Published on May 25, 2017
Exhibit 1.01
Ball Corporation
Conflict Minerals Report
For the Year Ended December 31, 2016
Introduction
This Conflict Minerals Report ("CMR") for the year ended December 31, 2016, is presented to comply with Rule 13p‑1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives which are limited to tin, tantalum, tungsten, and gold ("3TG" or "Conflict Minerals"). The reporting and disclosure requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
Company Overview
This report has been prepared by the Company (herein referred to as "Ball," the "Company," "we," "us," or "our"). The information provided in this CMR includes the activities of all our majority-owned subsidiaries and variable interest entities that are required to be consolidated.
Ball supplies innovative, sustainable packaging solutions for beverage, food and household products customers, as well as aerospace and other technologies and services primarily for the U.S. government. Our principal products include metal packaging for beverage, food and household products, as well as components related to aerospace and other technologies. We conducted an analysis of our products and found that some of our products contain Conflict Minerals that are necessary to their functionality or production.
Initially, we engaged with consultants to assist us with the design and implementation of our due diligence program, and to help establish processes and procedures for the review and validation of supplier responses. We continue to take steps to improve our program over previous years, including refining our due diligence program, and improving engagement with our suppliers to increase our response rates and the quality of responses received.
Reasonable Country of Origin Inquiry
In accordance with the Rule, we conducted, in good faith, a reasonable country of origin inquiry ("RCOI") designed to determine whether any of the necessary Conflict Minerals in our products originated in the Democratic Republic of the Congo or an adjoining country (the "Covered Countries") or were from recycled or scrap sources.
We used the Conflict Free Sourcing Initiative's ("CFSI") conflict minerals reporting template (the "Reporting Template") to obtain sourcing information from our direct suppliers. Our RCOI included assessing the responses we received from our suppliers in accordance with our due diligence framework.
1
Based on our assessment of the responses from our suppliers, we have reason to believe that some of the necessary 3TG used in our products may have originated in a Covered Country and may not have come from recycled or scrap sources.
Due Diligence
1. |
Design of Due Diligence
|
Our due diligence program has been designed to conform in all material respects with the framework in The Organisation for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas, and the related Supplements for gold and for tin, tantalum and tungsten (the "OECD Guidance"). Ball took the following steps in accordance with our due diligence program:
a. |
Establish Strong Company Management Systems
|
The Company has adopted and made public a conflict minerals policy. Our policy can be found at http://www.ball.com/Ball/media/Ball/Global/Downloads/Ball_Conflict_Minerals_Policy.pdf. This policy is made available to employees through an internal company portal, is publicly available on the Ball website, and is also disseminated to suppliers during our RCOI process. In addition to our conflict minerals policy, Ball has a Ball Business Ethics Code of Conduct ("The Code"), which outlines expected behaviors for all of our employees. The Code addresses Ball's commitment to compliance with all laws applicable to the way we do business and to social sustainability.
In order to strengthen engagement with suppliers, as part of establishing management systems, we have Supplier Guiding Principles, which are included as an exhibit to our form supplier agreements. The Supplier Guiding Principles, among other things, state our expectation that our suppliers will maintain ethical business practices, including compliance with laws related to human rights. More specifically, in 2016 we continued to include a Conflict Minerals certification as part of our form supplier agreements. Since many of our agreements are long-term contracts, it will take several years for existing agreements to expire and for the Conflict Minerals certification to be included in all supplier agreements.
We utilized the Reporting Template as a tool to collect information from our suppliers regarding the smelters and refiners from which Conflict Minerals in materials and/or components that are supplied to us are derived. We also continue to engage our suppliers through follow-up to improve response quality pursuant to our due diligence program, which includes steps to review responses.
Key management members and subject matter experts implement the due diligence program, including training new employees involved in the due diligence program and conducting Conflict Minerals Working Group meetings as deemed necessary. This group also implements procedures to review supplier responses, engage with suppliers and maintain records.
2
b. |
Identify and Assess Risk in the Supply Chain
|
We identified suppliers that potentially provide materials and/or components containing Conflict Minerals for our beverage, food or aerosol containers and the components manufactured by our aerospace division pursuant to the steps in our due diligence program.
In our efforts to determine the mine or location of origin of any Conflict Minerals in our supply chain with the greatest possible specificity, we sent in-scope suppliers the Reporting Template, requesting information pertaining to the source of Conflict Minerals in their materials and/or components, including the source of Conflict Minerals contained in any recycled or scrap materials. Responses were tracked, accompanying information or documentation was reviewed, and additional requests for information were sent, as deemed necessary. Follow-up was performed pursuant to our due diligence program with non-responders and suppliers that provided incomplete responses, based on internally defined criteria, in an effort to obtain more detailed information. Any named smelters in the responses were reviewed against the CFSI Conflict-Free Smelter Program's ("CFSI Program") list of conflict free smelters to confirm conflict-free status.
c. |
Design and Implement a Strategy to Respond to Risks
|
As described above, we utilize the Reporting Template to collect information from suppliers and identify risk. When a potential risk is identified, such as nonresponsive suppliers, incomplete Reporting Templates (based on internally defined criteria), or other potential risks, further inquiry takes place. The risk mitigation element of our due diligence program is dependent on the unique circumstances of any issues that may arise. Senior management members of the Conflict Minerals Working Group are advised of any situation where a potential risk is identified. We will also contact any of our suppliers found to be sourcing from the Covered Countries through noncertified smelters or potentially high-risk smelters, and potentially seek to establish an alternative source for Conflict Minerals.
d. |
Carryout Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
|
As part of our due diligence program, we rely on the information provided on the CFSI Program website to determine if the smelters disclosed by our suppliers are certified as conflict free.
e. |
Report on Supply Chain Due Diligence
|
Our due diligence program includes filing our Form SD and CMR with the SEC on an annual basis, as well as making our CMR publicly available at http://www.ball.com/Ball/media/Ball/Global/Downloads/Ball_Conflict_Minerals_Policy.pdf, as required by the Rule.
3
2. |
Supplier Survey Results
|
Inherent Limitation on Due Diligence Measures
As a downstream purchaser of materials and components that may contain Conflict Minerals, Ball must necessarily rely, in good faith, on our direct suppliers to provide us with information about the source of Conflict Minerals contained in the materials and/or components supplied to us. We do not have direct relationships with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain.
Results
As noted above, Ball supplies innovative, sustainable packaging solutions for beverage, food and household products customers, as well as aerospace and other technologies and services primarily for the U.S. government. The combined results of our due diligence are reported below:
We received responses from seventy-seven percent (77%) of the suppliers surveyed. Twenty-two percent (22%) of the suppliers surveyed indicated in their responses that their products contained no 3TG; thus they were not in-scope. Approximately fifty-seven (57%) of the in-scope suppliers surveyed indicated that materials or components they provided to the Company included Conflict Minerals from the Covered Countries; however these suppliers also indicated that the smelters through which these Conflict Minerals were processed are CFSI Program approved smelters, which we verified to be conflict free against the CFSI Program list of conflict free smelters. Forty-three percent (43%) of the in-scope suppliers surveyed remain undeterminable due to incomplete responses (based on internally defined criteria). Twenty-three percent (23%) of the suppliers surveyed did not respond to our initial survey request or the additional follow-up we conducted pursuant to our due diligence program.
3. |
Description of Products, Facilities Used and Country of Origin of Necessary Conflict Minerals
|
Ball is a manufacturer of metal packaging products as well as aerospace hardware, which are produced in a network of manufacturing facilities around the world. The tin contained in our metal packaging products is contained in the raw materials provided by our metal suppliers. Our aerospace hardware includes electronic components that contain tantalum, tin, tungsten and gold.
We have identified two hundred and seventy-two (272) smelters from our combined business. This smelter information is provided in Exhibit A. Approximately seventeen (17) smelters listed were not certified as conflict free under the CFSI Program as of the time we reviewed the CFSI Program list of certified conflict free smelters when our due diligence program was performed. It should be noted that, pursuant to CFSI Program rules and the certification process thereunder, some smelters may not have been compliant for the whole year, some may have failed their re-audit since our due diligence was performed and may be in the process of addressing relevant issues, or some smelters may have expired certifications since our due diligence was performed and a re-audit may or may not currently be in process. It should be noted that two (2) smelters included on our smelter list were certified as conflict free under the CFSI Program as of the time of our due diligence program was performed; however, there have been recent news articles regarding these particular smelters suggesting they may not be conflict free, although they are still reported as such on the CFSI Program list. The Company and the relevant suppliers continue to monitor the smelters' certification under the CFSI Program.
4
4. |
Steps to be Taken to Mitigate Risk
|
We intend to take the following steps to improve due diligence conducted regarding Conflict Minerals to further mitigate any risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries:
a. |
We will continue to review our due diligence process to ensure all relevant suppliers are sent the Reporting Template, that information is adequately collected and reviewed, appropriate follow-up measures are taken, and that any documentation is centrally collected and maintained.
|
b. |
We will continue tracking communication with suppliers to attempt to increase the response rate and improve content and accuracy of the supplier Reporting Template responses.
|
c. |
We will attempt to engage any of our suppliers found to be supplying us with 3TG from Covered Countries that support conflict to establish an alternative source of 3TG that does not support such conflict.
|
d. |
We will continue to include a Conflict Minerals clause in new supplier contracts.
|
5
Exhibit A
CFSI Program Processing Facilities as of May 25, 20171
Metal (*)
|
Smelter Name (*)
|
Facility Location(*)
|
Compliant
|
Gold
|
Advanced Chemical Company
|
United States of America
|
Yes
|
Gold
|
Almalyk Mining and Metallurgical Complex (AMMC)
|
Uzbekistan
|
Yes
|
Gold
|
Argor-Heraeus S.A.
|
Switzerland
|
Yes
|
Gold
|
Asahi Pretec Corp.
|
Japan
|
Yes
|
Gold
|
Asahi Refining Canada Ltd.
|
Canada
|
Yes
|
Gold
|
Asahi Refining USA Inc.
|
United States of America
|
Yes
|
Gold
|
Asaka Riken Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
|
Turkey
|
Yes
|
Gold
|
Aurubis AG
|
Germany
|
Yes
|
Gold
|
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
|
Philippines
|
Yes
|
Gold
|
Boliden AB
|
Sweden
|
Yes
|
Gold
|
C. Hafner GmbH + Co. KG
|
Germany
|
Yes
|
Gold
|
Caridad
|
Mexico
|
Yes
|
Gold
|
CCR Refinery - Glencore Canada Corporation
|
Canada
|
Yes
|
Gold
|
Chimet S.p.A.
|
Italy
|
Yes
|
Gold
|
Chugai Mining
|
Japan
|
Yes
|
Gold
|
Daejin Indus Co., Ltd.
|
Korea (Republic of)
|
Yes
|
Gold
|
Daye Non-Ferrous Metals Mining Ltd.
|
China
|
Yes
|
Gold
|
DODUCO GmbH
|
Germany
|
Yes
|
Gold
|
DSC (Do Sung Corporation)
|
Korea (Republic of)
|
Yes
|
Gold
|
Eco-System Recycling Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Elemetal Refining, LLC
|
United States of America
|
Yes
|
Gold
|
Gansu Seemine Material Hi-Tech Co., Ltd.
|
China
|
Yes
|
Gold
|
Geib Refining Corporation
|
United States of America
|
Yes
|
Gold
|
Great Wall Precious Metals Co., Ltd. of CBPM
|
China
|
Yes
|
Gold
|
Guangdong Jinding Gold Limited
|
China
|
Yes
|
Gold
|
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
|
China
|
Yes
|
Gold
|
Hangzhou Fuchunjiang Smelting Co., Ltd.
|
China
|
Yes
|
Gold
|
Heimerle + Meule GmbH
|
Germany
|
Yes
|
Gold
|
Heraeus Ltd. Hong Kong
|
China
|
Yes
|
Gold
|
Heraeus Precious Metals GmbH & Co. KG
|
Germany
|
Yes
|
Gold
|
HwaSeong CJ Co., Ltd.
|
Korea (Republic of)
|
Yes
|
Gold
|
Ishifuku Metal Industry Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Istanbul Gold Refinery
|
Turkey
|
Yes
|
Gold
|
Japan Mint
|
Japan
|
Yes
|
Gold
|
Jiangxi Copper Co., Ltd.
|
China
|
Yes
|
Gold
|
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
|
Russian Federation
|
Yes
|
Gold
|
JSC Uralelectromed
|
Russian Federation
|
Yes
|
Gold
|
JX Nippon Mining & Metals Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Kazakhmys Smelting LLC
|
Kazakhstan
|
Yes
|
Gold
|
Kazzinc
|
Kazakhstan
|
Yes
|
Gold
|
Kennecott Utah Copper LLC
|
United States of America
|
Yes
|
Gold
|
Kojima Chemicals Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Kyrgyzaltyn JSC
|
Kyrgyzstan
|
Yes
|
Gold
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
|
China
|
Yes
|
1
Metal (*)
|
Smelter Name (*)
|
Facility Location(*)
|
Compliant
|
Gold
|
LS-NIKKO Copper Inc.
|
Korea (Republic of)
|
Yes
|
Gold
|
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
|
China
|
Yes
|
Gold
|
Materion
|
United States of America
|
Yes
|
Gold
|
Matsuda Sangyo Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Metalor Technologies SA
|
Switzerland
|
Yes
|
Gold
|
Metalor USA Refining Corporation
|
United States of America
|
Yes
|
Gold
|
Metalúrgica Met-Mex Peñoles S.A. De C.V.
|
Mexico
|
Yes
|
Gold
|
Mitsui Mining and Smelting Co., Ltd.
|
Japan
|
Yes
|
Gold
|
MMTC-PAMP India Pvt., Ltd.
|
India
|
Yes
|
Gold
|
Morris and Watson
|
New Zealand
|
Yes
|
Gold
|
Moscow Special Alloys Processing Plant
|
Russian Federation
|
Yes
|
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.Ş.
|
Turkey
|
Yes
|
Gold
|
Navoi Mining and Metallurgical Combinat
|
Uzbekistan
|
Yes
|
Gold
|
Nihon Material Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
|
Austria
|
Yes
|
Gold
|
Ohura Precious Metal Industry Co., Ltd.
|
Japan
|
Yes
|
Gold
|
OJSC Novosibirsk Refinery
|
Russian Federation
|
Yes
|
Gold
|
PAMP S.A.
|
Switzerland
|
Yes
|
Gold
|
Penglai Penggang Gold Industry Co., Ltd.
|
China
|
Yes
|
Gold
|
Prioksky Plant of Non-Ferrous Metals
|
Russian Federation
|
Yes
|
Gold
|
PT Aneka Tambang (Persero) Tbk
|
Indonesia
|
Yes
|
Gold
|
Rand Refinery (Pty) Ltd.
|
South Africa
|
Yes
|
Gold
|
Republic Metals Corporation
|
United States of America
|
Yes
|
Gold
|
Royal Canadian Mint
|
Canada
|
Yes
|
Gold
|
Sabin Metal Corp.
|
United States of America
|
Yes
|
Gold
|
Samduck Precious Metals
|
Korea (Republic of)
|
Yes
|
Gold
|
Samwon Metals Corp.
|
Korea (Republic of)
|
Yes
|
Gold
|
SAXONIA Edelmetalle GmbH
|
Germany
|
Yes
|
Gold
|
Schone Edelmetaal B.V.
|
Netherlands
|
Yes
|
Gold
|
SEMPSA Joyería Platería S.A.
|
Spain
|
Yes
|
Gold
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
|
China
|
Yes
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
China
|
Yes
|
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
China
|
Yes
|
Gold
|
Singway Technology Co., Ltd.
|
Taiwan, Province of China
|
Yes
|
Gold
|
So Accurate Group, Inc.
|
United States of America
|
Yes
|
Gold
|
SOE Shyolkovsky Factory of Secondary Precious Metals
|
Russian Federation
|
Yes
|
Gold
|
Solar Applied Materials Technology Corp.
|
Taiwan, Province of China
|
Yes
|
Gold
|
Sumitomo Metal Mining Co., Ltd.
|
Japan
|
Yes
|
Gold
|
T.C.A S.p.A
|
Italy
|
Yes
|
Gold
|
Tanaka Kikinzoku Kogyo K.K.
|
Japan
|
Yes
|
Gold
|
The Refinery of Shandong Gold Mining Co., Ltd.
|
China
|
Yes
|
Gold
|
Tokuriki Honten Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Tongling Nonferrous Metals Group Co., Ltd.
|
China
|
Yes
|
Gold
|
Torecom
|
Korea (Republic of)
|
Yes
|
Gold
|
Umicore Brasil Ltda.
|
Brazil
|
Yes
|
Gold
|
Umicore Precious Metals Thailand
|
Thailand
|
Yes
|
Gold
|
Umicore S.A. Business Unit Precious Metals Refining
|
Belgium
|
Yes
|
Gold
|
United Precious Metal Refining, Inc.
|
United States of America
|
Yes
|
2
Metal (*)
|
Smelter Name (*)
|
Facility Location(*)
|
Compliant
|
Gold
|
Western Australian Mint trading as The Perth Mint
|
Australia
|
Yes
|
Gold
|
WIELAND Edelmetalle GmbH
|
Germany
|
Yes
|
Gold
|
Yamamoto Precious Metal Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Yokohama Metal Co., Ltd.
|
Japan
|
Yes
|
Gold
|
Yunnan Copper Industry Co., Ltd.
|
China
|
Yes
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
China
|
Yes
|
Gold
|
Zijin Mining Group Co., Ltd. Gold Refinery
|
China
|
Yes
|
Gold; Tin
|
Dowa
|
Japan
|
Yes
|
Gold; Tin
|
Mitsubishi Materials Corporation
|
Japan
|
Yes
|
Gold; Tungsten
|
Hunan Chenzhou Mining Co., Ltd.
|
China
|
Yes
|
Tantalum
|
Changsha South Tantalum Niobium Co., Ltd.
|
China
|
Yes
|
Tantalum
|
Conghua Tantalum and Niobium Smeltry
|
China
|
Yes
|
Tantalum
|
D Block Metals, LLC
|
United States of America
|
Yes
|
Tantalum
|
Duoluoshan
|
China
|
Yes
|
Tantalum
|
E.S.R. Electronics
|
United States of America
|
Yes
|
Tantalum
|
Exotech Inc.
|
United States of America
|
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 of America
|
Yes
|
Tantalum
|
Guangdong Zhiyuan New Material Co., Ltd.
|
China
|
Yes
|
Tantalum
|
H.C. Starck Co., Ltd.
|
Thailand
|
Yes
|
Tantalum
|
H.C. Starck GmbH Goslar
|
Germany
|
Yes
|
Tantalum
|
H.C. Starck GmbH Laufenburg
|
Germany
|
Yes
|
Tantalum
|
H.C. Starck Hermsdorf GmbH
|
Germany
|
Yes
|
Tantalum
|
H.C. Starck Inc.
|
United States of America
|
Yes
|
Tantalum
|
H.C. Starck Ltd.
|
Japan
|
Yes
|
Tantalum
|
H.C. Starck Smelting GmbH & Co. KG
|
Germany
|
Yes
|
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
China
|
Yes
|
Tantalum
|
Hi-Temp Specialty Metals, Inc.
|
United States of America
|
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 Blue Metals
|
Mexico
|
Yes
|
Tantalum
|
KEMET Blue Powder
|
United States of America
|
Yes
|
Tantalum
|
King-Tan Tantalum Industry Ltd.
|
China
|
Yes
|
Tantalum
|
LSM Brasil S.A.
|
Brazil
|
Yes
|
Tantalum
|
Metallurgical Products India Pvt., Ltd.
|
India
|
Yes
|
Tantalum
|
Mitsui Mining & Smelting
|
Japan
|
Yes
|
Tantalum
|
Molycorp Silmet A.S.
|
Estonia
|
Yes
|
Tantalum
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
China
|
Yes
|
Tantalum
|
Plansee SE Reutte
|
Austria
|
Yes
|
Tantalum
|
QuantumClean
|
United States of America
|
Yes
|
Tantalum
|
RFH Tantalum Smeltry Co., Ltd.
|
China
|
Yes
|
Tantalum
|
Solikamsk Magnesium Works OAO
|
Russian Federation
|
Yes
|
3
Metal (*)
|
Smelter Name (*)
|
Facility Location(*)
|
Compliant
|
Tantalum
|
Taki Chemical Co., Ltd.
|
Japan
|
Yes
|
Tantalum
|
Telex Metals
|
United States of America
|
Yes
|
Tantalum
|
Tranzact, Inc.
|
United States of America
|
Yes
|
Tantalum
|
Ulba Metallurgical Plant JSC
|
Kazakhstan
|
Yes
|
Tantalum
|
XinXing HaoRong Electronic Material Co., Ltd.
|
China
|
Yes
|
Tantalum
|
Yichun Jin Yang Rare Metal Co., Ltd.
|
China
|
Yes
|
Tantalum
|
Zhuzhou Cemented Carbide
|
China
|
Yes
|
Tantalum
|
Zhuzhou Cemented Carbide Group Co., Ltd.
|
China
|
Yes
|
Tantalum; Tin
|
Mineração Taboca S.A.
|
Brazil
|
Yes
|
Tantalum; Tin
|
Resind Indústria e Comércio Ltda.
|
Brazil
|
Yes
|
Tin
|
Alpha
|
United States of America
|
|
Tin
|
An Vinh Joint Stock Mineral Processing Company
|
Vietnam
|
Yes
|
Tin
|
China Tin Group Co., Ltd.
|
China
|
Yes
|
Tin
|
CNMC (Guangxi) PGMA Co., Ltd.
|
China
|
Yes
|
Tin
|
Cooperativa Metalurgica de Rondônia Ltda.
|
Brazil
|
Yes
|
Tin
|
CV Ayi Jaya
|
Indonesia
|
Yes
|
Tin
|
CV Gita Pesona
|
Indonesia
|
Yes
|
Tin
|
CV Serumpun Sebalai
|
Indonesia
|
Yes
|
Tin
|
CV Tiga Sekawan
|
Indonesia
|
Yes
|
Tin
|
CV United Smelting
|
Indonesia
|
Yes
|
Tin
|
CV Venus Inti Perkasa
|
Indonesia
|
Yes
|
Tin
|
Electro-Mechanical Facility of the Cao Bang Minerals &
Metallurgy Joint Stock Company |
Vietnam
|
Yes
|
Tin
|
EM Vinto
|
Bolivia (Plurinational State of)
|
Yes
|
Tin
|
Estanho de Rondônia S.A.
|
Brazil
|
Yes
|
Tin
|
Feinhütte Halsbrücke GmbH
|
Germany
|
No
|
Tin
|
Fenix Metals
|
Poland
|
Yes
|
Tin
|
Gejiu Kai Meng Industry and Trade LLC
|
China
|
Yes
|
Tin
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
China
|
Yes
|
Tin
|
Gejiu Zili Mining And Metallurgy Co., Ltd.
|
China
|
Yes
|
Tin
|
Huichang Jinshunda Tin Co., Ltd.
|
China
|
Yes
|
Tin
|
Jiangxi Ketai Advanced Material Co., Ltd.
|
China
|
Yes
|
Tin
|
Linwu Xianggui Ore Smelting Co., Ltd.
|
China
|
No
|
Tin
|
Malaysia Smelting Corporation (MSC)
|
Malaysia
|
Yes
|
Tin
|
Melt Metais e Ligas S.A.
|
Brazil
|
Yes
|
Tin
|
Metallic Resources, Inc.
|
United States
|
No
|
Tin
|
Metallo-Chimique N.V.
|
Belgium
|
Yes
|
Tin
|
Minsur
|
Peru
|
Yes
|
Tin
|
Nankang Nanshan Tin Manufactory Co., Ltd.
|
China
|
Yes
|
Tin
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company
|
Vietnam
|
Yes
|
Tin
|
O.M. Manufacturing Philippines, Inc.
|
Philippines
|
Yes
|
Tin
|
Operaciones Metalurgical S.A.
|
Bolivia (Plurinational State of)
|
Yes
|
Tin
|
Phoenix Metal Ltd.
|
Rwanda
|
Yes
|
Tin
|
PT Alam Lestari Kencana
|
Indonesia
|
No
|
Tin
|
PT Aries Kencana Sejahtera
|
Indonesia
|
Yes
|
Tin
|
PT Artha Cipta Langgeng
|
Indonesia
|
Yes
|
Tin
|
PT ATD Makmur Mandiri Jaya
|
Indonesia
|
Yes
|
4
Metal (*)
|
Smelter Name (*)
|
Facility Location(*)
|
Compliant
|
|
Tin
|
PT Babel Inti Perkasa
|
Indonesia
|
Yes
|
|
Tin
|
PT Bangka Kudai Tin
|
Indonesia
|
No
|
|
Tin
|
PT Bangka Prima Tin
|
Indonesia
|
Yes
|
|
Tin
|
PT Belitung Industri Sejahtera
|
Indonesia
|
Yes
|
|
Tin
|
PT BilliTin Makmur Lestari
|
Indonesia
|
No
|
|
Tin
|
PT Bukit Timah
|
Indonesia
|
Yes
|
|
Tin
|
PT Cipta Persada Mulia
|
Indonesia
|
Yes
|
|
Tin
|
PT DS Jaya Abadi
|
Indonesia
|
Yes
|
|
Tin
|
PT Eunindo Usaha Mandiri
|
Indonesia
|
Yes
|
|
Tin
|
PT Fang Di MulTindo
|
Indonesia
|
No
|
|
Tin
|
PT Inti Stania Prima
|
Indonesia
|
Yes
|
|
Tin
|
PT Justindo
|
Indonesia
|
Yes
|
|
Tin
|
PT Karimun Mining
|
Indonesia
|
Yes
|
|
Tin
|
PT Lautan Harmonis Sejahtera
|
Indonesia
|
Yes
|
|
Tin
|
PT Mitra Stania Prima
|
Indonesia
|
Yes
|
|
Tin
|
PT Panca Mega Persada
|
Indonesia
|
Yes
|
|
Tin
|
PT Pelat Timah Nusantara Tbk
|
Indonesia
|
No
|
|
Tin
|
PT Prima Timah Utama
|
Indonesia
|
Yes
|
|
Tin
|
PT Refined Bangka Tin
|
Indonesia
|
Yes
|
|
Tin
|
PT Sariwiguna Binasentosa
|
Indonesia
|
Yes
|
|
Tin
|
PT Seirama Tin Investment
|
Indonesia
|
No
|
|
Tin
|
PT Stanindo Inti Perkasa
|
Indonesia
|
Yes
|
|
Tin
|
PT Sukses Inti Makmur
|
Indonesia
|
Yes
|
|
Tin
|
PT Sumber Jaya Indah
|
Indonesia
|
No
|
|
Tin
|
PT Timah (Persero) Tbk Kundur
|
Indonesia
|
Yes
|
|
Tin
|
PT Timah (Persero) Tbk Mentok
|
Indonesia
|
No
|
|
Tin
|
PT Timah Nusantara
|
Indonesia
|
No
|
|
Tin
|
PT Tinindo Inter Nusa
|
Indonesia
|
Yes
|
|
Tin
|
PT Tirus Putra Mandiri
|
Indonesia
|
Yes
|
|
Tin
|
PT Tommy Utama
|
Indonesia
|
Yes
|
|
Tin
|
PT Wahana Perkit Jaya
|
Indonesia
|
Yes
|
|
Tin
|
Rui Da Hung
|
Taiwan
|
Yes
|
|
Tin
|
Soft Metais Ltda.
|
Brazil
|
Yes
|
|
Tin
|
Thaisarco
|
Thailand
|
Yes
|
|
Tin
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company
|
Vietnam
|
Yes
|
|
Tin
|
VQB Mineral and Trading Group JSC
|
Vietnam
|
Yes
|
|
Tin
|
White Solder Metalurgia e Mineração Ltda.
|
Brazil
|
Yes
|
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
China
|
Yes
|
|
Tin
|
Yunnan Tin Company Limited
|
China
|
Yes
|
|
Tin
|
Yunnan Tin Group (Holding) Company Limited
|
China
|
Yes
|
|
Tungsten
|
A.L.M.T. TUNGSTEN Corp.
|
Japan
|
Yes
|
|
Tungsten
|
Asia Tungsten Products Vietnam Ltd.
|
Vietnam
|
Yes
|
|
Tungsten
|
Chenzhou Diamond Tungsten Products Co., Ltd.
|
China
|
Yes
|
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
China
|
Yes
|
|
Tungsten
|
Dayu Jincheng Tungsten Industry Co., Ltd.
|
China
|
Yes
|
|
Tungsten
|
Dayu Weiliang Tungsten Co., Ltd.
|
China
|
Yes
|
|
Tungsten
|
Fujian Jinxin Tungsten Co., Ltd.
|
China
|
Yes
|
|
Tungsten
|
Ganxian Shirui New Material Co., Ltd.
|
China
|
No
|
5
Metal (*)
|
Smelter Name (*)
|
Facility Location(*)
|
Compliant
|
Tungsten
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
|
China
|
No
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Ganzhou Yatai Tungsten Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Global Tungsten & Powders Corp.
|
United States of America
|
Yes
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
China
|
Yes
|
Tungsten
|
H.C. Starck GmbH
|
Germany
|
Yes
|
Tungsten
|
H.C. Starck Smelting GmbH & Co.KG
|
Germany
|
Yes
|
Tungsten
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
|
China
|
Yes
|
Tungsten
|
Hunan Chunchang Nonferrous Metals Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Hydrometallurg, JSC
|
Russian Federation
|
Yes
|
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
|
Yes
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Kennametal Fallon
|
United States of America
|
Yes
|
Tungsten
|
Kennametal Huntsville
|
United States of America
|
Yes
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Niagara Refining LLC
|
United States of America
|
Yes
|
Tungsten
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
|
Vietnam
|
Yes
|
Tungsten
|
Philippine Chuangxin Industrial Co., Inc.
|
Philippines
|
Yes
|
Tungsten
|
Pobedit, JSC
|
Russian Federation
|
No
|
Tungsten
|
Sanher Tungsten Vietnam Co., Ltd.
|
Vietnam
|
No
|
Tungsten
|
South-East Nonferrous Metal Company Limited of Hengyang City
|
China
|
Yes
|
Tungsten
|
Tejing (Vietnam) Tungsten Co., Ltd.
|
Vietnam
|
Yes
|
Tungsten
|
Unecha Refractory Metals Plant
|
Russian Federation
|
No
|
Tungsten
|
Vietnam Youngsun Tungsten Industry Co., Ltd.
|
Vietnam
|
Yes
|
Tungsten
|
Wolfram Bergbau und Hütten AG
|
Austria
|
Yes
|
Tungsten
|
Woltech Korea Co., Ltd.
|
Korea, Republic of
|
Yes
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
|
China
|
Yes
|
Tungsten
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
|
China
|
Yes
|
1 Smelters included on this list are those reported for our combined business.
6