UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
L.B. Foster Company
(Exact name of registrant as specified in its charter)
| Pennsylvania | 000-10436 | 25-1324733 | ||
| (State or other jurisdiction of incorporation) |
(Commission File Number) |
(I.R.S. Employer Identification No.) |
| 415 Holiday Drive, Pittsburgh, Pennsylvania | 15220 | |
| (Address of principal executive offices) | (Zip Code) |
David J. Russo, (412)-928-3417
(Name and telephone number, including area code, of the person to contact in connection with this report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
Conflict Minerals Disclosure
A copy of L.B. Foster’s Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015 is provided as Exhibit 1.01 hereto and is publicly available on our corporate website, http://www.lbfoster.com/ at http://phx.corporate-ir.net/phoenix.zhtml?c=73803&p=irol-sec. Based upon representations made by the Company’s suppliers, L.B. Foster Company is unable to conclude, for some of its products, whether or not the origin of the conflict minerals used in its products during calendar year 2015 were sourced from the Democratic Republic of the Congo or adjoining countries (as defined by Rule 13p-1) or come from recycled or scrap sources.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
| Exhibit |
Description | |
| 1.01 | Conflict Minerals Report of L.B. Foster Company. | |
SIGNATURE
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.
| L.B. FOSTER COMPANY | ||||||
| (Registrant) | ||||||
| Date: May 27, 2016 | By: | /s/ David J. Russo | ||||
| David J. Russo | ||||||
| Senior Vice President, | ||||||
| Chief Financial Officer and Treasurer | ||||||
EXHIBIT INDEX
| Exhibit |
Description | |
| 1.01 | Conflict Minerals Report dated May 27, 2016, of L.B. Foster Company. | |
Exhibit 1.01
L.B. FOSTER COMPANY
Conflict Minerals Report
For the reporting period from January 1, 2015 to December 31, 2015
| 1 | Introduction |
This Conflict Minerals Report (the “Report”) of L.B. Foster Company (the “Company” or “we”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2015 to December 31, 2015.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite, and wolframite, including their derivatives, which are limited to tantalum, tin, and tungsten (collectively “3TG”). The “Covered Countries” for purposes of the Rule are the Democratic Republic of the Congo and the Adjoining Countries (as defined in the Rule).
As further described in this Report, the Company has determined that certain of its operations manufacture or contract to manufacture products that may contain 3TGs that are necessary to the functionality or production of such products.
L.B. Foster Company’s policy relating to 3TGs (the “Conflict Minerals Policy”) can be viewed on the Company’s website at http://www.lbfoster.com/corporate/conflict_minerals.asp.
| 1.1 | Company Overview |
L.B. Foster Company is a leading manufacturer, fabricator, and distributor of products and services for the rail, construction, energy, and utility markets. For rail markets, the Company provides a full line of new and used rail, trackwork, and accessories to railroads, mines, and industrial companies. The Company also designs and produces concrete railroad ties, insulated rail joints, power rail, track fasteners, coverboards, and special accessories for mass transit and other rail systems worldwide. Additionally, the Company engineers, manufactures, and assembles friction management products and railway wayside data collection and management systems. For the construction industry, the Company sells steel sheet piling, H-bearing piling, and pipe piling, and provides rental sheet piling for foundation requirements. In addition, the Company supplies precast concrete buildings and other precast concrete products, bridge decking, bridge railing, bridge forms, expansion joints, and other products for highway construction and repair. For tubular markets, the Company offers pipe coatings, precision measurement systems, and test and inspection services for natural gas pipelines and utilities. The Company also produces threaded pipe products for industrial water well and irrigation markets. Based upon Instruction 3 to Item 1.01 of Form SD, the Company is not reporting on products manufactured or contracted to be manufactured by its Tew Plus, LTD, subsidiary, which was acquired by the Company on November 23, 2015.
| 1.2 | Product Overview |
This Report relates to the Company’s products (i) for which 3TGs are necessary to the functionality or production of that product; (ii) that were manufactured or contracted to be manufactured by the Company; and (iii) for which the manufacture was completed during calendar year 2015.
L.B. Foster Company does not directly purchase 3TGs, but it purchases components that it uses in the products it manufactures. The Company identified certain products sold by the Company as possibly containing 3TGs that are necessary to the functionality or production of the products.
| 2 | Reasonable Country of Origin Inquiry (“RCOI”) |
The Company conducted a good faith RCOI regarding the 3TG in materials, components, and finished goods supplied to the Company, including the following steps (collectively, the “Program”):
Utilizing version 4.01 of CFSI’s Conflict Minerals Reporting Template (“CMRT”), the Company engaged its 908 potential 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products.
The Company retained a third party vendor (“Vendor”) to conduct supplier surveying via its platform that enables users to complete and track supplier communications. It also allows suppliers to upload completed CMRTs directly to the platform for assessment and management. Non-responsive suppliers were contacted a minimum of three times by the Vendor and then were also managed by the Vendor supply chain team in 1:1 communications, including offering assistance and further information to suppliers about the requirements of the Rule and the Program.
The 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 still retained. Suppliers were contacted with regard to invalid forms and were encouraged to resubmit a valid form. As of May 27, 2016, 34 invalid supplier submissions were not yet corrected.
Of the suppliers who responded that they provide 3TG to the Company, many did not include the name of any verified Smelters or Refiners (together, “SOR” or “Smelters”). Based on the responses received from the Company’s RCOI, which included thousands of alleged SOR names, a list was compiled of 320 verified, unique SORs, including information regarding associated countries of origin (the “Unique Smelter List”). The Company performed due diligence on the SORs which appeared on the Unique Smelter List that were known or reasonably believed to have sourced from the Covered Countries or that had unknown sourcing.
On the basis of the responses to our RCOI, the Company is unable to determine that 3TGs necessary to the functionality or production of our products did not originate in the Covered Countries. Accordingly, the Company undertook the following measures to assess the due diligence practices of the SORs listed on its unique smelter list that were known or reasonably believed to have sourced from the Covered Countries or that had unknown sourcing:
| 3 | Due Diligence |
| 3.1 | Design of Due Diligence |
L.B. Foster designed its due diligence process to be in conformity, in all material respects, with the due diligence framework in the Organization of Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, the “OECD Guidance”).
3.1.1 Establish Strong Company Management Systems
Conflict Minerals Policy
As described above, we have adopted a Conflict Minerals Policy, which is posted on our website at http://www.lbfoster.com/corporate/conflict_minerals.asp.
Internal Team and Training
The Company has established a management team responsible for the oversight of its conflict mineral assessment. The management team is overseen by the Chief Financial Officer and a team of subject matter experts from relevant functions such as quality, supply chain, operations, finance, and legal. Senior management is briefed about the results of our due diligence efforts on a regular basis.
We, in cooperation with our Vendor, have developed internal training programs to educate persons within the Company who may potentially have contact with suppliers or other external parties regarding the Company’s conflict minerals compliance efforts. We intend to review our training programs at least annually to make sure they are continuously aligned with current regulations, our initiatives, and the tools we use.
Control Systems
As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other manufacturers in our industry and other sectors.
Our controls include our Legal and Ethical Conduct Policy, which outlines expected behaviors for all our employees.
Supplier Engagement
We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers.
In accordance with the Organization for Economic Co-operation and Development requirement to strengthen engagement with suppliers, we have, in cooperation with our Vendor, provided education to suppliers on the conflict minerals regulations as well as the expectations of the law. In addition, we have leveraged the existing communications within the Company, specifically through our procurement personnel, to encourage supplier interactions with our Vendor as well for them to understand the need to complete the surveys. Feedback from this process has allowed us to enhance the training, to focus and adapt it to each user’s needs, and refine and clarify our supplier communications to ensure that our expectations are clear.
Grievance Mechanism
We have longstanding grievance mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Conflict Minerals Policy.
Records Maintenance
We have retained all relevant documentation from our RCOI and due diligence. Our existing policy related to relevant documentation of our conflict mineral compliance process requires that documentation will be retained for a period of at least five years.
3.1.2 Identify and Assess Risk in Our Supply Chain
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult for us to identify all vendors upstream from our direct suppliers.
We have identified 908 direct suppliers. We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. Many of the largest suppliers either are SEC registrants and subject to the Rule or are suppliers to other Securities and Exchange Commission (“SEC”) registrants who are subject to the Rule.
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as conflict free by third party sources such as the Conflict-Free Sourcing Initiative (“CFSI”) or the London Bullion Market Association (“LBMA”) Responsible Gold Programme pose a significant risk. Where a smelter is not identified as Conflict Free by such sources, we rate the risk as High, Medium, or Low. This rating is based on various factors, including whether the SOR has been identified as a valid SOR and has an associated Smelter Identification Number (under the CFSI, this is known as a CID), and the smelter’s geographic location, including proximity to the Covered Countries.
We calculate supplier risk based on the chances that a 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). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:
| • | Existence of a policy in place that includes conflict-free sourcing; |
| • | Implementation of due diligence measures for conflict-free sourcing; |
| • | Verification of due diligence information received from suppliers; and |
| • | Whether verification process includes corrective action management. |
Based on how each supplier’s program meets these criteria, their program strength is identified as either strong or weak.
As part of our risk management plan and to ensure suppliers understand our expectations, we have, through our Vendor, provided video and written training on conflict minerals and the CMRT. This includes instructions on completing the form, and one-on-one email and phone discussions with supplier personnel.
In accordance with our Conflict Minerals Policy, we engage suppliers whom we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we may then take steps to terminate a contract and find replacement suppliers.
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the
3TGs in our supply chain. This was done by adopting methodology outlined by the CFSI’s joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this industry joint effort, we made reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict Free” lists of sourced metals.
| 3.1.3 | Design and Implement a Strategy to Respond to Risks |
In response to this risk assessment, the Company has an approved risk management plan through which the conflict minerals program is implemented, managed, and monitored. Updates to this risk assessment are provided regularly to senior management.
As part of our risk management plan, to ensure suppliers understand our expectations, we have provided both video, recorded training and documented instructions through our Vendor and responded to questions of suppliers requiring further clarification. We then provided each supplier a copy of the EICC-GeSI reporting CMRT to complete for purposes of conflict minerals tracking. Furthermore, we reviewed responses to the reporting CMRT with specific suppliers where we needed clarification. As described in our Conflict Minerals Policy, we intend to engage any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in the Covered Countries to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.
| 3.1.4 | Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chains |
L.B. Foster does not have a direct relationship with conflict minerals smelters or refiners and as a result, the Company does not perform direct audits of these entities in its supply chain. L.B. Foster relies on the efforts of the industry associations that administer independent third-party smelter and refinery audit programs and encourages suppliers with more direct relationships with smelters to participate in comparable due diligence validation activities.
| 3.1.5 | Report on Supply Chain Due Diligence |
This conflict minerals report is being filed with the SEC as an exhibit to our specialized disclosure report on Form SD and is available on our website at http://phx.corporate-ir.net/phoenix.zhtml?c=73803&p=irol-sec.
| 4 | Due Diligence Results |
The majority of supplier responses received provided information at a company-wide level. We reviewed the responses against criteria we developed to determine which may require further engagement with our suppliers. Such criteria included untimely or incomplete responses as well as inconsistencies with the data reported. We have sent and continue to send additional requests to seek clarifications from suppliers to validate such data and obtain more complete and accurate responses.
Efforts to Determine Mine or Location of Origin
Due to our position in the supply chain, it is difficult for us to identify suppliers upstream from our direct suppliers and it is increasingly difficult to track 3TGs down to the mine or smelter level. Through continual follow-up, the Company requests additional status reports from direct suppliers. We work to validate the data obtained from suppliers by utilizing claims made by referenced refiners or smelters on their websites. For our position in the supply chain, we have determined to use this risk based approach to determine the origin of 3TGs in purchased products/materials.
Country of Origin
Based on the nature of information we received from our suppliers, we are unable to determine the country of origin of 3TG’s in our products.
Smelters or Refiners
For all responses that indicated a smelter, our Vendor compared the facilities listed to the list of smelters maintained by the Conflict-Free Sourcing Initiative (“CFSI”). If a supplier indicated that the facility was certified as “Conflict-Free,” our Vendor confirmed that the name was listed by CFSI as a certified smelter. No violations were identified. As of May 27, 2016, we have validated 320 smelters or refiners and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Schedule A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Schedule A any smelters or refiners that we have not been able to validate.
Based on the smelter lists provided by suppliers via the CMRTs and publically available information, we have identified 215 smelters that are certified conflict-free.
| 5 | Steps Taken to Mitigate Risk |
In 2016, we have taken, or plan to take, the following steps to mitigate the risk that our necessary 3TGs benefit armed groups.
| • | Continue to deploy our supply chain policy in accordance with OECD recommendations; |
| • | Enhance management processes to ensure risks related to the acquisition of components containing 3TGs are adequately managed; |
| • | Structure internal systems to support supply chain due diligence, including through the assignment of responsibility to senior staff to oversee the process and ensure availability of resources and implementation of “up the chain” communication processes; |
| • | Further augment our reasonable country of origin and due diligence process with our vendors; |
| • | Increase our supplier response rate while increasing the validation of Smelter information by substituting vendors that use 3TGs from the Covered Countries for the vendors that do not use 3TGs; and |
| • | Raise the awareness of suppliers to their use of conflict-free minerals and alert them to a potential request for an audit to prove that they are conflict free. |
Schedule A
The following lists the Smelters identified by our vendors as sources for their products that are certified by the “Conflict Free Smelter Program.”
The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the smelters or refiners identified by our direct suppliers contained in the tables below may contain smelters or refiners that processed conflict minerals that our direct suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the smelters or refiners included in the tables below were used to process the conflict minerals necessary to the functionality or production of our products during 2015. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed above were the country of origin of conflict minerals in our products during 2015, and therefore also unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the CFSI Conflict-Free Smelter Program or the LBMA Responsible Gold Programme and, as a result, are not responsible for the quality of these audits or the audit findings.
| Metal |
Standard Smelter Name |
Smelter Facility Location |
Conflict Free? | |||
| Gold |
Advanced Chemical Company | UNITED STATES | Unknown | |||
| Gold |
Aida Chemical Industries Co., Ltd. | JAPAN | Yes | |||
| Gold |
Aktyubinsk Copper Company TOO | KAZAKHSTAN | Unknown | |||
| Gold |
Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Unknown | |||
| Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Yes | |||
| Gold |
Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Unknown | |||
| Gold |
AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Yes | |||
| Gold |
Argor-Heraeus SA | SWITZERLAND | Yes | |||
| Gold |
Asahi Pretec Corporation | JAPAN | Yes | |||
| Gold |
Asahi Refining Canada Limited | CANADA | Yes | |||
| Gold |
Asahi Refining USA Inc. | UNITED STATES | Yes | |||
| Gold |
Asaka Riken Co., Ltd. | JAPAN | Yes | |||
| Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Unknown | |||
| Gold |
Aurubis AG | GERMANY | Yes | |||
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes | |||
| Gold |
Bauer Walser AG | GERMANY | Unknown | |||
| Gold |
Boliden AB | SWEDEN | Yes | |||
| Gold |
C. Hafner GmbH + Co. KG | GERMANY | Yes | |||
| Gold |
Caridad | MEXICO | Unknown | |||
| Gold |
CCR Refinery - Glencore Canada Corporation | CANADA | Yes | |||
| Gold |
Cendres + Métaux SA | SWITZERLAND | Unknown | |||
| Gold |
Chimet S.p.A. | ITALY | Yes | |||
| Gold |
Chugai Mining | JAPAN | Unknown | |||
| Gold |
Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Unknown | |||
| Gold |
Daye Non-Ferrous Metals Mining Ltd. | CHINA | Unknown | |||
| Gold |
Do Sung Corporation | KOREA, REPUBLIC OF | Unknown | |||
| Gold |
DODUCO GmbH | GERMANY | Yes | |||
| Gold |
Dowa | JAPAN | Yes | |||
| Gold |
Eco-System Recycling Co., Ltd. | JAPAN | Yes |
| Gold | Elemetal Refining, LLC | UNITED STATES | Yes | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Yes | |||
| Gold | Faggi Enrico S.p.A. | ITALY | Unknown | |||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Unknown | |||
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Unknown | |||
| Gold | Geib Refining Corporation | UNITED STATES | Unknown | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Unknown | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | Unknown | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Unknown | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Unknown | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Yes | |||
| Gold | Heraeus Ltd. Hong Kong | CHINA | Yes | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Yes | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Unknown | |||
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Unknown | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Yes | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Yes | |||
| Gold | Istanbul Gold Refinery | TURKEY | Yes | |||
| Gold | Japan Mint | JAPAN | Yes | |||
| Gold | Jiangxi Copper Company Limited | CHINA | Yes | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Yes | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Yes | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Yes | |||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Unknown | |||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Unknown | |||
| Gold | Kazzinc | KAZAKHSTAN | Yes | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Yes | |||
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | Unknown | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes | |||
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | Unknown | |||
| Gold | Korea Zinc 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 | Yes | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Unknown | |||
| Gold | Materion | UNITED STATES | Yes | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes | |||
| Gold | Metahub Industries Sdn. Bhd. | MALAYSIA | Unknown | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Yes | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Unknown | |||
| Gold | Metalor Technologies SA | SWITZERLAND | Yes | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES | Yes | |||
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Yes | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Yes | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Yes | |||
| Gold | Morris and Watson | NEW ZEALAND | Unknown | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Yes | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Yes | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Unknown | |||
| Gold | Nihon Material Co., Ltd. | JAPAN | Yes | |||
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Yes | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Yes | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Yes | |||
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | Unknown | |||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Yes | |||
| Gold | PAMP SA | SWITZERLAND | Yes | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Unknown | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Yes | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes | |||
| Gold | PX Précinox SA | SWITZERLAND | Yes | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Yes | |||
| Gold | Republic Metals Corporation | UNITED STATES | Yes | |||
| Gold | Royal Canadian Mint | CANADA | Yes | |||
| Gold | SAAMP | FRANCE | Unknown | |||
| Gold | Sabin Metal Corp. | UNITED STATES | Unknown | |||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Unknown |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Unknown | |||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Unknown | |||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Yes | |||
| Gold | SEMPSA Joyería Platería SA | SPAIN | Yes | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Unknown | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Yes | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Yes | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN | Yes | |||
| Gold | So Accurate Group, Inc. | UNITED STATES | Unknown | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Yes | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes | |||
| Gold | Sudan Gold Refinery | SUDAN | Unknown | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Yes | |||
| Gold | T.C.A S.p.A | ITALY | Yes | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Yes | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Yes | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Yes | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Unknown | |||
| Gold | Tony Goetz NV | BELGIUM | Unknown | |||
| Gold | Torecom | KOREA, REPUBLIC OF | Unknown | |||
| Gold | Umicore Brasil Ltda. | BRAZIL | Yes | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Yes | |||
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Yes | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes | |||
| Gold | Valcambi SA | SWITZERLAND | Yes | |||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Unknown | |||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Unknown | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes | |||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Yes | |||
| Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM | Unknown | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Yes | |||
| Tantalum | D Block Metals, LLC | UNITED STATES | Yes | |||
| Tantalum | Duoluoshan | CHINA | Yes | |||
| Tantalum | E.S.R. Electronics | UNITED STATES | Unknown | |||
| Tantalum | Exotech Inc. | UNITED STATES | Yes | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Yes | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Yes | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Yes | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Yes | |||
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | Unknown | |||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Yes | |||
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Yes | |||
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Yes | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Yes | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES | Yes | |||
| Tantalum | H.C. Starck Ltd. | JAPAN | Yes | |||
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Yes | |||
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Yes | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Yes | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | KEMET Blue Metals | MEXICO | Yes |
| Tantalum | KEMET Blue Powder | UNITED STATES | Yes | |||
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Yes | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Yes | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes | |||
| Tantalum | Mineração Taboca S.A. | BRAZIL | Yes | |||
| Tantalum | Mitsui Mining & Smelting | JAPAN | Yes | |||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Yes | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes | |||
| Tantalum | Plansee SE Liezen | AUSTRIA | Yes | |||
| Tantalum | Plansee SE Reutte | AUSTRIA | Yes | |||
| Tantalum | QuantumClean | UNITED STATES | Yes | |||
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Yes | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Yes | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Yes | |||
| Tantalum | Taki Chemicals | JAPAN | Yes | |||
| Tantalum | Telex Metals | UNITED STATES | Yes | |||
| Tantalum | Tranzact, Inc. | UNITED STATES | Yes | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Yes | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Yes | |||
| Tantalum | Zhuzhou Cemented Carbide | CHINA | Yes | |||
| Tin | Alpha | UNITED STATES | Yes | |||
| Tin | An Thai Minerals Company Limited | VIET NAM | Unknown | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Unknown | |||
| Tin | Chenzhou Yun Xiang mining limited liability company | CHINA | Unknown | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Yes | |||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Unknown | |||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Yes | |||
| Tin | CV Ayi Jaya | INDONESIA | Yes | |||
| Tin | CV Dua Sekawan | INDONESIA | Unknown | |||
| Tin | CV Gita Pesona | INDONESIA | Yes | |||
| Tin | CV Serumpun Sebalai | INDONESIA | Yes | |||
| Tin | CV Tiga Sekawan | INDONESIA | Unknown | |||
| Tin | CV United Smelting | INDONESIA | Yes | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Yes | |||
| Tin | Dowa | JAPAN | Yes | |||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Unknown | |||
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Yes | |||
| Tin | EM Vinto | BOLIVIA | Yes | |||
| Tin | Estanho de Rondônia S.A. | BRAZIL | Unknown | |||
| Tin | Feinhütte Halsbrücke GmbH | GERMANY | Unknown | |||
| Tin | Fenix Metals | POLAND | Yes | |||
| Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | Unknown | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Unknown | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Yes | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Unknown | |||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Unknown | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Unknown | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Unknown | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Unknown | |||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Yes | |||
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | Unknown | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Yes | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes | |||
| Tin | Melt Metais e Ligas S/A | BRAZIL | Yes | |||
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA | Unknown | |||
| Tin | Metallic Resources, Inc. | UNITED STATES | Yes | |||
| Tin | Metallo-Chimique N.V. | BELGIUM | Yes | |||
| Tin | Mineração Taboca S.A. | BRAZIL | Yes | |||
| Tin | Minsur | PERU | Yes |
| Tin | Mitsubishi Materials Corporation | JAPAN | Yes | |||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Unknown | |||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Unknown | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Yes | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Yes | |||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Yes | |||
| Tin | Phoenix Metal Ltd. | RWANDA | Unknown | |||
| Tin | PT Alam Lestari Kencana | INDONESIA | Unknown | |||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Yes | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Yes | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Yes | |||
| Tin | PT Bangka Kudai Tin | INDONESIA | Unknown | |||
| Tin | PT Bangka Prima Tin | INDONESIA | Yes | |||
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | Unknown | |||
| Tin | PT Bangka Tin Industry | INDONESIA | Yes | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Yes | |||
| Tin | PT BilliTin Makmur Lestari | INDONESIA | Yes | |||
| Tin | PT Bukit Timah | INDONESIA | Yes | |||
| Tin | PT Cipta Persada Mulia | INDONESIA | Yes | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Yes | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Yes | |||
| Tin | PT Fang Di MulTindo | INDONESIA | Unknown | |||
| Tin | PT Inti Stania Prima | INDONESIA | Yes | |||
| Tin | PT Justindo | INDONESIA | Yes | |||
| Tin | PT Karimun Mining | INDONESIA | Unknown | |||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Unknown | |||
| Tin | PT Mitra Stania Prima | INDONESIA | Yes | |||
| Tin | PT Panca Mega Persada | INDONESIA | Yes | |||
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | Unknown | |||
| Tin | PT Prima Timah Utama | INDONESIA | Yes | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Yes | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Yes | |||
| Tin | PT Seirama Tin Investment | INDONESIA | Unknown | |||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Yes | |||
| Tin | PT Sukses Inti Makmur | INDONESIA | Yes | |||
| Tin | PT Sumber Jaya Indah | INDONESIA | Yes | |||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Yes | |||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Yes | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Yes | |||
| Tin | PT Tirus Putra Mandiri | INDONESIA | Unknown | |||
| Tin | PT Tommy Utama | INDONESIA | Yes | |||
| Tin | PT Wahana Perkit Jaya | INDONESIA | Yes | |||
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Yes | |||
| Tin | Rui Da Hung | TAIWAN | Yes | |||
| Tin | Soft Metais Ltda. | BRAZIL | Yes | |||
| Tin | Thaisarco | THAILAND | Yes | |||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Unknown | |||
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Yes | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Unknown | |||
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Yes | |||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes | |||
| Tungsten | ACL Metais Eireli | BRAZIL | Unknown | |||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Yes | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Yes | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | H.C. Starck GmbH | GERMANY | Yes | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Yes | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Unknown | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA | Unknown | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Yes | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Yes | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Kennametal Fallon | UNITED STATES | Unknown | |||
| Tungsten | Kennametal Huntsville | UNITED STATES | Yes | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Unknown | |||
| Tungsten | Niagara Refining LLC | UNITED STATES | Yes | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Yes | |||
| Tungsten | Philippine Chuangin Industrial Co., Inc. | PHILIPPINES | Yes | |||
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | Unknown | |||
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM | Unknown | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Yes | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Yes | |||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes | |||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Unknown | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |