UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Fluidigm Corporation
(Exact name of registrant as specified in its charter)
| Delaware | 001-34180 | 77-0513190 | ||
| (State or other jurisdiction of incorporation) |
(Commission File Number) |
(IRS Employer Identification No.) | ||
| 7000 Shoreline Court, Suite 100, South San Francisco, California | 94080 | |||
| (Address of principal executive offices) | (Zip Code) | |||
Vikram Jog
Chief Financial Officer
(650) 266-6000
(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, 2015. |
Section 1 - Conflict Minerals Disclosure
| Item 1.01 | Conflict Minerals Disclosure and Report |
Conflict Minerals Disclosure
For the reporting period from January 1, 2015 to December 31, 2015, Fluidigm Corporation (the “Company”) determined that certain “conflict minerals,” as defined in Section 1, Item 1.01(d)(3) of Form SD, are necessary to the functionality or production of products manufactured by the Company, which are referred to in this Form SD as “necessary conflict minerals.” Accordingly, the Company conducted a reasonable country of origin inquiry to determine whether during 2015 its necessary conflict minerals originated in the Democratic Republic of the Congo or certain adjoining countries, which are referred to in this Form SD collectively as the “covered countries.” The Company then conducted due diligence designed to conform to the Organisation for Economic Co-operation and Development, or OECD, Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas in order to determine whether any of the Company’s necessary conflict minerals originated from any of the covered countries and whether these conflict minerals benefitted, directly or indirectly, armed groups in any of the covered countries.
In accordance with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, and this Specialized Disclosure Report on Form SD, the Company has filed a Conflict Minerals Report, which is attached as Exhibit 1.01 hereto. A copy of this Form SD and the Conflict Minerals Report are publicly available at http://investors.fluidigm.com/sec.cfm.
| Item 1.02 | Exhibit |
In accordance with Rule 13p-1, and this Form SD, the Company has filed its Conflict Minerals Report, which is attached as Exhibit 1.01 to this Form SD.
Section 2 - Exhibits
| Item 2.01 | Exhibits |
The following exhibit is filed as part of this Form SD.
| Exhibit No. |
Description | |
| 1.01 | Fluidigm Corporation Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD. | |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| FLUIDIGM CORPORATION | ||||||||
| (Registrant) | ||||||||
| By: | /s/ William M. Smith |
May 31, 2016 | ||||||
| William M. Smith | (Date) | |||||||
| EVP, Legal Affairs, General Counsel and Secretary | ||||||||
EXHIBIT INDEX
| Exhibit |
Description | |
| 1.01 | Fluidigm Corporation Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD. | |
Exhibit 1.01
Fluidigm Corporation
Conflict Minerals Report
For The Year Ended December 31, 2015
Cautionary Note Concerning Forward-Looking Statements: This Conflict Minerals Report contains forward-looking statements within the meaning of federal securities laws. These forward-looking statements include statements concerning Fluidigm’s objectives for its conflict minerals policy and compliance initiatives and actions it intends to take relating to conflict minerals. Forward-looking statements involve substantial risks and uncertainties that could cause actual results to differ materially from currently anticipated results. When considering forward-looking statements, you should consider, among other factors, the risk factors described in the reports and other filings that Fluidigm files with the United States Securities and Exchange Commission, including Fluidigm’s Annual Report on Form 10-K for the year ended December 31, 2015 and its subsequent Quarterly Reports on Form 10-Q. The risk factors included in these filings are not exhaustive, and risks that are not identified therein could materially affect whether Fluidigm realizes the results anticipated or implied by any forward-looking statements contained in this Conflict Minerals Report. Except as required by law, Fluidigm disclaims any obligation to update these forward-looking statements, whether as a result of new information, future events, or otherwise.
Introduction
This Conflict Minerals Report (this “Report”) for Fluidigm Corporation (“Fluidigm” or “we” or “our”) covers the reporting period from January 1, 2015 to December 31, 2015 and is presented in accordance with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). This Report is filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD (the “Form SD”). A copy of this Report and the Form SD are publicly available on our website at http://investors.fluidigm.com/sec.cfm. Information contained on, or that can be accessed through, our website, does not constitute part of this Report and inclusion of our website address in this Report is an inactive textual reference only.
In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). Section 1502 of the Act relates to conflict minerals and requires companies subject to the Act to file a Form SD annually with the United States Securities and Exchange Commission (“SEC”) to disclose whether the minerals specified in Rule 13p-1 and their derivatives, limited to tungsten, tantalum, tin, and gold (referred to as the “3TG minerals”), used in their products benefitted, directly or indirectly, armed groups in the Democratic Republic of the Congo and adjoining countries (collectively, the “Covered Countries”). This Report, which is an exhibit to our Form SD, describes the design and implementation of our conflict minerals due diligence measures undertaken, including a description of how these measures were designed to determine, to our knowledge, the source mines, countries of origin, and processing facilities for 3TG minerals contained in components used in our products.
Fluidigm Background and Covered Products
We create, manufacture, and market innovative technologies and life-science tools focused on the exploration and analysis of single cells, as well as the industrial application of genomics, based upon our core microfluidics and mass cytometry technologies. We sell instruments and consumables, including integrated fluidic circuits (“IFCs”), assays, and reagents. Our customers include those both in research and applied markets. Research customers are predominantly academic institutions, while our applied customers include clinical laboratories,
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biopharmaceutical, agricultural biotechnology (Ag-Bio) companies, and contract research organizations (CRO’s). Our microfluidic systems and instrumentation for commercial sale, as well as for internal research and development purposes, are manufactured at our facility in Singapore. Our proteomics analytical instruments for commercial sale, as well as for internal research and development purposes, are manufactured at our facility in Canada. We also manufacture IFCs for research and development, assays, and reagents at our facilities in South San Francisco, California.
We have determined that one or more of the 3TG minerals may be necessary to the functionality or production of certain products we manufactured, or contracted to manufacture, as applicable, during 2015, including our C1, Juno, Callisto, Polaris and Access Array, Biomark HD, EP1, and CyTOF 2 systems. As a result, all of our marketed systems and IFCs are considered “covered products” for purposes of this Report.
Our supply chain with respect to the covered products is complex, and there are many third parties in the supply chain between the original source of the 3TG minerals and the manufacture of the covered products. We do not purchase raw ore or unrefined 3TG minerals directly and make no purchases in the Covered Countries. As a result and as described more fully below, we rely on our suppliers to provide information on the origin of the conflict minerals contained in our products.
Fluidigm Reasonable Country of Origin Inquiry
In accordance with Rule 13p-1 and Form SD, we determined that one or more of the 3TG minerals may be necessary to the functionality or production of our systems and IFCs and that such 3TG minerals are incorporated into our products during the manufacturing process. Accordingly, we undertook a reasonable country of origin inquiry (“RCOI”). This good faith RCOI was reasonably designed to determine whether any of the 3TG minerals incorporated into our products originated in the Covered Countries.
Our RCOI consisted principally of submitting the conflict minerals reporting template (the “CFSI Template”) prepared by the Conflict-Free Sourcing Initiative (“CFSI”), an initiative of the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative, to suppliers of components for our products that are considered necessary to the functionality or production of our products and for which any 3TG minerals or their derivatives may be included (“first tier suppliers”). We reviewed all responses for completeness, reasonableness, and consistency, and we followed up for corrections and clarifications as we determined appropriate.
Fluidigm’s Due Diligence Process
Our due diligence measures were designed to conform, in all material respects, with the framework in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”). The objectives of our diligence initiative were to determine, to the best of our ability, whether any of the 3TG minerals are incorporated into our products; whether any such 3TG minerals incorporated into our products were necessary for the functionality and/or production of our products; the source and chain of custody of the 3TG minerals necessary for the functionality and/or production of our products; and whether any such 3TG minerals originated in the Covered Countries. In the event that 3TG minerals from the Covered Countries which benefit armed groups are found in our supply chain, we will take appropriate actions in a timely manner to resolve the situation.
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Due diligence measures that we implemented included, but were not limited, to the following:
| 1. | Establishment of Internal Management Systems |
| a. | Conflict Minerals Policy. In 2013, we adopted a written policy relating to the use of conflict minerals in our supply chain. We have communicated this written policy to each of our first tier suppliers. A copy of Fluidigm’s Conflict Minerals Policy is publicly available at http://files.shareholder.com/downloads/ABEA-5TB8PR/3172172539x0x735398/D7B54E37-F6AD-42DE-8862-A25472E9189F/Fluidigm_Conflict_Minerals_Policy.pdf. |
| b. | Internal Management to Support Supply Chain Due Diligence. Fluidigm’s legal department has been charged with the management of our conflict minerals program, working in collaboration with members from our operations team in Singapore, Canada, and the United States. |
| c. | Controls and Transparency. As described above, we undertook a RCOI with respect to conflict minerals in our supply chain by providing the CFSI Template to each of our first tier suppliers to gather information about their use of 3TG minerals, the smelters and refiners in their supply chain that are included in our products, and the countries of origin for 3TG minerals used in our products. We reviewed all responses for completeness, reasonableness, and consistency. We followed up for corrections and clarifications as we determined appropriate. |
| d. | Supplier Engagement. We continue to engage actively with our first tier suppliers to strengthen our relationship with them. We have communicated to our suppliers our commitment to source conflict minerals in a manner that does not, directly or indirectly, benefit armed groups in the Covered Countries. We will consider alternative arrangements for our supply needs if our suppliers are unable to cooperate in our due diligence efforts. In particular, as part of our supplier qualification process, we now require conflict minerals information from each new supplier of potentially applicable products. |
| e. | Grievance Mechanism. Our code of conduct includes procedures for reporting violations of our policies, including our Conflict Minerals Policy. We provide mechanisms for anonymous reporting of violations or concerns about the conduct of our business, including the implementation and enforcement of our Conflict Minerals Policy. |
| 2. | Identification and Assessment of Risks in the Supply Chain |
As discussed above, we identified our first tier suppliers and relied on them to provide the necessary information about the use of 3TG minerals in the products we purchase and incorporate into the manufacture of our systems and IFCs, and the source of such 3TG minerals. Similarly, our first tier suppliers rely on information provided by their suppliers to provide information regarding the country of origin of 3TG minerals included in our products.
| 3. | Designing and Implementing a Strategy to Respond to Identified Risks |
We have developed a formal risk management plan through which our conflict minerals program is managed and monitored. As part of this risk management plan, where applicable, we will review
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circumstances in which certain suppliers are unable to provide us with complete or reliable responses to the CFSI Template including, without limitation, considering whether to continue such contract or relationship or find a replacement supplier.
| 4. | Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
We do not have a direct relationship with any smelters or refiners in our supply chain. As a result, we do not and cannot conduct any audits directly. Instead, we support the development and implementation of independent third party audits of smelters such as the Conflict-Free Smelter Program (“CFSP”) by encouraging our suppliers to purchase materials from audited, conflict-free smelters and determining whether the smelters that were used to process these minerals were validated as conflict-free by the CFSP.
| 5. | Reporting on Supply Chain Due Diligence |
In 2016, we publicly filed the Form SD and this Report with the SEC. A copy of this Report and the Form SD are publicly available at http://investors.fluidigm.com/sec.cfm. This Report includes information about the RCOI methodology utilized by the Company, the design of our due diligence process in conformance with the OECD Framework, the list of known smelters and refiners utilized in our supply chain identified in our due diligence process, and a description of our products that incorporate 3TG minerals necessary to the functionality or production of such products.
Smelters and Refiners in Fluidigm’s Supply Chain
We adopted CFSI’s industry approach to trace back the origin of 3TG minerals by identifying smelters, refineries, or recyclers and scrap supplier sources. We have leveraged industry initiatives such as the CFSP, which is a voluntary initiative in which an independent third party audits smelters and refineries to determine if all of the minerals processed by the smelter or refiner originated from conflict free sources. Participation in the CFSP provides us with verified information about the sourcing activities of the smelters and refiners in our supply chain.
As discussed above, we submitted the CFSI Template to our first tier suppliers. Most of the responses received from our first tier suppliers provided information at company/division levels, rather than specific product/part number levels. As a result, we were unable to determine whether or to what extent any of the 3TG minerals reported as used by these first tier suppliers were contained specifically in components supplied to us. We also were unable to validate whether the smelters or refiners reported by such first tier suppliers are actually in our supply chain. Accordingly, based on information that was provided by our first tier suppliers or that was otherwise obtained through our due diligence process, we are unable to determine and describe all facilities used to process the 3TG minerals contained in our covered products.
Based on the information that was provided by our suppliers and otherwise obtained through the due diligence process, we believe that, to the extent reasonably determinable, the facilities that were used to process the 3TG minerals contained in the covered products included the smelters and refiners listed in Annex A attached hereto. This table includes only facilities that are listed in the CFSI Smelter Reference List as of May 26, 2016. An indication of “Compliant” in the far right column of the table indicates that the smelter or refinery has received a “conflict free” designation from an independent third party audit program or is presently undergoing a re-audit to maintain its “conflict free” designation. An indication of “In Process” in the far right column of the table indicates
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that the smelter or refinery has not yet received a “conflict free” designation, but is undergoing an audit process that will determine such status. An indication of “Unknown” in the far right column of the table indicates that the smelter or refinery has not received a “conflict free” designation from an independent third party audit program or the facility’s receipt of such designation is undeterminable.
Because the CFSI generally did not indicate individual countries of origin of the conflict minerals processed by smelters and refiners, we were not able to determine the countries of origin of the 3TG minerals processed by the listed smelters and refiners with greater specificity. Therefore, based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the 3TG minerals contained in the covered products.
As reported earlier, we endeavored to determine the mine or location of origin of the 3TG minerals contained in the covered products by conducting a supply-chain survey with our first tier suppliers using the CFSI Template and through the information made available by the CFSI to its members.
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Fluidigm. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect our 3TG mineral status. These factors include, but are not limited to, gaps in supplier data; gaps in smelter data; errors or omissions by suppliers; errors or omissions by smelters; the definition of a smelter not being finalized at the end of the 2015 reporting period; all instances of 3TG minerals necessary to the functionality or manufacturing of our products not yet having been identified; gaps in supplier education and knowledge; timeliness of data; public information not discovered during a reasonable search; errors in public data; language barriers and translation; supplier and smelter unfamiliarity with the protocols for identifying and sourcing potential 3TG minerals; oversight or errors in conflict free smelter audits; Covered Countries sourced materials being declared secondary materials; companies going out of business in 2015; certification programs being not equally advanced for all industry segments and metals; and smuggling of 3TG minerals from the Covered Countries to other countries.
Future Steps
We have communicated our expectations to our first tier suppliers regarding our commitment to sourcing minerals for our products in a manner that does not, directly or indirectly, finance or benefit armed groups in the DRC or adjoining countries. We expect to continue to increase our engagement with our relevant suppliers over the next year to build their knowledge and capacity so they are able to provide us with more complete and accurate information on the source and chain of custody of the 3TG included in components and parts purchased by us and incorporated into our products.
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Annex A
2015 Facility and Country List
| Metal |
Facility Name |
Country |
Compliance Status | |||
| Gold | Advanced Chemical Company | United States | In Process | |||
| Gold | Aida Chemical Industries Co., Ltd. | Japan | Compliant | |||
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | Unknown | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | Compliant | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | In Process | |||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | 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 | Compliant | |||
| Gold | Asaka Riken Co., Ltd. | Japan | Compliant | |||
| Gold | AURA-II | United States | Unknown | |||
| Gold | Aurubis AG | Germany | Compliant | |||
| Gold | Bangalore Refinery | India | Unknown | |||
| 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 | Unknown | |||
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | Compliant | |||
| Gold | Cendres + Métaux S.A. | Switzerland | In Process | |||
| Gold | Chimet S.p.A. | Italy | Compliant | |||
| Gold | Chugai Mining | Japan | Unknown | |||
| Gold | Daejin Indus Co., Ltd. | Korea, Republic of | In Process | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | Unknown | |||
| Gold | DODUCO GmbH | Germany | Compliant | |||
| Gold | Dowa | Japan | Compliant | |||
| Gold | DSC (Do Sung Corporation) | Korea, Republic of | In Process | |||
| Gold | Eco-System Recycling Co., Ltd. | Japan | Compliant | |||
| Gold | Elemetal Refining, LLC | United States | Compliant | |||
| Gold | Emirates Gold DMCC | United Arab Emirates | Compliant | |||
| Gold | Faggi Enrico S.p.A. | Italy | In Process | |||
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | Unknown | |||
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | China | Unknown | |||
| Gold | Geib Refining Corporation | United States | In Process | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | Unknown |
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| Gold | Guangdong Jinding Gold Limited | China | Unknown | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | Unknown | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Unknown | |||
| Gold | Heimerle + Meule GmbH | Germany | Compliant | |||
| Gold | Heraeus Ltd. Hong Kong | China | Compliant | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Compliant | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | Unknown | |||
| Gold | Hwasung CJ Co., Ltd. | Korea, Republic of | Unknown | |||
| 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 | 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 | Unknown | |||
| Gold | Kazakhmys Smelting LLC | Kazakhstan | Unknown | |||
| Gold | Kazzinc | Kazakhstan | Compliant | |||
| Gold | Kennecott Utah Copper LLC | United States | Compliant | |||
| Gold | KGHM Polska Miedź Spółka Akcyjna | Poland | In Process | |||
| Gold | Kojima Chemicals Co., Ltd. | Japan | Compliant | |||
| Gold | Korea Metal Co., Ltd. | Korea, Republic of | Unknown | |||
| Gold | Korea Zinc Co., Ltd. | Korea, Republic of | In Process | |||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | Unknown | |||
| Gold | L’azurde Company For Jewelry | Saudi Arabia | Unknown | |||
| Gold | Lingbao Gold Co., Ltd. | China | Unknown | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | Unknown | |||
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of | Compliant | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | Unknown | |||
| Gold | Materion | United States | 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 | In Process | |||
| Gold | Metalor Technologies S.A. | Switzerland | Compliant | |||
| Gold | Metalor USA Refining Corporation | United States | Compliant | |||
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | Mexico | Compliant | |||
| Gold | Mitsubishi Materials Corporation | Japan | Compliant | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Compliant |
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| Gold | MMTC-PAMP India Pvt., Ltd. | India | Compliant | |||
| Gold | Morris and Watson | New Zealand | Unknown | |||
| Gold | Morris and Watson | Australia | Unknown | |||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | Compliant | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey | Compliant | |||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | In Process | |||
| Gold | Nihon Material Co., Ltd. | Japan | Compliant | |||
| Gold | Ögussa Österreichische 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 | |||
| Gold | PAMP S.A. | Switzerland | Compliant | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | Unknown | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | Compliant | |||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Compliant | |||
| Gold | PX Précinox S.A. | Switzerland | Compliant | |||
| Gold | Rand Refinery (Pty) Ltd. | South Africa | Compliant | |||
| Gold | Remondis Argentia B.V. | Netherlands | Unknown | |||
| Gold | Republic Metals Corporation | United States | Compliant | |||
| Gold | Royal Canadian Mint | Canada | Compliant | |||
| Gold | SAAMP | France | Unknown | |||
| Gold | Sabin Metal Corp. | United States | Unknown | |||
| Gold | Samduck Precious Metals | Korea, Republic of | In Process | |||
| Gold | SAMWON Metals Corp. | Korea, Republic of | Unknown | |||
| Gold | SAXONIA Edelmetalle GmbH | Germany | In Process | |||
| Gold | Schone Edelmetaal B.V. | Netherlands | Compliant | |||
| Gold | SEMPSA Joyería Platería S.A. | Spain | Compliant | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | Unknown | |||
| 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 | Compliant | |||
| Gold | So Accurate Group, Inc. | United States | Unknown | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | Compliant | |||
| Gold | Solar Applied Materials Technology Corp. | Taiwan | Compliant | |||
| Gold | Sudan Gold Refinery | Sudan | Unknown | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | 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 |
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| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | Unknown | |||
| Gold | Tony Goetz NV | Belgium | Unknown | |||
| Gold | Torecom | Korea, Republic of | In Process | |||
| 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 | Compliant | |||
| Gold | Valcambi S.A. | Switzerland | Compliant | |||
| Gold | Western Australian Mint trading as The Perth Mint | Australia | Compliant | |||
| Gold | WIELAND Edelmetalle GmbH | Germany | In Process | |||
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan | Compliant | |||
| Gold | Yokohama Metal Co., Ltd. | Japan | Compliant | |||
| Gold | Yunnan Copper Industry Co., Ltd. | China | Unknown | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Compliant | |||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | China | Compliant | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | Compliant | |||
| Tantalum | Conghua Tantalum and Niobium Smeltry | China | Compliant | |||
| Tantalum | D Block Metals, LLC | United States | Compliant | |||
| Tantalum | Duoluoshan | China | Compliant | |||
| Tantalum | E.S.R. Electronics | United States | In Process | |||
| Tantalum | Exotech Inc. | United States | 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 | Compliant | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | Compliant | |||
| Tantalum | H.C. Starck Co., Ltd. | Thailand | Compliant | |||
| Tantalum | H.C. Starck GmbH Goslar | Germany | Compliant | |||
| Tantalum | H.C. Starck GmbH Laufenburg | Germany | Compliant | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany | Compliant | |||
| Tantalum | H.C. Starck Inc. | United States | Compliant | |||
| Tantalum | H.C. Starck Ltd. | Japan | Compliant | |||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | Compliant | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Compliant | |||
| Tantalum | Hi-Temp Specialty Metals, Inc. | United States | 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 Tanbre Co., Ltd. | China | Compliant | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Compliant | |||
| Tantalum | KEMET Blue Metals | Mexico | Compliant |
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| Tantalum | KEMET Blue Powder | United States | 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 | Mineração Taboca S.A. | Brazil | Compliant | |||
| Tantalum | Mitsui Mining & Smelting | Japan | Compliant | |||
| Tantalum | Molycorp Silmet A.S. | Estonia | Compliant | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Compliant | |||
| Tantalum | Plansee SE Liezen | Austria | Compliant | |||
| Tantalum | Plansee SE Reutte | Austria | Compliant | |||
| Tantalum | QuantumClean | United States | Compliant | |||
| Tantalum | Resind Indústria e Comércio Ltda. | Brazil | Compliant | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China | Compliant | |||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | Compliant | |||
| Tantalum | Taki Chemicals | Japan | Compliant | |||
| Tantalum | Telex Metals | United States | Compliant | |||
| Tantalum | Tranzact, Inc. | United States | 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 | China | Compliant | |||
| Tin | Alpha | United States | Compliant | |||
| Tin | An Thai Minerals Co., Ltd. | Viet Nam | In Process | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | In Process | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | In Process | |||
| Tin | China Tin Group Co., Ltd. | China | Compliant | |||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | China | Unknown | |||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | Brazil | Compliant | |||
| Tin | CV Ayi Jaya | Indonesia | Compliant | |||
| Tin | CV Dua Sekawan | Indonesia | In Process | |||
| Tin | CV Gita Pesona | Indonesia | Compliant | |||
| Tin | CV Serumpun Sebalai | Indonesia | Compliant | |||
| Tin | CV Tiga Sekawan | Indonesia | In Process | |||
| 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 | In Process | |||
| Tin | Elmet S.L.U. | Spain | Compliant | |||
| Tin | EM Vinto | Bolivia | Compliant | |||
| Tin | Estanho de Rondônia S.A. | Brazil | Unknown |
10
| Tin | Feinhütte Halsbrücke GmbH | Germany | Unknown | |||
| Tin | Fenix Metals | Poland | Compliant | |||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | China | In Process | |||
| Tin | Gejiu Jinye Mineral Company | China | In Process | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | In Process | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Compliant | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | In Process | |||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | Unknown | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China | In Process | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | In Process | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | China | Unknown | |||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China | Compliant | |||
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | China | Unknown | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | Brazil | Compliant | |||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Compliant | |||
| Tin | Melt Metais e Ligas S.A. | Brazil | Compliant | |||
| Tin | Metallic Resources, Inc. | United States | Compliant | |||
| Tin | Metallo-Chimique N.V. | Belgium | Compliant | |||
| Tin | Mineração Taboca S.A. | Brazil | Compliant | |||
| Tin | Minsur | Peru | Compliant | |||
| Tin | Mitsubishi Materials Corporation | Japan | Compliant | |||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | China | Unknown | |||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | In Process | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Compliant | |||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | Compliant | |||
| Tin | Operaciones Metalurgical S.A. | Bolivia | Compliant | |||
| Tin | Phoenix Metal Ltd. | Rwanda | In Process | |||
| Tin | PT Alam Lestari Kencana | Indonesia | Unknown | |||
| 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 Kudai Tin | Indonesia | Unknown | |||
| Tin | PT Bangka Prima Tin | Indonesia | Compliant | |||
| Tin | PT Bangka Timah Utama Sejahtera | Indonesia | Unknown | |||
| Tin | PT Bangka Tin Industry | Indonesia | Compliant | |||
| Tin | PT Belitung Industri Sejahtera | Indonesia | Compliant | |||
| Tin | PT BilliTin Makmur Lestari | Indonesia | Compliant | |||
| Tin | PT Bukit Timah | Indonesia | Compliant | |||
| Tin | PT Cipta Persada Mulia | Indonesia | Compliant | |||
| Tin | PT DS Jaya Abadi | Indonesia | Compliant | |||
| Tin | PT Eunindo Usaha Mandiri | Indonesia | Compliant |
11
| Tin | PT Fang Di MulTindo | Indonesia | Unknown | |||
| Tin | PT Inti Stania Prima | Indonesia | Compliant | |||
| Tin | PT Justindo | Indonesia | Compliant | |||
| Tin | PT Karimun Mining | Indonesia | In Process | |||
| Tin | PT Kijang Jaya Mandiri | Indonesia | In Process | |||
| Tin | PT Mitra Stania Prima | Indonesia | Compliant | |||
| Tin | PT Panca Mega Persada | Indonesia | Compliant | |||
| Tin | PT Pelat Timah Nusantara Tbk | Indonesia | Unknown | |||
| Tin | PT Prima Timah Utama | Indonesia | Compliant | |||
| Tin | PT Refined Bangka Tin | Indonesia | Compliant | |||
| Tin | PT Sariwiguna Binasentosa | Indonesia | Compliant | |||
| Tin | PT Seirama Tin Investment | Indonesia | Unknown | |||
| 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 Tirus Putra Mandiri | Indonesia | Unknown | |||
| Tin | PT Tommy Utama | Indonesia | Compliant | |||
| Tin | PT Wahana Perkit Jaya | Indonesia | Compliant | |||
| Tin | Resind Indústria e Comércio Ltda. | Brazil | Compliant | |||
| Tin | Rui Da Hung | Taiwan | Compliant | |||
| Tin | Soft Metais Ltda. | Brazil | Compliant | |||
| Tin | Thaisarco | Thailand | Compliant | |||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | In Process | |||
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | Compliant | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | Brazil | Compliant | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | In Process | |||
| Tin | Yunnan Tin Company Limited | China | Compliant | |||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | Compliant | |||
| Tungsten | ACL Metais Eireli | Brazil | In Process | |||
| 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 | Dayu Jincheng Tungsten Industry Co., Ltd. | China | Unknown | |||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China | Unknown | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | Compliant | |||
| Tungsten | Ganxian Shirui New Material Co., Ltd. | China | Unknown | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | Compliant | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Compliant |
12
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | China | Unknown | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Compliant | |||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China | Compliant | |||
| Tungsten | Global Tungsten & Powders Corp. | United States | Compliant | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | Compliant | |||
| Tungsten | H.C. Starck GmbH | Germany | Compliant | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany | Compliant | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | Compliant | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China | Compliant | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | China | Unknown | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | Compliant | |||
| Tungsten | Hydrometallurg, JSC | Russian Federation | Compliant | |||
| Tungsten | Japan New Metals Co., Ltd. | Japan | Compliant | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | In Process | |||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | China | In Process | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Compliant | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | China | Unknown | |||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | In Process | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | In Process | |||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China | Compliant | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | In Process | |||
| Tungsten | Kennametal Fallon | United States | In Process | |||
| Tungsten | Kennametal Huntsville | United States | Compliant | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | Compliant | |||
| Tungsten | Moliren Ltd | Russian Federation | In Process | |||
| Tungsten | Niagara Refining LLC | United States | Compliant | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Viet Nam | Compliant | |||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | Compliant | |||
| Tungsten | Pobedit, JSC | Russian Federation | Unknown | |||
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | Viet Nam | Unknown | |||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China | In Process | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Viet Nam | Compliant | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Viet Nam | Compliant | |||
| Tungsten | Wolfram Bergbau und Hütten AG | Austria | Compliant | |||
| Tungsten | Woltech Korea Co., Ltd. | Korea, Republic of | In Process | |||
| 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 | In Process | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | Compliant |
13