UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM SD
Specialized disclosure report
FREQUENCY ELECTRONICS, INC.
(Exact name of Registrant as specified in its charter)
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Delaware
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1-8061
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(State or other jurisdiction of
incorporation)
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(Commission File Number)
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55 CHARLES LINDBERGH BLVD., MITCHEL FIELD, N.Y.
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11553
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(Address of principal executive offices)
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(Zip Code)
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Steven Bernstein
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516-794-4500
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(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 to indicate the rule pursuant to which this form is being filed:
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☒
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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, 2023.
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☐
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Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended .
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Section 1. Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
(c) Conflict Minerals Report
Frequency Electronics, Inc. (the “Company”) evaluated its current product lines and determined that certain products the Company manufactures contain tin, tungsten, tantalum and/or gold (3TG) necessary to the production or functionality of such products.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, the instructions to Form SD, and the Public Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued by the Director of the Division of Corporation Finance of the Securities and Exchange Commission on April 29, 2014, the Company is filing herewith a Conflict Minerals Report, which is attached as Exhibit 1.01 and incorporated herein by reference.
The Company’s Conflict Minerals Policy is publicly available at the Company’s website: https://freqelec.com/vendors/. This Form SD, including the Company’s Conflict Minerals Report provided as Exhibit 1.01 hereto, is publicly available at the Company’s website: www.freqelec.com under Investor Relations/Financial/SEC Filings. The content of our website as referred to in this Form SD is included for general information only and is not incorporated by reference into this Form SD.
Item 1.02 Exhibits
Exhibit 1.01 Conflict Minerals Report
Section 2. Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable
Item 3.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
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FREQUENCY ELECTRONICS, INC.
(Registrant)
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Date: May 29, 2024
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By:
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/s/ Steven Bernstein
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Steven Bernstein
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Chief Financial Officer, Secretary and Treasurer
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Exhibit 1.01
Conflict Minerals Report
Frequency Electronics Inc. - For the Year Ended December 31, 2023
This Conflict Minerals Report for the year ended December 31, 2023 has been prepared by Frequency Electronics, Inc. (“Frequency” or the “Company,” “we,” “us,” or “our”) and is filed with the Securities and Exchange Commission (“SEC”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”), on a consolidated basis, in accordance with the instructions to Form SD, as modified by the Public Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued by the Director of the Division of Corporation Finance of the SEC on April 29, 2014 (the “SEC Statement”).
In accordance with the instructions to Form SD, as modified by the SEC Statement, this Report outlines the diligence measures undertaken by the Company to assess the source and chain of custody of necessary conflict minerals in its supply chain. This Report is not subject to an independent private sector audit in accordance with the instructions to Form SD and the guidance set forth in the SEC Statement.
Company Overview
Frequency designs, develops and manufactures high precision timing, frequency control and synchronization products for space and terrestrial applications. Frequency’s products are used in satellite payloads and in other commercial, government and military systems including C4ISR (“Command, Control, Communication, Computer, Intelligence, Security and Reconnaissance”), missiles, aircraft, GPS, secure radios, energy exploration and wireline and wireless communication networks. Frequency has received over 100 awards of excellence for achievements in providing high performance electronic assemblies for over 150 space and Department of Defense programs. The Company invests significant resources in research and development and strategic acquisitions world-wide to expand its capabilities and markets
Introduction
For the 2023 calendar year, Frequency determined that tin, tungsten, tantalum, and/or gold (3TGs) were necessary to the functionality or production of products that were manufactured or contracted to be manufactured. Therefore, Frequency Electronics, Inc. conducted a reasonable country of origin inquiry to determine whether any of the 3TGs in its products originated from Conflict-Affected and High-Risk Areas (CAHRAs), such as the Democratic Republic of the Congo (DRC) or an adjoining country (collectively referred to as the “Covered Countries”).
Based on the country of origin data, Frequency believes its products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), due diligence was performed on the source and chain of custody of the 3TGs in question. The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework of the Organization for Economic Co-Operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum, and tungsten (the “OECD Guidance”).
Frequency is committed to complying with the requirements of the Rule and upholding responsible sourcing practices. As such, the Company has put into place a robust due diligence program intended to uphold human rights and responsible practices across the supply chain.
Conflict Minerals Program & Policy
The Company has actively engaged with its customers and suppliers for several years with respect to the use of conflict minerals. Frequency adopted a conflict minerals policy articulating the conflict minerals supply chain due diligence process and the Company’s commitments to reporting obligations regarding conflict minerals. The policy is available online and can be found on our website https://freqelec.com/vendors/.
Description of Products
The Company’s largest business area is satellite payloads. We provide master timing systems, power converters, and frequency generation, synthesis and distribution systems. Frequency’s products are also incorporated into a variety of C4ISR, secure communications and electronic warfare systems, on ground-based, sea-borne and air-borne platforms.
Our commercial markets also include network infrastructure and other industrial uses. The Company’s products provide precise time distribution for communication networks. Based upon Frequency’s internal assessment, most of the electronic system and subsystem products that we manufacture contain one or more of the 3TGs that are necessary to their functionality or production (“Covered Products”).
Reasonable Country of Origin Inquiry
To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Frequency retained Assent Inc. (“Assent”), a third-party service provider, to assist us in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager.
To trace materials, and demonstrate transparency procured by the supply chain, Frequency utilized the Conflict Minerals Reporting Template (CMRT) to conduct a survey of all in-scope suppliers.
During the supplier survey, the Company contacted suppliers via the Assent Compliance Manager, a software-as-a-service (SaaS) platform provided by Assent that enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management.
Through the Assent Compliance Manager and the Assent team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the Assent Compliance Manager for future reporting and transparency. Frequency directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to Assent.
The Company’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which helps identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.
All submitted declaration forms are accepted so that data is retained, but they are classified as valid or invalid based on a set criteria of validation errors. Suppliers are contacted regarding invalid forms and are encouraged to correct validated errors to resubmit a valid form. Suppliers are provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses, and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback Frequency tracks program gaps to account for future improvement opportunities.
For 2023, there were 291 suppliers in scope of the conflict minerals program and 202 provided a completed CMRT. Frequency’s total response rate for 2023 was 69.42%. These metrics are summarized in the table below in order to assess progress over time:
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Year
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Suppliers in Scope
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% Responded
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2021
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447
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61.97%
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2022
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545
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63.3%
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2023
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291
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69.42
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Through reasonable due diligence practices, Frequency was able to take advantage of a broader set of country of origin data to complement efforts in establishing transparency in the supply chain. Based on the findings, Frequency was unable to determine all the possible countries that the 3TGs used in its products originated from. As such, Frequency performed further due diligence on the source and chain of custody of the minerals in question.
Due Diligence
Design of Due Diligence
Frequency designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance, and the Company continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.
Due diligence requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot be fully controlled by the Company. However, through active risk identification, and risk assessment, as well as continued outreach and process validation, we believe risk gaps have been mitigated. This aligns with industry standards and market expectations for downstream companies’ due diligence.
Due Diligence Performed
1) Establish Strong Company Management Systems
Internal Compliance Team
Frequency established a cross-functional Conflict Minerals Compliance Team led by Dave Tobias Vice President of Manufacturing, also comprising representatives from our purchasing, contracts, and finance teams. Subject matter experts from relevant functions such as purchasing, subcontracts, and engineering support this team. The Conflict Minerals Compliance Team is responsible for implementing our conflict minerals compliance strategy and briefing senior management about the results of our due diligence efforts.
The Company also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that the Company may undertake with suppliers and/or respective stakeholders in regard to conflict minerals.
The Company leverages Assent’s Managed Services in order to work with dedicated program specialists who support Frequency’s conflict minerals program. The Company communicates regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of reporting templates such as CMRT and CMRs, as well as Section 1502 of the Dodd-Frank Act.
Control Systems
The Company expects all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Frequency are “conflict free or responsibly sourced.” This means that the products should not contain minerals (3TGs) sourced from areas that have been identified to be in the presence of widespread human rights abuses and violations of law either directly or indirectly. The Company expects direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.
Frequency’s Supplier Code of Conduct applies to all direct suppliers and outlines certain expected behaviours and practices. This code of conduct is based on industry and internationally accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. The Supplier Code of Conduct is provided to all direct suppliers. If a supplier does not meet the Company’s requirements, the relationship with this supplier will be evaluated. The Supplier Code of Conduct is reviewed annually to ensure it continues to align with industry best practices.
Supplier Engagement
Frequency has strong relationships with Tier 1 direct suppliers. Frequency has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support, and other multilingual resources. Frequency’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly complete a CMRT. Suppliers are provided guidance in their native language, if needed.
The Company engages with suppliers directly to request a valid (free of validated errors) CMRT for the products that they supply to the Company. With respect to the OECD requirement to strengthen engagement with suppliers, the Company has developed an internal procedure that includes a supplier risk identification process that leads to further steps of supplier engagement in the form of escalations, such as in-person meetings and/or corrective actions. Feedback from this engagement process has allowed the Company to oversee improvements in supplier responses and supplier compliance for this initiative.
The Company continues to place a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources. Also, Assent’s automated feedback process that notifies suppliers of risks associated with their CMRT submission serves to educate suppliers of certain conflict minerals’ risks.
The Company believes that the combination of the Supplier Code of Conduct, Conflict Minerals Policy, and direct engagement with suppliers for conflict minerals training and support constitute a strong supplier engagement program.
Grievance Mechanisms
The Company established multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Frequency’s policies, including conflict minerals. Suppliers and others outside of Frequency may contact the Conflict Minerals Team, to report grievances.
Violations or grievances at the industry level can be reported to the Responsible Minerals Initiative (RMI) directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/
Maintain Records
The Company has adopted a policy to retain relevant documentation for a period of five years. Through Assent, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented by the Company. The Company stores all of the information and findings from this process in a database that can be audited by internal or external parties.
2) Identifying & Assessing Risk in the Supply Chain
Supplier Risk Evaluation
Risks associated with Tier 1 suppliers’ due diligence processes were assessed by their declaration responses on a CMRT, which the Assent Compliance Manager identifies automatically based on established criteria. These risks are addressed by Assent staff and members of the Company’s internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier’s conformity status, which is referred to as “conflict minerals status.”
Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT, rather than a product-level CMRT is submitted, Frequency is unable to identify which smelters or refiners actually processed the 3TGs contained in the products.
Assent’s supplier risk assessment (flagging suppliers’ risk as high, medium, low) identifies problematic suppliers in a company’s supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis that takes into account multiple conflict minerals factors.
Smelter/Refiners Risk Evaluation
Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters/refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent’s Smelter validation program compared listed facilities to the list of smelters/refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TGs processing facility that was operational during the 2023 calendar year.
Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (RMAP). Frequency does not have a direct relationship with smelters/refiners, and does not perform direct audits of the entities within its pre-supply chain. Smelters/refiners that are conformant to RMAP audit standards are considered to have their sourcing validated as “conflict free or responsibly sourced.” In cases where the smelter/refiner’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, further due diligence steps are followed to notify suppliers reporting these facilities. Smelters/refiners are actively monitored to proactively identify other risks pertaining to conflict minerals.
Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
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Geographic proximity to Conflict-Affected and High-Risk Areas
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Known mineral source country of origin
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Credible evidence of unethical or conflict sourcing
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Peer assessments conducted by credible third-party sources
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Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through Assent, suppliers with submissions that included any smelters/refiners of concern were immediately provided with feedback instructing suppliers to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to Frequency. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters/refiners of concern from the supply chain.
In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.
Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.
3) Design & Implement A Strategy to Respond to Risks
Together with Assent, Frequency developed processes to assess and respond to the risks identified in the supply chain. Frequency has a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and the Company’s expectations.
Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, the Company will assess if replacing that supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Team and the Frequency’s leadership team to ensure transparency within the Company.
4) Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Frequency does not have a direct relationship with any 3TG smelters/refiners and does not perform or direct audits of these entities within the supply chain. Instead, the Company relies on third-party audits of smelters/refiners (industry-recognized audit/assessment programs). As an example, RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters/refiners that agree to participate in the program.
Assent directly engages smelters/refiners that are not currently enrolled in an industry-recognized audit/assessment program to encourage their participation. Frequency is a signatory of these communications in accordance with the requirements of downstream companies detailed in the OECD Guidance.
5) Report Annually on Supply Chain Due Diligence
Frequency has published the Form SD for the year ended December 31, 2023. This report is available on the Company’s website: www.freqelec.com under Investor Relations/Financial/SEC Filings. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein.
The Company will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public report.
Due Diligence Results
Supply Chain Outreach Results
Supply chain outreach is required to identify the upstream sources of origin of t3TG. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. Upstream Data Transparency
Appendix A includes all smelters/refiners that suppliers listed in completed CMRTs that met the recognized definition of a 3TGs processing facility and were operational during the 2023 calendar year. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters/refiners may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing the smelters/refiners have the practice to list all smelters/refiners they may purchase from within the reporting period. Therefore, the smelters/refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters/refiners that actually processed the 3TGs contained in the Company’s products.
Although the potential for over-reporting is understood, Frequency has taken measures to validate all smelter/refiner data against validated audit programs and databases intended to verify the material types and mine sources of origin. From the gathered responses, 350 smelters that potentially posed a risk due to the presence of some red flag indicators were identified.
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Suppliers that identified these specific smelters of concern on their CMRT were contacted in accordance with the OECD Guidance, as stipulated in the previous sections. The section below provides an overview of the identified smelters classified according to their RMAP audit status. For comprehensive smelter details, please refer to Appendix A of this CMR.Status
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Number of identified smelters/refiners
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RMAP Conformant
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225
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RMAP Active
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6
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Not Enrolled
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90
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Non-Conformant
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29
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Country of Origin
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on reasonable identification of country-of-origin data obtained via Assent’s supply chain database (or other RCOI data when Frequency used alternative data sources). As mentioned in the above section, it is understood that overreporting might occur which could result in Appendix B having more countries than those strictly relevant to the Company’s products.
Steps to Be Taken to Mitigate Risk
For 2024, Frequency intends to take, the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in the Company’s products could originate from Conflict-Affected and High-Risk Areas:
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Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to:
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Using a comprehensive smelter/refiner library with detailed status and notes for each entity.
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Scanning for verifiable media sources on each smelter/refiner to flag risk issues.
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Comparing the list of smelters/refiners against government watch and denied parties lists.
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Engage with suppliers more closely, and provide more information and training resources regarding responsible sourcing of 3TGs.
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Encourage suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.
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Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts, as well as included in the terms and conditions of each purchase order issued.
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Following the OECD Guidance process, increase the emphasis on clean and validated smelter/ refiner information from the supply chain through feedback and detailed smelter/refiner analysis.
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Appendix A: Smelter List
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Metal
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Smelter Name
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Smelter Facility Location
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Smelter ID
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RMAP Audit Status
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Gold
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Royal Canadian Mint
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Canada
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CID001534
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Conformant
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Gold
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Advanced Chemical Company
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United States Of America
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CID000015
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Active
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Gold
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Aida Chemical Industries Co., Ltd.
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Japan
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CID000019
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Conformant
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Gold
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Agosi AG
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Germany
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CID000035
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Conformant
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Gold
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Almalyk Mining and Metallurgical Complex (AMMC)
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Uzbekistan
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CID000041
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Conformant
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Gold
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AngloGold Ashanti Corrego do Sitio Mineracao
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Brazil
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CID000058
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Conformant
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Gold
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Argor-Heraeus S.A.
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Switzerland
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CID000077
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Conformant
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Gold
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Asahi Pretec Corp.
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Japan
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CID000082
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Conformant
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Gold
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Asaka Riken Co., Ltd.
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Japan
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CID000090
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Conformant
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Gold
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Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
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Turkey
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CID000103
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Outreach Required
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Gold
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Aurubis AG
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Germany
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CID000113
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Conformant
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Gold
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
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Philippines
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CID000128
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Conformant
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Gold
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Boliden AB
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Sweden
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CID000157
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Conformant
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Gold
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C. Hafner GmbH + Co. KG
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Germany
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CID000176
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Conformant
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Gold
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Caridad
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Mexico
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CID000180
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Outreach Required
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Gold
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CCR Refinery - Glencore Canada Corporation
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Canada
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CID000185
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Conformant
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Gold
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Cendres + Metaux S.A.
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Switzerland
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CID000189
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Non Conformant
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Gold
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Yunnan Copper Industry Co., Ltd.
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China
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CID000197
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Outreach Required
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Gold
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Chimet S.p.A.
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Italy
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CID000233
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Conformant
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Gold
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Chugai Mining
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Japan
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CID000264
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Conformant
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Gold
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Daye Non-Ferrous Metals Mining Ltd.
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China
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CID000343
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Outreach Required
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Gold
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DSC (Do Sung Corporation)
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Korea, Republic Of
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CID000359
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Conformant
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Gold
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Dowa
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Japan
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CID000401
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Conformant
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Gold
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Eco-System Recycling Co., Ltd. East Plant
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Japan
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CID000425
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Conformant
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Gold
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JSC Novosibirsk Refinery
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Russian Federation
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CID000493
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RMI Due Diligence Review - Unable to Proceed
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Gold
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Refinery of Seemine Gold Co., Ltd.
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China
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CID000522
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Outreach Required
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Gold
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Guoda Safina High-Tech Environmental Refinery Co., Ltd.
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China
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CID000651
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Outreach Required
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Gold
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Hangzhou Fuchunjiang Smelting Co., Ltd.
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China
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CID000671
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Outreach Required
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Gold
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LT Metal Ltd.
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Korea, Republic Of
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CID000689
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Conformant
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Gold
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Heimerle + Meule GmbH
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Germany
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CID000694
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Conformant
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Gold
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Heraeus Metals Hong Kong Ltd.
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China
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CID000707
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Conformant
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Gold
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Heraeus Germany GmbH Co. KG
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Germany
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CID000711
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Conformant
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Gold
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Hunan Chenzhou Mining Co., Ltd.
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China
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CID000767
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Outreach Required
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Gold
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Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
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China
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CID000773
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Outreach Required
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Gold
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HwaSeong CJ CO., LTD.
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Korea, Republic Of
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CID000778
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Communication Suspended - Not Interested
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Gold
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Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
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China
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CID000801
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Conformant
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Gold
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Ishifuku Metal Industry Co., Ltd.
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Japan
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CID000807
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Conformant
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Gold
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Istanbul Gold Refinery
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Turkey
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CID000814
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Conformant
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Gold
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Japan Mint
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Japan
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CID000823
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Conformant
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Gold
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Jiangxi Copper Co., Ltd.
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China
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CID000855
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Conformant
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Gold
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Asahi Refining USA Inc.
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United States Of America
|
CID000920
|
Conformant
|
|
Gold
|
Asahi Refining Canada Ltd.
|
Canada
|
CID000924
|
Conformant
|
|
Gold
|
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
|
Russian Federation
|
CID000927
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
JSC Uralelectromed
|
Russian Federation
|
CID000929
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
JX Nippon Mining & Metals Co., Ltd.
|
Japan
|
CID000937
|
Conformant
|
|
Gold
|
Kazakhmys Smelting LLC
|
Kazakhstan
|
CID000956
|
Outreach Required
|
|
Gold
|
Kazzinc
|
Kazakhstan
|
CID000957
|
Conformant
|
|
Gold
|
Kennecott Utah Copper LLC
|
United States Of America
|
CID000969
|
Conformant
|
|
Gold
|
Kojima Chemicals Co., Ltd.
|
Japan
|
CID000981
|
Conformant
|
|
Gold
|
Kyrgyzaltyn JSC
|
Kyrgyzstan
|
CID001029
|
Non Conformant
|
|
Gold
|
L'azurde Company For Jewelry
|
Saudi Arabia
|
CID001032
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
Lingbao Gold Co., Ltd.
|
China
|
CID001056
|
Outreach Required
|
|
Gold
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
|
China
|
CID001058
|
Outreach Required
|
|
Gold
|
LS-NIKKO Copper Inc.
|
Korea, Republic Of
|
CID001078
|
Conformant
|
|
Gold
|
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
|
China
|
CID001093
|
Outreach Required
|
|
Gold
|
Materion
|
United States Of America
|
CID001113
|
Conformant
|
|
Gold
|
Matsuda Sangyo Co., Ltd.
|
Japan
|
CID001119
|
Conformant
|
|
Gold
|
Metalor Technologies (Suzhou) Ltd.
|
China
|
CID001147
|
Conformant
|
|
Gold
|
Metalor Technologies (Hong Kong) Ltd.
|
China
|
CID001149
|
Conformant
|
|
Gold
|
Metalor Technologies (Singapore) Pte., Ltd.
|
Singapore
|
CID001152
|
Conformant
|
|
Gold
|
Metalor Technologies S.A.
|
Switzerland
|
CID001153
|
Conformant
|
|
Gold
|
Metalor USA Refining Corporation
|
United States Of America
|
CID001157
|
Conformant
|
|
Gold
|
Metalurgica Met-Mex Penoles S.A. De C.V.
|
Mexico
|
CID001161
|
Conformant
|
|
Gold
|
Mitsubishi Materials Corporation
|
Japan
|
CID001188
|
Conformant
|
|
Gold
|
Mitsui Mining and Smelting Co., Ltd.
|
Japan
|
CID001193
|
Conformant
|
|
Gold
|
Moscow Special Alloys Processing Plant
|
Russian Federation
|
CID001204
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.S.
|
Turkey
|
CID001220
|
Conformant
|
|
Gold
|
Navoi Mining and Metallurgical Combinat
|
Uzbekistan
|
CID001236
|
Conformant
|
|
Gold
|
Nihon Material Co., Ltd.
|
Japan
|
CID001259
|
Conformant
|
|
Gold
|
Ohura Precious Metal Industry Co., Ltd.
|
Japan
|
CID001325
|
Conformant
|
|
Gold
|
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
|
Russian Federation
|
CID001326
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
MKS PAMP SA
|
Switzerland
|
CID001352
|
Conformant
|
|
Gold
|
Penglai Penggang Gold Industry Co., Ltd.
|
China
|
CID001362
|
Outreach Required
|
|
Gold
|
Prioksky Plant of Non-Ferrous Metals
|
Russian Federation
|
CID001386
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
PT Aneka Tambang (Persero) Tbk
|
Indonesia
|
CID001397
|
Conformant
|
|
Gold
|
PX Precinox S.A.
|
Switzerland
|
CID001498
|
Conformant
|
|
Gold
|
Rand Refinery (Pty) Ltd.
|
South Africa
|
CID001512
|
Conformant
|
|
Gold
|
Sabin Metal Corp.
|
United States Of America
|
CID001546
|
Communication Suspended - Not Interested
|
|
Gold
|
Samduck Precious Metals
|
Korea, Republic Of
|
CID001555
|
Non Conformant
|
|
Gold
|
Samwon Metals Corp.
|
Korea, Republic Of
|
CID001562
|
Communication Suspended - Not Interested
|
|
Gold
|
SEMPSA Joyeria Plateria S.A.
|
Spain
|
CID001585
|
Conformant
|
|
Gold
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
|
China
|
CID001619
|
Outreach Required
|
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
China
|
CID001622
|
Conformant
|
|
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
China
|
CID001736
|
Conformant
|
|
Gold
|
SOE Shyolkovsky Factory of Secondary Precious Metals
|
Russian Federation
|
CID001756
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
Solar Applied Materials Technology Corp.
|
Taiwan, Province Of China
|
CID001761
|
Conformant
|
|
Gold
|
Sumitomo Metal Mining Co., Ltd.
|
Japan
|
CID001798
|
Conformant
|
|
Gold
|
Super Dragon Technology Co., Ltd.
|
Taiwan, Province Of China
|
CID001810
|
Outreach Required
|
|
Gold
|
Tanaka Kikinzoku Kogyo K.K.
|
Japan
|
CID001875
|
Conformant
|
|
Gold
|
Great Wall Precious Metals Co., Ltd. of CBPM
|
China
|
CID001909
|
Outreach Required
|
|
Gold
|
Shandong Gold Smelting Co., Ltd.
|
China
|
CID001916
|
Conformant
|
|
Gold
|
Tokuriki Honten Co., Ltd.
|
Japan
|
CID001938
|
Conformant
|
|
Gold
|
Tongling Nonferrous Metals Group Co., Ltd.
|
China
|
CID001947
|
Outreach Required
|
|
Gold
|
Torecom
|
Korea, Republic Of
|
CID001955
|
Conformant
|
|
Gold
|
Umicore S.A. Business Unit Precious Metals Refining
|
Belgium
|
CID001980
|
Conformant
|
|
Gold
|
United Precious Metal Refining, Inc.
|
United States Of America
|
CID001993
|
Conformant
|
|
Gold
|
Valcambi S.A.
|
Switzerland
|
CID002003
|
Conformant
|
|
Gold
|
Western Australian Mint (T/a The Perth Mint)
|
Australia
|
CID002030
|
Conformant
|
|
Gold
|
Yamakin Co., Ltd.
|
Japan
|
CID002100
|
Conformant
|
|
Gold
|
Yokohama Metal Co., Ltd.
|
Japan
|
CID002129
|
Conformant
|
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
China
|
CID002224
|
Conformant
|
|
Gold
|
Gold Refinery of Zijin Mining Group Co., Ltd.
|
China
|
CID002243
|
Conformant
|
|
Gold
|
Morris and Watson
|
New Zealand
|
CID002282
|
Outreach Required
|
|
Gold
|
SAFINA A.S.
|
Czechia
|
CID002290
|
Conformant
|
|
Gold
|
Guangdong Jinding Gold Limited
|
China
|
CID002312
|
Outreach Required
|
|
Gold
|
Umicore Precious Metals Thailand
|
Thailand
|
CID002314
|
Non Conformant
|
|
Gold
|
MMTC-PAMP India Pvt., Ltd.
|
India
|
CID002509
|
Conformant
|
|
Gold
|
KGHM Polska Miedz Spolka Akcyjna
|
Poland
|
CID002511
|
Conformant
|
|
Gold
|
Fidelity Printers and Refiners Ltd.
|
Zimbabwe
|
CID002515
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
Singway Technology Co., Ltd.
|
Taiwan, Province Of China
|
CID002516
|
Non Conformant
|
|
Gold
|
Shandong Humon Smelting Co., Ltd.
|
China
|
CID002525
|
Outreach Required
|
|
Gold
|
Shenzhen Zhonghenglong Real Industry Co., Ltd.
|
China
|
CID002527
|
Outreach Required
|
|
Gold
|
Al Etihad Gold Refinery DMCC
|
United Arab Emirates
|
CID002560
|
Non Conformant
|
|
Gold
|
Emirates Gold DMCC
|
United Arab Emirates
|
CID002561
|
Non Conformant
|
|
Gold
|
International Precious Metal Refiners
|
United Arab Emirates
|
CID002562
|
Outreach Required
|
|
Gold
|
Kaloti Precious Metals
|
United Arab Emirates
|
CID002563
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
Sudan Gold Refinery
|
Sudan
|
CID002567
|
Outreach Required
|
|
Gold
|
T.C.A S.p.A
|
Italy
|
CID002580
|
Conformant
|
|
Gold
|
REMONDIS PMR B.V.
|
Netherlands
|
CID002582
|
Conformant
|
|
Gold
|
Fujairah Gold FZC
|
United Arab Emirates
|
CID002584
|
Outreach Required
|
|
Gold
|
Industrial Refining Company
|
Belgium
|
CID002587
|
Non Conformant
|
|
Gold
|
Shirpur Gold Refinery Ltd.
|
India
|
CID002588
|
Outreach Required
|
|
Gold
|
Korea Zinc Co., Ltd.
|
Korea, Republic Of
|
CID002605
|
Conformant
|
|
Gold
|
Marsam Metals
|
Brazil
|
CID002606
|
Non Conformant
|
|
Gold
|
TOO Tau-Ken-Altyn
|
Kazakhstan
|
CID002615
|
Conformant
|
|
Gold
|
Abington Reldan Metals, LLC
|
United States Of America
|
CID002708
|
Conformant
|
|
Gold
|
Shenzhen CuiLu Gold Co., Ltd.
|
China
|
CID002750
|
Outreach Required
|
|
Gold
|
Albino Mountinho Lda.
|
Portugal
|
CID002760
|
Outreach Required
|
|
Gold
|
SAAMP
|
France
|
CID002761
|
Non Conformant
|
|
Gold
|
L'Orfebre S.A.
|
Andorra
|
CID002762
|
Conformant
|
|
Gold
|
8853 S.p.A.
|
Italy
|
CID002763
|
Non Conformant
|
|
Gold
|
Italpreziosi
|
Italy
|
CID002765
|
Conformant
|
|
Gold
|
WIELAND Edelmetalle GmbH
|
Germany
|
CID002778
|
Conformant
|
|
Gold
|
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
|
Austria
|
CID002779
|
Conformant
|
|
Gold
|
AU Traders and Refiners
|
South Africa
|
CID002850
|
Non Conformant
|
|
Gold
|
GGC Gujrat Gold Centre Pvt. Ltd.
|
India
|
CID002852
|
Non Conformant
|
|
Gold
|
Sai Refinery
|
India
|
CID002853
|
Outreach Required
|
|
Gold
|
Modeltech Sdn Bhd
|
Malaysia
|
CID002857
|
Non Conformant
|
|
Gold
|
Bangalore Refinery
|
India
|
CID002863
|
Active
|
|
Gold
|
Kyshtym Copper-Electrolytic Plant ZAO
|
Russian Federation
|
CID002865
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
Degussa Sonne / Mond Goldhandel GmbH
|
Germany
|
CID002867
|
Outreach Required
|
|
Gold
|
Pease & Curren
|
United States Of America
|
CID002872
|
Communication Suspended - Not Interested
|
|
Gold
|
JALAN & Company
|
India
|
CID002893
|
Outreach Required
|
|
Gold
|
SungEel HiMetal Co., Ltd.
|
Korea, Republic Of
|
CID002918
|
Conformant
|
|
Gold
|
Planta Recuperadora de Metales SpA
|
Chile
|
CID002919
|
Conformant
|
|
Gold
|
ABC Refinery Pty Ltd.
|
Australia
|
CID002920
|
Outreach Required
|
|
Gold
|
Safimet S.p.A
|
Italy
|
CID002973
|
Non Conformant
|
|
Gold
|
State Research Institute Center for Physical Sciences and Technology
|
Lithuania
|
CID003153
|
Outreach Required
|
|
Gold
|
African Gold Refinery
|
Uganda
|
CID003185
|
RMI Due Diligence Review - Unable to Proceed
|
|
Gold
|
Gold Coast Refinery
|
Ghana
|
CID003186
|
Outreach Required
|
|
Gold
|
NH Recytech Company
|
Korea, Republic Of
|
CID003189
|
Conformant
|
|
Gold
|
QG Refining, LLC
|
United States Of America
|
CID003324
|
Outreach Required
|
|
Gold
|
Dijllah Gold Refinery FZC
|
United Arab Emirates
|
CID003348
|
Outreach Required
|
|
Gold
|
CGR Metalloys Pvt Ltd.
|
India
|
CID003382
|
Outreach Required
|
|
Gold
|
Sovereign Metals
|
India
|
CID003383
|
Outreach Required
|
|
Gold
|
Eco-System Recycling Co., Ltd. North Plant
|
Japan
|
CID003424
|
Conformant
|
|
Gold
|
Eco-System Recycling Co., Ltd. West Plant
|
Japan
|
CID003425
|
Conformant
|
|
Gold
|
Augmont Enterprises Private Limited
|
India
|
CID003461
|
Non Conformant
|
|
Gold
|
Kundan Care Products Ltd.
|
India
|
CID003463
|
Outreach Required
|
|
Gold
|
Emerald Jewel Industry India Limited (Unit 1)
|
India
|
CID003487
|
Outreach Required
|
|
Gold
|
Emerald Jewel Industry India Limited (Unit 2)
|
India
|
CID003488
|
Outreach Required
|
|
Gold
|
Emerald Jewel Industry India Limited (Unit 3)
|
India
|
CID003489
|
Outreach Required
|
|
Gold
|
Emerald Jewel Industry India Limited (Unit 4)
|
India
|
CID003490
|
Outreach Required
|
|
Gold
|
K.A. Rasmussen
|
Norway
|
CID003497
|
Outreach Required
|
|
Gold
|
Alexy Metals
|
United States Of America
|
CID003500
|
Non Conformant
|
|
Gold
|
MD Overseas
|
India
|
CID003548
|
Outreach Required
|
|
Gold
|
Metallix Refining Inc.
|
United States Of America
|
CID003557
|
Outreach Required
|
|
Gold
|
Metal Concentrators SA (Pty) Ltd.
|
South Africa
|
CID003575
|
Conformant
|
|
Gold
|
WEEEREFINING
|
France
|
CID003615
|
Conformant
|
|
Gold
|
Gold by Gold Colombia
|
Colombia
|
CID003641
|
Conformant
|
|
Gold
|
Dongwu Gold Group
|
China
|
CID003663
|
Outreach Required
|
|
Gold
|
Sam Precious Metals
|
United Arab Emirates
|
CID003666
|
Outreach Required
|
|
Gold
|
Coimpa Industrial LTDA
|
Brazil
|
CID004010
|
Conformant
|
|
Gold
|
GG Refinery Ltd.
|
Tanzania, United Republic Of
|
CID004506
|
Active
|
|
Tantalum
|
F&X Electro-Materials Ltd.
|
China
|
CID000460
|
Conformant
|
|
Tantalum
|
XIMEI RESOURCES (GUANGDONG) LIMITED
|
China
|
CID000616
|
Conformant
|
|
Tantalum
|
JiuJiang JinXin Nonferrous Metals Co., Ltd.
|
China
|
CID000914
|
Conformant
|
|
Tantalum
|
Jiujiang Tanbre Co., Ltd.
|
China
|
CID000917
|
Conformant
|
|
Tantalum
|
AMG Brasil
|
Brazil
|
CID001076
|
Conformant
|
|
Tantalum
|
Metallurgical Products India Pvt., Ltd.
|
India
|
CID001163
|
Conformant
|
|
Tantalum
|
Mineracao Taboca S.A.
|
Brazil
|
CID001175
|
Conformant
|
|
Tantalum
|
Mitsui Mining and Smelting Co., Ltd.
|
Japan
|
CID001192
|
Conformant
|
|
Tantalum
|
NPM Silmet AS
|
Estonia
|
CID001200
|
Conformant
|
|
Tantalum
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
China
|
CID001277
|
Conformant
|
|
Tantalum
|
QuantumClean
|
United States Of America
|
CID001508
|
Conformant
|
|
Tantalum
|
Yanling Jincheng Tantalum & Niobium Co., Ltd.
|
China
|
CID001522
|
Conformant
|
|
Tantalum
|
Solikamsk Magnesium Works OAO
|
Russian Federation
|
CID001769
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tantalum
|
Taki Chemical Co., Ltd.
|
Japan
|
CID001869
|
Conformant
|
|
Tantalum
|
Telex Metals
|
United States Of America
|
CID001891
|
Conformant
|
|
Tantalum
|
Ulba Metallurgical Plant JSC
|
Kazakhstan
|
CID001969
|
Conformant
|
|
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
China
|
CID002492
|
Conformant
|
|
Tantalum
|
D Block Metals, LLC
|
United States Of America
|
CID002504
|
Conformant
|
|
Tantalum
|
FIR Metals & Resource Ltd.
|
China
|
CID002505
|
Conformant
|
|
Tantalum
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
|
China
|
CID002506
|
Conformant
|
|
Tantalum
|
XinXing HaoRong Electronic Material Co., Ltd.
|
China
|
CID002508
|
Conformant
|
|
Tantalum
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
|
China
|
CID002512
|
Conformant
|
|
Tantalum
|
KEMET de Mexico
|
Mexico
|
CID002539
|
Conformant
|
|
Tantalum
|
TANIOBIS Co., Ltd.
|
Thailand
|
CID002544
|
Conformant
|
|
Tantalum
|
TANIOBIS GmbH
|
Germany
|
CID002545
|
Conformant
|
|
Tantalum
|
Materion Newton Inc.
|
United States Of America
|
CID002548
|
Conformant
|
|
Tantalum
|
TANIOBIS Japan Co., Ltd.
|
Japan
|
CID002549
|
Conformant
|
|
Tantalum
|
TANIOBIS Smelting GmbH & Co. KG
|
Germany
|
CID002550
|
Conformant
|
|
Tantalum
|
Global Advanced Metals Boyertown
|
United States Of America
|
CID002557
|
Conformant
|
|
Tantalum
|
Global Advanced Metals Aizu
|
Japan
|
CID002558
|
Conformant
|
|
Tantalum
|
Resind Industria e Comercio Ltda.
|
Brazil
|
CID002707
|
Conformant
|
|
Tantalum
|
Jiangxi Tuohong New Raw Material
|
China
|
CID002842
|
Conformant
|
|
Tantalum
|
RFH Yancheng Jinye New Material Technology Co., Ltd.
|
China
|
CID003583
|
Conformant
|
|
Tantalum
|
5D Production OU
|
Estonia
|
CID003926
|
Outreach Required
|
|
Tantalum
|
Guangdong Rising Rare Metals-EO Materials Ltd.
|
China
|
CID000291
|
Conformant
|
|
Tantalum
|
PowerX Ltd.
|
Rwanda
|
CID004054
|
Conformant
|
|
Tin
|
Minsur
|
Peru
|
CID001182
|
Conformant
|
|
Tin
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
|
China
|
CID000228
|
Conformant
|
|
Tin
|
Alpha
|
United States Of America
|
CID000292
|
Conformant
|
|
Tin
|
PT Aries Kencana Sejahtera
|
Indonesia
|
CID000309
|
Conformant
|
|
Tin
|
PT Premium Tin Indonesia
|
Indonesia
|
CID000313
|
Conformant
|
|
Tin
|
Dowa
|
Japan
|
CID000402
|
Conformant
|
|
Tin
|
EM Vinto
|
Bolivia (Plurinational State Of)
|
CID000438
|
Conformant
|
|
Tin
|
Estanho de Rondonia S.A.
|
Brazil
|
CID000448
|
Conformant
|
|
Tin
|
Fenix Metals
|
Poland
|
CID000468
|
Conformant
|
|
Tin
|
Gejiu Non-Ferrous Metal Processing Co., Ltd.
|
China
|
CID000538
|
Conformant
|
|
Tin
|
Gejiu Zili Mining And Metallurgy Co., Ltd.
|
China
|
CID000555
|
Non Conformant
|
|
Tin
|
Gejiu Kai Meng Industry and Trade LLC
|
China
|
CID000942
|
Non Conformant
|
|
Tin
|
China Tin Group Co., Ltd.
|
China
|
CID001070
|
Conformant
|
|
Tin
|
Malaysia Smelting Corporation (MSC)
|
Malaysia
|
CID001105
|
Conformant
|
|
Tin
|
Metallic Resources, Inc.
|
United States Of America
|
CID001142
|
Conformant
|
|
Tin
|
Mineracao Taboca S.A.
|
Brazil
|
CID001173
|
Conformant
|
|
Tin
|
Mitsubishi Materials Corporation
|
Japan
|
CID001191
|
Conformant
|
|
Tin
|
Jiangxi New Nanshan Technology Ltd.
|
China
|
CID001231
|
Conformant
|
|
Tin
|
Novosibirsk Tin Combine
|
Russian Federation
|
CID001305
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
Thailand
|
CID001314
|
Conformant
|
|
Tin
|
Operaciones Metalurgicas S.A.
|
Bolivia (Plurinational State Of)
|
CID001337
|
Conformant
|
|
Tin
|
PT Artha Cipta Langgeng
|
Indonesia
|
CID001399
|
Conformant
|
|
Tin
|
PT Babel Inti Perkasa
|
Indonesia
|
CID001402
|
Conformant
|
|
Tin
|
PT Babel Surya Alam Lestari
|
Indonesia
|
CID001406
|
Conformant
|
|
Tin
|
PT Bangka Tin Industry
|
Indonesia
|
CID001419
|
Active
|
|
Tin
|
PT Belitung Industri Sejahtera
|
Indonesia
|
CID001421
|
Conformant
|
|
Tin
|
PT Bukit Timah
|
Indonesia
|
CID001428
|
Conformant
|
|
Tin
|
PT Mitra Stania Prima
|
Indonesia
|
CID001453
|
Conformant
|
|
Tin
|
PT Panca Mega Persada
|
Indonesia
|
CID001457
|
Outreach Required
|
|
Tin
|
PT Prima Timah Utama
|
Indonesia
|
CID001458
|
Conformant
|
|
Tin
|
PT Refined Bangka Tin
|
Indonesia
|
CID001460
|
Conformant
|
|
Tin
|
PT Sariwiguna Binasentosa
|
Indonesia
|
CID001463
|
Conformant
|
|
Tin
|
PT Stanindo Inti Perkasa
|
Indonesia
|
CID001468
|
Conformant
|
|
Tin
|
PT Timah Tbk Kundur
|
Indonesia
|
CID001477
|
Conformant
|
|
Tin
|
PT Timah Tbk Mentok
|
Indonesia
|
CID001482
|
Conformant
|
|
Tin
|
PT Timah Nusantara
|
Indonesia
|
CID001486
|
Conformant
|
|
Tin
|
PT Tinindo Inter Nusa
|
Indonesia
|
CID001490
|
Conformant
|
|
Tin
|
PT Tommy Utama
|
Indonesia
|
CID001493
|
Conformant
|
|
Tin
|
Rui Da Hung
|
Taiwan, Province Of China
|
CID001539
|
Conformant
|
|
Tin
|
Thaisarco
|
Thailand
|
CID001898
|
Conformant
|
|
Tin
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
China
|
CID001908
|
Non Conformant
|
|
Tin
|
VQB Mineral and Trading Group JSC
|
Viet Nam
|
CID002015
|
Outreach Required
|
|
Tin
|
White Solder Metalurgia e Mineracao Ltda.
|
Brazil
|
CID002036
|
Conformant
|
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
China
|
CID002158
|
Conformant
|
|
Tin
|
Tin Smelting Branch of Yunnan Tin Co., Ltd.
|
China
|
CID002180
|
Conformant
|
|
Tin
|
CV Venus Inti Perkasa
|
Indonesia
|
CID002455
|
Conformant
|
|
Tin
|
Magnu's Minerais Metais e Ligas Ltda.
|
Brazil
|
CID002468
|
Conformant
|
|
Tin
|
PT Tirus Putra Mandiri
|
Indonesia
|
CID002478
|
Communication Suspended - Not Interested
|
|
Tin
|
Melt Metais e Ligas S.A.
|
Brazil
|
CID002500
|
Non Conformant
|
|
Tin
|
PT ATD Makmur Mandiri Jaya
|
Indonesia
|
CID002503
|
Conformant
|
|
Tin
|
O.M. Manufacturing Philippines, Inc.
|
Philippines
|
CID002517
|
Conformant
|
|
Tin
|
CV Ayi Jaya
|
Indonesia
|
CID002570
|
Conformant
|
|
Tin
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
|
Viet Nam
|
CID002572
|
Non Conformant
|
|
Tin
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company
|
Viet Nam
|
CID002573
|
Outreach Required
|
|
Tin
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company
|
Viet Nam
|
CID002574
|
Outreach Required
|
|
Tin
|
PT Cipta Persada Mulia
|
Indonesia
|
CID002696
|
Conformant
|
|
Tin
|
An Vinh Joint Stock Mineral Processing Company
|
Viet Nam
|
CID002703
|
Outreach Required
|
|
Tin
|
Resind Industria e Comercio Ltda.
|
Brazil
|
CID002706
|
Conformant
|
|
Tin
|
Super Ligas
|
Brazil
|
CID002756
|
Conformant
|
|
Tin
|
Aurubis Beerse
|
Belgium
|
CID002773
|
Conformant
|
|
Tin
|
Aurubis Berango
|
Spain
|
CID002774
|
Conformant
|
|
Tin
|
PT Bangka Prima Tin
|
Indonesia
|
CID002776
|
Conformant
|
|
Tin
|
PT Sukses Inti Makmur
|
Indonesia
|
CID002816
|
Conformant
|
|
Tin
|
PT Menara Cipta Mulia
|
Indonesia
|
CID002835
|
Conformant
|
|
Tin
|
Modeltech Sdn Bhd
|
Malaysia
|
CID002858
|
Non Conformant
|
|
Tin
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
|
China
|
CID003116
|
Conformant
|
|
Tin
|
Chifeng Dajingzi Tin Industry Co., Ltd.
|
China
|
CID003190
|
Conformant
|
|
Tin
|
PT Bangka Serumpun
|
Indonesia
|
CID003205
|
Conformant
|
|
Tin
|
Pongpipat Company Limited
|
Myanmar
|
CID003208
|
Outreach Required
|
|
Tin
|
Tin Technology & Refining
|
United States Of America
|
CID003325
|
Conformant
|
|
Tin
|
Dongguan CiEXPO Environmental Engineering Co., Ltd.
|
China
|
CID003356
|
Non Conformant
|
|
Tin
|
PT Rajawali Rimba Perkasa
|
Indonesia
|
CID003381
|
Conformant
|
|
Tin
|
Luna Smelter, Ltd.
|
Rwanda
|
CID003387
|
Conformant
|
|
Tin
|
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
|
China
|
CID003397
|
Conformant
|
|
Tin
|
Precious Minerals and Smelting Limited
|
India
|
CID003409
|
Active
|
|
Tin
|
Gejiu City Fuxiang Industry and Trade Co., Ltd.
|
China
|
CID003410
|
Outreach Required
|
|
Tin
|
PT Mitra Sukses Globalindo
|
Indonesia
|
CID003449
|
Conformant
|
|
Tin
|
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
|
Brazil
|
CID003486
|
Conformant
|
|
Tin
|
CRM Synergies
|
Spain
|
CID003524
|
Conformant
|
|
Tin
|
Fabrica Auricchio Industria e Comercio Ltda.
|
Brazil
|
CID003582
|
Conformant
|
|
Tin
|
DS Myanmar
|
Myanmar
|
CID003831
|
Conformant
|
|
Tin
|
PT Putera Sarana Shakti (PT PSS)
|
Indonesia
|
CID003868
|
Conformant
|
|
Tin
|
PT Rajehan Ariq
|
Indonesia
|
CID002593
|
Conformant
|
|
Tin
|
HuiChang Hill Tin Industry Co., Ltd.
|
China
|
CID002844
|
Conformant
|
|
Tin
|
Ma'anshan Weitai Tin Co., Ltd.
|
China
|
CID003379
|
Non Conformant
|
|
Tin
|
Mining Minerals Resources SARL
|
Congo, Democratic Republic Of The
|
CID004065
|
Conformant
|
|
Tin
|
Malaysia Smelting Corporation Berhad (Port Klang)
|
Malaysia
|
CID004434
|
In Communication
|
|
Tungsten
|
Kennametal Huntsville
|
United States Of America
|
CID000105
|
Conformant
|
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
China
|
CID000218
|
Conformant
|
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
China
|
CID000258
|
Conformant
|
|
Tungsten
|
CNMC (Guangxi) PGMA Co., Ltd.
|
China
|
CID000281
|
Outreach Required
|
|
Tungsten
|
Global Tungsten & Powders LLC
|
United States Of America
|
CID000568
|
Conformant
|
|
Tungsten
|
Hunan Chenzhou Mining Co., Ltd.
|
China
|
CID000766
|
Conformant
|
|
Tungsten
|
Hunan Jintai New Material Co., Ltd.
|
China
|
CID000769
|
Non Conformant
|
|
Tungsten
|
Japan New Metals Co., Ltd.
|
Japan
|
CID000825
|
Conformant
|
|
Tungsten
|
Kennametal Fallon
|
United States Of America
|
CID000966
|
Conformant
|
|
Tungsten
|
Wolfram Bergbau und Hutten AG
|
Austria
|
CID002044
|
Conformant
|
|
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
China
|
CID002082
|
Conformant
|
|
Tungsten
|
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
|
China
|
CID002313
|
Communication Suspended - Not Interested
|
|
Tungsten
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
China
|
CID002315
|
Conformant
|
|
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
China
|
CID002316
|
Conformant
|
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
China
|
CID002317
|
Conformant
|
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
China
|
CID002318
|
Conformant
|
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
China
|
CID002319
|
Conformant
|
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
China
|
CID002320
|
Conformant
|
|
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
China
|
CID002321
|
Conformant
|
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
China
|
CID002494
|
Conformant
|
|
Tungsten
|
Asia Tungsten Products Vietnam Ltd.
|
Viet Nam
|
CID002502
|
Conformant
|
|
Tungsten
|
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
|
China
|
CID002513
|
Conformant
|
|
Tungsten
|
H.C. Starck Tungsten GmbH
|
Germany
|
CID002541
|
Conformant
|
|
Tungsten
|
TANIOBIS Smelting GmbH & Co. KG
|
Germany
|
CID002542
|
Conformant
|
|
Tungsten
|
Masan High-Tech Materials
|
Viet Nam
|
CID002543
|
Conformant
|
|
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
China
|
CID002551
|
Conformant
|
|
Tungsten
|
Niagara Refining LLC
|
United States Of America
|
CID002589
|
Conformant
|
|
Tungsten
|
China Molybdenum Tungsten Co., Ltd.
|
China
|
CID002641
|
Conformant
|
|
Tungsten
|
Hydrometallurg, JSC
|
Russian Federation
|
CID002649
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tungsten
|
Unecha Refractory metals plant
|
Russian Federation
|
CID002724
|
Non Conformant
|
|
Tungsten
|
Philippine Chuangxin Industrial Co., Inc.
|
Philippines
|
CID002827
|
Conformant
|
|
Tungsten
|
ACL Metais Eireli
|
Brazil
|
CID002833
|
Non Conformant
|
|
Tungsten
|
Moliren Ltd.
|
Russian Federation
|
CID002845
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tungsten
|
Lianyou Metals Co., Ltd.
|
Taiwan, Province Of China
|
CID003407
|
Conformant
|
|
Tungsten
|
JSC "Kirovgrad Hard Alloys Plant"
|
Russian Federation
|
CID003408
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tungsten
|
NPP Tyazhmetprom LLC
|
Russian Federation
|
CID003416
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tungsten
|
Hubei Green Tungsten Co., Ltd.
|
China
|
CID003417
|
Conformant
|
|
Tungsten
|
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
|
Brazil
|
CID003427
|
Non Conformant
|
|
Tungsten
|
Cronimet Brasil Ltda
|
Brazil
|
CID003468
|
Conformant
|
|
Tungsten
|
Artek LLC
|
Russian Federation
|
CID003553
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tungsten
|
Fujian Xinlu Tungsten Co., Ltd.
|
China
|
CID003609
|
Conformant
|
|
Tungsten
|
OOO “Technolom” 2
|
Russian Federation
|
CID003612
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tungsten
|
OOO “Technolom” 1
|
Russian Federation
|
CID003614
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tungsten
|
LLC Vostok
|
Russian Federation
|
CID003643
|
RMI Due Diligence Review - Unable to Proceed
|
|
Tungsten
|
YUDU ANSHENG TUNGSTEN CO., LTD.
|
China
|
CID003662
|
Outreach Required
|
|
Tungsten
|
HANNAE FOR T Co., Ltd.
|
Korea, Republic Of
|
CID003978
|
Outreach Required
|
|
Tungsten
|
DONGKUK INDUSTRIES CO., LTD.
|
Korea, Republic Of
|
CID004060
|
Outreach Required
|
|
Tungsten
|
A.L.M.T. Corp.
|
Japan
|
CID000004
|
Conformant
|
|
Tungsten
|
Tungsten Vietnam Joint Stock Company
|
Viet Nam
|
CID003993
|
Conformant
|
|
Tungsten
|
Nam Viet Cromit Joint Stock Company
|
Viet Nam
|
CID004034
|
Outreach Required
|
|
Tungsten
|
Shinwon Tungsten (Fujian Shanghang) Co., Ltd.
|
China
|
CID004430
|
Conformant
|
|
Tungsten
|
Lianyou Resources Co., Ltd.
|
Taiwan, Province Of China
|
CID004397
|
Conformant
|
|
Tungsten
|
Kenee Mining Corporation Vietnam
|
Viet Nam
|
CID004619
|
Active
|
Appendix B: Countries of Origin
|
Albania
|
Ecuador
|
Kyrgyzstan
|
Saudi Arabia
|
|
Andorra
|
Egypt
|
Liberia
|
Senegal
|
|
Angola
|
El Salvador
|
Liechtenstein
|
Serbia
|
|
Argentina
|
Eritrea
|
Lithuania
|
Sierra Leone
|
|
Armenia
|
Estonia
|
Luxembourg
|
Singapore
|
|
Australia
|
Ethiopia
|
Madagascar
|
Slovakia
|
|
Austria
|
Fiji
|
Malaysia
|
Solomon Islandss
|
|
Azerbaijan
|
Finland
|
Mali
|
South Africa
|
|
Belarus
|
France
|
Mauritania
|
South Sudan
|
|
Belgium
|
Georgia
|
Mexico
|
Spain
|
|
Benin
|
Germany
|
Mongolia
|
Sudan
|
|
Bermuda
|
Ghana
|
Morocco
|
Suriname
|
|
Bolivia (Plurinational State of)
|
Guam
|
Mozambique
|
Sweden
|
|
Botswana
|
Guatemala
|
Myanmar
|
Switzerland
|
|
Brazil
|
Guinea
|
Namibia
|
Taiwan
|
|
Bulgaria
|
Guyana
|
Netherlands
|
Tajikistan
|
|
Burkina Faso
|
Honduras
|
New Zealand
|
Tanzania
|
|
Burundi
|
Hong Kong
|
Nicaragua
|
Thailand
|
|
Cambodia
|
Hungary
|
Niger
|
Togo
|
|
Canada
|
India
|
Nigeria
|
Turkey
|
|
Central African Republic
|
Indonesia
|
Norway
|
Uganda
|
|
Chile
|
Ireland
|
Oman
|
United Arab Emirates
|
|
China
|
Israel
|
Panama
|
United Kingdom
|
|
Colombia
|
Italy
|
Papua New Guinea
|
United States of America
|
|
Congo
|
Ivory Coast
|
Peru
|
Uruguay
|
|
Cyprus
|
Japan
|
Philippines
|
Uzbekistan
|
|
Democratic Republic of Congo
|
Jersey
|
Poland
|
VietNam
|
|
Djibouti
|
Kazakhstan
|
Portugal
|
Zambia
|
|
Dominica
|
Kenya
|
Russian Federation
|
|
|
Dominican Republic
|
Korea
|
Rwanda
|
|
Appendix C: CMRT Declaration Rejection/Approval Criteria
Assent Sustainability Platform Logic Structure
The following tables map the Assent Sustainability Platform’s status outputs and CMRT logic structure when determining supplier conflict mineral statuses as displayed on the dashboard. Using this table, and referencing the CMRT questions listed above, users will be able to determine what answers were provided by their suppliers to earn their conflict minerals statuses.
Dashboard Supplier Response Statuses
|
Supplier Status
|
Description
|
|
Not Submitted
|
A CMRT has not been submitted by the supplier
|
|
Complete
|
A CMRT has been submitted, and is valid and complete
|
|
Incomplete
|
A supplier with parts associated to them has submitted a partially completed Product-Level or User-Defined CMRT
|
|
Invalid Submission
|
A CMRT has been submitted and deemed invalid based on contradicting responses in the template
|
|
Out of Scope
|
The supplier is out of scope for conflict minerals and does not need to be contacted
|
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