UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D. C. 20549
FORM SD
Specialized Disclosure Report
| | |
| BABCOCK & WILCOX ENTERPRISES, INC. |
| (Exact name of registrant as specified in its charter) |
| | | | | | | | |
| DELAWARE | 001-36876 | 47-2783641 |
| (State or other jurisdiction | (Commission File | (IRS Employer Identification No.) |
| of incorporation or organization) | Number) | |
| | |
| 1200 EAST MARKET STREET, SUITE 650 | | |
| AKRON, OHIO | | 44305 |
| (Address of principal executive officers) | | (Zip Code) |
|
| Louis Salamone |
| Executive Vice President, Chief Financial Officer |
| (330) 753-4511 |
| (Name and Telephone number, including area code, of the person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
SECTION 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report.
This Specialized Disclosure Report on Form SD of Babcock & Wilcox Enterprises, Inc. is for the period from January 1, 2023 to December 31, 2023. In this Form SD, unless the context otherwise indicates, “B&W,” “we,” “us” and “our” mean Babcock & Wilcox Enterprises, Inc. and its consolidated subsidiaries.
We identified tin, tantalum, tungsten and gold (“3TG”) as necessary to the functionality or production of products that we manufactured or contracted to manufacture during the period from January 1, 2023 to December 31, 2023 (the “Reporting Period”). Accordingly, we are filing a Conflict Minerals Report as Exhibit 1.01 to this Form SD.
Our website address is www.babcock.com. We will make available through the Investor Relations section of this website under “SEC Filings,” this Form SD, including the Conflict Minerals Report, as soon as reasonably practicable after we electronically file our Form SD with the SEC. We have also posted our Conflict Minerals Policy on our website. Reference to our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
Item 1.02 Exhibit.
As specified in Section 2 of Form SD, we are hereby filing our Conflict Minerals Report as Exhibit 1.01 to this Form SD.
SECTION 2 - Exhibits
Item 2.01 Exhibits.
The following exhibit is filed as part of this annual, specialized disclosure report on Form SD:
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Exhibit
number | Description |
| |
| Conflict Minerals Report for the year ended December 31, 2023 as required by Items 1.01 and 1.02 of this Form. |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.
| | | | | | | | |
| | BABCOCK & WILCOX ENTERPRISES, INC. |
| | |
| May 23, 2024 | By: | /s/ Louis Salamone |
| | Louis Salamone |
| | Executive Vice President, Chief Financial Officer (Principal Financial and Accounting Officer and Duly Authorized Representative) |
EXHIBIT 1.01
BABCOCK & WILCOX ENTERPRISES, INC.
CONFLICT MINERALS REPORT
YEAR ENDED DECEMBER 31, 2023
Introduction
This Conflict Minerals Report (this "Report") has been prepared by management of Babcock & Wilcox Enterprises, Inc. In this Report, unless the context otherwise indicates, "B&W," "we," "us," the "Company" and "our" mean Babcock & Wilcox Enterprises, Inc. and its consolidated subsidiaries. This Report for the year ended December 31, 2023 (the “Reporting Period”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines “conflict minerals” as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold (“3TG”) as necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.
As described in this Report, B&W has reason to believe that some of the 3TG present in its supply chain may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”). Therefore, we performed a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TG in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we cannot rule out the possibility that we may have some suppliers that sourced 3TG from the Covered Countries and proceeded to conduct due diligence on our in scope suppliers.
Forward looking statements
Statements we make in this Report, which express a belief, expectation or intention, as well as those that are not historical fact, are forward- looking statements, including statements relating to our compliance efforts and expected actions identified under the “Steps to be taken” section of this Report. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other things, our ability to implement improvements in our conflict minerals program and identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see our other filings with the Securities and Exchange Commission (“SEC”), including our Annual Report on Form 10-K for the year ended December 31, 2023. B&W cautions not to place undue reliance on these forward-looking statements, which speak only as of the date of this Report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.
Overview
B&W is a growing, globally-focused renewable, environmental and thermal technologies provider with over 155 years of experience providing diversified energy and emissions control solutions to a broad range of industrial, electrical utility, municipal and other customers. B&W’s innovative products and services are organized into three market-facing segments. Our reportable segments are as follows:
•Babcock & Wilcox Renewable: Technologies for efficient and environmentally sustainable power and heat generation, including waste-to-energy, biomass-to-energy and black liquor systems for the pulp and paper industry. Our technologies support a circular economy, diverting waste from landfills to use for power generation and replacing fossil fuels, while recovering metals and reducing emissions.
•Babcock & Wilcox Environmental: A full suite of emissions control and environmental technology solutions for utility, waste to energy, biomass-to-energy, carbon black and industrial steam generation applications around the world. Our broad experience includes systems for cooling, ash handling, particulate control, nitrogen oxides and sulfur dioxides removal, chemical looping for carbon control, and mercury control.
•Babcock & Wilcox Thermal: Steam generation equipment, aftermarket parts, construction, maintenance and field services for plants in the power generation, oil and gas, and industrial sectors. We have an extensive global base of installed equipment for utilities and general industrial applications including refining, petrochemical, food processing, metals and others.
Our business depends significantly on the capital, operations and maintenance expenditures of global electric power generating companies, including renewable and thermal powered heat generation industries and industrial facilities with environmental compliance policy requirements. Several factors may influence these expenditures, including:
•climate change initiatives promoting environmental policies which include renewable energy options utilizing waste-to-energy or biomass to meet legislative requirements and clean energy portfolio standards in the United States, Europe, Middle East and Asia;
•regulations requiring environmental improvements in various industries and global markets;
•expectations regarding future governmental requirements to further limit or reduce greenhouse gas and other emissions in the United States, Europe and other international climate change sensitive countries;
•prices for electricity, along with the cost of production and distribution including the cost of fuels within the United States, Europe, Middle East and Asia;
•demand for electricity and other end products of steam-generating facilities;
•level of capacity utilization at operating power plants and other industrial uses of steam production;
•maintenance and upkeep requirements at operating power plants, including to address the accumulated effects of usage;
•overall strength of the industrial industry;
•ability of electric power generating companies and other steam users to raise capital; and
•the impact of geopolitical conflicts, including ongoing conflicts in Ukraine and the Middle East.
Customer demand is heavily affected by the variations in our customers' business cycles and by the overall economies and energy, environmental and noise abatement needs of the countries in which they operate.
Our products
We conducted an analysis of our products to determine which of our products were likely to contain 3TG. We have identified 3TG in products within each of our business segments that are necessary to the
functionality or production of products that we manufactured or contracted to manufacture during the Reporting Period.
Conflict minerals policy
We have adopted a conflict minerals policy, as follows, which is also publicly available on our website at “https://investors.babcock.com/assets/Governance-Documents/Conflict-Minerals-Policy.pdf”. The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
We support sourcing components and materials from companies that share our values regarding respect for human rights, ethics and environmental responsibility. We are committed to complying with the SEC disclosure requirements and are working with our suppliers to perform reasonable country of origin inquiries and due diligence in determining the potential for conflict minerals in our supply chain and products.
We expect our suppliers to partner with us in our commitment to compliance and have designed our efforts to align with conflict minerals reporting rules.
Description of RCOI
Our operations use materials, such as carbon and alloy steels in various forms and components and accessories for assembly, which are available from numerous sources. We generally purchase materials and components as needed for individual contracts.
As noted above, we manufacture a variety of products for which materials included in those products may differ from year to year. These products are highly complex, typically containing thousands of parts from many suppliers throughout the world. We may purchase the same materials from multiple different suppliers and distributors. These suppliers and distributors often obtain their materials from lower tier suppliers. Accordingly, our supply chain is deep and identifying the ultimate source of materials supplied to us is difficult. We rely on our direct suppliers to work with their suppliers to provide information on the smelters and origin of the 3TG contained in components and materials supplied to us.
During the Reporting Period, our compliance efforts included both our domestic and our international locations. For each of the products (or subassemblies) that we identified as containing 3TG necessary to their functionality or production, we identified the suppliers that provided the materials comprising each of these products. We specifically identified each supplier that provided the materials containing the 3TG that we identified, as the 3TG in these products and related supplier base was limited.
To determine whether necessary 3TGs in our products originated in Covered Countries, we retained Assent Compliance (“Assent”), our third party service provider, to assist us in reviewing our supply chain and identifying risks. We provided a list composed of suppliers associated with the covered products to Assent for upload to the Assent Compliance Manager tool (“ACM”).
B&W utilized the RBA-GeSI Conflict Minerals Reporting Template (“CMRT”) version 6.0 or higher to conduct a survey of all in scope suppliers. During the supplier survey, we contacted suppliers via the ACM, a software-as-a-service (SaaS) platform provided by Assent that enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the
OECD Guidance process expectations by evaluating the quality of each supplier response. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, question 1 of the CMRT asks suppliers whether any of the 3TGs are intentionally added or used in the products or in the production process. Question 2 also asks if any 3TGs remain in their products. We also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process. We conducted this analysis based on the following criteria:
•The company supplies packaging only (excluding labels)
•The company supplies us with items that do not end up in our products (including equipment used to make our products)
•The company is a test lab
•The company is a service provider only
•The company is in active litigation with B&W
Assent requested that all suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. B&W directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested such suppliers to complete the CMRT form and submit such form to Assent.
Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT.
All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regards to invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. As of May 9, 2024, there were 7 invalid supplier submissions that could not be corrected.
Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the Responsible Mineral Initiative (“RMI”) and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TGs. Our suppliers identified a total of 355 smelters and refiners that appear on the lists maintained by RMI. Of these 355 smelters and refiners, 238 are validated as conflict free by RMI or a cross-recognized initiative.
Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TGs contained in our products.
Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the conflict minerals in question.
As of May 9, 2024, there were 1,179 suppliers in scope of the conflict minerals program and 624 provided a completed CMRT. B&W’s total response rate for this reporting year was 53%. These metrics are summarized in the table below in order to assess progress over time:
| | | | | | | | | | | | | | | | | |
| Year | Suppliers in Scope | | % Responded | | % Invalid |
| | | | | |
| RY 2021 | 1,453 | | | 48 | % | | 0.9 | % |
| RY 2022 | 1,752 | | | 44 | % | | 1.1 | % |
| RY 2023 | 1,179 | | | 53 | % | | 0.6 | % |
Due diligence
Design of due diligence
We designed our due diligence measures to conform, in all material respects, with the framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“the Guidance”) and the related Supplements for gold, tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:
1.Establishing strong company management systems regarding conflict minerals;
2.Identifying and assessing risks in our supply chain;
3.Designing and implementing a strategy to respond to identified risks in our supply chain;
4.Utilizing independent third-party audits of supply chain diligence; and
5.Reporting annually on our supply chain due diligence
Due diligence requires B&W’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as we cannot fully own this process. However, through continued outreach and process validation, this aligns with industry standards and market expectations for downstream companies’ due diligence.
We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, B&W does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.
The Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we
rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.
Due diligence performed
1. Establish strong company management systems
Conflict minerals policy
We established a Conflict Minerals Policy related to our sourcing of 3TG as described in full in the “Conflict Minerals Policy” section above and posted this policy on our website at “https://investors.babcock.com/assets/Governance-Documents/Conflict-Minerals-Policy.pdf” within the “Investors” section under “Corporate Governance.” The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
Internal team
We commissioned a Conflict Minerals Steering Committee comprised of individuals in management positions across the procurement, legal and finance functions. The Conflict Minerals Steering Committee is led by members of our senior management. The Conflict Minerals Steering Committee governs our conflict minerals compliance effort and is responsible for providing guidance and direction for the implementation of our conflict minerals program.
We also use a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that we will undertake with suppliers in regards to conflict minerals. The use of Assent and its tools has allowed us to assist our suppliers in understanding our expectations and requirements with respect to conflict minerals compliance.
We leverage Assent’s Managed Services in order to work with dedicated program specialists who support B&W’s conflict minerals program. We communicate regularly with the Assent team in order to receive updates on program status.
Control systems and grievance mechanism
We do not typically have a direct relationship with smelters and refiners. However, we have controls in place designed to uphold our core values and ethical standards in all interactions with customers, vendors, suppliers, shareholders, fellow employees and others. These controls include a Code of Business Conduct and a Supplier Code of Conduct that outline expected behaviors for all employees, vendors and independent contractors. These Codes are publicly available on our website. To this end, anyone can utilize our Integrity Line as detailed in the Codes to proactively report a violation of our Code or policies, including our conflict minerals policy and related program efforts.
Maintain records
We have maintained company-wide document retention policies. These policies extend to the documentation accumulated in performing our due diligence procedures and requires that documentation will be retained for a period of 10 years.
In addition, we implemented a document retention policy through Assent to retain conflict minerals related documents for five years, including supplier responses to CMRTs. We store all the information and findings from this process in a database that can be audited by internal or external parties.
Supplier engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 6.3 or higher and Assent’s web-based reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information to support chain of custody of the 3TG identified in our products. We have provided suppliers access to our Conflict Minerals Policy through the website above or upon request.
We continue to emphasize supplier education and training. To accomplish this, we utilized Assent’s learning management system and provided all in-scope suppliers access to many conflict minerals training and support resources. This training was tracked and evaluated based on completion. B&W has a strong relationship with Tier 1 direct suppliers. As an extremely important part of the supply chain, B&W through Assent has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support and other multilingual resources. B&W suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly file a CMRT. Suppliers are provided guidance in their native language, if needed.
We believe that the combination of the Supplier Code of Conduct, our Conflict Minerals Policy, and direct engagement with suppliers for conflict minerals training and requests constitute a strong program when it comes to supplier engagement.
2. Identify and assess risks in the supply chain
Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in the Assent Compliance Manager system based on criteria established for supplier responses in the System. These risks are addressed by Assent Compliance Supply Chain staff and members of our supply chain team internally who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.
Many of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TGs in the components supplied to B&W. Additionally, some suppliers indicated that they received incomplete information regarding their supply chains from their suppliers
and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
In accordance with the Guidance, it is important to identify and assess risks associated with conflict minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the 2023 calendar year.
To assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed the RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.
Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
•Geographic proximity to the DRC and Covered Countries;
•Known mineral source country of origin;
•RMAP audit status;
•Credible evidence of unethical or conflict sourcing;
•Peer Assessments conducted by credible third-party sources.
As part of our risk management plan under the Guidance, when facilities of interest were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent Compliance, submissions that include any facilities of interest immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to B&W, and escalating up to removal of these smelters of interest from their supply chain.
As per the Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to the Assent’s learning management system to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the Guidance and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:
A. Have you established a conflict minerals sourcing policy?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Do you review due diligence information received from your suppliers against your company’s expectations?
H. Does your review process include corrective action management?
When suppliers meet or exceed those criteria (Yes to at least A, E, G, H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. As of May 9, 2024, a total of 64 of our responsive suppliers have been identified as having a weak program.
3. Design and implement a strategy to respond to risks
We report our findings annually to the Conflict Minerals Steering Committee prior to the issuance of Form SD and this Report. We also report any significant due diligence findings to the Conflict Minerals Steering Committee as they arise. For example, if we find that we source 3TG that directly or indirectly finances or benefits armed groups, in the Covered Countries, B&W will assess the supplier relationship and encourage the supplier in question to establish an alternative source of 3TG that does not support such conflict. We have found no instance where it was necessary to implement risk mitigation efforts as a result of a supplier’s response to our information request.
As per the Guidance, risk mitigation will depend on the supplier’s specific context. Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. We engage suppliers believed to be supplying 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the Guidance. Assent also communicates directly with smelters that have not yet been determined to be conformant with the RMAP in order to request sourcing information and encourage their involvement with the RMI program.
4. Carry-out independent third-party audit of supply chain due diligence at identified points in the supply chain
We do not typically have a direct relationship with smelters and refiners and therefore do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.
Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners.
5. Public reporting on supply chain due diligence
This Report, which constitutes our annual report on our due diligence efforts, is available on our website at “https://investors.babcock.com/home/financial-reports/ ” and is filed with the SEC. The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
Results of due diligence
Survey results
As described above, B&W actively surveys our supply chain and reviews the responses against criteria developed to determine whether further engagement is required. These criteria include: untimely responses, incomplete responses and inconsistencies within the data reported in the CMRT.
As of May 9, 2024 we received responses from over 53% of our 1,179 surveyed suppliers for the Reporting Period. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. A total of 7 suppliers were unable to correct their CMRTs and as such, are still listed as invalid submissions.
Supply chain outreach metrics are as follows:
| | | | | | | | | | | | | | | | | | | | |
| Number of In-Scope Suppliers for 2023 | | Change in Number of In-Scope Suppliers From 2022 | | Response Rate | | Valid Response Rate |
| 1,179 | | | (573) | | | 53 | % | | 52 | % |
Efforts to determine mine or location of origin
Given that we do not have established relationships with the ultimate smelters and refiners from which the 3TG in our products is sourced, we have determined that requesting our suppliers to complete the CMRT represents our good faith effort to determine the mines or locations of origin of 3TG in our supply chain.
Smelters and refiners
Of the suppliers surveyed, many completed the CMRT at the company, business unit or entity level and are unable to represent that 3TG from the processing facilities they listed had actually been included in components that they supplied to us. The quality of the responses that we received from our surveyed suppliers continues to be varied. Many of the responses provided by suppliers via the CMRT included the names of facilities listed by the suppliers as smelters or refiners ("SORs"). The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and Assent follows up on these, urging suppliers to resubmit the form and include smelter information. Any CMRTs submitted by suppliers unable to provide SORs used for the materials supplied to us are deemed invalid.
For all responses that indicated a smelter, Assent compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as "Conflict-Free," Assent confirmed that the name was listed by the RMI as a certified smelter. As of May 9, 2024, we have identified 355 smelters or refiners that were reported by our suppliers via the CMRT. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. All smelters and refiners listed by suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are attached in Appendix A. Appendix B includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI.
Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 225 smelters that are deemed RMAP Conformant - this indicates these smelters or refiners are compliant with the Conflict Free Smelter Program assessment protocols. There are 9 more smelters or refiners that are deemed RMAP Active - Smelters and refiners on the Active list have committed to undergo a RMAP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. The remaining 121 smelters listed have not yet been confirmed as Conflict-Free. We have assessed these facilities and determined that most of these are of low risk due to their geographic location. As mentioned above, there are 19 smelters or refiners that we consider “High Risk Smelters.
Risk mitigation activities were initiated on the suppliers submitting these entries in their CMRT. Through Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions including removal of these red-flag smelters from their supply chain. The submission of these smelters by B&W suppliers does not guarantee that these smelters or refiners are present in the B&W supply chain as these B&W suppliers were only able to provide company-level CMRTs and not able to provide product-level CMRTs directly linking those smelters or refiners to the products they provide to B&W.
As our suppliers are largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to make any determinations regarding the 3TG included in our products during the Reporting Period or to provide additional smelter and refiner names and country of origin of the necessary 3TGs at this time.
| | | | | | | | |
| Status | | Number of Identified Smelters and Refiners |
| RMAP Conformant | | 225 |
| RMAP Active | | 9 |
| Not Enrolled | | 92 |
| Non-Conformant | | 29 |
Countries of Origin
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. As mentioned in the above section, it is understood that many responses may provide more data than can be directly linked to products sold by our company, therefore, Appendix B may contain more countries than those that the Company’s products are being sourced from.
Steps to be taken
We are committed to complying with the provisions of the Rule and Form SD and expect to continue our conflict minerals program and related due diligence. Our next steps may include, but are not limited to the following:
•Engage with suppliers and direct them to training resources, including increasing the number who utilize Assent’s learning management system. This will encourage supplier participation and improve the overall efficiency of our Conflict Minerals Due Diligence Program.
•Increase the emphasis on clean and validated smelter and refiner information from our supply chain through Assent as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the RMAP program.
•Encourage our suppliers through Assent to develop and strengthen their internal policies to include due diligence procedures for their supply chains to improve the quality of the responses from such suppliers.
•Update and maintain the supplier list and contact information for subsequent supplier engagement.
•Further document procedures and timelines for administering the conflict mineral program.
Smelter & Refiner Risk Evaluation
Understanding the risks associated with the smelters and refiners potentially providing material into our supply chain is an important part of the due diligence process. Through Assent, comprehensive and ongoing analysis is conducted by Assent’s smelter library manager to assess sourcing risk. This information is used to:
•Provide supplier feedback.
•Determine the health of the Company’s overall program.
•Conduct outreach to smelters, refiners and their respective associations.
•Provide detailed analysis in this report.
The following risk categories are used for smelter evaluation and risk determination:
Geo-Risk: Did the mineral originate from or has been transported through a conflict-affected area as defined by Section 1502 of the Dodd-Frank Act (the DRC and its nine adjoining countries; Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia)?
Audit Status: Has the refiner’s due diligence practices been audited against a standard in conformance with the OECD Guidance? Assent relies on the RMI audit standard, including cross-recognition of the London Bullion Market Association (“LBMA”) Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance.
Sourcing risk: Has evidence of any other risk characteristic is supported by credible sources been identified?
Appendix A:
The following smelters and refiners were reported by our suppliers as being in their supply chains. Facilities that have been certified as conflict-free by an internationally-recognized validation scheme for 3TG smelters and refiners are designated below in the sixth column.
| | | | | | | | | | | | | | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | Smelter ID | RMAP Audit Status | Risk Status | Source from DRC? | Source from CAHRAs? |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | CID000211 | Conformant | Low Risk | Yes | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | CID000258 | Conformant | Low Risk | Yes | Yes |
| Tantalum | F&X Electro-Materials Ltd. | China | CID000460 | Conformant | Low Risk | Yes | Yes |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | CID000875 | Conformant | Low Risk | No | Yes |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | CID000917 | Conformant | Low Risk | Yes | Yes |
| Tantalum | NPM Silmet AS | Estonia | CID001200 | Conformant | Low Risk | No | Yes |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | CID001277 | Conformant | Low Risk | Yes | Yes |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | CID001969 | Conformant | Low Risk | Yes | Yes |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | CID002316 | Conformant | Low Risk | No | No |
| Tantalum | D Block Metals, LLC | United States Of America | CID002504 | Conformant | Low Risk | No | Yes |
| Tantalum | FIR Metals & Resource Ltd. | China | CID002505 | Conformant | Low Risk | No | Yes |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | CID002541 | Conformant | Low Risk | No | Yes |
| Tantalum | Global Advanced Metals Boyertown | United States Of America | CID002557 | Conformant | Low Risk | Yes | Yes |
| Tin | EM Vinto | Bolivia (Plurinational State Of) | CID000438 | Conformant | Low Risk | Yes | Yes |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | CID001105 | Conformant | Low Risk | Yes | Yes |
| Tin | Mineracao Taboca S.A. | Brazil | CID001173 | Conformant | Low Risk | No | No |
| Tin | Minsur | Peru | CID001182 | Conformant | Low Risk | No | Yes |
| Tin | PT Timah Tbk Mentok | Indonesia | CID001482 | Conformant | Low Risk | No | Yes |
| Tin | Thaisarco | Thailand | CID001898 | Conformant | Low Risk | Yes | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tungsten | A.L.M.T. Corp. | Japan | CID000004 | Conformant | Low Risk | Yes | Yes |
| Tungsten | Kennametal Huntsville | United States Of America | CID000105 | Conformant | Low Risk | No | Yes |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | CID000218 | Conformant | Low Risk | No | Yes |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | CID000228 | Conformant | Low Risk | No | Yes |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | CID000281 | Outreach Required | Medium Risk | No | No |
| Tin | Alpha | United States Of America | CID000292 | Conformant | Low Risk | No | Yes |
| Tin | PT Aries Kencana Sejahtera | Indonesia | CID000309 | Conformant | Low Risk | No | Yes |
| Tin | PT Premium Tin Indonesia | Indonesia | CID000313 | Conformant | Low Risk | Unknown | Unknown |
| Tin | Dowa | Japan | CID000402 | Conformant | Low Risk | No | Yes |
| Tin | Estanho de Rondonia S.A. | Brazil | CID000448 | Conformant | Low Risk | No | No |
| Tin | Fenix Metals | Poland | CID000468 | Conformant | Low Risk | No | Yes |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | CID000538 | Conformant | Low Risk | No | Yes |
| Tungsten | Global Tungsten & Powders LLC | United States Of America | CID000568 | Conformant | Low Risk | Yes | Yes |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | CID000616 | Conformant | Low Risk | Yes | Yes |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | CID000671 | Outreach Required | Medium Risk | No | No |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | CID000766 | Conformant | Low Risk | No | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | CID000767 | Outreach Required | Medium Risk | No | No |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | CID000769 | Conformant | Low Risk | No | Yes |
| Tungsten | Japan New Metals Co., Ltd. | Japan | CID000825 | Conformant | Low Risk | No | Yes |
| Gold | Jiangxi Copper Co., Ltd. | China | CID000855 | Conformant | Low Risk | Yes | Yes |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | CID000914 | Conformant | Low Risk | Yes | Yes |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | CID000942 | Non Conformant | Medium Risk | No | Yes |
| Tungsten | Kennametal Fallon | United States Of America | CID000966 | Conformant | Low Risk | Yes | Yes |
| Tin | China Tin Group Co., Ltd. | China | CID001070 | Conformant | Low Risk | No | Yes |
| Tantalum | AMG Brasil | Brazil | CID001076 | Conformant | Low Risk | Yes | Yes |
| Tin | Metallic Resources, Inc. | United States Of America | CID001142 | Conformant | Low Risk | No | Yes |
| Gold | Metalor Technologies (Suzhou) Ltd. | China | CID001147 | Conformant | Low Risk | No | No |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | CID001152 | Conformant | Low Risk | No | No |
| Gold | Metalor Technologies S.A. | Switzerland | CID001153 | Conformant | Low Risk | Yes | Yes |
| Gold | Metalor USA Refining Corporation | United States Of America | CID001157 | Conformant | Low Risk | No | Yes |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | CID001163 | Conformant | Low Risk | No | Yes |
| Tantalum | Mineracao Taboca S.A. | Brazil | CID001175 | Conformant | Low Risk | Yes | Yes |
| Tin | Mitsubishi Materials Corporation | Japan | CID001191 | Conformant | Low Risk | Yes | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001192 | Conformant | Low Risk | Yes | Yes |
| Tin | Jiangxi New Nanshan Technology Ltd. | China | CID001231 | Conformant | Low Risk | No | Yes |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | CID001314 | Conformant | Low Risk | No | Yes |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | CID001337 | Conformant | Low Risk | Yes | Yes |
| Tin | PT Artha Cipta Langgeng | Indonesia | CID001399 | Conformant | Low Risk | No | Yes |
| Tin | PT Babel Inti Perkasa | Indonesia | CID001402 | Conformant | Low Risk | No | Yes |
| Tin | PT Babel Surya Alam Lestari | Indonesia | CID001406 | Conformant | Low Risk | No | Yes |
| Tin | PT Bangka Tin Industry | Indonesia | CID001419 | In Communication | Medium Risk | Unknown | Unknown |
| Tin | PT Belitung Industri Sejahtera | Indonesia | CID001421 | Active | Medium Risk | No | Yes |
| Tin | PT Bukit Timah | Indonesia | CID001428 | Conformant | Low Risk | Yes | Yes |
| Tin | PT Mitra Stania Prima | Indonesia | CID001453 | Conformant | Low Risk | No | Yes |
| Tin | PT Panca Mega Persada | Indonesia | CID001457 | In Communication | Medium Risk | No | Yes |
| Tin | PT Prima Timah Utama | Indonesia | CID001458 | Conformant | Low Risk | No | Yes |
| Tin | PT Refined Bangka Tin | Indonesia | CID001460 | Conformant | Low Risk | No | Yes |
| Tin | PT Sariwiguna Binasentosa | Indonesia | CID001463 | Conformant | Low Risk | No | Yes |
| Tin | PT Stanindo Inti Perkasa | Indonesia | CID001468 | Conformant | Low Risk | Yes | Yes |
| Tin | PT Timah Tbk Kundur | Indonesia | CID001477 | Conformant | Low Risk | No | Yes |
| Tin | PT Tinindo Inter Nusa | Indonesia | CID001490 | Non Conformant | Medium Risk | Yes | Yes |
| Tin | PT Tommy Utama | Indonesia | CID001493 | Conformant | Low Risk | No | No |
| Tantalum | QuantumClean | United States Of America | CID001508 | Conformant | Low Risk | Yes | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | CID001522 | Conformant | Low Risk | No | Yes |
| Tin | Rui Da Hung | Taiwan, Province Of China | CID001539 | Conformant | Low Risk | No | Yes |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | CID001622 | Conformant | Low Risk | No | Yes |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | CID001769 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | Yes |
| Tantalum | Taki Chemical Co., Ltd. | Japan | CID001869 | Conformant | Low Risk | Yes | Yes |
| Tantalum | Telex Metals | United States Of America | CID001891 | Conformant | Low Risk | No | Yes |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | CID001908 | Non Conformant | Medium Risk | No | No |
| Gold | Shandong Gold Smelting Co., Ltd. | China | CID001916 | Conformant | Medium Risk | Yes | Yes |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | CID002036 | Conformant | Low Risk | No | Yes |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | CID002044 | Conformant | Low Risk | Yes | No |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | CID002082 | Conformant | Low Risk | Yes | Yes |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | CID002158 | Conformant | Low Risk | No | Yes |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | CID002180 | Conformant | Low Risk | No | Yes |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | CID002224 | Conformant | Low Risk | Yes | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | CID002313 | Communication Suspended - Not Interested | Medium Risk | No | No |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | CID002315 | Conformant | Low Risk | Yes | Yes |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | CID002317 | Conformant | Low Risk | Yes | Yes |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | CID002318 | Conformant | Low Risk | No | Yes |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | CID002319 | Conformant | Low Risk | No | Yes |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | CID002320 | Conformant | Low Risk | Yes | Yes |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | CID002321 | Conformant | Low Risk | No | Yes |
| Tin | CV Venus Inti Perkasa | Indonesia | CID002455 | Conformant | Low Risk | Yes | No |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | CID002468 | Conformant | Low Risk | Yes | Yes |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | CID002492 | Conformant | Low Risk | No | Yes |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | CID002494 | Conformant | Low Risk | No | Yes |
| Tin | Melt Metais e Ligas S.A. | Brazil | CID002500 | Non Conformant | Medium Risk | No | Yes |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | CID002502 | Conformant | Low Risk | Yes | Yes |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | CID002503 | Conformant | Low Risk | No | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | CID002506 | Conformant | Low Risk | Yes | Yes |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | CID002508 | Conformant | Low Risk | No | Yes |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | CID002512 | Conformant | Low Risk | No | No |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | CID002513 | Conformant | Low Risk | No | Yes |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | CID002517 | Conformant | Low Risk | No | Yes |
| Tantalum | KEMET de Mexico | Mexico | CID002539 | Conformant | Low Risk | Yes | Yes |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002542 | Conformant | Low Risk | Yes | Yes |
| Tungsten | Masan High-Tech Materials | Viet Nam | CID002543 | Conformant | Low Risk | No | Yes |
| Tantalum | TANIOBIS Co., Ltd. | Thailand | CID002544 | Conformant | Low Risk | Yes | Yes |
| Tantalum | TANIOBIS GmbH | Germany | CID002545 | Conformant | Low Risk | Yes | Yes |
| Tantalum | Materion Newton Inc. | United States Of America | CID002548 | Conformant | Low Risk | Yes | Yes |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | CID002549 | Conformant | Low Risk | Yes | Yes |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002550 | Conformant | Low Risk | Yes | Yes |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | CID002551 | Conformant | Low Risk | No | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tantalum | Global Advanced Metals Aizu | Japan | CID002558 | Conformant | Low Risk | Yes | Yes |
| Tin | CV Ayi Jaya | Indonesia | CID002570 | Conformant | Low Risk | No | Yes |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | CID002572 | Non Conformant | Medium Risk | No | No |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002573 | Outreach Required | Medium Risk | Yes | Yes |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002574 | Outreach Required | Medium Risk | No | No |
| Tungsten | Niagara Refining LLC | United States Of America | CID002589 | Conformant | Low Risk | No | Yes |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China | CID002641 | Conformant | Low Risk | No | No |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | CID002645 | Conformant | Low Risk | No | No |
| Tungsten | Hydrometallurg, JSC | Russian Federation | CID002649 | RMI Due Diligence Review - Unable to Proceed | High Risk | Yes | Yes |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | CID002703 | Outreach Required | Medium Risk | No | No |
| Tin | Resind Industria e Comercio Ltda. | Brazil | CID002706 | Conformant | Low Risk | No | Yes |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | CID002707 | Conformant | Low Risk | No | Yes |
| Tungsten | Unecha Refractory metals plant | Russian Federation | CID002724 | Non Conformant | High Risk | No | Yes |
| Tin | Super Ligas | Brazil | CID002756 | Active | Low Risk | No | No |
| Tin | Aurubis Beerse | Belgium | CID002773 | Conformant | Low Risk | Yes | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tin | Aurubis Berango | Spain | CID002774 | Conformant | Low Risk | Yes | Yes |
| Tin | PT Bangka Prima Tin | Indonesia | CID002776 | Conformant | Low Risk | Unknown | Unknown |
| Tin | PT Sukses Inti Makmur | Indonesia | CID002816 | Conformant | Low Risk | No | Yes |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | CID002827 | Conformant | Low Risk | No | No |
| Tungsten | ACL Metais Eireli | Brazil | CID002833 | Non Conformant | Medium Risk | No | Yes |
| Tin | PT Menara Cipta Mulia | Indonesia | CID002835 | Conformant | Low Risk | No | Yes |
| Tantalum | Jiangxi Tuohong New Raw Material | China | CID002842 | Conformant | Low Risk | No | Yes |
| Tungsten | Moliren Ltd. | Russian Federation | CID002845 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Tin | Modeltech Sdn Bhd | Malaysia | CID002858 | Non Conformant | Medium Risk | No | No |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | CID003116 | Conformant | Low Risk | No | Yes |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | CID003190 | Conformant | Low Risk | No | Yes |
| Tin | PT Bangka Serumpun | Indonesia | CID003205 | Conformant | Low Risk | No | Yes |
| Tin | Pongpipat Company Limited | Myanmar | CID003208 | Outreach Required | Medium Risk | No | Yes |
| Tin | Tin Technology & Refining | United States Of America | CID003325 | Conformant | Low Risk | No | Yes |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | CID003356 | Non Conformant | Medium Risk | No | No |
| Tin | PT Rajawali Rimba Perkasa | Indonesia | CID003381 | Conformant | Low Risk | No | Yes |
| Tin | Luna Smelter, Ltd. | Rwanda | CID003387 | Conformant | Low Risk | Yes | Yes |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | CID003397 | Non Conformant | Medium Risk | No | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China | CID003401 | Conformant | Low Risk | Yes | Yes |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | CID003407 | Conformant | Low Risk | Yes | Yes |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | CID003408 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Tin | Precious Minerals and Smelting Limited | India | CID003409 | Non Conformant | Medium Risk | No | No |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | CID003410 | Outreach Required | Medium Risk | No | No |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | CID003416 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | CID003417 | Conformant | Low Risk | No | No |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | CID003427 | Non Conformant | Medium Risk | Yes | Yes |
| Tin | PT Mitra Sukses Globalindo | Indonesia | CID003449 | Conformant | Low Risk | No | No |
| Tungsten | Cronimet Brasil Ltda | Brazil | CID003468 | Conformant | Low Risk | No | No |
| Tungsten | OOO “Technolom” 2 | Russian Federation | CID003612 | RMI Due Diligence Review - Unable to Proceed | High Risk | Unknown | Unknown |
| Tungsten | OOO “Technolom” 1 | Russian Federation | CID003614 | RMI Due Diligence Review - Unable to Proceed | High Risk | Unknown | Unknown |
| Gold | Advanced Chemical Company | United States Of America | CID000015 | Conformant | Low Risk | No | Yes |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | CID000019 | Conformant | Low Risk | No | Yes |
| Gold | Agosi AG | Germany | CID000035 | Conformant | Low Risk | No | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | CID000041 | Conformant | Low Risk | Yes | Yes |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | CID000058 | Conformant | Low Risk | Yes | No |
| Gold | Argor-Heraeus S.A. | Switzerland | CID000077 | Conformant | Low Risk | No | No |
| Gold | Asahi Pretec Corp. | Japan | CID000082 | Conformant | Low Risk | No | Yes |
| Gold | Asaka Riken Co., Ltd. | Japan | CID000090 | Conformant | Low Risk | Yes | Yes |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | CID000103 | Outreach Required | Low Risk | No | No |
| Gold | Aurubis AG | Germany | CID000113 | Conformant | Low Risk | No | No |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | CID000128 | Conformant | Low Risk | No | No |
| Gold | Boliden AB | Sweden | CID000157 | Conformant | Low Risk | No | No |
| Gold | C. Hafner GmbH + Co. KG | Germany | CID000176 | Conformant | Low Risk | No | No |
| Gold | Caridad | Mexico | CID000180 | Outreach Required | Low Risk | No | No |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | CID000185 | Conformant | Low Risk | Yes | Yes |
| Gold | Cendres + Metaux S.A. | Switzerland | CID000189 | Non Conformant | Medium Risk | No | No |
| Gold | Yunnan Copper Industry Co., Ltd. | China | CID000197 | Outreach Required | Medium Risk | Yes | Yes |
| Gold | Chimet S.p.A. | Italy | CID000233 | Conformant | Low Risk | No | No |
| Gold | Chugai Mining | Japan | CID000264 | Conformant | Low Risk | No | No |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | CID000343 | In Communication | Medium Risk | No | No |
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of | CID000359 | Conformant | Low Risk | No | No |
| Gold | Dowa | Japan | CID000401 | Conformant | Low Risk | No | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | CID000425 | Conformant | Low Risk | No | No |
| Gold | JSC Novosibirsk Refinery | Russian Federation | CID000493 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Gold | Refinery of Seemine Gold Co., Ltd. | China | CID000522 | Outreach Required | Medium Risk | No | No |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | CID000555 | Non Conformant | Medium Risk | Yes | Yes |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | CID000651 | Outreach Required | Medium Risk | No | No |
| Gold | LT Metal Ltd. | Korea, Republic Of | CID000689 | Conformant | Low Risk | No | No |
| Gold | Heimerle + Meule GmbH | Germany | CID000694 | Conformant | Low Risk | No | No |
| Gold | Heraeus Metals Hong Kong Ltd. | China | CID000707 | Conformant | Low Risk | No | No |
| Gold | Heraeus Germany GmbH Co. KG | Germany | CID000711 | Conformant | Low Risk | No | No |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | CID000773 | Outreach Required | Medium Risk | Yes | No |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | CID000778 | Communication Suspended - Not Interested | Medium Risk | No | No |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | CID000801 | Conformant | Low Risk | No | Yes |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | CID000807 | Conformant | Low Risk | No | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Istanbul Gold Refinery | Turkey | CID000814 | Conformant | Low Risk | Yes | Yes |
| Gold | Japan Mint | Japan | CID000823 | Conformant | Low Risk | No | No |
| Gold | Asahi Refining USA Inc. | United States Of America | CID000920 | Conformant | Low Risk | Yes | Yes |
| Gold | Asahi Refining Canada Ltd. | Canada | CID000924 | Conformant | Low Risk | No | Yes |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | CID000927 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Gold | JSC Uralelectromed | Russian Federation | CID000929 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | CID000937 | Conformant | Low Risk | Yes | Yes |
| Gold | Kazakhmys Smelting LLC | Kazakhstan | CID000956 | In Communication | Low Risk | No | No |
| Gold | Kazzinc | Kazakhstan | CID000957 | Conformant | Low Risk | No | Yes |
| Gold | Kennecott Utah Copper LLC | United States Of America | CID000969 | Conformant | Low Risk | No | Yes |
| Gold | Kojima Chemicals Co., Ltd. | Japan | CID000981 | Conformant | Low Risk | No | Yes |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | CID001029 | Non Conformant | Medium Risk | No | No |
| Gold | L'azurde Company For Jewelry | Saudi Arabia | CID001032 | RMI Due Diligence Review - Unable to Proceed | Medium Risk | No | No |
| Gold | Lingbao Gold Co., Ltd. | China | CID001056 | Outreach Required | Medium Risk | No | No |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | CID001058 | Outreach Required | Medium Risk | No | No |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | CID001078 | Conformant | Low Risk | No | No |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | CID001093 | Outreach Required | Medium Risk | No | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Materion | United States Of America | CID001113 | Conformant | Low Risk | No | Yes |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | CID001119 | Conformant | Low Risk | No | Yes |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | CID001149 | Conformant | Low Risk | Yes | Yes |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | CID001161 | Conformant | Low Risk | No | Yes |
| Gold | Mitsubishi Materials Corporation | Japan | CID001188 | Conformant | Low Risk | Yes | Yes |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001193 | Conformant | Low Risk | No | Yes |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | CID001204 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | CID001220 | Conformant | Low Risk | No | No |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | CID001236 | Conformant | Low Risk | No | No |
| Gold | Nihon Material Co., Ltd. | Japan | CID001259 | Conformant | Low Risk | Yes | Yes |
| Tin | Novosibirsk Tin Combine | Russian Federation | CID001305 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | CID001325 | Conformant | Low Risk | No | Yes |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | CID001326 | RMI Due Diligence Review - Unable to Proceed | High Risk | Yes | Yes |
| Gold | MKS PAMP SA | Switzerland | CID001352 | Conformant | Low Risk | Yes | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | CID001362 | Outreach Required | Medium Risk | No | No |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | CID001386 | RMI Due Diligence Review - Unable to Proceed | High Risk | Yes | Yes |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | CID001397 | Conformant | Low Risk | No | No |
| Tin | PT Timah Nusantara | Indonesia | CID001486 | Active | Medium Risk | Yes | Yes |
| Gold | PX Precinox S.A. | Switzerland | CID001498 | Conformant | Low Risk | No | No |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | CID001512 | Conformant | Low Risk | Yes | Yes |
| Gold | Royal Canadian Mint | Canada | CID001534 | Conformant | Low Risk | No | No |
| Gold | Sabin Metal Corp. | United States Of America | CID001546 | Communication Suspended - Not Interested | Medium Risk | No | Yes |
| Gold | Samduck Precious Metals | Korea, Republic Of | CID001555 | Non Conformant | Medium Risk | Yes | Yes |
| Gold | Samwon Metals Corp. | Korea, Republic Of | CID001562 | Communication Suspended - Not Interested | Medium Risk | No | No |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | CID001585 | Conformant | Low Risk | No | Yes |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | CID001619 | Outreach Required | Medium Risk | No | No |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | CID001736 | Conformant | Low Risk | No | No |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | CID001756 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | CID001761 | Conformant | Low Risk | No | Yes |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | CID001798 | Conformant | Low Risk | No | Yes |
| Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province Of China | CID001810 | Outreach Required | Medium Risk | No | No |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | CID001875 | Conformant | Low Risk | No | No |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | CID001909 | Outreach Required | Medium Risk | No | No |
| Gold | Tokuriki Honten Co., Ltd. | Japan | CID001938 | Conformant | Low Risk | Yes | Yes |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | CID001947 | Outreach Required | Medium Risk | No | No |
| Gold | Torecom | Korea, Republic Of | CID001955 | Conformant | Low Risk | No | No |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | CID001980 | Conformant | Low Risk | No | Yes |
| Gold | United Precious Metal Refining, Inc. | United States Of America | CID001993 | Conformant | Low Risk | No | Yes |
| Gold | Valcambi S.A. | Switzerland | CID002003 | Conformant | Low Risk | Yes | Yes |
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | CID002015 | Outreach Required | Medium Risk | Yes | Yes |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | CID002030 | Conformant | Low Risk | No | No |
| Gold | Yamakin Co., Ltd. | Japan | CID002100 | Conformant | Low Risk | No | Yes |
| Gold | Yokohama Metal Co., Ltd. | Japan | CID002129 | Conformant | Low Risk | Yes | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | CID002243 | Conformant | Medium Risk | No | No |
| Gold | Morris and Watson | New Zealand | CID002282 | In Communication | Low Risk | No | No |
| Gold | SAFINA A.S. | Czechia | CID002290 | Conformant | Low Risk | No | No |
| Gold | Guangdong Jinding Gold Limited | China | CID002312 | Outreach Required | Medium Risk | No | No |
| Gold | Umicore Precious Metals Thailand | Thailand | CID002314 | Non Conformant | Medium Risk | No | Yes |
| Gold | Geib Refining Corporation | United States Of America | CID002459 | Conformant | Low Risk | No | Yes |
| Tin | PT Tirus Putra Mandiri | Indonesia | CID002478 | In Communication | Medium Risk | No | No |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | CID002509 | Conformant | Medium Risk | Yes | Yes |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | CID002511 | Conformant | Low Risk | No | Yes |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | CID002515 | RMI Due Diligence Review - Unable to Proceed | High Risk | Yes | Yes |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | CID002516 | Non Conformant | Medium Risk | No | Yes |
| Gold | Shandong Humon Smelting Co., Ltd. | China | CID002525 | Outreach Required | Medium Risk | No | No |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | CID002527 | Outreach Required | Medium Risk | No | No |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | CID002560 | Conformant | Low Risk | No | Yes |
| Gold | Emirates Gold DMCC | United Arab Emirates | CID002561 | Conformant | Low Risk | Yes | Yes |
| Gold | International Precious Metal Refiners | United Arab Emirates | CID002562 | In Communication | Medium Risk | No | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Kaloti Precious Metals | United Arab Emirates | CID002563 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Gold | Sudan Gold Refinery | Sudan | CID002567 | Outreach Required | High Risk | Yes | Yes |
| Gold | T.C.A S.p.A | Italy | CID002580 | Conformant | Low Risk | No | Yes |
| Gold | REMONDIS PMR B.V. | Netherlands | CID002582 | Conformant | Low Risk | No | No |
| Gold | Fujairah Gold FZC | United Arab Emirates | CID002584 | Outreach Required | Medium Risk | No | No |
| Gold | Industrial Refining Company | Belgium | CID002587 | Non Conformant | High Risk | No | No |
| Gold | Shirpur Gold Refinery Ltd. | India | CID002588 | Outreach Required | Medium Risk | No | No |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | CID002605 | Conformant | Low Risk | No | Yes |
| Gold | Marsam Metals | Brazil | CID002606 | Non Conformant | Medium Risk | No | Yes |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | CID002615 | Conformant | Low Risk | No | No |
| Tin | PT Cipta Persada Mulia | Indonesia | CID002696 | Conformant | Low Risk | No | No |
| Gold | Abington Reldan Metals, LLC | United States Of America | CID002708 | Conformant | Low Risk | No | Yes |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China | CID002750 | Outreach Required | Medium Risk | Unknown | Unknown |
| Gold | Albino Mountinho Lda. | Portugal | CID002760 | Outreach Required | Low Risk | Unknown | Unknown |
| Gold | SAAMP | France | CID002761 | Conformant | Low Risk | No | No |
| Gold | L'Orfebre S.A. | Andorra | CID002762 | Conformant | Low Risk | Yes | Yes |
| Gold | 8853 S.p.A. | Italy | CID002763 | Non Conformant | Medium Risk | No | No |
| Gold | Italpreziosi | Italy | CID002765 | Conformant | Low Risk | No | No |
| Gold | WIELAND Edelmetalle GmbH | Germany | CID002778 | Conformant | Low Risk | No | Yes |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | CID002779 | Conformant | Low Risk | Yes | Yes |
| Gold | AU Traders and Refiners | South Africa | CID002850 | Non Conformant | Medium Risk | Yes | Yes |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India | CID002852 | Active | Medium Risk | No | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Sai Refinery | India | CID002853 | Outreach Required | Medium Risk | No | No |
| Gold | Modeltech Sdn Bhd | Malaysia | CID002857 | Non Conformant | Medium Risk | No | No |
| Gold | Bangalore Refinery | India | CID002863 | Conformant | Low Risk | No | Yes |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | CID002865 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | CID002867 | Outreach Required | Low Risk | No | No |
| Gold | Pease & Curren | United States Of America | CID002872 | Communication Suspended - Not Interested | Medium Risk | No | Yes |
| Gold | JALAN & Company | India | CID002893 | Outreach Required | Medium Risk | No | No |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | CID002918 | Conformant | Low Risk | No | Yes |
| Gold | Planta Recuperadora de Metales SpA | Chile | CID002919 | Conformant | Low Risk | Yes | No |
| Gold | ABC Refinery Pty Ltd. | Australia | CID002920 | Outreach Required | Low Risk | Unknown | Unknown |
| Gold | Safimet S.p.A | Italy | CID002973 | Non Conformant | Medium Risk | No | Yes |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | CID003153 | Outreach Required | Low Risk | Yes | Yes |
| Gold | African Gold Refinery | Uganda | CID003185 | RMI Due Diligence Review - Unable to Proceed | High Risk | Yes | No |
| Gold | Gold Coast Refinery | Ghana | CID003186 | Outreach Required | Medium Risk | No | No |
| Gold | NH Recytech Company | Korea, Republic Of | CID003189 | Conformant | Low Risk | No | No |
| Gold | QG Refining, LLC | United States Of America | CID003324 | Outreach Required | Low Risk | No | Yes |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | CID003348 | Outreach Required | Medium Risk | No | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | CGR Metalloys Pvt Ltd. | India | CID003382 | Outreach Required | Medium Risk | No | No |
| Gold | Sovereign Metals | India | CID003383 | Outreach Required | Medium Risk | Yes | Yes |
| Gold | C.I Metales Procesados Industriales SAS | Colombia | CID003421 | Active | Low Risk | No | No |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | CID003424 | Conformant | Low Risk | No | No |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | CID003425 | Conformant | Low Risk | No | No |
| Gold | Augmont Enterprises Private Limited | India | CID003461 | Active | Medium Risk | No | No |
| Gold | Kundan Care Products Ltd. | India | CID003463 | In Communication | Medium Risk | No | No |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | CID003486 | Conformant | Low Risk | Unknown | Unknown |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India | CID003487 | In Communication | Medium Risk | Unknown | Unknown |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India | CID003488 | In Communication | Medium Risk | Unknown | Unknown |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India | CID003489 | In Communication | Medium Risk | Unknown | Unknown |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India | CID003490 | In Communication | Medium Risk | Unknown | Unknown |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | K.A. Rasmussen | Norway | CID003497 | Outreach Required | Low Risk | Yes | No |
| Gold | Alexy Metals | United States Of America | CID003500 | Active | Low Risk | No | No |
| Tin | CRM Synergies | Spain | CID003524 | Conformant | Low Risk | No | No |
| Gold | Sancus ZFS (L’Orfebre, SA) | Colombia | CID003529 | Conformant | Low Risk | Unknown | Unknown |
| Gold | Sellem Industries Ltd. | Mauritania | CID003540 | Communication Suspended - Not Interested | Medium Risk | Unknown | Unknown |
| Gold | MD Overseas | India | CID003548 | In Communication | Medium Risk | No | No |
| Tungsten | Artek LLC | Russian Federation | CID003553 | RMI Due Diligence Review - Unable to Proceed | High Risk | No | No |
| Gold | Metallix Refining Inc. | United States Of America | CID003557 | In Communication | Low Risk | Unknown | Unknown |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | CID003575 | Conformant | Low Risk | No | No |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | CID003582 | Conformant | Low Risk | Unknown | Unknown |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | CID003583 | Conformant | Low Risk | Unknown | Unknown |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | CID003609 | Conformant | Low Risk | Unknown | Unknown |
| Gold | WEEEREFINING | France | CID003615 | Active | Low Risk | Unknown | Unknown |
| Gold | Gold by Gold Colombia | Colombia | CID003641 | Conformant | Low Risk | Unknown | Unknown |
| Tungsten | LLC Vostok | Russian Federation | CID003643 | RMI Due Diligence Review - Unable to Proceed | High Risk | Unknown | Unknown |
| Gold | Dongwu Gold Group | China | CID003663 | Outreach Required | Medium Risk | Unknown | Unknown |
| Tin | DS Myanmar | Myanmar | CID003831 | Conformant | Low Risk | Unknown | Unknown |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | CID003868 | Conformant | Low Risk | Unknown | Unknown |
| Tin | PT Rajehan Ariq | Indonesia | CID002593 | Conformant | Low Risk | No | |
| Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam | CID003993 | Conformant | Low Risk | Unknown | Unknown |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China | CID003662 | Outreach Required | Medium Risk | Unknown | Unknown |
| Tantalum | 5D Production OU | Estonia | CID003926 | Outreach Required | Low Risk | Unknown | Unknown |
| Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic Of | CID003978 | Outreach Required | Medium Risk | Unknown | Unknown |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of | CID004060 | In Communication | Medium Risk | Unknown | Unknown |
Appendix B:
Countries of origin:
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.
Afghanistan, Åland Islands, Albania, American Samoa, Andorra, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia (Plurinational State of), Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo, Democratic Republic of Congo, Djibouti, Dominica, Dominican Republic, Ecuador, Egypt, Eritrea, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Kazakhstan, Kenya, Korea, Kyrgyzstan, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, South Sudan, Spain, Sudan, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia, Zimbabwe
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