UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM SD
Specialized Disclosure Report
VIASAT, INC.
(Exact Name of Registrant as Specified in its Charter)
| Delaware | 000-21767 | 33-0174996 | ||
| (State or Other Jurisdiction of Incorporation) |
(Commission File No.) |
(I.R.S. Employer Identification No.) |
6155 El Camino Real
Carlsbad, California 92009
(Address of Principal Executive Offices, Including Zip Code)
Brett A. Church
(760) 476-2200
(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, 2017 |
Section 1 - Conflict Minerals Disclosure
| Item 1.01 | Conflict Minerals Disclosure and Report |
CONFLICT MINERALS DISCLOSURE
Viasat, Inc. is filing a Conflict Minerals Report for the calendar year ended December 31, 2017, which is attached hereto as Exhibit 1.01 and is publicly available in the Financial Information section of its website at investors.viasat.com under the heading “SEC Filings.”
| Item 1.02 | Exhibit |
Item 2.01 of this Form SD is incorporated by reference into this Item 1.02.
Section 2 – Exhibits
| Item 2.01 | Exhibits |
| Exhibit Number |
Description of Exhibit | |
| 1.01 | Conflict Minerals Report | |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| VIASAT, INC. | ||||||
| Date: May 25, 2018 | By | /s/ Shawn Duffy | ||||
| Shawn Duffy | ||||||
| Senior Vice President and Chief Financial Officer | ||||||
EXHIBIT 1.01
VIASAT, INC.
CONFLICT MINERALS REPORT
Reporting Period:
January 1, 2017 – December 31, 2017
This Conflict Minerals Report (this “Report”) of Viasat, Inc. for calendar year 2017 has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule imposes certain reporting obligations on every registrant having conflict minerals that are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured. Please refer to the Rule, Special Disclosure Report on Form SD (“Form SD”) and the 1934 Act Release No. 34-67716 (August 22, 2012) for definitions of the terms used in this Report, unless otherwise defined herein. This Report does not address any conflict minerals that were “outside the supply chain” prior to January 31, 2013, as any such conflict minerals are exempted under the Rule and Form SD. References in this Report to “Viasat,” “we,” “us” and “our” mean Viasat, Inc. and its consolidated subsidiaries.
| A. | Overview |
Viasat is an innovator in broadband technologies and services. Our end-to-end platform of high-capacity Ka-band satellites, ground infrastructure and user terminals enables us to provide cost-effective, high-speed, high-quality broadband solutions to enterprises, consumers and government users around the globe, whether on the ground, on the move or in flight. In addition, we develop and provide advanced wireless communications systems, secure networking systems and cybersecurity and information assurance products and services.
We manufacture or contract to manufacture a variety of advanced satellite-based and wireless products, systems and solutions. We have determined that the Rule applies to our business because necessary conflict minerals are contained in our products.
Therefore, in accordance with the Rule and Form SD, we have conducted, in good faith, a reasonable country of origin inquiry (“RCOI”) with our suppliers that was reasonably designed to determine whether any conflict minerals in our products originated in the Democratic Republic of Congo (“DRC”) or an adjoining country (collectively, “Covered Countries”) or are from recycled or scrap sources. Based on our RCOI, we had reason to believe that, in calendar year 2017, necessary conflict minerals contained in our products may have originated in the Covered Countries, and had reason to believe that such necessary conflict minerals may not be from recycled or scrap sources. Therefore, given the possibility that necessary conflict minerals in our products may have originated from Covered Countries and may not be from recycled or scrap sources, we have conducted due diligence on the source and chain of custody of those conflict minerals.
| B. | Design of Conflict Minerals Program |
We designed our conflict minerals program to conform in all material respects with the internationally recognized due diligence framework developed by The Organisation for Economic Co-operation and Development (“OECD”). See OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, available at http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf and the related Supplements for gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”).
Our conflict minerals program has been designed to address each of the five steps in the OECD Guidance due diligence framework as they relate to our position as a “downstream” purchaser in the conflict minerals supply chain, namely:
| • | establish strong company management systems regarding conflict minerals; |
| • | identify and assess risks in our supply chain; |
| • | design and implement a strategy to respond to identified risks in our supply chain; |
| • | utilize independent third-party audits of smelters and refiners; and |
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| • | report publicly on our supply chain due diligence. |
Because we are a downstream supplier, we are many steps removed from the mining of conflict minerals. The components and materials contained in our products are supplied by a large number of suppliers, through multiple tiers of distribution. Once minerals are in the supply chain, determining the smelter or the origin of minerals is a challenging process, and we are realistic about the limitations on what we can identify and control.
Consistent with these limitations, the OECD Guidance acknowledges that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. The Responsible Minerals Initiative (“RMI”) guidance on implementing the OECD Guidance further recommends that, in conducting due diligence, downstream companies identify relevant or highest priority “tier-1” (direct) suppliers and focus their due diligence efforts on those priority suppliers first. Suggested factors for prioritizing tier-1 suppliers include annual spend.
Company Management Systems
We have established an internal conflict minerals program to manage risks in our supply chain through policies and procedures that are designed to help us understand whether the minerals in our products contribute to the ongoing conflict in the DRC. As part of our program, we have established and maintain company management systems that involve multiple levels of our organization.
Viasat’s Statement on Conflict Minerals (which is publicly available on our website at www.viasat.com/legal/legal-statements) reflects our commitment to respect human rights through our responsible sourcing practices, as well as our commitment to avoid practices that may contribute to human rights abuses.
Our conflict minerals steering committee oversees the design and execution of our conflict minerals program. Members of our steering committee include senior executives from our finance, legal, operations, engineering and supply chain departments. The steering committee’s responsibilities include reviewing and approving our Statement on Conflict Minerals, the design of our conflict minerals program and the results of our RCOI and due diligence measures. Our steering committee meets as required throughout each calendar year to review and discuss our conflict minerals program, and is briefed as to the status and findings of the supply chain due diligence we conduct each year.
Our conflict minerals program is managed by a cross-functional compliance team, comprised of representatives from our contracts, supply chain, quality, finance and legal groups. This compliance team reports directly to our conflict minerals steering committee.
In addition to the company management systems described above, we have also implemented the following company management controls:
| • | we provide our Statement on Conflict Minerals to all of our “tier-1” (direct) suppliers that supply relevant components and materials to us (referred to in this Report as our “Tier-1 Suppliers”) and communicate to them our expectations as to our supply chain and the responsible sourcing of conflict minerals; |
| • | we have adopted internal procedures with respect to conflict minerals into our quality management system (QMS); |
| • | we have put in place a grievance mechanism regarding our conflict minerals program; |
| • | we have established and maintain a central repository of information to facilitate analysis and identification of supplier responses received from our supply chain due diligence; and |
| • | we have incorporated provisions on conflict minerals as part of our standard terms and conditions for purchase orders. |
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We also support industry forums that share and communicate information and develop policies on conflict minerals. In 2014, we became a member of the RMI, formerly known as the Conflict Free Sourcing Initiative, an organization committed to the responsible sourcing of conflict minerals, and we continue to be a supportive member of the organization. We also provide funding to non-profit and industry initiatives that support the responsible sourcing of conflict minerals through our RMI membership.
Identification and Assessment of Supply Chain Risk
We have developed and implemented a risk management plan to identify and assess risks in our supply chain. To identify and assess these risks, we identify all of our Tier-1 Suppliers and conduct an annual supply chain survey of our Tier-1 Suppliers using the Conflict Minerals Reporting Template (“CMRT”). . We have elected to use the CMRT to elicit supply chain information from our suppliers because (1) it provides information critical to our due diligence efforts, and (2) it is a commonly used tool across many industries, thus easing the burden on our suppliers.
To maximize the effectiveness of our due diligence measures, we concentrate our due diligence efforts primarily on those Tier-1 Suppliers representing a substantial majority of our total annual expenditure on relevant components and materials (referred to in this Report as our “Priority Suppliers”).
In reviewing the diligence data we receive (whether from a completed CMRT, responses to our inquiries or otherwise), we apply evaluation processes to assess the reasonableness of the data and to check for the presence of “red flags.” We consider red flags to be obvious indications or circumstances that indicate the supplier disclosure may be inaccurate or improper and thus, may not be reliable. Factors we take into account in identifying and assessing supplier risk include:
| • | the failure of a supplier to respond to our inquiries; |
| • | statements by a supplier that no conflict minerals are used in its products; |
| • | inadequacies and inconsistencies in, or incompleteness of, a supplier’s responses; |
| • | suppliers that indicate conflict minerals in their products may be sourced from Covered Countries; and |
| • | a supplier’s lack of sophistication, including unfamiliarity with the Rule. |
In addition, we use the CMRT to identify conflict minerals processing facilities when reported in our supply chain by our Priority Suppliers. We obtain and validate information (where available) on the country of origin and mine location of conflict minerals processed at the identified facilities by relying on the information received through the RMI’s third party audit program: the Responsible Minerals Assurance Process (“RMAP”), which offers third party audits of smelters and refiners to certify that that the minerals they process originate from conflict-free sources.
Designing and Implementing a Strategy to Respond to Risk
We have developed processes to assess and respond to the risks identified in our supply chain, such as sending corrective action letters to suppliers where appropriate. Our cross-functional compliance team manages the due diligence of our supply chain, and monitors, tracks and evaluates supplier responses to our due diligence efforts. Members of our cross-functional compliance team meet periodically to review the status and results of our due diligence measures and to discuss any actual or potential risks and red flags identified during diligence. Members of our cross-functional compliance team also monitor and track the measures we take to mitigate risks, and reports on risk management to our steering committee. In addition, we support the development of due diligence practices through participation in RMI working groups.
Independent Third-Party Audits of Smelters and Refiners
We do not have direct relationships with any smelters or refiners and accordingly do not directly audit any smelters or refiners in our supply chain. Instead, we rely on the third-party audits of smelters and refiners conducted as part of the RMAP. The RMAP uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program. The smelters and refiners that are found by the RMAP to be “compliant” are those for which the independent auditor has verified that the smelter and/or refiner does not process conflict minerals that have originated from mines in the Covered Countries that directly or indirectly financed or benefited armed groups. We also rely on the publicly available results of the RMAP third-party audits to validate the
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responsible sourcing practices of processing facilities in our supply chain. We support independent third-party audits of processing facilities through our RMI membership.
Public Reporting on our Supply Chain Due Diligence
We publish our Form SDs and Conflict Mineral Reports (including this Report) in the Financial Information section of our website at investors.viasat.com under the heading “SEC Filings,” and our Statement on Conflict Minerals is publicly available on our website at www.viasat.com/legal/legal-statements. Information found on or accessed through Viasat’s website is not considered part of this Report and is not incorporated by reference herein. We also publicly file our Form SDs (which include our Conflict Mineral Reports) with the Securities and Exchange Commission.
| C. | Due Diligence Measures Performed |
Set forth below is a description of the measures we performed to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products for calendar year 2017.
To determine whether necessary conflict minerals in our products in calendar year 2017 originated in Covered Countries, we assembled a comprehensive list of suppliers that provide goods and services directly to us. From this list, we identified over 800 Tier-1 Suppliers. We contacted each of these Tier-1 Suppliers individually, provided them with a link to our Statement on Conflict Minerals and a copy of the CMRT, and requested the return of the completed CMRT to us. Follow-up requests were sent to all Tier-1 Suppliers who did not respond. To maximize the effectiveness of our due diligence measures, we concentrate our due diligence efforts primarily on Priority Suppliers. We used our manufacturing data system to identify Priority Suppliers, and took additional measures to maximize the response rate from Priority Suppliers. We received responses from a majority of our Tier-1 Suppliers and nearly all of our Priority Suppliers.
We electronically aggregated and reviewed the data from all of the responses we received from our Tier-1 Suppliers by utilizing a third party provider called Source44 LLC d/b/a Source Intelligence (“Source Intelligence”), which is a certified B corporation specializing in conflict mineral reporting. The reports received from Source Intelligence identify quality issues (e.g. incomplete CMRTs, inconsistent responses, indication of DRC sourcing, no smelters or invalid smelters listed, not all smelters identified, etc.) and aggregate CMRT responses for analysis and reporting. Where red flags were identified, we attempted to further analyze the information provided on the CMRT in order to assess any actual or potential risks to our supply chain and develop a recommended course of action. We then communicated red flags identified in the CMRT responses through corrective action letter requests with our Priority Suppliers as appropriate.
We determined if the processing facilities reported to us by our Priority Suppliers adhere to responsible sourcing practices by verifying whether they are included on the list of RMAP-compliant processing facilities.
Members of our cross-functional compliance team met periodically to review the results from our due diligence efforts for calendar year 2017, and presented its findings to our steering committee.
| D. | Product Description |
Products Containing Necessary Conflict Minerals
We have determined that substantially all of the products we manufacture or contract to manufacture contain conflict minerals necessary to the functionality or production of such products.
Facilities Used to Process, and Country of Origin of, the Necessary Conflict Minerals in our Products
Based on the information provided by our Tier-1 Suppliers and information made available by RMI and RMAP, we believe that the facilities that have been used to process conflict minerals in our products in calendar year 2017 may include the smelters and refiners listed in Annex I. As discussed above, we are a downstream supplier, many steps removed from the mining of conflict minerals, and accordingly rely on the information
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provided to us by our Tier-1 Suppliers (who are themselves generally multiple tiers downstream) to determine the country of origin of, or the facilities used to process, the conflict minerals contained in our products.
Of the 321 smelters and refiners identified as potentially being in our supply chain:
| • | 255 smelters and refiners were identified as “RMAP-compliant,” meaning that the processing facility has been audited and certified as compliant with RMAP audit protocols (including processing facilities currently undergoing re-audit); and |
| • | 66 smelters and refiners were non-participating, meaning that they met the definition of a smelter or refiner under the RMAP audit protocols but did not participate in the RMAP. These 66 non-participating suppliers source material from countries as follows: |
| • | 35 of the smelters and refiners source material from level 1 countries (i.e., countries that are known to be active ore producing countries that are not identified as conflict regions or plausible areas of smuggling or export of conflict minerals); |
| • | 3 smelters and refiners source material from level 2 countries (i.e., countries that are known or plausible countries for export out of region, smuggling or transit of conflict minerals); |
| • | 2 smelters and refiners source material from level 3 countries (i.e., countries that are within conflict regions that are potentially supplying ore materials); and |
| • | 26 smelters and refiners source material from unknown locations. |
Not all of these facilities may have processed conflict minerals in our products. Much of the smelter and refiner information provided by our Tier-1 Suppliers was provided at a “company” level (meaning that they reported all of the smelters and refiners that may have processed the conflict minerals contained in all of their products, not just those pertaining to the products sold to us). They may also have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their own suppliers or for other reasons. Therefore, the list of processing facilities disclosed in Annex I may over-represent the number of processing facilities that process the conflict minerals contained in our products.
Efforts to Determine Mine or Location of Origin
We have determined that our due diligence efforts, including requesting our Tier-1 Suppliers to complete the CMRT and reviewing the RMAP status of identified smelters and refiners, represent our reasonable best efforts to determine the mines or locations of origin of the conflict minerals in our supply chain.
| E. | Future Steps to Mitigate Risk |
Our conflict minerals program is aimed at the continuous improvement of our understanding of our supply chain and risk reduction over time. We intend to continue to take steps to improve our due diligence processes and to minimize the risk that our necessary conflict minerals benefit armed groups. Due diligence is an ongoing, proactive and reactive process, and we are continuing to work with our suppliers to identify and prevent or mitigate risks of adverse impacts associated with conflict minerals.
The primary risks we identified in calendar year 2017 continue to be related to inconsistencies or inadequacies in, or the incompleteness of, suppliers’ responses to the CMRT, the inability of our suppliers to confirm whether or not minerals used in their parts and components were sourced from Covered Countries, and the associated difficulties in identifying the smelters and refiners in our supply chain. With respect to necessary conflict minerals contained in our products with respect to calendar year 2018, we expect to continue to engage with our suppliers to clearly communicate our expectations with regard to conflict minerals sourcing and to educate them on the importance of conflict mineral supply chain diligence. In particular, we continue to encourage our suppliers to work with their own immediate suppliers to improve the transparency, accuracy, validity¸ reliability and completeness of conflict mineral sourcing information (particularly with regard to information provided regarding smelters and refiners used to process conflict minerals and mine or location of origin and country of origin information), and to minimize the risk that our necessary conflict minerals benefit armed groups in the Covered Countries. As our Tier-1 Suppliers continue to report smelters and refiners that we believe are not operational or that may have been misidentified as smelters or refiners, we continue to work with our suppliers to re-validate, improve and refine reported information. We strive to use only Priority Suppliers that source from RMAP-compliant processing facilities in our supply chain to the extent reasonably practicable. In addition, we are
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exploring a new software tracking solution that may help us in the future to analyze conflict minerals information received from our suppliers more efficiently.
Certain of the matters discussed in this Report, including in particular, future steps to mitigate risks that the conflict minerals contained in our products could benefit armed groups in the Covered Countries, include forward-looking statements. Readers of this document are cautioned that our forward-looking statements are not guarantees of our future actions, which may differ materially from the expectations expressed in the forward-looking statements. We disclaim any obligation to update publicly any forward-looking statements, whether in response to new information, future events or otherwise, except as required by applicable law.
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Annex I
List of Smelters and Refiners Reported in Viasat’s Supply Chain in 2017
| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Gold | Japan Mint | Japan | ||
| Gold | Heraeus Metals Hong Kong Ltd. | China | ||
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | ||
| Gold | Samduck Precious Metals | Republic of Korea | ||
| Gold | Navoi Mining and Metallurgical Combinat (*) | Uzbekistan | ||
| Gold | Kennecott Utah Copper LLC | U.S.A. | ||
| Gold | KGHM Polska Miedz Spolka Akcyjna (*) | Poland | ||
| Gold | Metalor USA Refining Corporation | U.S.A. | ||
| Gold | Chimet S.p.A. | Italy | ||
| Gold | Sabin Metal Corp. (*) | U.S.A. | ||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. (*) | China | ||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO (*) | Russian Federation | ||
| Gold | Abington Reldan Metals, LLC (*) | U.S.A. | ||
| Gold | So Accurate Group, Inc. (*) | U.S.A. | ||
| Gold | Royal Canadian Mint | Canada | ||
| Gold | Fidelity Printers and Refiners Ltd. (*) | Zimbabwe | ||
| Gold | PX Precinox S.A. | Switzerland | ||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||
| Gold | Eco-System Recycling Co., Ltd. | Japan | ||
| Gold | Asahi Refining Canada Ltd. | Canada | ||
| Gold | WIELAND Edelmetalle GmbH | Germany | ||
| Gold | MMTC-PAMP India Pvt., Ltd. | India | ||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
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| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Gold | DS PRETECH Co., Ltd. (*) | Republic of Korea | ||
| Gold | Modeltech Sdn Bhd (*) | Malaysia | ||
| Gold | Refinery of Seemine Gold Co., Ltd. (*) | China | ||
| Gold | Valcambi S.A. | Switzerland | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | ||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM (*) | China | ||
| Gold | Safimet S.p.A | Italy | ||
| Gold | Republic Metals Corporation | U.S.A. | ||
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | ||
| Gold | Umicore Brasil Ltda. | Brazil | ||
| Gold | Materion | U.S.A. | ||
| Gold | HwaSeong CJ CO., LTD. (*) | Republic of Korea | ||
| Gold | Asahi Refining USA Inc. | U.S.A. | ||
| Gold | NH Recytech Company (*) | Republic of Korea | ||
| Gold | Yamakin Co., Ltd. | Japan | ||
| Gold | Kazzinc | Kazakhstan | ||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||
| Gold | Tokuriki Honten Co., Ltd. | Japan | ||
| Gold | Elemetal Refining, LLC (*) | U.S.A. | ||
| Gold | Korea Zinc Co., Ltd. | Republic of Korea | ||
| Gold | Aurubis AG | Germany | ||
| Gold | Istanbul Gold Refinery | Turkey | ||
| Gold | Tony Goetz NV (*) | Belgium | ||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | ||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
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| Metal |
Name of Smelter or Refiner |
Country of Smelter or Refiner | ||
| Gold | Remondis Argentia B.V. (*) | Netherlands | ||
| Gold | Hunan Chenzhou Mining Co., Ltd. (*) | China | ||
| Gold | Kaloti Precious Metals (*) | United Arab Emirates | ||
| Gold | Argor-Heraeus S.A. | Switzerland | ||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | ||
| Gold | Morris and Watson (*) | New Zealand | ||
| Gold | SAFINA A.S. (*) | Czech Republic | ||
| Gold | SAXONIA Edelmetalle GmbH | Germany | ||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | ||
| Gold | Penglai Penggang Gold Industry Co., Ltd. (*) | China | ||
| Gold | Sudan Gold Refinery (*) | Sudan | ||
| Gold | Boliden AB | Sweden | ||
| Gold | Geib Refining Corporation | U.S.A. | ||
| Gold | Asaka Riken Co., Ltd. | Japan | ||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | Russian Federation | ||
| Gold | Dowa | Japan | ||
| Gold | Lingbao Gold Co., Ltd. (*) | China | ||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. (*) | India | ||
| Gold | T.C.A S.p.A | Italy | ||
| Gold | Morris and Watson Gold Coast (*) | Australia | ||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | ||
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | ||
| Gold | Metalor Technologies S.A. | Switzerland | ||
| Gold | SungEel HiMetal Co., Ltd. | Republic of Korea | ||
| Gold | Degussa Sonne / Mond Goldhandel GmbH (*) | Germany |
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| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | ||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Gold | OJSC Novosibirsk Refinery | Russian Federation | ||
| Gold | Daejin Indus Co., Ltd. | Republic of Korea | ||
| Gold | DSC (Do Sung Corporation) | Republic of Korea | ||
| Gold | Cendres + Metaux S.A. | Switzerland | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. (*) | Turkey | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | ||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. (*) | China | ||
| Gold | Italpreziosi | Italy | ||
| Gold | Marsam Metals | Brazil | ||
| Gold | JSC Uralelectromed | Russian Federation | ||
| Gold | TOO Tau-Ken-Altyn (*) | Kazakhstan | ||
| Gold | SAAMP | France | ||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. (*) | China | ||
| Gold | Emirates Gold DMCC | United Arab Emirates | ||
| Gold | Advanced Chemical Company | U.S.A. | ||
| Gold | Bangalore Refinery (*) | India | ||
| Gold | L’azurde Company For Jewelry (*) | Saudi Arabia | ||
| Gold | Mitsubishi Materials Corporation | Japan | ||
| Gold | SAMWON METALS Corp. (*) | Republic of Korea | ||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | ||
| Gold | HeeSung Metal Ltd. | Republic of Korea | ||
| Gold | Torecom | Republic of Korea | ||
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
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| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | ||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | ||
| Gold | Schone Edelmetaal B.V. | Netherlands | ||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | ||
| Gold | Guangdong Jinding Gold Limited (*) | China | ||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | ||
| Gold | Matsuda Sangyo Co., Ltd. | Japan | ||
| Gold | AU Traders and Refiners | South Africa | ||
| Gold | LS-NIKKO Copper Inc. | Republic of Korea | ||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | ||
| Gold | Kazakhmys Smelting LLC (*) | Kazakhstan | ||
| Gold | Kojima Chemicals Co., Ltd. | Japan | ||
| Gold | Metalor Technologies (Suzhou) Ltd. | China | ||
| Gold | Solar Applied Materials Technology Corp. | Taiwan | ||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | ||
| Gold | Rand Refinery (Pty) Ltd. | South Africa | ||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | ||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. (*) | China | ||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | ||
| Gold | Universal Precious Metals Refining Zambia (*) | Zambia | ||
| Gold | Yokohama Metal Co., Ltd. | Japan | ||
| Gold | Al Etihad Gold LLC | United Arab Emirates | ||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | ||
| Gold | C. Hafner GmbH + Co. KG | Germany |
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| Metal |
Name of Smelter or Refiner |
Country of Smelter or Refiner | ||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | ||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | ||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. (*) | China | ||
| Gold | L’Orfebre S.A. (*) | Andorra | ||
| Gold | Umicore Precious Metals Thailand | Thailand | ||
| Gold | African Gold Refinery (*) | Uganda | ||
| Gold | Jiangxi Copper Co., Ltd. | China | ||
| Gold | Singway Technology Co., Ltd. | Taiwan | ||
| Gold | Nihon Material Co., Ltd. | Japan | ||
| Gold | Sai Refinery (*) | India | ||
| Gold | DODUCO Contacts and Refining GmbH | Germany | ||
| Gold | United Precious Metal Refining, Inc. | U.S.A. | ||
| Gold | Planta Recuperadora de Metales SpA | Chile | ||
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | ||
| Gold | State Research Institute Center for Physical Sciences and Technology (*) | Lithuania | ||
| Gold | Yunnan Copper Industry Co., Ltd. (*) | China | ||
| Gold | Asahi Pretec Corp. | Japan | ||
| Gold | PAMP S.A. | Switzerland | ||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | ||
| Gold | Heimerle + Meule GmbH | Germany | ||
| Gold | Aida Chemical Industries Co., Ltd. | Japan | ||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. (*) | China | ||
| Gold | Pease & Curren (*) | U.S.A. | ||
| Gold | Caridad (*) | Mexico |
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| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Gold | Chugai Mining (*) | Japan | ||
| Gold | Daye Non-Ferrous Metals Mining Ltd. (*) | China | ||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | ||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | ||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | ||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | ||
| Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | China | ||
| Tantalum | NPM Silmet AS | Estonia | ||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | ||
| Tantalum | Jiangxi Tuohong New Raw Material | China | ||
| Tantalum | H.C. Starck Inc. | U.S.A. | ||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China | ||
| Tantalum | LSM Brasil S.A. | Brazil | ||
| Tantalum | F&X Electro-Materials Ltd. | China | ||
| Tantalum | KEMET Blue Metals | Mexico | ||
| Tantalum | Telex Metals | U.S.A. | ||
| Tantalum | H.C. Starck Co., Ltd. | Thailand | ||
| Tantalum | Kemet Blue Powder | U.S.A. | ||
| Tantalum | Taki Chemical Co., Ltd. | Japan | ||
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | ||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | ||
| Tantalum | Exotech Inc. | U.S.A. | ||
| Tantalum | Power Resources Ltd. | Macedonia | ||
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
13
| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Tantalum | D Block Metals, LLC | U.S.A. | ||
| Tantalum | FIR Metals & Resource Ltd. | China | ||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | ||
| Tantalum | Mineracao Taboca S.A. | Brazil | ||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | ||
| Tantalum | XinXing Haorong Electronic Material Co., Ltd. | China | ||
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | ||
| Tantalum | Asaka Riken Co., Ltd. | Japan | ||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | ||
| Tantalum | H.C. Starck Ltd. | Japan | ||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | ||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | ||
| Tantalum | Global Advanced Metals Boyertown | U.S.A. | ||
| Tantalum | Duoluoshan (*) | China | ||
| Tantalum | Jiujiang Janny New Material Co., Ltd. | China | ||
| Tantalum | Global Advanced Metals Aizu | Japan | ||
| Tantalum | QuantumClean | U.S.A. | ||
| Tin | Yunnan Tin Company Limited | China | ||
| Tin | Operaciones Metalurgical S.A. | Bolivia | ||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | Brazil | ||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | ||
| Tin | PT Sukses Inti Makmur | Indonesia | ||
| Tin | PT Stanindo Inti Perkasa | Indonesia |
14
| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Tin | PT Karimun Mining | Indonesia | ||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | ||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | ||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company (*) | Vietnam | ||
| Tin | Fenix Metals | Poland | ||
| Tin | Mineracao Taboca S.A. | Brazil | ||
| Tin | PT Kijang Jaya Mandiri | Indonesia | ||
| Tin | CV Dua Sekawan | Indonesia | ||
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | ||
| Tin | Alpha | U.S.A. | ||
| Tin | PT Lautan Harmonis Sejahtera | Indonesia | ||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | ||
| Tin | PT Babel Inti Perkasa | Indonesia | ||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | ||
| Tin | Jiangxi New Nanshan Technology Ltd. | China | ||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company (*) | Vietnam | ||
| Tin | PT Artha Cipta Langgeng | Indonesia | ||
| Tin | PT Menara Cipta Mulia | Indonesia | ||
| Tin | PT DS Jaya Abadi | Indonesia | ||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. (*) | China | ||
| Tin | Soft Metais Ltda. | Brazil | ||
| Tin | PT Aries Kencana Sejahtera | Indonesia | ||
| Tin | Thaisarco | Thailand | ||
| Tin | Metallo Spain S.L.U. | Spain | ||
| Tin | PT Inti Stania Prima | Indonesia |
15
| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company (*) | Vietnam | ||
| Tin | PT Babel Surya Alam Lestari (*) | Indonesia | ||
| Tin | Huichang Jinshunda Tin Co., Ltd. | China | ||
| Tin | PT Bukit Timah | Indonesia | ||
| Tin | Super Ligas (*) | Brazil | ||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | ||
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia | ||
| Tin | Modeltech Sdn Bhd (*) | Malaysia | ||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | ||
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia | ||
| Tin | CV United Smelting | Indonesia | ||
| Tin | CV Tiga Sekawan | Indonesia | ||
| Tin | PT Mitra Stania Prima | Indonesia | ||
| Tin | An Vinh Joint Stock Mineral Processing Company (*) | Vietnam | ||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China | ||
| Tin | Pongpipat Company Limited (*) | Myanmar | ||
| Tin | PT Tinindo Inter Nusa | Indonesia | ||
| Tin | China Tin Group Co., Ltd. | China | ||
| Tin | PT Belitung Industri Sejahtera | Indonesia | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||
| Tin | PT Prima Timah Utama | Indonesia | ||
| Tin | CV Ayi Jaya | Indonesia | ||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | ||
| Tin | Estanho de Rondonia S.A. (*) | Brazil | ||
| Tin | Dowa | Japan |
16
| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Tin | PT Bangka Serumpun | Indonesia | ||
| Tin | Metallo Belgium N.V. | Belgium | ||
| Tin | Mitsubishi Materials Corporation | Japan | ||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China | ||
| Tin | Minsur | Peru | ||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. (*) | China | ||
| Tin | EM Vinto | Bolivia | ||
| Tin | Resind Industria e Comercio Ltda. | Brazil | ||
| Tin | Rui Da Hung | Taiwan | ||
| Tin | PT Tommy Utama | Indonesia | ||
| Tin | Melt Metais e Ligas S.A. | Brazil | ||
| Tin | CV Gita Pesona | Indonesia | ||
| Tin | PT Eunindo Usaha Mandiri | Indonesia | ||
| Tin | PT Sumber Jaya Indah | Indonesia | ||
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | ||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | ||
| Tin | PT Sariwiguna Binasentosa | Indonesia | ||
| Tin | CV Venus Inti Perkasa | Indonesia | ||
| Tin | PT Bangka Prima Tin | Indonesia | ||
| Tin | PT Panca Mega Persada | Indonesia | ||
| Tin | PT Bangka Tin Industry | Indonesia | ||
| Tin | Gejiu Jinye Mineral Company | China | ||
| Tin | Metallic Resources, Inc. | U.S.A. | ||
| Tin | PT Refined Bangka Tin | Indonesia | ||
| Tin | PT Premium Tin Indonesia | Indonesia |
17
| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | ||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | China | ||
| Tungsten | Woltech Korea Co., Ltd. | Republic of Korea | ||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | ||
| Tungsten | Japan New Metals Co., Ltd. | Japan | ||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam | ||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam | ||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | ||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China | ||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam | ||
| Tungsten | Global Tungsten & Powders Corp. | U.S.A. | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||
| Tungsten | Moliren Ltd. | Russian Federation | ||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | ||
| Tungsten | ACL Metais Eireli | Brazil | ||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | ||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | ||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | ||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam | ||
| Tungsten | Unecha Refractory Metals Plant | Russian Federation | ||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | ||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. (*) | China | ||
| Tungsten | Hydrometallurg, JSC | Russian Federation |
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| Metal |
Name of Smelter or Refiner |
Country of Smelter | ||
| Tungsten | Niagara Refining LLC | U.S.A. | ||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. (*) | China | ||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||
| Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. (*) | China | ||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | ||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. (*) | China | ||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | ||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | ||
| Tungsten | Kennametal Huntsville | U.S.A. | ||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China | ||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | ||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | ||
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | ||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | ||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | ||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | ||
| Tungsten | H.C. Starck Tungsten GmbH | Germany | ||
| Tungsten | Xiamen Tungsten Co., Ltd. | China | ||
| Tungsten | Kennametal Fallon | U.S.A. | ||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. (*) | China | ||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| * | Smelters or refiners that have not been identified as “RMAP-compliant.” |
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