UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Dell Technologies Inc.
(Exact name of registrant as specified in its charter)
Delaware | 001-37867 | 80-0890963 | ||
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||
One Dell Way, Round Rock, Texas | 78682 | |||
(Address of principal executive offices) | (Zip Code) | |||
Richard J. Rothberg, Esq.
General Counsel and Secretary
(800) 289-3355
(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:
þ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.
Section 1 — Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of the Conflict Minerals Report of Dell Technologies Inc. for the period January 1, 2019 to December 31, 2019 required by Item 1.01 is filed as Exhibit 1.01 hereto and is publicly available at https://corporate.delltechnologies.com/en-us/social-impact/advancing-sustainability/sustainable-supply-chain/responsible-sourcing.htm.
Item 1.02 Exhibit
The Conflict Minerals Report of Dell Technologies Inc. for the period January 1, 2019 to December 31, 2019 required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 — Exhibits
Item 2.01 Exhibits
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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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 undersigned hereunto duly authorized.
DELL TECHNOLOGIES INC. (Registrant) | ||||||
By: | /s/ Richard J. Rothberg | May 29, 2020 | ||||
Richard J. Rothberg, Esq. General Counsel and Secretary | Date | |||||
(Duly Authorized Officer) | ||||||
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Exhibit 1.01
Dell Technologies Inc.
Conflict Minerals Report
Introduction
This Conflict Minerals Report for Dell Technologies Inc. (“Dell” or “we,” “us,” “our”) is filed with the Securities and Exchange Commission (the “SEC”) as an exhibit to Dell’s Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting year ended December 31, 2019 (the “Reporting Period”). The Rule imposes disclosure of certain due diligence and reporting obligations on SEC reporting companies whose manufactured products or products contracted to be manufactured contain “conflict minerals” that are necessary to the functionality or production of Dell products. The Rule defines “conflict minerals” as cassiterite, columbite-tantalite, gold, wolframite and their derivatives limited to tin, tantalum, tungsten, and gold, also referred to as “3TG.”
Dell Products Covered by this Report
This Report relates to products: (i) for which conflict minerals are necessary to the functionality or production of such products; (ii) that were manufactured, or contracted to be manufactured, by Dell; and (iii) for which the manufacture was completed during the Reporting Period (the “Covered Products”). The Covered Products include the following product categories that were manufactured or contracted to be manufactured by Dell in the Reporting Period: branded hardware, such as desktop PCs, notebooks and tablets; branded and third-party peripherals, such as monitors and projectors; and server, storage and networking products.
Overview of Dell’s Conflict Minerals Program
As part of Dell’s global approach to ensure responsible sourcing of minerals, Dell supports, respects and upholds the internationally-recognized human rights of all people and labor rights for the workers of those in our supply chain. Dell manufactures and contracts to manufacture products for which 3TG minerals are necessary to their functionality or production. As a manufacturer of technology products, Dell does not purchase 3TG directly from mines, smelters, or refiners, but does purchase components and materials that may contain 3TG. Therefore, we collaborate with suppliers, industry peers, and other stakeholders to meet our program goals and customer expectations. In order to comply with the Rule, Dell conducts a good faith reasonable country of origin inquiry (“RCOI”) to determine whether any necessary 3TG contained in the Covered Products originated in the Democratic Republic of the Congo (the “DRC”), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, or Angola (together, the “Covered Countries”), or were from recycled or scrap sources.
Our approach to responsible sourcing follows the tenets set forth in the Organisation for Economic Co-operation and Development’s “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 3rd Edition (2016)” and the related Supplements for 3TG (the “OECD framework”). We participate in multi-stakeholder initiatives such as the Responsible Minerals Initiative (“RMI”). The RMI provides tools such as the Conflict Minerals Reporting Template (“CMRT”) and oversees the Responsible Minerals Assurance Process (“RMAP”), which verifies that sourcing practices are aligned to the OECD framework. We use these tools, RMI guidance, and the OECD framework to conduct due diligence on our 3TG supply chain and drive the actions towards the goals established at the beginning of the Reporting Period. These goals include a 100 percent CMRT response rate by in-scope suppliers and increasing the number of smelters and refiners participating in RMAP. Our work to increase the number of smelters and refiners (“SORs”) participating in RMAP resulted in 81 percent of all smelters and refiners reported in Dell’s supply chain designated as Active or Conformant to RMAP.
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Reasonable Country of Origin Inquiry
The CMRT survey, smelter and refiner review process, and third-party data constituted our Reasonable Country of Origin Inquiry (RCOI). This RCOI, combined with our risk assessment and mitigation efforts described in this report, represent Dell’s efforts to trace the source of 3TG in our supply chain to country of origin and the mine or location of origin as necessary.
On the basis of the responses to the RCOI, Dell performed further due diligence on 3TG contained in Covered Products that may originate from SORs known to source from Covered Countries and SORs that may source from Covered Countries.
Dell’s goal is to responsibly source 3TG that may originate from conflict-affected and high-risk areas, including the Covered Countries, through independent third-party audits that validate the alignment of assurance systems to the OECD framework at all applicable smelters and refiners. Of the 302 unique smelters and refiners reported to Dell by our suppliers, 244 are participating in the RMI RMAP program. Of these, 23 are known to be sourcing from the Covered Countries, and all are designated as “RMAP Conformant.” Dell continues to work with suppliers throughout its supply chain to assess and improve their information, reporting quality, and capacity; taking into account supply chain fluctuations and other changes in status or scope and relationships over time.
Due Diligence Process
Design of Due Diligence Measures
Dell’s due diligence measures have been designed to conform, in all material respects, with the OECD framework. Dell’s due diligence included the following elements of the OECD framework:
• | Step 1: Establish strong company management system; |
• | Step 2: Identify and assess risk in the supply chain; |
• | Step 3: Design and implement a strategy to respond to identified risks; |
• | Step 4: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain; and |
• | Step 5: Report on supply chain due diligence. |
Due Diligence Performed
Step 1: Establish Strong Company Management System
Dell has established a management system to determine 3TG source and chain of custody in its supply chain.
Responsible Sourcing Policy. Dell’s Responsible Sourcing Policy outlines a collaborative approach to addressing concerns about the risk of human rights violations in the upstream supply chain. The policy states our expectations for suppliers to have policies and due diligence practices in place to reasonably assure that products and components supplied to Dell are not sourced from a conflict region and do not benefit armed groups. Our policy also requires suppliers to take steps to remediate potential risks identified as a result of their due diligence efforts.
Dell abides by, and is held accountable to, the Responsible Business Alliance (RBA) Code of Conduct and Dell’s Supplier Principles, which also require direct material suppliers to have a conflict minerals policy and conduct due diligence on the source and chain of custody of materials in their products to reasonably assure they do not come from conflict sources.
Control System. Dell surveys its supply chain annually using the Conflict Minerals Reporting Template. This survey is the primary mechanism for identifying smelters and refiners that supply 3TG to components within the supply chain and for assessing the risks associated with 3TG. Following the collection of smelter and refiner data from suppliers, Dell utilizes the RMI’s RMAP to gain initial insights into whether the smelter is participating in RMAP and to determine the country of origin of 3TG for the smelters and refiners in our supply chain.
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Supplier Engagement. Responsible sourcing is embedded in Dell’s supply chain management business processes. Our accountability and supplier performance scorecard includes metrics on suppliers’ adherence to our Conflict Minerals expectations, alongside other metrics such as quality, cost and availability. This scorecard is used by Dell executives in business reviews with suppliers and provides a key input into business decisions.
Internal Team. Dell’s Responsible Minerals Governance Committee provides strategic direction and input to our Responsible Minerals Process, including Dell’s Responsible Minerals Policy, supplier requirements, communications, and risk management. The Committee is overseen by the Vice President of Supply Chain Sustainability, Risk, Tools and Governance. Leaders from functions also include Global Compliance, Procurement, Corporate Social Responsibility, Legal, and other internal stakeholders. Dell’s Procurement leadership also receives monthly program updates to ensure suppliers meet timelines and expectations.
Grievance Mechanism. Dell maintains an internal grievance reporting process for internal and external parties to report supply chain concerns. Reports, including those related to responsible sourcing of minerals, are made either directly to Dell or through Dell’s ethics hotline (accessible via telephone or web) maintained by a third-party provider. These reports are managed first by the third-party provider, then routed to the appropriate contact within Dell for continued investigation. Information about the various channels through which reports can be made is included in the publicly available Dell Code of Conduct, and in mandatory annual employee Code of Conduct training.
The web site http://dell-ethicsline.com provides all information, including local phone numbers for every country. Reporting can be leveraged via phone or web 24x7x365, anonymously where permitted by local law. Additionally, parties can contact the Dell Ethics & Compliance Office via ethics@dell.com (in a reporting process that is not anonymous).
Dell encourages the use of the RMI’s Grievance Mechanism to raise issues in the mineral supply chain. Anonymous public submissions can be raised through the RMI’s online Grievance Platform at www.mineralsgrievanceplatform.org.
Dell also maintains an anti-retaliation policy that encourages team members who know of or suspect a violation of applicable laws or regulations or any Dell policy, or suspect unethical, illegal or suspicious behavior to promptly report it through a number of available channels. Dell does not tolerate retaliation against anyone who reports suspected misconduct or assists with an investigation or audit in good faith. Team members who think they are being retaliated against, or that an investigation is being conducted inappropriately, are encouraged to report it immediately using any of the available reporting avenues.
Step 2: Identify and Assess Risks in the Supply Chain
To begin, we identify suppliers that are in scope for Dell’s Conflict Minerals Program. A supplier is selected for the Conflict Minerals Program if it meets one or more of the following criteria:
• | provides components to Dell that are known to, or could potentially, contain 3TG; |
• | receives at least a specified percentage of overall expenditures; or |
• | is considered high-risk for benefiting armed groups in the Covered Countries based on previously reported data. |
Dell requests an annual CMRT from in-scope suppliers and expects them to cascade this reporting requirement through the supply chain. Dell requires suppliers to provide comprehensive, accurate data on 3TG acquired from their supply chain through the CMRT process. This data is used to identify and verify the smelters and refiners in our supply chain that participate in RMAP. Collected CMRTs are analyzed to ensure conformity with Dell’s assessment.
We partner with a third-party software provider to efficiently manage our CMRT campaign. This tool performs an initial data validation check when the supplier submits a CMRT. CMRTs are also reviewed against internally-developed risk assessment frameworks, which evaluates progress on due diligence, confirms a conflict minerals policy is in place, and assesses the list of 3TG smelters and refiners in their supply chain.
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In 2019, we enhanced our efforts to improve the quality and accuracy of data reported. The accuracy of the data provided is key to enhance supply chain decision-making and ensure high risk concerns are addressed. Therefore, we increased the cadence of CMRT requests to confirm suppliers were reporting up-to-date information, enabling fluctuations in SORs use by sub-tier members of the supply chain.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
Dell is committed to promoting responsible sourcing through third-party verification of smelters and refiners. We require suppliers to progress towards sourcing exclusively from RMAP conformant smelters and refiners. As a reflection of this priority, we updated our risk mitigation process to address potential risks in our supply chain.
Dell encourages suppliers to promote responsible sourcing through RMI audits to validate alignment with the OECD framework. We recognize that some smelters or refiners cannot or may not align to our expectations and are unwilling to undergo a third-party audit. Alternatively, external factors may cause a smelter or refiner to drop out of RMAP conformance.
Accordingly, Dell’s due diligence process identifies smelters and refiners that lack audit validation or are at high risk of benefitting armed groups in conflict-affected and high-risk areas, including the Covered Countries. Evidence of such factors is drawn from CMRT and RMI databases, customer engagements as well as independent research. In the event of such findings, Dell will ask that the supplier remove the smelter or refiner in question from their supply chain.
Our approach is further enhanced by requiring suppliers to not only remove high-risk smelters and refiners, but also address those that do not, or cannot, achieve RMAP-conformance.
We began a targeted pilot with three suppliers that were reporting the highest number of non-RMAP audited smelters and refiners. These smelters and refiners are defined as those in the RMI audit status of: Non-Compliant, In Communication, Outreach Required, Due Diligence Vetting Process, and Communication Suspended - Not Interested.
We first engage and work with the relevant procurement team and supplier to develop a detailed plan for addressing SORs of concern, including parts affected, material breakdown of parts, and timelines for completion. If commitment towards this ambition or preparation of the plan is delayed, it is escalated to senior supply chain leaders.
These executives are provided with regular briefings and updates on any open items involving suppliers in their areas of responsibility. Potential consequences of this action range from reduced scoring in Quarterly Business Reviews (QBRs) to a reduction in business, until the necessary actions are addressed.
A key output from this pilot indicated that suppliers were inaccurately reporting SORs due to a lack of alignment on expectations and, in some cases a lack of data, leading to reporting including suppliers or materials not pertinent to our products or supply chain. Once these inaccuracies were identified, 95 smelters were removed from our supply chain. We continue to review opportunities to improve surveying and reporting capabilities, with supplier collaboration paramount to this process.
Dell is taking steps to enhance our global view of risks to promote ethical supply chains by monitoring environmental, health and safety, corruption, and labor incidents in the mining industry through a third-party service. With this service, we can identify actors in the supply chain that need direct support to improve capabilities or removal from our supply chain. Dell will continue to investigation additional third-party data sources to enhance our due diligence capability.
Step 4: Carry Out Independent Third-Party Audits of Supply Chain Due Diligence at Identified Points in the Supply Chain
As a downstream company, Dell uses RMAP for smelter and refiner audits to assess risks from the mine to the smelter or refiner. We understand that continued progress needs to be made to encourage smelters and refiners to participate in the RMAP program, including removing them from our supply chain if they will not or cannot participate. Through our continued partnership with suppliers to drive participation in the RMAP program, we see
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an increase in suppliers reporting 100% RMAP smelter and refiners, although the overall number of smelters and refiners participating in a RMAP audit is lower than in previous years.
Table 2: the following table shows 3TG smelters or refiners reported by Dell’s combined suppliers’ supply chain by metal and RMAP Status 1
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1 Active smelters and refiners are defined by RMAP as those that have committed to undergo a RMAP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain of Custody Certification.
Conformant smelters and refiners passed the audit/certification programs stated above.
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Based on consolidated CMRT information for the Reporting Period, there were 302 unique 3TG smelter or refiner facilities reported by Dell’s suppliers, 244 of which participate in RMAP. Many suppliers returned CMRTs representing their full supply chains, rather than scoping specifically to components incorporated into Dell’s Covered Products, indicating that not all smelters and refiners reported are providing material for Dell products. Dell publishes the full list of smelters and refiners reported by our suppliers in Appendix B.
The list of countries from which we believe 3TG in our Covered Products may have originated is published in Appendix A. Some 3TG also originates from recycled or scrap sources. This information was obtained using the Reasonable Country of Origin Inquiry (RCOI) report dated January 31, 2020 that is available to Dell as a member of RMI.
Step 5: Report on Supply Chain Due Diligence
This report and Dell’s Form SD will be filed with the SEC and be publicly available at www.sec.gov and www.dell.com/supplychain.
Dell also provides information related to social and environmental responsibility on our website and in our annual Supply Chain Sustainability Progress Reports.
References to Dell’s website are provided for convenience only, and its contents are not incorporated by reference into this report nor are they deemed filed with the SEC.
Continuous Improvement to Mitigate Risk
Dell intends to take the following steps, among others, to continue to improve the due diligence conducted by it and to further mitigate any future risk of sourcing 3TG that benefits armed groups from the Covered Countries:
1) | Continue to work closely with suppliers to obtain the necessary information on the origin of 3TG contained in the materials or components used in the Covered Products. |
2) | Work with smelters and refiners through our engagement with RMI to promote participation in RMAP. |
3) | Monitor incidents related to OECD Annex II risks to assess their impact on Dell’s supply chain. |
4) | Continue partnering with organizations dedicated to supporting mining communities and contributing to ethical sourcing of minerals. |
Cautionary Statement about Forward-Looking Statements
Statements in this report that relate to future events are forward-looking statements within the meaning of Section 21E of the Securities Exchange Act of 1934 and Section 27A of the Securities Act of 1933 and are based on Dell’s current expectations. In some cases, you can identify these statements by such forward-looking words as “anticipate,” “believe,” “confidence,” “could,” “estimate,” “expect,” “guidance,” “intend,” “may,” “objective,” “outlook,” “plan,” “project,” “possible,” “potential,” “should,” “will” and “would,” or similar words or expressions that refer to future events or outcomes. Dell’s results or events in future periods could differ materially from those expressed or implied by these forward-looking statements because of risks, uncertainties, and other factors, including those risks described in its reports filed with the SEC, including Dell’s Annual Report on Form 10-K for the fiscal year ended January 31, 2020, quarterly reports on Form 10-Q, and current reports on Form 8-K. These filings are available for review through the SEC’s website at www.sec.gov. Any or all forward-looking statements Dell makes may turn out to be wrong and can be affected by inaccurate assumptions Dell might make or by known or unknown risks, uncertainties and other factors, including those identified in this report. Accordingly, you should not place undue reliance on the forward-looking statements made in this report, which speak only as of its date. Dell does not undertake to update, and expressly disclaims any duty to update, its forward-looking statements, whether as a result of circumstances or events that arise after the date they are made, new information, or otherwise.
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Appendix A: Reasonable Country of Origin Inquiry List
Countries from which the minerals in Dell’s products may have originated based on sourcing information disclosed during the RMAP’s third-party auditing process and RMI’s Reasonable Country of Origin Inquiry report dated January 31, 2020. The origin of the 3TG processed by facilities listed in Appendix B are believed to be the following:
Argentina | Germany | Mexico | Somaliland |
Australia | Ghana | Mongolia | South Africa |
Austria | Guinea | Mozambique | Spain |
Bolivia | Guyana | Myanmar | Taiwan |
Brazil | India | Namibia | Tanzania |
Burundi | Indonesia | Nicaragua | Thailand |
Canada | Iceland | Niger | Uganda |
Chile | Japan | Nigeria | United Kingdom |
China | Kenya | Peru | United States of America |
Colombia | Laos | Portugal | Venezuela |
Democratic Republic of the Congo | Madagascar | Russian Federation | Vietnam |
Ecuador | Malaysia | Rwanda | Zimbabwe |
Ethiopia | Mali | Sierra Leone | |
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Appendix B: Dell Smelter and Refiner List
This list is based on Dell supplier data for the Reporting Period. In many cases, suppliers provided information encompassing their entire supply chain; this information was not limited to facilities that contributed 3TG used only in Dell products. As a result, we are unable to confirm whether our products in fact contain 3TG from all of these sources. This list only includes facilities reported by suppliers that are on the RMAP standard smelter list as of February 29, 2020.
Metal | Smelter Name | Smelter Country (*) |
Tantalum | Asaka Riken Co., Ltd. | JAPAN |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Global Advanced Metals Aizu | JAPAN |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Tantalum | H.C. Starck Co., Ltd. | THAILAND |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | KEMET Blue Metals | MEXICO |
Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA |
Tantalum | LSM Brasil S.A. | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
Tantalum | Mineracao Taboca S.A. | BRAZIL |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | NPM Silmet AS | ESTONIA |
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
Tantalum | QuantumClean | UNITED STATES OF AMERICA |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemical Co., Ltd. | JAPAN |
Tantalum | Telex Metals | UNITED STATES OF AMERICA |
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Metal | Smelter Name | Smelter Country (*) |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
Tin | Alpha | UNITED STATES OF AMERICA |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
Tin | Dowa | JAPAN |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | Estanho de Rondonia S.A. | BRAZIL |
Tin | Fenix Metals | POLAND |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd.” | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
Tin | Luna Smelter, Ltd. | RWANDA |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Melt Metais e Ligas S.A. | BRAZIL |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
Tin | Metallo Belgium N.V. | BELGIUM |
Tin | Metallo Spain S.L.U. | SPAIN |
Tin | Mineracao Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Modeltech Sdn Bhd | MALAYSIA |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
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Metal | Smelter Name | Smelter Country (*) |
Tin | Pongpipat Company Limited | MYANMAR |
Tin | Precious Minerals and Smelting Limited | INDIA |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT Refined Bangka Tin | INDONESIA |
Tin | PT Timah Tbk Kundur | INDONESIA |
Tin | PT Timah Tbk Mentok | INDONESIA |
Tin | Resind Industria e Comercio Ltda. | BRAZIL |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Super Ligas | BRAZIL |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM |
Tin | Thaisarco | THAILAND |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Company Limited | CHINA |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
Gold | 8853 S.p.A. | ITALY |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
Gold | African Gold Refinery | UGANDA |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
Gold | Argor-Heraeus S.A. | SWITZERLAND |
Gold | Asahi Pretec Corp. | JAPAN |
Gold | Asahi Refining Canada Ltd. | CANADA |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | AU Traders and Refiners | SOUTH AFRICA |
Gold | Aurubis AG | GERMANY |
Gold | Bangalore Refinery | INDIA |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
Gold | Boliden AB | SWEDEN |
Gold | C. Hafner GmbH + Co. KG | GERMANY |
Gold | Caridad | MEXICO |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
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Metal | Smelter Name | Smelter Country (*) |
Gold | Cendres + Metaux S.A. | SWITZERLAND |
Gold | CGR Metalloys Pvt Ltd. | INDIA |
Gold | Chimet S.p.A. | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
Gold | DODUCO Contacts and Refining GmbH | GERMANY |
Gold | Dowa | JAPAN |
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Italpreziosi | ITALY |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Kazzinc | KAZAKHSTAN |
11
Metal | Smelter Name | Smelter Country (*) |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
Gold | L'Orfebre S.A. | ANDORRA |
Gold | Lingbao Gold Co., Ltd. | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Marsam Metals | BRAZIL |
Gold | Materion | UNITED STATES OF AMERICA |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
Gold | Metalor Technologies S.A. | SWITZERLAND |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
Gold | Mitsubishi Materials Corporation | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
Gold | Modeltech Sdn Bhd | MALAYSIA |
Gold | Morris and Watson | NEW ZEALAND |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | NH Recytech Company | KOREA, REPUBLIC OF |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | PAMP S.A. | SWITZERLAND |
Gold | Pease & Curren | UNITED STATES OF AMERICA |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Planta Recuperadora de Metales SpA | CHILE |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
12
Metal | Smelter Name | Smelter Country (*) |
Gold | PX Precinox S.A. | SWITZERLAND |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
Gold | REMONDIS PMR B.V. | NETHERLANDS |
Gold | Royal Canadian Mint | CANADA |
Gold | SAAMP | FRANCE |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
Gold | Safimet S.p.A | ITALY |
Gold | SAFINA A.S. | CZECHIA |
Gold | Sai Refinery | INDIA |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
Gold | Sovereign Metals | INDIA |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
Gold | Sudan Gold Refinery | SUDAN |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
Gold | T.C.A S.p.A | ITALY |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | Tony Goetz NV | BELGIUM |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | Umicore Brasil Ltda. | BRAZIL |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
Gold | Valcambi S.A. | SWITZERLAND |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
13
Metal | Smelter Name | Smelter Country (*) |
Gold | Yamakin Co., Ltd. | JAPAN |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Tungsten | A.L.M.T. Corp. | JAPAN |
Tungsten | ACL Metais Eireli | BRAZIL |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tungsten | CP Metals Inc. | UNITED STATES OF AMERICA |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | GEM Co., Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
Tungsten | Japan New Metals Co., Ltd. | JAPAN |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
14
Metal | Smelter Name | Smelter Country (*) |
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
15