGIUM
|
Tin
|
|
White Solder Metalurgia e Mineração Ltda.
|
|
BRAZIL
|
Tin
|
|
Yokohama Metal Co Ltd
|
|
JAPAN
|
Tin
|
|
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.
|
|
CHINA
|
Tin
|
|
Yunnan Tin Company, Ltd.
|
|
CHINA
|
Tin
|
|
ZhongShi Metal Co., Ltd
|
|
CHINA
|
Tin
|
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
|
CHINA
|
Tin
|
|
Zijin Copper Co. Ltd.
|
|
CHINA
|
Tungsten
|
|
A.L.M.T. Corp.
|
|
JAPAN
|
Tungsten
|
|
Air Products
|
|
UNITED STATES
|
Tungsten
|
|
Chaozhou Xianglu Tungsten Industry Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Chenzhou Diamond Tungsten Products Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
China Minmetals Nonferrous Metals Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Dayu Weiliang Tungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Fujian Jinxin Tungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Ganzhou Grand Sea W & Mo Group Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Ganzhou Sinda W&Mo Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Global Tungsten & Powders Corp.
|
|
UNITED STATES
|
Tungsten
|
|
Guangdong Xianglu Tungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
H.C. Starck
|
|
UNITED STATES
|
Tungsten
|
|
H.C. Starck
|
|
RUSSIAN FEDERATION
|
Tungsten
|
|
H.C. Starck GmbH
|
|
GERMANY
|
Tungsten
|
|
H.C. Starck Smelting GmbH & Co.KG
|
|
GERMANY
|
Tungsten
|
|
Hunan Chenzhou Mining Group Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Hunan Chunchang Nonferrous Metals Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Japan New Metals Co., Ltd.
|
|
JAPAN
|
Table I. Names of Smelters or Refiners are believed to include:
|
|
|
|
|
|
|
|
Mineral
|
|
Smelter or Refiner Name
|
|
Smelter or Refiner Country Location
|
Tungsten
|
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Jiangxi Rare Earth & Rare Metals Tungsten Group Corp.
|
|
CHINA
|
Tungsten
|
|
Jiangxi Richsea New Materials Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Jiangxi Tungsten Co Ltd
|
|
CHINA
|
Tungsten
|
|
Jiangxi Tungsten Industry Group Co Ltd
|
|
CHINA
|
Tungsten
|
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Kennametal Fallon
|
|
UNITED STATES
|
Tungsten
|
|
Kennametal Huntsville
|
|
UNITED STATES
|
Tungsten
|
|
Malipo Haiyu Tungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Metallo Chimique
|
|
BELGIUM
|
Tungsten
|
|
Mitsubishi Materials Corporation
|
|
JAPAN
|
Tungsten
|
|
Mitsui Mining & Smelting
|
|
JAPAN
|
Tungsten
|
|
Nanchang Cemented Carbide Limited Liability Company
|
|
CHINA
|
Tungsten
|
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Plansee SE Liezen
|
|
AUSTRIA
|
Tungsten
|
|
Plansee SE Reutte
|
|
AUSTRIA
|
Tungsten
|
|
Solar Applied Materials Technology Corp.
|
|
TAIWAN
|
Tungsten
|
|
Sumitomo Metal Mining Co., Ltd.
|
|
JAPAN
|
Tungsten
|
|
TaeguTec Ltd.
|
|
REPUBLIC OF KOREA
|
Tungsten
|
|
Tejing (Vietnam) Tungsten Co., Ltd.
|
|
VIETNAM
|
Tungsten
|
|
Vietnam Youngsun Tungsten Industry Co., Ltd
|
|
VIETNAM
|
Tungsten
|
|
Wolfram Bergbau und Hütten AG
|
|
AUSTRIA
|
Tungsten
|
|
Wolfram Company CJSC
|
|
RUSSIAN FEDERATION
|
Tungsten
|
|
Xiamen Honglu Tungsten Molybdenum Industry Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Xiamen Tungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
|
|
CHINA
|
Tungsten
|
|
Zhuzhou Cement Carbide
|
|
CHINA
|
Table II. Countries of Origin of Conflict Minerals are believed to include:
|
|
|
|
|
|
Countries of Origin
|
|
|
|
AUSTRALIA
|
|
MEXICO
|
|
AUSTRIA
|
|
NETHERLANDS
|
|
BELGIUM
|
|
PERU
|
|
BOLIVIA
|
|
PHILIPPINES
|
|
BRAZIL
|
|
POLAND
|
|
CANADA
|
|
REPUBLIC OF KOREA
|
|
CHILE
|
|
RUSSIAN FEDERATION
|
|
CHINA
|
|
SAUDI ARABIA
|
|
CZECH REPUBLIC
|
|
SINGAPORE
|
|
ESTONIA
|
|
SOUTH AFRICA
|
|
GERMANY
|
|
SPAIN
|
|
HONG KONG
|
|
SWEDEN
|
|
INDIA
|
|
SWITZERLAND
|
|
INDONESIA
|
|
TAIWAN
|
|
ITALY
|
|
THAILAND
|
|
JAPAN
|
|
TURKEY
|
|
KAZAKHSTAN
|
|
UNITED STATES
|
|
KYRGYZSTAN
|
|
UZBEKISTAN
|
|
MALAYSIA
|
|
VIETNAM
|
|