DocumentUNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
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L.B. Foster Company |
(Exact name of registrant as specified in its charter) |
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Pennsylvania | 000-10436 | 25-1324733 |
(State or other jurisdiction of incorporation) | (Commission File Number) | (I.R.S. Employer Identification No.) |
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415 Holiday Drive, Suite 100, Pittsburgh, Pennsylvania | | | | 15220 |
(Address of principal executive offices) | | | | (Zip Code) |
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Sean M. Reilly, (412) 928-3400 |
(Name and telephone number, including area code, of the person to contact in connection with this report) |
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Check the appropriate box below to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies: |
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☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021 |
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, 2021 to December 31, 2021 is provided as Exhibit 1.01 hereto and is publicly available on our corporate website, https://www.lbfoster.com as well as the Securities and Exchange Commission’s EDGAR database at https://www.sec.gov.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
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Exhibit Number | Description |
1.01 | |
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.
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| | | L.B. FOSTER COMPANY |
| | | (Registrant) |
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Date: | May 27, 2022 | | /s/ Sean M. Reilly |
| | | Sean M. Reilly |
| | | Corporate Controller and Principal Accounting Officer |
DocumentL.B. FOSTER COMPANY
Conflict Minerals Report
For the reporting period from January 1, 2021 to December 31, 2021
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 from January 1, 2021 to December 31, 2021.
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 term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (collectively “3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (the “DRC”) or any adjoining country that shares an internationally recognized border with the DRC (collectively the “Covered Countries”).
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 https://www.lbfoster.com/en/about/corporate-responsibility/conflict-mineral.
1.1 Company Overview
L.B. Foster Company provides products and services for the rail industry and solutions to support critical infrastructure projects. The Company’s innovative engineering and product development solutions inspire the safety, reliability, and performance of its customers’ challenging requirements. The Company maintains locations in North America, South America, Europe, and Asia. The Company is organized and operates in three business segments: Rail, Technologies, and Services (“Rail”), Precast Concrete Products (“Precast”), and Steel Products and Measurement. The Rail segment is comprised of several manufacturing, distribution, and service businesses that provide a variety of products, solutions, and services for freight and passenger railroads and other industrial companies throughout the world. The Precast segment manufactures precast concrete products for the North American civil infrastructure market. The Steel Products and Measurement segment provides custom engineered solutions and services that help build and maintain critical civil and energy infrastructure throughout North and South America, Central America, and the Caribbean.
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 2021.
The Company does not directly purchase 3TGs, but it purchases components that it uses in the products it manufactures. The Company identified certain products it sells as possibly containing 3TGs that are necessary to the functionality or production of the products. These products include, but are not limited to, power rail, coverboards, mass transit and rail system accessories, certain friction management products, railway wayside data collection and management systems, expansion joints, precast concrete buildings, and precision measurement systems.
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 6.1 or higher of the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”), the Company engaged its 678 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 and were also subject to one on one communications by the Vendor, including offering assistance and further information to suppliers about the requirements of the Rule and the Program.
The Program continues to include 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 April 29, 2022, five 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 335 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.
Based on 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 below due diligence measures to assess the practices of the SORs listed on its Unique Smelter List that were known or reasonably believed to have been sourced from the Covered Countries or that had unknown sourcing.
3. Due Diligence
3.1 Design of Due Diligence
The Company 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”). The OECD Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We have developed our due diligence process to address each of these five steps.
3.1.1 Establish Strong Company Management Systems
Conflict Minerals Policy
As described above, we maintain a Conflict Minerals Policy, which is posted on our website at https://www.lbfoster.com/en/about/corporate-responsibility/conflict-mineral.
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 Principal Accounting Officer and a team of subject matter experts from relevant functions such as quality, supply chain, operations, finance, and legal.
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 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 OECD 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. We continue to utilize our Vendor’s Learning Management System to provide all in-scope suppliers access to their Conflict Minerals Training Course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
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 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 678 direct suppliers related to our in-scope products. 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 Securities and Exchange Commission (“SEC”) registrants and subject to the Rule or are suppliers to other SEC registrants who are subject to the Rule.
Risks are identified automatically in the reporting system based on criteria established for supplier responses. The primary risk we identified with respect to the reporting period for the year ended December 31, 2021 related to the nature of the responses received. Many of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG in the components supplied to the Company. Additionally, many suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
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 Responsible Minerals Assurance Process (“RMAP”) 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 RMI, this is known as a Country Identification Number, or “CID”), whether there is known or plausible evidence of unethical or conflict sourcing, and the smelter’s geographic location, including proximity to the Covered Countries.
When high-risk smelters were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our Vendor, submissions that include any of the high-risk smelters immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product CMRT to better identify the connection to products that they supply to the Company, and escalating up to removal of these high-risk smelters from their supply chain.
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;
•Whether the supplier reviews due diligence information received from their suppliers against your company’s expectations;
•Whether the verification process includes corrective action management.
Based on how each supplier’s program meets these criteria, its 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 to establish an alternative source of 3TGs that do not support conflict in the Covered Countries, as provided in the OECD guidance, when we have reason to believe those suppliers may be supplying us with 3TGs from sources that may support conflict in the Covered Countries. 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 the methodology outlined by the RMI’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 a reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all 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 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 Responsible Business Alliance (“RBA”) reporting CMRT to complete for purposes of conflict minerals tracking. Furthermore, we reviewed responses to the reporting CMRT with suppliers where we needed clarification. As described in our Conflict Minerals Policy, we intend to engage any of our suppliers that 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. We do not seek to embargo responsible sourcing of 3TGs from the DRC region or condone a general embargo on sourcing from the region.
3.1.4 Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chains
The Company does not have a direct relationship with conflict minerals smelters or refiners and thus, the Company does not perform direct audits of these entities in its supply chain. The Company 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 https://www.lbfoster.com.
4. Due Diligence Results
For the 2021 reporting year, the Company received complete and valid CMRTs from approximately 50% of its 678 suppliers surveyed. Most supplier responses received provided information at a company-wide level. We reviewed the responses against criteria we developed to determine which responses might 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.
4.1 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.
4.2 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.
4.3 Smelters or Refiners
For all responses that indicated a smelter, our Vendor compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as “conflict-free,” our Vendor confirmed that the name was listed by RMI as a certified smelter. As of April 29, 2022, we have determined that 335 smelters or refiners are listed as certified smelters/refiners by RMI 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 publicly available information, we have identified 230 smelters that are certified “conflict-free.” In addition, 19 smelters are active in the Responsible Minerals Assurance Process and are or have committed to undergoing an audit.
From the responses that we received, we identified 86 smelters that potentially posed a risk. These concerns stem from the location of the facilities and claims that fall outside of the scope of the conflict minerals law. For suppliers that identified these smelters of concern on their CMRT, we created an escalation plan. These suppliers were contacted by our Vendor and the Company to evaluate whether these smelters could be connected to the Company’s products. The suppliers were asked to complete a product-level CMRT, rather than a company-level CMRT, to better identify the connection to products that they supply to the Company. Other suppliers were evaluated internally to determine if they were in fact still active suppliers. If not, they were taken out of scope.
5. Steps Taken to Mitigate Risk
In 2022, 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;
•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 suppliers that do not use 3TGs from suppliers that use 3TGs from the Covered Countries; and
•Raise the awareness of suppliers to their use of “conflict-free” minerals.
Cautionary Statement on Forward-Looking Statements
This Report contains “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, and such forward-looking statements involve risks and uncertainties. These forward-looking statements are subject to various risks, uncertainties and other factors, including, among other matters, the Company’s suppliers’ responsiveness and cooperation with the Company’s due diligence efforts, the Company’s ability to identify and mitigate risks in its supply chain, whether smelters and refiners and other market participants responsibly source conflict minerals, and political and regulatory developments, whether in the Covered Countries, the United States, or elsewhere. The Company’s forward-looking statements in this Report are based on management’s current views, beliefs, and assumptions regarding future events. The Company undertakes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise, except as required by the federal securities laws.
Schedule A
The following lists the smelters/refiners identified by our suppliers as sources for their products that are certified by the “Responsible Minerals Assurance Process.”
The information that we received from much 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 include smelters or refiners that processed minerals that our direct suppliers supplied to their other customers, but not to us. We are unable to conclusively determine whether the smelters or refiners included in the tables below were used to process the 3TGs necessary to the functionality or production of our products during 2021. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed below were the country of origin of minerals in our products during 2021, and therefore we are unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the information that we received from our direct suppliers may yield inaccurate or incomplete information. For example, the information we 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 RMI Responsible Minerals Assurance Process – RMAP and, thus, are not responsible for the quality of these audits or the audit findings.
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Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Gold | Advanced Chemical Company | United States Of America | CID000015 |
Gold | Aida Chemical Industries Co., Ltd. | Japan | CID000019 |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | CID000035 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | CID000041 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | CID000058 |
Gold | Argor-Heraeus S.A. | Switzerland | CID000077 |
Gold | Asahi Pretec Corp. | Japan | CID000082 |
Gold | Asaka Riken Co., Ltd. | Japan | CID000090 |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | CID000103 |
Gold | Aurubis AG | Germany | CID000113 |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | CID000128 |
Gold | Boliden AB | Sweden | CID000157 |
Gold | C. Hafner GmbH + Co. KG | Germany | CID000176 |
Gold | Caridad | Mexico | CID000180 |
Gold | CCR Refinery - Glencore Canada Corporation | Canada | CID000185 |
Gold | Cendres + Metaux S.A. | Switzerland | CID000189 |
Gold | Yunnan Copper Industry Co., Ltd. | China | CID000197 |
Gold | Chimet S.p.A. | Italy | CID000233 |
Gold | Chugai Mining | Japan | CID000264 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | China | CID000343 |
Gold | DSC (Do Sung Corporation) | Korea, Republic Of | CID000359 |
Gold | Dowa | Japan | CID000401 |
Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | CID000425 |
Gold | OJSC Novosibirsk Refinery | Russian Federation | CID000493 |
Gold | Refinery of Seemine Gold Co., Ltd. | China | CID000522 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | CID000651 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | CID000671 |
Gold | LT Metal Ltd. | Korea, Republic Of | CID000689 |
Gold | Heimerle + Meule GmbH | Germany | CID000694 |
Gold | Heraeus Metals Hong Kong Ltd. | China | CID000707 |
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | CID000711 |
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Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Gold | Hunan Chenzhou Mining Co., Ltd. | China | CID000767 |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | CID000773 |
Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | CID000778 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | CID000801 |
Gold | Ishifuku Metal Industry Co., Ltd. | Japan | CID000807 |
Gold | Istanbul Gold Refinery | Turkey | CID000814 |
Gold | Japan Mint | Japan | CID000823 |
Gold | Jiangxi Copper Co., Ltd. | China | CID000855 |
Gold | Asahi Refining USA Inc. | United States Of America | CID000920 |
Gold | Asahi Refining Canada Ltd. | Canada | CID000924 |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | CID000927 |
Gold | JSC Uralelectromed | Russian Federation | CID000929 |
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | CID000937 |
Gold | Kazakhmys Smelting LLC | Kazakhstan | CID000956 |
Gold | Kazzinc | Kazakhstan | CID000957 |
Gold | Kennecott Utah Copper LLC | United States Of America | CID000969 |
Gold | Kojima Chemicals Co., Ltd. | Japan | CID000981 |
Gold | Kyrgyzaltyn JSC | Kyrgyzstan | CID001029 |
Gold | L'azurde Company For Jewelry | Saudi Arabia | CID001032 |
Gold | Lingbao Gold Co., Ltd. | China | CID001056 |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | CID001058 |
Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | CID001078 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | CID001093 |
Gold | Materion | United States Of America | CID001113 |
Gold | Matsuda Sangyo Co., Ltd. | Japan | CID001119 |
Gold | Metalor Technologies (Suzhou) Ltd. | China | CID001147 |
Gold | Metalor Technologies (Hong Kong) Ltd. | China | CID001149 |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | CID001152 |
Gold | Metalor Technologies S.A. | Switzerland | CID001153 |
Gold | Metalor USA Refining Corporation | United States Of America | CID001157 |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | CID001161 |
Gold | Mitsubishi Materials Corporation | Japan | CID001188 |
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001193 |
Gold | Moscow Special Alloys Processing Plant | Russian Federation | CID001204 |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | CID001220 |
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | CID001236 |
Gold | Nihon Material Co., Ltd. | Japan | CID001259 |
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | CID001325 |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | CID001326 |
Gold | PAMP S.A. | Switzerland | CID001352 |
Gold | Penglai Penggang Gold Industry Co., Ltd. | China | CID001362 |
Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | CID001386 |
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Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | CID001397 |
Gold | PX Precinox S.A. | Switzerland | CID001498 |
Gold | Rand Refinery (Pty) Ltd. | South Africa | CID001512 |
Gold | Royal Canadian Mint | Canada | CID001534 |
Gold | Sabin Metal Corp. | United States Of America | CID001546 |
Gold | Samduck Precious Metals | Korea, Republic Of | CID001555 |
Gold | Samwon Metals Corp. | Korea, Republic Of | CID001562 |
Gold | SEMPSA Joyeria Plateria S.A. | Spain | CID001585 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | CID001619 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | CID001622 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | CID001736 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | CID001756 |
Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | CID001761 |
Gold | Sumitomo Metal Mining Co., Ltd. | Japan | CID001798 |
Gold | Super Dragon Technology Co., Ltd. | China | CID001810 |
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | CID001875 |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | CID001909 |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | CID001916 |
Gold | Tokuriki Honten Co., Ltd. | Japan | CID001938 |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | CID001947 |
Gold | Torecom | Korea, Republic Of | CID001955 |
Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | CID001980 |
Gold | United Precious Metal Refining, Inc. | United States Of America | CID001993 |
Gold | Valcambi S.A. | Switzerland | CID002003 |
Gold | Western Australian Mint (T/a The Perth Mint) | Australia | CID002030 |
Gold | Yamakin Co., Ltd. | Japan | CID002100 |
Gold | Yokohama Metal Co., Ltd. | Japan | CID002129 |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | CID002224 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | CID002243 |
Gold | Morris and Watson | New Zealand | CID002282 |
Gold | SAFINA A.S. | Czechia | CID002290 |
Gold | Guangdong Jinding Gold Limited | China | CID002312 |
Gold | Umicore Precious Metals Thailand | Thailand | CID002314 |
Gold | Geib Refining Corporation | United States Of America | CID002459 |
Gold | MMTC-PAMP India Pvt., Ltd. | India | CID002509 |
Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | CID002511 |
Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | CID002515 |
Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | CID002516 |
Gold | Shandong Humon Smelting Co., Ltd. | China | CID002525 |
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | CID002527 |
Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | CID002560 |
Gold | Emirates Gold DMCC | United Arab Emirates | CID002561 |
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Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Gold | International Precious Metal Refiners | United Arab Emirates | CID002562 |
Gold | Kaloti Precious Metals | United Arab Emirates | CID002563 |
Gold | Sudan Gold Refinery | Sudan | CID002567 |
Gold | T.C.A S.p.A | Italy | CID002580 |
Gold | REMONDIS PMR B.V. | Netherlands | CID002582 |
Gold | Fujairah Gold FZC | United Arab Emirates | CID002584 |
Gold | Industrial Refining Company | Belgium | CID002587 |
Gold | Shirpur Gold Refinery Ltd. | India | CID002588 |
Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | CID002605 |
Gold | Marsam Metals | Brazil | CID002606 |
Gold | TOO Tau-Ken-Altyn | Kazakhstan | CID002615 |
Gold | Abington Reldan Metals, LLC | United States Of America | CID002708 |
Gold | SAAMP | France | CID002761 |
Gold | L'Orfebre S.A. | Andorra | CID002762 |
Gold | 8853 S.p.A. | Italy | CID002763 |
Gold | Italpreziosi | Italy | CID002765 |
Gold | WIELAND Edelmetalle GmbH | Germany | CID002778 |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | CID002779 |
Gold | AU Traders and Refiners | South Africa | CID002850 |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | CID002852 |
Gold | Sai Refinery | India | CID002853 |
Gold | Modeltech Sdn Bhd | Malaysia | CID002857 |
Gold | Bangalore Refinery | India | CID002863 |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | CID002865 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | CID002867 |
Gold | Pease & Curren | United States Of America | CID002872 |
Gold | JALAN & Company | India | CID002893 |
Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | CID002918 |
Gold | Planta Recuperadora de Metales SpA | Chile | CID002919 |
Gold | Safimet S.p.A | Italy | CID002973 |
Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | CID003153 |
Gold | African Gold Refinery | Uganda | CID003185 |
Gold | Gold Coast Refinery | Ghana | CID003186 |
Gold | NH Recytech Company | Korea, Republic Of | CID003189 |
Gold | QG Refining, LLC | United States Of America | CID003324 |
Gold | Dijllah Gold Refinery FZC | United Arab Emirates | CID003348 |
Gold | CGR Metalloys Pvt Ltd. | India | CID003382 |
Gold | Sovereign Metals | India | CID003383 |
Gold | C.I Metales Procesados Industriales SAS | Colombia | CID003421 |
Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | CID003424 |
Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | CID003425 |
Gold | Augmont Enterprises Private Limited | India | CID003461 |
| | | | | | | | | | | |
Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Gold | Kundan Care Products Ltd. | India | CID003463 |
Gold | Emerald Jewel Industry India Limited (Unit 1) | India | CID003487 |
Gold | Emerald Jewel Industry India Limited (Unit 2) | India | CID003488 |
Gold | Emerald Jewel Industry India Limited (Unit 3) | India | CID003489 |
Gold | Emerald Jewel Industry India Limited (Unit 4) | India | CID003490 |
Gold | K.A. Rasmussen | Norway | CID003497 |
Gold | Alexy Metals | United States Of America | CID003500 |
Gold | Sancus ZFS (L’Orfebre, SA) | Colombia | CID003529 |
Gold | Sellem Industries Ltd. | Mauritania | CID003540 |
Gold | MD Overseas | India | CID003548 |
Gold | Metallix Refining Inc. | United States Of America | CID003557 |
Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | CID003575 |
Gold | WEEEREFINING | France | CID003615 |
Gold | Value Trading | Belgium | CID003617 |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | CID000211 |
Tantalum | F&X Electro-Materials Ltd. | China | CID000460 |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | CID000616 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | CID000914 |
Tantalum | Jiujiang Tanbre Co., Ltd. | China | CID000917 |
Tantalum | LSM Brasil S.A. | Brazil | CID001076 |
Tantalum | Metallurgical Products India Pvt., Ltd. | India | CID001163 |
Tantalum | Mineracao Taboca S.A. | Brazil | CID001175 |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001192 |
Tantalum | NPM Silmet AS | Estonia | CID001200 |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | CID001277 |
Tantalum | QuantumClean | United States Of America | CID001508 |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | CID001522 |
Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | CID001769 |
Tantalum | Taki Chemical Co., Ltd. | Japan | CID001869 |
Tantalum | Telex Metals | United States Of America | CID001891 |
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | CID001969 |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | CID002492 |
Tantalum | D Block Metals, LLC | United States Of America | CID002504 |
Tantalum | FIR Metals & Resource Ltd. | China | CID002505 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | CID002506 |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | CID002508 |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | CID002512 |
Tantalum | KEMET Blue Metals | Mexico | CID002539 |
Tantalum | H.C. Starck Co., Ltd. | Thailand | CID002544 |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | CID002545 |
Tantalum | H.C. Starck Hermsdorf GmbH | Germany | CID002547 |
| | | | | | | | | | | |
Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Tantalum | H.C. Starck Inc. | United States Of America | CID002548 |
Tantalum | H.C. Starck Ltd. | Japan | CID002549 |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | CID002550 |
Tantalum | Global Advanced Metals Boyertown | United States Of America | CID002557 |
Tantalum | Global Advanced Metals Aizu | Japan | CID002558 |
Tantalum | Resind Industria e Comercio Ltda. | Brazil | CID002707 |
Tantalum | Jiangxi Tuohong New Raw Material | China | CID002842 |
Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | China | CID003583 |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | CID000228 |
Tin | Alpha | United States Of America | CID000292 |
Tin | Dowa | Japan | CID000402 |
Tin | EM Vinto | Bolivia (Plurinational State Of) | CID000438 |
Tin | Estanho de Rondonia S.A. | Brazil | CID000448 |
Tin | Fenix Metals | Poland | CID000468 |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | CID000538 |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | CID000555 |
Tin | Gejiu Kai Meng Industry and Trade LLC | China | CID000942 |
Tin | China Tin Group Co., Ltd. | China | CID001070 |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia | CID001105 |
Tin | Metallic Resources, Inc. | United States Of America | CID001142 |
Tin | Mineracao Taboca S.A. | Brazil | CID001173 |
Tin | Minsur | Peru | CID001182 |
Tin | Mitsubishi Materials Corporation | Japan | CID001191 |
Tin | Jiangxi New Nanshan Technology Ltd. | China | CID001231 |
Tin | Novosibirsk Processing Plant Ltd. | Russian Federation | CID001305 |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | CID001314 |
Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | CID001337 |
Tin | PT Artha Cipta Langgeng | Indonesia | CID001399 |
Tin | PT Babel Inti Perkasa | Indonesia | CID001402 |
Tin | PT Babel Surya Alam Lestari | Indonesia | CID001406 |
Tin | PT Bukit Timah | Indonesia | CID001428 |
Tin | PT Mitra Stania Prima | Indonesia | CID001453 |
Tin | PT Prima Timah Utama | Indonesia | CID001458 |
Tin | PT Refined Bangka Tin | Indonesia | CID001460 |
Tin | PT Sariwiguna Binasentosa | Indonesia | CID001463 |
Tin | PT Stanindo Inti Perkasa | Indonesia | CID001468 |
Tin | PT Timah Tbk Kundur | Indonesia | CID001477 |
Tin | PT Timah Tbk Mentok | Indonesia | CID001482 |
Tin | PT Timah Nusantara | Indonesia | CID001486 |
Tin | PT Tinindo Inter Nusa | Indonesia | CID001490 |
| | | | | | | | | | | |
Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Tin | Rui Da Hung | Taiwan, Province Of China | CID001539 |
Tin | Soft Metais Ltda. | Brazil | CID001758 |
Tin | Thaisarco | Thailand | CID001898 |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | CID001908 |
Tin | VQB Mineral and Trading Group JSC | Viet Nam | CID002015 |
Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | CID002036 |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | CID002158 |
Tin | Yunnan Tin Company Limited | China | CID002180 |
Tin | CV Venus Inti Perkasa | Indonesia | CID002455 |
Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | CID002468 |
Tin | Melt Metais e Ligas S.A. | Brazil | CID002500 |
Tin | PT ATD Makmur Mandiri Jaya | Indonesia | CID002503 |
Tin | O.M. Manufacturing Philippines, Inc. | Philippines | CID002517 |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | CID002572 |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002573 |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002574 |
Tin | PT Cipta Persada Mulia | Indonesia | CID002696 |
Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | CID002703 |
Tin | Resind Industria e Comercio Ltda. | Brazil | CID002706 |
Tin | Super Ligas | Brazil | CID002756 |
Tin | Metallo Belgium N.V. | Belgium | CID002773 |
Tin | Metallo Spain S.L.U. | Spain | CID002774 |
Tin | PT Sukses Inti Makmur | Indonesia | CID002816 |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam | CID002834 |
Tin | PT Menara Cipta Mulia | Indonesia | CID002835 |
Tin | Modeltech Sdn Bhd | Malaysia | CID002858 |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | CID003116 |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | CID003190 |
Tin | PT Bangka Serumpun | Indonesia | CID003205 |
Tin | Pongpipat Company Limited | Myanmar | CID003208 |
Tin | Tin Technology & Refining | United States Of America | CID003325 |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | CID003356 |
Tin | Ma'anshan Weitai Tin Co., Ltd. | China | CID003379 |
Tin | PT Masbro Alam Stania | Indonesia | CID003380 |
Tin | PT Rajawali Rimba Perkasa | Indonesia | CID003381 |
Tin | Luna Smelter, Ltd. | Rwanda | CID003387 |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | CID003397 |
Tin | Precious Minerals and Smelting Limited | India | CID003409 |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | CID003410 |
Tin | PT Mitra Sukses Globalindo | Indonesia | CID003449 |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | CID003486 |
Tin | CRM Synergies | Spain | CID003524 |
| | | | | | | | | | | |
Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Tin | PT Aries Kencana Sejahtera | Indonesia | CID000309 |
Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | CID003582 |
Tin | PT Belitung Industri Sejahtera | Indonesia | CID001421 |
Tin | PT Panca Mega Persada | Indonesia | CID001457 |
Tin | PT Tommy Utama | Indonesia | CID001493 |
Tin | PT Tirus Putra Mandiri | Indonesia | CID002478 |
Tungsten | A.L.M.T. Corp. | Japan | CID000004 |
Tungsten | Kennametal Huntsville | United States Of America | CID000105 |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | CID000218 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | CID000258 |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | CID000281 |
Tungsten | Global Tungsten & Powders Corp. | United States Of America | CID000568 |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | CID000766 |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | CID000769 |
Tungsten | Japan New Metals Co., Ltd. | Japan | CID000825 |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | CID000875 |
Tungsten | Kennametal Fallon | United States Of America | CID000966 |
Tungsten | Wolfram Bergbau und Hutten AG | Austria | CID002044 |
Tungsten | Xiamen Tungsten Co., Ltd. | China | CID002082 |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | CID002313 |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | CID002315 |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | CID002316 |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | CID002317 |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | CID002318 |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | CID002319 |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | CID002320 |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | CID002321 |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | CID002494 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | CID002502 |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | CID002513 |
Tungsten | H.C. Starck Tungsten GmbH | Germany | CID002541 |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | CID002542 |
Tungsten | Masan Tungsten Chemical LLC (MTC) | Viet Nam | CID002543 |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | CID002551 |
Tungsten | Niagara Refining LLC | United States Of America | CID002589 |
Tungsten | China Molybdenum Co., Ltd. | China | CID002641 |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | CID002645 |
Tungsten | Hydrometallurg, JSC | Russian Federation | CID002649 |
Tungsten | Unecha Refractory metals plant | Russian Federation | CID002724 |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | CID002827 |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | CID002830 |
Tungsten | ACL Metais Eireli | Brazil | CID002833 |
| | | | | | | | | | | |
Metal | Standard Smelter Name | Smelter Facility Location | RMI Audit Status |
Tungsten | Moliren Ltd. | Russian Federation | CID002845 |
Tungsten | KGETS Co., Ltd. | Korea, Republic Of | CID003388 |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China | CID003401 |
Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | CID003407 |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | CID003408 |
Tungsten | NPP Tyazhmetprom LLC | Russian Federation | CID003416 |
Tungsten | GEM Co., Ltd. | China | CID003417 |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | CID003427 |
Tungsten | Cronimet Brasil Ltda | Brazil | CID003468 |
Tungsten | Artek LLC | Russian Federation | CID003553 |
Tungsten | Fujian Xinlu Tungsten | China | CID003609 |
Tungsten | OOO “Technolom” 2 | Russian Federation | CID003612 |
Tungsten | OOO “Technolom” 1 | Russian Federation | CID003614 |