UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Netlist, Inc.
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Delaware |
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001-33170 |
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95-4812784 |
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(State or other jurisdiction
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(Commission
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(IRS Employer
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175 Technology Drive, Suite 150
Irvine, California 92618
(Address of Principal Executive Offices)
Chuck Hong
President and Chief Executive Officer
(949) 435-0025
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Form SD of Netlist , Inc. (the “ Company ”) has been prepared pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2015 to December 31, 2015.
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, is hereby incorporated by reference herein, and is publicly available at http://www.netlist.com/company/corporate-responsibility. The foregoing website reference is intended to be an inactive textual reference and the contents of the Company’s website are not incorporated into this report.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 - Exhibits
The following exhibit is filed as part of this report.
Item 2.01 Exhibits.
Exhibit 1.01 - 201 5 Conflict Minerals Report of Netlist, Inc. as required by Items 1.01 and 1.02 of this 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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Netlist , Inc. |
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Date: May 31, 2016 |
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/s/ Gail Sasaki |
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Gail Sasaki |
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Vice President and Chief Financial Officer |
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Exhibit 1.01
Conflict Minerals Report
For The Reporting Period from January 1, 2015 to December 31, 2015
This Conflict Minerals Report (the “ Report ”) of Netlist , Inc. (“ Netlist ” or the “ Company ”), has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “ Rule ”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2015 to December 31, 2015. As permitted by applicable guidance of the Securities and Exchange Commission, the Company has not obtained an independent private sector audit within the meaning of the Rule.
Overview of the Company and the Rule
Netlist designs, manufactures and sells a wide variety of high performance, logic-based memory subsystems for the global datacenter, storage and high-performance computing markets. The Company’s memory subsystems consist of combinations of dynamic random access memory integrated circuits (“ DRAM ”), NAND flash memory (“ NAND ”), application-specific integrated circuits and other components assembled on printed circuit boards. Netlist primarily markets and sells its products to leading original equipment manufacturer customers, hyper scale datacenter operators and storage vendors. The Company’s solutions are targeted at applications where memory plays a key role in meeting system performance requirements. The Company leverages a portfolio of proprietary technologies and design techniques, including combining discrete semiconductor technologies from third parties such as DRAM and NAND flash to function as one, efficient planar design, and alternative packaging technique to deliver memory subsystems with persistence, high density, small form factor, high signal integrity, attractive thermal characteristics, reduced power consumption and low cost per bit. The Company’s NVvault™ product is the first to offer both DRAM and NAND in a standard form factor memory subsystem as a persistent dual-in line memory module (“ DIMM ”) in mission critical applications. The Company’s HyperCloud ® technology incorporates its patented rank multiplication and load reduction technologies. The Company also has pending and issued patents covering fundamental aspects of hybrid memory DIMM designs that incorporate combinations of DRAM and/or NAND flash, such as its NVvault™ product. Netlist is focused on monetizing its patent portfolio through its products business and, where appropriate, through licensing arrangements with third parties that wish to incorporate its patented technologies in their products.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The Rule also requires such companies to conduct certain inquiries to determine whether such minerals originated in the countries specified in the Rule. The specified minerals are referred to for purposes of the Rule and this report as “ Conflict Minerals ” and include gold, columbite-tantalite (coltan), cassiterite and wolfamite, including their derivatives which are limited to tantalum, tin and tungsten. The specified countries, which are referred to as “ Covered Countries ” for purposes of the Rule and this Report, are the Democratic Republic of Congo (the “ DRC ”), the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Description of the Company’s Products Covered by this Report
This Report relates to the Company’s products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2015.
These products, which are referred to in this Report collectively as the “ Covered Products ,” are the following:
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Product Families |
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Description |
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NVvault™ |
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Memory Modules |
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HyperCloud ® |
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Memory Modules |
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Express Vault |
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Memory Modules |
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Flash |
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Memory Card |
Description of the Company’s Reasonable Country of Origin Inquiry
As described in this Report, the Company has determined that the following Conflict Minerals were necessary to the functionality or production of products contracted to be manufactured by the Company during the calendar year 2015: gold, tantalum, tin and tungsten. As a result, the Company conducted in good faith a reasonable country of origin inquiry (“ RCOI ”) reasonably designed to determine if any of these Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources. The Company’s supply chain is complex, and there are many third parties in the supply chain between the Company and the original sources of Conflict Minerals. The Company does not directly purchase Conflict Minerals from mines, smelters or refiners. Therefore, the Company must rely on its suppliers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products.
As such, the Company’s RCOI primarily consisted of submitting the Conflict Minerals Reporting Template (“ CMRT ”) prepared by the Conflict Free Sourcing Initiative (the “ CFSI ”), an initiative of the Electronic Industry Citizenship Coalition (“ EICC ”) and Global e-Sustainability Initiative (“ GeSI ”) to its suppliers which the Company determined use Conflict Minerals in the manufacture of, or in, its products in 2015. The Company received responses from all such suppliers. Responses were reviewed for completeness, reasonableness and consistency, and the Company followed up with its suppliers for corrections and clarifications as needed.
The Company was provided insufficient information to determine whether the Conflict Minerals used in its Covered Products or their manufacture originated from outside the Covered Countries or were from recycled or scrap sources.
Description of the Company’s Due Diligence Process
Based on this information, the Company performed additional due diligence on the source and chain of custody of these Conflict Minerals based on the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“ Framework ”) to determine if the Conflict Minerals that may have originated in the Covered Countries benefited armed groups. After performing the RCOI and due diligence in conformity with the Framework, the Company determined that its Covered Products are DRC conflict undeterminable with regard to calendar year 2015 because, for each of its Covered Products, the Company was unable to comprehensively determine the origin of all Conflict Minerals used in its Covered Products, the facilities used to process them, their country of origin or their mine or location of origin.
The Company’s due diligence measures have been designed to conform to the framework in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition , including the related supplements on gold, tin, tantalum and tungsten (the “ OECD Guidance ”). The OECD Guidance is an internationally recognized due diligence framework.
In accordance with the five-step OECD Guidance, the design of the Company’s due diligence includes, but is not limited to, the following five steps: (i) establishment of strong company management systems, (ii) identification and assessment of risks in the supply chain, (iii) designing and implementing a strategy to respond to identified risks, (iv) carrying out an independent third-party audit of smelter/refiner’s due diligence practices and (v) reporting on supply chain due diligence. A description of certain activities undertaken by the Company in respect of each of the five steps of the OECD Guidance is described below.
1. Establishment of Strong Company Management Systems
Netlist completed a number of steps to establish a management system for addressing the sourcing of Conflict Minerals in its Covered Products. These actions include:
a. Preparing a Supply Chain Policy for Conflict Minerals :
A copy of the Company’s Conflict Minerals policy is available at www.netlist.com. The foregoing website reference is intended to be an inactive textual reference and the contents of the Company’s website are not incorporated into this report.
As part of Netlist’s commitment to corporate responsibility and respecting human rights in its own operations and in its global supply chain, it is Netlist’s goal to seek to use tantalum, tin, tungsten and gold in its products that are “ DRC conflict free ” while continuing to support responsible in-region mineral sourcing from the DRC and Covered Countries.
Netlist’s Policy notes that Netlist expects its suppliers to have in place policies and due diligence measures that will enable it to reasonably assure that products and components supplied to it containing Conflict Minerals are DRC conflict free. Netlist expects its suppliers to comply with the EICC Code of Conduct and conduct their business in alignment with Netlist supply chain responsibility expectations.
b. Internal Management to Support Supply Chain Due Diligence : Members of Netlist’s management (the “ Conflict Minerals Team ”) participate in the design and execution of its conflict minerals program and cooperate to manage and support its supply chain due diligence. The Conflict Minerals Team identified the suppliers to be contacted, and adopted and approved for use the CMRT discussed above. The Company interacts with its suppliers to obtain updated and current CMRTs and analyze the information provided by each supplier on the sourcing of the Conflict Minerals used in the manufacture of the Covered Products. Each response is reviewed to identify missing information and unclear responses. Netlist’s Conflict Minerals Team meets regularly to discuss the results of the due diligence efforts and appropriate follow-up measures to be taken with its suppliers.
c. Controls and Transparency to Support Supply Chain Diligence : The Company uses the CMRT to identify the smelters and refiners that are in the supply chain of each of its suppliers. The Company periodically reviews and compares this list to the list of smelters and refiners identified by the CFSI to be active in the CFSI. This enables Netlist to identify the smelters and refiners that have been determined to be conflict-free and those that are actively progressing towards an audit to determine their status. The Company determined that this approach represents the most reasonable effort it can make to determine whether the minerals used in the production of its Covered Products are conflict-free.
d. Supplier Engagement : The Company is dependent upon its suppliers to identify the sources and status of the Conflict Minerals used in its Covered Products and to encourage each smelter and refinery in its supply chain to become an active participant in the CFSI. Netlist actively engages with its suppliers to strengthen its relationship with them and Netlist has communicated to its suppliers its commitment to sourcing Conflict Minerals in a manner that does not benefit armed groups in the Covered Countries.
2. Identification and Assessment of Risks in the Supply Chain
Because of Netlist’s position within its supply chain, it is difficult for Netlist to identify actors upstream from its suppliers. As discussed above, Netlist identified each of its suppliers and Netlist has relied upon them to provide it with the necessary information about the source of Conflict Minerals contained in Covered Products. Netlist’s suppliers are similarly reliant upon information provided by their suppliers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products.
Netlist requested each of its suppliers to complete the CMRT and review the sourcing information provided in response to its requests for accuracy and completeness. In the event Netlist finds the responses to the CMRT unclear or incomplete, it contacts the supplier in question for additional information and clarification. Netlist intends to contact each of its suppliers at least once every six months to check on the status of their continuing due diligence and to obtain updated information. The Company records all information obtained from the CMRTs to identify the smelters and refiners in its supply chain. The Company compares the list of the smelters and refiners in its supply chain to the lists compiled by the CFSI to determine which smelters have been determined to be compliant with the CFSI assessment protocols.
3. Designing and Implementing a Strategy to Respond to Identified Risks
In response to this risk assessment, the Company is designing and implementing a management plan which will be managed and monitored through the above-described Conflict Minerals Team under the oversight of its manufacturing management. As noted above, the Company obtains information from the CFSI to identify smelters that provide material to its supply chain and to determine whether these smelters are compliant with the CFSI assessment protocols.
Netlist has communicated its expectation to all of Netlist’s suppliers that products and components supplied to Netlist which contain Conflict Minerals be DRC conflict free.
4. Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
The Company does not have a direct relationship with any smelters or refiners in its supply chain and, as a result, the Company does not directly conduct audits. Instead, Netlist will support the development and implementation of independent third party audits of smelters such as the CFSI by encouraging its contract manufacturers and component suppliers to purchase materials from audited, conflict-free smelters and to determine that smelters used to process these minerals are validated as conflict-free as part of the CFSI.
5. Reporting on Supply Chain Due Diligence
In 2015, Netlist publicly filed the Form SD and this Report with the SEC, and a copy of this Report and the Form SD are publicly available at www.netlist.com. The foregoing website reference is intended to be an inactive textual reference and the contents of the Company’s website are not incorporated into this report.
This Report includes information about the RCOI methodology utilized by the Company, the design of its due diligence process in conformance with the OECD Guidelines, the list of known smelters utilized in its supply chain identified in its due diligence process and a description of its products that incorporate conflict minerals necessary to the functionality or production of such Covered Products.
Findings
Based on the information that was provided by the Company’s suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products include the smelters and refiners listed below, including whether such smelters participate in the CFSI.
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Metal |
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Standard Smelter Name |
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Smelter ID |
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CFSI |
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Country |
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Gold |
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Advanced Chemical Company |
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CID000015 |
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AU |
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UNITED STATES |
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Gold |
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Aida Chemical Industries Co., Ltd. |
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CID000019 |
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CF |
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JAPAN |
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Gold |
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Aktyubinsk Copper Company TOO |
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CID000028 |
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AU |
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KAZAKHSTAN |
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Gold |
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Allgemeine Gold-und Silberscheideanstalt A.G. |
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CID000035 |
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CF |
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GERMANY |
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Gold |
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Almalyk Mining and Metallurgical Complex (AMMC) |
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CID000041 |
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AU |
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UZBEKISTAN |
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Gold |
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AngloGold Ashanti Córrego do Sítio Mineração |
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CID000058 |
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CF |
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BRAZIL |
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Gold |
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Argor-Heraeus SA |
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CID000077 |
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CF |
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SWITZERLAND |
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Gold |
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Asahi Pretec Corporation |
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CID000082 |
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CF |
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JAPAN |
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Gold |
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Asaka Riken Co., Ltd. |
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CID000090 |
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CF |
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JAPAN |
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Gold |
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ATAkulche |
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CID000103 |
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AU |
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TURKEY |
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Gold |
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Aurubis AG |
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CID000113 |
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CF |
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GERMANY |
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Gold |
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
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CID000128 |
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CF |
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PHILIPPINES |
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Gold |
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Boliden AB |
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CID000157 |
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CF |
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SWEDEN |
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Gold |
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C. Hafner GmbH + Co. KG |
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CID000176 |
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CF |
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GERMANY |
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Gold |
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Caridad |
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CID000180 |
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AU |
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MEXICO |
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Gold |
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CCR Refinery - Glencore Canada Corporation |
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CID000185 |
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CF |
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CANADA |
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Gold |
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Cendres + Métaux SA |
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CID000189 |
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AU |
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SWITZERLAND |
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Gold |
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CHALCO Yunnan Copper Co. Ltd. |
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CID000197 |
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AU |
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CHINA |
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Gold |
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Chimet S.p.A. |
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CID000233 |
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CF |
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ITALY |
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Gold |
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Chugai Mining |
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CID000264 |
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AU |
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JAPAN |
|
Gold |
|
Daejin Indus Co., Ltd. |
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CID000328 |
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AU |
|
KOREA, REPUBLIC OF |
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Gold |
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Daye Non-Ferrous Metals Mining Ltd. |
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CID000343 |
|
AU |
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CHINA |
|
Gold |
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Do Sung Corporation |
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CID000359 |
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AU |
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KOREA, REPUBLIC OF |
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Gold |
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Doduco |
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CID000362 |
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CF |
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GERMANY |
|
Gold |
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Dowa |
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CID000401 |
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CF |
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JAPAN |
|
Gold |
|
Eco-System Recycling Co., Ltd. |
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CID000425 |
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CF |
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JAPAN |
|
Gold |
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FSE Novosibirsk Refinery |
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CID000493 |
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CF |
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RUSSIAN FEDERATION |
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Gold |
|
Gansu Seemine Material Hi-Tech Co., Ltd. |
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CID000522 |
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AU |
|
CHINA |
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Gold |
|
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
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CID000651 |
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AU |
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CHINA |
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Gold |
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Hangzhou Fuchunjiang Smelting Co., Ltd. |
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CID000671 |
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AU |
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CHINA |
|
Gold |
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Heimerle + Meule GmbH |
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CID000694 |
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CF |
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GERMANY |
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Gold |
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Heraeus Ltd. Hong Kong |
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CID000707 |
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CF |
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CHINA |
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Gold |
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Heraeus Precious Metals GmbH & Co. KG |
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CID000711 |
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CF |
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GERMANY |
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Gold |
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Hunan Chenzhou Mining Co., Ltd. |
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CID000767 |
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AU |
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CHINA |
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Gold |
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Hwasung CJ Co., Ltd. |
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CID000778 |
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AU |
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KOREA, REPUBLIC OF |
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Gold |
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Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
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CID000801 |
|
CF |
|
CHINA |
|
Gold |
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Ishifuku Metal Industry Co., Ltd. |
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CID000807 |
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CF |
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JAPAN |
|
Gold |
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Istanbul Gold Refinery |
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CID000814 |
|
CF |
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TURKEY |
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Gold |
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Japan Mint |
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CID000823 |
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CF |
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JAPAN |
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Gold |
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JCC |
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CID000855 |
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CF |
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CHINA |
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Gold |
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Johnson Matthey Inc |
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CID000920 |
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CF |
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UNITED STATES |
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Gold |
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Asahi Refining Canada Limited |
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CID000924 |
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CF |
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CANADA |
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Gold |
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JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
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CID000927 |
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CF |
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RUSSIAN FEDERATION |
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Gold |
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JSC Uralelectromed |
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CID000929 |
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CF |
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RUSSIAN FEDERATION |
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Gold |
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JX Nippon Mining & Metals Co., Ltd. |
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CID000937 |
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CF |
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JAPAN |
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Gold |
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Kazakhmys Smelting LLC |
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CID000956 |
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AU |
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KAZAKHSTAN |
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Gold |
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Kazzinc |
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CID000957 |
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CF |
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KAZAKHSTAN |
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Gold |
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Kennecott Utah Copper LLC |
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CID000969 |
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CF |
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UNITED STATES |
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Gold |
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Kojima Chemicals Co., Ltd. |
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CID000981 |
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CF |
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JAPAN |
|
Gold |
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Korea Metal Co., Ltd. |
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CID000988 |
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AU |
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KOREA, REPUBLIC OF |
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Gold |
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Kyrgyzaltyn JSC |
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CID001029 |
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AU |
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KYRGYZSTAN |
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Gold |
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L’ azurde Company For Jewelry |
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CID001032 |
|
AU |
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SAUDI ARABIA |
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Gold |
|
Lingbao Gold Company Limited |
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CID001056 |
|
AU |
|
CHINA |
|
Gold |
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
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CID001058 |
|
AU |
|
CHINA |
|
Gold |
|
LS-NIKKO Copper Inc. |
|
CID001078 |
|
CF |
|
KOREA, REPUBLIC OF |
|
Gold |
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Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
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CID001093 |
|
AU |
|
CHINA |
|
Gold |
|
Materion |
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CID001113 |
|
CF |
|
UNITED STATES |
|
Gold |
|
Matsuda Sangyo Co., Ltd. |
|
CID001119 |
|
CF |
|
JAPAN |
|
Gold |
|
Metalor Technologies (Suzhou) Ltd. |
|
CID001147 |
|
AU |
|
CHINA |
|
Gold |
|
Metalor Technologies (Hong Kong) Ltd. |
|
CID001149 |
|
CF |
|
CHINA |
|
Gold |
|
Metalor Technologies (Singapore) Pte., Ltd. |
|
CID001152 |
|
CF |
|
SINGAPORE |
|
Gold |
|
Metalor Technologies SA |
|
CID001153 |
|
CF |
|
SWITZERLAND |
|
Gold |
|
Metalor USA Refining Corporation |
|
CID001157 |
|
CF |
|
UNITED STATES |
|
Gold |
|
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V |
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CID001161 |
|
CF |
|
MEXICO |
|
Gold |
|
Mitsubishi Materials Corporation |
|
CID001188 |
|
CF |
|
JAPAN |
|
Gold |
|
Mitsui Mining and Smelting Co., Ltd. |
|
CID001193 |
|
CF |
|
JAPAN |
|
Gold |
|
Moscow Special Alloys Processing Plant |
|
CID001204 |
|
CF |
|
RUSSIAN FEDERATION |
|
Gold |
|
Nadir Metal Rafineri San. Ve Tic. A.Ş. |
|
CID001220 |
|
CF |
|
TURKEY |
|
Gold |
|
Navoi Mining and Metallurgical Combinat |
|
CID001236 |
|
AU |
|
UZBEKISTAN |
|
Gold |
|
Nihon Material Co., Ltd. |
|
CID001259 |
|
CF |
|
JAPAN |
|
Gold |
|
Ohio Precious Metals, LLC |
|
CID001322 |
|
CF |
|
UNITED STATES |
|
Gold |
|
Ohura Precious Metal Industry Co., Ltd. |
|
CID001325 |
|
CF |
|
JAPAN |
|
Gold |
|
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
|
CID001326 |
|
CF |
|
RUSSIAN FEDERATION |
|
Gold |
|
PAMP SA |
|
CID001352 |
|
CF |
|
SWITZERLAND |
|
Gold |
|
Penglai Penggang Gold Industry Co., Ltd. |
|
CID001362 |
|
AU |
|
CHINA |
|
Gold |
|
Prioksky Plant of Non-Ferrous Metals |
|
CID001386 |
|
CF |
|
RUSSIAN FEDERATION |
|
Gold |
|
PT Aneka Tambang (Persero) Tbk |
|
CID001397 |
|
CF |
|
INDONESIA |
|
Gold |
|
PX Précinox SA |
|
CID001498 |
|
CF |
|
SWITZERLAND |
|
Gold |
|
Rand Refinery (Pty) Ltd. |
|
CID001512 |
|
CF |
|
SOUTH AFRICA |
|
Gold |
|
Royal Canadian Mint |
|
CID001534 |
|
CF |
|
CANADA |
|
Gold |
|
Sabin Metal Corp. |
|
CID001546 |
|
AU |
|
UNITED STATES |
|
Gold |
|
Samdok Metal |
|
CID001555 |
|
AU |
|
KOREA, REPUBLIC OF |
|
Gold |
|
SAMWON Metals Corp. |
|
CID001562 |
|
AU |
|
KOREA, REPUBLIC OF |
|
Gold |
|
Schone Edelmetaal B.V. |
|
CID001573 |
|
CF |
|
NETHERLANDS |
|
Gold |
|
SEMPSA Joyería Platería SA |
|
CID001585 |
|
CF |
|
SPAIN |
|
Gold |
|
Shandong Tarzan Bio-Gold Industry Co., Ltd. |
|
CID001619 |
|
AU |
|
CHINA |
|
Gold |
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
|
CID001622 |
|
CF |
|
CHINA |
|
Gold |
|
Sichuan Tianze Precious Metals Co., Ltd. |
|
CID001736 |
|
CF |
|
CHINA |
|
Gold |
|
Accurate Refining Group |
|
CID001754 |
|
AU |
|
UNITED STATES |
|
Gold |
|
SOE Shyolkovsky Factory of Secondary Precious Metals |
|
CID001756 |
|
CF |
|
RUSSIAN FEDERATION |
|
Gold |
|
Solar Applied Materials Technology Corp. |
|
CID001761 |
|
CF |
|
TAIWAN |
|
Gold |
|
Sumitomo Metal Mining Co., Ltd. |
|
CID001798 |
|
CF |
|
JAPAN |
|
Gold |
|
Tanaka Kikinzoku Kogyo K.K. |
|
CID001875 |
|
CF |
|
JAPAN |
|
Gold |
|
Great Wall Precious Metals Co,. LTD. |
|
CID001909 |
|
AU |
|
CHINA |
|
Gold |
|
The Refinery of Shandong Gold Mining Co., Ltd. |
|
CID001916 |
|
CF |
|
CHINA |
|
Gold |
|
Tokuriki Honten Co., Ltd. |
|
CID001938 |
|
CF |
|
JAPAN |
|
Gold |
|
Anhui Tongling Nonferrous Metal Mining Co., Ltd. |
|
CID001947 |
|
AU |
|
CHINA |
|
Gold |
|
Torecom |
|
CID001955 |
|
AU |
|
KOREA, REPUBLIC OF |
|
Gold |
|
Umicore Brasil Ltda. |
|
CID001977 |
|
CF |
|
BRAZIL |
|
Gold |
|
Umicore SA Business Unit Precious Metals Refining |
|
CID001980 |
|
CF |
|
BELGIUM |
|
Gold |
|
United Precious Metal Refining, Inc. |
|
CID001993 |
|
CF |
|
UNITED STATES |
|
Gold |
|
Valcambi SA |
|
CID002003 |
|
CF |
|
SWITZERLAND |
|
Gold |
|
Western Australian Mint trading as The Perth Mint |
|
CID002030 |
|
CF |
|
AUSTRALIA |
|
Gold |
|
Yamamoto Precious Metal Co., Ltd. |
|
CID002100 |
|
CF |
|
JAPAN |
|
Gold |
|
Yokohama Metal Co., Ltd. |
|
CID002129 |
|
CF |
|
JAPAN |
|
Gold |
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
|
CID002224 |
|
CF |
|
CHINA |
|
Gold |
|
Zijin Mining Group Co., Ltd. Gold Refinery |
|
CID002243 |
|
CF |
|
CHINA |
|
Gold |
|
Morris and Watson |
|
CID002282 |
|
AU |
|
NEW ZEALAND |
|
Gold |
|
Guangdong Gaoyao Co |
|
CID002312 |
|
AU |
|
CHINA |
|
Gold |
|
Umicore Precious Metals Thailand |
|
CID002314 |
|
CF |
|
THAILAND |
|
Gold |
|
Faggi Enrico S.p.A. |
|
CID002355 |
|
AU |
|
ITALY |
|
Gold |
|
Geib Refining Corporation |
|
CID002459 |
|
AU |
|
UNITED STATES |
|
Gold |
|
MMTC-PAMP India Pvt., Ltd. |
|
CID002509 |
|
CF |
|
INDIA |
|
Gold |
|
Republic Metals Corporation |
|
CID002510 |
|
CF |
|
UNITED STATES |
|
Gold |
|
KGHM Polska Miedź Spółka Akcyjna |
|
CID002511 |
|
AU |
|
POLAND |
|
Gold |
|
Singway Technology Co., Ltd. |
|
CID002516 |
|
CF |
|
TAIWAN |
|
Gold |
|
T.C.A S.p.A |
|
CID002580 |
|
CF |
|
ITALY |
|
Gold |
|
Korea Zinc Co. Ltd. |
|
CID002605 |
|
AU |
|
KOREA, REPUBLIC OF |
|
Gold |
|
SAXONIA Edelmetalle GmbH |
|
CID002777 |
|
AU |
|
GERMANY |
|
Gold |
|
WIELAND Edelmetalle GmbH |
|
CID002778 |
|
AU |
|
GERMANY |
|
Gold |
|
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
|
CID002779 |
|
CF |
|
AUSTRIA |
|
Tantalum |
|
Changsha South Tantalum Niobium Co., Ltd. |
|
CID000211 |
|
AU |
|
CHINA |
|
Tantalum |
|
Conghua Tantalum and Niobium Smeltry |
|
CID000291 |
|
CF |
|
CHINA |
|
Tantalum |
|
Douluoshan Sapphire Rare Metal Co Ltd |
|
CID000410 |
|
CF |
|
CHINA |
|
Tantalum |
|
Exotech Inc. |
|
CID000456 |
|
CF |
|
UNITED STATES |
|
Tantalum |
|
F & X |
|
CID000460 |
|
CF |
|
CHINA |
|
Tantalum |
|
Guangdong Zhiyuan New Material Co., Ltd. |
|
CID000616 |
|
CF |
|
CHINA |
|
Tantalum |
|
H.C. Starck Group |
|
CID000654 |
|
AU |
|
GERMANY |
|
Tantalum |
|
Hi-Temp |
|
CID000731 |
|
CF |
|
UNITED STATES |
|
Tantalum |
|
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
|
CID000914 |
|
CF |
|
CHINA |
|
Tantalum |
|
Jiujiang Tanbre Co., Ltd. |
|
CID000917 |
|
CF |
|
CHINA |
|
Tantalum |
|
King-Tan Tantalum Industry Ltd. |
|
CID000973 |
|
CF |
|
CHINA |
|
Tantalum |
|
LSM Brasil S.A. |
|
CID001076 |
|
CF |
|
BRAZIL |
|
Tantalum |
|
Metallurgical Products India Pvt. Ltd. (MPIL) |
|
CID001163 |
|
CF |
|
INDIA |
|
Tantalum |
|
Mineração Taboca S.A. |
|
CID001175 |
|
CF |
|
BRAZIL |
|
Tantalum |
|
Mitsui Mining & Smelting |
|
CID001192 |
|
CF |
|
JAPAN |
|
Tantalum |
|
Molycorp Silmet A.S. |
|
CID001200 |
|
CF |
|
ESTONIA |
|
Tantalum |
|
Ningxia Orient Tantalum Industry Co., Ltd. |
|
CID001277 |
|
CF |
|
CHINA |
|
Tantalum |
|
QuantumClean |
|
CID001508 |
|
CF |
|
UNITED STATES |
|
Tantalum |
|
RFH |
|
CID001522 |
|
CF |
|
CHINA |
|
Tantalum |
|
Solikamsk |
|
CID001769 |
|
CF |
|
RUSSIAN FEDERATION |
|
Tantalum |
|
Taki Chemicals |
|
CID001869 |
|
CF |
|
JAPAN |
|
Tantalum |
|
Telex Metals |
|
CID001891 |
|
CF |
|
UNITED STATES |
|
Tantalum |
|
ULBA |
|
CID001969 |
|
CF |
|
KAZAKHSTAN |
|
Tantalum |
|
Zhuzhou Cemented Carbide |
|
CID002232 |
|
CF |
|
CHINA |
|
Tantalum |
|
Yichun Jin Yang Rare Metal Co., Ltd. |
|
CID002307 |
|
CF |
|
CHINA |
|
Tantalum |
|
Hengyang King Xing Lifeng New Materials Co., Ltd. |
|
CID002492 |
|
CF |
|
CHINA |
|
Tantalum |
|
D Block Metals, LLC |
|
CID002504 |
|
CF |
|
UNITED STATES |
|
Tantalum |
|
FIR Metals & Resource Ltd. |
|
CID002505 |
|
CF |
|
CHINA |
|
Tantalum |
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
|
CID002506 |
|
CF |
|
CHINA |
|
Tantalum |
|
XinXing HaoRong Electronic Material Co., Ltd. |
|
CID002508 |
|
CF |
|
CHINA |
|
Tantalum |
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
|
CID002512 |
|
CF |
|
CHINA |
|
Tantalum |
|
KEMET Blue Metals |
|
CID002539 |
|
CF |
|
MEXICO |
|
Tantalum |
|
Plansee SE Liezen |
|
CID002540 |
|
CF |
|
AUSTRIA |
|
Tantalum |
|
H.C. Starck Co., Ltd. |
|
CID002544 |
|
CF |
|
THAILAND |
|
Tantalum |
|
H.C. Starck GmbH Goslar |
|
CID002545 |
|
CF |
|
GERMANY |
|
Tantalum |
|
H.C. Starck GmbH Laufenburg |
|
CID002546 |
|
CF |
|
GERMANY |
|
Tantalum |
|
H.C. Starck Hermsdorf GmbH |
|
CID002547 |
|
CF |
|
GERMANY |
|
Tantalum |
|
H.C. Starck Inc. |
|
CID002548 |
|
CF |
|
UNITED STATES |
|
Tantalum |
|
H.C. Starck Ltd. |
|
CID002549 |
|
CF |
|
JAPAN |
|
Tantalum |
|
H.C. Starck Smelting GmbH & Co.KG |
|
CID002550 |
|
CF |
|
GERMANY |
|
Tantalum |
|
Plansee SE Reutte |
|
CID002556 |
|
CF |
|
AUSTRIA |
|
Tantalum |
|
Global Advanced Metals Boyertown |
|
CID002557 |
|
CF |
|
UNITED STATES |
|
Tantalum |
|
Global Advanced Metals Aizu |
|
CID002558 |
|
CF |
|
JAPAN |
|
Tantalum |
|
KEMET Blue Powder |
|
CID002568 |
|
CF |
|
UNITED STATES |
|
Tantalum |
|
Tranzact, Inc. |
|
CID002571 |
|
CF |
|
UNITED STATES |
|
Tin |
|
Chenzhou Yun Xiang mining limited liability company |
|
CID000228 |
|
AU |
|
CHINA |
|
Tin |
|
China Rare Metal Material Co., Ltd. |
|
CID000244 |
|
CF |
|
CHINA |
|
Tin |
|
CNMC (Guangxi) PGMA Co., Ltd. |
|
CID000278 |
|
AU |
|
CHINA |
|
Tin |
|
Alpha |
|
CID000292 |
|
CF |
|
UNITED STATES |
|
Tin |
|
Cooper Santa |
|
CID000295 |
|
CF |
|
BRAZIL |
|
Tin |
|
CV Gita Pesona |
|
CID000306 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Justindo |
|
CID000307 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Aries Kencana Sejahtera |
|
CID000309 |
|
CF |
|
INDONESIA |
|
Tin |
|
CV Serumpun Sebalai |
|
CID000313 |
|
CF |
|
INDONESIA |
|
Tin |
|
CV United Smelting |
|
CID000315 |
|
CF |
|
INDONESIA |
|
Tin |
|
Dowa |
|
CID000402 |
|
CF |
|
JAPAN |
|
Tin |
|
EM Vinto |
|
CID000438 |
|
CF |
|
BOLIVIA |
|
Tin |
|
Estanho de Rondônia S.A. |
|
CID000448 |
|
AU |
|
BRAZIL |
|
Tin |
|
Feinhütte Halsbrücke GmbH |
|
CID000466 |
|
AU |
|
GERMANY |
|
Tin |
|
Fenix Metals |
|
CID000468 |
|
CF |
|
POLAND |
|
Tin |
|
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
|
CID000538 |
|
CF |
|
CHINA |
|
Tin |
|
Gejiu Zi-Li |
|
CID000555 |
|
AU |
|
CHINA |
|
Tin |
|
Huichang Jinshunda Tin Co., Ltd. |
|
CID000760 |
|
AU |
|
CHINA |
|
Tin |
|
Gejiu Kai Meng Industry and Trade LLC |
|
CID000942 |
|
AU |
|
CHINA |
|
Tin |
|
Linwu Xianggui Ore Smelting Co., Ltd. |
|
CID001063 |
|
AU |
|
CHINA |
|
Tin |
|
China Tin Group Co., Ltd. |
|
CID001070 |
|
CF |
|
CHINA |
|
Tin |
|
Malaysia Smelting Corporation (MSC) |
|
CID001105 |
|
CF |
|
MALAYSIA |
|
Tin |
|
Metallic Resources, Inc. |
|
CID001142 |
|
CF |
|
UNITED STATES |
|
Tin |
|
Mineração Taboca S.A. |
|
CID001173 |
|
CF |
|
BRAZIL |
|
Tin |
|
Minsur |
|
CID001182 |
|
CF |
|
PERU |
|
Tin |
|
Mitsubishi Materials Corporation |
|
CID001191 |
|
CF |
|
JAPAN |
|
Tin |
|
Jiangxi Nanshan |
|
CID001231 |
|
AU |
|
CHINA |
|
Tin |
|
O.M. Manufacturing (Thailand) Co., Ltd. |
|
CID001314 |
|
CF |
|
THAILAND |
|
Tin |
|
OMSA |
|
CID001337 |
|
CF |
|
BOLIVIA |
|
Tin |
|
PT Alam Lestari Kencana |
|
CID001393 |
|
AU |
|
INDONESIA |
|
Tin |
|
PT Artha Cipta Langgeng |
|
CID001399 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Babel Inti Perkasa |
|
CID001402 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Bangka Kudai Tin |
|
CID001409 |
|
AU |
|
INDONESIA |
|
Tin |
|
PT Bangka Timah Utama Sejahtera |
|
CID001416 |
|
AU |
|
INDONESIA |
|
Tin |
|
PT Bangka Tin Industry |
|
CID001419 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Belitung Industri Sejahtera |
|
CID001421 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT BilliTin Makmur Lestari |
|
CID001424 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Bukit Timah |
|
CID001428 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT DS Jaya Abadi |
|
CID001434 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Eunindo Usaha Mandiri |
|
CID001438 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Fang Di MulTindo |
|
CID001442 |
|
AU |
|
INDONESIA |
|
Tin |
|
PT Karimun Mining |
|
CID001448 |
|
AU |
|
INDONESIA |
|
Tin |
|
PT Mitra Stania Prima |
|
CID001453 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Panca Mega Persada |
|
CID001457 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Prima Timah Utama |
|
CID001458 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Refined Bangka Tin |
|
CID001460 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Sariwiguna Binasentosa |
|
CID001463 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Seirama Tin Investment |
|
CID001466 |
|
AU |
|
INDONESIA |
|
Tin |
|
PT Stanindo Inti Perkasa |
|
CID001468 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Sumber Jaya Indah |
|
CID001471 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Timah (Persero) Tbk Kundur |
|
CID001477 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Timah |
|
CID001482 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Pelat Timah Nusantara Tbk |
|
CID001486 |
|
AU |
|
INDONESIA |
|
Tin |
|
PT Tinindo Inter Nusa |
|
CID001490 |
|
CF |
|
INDONESIA |
|
Tin |
|
PT Tommy Utama |
|
CID001493 |
|
CF |
|
INDONESIA |
|
Tin |
|
Rui Da Hung |
|
CID001539 |
|
CF |
|
TAIWAN |
|
Tin |
|
Soft Metais Ltda. |
|
CID001758 |
|
CF |
|
BRAZIL |
|
Tin |
|
Thailand Smelting & Refining Co., Ltd |
|
CID001898 |
|
CF |
|
THAILAND |
|
Tin |
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
|
CID001908 |
|
AU |
|
CHINA |
|
Tin |
|
VQB Mineral and Trading Group JSC |
|
CID002015 |
|
CF |
|
VIET NAM |
|
Tin |
|
White Solder Metalurgia e Mineração Ltda. |
|
CID002036 |
|
CF |
|
BRAZIL |
|
Tin |
|
Yunnan Chengfeng |
|
CID002158 |
|
AU |
|
CHINA |
|
Tin |
|
Yunnan Tin Company, Ltd. |
|
CID002180 |
|
CF |
|
CHINA |
|
Tin |
|
CV Venus Inti Perkasa |
|
CID002455 |
|
CF |
|
INDONESIA |
|
Tin |
|
Magnu’s Minerais Metais e Ligas Ltda. |
|
CID002468 |
|
CF |
|
BRAZIL |
|
Tin |
|
PT Tirus Putra Mandiri |
|
CID002478 |
|
AU |
|
INDONESIA |
|
Tin |
|
PT Wahana Perkit Jaya |
|
CID002479 |
|
CF |
|
INDONESIA |
|
Tin |
|
Melt Metais e Ligas S/A |
|
CID002500 |
|
CF |
|
BRAZIL |
|
Tin |
|
PT ATD Makmur Mandiri Jaya |
|
CID002503 |
|
CF |
|
INDONESIA |
|
Tin |
|
Phoenix Metal Ltd. |
|
CID002507 |
|
AU |
|
RWANDA |
|
Tin |
|
O.M. Manufacturing Philippines, Inc. |
|
CID002517 |
|
CF |
|
PHILIPPINES |
|
Tin |
|
PT Inti Stania Prima |
|
CID002530 |
|
CF |
|
INDONESIA |
|
Tin |
|
CV Ayi Jaya |
|
CID002570 |
|
CF |
|
INDONESIA |
|
Tin |
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
|
CID002572 |
|
AU |
|
VIET NAM |
|
Tin |
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
|
CID002573 |
|
AU |
|
VIET NAM |
|
Tin |
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
|
CID002574 |
|
AU |
|
VIET NAM |
|
Tin |
|
PT Cipta Persada Mulia |
|
CID002696 |
|
CF |
|
INDONESIA |
|
Tin |
|
An Vinh Joint Stock Mineral Processing Company |
|
CID002703 |
|
AU |
|
VIET NAM |
|
Tin |
|
Resind Indústria e Comércio Ltda. |
|
CID002706 |
|
CF |
|
BRAZIL |
|
Tin |
|
Metallo-Chimique N.V. |
|
CID002773 |
|
CF |
|
BELGIUM |
|
Tin |
|
Elmet S.L.U. (Metallo Group) |
|
CID002774 |
|
CF |
|
SPAIN |
|
Tin |
|
PT Bangka Prima Tin |
|
CID002776 |
|
CF |
|
INDONESIA |
|
Tungsten |
|
A.L.M.T. TUNGSTEN Corp. |
|
CID000004 |
|
CF |
|
JAPAN |
|
Tungsten |
|
Kennametal Huntsville |
|
CID000105 |
|
CF |
|
UNITED STATES |
|
Tungsten |
|
Guangdong Xianglu Tungsten Co., Ltd. |
|
CID000218 |
|
CF |
|
CHINA |
|
Tungsten |
|
Chongyi Zhangyuan Tungsten Co., Ltd. |
|
CID000258 |
|
CF |
|
CHINA |
|
Tungsten |
|
Dayu Weiliang Tungsten Co., Ltd. |
|
CID000345 |
|
AU |
|
CHINA |
|
Tungsten |
|
Fujian Jinxin Tungsten Co., Ltd. |
|
CID000499 |
|
CF |
|
CHINA |
|
Tungsten |
|
Global Tungsten & Powders Corp. |
|
CID000568 |
|
CF |
|
UNITED STATES |
|
Tungsten |
|
HC Starck GmbH |
|
CID000683 |
|
AU |
|
GERMANY |
|
Tungsten |
|
Hunan Chenzhou Mining Co., Ltd. |
|
CID000766 |
|
CF |
|
CHINA |
|
Tungsten |
|
Hunan Chunchang Nonferrous Metals Co., Ltd. |
|
CID000769 |
|
CF |
|
CHINA |
|
Tungsten |
|
Japan New Metals Co., Ltd. |
|
CID000825 |
|
CF |
|
JAPAN |
|
Tungsten |
|
Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
|
CID000868 |
|
AU |
|
CHINA |
|
Tungsten |
|
Ganzhou Huaxing Tungsten Products Co., Ltd. |
|
CID000875 |
|
CF |
|
CHINA |
|
Tungsten |
|
Kennametal Fallon |
|
CID000966 |
|
AU |
|
UNITED STATES |
|
Tungsten |
|
Tejing (Vietnam) Tungsten Co., Ltd. |
|
CID001889 |
|
CF |
|
VIET NAM |
|
Tungsten |
|
Vietnam Youngsun Tungsten Industry Co., Ltd. |
|
CID002011 |
|
CF |
|
VIET NAM |
|
Tungsten |
|
Wolfram Bergbau und Hütten AG |
|
CID002044 |
|
CF |
|
AUSTRIA |
|
Tungsten |
|
Xiamen Tungsten Co., Ltd. |
|
CID002082 |
|
CF |
|
CHINA |
|
Tungsten |
|
Shaoguan Xinhai Rendan Tungsten Industry Co. Ltd |
|
CID002095 |
|
CF |
|
CHINA |
|
Tungsten |
|
Zhuzhou Cemented Carbide Group Co Ltd |
|
CID002236 |
|
AU |
|
CHINA |
|
Tungsten |
|
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
|
CID002313 |
|
AU |
|
CHINA |
|
Tungsten |
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
|
CID002315 |
|
CF |
|
CHINA |
|
Tungsten |
|
Jiangxi Yaosheng Tungsten Co., Ltd. |
|
CID002316 |
|
AU |
|
CHINA |
|
Tungsten |
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
|
CID002317 |
|
AU |
|
CHINA |
|
Tungsten |
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
|
CID002318 |
|
AU |
|
CHINA |
|
Tungsten |
|
Malipo Haiyu Tungsten Co., Ltd. |
|
CID002319 |
|
CF |
|
CHINA |
|
Tungsten |
|
Xiamen H.C. |
|
CID002320 |
|
CF |
|
CHINA |
|
Tungsten |
|
Jiangxi Gan Bei Tungsten Co., Ltd. |
|
CID002321 |
|
CF |
|
CHINA |
|
Tungsten |
|
Ganzhou Seadragon W & Mo Co., Ltd. |
|
CID002494 |
|
CF |
|
CHINA |
|
Tungsten |
|
Asia Tungsten Products Vietnam Ltd. |
|
CID002502 |
|
CF |
|
VIET NAM |
|
Tungsten |
|
Chenzhou Diamond Tungsten Products Co., Ltd. |
|
CID002513 |
|
CF |
|
CHINA |
|
Tungsten |
|
Dayu Jincheng Tungsten Industry Co., Ltd. |
|
CID002518 |
|
AU |
|
CHINA |
|
Tungsten |
|
Ganxian Shirui New Material Co., Ltd. |
|
CID002531 |
|
AU |
|
CHINA |
|
Tungsten |
|
Pobedit, JSC |
|
CID002532 |
|
AU |
|
RUSSIAN FEDERATION |
|
Tungsten |
|
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
|
CID002535 |
|
CF |
|
CHINA |
|
Tungsten |
|
Ganzhou Yatai Tungsten Co., Ltd. |
|
CID002536 |
|
CF |
|
CHINA |
|
Tungsten |
|
Sanher Tungsten Vietnam Co., Ltd. |
|
CID002538 |
|
AU |
|
VIET NAM |
|
Tungsten |
|
H.C. Starck GmbH |
|
CID002541 |
|
CF |
|
GERMANY |
|
Tungsten |
|
H.C. Starck Smelting GmbH & Co.KG |
|
CID002542 |
|
CF |
|
GERMANY |
|
Tungsten |
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
|
CID002543 |
|
CF |
|
VIET NAM |
|
Tungsten |
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
|
CID002551 |
|
AU |
|
CHINA |
|
Tungsten |
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin |
|
CID002578 |
|
AU |
|
CHINA |
|
Tungsten |
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
|
CID002579 |
|
CF |
|
CHINA |
|
Tungsten |
|
Niagara Refining LLC |
|
CID002589 |
|
CF |
|
UNITED STATES |
|
Tungsten |
|
Hydrometallurg, JSC |
|
CID002649 |
|
CF |
|
RUSSIAN FEDERATION |
“CF” indicates that as of May 15, 2015, the smelter participates in the CFSI and has been certified and audited by the CFSI.
“AU” indicates that the smelter has agreed to participate in the CFSI, but that as of May 15, 2015, the audit process has not yet been completed.
Conclusion
After exercising the due diligence described above, the Company was unable to determine whether or not each of the Covered Products qualify as “DRC conflict free,” as defined under the Rule.
Future Steps
The Company has communicated its expectations regarding the use of Conflict Minerals to its suppliers. Since the end of 2015, the Company has engaged with its suppliers to update their information on the source and chain of custody of Conflict Minerals in supply chain and to require that all smelters utilized agree to participate in the CFSI.
The Company aims to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Covered Products finance or benefit armed groups (perpetrator of serious human rights abuses) in the Covered Countries:
· Enhancing its employee training relating to the Rule, the Company Policy and the Company’s procedures to identify and work with in-scope suppliers.
· Continuing to engage with suppliers to help them better understand the Rule and the Company Policy and to obtain accurate and complete information about the origin of Conflict Minerals in the Company’s supply chain, including improving the quality of the processing facility data provided by suppliers.
· Seeking opportunities to assist suppliers in building capabilities with a view to improving due diligence performance.
· Beginning an initiative to include language in its new supply contracts that requires suppliers to comply with the Company Policy.
· Engaging in industry initiatives encouraging conflict-free supply chains.
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of Conflict Minerals, Netlist’s due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals in or used to produce Netlist’s products. Netlist’s due diligence processes necessarily rely on the data supplied by its direct suppliers. Those direct suppliers, in turn, rely on similar information provided within their supply chains to identify the original sources of the Conflict Minerals. In addition, Netlist relies on information collected and provided by independent third-party audit programs.
Forward-Looking Statements
This Report contains forward-looking statements regarding the Company’s business, products and Conflict Minerals efforts, including steps the Company intends to take to mitigate the risk that Conflict Minerals in its products finance or benefit armed groups in the Covered Countries. Words such as “expects,” “believes,” “aims” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this Report. Additionally, statements concerning future matters that are not historical are forward-looking statements. Although forward-looking statements in this Report reflect the Company’s good faith judgment, such statements can only be based on facts and assumptions currently known by the Company. Consequently, forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include, among others: the risk that information reported to the Company by its suppliers, or industry information used by the Company, may be inaccurate; the risk that mines, smelters or refiners may not participate in the CFSP, which is a voluntary initiative; as well as risks discussed under the heading “Risk Factors” in the Company’s most recent Quarterly Report on Form 10-Q related to Conflict Minerals. Readers are urged not to place undue reliance on forward-looking statements, which speak only as of the date of this Report. The Company undertakes no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this Report.