UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Dell Technologies Inc.
(Exact name of registrant as specified in its charter)
| Delaware | 001-37867 | 80-0890963 | ||||||||||||
| (State or other jurisdiction of incorporation or organization) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||||||||||||
One Dell Way, Round Rock, Texas | 78682 | |||||||||||||
| (Address of principal executive offices) | (Zip Code) | |||||||||||||
Richard J. Rothberg, Esq.
General Counsel and Secretary
(800) 289-3355
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
þ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
o Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ____
Section 1 — Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of the Conflict Minerals Report of Dell Technologies Inc. for the period January 1, 2021 to December 31, 2021 required by Item 1.01 is filed as Exhibit 1.01 hereto and is publicly available at
https://corporate.delltechnologies.com/content/dam/delltechnologies/assets/corporate/pdf/progress-made-real-reports/dell-technologies-conflictminerals-report.pdf.
Item 1.02 Exhibit
The Conflict Minerals Report of Dell Technologies Inc. for the period January 1, 2021 to December 31, 2021 required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 3 — Exhibits
Item 3.01 Exhibits
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
DELL TECHNOLOGIES INC. (Registrant) | ||||||||||||||||||||
| By: | /s/ Richard J. Rothberg | May 31, 2022 | ||||||||||||||||||
| Richard J. Rothberg, Esq. General Counsel and Secretary | Date | |||||||||||||||||||
| (Duly Authorized Officer) | ||||||||||||||||||||
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Exhibit 1.01
Dell Technologies
Conflict Minerals Report
Introduction
This Conflict Minerals Report for Dell Technologies Inc. (individually and together with its consolidated subsidiaries, “Dell” or “we,” “us,” and “our”) is filed with the Securities and Exchange Commission (the “SEC”) as an exhibit to Dell’s Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting year ended December 31, 2021 (the “Reporting Period”). The Rule imposes disclosure of certain due diligence and reporting obligations on SEC reporting companies whose manufactured products or products contracted to be manufactured contain “conflict minerals” that are necessary to the functionality or production of Dell products. The Rule defines “conflict minerals” as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives limited to tin, tantalum, tungsten, and gold, also referred to as “3TG.”
Dell Products Covered by this Report
This Report relates to products: (i) for which conflict minerals are necessary to the functionality or production of such products; (ii) that were manufactured, or contracted to be manufactured, by Dell; and (iii) for which the manufacture was completed during the Reporting Period (the “Covered Products”). The Covered Products include the following product categories manufactured or contracted to be manufactured by Dell in the Reporting Period: branded hardware, such as desktop PCs, notebooks and tablets; branded and third-party peripherals, such as monitors and projectors; and server, storage and networking products.
Overview of Dell’s Conflict Minerals Program
As part of Dell’s global approach to ensure responsible sourcing of minerals, Dell supports and respects the protection of internationally proclaimed human rights of all people, including the basic human rights of our employees and workers within our supply chain.
Dell manufactures and contracts to manufacture products for which 3TG minerals are necessary to their functionality or production. As a manufacturer of technology products, Dell does not purchase 3TG directly from mines, smelters, or refiners, but does procure components and materials that may contain 3TG.
Therefore, Dell collaborates with suppliers, industry peers, and other stakeholders in an effort to ensure our products do not contain 3TG whose sale directly or indirectly finances armed conflict or contributes to human rights violations. In order to comply with the Rule, Dell conducts a good-faith Reasonable Country of Origin Inquiry (“RCOI”) to determine whether any necessary 3TG contained in the Covered Products originated in the Democratic Republic of the Congo (the “DRC”), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, or Angola (together, the “Covered Countries”), or were from recycled or scrap sources.
Dell’s due diligence process is designed to align with the five-step due diligence framework set forth in the Organisation for Economic Co-operation and Development’s “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 3rd Edition (2016)” and the related Supplements for 3TG (the “OECD framework”).
We participate in multi-stakeholder initiatives such as the Responsible Minerals Initiative (“RMI”). The RMI provides tools such as the Conflict Minerals Reporting Template (“CMRT”) and oversees the Responsible Minerals Assurance Process (“RMAP”), which verifies that sourcing practices of actors at identified points in the supply chain (i.e., 3TG smelters or refiners (“SORs”)) are aligned to the OECD framework. We use these tools, RMI guidance, and the OECD framework to conduct due diligence on our 3TG supply chain and drive our minerals sourcing actions towards the goals established at the beginning of the Reporting Period. This includes a 100 percent CMRT response rate by in-scope suppliers and increasing the number of smelters and refiners participating in RMAP.
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Reasonable Country of Origin Inquiry
Deploying a CMRT survey to relevant suppliers, conducting a smelter and refiner review, and considering other third-party data constituted the Reasonable Country of Origin Inquiry (“RCOI”). This RCOI, combined with our risk assessment and mitigation efforts described in this report, represents Dell’s efforts to trace the source of 3TG in our supply chain to country of origin and the mine or location of origin as necessary. On the basis of the RCOI findings, Dell performed further due diligence on 3TG contained in Covered Products that may originate from SORs known to source from Covered Countries and SORs that may source from Covered Countries. The results of the RCOI investigation are reported under “Due Diligence Results.”
Due Diligence Process
Design of Due Diligence Measures
Dell’s due diligence measures have been designed to conform, in all material respects, with the OECD framework.
Dell’s due diligence included the following elements of the OECD framework:
Step 1: Establish strong company management system
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain
Step 5: Report on supply chain due diligence
Due Diligence Performed
Step 1: Establish Strong Company Management System
Dell has established a management system to determine 3TG source and chain of custody in its supply chain.
Responsible Sourcing Policy. Dell’s Responsible Sourcing Policy outlines a collaborative approach to addressing concerns about the risk of human rights violations in the upstream supply chain. The policy states our expectations for suppliers to have policies and due diligence practices in place to reasonably assure that products and components supplied to Dell do not contain 3TG sourced from conflict mines.
Dell abides by, and is held accountable to, the Responsible Business Alliance (“RBA”) Code of Conduct and Dell’s Supplier Principles, which require direct material suppliers to maintain a conflict minerals policy and conduct due diligence on the source and chain of custody of materials in their products to reasonably assure they do not come from conflict sources.
Control System. Dell surveys its supply chain annually using the Conflict Minerals Reporting Template. This survey is the primary mechanism for identifying smelters and refiners that supply 3TG to components within the supply chain and assessing the risks associated with 3TG. Following the collection of smelter and refiner data from suppliers, Dell uses the RMI’s RMAP (and, as applicable, the London Bullion Market Association’s (“LBMA”) equivalent scheme) to gain initial insights into whether the smelter is participating in a third-party audit program and to determine the country of origin of 3TG for the smelters and refiners in our supply chain.
Supplier Engagement. Responsible sourcing is embedded in Dell’s supply chain management business processes. In addition to reviewing each CMRT received for completeness and communicating and following any required corrective actions, we incorporate metrics on suppliers’ adherence to Dell’s expectations in scorecards used in quarterly business reviews; the metrics are communicated to suppliers alongside other measures of core supply chain performance (quality, cost and availability).
Internal Team. Dell has a team of individuals dedicated to responsible sourcing management. These individuals work closely with other supply chain teams, such as Procurement and Engineering, to collect data from suppliers – and work with them in the event of errors or non-compliance. Performance is regularly communicated to these groups via monthly reports and escalation protocols.
The team members report to the Vice President for Supply Chain Assurance, with alignment and approval for policies, supplier requirements, communications and risk management addressed in the quarterly Social and Environmental Responsibility (“SER”) Steering Committee, consisting of the supply chain leadership team. Public
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reporting is subject to verification and approval from core functions, such as Legal and Environmental, Social & Governance (“ESG”), with final approval residing with the Chief Supply Chain Officer.
Grievance Mechanism. Dell maintains grievance reporting processes for internal and external parties to report supply chain concerns. Grievance reports, including those related to responsible sourcing of minerals, can be made either directly to Dell or through Dell’s ethics hotline (accessible via telephone or web) managed by a third-party provider. This provider receives such reports and directs them to the appropriate Dell contact for investigation. Information about these reporting channels is included in Dell’s Code of Conduct, and in mandatory annual Code of Conduct training for team members.
The web site http://dell-ethicsline.com provides comprehensive information, including local phone numbers for every country. Anonymous reports can be submitted by telephone or online. Additionally, parties can contact the Dell Ethics & Compliance Office via ethics@dell.com (in a reporting process that is not anonymous).
Dell also encourages the use of the RMI’s Grievance Mechanism for mineral supply chain issues. Anonymous submissions can be made at www.mineralsgrievanceplatform.org.
Dell maintains an anti-retaliation policy that encourages team members to promptly report a potential or actual violation of applicable laws, regulations, and Dell policies or suspected unethical, illegal, or suspicious behavior. Retaliation against anyone reporting concerns or assisting with an investigation or audit in good faith, is prohibited. Team members who suspect they are subject to retaliation are encouraged to report using available channels.
Step 2: Identify and Assess Risks in the Supply Chain
A supplier is identified in-scope for Dell’s Conflict Minerals Program if it meets one or more of the following criteria:
•supplies components to Dell that are known to, or could potentially, contain 3TG;
•collects a specified percentage of Dell spend; or
•is considered high-risk for manufacturing products that contain 3TG whose sale might benefit armed groups in the Covered Countries based on previously reported data.
Dell requests CMRTs from in-scope suppliers and expects them to disseminate this reporting requirement across the supply chain through a cascade approach. Suppliers are required to provide comprehensive, accurate data on 3TG acquired from their supply chain through the CMRT process. These data are used to identify and verify the smelters and refiners in our supply chain participating in RMAP (or, as applicable, the LBMA’s equivalent scheme). Collected CMRTs are analyzed to ensure conformity with Dell’s assessment.
Dell partners with a third-party software provider to manage the CMRT reporting campaign and enable initial data validation (to ensure survey completeness), followed by a more in-depth review using internally-developed risk assessment criteria. These criteria evaluate the smelters and refiners identified as being in Dell’s supply chain and assess the supplier’s due diligence undertaken and other aspects of the supplier’s program (including existence of a conflict minerals policy and use of CMRT).
Step 3: Design and Implement a Strategy to Respond to Identified Risks
Dell is committed to promoting responsible sourcing through third-party verification of smelters and refiners. Suppliers are required to progress towards the use of smelters and refiners designated to be conformant by RMAP or equivalent certifications, or who use 3TG minerals 100% from recycled or scrap sources.
In promoting the use of operators whose commitment to responsible sourcing is externally certified, Dell recognizes there are smelters or refiners who do not align to these expectations or are unwilling to undergo a third-party audit. Alternatively, external factors may cause a smelter or refiner to lose RMAP Conformant status.
Accordingly, Dell’s due diligence draws on RMI databases, customer engagements, and independent research to identify non-certified smelters and refiners or those at risk of benefitting armed groups in conflict-affected and high-risk areas, including the Covered Countries. In such events, Dell requires suppliers to remove the smelter or refiner in question from their supply chain.
This approach is enhanced by reviewing not only high-risk smelters and refiners, but also those that do not, or cannot, achieve RMAP conformance. The relevant Dell procurement teams help engage suppliers to develop a plan to address smelters or refiners of concern, including identifying parts affected, material breakdown of parts, and timelines for completion. Progress is managed on a regular basis, with executive oversight on both sides, with
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regular briefings leading to potentially impacted scoring in quarterly business reviews. If the issue is not resolved, further options may be considered, including pursuing alternate sourcing.
To expedite such processes, there is a focus on ensuring that data collection targets parts and sub-tier suppliers directly in the supply chain for Dell products. We continue to review opportunities to improve surveying and reporting capabilities, with supplier collaboration of paramount importance to this process.
Step 4: Carry Out Independent Third-Party Audits of Supply Chain Due Diligence at Identified Points in the Supply Chain
As a downstream company, Dell uses RMAP for smelter and refiner audits to assess risks from the mine to the smelter or refiner and requires participation in third-party audits, including removing from Dell’s supply chain those facilities unwilling to participate. Participation in independent, third-party certification programs provides assurance that smelters and refiners have enough systems and controls in place to ensure their sourcing practices align with the OECD Guidance and do not support conflict, including in the DRC and adjacent countries. Through our membership and participation in the RMI, we continue to support development and implementation of tools and process aimed at advancing cross-industry due diligence practices.
Step 5: Report on Supply Chain Due Diligence
This report and Dell’s Form SD will be filed with the SEC and be publicly available at www.sec.gov
and www.dell.com/supplychain.
Dell also provides information related to social and environmental responsibility on our website and in our annual ESG report.
References to Dell’s website are provided for convenience only, and its contents are not incorporated by reference into this report nor are they deemed filed with the SEC.
Due Diligence Results
Based on consolidated CMRT information for the Reporting Period and subsequent corrective actions carried out with suppliers, 264 unique 3TG smelter or refiner facilities were identified in Dell’s supply chain as of March 25, 2022. 100 percent of in-scope suppliers provided a CMRT in response to our survey request. Our work to increase the number of smelters and refiners participating in RMAP resulted in the designation of 256 (97 percent) smelters and refiners reported in Dell’s supply chain as conformant1. The remaining eight smelters and refiners have recently stopped participating in a third-party audit program, or were not willing to complete a third-party audit within established timelines, therefore they are considered by Dell to be non-compliant; we are collaborating with our suppliers to transition away from these entities according to the risk mitigation strategy previously noted.
As a result of our due diligence activities, Dell found no reason to conclude that any smelter or refiner reported in Dell’s supply chain sourced 3TG that directly or indirectly financed or benefited armed groups in the Covered Countries. Of all the 264 smelters and refiners, 44 are known to be sourcing from the DRC or an adjoining country, and all are designated as “RMAP Conformant”.
Many suppliers returned CMRTs encompassing their entire supply chains, rather than focusing only on components incorporated into Dell’s Covered Products, therefore some smelters and refiners reported might not be providing material for Dell products. Dell continues to work with suppliers throughout its supply chain to assess and improve their information, reporting quality, and capacity, taking into account supply chain fluctuations and other changes in status or scope and relationships over time. The full list of smelters and refiners reported by our suppliers is published in Appendix B.
The list of countries from which we believe 3TG in our Covered Products may have originated is published in Appendix A. Some 3TG also originates from recycled or scrap sources. This information was obtained using the RCOI report dated March 25, 2022 that is available to Dell as a member of RMI.
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1 In addition to smelters and refiners that are participating in RMAP (“Active” and/or “Conformant”), Dell includes smelters and refiners with equivalent assurance (that is, London Bullion Market Association (“LBMA”) Certified).
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Continuous Improvement to Mitigate Risk
Dell will continue taking the following steps, among others, to improve the due diligence conducted and to further mitigate risk of sourcing 3TG that benefits armed groups from the Covered Countries:
1) Work closely with suppliers to obtain necessary information on the origin of 3TG contained in materials or components used in the Covered Products.
2) Work with supply chain actors through engagement with RMI to promote smelter and refiner participation in RMAP and other equivalent third-party certifications.
3) Monitor incidents related to OECD Annex II risks to assess their impact on Dell’s supply chain.
4) Partner with organizations dedicated to supporting mining communities and contributing to ethical sourcing of minerals.
Cautionary Statement about Forward-Looking Statements
Statements in this report that relate to future events are forward-looking statements within the meaning of Section 21E of the Securities Exchange Act of 1934 and Section 27A of the Securities Act of 1933 and are based on Dell’s current expectations. In some cases, you can identify these statements by such forward-looking words as “anticipate,” “believe,” “confidence,” “could,” “estimate,” “expect,” “guidance,” “intend,” “may,” “objective,” “outlook,” “plan,” “project,” “possible,” “potential,” “should,” “will” and “would,” or similar words or expressions that refer to future events or outcomes. Dell’s results or events in future periods could differ materially from those expressed or implied by these forward-looking statements because of risks, uncertainties, and other factors, including those risks described in its reports filed with the SEC, including Dell’s Annual Report on Form 10-K for the fiscal year ended January 28, 2022, quarterly reports on Form 10-Q, and current reports on Form 8-K. These filings are available for review through the SEC’s website at www.sec.gov. Any or all forward-looking statements Dell makes may turn out to be wrong and can be affected by inaccurate assumptions Dell might make or by known or unknown risks, uncertainties, and other factors, including those identified in this report. Accordingly, you should not place undue reliance on the forward-looking statements made in this report, which speak only as of its date. Dell does not undertake to update, and expressly disclaims any duty to update, its forward-looking statements, whether as a result of circumstances or events that arise after the date they are made, new information, or otherwise.
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Appendix A: Reasonable Country of Origin Inquiry List
The following list identifies countries from which the minerals in Dell’s products may have originated based on sourcing information disclosed during the RMAP’s third-party auditing process and RMI’s Reasonable Country of Origin Inquiry report dated March 25, 2022. The countries of origin of the 3TG processed by facilities listed in Appendix B are believed to be the following:
| Argentina | Guinea | Russia | ||||||
| Australia | Guyana | Rwanda | ||||||
| Austria | India | Sierra Leone | ||||||
| Belgium | Indonesia | South Africa | ||||||
| Benin | Japan | South Korea | ||||||
| Bolivia | Laos | Spain | ||||||
| Brazil | Madagascar | Swaziland | ||||||
| Burundi | Malaysia | Sweden | ||||||
| Canada | Mexico | Taiwan | ||||||
| China | Mongolia | Tanzania | ||||||
| Colombia | Mozambique | Thailand | ||||||
| Congo, Democratic Republic of the | Myanmar | Uganda | ||||||
| Ecuador | Namibia | United Kingdom of Great Britain and Northern Ireland | ||||||
| Eritrea | Niger | United States of America | ||||||
| Ethiopia | Nigeria | Uzbekistan | ||||||
| France | Peru | Venezuela | ||||||
| Germany | Philippines | Vietnam | ||||||
| Ghana | Portugal | Zimbabwe | ||||||
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Appendix B: Dell Smelter and Refiner List
This list is based on Dell supplier data for the Reporting Period. In many cases, suppliers provided information encompassing their entire supply chain; this information was not limited to facilities that contributed 3TG used only in Dell products. As a result, we are unable to confirm whether our products in fact contain 3TG from all of these sources. This list only includes facilities reported by suppliers that are on the RMI’s eligible smelter list as of March 25, 2022.
| Metal | Smelter Name | Smelter Country | ||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | ||||||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | ||||||
| Tantalum | Global Advanced Metals Aizu | JAPAN | ||||||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||||||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||||||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | ||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | KEMET de Mexico | MEXICO | ||||||
| Tantalum | LSM Brasil S.A. | BRAZIL | ||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||||||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||||||
| Tantalum | NPM Silmet AS | ESTONIA | ||||||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||||||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||||||
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||||||
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | ||||||
| Tantalum | TANIOBIS GmbH | GERMANY | ||||||
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | ||||||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||||||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | ||||||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||||||
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | ||||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||||||
| Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | CHINA | ||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tin | Alpha | UNITED STATES OF AMERICA | ||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||||||
| Tin | China Tin Group Co., Ltd. | CHINA | ||||||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | ||||||
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| Metal | Smelter Name | Smelter Country | ||||||
| Tin | CRM Synergies | SPAIN | ||||||
| Tin | CV Venus Inti Perkasa | INDONESIA | ||||||
| Tin | Dowa | JAPAN | ||||||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin | Estanho de Rondonia S.A. | BRAZIL | ||||||
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | ||||||
| Tin | Fenix Metals | POLAND | ||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||||||
| Tin | Luna Smelter, Ltd. | RWANDA | ||||||
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | ||||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | ||||||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||||||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | ||||||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||||||
| Tin | Metallo Belgium N.V. | BELGIUM | ||||||
| Tin | Metallo Spain S.L.U. | SPAIN | ||||||
| Tin | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tin | Minsur | PERU | ||||||
| Tin | Mitsubishi Materials Corporation | JAPAN | ||||||
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | ||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||||||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||||||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | ||||||
| Tin | PT Artha Cipta Langgeng | INDONESIA | ||||||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||||||
| Tin | PT Babel Inti Perkasa | INDONESIA | ||||||
| Tin | PT Babel Surya Alam Lestari | INDONESIA | ||||||
| Tin | PT Bangka Serumpun | INDONESIA | ||||||
| Tin | PT Bukit Timah | INDONESIA | ||||||
| Tin | PT Cipta Persada Mulia | INDONESIA | ||||||
| Tin | PT Masbro Alam Stania | INDONESIA | ||||||
| Tin | PT Menara Cipta Mulia | INDONESIA | ||||||
| Tin | PT Mitra Stania Prima | INDONESIA | ||||||
| Tin | PT Mitra Sukses Globalindo | INDONESIA | ||||||
| Tin | PT Prima Timah Utama | INDONESIA | ||||||
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | ||||||
| Tin | PT Refined Bangka Tin | INDONESIA | ||||||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | ||||||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | ||||||
| Tin | PT Sukses Inti Makmur | INDONESIA | ||||||
| Tin | PT Timah Nusantara | INDONESIA | ||||||
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| Metal | Smelter Name | Smelter Country | ||||||
| Tin | PT Timah Tbk Kundur | INDONESIA | ||||||
| Tin | PT Timah Tbk Mentok | INDONESIA | ||||||
| Tin | PT Tinindo Inter Nusa | INDONESIA | ||||||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||||||
| Tin | Soft Metais Ltda. | BRAZIL | ||||||
| Tin | Super Ligas | BRAZIL | ||||||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||||||
| Tin | Thaisarco | THAILAND | ||||||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tin | Yunnan Tin Company Limited | CHINA | ||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Gold | 8853 S.p.A. | ITALY | ||||||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||||||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||||||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | Alexy Metals | UNITED STATES OF AMERICA | ||||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||||||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | ||||||
| Gold | Asahi Pretec Corp. | JAPAN | ||||||
| Gold | Asahi Refining Canada Ltd. | CANADA | ||||||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Gold | Augmont Enterprises Private Limited | INDIA | ||||||
| Gold | Aurubis AG | GERMANY | ||||||
| Gold | Bangalore Refinery | INDIA | ||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||||||
| Gold | Boliden AB | SWEDEN | ||||||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | ||||||
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | ||||||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||||||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | ||||||
| Gold | Chimet S.p.A. | ITALY | ||||||
| Gold | Chugai Mining | JAPAN | ||||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||||||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||||||
| Gold | Dowa | JAPAN | ||||||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||||||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||||||
9
| Metal | Smelter Name | Smelter Country | ||||||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||||||
| Gold | Heimerle + Meule GmbH | GERMANY | ||||||
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | ||||||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||||||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold | Istanbul Gold Refinery | TURKEY | ||||||
| Gold | Italpreziosi | ITALY | ||||||
| Gold | Japan Mint | JAPAN | ||||||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | ||||||
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||||||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||||||
| Gold | Kazzinc | KAZAKHSTAN | ||||||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||||||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||||||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | L'Orfebre S.A. | ANDORRA | ||||||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||||||
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Marsam Metals | BRAZIL | ||||||
| Gold | Materion | UNITED STATES OF AMERICA | ||||||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||||||
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | ||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||||||
| Gold | Metalor Technologies S.A. | SWITZERLAND | ||||||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||||||
| Gold | Mitsubishi Materials Corporation | JAPAN | ||||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||||||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||||||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||||
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | ||||||
| Gold | Nihon Material Co., Ltd. | JAPAN | ||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||||||
| Gold | PAMP S.A. | SWITZERLAND | ||||||
| Gold | Planta Recuperadora de Metales SpA | CHILE | ||||||
10
| Metal | Smelter Name | Smelter Country | ||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||||||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||||||
| Gold | PX Precinox S.A. | SWITZERLAND | ||||||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||||||
| Gold | REMONDIS PMR B.V. | NETHERLANDS | ||||||
| Gold | Royal Canadian Mint | CANADA | ||||||
| Gold | SAAMP | FRANCE | ||||||
| Gold | Safimet S.p.A | ITALY | ||||||
| Gold | SAFINA A.S. | CZECHIA | ||||||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||||
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | ||||||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||||||
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||||||
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | ||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||||||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||||||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||||||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | T.C.A S.p.A | ITALY | ||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||||||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||||||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||||||
| Gold | Torecom | KOREA, REPUBLIC OF | ||||||
| Gold | Umicore Precious Metals Thailand | THAILAND | ||||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||||||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Valcambi S.A. | SWITZERLAND | ||||||
| Gold | WEEEREFINING | FRANCE | ||||||
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||||||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | ||||||
| Gold | Yamakin Co., Ltd. | JAPAN | ||||||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | ||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||||||
| Tungsten | A.L.M.T. Corp. | JAPAN | ||||||
| Tungsten | ACL Metais Eireli | BRAZIL | ||||||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Cronimet Brasil Ltda | BRAZIL | ||||||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||||||
| Tungsten | Fujian Xinlu Tungsten | CHINA | ||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||||||
11
| Metal | Smelter Name | Smelter Country | ||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||||||
| Tungsten | GEM Co., Ltd. | CHINA | ||||||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||||||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | ||||||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||||||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||||||
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | ||||||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||||||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||||||
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | ||||||
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION | ||||||
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION | ||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||||||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||||||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||||||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||||||
12