UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
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Form SD
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Specialized Disclosure Report
Allot Communications Ltd.
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Israel
(State or other jurisdiction of incorporation)
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001-33129
(Commission File Number)
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N/A
(I.R.S. Employer Identification No.)
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22 Hanagar Street
Neve Ne’eman Industrial Zone B
Hod-Hasharon 4501317
Israel
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Rael Kolevsohn
General Counsel
Tel +972-9-7619200
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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:
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☒
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Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.
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SECTION 1 – CONFLICT MINERALS DISCLOSURE
Item 1.01 Conflict Minerals Disclosure and Report
Introduction
This Specialized Disclosure Form (“Form SD”) of Allot Communications Ltd. (the “Company,” “we,” or “us”) is filed pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period from January 1, 2015 to December 31, 2015.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”), that originated in the Democratic Republic of the Congo (“DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).
Conclusion Based on Reasonable Country of Origin Inquiry
In accordance with the Rule, the Company has concluded in good faith that during the year ended December 31, 2015:
| - | Certain of the Company’s operations manufactured, or contracted to manufacture, products (the “Covered Products”) for which the Conflict Minerals are necessary to the functionality or production of those products. |
| - | Based on the Company’s good faith reasonable country of origin inquiry regarding the Conflict Minerals, which was designed to determine whether any of the Conflict Minerals contained in the Company’s Covered Products originated in the Covered Countries and whether any of the Conflict Minerals contained in the Covered Products are or may be from recycled or scrap sources, the Company had reason to believe that (i) the Conflict Minerals contained in its Covered Products may have originated in the Covered Countries and (ii) such Conflict Minerals may not be from recycled or scrap sources. |
On the basis of these conclusions, the Company proceeded to exercise due diligence with respect to the source and chain of custody of the Conflict Minerals contained in its Covered Products. The Conflict Minerals Report describing the Company’s due diligence efforts is attached as Exhibit 1.01 to this Form SD for the reporting period from January 1, 2015 to December 31, 2015. This Conflict Minerals Report has not been subject to an independent private sector audit.
Countries of origin identified as a result of the Company’s reasonable country of origin inquiry include, to the extent known, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Czech Republic, Estonia, France, Germany, Hong Kong, India, Indonesia, Italy, Japan, Kazakhstan, Republic Of Korea, Kyrgyzstan, Malaysia, Mexico, Netherlands, New Zealand, Peru, Philippines, Poland, Russian Federation, Rwanda, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, United Arab Emirates, United Kingdom, United States, Uzbekistan, Vietnam and Zimbabwe.
Conflict Minerals Disclosure
A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD, and is publicly available on the Company’s website at http://investors.allot.com/sec.cfm. Unless otherwise stated in this Form SD and the Conflict Minerals Report filed as Exhibit 1.01 hereto, any documents, third-party materials or references to websites (including the Company’s) are not incorporated by reference in, or considered to be a part of, this Form SD and the attached Conflict Minerals Report.
2
Forward-Looking Statements
In addition to historical facts, this Form SD and the attached Conflict Minerals Report contain forward-looking statements within the meaning of Section 27A of the U.S. Securities Act of 1933, as amended, Section 21E of the U.S. Securities Exchange Act of 1934, as amended, and the safe harbor provisions of the U.S. Private Securities Litigation Reform Act of 1995. We have based these forward-looking statements on our current expectations and projections about future events. Forward-looking statements include information concerning our possible or assumed future results of operations, business strategies, financing plans, competitive position, industry environment, potential growth opportunities, potential market opportunities and the effects of competition. Forward-looking statements include all statements that are not historical facts and can be identified by terms such as “anticipates,” “believes,” “could,” “seeks,” “estimates,” “expects,” “intends,” “may,” “plans,” “potential,” “predicts,” “projects,” “should,” “will,” “would” or similar expressions that convey uncertainty of future events or outcomes and the negatives of those terms. All forward-looking statements in this Form SD and the attached Conflict Minerals Report reflect our current views about future events, are based on assumptions and are subject to risks and uncertainties that could cause our actual results to differ materially from future results expressed or implied by the forward-looking statements. Many of these factors are beyond our ability to control or predict. Important factors that could cause actual outcomes to differ materially from those contained in any forward-looking statement include those described in the Company’s reports, including its annual report on Form 20-F for the fiscal year ended December 31, 2015, and other forms filed by the Company with or furnished by the Company to the Securities and Exchange Commission. You should not put undue reliance on any forward-looking statements. Unless we are required to do so under U.S. federal securities laws or other applicable laws, we do not intend to update or revise any forward-looking statements.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.
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SECTION 2 – EXHIBITS
The following exhibit is filed as part of this report.
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Exhibit No.
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Description
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1.01
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Conflict Minerals Report of Allot Communications Ltd.
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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.
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Allot Communications Ltd.
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By:
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/s/ Rael Kolevsohn
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June 2, 2016
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Rael Kolevsohn, General Counsel
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EXHIBIT INDEX
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Exhibit No.
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Description
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1.01
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Conflict Minerals Report of Allot Communications Ltd.
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6
Exhibit 1.01
Allot Communications Ltd.
Conflict Minerals Report
For the reporting period from January 1, 2015 to December 31, 2015
INTRODUCTION
This Conflict Minerals Report (the “Report”) of Allot Communications Ltd. ( “Allot,” “Company,” “we” or “us”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period between January 1, 2015 and December 31, 2015 (the “2015 calendar year”). The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”), that originated in the Democratic Republic of the Congo (“DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).
REASONABLE COUNTRY OF ORIGIN INQUIRY
Pursuant to the Rule, the Company conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the Conflict Minerals. This good faith RCOI was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries or whether any of the Conflict Minerals may be from recycled or scrap sources. Following this inquiry, the Company had reason to believe that during the year ended December 31, 2015:
| - | Allot has manufactured or contracted to manufacture products as to which Conflict Minerals are necessary to the functionality or production of those products; and |
| - | Based on its good faith reasonable country of origin inquiry, Allot has reason to believe that certain of the Conflict Minerals necessary to the functionality or production of such products may have originated from the Covered Countries and has reason to believe that those minerals may not be solely from recycled or scrap sources |
Therefore, the Company had performed due diligence on the source and chain of custody of the Conflict Minerals. There is significant overlap between the Company’s RCOI efforts and its due diligence measures performed. The due diligence measures performed by the Company are discussed below.
Allot is filing this Report with its Form SD as required under the Rule. This Report has not been subject to an independent private sector audit.
PART I. DESCRIPTION OF THE COMPANY’S PRODUCTS COVERED BY THIS REPORT
Allot is a leading global provider of intelligent broadband solutions, focused on developing mobile, fixed and enterprise networks to support the “digital lifestyle.” Allot’s solutions, which are based on deep packet inspection technology, identify and leverage the business intelligence in data networks, empowering network operators to shape users’ digital lifestyle experiences and to capitalize on the network traffic they generate. As described in this Report, during the reporting period between January 1, 2015 and December 31, 2015, certain of the Company’s operations manufactured, or contracted to manufacture, products for which the Conflict Minerals are necessary to the functionality or production of those products (collectively, the “Covered Products”).
During the 2015 calendar year, the Covered Products included the following:
| - | Allot Service Gateway, Sigma E, Allot Service Gateway Tera and VDC Product Families |
| o | Highly scalable mobile platforms that enable Internet providers to manage high-speed broadband performance and to control infrastructure and operating costs; and |
| - | NetEnforcer Device Family |
| o | Purpose-built devices for monitoring and managing data traffic on enterprise, cloud and broadband service provider networks that provide essential visibility, policy enforcement and traffic steering for a wide range of networks |
PART II. THE COMPANY’S DUE DILIGENCE PROCESS
The Company’s due diligence measures have been designed to conform to the five-step framework laid out by the Organization for Economic Co-operation and Development in its OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition (2013) including the related supplements on gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”).
OECD Guidance Step 1: Establish strong company management systems for conflict minerals supply chain due diligence and reporting compliance.
Adopt and commit to a supply chain policy for minerals originating from conflict-affected and high-risk areas.
The Company has adopted a policy relating to the Conflict Minerals (the “Policy”), which incorporates the standards set forth in the OECD Guidance. Specifically, the Policy states that the Company supports the actions of governments and organizations to increase supply chain transparency and enable companies to source conflict-free minerals. Further, the Company has initiated a comprehensive process to meet its regulatory obligations related to the sourcing of Conflict Minerals, taking steps to expand its supply chain due diligence measures and internal controls for the Conflict Minerals.
The Policy is available on the Company’s website at http://www.allot.com/company/get-to-know-allot/quality-management/.
Structure internal management systems to support supply chain due diligence.
The Company’s compliance with the Policy and the Rule is overseen by the head of the Company’s engineering department. A team of subject matter experts from relevant departments within the Company, including the engineering, quality assurance and legal departments, is collectively responsible for implementing the Company’s conflict minerals strategy and compliance processes and for training employees outside of the team on their roles and responsibilities in connection with the compliance program. Additionally, this team meets regularly to assess the progress of the Company’s compliance program and reports to management from time to time. The team reported progress and results of its due diligence efforts to management at review sessions held at various times throughout the 2015 calendar year.
Establish a system of controls and transparency over the Conflict Minerals supply chain.
The Company has established a system of controls to promote transparency over its conflict minerals supply chain by utilizing the Conflict Minerals Reporting Template (as further described below), which is designed to facilitate the transfer of information through the supply chain regarding each mineral’s country of origin and the smelters and refiners being utilized for the mineral.
To educate its senior management regarding sourcing practices, the Company has participated in various focus groups and forums relating to responsible sourcing of Conflict Minerals, including several presentations given by the Institute of Printed Circuits, ILTAM – The Israeli Users’ Association of Advanced Technologies in Hi-Tech Integrated Systems.
A - 2
Consistent with the Company’s commitment to sourcing products from suppliers that share its values with regard to human rights, ethics and social and environmental responsibility, as outlined in the Policy, and in compliance with the Rule, the Company has undertaken a multi-stage diligence inquiry to verify the possible sources of the Conflict Minerals contained in the products manufactured or contracted to be manufactured by the Company. The team overseeing the Company’s conflict minerals strategy and compliance program has led this inquiry, with each focus group listed below tasked with specific responsibilities relating to the due diligence efforts:
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Engineering focus group
o Identifying and providing information regarding all parts and components used in all products manufactured or contracted to be manufactured by the Company, and all
raw materials used in the manufacturing process.
o Establishing and implementing a new and advance module, within our new Product Lifecycle Management system for tracking and reporting various Green standards data.
o Finding substitutions for Part, in which their manufacturers fail to comply to the regulation.
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Quality Assurance focus group
o Ensuring that the Company’s Policy is addressed and implemented by suppliers in contracts and purchase orders.
o Promoting transparency and ensuring that information concerning the Company’s compliance is available to customers and sales personnel.
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Legal focus group
o Ensuring that the Company complies with relevant laws, regulations and contractual obligations, including the related reporting requirements, contract reviews and
other issues.
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Strengthen the Company’s engagement with suppliers.
The Company informs its in-scope manufacturers and suppliers of its materials disclosure requirements, including its compliance with the OECD Guidance and the Rule, and of specification updates that the Company communicates and tracks electronically. Moreover, the Company has revised the terms of its purchase order and contract terms and conditions to ensure that manufacturers and suppliers are expressly required to procure the Conflict Minerals from sources that have been verified as conflict-free and to support the supply chain due diligence process employed by the Company.
Establish a company-level grievance mechanism.
The Company maintains an open reporting system through which employees and third parties may report concerns about potential or actual violations of the Policy. Concerns may be reported anonymously or for attribution through several channels, including through an employee’s immediate manager or the Company’s legal department.
OECD Guidance Step 2: Identify and assess risks in the Company’s supply chain.
Identify risks in the supply chain.
The Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company’s supply chain with respect to the Covered Products is complex, with multiple intermediaries and third parties in the supply chain between the Company’s manufacture of the Covered Products and the original sources of Conflict Minerals. As a result, the Company designed its due diligence to conform to the requirements of the Rule and the OECD Guidance, as applicable for downstream companies. The Company relied and continues to rely on its suppliers to provide information regarding the origin of Conflict Minerals included in the Covered Products. Because the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, the Company relied on its linkages to suppliers to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain.
A - 3
The first step in the Company’s due diligence process was to determine which products manufactured or contracted to be manufactured by the Company during the 2015 calendar year may fall within the scope of the Rule and which first-tier suppliers and manufacturers the Company ought to engage in its due diligence efforts.
| - | The engineering focus group reviewed the catalog of the products manufactured or contracted to be manufactured by the Company in the 2015 calendar year to determine which components contain Conflict Minerals necessary to the functionality or production of the products. The Company’s Product Lifecycle Management software was used to generate a list of all of the components of these products. Based on the components used in products manufactured or contracted to be manufactured by the Company, the Covered Products were identified. The Covered Products are listed in Part I of this Report. |
| - | The engineering focus group also generated through the Company’s Product Lifecycle Management system, a list of the manufacturers or suppliers of the components of the Covered Products, allowing the engineering focus group to identify the Company’s first-tier manufacturers and suppliers. |
| - | Based on the engineering focus group’s findings, the Company engaged a new expert-consulting agency, GreenSoft Technology, Inc., in order to gather relevant information needed for updating the Company’s recently implemented Product Governance and Compliance module. This module stores information, such as documents received from manufacturers and suppliers, reflecting active components used by the Company and the degree to which the Company’s manufacturers and suppliers adhere to relevant laws. In recording this data, the system ensures a fixed tracking of sources of components and raw materials. |
Once the final first-tier manufacturer and supplier list was confirmed, all manufacturers and suppliers identified in connection with the Covered Products were then contacted by GreenSoft Technology, Inc. and provided with a supply chain survey in the form of the Electronic Industry Citizenship Coalition's Conflict Minerals Reporting Template (the “EICC Conflict Minerals Reporting Template”). The Company modeled its survey after versions 3.01 – 4.01 of the EEIC Conflict Minerals Reporting Template for a part of the year, and then adopted version 4.01b of the EEIC Conflict Minerals Reporting Template following its release on November 16, 2015. In its cover letter enclosing the template, GreenSoft Technology, Inc. (i) reiterated the requirements of the Rule and its applicability to the Company and (ii) requested that each recipient manufacturer or supplier complete the survey for all products supplied to the Company during the 2015 calendar year.
As set forth in the EICC Conflict Minerals Reporting Template and the OECD Guidance, manufacturers and suppliers which completed the survey, made representations or provided information regarding the following:
| - | the country of origin for the Conflict Minerals contained in the components or products provided by the solicited manufacturer or supplier to the Company; |
| - | whether such Conflict Minerals directly or indirectly finance armed conflict in the Covered Countries; |
| - | all of the smelters in the manufacturer or supplier’s supply chain for such Conflict Minerals; |
| - | whether such smelters have been validated as in compliance with the Conflict-Free Smelter Initiative’s (“CFSI”) Conflict-Free Smelter Program (“CFSP”); |
| - | whether the manufacturer or supplier has its own Conflict Minerals policy that requires its own direct suppliers to be DRC conflict-free; and |
| - | whether the manufacturer or supplier uses the EICC Conflict Minerals Reporting Template with its own suppliers to gather similar information. |
A - 4
Assess risk in the supply chain.
The information in the surveys received from manufacturers and suppliers was compared against the CFSI’s Conflict-Free Smelter list. The Company adopted the following multi-step process to evaluate the surveys:
| - | If correctly completed, each survey identified the smelters and refiners within the solicited supplier or manufacturer’s supply chain. Thus, the Company compared each completed survey against the CFSI Conflict-Free Smelter list to determine whether the smelters or refiners associated with the surveyed supplier or manufacturer qualified as “conflict-free.” The CFSP uses independent third-party auditors to audit the source, including mines of origin and chain of custody, of the Conflict Minerals processed by smelters and refiners which agree to undergo an audit. The smelter or refiner is considered “conflict-free” on the CFSI Conflict-Free Smelter list if the audited smelter or refiner adheres to the CFSP’s assessment protocols and the independent auditor verifies separately that the smelter’s or refiner’s Conflict Minerals originated from conflict-free sources. To be compliant with CFSI standards, smelters and refiners must disclose to the auditors the identities or locations of the mines from which they source their Conflict Minerals. The CFSI Conflict-Free Smelter list includes the names, locations and links to conflict minerals policies of all smelters and refiners deemed compliant with the CFSP’s assessment protocols. Smelters and refiners labeled as “active” have committed to undergo an audit which remains in progress. “Active” smelters and refiners may be at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase, but may not retain their “active” status if they are unresponsive to requests for re-audit or corrective action past a certain time. |
| - | The Company worked with individual manufacturers and suppliers that had questions or concerns regarding the survey modeled after the CMRT Conflict Minerals Reporting Template or regarding the Rule. |
| - | Manufacturers and suppliers that returned surveys that appeared to be incomplete or incorrect were contacted again with a follow-up request to provide the missing information or to correct the inaccuracies. |
| - | Manufacturers and suppliers that failed to respond to the follow-up request were issued an official notification by the Company’s senior officers informing them that continued refusal could result in cancelation of all contractual engagements. |
All completed surveys received from suppliers were stored electronically in a central location accessible to authorized employees of the Company involved in the due diligence process and will be retained in accordance with the Company’s document retention guidelines.
Following the process outlined above, as of December 31, 2015, the Company received completed survey responses from approximately 57% of manufacturers and suppliers on the list, responsible for manufactured parts used in the Covered Products included in the supply chain survey. The Company relied on the completed surveys it received from its manufacturers and suppliers as the main source of documentation supporting the representations made by such parties regarding the source and chain of custody of relevant Conflict Minerals.
OECD Guidance Step 3: Design and implement a strategy to respond to identified risks.
Report findings to designated senior management.
The team overseeing the Company’s conflict minerals strategy and compliance program reported its due diligence findings to senior management overseeing the supply chain and engineering departments, including the Corporate Quality Assistant Vice President and the Vice President for Operations. All completed surveys from manufacturers and suppliers were stored electronically in a central location accessible to authorized employees in the Company’s engineering and legal departments. The Company’s quality assurance department was involved in the design and was responsible for the internal audit of the due diligence process.
Devise and adopt a risk management plan.
In light of the complexity of the Company’s and its suppliers’ supply chains, the Company is currently unable to assess adequately all of the risks in its supply chain. However, the Company has taken and continues to take steps to manage risks, including:
| - | engaging with manufacturers and suppliers to obtain current, accurate and complete information about the Company’s supply chains; |
| - | encouraging manufacturers and suppliers to implement responsible sourcing and—to the extent that the Company is a downstream company with limited control over smelters and refiners—asking manufacturers and suppliers to encourage smelters and refiners to obtain a “conflict-free” designation from an independent, third-party auditor; |
| - | taking part in industry initiatives promoting “conflict-free” supply chains; and |
| - | advocating that our industry membership organizations develop and implement due diligence capability training modules in cooperation with relevant international organizations, non-governmental organizations, stakeholders and other experts. |
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The Company employs an escalation process whereby it promptly engages directly with suppliers or manufacturers upon obtaining any information that may indicate that such suppliers or manufacturers may be sourcing Conflict Minerals from any of the Covered Countries. Various steps taken by the Company in such instances may include requiring a contracted supplier or manufacturer to find an alternative source for the Covered Minerals for use in products or components supplied to the Company, or, if appropriate in light of all relevant factors, suspending or terminating contractual relationship with the supplier or manufacturer. The Company’s risk management plan is ultimately to discontinue doing business with any supplier found to be purchasing the Conflict Minerals, the trading of which directly or indirectly finance or benefit armed groups in the Covered Countries, after attempts at corrective actions are not successful.
OECD Guidance Step 4: Carry out independent third-party audit of smelter/refiner due diligence practices.
Due to the Company’s position in the supply chain, the Company does not have a direct relationship with smelters and refiners, nor does it perform direct audits of the smelters and refiners that provide its supply chain with the Conflict Minerals contained in the Company’s Covered Products. The Company relies upon industry efforts to influence smelters and refiners to undergo audits and become certified through the CFSP.
OECD Guidance Step 5: Report annually on supply chain due diligence.
The Company has filed with the Securities and Exchange Commission its specialized disclosure report on Form SD, which includes this Conflict Minerals Report as Exhibit 1.01, for the reporting period from January 1, 2015 to December 31, 2015. In accordance with OECD Guidance and the Rule, the Company has also made these disclosures available on its website at http://investors.allot.com/sec.cfm.
PART III. THE COMPANY’S DUE DILIGENCE FINDINGS AND CONCLUSIONS
Country of Origin of the Conflict Minerals in the Covered Products
Based on the information obtained by the Company during the due diligence process, the Company does not have sufficient information, with respect to the Covered Products, to determine the country of origin of all of the Conflict Minerals in all the Covered Products. However, based on the information that has been obtained, to the extent reasonably determinable by the Company, with respect to the smelters and refineries identified by the Company, such countries of origin are believed to include, to the extent known, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Czech Republic, Estonia, France, Germany, Hong Kong, India, Indonesia, Italy, Japan, Kazakhstan, Republic Of Korea, Kyrgyzstan, Malaysia, Mexico, Netherlands, New Zealand, Peru, Philippines, Poland, Russian Federation, Rwanda, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, United Arab Emirates, United Kingdom, United States, Uzbekistan, Vietnam and Zimbabwe.
Facilities Used to Process the Conflict Minerals in the Covered Products
Following the process outlined above, the Company received responses from approximately 57% of the surveyed suppliers. Therefore, the Company was unable to conclusively determine the origin of all the Conflict Minerals contained in the Covered Products.
However, based on the information that was provided by the Company’s suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products during the covered period included the smelters and refineries listed on Appendix A to this Report. The smelters and refiners that the Company has been able to determine as CFSP compliant are identified by an asterisk in Appendix A (Smelters which are in Active CSFP status are identified by two asterisks). The smelters and refiners identified in Appendix A to this Report were identified by our suppliers and the Company cannot be certain that these smelters and refiners were in fact in the Company’s supply chain during the period covered by this Report.
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PART IV. IMPLEMENTATION OF STRATEGIES TO RESPOND TO IDENTIFIED RISKS AND FUTURE STEPS
We have taken, and intend to continue to take, steps to improve our due diligence processes and to minimize the risk that our necessary conflict minerals benefit armed groups. Going forward, the Company plans to continue to engage with its manufacturers and suppliers to obtain current, accurate and complete information about its supply chains and will continue to improve its due diligence efforts to ensure responsible sourcing in compliance with the Policy. The Company also intends to continue its engagement with industry programs and groups to encourage the further adoption, improvement and reliability of relevant programs, tools and standards. The Company intends to monitor the performance and efficiency of its due diligence efforts and to establish procedures designed to account for any new risks in the risk management plan. The Company also plans to continue to encourage its suppliers to use conflict-free smelters and refiners as capacity becomes available.
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Appendix A
CURRENTLY KNOWN SMELTER AND REFINERY LIST
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Metal
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Smelter name
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Smelter Country
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Gold
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Acade Metals Co.,LTD
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China
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Gold
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Acade Noble Metal (Zhao Yuan) Corporation
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China
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Gold
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Accurate Refining Group
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United States
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Gold
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Advanced Chemical Company**
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United States
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Gold
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AGR Matthey*
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Australia
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Gold
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AIDA Chemical Industories Co.,Ltd*
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Japan
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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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Aktyubinsk Copper Company TOO
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Kazakhstan
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Gold
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Al Etihad Gold Refinery DMCC
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United Arab Emirates
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Gold
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Allgemeine Gold & Silberscheideanstalt*
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Germany
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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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Amagasaki Factory, Hyogo Prefecture, Japan*
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Japan
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Gold
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AngloGold Ashanti Córrego do Sítio Mineração*
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Brazil
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Gold
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AngloGold Ashanti Mineração Ltda*
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Brazil
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Gold
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Anhui Tongling Nonferrous Metal Mining Co., Ltd.
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China
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Gold
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ANZ (Perth Mint 4N)*
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Australia
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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 Corp*
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Japan
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Gold
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Asahi Refining Canada Limited*
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Canada
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Gold
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Asahi Refining USA Inc.*
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United States
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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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ATAkulche
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Turkey
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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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Baiyin Nonferrous Group Co.,Ltd
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China
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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*
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Canada
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Gold
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CCR*
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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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Central Bank of the Philippines Gold Refinery & Mint*
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Philippines
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* CFSP-compliant, based on CFSI
** CFSP-Active List
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Metal
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Smelter name
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Smelter Country
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Gold
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CHALCO Yunnan Copper Co. Ltd.
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China
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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 Gold International Resources Corp. Ltd.
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China
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Gold
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China Golddeal
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China
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Gold
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China Henan Zhongyuan Gold Smelter*
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China
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Gold
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China National Gold Group Corporation
|
China
|
|
Gold
|
China's Shandong Gold Mining Co., Ltd*
|
China
|
|
Gold
|
Chugai Mining
|
Japan
|
|
Gold
|
CHUGAI MINING CO.,LTD
|
Japan
|
|
Gold
|
Codelco
|
Chile
|
|
Gold
|
Colt Refining
|
United States
|
|
Gold
|
Cookson SEMPSA*
|
Spain
|
|
Gold
|
Daejin Indus Co., Ltd.
|
Korea, Republic Of
|
|
Gold
|
Daejin Industry
|
Korea, Republic Of
|
|
Gold
|
DaeryongENC
|
Korea, Republic Of
|
|
Gold
|
Daye Non-Ferrous Metals Mining Ltd.**
|
China
|
|
Gold
|
Do Sung Corporation
|
Korea, Republic Of
|
|
Gold
|
DODUCO GmbH*
|
Germany
|
|
Gold
|
Doduco*
|
Germany
|
|
Gold
|
Dongguan Standard Electronic Material.Co.,Ltd
|
China
|
|
Gold
|
Dosung metal
|
Korea, Republic Of
|
|
Gold
|
Dowa Kogyo k.k.*
|
Japan
|
|
Gold
|
Dowa Metals & Mining Co. Ltd*
|
Japan
|
|
Gold
|
Dowa Metals & Mining.*
|
Japan
|
|
Gold
|
Dowa*
|
Japan
|
|
Gold
|
DSC (Do Sung Corporation)**
|
Korea, Republic Of
|
|
Gold
|
Eco-System Recycling Co., Ltd.*
|
Japan
|
|
Gold
|
Elemetal Refining, LLC*
|
United States
|
|
Gold
|
Faggi Enrico S.p.A.**
|
Italy
|
|
Gold
|
Feinhütte Halsbrücke GmbH
|
Germany
|
|
Gold
|
Ferro Corporation
|
United States
|
|
Gold
|
Fidelity Printers and Refiners Ltd.
|
Zimbabwe
|
|
Gold
|
FSE Novosibirsk Refinery*
|
Russian Federation
|
|
Gold
|
Fujian Zijin mining stock company gold smelter*
|
China
|
|
Gold
|
Gansu Seemine Material Hi-Tech Co., Ltd.
|
China
|
|
Gold
|
Geib Refining Corporation
|
United States
|
|
Gold
|
Gold Mining in Shandong (Laizhou) Limited Company*
|
China
|
|
Gold
|
Great Wall Precious Metals Co,. LTD.**
|
China
|
|
Gold
|
Great Wall Precious Metals Co., Ltd. of CBPM**
|
China
|
|
Gold
|
Guangdong Gaoyao Co
|
China
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 9
|
Metal
|
Smelter name
|
Smelter Country
|
|
Gold
|
Guangdong Jinding Gold Limited
|
China
|
|
Gold
|
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
|
China
|
|
Gold
|
Hangzhou Fuchunjiang Smelting Co., Ltd.
|
China
|
|
Gold
|
Harima Smelter
|
Japan
|
|
Gold
|
Heesung Metal Ltd.
|
Korea, Republic Of
|
|
Gold
|
Heimerle + Meule GmbH*
|
Germany
|
|
Gold
|
Henan Zhongyuan Gold Smelter of Zhongjin Gold Co. Ltd.*
|
China
|
|
Gold
|
Heraeus (zhaoyuan)Precious Metal Materials Co.,Ltd.
|
China
|
|
Gold
|
Heraeus Hong Kong**
|
Hong Kong
|
|
Gold
|
Heraeus Ltd. Hong Kong*
|
China
|
|
Gold
|
Heraeus Ltd. Hong Kong**
|
Hong Kong
|
|
Gold
|
Heraeus Precious Metals GmbH & Co. KG*
|
Germany
|
|
Gold
|
Heraeus Precious Metals North America (HPMN)
|
United States
|
|
Gold
|
Heraeus Zhaoyuan (Changshu) Electronic Material Co., Ltd.
|
China
|
|
Gold
|
Hishikari Gold Mine (Isa)
|
Japan
|
|
Gold
|
Hisikari Mine
|
Japan
|
|
Gold
|
Hunan Chenzhou Mining Co., Ltd.
|
China
|
|
Gold
|
Hunan Chenzhou Mining Group Co., Ltd.
|
China
|
|
Gold
|
Hunan Chenzhou Mining Industry 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
|
Jiangxi Copper Company Limited*
|
China
|
|
Gold
|
Jinlong Copper Co., Ltd.
|
China
|
|
Gold
|
Johnson Matthey Canada*
|
Canada
|
|
Gold
|
Johnson Matthey HongKong Ltd.**
|
Hong Kong
|
|
Gold
|
Johnson Matthey Inc. (USA)*
|
United States
|
|
Gold
|
Johnson Matthey Ltd*
|
Canada
|
|
Gold
|
JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
|
Russian Federation
|
|
Gold
|
JSC Uralelectromed*
|
Russian Federation
|
|
Gold
|
JX Nippon Mining & Metals Co., Ltd.*
|
Japan
|
|
Gold
|
Kangqiang Electronics Co., Ltd
|
China
|
|
Gold
|
Kazakhmys Smelting LLC
|
Kazakhstan
|
|
Gold
|
Kazzinc Ltd*
|
Kazakhstan
|
|
Gold
|
Kazzinc*
|
Kazakhstan
|
|
Gold
|
Kennecott Utah Copper LLC*
|
United States
|
|
Gold
|
KGHM Polska Miedź Spółka Akcyjna**
|
Poland
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 10
|
Metal
|
Smelter name
|
Smelter Country
|
|
Gold
|
Kojima Chemicals Co. Ltd*
|
Japan
|
|
Gold
|
Kojima Chemicals Co., Ltd.*
|
Japan
|
|
Gold
|
Kojima Kagaku Yakuhin Co., Ltd*
|
Japan
|
|
Gold
|
Kojima-Chemical*
|
Japan
|
|
Gold
|
Korea Metal Co., Ltd.
|
Korea, Republic Of
|
|
Gold
|
Korea Zinc Co. Ltd.
|
Korea, Republic Of
|
|
Gold
|
Kunshan Jinli chemical industry reagents co.,Ltd.
|
China
|
|
Gold
|
Kyrgyzaltyn JSC**
|
Kyrgyzstan
|
|
Gold
|
L' azurde Company For Jewelry
|
Saudi Arabia
|
|
Gold
|
LG-Nikko Copper Inc.*
|
Korea, Republic Of
|
|
Gold
|
LG-Nikko*
|
Korea, Republic Of
|
|
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 Gold Refinery Co., Ltd.
|
China
|
|
Gold
|
Luoyang Zijin Yinhui Metal Smelt Co Ltd
|
China
|
|
Gold
|
Materion Advanced Metals*
|
United States
|
|
Gold
|
Materion*
|
United States
|
|
Gold
|
Matsuda Sangyo Co., Ltd.*
|
Japan
|
|
Gold
|
MEM(Sumitomo Group)*
|
Japan
|
|
Gold
|
Metahub Industries Sdn. Bhd.
|
Malaysia
|
|
Gold
|
Metalor Switzerland*
|
Switzerland
|
|
Gold
|
Metalor Technologies (Hong Kong) Ltd.*
|
China
|
|
Gold
|
Metalor Technologies (Hong Kong) Ltd.**
|
Hong Kong
|
|
Gold
|
Metalor Technologies (Singapore) Pte., Ltd.*
|
Singapore
|
|
Gold
|
Metalor Technologies (Suzhou) Ltd.**
|
China
|
|
Gold
|
Metalor Technologies SA*
|
Switzerland
|
|
Gold
|
Metalor USA Refining Corporation*
|
United States
|
|
Gold
|
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V*
|
Mexico
|
|
Gold
|
Met-Mex Peñoles, S.A.*
|
Mexico
|
|
Gold
|
Mitsubishi Materials Corporation*
|
Japan
|
|
Gold
|
Mitsui & Co Precious Metals Inc*
|
Japan
|
|
Gold
|
Mitsui Kinzoku Co., Ltd.*
|
Japan
|
|
Gold
|
Mitsui Mining and Smelting Co., Ltd.*
|
Japan
|
|
Gold
|
MK Electron co., Ltd.
|
Korea, Republic Of
|
|
Gold
|
MMTC-PAMP India Pvt., Ltd.*
|
India
|
|
Gold
|
Morris and Watson
|
New Zealand
|
|
Gold
|
Moscow Special Alloys Processing Plant*
|
Russian Federation
|
|
Gold
|
N.E.Chemcat Corporation
|
Japan
|
|
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.Ş.*
|
Turkey
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 11
|
Metal
|
Smelter name
|
Smelter Country
|
|
Gold
|
Navoi Mining and Metallurgical Combinat**
|
Uzbekistan
|
|
Gold
|
Nihon Material Co., Ltd.*
|
Japan
|
|
Gold
|
Nippon Mining*
|
Japan
|
|
Gold
|
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
|
Austria
|
|
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 Krastsvetmet)*
|
Russian Federation
|
|
Gold
|
OJSC Kolyma Refinery
|
Russian Federation
|
|
Gold
|
OJSC Krastsvetmet*
|
Russian Federation
|
|
Gold
|
OJSC Novosibirsk Refinery*
|
Russian Federation
|
|
Gold
|
PAMP SA*
|
Switzerland
|
|
Gold
|
Pan Pacific Copper Co Ltd.*
|
Japan
|
|
Gold
|
Pan Pacific Copper Co. LTD*
|
Japan
|
|
Gold
|
Penglai Penggang Gold Industry Co., Ltd.
|
China
|
|
Gold
|
Perth Mint*
|
Australia
|
|
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
|
Realized the enterprise co.,ltd.
|
China
|
|
Gold
|
Remondis Argentia B.V.
|
Netherlands
|
|
Gold
|
Republic Metals Corporation*
|
United States
|
|
Gold
|
Royal Canadian Mint*
|
Canada
|
|
Gold
|
Sabin Metal Corp.
|
United States
|
|
Gold
|
Samdok metal
|
Korea, Republic Of
|
|
Gold
|
Samdok Metal**
|
Korea, Republic Of
|
|
Gold
|
Samduck Precious Metals**
|
Korea, Republic Of
|
|
Gold
|
SAMWON METALS Corp.
|
Korea, Republic Of
|
|
Gold
|
SANMENXIA HENGSHENG SCIENCE AND TECHNOLOGY R&D CO.,LTD
|
China
|
|
Gold
|
Sanmenxia HengSheng Science Technology R&D CO.LTD
|
China
|
|
Gold
|
SAXONIA Edelmetalle GmbH**
|
Germany
|
|
Gold
|
Schone Edelmetaal B.V.*
|
Netherlands
|
|
Gold
|
Schone Edelmetaal*
|
Netherlands
|
|
Gold
|
ScotiaMocatta, The Bank of Nova Scotia
|
Hong Kong
|
|
Gold
|
SD(Samdok) Metal
|
Korea, Republic Of
|
|
Gold
|
SEMPSA Joyería Platería SA*
|
Spain
|
|
Gold
|
Sempsa JP (Cookson Sempsa)*
|
Spain
|
|
Gold
|
Shandong zhaojin gold*
|
China
|
|
Gold
|
Shandong Gold Mine(Laizhou) Smelter Co., Ltd.*
|
China
|
|
Gold
|
Shandong Gold Mining (Laizhou)*
|
China
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 12
|
Metal
|
Smelter name
|
Smelter Country
|
|
Gold
|
Shandong laizhou city, the three mountain island street agency*
|
China
|
|
Gold
|
Shandong Tarzan Bio-Gold Industry Co., Ltd.
|
China
|
|
Gold
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
|
China
|
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*
|
China
|
|
Gold
|
Shang Hai Gold Exchange
|
China
|
|
Gold
|
Shangdong Gold (Laizhou)*
|
China
|
|
Gold
|
Shenzhen ZhonghenglongRealIndustryCo.,Ltd.
|
China
|
|
Gold
|
Shonan Plant Tanaka Kikinzoku*
|
Japan
|
|
Gold
|
Sichuan Tianze Precious Metals Co., Ltd*
|
China
|
|
Gold
|
Singway Technology Co., Ltd.*
|
Taiwan
|
|
Gold
|
SMM*
|
Japan
|
|
Gold
|
So Accurate Group, Inc.
|
United States
|
|
Gold
|
So Accurate Refining Group
|
United States
|
|
Gold
|
SOE Shyolkovsky Factory of Secondary Precious Metals*
|
Russian Federation
|
|
Gold
|
Solar Applied Materials Technology Corp.*
|
Taiwan
|
|
Gold
|
Sudan Gold Refinery
|
Sudan
|
|
Gold
|
Sumitomo Kinzoku Kozan K.K.*
|
Japan
|
|
Gold
|
Sumitomo Metal Mining Co., Ltd.*
|
Japan
|
|
Gold
|
Suzhou Xingrui Noble
|
China
|
|
Gold
|
Suzhou Xinrui Noble metal material co.ltd
|
China
|
|
Gold
|
T.C.A S.p.A*
|
Italy
|
|
Gold
|
Taizhou Delta Electronics Co., Ltd.
|
China
|
|
Gold
|
Tanaka kikinzoku kogyo K.k*
|
Japan
|
|
Gold
|
Tanaka Denshi Kogyo K.K*
|
Japan
|
|
Gold
|
Tanaka Electronics(Hong Kong)Pte.Ltd*
|
Japan
|
|
Gold
|
TANAKA Electronics(Malasia) SDN. BHD.*
|
Japan
|
|
Gold
|
Tanaka Electronics（Singapore）Pte.Ltd*
|
Japan
|
|
Gold
|
Tanaka Kikinzoku Kogyo K.K.*
|
Japan
|
|
Gold
|
Technic, Inc.
|
United States
|
|
Gold
|
The Great Wall Gold and Silver Refinery of China**
|
China
|
|
Gold
|
The Hutti Gold Company
|
India
|
|
Gold
|
THE HUTTI GOLD MINES CO.LTD
|
India
|
|
Gold
|
The Perth Mint*
|
Australia
|
|
Gold
|
The Refinery of Shandong Gold Mining Co., Ltd.*
|
China
|
|
Gold
|
Tiancheng Chemical
|
China
|
|
Gold
|
Tokuriki Honten Co., Ltd.*
|
Japan
|
|
Gold
|
Tongling Nonferrous Metals Group Co., Ltd.
|
China
|
|
Gold
|
TongLing Nonferrous Metals Group Holdings Co;Ltd
|
China
|
|
Gold
|
Torecom**
|
Korea, Republic Of
|
|
Gold
|
Toyo Smelter & Refinery*
|
Japan
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 13
|
Metal
|
Smelter name
|
Smelter Country
|
|
Gold
|
UBS AG Bahnhofstr.
|
Switzerland
|
|
Gold
|
Umicore Brasil Ltda.*
|
Brazil
|
|
Gold
|
Umicore Feingold*
|
Belgium
|
|
Gold
|
Umicore Galvanotechnik GmbH
|
Germany
|
|
Gold
|
Umicore Materials AG
|
Switzerland
|
|
Gold
|
Umicore Precious Metals Thailand*
|
Thailand
|
|
Gold
|
Umicore SA Business Unit Precious Metals Refining*
|
Belgium
|
|
Gold
|
United Precious Metal Refining, Inc.*
|
United States
|
|
Gold
|
United Refining
|
United States
|
|
Gold
|
United Refining Company
|
United States
|
|
Gold
|
UYEMURA
|
United States
|
|
Gold
|
Uyemura USA
|
United States
|
|
Gold
|
Valcambi SA*
|
Switzerland
|
|
Gold
|
Western Australian Mint trading as The Perth Mint*
|
Australia
|
|
Gold
|
WIELAND Edelmetalle GmbH**
|
Germany
|
|
Gold
|
Williams Advanced Materials*
|
United States
|
|
Gold
|
Williams/ Williams Brewster
|
United States
|
|
Gold
|
Wuxi Middle Treasure Materials
|
China
|
|
Gold
|
Wuxi Middle Treasures Materials
|
China
|
|
Gold
|
Xstrata Canada Corporation*
|
Canada
|
|
Gold
|
Xstrata*
|
Canada
|
|
Gold
|
Yamamoto Precious Metal Co., Ltd.*
|
Japan
|
|
Gold
|
Yamamoto Precision Metals*
|
Japan
|
|
Gold
|
Yantai Zhaojin Kanfort Precious Metals Incorporated Company
|
China
|
|
Gold
|
Yantai Zhaojinlufu
|
China
|
|
Gold
|
Yokohama Metal Co., Ltd.*
|
Japan
|
|
Gold
|
Yunnan Copper Industry Co., Ltd.
|
China
|
|
Gold
|
Zhao Jin Mining Industry Co Ltd*
|
China
|
|
Gold
|
Zhao Yuan Gold Mine*
|
China
|
|
Gold
|
Zhao Yuan Jin Kuang*
|
China
|
|
Gold
|
Zhaojin Gold & Silver Refinery Co.,Ltd*
|
China
|
|
Gold
|
Zhaojin Lai Fuk （烟台招金励福贵金属股份有限公司）*
|
China
|
|
Gold
|
Zhaojin Mining Industry Co., Ltd.*
|
China
|
|
Gold
|
Zhaojin Mining Industry Co., Ltd.*
|
China
|
|
Gold
|
Zhongjin Gold Corporation Limited*
|
China
|
|
Gold
|
Zhongkuang Gold Industry Co., Ltd.
|
China
|
|
Gold
|
Zhongshan Public Security Bureau, Guangdong Province ,China
|
China
|
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
|
China
|
|
Gold
|
Zijin Kuang Ye Refinery*
|
China
|
|
Gold
|
Zijin Mining Group Co. Ltd*
|
China
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 14
|
Metal
|
Smelter name
|
Smelter Country
|
|
Gold
|
Zijin Mining Group Co., Ltd. Gold Refinery*
|
China
|
|
Gold
|
Zijin Mining Industry Corporation (Shanghang) gold smelting plant*
|
China
|
|
Gold
|
Zijin Mining Industry Corporation*
|
China
|
|
Tantalum
|
ANHUI HERRMAN IMPEX CO., LTD
|
China
|
|
Tantalum
|
Cabot Corporation*
|
United States
|
|
Tantalum
|
Changsha South Tantalum Niobium Co., Ltd.*
|
China
|
|
Tantalum
|
Changsha Southern*
|
China
|
|
Tantalum
|
Conghua Tantalum and Niobium Smeltry*
|
China
|
|
Tantalum
|
D Block Metals, LLC*
|
United States
|
|
Tantalum
|
Douluoshan Sapphire Rare Metal Co Ltd*
|
China
|
|
Tantalum
|
Duoluoshan*
|
China
|
|
Tantalum
|
Exotech Inc.*
|
United States
|
|
Tantalum
|
F & X*
|
China
|
|
Tantalum
|
F&X Electro-Materials Ltd.*
|
China
|
|
Tantalum
|
FIR Metals & Resource Ltd.*
|
China
|
|
Tantalum
|
Gannon & Scott
|
United States
|
|
Tantalum
|
Global Advanced Metals Aizu*
|
Japan
|
|
Tantalum
|
Global Advanced Metals Boyertown*
|
United States
|
|
Tantalum
|
Global Advanced Metals*
|
United States
|
|
Tantalum
|
Guangdong Zhiyuan New Material Co., Ltd.*
|
China
|
|
Tantalum
|
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
|
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 GmbH*
|
Germany
|
|
Tantalum
|
H.C. Starck Group*
|
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 Specialty Metals, Inc.*
|
United States
|
|
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
|
JX Nippon Mining & Metals Co., Ltd.
|
Japan
|
|
Tantalum
|
KEMET Blue Metals*
|
Mexico
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 15
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tantalum
|
Kemet Blue Powder*
|
United States
|
|
Tantalum
|
King-Tan Tantalum Industry Ltd.*
|
China
|
|
Tantalum
|
LSM Brasil S.A.*
|
Brazil
|
|
Tantalum
|
Metallurgical Products India (Pvt.) Ltd.*
|
India
|
|
Tantalum
|
Metallurgical Products India Pvt. Ltd. (MPIL)*
|
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
|
Plansee*
|
Austria
|
|
Tantalum
|
QuantumClean*
|
United States
|
|
Tantalum
|
Resind Indústria e Comércio Ltda.*
|
Brazil
|
|
Tantalum
|
RFH Tantalum Smeltry Co., Ltd.*
|
China
|
|
Tantalum
|
RFH*
|
China
|
|
Tantalum
|
Shanghai Jiangxi Metals Co. Ltd
|
China
|
|
Tantalum
|
Solikamsk Magnesium Works OAO*
|
Russian Federation
|
|
Tantalum
|
Solikamsk Metal Works*
|
Russian Federation
|
|
Tantalum
|
Solikamsk*
|
Russian Federation
|
|
Tantalum
|
Takei Chemicals*
|
Japan
|
|
Tantalum
|
Taki Chemicals*
|
Japan
|
|
Tantalum
|
Tantalite Resources
|
South Africa
|
|
Tantalum
|
Tantalum
|
China
|
|
Tantalum
|
Telex Metals*
|
United States
|
|
Tantalum
|
Telex*
|
United States
|
|
Tantalum
|
Tranzact, Inc.*
|
United States
|
|
Tantalum
|
ULBA Metallurgical Plant JSC*
|
Kazakhstan
|
|
Tantalum
|
Ulba*
|
Kazakhstan
|
|
Tantalum
|
XinXing HaoRong Electronic Material CO.,LTD*
|
China
|
|
Tantalum
|
Yichun Jin Yang Rare Metal Co., Ltd.*
|
China
|
|
Tantalum
|
Zhaoqing Duoluoshan Non-ferrous Metals Co.,Ltd*
|
China
|
|
Tantalum
|
Zhuzhou Cement Carbide*
|
China
|
|
Tantalum
|
Zhuzhou Cemented Carbide*
|
China
|
|
Tin
|
5N Plus
|
Germany
|
|
Tin
|
AIM
|
Canada
|
|
Tin
|
Alent plc*
|
United States
|
|
Tin
|
Alpha Metals (Taiwan) Inc.
|
Taiwan
|
|
Tin
|
Alpha Metals Korea Ltd.
|
Korea, Republic Of
|
|
Tin
|
Alpha Metals Korea Ltd.*
|
United States
|
|
Tin
|
Alpha Metals*
|
United States
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 16
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tin
|
alpha*
|
United States
|
|
Tin
|
Amalgamated Metal Corp PLC*
|
Peru
|
|
Tin
|
Amalgamet
|
United States
|
|
Tin
|
Amalgamet Inc
|
United States
|
|
Tin
|
American Iron and Metal
|
Canada
|
|
Tin
|
An Thai Minerals Company Limited
|
Vietnam
|
|
Tin
|
An Vinh Joint Stock Mineral Processing Company**
|
Vietnam
|
|
Tin
|
Bangka Tin,Mentok,PT Timah (Persero) TBK*
|
Indonesia
|
|
Tin
|
Baoshida Swissmetall
|
Switzerland
|
|
Tin
|
Best Metais e Soldas SA
|
Brazil
|
|
Tin
|
BML*
|
Indonesia
|
|
Tin
|
Brand IMLI*
|
Indonesia
|
|
Tin
|
Brand RBT*
|
Indonesia
|
|
Tin
|
Brinkmann Chemie AG
|
Germany
|
|
Tin
|
Butterworth Smelter*
|
Malaysia
|
|
Tin
|
CFC Cooperativa dos Fundidores de Cassiterita da Amazônia Ltda.
|
Brazil
|
|
Tin
|
Chengfeng Metals Co Pte Ltd
|
China
|
|
Tin
|
Chenzhou Yunxiang Mining and Metallurgy Company Limited
|
China
|
|
Tin
|
China Lai Bin tin smelting co.,ltd*
|
China
|
|
Tin
|
China Rare Metal Material Co., Ltd.*
|
China
|
|
Tin
|
China Rare Metal Materials Company*
|
China
|
|
Tin
|
China Tin (Hechi)*
|
China
|
|
Tin
|
China Tin Co.,Ltd.*
|
China
|
|
Tin
|
China Tin Group Co., Ltd.*
|
China
|
|
Tin
|
China tin group in Guangxi*
|
China
|
|
Tin
|
China Tin Lai Ben Smelter Co., Ltd.*
|
China
|
|
Tin
|
China Tin*
|
China
|
|
Tin
|
China Yunnan Tin Co Ltd.*
|
China
|
|
Tin
|
Chofu Works
|
Japan
|
|
Tin
|
CNMC (Guangxi) PGMA Co., Ltd.
|
China
|
|
Tin
|
Cookson Group
|
Taiwan
|
|
Tin
|
Cookson*
|
United States
|
|
Tin
|
Cooper Santa*
|
Brazil
|
|
Tin
|
Cooperativa Metalurgica de Rondônia Ltda.*
|
Brazil
|
|
Tin
|
CV Ayi Jaya*
|
Indonesia
|
|
Tin
|
CV DS Jaya Abadi*
|
Indonesia
|
|
Tin
|
CV Duta Putra Bangka
|
Indonesia
|
|
Tin
|
CV Gita Pesona*
|
Indonesia
|
|
Tin
|
CV JusTindo*
|
Indonesia
|
|
Tin
|
CV Makmur Jaya
|
Indonesia
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 17
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tin
|
CV Nurjanah*
|
Indonesia
|
|
Tin
|
CV Prima Timah Utama*
|
Indonesia
|
|
Tin
|
CV Serumpun Sebalai*
|
Indonesia
|
|
Tin
|
CV United Smelting*
|
Indonesia
|
|
Tin
|
CV Venus Inti Perkasa*
|
Indonesia
|
|
Tin
|
Da Tong Co., Ltd*
|
Taiwan
|
|
Tin
|
Daewoo International
|
Korea, Republic Of
|
|
Tin
|
Doduco
|
Germany
|
|
Tin
|
Dongguan City JiuBo Electronic Science and Technology Co.,LTD
|
China
|
|
Tin
|
Dowa Metaltech Co., Ltd.*
|
Japan
|
|
Tin
|
Dowa*
|
Japan
|
|
Tin
|
Electroloy Metal Co. Ltd
|
China
|
|
Tin
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company**
|
Vietnam
|
|
Tin
|
Elmet S.L.U. (Metallo Group)*
|
Spain
|
|
Tin
|
EM Vinto*
|
Bolivia
|
|
Tin
|
EMPERESA METALURGICA VINTO*
|
Bolivia
|
|
Tin
|
Empresa Metalúrgica Vinto*
|
Bolivia
|
|
Tin
|
Empressa Nacional de Fundiciones (ENAF)*
|
Bolivia
|
|
Tin
|
Estanho de Rondônia S.A.
|
Brazil
|
|
Tin
|
Feinhütte Halsbrücke GmbH
|
Germany
|
|
Tin
|
Fenix Metals*
|
Poland
|
|
Tin
|
FSE Novosibirsk Refinery
|
Russian Federation
|
|
Tin
|
Fuji Metal Mining
|
Thailand
|
|
Tin
|
Fuji Metal Mining Corp.
|
Taiwan
|
|
Tin
|
Funsur Smelter*
|
Peru
|
|
Tin
|
Funsur*
|
Peru
|
|
Tin
|
Furukawa Electric
|
Japan
|
|
Tin
|
Geiju City Datun Chengfeng Smelter**
|
China
|
|
Tin
|
Geiju Non-Ferrous Metal Processing Co. Ltd.*
|
China
|
|
Tin
|
Gejiu Jin Ye Mineral Co., Ltd.
|
China
|
|
Tin
|
Gejiu Jinye Mineral Co., Ltd.
|
China
|
|
Tin
|
Gejiu Kai Meng Industry and Trade LLC**
|
China
|
|
Tin
|
Gejiu Non-Ferrous Metal Processing Co., Ltd.*
|
China
|
|
Tin
|
Gejiu YunXin Colored Electrolysis Ltd
|
China
|
|
Tin
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
China
|
|
Tin
|
Gejiu Zi-Li
|
China
|
|
Tin
|
Gejiu Zili Mining And Metallurgy Co., Ltd.
|
China
|
|
Tin
|
Gold Bell Group
|
China
|
|
Tin
|
Guang Xi Liu Xhou*
|
China
|
|
Tin
|
GuangDong Jiatian Stannum Products Co., Ltd
|
China
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 18
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tin
|
GuangXi China Tin*
|
China
|
|
Tin
|
Guangxi Pinggui PGMA Co. Ltd.
|
China
|
|
Tin
|
GuanXi China Tin Group Co.,LTD*
|
China
|
|
Tin
|
Heimerle + Meule GmbH
|
Germany
|
|
Tin
|
Heraeus Oriental Hitec Co., Ltd.
|
Korea, Republic Of
|
|
Tin
|
Heraeus Precious Metals GmbH & Co. KG
|
Germany
|
|
Tin
|
Hitachi Cable, Ltd.
|
Japan
|
|
Tin
|
Honeywell Electronic Materials, Inc
|
United States
|
|
Tin
|
Huichang Jinshunda Tin Co., Ltd.
|
China
|
|
Tin
|
Huichang Shun Tin Kam Industries, Ltd.
|
China
|
|
Tin
|
IBF IND Brasileira de Ferrolligas Ltda
|
Brazil
|
|
Tin
|
Impag AG
|
Switzerland
|
|
Tin
|
Imperial Zinc
|
United States
|
|
Tin
|
Indonesian State Tin Corporation Mentok Smelter*
|
Indonesia
|
|
Tin
|
Indra Eramulti Logam*
|
Indonesia
|
|
Tin
|
IPS
|
France
|
|
Tin
|
Jean GOLDSCHMIDT INTERNATIONAL S.A.
|
Belgium
|
|
Tin
|
Jiangxi Ketai Advanced Material Co., Ltd.*
|
China
|
|
Tin
|
Jiangxi Nanshan
|
China
|
|
Tin
|
Jiangxi Shunda Huichang Kam Tin Co., Ltd.
|
China
|
|
Tin
|
Kai Unita Trade Limited Liability Company**
|
China
|
|
Tin
|
Ketabang
|
Indonesia
|
|
Tin
|
KOVOHUTĚ PŘÍBRAM NÁSTUPNICKÁ, A.S.
|
Czech Republic
|
|
Tin
|
Kundur Smelter*
|
Indonesia
|
|
Tin
|
Lai'bin China Tin Smelting Ltd.*
|
China
|
|
Tin
|
Linwu Xianggui Ore Smelting Co., Ltd.
|
China
|
|
Tin
|
Linwu Xianggui Smelter Co
|
China
|
|
Tin
|
Liuzhhou China Tin*
|
China
|
|
Tin
|
Liuzhou China Tin*
|
China
|
|
Tin
|
Magnu's Minerais Metais e Ligas Ltda.*
|
Brazil
|
|
Tin
|
Malaysia Smelting Corp*
|
Malaysia
|
|
Tin
|
Malaysia Smelting Corporation (MSC)*
|
Malaysia
|
|
Tin
|
MCP Metal Specialties, Inc.
|
United Kingdom
|
|
Tin
|
Melt Metais e Ligas S/A*
|
Brazil
|
|
Tin
|
Mentok Smelter (PT Timah)*
|
Indonesia
|
|
Tin
|
Mentok Smelter*
|
Indonesia
|
|
Tin
|
Metahub Industries Sdn. Bhd.
|
Malaysia
|
|
Tin
|
Metallic Materials Branch L of Guangxi China Tin Group CO.,LTD*
|
China
|
|
Tin
|
Metallic Materials Branch of Guangxi China Tin Group Co.,Ltd.*
|
China
|
|
Tin
|
Metallic Resources, Inc.*
|
United States
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 19
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tin
|
Metallo Chimique*
|
Belgium
|
|
Tin
|
Metallo-Chimique N.V.*
|
Belgium
|
|
Tin
|
Metallum Metal Trading Company
|
Switzerland
|
|
Tin
|
Mineração Taboca S.A.*
|
Brazil
|
|
Tin
|
Ming Li Jia Smelt Metal Factory
|
China
|
|
Tin
|
Minmetals Ganzhou Tin Co. Ltd.
|
China
|
|
Tin
|
Minsur*
|
Peru
|
|
Tin
|
Mitsubishi Materials Corporation*
|
Japan
|
|
Tin
|
MSC Croporation Berhad*
|
Malaysia
|
|
Tin
|
MSC*
|
Malaysia
|
|
Tin
|
Nankang Nanshan Tin Manufactory Co., Ltd.
|
China
|
|
Tin
|
Nathan Trotter & Co., Inc.
|
United States
|
|
Tin
|
NENTOK*
|
Indonesia
|
|
Tin
|
NGHE TIN NON-FERROUS METAL
|
Vietnam
|
|
Tin
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company
|
Vietnam
|
|
Tin
|
Nihon Genma MFG Co., Ltd.
|
Thailand
|
|
Tin
|
Nihon Kagaku Sangyo Co., Ltd.
|
Japan
|
|
Tin
|
Novosibirsk Integrated Tin Works
|
Russian Federation
|
|
Tin
|
Novosibirsk Processing Plant Ltd.
|
Russian Federation
|
|
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.*
|
Thailand
|
|
Tin
|
O.M. Manufacturing Philippines, Inc.*
|
Philippines
|
|
Tin
|
OMSA*
|
Bolivia
|
|
Tin
|
Operaciones Metalugicas SA.*
|
Bolivia
|
|
Tin
|
Operaciones Metalurgical S.A.*
|
Bolivia
|
|
Tin
|
Phoenix Metal Ltd.**
|
Rwanda
|
|
Tin
|
PL Timah Tbk*
|
Indonesia
|
|
Tin
|
Poongsan
|
Korea, Republic Of
|
|
Tin
|
POONGSAN CORPORATION
|
Korea, Republic Of
|
|
Tin
|
PT Bangka Putra Karya
|
Indonesia
|
|
Tin
|
PT Alam Lestari Kencana
|
Indonesia
|
|
Tin
|
PT Aries Kencana Sejahtera*
|
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 Prima Tin*
|
Indonesia
|
|
Tin
|
PT Bangka Putra Karya
|
Indonesia
|
|
Tin
|
PT Bangka Timah Utama Sejahtera
|
Indonesia
|
|
Tin
|
PT Bangka Tin Industry
|
Indonesia
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 20
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tin
|
PT Belitung Industri Sejahtera*
|
Indonesia
|
|
Tin
|
PT BilliTin Makmur Lestari*
|
Indonesia
|
|
Tin
|
PT Bukit Timah*
|
Indonesia
|
|
Tin
|
PT Cipta Persada Mulia*
|
Indonesia
|
|
Tin
|
PT Donna Kembara Jaya
|
Indonesia
|
|
Tin
|
PT DS Jaya Abadi*
|
Indonesia
|
|
Tin
|
PT Eunindo Usaha Mandiri*
|
Indonesia
|
|
Tin
|
PT Fang Di MulTindo
|
Indonesia
|
|
Tin
|
PT HANJAYA PERKASA METALS
|
Indonesia
|
|
Tin
|
PT HP Metals Indonesia
|
Indonesia
|
|
Tin
|
PT Indora Ermulti*
|
Indonesia
|
|
Tin
|
PT Indra Eramult Logam Industri*
|
Indonesia
|
|
Tin
|
PT Indra Eramulti Logam Industri*
|
Indonesia
|
|
Tin
|
PT Inti Stania Prima*
|
Indonesia
|
|
Tin
|
PT Justindo*
|
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 (RBT)*
|
Indonesia
|
|
Tin
|
PT Refined Bangka Tin*
|
Indonesia
|
|
Tin
|
PT Refined Banka Tin*
|
Indonesia
|
|
Tin
|
PT Sariwiguna Binasentosa*
|
Indonesia
|
|
Tin
|
PT Seirama Tin Investment
|
Indonesia
|
|
Tin
|
PT Stanindo Inti Perkasa*
|
Indonesia
|
|
Tin
|
PT Sukses Inti Makmur*
|
Indonesia
|
|
Tin
|
PT Sumber Jaya Indah*
|
Indonesia
|
|
Tin
|
PT Supra Sukses Trinusa
|
Indonesia
|
|
Tin
|
PT TAMBANG TIMAH (BANKA)*
|
Indonesia
|
|
Tin
|
PT Tambang Timah Tbk (Persero)*
|
Indonesia
|
|
Tin
|
PT Tambang Timah*
|
Indonesia
|
|
Tin
|
PT Timah
|
Indonesia
|
|
Tin
|
PT Timah (Persero) Tbk Mentok*
|
Indonesia
|
|
Tin
|
PT Timah (Persero), Tbk*
|
Indonesia
|
|
Tin
|
PT Timah Nusantara
|
Indonesia
|
|
Tin
|
PT Tinindo Inter Nusa*
|
Indonesia
|
|
Tin
|
PT Tirus Putra Mandiri
|
Indonesia
|
|
Tin
|
PT Tommy Utama*
|
Indonesia
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 21
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tin
|
PT Wahana Perkit Jaya*
|
Indonesia
|
|
Tin
|
PT Yinchendo Mining Industry
|
Indonesia
|
|
Tin
|
PT. CITRALOGAM ALPHASEJAHTERA
|
Indonesia
|
|
Tin
|
Rahman Hydrulic Tin Sdn Bhd
|
Malaysia
|
|
Tin
|
Resind Indústria e Comércio Ltda.*
|
Brazil
|
|
Tin
|
Rui Da Hung*
|
Taiwan
|
|
Tin
|
Samhwa Non-Ferrous Metal. Inc Co.,Ltd.
|
Korea, Republic Of
|
|
Tin
|
Senju Metal Industry Co. (SMIC)
|
Japan
|
|
Tin
|
SENJU METAL INDUSTRY CO.,LTD.
|
Japan
|
|
Tin
|
Smelting Branch of Yunnan Tin Company Ltd*
|
China
|
|
Tin
|
So Accurate Group, Inc.
|
United States
|
|
Tin
|
Soft Metais, Ltda.*
|
Brazil
|
|
Tin
|
Standard Sp z o.o.
|
Poland
|
|
Tin
|
Taboca*
|
Brazil
|
|
Tin
|
Taicang City Nancang Metal Material Co.,Ltd
|
China
|
|
Tin
|
Thai Solder Industry Corp., Ltd.
|
Thailand
|
|
Tin
|
Thailand Smelting & Refining Co., Ltd*
|
Thailand
|
|
Tin
|
Thaisarco*
|
Thailand
|
|
Tin
|
The Gejiu cloud new colored electrolytic**
|
China
|
|
Tin
|
Timah Indonesian State Tin Corporation*
|
Indonesia
|
|
Tin
|
Tin Products Manufacturing Co.LTD. of YTCL*
|
China
|
|
Tin
|
Tin*
|
Indonesia
|
|
Tin
|
Toboca/ Paranapenema*
|
Brazil
|
|
Tin
|
TONGDING METALLIC MATERIAL CO.LTD
|
China
|
|
Tin
|
Traxys
|
France
|
|
Tin
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company**
|
Vietnam
|
|
Tin
|
UNI BROS METAL PTE LTD
|
Singapore
|
|
Tin
|
Unit Metalurgi PT Timah Persero TBK*
|
Indonesia
|
|
Tin
|
Unit Timah Kundur PT Tambang*
|
Indonesia
|
|
Tin
|
VERTEX METALS INCORPORATION
|
Taiwan
|
|
Tin
|
VQB Mineral and Trading Group JSC*
|
Vietnam
|
|
Tin
|
Westfalenzinn
|
Germany
|
|
Tin
|
Westmetall GmbH & Co.KG
|
Germany
|
|
Tin
|
White Solder Metalurgia e Mineração Ltda.*
|
Brazil
|
|
Tin
|
White Solder Metalurgica*
|
Brazil
|
|
Tin
|
Wilhelm Grillo Handelsgesellschaft mbH
|
Germany
|
|
Tin
|
Wilhelm Westmetall
|
Germany
|
|
Tin
|
XiHai - Liuzhou China Tin Group Co ltd - list as "China Tin"*
|
China
|
|
Tin
|
XiHai - Liuzhou China Tin Group Co ltd*
|
China
|
|
Tin
|
Yifeng Tin Industry (Chenzhou) Co Ltd
|
China
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 22
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tin
|
YTCL*
|
China
|
|
Tin
|
Yun Nan Tin Co. LTD*
|
China
|
|
Tin
|
Yun'an Dian'xi Tin Mine
|
China
|
|
Tin
|
Yunan Gejiu Yunxin Electrolyze Limited**
|
China
|
|
Tin
|
Yunnan Chengfeng
|
China
|
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.**
|
China
|
|
Tin
|
Yunnan Geiju Zili Metallurgy Co. Ltd.
|
China
|
|
Tin
|
YunNan GeJiu Jin Ye Mineral Co.,Ltd
|
China
|
|
Tin
|
Yunnan Tin Company, Ltd.*
|
China
|
|
Tin
|
Yunnan Tin Group (Holding) Company Limited*
|
China
|
|
Tin
|
Yunnan Tin Group Co., Ltd.*
|
China
|
|
Tin
|
Yunnan wind Nonferrous Metals Co., Ltd.
|
China
|
|
Tin
|
Yunnan, China Rare Metal Materials Company*
|
China
|
|
Tin
|
Yuntinic Resources Inc.*
|
China
|
|
Tin
|
Yuntinic Resources*
|
China
|
|
Tungsten
|
A.L.M.T. Corp.*
|
Japan
|
|
Tungsten
|
A.L.M.T. TUNGSTEN Corp.*
|
Japan
|
|
Tungsten
|
Air Products
|
United States
|
|
Tungsten
|
ALMT Corp*
|
Japan
|
|
Tungsten
|
Asia Tungsten Products Vietnam Ltd.*
|
Vietnam
|
|
Tungsten
|
ATI Metalworking Products*
|
United States
|
|
Tungsten
|
ATI Tungsten Materials*
|
United States
|
|
Tungsten
|
Axis Material Limited
|
Japan
|
|
Tungsten
|
Chaozhou Xianglu Tungsten Industry Co., Ltd.*
|
China
|
|
Tungsten
|
Chengdu Hongbo Industrial co,Ltd
|
China
|
|
Tungsten
|
Chenzhou Diamond Tungsten Products Co., Ltd.*
|
China
|
|
Tungsten
|
China Minmetals Corporation
|
China
|
|
Tungsten
|
China Minmetals Nonferrous Metals Co Ltd
|
China
|
|
Tungsten
|
China National Non Ferrous*
|
China
|
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.*
|
China
|
|
Tungsten
|
Dayu Jincheng Tungsten Industry Co., Ltd.
|
China
|
|
Tungsten
|
Dayu Weiliang Tungsten Co., Ltd.
|
China
|
|
Tungsten
|
Fujian Jinxin Tungsten Co., Ltd.*
|
China
|
|
Tungsten
|
Ganxian Shirui New Material Co., Ltd.
|
China
|
|
Tungsten
|
Ganzhou Grand Sea W & Mo Group Co Ltd*
|
China
|
|
Tungsten
|
Ganzhou Haichuang Tungsten Industry Co., Ltd.
|
China
|
|
Tungsten
|
Ganzhou Hongfei Tungsten & Molybdenum Materials 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
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 23
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.*
|
China
|
|
Tungsten
|
Ganzhou Yatai Tungsten Co., Ltd.*
|
China
|
|
Tungsten
|
Global Tungsten & Powders Corp.*
|
United States
|
|
Tungsten
|
Golden Egret
|
China
|
|
Tungsten
|
GTP*
|
United States
|
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.*
|
China
|
|
Tungsten
|
Guangdong Xianglu Tungsten Industry Co., Ltd.*
|
China
|
|
Tungsten
|
H.C. Starck GmbH*
|
Germany
|
|
Tungsten
|
H.C. Starck Smelting GmbH & Co.KG*
|
Germany
|
|
Tungsten
|
Hitachi Ltd.
|
Japan
|
|
Tungsten
|
Hi-Temp
|
United States
|
|
Tungsten
|
Hunan Chenzhou Mining Co., Ltd.*
|
China
|
|
Tungsten
|
Hunan Chenzhou Mining Group Co*
|
China
|
|
Tungsten
|
Hunan Chenzhou Mining Group Co., Ltd.*
|
China
|
|
Tungsten
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
|
China
|
|
Tungsten
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin*
|
China
|
|
Tungsten
|
Hunan Chunchang Nonferrous Metals Co., Ltd.*
|
China
|
|
Tungsten
|
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.*
|
China
|
|
Tungsten
|
Hydrometallurg, JSC*
|
Russian Federation
|
|
Tungsten
|
Japan New Metals Co., Ltd.*
|
Japan
|
|
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.**
|
China
|
|
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
|
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 Xiushui Xianggan Nonferrous Metals Co., Ltd.*
|
China
|
|
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.**
|
China
|
|
Tungsten
|
JX Nippon Mining & Metals Co., Ltd.
|
Japan
|
|
Tungsten
|
JX Nippon Mining&Matel Co., Ltd
|
Japan
|
|
Tungsten
|
Kanto Denka Kogyo Co., Ltd.
|
Japan
|
|
Tungsten
|
Kennametal Fallon**
|
United States
|
|
Tungsten
|
Kennametal Huntsville*
|
United States
|
|
Tungsten
|
KYORITSU GOKIN CO.,LTD.
|
Japan
|
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.*
|
China
|
|
Tungsten
|
Nanchang Cemented Carbide Limited Liability Company
|
China
|
|
Tungsten
|
Niagara Refining LLC*
|
United States
|
* CFSP-compliant, based on CFSI
** CFSP-Active List
A - 24
|
Metal
|
Smelter name
|
Smelter Country
|
|
Tungsten
|
NingHua XingLuoKeng TungSten Mining CO.,LTD
|
China
|
|
Tungsten
|
North American Tungsten
|
Canada
|
|
Tungsten
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC*
|
Vietnam
|
|
Tungsten
|
Pobedit, JSC
|
Russian Federation
|
|
Tungsten
|
Sanher Tungsten Vietnam Co., Ltd.
|
Vietnam
|
|
Tungsten
|
SEMPSA Joyería Platería SA
|
Spain
|
|
Tungsten
|
Shaoguan Xinhai Rendan Tungsten Industry Co. Ltd*
|
China
|
|
Tungsten
|
Sumitomo
|
China
|
|
Tungsten
|
Sumitomo Metal Mining Co., Ltd.
|
China
|
|
Tungsten
|
TaeguTec
|
Korea, Republic Of
|
|
Tungsten
|
Tejing (Vietnam) Tungsten Co., Ltd.
|
United States
|
|
Tungsten
|
Tejing (Vietnam) Tungsten Co., Ltd.*
|
Vietnam
|
|
Tungsten
|
ULVAC, Inc.
|
Japan
|
|
Tungsten
|
Umicore Materials AG
|
Switzerland
|
|
Tungsten
|
Vietnam Youngsun Tungsten Industry Co., Ltd.*
|
Vietnam
|
|
Tungsten
|
Voss Metals Company, Inc
|
United States
|
|
Tungsten
|
WBH*
|
Austria
|
|
Tungsten
|
WBH,Wolfram [Austria]*
|
Austria
|
|
Tungsten
|
Wolfram Bergbau und Hütten AG*
|
Austria
|
|
Tungsten
|
Wolfram Company CJSC
|
Russian Federation
|
|
Tungsten
|
Xiamen Golden Egret Special Alloy Co. Ltd.
|
China
|
|
Tungsten
|
Xiamen H.C.*
|
China
|
|
Tungsten
|
Xiamen Honglu Tungsten Molybdenum 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 Cemented Carbide Group Co Ltd*
|
China
|