UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
NOVONIX LIMITED |
(Exact name of the registrant as specified in its charter) |
Australia |
(State or other jurisdiction of incorporation)
|
001-41208 |
(Commission file number) |
NOVONIX LIMITED, Level 8, 46 Edward Street, Brisbane QLD 4000, Australia |
(Address of principle executive offices) |
Suzanne Yeates, +61 439 310 818 |
(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:
___X___ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
_________Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended December 31, 2023.
1
Section 1 – Conflict Minerals Disclosure
NOVONIX Limited has determined that, during 2023, NOVONIX Limited or its consolidated subsidiaries manufactured and contracted to manufacture products as to which conflict minerals, as defined in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, are necessary to the functionality or production of its products. NOVONIX Limited has conducted a good faith reasonable country of origin inquiry regarding those conflict minerals reasonably designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo or an adjoining country or were from recycled or scrap sources. Based on the RCOI, NOVONIX Limited has reason to believe that some portion of the conflict minerals necessary to the functionality or production of its products may have originated in the Democratic Republic of the Congo or an adjoining country and has reason to believe that some of this material was not derived from recycled or scrap sources.
Item 1.01 Conflict Minerals Disclosure and Report
A copy of the Conflict Minerals Report of NOVONIX Limited is filed as Exhibit 1.01 hereto and is also publicly available at https://www.novonixgroup.com/wp-content/uploads/2024/05/2023-Conflict-Minerals-Report.pdf. The information contained on this website is not being incorporated by reference into this Form SD.
Item 1.02 Exhibit
A copy of the Conflict Minerals Report of NOVONIX Limited is filed as Exhibit 1.01 hereto.
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable.
Item 3.01 Exhibits
Exhibit Number |
Description |
1.01 |
Conflict Minerals Report for the reporting period ending December 31, 2023 |
2
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 undersigned hereunto duly authorized.
NOVONIX LIMITED
By: /s/ Dr. John Christopher Burns Dr John Christopher Burns Chief Executive Officer |
|
|
|
Date: May 31, 2024
3
Exhibit 1.01
NOVONIX LIMITED
CONFLICT MINERALS REPORT
(For the reporting period ending December 31, 2023)
Introduction
This Conflict Minerals Report (the “Report”) of NOVONIX Limited (“Novonix” or the “Company”) has been prepared pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2023 to December 31, 2023.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products (“Covered Products”) for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”), that originated in the Democratic Republic of the Congo (“DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).
Novonix has determined that, during calendar year 2023, Novonix or its consolidated subsidiaries manufactured and contracted to manufacture products as to which conflict minerals, as defined in the Rule, are necessary to the functionality or production of those products. Novonix has conducted a good faith reasonable country of origin inquiry (the “RCOI”) regarding those Conflict Minerals in its supply chain between January 1 and December 31 2023, reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries or were from recycled or scrap sources. Based on the RCOI, Novonix has reason to believe that some portion of the Conflict Minerals necessary to the functionality or production of its products may have originated in the Covered Countries and has reason to believe that some portion of such minerals was not derived from recycled or scrap sources.
Company and Product Overview
Novonix is an Australian-headquartered company with operations in both the United States and Canada. The Company is a leading battery technology company that manufactures industry-leading battery cell testing equipment in Canada and is growing its high-performance synthetic graphite anode material manufacturing operations in the United States.
Novonix has reviewed the activities of its consolidated subsidiaries and has concluded that this Conflict Minerals Report should address the activities of its Battery Technology Solutions segment, which manufactures Ultra-High Precision Coulometry battery testing systems. Based on its review, the Company has determined that it manufactured or contracted to manufacture Covered Products.
As a “downstream” purchaser of component parts, the Company is at the end of a very long supply chain. It manufactures or contracts to manufacture Covered Products, but does not directly source Conflict Minerals from mines, smelters or refiners, nor does it conduct purchasing activities directly in the Covered Countries. As such, the Company relies on its direct suppliers to provide information on the origin of any Conflict Minerals contained in any components and materials supplied to its operating subsidiaries, including sources of Conflict Minerals that are supplied to them from lower tier suppliers.
1
Reasonable Country of Origin Inquiry
Novonix conducted a RCOI for its operations as of December 31, 2023. The Company supports the Responsible Minerals Initiative (“RMI”) and uses the RMI’s Conflict Minerals Reporting Template (“CMRT”) as part of its RCOI process.
As part of the foregoing, the Company’s products and suppliers were assessed in order to identify Conflict Minerals scope and risk. The Company identified 44 components containing Conflict Minerals in its products. After reviewing its records and sourcing information for those components, the Company identified all its direct suppliers of the components containing Conflict Minerals.
The Company identified 4 direct suppliers (“In-Scope Suppliers”) for inclusion in the 2023 RCOI. The Company contacted the In-Scope Suppliers and requested CMRTs against established criteria to determine if further follow-up was required. The Company sent additional requests to those In-Scope Suppliers who did not complete the CMRT after the initial request, or whose CMRT was determined to be incomplete. As necessary, the Company provided guidance to those In-Scope Suppliers who were unfamiliar with the CMRT. After completing its procedural escalation steps, the Company received completed responses from 1 of the In-Scope Suppliers surveyed. For the 3 non-responsive In-Scope Suppliers, the Company contacted the 5 sub-suppliers (i.e., parts manufacturers) of the components that the 3 non-responsive In-Scope Suppliers supply to the Company. Novonix received CMRTs directly from 2 of the 5 sub-suppliers/parts manufacturers identified and indirectly (through 1 of its In-Scope Suppliers) from 2 of the 5 sub-suppliers. The Company did not receive a CMRT from 1 of the 5 sub-suppliers. Due to the complexity of its supply chain, Novonix relies on its suppliers for the accuracy and completeness of this information.
From the 5 responses received, the In-Scope Suppliers identified approximately 336 smelters or refiners. Of the 336 smelters or refiners, approximately 154 were identified as conformant smelters/refiners (as determined by the RMI and defined below).
Due Diligence
As required under the Rule, for the reporting period from January 1 to December 31, 2023, Novonix has taken or is taking the measures described in this herein to exercise due diligence on the source and chain of custody of Covered Minerals necessary to the functionality or production of the Covered Products. Novonix’s due diligence measures have been designed to align with the framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”), as it relates to Novonix’s position as a “downstream” purchaser.
2
Description of Due Diligence Measures
Step |
Actions Taken |
Establish strong company management systems.
|
As a company that is in the early stage of its business life cycle, we are still in the process of developing and implementing our supply chain strategy, organization and policies, both to facilitate the growth and maturity of our commercial business operations as well as to align with the priorities we have identified as part of our Environmental, Social and Governance (“ESG”) program, which we began developing in 2022. Our ESG program includes among its priorities social impacts in the supply chain, and our ESG Committee is comprised of internal subject matter experts from across the Company, including supply chain management.
We are developing, further refining, and prioritizing the policies, processes, and systems, including data collection and risk identification and mitigation, with a view to establishing strong company management systems that facilitate appropriate oversight by senior management. While much of this effort aligns with the development of our ESG program, our supply chain initiatives depend on the growth of our business and manufacturing operations and our position in the industry, as well as the implementation of our supply chain strategy and the organization needed to execute it. As part of the continued development of our supply chain strategy and organization, we intend to adopt a supplier code of conduct that will guide our commitment to conduct business and source materials and components from responsible suppliers who meet the highest applicable legal and ethical standards. As part of this effort, we will evaluate the proper policy, supplier due diligence, internal controls, and contractual and other supplier standards that will form the basis for our management system.
|
Identify and assess risk in the supply chain. |
The Company assesses risk in two phases: first, it identifies direct suppliers that may contribute necessary Conflict Minerals to its products; and second, it seeks declarations from those direct suppliers using the CMRT, and assesses risk based on answers provided by In-Scope Suppliers in the CMRT.
Where applicable and appropriate, the Company uses industry validation schemes to identify smelters and refiners compliant with such schemes for use in its supply chain. The Company is working to develop standard supplier-vetting procedures. |
3
Step |
Actions Taken |
Design and implement a strategy to respond to identified risks. |
The Company: • reports information gathered and the actual and potential risks identified from its Conflict Minerals due diligence to senior management; • is working to develop a risk management plan consistent with the steps described above and, as appropriate, with OECD guidelines; and • is working to develop a risk management plan consistent with the steps described above; and • is working to communicate with its direct suppliers the Company’s supply chain due diligence expectations with respect to Conflict Minerals. |
Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain. |
Neither the Company, nor any of its consolidated subsidiaries, typically has a direct relationship with mines, smelters or refiners of Conflict Minerals and thus does not perform or direct audits of these entities.
The Company tracks the mines, smelters and refiners that have been identified by its consolidated subsidiaries’ direct suppliers as part of the CMRT and will take appropriate action as necessary. |
Report on supply chain due diligence. |
The Company has submitted and complied with its obligations under Form SD, including, but not limited to, the filing of this Conflict Minerals Report as required.
This Conflict Minerals Report is publicly available on the Company’s website at https://www.novonixgroup.com/wp-content/uploads/2024/05/2023-Conflict-Minerals-Report.pdf. |
Independent Private Sector Audit
No independent private sector audit of this Conflict Minerals Report was performed for the calendar year ended December 31, 2023.
Due Diligence Results
Based on the information provided by our suppliers and information otherwise obtained through the due diligence process, Novonix has reasonably determined that the facilities that may have been used to process Novonix’s Covered Minerals in 2023 include the smelters and refiners (“SORs”) listed in Annex I.
4
Based on information received through the RMI Responsible Minerals Assurance Process (“RMAP”) or equivalent independent third-party audit programs, Novonix has reason to believe the countries of origin for the Covered Minerals contained in the materials received by our Covered Minerals Suppliers may include certain Covered Countries.
As a downstream purchaser of products which contain Conflict Minerals, there are inherent limitations in the due diligence measures that we carry out and our inquiries can provide only a reasonable assurance regarding the source and chain of custody. Novonix does not have any direct relationships with the mines or smelters so rely on the information provided by its direct suppliers, who can be engaged in a complex process that changes over time. We are seeking data that covers the entire reporting year and ask our suppliers to update us if the sourcing data changes.
Risk Mitigation and Future Due Diligence Measures
In the future, the Company intends to monitor RMI and other industry and regulatory initiatives related to Conflict Minerals and, where appropriate, engage third-party experts to assist the Company with its conflict minerals due diligence procedures. The Company looks to improve its due diligence processes including through contractual mechanisms and by increasing our supplier response rate and improving the accuracy of responses. The Company also intends to communicate and monitor compliance with the Company’s Supplier Code of Conduct and a Conflict Minerals Policy for its suppliers upon their adoption.
The Company intends to continue carefully reviewing the activities of its consolidated subsidiaries to determine whether additional reporting may be required in the future.
Cautionary Note Concerning Forward-Looking Statements
Information provided in this Conflict Minerals Report, particularly under the heading “Risk Mitigation and Future Due Diligence Measures,” may contain statements relating to current expectations and plans that are “forward-looking statements” as defined in the Private Securities Litigation Reform Act of 1995. All statements other than statements of historical fact are forward-looking statements. You can identify such statements by words such as “future”, “intend”, “expect”, “go-forward” and “may” and the negative of these or similar terms and phrases. These forward-looking statements generally relate to the Company’s plans, objectives and expectations for future plans and events and are based upon its management’s current estimates. These statements are subject to risks and uncertainties and may not prove to be accurate. These risks and uncertainties include those 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, limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers and other factors discussed under the heading “Risk Factors” as described in the Company’s annual report on Form 20-F filed with the SEC on February 28, 2024 and other documents subsequently filed with or furnished to the SEC. These forward-looking statements are made only as of the date hereof, and, except as required by applicable law, the Company undertakes no obligation to update or revise the forward- looking statements, whether as a result of new information, future events or otherwise.
5
ANNEX I
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
BELGIUM |
Conformant |
Gold |
United Precious Metal Refining, Inc. |
UNITED STATES OF AMERICA |
Conformant |
Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN |
Conformant |
Gold |
Western Australian Mint (T/a The Perth Mint) |
AUSTRALIA |
Conformant |
Gold |
Argor-Heraeus S.A. |
SWITZERLAND |
Conformant |
Gold |
WIELAND Edelmetalle GmbH |
GERMANY |
Conformant |
Gold |
Asahi Pretec Corp. |
JAPAN |
Conformant |
Gold |
Asaka Riken Co., Ltd. |
JAPAN |
Conformant |
Gold |
Heraeus Metals Hong Kong Ltd. |
CHINA |
Conformant |
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CHINA |
Conformant |
Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN |
Conformant |
Gold |
Jiangxi Copper Co., Ltd. |
CHINA |
Conformant |
Gold |
JX Nippon Mining & Metals Co., Ltd. |
JAPAN |
Conformant |
Gold |
Kojima Chemicals Co., Ltd. |
JAPAN |
Conformant |
Gold |
LS MnM Inc. |
KOREA, REPUBLIC OF |
Conformant |
Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN |
Conformant |
Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA |
Conformant |
Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA |
Conformant |
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE |
Conformant |
6
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Metalor Technologies S.A. |
SWITZERLAND |
Conformant |
Gold |
Metalor USA Refining Corporation |
UNITED STATES OF AMERICA |
Conformant |
Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. |
MEXICO |
Conformant |
Gold |
Mitsubishi Materials Corporation |
JAPAN |
Conformant |
Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
Conformant |
Gold |
Nihon Material Co., Ltd. |
JAPAN |
Conformant |
Gold |
MKS PAMP SA |
SWITZERLAND |
Conformant |
Gold |
PX Precinox S.A. |
SWITZERLAND |
Conformant |
Gold |
Rand Refinery (Pty) Ltd. |
SOUTH AFRICA |
Conformant |
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CHINA |
Conformant |
Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
CHINA |
Conformant |
Gold |
Solar Applied Materials Technology Corp. |
TAIWAN, PROVINCE OF CHINA |
Conformant |
Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
Conformant |
Gold |
Tanaka Kikinzoku Kogyo K.K. |
JAPAN |
Conformant |
Gold |
Tokuriki Honten Co., Ltd. |
JAPAN |
Conformant |
Gold |
Valcambi S.A. |
SWITZERLAND |
Conformant |
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA |
Conformant |
Gold |
Torecom |
KOREA, REPUBLIC OF |
Conformant |
Gold |
Heimerle + Meule GmbH |
GERMANY |
Conformant |
Gold |
Japan Mint |
JAPAN |
Conformant |
7
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Asahi Refining Canada Ltd. |
CANADA |
Conformant |
Gold |
Royal Canadian Mint |
CANADA |
Conformant |
Gold |
Heraeus Germany GmbH Co. KG |
GERMANY |
Conformant |
Gold |
Kennecott Utah Copper LLC |
UNITED STATES OF AMERICA |
Conformant |
Gold |
Agosi AG |
GERMANY |
Conformant |
Gold |
Shandong Gold Smelting Co., Ltd. |
CHINA |
Conformant |
Gold |
Materion |
UNITED STATES OF AMERICA |
Conformant |
Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA |
Conformant |
Gold |
Asahi Refining USA Inc. |
UNITED STATES OF AMERICA |
Conformant |
Gold |
Dowa |
JAPAN |
Conformant |
Gold |
Aurubis AG |
GERMANY |
Conformant |
Gold |
Chimet S.p.A. |
ITALY |
Conformant |
Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
Conformant |
Gold |
SEMPSA Joyeria Plateria S.A. |
SPAIN |
Conformant |
Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
BRAZIL |
Conformant |
Gold |
Boliden Ronnskar |
SWEDEN |
Conformant |
Gold |
Eco-System Recycling Co., Ltd. East Plant |
JAPAN |
Conformant |
Gold |
Geib Refining Corporation |
UNITED STATES OF AMERICA |
Unknown |
Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
CHINA |
Conformant |
Gold |
Istanbul Gold Refinery |
TURKEY |
Conformant |
8
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
AUSTRIA |
Conformant |
Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN |
Conformant |
Gold |
Abington Reldan Metals, LLC |
UNITED STATES OF AMERICA |
Conformant |
Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN |
Conformant |
Gold |
KGHM Polska Miedz Spolka Akcyjna |
POLAND |
Conformant |
Gold |
Alexy Metals |
UNITED STATES OF AMERICA |
Unknown |
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES |
Conformant |
Gold |
Chugai Mining |
JAPAN |
Conformant |
Gold |
DSC (Do Sung Corporation) |
KOREA, REPUBLIC OF |
Conformant |
Gold |
Eco-System Recycling Co., Ltd. North Plant |
JAPAN |
Conformant |
Gold |
Eco-System Recycling Co., Ltd. West Plant |
JAPAN |
Conformant |
Gold |
Italpreziosi |
ITALY |
Conformant |
Gold |
L'Orfebre S.A. |
ANDORRA |
Conformant |
Gold |
MMTC-PAMP India Pvt., Ltd. |
INDIA |
Conformant |
Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. |
TURKEY |
Conformant |
Gold |
Planta Recuperadora de Metales SpA |
CHILE |
Conformant |
Gold |
REMONDIS PMR B.V. |
NETHERLANDS |
Conformant |
Gold |
SAFINA A.S. |
CZECHIA |
Conformant |
Gold |
T.C.A S.p.A |
ITALY |
Conformant |
Gold |
Yamakin Co., Ltd. |
JAPAN |
Conformant |
9
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Yokohama Metal Co., Ltd. |
JAPAN |
Conformant |
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
UZBEKISTAN |
Conformant |
Gold |
LT Metal Ltd. |
KOREA, REPUBLIC OF |
Conformant |
Gold |
Kazzinc |
KAZAKHSTAN |
Conformant |
Gold |
PT Aneka Tambang (Persero) Tbk |
INDONESIA |
Conformant |
Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
CHINA |
Unknown |
Gold |
Korea Zinc Co., Ltd. |
KOREA, REPUBLIC OF |
Conformant |
Gold |
SungEel HiMetal Co., Ltd. |
KOREA, REPUBLIC OF |
Conformant |
Gold |
TOO Tau-Ken-Altyn |
KAZAKHSTAN |
Conformant |
Gold |
NH Recytech Company |
KOREA, REPUBLIC OF |
Conformant |
Gold |
Metal Concentrators SA (Pty) Ltd. |
SOUTH AFRICA |
Conformant |
Gold |
Gold by Gold Colombia |
COLOMBIA |
Conformant |
Gold |
Advanced Chemical Company |
UNITED STATES OF AMERICA |
Conformant |
Gold |
8853 S.p.A. |
ITALY |
Unknown |
Gold |
ABC Refinery Pty Ltd. |
AUSTRALIA |
Unknown |
Gold |
African Gold Refinery |
UGANDA |
Unknown |
Gold |
Al Etihad Gold Refinery DMCC |
UNITED ARAB EMIRATES |
Unknown |
Gold |
Al Ghaith Gold |
UNITED ARAB EMIRATES |
Unknown |
Gold |
Albino Mountinho Lda. |
PORTUGAL |
Unknown |
Gold |
ARY Aurum Plus |
UNITED ARAB EMIRATES |
Unknown |
10
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
TURKEY |
Unknown |
Gold |
AU Traders and Refiners |
SOUTH AFRICA |
Unknown |
Gold |
Augmont Enterprises Private Limited |
INDIA |
Unknown |
Gold |
Bangalore Refinery |
INDIA |
Active |
Gold |
C.I Metales Procesados Industriales SAS |
COLOMBIA |
Unknown |
Gold |
Caridad |
MEXICO |
Unknown |
Gold |
Cendres + Metaux S.A. |
SWITZERLAND |
Unknown |
Gold |
CGR Metalloys Pvt Ltd. |
INDIA |
Unknown |
Gold |
Daye Non-Ferrous Metals Mining Ltd. |
CHINA |
Unknown |
Gold |
Degussa Sonne / Mond Goldhandel GmbH |
GERMANY |
Unknown |
Gold |
Dijllah Gold Refinery FZC |
UNITED ARAB EMIRATES |
Unknown |
Gold |
DODUCO Contacts and Refining GmbH |
GERMANY |
Unknown |
Gold |
Dongwu Gold Group |
CHINA |
Unknown |
Gold |
DS PRETECH Co., Ltd. |
KOREA, REPUBLIC OF |
Unknown |
Gold |
Emerald Jewel Industry India Limited (Unit 1) |
INDIA |
Unknown |
Gold |
Emerald Jewel Industry India Limited (Unit 2) |
INDIA |
Unknown |
Gold |
Emerald Jewel Industry India Limited (Unit 3) |
INDIA |
Unknown |
Gold |
Emerald Jewel Industry India Limited (Unit 4) |
INDIA |
Unknown |
Gold |
Emirates Gold DMCC |
UNITED ARAB EMIRATES |
Unknown |
Gold |
Fidelity Printers and Refiners Ltd. |
ZIMBABWE |
Unknown |
11
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Fujairah Gold FZC |
UNITED ARAB EMIRATES |
Unknown |
Gold |
GGC Gujrat Gold Centre Pvt. Ltd. |
INDIA |
Unknown |
Gold |
Gold Coast Refinery |
GHANA |
Unknown |
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
CHINA |
Unknown |
Gold |
Guangdong Hua Jian Trade Co., Ltd. |
CHINA |
Unknown |
Gold |
Guangdong Jinding Gold Limited |
CHINA |
Unknown |
Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
CHINA |
Unknown |
Gold |
Hang Seng Technology |
CHINA |
Unknown |
Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
CHINA |
Unknown |
Gold |
Henan Yuguang Gold & Lead Co., Ltd. |
CHINA |
Unknown |
Gold |
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
CHINA |
Unknown |
Gold |
Hung Cheong Metal Manufacturing Limited |
CHINA |
Unknown |
Gold |
HwaSeong CJ CO., LTD. |
KOREA, REPUBLIC OF |
Unknown |
Gold |
Industrial Refining Company |
BELGIUM |
Unknown |
Gold |
International Precious Metal Refiners |
UNITED ARAB EMIRATES |
Unknown |
Gold |
JALAN & Company |
INDIA |
Unknown |
Gold |
Jinlong Copper Co., Ltd. |
CHINA |
Unknown |
Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
RUSSIAN FEDERATION |
Unknown |
Gold |
JSC Uralelectromed |
RUSSIAN FEDERATION |
Unknown |
Gold |
K.A. Rasmussen |
NORWAY |
Unknown |
12
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Kaloti Precious Metals |
UNITED ARAB EMIRATES |
Unknown |
Gold |
Kazakhmys Smelting LLC |
KAZAKHSTAN |
Unknown |
Gold |
Kundan Care Products Ltd. |
INDIA |
Unknown |
Gold |
Kyrgyzaltyn JSC |
KYRGYZSTAN |
Unknown |
Gold |
Kyshtym Copper-Electrolytic Plant ZAO |
RUSSIAN FEDERATION |
Unknown |
Gold |
L'azurde Company For Jewelry |
SAUDI ARABIA |
Unknown |
Gold |
Lingbao Gold Co., Ltd. |
CHINA |
Unknown |
Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
CHINA |
Unknown |
Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
CHINA |
Unknown |
Gold |
Marsam Metals |
BRAZIL |
Unknown |
Gold |
MD Overseas |
INDIA |
Unknown |
Gold |
Metallix Refining Inc. |
UNITED STATES OF AMERICA |
Unknown |
Gold |
Morris and Watson |
NEW ZEALAND |
Unknown |
Gold |
Moscow Special Alloys Processing Plant |
RUSSIAN FEDERATION |
Unknown |
Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
RUSSIAN FEDERATION |
Unknown |
Gold |
JSC Novosibirsk Refinery |
RUSSIAN FEDERATION |
Unknown |
Gold |
Pease & Curren |
UNITED STATES OF AMERICA |
Unknown |
Gold |
Penglai Penggang Gold Industry Co., Ltd. |
CHINA |
Unknown |
Gold |
Prioksky Plant of Non-Ferrous Metals |
RUSSIAN FEDERATION |
Unknown |
Gold |
QG Refining, LLC |
UNITED STATES OF AMERICA |
Unknown |
13
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Refinery of Seemine Gold Co., Ltd. |
CHINA |
Unknown |
Gold |
SAAMP |
FRANCE |
Unknown |
Gold |
Sabin Metal Corp. |
UNITED STATES OF AMERICA |
Unknown |
Gold |
Safimet S.p.A |
ITALY |
Unknown |
Gold |
Sai Refinery |
INDIA |
Unknown |
Gold |
Samduck Precious Metals |
KOREA, REPUBLIC OF |
Unknown |
Gold |
Samwon Metals Corp. |
KOREA, REPUBLIC OF |
Unknown |
Gold |
Sancus ZFS (L’Orfebre, SA) |
COLOMBIA |
Unknown |
Gold |
SAXONIA Edelmetalle GmbH |
GERMANY |
Unknown |
Gold |
Sellem Industries Ltd. |
MAURITANIA |
Unknown |
Gold |
Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co., Ltd. |
CHINA |
Unknown |
Gold |
Shandong Hengbang Smelter Co., Ltd. |
CHINA |
Unknown |
Gold |
Shandong Humon Smelting Co., Ltd. |
CHINA |
Unknown |
Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
CHINA |
Unknown |
Gold |
Shandong Yanggu Xiangguang Co., Ltd. |
CHINA |
Unknown |
Gold |
Shenzhen CuiLu Gold Co., Ltd. |
CHINA |
Unknown |
Gold |
Shenzhen Heng Zhong Industry Co., Ltd. |
CHINA |
Unknown |
Gold |
Shenzhen Zhonghenglong Real Industry Co., Ltd. |
CHINA |
Unknown |
Gold |
Shirpur Gold Refinery Ltd. |
INDIA |
Unknown |
Gold |
Singway Technology Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
Unknown |
14
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Sino-Platinum Metals Co., Ltd. |
CHINA |
Unknown |
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
RUSSIAN FEDERATION |
Unknown |
Gold |
Sovereign Metals |
INDIA |
Unknown |
Gold |
State Research Institute Center for Physical Sciences and Technology |
LITHUANIA |
Unknown |
Gold |
Sudan Gold Refinery |
SUDAN |
Unknown |
Gold |
Super Dragon Technology Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
Unknown |
Gold |
Umicore Brasil Ltda. |
BRAZIL |
Unknown |
Gold |
Umicore Precious Metals Thailand |
THAILAND |
Unknown |
Gold |
Universal Precious Metals Refining Zambia |
ZAMBIA |
Unknown |
Gold |
Value Trading |
BELGIUM |
Unknown |
Gold |
Viagra Di precious metals (Zhaoyuan) Co., Ltd. |
CHINA |
Unknown |
Gold |
WEEEREFINING |
FRANCE |
Unknown |
Gold |
Wuzhong Group |
CHINA |
Unknown |
Gold |
Yunnan Copper Industry Co., Ltd. |
CHINA |
Unknown |
Gold |
Yunnan Gold Mining Group Co., Ltd. (YGMG) |
CHINA |
Unknown |
Gold |
Zhe Jiang Guang Yuan Noble Metal Smelting Factory |
CHINA |
Unknown |
Gold |
Zhongkuang Gold Industry Co., Ltd. |
CHINA |
Unknown |
Gold |
Zhongshan Hyper-Toxic Substance Monopolized Co., Ltd. |
CHINA |
Unknown |
Gold |
Zhongshan Poison Material Proprietary Co., Ltd. |
CHINA |
Unknown |
Gold |
Zhuhai toxic materials Monopoly Ltd. |
CHINA |
Unknown |
15
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Gold |
Zhuzhou Smelting Group Co., Ltd |
CHINA |
Unknown |
Tin |
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
CHINA |
Conformant |
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CHINA |
Conformant |
Tin |
PT Timah Tbk Mentok |
INDONESIA |
Conformant |
Tin |
PT Timah Tbk Kundur |
INDONESIA |
Conformant |
Tin |
Rui Da Hung |
TAIWAN, PROVINCE OF CHINA |
Conformant |
Tin |
PT Bangka Serumpun |
INDONESIA |
Conformant |
Tin |
PT Refined Bangka Tin |
INDONESIA |
Conformant |
Tin |
PT Artha Cipta Langgeng |
INDONESIA |
Conformant |
Tin |
Minsur |
PERU |
Conformant |
Tin |
PT Menara Cipta Mulia |
INDONESIA |
Conformant |
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA |
Conformant |
Tin |
Alpha |
UNITED STATES OF AMERICA |
Conformant |
Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
Conformant |
Tin |
Dowa |
JAPAN |
Conformant |
Tin |
Mitsubishi Materials Corporation |
JAPAN |
Conformant |
Tin |
EM Vinto |
BOLIVIA (PLURINATIONAL STATE OF) |
Conformant |
Tin |
Fenix Metals |
POLAND |
Conformant |
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA |
Conformant |
Tin |
Aurubis Beerse |
BELGIUM |
Conformant |
16
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Tin |
China Tin Group Co., Ltd. |
CHINA |
Conformant |
Tin |
Mineracao Taboca S.A. |
BRAZIL |
Conformant |
Tin |
Operaciones Metalurgicas S.A. |
BOLIVIA (PLURINATIONAL STATE OF) |
Conformant |
Tin |
Metallic Resources, Inc. |
UNITED STATES OF AMERICA |
Conformant |
Tin |
Thaisarco |
THAILAND |
Conformant |
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
Conformant |
Tin |
PT Babel Inti Perkasa |
INDONESIA |
Conformant |
Tin |
PT Babel Surya Alam Lestari |
INDONESIA |
Conformant |
Tin |
PT Bukit Timah |
INDONESIA |
Conformant |
Tin |
PT Mitra Stania Prima |
INDONESIA |
Conformant |
Tin |
PT Prima Timah Utama |
INDONESIA |
Conformant |
Tin |
PT Sariwiguna Binasentosa |
INDONESIA |
Conformant |
Tin |
PT Stanindo Inti Perkasa |
INDONESIA |
Conformant |
Tin |
White Solder Metalurgia e Mineracao Ltda. |
BRAZIL |
Conformant |
Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
Conformant |
Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
Conformant |
Tin |
PT Cipta Persada Mulia |
INDONESIA |
Conformant |
Tin |
Aurubis Berango |
SPAIN |
Conformant |
Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
CHINA |
Conformant |
Tin |
Tin Technology & Refining |
UNITED STATES OF AMERICA |
Conformant |
17
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Tin |
PT Rajawali Rimba Perkasa |
INDONESIA |
Conformant |
Tin |
Luna Smelter, Ltd. |
RWANDA |
Conformant |
Tin |
PT Mitra Sukses Globalindo |
INDONESIA |
Conformant |
Tin |
CRM Synergies |
SPAIN |
Conformant |
Tin |
Jiangxi New Nanshan Technology Ltd. |
CHINA |
Conformant |
Tin |
Fabrica Auricchio Industria e Comercio Ltda. |
BRAZIL |
Conformant |
Tin |
PT Tommy Utama |
INDONESIA |
Conformant |
Tin |
CV Venus Inti Perkasa |
INDONESIA |
Conformant |
Tin |
PT Putera Sarana Shakti (PT PSS) |
INDONESIA |
Conformant |
Tin |
PT Sukses Inti Makmur |
INDONESIA |
Conformant |
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
CHINA |
Conformant |
Tin |
PT Aries Kencana Sejahtera |
INDONESIA |
Conformant |
Tin |
PT Rajehan Ariq |
INDONESIA |
Conformant |
Tin |
Ma'anshan Weitai Tin Co., Ltd. |
INDONESIA |
Unknown |
Tin |
PT Tinindo Inter Nusa |
INDONESIA |
Conformant |
Tin |
PT Timah Nusantara |
INDONESIA |
Conformant |
Tin |
Estanho de Rondonia S.A. |
BRAZIL |
Conformant |
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
BRAZIL |
Conformant |
Tin |
Resind Industria e Comercio Ltda. |
BRAZIL |
Conformant |
Tin |
CV Ayi Jaya |
INDONESIA |
Conformant |
18
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Tin |
Super Ligas |
BRAZIL |
Conformant |
Tin |
PT Panca Mega Persada |
INDONESIA |
Unknown |
Tin |
PT Belitung Industri Sejahtera |
INDONESIA |
Conformant |
Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
BRAZIL |
Conformant |
Tin |
PT Premium Tin Indonesia |
INDONESIA |
Conformant |
Tin |
PT Bangka Prima Tin |
INDONESIA |
Conformant |
Tin |
DS Myanmar |
MYANMAR |
Conformant |
Tin |
Mining Minerals Resources SARL |
CONGO, DEMOCRATIC REPUBLIC OF THE |
Conformant |
Tin |
An Vinh Joint Stock Mineral Processing Company |
VIET NAM |
Unknown |
Tin |
Chofu Works |
JAPAN |
Unknown |
Tin |
Dongguan CiEXPO Environmental Engineering Co., Ltd. |
CHINA |
Unknown |
Tin |
Dongguan City Xida Soldering Tin Products Co. |
CHINA |
Unknown |
Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
VIET NAM |
Unknown |
Tin |
Gejiu City Fuxiang Industry and Trade Co., Ltd. |
CHINA |
Unknown |
Tin |
Gejiu Fengming Metallurgy Chemical Plant |
CHINA |
Unknown |
Tin |
Gejiu Kai Meng Industry and Trade LLC |
CHINA |
Unknown |
Tin |
Gejiu Yunxi Group Corp. |
CHINA |
Unknown |
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CHINA |
Unknown |
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CHINA |
Unknown |
Tin |
GUANGXI HUA TIN GOLD MINUTE FEE, LTD. |
CHINA |
Unknown |
19
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Tin |
Guangxi Nonferrous Metals Group |
CHINA |
Unknown |
Tin |
Guangxi Zhongshan Jin Yi Smelting Co., Ltd. |
CHINA |
Unknown |
Tin |
Hezhou Jinwei Tin Co., Ltd. |
CHINA |
Unknown |
Tin |
Hongqiao Metals (Kunshan) Co., Ltd. |
CHINA |
Unknown |
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
CHINA |
Unknown |
Tin |
Jiang Xi Jia Wang Technology Tin Products Environmental Ltd. |
CHINA |
Unknown |
Tin |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA |
Unknown |
Tin |
LIAN JING |
CHINA |
Unknown |
Tin |
Ma An Shan Shu Guang Smelter Corp. |
CHINA |
Unknown |
Tin |
Ma'anshan Weitai Tin Co., Ltd. |
CHINA |
Unknown |
Tin |
Materials Eco-Refining Co., Ltd. |
JAPAN |
Unknown |
Tin |
Melt Metais e Ligas S.A. |
BRAZIL |
Unknown |
Tin |
Metahub Industries Sdn. Bhd. |
MALAYSIA |
Unknown |
Tin |
Minchali Metal Industry Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
Unknown |
Tin |
Ming Li Jia smelt Metal Factory |
CHINA |
Unknown |
Tin |
Modeltech Sdn Bhd |
MALAYSIA |
Unknown |
Tin |
Ney Metals and Alloys |
UNITED STATES OF AMERICA |
Unknown |
Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
VIET NAM |
Unknown |
Tin |
Novosibirsk Tin Combine |
RUSSIAN FEDERATION |
Unknown |
Tin |
OMODEO A. E S. METALLEGHE SRL |
ITALY |
Unknown |
20
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Tin |
Pongpipat Company Limited |
MYANMAR |
Unknown |
Tin |
Precious Minerals and Smelting Limited |
INDIA |
Unknown |
Tin |
PT Bangka Tin Industry |
INDONESIA |
Unknown |
Tin |
PT Lautan Harmonis Sejahtera |
INDONESIA |
Unknown |
Tin |
PT Masbro Alam Stania |
INDONESIA |
Unknown |
Tin |
PT Rajehan Ariq |
INDONESIA |
Unknown |
Tin |
PT Tirus Putra Mandiri |
INDONESIA |
Unknown |
Tin |
Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co., Ltd. |
CHINA |
Unknown |
Tin |
Shenzhen Hong Chang Metal Manufacturing Factory |
CHINA |
Unknown |
Tin |
Sichuan Guanghan Jiangnan casting smelters |
CHINA |
Unknown |
Tin |
Sigma Tin Alloy Co., Ltd. |
CHINA |
Unknown |
Tin |
Soft Metais Ltda. |
BRAZIL |
Unknown |
Tin |
Solder Court Ltd. |
CHINA |
Unknown |
Tin |
Suzhou Nuonengda Chemical Co., Ltd. |
CHINA |
Unknown |
Tin |
Taicang City Nancang Metal Material Co., Ltd. |
CHINA |
Unknown |
Tin |
Taiwan Huanliang |
TAIWAN, PROVINCE OF CHINA |
Unknown |
Tin |
Thai Nguyen Mining and Metallurgy Co., Ltd. |
VIET NAM |
Unknown |
Tin |
Thailand Mine Factory |
THAILAND |
Unknown |
Tin |
Three green surface technology limited company |
CHINA |
Unknown |
Tin |
TIN PLATING GEJIU |
CHINA |
Unknown |
21
Covered Minerals |
Smelter or Refiner Name |
Country location of Smelter or Refiner |
RMI Active and Conformant |
Tin |
TONG LONG |
CHINA |
Unknown |
Tin |
Top-Team Technology (Shenzhen) Ltd. |
CHINA |
Unknown |
Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
VIET NAM |
Unknown |
Tin |
VQB Mineral and Trading Group JSC |
VIET NAM |
Unknown |
Tin |
WUJIANG CITY LUXE TIN FACTORY |
CHINA |
Unknown |
Tin |
Xiamen Honglu Tungsten Molybdenum Co., Ltd. |
CHINA |
Unknown |
Tin |
Xianghualing Tin Industry Co., Ltd. |
CHINA |
Unknown |
Tin |
Xin Furukawa Metal ( Wuxi ) Co., Ltd. |
CHINA |
Unknown |
Tin |
XURI |
CHINA |
Unknown |
Tin |
Yifeng Tin |
CHINA |
Unknown |
Tin |
Yiquan Manufacturing |
CHINA |
Unknown |
Tin |
Yuecheng Tin Co., Ltd. |
CHINA |
Unknown |
Tin |
Yunnan Chengo Electric Smelting Plant |
CHINA |
Unknown |
Tin |
Yunnan Copper Zinc Industry Co., Ltd. |
CHINA |
Unknown |
Tin |
Yunnan Geiju Smelting Corp. |
CHINA |
Unknown |
Tin |
Yunnan Industrial Co., Ltd. |
CHINA |
Unknown |
Tin |
Yunnan Malipo Baiyi Kuangye Co. |
CHINA |
Unknown |
Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
CHINA |
Unknown |
Tin |
Zhongshan Jinye Smelting Co., Ltd. |
CHINA |
Unknown |
22