UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
__________________________________________
FORM SD
Specialized Disclosure Report
__________________________________________
IPG PHOTONICS CORPORATION
(Exact name of registrant as specified in its charter)
 
 
 
 
 
Delaware
 
001-33155 
 
04-3444218
(State or other jurisdiction
 
(Commission
 
(IRS Employer
of incorporation or organization)
 
File Number)
 
Identification No.)
 
 
 
 
 
50 Old Webster Road,
Oxford, Massachusetts
 
 
 
01540
(Address of principal executive offices)
 
 
 
(Zip Code)
Angelo P. Lopresti, telephone: (508) 373-1100
(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:
ý
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.





Introduction
IPG Photonics Corporation (“IPG” or the “Company”) is the leading developer and manufacturer of a broad line of high-performance fiber lasers, fiber amplifiers and diode lasers that are used for diverse applications, primarily in materials processing. Fiber lasers are a relatively new generation of lasers that combine the advantages of semiconductor diodes, such as long life and high efficiency, with the high amplification and precise beam qualities of specialty optical fibers to deliver superior performance, reliability and usability. Our diverse lines of low, mid and high-power lasers and amplifiers are used in materials processing, advanced, communications and medical applications. We sell our products globally to original equipment manufacturers (“OEMs”), system integrators and end users. We are vertically integrated such that we design and manufacture most of the key components used in our finished products, from semiconductor diodes to optical fiber preforms, finished fiber lasers and amplifiers. We also manufacture complementary products used with our lasers including optical delivery cables, fiber couplers, beam switches, optical processing heads and chillers. In addition, we offer laser-based systems for certain markets and applications.

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

The Conflict Minerals Report for the calendar year ended December 31, 2014 filed herewith as Exhibit 1.01 to this Form SD, is available at http://investor.ipgphotonics.com/sec.cfm.
Item 1.02 Exhibit

The Conflict Minerals Report required by Items 1.01 and 1.02 is filed as Exhibit 1.01 to this Form SD.

Section 2 - Exhibits

Item 2.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report for the year ended December 31, 2014.






Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this Specialied Disclosure Report to be signed on its behalf by the undersigned thereunto duly authorized.
 
 
 
 
 
 
 
 
IPG PHOTONICS CORPORATION
 
 
 
June 1, 2015
 
By:
 
/s/ Angelo P. Lopresti
 
 
 
 
Angelo P. Lopresti
 
 
 
 
Senior Vice President, General Counsel and Corporate Secretary
 
 
 
 
 





Exhibit 1.01


Conflict Minerals Report

1.
Introduction

IPG Photonics Corporation (the “Company”) manufactures certain products, described more fully below, that contain “Conflict Minerals” within the meaning of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). For purposes of the Act, “Conflict Minerals” are currently defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold. Recognizing that some Conflict Minerals that are sourced from the Democratic Republic of the Congo or its adjoining countries (the “DRC Region”) are used to support the conflict and humanitarian crisis in the DRC Region, and in compliance with the Act’s requirements, the Company sought to determine the origins of its Conflict Minerals to minimize the risk that its Conflict Minerals directly or indirectly financed or benefited the armed groups responsible for the humanitarian crises in the DRC Region.

2.    Scope of Company’s Conflict Minerals Report

The information contained in this report includes the activities of the Company’s consolidated subsidiaries. Because the Company was unable to determine the source of all of its Conflict Minerals, and pursuant to the guidance issued by Securities and Exchange Commission (“SEC”), this report is not subject to an independent private sector audit.

3.    Product Description

The Company manufactures high-performance optical fiber-based lasers and amplifiers, packaged diodes, direct diode lasers, laser systems, communications systems and materials processing laser systems that utilize its optical-based products. The Company manufactures diode-pumped fiber lasers and fiber amplifiers for a variety of materials processing, micromachining, telecommunications, medical and other advanced applications. Such products contain parts or components that contain Conflict Minerals that are necessary for the functionality or production of these products. Therefore, the Company’s products are subject to the reporting obligations of Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “1934 Act”).

4.    Reasonable Country of Origin Inquiry

The Company does not have direct relationships with smelters or refiners (“SORs”) but is familiar with and became a member of the Conflict Free Smelter Initiative (“CFSI”), an initiative which supports the validation and certification of smelters as “conflict free”. As recognized by the CFSI in its white paper “Reasonable Practices to Identify Sources of Conflict Minerals: Practical Guidance for Downstream Companies”, the Company, as a “downstream” company, possesses no independent means of determining the source and origin of conflict mineral ores processed by smelters or refiners. The Company does not purchase raw ore or unrefined Conflict Minerals and has no direct suppliers in the DRC Region. The Company purchases materials used in its products from a large network of suppliers, and some of those materials contain Conflict Minerals. The Company relies on its suppliers to assist in its efforts to determine the origins of the Conflict Minerals contained in the materials they supply to the Company.

The Company conducted a Reasonable Country of Origin Inquiry (“RCOI”), an inquiry regarding the origin of Conflict Minerals designed to determine the origination of minerals used by the Company’s suppliers and whether such minerals are from recycled or scrap sources. In preparation for its RCOI, the Company sought to identify the vendors that supply the Company with materials that are incorporated into the Company’s products and that reasonably could contain Conflict Minerals. Using the CFSI reporting template, the Company gathered information from the vendors concerning whether, among other things, the Conflict Minerals originated in the DRC Region or were from recycled or scrap sources. The CFSI template is the standard reporting template for companies to use to facilitate disclosure and communication of information regarding suppliers that provide materials to a company’s supply chain. Because the CFSI reporting template is not currently available in Russian, the Company used an online survey based on the questions contained in the CFSI reporting template for the targeted vendors of its Russian subsidiary, NTO IRE-Polus. The Company’s online survey provided the NTO IRE-Polus vendors with the ability to elaborate on their answers to questions, as well as the ability to attach documents such as conflict minerals statements or policies.

In response to the Company’s RCOI, many suppliers responded that they were in the process of surveying their own suppliers or were uncertain about the origins of their Conflict Minerals. Accordingly, the Company was unable to

Page 1


determine the source of all of its Conflict Minerals and proceeded with further due diligence measures to determine the origins of its Conflict Minerals. There is substantial overlap between the Company’s RCOI efforts and its due diligence measures described below.

5.    Design of the Company’s Due Diligence and Description of Due Diligence Process
   
The Company’s Conflict Minerals compliance framework and due diligence were based on the Organisation for Economic Co-operation and Development 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 (together, the “Guidance”), with a particular focus on the recommendations issued for downstream companies. Downstream companies must exercise due diligence on the source and chain of custody of the Conflict Minerals contained in their products. Such due diligence measures must conform to a nationally or internationally recognized due diligence framework, such as the Guidance. Notwithstanding that the Company has no independent means of determining the source and origin of conflict minerals ores processed by SORs, the Company implemented a due diligence program to identify and seek to trace the Conflict Minerals in its supply chain in order to meet its obligations under Rule 13p-1 under the 1934 Act. The Company’s due diligence program was based on the Guidance.

5.1 Due Diligence Measures Consistent With Step 1 of The Guidance (Management Systems)

The Company maintained a management system to support the Company’s compliance obligations. The Company’s management system included the IPG Photonics Corporation Conflict Minerals Policy (the “Policy”), which is published on the Company’s publicly available website at http://www.ipgphotonics.com/conflict_minerals.htm. The management system also included the Company’s Conflict Minerals Compliance Procedure (the “Procedure”), which established a cross-departmental team consisting of representatives from the purchasing, finance, legal, information technology and product/manufacturing departments, to execute and monitor the effectiveness of the Policy and the Procedure. The Procedure provides a process to request information from the Company’s first-tier suppliers concerning the origins of their materials and the identity of the SORs in their own supply chains. The Company maintains its engagement with its suppliers through a provision in IPG Photonics’ Terms and Conditions of Purchase, which governs the terms of the Company’s relationships with many of its suppliers. This provision requires the Company’s first-tier suppliers to be in compliance with the Act and to provide disclosure to the Company concerning the sources of their Conflict Minerals. The Procedure also implements an IPG Photonics Vendor Sourcing Information Form for Conflict Minerals and Component Vendors, which requests that new suppliers of the Company provide information concerning whether its products contain Conflict Minerals and if so, the sourcing of its Conflict Minerals.

5.2    Due Diligence Measures Consistent With Step 2 of the Guidance (Identify and Assess Risk in the Supply Chain)

Because of the variety and complexity of its products and the changing nature of its extensive supply chain, the Company cannot identify the upstream suppliers in its direct suppliers’ supply chains. As a result, the Company has relied on the responses it has received from its direct suppliers concerning the origin of the Conflict Minerals contained in the parts and components supplied to the Company, including the information provided from upstream suppliers of the Company’s direct suppliers. The Company sought to identify the SORs in its supply chain by surveying its direct suppliers using the CFSI reporting template. The Company issued follow-up requests for information to direct suppliers who did not respond to the survey. The Company also reviewed information collected from vendors and conducted due diligence to determine whether the SORs identified by its suppliers were appropriately identified as SORs. The Company documented and reviewed the country of origin information for the SORs identified by its vendors in response to the survey.

5.3    Due Diligence Measures Consistent With Step 3 of the Guidance (Risk Management Plan)

As recognized by the CFSI, the Company, as a downstream company with no direct relationship to SORs, can only “mitigate risk through working with [its] direct suppliers individually or collectively to identify SORs.” Accordingly, the Company sought to increase its visibility into its supply chain by reviewing the SORs identified by its vendors to determine whether they were identified as CFSI compliant, or “conflict free”. The Company also reviewed the geographical locations of the SORs identified by its suppliers to determine if these SORs appeared to be in “red flag” locations, such as the DRC Region. Based on the SORs identified by its suppliers and the Company’s related due diligence, the Company identified only one SOR in the DRC Region, and this SOR appeared on the CFSI compliant list. Of the almost 250 SORs that the Company reasonably determined may have been the source of the Company’s

Page 2


Conflict Minerals, over 150 of those SORs appear on the CFSI compliant lists as being “conflict free”.

5.4    Due Diligence Measures Consistent With Step 4 of the Guidance (Audit Smelters or Refiners)
  
The Company supported the CFSI by becoming a member of CFSI, using the CFSI reporting template to survey its vendors, and reviewing the list of SORs identified by the Company’s vendors to determine whether the SORs were on the CFSI compliant list.

5.5    Due Diligence Measures Consistent With Step 5 of the Guidance (Report Findings)

The Company posted the Policy on its publicly available website at http://www.ipgphotonics.com/conflict_minerals.htm and has prepared this Conflict Minerals Report as its annual report on the Company’s Conflict Minerals Due Diligence.

6.    Future Due Diligence Measures

During the reporting period for the calendar year ending December 31, 2015 the Company plans to take the following actions to increase its visibility into the origins of its Conflict Minerals:

a.
Seek to increase the response rate from its direct suppliers.
b.
Evaluate the services of third-party vendors to assist the Company in the collection and assimilation of the sourcing information the Company receives from its direct suppliers.

7.
SORs and Countries of Origin of The Company’s Conflict Minerals

Based on the Company’s due diligence measures and its review of publicly available information concerning the entities identified to the Company as SORs by its vendors, the Company has identified the following SORs and/or countries of origin as those that processed or served as the origin of the Conflict Minerals contained in its products. Because many of its direct suppliers reported their information to the Company on a “company” level rather than “product” level, the Company cannot know with certainty whether any of its products contained any Conflict Minerals from any particular country or SOR identified to the Company. Also, because the Company did not receive responses from all of its suppliers of Conflict Minerals, the Company does not know the origins of all of the Conflict Minerals in its products. The Company therefore cannot conclude that its products do not contain Conflict Minerals originating from the DRC Region in addition to the one disclosure that has been reported to the Company.

Metal (*)
Smelter Name (*)
Smelter Country (*)
Gold
Advanced Chemical Company
UNITED STATES
Gold
Aida Chemical Industries Co. Ltd.
JAPAN
Gold
Allgemeine Gold- und Silberscheideanstalt A.G.
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
AngloGold Ashanti Córrego do Sítio Minerção
BRAZIL
Gold
Argor-Heraeus SA
SWITZERLAND
Gold
Asahi Pretec Corporation
JAPAN
Gold
Asaka Riken Co Ltd
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
Aurubis AG
GERMANY
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Bauer Walser AG
GERMANY
Gold
Boliden AB
SWEDEN
Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
Caridad
MEXICO
Gold
CCR Refinery – Glencore Canada Corporation
CANADA
Gold
Cendres + Métaux SA
SWITZERLAND
Gold
Chimet S.p.A.
ITALY

Page 3


Gold
China National Gold Group Corporation
CHINA
Gold
Chugai Mining
JAPAN
Gold
Colt Refining
UNITED STATES
Gold
Daejin Indus Co. Ltd
KOREA, REPUBLIC OF
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
Do Sung Corporation
KOREA, REPUBLIC OF
Gold
Doduco
GERMANY
Gold
Dowa
JAPAN
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Ekaterinburg
RUSSIAN FEDERATION
Gold
FSE Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
Gansu Seemine Material Hi-Tech Co Ltd
CHINA
Gold
Great Wall Gold & Silver Refinery
CHINA
Gold
Guangdong Jinding Gold Limited
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus GmbH
GERMANY
Gold
Heraeus Ltd. Hong Kong
HONG KONG
Gold
Hunan Chenzhou Mining Group Co., Ltd.
CHINA
Gold
Hwasung CJ Co. Ltd
KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Japan Mint
JAPAN
Gold
JCC
CHINA
Gold
Johnson Matthey Canada
CANADA
Gold
Johnson Matthey Inc
UNITED STATES
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
JSC Uralectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kazzinc Ltd
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES
Gold
Kojima Chemicals Co. Ltd
JAPAN
Gold
Korea Metal Co. Ltd
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
L' azurde Company For Jewelry
SAUDI ARABIA
Gold
Lingbao Gold Company Limited
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
CHINA
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
Luoyang Zijin Yinhui Metal Smelt Co Ltd
CHINA
Gold
Materion
UNITED STATES
Gold
Matsuda Sangyo Co. Ltd
JAPAN
Gold
Metalor Technologies (Hong Kong) Ltd
HONG KONG
Gold
Metalor Technologies (Singapore) Pte. Ltd.
SINGAPORE
Gold
Metalor Technologies SA
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES
Gold
Met-Mex Peñoles, S.A.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN

Page 4


Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Gold
Faggi Enrico SPA
ITALY
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
Geib Refining Corp
United States
Gold
Nihon Material Co. LTD
JAPAN
Gold
Ohio Precious Metals, LLC
UNITED STATES
Gold
Ohura Precious Metal Industry Co., Ltd
JAPAN
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
RUSSIAN FEDERATION
Gold
OJSC Kolyma Refinery
RUSSIAN FEDERATION
Gold
PAMP SA
SWITZERLAND
Gold
Penglai Penggang Gold Industry Co Ltd
CHINA
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Précinox SA
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd
SOUTH AFRICA
Gold
Republic Metals Corporation
UNITED STATES
Gold
Royal Canadian Mint
CANADA
Gold
Sabin Metal Corp.
UNITED STATES
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
SAMWON METALS Corp.
KOREA, REPUBLIC OF
Gold
Schone Edelmetaal
NETHERLANDS
Gold
SEMPSA Joyería Platería SA
SPAIN
Gold
ShanDong Gold Mining Co;Ltd
CHINA
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd
CHINA
Gold
So Accurate Group, Inc.
UNITED STATES
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
Tokuriki Honten Co., Ltd
JAPAN
Gold
Tongling nonferrous Metals Group Co.,Ltd
CHINA
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda
BRAZIL
Gold
Umicore Hoboken,Umicore Beligium,Umicore SA,Umicore Precious Metals Refining
BELGIUM
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Gold
Valcambi SA
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Gold
YAMAMOTO PRECIOUS METAL CO., LTD.
JAPAN
Gold
Yokohama Metal Co Ltd
JAPAN
Gold
Yunnan Copper Industry Co Ltd
CHINA
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

Page 5


Tantalum
Duoluoshan
CHINA
Tantalum
Exotech Inc.
UNITED STATES
Tantalum
F&X Electro-Materials Ltd.
CHINA
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
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
Kemet Blue Powder
UNITED STATES
Tantalum
Kemit Blue Metals
MEXICO
Tantalum
King-Tan Tantalum Industry Ltd
CHINA
Tantalum
LSM Brasil S.A.
BRAZIL
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 Chemical Co., Ltd.
JAPAN
Tantalum
Telex
UNITED STATES
Tantalum
Ulba
KAZAKHSTAN
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd
CHINA
Tantalum
Zhuzhou Cement Carbide
CHINA
Tin
Alpha
UNITED STATES
Tin
China Rare Metal Materials Company
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
CNMC (Guangxi) PGMA Co. Ltd.
CHINA
Tin
COOPERMETAL - Cooperativa Metalúrgica de Rondônia Ltda.
BRAZIL
Tin
CV DS Jaya Abadi
INDONESIA
Tin
CV Gita Pesona
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

Page 6


Tin
EM Vinto
BOLIVIA
Tin
Estanho de Rondônia S.A.
BRAZIL
Tin
Feinhütte Halsbrücke GmbH
GERMANY
Tin
Fenix Metals
POLAND
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co. Ltd.
CHINA
Tin
Gejiu Zi-Li
CHINA
Tin
Huichang Jinshunda Tin Co. Ltd
CHINA
Tin
Jiangxi Shunda Huichang Kam Tin 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
Metallic Resources Inc
UNITED STATES
Tin
Metallo Chimique
BELGIUM
Tin
Mineração Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Tin
NGHE TIN NON-FERROUS METAL
VIETNAM
Tin
Novosibirsk Integrated Tin Works
RUSSIAN FEDERATION
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgica S.A.
BOLIVIA
Tin
PT Alam Lestari Kencana
INDONESIA
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
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 Bellitin Makmur Lestari,BML
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 Inti Stania Prima
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

Page 7


Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Sumber Jaya Indah
INDONESIA
Tin
PT Supra Sukses Trinusa
INDONESIA
Tin
PT Tambang Timah
INDONESIA
Tin
PT Tambang Timah
INDONESIA
Tin
PT Timah (Persero), Tbk
INDONESIA
Tin
PT Timah Nusantara
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
PT Yinchendo Mining Industry
INDONESIA
Tin
PT. Stanlndo Inti Perkasa(Former CV DS Jaya Abadi)
INDONESIA
Tin
Rui Da Hung
TAIWAN
Tin
Soft Metais, Ltda.
BRAZIL
Tin
Thaisarco
THAILAND
Tin
VQB MINERAL AND TRADING GROUP JOINT STOCK COMPANY
VIET NAM
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Tin
YTCL,Yuntinic Resources Inc.,Smelting Branch of Yunnan Tin Company Limited,Yun Nan Tin Co. LTD
CHINA
Tin
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.
CHINA
Tin
Yunnan Tin Company, Ltd.
CHINA
Tungsten
A.L.M.T. Corp.
JAPAN
Tungsten
ATI Tungsten Materials
UNITED STATES
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
Chenzhou,Chenzhou Mining Group
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Chunbao Carbide Science & Technology Co.,Ltd
TAIWAN
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co. Ltd.,Ganzhou Huaxin Tungsten Products Ltd,JTGC,China National Nonferrous,China National Nonferrous Metals Imp. & Exp. Jiangxi Corporation Ltd.,CNIECJX,Jiangxi Tungsten 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
Global Tungsten & Powders Corp.
UNITED STATES
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
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 Chuangda Tungsten & Vanadium Co., Ltd.
CHINA
Tungsten
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.
CHINA
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
JSC Pobedit
RUSSIAN FEDERATION
Tungsten
Kennametal Fallon
UNITED STATES

Page 8


Tungsten
Kennametal Huntsville
UNITED STATES
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd
VIET NAM
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Tungsten
Wolfram Company CJSC
RUSSIAN FEDERATION
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA


8.    The Company has placed this report on its publicly available web site at http://investor.ipgphotonics.com/sec.cfm




Page 9
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