twin20240529_sd.htm

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

 

 

FORM SD

(Specialized Disclosure Report)

 

 

TWIN DISC, INCORPORATED

(Exact name of registrant as specified in its charter)

 

Wisconsin

1-7635

390667110

(State or other jurisdiction of

(Commission File No.)

(I.R.S. Employer

incorporation or organization)

 

Identification No.)

     
     
     

222 E. Erie Street, Milwaukee, Wi.

 

53202

(Address of principal executive offices)

 

(Zip Code)

     
     

Jeffrey S. Knutson (262) 638-4000

 

(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:

 

☑ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.

 

1

 

 

Section 1

Conflict Minerals Disclosures

 

Item 1.01

Conflict Minerals Disclosure and Report

 

This Specialized Disclosure Report on Form SD (the "Report") is intended to satisfy the filing obligations of Twin Disc, Incorporated (the "Company") pursuant to Rule 13p-1 (the "Rule") under the Securities and Exchange Act of 1934 for the full calendar year of 2023. Terms not defined herein shall have the meanings assigned to such terms in Form SD and the Conflict Minerals Final Rule (SEC Release No. 34-67716, August 22, 2012).

 

The Company first determined that Conflict Minerals are necessary to the functionality or production of a product manufactured by the Company or contracted to be manufactured by the Company. Although the Company does not itself intentionally add Conflict Minerals to the products it manufactures, it concluded certain components of products it receives from suppliers that are incorporated into products it manufactures likely contain Conflict Minerals that are necessary to functionality or production of the Company's products.

 

Accordingly, the Company performed a good faith reasonable country of origin inquiry ("RCOI") to determine whether the necessary Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country (the "Conflict Region") or were from recycled or scrap sources. In reviewing the results from its RCOI, the Company has reason to believe that certain of its necessary Conflict Minerals originated, or may have originated, in the Conflict Region and are not from recycled or scrap sources. These Conflict Minerals were subject to the exercise of due diligence by the Company as described in the Conflict Minerals Report attached as an exhibit hereto. A copy of the Company's Conflict Minerals Report is publicly available at http://ir.twindisc.com/financial-information/sec-filings

 

Item 1.02

Exhibit

 

The Company has filed, as an exhibit to this Form SD, the Conflict Minerals Report for the year ended December 31, 2023, as required by Item 1.01 and 1.02 of this Form.

 

Section 2

Exhibits

 

Item 2.01.

Exhibits

 

Exhibit No.

Description of Exhibit

 

1.01

Conflict Minerals Report for the year ended December 31, 2023, as required by Items 1.01 and 1.02 of this Form.

 

 

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.

 

 

TWIN DISC, INCORPORATED

   
   
   

Date: May 30, 2024

/s/ JEFFREY S. KNUTSON

 

Jeffrey S. Knutson

 

Vice President – Finance, Chief Financial Officer,

 

Treasurer and Secretary

   

 

2

Exhibit 1.01

 

TWIN DISC, INCORPORATED

CONFLICT MINERALS REPORT

FOR THE YEAR ENDED DECEMBER 31, 2023

 

I.

Overview

 

This is the Conflict Minerals Report of Twin Disc, Incorporated ("Twin Disc" or the "Company") for the year ended December 31, 2023, pursuant to Rule 13p-1 (the "Rule") under the Securities and Exchange Act of 1934 (the "Exchange Act"). Terms not defined herein shall have the meanings assigned to such terms in Form SD and the Conflict Minerals Final Rule (SEC Release No. 34-67716, August 22, 2012).

 

The Company designs, manufactures and sells marine and heavy-duty off-highway power transmission equipment. Products offered include marine transmissions, azimuth drives, surface drives, propellers and boat management systems, as well as power-shift transmissions, hydraulic torque converters, power take-offs, industrial clutches and control systems. The Company sells its products to customers primarily in the pleasure craft, commercial and military marine markets, as well as in the energy and natural resources, government and industrial markets. The Company's worldwide sales to both domestic and foreign customers are transacted through a direct sales force and a distributor network.         

 

As described in more detail below, the Company performed a good faith reasonable country of origin inquiry ("RCOI") to determine whether the necessary Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country or were from recycled or scrap sources. In reviewing the results from its RCOI, the Company has reason to believe that certain of its necessary Conflict Minerals originated, or may have originated, in the Democratic Republic of the Congo or an adjoining country and are not from recycled or scrap sources. These Conflict Minerals were subject to the exercise of due diligence by the Company as described herein.

 

II.

Policy on Conflict Minerals

 

The Company has adopted the following Conflict Minerals Policy, which is also published on the Company's website at https://ir.twindisc.com/governance/documents-and-charters:

 

Introduction to the Conflict Minerals Rule

 

On August 22, 2012, the U.S. Securities and Exchange Commission approved the final rule on conflict minerals with the desired objective of ending human-rights atrocities and the financing of armed conflict in the Democratic Republic of the Congo (DRC) and adjoining countries. The conflict minerals rule requires all public companies, such as Twin Disc, to determine whether tin, tantalum, tungsten, gold, and their related derivatives (Conflict Minerals) are necessary to the functionality or production of products they manufacture or contract to manufacture, and, if so, whether such Conflict Minerals originated from the DRC or adjoining countries. While the burden of the rule's inquiry and disclosure obligations rests with public companies, all members within the supply chain network of each public Company are also impacted.

 

What Twin Disc is Doing

 

As a responsible global corporate citizen, Twin Disc is committed to promoting human rights in the DRC and adjoining countries. To accomplish these objectives, Twin Disc will:

 

 

Gather information from its suppliers aimed at identifying the source of any Conflict Minerals in the products it manufactures or contracts to manufacture.

 

 

Enhance its supply chain due diligence measures, which will conform to a due diligence framework consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or other nationally or internationally recognized framework.

 

 

1

 

 

Comply with the requirements of the SEC's conflict minerals rule.

 

Twin Disc's Expectations for Suppliers

 

To ensure compliance with its conflict minerals policy, the Company expects each of its suppliers to:

 

 

Make reasonable inquiries as to the country of origin of any Conflict Minerals in products it delivers to the Company and require the same of all upstream suppliers.

 

 

Conduct due diligence to confirm whether Conflict Minerals were sourced from a conflict-free source.

 

 

Thoroughly document its due diligence efforts to determine that any materials and products containing Conflict Minerals are DRC conflict free.

 

 

Timely, completely, and accurately respond to the Company's Conflict Minerals Country of Origin Questionnaire and any follow-up inquiries.

 

The Company evaluates its relationships with its suppliers on an ongoing basis. In the event it determines that a supplier has failed to comply with the requirements of this conflict minerals policy, the Company reserves the right to take appropriate action(s) to address the noncompliance, which may include discontinuing its business relationship with such supplier.

 

Comments or Questions

 

Any comments, questions, or concerns regarding Twin Disc's conflict minerals policy should be addressed to: Ross Miller, Twin Disc, Incorporated, (262) 638-4344.

 

III.

Supply Chain

 

The Company is a downstream manufacturer and is many steps removed from smelters and refiners that process minerals and ore. The Company does not purchase raw ore or unrefined Conflict Minerals and does not, to the best of its knowledge, directly purchase any Conflict Minerals from any of the Covered Countries. As a result, the Company relies on its direct suppliers to provide origin information on Conflict Minerals contained in components or materials shipped to the Company. Similarly, the Company's direct suppliers may rely on their suppliers for such information.

 

IV.

Reasonable Country of Origin Inquiry

 

The Company first determined that Conflict Minerals are necessary to the functionality or production of a product manufactured by the Company or contracted to be manufactured by the Company. Although the Company does not itself intentionally add Conflict Minerals to the products that it manufactures, it concluded that certain components of products that it receives from suppliers that are incorporated into products that it manufactures likely contain Conflict Minerals that are necessary to functionality or production of the Company's products.

 

Accordingly, the Company performed a good faith reasonable country of origin inquiry ("RCOI") to determine whether the necessary Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country or were from recycled or scrap sources. To begin the RCOI, the Company's engineering group reviewed the Company's product portfolio for items that could include any of the Conflict Minerals. This was performed at each of the Company's manufacturing entities, with guidance provided by the engineering group of the Company's main corporate office where necessary. Once the products were identified, the engineering group provided a list of suppliers of these products to the Company's purchasing group.

 

2

 

The Company's purchasing or customer service group then sent out a Conflict Minerals Reporting Template ("CMRT") to each of the suppliers identified through the above process. The CMRT is a standardized reporting template developed by the Responsible Minerals Initiative ("RMI") (established by the Responsible Business Alliance or "RBA", a coalition dedicated to improving social, environmental, and ethical conditions in supply chains) that facilitates the transfer of information through the supply chain regarding mineral country of origin and smelters and refiners being utilized.  The CMRT solicits responses to the following questions: whether: (1) any Conflict Minerals are intentionally added to the products that were supplied to the Company; (2) any of the Conflict Minerals are necessary to the functionality of the supplier's products that were supplied to the Company; (3) any necessary Conflict Minerals originated from the Democratic Republic of the Congo or an adjoining country; (4) the supplier has smelters in its supply chain that source Conflict Minerals from conflict-affected and high risk areas; (5) 100% of the necessary Conflict Minerals originated from recycled or scrap sources; (6) the supplier has determined the supply chain response percentage from all relevant suppliers; (7) the supplier identified all of the smelters the supplier and its suppliers use to supply the necessary Conflict Minerals; (8) the supplier has received and reported supply chain data/information regarding the necessary Conflict Minerals from all relevant suppliers; (9) the supplier has a policy in place that includes responsible mineral sourcing; and (10) the supplier has implemented specified country of origin inquiries and/or due diligence measures for DRC conflict-free sourcing. The Company kept track of the responses it received and followed up on a regular basis with suppliers that did not respond and with suppliers whose responses were deemed insufficient, assessed whether it was reasonable to rely on the suppliers' responses to the questionnaires, and sought to identify warning signs or red flags that would require the Company to engage in due diligence under the Conflict Minerals Final Rule.

 

As of the date of this Report, the Company has received meaningful responses from 56% of the 102 suppliers that received questionnaires. Most of the Company's suppliers provided data in response to the Company's RCOI at the supplier company level or a division/segment level, rather than at a level directly relating to a part number that the supplier provides to the Company. The Company was therefore unable to conclusively determine whether any of the Conflict Minerals that these suppliers reported was contained in components or parts that the suppliers provided to the Company or whether any of the smelters and refiners identified by these suppliers are actually in the Company's supply chain. It has been inherently difficult to ascertain the ultimate source of Conflict Minerals in products the Company manufactures.

 

Seventeen suppliers whose components were incorporated into products manufactured by the Company in 2023 indicated their products contained tin, tantalum, tungsten, or gold that may have originated in the DRC or a surrounding country and were not from recycled or scrap sources. These suppliers provided the names of the smelters that they source from to the extent they are known or have been disclosed to the suppliers. The Company compared these smelter names against those listed as conformant on the website www.responsiblemineralsinitiative.org and was able to confirm that some of the smelters identified by these suppliers are, in fact, conformant with the Responsible Minerals Assurance Process assessment protocols (RMAP), a program that uses third party independent auditors to validate that participating smelters and refiners have adequate policies and due diligence processes in place to trace the origin of the minerals that they process and assess whether they were obtained from conflict free sources, established by the RBA. The Company was not able to confirm whether the other smelters named by these suppliers are conflict-free. Also, the Company notes the suppliers themselves were unable to name the locations of some of the mines from which Conflict Minerals are sourced.

 

The supplier responses we received mentioned approximately 404 smelters (listed in Exhibit A) as potentially having processed the necessary conflict minerals in our products during 2023. The table below summarizes certain information pertaining to the 404 identified smelters:

 

Total number of identified smelters: 404         

Number of RMI "Conformant" smelters: 225

Number of RMI "Active" smelters: 8

Number of identified smelters not rated "Conformant" or "Active" (Unclassified): 171

 

As noted above, most of our suppliers indicated Conflict Minerals are present in their products responded at the company level, meaning they reported the smelter information for all of their products, not just for the products sold to the Company. As such, the list of identified smelters disclosed in Exhibit A likely contains more smelters than those that process or refine the necessary Conflict Minerals contained in the Company's products. The Company was therefore unable to determine with certainty the identity of all smelters used by our supply chain to process necessary Conflict Minerals for its products.

 

3

 

The responses to the Company's RCOI received from suppliers did not provide a compelling basis for the Company to conclude that Conflict Minerals in products supplied to the Company were from the DRC or a surrounding country, and/or whether or not they are conflict-free. To date, this process has not uncovered any additional red flags, but the process is ongoing.

 

V.

Due Diligence Processes

 

The Company's due diligence processes are designed to conform with the due diligence framework as described in the Organization for Economic Cooperation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Guidance") and the related Supplements for gold and for tin, tantalum and tungsten. The Company's due diligence efforts are set forth below:

 

Step 1:         Establish Strong Company Management Systems

 

As described above, the Company has adopted a Conflict Minerals Policy. In addition, the Company has established a management team relating to Conflict Minerals. The management team is overseen by the Manager of Global Compliance and Internal Audit, and includes Quality Assurance and Continuous Improvement personnel, and a Design Engineer of the Company. The Company has adopted detailed written procedures regarding its RCOI and due diligence, and these procedures assign specific tasks to specific members of the Conflict Minerals team. The Conflict Minerals team periodically reports to the Company's Chief Financial Officer, Treasurer and Secretary ("CFO") as well as to the Disclosure Committee, which includes the Company's CFO, the Vice President of Human Resources of the Company, the Corporate Controller of the Company, and the Manager of Global Compliance and Internal Audit Department of the Company. A representative from outside securities legal counsel for the Company also participates in the meetings and activities of the Disclosure Committee in an advisory capacity.

 

Step 2:         Identify and Assess Risks in Supply Chain

 

As described above, the Company engaged in a good-faith RCOI to determine whether the necessary Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country or were from recycled or scrap sources. With respect to suppliers that indicated that their products contained tin, tantalum, tungsten and/or gold that originated in the Democratic Republic of the Congo or a surrounding country and were not from recycled or scrap sources, the Company verified that the smelters and refiners identified by those suppliers are conformant with the Responsible Minerals Assurance Process assessment protocols established by the RBI. With respect to other suppliers, the Company is continuing the process of comparing the identified smelters and refiners with the RBA list of conformant smelters and refiners, beginning with the suppliers whose products the Company determined are most likely to contain Conflict Minerals.

 

Step 3:         Design and Implement a Risk Management Plan

 

The Company continued, and is continuing, to develop and execute processes to (i) identify suppliers that provide products to the Company that may contain Conflict Minerals, (ii) conduct a good faith RCOI of its supply chain, and (iii) engage in due diligence with respect to Conflict Minerals.

 

Step 4:         Independent Third-Party Audit of Smelters' or Refiners' Due Diligence Practices

 

The Company is a downstream manufacturer and is many steps removed from smelters and refiners who process minerals and ore. The Company does not purchase raw ore or unrefined Conflict Minerals and does not, to the best of its knowledge, directly purchase any Conflict Minerals from any of the Covered Countries. Therefore, the Company does not perform or direct audits of smelters and refiners within its supply chain.

 

4

 

Step 5:         Report Findings

 

This Conflict Minerals Report is being filed with the SEC as an exhibit to the Company's specialized disclosure report on Form SD and is publicly available on the Company's website at the following link: http://ir.twindisc.com/financial-information/sec-filings.

 

VI.

Due Diligence Results

 

The products manufactured by the Company that contain Conflict Minerals that may have originated in the Democratic Republic of the Congo or a surrounding country and are not from recycled or scrap sources include, but may not be limited to, electronic control systems and electronic components (such as sensors and valve coils) in transmissions and power take-offs. The Company's website, www.twindisc.com, contains detailed information describing these and other products that the Company manufactures. The information contained on the Company's website is not a part of, nor incorporated by reference into, this Conflict Minerals Report or the Specialized Disclosure Report on Form SD and shall not be deemed "filed" under the Exchange Act.

 

As a result of the Company's exercise of due diligence on the source and chain of custody of Conflict Minerals necessary to the functionality of products manufactured or contracted for manufacture by the Company during the year ended December 31, 2023, the Company has reason to believe that certain of its products have not been found to be DRC conflict free. Based on the due diligence performed, the Company is unable to fully determine the facilities used to process the Conflict Minerals or their country of origin. The Company's efforts to determine the mine(s) or location of origin with the greatest possible specificity included the use of the due diligence measures described above.

 

 

Exhibit A

 

Smelter Name

Country

5D PRODUCTION OU

ESTONIA

8853 S.P.A.

ITALY

A.L.M.T. TUNGSTEN CORP.

JAPAN

ABC REFINERY PTY LTD.

AUSTRALIA

ABINGTON RELDAN METALS, LLC

UNITED STATES

ACL METAIS EIRELI

BRAZIL

ADVANCED CHEMICAL COMPANY

UNITED STATES

AFRICAN GOLD REFINERY

UGANDA

AIDA CHEMICAL INDUSTRIES CO., LTD.

JAPAN

AL ETIHAD GOLD REFINERY DMCC

UNITED ARAB EMIRATES

ALBASTEEL INDUSTRIA E COMERCIO DE LIGAS PARA FUNDICAO LTD.

BRAZIL

ALBINO MOUNTINHO LDA.

PORTUGAL

ALEXY METALS

UNITED STATES

ALLGEMEINE GOLD-UND SILBERSCHEIDEANSTALT A.G.

GERMANY

ALMALYK MINING AND METALLURGICAL COMPLEX (AMMC)

UZBEKISTAN

ALPHA

UNITED STATES

AMG BRASIL

BRAZIL

AN VINH JOINT STOCK MINERAL PROCESSING COMPANY

VIET NAM

ANGLOGOLD ASHANTI CORREGO DO SITIO MINERACAO

BRAZIL

ARGOR-HERAEUS S.A.

SWITZERLAND

 

5

 

ARTEK LLC

RUSSIAN FEDERATION

ASAHI PRETEC CORP.

JAPAN

ASAHI REFINING CANADA LTD.

CANADA

ASAHI REFINING USA INC.

UNITED STATES

ASAKA RIKEN CO., LTD.

JAPAN

ASIA TUNGSTEN PRODUCTS VIETNAM LTD.

VIET NAM

ATASAY KUYUMCULUK SANAYI VE TICARET A.S.

TURKEY

AU TRADERS AND REFINERS

SOUTH AFRICA

AUGMONT ENTERPRISES PRIVATE LIMITED

INDIA

AURUBIS AG

GERMANY

AVON SPECIALTY METALS LTD

UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND

BANGALORE REFINERY

INDIA

BANGKO SENTRAL NG PILIPINAS (CENTRAL BANK OF THE PHILIPPINES)

PHILIPPINES

BOLIDEN AB

SWEDEN

C. HAFNER GMBH + CO. KG

GERMANY

C.I METALES PROCESADOS INDUSTRIALES SAS

COLOMBIA

CARIDAD

MEXICO

CCR REFINERY - GLENCORE CANADA CORPORATION

CANADA

CENDRES + METAUX S.A.

SWITZERLAND

CGR METALLOYS PVT LTD.

INDIA

CHANGSHA SOUTH TANTALUM NIOBIUM CO., LTD.

CHINA

CHENZHOU DIAMOND TUNGSTEN PRODUCTS CO., LTD.

CHINA

CHENZHOU YUNXIANG MINING AND METALLURGY CO., LTD.

CHINA

CHIFENG DAJINGZI TIN INDUSTRY CO., LTD.

CHINA

CHIMET S.P.A.

ITALY

CHINA MOLYBDENUM CO., LTD.

CHINA

CHINA TIN GROUP CO., LTD.

CHINA

CHONGYI ZHANGYUAN TUNGSTEN CO., LTD.

CHINA

CHUGAI MINING

JAPAN

CNMC (GUANGXI) PGMA CO., LTD.

CHINA

CRM FUNDICAO DE METAIS E COMERCIO DE EQUIPAMENTOS ELETRONICOS DO BRASIL LTDA

BRAZIL

CRM SYNERGIES

SPAIN

CRONIMET BRASIL LTDA

BRAZIL

CV AYI JAYA

INDONESIA

CV DUA SEKAWAN

INDONESIA

CV GITA PESONA

INDONESIA

CV UNITED SMELTING

INDONESIA

 

6

 

CV VENUS INTI PERKASA

INDONESIA

D BLOCK METALS, LLC

UNITED STATES

DAEJIN INDUS CO., LTD.

KOREA, REPUBLIC OF

DAYE NON-FERROUS METALS MINING LTD.

CHINA

DEGUSSA SONNE / MOND GOLDHANDEL GMBH

GERMANY

DIJLLAH GOLD REFINERY FZC

UNITED ARAB EMIRATES

DODUCO CONTACTS AND REFINING GMBH

GERMANY

DONGGUAN CIEXPO ENVIRONMENTAL ENGINEERING CO., LTD.

CHINA

DONGWU GOLD GROUP

CHINA

DOWA

JAPAN

DRAGON SILVER HOLDINGS LIMITED

CHINA

DS MYANMAR

MYANMAR

DSC (DO SUNG CORPORATION)

KOREA, REPUBLIC OF

DUOLUOSHAN

CHINA

ECO-SYSTEM RECYCLING CO., LTD. EAST PLANT

JAPAN

ECO-SYSTEM RECYCLING CO., LTD. NORTH PLANT

JAPAN

ECO-SYSTEM RECYCLING CO., LTD. WEST PLANT

JAPAN

ELECTRO-MECHANICAL FACILITY OF THE CAO BANG MINERALS & METALLURGY JOINT STOCK COMPANY

VIET NAM

ELEMETAL REFINING, LLC

UNITED STATES OF AMERICA

EM VINTO

BOLIVIA

EMERALD JEWEL INDUSTRY INDIA LIMITED (UNIT 1)

INDIA

EMERALD JEWEL INDUSTRY INDIA LIMITED (UNIT 2)

INDIA

EMERALD JEWEL INDUSTRY INDIA LIMITED (UNIT 3)

INDIA

EMERALD JEWEL INDUSTRY INDIA LIMITED (UNIT 4)

INDIA

EMIRATES GOLD DMCC

UNITED ARAB EMIRATES

ESTANHO DE RONDONIA S.A.

BRAZIL

EXOTECH INC.

UNITED STATES OF AMERICA

F&X ELECTRO-MATERIALS LTD.

CHINA

FABRICA AURICCHIO INDUSTRIA E COMERCIO LTDA.

BRAZIL

FEINHUTTE HALSBRUCKE GMBH

GERMANY

FENIX METALS

POLAND

FIDELITY PRINTERS AND REFINERS LTD.

ZIMBABWE

FIR METALS & RESOURCE LTD.

CHINA

FUJAIRAH GOLD FZC

UNITED ARAB EMIRATES

FUJIAN GANMIN RAREMETAL CO., LTD.

CHINA

FUJIAN JINXIN TUNGSTEN CO., LTD.

CHINA

FUJIAN XINLU TUNGSTEN

CHINA

GANZHOU HAICHUANG TUNGSTEN CO., LTD.

CHINA

 

7

 

GANZHOU HUAXING TUNGSTEN PRODUCTS CO., LTD.

CHINA

GANZHOU JIANGWU FERROTUNGSTEN CO., LTD.

CHINA

GANZHOU SEADRAGON W & MO CO., LTD.

CHINA

GANZHOU SUNNY NON-FERROUS METALS CO., LTD.

CHINA

GANZHOU YATAI TUNGSTEN CO., LTD.

CHINA

GEIB REFINING CORPORATION

UNITED STATES

GEJIU CITY FUXIANG INDUSTRY AND TRADE CO., LTD.

CHINA

GEJIU FENGMING METALLURGY CHEMICAL PLANT

CHINA

GEJIU JINYE MINERAL COMPANY

CHINA

GEJIU KAI MENG INDUSTRY AND TRADE LLC

CHINA

GEJIU NON-FERROUS METAL PROCESSING CO., LTD.

CHINA

GEJIU YUNXIN NONFERROUS ELECTROLYSIS CO., LTD.

CHINA

GEJIU ZILI MINING AND METALLURGY CO., LTD.

CHINA

GG REFINERY LTD.

TANZANIA, UNITED REPUBLIC OF

GGC GUJRAT GOLD CENTRE PVT. LTD.

INDIA

GLOBAL ADVANCED METALS AIZU

JAPAN

GLOBAL ADVANCED METALS BOYERTOWN

UNITED STATES

GLOBAL TUNGSTEN & POWDERS CORP.

UNITED STATES

GOLD BY GOLD COLOMBIA

COLOMBIA

GOLD COAST REFINERY

GHANA

GOLD REFINERY OF ZIJIN MINING GROUP CO., LTD.

CHINA

GREAT WALL PRECIOUS METALS CO., LTD. OF CBPM

CHINA

GUANGDONG HANHE NON-FERROUS METAL CO., LTD.

CHINA

GUANGDONG JINDING GOLD LIMITED

CHINA

GUANGDONG RISING RARE METALS-EO MATERIALS LTD.

CHINA

GUANGDONG XIANGLU TUNGSTEN CO., LTD.

CHINA

GUANYANG GUIDA NONFERROUS METAL SMELTING PLANT

CHINA

GUODA SAFINA HIGH-TECH ENVIRONMENTAL REFINERY CO., LTD.

CHINA

H.C. STARCK HERMSDORF GMBH

GERMANY

H.C. STARCK INC.

UNITED STATES

H.C. STARCK TUNGSTEN GMBH

GERMANY

HANGZHOU FUCHUNJIANG SMELTING CO., LTD.

CHINA

HANNAE FOR T CO., LTD.

KOREA, REPUBLIC OF

HEIMERLE + MEULE GMBH

GERMANY

HENGYANG KING XING LIFENG NEW MATERIALS CO., LTD.

CHINA

HERAEUS METALS HONG KONG LTD.

CHINA

HERAEUS PRECIOUS METALS GMBH & CO. KG

GERMANY

HUICHANG HILL TIN INDUSTRY CO., LTD.

CHINA

HUICHANG JINSHUNDA TIN CO., LTD.

CHINA

 

8

 

HUNAN CHENZHOU MINING CO., LTD.

CHINA

HUNAN CHUANGDA VANADIUM TUNGSTEN CO., LTD. WUJI

CHINA

HUNAN CHUNCHANG NONFERROUS METALS CO., LTD.

CHINA

HUNAN GUIYANG YINXING NONFERROUS SMELTING CO., LTD.

CHINA

HWASEONG CJ CO., LTD.

KOREA, REPUBLIC OF

HYDROMETALLURG, JSC

RUSSIAN FEDERATION

INDUSTRIAL REFINING COMPANY

BELGIUM

INNER MONGOLIA QIANKUN GOLD AND SILVER REFINERY SHARE CO., LTD.

CHINA

INTERNATIONAL PRECIOUS METAL REFINERS

UNITED ARAB EMIRATES

ISHIFUKU METAL INDUSTRY CO., LTD.

JAPAN

ISTANBUL GOLD REFINERY

TURKEY

ITALPREZIOSI

ITALY

JALAN & COMPANY

INDIA

JAPAN MINT

JAPAN

JAPAN NEW METALS CO., LTD.

JAPAN

JIANGWU H.C. STARCK TUNGSTEN PRODUCTS CO., LTD.

CHINA

JIANGXI COPPER CO., LTD.

CHINA

JIANGXI DAYU LONGXINTAI TUNGSTEN CO., LTD.

CHINA

JIANGXI DINGHAI TANTALUM & NIOBIUM CO., LTD.

CHINA

JIANGXI GAN BEI TUNGSTEN CO., LTD.

CHINA

JIANGXI KETAI ADVANCED MATERIAL CO., LTD.

CHINA

JIANGXI MINMETALS GAO'AN NON-FERROUS METALS CO., LTD.

CHINA

JIANGXI NEW NANSHAN TECHNOLOGY LTD.

CHINA

JIANGXI TONGGU NON-FERROUS METALLURGICAL & CHEMICAL CO., LTD.

CHINA

JIANGXI TUOHONG NEW RAW MATERIAL

CHINA

JIANGXI XINSHENG TUNGSTEN INDUSTRY CO., LTD.

CHINA

JIANGXI XIUSHUI XIANGGAN NONFERROUS METALS CO., LTD.

CHINA

JIANGXI YAOSHENG TUNGSTEN CO., LTD.

CHINA

JINGMEN DEWEI GEM TUNGSTEN RESOURCES RECYCLING CO., LTD.

CHINA

JIUJIANG JANNY NEW MATERIAL CO., LTD.

CHINA

JIUJIANG JINXIN NONFERROUS METALS CO., LTD.

CHINA

JIUJIANG TANBRE CO., LTD.

CHINA

JIUJIANG ZHONGAO TANTALUM & NIOBIUM CO., LTD.

CHINA

JSC "KIROVGRAD HARD ALLOYS PLANT"

RUSSIAN FEDERATION

JSC EKATERINBURG NON-FERROUS METAL PROCESSING PLANT

RUSSIAN FEDERATION

JSC URALELECTROMED

RUSSIAN FEDERATION

JX NIPPON MINING & METALS CO., LTD.

JAPAN

K.A. RASMUSSEN

NORWAY

 

9

 

KALOTI PRECIOUS METALS

UNITED ARAB EMIRATES

KAZAKHMYS SMELTING LLC

KAZAKHSTAN

KAZZINC

KAZAKHSTAN

KEMET BLUE POWDER

UNITED STATES OF AMERICA

KEMET DE MEXICO

MEXICO

KENEE MINING CORPORATION VIETNAM

VIET NAM

KENNAMETAL FALLON

UNITED STATES

KENNAMETAL HUNTSVILLE

UNITED STATES

KENNECOTT UTAH COPPER LLC

UNITED STATES

KGETS CO., LTD.

KOREA, REPUBLIC OF

KGHM POLSKA MIEDZ SPOLKA AKCYJNA

POLAND

KING-TAN TANTALUM INDUSTRY LTD.

CHINA

KOJIMA CHEMICALS CO., LTD.

JAPAN

KOREA ZINC CO., LTD.

KOREA, REPUBLIC OF

KP SANGHVI INTERNATIONAL AIRPORT

INDIA

KUNDAN CARE PRODUCTS LTD.

INDIA

KYRGYZALTYN JSC

KYRGYZSTAN

KYSHTYM COPPER-ELECTROLYTIC PLANT ZAO

RUSSIAN FEDERATION

L'AZURDE COMPANY FOR JEWELRY

SAUDI ARABIA

LIANYOU METALS CO., LTD.

TAIWAN

LINGBAO GOLD CO., LTD.

CHINA

LINGBAO JINYUAN TONGHUI REFINERY CO., LTD.

CHINA

LLC VOSTOK

RUSSIAN FEDERATION

L'ORFEBRE S.A.

ANDORRA

LS-NIKKO COPPER INC.

KOREA, REPUBLIC OF

LT METAL LTD.

KOREA, REPUBLIC OF

LUNA SMELTER, LTD.

RWANDA

LUOYANG ZIJIN YINHUI GOLD REFINERY CO., LTD.

CHINA

MA'ANSHAN WEITAI TIN CO., LTD.

CHINA

MAGNU'S MINERAIS METAIS E LIGAS LTDA.

BRAZIL

MALAYSIA SMELTING CORPORATION (MSC)

MALAYSIA

MALAYSIA SMELTING CORPORATION BERHAD (PORT KLANG)

MALAYSIA

MALIPO HAIYU TUNGSTEN CO., LTD.

CHINA

MARSAM METALS

BRAZIL

MASAN HIGH-TECH MATERIALS

VIET NAM

MATERION

UNITED STATES

MATSUDA SANGYO CO., LTD.

JAPAN

MD OVERSEAS

INDIA

MELT METAIS E LIGAS S.A.

BRAZIL

 

10

 

METAL CONCENTRATORS SA (PTY) LTD.

SOUTH AFRICA

METALLIC RESOURCES, INC.

UNITED STATES

METALLIX REFINING INC.

UNITED STATES

METALLO BELGIUM N.V.

BELGIUM

METALLO SPAIN S.L.U.

SPAIN

METALLURGICAL PRODUCTS INDIA PVT., LTD.

INDIA

METALOR TECHNOLOGIES (HONG KONG) LTD.

CHINA

METALOR TECHNOLOGIES (SINGAPORE) PTE., LTD.

SINGAPORE

METALOR TECHNOLOGIES (SUZHOU) LTD.

CHINA

METALOR TECHNOLOGIES S.A.

SWITZERLAND

METALOR USA REFINING CORPORATION

UNITED STATES

METALURGICA MET-MEX PENOLES S.A. DE C.V.

MEXICO

MINERACAO TABOCA S.A.

BRAZIL

MINSUR

PERU

MITSUBISHI MATERIALS CORPORATION

JAPAN

MITSUI MINING AND SMELTING CO., LTD.

JAPAN

MMTC-PAMP INDIA PVT., LTD.

INDIA

MODELTECH SDN BHD

MALAYSIA

MOLIREN LTD.

RUSSIAN FEDERATION

MORRIS AND WATSON

NEW ZEALAND

MORRIS AND WATSON GOLD COAST

AUSTRALIA

MOSCOW SPECIAL ALLOYS PROCESSING PLANT

RUSSIAN FEDERATION

NADIR METAL RAFINERI SAN. VE TIC. A.S.

TURKEY

NAVOI MINING AND METALLURGICAL COMBINAT

UZBEKISTAN

NGHE TINH NON-FERROUS METALS JOINT STOCK COMPANY

VIET NAM

NH RECYTECH COMPANY

KOREA, REPUBLIC OF

NIAGARA REFINING LLC

UNITED STATES

NIHON MATERIAL CO., LTD.

JAPAN

NINGXIA ORIENT TANTALUM INDUSTRY CO., LTD.

CHINA

NOVOSIBIRSK PROCESSING PLANT LTD.

RUSSIAN FEDERATION

NPM SILMET AS

ESTONIA

NPP TYAZHMETPROM LLC

RUSSIAN FEDERATION

O.M. MANUFACTURING (THAILAND) CO., LTD.

THAILAND

O.M. MANUFACTURING PHILIPPINES, INC.

PHILIPPINES

OGUSSA OSTERREICHISCHE GOLD- UND SILBER-SCHEIDEANSTALT GMBH

AUSTRIA

OHURA PRECIOUS METAL INDUSTRY CO., LTD.

JAPAN

OJSC "THE GULIDOV KRASNOYARSK NON-FERROUS METALS PLANT" (OJSC KRASTSVETMET)

RUSSIAN FEDERATION

OJSC NOVOSIBIRSK REFINERY

RUSSIAN FEDERATION

 

11

 

OOO “TECHNOLOM” 1

RUSSIAN FEDERATION

OOO “TECHNOLOM” 2

RUSSIAN FEDERATION

OPERACIONES METALURGICAS S.A.

BOLIVIA

PAMP S.A.

SWITZERLAND

PEASE & CURREN

UNITED STATES

PENGLAI PENGGANG GOLD INDUSTRY CO., LTD.

CHINA

PHILIPPINE CHUANGXIN INDUSTRIAL CO., INC.

PHILIPPINES

PLANSEE SE REUTTE

AUSTRIA

PLANTA RECUPERADORA DE METALES SPA

CHILE

PONGPIPAT COMPANY LIMITED

MYANMAR

POWER RESOURCES LTD.

MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF

PRECIOUS MINERALS AND SMELTING LIMITED

INDIA

PRIOKSKY PLANT OF NON-FERROUS METALS

RUSSIAN FEDERATION

PT ANEKA TAMBANG (PERSERO) TBK

INDONESIA

PT ARIES KENCANA SEJAHTERA

INDONESIA

PT ARTHA CIPTA LANGGENG

INDONESIA

PT ATD MAKMUR MANDIRI JAYA

INDONESIA

PT BABEL INTI PERKASA

INDONESIA

PT BABEL SURYA ALAM LESTARI

INDONESIA

PT BANGKA PRIMA TIN

INDONESIA

PT BANGKA SERUMPUN

INDONESIA

PT BANGKA TIN INDUSTRY

INDONESIA

PT BELITUNG INDUSTRI SEJAHTERA

INDONESIA

PT BUKIT TIMAH

INDONESIA

PT CIPTA PERSADA MULIA

INDONESIA

PT DS JAYA ABADI

INDONESIA

PT EUNINDO USAHA MANDIRI

INDONESIA

PT INTI STANIA PRIMA

INDONESIA

PT KARIMUN MINING

INDONESIA

PT KIJANG JAYA MANDIRI

INDONESIA

PT MASBRO ALAM STANIA

INDONESIA

PT MENARA CIPTA MULIA

INDONESIA

PT MITRA STANIA PRIMA

INDONESIA

PT MITRA SUKSES GLOBALINDO

INDONESIA

PT O.M. INDONESIA

INDONESIA

PT PANCA MEGA PERSADA

INDONESIA

PT PREMIUM TIN INDONESIA

INDONESIA

PT PRIMA TIMAH UTAMA

INDONESIA

 

12

 

PT PUTERA SARANA SHAKTI (PT PSS)

INDONESIA

PT RAJAWALI RIMBA PERKASA

INDONESIA

PT RAJEHAN ARIQ

INDONESIA

PT REFINED BANGKA TIN

INDONESIA

PT SARIWIGUNA BINASENTOSA

INDONESIA

PT STANINDO INTI PERKASA

INDONESIA

PT SUKSES INTI MAKMUR

INDONESIA

PT SUMBER JAYA INDAH

INDONESIA

PT TIMAH NUSANTARA

INDONESIA

PT TIMAH TBK KUNDUR

INDONESIA

PT TIMAH TBK MENTOK

INDONESIA

PT TININDO INTER NUSA

INDONESIA

PT TIRUS PUTRA MANDIRI

INDONESIA

PT TOMMY UTAMA

INDONESIA

PX PRECINOX S.A.

SWITZERLAND

QG REFINING, LLC

UNITED STATES

QUANTUMCLEAN

UNITED STATES

RAND REFINERY (PTY) LTD.

SOUTH AFRICA

REFINERY OF SEEMINE GOLD CO., LTD.

CHINA

REMONDIS PMR B.V.

NETHERLANDS

REPUBLIC METALS CORPORATION

UNITED STATES OF AMERICA

RESIND INDUSTRIA E COMERCIO LTDA.

BRAZIL

RFH METALS & CHEMICALS CO., LTD.

CHINA

RFH YANCHENG JINYE NEW MATERIAL TECHNOLOGY CO., LTD.

CHINA

RIAN RESOURCES SDN. BHD.

MALAYSIA

ROYAL CANADIAN MINT

CANADA

RUI DA HUNG

TAIWAN

SAAMP

FRANCE

SABIN METAL CORP.

UNITED STATES

SAFIMET S.P.A

ITALY

SAFINA A.S.

CZECH REPUBLIC

SAI REFINERY

INDIA

SAMDUCK PRECIOUS METALS

KOREA, REPUBLIC OF

SAMWON METALS CORP.

KOREA, REPUBLIC OF

SANCUS ZFS (L’ORFEBRE, SA)

COLOMBIA

SAXONIA EDELMETALLE GMBH

GERMANY

SCHONE EDELMETAAL B.V.

NETHERLANDS

SELLEM INDUSTRIES LTD.

MAURITANIA

SEMPSA JOYERIA PLATERIA S.A.

SPAIN

 

13

 

SHANDONG GOLD SMELTING CO., LTD.

CHINA

SHANDONG HUMON SMELTING CO., LTD.

CHINA

SHANDONG TIANCHENG BIOLOGICAL GOLD INDUSTRIAL CO., LTD.

CHINA

SHANDONG ZHAOJIN GOLD & SILVER REFINERY CO., LTD.

CHINA

SHENZHEN CUILU GOLD CO., LTD.

CHINA

SHENZHEN ZHONGHENGLONG REAL INDUSTRY CO., LTD.

CHINA

SHIRPUR GOLD REFINERY LTD.

INDIA

SICHUAN TIANZE PRECIOUS METALS CO., LTD.

CHINA

SINGWAY TECHNOLOGY CO., LTD.

TAIWAN

SMELTER NOT LISTED

KOREA, REPUBLIC OF

SO ACCURATE GROUP, INC.

UNITED STATES OF AMERICA

SOE SHYOLKOVSKY FACTORY OF SECONDARY PRECIOUS METALS

RUSSIAN FEDERATION

SOFT METAIS LTDA.

BRAZIL

SOLAR APPLIED MATERIALS TECHNOLOGY CORP.

TAIWAN

SOLIKAMSK MAGNESIUM WORKS OAO

RUSSIAN FEDERATION

SOUTH-EAST NONFERROUS METAL COMPANY LIMITED OF HENGYANG CITY

CHINA

SOVEREIGN METALS

INDIA

STATE RESEARCH INSTITUTE CENTER FOR PHYSICAL SCIENCES AND TECHNOLOGY

LITHUANIA

SUDAN GOLD REFINERY

SUDAN

SUMITOMO METAL MINING CO., LTD.

JAPAN

SUNGEEL HIMETAL CO., LTD.

KOREA, REPUBLIC OF

SUPER DRAGON TECHNOLOGY CO., LTD.

TAIWAN

SUPER LIGAS

BRAZIL

T.C.A S.P.A

ITALY

TAIKE TECHNOLOGY(SUZHOU)CO.,LTD.

CHINA

TAKI CHEMICAL CO., LTD.

JAPAN

TANAKA KIKINZOKU KOGYO K.K.

JAPAN

TANIOBIS CO., LTD.

THAILAND

TANIOBIS GMBH

GERMANY

TANIOBIS JAPAN CO., LTD.

JAPAN

TANIOBIS SMELTING GMBH & CO. KG

GERMANY

TEJING (VIETNAM) TUNGSTEN CO., LTD.

VIET NAM

TELEX METALS

UNITED STATES

THAI NGUYEN MINING AND METALLURGY CO., LTD.

VIET NAM

THAISARCO

THAILAND

TIN TECHNOLOGY & REFINING

UNITED STATES

TOKURIKI HONTEN CO., LTD.

JAPAN

TONGLING NONFERROUS METALS GROUP CO., LTD.

CHINA

 

14

 

TOO TAU-KEN-ALTYN

KAZAKHSTAN

TORECOM

KOREA, REPUBLIC OF

TRATHO METAL QUIMICA

BRAZIL

TUYEN QUANG NON-FERROUS METALS JOINT STOCK COMPANY

VIET NAM

ULBA METALLURGICAL PLANT JSC

KAZAKHSTAN

UMICORE BRASIL LTDA.

BRAZIL

UMICORE PRECIOUS METALS THAILAND

THAILAND

UMICORE S.A. BUSINESS UNIT PRECIOUS METALS REFINING

BELGIUM

UNECHA REFRACTORY METALS PLANT

RUSSIAN FEDERATION

UNITED PRECIOUS METAL REFINING, INC.

UNITED STATES

UNIVERSAL PRECIOUS METALS REFINING ZAMBIA

ZAMBIA

V&D NEW MATERIALS (JIANGSU) CO., LTD.

CHINA

VALCAMBI S.A.

SWITZERLAND

VALUE TRADING

BELGIUM

VIETNAM YOUNGSUN TUNGSTEN INDUSTRY CO., LTD.

VIET NAM

VQB MINERAL AND TRADING GROUP JSC

VIET NAM

WEEEREFINING

FRANCE

WESTERN AUSTRALIAN MINT (T/A THE PERTH MINT)

AUSTRALIA

WHITE SOLDER METALURGIA E MINERACAO LTDA.

BRAZIL

WIELAND EDELMETALLE GMBH

GERMANY

WOLFRAM BERGBAU UND HUTTEN AG

AUSTRIA

WOLTECH KOREA CO., LTD.

KOREA, REPUBLIC OF

XIAMEN TUNGSTEN (H.C.) CO., LTD.

CHINA

XIAMEN TUNGSTEN CO., LTD.

CHINA

XIMEI RESOURCES (GUANGDONG) LIMITED

CHINA

XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD.

CHINA

XINFENG HUARUI TUNGSTEN & MOLYBDENUM NEW MATERIAL CO., LTD.

CHINA

XINHAI RENDAN SHAOGUAN TUNGSTEN CO., LTD.

CHINA

XINXING HAORONG ELECTRONIC MATERIAL CO., LTD.

CHINA

YAMAKIN CO., LTD.

JAPAN

YANLING JINCHENG TANTALUM & NIOBIUM CO., LTD.

CHINA

YICHUN JIN YANG RARE METAL CO., LTD.

CHINA

YOKOHAMA METAL CO., LTD.

JAPAN

YUDU ANSHENG TUNGSTEN CO., LTD.

CHINA

YUNNAN CHENGFENG NON-FERROUS METALS CO., LTD.

CHINA

YUNNAN COPPER INDUSTRY CO., LTD.

CHINA

YUNNAN TIN COMPANY LIMITED

CHINA

YUNNAN YUNFAN NON-FERROUS METALS CO., LTD.

CHINA

ZHONGYUAN GOLD SMELTER OF ZHONGJIN GOLD CORPORATION

CHINA

ZHUZHOU CEMENTED CARBIDE GROUP CO., LTD.

CHINA

 

15