CONFLICT MINERALS REPORT
OF
PATRICK INDUSTRIES, INC.
In Accord with Rule 13p-1 under the Securities Exchange Act of 1934
This Conflict Minerals Report (this “Report” or “CMR”) of Patrick Industries, Inc. (“Patrick” or “we”) for the year ended December 31, 2022 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule, adopted by the Securities and Exchange Commission (“SEC”), imposes certain reporting obligations on SEC issuers whose manufactured products contain certain minerals which are necessary to the functionality or production of their products. These minerals are columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, presently limited to tantalum, tin and tungsten (“3TG” or “Conflict Minerals”). The Rule focuses on 3TG emanating from the Democratic Republic of the Congo (“DRC”) and certain adjoining countries (together with the DRC, the “Covered Countries”). If the issuer has reason to believe that any of the Conflict Minerals in its supply chain may have originated in the Covered Countries and such Conflict Minerals are not from recycled or scrap sources, or if the issuer is unable to determine the country of origin of such Conflict Minerals, then the issuer must submit a CMR to the SEC that includes a description of the due diligence measures the issuer undertook with respect to the Conflict Minerals’ source and chain of custody.
This Report relates to the diligence process undertaken for the Company’s products that were manufactured, or contracted to be manufactured, during calendar year 2022 and that contain Conflict Minerals.
Patrick is a leading component solutions provider for the RV, marine, manufactured housing, and various industrial markets – including single and multifamily housing, hospitality, institutional and commercial markets.
Executive Summary
The Company has determined that tin, tungsten, tantalum and/or gold were necessary to the functionality or production of certain of our manufactured or distributed product categories. Therefore, Patrick conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any 3TGs in our products originated from the Covered Countries. A listing of the countries of origin appears at Appendix A attached to this Report.
Based on the RCOI, Patrick believes certain of its products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with the Rule, conducted due diligence on the source and chain of custody of the 3TGs in question to determine whether such products are “conflict free or responsibly sourced.” The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework of the Organization for Economic Co-Operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum, and tungsten (the “OECD Guidance”).
After conducting a reasonable RCOI and a supply chain due diligence inquiry, we have been unable to determine that certain of our Conflict Minerals did not originate in the Covered Countries or come from recycled or scrap sources, or that such Conflict Minerals did not directly or indirectly finance or benefit armed groups in the Covered Countries.
To determine whether necessary 3TGs in certain of our products originated in Conflict-Affected and High-Risk Areas, Patrick retained a third-party service provider to assist the Company with a review of the supply chain for such products. A list of suppliers and parts associated with the in-scope products was uploaded to its proprietary software by the third-party Compliance Manager.
To trace materials, and demonstrate transparency procured by the supply chain, Patrick utilized the Conflict Minerals Reporting Template (“CMRT”) Version 6.2 or higher to conduct a survey of all in-scope suppliers. During the supplier survey, the Company contacted suppliers via the third-party Compliance Manager, a software-as-a-service (SaaS) platform that enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The third-party Compliance Manager also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the
metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations, are managed through this platform.
Via the third-party Compliance Manager and team, the Company requested that all suppliers complete a CMRT. The Company included training and education to guide suppliers on best practices and the use of this template. The third-party monitored and tracked all communications for future reporting and transparency. Patrick directly contacted its suppliers that were unresponsive to the third-party’s communications during the diligence process and requested that such suppliers complete the CMRT and submit it to the third-party.
The Company’s program continues to include automated data validation on all submitted CMRTs. The goal for data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which helps Patrick identify areas that require further classification or risk assessment, as well as aids the Company in understanding the due diligence efforts of Tier 1 suppliers. The results of this data validation process contribute to the program’s health assessment and are shared with the suppliers to ensure the suppliers’ understanding of areas that require clarification or improvement.
All submitted declaration forms are accepted so that data is retained, but are classified as valid or invalid based upon a set criteria for validation errors. Suppliers are contacted regarding invalid forms and are encouraged to correct validation errors and to resubmit a valid corrected form. Suppliers are provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses, and directly engaged assistance through the third-party’s multilingual Supplier Experience team. Some suppliers may remain unresponsive to feedback. Therefore, Patrick tracks program gaps to account for future improvement opportunities. As of April 23, 2023, Patrick had 535 suppliers in scope for the Conflict Minerals program, of which 263 provided a completed CMRT for a response rate in the reporting year of 49.16%.
Supply Chain Results
Supply chain outreach was used to help identify the upstream sources of origin of tin, tantalum, tungsten, and gold. CMRTs were sent to and requested from Tier 1 suppliers and Patrick expects to continue to require these Tier 1 suppliers to follow this process until the smelter and/or refinery sources are identified. The following is the result of the outreach conducted by Patrick for the 2022 reporting year.
Supply Chain Outreach Metrics
| | | | | |
| Number of In Scope Suppliers | Response Rate |
| 535 | 49.16% |
Appendix B attached hereto includes all smelters/refiners that the Tier 1 suppliers listed in completed CMRTs that met the recognized definition of a 3TGs processing facility and were operational during the 2022 calendar year. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to trace the specific smelters that produced the materials used in the Company’s products. As a result, those providing the smelters/refiners have the practice to list in the completed CMRTs all smelters/refiners they may purchase from within the reporting period. Therefore, the smelters/refiners (as sources) listed in Appendix B are likely to be more comprehensive than the list of smelters/refiners, which actually processed the 3TGs contained in the Company’s products.
Although the potential for over-reporting is understood, Patrick has taken measures to validate all smelter/refiner data against validated audit programs and databases intended to verify the material types and mine sources of origin. The gathered responses identified six (6) smelters that potentially pose a risk of being a source of Conflict Minerals.
Due Diligence
Established a Company Management System
Patrick established a cross-functional Conflict Minerals Compliance Team led by Patrick’s Director of Product Compliance. The Conflict Minerals Compliance Team is responsible for implementing the Company’s Conflict Minerals compliance strategy and briefing senior management about the results of its due diligence efforts.
The Company also uses a third-party service provider to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps with suppliers and/or respective stakeholders relating to Conflict Minerals.
The Company leverages its third-party provider’s Managed Services in order to work with dedicated program specialists who support Patrick’s Conflict Minerals program. The Company communicates regularly with the third-party team, receiving updates on the program’s status.
The Company expects its suppliers to have policies and procedures in place to help ensure that 3TGs used in the manufacture of the products sold to Patrick are “conflict free or responsibly sourced.” This means that the products should not contain minerals (3TGs) sourced from the Covered Countries. The Company expects direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.
The Company engages with suppliers directly to request a valid (free of validated errors) CMRT for the products that they supply to the Company. With respect to the OECD requirement to strengthen engagement with suppliers, the Company has developed an internal procedure that includes a supplier risk identification process that then leads to further steps of supplier engagement in the form of escalations, such as in-person meetings and/or corrective actions. Feedback from this engagement process has allowed the Company to oversee improvements in supplier responses and supplier compliance for this initiative.
The Company continues to place a strong emphasis on supplier education and training. To accomplish this, the third-party’s online resources are leveraged, and in-scope suppliers have been provided with access to their library of Conflict Minerals training and support resources.
Violations or grievances at the industry level can be reported to the Responsible Mineral Initiative (“RMI”) directly via the following: http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.
The Company adopted a policy to retain relevant documentation for a period of five (5) years. Through its third-party provider, a document retention policy to retain Conflict Minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. The Company stores all of the information and findings from this process in a database that can be audited by internal or external parties.
Identifying & Assessing Risks in the Supply Chain
Risks associated with Tier 1 suppliers’ due diligence processes were assessed by their declaration responses on the CMRT, which the Company’s third-party provider’s Compliance Manager identified automatically based upon established criteria. These risks are to be addressed by the third-party provider’s staff and members of the Company’s internal Conflict Minerals Compliance Team. The Company, through its third-party provider, engages with suppliers to gather pertinent data and request corrective actions if applicable, and performs an overall assessment of the supplier’s conformity status, referred to as the “Conflict Minerals status.”
Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, Patrick is unable to determine if any of the specified smelters/refiners were used for 3TGs in the products supplied to the Company.
The third-party’s supplier risk assessment (flagging suppliers’ risk as high, medium, low) identifies problematic suppliers in the Company’s supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis that takes into account multiple Conflict Minerals factors.
Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters/refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. The third-party’s smelter validation program compared the listed facilities with the list of smelters/refiners consolidated by the RMI to help identify facilities that met the recognized definition of a 3TGs processing facility and was operational during the 2022 calendar year.
The third-party provider determined whether the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). Patrick does not have a direct relationship with smelters/refiners, and does not perform direct audits of these entities. Smelters that conform to the RMAP audit standards are considered to have their sourcing validated as “conflict free or responsibly sourced.” In cases where the smelter/refinery due diligence practices have not been audited against the RMAP standard or they are considered non-conforming by RMAP, further due diligence steps are followed to notify suppliers reporting of these facilities. Smelters/refiners are actively monitored to proactively identify other risks pertaining to Conflict Minerals.
Each facility that meets the definition of a smelter or refiner of a 3TG is assessed according to red flag indicators defined in the OECD Guidance. The third-party provider uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flag factors. These factors include:
•Geographic proximity to Covered Countries;
•Known mineral source country of origin;
•RMAP audit status;
•Credible evidence of unethical or conflict sourcing;
•Peer assessments conducted by credible third-party sources; and
•Sanctions risk.
Risk mitigation activities were initiated whenever a supplier’s CMRT reports facilities of concern. Through the third-party provider, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing suppliers to take their own independent risk mitigation actions. Additional escalation may have been necessary to address any continued sourcing from these smelters of concern. Suppliers were given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters of concern from the supply chain, when applicable.
In addition, suppliers were provided educational materials on mitigating the risks identified through the data collection process. Suppliers were also evaluated on program strength, which assisted and will assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program was based on certain questions in the CMRT related to the suppliers’ Conflict Minerals practices and policies.
Risk Response
Together with a third-party provider, Patrick developed processes to assess and respond to the risks identified in the supply chain. Patrick has a risk management plan through which the Conflict Minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the Rules and the Company’s expectations.
Feedback on supplier submissions is given directly to suppliers and educational resources may be provided to assist suppliers with corrective action methods or improvements to the suppliers’ internal programs. In cases where a supplier has been non-responsive or is not committed to corrective action plans, the Company assesses whether the replacement of the supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Compliance Team and Patrick’s senior management.
Independent Auditing of Smelter
Patrick does not have a direct relationship with any 3TG smelters/refiners and does not perform or direct audits of these entities within the supply chain. Instead, the Company relies on third-party audits of smelters/refiners (industry recognized audit/assessment programs). As an example, RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of any Conflict Minerals used by smelters/refiners that agree to participate in the program.
The third-party provider directly engages smelters/refiners that are not currently enrolled in an industry recognized audit/assessment program to encourage their participation and for those smelters/refiners already conforming to the corresponding program’s standards, the third-party provider issues written appreciation for their efforts on behalf of the compliance partners. Patrick is a signatory to these communications in accordance with the requirements of downstream companies detailed in the OECD Guidance.
Report on Supply Chain Diligence
Inherent Limitations on Diligence Measures
This Report is available on the Investor Relations section of the Company’s website at https://ir.patrickind.com/SEC-filings. Information found on or accessed through this website is not considered part of this Report and is not incorporated by reference herein. Patrick has also publicly filed a Form SD and this Report with the SEC.
The Company has also considered impacts from the EU Conflict Minerals Regulation when disclosing details concerning due diligence efforts. The Company intends to continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure efforts through the form of public report.
Results of Reasonable Country of Origin Inquiry Efforts
For 2022, Patrick conducted a supply chain survey of 535 suppliers that were determined may contribute necessary Conflict Minerals to our products. The results of our RCOI as of April 27, 2023 are as follows:
•49% of the surveyed suppliers provided a CMRT in response to our supply chain survey request.
•The surveyed suppliers identified 535 operational smelter and refinery facilities that may process the necessary Conflict Minerals contained in the products provided to us.
•We know or have reason to believe that a portion of the Conflict Minerals processed by at least six (6) of these 535 smelters and refiners may have originated in the Covered Countries and may not be solely from recycled or scrap sources. The Company is evaluating changes to our supply chain to determine the feasibility of alternative sources to the six (6) smelters and/or refiners identified.
Risks on Disclosure
The statements above are based on the RCOI process and due diligence and are based on the infrastructure and information available at the time. The Company’s due diligence process has not been audited by an independent third-party auditor. A number of factors could introduce errors or otherwise affect the statements made in this Report. These factors include, but are not limited to, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers, errors or omissions by smelters, confusion by suppliers over requirements of SEC final rules, gaps in supplier and/or smelter education and knowledge, timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation errors, oversights of errors in third-party conflict free smelter audits, Covered Countries sources materials being declared secondary materials, illegally tagged Conflict Minerals being introduced into the supply chain, companies going out of business in 2022, and smuggling of Conflict Minerals to countries beyond the Covered Countries.
APPENDIX A
COUNTRIES OF ORIGIN
| | | | | | | | | | | | | | | | | | | | | | | | | | |
| Andorra | | Estonia | | Lithuania | | Portugal | | Thailand |
| | | | | | | | |
| Australia | | France | | Malaysia | | Russian Federation | | Turkey |
| | | | | | | | |
| Austria | | Germany | | Mauritania | | Rwanda | | Uganda |
| | | | | | | | |
| Belgium | | Ghana | | Mexico | | Saudi Arabia | | United Arab Emirates |
| | | | | | | | |
| Bolivia | | India | | Myanmar | | Singapore | | United States Of America |
| | | | | | | | |
| Brazil | | Indonesia | | Netherlands | | South Africa | | Uzbekistan |
| | | | | | | | |
| Canada | | Italy | | New Zealand | | Spain | | Viet Nam |
| | | | | | | | |
| Chile | | Japan | | Norway | | Sudan | | Zimbabwe |
| | | | | | | | |
| China | | Kazakhstan | | Peru | | Sweden | | |
| | | | | | | | |
| Colombia | | Korea, Republic Of | | Philippines | | Switzerland | | |
| | | | | | | | |
| Czechia | | Kyrgyzstan | | Poland | | Taiwan, Province Of China | | |
APPENDIX B
CONFLICT MINERALS SOURCING INFORMATION
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Smelter | | Country of Origin | | Smelter ID |
| Gold | | L'Orfebre S.A. | | Andorra | | CID002762 |
| Gold | | Western Australian Mint (T/a The Perth Mint) | | Australia | | CID002030 |
| Gold | | ABC Refinery Pty Ltd. | | Australia | | CID002920 |
| Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | Austria | | CID002779 |
| Tungsten | | Wolfram Bergbau und Hutten AG | | Austria | | CID002044 |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | Belgium | | CID001980 |
| Gold | | Industrial Refining Company | | Belgium | | CID002587 |
| Tin | | Aurubis Beerse | | Belgium | | CID002773 |
| Tin | | Operaciones Metalurgicas S.A. | | Bolivia | | CID001337 |
| Tin | | EM Vinto | | Bolivia | | CID000438 |
| Gold | | AngloGold Ashanti Corrego do Sitio Mineracao | | Brazil | | CID000058 |
| Gold | | Marsam Metals | | Brazil | | CID002606 |
| Tantalum | | AMG Brasil | | Brazil | | CID001076 |
| Tantalum | | Mineracao Taboca S.A. | | Brazil | | CID001175 |
| Tantalum | | Resind Industria e Comercio Ltda. | | Brazil | | CID002707 |
| Tin | | Mineracao Taboca S.A. | | Brazil | | CID001173 |
| Tin | | White Solder Metalurgia e Mineracao Ltda. | | Brazil | | CID002036 |
| Tin | | Estanho de Rondonia S.A. | | Brazil | | CID000448 |
| Tin | | Magnu's Minerais Metais e Ligas Ltda. | | Brazil | | CID002468 |
| Tin | | Melt Metais e Ligas S.A. | | Brazil | | CID002500 |
| Tin | | Resind Industria e Comercio Ltda. | | Brazil | | CID002706 |
| Tin | | Super Ligas | | Brazil | | CID002756 |
| Tin | | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | | Brazil | | CID003486 |
| Tin | | Fabrica Auricchio Industria e Comercio Ltda. | | Brazil | | CID003582 |
| Tungsten | | ACL Metais Eireli | | Brazil | | CID002833 |
| Tungsten | | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | | Brazil | | CID003427 |
| Tungsten | | Cronimet Brasil Ltda | | Brazil | | CID003468 |
| Gold | | CCR Refinery - Glencore Canada Corporation | | Canada | | CID000185 |
| Gold | | Asahi Refining Canada Ltd. | | Canada | | CID000924 |
| Gold | | Royal Canadian Mint | | Canada | | CID001534 |
| Gold | | Planta Recuperadora de Metales SpA | | Chile | | CID002919 |
| Gold | | Yunnan Copper Industry Co., Ltd. | | China | | CID000197 |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | | China | | CID000343 |
| Gold | | Refinery of Seemine Gold Co., Ltd. | | China | | CID000522 |
| Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | China | | CID000651 |
| | | | | | | | | | | | | | | | | | | | |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | China | | CID000671 |
| Gold | | Heraeus Metals Hong Kong Ltd. | | China | | CID000707 |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | | China | | CID000767 |
| Gold | | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | | China | | CID000773 |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | China | | CID000801 |
| Gold | | Jiangxi Copper Co., Ltd. | | China | | CID000855 |
| Gold | | Lingbao Gold Co., Ltd. | | China | | CID001056 |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | China | | CID001058 |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | China | | CID001093 |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | China | | CID001147 |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | China | | CID001149 |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | China | | CID001362 |
| Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | China | | CID001619 |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | China | | CID001622 |
| Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | China | | CID001736 |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | | China | | CID001909 |
| Gold | | Shandong Gold Smelting Co., Ltd. | | China | | CID001916 |
| Gold | | Tongling Nonferrous Metals Group Co., Ltd. | | China | | CID001947 |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | China | | CID002224 |
| Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | China | | CID002243 |
| Gold | | Guangdong Jinding Gold Limited | | China | | CID002312 |
| Gold | | Shandong Humon Smelting Co., Ltd. | | China | | CID002525 |
| Gold | | Shenzhen Zhonghenglong Real Industry Co., Ltd. | | China | | CID002527 |
| Gold | | Shenzhen CuiLu Gold Co., Ltd. | | China | | CID002750 |
| Gold | | Dongwu Gold Group | | China | | CID003663 |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | China | | CID000211 |
| Tantalum | | F&X Electro-Materials Ltd. | | China | | CID000460 |
| Tantalum | | XIMEI RESOURCES (GUANGDONG) LIMITED | | China | | CID000616 |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | China | | CID000914 |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | China | | CID000917 |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | China | | CID001277 |
| Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | China | | CID001522 |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | China | | CID002492 |
| Tantalum | | FIR Metals & Resource Ltd. | | China | | CID002505 |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | China | | CID002506 |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | China | | CID002508 |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | China | | CID002512 |
| Tantalum | | Jiangxi Tuohong New Raw Material | | China | | CID002842 |
| | | | | | | | | | | | | | | | | | | | |
| Tantalum | | RFH Yancheng Jinye New Material Technology Co., Ltd. | | China | | CID003583 |
| Tin | | China Tin Group Co., Ltd. | | China | | CID001070 |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | China | | CID000228 |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | China | | CID000538 |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | China | | CID000555 |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | China | | CID000942 |
| Tin | | Jiangxi New Nanshan Technology Ltd. | | China | | CID001231 |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | China | | CID001908 |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | China | | CID002158 |
| Tin | | Tin Smelting Branch of Yunnan Tin Co., Ltd. | | China | | CID002180 |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | China | | CID003116 |
| Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | China | | CID003190 |
| Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | | China | | CID003356 |
| Tin | | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | | China | | CID003397 |
| Tin | | Gejiu City Fuxiang Industry and Trade Co., Ltd. | | China | | CID003410 |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | China | | CID000218 |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | China | | CID000258 |
| Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | | China | | CID000281 |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | China | | CID000766 |
| Tungsten | | Hunan Jintai New Material Co., Ltd. | | China | | CID000769 |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | China | | CID000875 |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | China | | CID002082 |
| Tungsten | | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | | China | | CID002313 |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | China | | CID002315 |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | China | | CID002316 |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | China | | CID002317 |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | China | | CID002318 |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | China | | CID002319 |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | China | | CID002320 |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | China | | CID002321 |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | China | | CID002494 |
| Tungsten | | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | | China | | CID002513 |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | China | | CID002551 |
| Tungsten | | China Molybdenum Tungsten Co., Ltd. | | China | | CID002641 |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | China | | CID002645 |
| Tungsten | | Fujian Ganmin RareMetal Co., Ltd. | | China | | CID003401 |
| Tungsten | | Hubei Green Tungsten Co., Ltd. | | China | | CID003417 |
| Tungsten | | Fujian Xinlu Tungsten Co., Ltd. | | China | | CID003609 |
| | | | | | | | | | | | | | | | | | | | |
| Tungsten | | YUDU ANSHENG TUNGSTEN CO., LTD. | | China | | CID003662 |
| Gold | | C.I Metales Procesados Industriales SAS | | Colombia | | CID003421 |
| Gold | | Sancus ZFS (L’Orfebre, SA) | | Colombia | | CID003529 |
| Gold | | Gold by Gold Colombia | | Colombia | | CID003641 |
| Gold | | SAFINA A.S. | | Czechia | | CID002290 |
| Tantalum | | NPM Silmet AS | | Estonia | | CID001200 |
| Tantalum | | 5D Production OU | | Estonia | | CID003926 |
| Gold | | SAAMP | | France | | CID002761 |
| Gold | | WEEEREFINING | | France | | CID003615 |
| Gold | | Agosi AG | | Germany | | CID000035 |
| Gold | | Aurubis AG | | Germany | | CID000113 |
| Gold | | C. Hafner GmbH + Co. KG | | Germany | | CID000176 |
| Gold | | Heimerle + Meule GmbH | | Germany | | CID000694 |
| Gold | | Heraeus Germany GmbH Co. KG | | Germany | | CID000711 |
| Gold | | WIELAND Edelmetalle GmbH | | Germany | | CID002778 |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | | Germany | | CID002867 |
| Tantalum | | TANIOBIS GmbH | | Germany | | CID002545 |
| Tantalum | | TANIOBIS Smelting GmbH & Co. KG | | Germany | | CID002550 |
| Tungsten | | H.C. Starck Tungsten GmbH | | Germany | | CID002541 |
| Tungsten | | TANIOBIS Smelting GmbH & Co. KG | | Germany | | CID002542 |
| Gold | | Gold Coast Refinery | | Ghana | | CID003186 |
| Gold | | MMTC-PAMP India Pvt., Ltd. | | India | | CID002509 |
| Gold | | Shirpur Gold Refinery Ltd. | | India | | CID002588 |
| Gold | | GGC Gujrat Gold Centre Pvt. Ltd. | | India | | CID002852 |
| Gold | | Sai Refinery | | India | | CID002853 |
| Gold | | Bangalore Refinery | | India | | CID002863 |
| Gold | | JALAN & Company | | India | | CID002893 |
| Gold | | CGR Metalloys Pvt Ltd. | | India | | CID003382 |
| Gold | | Sovereign Metals | | India | | CID003383 |
| Gold | | Augmont Enterprises Private Limited | | India | | CID003461 |
| Gold | | Kundan Care Products Ltd. | | India | | CID003463 |
| Gold | | Emerald Jewel Industry India Limited (Unit 1) | | India | | CID003487 |
| Gold | | Emerald Jewel Industry India Limited (Unit 2) | | India | | CID003488 |
| Gold | | Emerald Jewel Industry India Limited (Unit 3) | | India | | CID003489 |
| Gold | | Emerald Jewel Industry India Limited (Unit 4) | | India | | CID003490 |
| Gold | | MD Overseas | | India | | CID003548 |
| Tantalum | | Metallurgical Products India Pvt., Ltd. | | India | | CID001163 |
| Tin | | Precious Minerals and Smelting Limited | | India | | CID003409 |
| | | | | | | | | | | | | | | | | | | | |
| Gold | | PT Aneka Tambang (Persero) Tbk | | Indonesia | | CID001397 |
| Tin | | PT Refined Bangka Tin | | Indonesia | | CID001460 |
| Tin | | PT Timah Tbk Kundur | | Indonesia | | CID001477 |
| Tin | | PT Timah Tbk Mentok | | Indonesia | | CID001482 |
| Tin | | PT Tinindo Inter Nusa | | Indonesia | | CID001490 |
| Tin | | PT Artha Cipta Langgeng | | Indonesia | | CID001399 |
| Tin | | PT Babel Inti Perkasa | | Indonesia | | CID001402 |
| Tin | | PT Babel Surya Alam Lestari | | Indonesia | | CID001406 |
| Tin | | PT Belitung Industri Sejahtera | | Indonesia | | CID001421 |
| Tin | | PT Bukit Timah | | Indonesia | | CID001428 |
| Tin | | PT Mitra Stania Prima | | Indonesia | | CID001453 |
| Tin | | PT Panca Mega Persada | | Indonesia | | CID001457 |
| Tin | | PT Prima Timah Utama | | Indonesia | | CID001458 |
| Tin | | PT Sariwiguna Binasentosa | | Indonesia | | CID001463 |
| Tin | | PT Stanindo Inti Perkasa | | Indonesia | | CID001468 |
| Tin | | PT Timah Nusantara | | Indonesia | | CID001486 |
| Tin | | CV Venus Inti Perkasa | | Indonesia | | CID002455 |
| Tin | | PT Tirus Putra Mandiri | | Indonesia | | CID002478 |
| Tin | | PT ATD Makmur Mandiri Jaya | | Indonesia | | CID002503 |
| Tin | | PT Cipta Persada Mulia | | Indonesia | | CID002696 |
| Tin | | PT Sukses Inti Makmur | | Indonesia | | CID002816 |
| Tin | | PT Menara Cipta Mulia | | Indonesia | | CID002835 |
| Tin | | PT Bangka Serumpun | | Indonesia | | CID003205 |
| Tin | | PT Rajawali Rimba Perkasa | | Indonesia | | CID003381 |
| Tin | | PT Mitra Sukses Globalindo | | Indonesia | | CID003449 |
| Tin | | PT Aries Kencana Sejahtera | | Indonesia | | CID000309 |
| Tin | | PT Tommy Utama | | Indonesia | | CID001493 |
| Tin | | CV Ayi Jaya | | Indonesia | | CID002570 |
| Tin | | PT Premium Tin Indonesia | | Indonesia | | CID000313 |
| Tin | | PT Bangka Tin Industry | | Indonesia | | CID001419 |
| Tin | | PT Bangka Prima Tin | | Indonesia | | CID002776 |
| Tin | | PT Putera Sarana Shakti (PT PSS) | | Indonesia | | CID003868 |
| Tin | | PT Rajehan Ariq | | Indonesia | | CID002593 |
| Gold | | Chimet S.p.A. | | Italy | | CID000233 |
| Gold | | T.C.A S.p.A | | Italy | | CID002580 |
| Gold | | 8853 S.p.A. | | Italy | | CID002763 |
| Gold | | Italpreziosi | | Italy | | CID002765 |
| Gold | | Safimet S.p.A | | Italy | | CID002973 |
| | | | | | | | | | | | | | | | | | | | |
| Gold | | Aida Chemical Industries Co., Ltd. | | Japan | | CID000019 |
| Gold | | Asahi Pretec Corp. | | Japan | | CID000082 |
| Gold | | Asaka Riken Co., Ltd. | | Japan | | CID000090 |
| Gold | | Chugai Mining | | Japan | | CID000264 |
| Gold | | Dowa | | Japan | | CID000401 |
| Gold | | Eco-System Recycling Co., Ltd. East Plant | | Japan | | CID000425 |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | Japan | | CID000807 |
| Gold | | Japan Mint | | Japan | | CID000823 |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | Japan | | CID000937 |
| Gold | | Kojima Chemicals Co., Ltd. | | Japan | | CID000981 |
| Gold | | Matsuda Sangyo Co., Ltd. | | Japan | | CID001119 |
| Gold | | Mitsubishi Materials Corporation | | Japan | | CID001188 |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | Japan | | CID001193 |
| Gold | | Nihon Material Co., Ltd. | | Japan | | CID001259 |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | Japan | | CID001325 |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | Japan | | CID001798 |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | Japan | | CID001875 |
| Gold | | Tokuriki Honten Co., Ltd. | | Japan | | CID001938 |
| Gold | | Yamakin Co., Ltd. | | Japan | | CID002100 |
| Gold | | Yokohama Metal Co., Ltd. | | Japan | | CID002129 |
| Gold | | Eco-System Recycling Co., Ltd. North Plant | | Japan | | CID003424 |
| Gold | | Eco-System Recycling Co., Ltd. West Plant | | Japan | | CID003425 |
| Tantalum | | Mitsui Mining and Smelting Co., Ltd. | | Japan | | CID001192 |
| Tantalum | | Taki Chemical Co., Ltd. | | Japan | | CID001869 |
| Tantalum | | TANIOBIS Japan Co., Ltd. | | Japan | | CID002549 |
| Tantalum | | Global Advanced Metals Aizu | | Japan | | CID002558 |
| Tin | | Dowa | | Japan | | CID000402 |
| Tin | | Mitsubishi Materials Corporation | | Japan | | CID001191 |
| Tungsten | | A.L.M.T. Corp. | | Japan | | CID000004 |
| Tungsten | | Japan New Metals Co., Ltd. | | Japan | | CID000825 |
| Gold | | Kazakhmys Smelting LLC | | Kazakhstan | | CID000956 |
| Gold | | Kazzinc | | Kazakhstan | | CID000957 |
| Gold | | TOO Tau-Ken-Altyn | | Kazakhstan | | CID002615 |
| Tantalum | | Ulba Metallurgical Plant JSC | | Kazakhstan | | CID001969 |
| Gold | | DSC (Do Sung Corporation) | | Korea, Republic Of | | CID000359 |
| Gold | | LT Metal Ltd. | | Korea, Republic Of | | CID000689 |
| Gold | | HwaSeong CJ CO., LTD. | | Korea, Republic Of | | CID000778 |
| Gold | | LS-NIKKO Copper Inc. | | Korea, Republic Of | | CID001078 |
| | | | | | | | | | | | | | | | | | | | |
| Gold | | Samduck Precious Metals | | Korea, Republic Of | | CID001555 |
| Gold | | Samwon Metals Corp. | | Korea, Republic Of | | CID001562 |
| Gold | | Torecom | | Korea, Republic Of | | CID001955 |
| Gold | | Korea Zinc Co., Ltd. | | Korea, Republic Of | | CID002605 |
| Gold | | SungEel HiMetal Co., Ltd. | | Korea, Republic Of | | CID002918 |
| Gold | | NH Recytech Company | | Korea, Republic Of | | CID003189 |
| Tungsten | | HANNAE FOR T Co., Ltd. | | Korea, Republic Of | | CID003978 |
| Tungsten | | DONGKUK INDUSTRIES CO., LTD. | | Korea, Republic Of | | CID004060 |
| Gold | | Kyrgyzaltyn JSC | | Kyrgyzstan | | CID001029 |
| Gold | | State Research Institute Center for Physical Sciences and Technology | | Lithuania | | CID003153 |
| Gold | | Modeltech Sdn Bhd | | Malaysia | | CID002857 |
| Tin | | Malaysia Smelting Corporation (MSC) | | Malaysia | | CID001105 |
| Tin | | Modeltech Sdn Bhd | | Malaysia | | CID002858 |
| Gold | | Sellem Industries Ltd. | | Mauritania | | CID003540 |
| Gold | | Caridad | | Mexico | | CID000180 |
| Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | Mexico | | CID001161 |
| Tantalum | | KEMET de Mexico | | Mexico | | CID002539 |
| Tin | | Pongpipat Company Limited | | Myanmar | | CID003208 |
| Tin | | DS Myanmar | | Myanmar | | CID003831 |
| Gold | | REMONDIS PMR B.V. | | Netherlands | | CID002582 |
| Gold | | Morris and Watson | | New Zealand | | CID002282 |
| Gold | | K.A. Rasmussen | | Norway | | CID003497 |
| Tin | | Minsur | | Peru | | CID001182 |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | Philippines | | CID000128 |
| Tin | | O.M. Manufacturing Philippines, Inc. | | Philippines | | CID002517 |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | Philippines | | CID002827 |
| Gold | | KGHM Polska Miedz Spolka Akcyjna | | Poland | | CID002511 |
| Tin | | Fenix Metals | | Poland | | CID000468 |
| Gold | | Albino Mountinho Lda. | | Portugal | | CID002760 |
| Gold | | JSC Novosibirsk Refinery | | Russian Federation | | CID000493 |
| Gold | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | Russian Federation | | CID000927 |
| Gold | | JSC Uralelectromed | | Russian Federation | | CID000929 |
| Gold | | Moscow Special Alloys Processing Plant | | Russian Federation | | CID001204 |
| Gold | | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | | Russian Federation | | CID001326 |
| Gold | | Prioksky Plant of Non-Ferrous Metals | | Russian Federation | | CID001386 |
| Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | Russian Federation | | CID001756 |
| Gold | | Kyshtym Copper-Electrolytic Plant ZAO | | Russian Federation | | CID002865 |
| Tantalum | | Solikamsk Magnesium Works OAO | | Russian Federation | | CID001769 |
| | | | | | | | | | | | | | | | | | | | |
| Tin | | Novosibirsk Tin Combine | | Russian Federation | | CID001305 |
| Tungsten | | Hydrometallurg, JSC | | Russian Federation | | CID002649 |
| Tungsten | | Unecha Refractory metals plant | | Russian Federation | | CID002724 |
| Tungsten | | Moliren Ltd. | | Russian Federation | | CID002845 |
| Tungsten | | JSC "Kirovgrad Hard Alloys Plant" | | Russian Federation | | CID003408 |
| Tungsten | | NPP Tyazhmetprom LLC | | Russian Federation | | CID003416 |
| Tungsten | | Artek LLC | | Russian Federation | | CID003553 |
| Tungsten | | OOO “Technolom” 2 | | Russian Federation | | CID003612 |
| Tungsten | | OOO “Technolom” 1 | | Russian Federation | | CID003614 |
| Tungsten | | LLC Vostok | | Russian Federation | | CID003643 |
| Tin | | Luna Smelter, Ltd. | | Rwanda | | CID003387 |
| Gold | | L'azurde Company For Jewelry | | Saudi Arabia | | CID001032 |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | Singapore | | CID001152 |
| Gold | | Rand Refinery (Pty) Ltd. | | South Africa | | CID001512 |
| Gold | | AU Traders and Refiners | | South Africa | | CID002850 |
| Gold | | Metal Concentrators SA (Pty) Ltd. | | South Africa | | CID003575 |
| Gold | | SEMPSA Joyeria Plateria S.A. | | Spain | | CID001585 |
| Tin | | Aurubis Berango | | Spain | | CID002774 |
| Tin | | CRM Synergies | | Spain | | CID003524 |
| Gold | | Sudan Gold Refinery | | Sudan | | CID002567 |
| Gold | | Boliden AB | | Sweden | | CID000157 |
| Gold | | Argor-Heraeus S.A. | | Switzerland | | CID000077 |
| Gold | | Cendres + Metaux S.A. | | Switzerland | | CID000189 |
| Gold | | Metalor Technologies S.A. | | Switzerland | | CID001153 |
| Gold | | MKS PAMP SA | | Switzerland | | CID001352 |
| Gold | | PX Precinox S.A. | | Switzerland | | CID001498 |
| Gold | | Valcambi S.A. | | Switzerland | | CID002003 |
| Gold | | Solar Applied Materials Technology Corp. | | Taiwan, Province Of China | | CID001761 |
| Gold | | Super Dragon Technology Co., Ltd. | | Taiwan, Province Of China | | CID001810 |
| Gold | | Singway Technology Co., Ltd. | | Taiwan, Province Of China | | CID002516 |
| Tin | | Rui Da Hung | | Taiwan, Province Of China | | CID001539 |
| Tungsten | | Lianyou Metals Co., Ltd. | | Taiwan, Province Of China | | CID003407 |
| Gold | | Umicore Precious Metals Thailand | | Thailand | | CID002314 |
| Tantalum | | TANIOBIS Co., Ltd. | | Thailand | | CID002544 |
| Tin | | Thaisarco | | Thailand | | CID001898 |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | Thailand | | CID001314 |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | Turkey | | CID000103 |
| Gold | | Istanbul Gold Refinery | | Turkey | | CID000814 |
| | | | | | | | | | | | | | | | | | | | |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.S. | | Turkey | | CID001220 |
| Gold | | African Gold Refinery | | Uganda | | CID003185 |
| Gold | | Al Etihad Gold Refinery DMCC | | United Arab Emirates | | CID002560 |
| Gold | | Emirates Gold DMCC | | United Arab Emirates | | CID002561 |
| Gold | | International Precious Metal Refiners | | United Arab Emirates | | CID002562 |
| Gold | | Kaloti Precious Metals | | United Arab Emirates | | CID002563 |
| Gold | | Fujairah Gold FZC | | United Arab Emirates | | CID002584 |
| Gold | | Dijllah Gold Refinery FZC | | United Arab Emirates | | CID003348 |
| Gold | | Advanced Chemical Company | | United States Of America | | CID000015 |
| Gold | | Asahi Refining USA Inc. | | United States Of America | | CID000920 |
| Gold | | Kennecott Utah Copper LLC | | United States Of America | | CID000969 |
| Gold | | Materion | | United States Of America | | CID001113 |
| Gold | | Metalor USA Refining Corporation | | United States Of America | | CID001157 |
| Gold | | Sabin Metal Corp. | | United States Of America | | CID001546 |
| Gold | | United Precious Metal Refining, Inc. | | United States Of America | | CID001993 |
| Gold | | Geib Refining Corporation | | United States Of America | | CID002459 |
| Gold | | Abington Reldan Metals, LLC | | United States Of America | | CID002708 |
| Gold | | Pease & Curren | | United States Of America | | CID002872 |
| Gold | | QG Refining, LLC | | United States Of America | | CID003324 |
| Gold | | Alexy Metals | | United States Of America | | CID003500 |
| Gold | | Metallix Refining Inc. | | United States Of America | | CID003557 |
| Tantalum | | QuantumClean | | United States Of America | | CID001508 |
| Tantalum | | Telex Metals | | United States Of America | | CID001891 |
| Tantalum | | D Block Metals, LLC | | United States Of America | | CID002504 |
| Tantalum | | Materion Newton Inc. | | United States Of America | | CID002548 |
| Tantalum | | Global Advanced Metals Boyertown | | United States Of America | | CID002557 |
| Tin | | Tin Technology & Refining | | United States Of America | | CID003325 |
| Tin | | Alpha | | United States Of America | | CID000292 |
| Tin | | Metallic Resources, Inc. | | United States Of America | | CID001142 |
| Tungsten | | Kennametal Huntsville | | United States Of America | | CID000105 |
| Tungsten | | Global Tungsten & Powders LLC | | United States Of America | | CID000568 |
| Tungsten | | Kennametal Fallon | | United States Of America | | CID000966 |
| Tungsten | | Niagara Refining LLC | | United States Of America | | CID002589 |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | Uzbekistan | | CID000041 |
| Gold | | Navoi Mining and Metallurgical Combinat | | Uzbekistan | | CID001236 |
| Tin | | VQB Mineral and Trading Group JSC | | Viet Nam | | CID002015 |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | Viet Nam | | CID002572 |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | Viet Nam | | CID002573 |
| | | | | | | | | | | | | | | | | | | | |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | Viet Nam | | CID002574 |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | Viet Nam | | CID002703 |
| Tungsten | | Asia Tungsten Products Vietnam Ltd. | | Viet Nam | | CID002502 |
| Tungsten | | Masan High-Tech Materials | | Viet Nam | | CID002543 |
| Gold | | Fidelity Printers and Refiners Ltd. | | Zimbabwe | | CID002515 |
