Dover Corporation

05/31/2023 | Press release | Distributed by Public on 05/31/2023 13:32

Specialized Disclosure Report - Form SD

Dover Corporation
Conflict Minerals Report
For the Year Ended December 31, 2022

The Company has made statements in this Conflict Minerals Report that may constitute forward-looking statements about its plans to take additional actions or to implement additional policies or procedures with respect to its "reasonable country of origin inquiry" and due diligence to determine the origin of Conflict Minerals included in the Company products. The Company undertakes no obligation to update or revise any forward-looking statement, whether as a result of new information, future events or otherwise. The Company's reporting obligations under the Dodd-Frank Act may change in the future, and its ability to implement certain processes may differ materially from those anticipated or implied in this report. Additionally, the Company relies on its direct material suppliers, which may be many steps removed from smelters or refiners of Conflict Minerals in supply chains, for information required to meet its reporting obligations. There can be no assurance that the information received from its direct suppliers will be complete and accurate or that when the Company receives such information, it will be able to make a determination as to whether the products manufactured contain Conflict Minerals originating in certain countries in support of armed groups operating in those countries.

This report for the year ended December 31, 2022 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. "Conflict Minerals" or "3TG" minerals are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold.

Based on information received to date, Dover Corporation ("Dover" or the "Company") is unable to conclude whether the Conflict Minerals used in its products may have originated from the Democratic Republic of the Congo (the "DRC") or adjoining countries (collectively, the DRC and adjoining countries are the "Covered Countries") in circumstances that support armed groups in the region.

The information contained in this report is not audited.

The Company conducted a Reasonable Country of Origin Inquiry ("RCOI") concerning Conflict Minerals included in its products.


The Company's products include a variety of industrial equipment as outlined below. These products, along with their manufacturing locations, are more fully described on its website, Information contained on the Company's website or otherwise actively linked to this report is not part of, nor incorporated by reference into, this report or the Company's Form SD.

Engineered Products. Products in the Company's Engineered Products segment include electronic components that incorporate tantalum, tin and gold. Other product lines incorporate tungsten and tantalum where required for durability or strength.

Clean Energy & Fueling. Products in the Company's Clean Energy & Fueling segment include electronic components and measuring device components that incorporate tantalum, tin and gold. Other product lines incorporate tungsten and tantalum where required for durability or strength.

Imaging & Identification. Products in the Company's Imaging & Identification segment include electronic components that incorporate tantalum, tin and gold. Other product lines incorporate tungsten and tantalum where required for durability or strength.


Pumps & Process Solutions. Products in the Company's Pumps & Process Solutions segment include electronic components and measuring device components that incorporate tantalum, tin and gold. Product lines incorporate tungsten and tantalum, as in the pump product lines, where required for durability.

Climate & Sustainability Technologies. Products manufactured in the Company's Climate & Sustainability Technologies segment include electronic components that incorporate tantalum, tin and gold. Lighting in the refrigeration and food equipment may include tungsten. Other industrial product lines may include tantalum and tungsten where required for durability.


The Company has adopted a "conflict free" supply chain policy. The policy has been communicated to suppliers through the Company's Supplier Code of Conduct, the Conflict Minerals survey process and through its efforts to implement related terms and conditions in supplier contracts. As part of its regular internal audit processes, the Company audits whether its operating companies have incorporated the Company's Supplier Code of Conduct and approved terms and conditions into their standard documents.

The Company's Conflict Minerals Policy is available on the Company's website at:

III.Design of the Due Diligence Process

The Company has undertaken to identify and assess the conflict mineral risk in its supply chain in accordance with 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, including the Supplement on Tin, Tantalum and Tungsten, and the Supplement on Gold (the "OECD Guidance") and in accordance with the requirements of the Dodd-Frank Act. The Company's activities are described in the five steps outlined in that OECD Guidance and in the Responsible Minerals Initiative's (formerly the Conflict Free Sourcing Initiative) Five Practical Steps for Conflict Minerals Due Diligence and SEC Disclosure.

Step 1. Establish Strong Company Management Systems

Since 2013, the Company has appointed senior executives to oversee the Conflict Minerals reporting and compliance processes. To manage the day-to-day administration of the RCOI process, the Company appointed a separate Conflict Minerals team. In 2013, the Company retained a major accounting firm to assist it in the preliminary planning and initial execution of its RCOI in accordance with the standards set forth in the OECD Guidance, and selected, developed and implemented a survey tool and database functionality that allowed it to receive, review and report on the results of its survey process. The Company has implemented a process to retain the information obtained through the survey tool for a period of not less than five years. In 2015, in anticipation of a requirement to obtain an audit of its Conflict Minerals disclosure, the Company retained a separate accounting firm to review its Conflict Minerals survey processes; however, the Company has not undertaken an audit, as permitted by guidance issued by the U.S. Securities and Exchange Commission. In 2019, the Company engaged a nationally recognized third party provider to assist with identifying and surveying suppliers, and to provide additional data collection and data analysis assistance. The third party provider's survey tool replaced the Company-developed survey tool that was used through 2018 reporting. The third party provider was selected based on its experience, access to shared supplier databases and technical solutions to assist in the Conflict Minerals survey process, and has continued to work with the Company for the 2022 report. Information obtained through the third party provider's survey tool will also be retained for five years, in accordance with the Company's policy.

The Company's Conflict Minerals reporting program aligns with the OECD Due Diligence Guidance and the requirements of the Dodd-Frank Act. The Company is aware that its customers have also sought information on smelters and refiners who may be involved in human trafficking or in Russian extraction and smelting suppliers, however this report submitted in accordance with the Dodd-Frank Act requirements does not address those issues.

Step 2. Identify and Assess Risks in the Supply Chain

The Conflict Minerals team engaged with operating company supply chain, operations and engineering personnel to determine the applicable categories of purchasing activity and to identify parts, materials and components which its operating companies reasonably expected may contain Conflict Minerals or where mineral content is unknown.

Based on data collected in 2012 through 2021, the Company has been able to refine its process of identifying a list of suppliers to survey where the purchased items were directly incorporated into the Company's products. Suppliers of indirect materials, consulting fees, and capital project costs, for example, were not included in the surveys. By following this approach, the Company was able to concentrate its 2022 survey efforts on relevant suppliers, including those with the potentially highest risk on the Company's operating companies, based on the largest spend within the Company's supply chain. The Company was also able to leverage its third party survey provider's expertise and access to supplier surveys for other clients to obtain information from more suppliers who were potentially in scope for products that included Conflict Minerals, and help identify risks within the Company's supply chains.

In 2022, Company has issued surveys to 664 suppliers of parts, materials and components that potentially include Conflict Minerals based on classifications in the Company's spend management system and information available through supply chain and engineering personnel. The Company's third party provider followed up on survey responses that included discrepancies or did not address the survey questions or where information provided by suppliers indicated potential sources within the Covered Countries.

In the 2022 survey responses, suppliers were asked to identify smelters located in the Covered Countries that might be the source of 3TG minerals included in products purchased by the Company. In some cases, suppliers were unable to identify the smelters or countries of origin in their supply chain. Many suppliers responded to the survey at the company level, by providing information related to all of the items the supplier produces, without identifying smelters specific to the items purchased by the Company. A large number of the Company's suppliers remain several steps removed from the ultimate smelter, or are unable to identify smelters specific to the products purchased by the Company, because of the number of lower level suppliers with incomplete information about their own sources. In responses received, 173 suppliers identified tin, 121 identified tantalum, 127 identified tungsten, and 139 identified gold smelters as being located in the Covered Countries. Using the smelter information provided by suppliers, the third party survey provider reviewed the smelter information provided to determine if the smelters were included in the RBA Conformant Smelter or supplier identification list (the "RBA List") and other published smelter information and reported findings to the Company.

The Company is aware that some of the smelters with identification numbers from the Responsible Business Alliance ("RBA") have not completed the RBA audit process or periodic reaudit or recertification processes. Smelters identified on an RBA active list have committed to participate in a certification program with respect to the sources of their raw materials. Smelters on the active list are at various stages of the audit cycle, which may include post-audit corrective actions. RBA has indicated that the time it takes a smelter to complete an audit cycle varies.

The Company has identified 314 smelters that align with RBA List numbers based on the information provided by its suppliers for the current year. Because of the functionality of the survey tool in use, there are additional "smelter" names provided by suppliers that could not be tied to or verified to the RBA List when reviewed by the third party survey company. The information provided for these non- RBA entities is not adequate for the Company to verify that the identified entities are, in fact, smelters.

A number of suppliers have indicated that the Conflict Minerals included in their products come from recycled sources, but generally could not certify that all of the Conflict Minerals used come from recycled sources. The Company relies on its suppliers to conduct the intermediate due diligence of second, third or lower level suppliers, and based on the responses from suppliers in its inquiry, suppliers have not received sufficient information to be able to complete those inquiries to date.

Step 3. Design and Implement a Strategy to Respond to Identified Risks


The Company's management is briefed on the status of due diligence efforts on a regular basis. The Company's Conflict Minerals Policy has been distributed to the operating companies in each of the Company's five business segments and is incorporated into contracts and purchase orders placed by those operating companies. The Company has developed a risk management plan that outlines the Company's response to any identified risks related to sourcing of materials from the Covered Countries, although the Company is currently not aware of any circumstance where it has been necessary to consider implementing those risk mitigation efforts and has not suspended trade or disengaged from a supplier. Where suppliers have not been able to provide information on smelters, the Company may have a risk that the smelters used by such suppliers are not compliant with its policy.

Step 4. Carry Out an Independent Third-Party Audit of Smelter's or Refiner's Due Diligence Practices

The Company currently does not engage in independent auditing of smelters or refiners identified in its supply chain. The Company is a member of the Responsible Minerals Initiative ("RMI") and supports the auditing efforts of that organization through its financial support.

Step 5. Report Annually on Supply Chain Due Diligence

This Conflict Minerals Report constitutes our annual report on the Conflict Minerals due diligence of the Company. A copy of this Conflict Minerals Report is available on the Dover Corporation website at

IV. Results of the Company's Due Diligence to Date1

Dover's survey methodology was first developed, piloted and deployed during the 2013 calendar year. Surveys of operating company suppliers have been conducted beginning in 2013 and have continued through March 31, 2023. The original survey format used was updated as changes were made in the recommended RMI format. Since 2019, the Company has retained the services of a nationally recognized third-party provider with expertise in Conflict Minerals solicitations and that also provided a platform to review responses and enhance follow- up on missing or incomplete surveys. That third party was also retained for the 2022 solicitation and reporting. In conducting a "Reasonable Country of Origin Inquiry" for the period from January 1, 2022 through March 31, 2023, the Company reviewed and determined applicability of the RCOI process for suppliers that account for about 45% of its annualized materials related spend for 2022.

The Company received survey responses back from about 74% of the suppliers surveyed. A number of respondents indicated that their products contain Conflict Minerals, but those suppliers cannot yet determine whether those Conflict Minerals originate in the Covered Countries for one or more of the 3TG minerals. Of those suppliers who could not identify any sources, 61 included tin, 48 included tantalum, 47 included tungsten, and 64 suppliers included gold in their products.

Of those respondents that said they had identified all sources of a specific 3TG mineral, a number had identified that their supply chain sources included Covered Country sources. Of those suppliers who had said they had identified all sources for one or more 3TG minerals, including Covered Country sources, in their own supply chains, 114 identified all tin sources, 43 identified all tantalum sources, 52 identified all tungsten sources and 64 had identified all gold sources.

Of the respondents, 247 suppliers indicated that they have developed corrective action plans concerning Conflict Minerals in their products.

Many suppliers responded to the surveys by providing information for Conflict Mineral content and smelters for all products they sell, without distinguishing those contents or smelters applicable to the
1 Supplier responses include surveys issued and answers received by the Company in 2022 and through March 31, 2023. In determining spend, the Company has considered internal information through March 2023, for spend incurred in calendar year 2022, not including any operating company entities which were divested in the course of 2022, where the spend data for those entities was removed from the database, or those entities acquired during 2022 which are not currently integrated into the Company's spend database.


products purchased by the Company from them. Accordingly, Dover is unable to determine specific smelters or sources that may be included in the products purchased from those suppliers. The Company continues to issue surveys to suppliers and follow-up on the information received in response to surveys.

The Company's suppliers have provided information on smelters in response to the Company's surveys. Because the Company is a number of steps removed from the smelter sources and its suppliers are unable to link any specific smelter to the products and materials provided by those suppliers to the Company, the Company is unable to confirm that any of the smelter names provided are, in fact, sources of Conflict Minerals in the Company's products. Based on these survey responses through March 31, 2023, the Company has identified 314 smelters from the RBA List. Such smelters are included in the list attached as Annex A to this Report. Suppliers have also provided names that the suppliers describe as "smelters" but could not be linked by the Company's consultant to actual smelters on the RBA List and as such, may not, in fact, be smelters. In most cases, this incomplete information provided by suppliers consists of partial names and/or locations. The Company believes those incomplete or unmatched names may result in additional sources of the 3TG minerals that are not included in the RBA List. The Company and its third-party survey consultant believe that many of those names likely could be matched to RBA lists, or to non-smelter company names if the Company's suppliers had more complete information from their own supply chain.

Dover is unable to determine where the Conflict Minerals included in its supply chain originate. As a result, Dover is unable to make a determination as to whether the Conflict Minerals included in its supply chain financed or benefited armed groups in the Covered Countries, or came from recycled or scrap sources, or to discern which of the identified facilities (smelters or refiners) process such Conflict Minerals.

Because the Company is several steps removed from smelters and mines, the Company must rely on suppliers in its supply chain to complete their own due diligence on country of origin.

V.Additional Steps of the Company to Mitigate Risks and Improve Due Diligence

The Company, through members of its Conflict Minerals team, participates in industry-wide programs to facilitate sharing of information about smelter programs and conflict-free sourcing, including the RMI, and to review developments in reporting. The Company has also participated in training sessions with its third-party survey provider.

The Company has considered processes for corrective actions including remediation or termination that may be taken where suppliers identify problematic sources of Conflict Minerals during the survey process. For specific suppliers, corrective actions may depend on factors such as vendor size, risk level, vendor capabilities and the Company's ability to meet quality control requirements associated with customer specifications. To date, the Company has not undertaken remediation with any supplier. Because the Company is a number of steps removed from smelters within its supply chain, lack of information from suppliers on smelters continues to be a risk that the Company seeks to address.

The Company continues to implement Conflict Minerals contract clauses where appropriate for its suppliers. The Company's Supplier Code of Conduct includes Conflict Minerals reporting requirements, and the Company's operating companies are communicating those requirements to the supply chain.



All Smelter Identification Numbers refer to CFS assigned numbers.

Gold Advanced Chemical Company United States Of America CID000015
Gold Aida Chemical Industries Co., Ltd. Japan CID000019
Gold Allgemeine Gold-und Silberscheideanstalt A.G. Germany CID000035
Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan CID000041
Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil CID000058
Gold Argor-Heraeus S.A. Switzerland CID000077
Gold Asahi Pretec Corp. Japan CID000082
Gold Asaka Riken Co., Ltd. Japan CID000090
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey CID000103
Gold Aurubis AG Germany CID000113
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines CID000128
Gold Boliden AB Sweden CID000157
Gold C. Hafner GmbH + Co. KG Germany CID000176
Gold Caridad Mexico CID000180
Gold CCR Refinery - Glencore Canada Corporation Canada CID000185
Gold Cendres + Metaux S.A. Switzerland CID000189
Gold Yunnan Copper Industry Co., Ltd. China CID000197
Gold Chimet S.p.A. Italy CID000233
Gold Chugai Mining Japan CID000264
Gold Daye Non-Ferrous Metals Mining Ltd. China CID000343
Gold DSC (Do Sung Corporation) Korea, Republic Of CID000359
Gold Dowa Japan CID000401
Gold Eco-System Recycling Co., Ltd. East Plant Japan CID000425
Gold OJSC Novosibirsk Refinery Russian Federation CID000493
Gold Refinery of Seemine Gold Co., Ltd. China CID000522
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. China CID000651
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. China CID000671
Gold LT Metal Ltd. Korea, Republic Of CID000689
Gold Heimerle + Meule GmbH Germany CID000694
Gold Heraeus Metals Hong Kong Ltd. China CID000707
Gold Heraeus Precious Metals GmbH & Co. KG Germany CID000711
Gold Hunan Chenzhou Mining Co., Ltd. China CID000767
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China CID000773
Gold HwaSeong CJ CO., LTD. Korea, Republic Of CID000778
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China CID000801
Gold Ishifuku Metal Industry Co., Ltd. Japan CID000807
Gold Istanbul Gold Refinery Turkey CID000814

Gold Japan Mint Japan CID000823
Gold Jiangxi Copper Co., Ltd. China CID000855
Gold Asahi Refining USA Inc. United States Of America CID000920
Gold Asahi Refining Canada Ltd. Canada CID000924
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation CID000927
Gold JSC Uralelectromed Russian Federation CID000929
Gold JX Nippon Mining & Metals Co., Ltd. Japan CID000937
Gold Kazakhmys Smelting LLC Kazakhstan CID000956
Gold Kazzinc Kazakhstan CID000957
Gold Kennecott Utah Copper LLC United States Of America CID000969
Gold Kojima Chemicals Co., Ltd. Japan CID000981
Gold Kyrgyzaltyn JSC Kyrgyzstan CID001029
Gold L'azurde Company For Jewelry Saudi Arabia CID001032
Gold Lingbao Gold Co., Ltd. China CID001056
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. China CID001058
Gold LS-NIKKO Copper Inc. Korea, Republic Of CID001078
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China CID001093
Gold Materion United States Of America CID001113
Gold Matsuda Sangyo Co., Ltd. Japan CID001119
Gold Metalor Technologies (Suzhou) Ltd. China CID001147
Gold Metalor Technologies (Hong Kong) Ltd. China CID001149
Gold Metalor Technologies (Singapore) Pte., Ltd. Singapore CID001152
Gold Metalor Technologies S.A. Switzerland CID001153
Gold Metalor USA Refining Corporation United States Of America CID001157
Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico CID001161
Gold Mitsubishi Materials Corporation Japan CID001188
Gold Mitsui Mining and Smelting Co., Ltd. Japan CID001193
Gold Moscow Special Alloys Processing Plant Russian Federation CID001204
Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey CID001220
Gold Navoi Mining and Metallurgical Combinat Uzbekistan CID001236
Gold Nihon Material Co., Ltd. Japan CID001259
Gold Ohura Precious Metal Industry Co., Ltd. Japan CID001325
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation CID001326
Gold PAMP S.A. Switzerland CID001352
Gold Penglai Penggang Gold Industry Co., Ltd. China CID001362
Gold Prioksky Plant of Non-Ferrous Metals Russian Federation CID001386
Gold PT Aneka Tambang (Persero) Tbk Indonesia CID001397
Gold PX Precinox S.A. Switzerland CID001498
Gold Rand Refinery (Pty) Ltd. South Africa CID001512
Gold Royal Canadian Mint Canada CID001534
Gold Sabin Metal Corp. United States Of America CID001546

Gold Samduck Precious Metals Korea, Republic Of CID001555
Gold Samwon Metals Corp. Korea, Republic Of CID001562
Gold SEMPSA Joyeria Plateria S.A. Spain CID001585
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China CID001619
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China CID001622
Gold Sichuan Tianze Precious Metals Co., Ltd. China CID001736
Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation CID001756
Gold Solar Applied Materials Technology Corp. Taiwan, Province Of China CID001761
Gold Sumitomo Metal Mining Co., Ltd. Japan CID001798
Gold Super Dragon Technology Co., Ltd. Taiwan, Province Of China CID001810
Gold Tanaka Kikinzoku Kogyo K.K. Japan CID001875
Gold Great Wall Precious Metals Co., Ltd. of CBPM China CID001909
Gold The Refinery of Shandong Gold Mining Co., Ltd. China CID001916
Gold Tokuriki Honten Co., Ltd. Japan CID001938
Gold Tongling Nonferrous Metals Group Co., Ltd. China CID001947
Gold Torecom Korea, Republic Of CID001955
Gold Umicore S.A. Business Unit Precious Metals Refining Belgium CID001980
Gold United Precious Metal Refining, Inc. United States Of America CID001993
Gold Valcambi S.A. Switzerland CID002003
Gold Western Australian Mint (T/a The Perth Mint) Australia CID002030
Gold Yamakin Co., Ltd. Japan CID002100
Gold Yokohama Metal Co., Ltd. Japan CID002129
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation China CID002224
Gold Gold Refinery of Zijin Mining Group Co., Ltd. China CID002243
Gold Morris and Watson New Zealand CID002282
Gold SAFINA A.S. Czechia CID002290
Gold Guangdong Jinding Gold Limited China CID002312
Gold Umicore Precious Metals Thailand Thailand CID002314
Gold Geib Refining Corporation United States Of America CID002459
Gold MMTC-PAMP India Pvt., Ltd. India CID002509
Gold KGHM Polska Miedz Spolka Akcyjna Poland CID002511
Gold Fidelity Printers and Refiners Ltd. Zimbabwe CID002515
Gold Singway Technology Co., Ltd. Taiwan, Province Of China CID002516
Gold Shandong Humon Smelting Co., Ltd. China CID002525
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China CID002527
Gold Al Etihad Gold Refinery DMCC United Arab Emirates CID002560
Gold Emirates Gold DMCC United Arab Emirates CID002561
Gold International Precious Metal Refiners United Arab Emirates CID002562
Gold Kaloti Precious Metals United Arab Emirates CID002563
Gold Sudan Gold Refinery Sudan CID002567
Gold T.C.A S.p.A Italy CID002580

Gold REMONDIS PMR B.V. Netherlands CID002582
Gold Fujairah Gold FZC United Arab Emirates CID002584
Gold Industrial Refining Company Belgium CID002587
Gold Shirpur Gold Refinery Ltd. India CID002588
Gold Korea Zinc Co., Ltd. Korea, Republic Of CID002605
Gold Marsam Metals Brazil CID002606
Gold TOO Tau-Ken-Altyn Kazakhstan CID002615
Gold Abington Reldan Metals, LLC United States Of America CID002708
Gold Shenzhen CuiLu Gold Co., Ltd. China CID002750
Gold Albino Mountinho Lda. Portugal CID002760
Gold SAAMP France CID002761
Gold L'Orfebre S.A. Andorra CID002762
Gold 8853 S.p.A. Italy CID002763
Gold Italpreziosi Italy CID002765
Gold WIELAND Edelmetalle GmbH Germany CID002778
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria CID002779
Gold AU Traders and Refiners South Africa CID002850
Gold GGC Gujrat Gold Centre Pvt. Ltd. India CID002852
Gold Sai Refinery India CID002853
Gold Modeltech Sdn Bhd Malaysia CID002857
Gold Bangalore Refinery India CID002863
Gold Kyshtym Copper-Electrolytic Plant ZAO Russian Federation CID002865
Gold Degussa Sonne / Mond Goldhandel GmbH Germany CID002867
Gold Pease & Curren United States Of America CID002872
Gold JALAN & Company India CID002893
Gold SungEel HiMetal Co., Ltd. Korea, Republic Of CID002918
Gold Planta Recuperadora de Metales SpA Chile CID002919
Gold ABC Refinery Pty Ltd. Australia CID002920
Gold Safimet S.p.A Italy CID002973
Gold State Research Institute Center for Physical Sciences and Technology Lithuania CID003153
Gold African Gold Refinery Uganda CID003185
Gold Gold Coast Refinery Ghana CID003186
Gold NH Recytech Company Korea, Republic Of CID003189
Gold QG Refining, LLC United States Of America CID003324
Gold Dijllah Gold Refinery FZC United Arab Emirates CID003348
Gold CGR Metalloys Pvt Ltd. India CID003382
Gold Sovereign Metals India CID003383
Gold C.I Metales Procesados Industriales SAS Colombia CID003421
Gold Eco-System Recycling Co., Ltd. North Plant Japan CID003424
Gold Eco-System Recycling Co., Ltd. West Plant Japan CID003425
Gold Augmont Enterprises Private Limited India CID003461

Gold Kundan Care Products Ltd. India CID003463
Gold Emerald Jewel Industry India Limited (Unit 1) India CID003487
Gold Emerald Jewel Industry India Limited (Unit 2) India CID003488
Gold Emerald Jewel Industry India Limited (Unit 3) India CID003489
Gold Emerald Jewel Industry India Limited (Unit 4) India CID003490
Gold K.A. Rasmussen Norway CID003497
Gold Alexy Metals United States Of America CID003500
Gold Sancus ZFS (L'Orfebre, SA) Colombia CID003529
Gold Sellem Industries Ltd. Mauritania CID003540
Gold MD Overseas India CID003548
Gold Metallix Refining Inc. United States Of America CID003557
Gold Metal Concentrators SA (Pty) Ltd. South Africa CID003575
Gold WEEEREFINING France CID003615
Gold Gold by Gold Colombia Colombia CID003641
Gold Dongwu Gold Group China CID003663
Tantalum Changsha South Tantalum Niobium Co., Ltd. China CID000211
Tantalum F&X Electro-Materials Ltd. China CID000460
Tantalum Guangdong Zhiyuan New Material Co., Ltd. China CID000616
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. China CID000914
Tantalum Jiujiang Tanbre Co., Ltd. China CID000917
Tantalum LSM Brasil S.A. Brazil CID001076
Tantalum Metallurgical Products India Pvt., Ltd. India CID001163
Tantalum Mineracao Taboca S.A. Brazil CID001175
Tantalum Mitsui Mining and Smelting Co., Ltd. Japan CID001192
Tantalum NPM Silmet AS Estonia CID001200
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. China CID001277
Tantalum QuantumClean United States Of America CID001508
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China CID001522
Tantalum Solikamsk Magnesium Works OAO Russian Federation CID001769
Tantalum Taki Chemical Co., Ltd. Japan CID001869
Tantalum Telex Metals United States Of America CID001891
Tantalum Ulba Metallurgical Plant JSC Kazakhstan CID001969
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China CID002492
Tantalum D Block Metals, LLC United States Of America CID002504
Tantalum FIR Metals & Resource Ltd. China CID002505
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China CID002506
Tantalum XinXing HaoRong Electronic Material Co., Ltd. China CID002508
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China CID002512
Tantalum KEMET Blue Metals Mexico CID002539
Tantalum H.C. Starck Co., Ltd. Thailand CID002544
Tantalum H.C. Starck Tantalum and Niobium GmbH Germany CID002545

Tantalum H.C. Starck Inc. United States Of America CID002548
Tantalum H.C. Starck Ltd. Japan CID002549
Tantalum H.C. Starck Smelting GmbH & Co. KG Germany CID002550
Tantalum Global Advanced Metals Boyertown United States Of America CID002557
Tantalum Global Advanced Metals Aizu Japan CID002558
Tantalum Resind Industria e Comercio Ltda. Brazil CID002707
Tantalum Jiangxi Tuohong New Raw Material China CID002842
Tantalum Yancheng Jinye New Material Technology Co., Ltd. China CID003583
Tantalum 5D Production OU Estonia CID003926
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China CID000228
Tin Alpha United States Of America CID000292
Tin PT Aries Kencana Sejahtera Indonesia CID000309
Tin Smelter Not Listed Indonesia CID000313
Tin Dowa Japan CID000402
Tin EM Vinto Bolivia (Plurinational State Of) CID000438
Tin Estanho de Rondonia S.A. Brazil CID000448
Tin Fenix Metals Poland CID000468
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. China CID000538
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. China CID000555
Tin Gejiu Kai Meng Industry and Trade LLC China CID000942
Tin China Tin Group Co., Ltd. China CID001070
Tin Malaysia Smelting Corporation (MSC) Malaysia CID001105
Tin Metallic Resources, Inc. United States Of America CID001142
Tin Mineracao Taboca S.A. Brazil CID001173
Tin Minsur Peru CID001182
Tin Mitsubishi Materials Corporation Japan CID001191
Tin Jiangxi New Nanshan Technology Ltd. China CID001231
Tin Novosibirsk Processing Plant Ltd. Russian Federation CID001305
Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand CID001314
Tin Operaciones Metalurgicas S.A. Bolivia (Plurinational State Of) CID001337
Tin PT Artha Cipta Langgeng Indonesia CID001399
Tin PT Babel Inti Perkasa Indonesia CID001402
Tin PT Babel Surya Alam Lestari Indonesia CID001406
Tin Smelter Not Listed Indonesia CID001419
Tin PT Belitung Industri Sejahtera Indonesia CID001421
Tin PT Bukit Timah Indonesia CID001428
Tin PT Mitra Stania Prima Indonesia CID001453
Tin PT Panca Mega Persada Indonesia CID001457
Tin PT Prima Timah Utama Indonesia CID001458
Tin PT Refined Bangka Tin Indonesia CID001460
Tin PT Sariwiguna Binasentosa Indonesia CID001463

Tin PT Stanindo Inti Perkasa Indonesia CID001468
Tin PT Timah Tbk Kundur Indonesia CID001477
Tin PT Timah Tbk Mentok Indonesia CID001482
Tin PT Timah Nusantara Indonesia CID001486
Tin PT Tinindo Inter Nusa Indonesia CID001490
Tin PT Tommy Utama Indonesia CID001493
Tin Rui Da Hung Taiwan, Province Of China CID001539
Tin Thaisarco Thailand CID001898
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China CID001908
Tin VQB Mineral and Trading Group JSC Viet Nam CID002015
Tin White Solder Metalurgia e Mineracao Ltda. Brazil CID002036
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China CID002158
Tin Yunnan Tin Company Limited China CID002180
Tin CV Venus Inti Perkasa Indonesia CID002455
Tin Magnu's Minerais Metais e Ligas Ltda. Brazil CID002468
Tin PT Tirus Putra Mandiri Indonesia CID002478
Tin Melt Metais e Ligas S.A. Brazil CID002500
Tin PT ATD Makmur Mandiri Jaya Indonesia CID002503
Tin O.M. Manufacturing Philippines, Inc. Philippines CID002517
Tin Smelter Not Listed Indonesia CID002570
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Viet Nam CID002572
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company Viet Nam CID002573
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company Viet Nam CID002574
Tin PT Cipta Persada Mulia Indonesia CID002696
Tin An Vinh Joint Stock Mineral Processing Company Viet Nam CID002703
Tin Resind Industria e Comercio Ltda. Brazil CID002706
Tin Super Ligas Brazil CID002756
Tin Metallo Belgium N.V. Belgium CID002773
Tin Metallo Spain S.L.U. Spain CID002774
Tin Smelter Not Listed Indonesia CID002776
Tin PT Sukses Inti Makmur Indonesia CID002816
Tin PT Menara Cipta Mulia Indonesia CID002835
Tin Modeltech Sdn Bhd Malaysia CID002858
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China CID003116
Tin Chifeng Dajingzi Tin Industry Co., Ltd. China CID003190
Tin PT Bangka Serumpun Indonesia CID003205
Tin Pongpipat Company Limited Myanmar CID003208
Tin Tin Technology & Refining United States Of America CID003325
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China CID003356
Tin PT Rajawali Rimba Perkasa Indonesia CID003381

Tin Luna Smelter, Ltd. Rwanda CID003387
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China CID003397
Tin Precious Minerals and Smelting Limited India CID003409
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China CID003410
Tin PT Mitra Sukses Globalindo Indonesia CID003449
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil CID003486
Tin CRM Synergies Spain CID003524
Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil CID003582
Tin DS Myanmar Myanmar CID003831
Tin PT Putera Sarana Shakti (PT PSS) Indonesia CID003868
Tungsten A.L.M.T. Corp. Japan CID000004
Tungsten Kennametal Huntsville United States Of America CID000105
Tungsten Guangdong Xianglu Tungsten Co., Ltd. China CID000218
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China CID000258
Tungsten CNMC (Guangxi) PGMA Co., Ltd. China CID000281
Tungsten Global Tungsten & Powders Corp. United States Of America CID000568
Tungsten Hunan Chenzhou Mining Co., Ltd. China CID000766
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. China CID000769
Tungsten Japan New Metals Co., Ltd. Japan CID000825
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. China CID000875
Tungsten Kennametal Fallon United States Of America CID000966
Tungsten Wolfram Bergbau und Hutten AG Austria CID002044
Tungsten Xiamen Tungsten Co., Ltd. China CID002082
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China CID002313
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China CID002315
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China CID002316
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China CID002317
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China CID002318
Tungsten Malipo Haiyu Tungsten Co., Ltd. China CID002319
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China CID002320
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China CID002321
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China CID002494
Tungsten Asia Tungsten Products Vietnam Ltd. Viet Nam CID002502
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. China CID002513
Tungsten H.C. Starck Tungsten GmbH Germany CID002541
Tungsten TANIOBIS Smelting GmbH & Co. KG Germany CID002542
Tungsten Masan Tungsten Chemical LLC (MTC) Viet Nam CID002543
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China CID002551
Tungsten Niagara Refining LLC United States Of America CID002589
Tungsten China Molybdenum Co., Ltd. China CID002641
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. China CID002645

Tungsten Hydrometallurg, JSC Russian Federation CID002649
Tungsten Unecha Refractory metals plant Russian Federation CID002724
Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines CID002827
Tungsten ACL Metais Eireli Brazil CID002833
Tungsten Moliren Ltd. Russian Federation CID002845
Tungsten Fujian Ganmin RareMetal Co., Ltd. China CID003401
Tungsten Lianyou Metals Co., Ltd. Taiwan, Province Of China CID003407
Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation CID003408
Tungsten NPP Tyazhmetprom LLC Russian Federation CID003416
Tungsten GEM Co., Ltd. China CID003417
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil CID003427
Tungsten Cronimet Brasil Ltda Brazil CID003468
Tungsten Artek LLC Russian Federation CID003553
Tungsten Fujian Xinlu Tungsten China CID003609
Tungsten OOO "Technolom" 2 Russian Federation CID003612
Tungsten OOO "Technolom" 1 Russian Federation CID003614
Tungsten LLC Volstok Russian Federation CID003643
Tungsten HANNAE FOR T Co., Ltd. Korea, Republic Of CID003978
Tungsten Smelter Name Not Listed Viet Nam CID003993
Tungsten Smelter Name Not Listed Korea, Republic Of CID004060