aray-sd.htm

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM SD

 

SPECIALIZED DISCLOSURE REPORT

 

 

ACCURAY INCORPORATED

(Exact name of registrant as specified in its charter)

 

Delaware
(State or other jurisdiction of incorporation or organization)

 

001-33301

 

20-8370041

(Commission File Number)

 

(IRS Employer Identification No.)

 

 

1310 Chesapeake Terrace
Sunnyvale, California 94089

(Address of principal executive offices)

(Zip Code)

 

 

Jesse Chew

Senior Vice President, General Counsel and Corporate Secretary

(408) 716-4600

(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:

 

 

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.

 

 

 

 


 

Section 1 — Conflict Minerals Disclosure

 

Item 1.01Conflict Minerals Disclosure and Report

 

This Form SD of Accuray Incorporated (“Accuray”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2019 to December 31, 2019. A copy of Accuray’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available on Accuray’s website at http://investors.accuray.com/financial-information/sec-filings.

 

Item 1.02Exhibit

 

As specified in Section 2, Item 2.01 of this Form SD, Accuray is hereby filing its Conflict Minerals Report as Exhibit 1.01.

 

 

Section 2 — Exhibits

 

Item 2.01 Exhibits

 

The following exhibit is filed as part of this Form SD.

 

 

 

Exhibit Number

 

 

1.01

 

Conflict Minerals Report of Accuray Incorporated

 


 

1


 

 

SIGNATURE

 

 

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.

 

 

 

 

 

 

 

 

ACCURAY INCORPORATED

 

 

 

Date: May 29, 2020

By:

/s/ Jesse Chew

 

 

Jesse Chew

 

 

Senior Vice President, General Counsel & Corporate Secretary

 

 

 

 

 

 

 

 

 

 

2

aray-ex101_6.htm

EXHIBIT 1.01

CONFLICT MINERALS REPORT OF ACCURAY INCORPORATED

FOR THE REPORTING PERIOD FROM JANUARY 1, 2019 TO DECEMBER 31, 2019

 

Background

 

This Conflict Minerals Report (“Report”) of Accuray Incorporated (“Accuray”) for calendar year 2019 (the “Reporting Period”) has been prepared in accordance with Rule 13p-1 and Form SD under the Securities Exchange Act of 1934, as amended (together, the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to Conflict Minerals (as defined below) as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

 

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 are collectively referred 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 the purposes of the Rule and this Report are the Democratic Republic of the Congo (“DRC”) and adjoining countries, which currently include the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

 

If Conflict Minerals are necessary to the functionality or production of products manufactured or contracted to be manufactured by a company, the company is required to conduct a good faith reasonable country of origin inquiry (“RCOI”) to determine whether any of the necessary Conflict Minerals in those products originated in the Covered Countries and whether any of the necessary Conflict Minerals may be from recycled or scrap sources. If, as a result of the RCOI, a company has reason to believe that any of the necessary Conflict Minerals in its supply chain may have originated in the Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the company must perform due diligence on the Conflict Minerals’ source and chain of custody.

 

Company Overview

 

Accuray is a radiation oncology company that develops, manufactures, sells and supports precise, innovative treatment solutions which set the standard of radiation therapy care with the aim of helping patients live longer, better lives. Our innovative technologies, the CyberKnife and TomoTherapy Systems, including the Radixact System, our next generation TomoTherapy platform, are designed to deliver advanced treatments, including stereotactic radiosurgery (SRS), stereotactic body radiation therapy (SBRT), intensity modulated radiation therapy (IMRT), image guided radiation therapy (IGRT), and adaptive radiation therapy. The CyberKnife Systems and the TomoTherapy Systems, including the Radixact Systems, have clinical applications that are designed to enable customers to deliver the most precise treatments while minimizing side effects and maximizing patient comfort and care. Each of these systems serves patient populations treated by the same medical specialty, radiation oncology, with advanced capabilities. Accuray is headquartered in the United States and also has primary offices in Switzerland, China, Hong Kong and Japan and conducts its business worldwide.

 

Description of the Products Covered by this Report

 

This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of such product; (ii) that were manufactured, or contracted to be manufactured, by Accuray; and (iii) for which the manufacture was completed during calendar year 2019. These products, which are referred to in this Report collectively as the “Covered Products,” are the CyberKnife and TomoTherapy Systems, including the Radixact System.

 

Supply Chain Overview

 

All of Accuray’s products are complex and require the integration of a number of components from several sources. Such components are manufactured by Accuray or contract manufacturers or are otherwise purchased by Accuray from third parties. As such, Accuray is many steps removed from the mining of Conflict Minerals; Accuray does not purchase raw or unrefined Conflict Minerals, and does no purchasing in the Covered Countries. Accuray’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of the Conflict Minerals. In this regard, Accuray does not purchase the Conflict Minerals directly from mines, smelters or refiners. As explained further below, Accuray must therefore rely on its suppliers to provide information regarding the origin of the Conflict Minerals in the Covered Products.

 

Reasonable Country-of-Origin Inquiry

 


 

 

Accuray has conducted a good faith RCOI regarding the Conflict Minerals that were necessary to the functionality or production of the Covered Products (the “Necessary Conflict Minerals”). This RCOI was reasonably designed to determine whether any of the Necessary Conflict Minerals originated in the Covered Countries or came from recycled or scrap sources. The RCOI comprised of the conduct described under the caption “Description of Due Diligence Measures—Identify and Assess Risk in the Supply Chain” below. As a result of the RCOI, Accuray knows or has reason to believe that a portion of its Necessary Conflict Minerals originated or may have originated in the “Covered Countries” and knows or has reason to believe that those Necessary Conflict Minerals may not be from recycled or scrap sources. In response, Accuray also performed due diligence on the source and chain of custody of the Necessary Conflict Minerals to seek to determine whether the Covered Products were “DRC conflict free” (as defined in the Rule). Suppliers define the scope of their representations to us at their own discretion and, as a result, the information provided to Accuray may be provided at a company level, division level, product category level or at a product level.  Therefore, as a downstream procurer of components that may or may not contain Conflict Minerals, Accuray’s RCOI efforts and due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody on Conflict Minerals.

 

Due Diligence Performed

 

Design of Due Diligence

 

Accuray designed its due diligence measures to be in conformity with, in all material respects, the internationally recognized due diligence 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: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Framework”), consistent with Accuray’s position as a downstream purchaser. The scope of Accuray’s due diligence remained on Conflict Minerals – namely tin, tantalum, tungsten and gold (together, the “3TG”). Accuray integrated the five-step OECD Framework into its due diligence measures as described below.

 

Description of Due Diligence Measures

 

Accuray’s due diligence measures performed with respect to Covered Products included the following:

 

 

 

1.

OECD Step 1 - Establish Strong Company Management Systems

 

Conflict Minerals policy statement. Accuray adopted a policy statement regarding Conflict Minerals that outlines its commitment to prevent the use of Conflict Minerals that, directly or indirectly, finance or benefit armed groups in the Covered Countries. This statement is available on Accuray’s website at www.accuray.com/conflict-minerals-policy-statement, and suppliers are expected to follow this policy and provide Accuray with conflict-free parts and products. In addition, in connection with Accuray’s outreach described below, a letter communicating Accuray’s commitment to sourcing responsibly was sent to material suppliers.

 

Conflict Minerals team. Accuray’s Conflict Minerals team, consisting of a cross-functional team of individuals from Accuray’s manufacturing and supply chain teams as well as the legal team, collectively reviewed Accuray’s Conflict Mineral supply chain. The team had a biweekly meeting cadence in 2020 to review responses from Accuray’s suppliers for Conflict Minerals in components supplied to Accuray for the calendar year ended 2019. The executive team at Accuray had oversight responsibility for the work done by the Conflict Minerals team. The team reported to the executive team as needed. Further, the Conflict Minerals team members have been trained regarding the Rule, Conflict Minerals and properly reviewing and validating supplier responses.

 

System of controls and transparency. Accuray has developed and implemented a Supplier Code of Conduct, which describes the minimum standards of ethical and responsible conduct for Accuray’s suppliers. Accuray may periodically evaluate a supplier’s compliance with such standards to determine whether to continue the business relationship with such supplier. Failure to follow any of the provisions of such code can result in termination of any and all agreements with Accuray. In addition, Accuray maintains an internal electronic database for collecting and retaining supplier responses and other information necessary to support Conflict Minerals inquiry and reporting in order to enhance its due diligence processes and improve the accuracy and completeness of supplier data. The Conflict Minerals team regularly reviewed and monitored the electronic database throughout the due diligence process, including via recurrent meetings.

 

 


EXHIBIT 1.01

Strengthen engagement with suppliers. To help suppliers understand Accuray’s expectations and its due diligence and disclosure obligations under the Rule, and to facilitate supplier responsiveness to Accuray’s inquiry, Accuray provided suppliers with background information about the Rule, Accuray’s policy with respect to Conflict Minerals in its supply chain and systematically answered supplier questions. Accuray also engaged in dialogue with suppliers regarding their responses and provided additional feedback to suppliers that had questions on how to complete the inquiry. In the event that suppliers were not able to provide complete responses, Accuray made additional inquiries into what processes were in place to provide more complete responses in the future and encouraged suppliers to make incremental improvements.

 

Establish a company grievance mechanism. Accuray maintains a whistleblower hotline that is available to report, confidentially and anonymously, violations of Accuray’s policies or other illegal or unethical behavior, online at www.accuray.ethicspoint.com or by phone at (800) 499-8895. Concerned parties who wish to report information regarding Accuray’s sourcing and use of Conflict Minerals in its products can do so through this existing hotline.

 

 

 

2.

OECD Step 2 - Identify and Assess Risk in the Supply Chain

 

To identify risks in Accuray’s supply chain, Accuray relied on suppliers to provide information on the origin of the Conflict Minerals contained in supplier products or components that are included in the Covered Products. Accuray conducted a comprehensive analysis of component suppliers of the Covered Products according to the bill of materials and compiled a list of in-scope suppliers based on the probability of any 3TG in their product. Accuray contacted all suppliers on such list requesting that each complete the Conflict Minerals Reporting Template (“Template”) developed by Responsible Minerals Initiative (“RMI,” and formerly the Conflict-Free Sourcing Initiative). Accuray considered all such suppliers contacted to be “in scope” for purposes of its assessment.

 

The Template provided a standardized method for Accuray to use in the collection of representations, statements and data from Accuray’s suppliers related to the presence, use, source and chain of custody of the Conflict Minerals in supplier parts that are incorporated in supplier products or components included in the Covered Products in order to determine whether the Necessary Conflict Minerals in supplier products or components were or were not “DRC conflict free” (as defined in the Rule). The Template requested suppliers to include the country of origin of any Conflict Minerals and the facilities used to process these minerals. Suppliers were asked to confirm whether the particular products they supply to Accuray contained any 3TGs and identify materials down to the smelter and mine.

 

The collection process included an introductory notification from Accuray to all in-scope suppliers describing the compliance requirements and requesting completion of the Template. For non-responsive suppliers, several follow-up notifications were sent requesting survey completion. Accuray also contacted suppliers that remained unresponsive by telephone (sometimes, on multiple occasions) to confirm contact information, remind the supplier about the information request and offer assistance. The Conflict Minerals team evaluated the information collected, including subjecting the results to a quality review check sheet. If discrepancies, errors or omissions were identified, the response for that supplier was deemed incomplete and Accuray followed-up with such supplier for correction or clarification. Responses were also reviewed and compared with other information in Accuray’s possession and, where appropriate, Accuray made further inquiries of the suppliers. The Conflict Minerals team monitored the status of the outreach and supplier responses through information made available via the electronic database and requested additional follow-up as appropriate.

 

Accuray compared the names of smelters and refiners listed by suppliers in completed Templates against lists published by the RMI to verify that the identified facilities are known metal processors. Accuray also compared the identified smelters and facilities against lists published by the Responsible Minerals Assurance Process (“RMAP,” and formerly the Conflict-Free Smelter Program), developed by the RMI, of smelters and refiners that have been certified as conflict-free (i.e., conformant with RMAP assessment protocols) or that are “active” in the RMAP process (i.e., they have agreed to participate in the RMAP but the audit process has not yet been completed).

 

 

3.

OECD Step 3 - Design and Implement a Strategy to Respond to Risk

 

Accuray is in the process of designing a process for completing a risk assessment after collecting data from the in-scope suppliers to identify supply chain risks incurred during the current reporting year. Accuray currently determines on a case-by-case basis the appropriate risk mitigation strategy for any supply chain risks identified in the course of its due diligence efforts. Potential outcomes under this risk mitigation strategy include continuing to work with the supplier while risks are addressed, suspending the relationship on a temporary basis while risk mitigation is pursued or discontinuing the relationship with the supplier where risk mitigation efforts have failed. Additional factors are taken into consideration in determining the appropriate

 


 

risk mitigation strategy for certain suppliers, including supplier size and capabilities, whether alternatives are available and Accuray’s dependence on the supplier.

 

 

 

4.

OECD Step 4 - Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices

 

As Accuray has no direct relationship with smelters or refiners in its supply chain, it did not perform or direct audits of these entities within its supply chain. As an alternative, the Conflicts Mineral team reviewed publicly available data collected and published by RMAP. RMAP performs an independent third-party audit program that evaluates smelter and refiner procurement activities and determines whether the smelter or refiner demonstrated that it has systems and controls in place to ensure that all materials it processed originated from conflict-free sources.

 

 

 

5.

OECD Step 5 - Report on Supply Chain Due Diligence

As required under the Rule, Accuray has filed its Form SD, which contains this Report as an exhibit, with the SEC for the Reporting Period. Accuray expects to report annually, as required by the Rule, and has posted this Report on its website.

 

Due Diligence Outcome

 

As a result of its due diligence measures described above, Accuray received responses from 106 out of 107 (99%) in-scope suppliers that were contacted, with 96 of such suppliers providing a Template. The Conflicts Mineral team continues to follow up with 1 in-scope supplier from whom we have not yet received relevant information.  Among the suppliers who responded:

 

 

35 suppliers provided a completed Template incorporating responses from 100% of suppliers in their supply chain, including the names and locations of smelters and refiners that process Conflict Minerals used in components provided by such supplier, with 12 of such suppliers providing Templates that identified materials down to the location of mine.

 

Of those suppliers that provided a Template, 61 provided inconsistent or incomplete information or provided information that suggest persistent issues remain with comprehension of the topic or how to accurately complete the Template.

 

8 suppliers did not provide Templates, but instead provided only company policy statements or declarations.

 

2 suppliers responded that the products supplied to Accuray did not contain any 3TG.  

 

46 or 38% of tungsten smelters and refiners identified are verified “conflict-free” for tungsten.

 

85 or 26% of tin smelters and refiners identified are verified “conflict-free” for tin.

 

41 or 53% of tantalum smelters and refiners identified are verified “conflict-free” for tantalum.

 

110 or 35% of gold smelters and refiners identified are verified “conflict-free” for gold.

 

Given that not all smelters identified by our suppliers were certified as “conflict free” by an independent third-party audit program, and that a number of supplier responses regarding the sources of raw materials for the Covered Products were determined to be uncertain or unknown (including because certain suppliers were only able to provide responses at the company-level rather than information specific to Accuray products), Accuray was unable to precisely determine whether or not all supplier parts in its supply chain for the Covered Products contain Necessary Conflict Minerals from the Covered Countries or, in the alternative, utilized Conflict Minerals in their manufacture that either financed or benefited, directly or indirectly, armed groups in the Covered Countries. As such, Accuray’s due diligence in 2019 found that Accuray products containing or utilizing Conflict Minerals are “DRC conflict undeterminable” (as defined in the Rule).

 

The statements above are based on the RCOI process and due diligence performed in good faith by Accuray. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect this Report. These factors include, but are not limited to, gaps in product or product content information, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers or third-party service providers, errors or omissions by smelters, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the protocol, oversights or errors in conflict-free smelter audits, Covered Countries' sourced materials being declared secondary materials, companies not continuing in business in 2019 or 2020, certification programs that are not equally advanced for all industry segments and metals, and smuggling of the Conflict Minerals to countries beyond the Covered Countries.

 

Identified Smelters and Refiners

 

 


EXHIBIT 1.01

As a result of Accuray’s RCOI and due diligence, Accuray has compiled a list on Schedule 1 of the smelter and refiner facilities identified by its suppliers in completed Templates provided by such suppliers. Out of the 96 suppliers that provided smelter lists, 20 provided the smelters at the product level (i.e., they provided information for the particular types of products and components they supplied to Accuray), 71 provided smelters at the company level (i.e., they provided information regarding all Conflict Minerals used in every component and product they manufacture rather than responses specific to the types of products and components used in the Covered Products), and 5 were “user defined.” As a result, some of the smelters and refiners reported to Accuray and identified on Schedule 1 may not actually have been used to process the Necessary Conflict Minerals in the Covered Products.

 

Identified Countries of Origin of Necessary Conflict Minerals

 

Accuray does not have sufficient information to reliably determine the countries of origin of all of the Necessary Conflict Minerals in the Covered Products given that certain suppliers provided inconsistent or incomplete responses or provided information at the company level. However, based on information provided by Accuray’s in-scope suppliers in completed Templates, Accuray believes that the countries of origin may include the countries listed in Schedule 2. As discussed above, because some suppliers provided information at the company level, the countries of origin of the Necessary Conflict Minerals in the Covered Products may not actually include certain of the countries in Schedule 2. 

 

Efforts to Determine Mine or Location of Origin

 

Accuray’s efforts to determine the mines or locations of origin of the Necessary Conflict Minerals with the greatest possible specificity included the use of the RCOI and due diligence measures described above.

 

Future Due Diligence and Risk Mitigation

 

Accuray expects to take the following steps, among others, to continue to improve the due diligence conducted and to further mitigate the risk that the Necessary Conflict Minerals in Accuray’s products benefit armed groups in the Covered Countries:

 

1.

Accuray intends to continue to enhance supplier communication and engagement to improve due diligence data accuracy and completeness, including directing suppliers to training resources and continuing efforts to obtain from suppliers a completed Template response that identifies materials down to the smelter and mine.

 

2.

Accuray intends to continue to encourage its suppliers to implement responsible sourcing by using Conflict Minerals only from smelters or refiners that have been certified as conflict-free through the RMAP.

 

3.

Accuray intends to continue to compare smelters and refiners identified through the due diligence process against lists of facilities that have received a third-party “conflict free” designation and track those that have not received such a designation.

 

4.

Accuray intends to communicate to new in-scope suppliers Accuray’s sourcing expectations, including through the dissemination of the Supplier Code of Conduct as well as including a clause in new or renewed supplier contracts that will require compliance with such code.

 

Inherent Limitations on Due Diligence Measures

 

Accuray’s supply chain with respect to the Covered Products is complex, and its procurement and manufacturing process is significantly removed from the sourcing, mining, smelting and refining of Conflict Minerals. As a result, Accuray does not have direct contractual relationships with smelters, refiners or mines, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of Conflict Minerals. Moreover, Accuray believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals and, therefore, has taken steps to identify the applicable smelters and refiners of Necessary Conflict Minerals in Accuray’s supply chain by using the Template. However, tracing these minerals to their sources is a challenge that requires Accuray to rely on its direct suppliers in its efforts to achieve supply chain transparency, including obtaining information regarding the origin of the Necessary Conflict Minerals. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. In addition, because of the Accuray’s relative location within the supply chain in relation to the actual extraction and transport of Conflict Minerals, its ability to verify the accuracy of information reported by suppliers is limited.

 

Cautionary Note on Forward-looking Statements

 

This Report includes forward-looking statements within the meaning of Section 21E of the Securities Exchange Act of 1934, as amended. All statements other than statements of historical facts contained in this Report, including without limitation, statements regarding the Company’s intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts and strategy, are forward-looking statements. In some cases, you can identify forward-looking statements by

 


 

terminology such as “believe,” “will,” “may,” “seek,” “estimate,” “continue,” “anticipate,” “evaluate,” “intend,” “should,” “plan,” “expect,” “predict,” “could,” “potentially” and similar expressions that convey uncertainty of future events or outcomes. These forward looking statements are subject to risks and uncertainties that could cause actual results and events to differ materially and adversely from those anticipated or implied which include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and Accuray’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others, and the other risks identified above under the caption “Due Diligence Outcome.” Accuray undertakes no obligation to revise or publicly release the results of any revision to these forward-looking statements, except as required by law. Subsequent events may affect Accuray’s future determinations under the Rule. Accuray’s due diligence and reporting obligations under the Rule may change in the future and its ability to implement certain processes or obtain information from its suppliers may differ materially from those anticipated or implied in this Report. Given these risks and uncertainties, readers are cautioned not to place undue reliance on such forward-looking statements.


 


EXHIBIT 1.01

Schedule 1

 

Smelter and Refiner Information

 

Based on the information that was provided by Accuray’s suppliers in completed Templates, Accuray believes that, to the extent reasonably determinable by Accuray, the facilities that may have been used to process the Necessary Conflict Minerals contained in the Covered Products included the smelters and refiners identified below. However, as noted above, where Accuray’s suppliers provided information on a division- or company-wide basis regarding all Conflict Minerals used in every component and product they manufacture rather than responses specific to the types of products and components supplied to Accuray for use in the Covered Products, the smelters and refiners reported to Accuray by those suppliers may not actually have been used to process the Necessary Conflict Minerals in the Covered Products.

 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

Unknown

5N PLUS UK ltd

N (Unknown)

GERMANY

Gold

CID002763

8853 S.p.A.

Y

AUSTRALIA

Gold

CID002708

Abington Reldan Metals, LLC

N

ITALY

Gold

CID000009

Acade Noble Metal (Zhao Yuan) Corporation

N

JAPAN

Gold

CID000015

Advanced Chemical Company

Y

UNITED STATES OF AMERICA

Gold

CID003185

African Gold Refinery

N

CHINA

Gold

CID000035

AGoSI

N

CHINA

Gold

CID000019

Aida Chemical Industries Co. Ltd.

Y

BRAZIL

Gold

CID000019

Aida Chemical Industries Co., Ltd.

Y

UNITED STATES OF AMERICA

Gold

CID000028

Aktyubinsk Copper Company TOO

N

UNITED STATES OF AMERICA

Gold

CID002560

Al Etihad Gold Refinery DMCC

Y

UGANDA

Gold

CID000035

Allgemeine Gold-und Silberscheideanstalt A.G.

Y

GERMANY

Gold

CID000041

Almalyk Mining and Metallurgical Complex (AMMC)

Y

JAPAN

Gold

Unknown

Ampere Polska Sp.z.o.o (trader)

N (Unknown)

JAPAN

Gold

CID000058

AngloGold Ashanti Corrego do Sitio Mineracao

Y

CANADA

Gold

Unknown

ANZ Banking

N (Unknown)

KAZAKHSTAN

Gold

CID000077

Argor-Heraeus S.A.

Y

UNITED ARAB EMIRATES

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

Unknown

ARY Aurum Plus

N (Unknown)

BRAZIL

Gold

CID000082

Asahi Pretec Corp.

Y

GERMANY

Gold

CID000924

Asahi Refining Canada Ltd.

Y

UZBEKISTAN

Gold

CID000920

Asahi Refining USA Inc.

Y

UNITED STATES OF AMERICA

Gold

CID000090

Asaka Riken Co., Ltd.

Y

VIET NAM

Gold

Unknown

Asha Enterprise

N (Unknown)

UNITED STATES

Gold

CID000103

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

N

UNITED STATES

Gold

CID002851

AURA-II

N

UNITED KINGDOM

Gold

CID000113

Aurubis AG

Y

PERU

Gold

CID000120

Baiyin Nonferrous Metals Corporation (BNMC)

N

UNITED STATES

Gold

CID002863

Bangalore Refinery

N

CANADA

Gold

CID000128

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Y

TAIWAN

Gold

CID000049

Bauer Walser AG

N

UNITED STATES OF AMERICA

Gold

CID000157

Boliden AB

Y

VIET NAM

Gold

CID000176

C. Hafner GmbH + Co. KG

Y

VIET NAM

Gold

CID000180

Caridad

N

CHINA

Gold

CID000185

CCR Refinery - Glencore Canada Corporation

Y

CHINA

Gold

CID000189

Cendres + Metaux S.A.

Y

CHINA

Gold

CID003382

CGR Metalloys Pvt Ltd.

N

BRAZIL

Gold

CID000197

CHALCO Yunnan Copper Co. Ltd.

N

CHINA

Gold

Unknown

Changzhou Chemical Research Institute Co. Ltd.

N (Unknown)

AUSTRIA

Gold

Unknown

Cheong Hing

N (Unknown)

CHINA

Gold

CID000233

Chimet S.p.A.

Y

SWITZERLAND

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

Unknown

China  Sino-Platinum Metals Co.,Ltd

N (Unknown)

UNITED ARAB EMIRATES

Gold

CID000235

China Gold International Resources Corp. Ltd.

N

JAPAN

Gold

Unknown

China Golddeal

N (Unknown)

CANADA

Gold

Unknown

China National Gold Group Corporation

N (Unknown)

UNITED STATES OF AMERICA

Gold

CID000264

Chugai Mining

Y

CHINA

Gold

CID000284

Codelco

N

JAPAN

Gold

CID000288

Colt Refining

N

JAPAN

Gold

CID000328

Daejin Indus Co., Ltd.

N

JAPAN

Gold

CID000333

DaeryongENC

N

CANADA

Gold

CID000343

Daye Non-Ferrous Metals Mining Ltd.

N

VIET NAM

Gold

Unknown

Dayu Weiliang Tungsten Co., Ltd.

N (Unknown)

TURKEY

Gold

CID003348

Dijllah Gold Refinery FZC

N

UNITED STATES

Gold

Unknown

Dingnan Jiawang environmental Tin technology Co.

N (Unknown)

UNITED STATES

Gold

CID000362

DODUCO Contacts and Refining GmbH

Y

UNITED STATES OF AMERICA

Gold

Unknown

Dong'guan Dong wu Violent-toxic Chemical Products Co., Ltd.

N (Unknown)

GERMANY

Gold

Unknown

Dongguan Dongxu Metal Surface Hanlde Co Ltd

N (Unknown)

AUSTRALIA

Gold

Unknown

Dongguanshi Sutande Dianzi Cailiao Youxiangongsi

N (Unknown)

UNITED KINGDOM

Gold

Unknown

Dosung metal

N (Unknown)

JAPAN

Gold

CID000401

Dowa

Y

CHINA

Gold

CID003195

DS PRETECH Co., Ltd.

Y

GERMANY

Gold

CID000359

DSC (Do Sung Corporation)

Y

INDIA

Gold

Unknown

DUOXIN

N (Unknown)

PHILIPPINES

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

Unknown

ECHEMEMI ENTERPRISE CORP.(FUTURES EXCHANGE)

N (Unknown)

GERMANY

Gold

CID000425

Eco-System Recycling Co., Ltd. East Plant

Y

CHINA

Gold

CID003424

Eco-System Recycling Co., Ltd. North Plant

Y

CHINA

Gold

CID003425

Eco-System Recycling Co., Ltd. West Plant

Y

BRAZIL

Gold

CID001322

Elemetal Refining, LLC

N

CHINA

Gold

CID002561

Emirates Gold DMCC

Y

SWEDEN

Gold

Unknown

ESG Edelmetallservice GmbH & Co. KG

N (Unknown)

INDONESIA

Gold

CID002355

Faggi Enrico S.p.A.

N

GERMANY

Gold

CID002515

Fidelity Printers and Refiners Ltd.

N

UNITED KINGDOM

Gold

CID002584

Fujairah Gold FZC

N

UNITED STATES

Gold

CID002852

GCC Gujrat Gold Centre Pvt. Ltd.

N

CHINA

Gold

CID002459

Geib Refining Corporation

Y

MALAYSIA

Gold

Unknown

Gejiu Yunxi Group Corp.

N (Unknown)

GERMANY

Gold

Unknown

Gold and Siver Refining Strokes Ltd.

N (Unknown)

UNITED STATES OF AMERICA

Gold

CID002243

Gold Refinery of Zijin Mining Group Co., Ltd.

Y

MEXICO

Gold

Unknown

Gong an ju

N (Unknown)

CANADA

Gold

CID001909

Great Wall Precious Metals Co., Ltd. of CBPM

N

SWITZERLAND

Gold

CID001909

Great Wall Precious Metals Co., Ltd. of CBPM

N

SOUTH AFRICA

Gold

Unknown

GUANG XI HUA XI CORP

N (Unknown)

JAPAN

Gold

Unknown

GUANGDONG HUA JIAN TRADE DO.,LTD

N (Unknown)

UNITED STATES OF AMERICA

Gold

CID002312

Guangdong Jinding Gold Limited

N

INDIA

Gold

CID000611

GUANGDONG JINXIAN GAOXIN CAI LIAO GONG SI

N

CHINA

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

Unknown

Guangdong macro jin precious metal smelting

N (Unknown)

CHINA

Gold

Unknown

Guangdong MingFa Precious Metal Co.,Ltd

N (Unknown)

CHINA

Gold

Unknown

Guangxi Huaxi Group

N (Unknown)

CHINA

Gold

Unknown

Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch

N (Unknown)

CHINA

Gold

CID000651

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

N

CHINA

Gold

Unknown

H. Kramer & Co.

N (Unknown)

HONG KONG

Gold

CID000670

Hang Seng Technology

N

CHINA

Gold

CID000671

Hangzhou Fuchunjiang Smelting Co., Ltd.

N

ITALY

Gold

Unknown

Harima Smelter

N (Unknown)

CHINA

Gold

Unknown

Harmony Gold Refinery

N (Unknown)

CHINA

Gold

CID000694

Heimerle + Meule GmbH

Y

CHINA

Gold

CID000702

Henan Sanmenxia Lingbao Jinyuan Mining Co., Ltd.

N

CHINA

Gold

CID002519

Henan Yuguang Gold & Lead Co., Ltd.

N

CHINA

Gold

Unknown

Henan zhongyuan gold melter

N (Unknown)

CHINA

Gold

Unknown

Heraeus Hong Kong,Heraeus limited,Heraeus Technology Center

N (Unknown)

CHINA

Gold

CID000707

Heraeus Metals Hong Kong Ltd.

Y

CHINA

Gold

CID000711

Heraeus Precious Metals GmbH & Co. KG

Y

CHINA

Gold

Unknown

Heraeus Zhaoyuan (Changshu) Electronic Material Co., Ltd.

N (Unknown)

CHINA

Gold

Unknown

Heraeus Zhaoyuan Precious Metal Materials Co.,Ltd.

N (Unknown)

CHINA

Gold

CID000718

HeTai Gold Mineral GuangDong Ltd. Co.

Y

CHINA

Gold

Unknown

Hon Hai

N (Unknown)

JAPAN

Gold

Unknown

Hon Shen Co. Ltd

N (Unknown)

SINGAPORE

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

Unknown

HonHai Precision Co., Ltd.

N (Unknown)

China

Gold

CID000767

Hunan Chenzhou Mining Co., Ltd.

N

CHINA

Gold

CID000773

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

N

CHILE

Gold

CID000778

HwaSeong CJ CO., LTD.

N

UNITED STATES OF AMERICA

Gold

CID000801

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

Y

CHINA

Gold

CID002562

International Precious Metal Refiners

N

SPAIN

Gold

CID000807

Ishifuku Metal Industry Co., Ltd.

Y

BRAZIL

Gold

CID000814

Istanbul Gold Refinery

Y

BRAZIL

Gold

CID002765

Italpreziosi

Y

MALAYSIA

Gold

CID000823

Japan Mint

Y

UNITED STATES OF AMERICA

Gold

CID000830

Japan Pure Chemical

N

UNITED STATES OF AMERICA

Gold

Unknown

Jhonson Mattehey

N (Unknown)

RUSSIAN FEDERATION

Gold

Unknown

Jia Lung Corp

N (Unknown)

INDONESIA

Gold

CID000855

Jiangxi Copper Co., Ltd.

Y

INDONESIA

Gold

Unknown

Jie sheng

N (Unknown)

INDONESIA

Gold

Unknown

Jin Dong Heng

N (Unknown)

INDONESIA

Gold

CID000884

Jin Jinyin refining company limited

N

INDONESIA

Gold

Unknown

JinBao Electronic Co.,Ltd.

N (Unknown)

INDONESIA

Gold

Unknown

Jinfeng Gold Mine Smelter

N (Unknown)

INDONESIA

Gold

Unknown

Jinli Enterprise Co., Ltd.

N (Unknown)

INDONESIA

Gold

CID000909

Jinlong Copper Co., Ltd.

Y

INDONESIA

Gold

Unknown

Johnson Matthey HongKong Ltd

N (Unknown)

UNITED STATES

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

CID000927

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

N

UNITED STATES OF AMERICA

Gold

CID000929

JSC Uralelectromed

Y

VIET NAM

Gold

CID000937

JX Nippon Mining & Metals Co., Ltd.

Y

KOREA, REPUBLIC OF

Gold

Unknown

K.A.Rasmussen as

N (Unknown)

KOREA, REPUBLIC OF

Gold

CID002563

Kaloti Precious Metals

N

KOREA, REPUBLIC OF

Gold

CID000948

Kanfort Industrial (Yantai) Co. Ltd.

N

KOREA, REPUBLIC OF

Gold

CID000956

Kazakhmys Smelting LLC

N

CHINA

Gold

CID000957

Kazzinc

Y

CHINA

Gold

Unknown

Kee Shing

N (Unknown)

CHINA

Gold

CID000969

Kennecott Utah Copper LLC

Y

CHINA

Gold

CID002511

KGHM Polska Miedz Spolka Akcyjna

Y

CHINA

Gold

CID000981

Kojima Chemicals Co. Ltd

Y

CHINA

Gold

Unknown

Kombinat Gorniczo Hutniczy Miedz Polska Miedz S.A.

N (Unknown)

RWANDA

Gold

CID000988

Korea Metal Co., Ltd.

N

UNITED ARAB EMIRATES

Gold

CID002605

Korea Zinc Co., Ltd.

Y

CHINA

Gold

CID000991

Kosak Seiren

N

GERMANY

Gold

CID001009

Kunshan Jinli chemical industry reagents co.,Ltd.

N

CHINA

Gold

Unknown

KUNSHAN SHING LEE SOLDERING MANUFACTURE CO., LTD.

N (Unknown)

CHINA

Gold

CID001024

KYOCERA

N

CHINA

Gold

CID001029

Kyrgyzaltyn JSC

Y

CHINA

Gold

CID002865

Kyshtym Copper-Electrolytic Plant ZAO

N

CHINA

Gold

CID001032

L'azurde Company For Jewelry

N

CHINA

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

CID001036

LBMA

N

BRAZIL

Gold

CID001056

Lingbao Gold Co., Ltd.

N

CHINA

Gold

CID001058

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

N

KOREA, REPUBLIC OF

Gold

Unknown

LINXENS

N (Unknown)

CHINA

Gold

Unknown

LITTELFUSE

N (Unknown)

JAPAN

Gold

Unknown

LONDON BULLION MARKET ASSOCIATION

N (Unknown)

JAPAN

Gold

CID002762

L'Orfebre S.A.

Y

GERMANY

Gold

CID001078

LS-NIKKO Copper Inc.

Y

KOREA, REPUBLIC OF

Gold

CID000689

LT Metal Ltd.

Y

KOREA, REPUBLIC OF

Gold

CID001093

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

N

KOREA, REPUBLIC OF

Gold

CID002606

Marsam Metals

Y

CHINA

Gold

CID001113

Materion

Y

CHINA

Gold

CID001119

Matsuda Sangyo Co., Ltd.

Y

UNITED STATES OF AMERICA

Gold

CID002821

Metahub Industries Sdn. Bhd.

N

CHINA

Gold

CID001153

Metalor Switzerland

Y

JAPAN

Gold

CID001149

Metalor Technologies (Hong Kong) Ltd.

Y

JAPAN

Gold

CID001152

Metalor Technologies (Singapore) Pte., Ltd.

Y

JAPAN

Gold

CID001147

Metalor Technologies (Suzhou) Ltd.

Y

MALAYSIA

Gold

CID001153

Metalor Technologies S.A.

Y

SINGAPORE

Gold

CID001157

Metalor USA Refining Corporation

Y

VIET NAM

Gold

CID001161

Metalurgica Met-Mex Penoles S.A. De C.V.

Y

UNITED STATES OF AMERICA

Gold

CID001188

Mitsubishi Materials Corporation

Y

SPAIN

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

CID001193

Mitsui Kinzoku Co., Ltd.

Y

BOLIVIA (PLURINATIONAL STATE OF)

Gold

CID001196

MK electron

N

UNITED ARAB EMIRATES

Gold

CID002509

MMTC-PAMP India Pvt., Ltd.

Y

GERMANY

Gold

CID002857

Modeltech Sdn Bhd

N

BRAZIL

Gold

Unknown

Morigin Company

N (Unknown)

ETHIOPIA

Gold

CID002282

Morris and Watson

N

UNITED STATES OF AMERICA

Gold

CID002866

Morris and Watson Gold Coast

N

CHINA

Gold

CID001204

Moscow Special Alloys Processing Plant

Y

ITALY

Gold

CID001798

N.E. Chemcat Corporation

N

GERMANY

Gold

CID001220

Nadir Metal Rafineri San. Ve Tic. A.S.

Y

POLAND

Gold

CID001236

Navoi Mining and Metallurgical Combinat

N

ZIMBABWE

Gold

CID003189

NH Recytech Company

N

CHINA

Gold

CID001259

Nihon Material Co., Ltd.

Y

UNITED ARAB EMIRATES

Gold

CID002441

Nihon Superior Co., Ltd.

N

JAPAN

Gold

Unknown

Niihama Nickel Refinery

N (Unknown)

CHINA

Gold

Unknown

Nippon Mining & Mtetals

N (Unknown)

CHINA

Gold

Unknown

Nyrstar Metals

N (Unknown)

CHINA

Gold

CID002779

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

Y

TAIWAN

Gold

CID001323

Ohio Precious Metals LLC.

N

JAPAN

Gold

CID001325

Ohura Precious Metal Industry Co., Ltd.

Y

GERMANY

Gold

CID001326

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

Y

UNITED STATES

Gold

CID001328

OJSC Kolyma Refinery

N

CHINA

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

CID000493

OJSC Novosibirsk Refinery

Y

CHINA

Gold

Unknown

Outo Kumpu Stainless Inc.

N (Unknown)

CHINA

Gold

CID001352

PAMP S.A.

Y

CHINA

Gold

CID002872

Pease & Curren

N

CHINA

Gold

CID001362

Penglai Penggang Gold Industry Co., Ltd.

N

CHINA

Gold

CID002919

Planta Recuperadora de Metales SpA

Y

CHINA

Gold

CID002581

Precious Metals Sales Corp.

N

CHINA

Gold

CID001386

Prioksky Plant of Non-Ferrous Metals

Y

CHINA

Gold

CID001397

PT Aneka Tambang (Persero) Tbk

Y

CHINA

Gold

CID001498

PX Precinox S.A.

N

INDIA

Gold

CID003324

QG Refining, LLC

N

UNITED STATES OF AMERICA

Gold

CID001512

Rand Refinery (Pty) Ltd.

Y

CHINA

Gold

Unknown

Realized the enterprise co.,ltd.

N (Unknown)

CHINA

Gold

CID000522

Refinery of Seemine Gold Co., Ltd.

N

CHINA

Gold

CID002582

Remondis Argentia B.V.

Y

CHINA

Gold

CID002510

Republic Metals Corporation

Y

CHINA

Gold

CID001530

Rohm & Haas Elec. Mat'ls

N

CHINA

Gold

CID001534

Royal Canadian Mint

Y

CHINA

Gold

CID002761

SAAMP

Y

CHINA

Gold

CID001546

Sabin Metal Corp.

Y

CHINA

Gold

CID002973

Safimet S.p.A

Y

CHINA

Gold

CID002290

SAFINA A.S.

Active

CHINA

Gold

CID002853

Sai Refinery

N

CHINA

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

CID001555

Samduck Precious Metals

N

CHINA

Gold

CID001562

SAMWON Metals Corp.

N

CHINA

Gold

CID001567

Sanmenxia hang seng science and technology, research and development Co., LTD

N

UNITED STATES

Gold

CID002777

SAXONIA Edelmetalle GmbH

Y

UNITED STATES OF AMERICA

Gold

CID001573

Schone Edelmetaal B.V.

N

JAPAN

Gold

CID001577

ScotiaMocatta, The Bank of Nova Scotia

N

UNITED STATES OF AMERICA

Gold

CID001585

SEMPSA Joyeria Plateria S.A.

Y

UNITED STATES OF AMERICA

Gold

Unknown

Sen Silver

N (Unknown)

CHINA

Gold

Unknown

SEVELAR

N (Unknown)

CHINA

Gold

CID001600

Sewon Korea

N

CHINA

Gold

CID001604

Shan Dong Huangjin

N

CHINA

Gold

CID001605

Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co. Ltd.

N

CHINA

Gold

CID001607

Shandon Jin Jinyin Refining Limited

N

UNITED STATES

Gold

Unknown

Shandong Guoda gold Co., LTD.

N (Unknown)

CHINA

Gold

Unknown

Shandong Hengbang Smelter Co.,ltd

N (Unknown)

CHINA

Gold

CID002525

Shandong Humon Smelting Co., Ltd.

N

UNITED STATES

Gold

CID001619

Shandong Tarzan Bio-Gold Industry Co., Ltd.

N

TAIWAN, REPUBLIC OF CHINA

Gold

CID002614

Shandong Yanggu Xiangguang Co. Ltd.

N

CHINA

Gold

CID001622

Shandong Zhaojin Gold & Silver Refinery Co. Ltd

Y

CHINA

Gold

Unknown

Shangdong zhaoyuanzhaojin Company

N (Unknown)

CHINA

Gold

CID001631

Shanghai Gold Exchange

N

CHINA

Gold

Unknown

Shen Zhen Thousand Island Ltd.

N (Unknown)

CHINA

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

CID001690

Shenzhen fujun material technology co.,ltd

N

CHINA

Gold

CID001692

Shenzhen Heng Zhong Industry Co.,Ltd.

N

CHINA

Gold

Unknown

Shenzhen Kuril company

N (Unknown)

CHINA

Gold

CID001707

SHENZHEN TIANCHENG CHEMICAL CO LTD

N

CHINA

Gold

Unknown

ShenZhen urban pubic bureau of China

N (Unknown)

CHINA

Gold

CID002527

Shenzhen Zhonghenglong Real Industry Co., Ltd.

N

CHINA

Gold

CID001723

SHINKO ELECTRIC INDUSTRIES CO., LTD.  

N

CHINA

Gold

CID001756

Shyolkovsky

N

CHINA

Gold

CID001736

Sichuan Tianze Precious Metals Co., Ltd.

Y

CHINA

Gold

CID002516

Singway Technology Co., Ltd.

Y

CHINA

Gold

CID001745

SINO-PLATINUM METALS CO.,LTD

N

CHINA

Gold

Unknown

SKE (China): Shanghai Kyocera Electronics CO. LTD.

N (Unknown)

CHINA

Gold

Unknown

SMM

N (Unknown)

CHINA

Gold

CID001754

So Accurate Group, Inc.

N

CHINA

Gold

CID001756

SOE Shyolkovsky Factory of Secondary Precious Metals

Y

RUSSIAN FEDERATION

Gold

 

Sojitz

N

THAILAND

Gold

CID001761

Solar Applied Materials Technology Corp.

Y

GERMANY

Gold

CID003383

Sovereign Metals

N

GERMANY

Gold

Unknown

Stanchem Sp.j. (trader)

N (Unknown)

UNITED STATES OF AMERICA

Gold

CID001783

Standard Bank

N

JAPAN

Gold

CID003153

State Research Institute Center for Physical Sciences and Technology

N

GERMANY

Gold

Unknown

Strain DS Force Shop

N (Unknown)

GERMANY

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

CID002567

Sudan Gold Refinery

N

GERMANY

Gold

CID001798

Sumitomo Metal Mining Co., Ltd.

Y

GERMANY

Gold

CID001804

Sun Surface Technology Co Ltd

N

UNITED KINGDOM

Gold

CID002918

SungEel HiMetal Co., Ltd.

Y

MALAYSIA

Gold

CID001810

Super Dragon Technology Co., Ltd.

Y

KOREA, REPUBLIC OF

Gold

CID002756

Super Ligas

N

CHINA

Gold

CID001826

Suzhou Xingrui Noble

N

CHINA

Gold

CID002580

T.C.A S.p.A

Y

JAPAN

Gold

Unknown

Taiwan Bank Purchase Fund

N (Unknown)

SOUTH AFRICA

Gold

Unknown

Tanaka Denshi Kogyo K.K

N (Unknown)

NEW ZEALAND

Gold

CID001875

Tanaka Kikinzoku Kogyo K.K.

Y

GERMANY

Gold

CID001887

Technic Inc

N

CHINA

Gold

CID001916

The Refinery of Shandong Gold Mining Co., Ltd.

Y

CHINA

Gold

CID001938

Tokuriki Honten Co., Ltd.

Y

UNITED STATES OF AMERICA

Gold

CID001947

Tongling Nonferrous Metals Group Co., Ltd.

N

CHINA

Gold

CID002587

Tony Goetz NV

N

CHINA

Gold

CID002615

TOO Tau-Ken-Altyn

N

HONG KONG

Gold

CID001955

Torecom

Y

CHINA

Gold

Unknown

Toyo Smelter & Refinery

N (Unknown)

CHINA

Gold

Unknown

UBS AG

N (Unknown)

GERMANY

Gold

CID001977

Umicore Brasil Ltda.

Y

HONG KONG

Gold

CID002314

Umicore Precious Metals Thailand

Y

CHINA

Gold

CID001980

Umicore S.A. Business Unit Precious Metals Refining

Y

CHINA

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

CID001986

UNIFORCE METAL INDUSTRIAL CORP.

N

CHINA

Gold

CID001993

United Precious Metal Refining, Inc.

Y

CHINA

Gold

Unknown

United Refining

N (Unknown)

CHINA

Gold

CID002854

Universal Precious Metals Refining Zambia

N

TAIWAN

Gold

Unknown

UYEMURA

N (Unknown)

JAPAN

Gold

CID002003

Valcambi SA

Y

JAPAN

Gold

CID002009

Viagra Di precious metals (Zhaoyuan) Co., Ltd.

N

JAPAN

Gold

Unknown

WAM Technologies Taiwan Co.,Ltd.

N (Unknown)

UNITED STATES OF AMERICA

Gold

CID002030

Western Australian Mint (T/a The Perth Mint)

Y

TAIWAN

Gold

CID002778

WIELAND Edelmetalle GmbH

Y

TAIWAN

Gold

Unknown

WILLIAMS GOLD REFINING CO INC

N (Unknown)

CHINA

Gold

Unknown

Wind Yunnan Nonferrous Metals Co., Ltd.

N (Unknown)

TAIWAN

Gold

Unknown

Wuxi Middle Treasure Materials

N (Unknown)

BOLIVIA (PLURINATIONAL STATE OF)

Gold

CID002063

Wuzhong Group

N

TAIWAN

Gold

CID002100

Yamakin Co., Ltd.

Y

CHINA

Gold

Unknown

Yantai Zhaojin Kanfort Precious Metals Co., Ltd.

N (Unknown)

CHINA

Gold

CID002129

Yokohama Metal Co., Ltd.

Y

CHINA

Gold

CID002134

Yoo Chang Metal

N

CHINA

Gold

CID000197

Yunnan Copper Industry Co., Ltd.

N

CHINA

Gold

Unknown

Zhaoyuan Li Fu Industrial

N (Unknown)

CHINA

Gold

Unknown

ZHAOYUAN LIFUSHIYE Co., Ltd

N (Unknown)

CHINA

Gold

CID002205

Zhe Jiang Guang Yuan Noble Metal Smelting Factory

N

CHINA

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Gold

CID002224

Zhongjin Gold Corporation Limited

Y

CHINA

Gold

CID002214

Zhongkuang Gold Industry Co., Ltd.

N

CHINA

Gold

CID002219

Zhongshan Hyper-Toxic Substance Monopolized Co., Ltd.

N

CHINA

Gold

Unknown

ZHONGSHAN POISON MATERIAL PROPRIETARY CO., LTD

N (Unknown)

CHINA

Gold

Unknown

Zhongshan Public Security Bureau, Guangdong Province ,China

N (Unknown)

GERMANY

Gold

CID002224

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

Y

KOREA, REPUBLIC OF

Tantalum

Unknown

Advanced Metallurgical Group N.V. (AMG)

N (Unknown)

RUSSIAN FEDERATION

Tantalum

Unknown

ANHUI HERRMAN IMPEX CO.

N (Unknown)

KOREA, REPUBLIC OF

Tantalum

CID000092

Asaka Riken Co., Ltd.

Y

BRAZIL

Tantalum

CID002705

Avon Specialty Metals Ltd.

N

UNITED STATES

Tantalum

Unknown

Cabot Corporation

N (Unknown)

INDONESIA

Tantalum

Unknown

Central Bank of the DPR of Korea

N (Unknown)

CHINA

Tantalum

CID000196

CFC Cooperativa dos Fundidores de Cassiterita da Amazonia Ltda.

N

CHINA

Tantalum

CID000211

Changsha South Tantalum Niobium Co., Ltd.

Y

CHINA

Tantalum

Unknown

China Shenzhen Morgan Sputtering Targets & Technology Co., Ltd.

N (Unknown)

UNITED ARAB EMIRATES

Tantalum

CID003402

CP Metals Inc.

Y

JAPAN

Tantalum

CID002504

D Block Metals, LLC

Y

TURKEY

Tantalum

Unknown

DONGGUAN CITY XIDA SOLDERING TIN PRODUCTS CO

N (Unknown)

ITALY

Tantalum

CID000410

Douluoshan Sapphire Rare Metal Co Ltd

N

JAPAN

Tantalum

CID000410

Duoluoshan

N

JAPAN

Tantalum

CID002590

E.S.R. Electronics

N

JAPAN

Tantalum

Unknown

Ethiopian Minerals Development Share Company

N (Unknown)

JAPAN

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Tantalum

CID000456

Exotech Inc.

Y

JAPAN

Tantalum

CID000460

F&X Electro-Materials Ltd.

Y

TAIWAN, REPUBLIC OF CHINA

Tantalum

CID002505

FIR Metals & Resource Ltd.

Y

BELGIUM

Tantalum

Unknown

Fujian Nanping

N (Unknown)

UNITED STATES

Tantalum

Unknown

Gannon & Scott

N (Unknown)

TAIWAN

Tantalum

CID000564

Global Advanced Metals

N

CHINA

Tantalum

CID002558

Global Advanced Metals Aizu

Y

CHINA

Tantalum

CID002557

Global Advanced Metals Boyertown

Y

CHINA

Tantalum

CID000291

Guangdong Rising Rare Metals-EO Materials Ltd.

Y

CHINA

Tantalum

CID000616

Guangdong Zhiyuan New Material Co., Ltd.

Y

CHINA

Tantalum

Unknown

Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch

N (Unknown)

CHINA

Tantalum

CID002544

H.C. Starck Co., Ltd.

Y

CHINA

Tantalum

CID002546

H.C. Starck GmbH Laufenburg

N

CHINA

Tantalum

CID002547

H.C. Starck Hermsdorf GmbH

Y

CHINA

Tantalum

CID002548

H.C. Starck Inc.

Y

CHINA

Tantalum

CID002549

H.C. Starck Ltd.

Y

CHINA

Tantalum

CID002550

H.C. Starck Smelting GmbH & Co. KG

Y

CHINA

Tantalum

CID002545

H.C. Starck Tantalum and Niobium GmbH

Y

CHINA

Tantalum

Unknown

Henan Yuguang Gold & Lead Co., Ltd.

N (Unknown)

CHINA

Tantalum

CID002492

Hengyang King Xing Lifeng New Materials Co., Ltd.

Y

CHINA

Tantalum

CID000731

Hi-Temp Specialty Metals, Inc.

N

CHINA

Tantalum

CID002512

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

Y

CHINA

Tantalum

Unknown

Jiangxi huayu metal co., ltd.

N (Unknown)

CHINA

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Tantalum

CID002842

Jiangxi Tuohong New Raw Material

Y

GERMANY

Tantalum

Unknown

Jiangxi Yichun

N (Unknown)

CHINA

Tantalum

CID003191

Jiujiang Janny New Material Co., Ltd.

Y

CHINA

Tantalum

CID000914

JiuJiang JinXin Nonferrous Metals Co., Ltd.

Y

CHINA

Tantalum

CID000917

Jiujiang Tanbre Co., Ltd.

Y

CHINA

Tantalum

CID002506

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

Y

CHINA

Tantalum

CID002539

KEMET Blue Metals

Y

CHINA

Tantalum

CID002568

KEMET Blue Powder

Y

CHINA

Tantalum

CID000973

King-Tan Tantalum Industry Ltd

N

CHINA

Tantalum

CID000973

King-Tan Tantalum Industry Ltd.

N

CHINA

Tantalum

CID001076

LSM Brasil S.A.

Y

CHINA

Tantalum

CID001140

Metal Do

N

CHINA

Tantalum

CID001163

Metallurgical Products India Pvt. Ltd. (MPIL)

Y

CHINA

Tantalum

CID001175

Mineracao Taboca S.A.

Y

CHINA

Tantalum

CID001192

Mitsui Mining & Smelting

Y

CHINA

Tantalum

Unknown

Nantong Tongjie Electrical Co., Ltd.

N (Unknown)

CHINA

Tantalum

CID001277

Ningxia Non-ferrous Metal Smeltery

N

RUSSIAN FEDERATION

Tantalum

CID001277

Ningxia Orient Tantalum Industry Co., Ltd.

Y

RUSSIAN FEDERATION

Tantalum

CID001200

NPM Silmet AS

Y

RUSSIAN FEDERATION

Tantalum

CID001309

NTET, Thailand

N

CHINA

Tantalum

CID001368

Plansee

N

JAPAN

Tantalum

CID002540

Plansee SE Liezen

N

NORWAY

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Tantalum

CID002556

Plansee SE Reutte

N

UNITED ARAB EMIRATES

Tantalum

CID002847

Power Resources Ltd.

Y

CHINA

Tantalum

CID001508

QuantumClean

Y

CHINA

Tantalum

CID002707

Resind Industria e Comercio Ltda.

Y

KAZAKHSTAN

Tantalum

CID001522

RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.

Y

KAZAKHSTAN

Tantalum

CID001634

Shanghai Jiangxi Metals Co. Ltd

N

HONG KONG

Tantalum

CID001769

Solikamsk

Y

AUSTRALIA

Tantalum

CID001869

Taki Chemical Co., Ltd.

Y

MEXICO

Tantalum

CID001879

Tantalite Resources

N

UNITED STATES OF AMERICA

Tantalum

CID001891

Telex Metals

Y

UNITED STATES OF AMERICA

Tantalum

Unknown

Ton Yi Industrial Corporation

N (Unknown)

UNITED STATES OF AMERICA

Tantalum

CID002571

Tranzact, Inc.

N

UNITED STATES OF AMERICA

Tantalum

CID001969

Ulba Metallurgical Plant JSC

Y

CHINA

Tantalum

CID002508

XinXing HaoRong Electronic Material Co., Ltd.

Y

KOREA, REPUBLIC OF

Tantalum

CID002307

Yichun Jin Yang Rare Metal Co., Ltd.

N

POLAND

Tantalum

CID002232

Zhuzhou Cemented Carbide Group Co., Ltd.

N

INDONESIA

Tin

CID002662

5N PLUS

N

CHINA

Tin

CID000011

AcademyPreciousMetals(China)Co.,Ltd

N

CHINA

Tin

CID000023

AIM Group

N

INDONESIA

Tin

CID000292

Alpha

Y

JAPAN

Tin

Unknown

ALPHA ASSEMBLY

N (Unknown)

JAPAN

Tin

Unknown

Amalgamated Metals Corporation, Ketabang

N (Unknown)

POLAND

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Tin

Unknown

Amalgament

N (Unknown)

KOREA, REPUBLIC OF

Tin

Unknown

Amalgamet

N (Unknown)

KOREA, REPUBLIC OF

Tin

CID000049

American Iron and Metal

N

JAPAN

Tin

Unknown

Ami Bridge Enterprise Co., Ltd.

N (Unknown)

CZECH REPUBLIC

Tin

CID002825

An Thai Minerals Co., Ltd.

N

CHINA

Tin

CID002703

An Vinh Joint Stock Mineral Processing Company

N

KOREA, REPUBLIC OF

Tin

CID000054

An Xin Xuan Xin Yue You Se Jin Shu Co. Ltd.

N

RUSSIAN FEDERATION

Tin

CID002714

Angelcast Enterprise Co., Ltd.

N

JAPAN

Tin

CID000071

Aoki Loboratories Ltd.

N

JAPAN

Tin

Unknown

Asahi Solder Technology (Wuxi) Co., Ltd.

N (Unknown)

KYRGYZSTAN

Tin

Unknown

Asahiseiren Co.,Ltd

N (Unknown)

RUSSIAN FEDERATION

Tin

Unknown

ATI Metalworking Products

N (Unknown)

CHINA

Tin

Unknown

Atlantic Metals

N (Unknown)

SAUDI ARABIA

Tin

Unknown

Ausmelt Limited

N (Unknown)

JAPAN

Tin

Unknown

Balver Zinn

N (Unknown)

CHINA

Tin

Unknown

Beijing Oriental Guide Welding Materials Co., Ltd.

N (Unknown)

TAIWAN, REPUBLIC OF CHINA

Tin

CID000151

Best Metals

N

CHINA

Tin

Unknown

BML

N (Unknown)

CHINA

Tin

Unknown

Bonoka.Beliting INDONESIA

N (Unknown)

CHINA

Tin

Unknown

Brinkmann Chemie AG

N (Unknown)

FRANCE

Tin

Unknown

Britannia Refined Metals Ltd.

N (Unknown)

UNITED STATES

Tin

Unknown

Butterworth Smelter

N (Unknown)

CHINA

 


 

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Tin

CID000228

Chenzhou Yun Xiang mining limited liability company

Y

UNITED KINGDOM

Tin

CID003190

Chifeng Dajingzi Tin Industry Co., Ltd.

Y

ANDORRA

Tin

Unknown

China Hongqiao

N (Unknown)

BRAZIL

Tin

Unknown

China Huaxi Group Nandan

N (Unknown)

KOREA, REPUBLIC OF

Tin

CID000244

China Rare Metal Material Co., Ltd.

N

KOREA, REPUBLIC OF

Tin

CID001070

China Tin Group Co., Ltd.

Y

RWANDA

Tin

Unknown

CINTAS METALICAS S.A

N (Unknown)

CHINA

Tin

CID000278

CNMC (Guangxi) PGMA Co. Ltd.

N

CHINA

Tin

Unknown

Cookson Alpha Metals(Shenzhen)Co.Ltd

N (Unknown)

TAIWAN

Tin

Unknown

Cooper Santa

N (Unknown)

CHINA

Tin

CID000295

Cooperativa Metalurgica de Rondônia Ltda.

N

BRAZIL

Tin

Unknown

Corporation Berhad (MSC)

N (Unknown)

MALAYSIA

Tin

Unknown

CSC Pure Technologies

N (Unknown)

MALAYSIA

Tin

CID002570

CV Ayi Jaya

Y

CHINA

Tin

CID002592

CV Dua Sekawan

Y

BRAZIL

Tin

CID000304

CV Duta Putra Bangka

N

VIET NAM

Tin

CID000306

CV Gita Pesona

Y

JAPAN

Tin

Unknown

CV JusTindo

N (Unknown)

UNITED STATES OF AMERICA

Tin

CID000308

CV Makmur Jaya

N

JAPAN

Tin

CID001458

CV Prima Timah Utama

Y

JAPAN

Tin

CID000315

CV United Smelting

Y

JAPAN

Tin

CID002455

CV Venus Inti Perkasa

Y

GERMANY

 


EXHIBIT 1.01

Metal (*)

Smelter Identification Number Input Column

Smelter or refiner name

RMAP conformant*

Smelter Country (*)

Tin

CID003154

Da Nang Processing Import and Export Joint Stock

N

UNITED STATES

Tin

Unknown

DAE CHANG IND CO LTD

N (Unknown)

UNITED KINGDOM

Tin

Unknown

Dae Kil

N (Unknown)

SPAIN

Tin

Unknown