UNITED STATES
SECURITIES AND EXCHANGE
COMMISSION
Washington, D.C. 20549
Form SD
SPECIALIZED DISCLOSURE
REPORT
(Exact name of the registrant
as specified in charter)
DELAWARE |
001-35720 |
45-3052669 |
(State
or other jurisdiction of
incorporation or organization) |
(Commission
File Number) |
(IRS
Employer
Identification No.) |
15
Koch Road |
|
Corte
Madera, CA |
94925 |
(Address
of principal executive offices) |
(Zip
code) |
Jack Preston
(415)
924-1005
(Name and telephone number,
including area code, of the person
to contact in connection with this
report.)
Check the appropriate box to indicate the rule pursuant to which
this form is being filed, and provide the period to which the information in this form applies:
x |
Rule 13p-1 under the
Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
Section 1
— Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Specialized Disclosure Report on Form SD of RH (the “Company,”
“we” or “our”) is filed pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act
of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2023 to December 31, 2023 (the “reporting
period”).
The Company determined that during the reporting period, RH contracted
to manufacture products as to which conflict minerals are necessary to the functionality or production of such products. As a result,
the Company has conducted a good faith reasonable country of origin inquiry to determine whether the necessary conflict minerals originated
in the Democratic Republic of the Congo or an adjoining country or came from recycled or scrap sources. A description of our reasonable
country of origin inquiry process, the result of the inquiry, and the determination we reached as a result of this inquiry process is
included in our Conflict Minerals Report attached as Exhibit 1.01 to this Form SD.
A copy of the Conflict Minerals Report filed for the calendar year
ended December 31, 2023 is publicly available electronically on the Investor Relations section of the Company’s website at
ir.rh.com, by clicking on “Financials & Filings,” and then “SEC Filings.”
Item 1.02 Exhibit
The Conflict Minerals Report for the calendar year ended December 31,
2023 is filed as Exhibit 1.01 hereto.
Section 2 — Exhibits
Item 2.01 Exhibits
Exhibit 1.01 RH Conflict Minerals Report, as required by Items 1.01 and 1.02 of Form SD.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934,
as amended, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
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RH |
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Dated: May 28, 2024 |
By: |
/s/ Jack Preston |
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Name: |
Jack Preston |
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Title: |
Chief Financial Officer |
2023 Exhibit 1.01
Conflict Minerals Report of RH in Accordance with Rule 13p-1
under the Securities and Exchange Act of 1934
I. Introduction
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1. |
Overview
of our Conflict Minerals Report |
This Conflict Minerals Report of RH (the “Company,” “we,”
“us” or “our”) is prepared in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange
Act of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2023 to December 31, 2023 (the
“reporting period”). RH is inclusive of its wholly-owned subsidiary Restoration Hardware, Inc. and its subsidiaries,
including, but not limited to, the subsidiary that owns the business operating under the name “Waterworks.” The information
provided in this Conflict Minerals Report on behalf of RH is inclusive of Waterworks, its products and supply chain.
The Rule requires issuers that manufacture or contract to manufacture
products that contain conflict minerals that are necessary to the functionality or production of those products to, among other things,
disclose annually whether any of those conflict minerals originated in the Covered Countries and, if so, to submit a report to the Securities
and Exchange Commission (the “SEC”) that includes a description of the measures they took to exercise due diligence on the
conflict minerals’ source and chain of custody. Conflict minerals are defined as columbite-tantalite (coltan), cassiterite, gold,
wolframite and their derivatives, which are limited to tantalum, tin and tungsten (the “conflict minerals”). The “Covered
Countries” for purposes of the Rule 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.
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2. |
Overview
of our Supply Chain, Verification Process and Conflict Minerals Policy |
During the reporting period, RH did not own or operate any manufacturing
facilities that manufacture products that contain conflict minerals that are necessary to the functionality or production of those products.
Instead, RH contracted and had relationships with third-party suppliers who manufacture products for RH that contain conflict minerals
that are necessary to the functionality or production of those products. These products that the Company “contracts to manufacture,”
as such term is referred to by the Rule, are herein referred to as the “Subject Products.” The Subject Products are manufactured
for the Company through such suppliers’ own factories or factories with which such suppliers have commercial relationships. The
Company must therefore rely on its third-party suppliers to provide information regarding the existence of conflict minerals in the Subject
Products and their origin.
The Company relied upon multi-stakeholder initiatives that provide
verification processes for conflict-free minerals from the smelters or refiners who may provide those minerals to companies in our supply
chain. The Company is many steps removed from the mining of conflict minerals. The Company does not purchase raw or unrefined conflict
minerals and conducts no purchasing activities directly in the Covered Countries. The statements herein are based on the activities performed
to date, in good faith, by the Company and on the information available at the time of this filing. There are factors that could affect
the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data,
errors or omissions in the information provided by suppliers or smelters, ongoing identification of smelters in our supply chain, and
incomplete information from industry or other third-party sources, among other factors.
We maintain a Conflict Minerals Policy that is incorporated into our
Vendor’s Operation Manual (the “Vendor Manual”), which our suppliers are able to access via a secure website.
II. Description of Products Covered by this Conflict Minerals Report
RH offers merchandise assortments across a growing number of categories,
including furniture, lighting, textiles, bathware, décor, outdoor and garden and children’s furnishings. The Subject Products
include products sold by the Company in the following categories: furniture, bathware, plumbing fixtures, lighting fixtures, kitchen
and bath hardware, décor, outdoor and garden and children’s furnishings.
III. Reasonable Country of Origin Inquiry
In accordance with the Rule, we conducted in good faith a reasonable
country of origin inquiry (the “RCOI”) that was reasonably designed to determine whether any of the necessary conflict minerals
in the Subject Products originated in the Covered Countries or were from recycled or scrap sources. Since 2021,
RH has partnered with Assent, a supply chain data management company that enhances automation and accuracy when collecting, submitting
or managing data related to ESG, product safety and vendor compliance. Assent coordinated RH’s communications with its suppliers,
including follow-up outreach and data gathering in support of its RCOI for this reporting year.
To conduct our RCOI, we used a conflict minerals reporting template
(version 6.31) developed by the Responsible Minerals Initiative (“RMI”) (formerly Conflict Free Sourcing Initiative (“CFSI”)),
an initiative founded by members of the Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability
Initiative (“GeSI”). Assent, on RH’s behalf, requested this information from our direct suppliers who manufacture our
Subject Products.
Based on our RCOI, we have reason to believe that some of the necessary
conflict minerals used in our Subject Products may have originated in the Covered Countries and may not have been from recycled or scrap
sources. Accordingly, we conducted due diligence to determine the source and chain of custody of these conflict minerals.
IV. Due Diligence Process
We have designed our diligence efforts to generally conform to the
Organization for Economic Cooperation and Development’s (the “OECD”) Due Diligence Guidance for Responsible Supply
Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying supplements (the “OECD Guidance”).
The OECD Guidance identifies five due diligence steps: (i) Establish
Strong Company Management Systems; (ii) Identify and Assess Risks in the Supply Chain; (iii) Design and Implement a Strategy
to Respond to Identified Risks; (iv) Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence; and (v) Report
Annually on Supply Chain Due Diligence.
The due diligence steps that we executed included the following:
Step |
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OECD
Guidance Steps |
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Due
diligence activities performed by RH |
1 |
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Establish
Strong Company Management Systems |
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Maintain
Conflict Minerals Policy |
● |
We
maintained a Conflict Minerals Policy that is published online, in our Vendor Manual. |
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Maintained
Conflict Minerals Compliance Team |
● |
We maintained
an internal conflict minerals team composed of a representative from the legal department and a representative from our vendor compliance
team (the “Conflict Minerals Compliance Team”). The team was structured to ensure our annual conflict minerals due diligence
was executed. |
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● |
Our Conflict Minerals Compliance Team periodically reported on
its due diligence activities to the legal department and the Vendor Compliance and Product Compliance teams. |
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Internal
Engagement |
● |
We educated
and continue educating relevant employees on our conflict minerals program and reporting obligations. |
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Supplier
Engagement |
● |
We provided our direct suppliers information on conflict minerals
and our disclosure requirements. |
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● |
Our Conflict Minerals Compliance Team engaged Assent,
a supply chain data management company that enhances automation and accuracy when collecting, submitting or managing data related
to ESG. |
2 |
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Identify
and Assess Risks in the Supply Chain |
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Identified
Products in Scope |
● |
Our
Conflict Minerals Compliance Team conducted a review of the products contracted to be manufactured during the reporting period to
identify suppliers that manufacture product categories and Subject Products that may contain conflict minerals. |
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Inquired
about Due Diligence Measures Performed by Direct Suppliers |
● |
We used
the responses from our direct suppliers to the RMI reporting template to review their due diligence activities, including whether
they had adopted a conflict minerals policy, required their own suppliers to source from processing facilities validated by an independent
audit firm, and implemented a review process that includes corrective action management. |
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As deemed
appropriate by us, we followed up by email or phone with the suppliers who did not respond to our request to complete the RMI reporting
template, or who submitted incomplete responses or responses that we determined may have contained errors or inaccuracies. |
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● |
We employed a conflict minerals data management tool that tracks
communications sent to direct suppliers and consolidates suppliers’ responses to the RMI template for analysis and
reporting. |
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Identified
Smelters |
● |
We collected
a list of smelters/processors that are in our supply chain by utilizing the RMI reporting template via a web-based platform. We determined
if the processing facilities adhere to responsible sourcing practices by reconciling that list to the list of facilities designated
by the RMI Responsible Minerals Assurance Program (“RMAP”) as RMAP Conformant Smelters & Refiners and the RMI
list of Active Smelters & Refiners that have committed to undergo the RMAP audit. We have provided lists of smelters/processors
that are reported in our supply chain in Appendix A. |
3 |
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Design
and Implement a Strategy to Respond to Identified Risks |
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Internal
Reporting System |
● |
Our Conflict Minerals Compliance Team periodically reported on
its due diligence activities to the legal department and the Vendor Compliance and Product Compliance teams. |
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Maintained
Conflict Minerals Policy |
● |
We maintained
a Conflict Minerals Policy that is published online, in our Vendor Manual. |
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Verified
Smelters |
● |
As part
of our risk mitigation process, we determined if the processing facilities identified in our supply chain adhere to responsible sourcing
practices by reconciling the list of smelters collected from our direct suppliers to the list of smelter facilities that have been
verified as complying with the RMAP and the RMI list of Active Smelters & Refiners that have committed to undergo the RMAP
audit. |
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4 |
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Carry
out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence |
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● |
We relied
on the RMI’s published lists to verify the RMAP compliance status of smelters/processors that are reported in our supply chain. |
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5 |
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Report
Annually on Supply Chain Due Diligence |
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This
Conflict Minerals Report is filed with the SEC and publicly available on our website at ir.rh.com, by clicking on “Financials &
Filings,” and then “SEC Filings.” |
V. Review of Due Diligence Results
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1. |
Facilities
Used to Process Conflict Minerals in Subject Products |
Based on our due diligence process and the information received from
our direct suppliers, we have identified, in Appendix A, facilities that may have been used to process conflict minerals used
in the Subject Products.
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2. |
Country
of Origin of Conflict Minerals in Subject Products |
Based on the information provided by our direct suppliers, we have
reason to believe that some of the products RH sold during the reporting year contain necessary conflict minerals that may have originated
from the Covered Countries. Our direct suppliers indicated that there are in total two hundred and twenty-seven facilities that do not
use any conflict minerals in products supplied to RH. One hundred and eighteen of the facilities may intentionally add conflict minerals
necessary to the function and/or production of the product. Of these one hundred and eighteen facilities: seventy-eight indicated that
the products they sold to RH contained necessary conflict minerals that did not originate in the DRC and nineteen did not know the country
of origin of the necessary conflict minerals in their products, including if conflict minerals in finished products originated in the
Covered Countries. In addition, as of April 24, 2024, with respect to RH, and April 29, 2024, with respect to Waterworks, approximately
30% of our direct suppliers did not respond to our survey. Accordingly, notwithstanding our due diligence efforts, we were unable to
determine the origin of a portion of conflict minerals contained in certain of the Subject Products.
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3. |
Efforts
to Identify the Mine or Location of Origin of the Conflict Minerals |
Our reasonable country-of-origin inquiry and due diligence process
described above represent our efforts to identify the mine or location of origin for the conflict minerals contained in the Subject Products
for this reporting period.
VI. Steps Taken to Mitigate Risk
RH intends to continue to require our suppliers to comply with our
Conflict Minerals Policy and to keep it posted online in our Vendor Manual for all suppliers to access. Over time, we anticipate that
the amount of information available globally on the traceability and sourcing of conflict minerals will increase and improve our knowledge.
We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes
in facts or circumstances are identified. We expect that our direct suppliers will comply with our Conflict Minerals Policy and (i) provide
appropriate information and conduct necessary due diligence to facilitate our compliance with the Rule, (ii) implement and communicate
to their relevant personnel and suppliers policies that are consistent with the Policy, (iii) put in place procedures and contractual
provisions for the traceability of conflict minerals, working with their suppliers as applicable, (iv) use reasonable efforts to
source conflict minerals from smelters and refiners that have been validated by a recognized, independent third party as DRC conflict
free, and (v) adopt a risk management strategy with respect to identified risks in the supply chain that is consistent with our
Conflict Minerals Policy.
In addition to the due diligence steps that we took during the reporting
period, which we intend to continue for 2024, as applicable, we intend to communicate to new suppliers our sourcing expectations, including
by disseminating our Conflict Minerals Policy to them.
VII. Independent Private Sector Audit
Not required for the reporting period.
Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements
within the meaning of the federal securities laws including statements related to our business, products and conflict mineral efforts,
including steps we intend to take in the future to mitigate the risk that the conflict minerals used in the Subject Products benefit
the armed groups on the Covered Countries, use of Assent with respect to our supply chain data management to enhance automation and accuracy
of collecting, submitting or managing data related to our ESG, product safety and vendor compliance, Assent’s ability to communicate
with our suppliers, including follow-up outreach and data gathering in support of our reporting, our ability to monitor the progress
of our suppliers or that our suppliers would comply with our Conflict Mineral Policy and our requests for timely and accurate information,
our suppliers’ ability to source conflict minerals from smelters and refiners that have been validated by a recognized, independent
third party as DRC conflict free, and the effectiveness of any of our risk management strategies to identify risks in the supply chain
consistent with our Conflict Minerals Policy. You can identify forward-looking statements by the fact that they do not relate strictly
to historical or current facts. These statements may include words such as “anticipate,” “estimate,” “expect,”
“project,” “plan,” “intend,” “believe,” “may,” “will,” “should,”
“likely” and other words and terms of similar meaning in connection with any discussion of the timing or nature of future
events. We cannot assure you that future developments affecting us will be those that we have anticipated. Important risks and uncertainties
that may cause these forward-looking statements to differ materially from our expectations include, among others: failure to carry out
our plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; implementation
of satisfactory traceability and other compliance measures by our direct and indirect suppliers; lack of progress by smelter or refiner
validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities); internal
and external resource constraints; political developments in the Covered Countries and regulatory developments in the United States,
as well as those risks and uncertainties disclosed under the sections entitled “Risk Factors” and “Management’s
Discussion and Analysis of Financial Condition and Results of Operations” in RH Form 10-K filed with the SEC on March 28,
2024, and similar disclosures in subsequent reports filed with the SEC, which are available on our investor relations website at ir.rh.com
and on the SEC website at www.sec.gov. Any forward-looking statement made by us in this Conflict Minerals Report speaks only as of the
date on which we make it. We undertake no obligation to publicly update any forward-looking statement, whether as a result of new information,
future developments or otherwise, except as may be required by any applicable securities laws.
Appendix A
Processing Facilities
Table 1. RMAP-conformant processing facilities as listed by RMI
as of April 2024
Processing facilities and their locations reported in our supply chain
that are reported by RMI as conformant with the RMAP.
Mineral |
Facility
ID |
Processing
Facility Name |
Country |
Tungsten |
CID000004 |
A.L.M.T.
Corp. |
Japan |
Gold |
CID002708 |
Abington
Reldan Metals, LLC |
United
States Of America |
Gold |
CID000035 |
Agosi
AG |
Germany |
Gold |
CID000019 |
Aida
Chemical Industries Co., Ltd. |
Japan |
Gold |
CID000041 |
Almalyk
Mining and Metallurgical Complex (AMMC) |
Uzbekistan |
Tin |
CID000292 |
Alpha |
United
States Of America |
Tantalum |
CID001076 |
AMG
Brasil |
Brazil |
Gold |
CID000058 |
AngloGold
Ashanti Corrego do Sitio Mineracao |
Brazil |
Gold |
CID000077 |
Argor-Heraeus
S.A. |
Switzerland |
Gold |
CID000082 |
Asahi
Pretec Corp. |
Japan |
Gold |
CID000924 |
Asahi
Refining Canada Ltd. |
Canada |
Gold |
CID000920 |
Asahi
Refining USA Inc. |
United
States Of America |
Gold |
CID000090 |
Asaka
Riken Co., Ltd. |
Japan |
Tungsten |
CID002502 |
Asia
Tungsten Products Vietnam Ltd. |
Viet
Nam |
Gold |
CID000113 |
Aurubis
AG |
Germany |
Tin |
CID002773 |
Aurubis
Beerse |
Belgium |
Tin |
CID002774 |
Aurubis
Berango |
Spain |
Gold |
CID000128 |
Bangko
Sentral ng Pilipinas (Central Bank of the Philippines) |
Philippines |
Gold |
CID000157 |
Boliden
AB |
Sweden |
Gold |
CID000176 |
C.
Hafner GmbH + Co. KG |
Germany |
Gold |
CID000185 |
CCR
Refinery - Glencore Canada Corporation |
Canada |
Tin |
CID000228 |
Chenzhou
Yunxiang Mining and Metallurgy Co., Ltd. |
China |
Tin |
CID003190 |
Chifeng
Dajingzi Tin Industry Co., Ltd. |
China |
Gold |
CID000233 |
Chimet
S.p.A. |
Italy |
Tungsten |
CID002641 |
China
Molybdenum Tungsten Co., Ltd. |
China |
Tin |
CID001070 |
China
Tin Group Co., Ltd. |
China |
Tungsten |
CID000258 |
Chongyi
Zhangyuan Tungsten Co., Ltd. |
China |
Gold |
CID000264 |
Chugai
Mining |
Japan |
Gold |
CID004010 |
Coimpa
Industrial LTDA |
Brazil |
Tin |
CID003486 |
CRM
Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
Brazil |
Tin |
CID003524 |
CRM
Synergies |
Spain |
Tungsten |
CID003468 |
Cronimet
Brasil Ltda |
Brazil |
Tin |
CID002570 |
CV
Ayi Jaya |
Indonesia |
Tin |
CID002455 |
CV
Venus Inti Perkasa |
Indonesia |
Tantalum |
CID002504 |
D
Block Metals, LLC |
United
States Of America |
Tin |
CID000402 |
Dowa |
Japan |
Tin |
CID003831 |
DS
Myanmar |
Myanmar |
Gold |
CID000359 |
DSC
(Do Sung Corporation) |
Korea,
Republic Of |
Gold |
CID000425 |
Eco-System
Recycling Co., Ltd. East Plant |
Japan |
Gold |
CID003424 |
Eco-System
Recycling Co., Ltd. North Plant |
Japan |
Gold |
CID003425 |
Eco-System
Recycling Co., Ltd. West Plant |
Japan |
Tin |
CID000438 |
EM
Vinto |
Bolivia
(Plurinational State Of) |
Tin |
CID000448 |
Estanho
de Rondonia S.A. |
Brazil |
Tantalum |
CID000460 |
F&X
Electro-Materials Ltd. |
China |
Tin |
CID003582 |
Fabrica
Auricchio Industria e Comercio Ltda. |
Brazil |
Tin |
CID000468 |
Fenix
Metals |
Poland |
Tantalum |
CID002505 |
FIR
Metals & Resource Ltd. |
China |
Tungsten |
CID003609 |
Fujian
Xinlu Tungsten Co., Ltd. |
China |
Tungsten |
CID002315 |
Ganzhou
Jiangwu Ferrotungsten Co., Ltd. |
China |
Tungsten |
CID002494 |
Ganzhou
Seadragon W & Mo Co., Ltd. |
China |
Tin |
CID000538 |
Gejiu
Non-Ferrous Metal Processing Co., Ltd. |
China |
Tantalum |
CID002558 |
Global
Advanced Metals Aizu |
Japan |
Tantalum |
CID002557 |
Global
Advanced Metals Boyertown |
United
States Of America |
Tungsten |
CID000568 |
Global
Tungsten & Powders LLC |
United
States Of America |
Gold |
CID003641 |
Gold
by Gold Colombia |
Colombia |
Gold |
CID002243 |
Gold
Refinery of Zijin Mining Group Co., Ltd. |
China |
Tin |
CID003116 |
Guangdong
Hanhe Non-Ferrous Metal Co., Ltd. |
China |
Tantalum |
CID000291 |
Guangdong
Rising Rare Metals-EO Materials Ltd. |
China |
Tungsten |
CID000218 |
Guangdong
Xianglu Tungsten Co., Ltd. |
China |
Tungsten |
CID002541 |
H.C.
Starck Tungsten GmbH |
Germany |
Gold |
CID000694 |
Heimerle
+ Meule GmbH |
Germany |
Tantalum |
CID002492 |
Hengyang
King Xing Lifeng New Materials Co., Ltd. |
China |
Gold |
CID000711 |
Heraeus
Germany GmbH Co. KG |
Germany |
Gold |
CID000707 |
Heraeus
Metals Hong Kong Ltd. |
China |
Tungsten |
CID003417 |
Hubei
Green Tungsten Co., Ltd. |
China |
Tin |
CID002844 |
HuiChang
Hill Tin Industry Co., Ltd. |
China |
Tungsten |
CID000766 |
Hunan
Chenzhou Mining Co., Ltd. |
China |
Tungsten |
CID002513 |
Hunan
Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
China |
Gold |
CID000801 |
Inner
Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
China |
Gold |
CID000807 |
Ishifuku
Metal Industry Co., Ltd. |
Japan |
Gold |
CID000814 |
Istanbul
Gold Refinery |
Turkey |
Gold |
CID002765 |
Italpreziosi |
Italy |
Gold |
CID000823 |
Japan
Mint |
Japan |
Tungsten |
CID000825 |
Japan
New Metals Co., Ltd. |
Japan |
Tungsten |
CID002551 |
Jiangwu
H.C. Starck Tungsten Products Co., Ltd. |
China |
Gold |
CID000855 |
Jiangxi
Copper Co., Ltd. |
China |
Tantalum |
CID002512 |
Jiangxi
Dinghai Tantalum & Niobium Co., Ltd. |
China |
Tungsten |
CID002321 |
Jiangxi
Gan Bei Tungsten Co., Ltd. |
China |
Tin |
CID001231 |
Jiangxi
New Nanshan Technology Ltd. |
China |
Tungsten |
CID002318 |
Jiangxi
Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
China |
Tantalum |
CID002842 |
Jiangxi
Tuohong New Raw Material |
China |
Tungsten |
CID002317 |
Jiangxi
Xinsheng Tungsten Industry Co., Ltd. |
China |
Tungsten |
CID002316 |
Jiangxi
Yaosheng Tungsten Co., Ltd. |
China |
Tantalum |
CID000914 |
JiuJiang
JinXin Nonferrous Metals Co., Ltd. |
China |
Tantalum |
CID000917 |
Jiujiang
Tanbre Co., Ltd. |
China |
Tantalum |
CID002506 |
Jiujiang
Zhongao Tantalum & Niobium Co., Ltd. |
China |
Gold |
CID000937 |
JX
Nippon Mining & Metals Co., Ltd. |
Japan |
Gold |
CID000957 |
Kazzinc |
Kazakhstan |
Tantalum |
CID002539 |
KEMET
de Mexico |
Mexico |
Tungsten |
CID000966 |
Kennametal
Fallon |
United
States Of America |
Tungsten |
CID000105 |
Kennametal
Huntsville |
United
States Of America |
Gold |
CID000969 |
Kennecott
Utah Copper LLC |
United
States Of America |
Gold |
CID002511 |
KGHM
Polska Miedz Spolka Akcyjna |
Poland |
Gold |
CID000981 |
Kojima
Chemicals Co., Ltd. |
Japan |
Gold |
CID002605 |
Korea
Zinc Co., Ltd. |
Korea,
Republic Of |
Tungsten |
CID003407 |
Lianyou
Metals Co., Ltd. |
Taiwan,
Province Of China |
Gold |
CID002762 |
L'Orfebre
S.A. |
Andorra |
Gold |
CID001078 |
LS-NIKKO
Copper Inc. |
Korea,
Republic Of |
Gold |
CID000689 |
LT
Metal Ltd. |
Korea,
Republic Of |
Tin |
CID003387 |
Luna
Smelter, Ltd. |
Rwanda |
Tin |
CID002468 |
Magnu's
Minerais Metais e Ligas Ltda. |
Brazil |
Tin |
CID001105 |
Malaysia
Smelting Corporation (MSC) |
Malaysia |
Tungsten |
CID002319 |
Malipo
Haiyu Tungsten Co., Ltd. |
China |
Tungsten |
CID002543 |
Masan
High-Tech Materials |
Viet
Nam |
Gold |
CID001113 |
Materion |
United
States Of America |
Tantalum |
CID002548 |
Materion
Newton Inc. |
United
States Of America |
Gold |
CID001119 |
Matsuda
Sangyo Co., Ltd. |
Japan |
Gold |
CID003575 |
Metal
Concentrators SA (Pty) Ltd. |
South
Africa |
Tin |
CID001142 |
Metallic
Resources, Inc. |
United
States Of America |
Tantalum |
CID001163 |
Metallurgical
Products India Pvt., Ltd. |
India |
Gold |
CID001149 |
Metalor
Technologies (Hong Kong) Ltd. |
China |
Gold |
CID001152 |
Metalor
Technologies (Singapore) Pte., Ltd. |
Singapore |
Gold |
CID001147 |
Metalor
Technologies (Suzhou) Ltd. |
China |
Gold |
CID001153 |
Metalor
Technologies S.A. |
Switzerland |
Gold |
CID001157 |
Metalor
USA Refining Corporation |
United
States Of America |
Gold |
CID001161 |
Metalurgica
Met-Mex Penoles S.A. De C.V. |
Mexico |
Tin |
CID001173 |
Mineracao
Taboca S.A. |
Brazil |
Tin |
CID004065 |
Mining
Minerals Resources SARL |
Congo,
Democratic Republic Of The |
Tin |
CID001182 |
Minsur |
Peru |
Tin |
CID001191 |
Mitsubishi
Materials Corporation |
Japan |
Tantalum |
CID001192 |
Mitsui
Mining and Smelting Co., Ltd. |
Japan |
Gold |
CID001352 |
MKS
PAMP SA |
Switzerland |
Gold |
CID002509 |
MMTC-PAMP
India Pvt., Ltd. |
India |
Gold |
CID001220 |
Nadir
Metal Rafineri San. Ve Tic. A.S. |
Turkey |
Gold |
CID001236 |
Navoi
Mining and Metallurgical Combinat |
Uzbekistan |
Gold |
CID003189 |
NH
Recytech Company |
Korea,
Republic Of |
Tungsten |
CID002589 |
Niagara
Refining LLC |
United
States Of America |
Gold |
CID001259 |
Nihon
Material Co., Ltd. |
Japan |
Tantalum |
CID001277 |
Ningxia
Orient Tantalum Industry Co., Ltd. |
China |
Tantalum |
CID001200 |
NPM
Silmet AS |
Estonia |
Tin |
CID001314 |
O.M.
Manufacturing (Thailand) Co., Ltd. |
Thailand |
Tin |
CID002517 |
O.M.
Manufacturing Philippines, Inc. |
Philippines |
Gold |
CID002779 |
Ogussa
Osterreichische Gold- und Silber-Scheideanstalt GmbH |
Austria |
Gold |
CID001325 |
Ohura
Precious Metal Industry Co., Ltd. |
Japan |
Tin |
CID001337 |
Operaciones
Metalurgicas S.A. |
Bolivia
(Plurinational State Of) |
Tungsten |
CID002827 |
Philippine
Chuangxin Industrial Co., Inc. |
Philippines |
Gold |
CID002919 |
Planta
Recuperadora de Metales SpA |
Chile |
Tantalum |
CID004054 |
PowerX
Ltd. |
Rwanda |
Gold |
CID001397 |
PT
Aneka Tambang (Persero) Tbk |
Indonesia |
Tin |
CID000309 |
PT
Aries Kencana Sejahtera |
Indonesia |
Tin |
CID001399 |
PT
Artha Cipta Langgeng |
Indonesia |
Tin |
CID002503 |
PT
ATD Makmur Mandiri Jaya |
Indonesia |
Tin |
CID001402 |
PT
Babel Inti Perkasa |
Indonesia |
Tin |
CID001406 |
PT
Babel Surya Alam Lestari |
Indonesia |
Tin |
CID002776 |
PT
Bangka Prima Tin |
Indonesia |
Tin |
CID003205 |
PT
Bangka Serumpun |
Indonesia |
Tin |
CID001421 |
PT
Belitung Industri Sejahtera |
Indonesia |
Tin |
CID001428 |
PT
Bukit Timah |
Indonesia |
Tin |
CID002696 |
PT
Cipta Persada Mulia |
Indonesia |
Tin |
CID002835 |
PT
Menara Cipta Mulia |
Indonesia |
Tin |
CID001453 |
PT
Mitra Stania Prima |
Indonesia |
Tin |
CID003449 |
PT
Mitra Sukses Globalindo |
Indonesia |
Tin |
CID000313 |
PT
Premium Tin Indonesia |
Indonesia |
Tin |
CID001458 |
PT
Prima Timah Utama |
Indonesia |
Tin |
CID003868 |
PT
Putera Sarana Shakti (PT PSS) |
Indonesia |
Tin |
CID003381 |
PT
Rajawali Rimba Perkasa |
Indonesia |
Tin |
CID002593 |
PT
Rajehan Ariq |
Indonesia |
Tin |
CID001460 |
PT
Refined Bangka Tin |
Indonesia |
Tin |
CID001463 |
PT
Sariwiguna Binasentosa |
Indonesia |
Tin |
CID001468 |
PT
Stanindo Inti Perkasa |
Indonesia |
Tin |
CID002816 |
PT
Sukses Inti Makmur |
Indonesia |
Tin |
CID001486 |
PT
Timah Nusantara |
Indonesia |
Tin |
CID001477 |
PT
Timah Tbk Kundur |
Indonesia |
Tin |
CID001482 |
PT
Timah Tbk Mentok |
Indonesia |
Tin |
CID001490 |
PT
Tinindo Inter Nusa |
Indonesia |
Tin |
CID001493 |
PT
Tommy Utama |
Indonesia |
Gold |
CID001498 |
PX
Precinox S.A. |
Switzerland |
Tantalum |
CID001508 |
QuantumClean |
United
States Of America |
Gold |
CID001512 |
Rand
Refinery (Pty) Ltd. |
South
Africa |
Gold |
CID002582 |
REMONDIS
PMR B.V. |
Netherlands |
Tin |
CID002706 |
Resind
Industria e Comercio Ltda. |
Brazil |
Tantalum |
CID003583 |
RFH
Yancheng Jinye New Material Technology Co., Ltd. |
China |
Gold |
CID001534 |
Royal
Canadian Mint |
Canada |
Tin |
CID001539 |
Rui
Da Hung |
Taiwan,
Province Of China |
Gold |
CID002290 |
SAFINA
A.S. |
Czechia |
Gold |
CID001585 |
SEMPSA
Joyeria Plateria S.A. |
Spain |
Gold |
CID001916 |
Shandong
Gold Smelting Co., Ltd. |
China |
Gold |
CID001622 |
Shandong
Zhaojin Gold & Silver Refinery Co., Ltd. |
China |
Tungsten |
CID004430 |
Shinwon
Tungsten (Fujian Shanghang) Co., Ltd. |
China |
Gold |
CID001736 |
Sichuan
Tianze Precious Metals Co., Ltd. |
China |
Gold |
CID001761 |
Solar
Applied Materials Technology Corp. |
Taiwan,
Province Of China |
Gold |
CID001798 |
Sumitomo
Metal Mining Co., Ltd. |
Japan |
Gold |
CID002918 |
SungEel
HiMetal Co., Ltd. |
Korea,
Republic Of |
Tin |
CID002756 |
Super
Ligas |
Brazil |
Gold |
CID002580 |
T.C.A
S.p.A |
Italy |
Tantalum |
CID001869 |
Taki
Chemical Co., Ltd. |
Japan |
Gold |
CID001875 |
Tanaka
Kikinzoku Kogyo K.K. |
Japan |
Tantalum |
CID002544 |
TANIOBIS
Co., Ltd. |
Thailand |
Tantalum |
CID002545 |
TANIOBIS
GmbH |
Germany |
Tantalum |
CID002549 |
TANIOBIS
Japan Co., Ltd. |
Japan |
Tungsten |
CID002542 |
TANIOBIS
Smelting GmbH & Co. KG |
Germany |
Tantalum |
CID001891 |
Telex
Metals |
United
States Of America |
Tin |
CID001898 |
Thaisarco |
Thailand |
Tin |
CID002180 |
Tin
Smelting Branch of Yunnan Tin Co., Ltd. |
China |
Tin |
CID003325 |
Tin
Technology & Refining |
United
States Of America |
Gold |
CID001938 |
Tokuriki
Honten Co., Ltd. |
Japan |
Gold |
CID002615 |
TOO
Tau-Ken-Altyn |
Kazakhstan |
Gold |
CID001955 |
Torecom |
Korea,
Republic Of |
Tungsten |
CID003993 |
Tungsten
Vietnam Joint Stock Company |
Viet
Nam |
Tantalum |
CID001969 |
Ulba
Metallurgical Plant JSC |
Kazakhstan |
Gold |
CID001980 |
Umicore
S.A. Business Unit Precious Metals Refining |
Belgium |
Gold |
CID001993 |
United
Precious Metal Refining, Inc. |
United
States Of America |
Gold |
CID002003 |
Valcambi
S.A. |
Switzerland |
Gold |
CID003615 |
WEEEREFINING |
France |
Gold |
CID002030 |
Western
Australian Mint (T/a The Perth Mint) |
Australia |
Tin |
CID002036 |
White
Solder Metalurgia e Mineracao Ltda. |
Brazil |
Gold |
CID002778 |
WIELAND
Edelmetalle GmbH |
Germany |
Tungsten |
CID002044 |
Wolfram
Bergbau und Hutten AG |
Austria |
Tungsten |
CID002320 |
Xiamen
Tungsten (H.C.) Co., Ltd. |
China |
Tungsten |
CID002082 |
Xiamen
Tungsten Co., Ltd. |
China |
Tantalum |
CID000616 |
XIMEI
RESOURCES (GUANGDONG) LIMITED |
China |
Tantalum |
CID002508 |
XinXing
HaoRong Electronic Material Co., Ltd. |
China |
Gold |
CID002100 |
Yamakin
Co., Ltd. |
Japan |
Tantalum |
CID001522 |
Yanling
Jincheng Tantalum & Niobium Co., Ltd. |
China |
Gold |
CID002129 |
Yokohama
Metal Co., Ltd. |
Japan |
Tin |
CID002158 |
Yunnan
Chengfeng Non-ferrous Metals Co., Ltd. |
China |
Tin |
CID003397 |
Yunnan
Yunfan Non-ferrous Metals Co., Ltd. |
China |
Gold |
CID002224 |
Zhongyuan
Gold Smelter of Zhongjin Gold Corporation |
China |
Table 2. RMAP-participating processing facilities as listed by
RMI as of April 2024
Processing facilities and their locations reported in our supply chain
that are reported by RMI as active with the RMAP.
Mineral |
Facility
ID |
Processing
Facility Name |
Country |
Gold |
CID000015 |
Advanced
Chemical Company |
United
States Of America |
Gold |
CID002863 |
Bangalore
Refinery |
India |
Tin |
CID003409 |
Precious
Minerals and Smelting Limited |
India |
Tin |
CID001419 |
PT
Bangka Tin Industry |
Indonesia |
Table 3. RMAP-non-participating processing facilities as of April 2024
Processing facilities and their locations reported in our supply chain
that are not reported as either compliant with or participating in the RMAP.
Mineral |
Facility
ID |
Processing
Facility Name |
Country |
Tantalum |
CID003926 |
5D Production OU |
Estonia |
Gold |
CID002763 |
8853 S.p.A. |
Italy |
Gold |
CID002920 |
ABC Refinery Pty Ltd. |
Australia |
Tungsten |
CID002833 |
ACL Metais Eireli |
Brazil |
Gold |
CID003185 |
African Gold Refinery |
Uganda |
Gold |
CID002560 |
Al Etihad Gold Refinery
DMCC |
United Arab Emirates |
Tungsten |
CID003427 |
Albasteel Industria e Comercio
de Ligas Para Fundicao Ltd. |
Brazil |
Gold |
CID002760 |
Albino Mountinho Lda. |
Portugal |
Gold |
CID003500 |
Alexy Metals |
United States Of America |
Tin |
CID002703 |
An Vinh Joint Stock Mineral
Processing Company |
Viet Nam |
Tungsten |
CID003553 |
Artek LLC |
Russian Federation |
Gold |
CID000103 |
Atasay Kuyumculuk Sanayi
Ve Ticaret A.S. |
Turkey |
Gold |
CID002850 |
AU Traders
and Refiners |
South Africa |
Gold |
CID003461 |
Augmont Enterprises Private
Limited |
India |
Gold |
CID000180 |
Caridad |
Mexico |
Gold |
CID000189 |
Cendres + Metaux S.A. |
Switzerland |
Gold |
CID003382 |
CGR Metalloys Pvt Ltd. |
India |
Tungsten |
CID000281 |
CNMC (Guangxi) PGMA Co., Ltd. |
China |
Gold |
CID000343 |
Daye Non-Ferrous Metals
Mining Ltd. |
China |
Gold |
CID002867 |
Degussa Sonne / Mond Goldhandel
GmbH |
Germany |
Gold |
CID003348 |
Dijllah Gold Refinery FZC |
United Arab Emirates |
Tin |
CID003356 |
Dongguan CiEXPO Environmental
Engineering Co., Ltd. |
China |
Tungsten |
CID004060 |
DONGKUK INDUSTRIES CO., LTD. |
Korea, Republic Of |
Gold |
CID003663 |
Dongwu Gold Group |
China |
Tin |
CID002572 |
Electro-Mechanical Facility of the Cao Bang Minerals &
Metallurgy Joint Stock Company |
Viet Nam |
Gold |
CID003487 |
Emerald Jewel Industry
India Limited (Unit 1) |
India |
Gold |
CID003488 |
Emerald Jewel Industry
India Limited (Unit 2) |
India |
Gold |
CID003489 |
Emerald Jewel Industry
India Limited (Unit 3) |
India |
Gold |
CID003490 |
Emerald Jewel Industry
India Limited (Unit 4) |
India |
Gold |
CID002561 |
Emirates Gold DMCC |
United Arab Emirates |
Gold |
CID002515 |
Fidelity Printers and Refiners
Ltd. |
Zimbabwe |
Gold |
CID002584 |
Fujairah Gold FZC |
United Arab Emirates |
Tungsten |
CID002645 |
Ganzhou Haichuang Tungsten
Co., Ltd. |
China |
Tungsten |
CID000875 |
Ganzhou Huaxing Tungsten
Products Co., Ltd. |
China |
Gold |
CID002459 |
Geib Refining Corporation |
United States Of America |
Tin |
CID003410 |
Gejiu City Fuxiang Industry
and Trade Co., Ltd. |
China |
Tin |
CID000942 |
Gejiu Kai Meng Industry
and Trade LLC |
China |
Tin |
CID001908 |
Gejiu Yunxin Nonferrous
Electrolysis Co., Ltd. |
China |
Tin |
CID000555 |
Gejiu Zili Mining And Metallurgy
Co., Ltd. |
China |
Gold |
CID002852 |
GGC Gujrat Gold Centre
Pvt. Ltd. |
India |
Gold |
CID003186 |
Gold Coast Refinery |
Ghana |
Gold |
CID001909 |
Great Wall Precious Metals
Co., Ltd. of CBPM |
China |
Gold |
CID002312 |
Guangdong Jinding Gold
Limited |
China |
Gold |
CID000651 |
Guoda Safina High-Tech
Environmental Refinery Co., Ltd. |
China |
Gold |
CID000671 |
Hangzhou Fuchunjiang Smelting
Co., Ltd. |
China |
Tungsten |
CID003978 |
HANNAE FOR T Co., Ltd. |
Korea, Republic Of |
Gold |
CID000767 |
Hunan Chenzhou Mining Co., Ltd. |
China |
Gold |
CID000773 |
Hunan Guiyang yinxing Nonferrous
Smelting Co., Ltd. |
China |
Tungsten |
CID000769 |
Hunan Jintai New Material
Co., Ltd. |
China |
Gold |
CID000778 |
HwaSeong CJ CO., LTD. |
Korea, Republic Of |
Tungsten |
CID002649 |
Hydrometallurg, JSC |
Russian Federation |
Gold |
CID002587 |
Industrial Refining Company |
Belgium |
Gold |
CID002562 |
International Precious
Metal Refiners |
United Arab Emirates |
Gold |
CID002893 |
JALAN & Company |
India |
Tungsten |
CID002313 |
Jiangxi Minmetals
Gao'an Non-ferrous Metals Co., Ltd. |
China |
Tungsten |
CID003408 |
JSC "Kirovgrad Hard
Alloys Plant" |
Russian Federation |
Gold |
CID000927 |
JSC Ekaterinburg Non-Ferrous
Metal Processing Plant |
Russian Federation |
Gold |
CID000493 |
JSC Novosibirsk Refinery |
Russian Federation |
Gold |
CID000929 |
JSC Uralelectromed |
Russian Federation |
Gold |
CID003497 |
K.A. Rasmussen |
Norway |
Gold |
CID002563 |
Kaloti Precious Metals |
United Arab Emirates |
Gold |
CID000956 |
Kazakhmys Smelting LLC |
Kazakhstan |
Gold |
CID003463 |
Kundan Care Products Ltd. |
India |
Gold |
CID001029 |
Kyrgyzaltyn JSC |
Kyrgyzstan |
Gold |
CID002865 |
Kyshtym Copper-Electrolytic
Plant ZAO |
Russian Federation |
Gold |
CID001032 |
L'azurde Company For Jewelry |
Saudi Arabia |
Gold |
CID001056 |
Lingbao Gold Co., Ltd. |
China |
Gold |
CID001058 |
Lingbao Jinyuan Tonghui
Refinery Co., Ltd. |
China |
Tungsten |
CID003643 |
LLC Vostok |
Russian Federation |
Gold |
CID001093 |
Luoyang Zijin Yinhui Gold
Refinery Co., Ltd. |
China |
Tin |
CID003379 |
Ma'anshan Weitai Tin Co., Ltd. |
China |
Gold |
CID002606 |
Marsam Metals |
Brazil |
Gold |
CID003548 |
MD Overseas |
India |
Tin |
CID002500 |
Melt Metais e Ligas S.A. |
Brazil |
Gold |
CID003557 |
Metallix Refining Inc. |
United States Of America |
Gold |
CID002857 |
Modeltech Sdn Bhd |
Malaysia |
Tungsten |
CID002845 |
Moliren Ltd. |
Russian Federation |
Gold |
CID002282 |
Morris and Watson |
New Zealand |
Gold |
CID001204 |
Moscow Special Alloys Processing
Plant |
Russian Federation |
Tungsten |
CID004034 |
Nam Viet Cromit Joint Stock
Company |
Viet Nam |
Tin |
CID002573 |
Nghe Tinh Non-Ferrous Metals
Joint Stock Company |
Viet Nam |
Tin |
CID001305 |
Novosibirsk Tin Combine |
Russian Federation |
Tungsten |
CID003416 |
NPP Tyazhmetprom LLC |
Russian Federation |
Gold |
CID001326 |
OJSC "The Gulidov
Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
Russian Federation |
Tungsten |
CID003614 |
OOO “Technolom”
1 |
Russian Federation |
Tungsten |
CID003612 |
OOO “Technolom”
2 |
Russian Federation |
Gold |
CID002872 |
Pease & Curren |
United States Of America |
Gold |
CID001362 |
Penglai Penggang Gold Industry
Co., Ltd. |
China |
Tin |
CID003208 |
Pongpipat Company Limited |
Myanmar |
Gold |
CID001386 |
Prioksky Plant of Non-Ferrous
Metals |
Russian Federation |
Tin |
CID003380 |
PT Masbro Alam Stania |
Indonesia |
Tin |
CID001457 |
PT Panca Mega Persada |
Indonesia |
Tin |
CID002478 |
PT Tirus Putra Mandiri |
Indonesia |
Gold |
CID003324 |
QG Refining, LLC |
United States Of America |
Gold |
CID000522 |
Refinery of Seemine Gold
Co., Ltd. |
China |
Gold |
CID002761 |
SAAMP |
France |
Gold |
CID001546 |
Sabin Metal
Corp. |
United States
Of America |
Gold |
CID002973 |
Safimet S.p.A |
Italy |
Gold |
CID002853 |
Sai Refinery |
India |
Gold |
CID003666 |
Sam Precious Metals |
United Arab Emirates |
Gold |
CID001555 |
Samduck Precious Metals |
Korea, Republic Of |
Gold |
CID001562 |
Samwon Metals Corp. |
Korea, Republic Of |
Gold |
CID003529 |
Sancus ZFS (L’Orfebre,
SA) |
Colombia |
Gold |
CID003540 |
Sellem Industries Ltd. |
Mauritania |
Gold |
CID002525 |
Shandong Humon Smelting
Co., Ltd. |
China |
Gold |
CID001619 |
Shandong Tiancheng Biological
Gold Industrial Co., Ltd. |
China |
Gold |
CID002750 |
Shenzhen CuiLu Gold Co., Ltd. |
China |
Gold |
CID002527 |
Shenzhen Zhonghenglong
Real Industry Co., Ltd. |
China |
Gold |
CID002588 |
Shirpur Gold Refinery Ltd. |
India |
Gold |
CID002516 |
Singway Technology Co., Ltd. |
Taiwan, Province Of China |
Gold |
CID001756 |
SOE Shyolkovsky Factory
of Secondary Precious Metals |
Russian Federation |
Tantalum |
CID001769 |
Solikamsk Magnesium Works
OAO |
Russian Federation |
Gold |
CID003383 |
Sovereign Metals |
India |
Gold |
CID003153 |
State Research Institute
Center for Physical Sciences and Technology |
Lithuania |
Gold |
CID002567 |
Sudan Gold Refinery |
Sudan |
Gold |
CID001810 |
Super Dragon Technology
Co., Ltd. |
Taiwan, Province Of China |
Gold |
CID001947 |
Tongling Nonferrous Metals
Group Co., Ltd. |
China |
Tin |
CID002574 |
Tuyen Quang Non-Ferrous
Metals Joint Stock Company |
Viet Nam |
Gold |
CID002314 |
Umicore Precious Metals
Thailand |
Thailand |
Tungsten |
CID002724 |
Unecha Refractory metals
plant |
Russian Federation |
Tin |
CID002015 |
VQB Mineral and Trading
Group JSC |
Viet Nam |
Tungsten |
CID003662 |
YUDU ANSHENG TUNGSTEN CO., LTD. |
China |
Gold |
CID000197 |
Yunnan Copper Industry
Co., Ltd. |
China |
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