Exhibit 1.01
Energy Recovery Inc.
Conflict Minerals Report
For The Calendar Year Ended December 31, 2019
Introduction
For the year ended December 31, 2019, Energy Recovery, Inc. (the “Company”, “Energy Recovery”, “our”, “us”, or “we”) in good faith, has conducted a reasonable country of origin inquiry (“RCOI”) of our products using the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). This report is presented to comply with Rule 13p-1 under The Securities Exchange Act of 1934 (the “Rule”) as adopted by the Securities and Exchange Commission (“SEC”).
The term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (“3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC (collectively known as the “Covered Countries”).
The scope of the survey was to determine whether any of the conflict minerals contained in our products originated in the Covered Countries as defined by the Rule.
Based on the analysis of our products and suppliers, we concluded that some of our products contain one or more of the 3TGs and that these minerals are necessary to the product’s functionality or production. Consequently, the products we manufacture are subject to the reporting obligations of the Rule.
Company Overview
We are an energy solutions provider to industrial fluid flow markets worldwide. Our core competencies are fluid dynamics and advanced material science. Our products make industrial processes more operational and capital expenditure efficient. Our solutions convert wasted pressure energy into a reusable asset and preserve or eliminate pumping technology in hostile processing environments. Our solutions are marketed and sold in fluid flow markets, such as water desalination, oil and gas, and chemical processing, under the trademarks ERI®, PX®, Pressure Exchanger®, PX Pressure Exchanger®, AT™, AquaBold™, VorTeq™, MTeq™, IsoBoost®, and IsoGen®. Our solutions are owned, manufactured, and/or developed, in whole or in part, in the United States of America (“U.S.”) and the Republic of Ireland.
Product Overview
Based on our analysis of our products, we concluded that adapters, spiral rings, nuts, pump bases, fittings, and connectors used in our PX Pressure Exchanger and AquaBold pumps, and other pumps and turbochargers contain hastelloy and/or welded carbon steel. These metals contain tin. As part of the data collection process, our supply chain, via Company-Level CMRTs, claimed the use of all 3TG metals.
Conflict Minerals Policy
We are committed to complying with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and plan to procure our products from conflict-free sources. We have considered the rule’s requirements along with related guidance from the Organization for Economic Cooperation and Development (the “OECD”), and we expect our suppliers to comply with the Code of Conduct of the Responsible Business Alliance (“RBA”, formerly the Electronic Industry Citizen Coalition, or the EICC) and conduct their businesses in alignment with our expectations of supply chain responsibility.
In support of this policy, we:
•Exercise due diligence with suppliers of products containing or expected to contain 3TGs consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers.
•Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm that the 3TGs in our supply chain are procured from conflict-free sources.
•Collaborate with our suppliers and others on industry-wide solutions to enable products that are DRC conflict-free.
Reasonable Country of Origin Inquiry
With the assistance of a third-party service provider, Assent Compliance (the “Vendor”), we conducted a good faith RCOI regarding the 3TGs in materials, components, and finished goods supplied to us, including the steps discussed below.
Utilizing version 5.12 or higher of RMI’s CMRT, we engaged 12 potential 3TG suppliers to collect information regarding the presence and sourcing of 3TGs in their products that they provide to us.
We procure components from the following major types of suppliers:
•Manufacturer or direct supplier;
•Contract manufacturer producing items to match specifications and standards set by us; or
•Distributor or reseller of manufactured components for other manufacturers.
The Vendor followed up with all unresponsive suppliers through a defined process via both automated email and one-to-one email, including offering assistance and further information to suppliers about the requirements of the Act and our program. If, after these outreach efforts a supplier still did not respond to the survey, a Company supply chain manager was asked to directly contact the supplier for a response.
Our program includes automated data validation on all submitted CMRTs via the Vendor’s software. 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 retained. Suppliers were contacted with regard to invalid forms and were encouraged to resubmit a valid form. As of the date of this filing, we had one invalid supplier submission.
For suppliers who responded that the materials or goods they supplied to us did not contain 3TGs, our supply chain manager and the Vendor verified the responses, and only after such verification were these suppliers removed from the survey process.
Of the suppliers who responded that 3TGs metals are in materials, components, and/or finished goods supplied to us, some did not include the name of any or all verified smelters or refiners. Based on the responses received from the RCOI, which included thousands of alleged smelter or refiner names, a list was compiled of 264 verified, unique smelters or refiners, including information regarding associated countries of origin (the “unique smelter list”). This list was determined by comparing supplier responses to the list of smelters and refiners maintained by the RMI. We, via the Vendor, performed due diligence on the unique smelter list that were known or reasonably believed to have sourced from the DRC or that had unknown sourcing. In the event that a supplier declared that a facility was certified as conflict-free, the Vendor confirmed that the facility was listed on the RMI’s list of conformant conflict-free smelters and refiners.
Results of our RCOI
As of the date of this filing, based on our supplier responses to our survey and our analysis of such responses as they apply to the calendar year ended December 31, 2019, while there is some indication of DRC sourcing by some of our suppliers, due to the submission of many company-level CMRTs, we cannot ascertain if any DRC sources were used in our products. Accordingly, we have continued to proceed with additional due diligence procedures for the purpose of determining the status of our products as it pertains to the source and chain of custody of any such conflict minerals.
Exercise Due Diligence on the Source and Chain of Custody of Our Conflict Minerals
We are required to exercise due diligence on the source and chain of custody of conflict minerals and to follow a nationally or internationally recognized due diligence framework. Our due diligence measures have been designed to conform, in all material respects, with the framework in the 2nd Edition of the OECD Due Diligence Guidance for Responsible Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”), which is a nationally or internationally recognized due diligence framework, and the related supplements for 3TGs. We have adopted and communicated our conflict mineral policy to our suppliers and customers, as well as implemented RCOI to our new and existing suppliers. In addition, there are programs in place to encourage our suppliers to source from RMI conformant smelters.
Consistent with the OECD Guidance, the design of our due diligence has the following features:
1.0Establish strong company management systems
2.0Identify and assess risks in the supply chain
3.0Design and implement a strategy to respond to identified risks
4.0Carry out independent third-party audit of smelter/refiner’s due diligence practices
5.0Report annually on supply chain due diligence
These features are discussed in more detail below.
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of 3TGs, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary 3TGs. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary minerals. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.
We also anticipate the need to rely, to a large extent, on information collected and provided by independent third-party audit programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.
Brief description of due diligence measures taken
1.0 Strong Company Management Systems:
Internal Team
We established a management system for complying with the applicable rules. Our management system includes the development of a Conflict Minerals Committee and an Executive Management Oversight Committee. The Conflict Minerals Committee is composed of our Supply Chain Manager and Sr. Director, SEC Reporting. Our Executive Management Oversight Committee is composed of our Chief Financial Officer and Chief Accounting Officer, Corporate Controller, and Vice President of Operations. Our Conflict Minerals Committee, supported by a team of subject matter experts from relevant functions such as purchasing, engineering, finance, and legal, is responsible for implementing our conflict mineral compliance policy and strategy. The Executive Management Oversight Committee is briefed about the results of our due diligence efforts periodically.
Control Systems
Controls include, but are not limited to, our Code of Business Conduct and Ethics, our Conflict Minerals Policy, regular monitoring of changes in applicable laws, regulations, and guidance, whistleblower mechanisms, regular training of key employee groups, and on-site visits and audits of our suppliers. Our Conflict Minerals Policy related to our sourcing of 3TGs is posted on our website at “https://ir.energyrecovery.com/websites/energyrecover/English/6300/corporate-governance.html,” within the “Investor” section under “Corporate Governance.”
We provide training to all compliance team members and have developed training materials for our suppliers to enable them to comply with the conflict minerals compliance and reporting process and also with our policies.
This year, we continued to place a stronger emphasis on supplier education and training. To accomplish this, we utilized our third-party vendor’s learning management system and directed all in-scope suppliers to their conflict minerals training courses and publicly available training materials.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 5.12 or higher and a third-party vendor’s software reporting tool for collecting the applicable information 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 the 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.
Grievance Mechanism
We maintain several methods in which employees or third parties may notify us of potential issues with our Conflict Minerals Program, including an anonymous employee hotline, email resources both internally and on our website, direct phone numbers, and our open-door policy.
Maintain records
We maintain Company-wide document retention policies. These policies extend to the documentation accumulated in performing our 3TG due diligence procedures and requires that documentation be retained for a period of five years.
2.0 Identification and Assessment of Risks in the Supply Chain:
We made reasonable efforts to identify suppliers that provide products that may potentially contain conflict minerals by conducting a supply chain survey through the use of the CMRT. By way of the CMRT, we requested suppliers to identify smelters and refiners and country of origin information for the 3TGs in products that they supply to us. We followed up with suppliers that did not respond to CMRT by requesting their responses multiple times. We then compared any smelters or refiners identified by the supply chain survey against the list of facilities that have received a “conflict free” designation from the RMI’s Responsible Minerals Assurance Process (“RMAP”). We also reviewed the responses to identify red flags for further follow-up and to identify any key risks to our supply chain.
It is important to note that we have relied on supplier responses to provide us with the information about the source of 3TGs contained in the parts and components they supply to us. Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to the recognized industry best practices.
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Assent uses the following factors to determine the level of risk that each smelter or refiner poses to the supply chain:
1.Geographic proximity to the DRC and Covered Countries;
2.RMAP audit status;
3.Credible evidence of unethical or conflict sourcing;
4.Known mineral source country of origin; and
5.Peer assessments conducted by credible third-party sources.
As part of our risk management plan under the OECD Guidance, if these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, 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 submission of a product specific CMRT to better identify the connection to products that they supply to us, and escalating up to removal of these high-risk smelters from our supply chain.
As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. If necessary, suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.
In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
We also calculate supplier risk based on the chances that the supplier provides 3TGs that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have “unknown” as some of the answers. It has been decided that penalizing or failing them for working through the process is likely not the best approach and it does not meet the goals or spirit of the Rule. However, evaluating and tracking the strength of the program does meet the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are the following questions from 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 the above criteria, by answering yes to all four questions, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. We store all of this information and will continue to assess our suppliers’ program strength and monitor any improvements or changes.
3.0 Strategic Response to Identified Risks:
We have implemented a risk mitigation response plan to monitor and track suppliers, smelters, and refiners identified as not meeting the requirements set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements. We continuously make every reasonable effort to encourage suppliers who are sourcing from non-conformant smelters or refiners to move towards using conformant facilities.
If a supplier fails to remedy the risks identified by our compliance risk assessment, the Conflict Minerals Committee escalates the risk to the Executive Management Oversight Committee to determine whether to approve or reject the supplier based on the following factors: a cost and benefit analysis; potential risk factors; any existing competitive bids; and whether the supplier is the Company’s single source of supply. If the Executive Management Oversight Committee decides to continue the business relationship due to inherent limitations of the supply chain, we use reasonable efforts to follow up with the supplier for its corrective plan and encourage the supplier to work with conflict-free smelters. We also provide periodic compliance updates or reports to the Executive Management Oversight Committee with oversight of the Conflict Minerals Committee summarizing our risk mitigation efforts.
4.0 Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices:
We do not have a direct relationship with 3TG metal smelters and refiners, and therefore we are not able to perform direct audits of those entities that provide the 3TG metals to our supply chain. We do, however, rely upon industry efforts, including the RMI, to influence smelters and refiners to become audited and certified through RMI’s RMAP program. We rely upon the summary audit reports for the compliance status of smelters generated by the RMI program to validate the responses received from our suppliers to our RCOI process and to address red flags identified in Step 2 above. We believe our efforts adequately address this requirement in the OECD Guidance.
5.0 Annual Report on Supply Chain Due Diligence:
In addition to this report, our Conflict Minerals Sourcing Policy is posted on our Company website at “https://ir.energyrecovery.com/websites/energyrecover/English/6300/corporate-governance.html.”
Results of due diligence measures taken
Due to the level of complexity of our products and the respective supply chain, it will take additional time and resources for a number of our suppliers to verify, specifically for our products, the source mines and country of origin of all of the minerals used by their smelters. We are committed to continuing the use of our supply chain due diligence processes, leveraging the industry standard RMI program, and the ongoing update of our supplier RCOI information as we continue to develop additional transparency into our supply chain. As of the date of this filing, however, based on the performance of our due diligence procedures noted above for the calendar year ended December 31, 2019, we are not able to accurately trace and identify the source mine, country of origin, and chain of custody of all of the 3TGs which are necessary to the functionality or production of our products, or determine whether such 3TGs are sourced from conflict-free sources for all of our products.
Efforts to Determine the Mine or Location of Origin of the Conflict Minerals in our Products
Tracing materials back to their mine and source country of origin is a complex endeavor, but an important aspect of responsible sourcing. To help establish our supply chain sourcing programs, we have followed currently established industry guidelines, such as those specified by the RMAP program that will enable companies to source minerals from conflict-free sources.
After a review and analysis of all of our products and suppliers, with the assistance of the Vendor, 264 smelters or refiners were identified and verified. See Appendix A for the smelter list. Of the 264 verified smelters, 221 smelters are conformant with RMAP and therefore, considered conflict-free by the RMI. Of the 43 smelters that are non-conformant, we are not aware that any of these smelters source 3TGs from conflict sources.
Steps to Mitigate Risk
We are committed to complying with the provisions of the Rule and Form SD and expect to continue our efforts to improve our Conflict Minerals Program and related due diligence. As we further develop our program and procedures, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to the following:
•Engage with suppliers and direct them to training resources, including increasing the number who utilize our third-party vendor’s learning management system, to attempt to increase our response rate and improve the content of responses to assist in our RCOI process and our efforts to determine the processing facilities for and country of origin of 3TGs with the greatest specificity possible;
•Engage suppliers and encourage them to provide responses at the product level;
•Implement a strategy to respond to identified risk, including but not limited to, potential action to be taken against suppliers that do not respond to our requests or do not provide reasonable information to support our due diligence activities; and
•Engage any of our suppliers found to be supplying us with 3TGs from sources that support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict.
Conflict Minerals Report
The Conflict Minerals Report for the calendar year ended December 31, 2019, filed herewith as Exhibit 1.01, is available on our Company website at “https://ir.energyrecovery.com/websites/energyrecover/English/6300/corporate-governance.html.”
Appendix A
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | Smelter ID |
| Gold | | Abington Reldan Metals, LLC | | UNITED STATES OF AMERICA | | CID002708 |
| Gold | | Advanced Chemical Company | | UNITED STATES OF AMERICA | | CID000015 |
| Gold | | Aida Chemical Industries Co., Ltd. | | JAPAN | | CID000019 |
| Gold | | Al Etihad Gold Refinery DMCC | | UNITED ARAB EMIRATES | | CID002560 |
| 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 | | Asahi Refining Canada Ltd. | | CANADA | | CID000924 |
| Gold | | Asahi Refining USA Inc. | | UNITED STATES OF AMERICA | | CID000920 |
| Gold | | Asaka Riken Co., Ltd. | | JAPAN | | CID000090 |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | TURKEY | | CID000103 |
| Gold | | AU Traders and Refiners | | SOUTH AFRICA | | CID002850 |
| 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 | | Chimet S.p.A. | | ITALY | | CID000233 |
| Gold | | Chugai Mining | | JAPAN | | CID000264 |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | | CHINA | | CID000343 |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | | GERMANY | | CID002867 |
| Gold | | DODUCO Contacts and Refining GmbH | | GERMANY | | CID000362 |
| Gold | | Dowa | | JAPAN | | CID000401 |
| Gold | | DSC (Do Sung Corporation) | | KOREA, REPUBLIC OF | | CID000359 |
| Gold | | Eco-System Recycling Co., Ltd. East Plant | | JAPAN | | CID000425 |
| Gold | | Emirates Gold DMCC | | UNITED ARAB EMIRATES | | CID002561 |
| Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | | INDIA | | CID002852 |
| Gold | | Geib Refining Corporation | | UNITED STATES OF AMERICA | | CID002459 |
| Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | CHINA | | CID002243 |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | | CHINA | | CID001909 |
| Gold | | Guangdong Jinding Gold Limited | | CHINA | | CID002312 |
| Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | CHINA | | CID000651 |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | CHINA | | CID000671 |
| 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 |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | Smelter ID |
| 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 | | Italpreziosi | | ITALY | | CID002765 |
| Gold | | Japan Mint | | JAPAN | | CID000823 |
| Gold | | Jiangxi Copper Co., Ltd. | | CHINA | | CID000855 |
| 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 | | KGHM Polska Miedz Spolka Akcyjna | | POLAND | | CID002511 |
| Gold | | Kojima Chemicals Co., Ltd. | | JAPAN | | CID000981 |
| Gold | | Korea Zinc Co., Ltd. | | KOREA, REPUBLIC OF | | CID002605 |
| Gold | | Kyrgyzaltyn JSC | | KYRGYZSTAN | | CID001029 |
| Gold | | Kyshtym Copper-Electrolytic Plant ZAO | | RUSSIAN FEDERATION | | CID002865 |
| 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 | | L'Orfebre S.A. | | ANDORRA | | CID002762 |
| Gold | | LS-NIKKO Copper Inc. | | KOREA, REPUBLIC OF | | CID001078 |
| Gold | | LT Metal Ltd. | | KOREA, REPUBLIC OF | | CID000689 |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | CHINA | | CID001093 |
| Gold | | Marsam Metals | | BRAZIL | | CID002606 |
| Gold | | Materion | | UNITED STATES OF AMERICA | | CID001113 |
| Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN | | CID001119 |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | CHINA | | CID001149 |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | SINGAPORE | | CID001152 |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | CHINA | | CID001147 |
| 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 | | MMTC-PAMP India Pvt., Ltd. | | INDIA | | CID002509 |
| Gold | | Modeltech Sdn Bhd | | MALAYSIA | | CID002857 |
| Gold | | Morris and Watson | | NEW ZEALAND | | CID002282 |
| 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 |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | Smelter ID |
| Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | AUSTRIA | | CID002779 |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | JAPAN | | CID001325 |
| Gold | | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | | RUSSIAN FEDERATION | | CID001326 |
| Gold | | OJSC Novosibirsk Refinery | | RUSSIAN FEDERATION | | CID000493 |
| Gold | | PAMP S.A. | | SWITZERLAND | | CID001352 |
| Gold | | Pease & Curren | | UNITED STATES OF AMERICA | | CID002872 |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | CHINA | | CID001362 |
| Gold | | Planta Recuperadora de Metales SpA | | CHILE | | CID002919 |
| 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 | | Refinery of Seemine Gold Co., Ltd. | | CHINA | | CID000522 |
| Gold | | REMONDIS PMR B.V. | | NETHERLANDS | | CID002582 |
| Gold | | Royal Canadian Mint | | CANADA | | CID001534 |
| Gold | | SAAMP | | FRANCE | | CID002761 |
| Gold | | Sabin Metal Corp. | | UNITED STATES OF AMERICA | | CID001546 |
| Gold | | Safimet S.p.A | | ITALY | | CID002973 |
| Gold | | SAFINA A.S. | | CZECH REPUBLIC | | CID002290 |
| Gold | | Sai Refinery | | INDIA | | CID002853 |
| Gold | | Samduck Precious Metals | | KOREA, REPUBLIC OF | | CID001555 |
| Gold | | Samwon Metals Corp. | | KOREA, REPUBLIC OF | | CID001562 |
| Gold | | SAXONIA Edelmetalle GmbH | | GERMANY | | CID002777 |
| 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 | | Singway Technology Co., Ltd. | | TAIWAN, PROVINCE OF CHINA | | CID002516 |
| Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | RUSSIAN FEDERATION | | CID001756 |
| Gold | | Solar Applied Materials Technology Corp. | | TAIWAN, PROVINCE OF CHINA | | CID001761 |
| Gold | | State Research Institute Center for Physical Sciences and Technology | | LITHUANIA | | CID003153 |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | JAPAN | | CID001798 |
| Gold | | SungEel HiMetal Co., Ltd. | | KOREA, REPUBLIC OF | | CID002918 |
| Gold | | T.C.A S.p.A | | ITALY | | CID002580 |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | JAPAN | | CID001875 |
| 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 | | TOO Tau-Ken-Altyn | | KAZAKHSTAN | | CID002615 |
| Gold | | Torecom | | KOREA, REPUBLIC OF | | CID001955 |
| Gold | | Umicore Brasil Ltda. | | BRAZIL | | CID001977 |
| Gold | | Umicore Precious Metals Thailand | | THAILAND | | CID002314 |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | BELGIUM | | CID001980 |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | Smelter ID |
| 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 | | WIELAND Edelmetalle GmbH | | GERMANY | | CID002778 |
| Gold | | Yamakin Co., Ltd. | | JAPAN | | CID002100 |
| Gold | | Yokohama Metal Co., Ltd. | | JAPAN | | CID002129 |
| Gold | | Yunnan Copper Industry Co., Ltd. | | CHINA | | CID000197 |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | CHINA | | CID002224 |
| Tantalum | | Asaka Riken Co., Ltd. | | JAPAN | | CID000092 |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA | | CID000211 |
| Tantalum | | D Block Metals, LLC | | UNITED STATES OF AMERICA | | CID002504 |
| Tantalum | | Exotech Inc. | | UNITED STATES OF AMERICA | | CID000456 |
| Tantalum | | F&X Electro-Materials Ltd. | | CHINA | | CID000460 |
| Tantalum | | FIR Metals & Resource Ltd. | | CHINA | | CID002505 |
| Tantalum | | Global Advanced Metals Aizu | | JAPAN | | CID002558 |
| Tantalum | | Global Advanced Metals Boyertown | | UNITED STATES OF AMERICA | | CID002557 |
| Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA | | CID000616 |
| Tantalum | | H.C. Starck Co., Ltd. | | THAILAND | | CID002544 |
| Tantalum | | H.C. Starck Hermsdorf GmbH | | GERMANY | | CID002547 |
| 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 | | H.C. Starck Tantalum and Niobium GmbH | | GERMANY | | CID002545 |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | CHINA | | CID002492 |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | CHINA | | CID002512 |
| Tantalum | | Jiangxi Tuohong New Raw Material | | CHINA | | CID002842 |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA | | CID000914 |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | CHINA | | CID000917 |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | CHINA | | CID002506 |
| Tantalum | | KEMET Blue Metals | | MEXICO | | CID002539 |
| 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 | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA | | CID001277 |
| Tantalum | | NPM Silmet AS | | ESTONIA | | CID001200 |
| Tantalum | | PRG Dooel | | NORTH MACEDONIA, REPUBLIC OF | | CID002847 |
| Tantalum | | QuantumClean | | UNITED STATES OF AMERICA | | CID001508 |
| Tantalum | | Resind Industria e Comercio Ltda. | | BRAZIL | | CID002707 |
| 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 | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA | | CID002508 |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | Smelter ID |
| Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | CHINA | | CID001522 |
| Tin | | Alpha | | UNITED STATES OF AMERICA | | CID000292 |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | VIET NAM | | CID002703 |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CHINA | | CID000228 |
| Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | CHINA | | CID003190 |
| Tin | | China Tin Group Co., Ltd. | | CHINA | | CID001070 |
| Tin | | Dowa | | JAPAN | | CID000402 |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | VIET NAM | | CID002572 |
| Tin | | EM Vinto | | BOLIVIA (PLURINATIONAL STATE OF) | | CID000438 |
| Tin | | Estanho de Rondonia S.A. | | BRAZIL | | CID000448 |
| Tin | | Fenix Metals | | POLAND | | CID000468 |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | CHINA | | CID000942 |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | CHINA | | CID000538 |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | CHINA | | CID001908 |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | CHINA | | CID000555 |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | CHINA | | CID003116 |
| Tin | | Guanyang Guida Nonferrous Metal Smelting Plant | | CHINA | | CID002849 |
| Tin | | HuiChang Hill Tin Industry Co., Ltd. | | CHINA | | CID002844 |
| Tin | | Huichang Jinshunda Tin Co., Ltd. | | CHINA | | CID000760 |
| Tin | | Jiangxi New Nanshan Technology Ltd. | | CHINA | | CID001231 |
| Tin | | Magnu's Minerais Metais e Ligas Ltda. | | BRAZIL | | CID002468 |
| Tin | | Malaysia Smelting Corporation (MSC) | | MALAYSIA | | CID001105 |
| Tin | | Melt Metais e Ligas S.A. | | BRAZIL | | CID002500 |
| Tin | | Metallic Resources, Inc. | | UNITED STATES OF AMERICA | | CID001142 |
| Tin | | Metallo Belgium N.V. | | BELGIUM | | CID002773 |
| Tin | | Metallo Spain S.L.U. | | SPAIN | | CID002774 |
| Tin | | Mineracao Taboca S.A. | | BRAZIL | | CID001173 |
| Tin | | Minsur | | PERU | | CID001182 |
| Tin | | Mitsubishi Materials Corporation | | JAPAN | | CID001191 |
| Tin | | Modeltech Sdn Bhd | | MALAYSIA | | CID002858 |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | VIET NAM | | CID002573 |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND | | CID001314 |
| Tin | | O.M. Manufacturing Philippines, Inc. | | PHILIPPINES | | CID002517 |
| Tin | | Operaciones Metalurgicas S.A. | | BOLIVIA (PLURINATIONAL STATE OF) | | CID001337 |
| Tin | | Pongpipat Company Limited | | MYANMAR | | CID003208 |
| Tin | | PT Artha Cipta Langgeng | | INDONESIA | | CID001399 |
| Tin | | PT ATD Makmur Mandiri Jaya | | INDONESIA | | CID002503 |
| Tin | | PT Menara Cipta Mulia | | INDONESIA | | CID002835 |
| Tin | | PT Mitra Stania Prima | | INDONESIA | | CID001453 |
| Tin | | PT Refined Bangka Tin | | INDONESIA | | CID001460 |
| Tin | | PT Timah Tbk Kundur | | INDONESIA | | CID001477 |
| Tin | | PT Timah Tbk Mentok | | INDONESIA | | CID001482 |
| Tin | | Resind Industria e Comercio Ltda. | | BRAZIL | | CID002706 |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | Smelter ID |
| Tin | | Rui Da Hung | | TAIWAN, PROVINCE OF CHINA | | CID001539 |
| Tin | | Soft Metais Ltda. | | BRAZIL | | CID001758 |
| Tin | | Super Ligas | | BRAZIL | | CID002756 |
| Tin | | Thaisarco | | THAILAND | | CID001898 |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | VIET NAM | | CID002574 |
| 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 |
| Tungsten | | A.L.M.T. Corp. | | JAPAN | | CID000004 |
| Tungsten | | ACL Metais Eireli | | BRAZIL | | CID002833 |
| Tungsten | | Asia Tungsten Products Vietnam Ltd. | | VIET NAM | | CID002502 |
| Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA | | CID002513 |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | CHINA | | CID000258 |
| Tungsten | | Fujian Jinxin Tungsten Co., Ltd. | | CHINA | | CID000499 |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | CHINA | | CID002645 |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA | | CID000875 |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA | | CID002315 |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA | | CID002494 |
| Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES OF AMERICA | | CID000568 |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | CHINA | | CID000218 |
| Tungsten | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY | | CID002542 |
| Tungsten | | H.C. Starck Tungsten GmbH | | GERMANY | | CID002541 |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | CHINA | | CID000766 |
| Tungsten | | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | | CHINA | | CID002579 |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | CHINA | | CID000769 |
| Tungsten | | Hunan Litian Tungsten Industry Co., Ltd. | | CHINA | | CID003182 |
| Tungsten | | Hydrometallurg, JSC | | RUSSIAN FEDERATION | | CID002649 |
| Tungsten | | Japan New Metals Co., Ltd. | | JAPAN | | CID000825 |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | CHINA | | CID002551 |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA | | CID002321 |
| Tungsten | | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | | CHINA | | CID002313 |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA | | CID002318 |
| Tungsten | | Jiangxi Xianglu Tungsten Co., Ltd. | | CHINA | | CID002647 |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA | | CID002317 |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | CHINA | | CID002316 |
| Tungsten | | Kennametal Fallon | | UNITED STATES OF AMERICA | | CID000966 |
| Tungsten | | Kennametal Huntsville | | UNITED STATES OF AMERICA | | CID000105 |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA | | CID002319 |
| Tungsten | | Masan Tungsten Chemical LLC (MTC) | | VIET NAM | | CID002543 |
| Tungsten | | Moliren Ltd. | | RUSSIAN FEDERATION | | CID002845 |
| Tungsten | | Niagara Refining LLC | | UNITED STATES OF AMERICA | | CID002589 |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | PHILIPPINES | | CID002827 |
| Tungsten | | Tejing (Vietnam) Tungsten Co., Ltd. | | VIET NAM | | CID001889 |
| Tungsten | | Unecha Refractory metals plant | | RUSSIAN FEDERATION | | CID002724 |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | Smelter ID |
| Tungsten | | Wolfram Bergbau und Hutten AG | | AUSTRIA | | CID002044 |
| Tungsten | | Woltech Korea Co., Ltd. | | KOREA, REPUBLIC OF | | CID002843 |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA | | CID002320 |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | CHINA | | CID002082 |
| Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA | | CID002830 |
| Tungsten | | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | | CHINA | | CID002095 |