UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
_________________________
FORM SD
_________________________
Specialized Disclosure Report
_________________________
Pitney Bowes Inc.
(Exact name of registrant as specified in its charter)
_________________________
Delaware | 1-3579 | 06-0495050 | ||
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) | ||
World Headquarters
3001 Summer Street Road
Stamford, Connecticut 06926-0700
(Address of principal executive offices) (Zip Code)
John Thaler, Director, Global Environment, Health and Safety
(203) 922-4084
(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, 2017.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
In accordance with Section 1502 of the Dodd-Frank Financial Reform and Consumer Protection Act (the “Act”) and Rule 13p-1 under the Securities and Exchange Act of 1934 (the “Rule”), Pitney Bowes Inc. (the “Company”) has determined that it is subject to the reporting requirements under the Act and the Rule and that certain products that Pitney Bowes contracted to manufacture during calendar year 2017 contain “conflict minerals” as defined in the Rule (in the form of gold and the derivatives tantalum, tin and tungsten) necessary to the functionality of those products. The Company has undertaken a reasonable inquiry into the country of origin of the conflict minerals in our products to assess whether any of those conflict minerals originated in the Democratic Republic of Congo or an “adjoining country” as defined in the Rule or were “conflict minerals from recycled or scrap sources” as defined in the Rule. To maximize efficiency, we combined our inquiry with our due diligence activities. Our inquiry and due diligence activities are described in the Conflict Minerals Report attached hereto as Exhibit 1.02.
Conflict Minerals Disclosure
A copy of Pitney Bowes Inc.’s Conflict Minerals Report filed for the calendar year ended December 31, 2017 is publicly available at http://www.pitneybowes.com/us/our-company/corporate-responsibility).
Item 1.02 Exhibit
Pitney Bowes Inc.’s Conflict Minerals Report for the calendar year ended December 31, 2017 is filed as Exhibit 1.02 hereto.
Section 2 - Exhibits
Item 2.01 Exhibits
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 undersigned hereunto duly authorized.
Pitney Bowes Inc. (Registrant) | ||
/s/ Daniel J. Goldstein | ||
Daniel J. Goldstein | ||
Executive Vice President and Chief Legal & Compliance Officer | ||
Dated: May 31, 2018
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Exhibit 1.02
Pitney Bowes Inc. Conflict Minerals Report
(as required by Item 1.01 and 1.02 of Form SD)
Pitney Bowes Inc. (“we,” “us,” “our,” or the “Company”) submits this report pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934 and adopted by the Securities and Exchange Commission pursuant to Section 1502 of the Dodd-Frank Financial Reform and Consumer Protection Act (the “Act”). This report describes the inquiry the Company undertook to obtain information from internal and external sources to ascertain whether any Pitney Bowes product contains tantalum, tin, tungsten, or gold (“Conflict Minerals” or “3TG”) that originated in the Democratic Republic of the Congo or adjoining countries, as defined in the Act (collectively, the “Covered Countries”), and the due diligence Pitney Bowes conducted on the source and chain of custody of such minerals. This report covers parts and products manufactured or contracted to manufacture by the Company in the 2017 calendar year. Based on our inquiry, we have found that Conflict Minerals are necessary to the functionality or production of some of our products manufactured or contracted to manufacture in 2017.
Based on our due diligence for these 2017 products, our suppliers identified a total of 337 potential smelters or refiners of 3TG in their supply chains. However, 20 of these smelters or refiners are no longer included in the Smelter Reference List of RMI’s (formerly the Conflict-Free Sourcing Initiative or CFSI) Conflict Minerals Reporting Template based on RMI’s determination that these entities did not actually engage in smelting or refining activities or are no longer in operation. Of the 317 remaining smelters or refiners, 252 (or 80%) were listed by RMI as conformant with the Responsible Minerals Assurance Process (formerly the Conflict Free Smelter Program) or in process to become conformant (as of December 1, 2017). The remaining 65 smelters or refiners identified are not yet participating in an auditing program; however, we have no information that would indicate that these smelters or refiners sourced 3TG from the Covered Countries. For a list of the reported entities identified by our suppliers that are also identified as smelters or refiners of 3TG in RMI’s Smelter Reference List, please refer to Appendix A.
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry to determine whether any of the necessary conflict minerals in our products originated in the Covered Countries or were from recycled or scrap sources. To make this determination, we focused on engaging our direct suppliers to identify the smelters and refiners of necessary conflict minerals that may have been contained in our products and that are recognized by the RMI to be processors of conflict minerals, and reviewing available information on the sourcing of conflict minerals by these smelters and refiners.
As a downstream company, we are several levels removed from mining minerals. We did not buy any minerals directly from mines, smelters, or refiners for use in these 2017 products. Information regarding the countries from which the identified smelters and refiners may source 3TG was not readily available to us and was not always provided to us by the Surveyed Suppliers (defined below). As part of our efforts to determine the mine or location of origin of 3TG in our products, we searched for publicly available information on the sourcing practices of identified smelters and refiners. In some instances, conflict mineral policies and related resources were available on the RMI website for identified smelters and refiners that are listed as conformant with Responsible Minerals Assurance Process assessment protocols. However, we were unable to locate country of origin information for the Conflict Minerals processed by many of the identified smelters and refiners. In addition, many of the Surveyed Suppliers identified all of the smelters and refiners potentially associated with all of their product offering and did not always limit the information provided to products supplied to Pitney Bowes. To the extent we located information on the potential origin of 3TG processed by these conformant smelters or refiners, we identify those countries in Appendix B. However, due to limitations discussed above, Pitney Bowes is unable to confirm whether necessary 3TG metals contained in our products in fact originated in any of these countries.
Our due diligence activities are further described in this report.
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1. Pitney Bowes’ Design of Due Diligence
A. Due Diligence Framework
We designed our due diligence to conform, in all material respects, with the framework set out in the “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” and related Supplements on Tin, Tantalum and Tungsten and on Gold (“OECD Guidance”), published by the Organisation for Economic Cooperation and Development (the “OECD”). Since the Company does not buy Conflict Minerals directly from mines, smelters or refiners, we must rely on our suppliers to provide us with information regarding the source of the Conflict Minerals contained in the products and parts those suppliers provide to us. Our direct suppliers are similarly reliant upon information provided by their suppliers. In this regard, we have designed our due diligence to leverage the due diligence tools developed by RMI, including a supplier survey based on the Template, which is designed to help companies identify the smelters and refiners that process the Conflict Minerals in a company’s supply chain. We have incorporated the following five-step, risk-based approach to 3TG due diligence based on OECD Guidance into the design of our Conflict Minerals due diligence program:
• | establish and maintain appropriate internal management systems to identify and manage the 3TG in our global supply chain; |
• | identify and assess any risks associated with the use of 3TG in our supply chain by obtaining and evaluating 3TG sourcing information from suppliers; |
• | design and implement a strategy to respond to 3TG risks in our supply chain; |
• | support independent auditing of smelter and refiner due diligence practices; and |
• | report publicly on supply chain due diligence. |
B. Scope of Due Diligence.
In order to determine if products manufactured or contracted to manufacture by Pitney Bowes contain 3TG sourced from Covered Countries, we sought out industry best practices, reviewed current guidance from various associations such as the OECD and the Information Technology Industry Council (“ITIC”), and attended industry association meetings to assess how other multinational corporations were approaching Conflict Minerals compliance.
Working with outside consultants, we developed a Conflict Minerals survey based on the Template and guidance from the RMI and ITIC. We began with a list of the top 100 suppliers who provide nearly 95% of the total dollar spend for Pitney Bowes. Ultimately we sent the Conflict Minerals survey to the 57 suppliers who (the “Surveyed Suppliers”) are impacted by this rule, eliminating suppliers that provide Pitney Bowes with products that either do not contain tin, tantalum, tungsten or gold, or otherwise supplied equipment that is out of scope. We asked the Surveyed Suppliers to respond with certain information, including their Conflict Minerals policies, usage of 3TG, and the smelters and refiners of Conflict Minerals in their supply chains.
The Surveyed Suppliers who completed the survey were asked to attest to the accuracy of their survey responses. The Product Compliance Team (defined below) monitored supplier responses to our surveys and contacted the Surveyed Suppliers who submitted incomplete responses or who failed to respond. We requested updated submittals from the Surveyed Suppliers that submitted responses with a less than 75% response rate from their supply chain and suppliers that listed smelters with inaccurate information. Data received from Surveyed Suppliers through April 6, 2018 have been included in this report.
We collected and tracked the survey responses in our product compliance database for consolidation, validation, and further analysis. We also generated monthly status reports to track and review our progress in data collection and evaluate which suppliers needed additional help in completing the survey.
C. Due Diligence Results for Pitney Bowes’ 2017 Products
Based on our due diligence, we determined that Conflict Minerals were necessary to the functionality or production of various products from our hardware product offerings list, which includes a varied array of equipment that processes direct mail and/or enables transactional mail management and analytics that we manufactured or contracted to manufacture in 2017.
Some examples of these products include: postage meters, low-/medium-/high-volume mailing systems that can weigh, seal
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and apply postage to envelopes; inserters; sorters; folders; mail openers; tabbers; scales; mail kiosks; monitors; printers; accessories; and peripherals.
D. Pitney Bowes’ Conflict Minerals Disclosure Posting
We have made public our activities related to Conflict Minerals in our Corporate Responsibility Report published in October 2017. We have also posted this Conflict Minerals Report on our website (follow this link for more information: Pitney Bowes Corporate Responsibility).
2. Pitney Bowes’ Due Diligence Measures Undertaken for 2017 Products
In an effort to continue to identify and mitigate any risk that the use of 3TG in our products going forward may benefit armed groups in the Covered Countries, we have incorporated the relevant aspects of the OECD Guidance (as summarized in the sections that follow) into our risk management program for product stewardship requirements (including Conflict Minerals).
A. Development of an Internal, Strong Management System.
1. High level management oversight
In order to provide effective management support for, and high level escalation of issues relating to, the Company’s overall supply chain due diligence efforts (inclusive of conflict minerals), we formed two cross-functional teams: the Environmental Product Compliance Team (the “Product Compliance Team”) and the Environmental Committee (the “Environmental Committee”).
The Product Compliance Team is comprised of representatives from Procurement, Supply Chain, Quality, Engineering, Environmental Health and Safety (“EHS”), Finance and Global Product Line Management and other support groups. This team is responsible for assisting the Company in meeting the requirements of global product-compliance regulations.
The Environmental Committee is made up of departmental managers holding senior positions in various departments in the company including: Procurement, Global Supply Chain, Engineering, EHS, Quality, Ethics and Compliance, Legal, Finance, Business Continuity, Global Product Line Management, Enterprise Risk and Internal Audit and oversees the work of the Product Compliance Team. The Environmental Committee is tasked with providing guidance regarding environmental product compliance, authorizing the financial and human resources needed for product compliance, and enforcing corrective action measures within Company operations and within our supply chain. The Environmental Committee reports potential issues and company risks to the Enterprise Risk Management team. The Enterprise Risk Management team, comprised or members or senior management from various functions and business units, reviews the Company’s efforts in managing a wide range of risks of the Company.
2. Pitney Bowes’ Conflict Minerals policy and procedures
We established a conflict minerals policy to guide our communications with and expectations for suppliers regarding Conflict Minerals. It is the Company’s goal that we will not knowingly manufacture or contract to manufacture products that include Conflict Minerals that originate from the Covered Countries, unless they were processed by smelters and refiners that are certified as “conflict free” or came from recycled or scrap sources. We communicated our expectation that our Surveyed Suppliers source products, parts and components from socially responsible sources and conduct reasonable due diligence on their supply chains in an effort to assure that Conflict Minerals are not knowingly sourced from the Covered Countries unless they were processed by smelters and refiners that are conformant with the Responsible Minerals Assurance Process or came from recycled or scrap sources.
We also adopted certain procedures and took the following steps regarding our use of 3TG:
• | updated our Supplier Code of Conduct with a new section that outlines Conflict Minerals and other product compliance requirements; |
• | revised our engineering standards and specifications to include requirements to specify that suppliers must meet Section 1502(4) of the Dodd Frank Act; |
• | amended our audit templates to include periodic audits of supplier requirements with respect to products containing 3TG; |
• | developed a product review process that includes consideration of Conflict Minerals issues; |
• | updated and distributed to all new suppliers our contractual language regarding certification that 3TG from Covered Countries is conflict free or came from recycled or scrap sources; |
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• | published Conflict Minerals information on our website and in our Corporate Responsibility Report; |
• | added Conflict Minerals to the Enterprise Risk Management review activity to ensure frequent review by our management; |
• | included review of Conflict Minerals supply chain data and related processes to the Company’s standardized environmental compliance reviews of key suppliers; |
• | conducted training classes through our automated training tool, webex or in person that educated relevant employees; |
• | educated Suppliers and other partners regarding Conflict Minerals during some business reviews; |
• | required Surveyed Suppliers to complete surveys with the goal of identifying the smelters and refineries used to process Conflict Minerals in their supply chain; |
• | developed internal policies, written procedures, tools and training to ensure effective implementation of our Conflict Minerals management program; |
• | tracked and reported supplier data in a product compliance information database; |
• | developed and implemented a supplier escalation protocol to ensure consistent and thorough management of unresponsive suppliers - this protocol documents our supplier engagement and how we interact with unresponsive suppliers or suppliers who provide incomplete, questionable, or indeterminable information; and |
• | benchmarked Conflict Minerals best practices with other multinational corporations. |
We also revised our written internal product environmental compliance requirements to include Conflict Minerals requisites as documented in our Environmental Compliance Standard Operating System.
3. Pitney Bowes’ system of controls and transparency over the 3TG supply chain
As part of the Company’s broader requirement that our suppliers provide us with accurate and complete information relating to the sources of all substances contained in any product, part or component they provide to us, we required that Surveyed Suppliers provide us with information on Conflict Minerals contained in such products, parts, or components.
Surveyed Suppliers who failed to respond to our request for data were subject to additional evaluation to determine whether further engagement or escalation was necessary.
4. Pitney Bowes’ engagement with suppliers
The Company has multiple methods to encourage our suppliers to commit to our policies requiring responsible supplier operations. We have communicated our Conflict Minerals requirements to our Suppliers and other product stewardship requirements, as applicable, to our global supply chain. In connection with our data collection efforts, we have explained to our Suppliers our requirements that they conduct their operations as socially responsible suppliers. In addition, we have revised our supplier form contract wording to include compliance with our Conflict Minerals efforts. Our supplier contracts have long contained provisions giving us the right to conduct unannounced visits to supplier sites and to request documentation to confirm the supplier’s compliance with our policies and contractual requirements. Our Surveyed Suppliers have received training regarding Conflict Minerals requirements and completion of our product compliance database.
5. Pitney Bowes’ Company-level grievance mechanism
For many years, Pitney Bowes has maintained an Ethics Help Line which is available toll-free, 24 hours a day, seven days a week. The Ethics Help Line is operated by an outside firm and enables employees, clients and others to make inquiries and report concerns about potential violations of Company policy or the law, in many languages, without fear of retaliation. Anyone can contact the Ethics Help Line to report any concerns about Conflict Minerals that may be contained in our products.
B. Identification and Assessment of Risk in Our Supply Chain.
The Company continues its program of conducting supply chain due diligence and risk assessment on supplier sources of 3TGs as described above in Section 1.
C. Strategy for Responding to Identified Risks in Our 3TG Supply Chain.
As described above, the Product Compliance Team monitored supplier responses to our surveys and contacted Surveyed Suppliers who submitted incomplete responses or who failed to respond so that we could understand what was preventing them from submitting a full and final attestation regarding their product line. The Product Compliance Team also reviewed the data from the product compliance database to determine which Surveyed Suppliers had data gaps, had raised questions or had not been responsive. Any Surveyed Suppliers that were considered non-responsive or higher risk were escalated to designated internal teams and management for further evaluation as they were identified.
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We also reported the findings and information gathered through our inquiry and due diligence to Pitney Bowes senior management.
D. Support for Independent Third-party Audits of Supply Chain Due Diligence
Since we do not have direct relationships with smelters or refiners, we did not perform direct audits of these entities’ supply chains of Conflict Minerals. However, we supported the development and implementation of smelter and refiner sourcing audits conducted by independent third parties and industry groups, such as the RMI’s Responsible Minerals Assurance Process, through our conflict minerals policy and expectations regarding conflict-free sourcing of minerals from the Covered Countries.
3. Future Actions to Further Minimize Any Risk of Conflict Minerals Benefitting Armed Groups
The Company will continue to request information from our supply chain in order to meet the requirements of the Rule. Where there is reason to believe that a supplier is not adopting a Conflict Minerals policy or providing the necessary data to us, we will work with the supplier to address the issue. In the event of continued supplier deficiencies, we will consider appropriate measures including, if and as appropriate, termination of our relationship with a supplier.
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Appendix A
List of Smelters / Refiners Identified by the Surveyed Suppliers
The following list provides the name, location and status of smelters and refiners identified by the Surveyed Suppliers. Pitney Bowes is unable to confirm that any or all smelters and refiners in this list processed the necessary 3TG metals contained in our products, since a number of the Surveyed Suppliers identified all smelters and refiners in their total supply chain and did not limit their responses to the specific products supplied to Pitney Bowes.
Smelter and refiner names and locations were drawn from the Smelter Reference List in the latest version of the Template. Smelters or refiners designated as “Conformant” were listed by RMI as conformant with Responsible Minerals Assurance Process assessment protocols as of December 1, 2017 ; smelters or refiners designated as “Active” were listed by RMI as of this date as having committed to undergo an audit or as participating in a similar assessment program such as the LBMA Responsible Gold Certification or Responsible Jewelry Council’s Chain-of-Custody Certification. Smelters or refiners listed as “In Communication” or “Outreach Required” have begun discussions with or will be encouraged to participate in the RMAP audit. Entities that are no longer recognized as smelters or refiners are not included in the reference list below (for example, if they are no longer included in the Smelter Reference List of the Template based on RMI’s determination that the entity did not actually engage in smelting or refining activities or if we or RMI believe they are no longer in operation).
Metal | Smelter /Refiner Name | Smelter/Refiner Location | RMI Audit Status |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Non-Compliant |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Compliant |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant |
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Compliant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Compliant |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Compliant |
Gold | Argor-Heraeus S.A. | SWITZERLAND | Compliant |
Gold | Asahi Pretec Corp. | JAPAN | Compliant |
Gold | Asahi Refining Canada Ltd. | CANADA | Compliant |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Compliant |
Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Not Yet Participating |
Gold | AU Traders and Refiners | SOUTH AFRICA | Compliant |
Gold | Aurubis AG | GERMANY | Compliant |
Gold | Bangalore Refinery | INDIA | Active |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant |
Gold | Boliden AB | SWEDEN | Compliant |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant |
Gold | Caridad | MEXICO | In Communication |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Compliant |
Gold | Cendres + Metaux S.A. | SWITZERLAND | Compliant |
Gold | Chimet S.p.A. | ITALY | Compliant |
Gold | Chugai Mining | JAPAN | In Communication |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Outreach Required |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Outreach Required |
Gold | DODUCO GmbH | GERMANY | Compliant |
Gold | Dowa | JAPAN | Compliant |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Compliant |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant |
Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | Non Compliant |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Compliant |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Outreach Required |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Outreach Required |
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Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Outreach Required |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Compliant |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Compliant |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Outreach Required |
Gold | Guangdong Jinding Gold Limited | CHINA | Outreach Required |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Outreach Required |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Outreach Required |
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Compliant |
Gold | Heimerle + Meule GmbH | GERMANY | Compliant |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Compliant |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Outreach Required |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | In Communication |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Compliant |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant |
Gold | Istanbul Gold Refinery | TURKEY | Compliant |
Gold | Italpreziosi | ITALY | Compliant |
Gold | Japan Mint | JAPAN | Compliant |
Gold | Jiangxi Copper Co., Ltd. | CHINA | Compliant |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Compliant |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Outreach Required |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | In Communication |
Gold | Kazzinc | KAZAKHSTAN | Compliant |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Compliant |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Active |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Compliant |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Compliant |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Outreach Required |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Outreach Required |
Gold | Lingbao Gold Co., Ltd. | CHINA | Outreach Required |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Outreach Required |
Gold | L'Orfebre S.A. | ANDORRA* | Outreach Required |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Outreach Required |
Gold | Marsam Metals | BRAZIL | Compliant |
Gold | Materion | UNITED STATES OF AMERICA | Compliant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Compliant |
Gold | Metalor Technologies S.A. | SWITZERLAND | Compliant |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Compliant |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Compliant |
Gold | Mitsubishi Materials Corporation | JAPAN | Compliant |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant |
Gold | Modeltech Sdn Bhd | MALAYSIA | Active |
Gold | Morris and Watson | NEW ZEALAND | Outreach Required |
Gold | Morris and Watson Gold Coast | AUSTRALIA | Outreach Required |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Compliant |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Active |
Gold | Nihon Material Co., Ltd. | JAPAN | Compliant |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant |
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Gold | PAMP S.A. | SWITZERLAND | Compliant |
Gold | Pease & Curren | UNITED STATES OF AMERICA | Outreach Required |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Outreach Required |
Gold | Planta Recuperadora de Metales SpA | CHILE | Active |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Compliant |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant |
Gold | PX Precinox S.A. | SWITZERLAND | Compliant |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant |
Gold | Remondis Argentia B.V. | NETHERLANDS | Active |
Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | Compliant |
Gold | Royal Canadian Mint | CANADA | Compliant |
Gold | SAAMP | FRANCE | Compliant |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Outreach Required |
Gold | Safimet S.p.A* | ITALY* | Outreach Required |
Gold | SAFINA A.S. | CZECH REPUBLIC | Active |
Gold | Sai Refinery | INDIA | Outreach Required |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Compliant |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | In Communication |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | Compliant |
Gold | Schone Edelmetaal B.V. | NETHERLANDS | Compliant |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Compliant |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Outreach Required |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Compliant |
Gold | So Accurate Group, Inc. | UNITED STATES OF AMERICA | Outreach Required |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Compliant |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Outreach Required |
Gold | Sudan Gold Refinery | SUDAN | Outreach Required |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
Gold | T.C.A S.p.A | ITALY | Compliant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Compliant |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Outreach Required |
Gold | Tony Goetz NV | BELGIUM | Active |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | In Communication |
Gold | Torecom | KOREA, REPUBLIC OF | Compliant |
Gold | Umicore Brasil Ltda. | BRAZIL | Compliant |
Gold | Umicore Precious Metals Thailand | THAILAND | Compliant |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Compliant |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Compliant |
Gold | Valcambi S.A. | SWITZERLAND | Compliant |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Compliant |
Gold | WIELAND Edelmetalle GmbH | GERMANY | Compliant |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Compliant |
Gold | Yokohama Metal Co., Ltd. | JAPAN | Compliant |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Outreach Required |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant |
Tantalum | Asaka Riken Co., Ltd. | JAPAN | Compliant |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Compliant |
Tantalum | Duoluoshan | CHINA | Compliant |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Compliant |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | Compliant |
Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Compliant |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Compliant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant |
8
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Compliant |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Compliant |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Compliant |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Compliant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Compliant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant |
Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | CHINA | Compliant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
Tantalum | KEMET Blue Metals | MEXICO | Compliant |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Compliant |
Tantalum | LSM Brasil S.A. | BRAZIL | Compliant |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Compliant |
Tantalum | Mineracao Taboca S.A. | BRAZIL | Compliant |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant |
Tantalum | NPM Silmet AS | ESTONIA | Compliant |
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | Compliant |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | Compliant |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Compliant |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | Compliant |
Tantalum | Telex Metals | UNITED STATES OF AMERICA | Compliant |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Compliant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant |
Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | Compliant |
Tin | Alpha | UNITED STATES OF AMERICA | Compliant |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Outreach Required |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Compliant |
Tin | China Tin Group Co., Ltd. | CHINA | Compliant |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Outreach Required |
Tin | CV Ayi Jaya | INDONESIA | Compliant |
Tin | CV Dua Sekawan | INDONESIA | Compliant |
Tin | CV Gita Pesona | INDONESIA | Compliant |
Tin | CV Serumpun Sebalai | INDONESIA | Compliant |
Tin | CV Tiga Sekawan | INDONESIA | Compliant |
Tin | CV United Smelting | INDONESIA | Compliant |
Tin | CV Venus Inti Perkasa | INDONESIA | Compliant |
Tin | Dowa | JAPAN | Compliant |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Active |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Compliant |
Tin | Estanho de Rondonia S.A. | BRAZIL | Outreach Required |
Tin | Fenix Metals | POLAND | Compliant |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Compliant |
Tin | Gejiu Jinye Mineral Company | CHINA | Compliant |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Compliant |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | In Communication |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Compliant |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Compliant |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Compliant |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Compliant |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Compliant |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Compliant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Compliant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant |
9
Tin | Melt Metais e Ligas S.A. | BRAZIL | Compliant |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Compliant |
Tin | Metallo Belgium N.V. | BELGIUM | Compliant |
Tin | Metallo Spain S.L.U. | SPAIN | Compliant |
Tin | Mineracao Taboca S.A. | BRAZIL | Compliant |
Tin | Minsur | PERU | Compliant |
Tin | Mitsubishi Materials Corporation | JAPAN | Compliant |
Tin | Modeltech Sdn Bhd | MALAYSIA | Active |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Active |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Outreach Required |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant |
Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Compliant |
Tin | PT Aries Kencana Sejahtera | INDONESIA | Compliant |
Tin | PT Artha Cipta Langgeng | INDONESIA | Compliant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant |
Tin | PT Babel Inti Perkasa | INDONESIA | Compliant |
Tin | PT Bangka Prima Tin | INDONESIA | Compliant |
Tin | PT Bangka Tin Industry | INDONESIA | Compliant |
Tin | PT Belitung Industri Sejahtera | INDONESIA | Compliant |
Tin | PT Bukit Timah | INDONESIA | Compliant |
Tin | PT DS Jaya Abadi | INDONESIA | Compliant |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Compliant |
Tin | PT Inti Stania Prima | INDONESIA | Compliant |
Tin | PT Karimun Mining | INDONESIA | Compliant |
Tin | PT Kijang Jaya Mandiri | INDONESIA | Compliant |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Compliant |
Tin | PT Menara Cipta Mulia | INDONESIA | Compliant |
Tin | PT Mitra Stania Prima | INDONESIA | Compliant |
Tin | PT O.M. Indonesia | INDONESIA | Compliant |
Tin | PT Panca Mega Persada | INDONESIA | Compliant |
Tin | PT Prima Timah Utama | INDONESIA | Compliant |
Tin | PT Refined Bangka Tin | INDONESIA | Compliant |
Tin | PT Sariwiguna Binasentosa | INDONESIA | Compliant |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Compliant |
Tin | PT Sukses Inti Makmur | INDONESIA | Compliant |
Tin | PT Sumber Jaya Indah | INDONESIA | Compliant |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Compliant |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Compliant |
Tin | PT Tinindo Inter Nusa | INDONESIA | Compliant |
Tin | PT Tommy Utama | INDONESIA | Compliant |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | Compliant |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Compliant |
Tin | Soft Metais Ltda. | BRAZIL | Compliant |
Tin | Super Ligas | BRAZIL | Outreach Required |
Tin | Thaisarco | THAILAND | Compliant |
Tin | Thaisarco | THAILAND | Compliant |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Outreach Required |
Tin | VQB Mineral and Trading Group JSC | VIET NAM | Compliant |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Compliant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Compliant |
Tin | Yunnan Copper Industry Co., Ltd. | CHINA* | Outreach Required |
Tin | Yunnan Tin Company Limited | CHINA | Compliant |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Compliant |
Tungsten | ACL Metais Eireli | BRAZIL | Compliant |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Compliant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Active |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant |
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Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Non Compliant |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Compliant |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Compliant |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Compliant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Compliant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Active |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Compliant |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Outreach Required |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Outreach Required |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Compliant |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Compliant |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Compliant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Compliant |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Compliant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Compliant |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Compliant |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Compliant |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Compliant |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Compliant |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Compliant |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Compliant |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Compliant |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Compliant |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Compliant |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant |
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APPENDIX B
Countries of Origin
Potential countries of origin for 3TG processed by conformant smelters or refiners may include (but are not necessarily limited to):
ANDORRA |
AUSTRALIA |
AUSTRIA |
BELGIUM |
BOLIVIA |
BRAZIL |
CANADA |
CHILE |
CHINA |
CZECH REPUBLIC |
ESTONIA |
FRANCE |
GERMANY |
INDIA |
INDONESIA |
ITALY |
JAPAN |
KAZAKHSTAN |
KOREA, REPUBLIC OF |
KYRGYZSTAN |
LITHUANIA |
MACEDONIA |
MALAYSIA |
MEXICO |
NETHERLANDS |
NEW ZEALAND |
PERU |
PHILIPPINES |
POLAND |
RUSSIAN FEDERATION |
SAUDI ARABIA |
SINGAPORE |
SOUTH AFRICA |
SPAIN |
SUDAN |
SWEDEN |
SWITZERLAND |
TAIWAN |
THAILAND |
TURKEY |
UNITED ARAB EMIRATES |
UNITED STATES OF AMERICA |
UZBEKISTAN |
VIET NAM |
ZIMBABWE |
12