UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
STRYKER CORPORATION
(Exact name of registrant as specified in its charter)
| | | | | | | | | | | | | | |
| Michigan | | 001-13149 | | 38-1239739 |
| (State of incorporation) | | (Commission File Number) | | (I.R.S. Employer Identification No.) |
| | | | |
| 1941 Stryker Way Portage, Michigan | | 49002 |
| (Address of principal executive offices) | | (Zip Code) |
| | | | |
| Viju S. Menon, Group President, Global Quality and Operations; (269) 385-2600 |
| (Name and telephone number, including area code, of the person to contact in connection with this report) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| | | | | | | | |
| X | | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023 |
| |
Section 1 - Conflict Minerals Disclosure
| | | | | |
| ITEM 1.01 and 1.02 | Conflict Minerals Disclosure and Report, Exhibit |
A copy of Stryker Corporation’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at www.stryker.com. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Section 2 - Exhibits
The following exhibit is filed as part of this report:
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.
| | | | | | | | | | | |
| | | STRYKER CORPORATION |
| | | (Registrant) |
| | | |
| | | |
| Date: | May 24, 2024 | | /s/ VIJU S. MENON |
| | | Viju S. Menon |
| | | Group President, Global Quality and Operations |
Exhibit 1.01
CONFLICT MINERALS REPORT OF STRYKER CORPORATION
For the year ended December 31, 2023
Stryker has made statements in this conflict minerals report that may constitute forward-looking statements about our plans to take additional actions or to implement additional policies or procedures with respect to our due diligence efforts to determine the origin of so-called conflict minerals included in our products. Stryker undertakes no obligation to publicly update or revise any forward-looking statement, whether as a result of new information, future events or otherwise. Stryker’s reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report. In addition, there are factors that could affect the accuracy of statements made in this report, including, without limitation: incomplete or unavailable supplier, smelter or refiner data; errors, omissions, or fraud by suppliers, smelters or refiners; changing definitions or methodologies for confirming smelters or refiners; incomplete, unclear, or modified guidance from third-party industry and other sources; continuing guidance regarding the conflict minerals rules and other issues.
This is the Conflict Minerals Report of Stryker Corporation for calendar year 2023 (the “Reporting Period”) in accordance with Rule 13p-1 of the Securities Exchange Act of 1934 (“Rule 13p-1”). The term “3TG” as used in this report includes cassiterite, columbite-tantalite, wolframite, gold, and their derivatives tin, tantalum, and tungsten. Based on our Conflict Minerals Program and due diligence efforts described in more detail herein, we have not found any evidence to indicate the 3TG in our products directly or indirectly financed or benefited armed groups in the Covered Countries (defined below) for the year ended December 31, 2023.
1.Conflict Minerals Rule
Effective November 2012, the United States Securities and Exchange Commission (the “Commission”) adopted Rule 13p-1 pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) relating to the use of conflict minerals. Section 1502 added Section 13(p) of the Act, which obligated the Commission to promulgate rules requiring public companies with 3TG that are necessary to the functionality or production of products that they manufacture to disclose annually whether those minerals originated in the Democratic Republic of the Congo or an adjoining country (“Covered Countries”). If an issuer’s 3TG originated in a Covered Country, Rule 13p-1 requires the issuer to file a report with the Commission that describes the measures it has taken to exercise due diligence to determine the source and chain of custody of 3TG in its products.
2.Company Overview
Stryker Corporation is a global leader in medical technologies and, together with our customers, we are driven to make healthcare better. We offer innovative products and services in MedSurg, Neurotechnology, Orthopaedics and Spine that help improve patient and healthcare outcomes. Our core values of Integrity, Accountability, People and Performance guide our behaviors and actions and are fundamental to how we execute our mission. Stryker was incorporated in Michigan in 1946 as the successor company to a business founded in 1941 by Dr. Homer H. Stryker, a prominent orthopaedic surgeon and inventor of several medical products.
As used herein, and except where the context otherwise requires, “Stryker,” “we,” “us” and “our” refer to Stryker Corporation and our consolidated subsidiaries that are subject to the reporting requirements of Rule 13p-1.
3.Product Overview
Our products are sold in approximately 75 countries through company-owned subsidiaries and branches as well as third-party dealers and distributors. Our products include surgical equipment and surgical navigation systems; endoscopic and communications systems; patient handling, emergency medical equipment and intensive care disposable products; clinical communication and workflow solutions; neurosurgical and neurovascular devices; implants used in joint replacement and trauma surgeries; Mako Robotic-Arm Assisted technology; spinal devices; as well as other products used in a variety of medical specialties. Most of our products are marketed directly to doctors, hospitals and other healthcare facilities. 3TG is necessary to the functionality of many of these products.
4.Conflict Minerals Program Overview
We are committed to conducting our affairs ethically and lawfully and expect that the businesses we associate with will do the same. We are a member of the Responsible Minerals Initiative (“RMI”) and maintain a Conflict Minerals Program that follows
the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Framework”) because our products may contain components or materials that utilize 3TG. We rely heavily on input from our suppliers utilizing RMI’s Conflict Minerals Reporting Template (“CMRT”) to determine whether any 3TG in our products originated in the Covered Countries because we do not purchase 3TG directly from mines, smelters or refiners. Our Conflict Minerals program is outlined in further detail below.
4.1 Strong Company Management Systems
4.1.1 Conflict Minerals Policy
We maintain a Conflict Minerals Policy that reinforces our commitment to responsible sourcing in the Covered Countries and sets the expectation that our suppliers will procure 3TG from socially responsible sources. This policy is available publicly at www.stryker.com/conflictminerals.
4.1.2 Conflict Minerals Team
Our Conflict Minerals Team, consisting of a program manager and representatives from the procurement, legal and compliance teams, is responsible for executing our Conflict Minerals Program. A committee consisting of senior leaders reviews the Conflict Minerals Team’s progress to ensure compliance with our policies and the Act.
4.1.3 Multi-Stakeholder Group Participation
We are a member of the RMI, which facilitates engagement with industry peers, subject matter experts and other stakeholder groups, including non-governmental organizations, socially responsible investor groups, governments and multilateral institutions to align on expectations and best practices in conducting our supply chain activities. Membership also provides us access to the most up-to-date Reasonable Country of Origin information for facilities participating in the Responsible Minerals Assurance Process (“RMAP”), training resources and other tools.
4.1.4 Supplier Relationship Strategy
As a manufacturer and seller of medical devices, we are subject to strict quality and regulatory requirements throughout the world. Due to these requirements and the nature of our products, we predominantly maintain long-term relationships with our suppliers, which enables strong collaboration and a deeper understanding of our requirements. We leverage these relationships to maximize due diligence engagement and engage in risk mitigation activities.
4.1.5 Supplier Engagement
We engage suppliers in our due diligence activities through the use of the standardized CMRT developed by the RMI. The CMRT streamlines the transfer of information about the potential country of origin of the minerals used in our products and the smelters or refiners (“SORs”) utilized in our supply chain. We collect and analyze supplier CMRTs through the use of a third-party partner who is a global leader for supply chain compliance solutions. This partner enables the collection of supplier data and the subsequent analysis and validation of that information within their web-based platform.
4.1.6 Supply Contracts
Our supply agreements and standard purchase order terms and conditions contain provisions requiring supplier compliance with our Supplier Code of Conduct. The Supplier Code of Conduct requires implementation of appropriate supply chain due diligence processes to ensure that materials come from legitimate sources. Our Supplier Code of Conduct is publicly available at www.stryker.com/poterms.
4.1.7 Training
We conduct annual conflict minerals training for relevant procurement teams. The training provides an overview of conflict minerals and associated legislation, our Conflict Minerals Policy and Program and supplier engagement on conflict minerals.
4.1.8 Grievance Mechanism
We maintain conflictminerals@stryker.com as a dedicated email address for questions regarding our Conflict Minerals Policy. We also maintain an ethics hotline publicly available at www.ethicshotline.stryker.com as a mechanism for interested parties to voice concerns regarding compliance.
4.2 Identification and Assessment of Risks in Supply Chain
4.2.1As a finished medical device manufacturer, we are far removed from the mining of 3TG. We do not directly purchase raw ore or unrefined minerals from mines or SORs, including from those located in the Covered Countries.
4.2.2We rely on our suppliers to conduct appropriate due diligence within their supply chains and provide accurate information to determine the origin of 3TG contained in our products. We perform an annual review of suppliers subject to our conflict minerals assessment process (“In-Scope Suppliers”). The Conflict Minerals Team identifies In-Scope Suppliers by reviewing our approved supplier list and filtering this information using commodity assignment, spend and activity data. The resulting suppliers undergo an additional review conducted by our procurement team to finalize the list of In-Scope Suppliers who are most likely to be supplying components or products that contain 3TG.
4.2.3We utilize a third-party partner to collect information from the In-Scope Suppliers regarding the presence and sourcing of 3TGs used in the products and components supplied to us using the CMRT at a company, product, or user-defined level, depending on the supplier’s ability to provide the required data.
4.2.4We review the information provided by the In-Scope Suppliers against the most current identified SOR lists, including those published by the Commerce Department, RMI, the London Bullion Market Association and the Responsible Jewellery Council. We also assess the physical location of SORs that are known and/or participating in RMAP or a similar recognized framework such as the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain-of-Custody Certification (each a “Recognized Framework”).
4.2.5We review the information provided by In-Scope Suppliers and the third-party data to identify any SORs that we consider high-risk in relation to 3TG sourcing, including those that are either located in or sourcing from a Covered Country and are not participating in RMAP or a Recognized Framework.
4.3 Strategy to Respond to Risks
4.3.1 Assessment Process
4.3.1.1 Non-response Risk
We track assessment response rates and non-responsive In-Scope Suppliers during the assessment process using a dashboard and other reports. Our third-party partner sends reminders both via email and telephone throughout the assessment period. Continued non-response is escalated to our procurement team. Non-responses at the end of the assessment period are noted and factored into our supplier management strategy and future year assessment activities for the non-responsive In-Scope Supplier.
4.3.1.2 Data Inconsistency Risk
Our third-party partner automatically performs an initial evaluation of any inconsistencies or gaps in the information submitted by In-Scope Suppliers and performs follow-up to resolve any issues.
4.3.2 Risk Mitigation Activities
The results of risk identification activities are communicated to our Procurement Leadership Team. We determine, on a case-by-case basis, the appropriate mitigation strategy for any high risk SORs. Due to the nature of our products, we are unable to make supply chain related changes without significant quality and safety related due diligence and, in some instances, a lengthy regulatory approval process. As such, we
primarily emphasize supplier education and cooperative efforts to bring existing supply chains into conformance with our Conflict Minerals Policy. These efforts may include further investigation to understand a high-risk SOR’s actual role in our product supply chain and leveraging upstream supplier relationships to promote SOR participation in the RMAP or a Recognized Framework. We may, however, pursue the removal from our supply chain of any confirmed high-risk SOR that is unwilling to participate in the RMAP or a Recognized Framework. With the understanding that risk mitigation activities are an ongoing effort, we monitor the status of these high-risk SORs and In-Scope Supplier activities over subsequent assessment periods to understand the effectiveness of this strategy and enact further corrective action if necessary.
4.4 Carrying out Independent Third-Party Audits
4.4.1 Independent Third-Party Audits
As a downstream company, we are far removed from the SORs providing 3TG and therefore do not perform or direct our own audits of SORs. Instead, we rely on the RMI’s RMAP and other Recognized Frameworks to enable our SOR due diligence activities.
4.5 Public Report
4.5.1 Annual SEC Reporting
We comply with annual reporting requirements as set forth in Rule 13p-1 by filing with the SEC a Form SD and including this report.
4.5.2 Public Availability
This Conflict Minerals Report is also publicly available in the “Investor Relations” section of our website at investors.stryker.com and referenced in our annual “Comprehensive Report” available at www.stryker.com/crhub.
5.2023 Reasonable Country of Origin Inquiry Results
5.1 In-Scope Suppliers
We determined, that during the Reporting Period, we manufactured and/or contracted to manufacture products containing 3TG that were necessary for the functionality or production of our products. A total of 693 suppliers were identified as In-Scope Suppliers potentially providing us with materials or products containing 3TG.
5.2 Process Overview
We conducted a Reasonable Country of Origin Inquiry (“RCOI”) of the In-Scope Suppliers to determine whether 3TG contained in our products originated from the Covered Countries. We completed the RCOI by requiring that In-Scope Suppliers complete CMRT version 6.22 or higher.
We communicated to the In-Scope Suppliers the importance of participating in our 2023 RCOI and provided initial information on the required activities. Using our third-party partner, we provided In-Scope Suppliers with a CMRT submission portal and submission instructions and an email submission option for those In-Scope Suppliers unwilling or unable to use the portal. Suppliers were engaged between January 22, 2024 and April 26, 2024 to provide the required information for our RCOI. During this period, up to eight reminder emails were sent to each non-responsive supplier and, if a supplier remained non-responsive, additional reminders occurred via telephone or directly from our procurement team. Throughout the process, responses were reviewed for plausibility, consistency and gaps, and we engaged in follow-up activities as necessary.
5.3 Supplier Responses
The response rate of the In-Scope Suppliers during the RCOI was 90%. Of the responding suppliers, 42% identified the presence of 3TG in the materials or products supplied to us. These suppliers identified a total of 345 SORs that could be verified as active using the resources described in section 4.2.4. Of these verified SORs, there was an indication that 54 are either located in or sourced from the Covered Countries. 47 out of 54 SORs are conformant to a Recognized Framework.
5.4 Determination
Based on the results of the RCOI, we have reason to believe that some 3TG in our products may have originated in the Covered Countries and may not have come from recycled or scrap sources. Therefore, we conducted additional due diligence to determine the Country of Origin of the 3TG in our products and whether our supply chain activities directly or indirectly financed or benefited armed groups in the Covered Countries in accordance with Rule 13p-1. The results of our diligence are outlined below.
6.Due Diligence
6.1 Results
Using the results of the RCOI, and in accordance with the steps described in section 4 above, we performed additional due diligence on those SORs located in or sourcing from the Covered Countries, focusing on the SOR RMAP participation during the Reporting Period. The results of that due diligence can be found in Table 1.
Table 1
| | | | | | | | | | | | | | |
| Metal | SOR RMAP Status | Total |
| Conformant | Active | Not Enrolled |
| Tantalum | 20 | 0 | 0 | 20 |
| Tin | 12 | 1 | 1 | 14 |
| Tungsten | 8 | 0 | 1 | 9 |
| Gold | 7 | 1 | 3 | 11 |
6.2 Risk Mitigation Activities
We focused our resulting risk mitigation activities on the SORs that either source from or are located in a Covered Country whose RMAP status was found to be “Not Enrolled” and who have not indicated intent to become “Active” or “Conformant”. “Conformant” meaning independently assessed and found conformant with the relative RMAP standard, “Active” meaning engaged in the RMAP program but not yet conformant, and “Not Enrolled” referring to all other statuses. As a downstream company, and in alignment with the risk mitigation activities described in 4.3.2. above, we issued notifications to the In-Scope Suppliers who included these SORs in their CMRT submissions. These notifications focused on engaging the SOR, either directly or through any necessary upstream suppliers, to promote participation in the RMAP and to consider removal of the SOR from their supply chain if they are unwilling or unable to participate in the RMAP. We will continue to engage with the RMI and their other member companies to promote SOR participation in the RMAP. We also continue to monitor In-Scope Supplier responses to these notifications and determine if any additional actions are needed.
6.3 Conclusion
Based on due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the 3TG contained in our products. As in previous years, while we cannot conclusively determine the countries of origin, we have not found any evidence to indicate the 3TG in our products directly or indirectly financed or benefited armed groups in the Covered Countries for the year ended December 31, 2023. The list of SORs which is based on the information provided by In-Scope Suppliers can be found in Appendix A and the Countries of Origin identified as believed to be associated with these materials are listed in Appendix B.
Appendix A: Smelter or Refiner List
This list is based on data provided by our suppliers for reporting year 2023. In-Scope Suppliers predominantly provided company-level information which included the supplier’s entire supply chain and, as such, this information was not limited to SORs that contributed 3TG used specifically in our products. As a result, we are unable to confirm whether our products contain 3TG from all of these sources. Additionally, this list only includes facilities reported by suppliers that are on the RMAP list as of April 26, 2024.
| | | | | | | | | | | |
| Metal | Name | Location | RMAP Status |
| Gold | 8853 S.p.A. | Italy | Not Enrolled |
| Gold | ABC Refinery Pty Ltd. | Australia | Not Enrolled |
| Gold | Abington Reldan Metals, LLC | United States | Conformant |
| Gold | Advanced Chemical Company | United States | Active |
| Gold | African Gold Refinery | Uganda | Not Enrolled |
| Gold | Agosi AG | Germany | Conformant |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | Conformant |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | Not Enrolled |
| Gold | Albino Mountinho Lda. | Portugal | Not Enrolled |
| Gold | Alexy Metals | United States | Not Enrolled |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Conformant |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | Conformant |
| Gold | Argor-Heraeus S.A. | Switzerland | Conformant |
| Gold | Asahi Pretec Corp. | Japan | Conformant |
| Gold | Asahi Refining Canada Ltd. | Canada | Conformant |
| Gold | Asahi Refining USA Inc. | United States | Conformant |
| Gold | Asaka Riken Co., Ltd. | Japan | Conformant |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | Not Enrolled |
| Gold | Attero Recycling Pvt Ltd | India | Not Enrolled |
| Gold | AU Traders and Refiners | South Africa | Not Enrolled |
| Gold | Augmont Enterprises Private Limited | India | Active |
| Gold | Aurubis AG | Germany | Conformant |
| Gold | Bangalore Refinery | India | Active |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Conformant |
| Gold | Boliden AB | Sweden | Conformant |
| Gold | C. Hafner GmbH + Co. KG | Germany | Conformant |
| Gold | Caridad | Mexico | Not Enrolled |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | Conformant |
| Gold | Cendres + Metaux S.A. | Switzerland | Not Enrolled |
| Gold | CGR Metalloys Pvt Ltd. | India | Not Enrolled |
| Gold | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | Not Enrolled |
| Gold | Chimet S.p.A. | Italy | Conformant |
| Gold | Chugai Mining | Japan | Conformant |
| Gold | Coimpa Industrial LTDA | Brazil | Conformant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | Not Enrolled |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | Not Enrolled |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | Not Enrolled |
| Gold | Dongwu Gold Group | China | Not Enrolled |
| Gold | Dowa | Japan | Conformant |
| Gold | DSC (Do Sung Corporation) | Korea, Republic of | Conformant |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | Conformant |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | Conformant |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | Conformant |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India | Not Enrolled |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India | Not Enrolled |
| | | | | | | | | | | |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India | Not Enrolled |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India | Not Enrolled |
| Gold | Emirates Gold DMCC | United Arab Emirates | Not Enrolled |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | Not Enrolled |
| Gold | Fujairah Gold FZC | United Arab Emirates | Not Enrolled |
| Gold | Geib Refining Corporation | United States | Not Enrolled |
| Gold | GG Refinery Ltd. | Tanzania | Active |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India | Active |
| Gold | Gold by Gold Colombia | Colombia | Conformant |
| Gold | Gold Coast Refinery | Ghana | Not Enrolled |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | Conformant |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | Not Enrolled |
| Gold | Guangdong Jinding Gold Limited | China | Not Enrolled |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | Not Enrolled |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Not Enrolled |
| Gold | Heimerle + Meule GmbH | Germany | Conformant |
| Gold | Heraeus Germany GmbH Co. KG | Germany | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | China | Conformant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | Not Enrolled |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | Not Enrolled |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic of | Not Enrolled |
| Gold | Industrial Refining Company | Belgium | Not Enrolled |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | Conformant |
| Gold | International Precious Metal Refiners | United Arab Emirates | Not Enrolled |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Conformant |
| Gold | Istanbul Gold Refinery | Turkey | Conformant |
| Gold | Italpreziosi | Italy | Conformant |
| Gold | JALAN & Company | India | Not Enrolled |
| Gold | Japan Mint | Japan | Conformant |
| Gold | Jiangxi Copper Co., Ltd. | China | Conformant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | Not Enrolled |
| Gold | JSC Novosibirsk Refinery | Russian Federation | Not Enrolled |
| Gold | JSC Uralelectromed | Russian Federation | Not Enrolled |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | Conformant |
| Gold | K.A. Rasmussen | Norway | Not Enrolled |
| Gold | Kaloti Precious Metals | United Arab Emirates | Not Enrolled |
| Gold | Kazakhmys Smelting LLC | Kazakhstan | Not Enrolled |
| Gold | Kazzinc | Kazakhstan | Conformant |
| Gold | Kennecott Utah Copper LLC | United States | Conformant |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | Conformant |
| Gold | Kojima Chemicals Co., Ltd. | Japan | Conformant |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic of | Conformant |
| Gold | Kundan Care Products Ltd. | India | Not Enrolled |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | Not Enrolled |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | Not Enrolled |
| Gold | L’azurde Company For Jewelry | Saudi Arabia | Not Enrolled |
| Gold | Lingbao Gold Co., Ltd. | China | Not Enrolled |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | Not Enrolled |
| Gold | L’Orfebre S.A. | Andorra | Conformant |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of | Conformant |
| Gold | LT Metal Ltd. | Korea, Republic of | Conformant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | Not Enrolled |
| Gold | Marsam Metals | Brazil | Not Enrolled |
| Gold | Materion | United States | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | Conformant |
| | | | | | | | | | | |
| Gold | MD Overseas | India | Not Enrolled |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | Conformant |
| Gold | Metallix Refining Inc. | United States | Not Enrolled |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | Conformant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | Conformant |
| Gold | Metalor Technologies (Suzhou) Ltd. | China | Conformant |
| Gold | Metalor Technologies S.A. | Switzerland | Conformant |
| Gold | Metalor USA Refining Corporation | United States | Conformant |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | Conformant |
| Gold | Mitsubishi Materials Corporation | Japan | Conformant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
| Gold | MKS PAMP SA | Switzerland | Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | Conformant |
| Gold | Modeltech Sdn Bhd | Malaysia | Not Enrolled |
| Gold | Morris and Watson | New Zealand | Not Enrolled |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | Not Enrolled |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | Conformant |
| Gold | NH Recytech Company | Korea, Republic of | Conformant |
| Gold | Nihon Material Co., Ltd. | Japan | Conformant |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | Conformant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | Conformant |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | Russian Federation | Not Enrolled |
| Gold | Pease & Curren | United States | Not Enrolled |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | Not Enrolled |
| Gold | Planta Recuperadora de Metales SpA | Chile | Conformant |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | Not Enrolled |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Conformant |
| Gold | PX Precinox S.A. | Switzerland | Conformant |
| Gold | QG Refining, LLC | United States | Not Enrolled |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | Conformant |
| Gold | Refinery of Seemine Gold Co., Ltd. | China | Not Enrolled |
| Gold | REMONDIS PMR B.V. | Netherlands | Conformant |
| Gold | Royal Canadian Mint | Canada | Conformant |
| Gold | SAAMP | France | Not Enrolled |
| Gold | Sabin Metal Corp. | United States | Not Enrolled |
| Gold | Safimet S.p.A | Italy | Not Enrolled |
| Gold | SAFINA A.S. | Czech Republic | Conformant |
| Gold | Sai Refinery | India | Not Enrolled |
| Gold | Sam Precious Metals | United Arab Emirates | Not Enrolled |
| Gold | SAMWON METALS Corp. | Korea, Republic of | Not Enrolled |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | Conformant |
| Gold | Shandong Gold Smelting Co., Ltd. | China | Conformant |
| Gold | Shandong Humon Smelting Co., Ltd. | China | Not Enrolled |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | Not Enrolled |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | Conformant |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China | Not Enrolled |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | Not Enrolled |
| Gold | Shirpur Gold Refinery Ltd. | India | Not Enrolled |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | Conformant |
| Gold | Singway Technology Co., Ltd. | Taiwan | Not Enrolled |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | Not Enrolled |
| Gold | Solar Applied Materials Technology Corp. | Taiwan | Conformant |
| Gold | Sovereign Metals | India | Not Enrolled |
| | | | | | | | | | | |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | Not Enrolled |
| Gold | Sudan Gold Refinery | Sudan | Not Enrolled |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | Conformant |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of | Conformant |
| Gold | Super Dragon Technology Co., Ltd. | Taiwan | Not Enrolled |
| Gold | T.C.A S.p.A | Italy | Conformant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | Conformant |
| Gold | Tokuriki Honten Co., Ltd. | Japan | Conformant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | Not Enrolled |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | Conformant |
| Gold | Torecom | Korea, Republic of | Conformant |
| Gold | Umicore Precious Metals Thailand | Thailand | Not Enrolled |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | Conformant |
| Gold | United Precious Metal Refining, Inc. | United States | Conformant |
| Gold | Valcambi S.A. | Switzerland | Conformant |
| Gold | WEEEREFINING | France | Conformant |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | Conformant |
| Gold | White Solder Metalurgia e Mineracao Ltda. | Brazil | Not Enrolled |
| Gold | WIELAND Edelmetalle GmbH | Germany | Conformant |
| Gold | Yamakin Co., Ltd. | Japan | Conformant |
| Gold | Yokohama Metal Co., Ltd. | Japan | Conformant |
| Gold | Yunnan Copper Industry Co., Ltd. | China | Not Enrolled |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Conformant |
| Tantalum | 5D Production OU | Estonia | Not Enrolled |
| Tantalum | AMG Brasil | Brazil | Conformant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | Conformant |
| Tantalum | D Block Metals, LLC | United States | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | China | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | China | Conformant |
| Tantalum | Global Advanced Metals Aizu | Japan | Conformant |
| Tantalum | Global Advanced Metals Boyertown | United States | Conformant |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | Conformant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | China | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | Conformant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | KEMET de Mexico | Mexico | Conformant |
| Tantalum | Materion Newton Inc. | United States | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | Conformant |
| Tantalum | Mineracao Taboca S.A. | Brazil | Conformant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
| Tantalum | Molycorp Silmet A.S. | Estonia | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conformant |
| Tantalum | PowerX Ltd. | Rwanda | Conformant |
| Tantalum | QuantumClean | United States | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | Conformant |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | Conformant |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | Not Enrolled |
| Tantalum | Taki Chemical Co., Ltd. | Japan | Conformant |
| Tantalum | TANIOBIS Co., Ltd. | Thailand | Conformant |
| Tantalum | TANIOBIS GmbH | Germany | Conformant |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | Conformant |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | Conformant |
| | | | | | | | | | | |
| Tantalum | Telex Metals | United States | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Conformant |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | Conformant |
| Tantalum | XinXing Haorong Electronic Material Co., Ltd. | China | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tin | Alpha | United States | Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | Not Enrolled |
| Tin | Asahi Refining Canada Ltd. | Canada | Not Enrolled |
| Tin | Aurubis Beerse | Belgium | Conformant |
| Tin | Aurubis Berango | Spain | Conformant |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | Conformant |
| Tin | China Tin Group Co., Ltd. | China | Conformant |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | Conformant |
| Tin | CRM Synergies | Spain | Conformant |
| Tin | CV Ayi Jaya | Indonesia | Conformant |
| Tin | CV Venus Inti Perkasa | Indonesia | Conformant |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | Not Enrolled |
| Tin | Dowa | Japan | Conformant |
| Tin | DS Myanmar | Myanmar | Conformant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | Not Enrolled |
| Tin | EM Vinto | Bolivia | Conformant |
| Tin | Estanho de Rondonia S.A. | Brazil | Conformant |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | Conformant |
| Tin | Fenix Metals | Poland | Conformant |
| Tin | Geib Refining Corporation | United States | Not Enrolled |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | Not Enrolled |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | Not Enrolled |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Conformant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Not Enrolled |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | Not Enrolled |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | China | Conformant |
| Tin | Luna Smelter, Ltd. | Rwanda | Conformant |
| Tin | Ma’anshan Weitai Tin Co., Ltd. | China | Not Enrolled |
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | Brazil | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Conformant |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia | Active |
| Tin | Melt Metais e Ligas S.A. | Brazil | Not Enrolled |
| Tin | Metallic Resources, Inc. | United States | Conformant |
| Tin | Mineracao Taboca S.A. | Brazil | Conformant |
| Tin | Mining Minerals Resources SARL | DRC- Congo (Kinshasa) | Conformant |
| Tin | Minsur | Peru | Conformant |
| Tin | Mitsubishi Materials Corporation | Japan | Conformant |
| Tin | Modeltech Sdn Bhd | Malaysia | Not Enrolled |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | Not Enrolled |
| Tin | Novosibirsk Tin Combine | Russian Federation | Not Enrolled |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | Conformant |
| Tin | Operaciones Metalurgicas S.A. | Bolivia | Conformant |
| Tin | Pongpipat Company Limited | Myanmar | Not Enrolled |
| Tin | Precious Minerals and Smelting Limited | India | Active |
| | | | | | | | | | | |
| Tin | PT Aries Kencana Sejahtera | Indonesia | Conformant |
| Tin | PT Artha Cipta Langgeng | Indonesia | Conformant |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | Conformant |
| Tin | PT Babel Inti Perkasa | Indonesia | Conformant |
| Tin | PT Babel Surya Alam Lestari | Indonesia | Conformant |
| Tin | PT Bangka Prima Tin | Indonesia | Conformant |
| Tin | PT Bangka Serumpun | Indonesia | Conformant |
| Tin | PT Bangka Tin Industry | Indonesia | Active |
| Tin | PT Belitung Industri Sejahtera | Indonesia | Conformant |
| Tin | PT Bukit Timah | Indonesia | Conformant |
| Tin | PT Cipta Persada Mulia | Indonesia | Conformant |
| Tin | PT Menara Cipta Mulia | Indonesia | Conformant |
| Tin | PT Mitra Stania Prima | Indonesia | Conformant |
| Tin | PT Mitra Sukses Globalindo | Indonesia | Conformant |
| Tin | PT Panca Mega Persada | Indonesia | Not Enrolled |
| Tin | PT Premium Tin Indonesia | Indonesia | Conformant |
| Tin | PT Prima Timah Utama | Indonesia | Conformant |
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | Conformant |
| Tin | PT Rajawali Rimba Perkasa | Indonesia | Conformant |
| Tin | PT Rajehan Ariq | Indonesia | Conformant |
| Tin | PT Refined Bangka Tin | Indonesia | Conformant |
| Tin | PT Sariwiguna Binasentosa | Indonesia | Conformant |
| Tin | PT Stanindo Inti Perkasa | Indonesia | Conformant |
| Tin | PT Sukses Inti Makmur | Indonesia | Conformant |
| Tin | PT Timah Tbk Kundur | Indonesia | Conformant |
| Tin | PT Timah Tbk Mentok | Indonesia | Conformant |
| Tin | PT Tinindo Inter Nusa | Indonesia | Conformant |
| Tin | PT Tirus Putra Mandiri | Indonesia | Not Enrolled |
| Tin | PT Tommy Utama | Indonesia | Conformant |
| Tin | Resind Industria e Comercio Ltda. | Brazil | Conformant |
| Tin | Rui Da Hung | Taiwan | Conformant |
| Tin | Super Ligas | Brazil | Conformant |
| Tin | Thaisarco | Thailand | Conformant |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | Conformant |
| Tin | Tin Technology & Refining | United States | Conformant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | Not Enrolled |
| Tin | Valcambi S.A. | Switzerland | Not Enrolled |
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | Not Enrolled |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Conformant |
| Tin | Yunnan Tin Company Limited | China | Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | Not Enrolled |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | Conformant |
| Tungsten | ACL Metais Eireli | Brazil | Not Enrolled |
| Tungsten | Alba steel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | Not Enrolled |
| Tungsten | Artek LLC | Russian Federation | Not Enrolled |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | Conformant |
| Tungsten | China Molybdenum Co., Ltd. | China | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | Not Enrolled |
| Tungsten | Cronimet Brasil Ltda | Brazil | Conformant |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic of | Not Enrolled |
| Tungsten | Fujian Xinlu Tungsten | China | Conformant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Conformant |
| | | | | | | | | | | |
| Tungsten | Global Tungsten & Powders Corp. | United States | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | Conformant |
| Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic of | Not Enrolled |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | Conformant |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | Not Enrolled |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | Conformant |
| Tungsten | Hydrometallurg, JSC | Russian Federation | Not Enrolled |
| Tungsten | Japan New Metals Co., Ltd. | Japan | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | Conformant |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | China | Not Enrolled |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Conformant |
| Tungsten | JSC “Kirovgrad Hard Alloys Plant” | Russian Federation | Not Enrolled |
| Tungsten | Kenee Mining Corporation Vietnam | Viet Nam | Active |
| Tungsten | Kennametal Fallon | United States | Conformant |
| Tungsten | Kennametal Huntsville | United States | Conformant |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan | Conformant |
| Tungsten | Lianyou Resources Co., Ltd. | Taiwan | Conformant |
| Tungsten | LLC Vostok | Russian Federation | Not Enrolled |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Masan High-Tech Materials | Viet Nam | Conformant |
| Tungsten | Moliren Ltd. | Russian Federation | Not Enrolled |
| Tungsten | Nam Viet Cromit Joint Stock Company | Viet Nam | Not Enrolled |
| Tungsten | Niagara Refining LLC | United States | Conformant |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | Not Enrolled |
| Tungsten | OOO “Technolom” 1 | Russian Federation | Not Enrolled |
| Tungsten | OOO “Technolom” 2 | Russian Federation | Not Enrolled |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | Conformant |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | China | Conformant |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | Conformant |
| Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam | Conformant |
| Tungsten | Unecha Refractory Metals Plant | Russian Federation | Not Enrolled |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | Conformant |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China | Not Enrolled |
Appendix B: Countries of Origin of 3TG
The origin of the 3TG processed by facilities listed in Appendix A are believed to be:
| | | | | | | | |
| Angola* | Guyana | Papua New Guinea |
| Argentina | Hong Kong | Peru |
| Armenia | Hungary | Philippines |
| Australia | India | Poland |
| Austria | Indonesia | Portugal |
| Belarus | Ireland | Russian Federation |
| Belgium | Israel | Rwanda* |
| Bermuda | Italy | Saudi Arabia |
| Bolivia | Ivory Coast | Sierra Leone |
| Brazil | Japan | Singapore |
| Burundi* | Jersey | Slovakia |
| Cambodia | Kazakhstan | South Africa |
| Canada | Kenya | South Sudan* |
| Central African Republic* | Korea, Republic of | Spain |
| Chile | Kyrgyzstan | Suriname |
| China | Laos | Sweden |
| Colombia | Luxembourg | Switzerland |
| Congo (Brazzaville)* | Madagascar | Taiwan |
| Czech Republic | Malaysia | Tajikistan |
| Djibouti | Mali | Tanzania* |
| DRC- Congo (Kinshasa)* | Mexico | Thailand |
| Ecuador | Mongolia | Turkey |
| Egypt | Morocco | Uganda* |
| Estonia | Mozambique | United Arab Emirates |
| Ethiopia | Myanmar | United Kingdom |
| Finland | Namibia | United States |
| France | Netherlands | Uzbekistan |
| Germany | New Zealand | Viet Nam |
| Ghana | Niger | Zambia* |
| Guinea | Nigeria | Zimbabwe |
*Covered Country
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