Inogen, Inc.
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 Inogen’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 Inogen files with the United States Securities and Exchange Commission, including Inogen’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 Inogen realizes the results anticipated or implied by any forward-looking statements contained in this Conflict Minerals Report. Except as required by law, Inogen 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 Inogen, Inc. (“Inogen” 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://investor.inogen.com/. 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”), 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 contained in components used in our products.
Inogen Background and Covered Products
We are a medical technology company that primarily develops, manufactures and markets innovative portable oxygen concentrators used to deliver supplemental long-term oxygen therapy to patients suffering from chronic respiratory conditions. We manufacture our Inogen One systems and Inogen At Home systems at our facility in Richardson, Texas and compressors at our facility in Goleta, California. In the United States, we market and distribute our products directly to consumers, through a wide variety of direct-to-consumer marketing strategies including a
physician referral model, as well as through distributors, resellers, private label partners, and home medical equipment providers. In addition, we sell through distributors, resellers, and home medical equipment providers in certain markets within Europe, the Asia-Pacific region, Latin America, the Middle East, and Africa. Our manufacturing operations require a wide variety of raw materials that we rely on third-party manufacturers to supply.
We have determined that one or more of the 3TG may be necessary to the functionality or production of the oxygen concentrators we manufactured during 2015, including our Inogen One G2, Inogen One G3, and Inogen At Home. As a result, all of our concentrators 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 and the manufacture of the covered products. We do not purchase raw ore or unrefined 3TG 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.
Inogen Reasonable Country of Origin Inquiry
In accordance with Rule 13p-1 and Form SD, we determined that one or more of the 3TG may be necessary to the functionality or production of our oxygen concentrators and that such 3TG 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 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 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.
Inogen’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 one or more of the 3TG is incorporated into our products; whether any such 3TG incorporated into our products was necessary for the functionality and/or production of our products; the source and chain of custody of the 3TG necessary for the functionality and/or production of our products; and whether any such 3TG originated in the Covered Countries. In the event that 3TG 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.
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 2015, 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 Inogen’s Conflict Minerals Policy is publicly available at http://investor.inogen.com/govdocs. |
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|
b. |
Internal Management to Support Supply Chain Due Diligence. The Inogen finance department has been charged with the management of our conflict minerals program, working in collaboration with members from our operations team in California and Texas. |
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|
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, the smelters and refiners in their supply chain that are included in our products, and the countries of origin for 3TG used in our products. We reviewed all responses for completeness, reasonableness, and consistency. We followed up for corrections and clarifications as we determined appropriate. |
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|
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. |
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e. |
Grievance Mechanism. Our code of conduct includes procedures for reporting violations of our policies, and 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 in the products we purchase and incorporate into the manufacture of our oxygen concentrators, and the source of such 3TG. Similarly, our first tier suppliers rely on information provided by their suppliers to provide information regarding the country of origin of 3TG included in our products.
3.Designing and Implementing a Strategy to Respond to Identified Risks
We will review 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.
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|
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 have supported 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://investor.inogen.com/. 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 necessary to the functionality or production of such products.
Smelters and Refiners in Inogen’s Supply Chain
We adopted CFSI’s industry approach to trace back the origin of 3TG 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 reported as used by these first tier suppliers
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 2015, 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 Inogen’s Conflict Minerals Policy is publicly available at http://investor.inogen.com/govdocs. |
|
|
b. |
Internal Management to Support Supply Chain Due Diligence. The Inogen finance department has been charged with the management of our conflict minerals program, working in collaboration with members from our operations team in California and Texas. |
|
|
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, the smelters and refiners in their supply chain that are included in our products, and the countries of origin for 3TG 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. |
|
|
e. |
Grievance Mechanism. Our code of conduct includes procedures for reporting violations of our policies, and 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 in the products we purchase and incorporate into the manufacture of our oxygen concentrators, and the source of such 3TG. Similarly, our first tier suppliers rely on information provided by their suppliers to provide information regarding the country of origin of 3TG included in our products.
3.Designing and Implementing a Strategy to Respond to Identified Risks
We will review 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 have supported 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://investor.inogen.com/. 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 necessary to the functionality or production of such products.
Smelters and Refiners in Inogen’s Supply Chain
We adopted CFSI’s industry approach to trace back the origin of 3TG 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 reported as used by these first tier suppliers was 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 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 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 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 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 contained in the covered products.
As reported earlier, we endeavored to determine the mine or location of origin of the 3TG 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.
The statements above are based on the RCOI process and due diligence performed in good faith by Inogen. 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 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 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; 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 from the Covered Countries to other countries.
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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2015 Facility and Country List |
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Metal |
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Smelter |
|
Country |
|
Compliance Status |
|
Gold |
|
Advanced Chemical Company |
|
UNITED STATES |
|
In Process |
|
Gold |
|
Aida Chemical Industries Co., Ltd. |
|
JAPAN |
|
Compliant |
|
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 SA |
|
SWITZERLAND |
|
Compliant |
|
Gold |
|
Asahi Pretec Corporation |
|
JAPAN |
|
Compliant |
|
Gold |
|
Asaka Riken Co., Ltd. |
|
JAPAN |
|
Compliant |
|
Gold |
|
Aurubis AG |
|
GERMANY |
|
Compliant |
|
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 SA |
|
SWITZERLAND |
|
In Process |
|
Gold |
|
Yunnan Copper Industry Co., Ltd. |
|
CHINA |
|
Unknown |
|
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 |
|
DSC (Do Sung Corporation) |
|
KOREA, REPUBLIC OF |
|
In Process |
|
Gold |
|
DODUCO GmbH |
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GERMANY |
|
Compliant |
|
Gold |
|
Dowa |
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JAPAN |
|
Compliant |
|
Gold |
|
Eco-System Recycling Co., Ltd. |
|
JAPAN |
|
Compliant |
|
Gold |
|
OJSC Novosibirsk Refinery |
|
RUSSIAN FEDERATION |
|
Compliant |
|
Gold |
|
Gansu Seemine Material Hi-Tech Co., Ltd. |
|
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 |
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GERMANY |
|
Compliant |
|
Gold |
|
Heraeus Ltd. Hong Kong |
|
CHINA |
|
Compliant |
|
Gold |
|
Heraeus Precious Metals GmbH & Co. KG |
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GERMANY |
|
Compliant |
|
Gold |
|
Hunan Chenzhou Mining Co., Ltd. |
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CHINA |
|
Unknown |
|
Gold |
|
Hwasung CJ Co., Ltd. |
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KOREA, REPUBLIC OF |
|
Unknown |
|
Gold |
|
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
|
CHINA |
|
Compliant |
|
Gold |
|
Ishifuku Metal Industry Co., Ltd. |
|
JAPAN |
|
Compliant |
|
Gold |
|
Istanbul Gold Refinery |
|
TURKEY |
|
Compliant |
|
Gold |
|
Japan Mint |
|
JAPAN |
|
Compliant |
|
Gold |
|
Jiangxi Copper Company Limited |
|
CHINA |
|
Compliant |
|
Gold |
|
Asahi Refining USA Inc. |
|
UNITED STATES |
|
Compliant |
|
Gold |
|
Asahi Refining Canada Limited |
|
CANADA |
|
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 |
|
Kazakhmys Smelting LLC |
|
KAZAKHSTAN |
|
Unknown |
|
Gold |
|
Kazzinc |
|
KAZAKHSTAN |
|
Compliant |
|
Gold |
|
Kennecott Utah Copper LLC |
|
UNITED STATES |
|
Compliant |
|
Gold |
|
Kojima Chemicals Co., Ltd. |
|
JAPAN |
|
Compliant |
|
|
Smelter |
|
Country |
|
Compliance Status |
|
|
Gold |
|
Korea Metal Co., Ltd. |
|
KOREA, REPUBLIC OF |
|
Unknown |
|
Gold |
|
Kyrgyzaltyn JSC |
|
KYRGYZSTAN |
|
Unknown |
|
Gold |
|
L' azurde Company For Jewelry |
|
SAUDI ARABIA |
|
Unknown |
|
Gold |
|
Lingbao Gold Company Limited |
|
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 (Suzhou) Ltd. |
|
CHINA |
|
In Process |
|
Gold |
|
Metalor Technologies (Hong Kong) Ltd. |
|
CHINA |
|
Compliant |
|
Gold |
|
Metalor Technologies (Singapore) Pte., Ltd. |
|
SINGAPORE |
|
Compliant |
|
Gold |
|
Metalor Technologies SA |
|
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 |
|
Gold |
|
Moscow Special Alloys Processing Plant |
|
RUSSIAN FEDERATION |
|
Compliant |
|
Gold |
|
|
TURKEY |
|
Compliant |
|
|
Gold |
|
Navoi Mining and Metallurgical Combinat |
|
UZBEKISTAN |
|
In Process |
|
Gold |
|
Nihon Material Co., Ltd. |
|
JAPAN |
|
Compliant |
|
Gold |
|
Elemetal Refining, LLC |
|
UNITED STATES |
|
Compliant |
|
Gold |
|
Ohura Precious Metal Industry Co., Ltd. |
|
JAPAN |
|
Compliant |
|
Gold |
|
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) |
|
RUSSIAN FEDERATION |
|
Compliant |
|
Gold |
|
PAMP SA |
|
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 SA |
|
SWITZERLAND |
|
Compliant |
|
Gold |
|
Rand Refinery (Pty) Ltd. |
|
SOUTH AFRICA |
|
Compliant |
|
Gold |
|
Royal Canadian Mint |
|
CANADA |
|
Compliant |
|
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 |
|
Schone Edelmetaal B.V. |
|
NETHERLANDS |
|
Compliant |
|
Gold |
|
SEMPSA Joyería Platería SA |
|
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 |
|
Accurate Refining Group |
|
UNITED STATES |
|
Unknown |
|
Gold |
|
SOE Shyolkovsky Factory of Secondary Precious Metals |
|
RUSSIAN FEDERATION |
|
Compliant |
|
Gold |
|
Solar Applied Materials Technology Corp. |
|
TAIWAN |
|
Compliant |
|
Gold |
|
Sumitomo Metal Mining Co., Ltd. |
|
JAPAN |
|
Compliant |
|
Gold |
|
Tanaka Electronics(Hong Kong)Pte.Ltd |
|
JAPAN |
|
Compliant |
|
Gold |
|
Great Wall Precious Metals Co., Ltd. of CBPM |
|
CHINA |
|
Unknown |
|
Gold |
|
The Refinery of Shandong Gold Mining Co., Ltd. |
|
CHINA |
|
Compliant |
|
Gold |
|
Tokuriki Honten Co., Ltd. |
|
JAPAN |
|
Compliant |
|
|
Smelter |
|
Country |
|
Compliance Status |
|
|
Gold |
|
Tongling Nonferrous Metals Group Co., Ltd. |
|
CHINA |
|
Unknown |
|
Gold |
|
Torecom |
|
KOREA, REPUBLIC OF |
|
In Process |
|
Gold |
|
Umicore Brasil Ltda. |
|
BRAZIL |
|
Compliant |
|
Gold |
|
Umicore SA Business Unit Precious Metals Refining |
|
BELGIUM |
|
Compliant |
|
Gold |
|
United Precious Metal Refining, Inc. |
|
UNITED STATES |
|
Compliant |
|
Gold |
|
Valcambi SA |
|
SWITZERLAND |
|
Compliant |
|
Gold |
|
Western Australian Mint trading as The Perth Mint |
|
AUSTRALIA |
|
Compliant |
|
Gold |
|
Yamamoto Precious Metal Co., Ltd. |
|
JAPAN |
|
Compliant |
|
Gold |
|
Yokohama Metal Co., Ltd. |
|
JAPAN |
|
Compliant |
|
Gold |
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
|
CHINA |
|
Compliant |
|
Gold |
|
Zijin Mining Group Co., Ltd. Gold Refinery |
|
CHINA |
|
Compliant |
|
Gold |
|
Guangdong Jinding Gold Limited |
|
CHINA |
|
Unknown |
|
Gold |
|
Umicore Precious Metals Thailand |
|
THAILAND |
|
Compliant |
|
Gold |
|
Faggi Enrico S.p.A. |
|
ITALY |
|
In Process |
|
Gold |
|
Geib Refining Corporation |
|
UNITED STATES |
|
In Process |
|
Gold |
|
MMTC-PAMP India Pvt., Ltd. |
|
INDIA |
|
Compliant |
|
Gold |
|
Republic Metals Corporation |
|
UNITED STATES |
|
Compliant |
|
Gold |
|
|
POLAND |
|
In Process |
|
|
Gold |
|
Fidelity Printers and Refiners Ltd. |
|
ZIMBABWE |
|
Unknown |
|
Gold |
|
Singway Technology Co., Ltd. |
|
TAIWAN |
|
Compliant |
|
Tantalum |
|
Changsha South Tantalum Niobium Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Conghua Tantalum and Niobium Smeltry |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Duoluoshan |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Exotech Inc. |
|
UNITED STATES |
|
Compliant |
|
Tantalum |
|
F&X Electro-Materials Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Guangdong Zhiyuan New Material Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Hi-Temp Specialty Metals, Inc. |
|
UNITED STATES |
|
Compliant |
|
Tantalum |
|
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Jiujiang Tanbre Co., Ltd. |
|
CHINA |
|
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 |
|
QuantumClean |
|
UNITED STATES |
|
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 |
|
Ulba Metallurgical Plant JSC |
|
KAZAKHSTAN |
|
Compliant |
|
Tantalum |
|
Zhuzhou Cemented Carbide |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Yichun Jin Yang Rare Metal Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Hengyang King Xing Lifeng New Materials Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
D Block Metals, LLC |
|
UNITED STATES |
|
Compliant |
|
Tantalum |
|
FIR Metals & Resource Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
XinXing HaoRong Electronic Material Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tantalum |
|
KEMET Blue Metals |
|
MEXICO |
|
Compliant |
|
Tantalum |
|
Plansee SE Liezen |
|
AUSTRIA |
|
Compliant |
|
Tantalum |
|
H.C. Starck Co., Ltd. |
|
THAILAND |
|
Compliant |
|
|
Smelter |
|
Country |
|
Compliance Status |
|
|
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 |
|
Plansee SE Reutte |
|
AUSTRIA |
|
Compliant |
|
Tantalum |
|
Global Advanced Metals Boyertown |
|
UNITED STATES |
|
Compliant |
|
Tantalum |
|
Global Advanced Metals Aizu |
|
JAPAN |
|
Compliant |
|
Tantalum |
|
KEMET Blue Powder |
|
UNITED STATES |
|
Compliant |
|
Tin |
|
Chenzhou Yunxiang Mining and Metallurgy Company Limited |
|
CHINA |
|
In Process |
|
Tin |
|
Jiangxi Ketai Advanced Material Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tin |
|
CNMC (Guangxi) PGMA Co., Ltd. |
|
CHINA |
|
Unknown |
|
Tin |
|
Alpha |
|
UNITED STATES |
|
Compliant |
|
Tin |
|
Cooperativa Metalurgica de Rondônia Ltda. |
|
BRAZIL |
|
Compliant |
|
Tin |
|
CV Gita Pesona |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Justindo |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Aries Kencana Sejahtera |
|
INDONESIA |
|
Compliant |
|
Tin |
|
CV Serumpun Sebalai |
|
INDONESIA |
|
Compliant |
|
Tin |
|
CV United Smelting |
|
INDONESIA |
|
Compliant |
|
Tin |
|
Dowa |
|
JAPAN |
|
Compliant |
|
Tin |
|
EM Vinto |
|
BOLIVIA |
|
Compliant |
|
Tin |
|
Estanho de Rondônia S.A. |
|
BRAZIL |
|
Unknown |
|
Tin |
|
Feinhütte Halsbrücke GmbH |
|
GERMANY |
|
Unknown |
|
Tin |
|
Fenix Metals |
|
POLAND |
|
Compliant |
|
Tin |
|
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tin |
|
Gejiu Zili Mining And Metallurgy Co., Ltd. |
|
CHINA |
|
Unknown |
|
Tin |
|
Huichang Jinshunda Tin Co., Ltd. |
|
CHINA |
|
Unknown |
|
Tin |
|
Gejiu Kai Meng Industry and Trade LLC |
|
CHINA |
|
In Process |
|
Tin |
|
Linwu Xianggui Ore Smelting Co., Ltd. |
|
CHINA |
|
Unknown |
|
Tin |
|
China Tin Group Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tin |
|
Malaysia Smelting Corporation (MSC) |
|
MALAYSIA |
|
Compliant |
|
Tin |
|
Metallic Resources, Inc. |
|
UNITED STATES |
|
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 |
|
O.M. Manufacturing (Thailand) Co., Ltd. |
|
THAILAND |
|
Compliant |
|
Tin |
|
Operaciones Metalurgical S.A. |
|
BOLIVIA |
|
Compliant |
|
Tin |
|
PT Alam Lestari Kencana |
|
INDONESIA |
|
Unknown |
|
Tin |
|
PT Artha Cipta Langgeng |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Babel Inti Perkasa |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Bangka Kudai Tin |
|
INDONESIA |
|
Unknown |
|
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 DS Jaya Abadi |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Eunindo Usaha Mandiri |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Fang Di MulTindo |
|
INDONESIA |
|
Unknown |
|
Tin |
|
PT Karimun Mining |
|
INDONESIA |
|
In Process |
|
Tin |
|
PT Mitra Stania Prima |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Panca Mega Persada |
|
INDONESIA |
|
Compliant |
|
|
Smelter |
|
Country |
|
Compliance Status |
|
|
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 Sumber Jaya Indah |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Tambang Timah |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Timah (Persero) Tbk Mentok |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Pelat Timah Nusantara Tbk |
|
INDONESIA |
|
Unknown |
|
Tin |
|
PT Tinindo Inter Nusa |
|
INDONESIA |
|
Compliant |
|
Tin |
|
PT Tommy Utama |
|
INDONESIA |
|
Compliant |
|
Tin |
|
Rui Da Hung |
|
TAIWAN |
|
Compliant |
|
Tin |
|
Soft Metais Ltda. |
|
BRAZIL |
|
Compliant |
|
Tin |
|
Thailand Smelting & Refining Co Ltd |
|
THAILAND |
|
Compliant |
|
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, Ltd. |
|
CHINA |
|
Compliant |
|
Tin |
|
CV Venus Inti Perkasa |
|
INDONESIA |
|
Compliant |
|
Tin |
|
Magnu's Minerais Metais e Ligas Ltda. |
|
BRAZIL |
|
Compliant |
|
Tin |
|
PT Tirus Putra Mandiri |
|
INDONESIA |
|
Unknown |
|
Tin |
|
PT Wahana Perkit Jaya |
|
INDONESIA |
|
Compliant |
|
Tin |
|
Melt Metais e Ligas S/A |
|
BRAZIL |
|
Compliant |
|
Tin |
|
PT ATD Makmur Mandiri Jaya |
|
INDONESIA |
|
Compliant |
|
Tin |
|
Phoenix Metal Ltd. |
|
RWANDA |
|
In Process |
|
Tin |
|
O.M. Manufacturing Philippines, Inc. |
|
PHILIPPINES |
|
In Process |
|
Tin |
|
PT Inti Stania Prima |
|
INDONESIA |
|
Compliant |
|
Tin |
|
CV Ayi Jaya |
|
INDONESIA |
|
Compliant |
|
Tin |
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
|
VIET NAM |
|
In Process |
|
Tin |
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
|
VIET NAM |
|
In Process |
|
Tin |
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
|
VIET NAM |
|
In Process |
|
Tin |
|
PT Cipta Persada Mulia |
|
INDONESIA |
|
Compliant |
|
Tin |
|
An Vinh Joint Stock Mineral Processing Company |
|
VIET NAM |
|
In Process |
|
Tin |
|
Resind Indústria e Comércio Ltda. |
|
BRAZIL |
|
Compliant |
|
Tin |
|
Metallo-Chimique N.V. |
|
BELGIUM |
|
Compliant |
|
Tin |
|
Elmet S.L.U. (Metallo Group) |
|
SPAIN |
|
Compliant |
|
Tin |
|
PT Bangka Prima Tin |
|
INDONESIA |
|
Compliant |
|
Tungsten |
|
A.L.M.T. TUNGSTEN Corp. |
|
JAPAN |
|
Compliant |
|
Tungsten |
|
Kennametal Huntsville |
|
UNITED STATES |
|
Compliant |
|
Tungsten |
|
Guangdong Xianglu Tungsten Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Chongyi Zhangyuan Tungsten Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Dayu Weiliang Tungsten Co., Ltd. |
|
CHINA |
|
In Process |
|
Tungsten |
|
Fujian Jinxin Tungsten Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Global Tungsten & Powders Corp. |
|
UNITED STATES |
|
Compliant |
|
Tungsten |
|
Hunan Chenzhou Mining Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Hunan Chunchang Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Japan New Metals Co., Ltd. |
|
JAPAN |
|
Compliant |
|
Tungsten |
|
Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
|
CHINA |
|
In Process |
|
Tungsten |
|
Ganzhou Huaxing Tungsten Products Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Kennametal Fallon |
|
UNITED STATES |
|
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 |
|
Xiamen Tungsten Co., Ltd. |
|
CHINA |
|
Compliant |
|
|
Smelter |
|
Country |
|
Compliance Status |
|
|
Tungsten |
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
|
CHINA |
|
Unknown |
|
Tungsten |
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Jiangxi Yaosheng Tungsten Co., Ltd. |
|
CHINA |
|
In Process |
|
Tungsten |
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
|
CHINA |
|
In Process |
|
Tungsten |
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
|
CHINA |
|
In Process |
|
Tungsten |
|
Malipo Haiyu Tungsten Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Xiamen Tungsten (H.C.) Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Jiangxi Gan Bei Tungsten Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Ganzhou Seadragon W & Mo Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Asia Tungsten Products Vietnam Ltd. |
|
VIET NAM |
|
Compliant |
|
Tungsten |
|
Chenzhou Diamond Tungsten Products Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Dayu Jincheng Tungsten Industry Co., Ltd. |
|
CHINA |
|
Unknown |
|
Tungsten |
|
Ganxian Shirui New Material Co., Ltd. |
|
CHINA |
|
Unknown |
|
Tungsten |
|
Pobedit, JSC |
|
RUSSIAN FEDERATION |
|
In Process |
|
Tungsten |
|
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Ganzhou Yatai Tungsten Co., Ltd. |
|
CHINA |
|
Compliant |
|
Tungsten |
|
H.C. Starck GmbH |
|
GERMANY |
|
Compliant |
|
Tungsten |
|
H.C. Starck Smelting GmbH & Co.KG |
|
GERMANY |
|
Compliant |
|
Tungsten |
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
|
VIET NAM |
|
Compliant |
|
Tungsten |
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
|
CHINA |
|
In Process |
|
Tungsten |
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
|
CHINA |
|
Compliant |
|
Tungsten |
|
Hydrometallurg, JSC |
|
RUSSIAN FEDERATION |
|
Compliant |