UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
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H.B. FULLER COMPANY
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(Exact name of the registrant as specified in its charter)
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Minnesota
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001-09225
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41-0268370
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(State or other jurisdiction of
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(Commission
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(IRS Employer
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incorporation or organization)
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File Number)
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Identification No.)
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1200 Willow Lake Boulevard, P.O. Box 64683 St. Paul, MN
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55164-0683
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(Address of principle executive offices)
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(Zip code)
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John J. Corkrean, Executive Vice President and Chief Financial Officer (651) 236-5900
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(Name and telephone number, including area code, of the person to contact in connection with this report.)
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Check the appropriate box to indicate the rule pursuant to which this form is being filed and provide the period to which the information in this form applies:
☒
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Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
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☐
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Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the reporting period from January 1 to December 31, 2023.
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Section 1 – Conflict Minerals Disclosure
Item 1.01 – Conflicts Minerals Disclosure and Report
This Form SD of H.B. Fuller Company (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023.
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available at www.hbfuller.com.
Item 1.02 Exhibit
As specified in Item 1.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01. Resource Extraction Issuer Disclosure and Report
Not applicable
Section 3 -- Exhibits
Item 3.01 Exhibits
The following exhibit is filed as part of this report.
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.
May 31, 2024
H.B. FULLER COMPANY
By:
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/s/ John J. Corkrean |
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John J. Corkrean
Executive Vice President and Chief Financial Officer
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Exhibit 1.01
H.B. FULLER COMPANY
Conflict Minerals Report
For the reporting period from January 1, 2023 to December 31, 2023
This Conflict Minerals Report (the “Report”) of H.B. Fuller Company (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities and Exchange Act of 1934, as amended, for the reporting period from January 1, 2023 to December 31, 2023.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which we collectively refer to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain of the Company’s operations manufacture, or contract to manufacture, products, and the Conflict Minerals are necessary to the functionality of those products.
If a registrant has reason to believe that any of the Conflict Minerals necessary to the functionality or production of their products may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the source of the Conflict Minerals. The registrant must annually submit a report, Conflict Minerals Report (a “CMR”), to the U.S. Securities and Exchange Commission (the “SEC”) that includes a description of those due diligence measures.
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a.
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Company Overview. The Company is a leading worldwide formulator, manufacturer and marketer of adhesives, sealants and other specialty chemical products. Sales operations span 35 countries in North America, Europe, Latin America, the Asia Pacific region, India, the Middle East and Africa. Industrial adhesives represent our core product offering. Customers use our adhesives products in manufacturing common consumer and industrial goods, including food and beverage containers, disposable diapers, medical products, windows, doors, appliances, sportswear, footwear, multi-wall bags, water filtration products, insulation, textiles, automobiles, recreational vehicles, buses, trucks and trailers, marine products, solar energy systems, electronics and products for the aerospace and defense industries. In addition, we have established a variety of product offerings for residential, commercial and industrial construction markets, including sealing and waterproofing solutions for airports, roads, highways, bridges and utilities; pressure-sensitive adhesives, tapes and sealants for the commercial roofing industry; and level-setting products, ready-to-use grouts, mortars, and pressure sensitive adhesives that enable contractors and do-it-yourself consumers to quickly install flooring and tiling applications more reliably and efficiently. We also provide our customers with technical support and unique solutions designed to address their specific needs.
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b.
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Conflict Minerals Compliance Program (CMCP) Description. The SEC Final Conflict Minerals Rule (the “SEC Final Rule”) requires a three-step compliance process: the first step is determining the applicability of the Rule; the second step is conducting a “reasonable country of origin inquiry” (RCOI) to determine whether or not there is reason to believe that tin, tantalum, tungsten, or gold (3TG), also referred to as Conflict Minerals, from the Democratic Republic of the Congo or adjoining countries are present in the company’s products; and if so, the third step is conducting due diligence to determine the source and origin of those Conflict Minerals based on the facilities (smelter or refiners, “SORs”) in which they were processed. Companies requiring due diligence must use a nationally or internationally recognized standard such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance1) to meet the SEC regulatory requirements. The sections below describe our approach to meet each of the three steps in the SEC Final Rule compliance process; these activities were completed in concert with a third party vendor.
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1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
2.
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Applicability of the Conflict Minerals Rule.
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a.
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Product Overview. This report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2023. These products (referred to collectively as “Covered Products” in this Report) are the following:
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Certain equipment used or sold in our Adhesive Coated Products business, which the Company manufactures or contracts to manufacture, which contain electronic components and materials.
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Certain products manufactured or assembled by Engent, Inc. ("Engent"), a subsidiary of the Company, for its customers which contain electronic components and materials. Engent, Inc. is a wholly owned subsidiary of the Company and is a provider of manufacturing, research and development services to the electronics industry.
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Certain equipment manufactured or assembled by Tonsan Adhesive, Inc. ("Tonsan"), a subsidiary of the Company, for its customers which contain electronic components and materials. Tonsan, which is based in Beijing, China, manufactures engineering adhesives across numerous industries including photovoltaic, electronics, automotive, heavy machinery and transportation.
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3. Reasonable Country of Origin Inquiry (RCOI). The Company has conducted a good faith reasonable country of origin inquiry regarding the Conflict Minerals. This good faith reasonable country of origin inquiry was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap resources.
To complete the RCOI required by the SEC Final Rule, we engaged the Company’s applicable suppliers to collect information about the presence and sourcing of tantalum, tin, tungsten and gold (3TG) used in the products and components supplied to H.B. Fuller. The program utilized the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (CMRT). Only CMRT version 6.31 or higher was accepted. Suppliers were offered two options to submit the required information: either by uploading the CMRT in MS Excel format or by completing an online survey version of this template directly in the vendor platform. In certain cases, if a supplier was unable to complete on the platform, H.B. Fuller or its third-party vendor uploaded the CMRT on their behalf.
The RCOI began with an introduction email sent by H.B. Fuller to its relevant suppliers describing the Conflict Minerals Compliance Program (CMCP) and identifying our vendor as a partner in the process. This letter also contained a registration and survey request link for the on-line data collection platform.
Subsequent engagement followed these steps:
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Following the initial introductions to the program and information request, up to three reminder emails were sent to each non-responsive supplier requesting survey completion.
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For suppliers who remained non-responsive to these email reminders, an escalation process was initiated. The Company contacted the non-responsive suppliers to request their participation in the program.
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Suppliers were asked to provide information regarding the sourcing of their materials with the goal of identifying the 3TG smelters or refiners (“SORs”) and associated mine countries of origin. Suppliers who had already performed a RCOI through the use of the CMRT were asked to upload this document into the vendor system or to provide this information in the online survey version.
The Company gave its suppliers the ability to share information at a level with which they were most comfortable (i.e. company, product or user-defined), but the declaration scope had to be specified.
Suppliers were requested to provide an electronic signature before submitting their data to the Company to verify that all answers submitted were accurate to the best of the supplier’s knowledge, but the suppliers were not required to provide an electronic signature to submit their data.
Supplier responses were evaluated for plausibility, consistency, and gaps. If any of the following “quality control” (QC) flags were raised, suppliers were contacted by the vendor on a bi-weekly basis up to three times.
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One or more smelter or refiners (SORs) were listed for an unused metal;
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SOR information was not provided for a used metal, or SOR information provided was not a verified metal processor;
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Supplier answered yes to sourcing from the Democratic Republic of the Congo or adjoining countries (“DRC”), but none of the SORs listed are known to source from the region;
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Supplier indicated that they have not received Conflict Minerals data for each metal from all relevant suppliers;
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Supplier indicated they have not identified all of the SORs used for the products included in the declaration scope;
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Supplier indicated they have not provided all applicable SOR information received; and;
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Supplier indicated 100% of the 3TG for products covered by the declaration originates from scrap/recycled sources, but one or more SORs listed are not known to be exclusive recyclers.
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In response to our RCOI, most smelters in our supply chain that refined Conflict Minerals sourced these materials from countries other than Covered Countries. Some Conflict Minerals in our supply chain may have originated from the Covered Countries. The majority of smelters in our supply chain are certified as noted on Schedule 1.
4. Design of Due Diligence Framework. The Company’s due diligence measures have been designed to conform to the framework in the OECD Guidance in all material respects.
5. Due Diligence Measures Performed. The Company has adopted a policy relating to Conflict Minerals (the “Company Policy”), incorporating the standards set forth in the OECD Guidance. The policy generally states that the Company is committed to ethical practices and compliance with applicable laws and regulations, including the SEC’s regulations and the Conflict Minerals Rules. The Company does not generally source Conflict Minerals directly from the source of supply (mines, smelters, refiners) and the Company is therefore generally removed by several levels from sources of supply of Conflict Minerals. The Company Policy commits the Company to diligently work with its global supply chain partners to identify the origin of any Conflict Minerals they may supply to the Company. The Company is committed to compliance with the Conflict Minerals Rules, including understanding the Conflict Minerals Rules, communicating and educating our personnel, suppliers and customers regarding the Conflict Minerals Rules and to create processes and procedures to conduct supply chain due diligence and comply with reporting requirements. The Company values its supplier and customer relationships and will work with our suppliers over time to ensure our compliance with the Conflict Minerals Rules.
The Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals and has therefore asked its suppliers to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain. Most of the suppliers who provided information regarding smelters provided this information on a company level versus a product level. Therefore, we do not know if the materials from the smelters we have included in this Conflict Minerals Report are in our products. It is possible that we may not get product level information.
The Company has a steering committee which oversees the activities of a multi-functional group of personnel who have worked on due diligence and compliance related to Conflict Minerals. The composition of the steering committee includes two executive level officers. The multi-functional group includes employees from the Company covering areas such as regulatory, sourcing, finance, legal, and operations.
In general, in our initial compliance efforts, a review of products and raw materials contained therein (including chemical composition) or components (for equipment) was completed and a list of suppliers of raw materials or components where Conflict Minerals were determined to be potentially present was assembled. New products and the raw materials used in those products are reviewed as such products are developed. The focus has been on top-tier suppliers of these raw materials or components. For these top-tier suppliers, the Company used a third-party vendor to send out questionnaires including the EICC®-GeSI form (“Supplier Questionnaire”) to inquire about the country of origin of Conflict Minerals potentially included in the Company’s Covered Products. This template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a supplier’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the supplier and its suppliers use. In addition, the template contains questions about the origin of Conflict Minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are available on EICC’s website. Responses to these questionnaires were monitored and follow-up communication was sent if a response was not received. The Company has not had any direct contact with mines, smelters or refiners.
The Company has undertaken an internal education process to ensure that relevant personnel are aware of the Conflict Minerals Rules and it has conducted training of several employee groups since the inception of due diligence efforts. In addition, it has designated personnel to respond to customer and supplier inquiries regarding the Conflict Minerals Rules. These personnel are part of the multi-functional group working on due diligence and compliance efforts.
The Company will continue to review any suppliers who are materially non-compliant with our Conflict Minerals Policy and communicate the Company’s expectation regarding compliance with our Conflict Minerals Policy. The Company will make reasonable efforts to find suppliers who comply with our Conflict Minerals Policy and who will meet our needs. The products that we manufacture that are subject to the reporting obligations of the Rule contain 3TG of unknown origin. We have not been able to determine whether the 3TG used in our products came from recycled or scrap sources, or if not, whether the 3TG originated from a Covered Country, or the specific facilities used to process these minerals, or their specific country, location or mine of origin.
Facilities That May Have Been Used to Process Necessary Conflict Minerals, if Known, for H.B. Fuller Products.
Schedule 1 to this Conflict Minerals Report includes a list of facilities that may have been used to process necessary Conflict Minerals for Company products. This list is based on our due diligence for 2023. Most of the information was provided to us on a company level versus a product level, and the suppliers did not generally limit their responses to facility information for Conflict Minerals in products they supply to us specifically.
Countries of Origin of the Conflict Minerals Processed by These Facilities.
Schedule 2 to this Conflict Minerals Report includes a list of potential countries of origin for each facility noted on the Schedule to the extent identified by the applicable smelter. Conflict Minerals contained in our Covered Products did not necessarily originate in the countries listed on Schedule 2. This is because our suppliers and manufacturers generally provided smelter and country of origin information in the survey responses at the company level (representing the suppliers’ and manufacturers’ entire product lines), and generally did not limit their responses to countries of origin for products they supply to us specifically. A small number of suppliers reported that the 3TG in their products comes from or may come from the Covered Countries, and some of these suppliers further reported that some of the 3TG in their products comes from scrap or recycled sources.
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a.
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Summary of Survey Results and Conclusion.
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Based on the due diligence efforts and the absence of full supply chain visibility, the Company is unable to determine the source of origin of the Conflict Minerals and does not have sufficient information to conclusively determine the countries of origin of 3TG in the Company’s Covered Products.
As set forth above, the Company will continue to engage with its suppliers to obtain complete and accurate information about its supply chain as it relates to Conflict Minerals and their origins.
Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements, which are based on our current expectations and involve numerous risks and uncertainties that may cause these forward-looking statements to be inaccurate. These statements include statements regarding our goals for future improvements to our due diligence process and to mitigate the risk about the sourcing of our Conflict Minerals. All forward-looking statements involve risk and uncertainty. Risks that may cause these forward-looking statements to be inaccurate include, without limitation: failure to carry out these plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; and lack of progress by smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities). In addition, you should also consider the important factors described in reports and documents that we file from time to time with the SEC, including the factors described under the sections titled “Risk Factors” in our most recently submitted Annual and Quarterly Reports on Form 10-K and Form 10-Q, respectively, and there may be other risks and uncertainties that we are unable to identify at this time. We do not undertake to update or revise any forward-looking statements, except as required by law.
Schedule 1
Metal
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Standard Smelter or Refiner Name
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Facility Location (Country)
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Certified Smelter*
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Gold
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8853 S.p.A.
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Italy
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NO
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Gold
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ABC Refinery Pty Ltd.
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Australia
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NO
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Gold
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Abington Reldan Metals, LLC
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United States
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YES
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Gold
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Advanced Chemical Company
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United States
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NO
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Gold
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African Gold Refinery
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Uganda
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NO
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Gold
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Agosi AG
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Germany
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YES
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Gold
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Aida Chemical Industries Co., Ltd.
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Japan
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YES
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Gold
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Al Etihad Gold Refinery DMCC
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United Arab Emirates
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NO
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Gold
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Albino Mountinho Lda.
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Portugal
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NO
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Gold
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Alexy Metals
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United States
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NO
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Gold
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Almalyk Mining and Metallurgical Complex (AMMC)
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Uzbekistan
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YES
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Gold
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AngloGold Ashanti Corrego do Sitio Mineracao
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Brazil
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YES
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Gold
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Argor-Heraeus S.A.
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Switzerland
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YES
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Gold
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Asahi Pretec Corp.
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Japan
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YES
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Gold
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Asahi Refining Canada Ltd.
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Canada
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YES
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Gold
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Asahi Refining USA Inc.
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United States
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YES
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Gold
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Asaka Riken Co., Ltd.
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Japan
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YES
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Gold
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Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
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Turkey
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NO
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Gold
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AU Traders and Refiners
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South Africa
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NO
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Gold
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Augmont Enterprises Private Limited
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India
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NO
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Gold
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Aurubis AG
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Germany
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YES
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Gold
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Bangalore Refinery
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India
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NO
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Gold
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
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Philippines
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YES
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Gold
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Boliden AB
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Sweden
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YES
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Gold
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C. Hafner GmbH + Co. KG
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Germany
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YES
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Gold
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Caridad
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Mexico
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NO
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Gold
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CCR Refinery - Glencore Canada Corporation
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Canada
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YES
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Gold
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Cendres + Metaux S.A.
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Switzerland
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NO
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Gold
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CGR Metalloys Pvt Ltd.
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India
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NO
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Gold
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Chimet S.p.A.
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Italy
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YES
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Gold
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Chugai Mining
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Japan
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YES
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Gold
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Coimpa Industrial LTDA
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Brazil
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YES
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Gold
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Daye Non-Ferrous Metals Mining Ltd.
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China
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NO
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Gold
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Degussa Sonne / Mond Goldhandel GmbH
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Germany
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NO
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Gold
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Dijllah Gold Refinery FZC
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United Arab Emirates
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NO
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Gold
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Dongwu Gold Group
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China
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NO
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Gold
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Dowa
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Japan
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YES
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Gold
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DSC (Do Sung Corporation)
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Republic of Korea
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YES
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Gold
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Eco-System Recycling Co., Ltd. East Plant
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Japan
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YES
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Gold
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Eco-System Recycling Co., Ltd. North Plant
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Japan
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YES
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Gold
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Eco-System Recycling Co., Ltd. West Plant
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Japan
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YES
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Gold
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Emerald Jewel Industry India Limited (Unit 1)
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India
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NO
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Gold
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Emerald Jewel Industry India Limited (Unit 2)
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India
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NO
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Gold
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Emerald Jewel Industry India Limited (Unit 3)
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India
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NO
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Gold
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Emerald Jewel Industry India Limited (Unit 4)
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India
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NO
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Gold
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Emirates Gold DMCC
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United Arab Emirates
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NO
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Gold
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Fidelity Printers and Refiners Ltd.
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Zimbabwe
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NO
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Gold
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Fujairah Gold FZC
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United Arab Emirates
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NO
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Gold
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GGC Gujrat Gold Centre Pvt. Ltd.
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India
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NO
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Gold
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Gold by Gold Colombia
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Colombia
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YES
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Gold
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Gold Coast Refinery
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Ghana
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NO
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Gold
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Gold Refinery of Zijin Mining Group Co., Ltd.
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China
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YES
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Gold
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Great Wall Precious Metals Co., Ltd. of CBPM
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China
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YES
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Gold
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Guangdong Jinding Gold Limited
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China
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NO
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Gold
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Guoda Safina High-Tech Environmental Refinery Co., Ltd.
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China
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NO
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Gold
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Hangzhou Fuchunjiang Smelting Co., Ltd.
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China
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NO
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Gold
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Heimerle + Meule GmbH
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Germany
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YES
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Gold
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Heraeus Germany GmbH Co. KG
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Germany
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YES
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Gold
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Heraeus Metals Hong Kong Ltd.
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China
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YES
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Gold
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Hunan Chenzhou Mining Co., Ltd.
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China
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NO
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Gold
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Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
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China
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NO
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Gold
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HwaSeong CJ CO., LTD.
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Republic of Korea
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NO
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Gold
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Industrial Refining Company
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Belgium
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NO
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Gold
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Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
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China
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YES
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Gold
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International Precious Metal Refiners
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United Arab Emirates
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NO
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Gold
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Ishifuku Metal Industry Co., Ltd.
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Japan
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YES
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Gold
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Istanbul Gold Refinery
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Turkey
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YES
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Gold
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Italpreziosi
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Italy
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YES
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Gold
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JALAN & Company
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India
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NO
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Gold
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Japan Mint
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Japan
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YES
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Gold
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Jiangxi Copper Co., Ltd.
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China
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YES
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Gold
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JSC Ekaterinburg Non-Ferrous Metal Processing Plant
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Russian Federation
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NO
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Gold
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JSC Novosibirsk Refinery
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Russian Federation
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NO
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Gold
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JSC Uralelectromed
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Russian Federation
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NO
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Gold
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JX Nippon Mining & Metals Co., Ltd.
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Japan
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YES
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Gold
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K.A. Rasmussen
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Norway
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NO
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Gold
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Kaloti Precious Metals
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United Arab Emirates
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NO
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Gold
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Kazakhmys Smelting LLC
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Kazakhstan
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NO
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Gold
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Kazzinc
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Kazakhstan
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YES
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Gold
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Kennecott Utah Copper LLC
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United States
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YES
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Gold
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KGHM Polska Miedz Spolka Akcyjna
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Poland
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YES
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Gold
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Kojima Chemicals Co., Ltd.
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Japan
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YES
|
Gold
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Korea Zinc Co., Ltd.
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Republic of Korea
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YES
|
Gold
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Kundan Care Products Ltd.
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India
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NO
|
Gold
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Kyrgyzaltyn JSC
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Kyrgyzstan
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NO
|
Gold
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Kyshtym Copper-Electrolytic Plant ZAO
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Russian Federation
|
NO
|
Gold
|
L'azurde Company For Jewelry
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Saudi Arabia
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NO
|
Gold
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Lingbao Gold Co., Ltd.
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China
|
NO
|
Gold
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Lingbao Jinyuan Tonghui Refinery Co., Ltd.
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China
|
NO
|
Gold
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L'Orfebre S.A.
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Andorra
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YES
|
Gold
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LS-NIKKO Copper Inc.
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Republic of Korea
|
YES
|
Gold
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LT Metal Ltd.
|
Republic of Korea
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YES
|
Gold
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Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
|
China
|
NO
|
Gold
|
Marsam Metals
|
Brazil
|
NO
|
Gold
|
Materion
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United States
|
YES
|
Gold
|
Matsuda Sangyo Co., Ltd.
|
Japan
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YES
|
Gold
|
MD Overseas
|
India
|
NO
|
Gold
|
Metal Concentrators SA (Pty) Ltd.
|
South Africa
|
YES
|
Gold
|
Metallix Refining Inc.
|
United States
|
NO
|
Gold
|
Metalor Technologies (Hong Kong) Ltd.
|
China
|
YES
|
Gold
|
Metalor Technologies (Singapore) Pte., Ltd.
|
Singapore
|
YES
|
Gold
|
Metalor Technologies (Suzhou) Ltd.
|
China
|
YES
|
Gold
|
Metalor Technologies S.A.
|
Switzerland
|
YES
|
Gold
|
Metalor USA Refining Corporation
|
United States
|
YES
|
Gold
|
Metalurgica Met-Mex Penoles S.A. De C.V.
|
Mexico
|
YES
|
Gold
|
Mitsubishi Materials Corporation
|
Japan
|
YES
|
Gold
|
Mitsui Mining and Smelting Co., Ltd.
|
Japan
|
YES
|
Gold
|
MKS PAMP SA
|
Switzerland
|
YES
|
Gold
|
MMTC-PAMP India Pvt., Ltd.
|
India
|
YES
|
Gold
|
Modeltech Sdn Bhd
|
Malaysia
|
NO
|
Gold
|
Morris and Watson
|
New Zealand
|
NO
|
Gold
|
Moscow Special Alloys Processing Plant
|
Russian Federation
|
NO
|
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.S.
|
Turkey
|
YES
|
Gold
|
Navoi Mining and Metallurgical Combinat
|
Uzbekistan
|
YES
|
Gold
|
NH Recytech Company
|
Republic of Korea
|
YES
|
Gold
|
Nihon Material Co., Ltd.
|
Japan
|
YES
|
Gold
|
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
|
Austria
|
YES
|
Gold
|
Ohura Precious Metal Industry Co., Ltd.
|
Japan
|
YES
|
Gold
|
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
|
Russian Federation
|
NO
|
Gold
|
Pease & Curren
|
United States
|
NO
|
Gold
|
Penglai Penggang Gold Industry Co., Ltd.
|
China
|
NO
|
Gold
|
Planta Recuperadora de Metales SpA
|
Chile
|
YES
|
Gold
|
Prioksky Plant of Non-Ferrous Metals
|
Russian Federation
|
NO
|
Gold
|
PT Aneka Tambang (Persero) Tbk
|
Indonesia
|
YES
|
Gold
|
PX Precinox S.A.
|
Switzerland
|
YES
|
Gold
|
QG Refining, LLC
|
United States
|
NO
|
Gold
|
Rand Refinery (Pty) Ltd.
|
South Africa
|
YES
|
Gold
|
Refinery of Seemine Gold Co., Ltd.
|
China
|
NO
|
Gold
|
REMONDIS PMR B.V.
|
Netherlands
|
YES
|
Gold
|
Royal Canadian Mint
|
Canada
|
YES
|
Gold
|
SAAMP
|
France
|
NO
|
Gold
|
Sabin Metal Corp.
|
United States
|
NO
|
Gold
|
Safimet S.p.A
|
Italy
|
NO
|
Gold
|
SAFINA A.S.
|
Czech Republic
|
YES
|
Gold
|
Sai Refinery
|
India
|
NO
|
Gold
|
Sam Precious Metals
|
United Arab Emirates
|
NO
|
Gold
|
Samduck Precious Metals
|
Republic of Korea
|
NO
|
Gold
|
SAMWON METALS Corp.
|
Republic of Korea
|
NO
|
Gold
|
SEMPSA Joyeria Plateria S.A.
|
Spain
|
YES
|
Gold
|
Shandong Gold Smelting Co., Ltd.
|
China
|
YES
|
Gold
|
Shandong Humon Smelting Co., Ltd.
|
China
|
NO
|
Gold
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
|
China
|
NO
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
China
|
YES
|
Gold
|
Shenzhen CuiLu Gold Co., Ltd.
|
China
|
NO
|
Gold
|
Shenzhen Zhonghenglong Real Industry Co., Ltd.
|
China
|
NO
|
Gold
|
Shirpur Gold Refinery Ltd.
|
India
|
NO
|
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
China
|
YES
|
Gold
|
Singway Technology Co., Ltd.
|
Taiwan, Province of China
|
NO
|
Gold
|
SOE Shyolkovsky Factory of Secondary Precious Metals
|
Russian Federation
|
NO
|
Gold
|
Solar Applied Materials Technology Corp.
|
Taiwan, Province of China
|
YES
|
Gold
|
Sovereign Metals
|
India
|
NO
|
Gold
|
State Research Institute Center for Physical Sciences and Technology
|
Lithuania
|
NO
|
Gold
|
Sudan Gold Refinery
|
Sudan
|
NO
|
Gold
|
Sumitomo Metal Mining Co., Ltd.
|
Japan
|
YES
|
Gold
|
SungEel HiMetal Co., Ltd.
|
Republic of Korea
|
YES
|
Gold
|
Super Dragon Technology Co., Ltd.
|
Taiwan, Province of China
|
NO
|
Gold
|
T.C.A S.p.A
|
Italy
|
YES
|
Gold
|
Tanaka Kikinzoku Kogyo K.K.
|
Japan
|
YES
|
Gold
|
Tokuriki Honten Co., Ltd.
|
Japan
|
YES
|
Gold
|
Tongling Nonferrous Metals Group Co., Ltd.
|
China
|
NO
|
Gold
|
TOO Tau-Ken-Altyn
|
Kazakhstan
|
YES
|
Gold
|
Torecom
|
Republic of Korea
|
YES
|
Gold
|
Umicore Precious Metals Thailand
|
Thailand
|
NO
|
Gold
|
Umicore S.A. Business Unit Precious Metals Refining
|
Belgium
|
YES
|
Gold
|
United Precious Metal Refining, Inc.
|
United States
|
YES
|
Gold
|
Valcambi S.A.
|
Switzerland
|
YES
|
Gold
|
WEEEREFINING
|
France
|
YES
|
Gold
|
Western Australian Mint (T/a The Perth Mint)
|
Australia
|
YES
|
Gold
|
WIELAND Edelmetalle GmbH
|
Germany
|
YES
|
Gold
|
Yamakin Co., Ltd.
|
Japan
|
YES
|
Gold
|
Yokohama Metal Co., Ltd.
|
Japan
|
YES
|
Gold
|
Yunnan Copper Industry Co., Ltd.
|
China
|
NO
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
China
|
YES
|
Tantalum
|
5D Production OU
|
Estonia
|
NO
|
Tantalum
|
AMG Brasil
|
Brazil
|
YES
|
Tantalum
|
Changsha South Tantalum Niobium Co., Ltd.
|
China
|
YES
|
Tantalum
|
D Block Metals, LLC
|
United States
|
YES
|
Tantalum
|
F&X Electro-Materials Ltd.
|
China
|
YES
|
Tantalum
|
FIR Metals & Resource Ltd.
|
China
|
YES
|
Tantalum
|
Global Advanced Metals Aizu
|
Japan
|
YES
|
Tantalum
|
Global Advanced Metals Boyertown
|
United States
|
YES
|
Tantalum
|
Guangdong Rising Rare Metals-EO Materials Ltd.
|
China
|
NO
|
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
China
|
YES
|
Tantalum
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
|
China
|
YES
|
Tantalum
|
Jiangxi Tuohong New Raw Material
|
China
|
YES
|
Tantalum
|
JiuJiang JinXin Nonferrous Metals Co., Ltd.
|
China
|
YES
|
Tantalum
|
Jiujiang Tanbre Co., Ltd.
|
China
|
YES
|
Tantalum
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
|
China
|
YES
|
Tantalum
|
KEMET de Mexico
|
Mexico
|
YES
|
Tantalum
|
Materion Newton Inc.
|
United States
|
YES
|
Tantalum
|
Metallurgical Products India Pvt., Ltd.
|
India
|
YES
|
Tantalum
|
Mineracao Taboca S.A.
|
Brazil
|
YES
|
Tantalum
|
Mitsui Mining and Smelting Co., Ltd.
|
Japan
|
YES
|
Tantalum
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
China
|
YES
|
Tantalum
|
NPM Silmet AS
|
Estonia
|
YES
|
Tantalum
|
PowerX Ltd.
|
Rwanda
|
YES
|
Tantalum
|
QuantumClean
|
United States
|
YES
|
Tantalum
|
Resind Industria e Comercio Ltda.
|
Brazil
|
YES
|
Tantalum
|
RFH Yancheng Jinye New Material Technology Co., Ltd.
|
China
|
YES
|
Tantalum
|
Solikamsk Magnesium Works OAO
|
Russian Federation
|
NO
|
Tantalum
|
Taki Chemical Co., Ltd.
|
Japan
|
YES
|
Tantalum
|
TANIOBIS Co., Ltd.
|
Thailand
|
YES
|
Tantalum
|
TANIOBIS GmbH
|
Germany
|
YES
|
Tantalum
|
TANIOBIS Japan Co., Ltd.
|
Japan
|
YES
|
Tantalum
|
TANIOBIS Smelting GmbH & Co. KG
|
Germany
|
YES
|
Tantalum
|
Telex Metals
|
United States
|
YES
|
Tantalum
|
Ulba Metallurgical Plant JSC
|
Kazakhstan
|
YES
|
Tantalum
|
XIMEI RESOURCES (GUANGDONG) LIMITED
|
China
|
YES
|
Tantalum
|
XinXing Haorong Electronic Material Co., Ltd.
|
China
|
YES
|
Tantalum
|
Yanling Jincheng Tantalum & Niobium Co., Ltd.
|
China
|
YES
|
Tin
|
Alpha
|
United States
|
YES
|
Tin
|
An Vinh Joint Stock Mineral Processing Company
|
Vietnam
|
NO
|
Tin
|
Aurubis Beerse
|
Belgium
|
YES
|
Tin
|
Aurubis Berango
|
Spain
|
YES
|
Tin
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
|
China
|
YES
|
Tin
|
Chifeng Dajingzi Tin Industry Co., Ltd.
|
China
|
YES
|
Tin
|
China Tin Group Co., Ltd.
|
China
|
YES
|
Tin
|
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
|
Brazil
|
YES
|
Tin
|
CRM Synergies
|
Spain
|
YES
|
Tin
|
CV Ayi Jaya
|
Indonesia
|
YES
|
Tin
|
CV Venus Inti Perkasa
|
Indonesia
|
YES
|
Tin
|
Dongguan CiEXPO Environmental Engineering Co., Ltd.
|
China
|
NO
|
Tin
|
Dowa
|
Japan
|
YES
|
Tin
|
DS Myanmar
|
Myanmar
|
YES
|
Tin
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
|
Vietnam
|
NO
|
Tin
|
EM Vinto
|
Bolivia
|
YES
|
Tin
|
Estanho de Rondonia S.A.
|
Brazil
|
YES
|
Tin
|
Fabrica Auricchio Industria e Comercio Ltda.
|
Brazil
|
YES
|
Tin
|
Fenix Metals
|
Poland
|
YES
|
Tin
|
Gejiu City Fuxiang Industry and Trade Co., Ltd.
|
China
|
NO
|
Tin
|
Gejiu Kai Meng Industry and Trade LLC
|
China
|
NO
|
Tin
|
Gejiu Non-Ferrous Metal Processing Co., Ltd.
|
China
|
YES
|
Tin
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
China
|
NO
|
Tin
|
Gejiu Zili Mining And Metallurgy Co., Ltd.
|
China
|
NO
|
Tin
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
|
China
|
YES
|
Tin
|
HuiChang Hill Tin Industry Co., Ltd.
|
China
|
YES
|
Tin
|
Jiangxi New Nanshan Technology Ltd.
|
China
|
YES
|
Tin
|
Luna Smelter, Ltd.
|
Rwanda
|
YES
|
Tin
|
Ma'anshan Weitai Tin Co., Ltd.
|
China
|
NO
|
Tin
|
Magnu's Minerais Metais e Ligas Ltda.
|
Brazil
|
YES
|
Tin
|
Malaysia Smelting Corporation (MSC)
|
Malaysia
|
YES
|
Tin
|
Melt Metais e Ligas S.A.
|
Brazil
|
NO
|
Tin
|
Metallic Resources, Inc.
|
United States
|
YES
|
Tin
|
Mineracao Taboca S.A.
|
Brazil
|
YES
|
Tin
|
Mining Minerals Resources SARL
|
DRC- Congo (Kinshasa)
|
YES
|
Tin
|
Minsur
|
Peru
|
YES
|
Tin
|
Mitsubishi Materials Corporation
|
Japan
|
YES
|
Tin
|
Modeltech Sdn Bhd
|
Malaysia
|
NO
|
Tin
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company
|
Vietnam
|
NO
|
Tin
|
Novosibirsk Tin Combine
|
Russian Federation
|
NO
|
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
Thailand
|
YES
|
Tin
|
O.M. Manufacturing Philippines, Inc.
|
Philippines
|
YES
|
Tin
|
Operaciones Metalurgicas S.A.
|
Bolivia
|
YES
|
Tin
|
Pongpipat Company Limited
|
Myanmar
|
NO
|
Tin
|
Precious Minerals and Smelting Limited
|
India
|
NO
|
Tin
|
PT Aries Kencana Sejahtera
|
Indonesia
|
YES
|
Tin
|
PT Artha Cipta Langgeng
|
Indonesia
|
YES
|
Tin
|
PT ATD Makmur Mandiri Jaya
|
Indonesia
|
YES
|
Tin
|
PT Babel Inti Perkasa
|
Indonesia
|
YES
|
Tin
|
PT Babel Surya Alam Lestari
|
Indonesia
|
YES
|
Tin
|
PT Bangka Prima Tin
|
Indonesia
|
YES
|
Tin
|
PT Bangka Serumpun
|
Indonesia
|
YES
|
Tin
|
PT Bangka Tin Industry
|
Indonesia
|
NO
|
Tin
|
PT Belitung Industri Sejahtera
|
Indonesia
|
NO
|
Tin
|
PT Bukit Timah
|
Indonesia
|
YES
|
Tin
|
PT Cipta Persada Mulia
|
Indonesia
|
YES
|
Tin
|
PT Menara Cipta Mulia
|
Indonesia
|
YES
|
Tin
|
PT Mitra Stania Prima
|
Indonesia
|
YES
|
Tin
|
PT Mitra Sukses Globalindo
|
Indonesia
|
YES
|
Tin
|
PT Panca Mega Persada
|
Indonesia
|
NO
|
Tin
|
PT Premium Tin Indonesia
|
Indonesia
|
YES
|
Tin
|
PT Prima Timah Utama
|
Indonesia
|
YES
|
Tin
|
PT Putera Sarana Shakti (PT PSS)
|
Indonesia
|
YES
|
Tin
|
PT Rajawali Rimba Perkasa
|
Indonesia
|
YES
|
Tin
|
PT Rajehan Ariq
|
Indonesia
|
YES
|
Tin
|
PT Refined Bangka Tin
|
Indonesia
|
YES
|
Tin
|
PT Sariwiguna Binasentosa
|
Indonesia
|
YES
|
Tin
|
PT Stanindo Inti Perkasa
|
Indonesia
|
YES
|
Tin
|
PT Sukses Inti Makmur
|
Indonesia
|
YES
|
Tin
|
PT Timah Tbk Kundur
|
Indonesia
|
YES
|
Tin
|
PT Timah Tbk Mentok
|
Indonesia
|
YES
|
Tin
|
PT Tinindo Inter Nusa
|
Indonesia
|
YES
|
Tin
|
PT Tirus Putra Mandiri
|
Indonesia
|
NO
|
Tin
|
PT Tommy Utama
|
Indonesia
|
YES
|
Tin
|
Resind Industria e Comercio Ltda.
|
Brazil
|
YES
|
Tin
|
Rui Da Hung
|
Taiwan, Province of China
|
YES
|
Tin
|
Super Ligas
|
Brazil
|
YES
|
Tin
|
Thaisarco
|
Thailand
|
YES
|
Tin
|
Tin Smelting Branch of Yunnan Tin Co., Ltd.
|
China
|
YES
|
Tin
|
Tin Technology & Refining
|
United States
|
YES
|
Tin
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company
|
Vietnam
|
NO
|
Tin
|
VQB Mineral and Trading Group JSC
|
Vietnam
|
NO
|
Tin
|
White Solder Metalurgia e Mineracao Ltda.
|
Brazil
|
YES
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
China
|
YES
|
Tin
|
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
|
China
|
YES
|
Tungsten
|
A.L.M.T. TUNGSTEN Corp.
|
Japan
|
YES
|
Tungsten
|
ACL Metais Eireli
|
Brazil
|
NO
|
Tungsten
|
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
|
Brazil
|
NO
|
Tungsten
|
Artek LLC
|
Russian Federation
|
NO
|
Tungsten
|
Asia Tungsten Products Vietnam Ltd.
|
Vietnam
|
YES
|
Tungsten
|
China Molybdenum Co., Ltd.
|
China
|
YES
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
China
|
YES
|
Tungsten
|
CNMC (Guangxi) PGMA Co., Ltd.
|
China
|
NO
|
Tungsten
|
Cronimet Brasil Ltda
|
Brazil
|
YES
|
Tungsten
|
DONGKUK INDUSTRIES CO., LTD.
|
Republic of Korea
|
NO
|
Tungsten
|
Fujian Xinlu Tungsten Co., Ltd.
|
China
|
YES
|
Tungsten
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
China
|
YES
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
China
|
YES
|
Tungsten
|
Global Tungsten & Powders Corp.
|
United States
|
YES
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
China
|
YES
|
Tungsten
|
H.C. Starck Tungsten GmbH
|
Germany
|
YES
|
Tungsten
|
HANNAE FOR T Co., Ltd.
|
Republic of Korea
|
NO
|
Tungsten
|
Hubei Green Tungsten Co., Ltd.
|
China
|
YES
|
Tungsten
|
Hunan Chenzhou Mining Co., Ltd.
|
China
|
YES
|
Tungsten
|
Hunan Jintai New Material Co., Ltd.
|
China
|
NO
|
Tungsten
|
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
|
China
|
YES
|
Tungsten
|
Hydrometallurg, JSC
|
Russian Federation
|
NO
|
Tungsten
|
Japan New Metals Co., Ltd.
|
Japan
|
YES
|
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
China
|
YES
|
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
China
|
YES
|
Tungsten
|
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
|
China
|
NO
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
China
|
YES
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
China
|
YES
|
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
China
|
YES
|
Tungsten
|
JSC "Kirovgrad Hard Alloys Plant"
|
Russian Federation
|
NO
|
Tungsten
|
Kennametal Fallon
|
United States
|
YES
|
Tungsten
|
Kennametal Huntsville
|
United States
|
YES
|
Tungsten
|
Lianyou Metals Co., Ltd.
|
Taiwan, Province of China
|
YES
|
Tungsten
|
LLC Vostok
|
Russian Federation
|
NO
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
China
|
YES
|
Tungsten
|
Masan High-Tech Materials
|
Vietnam
|
YES
|
Tungsten
|
Moliren Ltd.
|
Russian Federation
|
NO
|
Tungsten
|
Nam Viet Cromit Joint Stock Company
|
Vietnam
|
NO
|
Tungsten
|
Niagara Refining LLC
|
United States
|
YES
|
Tungsten
|
NPP Tyazhmetprom LLC
|
Russian Federation
|
NO
|
Tungsten
|
OOO “Technolom” 1
|
Russian Federation
|
NO
|
Tungsten
|
OOO “Technolom” 2
|
Russian Federation
|
NO
|
Tungsten
|
Philippine Chuangxin Industrial Co., Inc.
|
Philippines
|
YES
|
Tungsten
|
Shinwon Tungsten (Fujian Shanghang) Co., Ltd.
|
China
|
YES
|
Tungsten
|
TANIOBIS Smelting GmbH & Co. KG
|
Germany
|
YES
|
Tungsten
|
Tungsten Vietnam Joint Stock Company
|
Vietnam
|
YES
|
Tungsten
|
Unecha Refractory Metals Plant
|
Russian Federation
|
NO
|
Tungsten
|
Wolfram Bergbau und Hutten AG
|
Austria
|
YES
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
China
|
YES
|
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
China
|
YES
|
Tungsten
|
YUDU ANSHENG TUNGSTEN CO., LTD.
|
China
|
NO
|
* A “Yes” in this column indicates that the smelter (i) has an active certification with the Responsible Minerals Assurance Process (“RMAP”) or is in the process of renewing their certification, (ii) is actively moving through the RMAP certification process, (iii) is a tungsten smelter that has committed to obtain a RMAP certification within 2 years of membership with the Tungsten Industry-Conflict Minerals Committee (TI-CMC), (iv) has obtained a Responsible Gold Certification from the London Bullion Market Association (LBMA), or (v) has obtained a Chain-of-Custody Certification from the Responsible Jewelry Council (RJC).
A “No” in this column indicates that we are unaware of one of the above-referenced certifications for this smelter.
Schedule 2
The following list of potential countries of origin is based on publicly available information, our RCOI, and due diligence. It is important to note that this is also based on company level responses and therefore it is not certain which of these countries of origin can be linked to our products.
Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Republic of the Congo, Czech Republic, Democratic Republic of the Congo, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong SAR, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Jersey, Kazakhstan, Kenya, Republic of Korea, Kyrgyzstan, Laos, Luxembourg, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Sweden, Switzerland, Taiwan (Province of China), Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Vietnam, Zambia, Zimbabwe.
Grafico Azioni H B Fuller (NYSE:FUL)
Storico
Da Dic 2024 a Gen 2025
Grafico Azioni H B Fuller (NYSE:FUL)
Storico
Da Gen 2024 a Gen 2025