EX-1.01
Published on May 25, 2022
Conflict Minerals Report of RH in Accordance with Rule 13p-1 under the Securities and Exchange Act of 1934
I. Introduction
1. Overview of our Conflict Minerals Report
This Conflict Minerals Report of RH (the Company, us, we) is prepared in accordance with Rule 13p-1 (the Rule) under the Securities Exchange Act of 1934, as amended (the Exchange Act), for the reporting period January 1, 2021 to December 31, 2021 (the reporting period). RH is inclusive of its wholly-owned subsidiary Restoration Hardware, Inc. and its subsidiaries, including, but not limited to, the subsidiary that owns the business operating under the name Waterworks. The information provided in this Conflict Minerals Report on behalf of RH is inclusive of Waterworks, its products and supply chain.
The Rule requires issuers that manufacture or contract to manufacture products that contain conflict minerals that are necessary to the functionality or production of those products to, among other things, disclose annually whether any of those conflict minerals originated in the Covered Countries and if so, to submit a report to the Securities and Exchange Commission (the SEC) that includes a description of the measures they took to exercise due diligence on the conflict minerals source and chain of custody. Conflict minerals are defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are limited to tantalum, tin and tungsten (the conflict minerals). The Covered Countries for purposes of the Rule are the Democratic Republic of the Congo (DRC), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
2. Overview of our Supply Chain, Verification Process and Conflict Minerals Policy
During the reporting period, RH did not own or operate any manufacturing facilities that manufacture products that contain conflict minerals that are necessary to the functionality or production of those products. Instead, RH contracted and had relationships with third-party suppliers who manufacture products for RH that contain conflict minerals that are necessary to the functionality or production of those products. These products that the Company contracts to manufacture, as such term is referred to by the Rule, are herein referred to as the Subject Products. The Subject Products are manufactured for the Company through such suppliers own factories or factories with which such suppliers have commercial relationships. The Company must therefore rely on its third-party suppliers to provide information regarding the existence of conflict minerals in the Subject Products and their origin.
The Company relied upon multi-stakeholder initiatives that provide verification processes for conflict-free minerals from the smelters or refiners who may provide those minerals to companies in our supply chain. The Company is many steps removed from the mining of conflict minerals. The Company does not purchase raw or unrefined conflict minerals and conducts no purchasing activities directly in the Covered Countries. The statements herein are based on the activities performed to date, in good faith, by the Company and on the information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions in the information provided by suppliers or smelters, ongoing identification of smelters in our supply chain, and incomplete information from industry or other third-party sources, among other factors.
We maintain a Conflict Minerals Policy that is incorporated into our Vendors Operation Manual (the Vendor Manual), which our suppliers are able to access via a secure website.
II. Description of Products Covered by this Conflict Minerals Report
RH offers merchandise assortments across a growing number of categories, including furniture, lighting, textiles, bathware, décor, outdoor and garden, and childrens furnishings. The Subject Products included products sold by the Company in the following categories: furniture, bathware, plumbing fixtures, lighting fixtures, kitchen and bath hardware, décor, outdoor and garden, and childrens furnishings.
III. Reasonable Country of Origin Inquiry
In accordance with the Rule, we conducted in good faith a reasonable country of origin inquiry (the RCOI) that was reasonably designed to determine whether any of the necessary conflict minerals in the Subject Products originated in the Covered Countries or were from recycled or scrap sources. In 2021, RH partnered with Assent, a supply chain data management company that enhances automation and accuracy when collecting, submitting or managing data related to ESG, product safety and vendor compliance. Assent coordinated RHs communications with its suppliers, including follow-up outreach and data gathering in support of its RCOI for this reporting year.
To conduct our RCOI, we used a conflict minerals reporting template (version 6.1) developed by the Responsible Minerals Initiative (RMI) (formerly Conflict Free Sourcing Initiative (CFSI)), an initiative founded by members of the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI). Assent, on RHs behalf, requested this information from our direct suppliers who manufacture our Subject Products.
Based on our RCOI, we have reason to believe that some of the necessary conflict minerals used in our Subject Products may have originated in the Covered Countries and may not have been from recycled or scrap sources. Accordingly, we conducted due diligence to determine the source and chain of custody of these conflict minerals.
IV. Due Diligence Process
We have designed our diligence efforts to generally conform to the Organization for Economic Cooperation and Developments (the OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying supplements (the OECD Guidance).
The OECD Guidance identifies five due diligence steps: (i) Establish Strong Company Management Systems; (ii) Identify and Assess Risks in the Supply Chain; (iii) Design and Implement a Strategy to Respond to Identified Risks; (iv) Carry out Independent Third-Party Audit of Smelter/Refiners Due Diligence; and (v) Report Annually on Supply Chain Due Diligence.
The due diligence steps that we executed included the following:
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Step |
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OECD Guidance Steps |
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Due diligence activities performed by RH | ||
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1 |
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Establish Strong Company Management Systems |
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Maintain Conflict Minerals Policy |
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We maintained a Conflict Minerals Policy that is published online, in our Vendor Manual. |
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Maintained Conflict Minerals Compliance Team |
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We maintained an internal conflict minerals team composed of a representative from the legal department and a representative from our vendor compliance team (the Conflict Minerals Compliance Team). The team was structured to ensure our annual conflict minerals due diligence was executed. |
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Our Conflict Minerals Compliance Team periodically reported on its due diligence activities to the legal department and the Vendor Compliance and Product Compliance teams. |
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Internal Engagement |
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We educated and continue educating relevant employees on our conflict minerals program and reporting obligations. |
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Supplier Engagement |
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We provided our direct suppliers information on conflict minerals and our disclosure requirements. |
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Our Conflict Minerals Compliance Team engaged Assent, a supply chain data management company that enhances automation and accuracy when collecting, submitting or managing data related to ESG. |
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2 |
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Identify and Assess Risks in the Supply Chain |
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Identified Products in Scope |
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Our Conflict Minerals Compliance Team conducted a review of the products contracted to be manufactured during the reporting period to identify suppliers that manufacture product categories and Subject Products that may contain conflict minerals. |
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Inquired about Due Diligence Measures Performed by Direct Suppliers |
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We used the responses from our direct suppliers to the RMI reporting template to review their due diligence activities, including whether they had adopted a conflict minerals policy, required their own suppliers to source from processing facilities validated by an independent audit firm, and implemented a review process that includes corrective action management. |
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As deemed appropriate by us, we followed up by email or phone with the suppliers who did not respond to our request to complete the RMI reporting template, or who submitted incomplete responses or responses that we determined may have contained errors or inaccuracies. |
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We employed a conflict minerals data management tool that tracks communications sent to direct suppliers and consolidates suppliers responses to the RMI template for analysis and reporting. |
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Identified Smelters |
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We collected a list of smelters/processors that are in our supply chain by utilizing the RMI reporting template via a web-based platform. We determined if the processing facilities adhere to responsible sourcing practices by reconciling that list to the list of facilities designated by the RMI Responsible Minerals Assurance Program (RMAP) as RMAP Conformant Smelters & Refiners and the RMI list of Active Smelters & Refiners that have committed to undergo the RMAP audit. We have provided lists of smelters/processors that are reported in our supply chain in Appendix A. |
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3 |
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Design and Implement a Strategy to Respond to Identified Risks |
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Internal Reporting System |
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Our Conflict Minerals Compliance Team periodically reported on its due diligence activities to the legal department and the Vendor Compliance and Product Compliance teams. |
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Maintained Conflict Minerals Policy |
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We maintained a Conflict Minerals Policy that is published online, in our Vendor Manual. |
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Verified Smelters |
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As part of our risk mitigation process, we determined if the processing facilities identified in our supply chain adhere to responsible sourcing practices by reconciling the list of smelters collected from our direct suppliers to the list of smelter facilities that have been verified as complying with the RMAP and the RMI list of Active Smelters & Refiners that have committed to undergo the RMAP audit. |
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4 |
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Carry out Independent Third-Party Audit of Smelter/Refiners Due Diligence |
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We relied on the RMIs published lists to verify the RMAP compliance status of smelters/processors that are reported in our supply chain. |
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5 |
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Report Annually on Supply Chain Due Diligence |
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This Conflict Minerals Report is filed with the SEC and publicly available on our website at ir.rh.com, by clicking on Financials & Filings, and then SEC Filings. |
V. Review of Due Diligence Results
1. Facilities Used to Process Conflict Minerals in Subject Products
Based on our due diligence process and the information received from our direct suppliers, we have identified, in Appendix A, facilities that may have been used to process conflict minerals used in the Subject Products.
2. Country of Origin of Conflict Minerals in Subject Products
Based on the information provided by our direct suppliers, we have reason to believe that some of the products RH sold during the reporting year contain necessary conflict minerals that may have originated from the Covered Countries. Two hundred of our direct suppliers indicated that they do not use any conflict minerals in products supplied to RH. Nineteen of our direct suppliers indicated that products supplied to RH contained intentionally added conflict minerals necessary to the function and/or production of the product. Of these nineteen direct suppliers: twelve indicated that the products they sold to RH contained necessary conflict minerals that did not originate in the DRC and seven did not know the country of origin of the necessary conflict minerals in their products, including if conflict minerals in finished products originated in the Covered Countries. In addition, 29% of our direct suppliers did not respond to our survey. Accordingly, notwithstanding our due diligence efforts, we were unable to determine the origin of a portion of conflict minerals contained in certain of the Subject Products.
3. Efforts to Identify the Mine or Location of Origin of the Conflict Minerals
Our reasonable country-of-origin inquiry and due diligence process described above represent our efforts to identify the mine or location of origin for the conflict minerals contained in the Subject Products for this reporting period.
VI. Steps Taken to Mitigate Risk
RH intends to continue to require our suppliers to comply with our Conflict Minerals Policy and to keep it posted online in our Vendor Manual for all suppliers to access. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of conflict minerals will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. We expect that our direct suppliers will comply with our Conflict Minerals Policy and (i) provide appropriate information and conduct necessary due diligence to facilitate our compliance with the Rule, (ii) implement and communicate to their relevant personnel and suppliers policies that are consistent with the Policy, (iii) put in place procedures and contractual provisions for the traceability of conflict minerals, working with their suppliers as applicable, (iv) use reasonable efforts to source conflict minerals from smelters and refiners that have been validated by a recognized, independent third party as DRC conflict free, and (v) adopt a risk management strategy with respect to identified risks in the supply chain that is consistent with our Conflict Minerals Policy.
In addition to the due diligence steps that we took during the reporting period, which we intend to continue for 2022 as applicable, we intend to communicate to new suppliers our sourcing expectations, including by disseminating our Conflict Minerals Policy to them.
VII. Independent Private Sector Audit
Not required for the reporting period.
Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements within the meaning of the federal securities laws including statements related to our business, products and conflict mineral efforts, including steps we intend to take in the future to mitigate the risk that the conflict minerals used in the Subject Products benefit the armed groups on the Covered Countries, use of Assent with respect to our supply chain data management to enhance automation and accuracy of collecting, submitting or managing data related to our ESG, product safety and vendor compliance, Assents ability to communicate with our suppliers, including follow-up outreach and data gathering in support of our reporting, our ability to monitor the progress of our suppliers or that our suppliers would comply with our Conflict Mineral Policy and our requests for timely and accurate information, our suppliers ability to source conflict minerals from smelters and refiners that have been validated by a recognized, independent third party as DRC conflict free, and the effectiveness of any of our risk management strategies to identify risks in the supply chain consistent with our Conflict Minerals Policy. You can identify forward-looking statements by the fact that they do not relate strictly to historical or current facts. These statements may include words such as anticipate, estimate, expect, project, plan, intend, believe, may, will, should, likely and other words and terms of similar meaning in connection with any discussion of the timing or nature of future events. We cannot assure you that future developments affecting us will be those that we have anticipated. Important risks and uncertainties that may cause these forward-looking statements to differ materially from our expectations include, among others: failure to carry out our plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers; lack of progress by smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities); internal and external resource constraints; political developments in the Covered Countries and regulatory developments in the United States, as well as those risks and uncertainties disclosed under the sections entitled Risk Factors and Managements Discussion and Analysis of Financial Condition and Results of Operations in RH Form 10-K filed with the SEC on March 30, 2022, and similar disclosures in subsequent reports filed with the SEC, which are available on our investor relations website at ir.rh.com and on the SEC website at www.sec.gov. Any forward-looking statement made by us in this Conflict Minerals Report speaks only as of the date on which we make it. We undertake no obligation to publicly update any forward-looking statement, whether as a result of new information, future developments or otherwise, except as may be required by any applicable securities laws.
Appendix A
Processing Facilities
Table 1. RMAP-conformant processing facilities as listed by RMI as of May 6, 2022
Processing facilities and their locations reported in our supply chain that are reported by RMI as conformant with the RMAP.
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Mineral |
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Facility ID |
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Processing Facility Name |
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Country |
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Gold |
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CID002763 |
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8853 S.p.A. |
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ITALY |
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Gold |
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CID000015 |
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Advanced Chemical Company |
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UNITED STATES OF AMERICA |
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Gold |
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CID000019 |
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Aida Chemical Industries Co., Ltd. |
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JAPAN |
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Gold |
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CID000035 |
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Allgemeine Gold-und Silberscheideanstalt A.G. |
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GERMANY |
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Gold |
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CID000041 |
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Almalyk Mining and Metallurgical Complex (AMMC) |
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UZBEKISTAN |
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Gold |
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CID000058 |
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AngloGold Ashanti Corrego do Sitio Mineracao |
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BRAZIL |
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Gold |
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CID000077 |
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Argor-Heraeus S.A. |
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SWITZERLAND |
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Gold |
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CID000082 |
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Asahi Pretec Corp. |
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JAPAN |
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Gold |
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CID000924 |
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Asahi Refining Canada Ltd. |
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CANADA |
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Gold |
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CID000920 |
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Asahi Refining USA Inc. |
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UNITED STATES OF AMERICA |
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Gold |
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CID000090 |
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Asaka Riken Co., Ltd. |
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JAPAN |
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Gold |
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CID000113 |
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Aurubis AG |
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GERMANY |
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Gold |
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CID002863 |
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Bangalore Refinery |
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INDIA |
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Gold |
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CID000128 |
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
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PHILIPPINES |
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Gold |
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CID000157 |
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Boliden AB |
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SWEDEN |
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Gold |
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CID000176 |
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C. Hafner GmbH + Co. KG |
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GERMANY |
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Gold |
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CID000185 |
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CCR Refinery - Glencore Canada Corporation |
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CANADA |
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Gold |
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CID000189 |
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Cendres + Metaux S.A. |
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SWITZERLAND |
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Gold |
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CID000233 |
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Chimet S.p.A. |
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ITALY |
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Gold |
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CID000264 |
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Chugai Mining |
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JAPAN |
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Gold |
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CID000401 |
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Dowa |
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JAPAN |
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Gold |
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CID000359 |
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DSC (Do Sung Corporation) |
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KOREA, REPUBLIC OF |
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Gold |
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CID000425 |
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Eco-System Recycling Co., Ltd. East Plant |
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JAPAN |
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Gold |
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CID003425 |
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Eco-System Recycling Co., Ltd. West Plant |
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JAPAN |
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Gold |
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CID002561 |
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Emirates Gold DMCC |
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UNITED ARAB EMIRATES |
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Gold |
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CID002459 |
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Geib Refining Corporation |
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UNITED STATES OF AMERICA |
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Gold |
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CID002243 |
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Gold Refinery of Zijin Mining Group Co., Ltd. |
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CHINA |
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Gold |
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CID000694 |
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Heimerle + Meule GmbH |
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GERMANY |
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Gold |
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CID000707 |
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Heraeus Metals Hong Kong Ltd. |
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CHINA |
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Gold |
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CID000711 |
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Heraeus Precious Metals GmbH & Co. KG |
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GERMANY |
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Gold |
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CID000801 |
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Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
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CHINA |
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Gold |
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CID000807 |
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Ishifuku Metal Industry Co., Ltd. |
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JAPAN |
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Gold |
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CID000814 |
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Istanbul Gold Refinery |
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TURKEY |
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Gold |
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CID002765 |
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Italpreziosi |
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ITALY |
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Gold |
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CID000823 |
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Japan Mint |
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JAPAN |
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Gold |
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CID000855 |
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Jiangxi Copper Co., Ltd. |
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CHINA |
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Gold |
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CID000937 |
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JX Nippon Mining & Metals Co., Ltd. |
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JAPAN |
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Gold |
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CID000957 |
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Kazzinc |
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KAZAKHSTAN |
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Gold |
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CID000969 |
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Kennecott Utah Copper LLC |
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UNITED STATES OF AMERICA |
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Gold |
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CID002511 |
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KGHM Polska Miedz Spolka Akcyjna |
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POLAND |
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Gold |
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CID000981 |
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Kojima Chemicals Co., Ltd. |
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JAPAN |
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Gold |
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CID002605 |
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Korea Zinc Co., Ltd. |
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KOREA, REPUBLIC OF |
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Gold |
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CID002762 |
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LOrfebre S.A. |
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ANDORRA |
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Gold |
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CID001078 |
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LS-NIKKO Copper Inc. |
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KOREA, REPUBLIC OF |
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Gold |
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CID000689 |
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LT Metal Ltd. |
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KOREA, REPUBLIC OF |
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Gold |
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CID002606 |
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Marsam Metals |
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BRAZIL |
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Gold |
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CID001113 |
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Materion |
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UNITED STATES OF AMERICA |
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Gold |
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CID001119 |
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Matsuda Sangyo Co., Ltd. |
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JAPAN |
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Gold |
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CID003575 |
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Metal Concentrators SA (Pty) Ltd. |
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SOUTH AFRICA |
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Gold |
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CID001149 |
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Metalor Technologies (Hong Kong) Ltd. |
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CHINA |
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Gold |
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CID001152 |
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Metalor Technologies (Singapore) Pte., Ltd. |
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SINGAPORE |
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Gold |
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CID001147 |
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Metalor Technologies (Suzhou) Ltd. |
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CHINA |
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Gold |
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CID001153 |
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Metalor Technologies S.A. |
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SWITZERLAND |
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Gold |
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CID001157 |
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Metalor USA Refining Corporation |
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UNITED STATES OF AMERICA |
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Gold |
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CID001161 |
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Metalurgica Met-Mex Penoles S.A. De C.V. |
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MEXICO |
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Gold |
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CID001188 |
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Mitsubishi Materials Corporation |
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JAPAN |
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Gold |
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CID001193 |
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Mitsui Mining and Smelting Co., Ltd. |
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JAPAN |
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Gold |
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CID002509 |
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MMTC-PAMP India Pvt., Ltd. |
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INDIA |
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Gold |
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CID001220 |
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Nadir Metal Rafineri San. Ve Tic. A.S. |
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TURKEY |
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Gold |
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CID001236 |
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Navoi Mining and Metallurgical Combinat |
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UZBEKISTAN |
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Gold |
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CID001259 |
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Nihon Material Co., Ltd. |
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JAPAN |
|
Gold |
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CID002779 |
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Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
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AUSTRIA |
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Gold |
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CID001325 |
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Ohura Precious Metal Industry Co., Ltd. |
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JAPAN |
|
Gold |
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CID001352 |
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PAMP S.A. |
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SWITZERLAND |
|
Gold |
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CID002919 |
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Planta Recuperadora de Metales SpA |
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CHILE |
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Gold |
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CID001397 |
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PT Aneka Tambang (Persero) Tbk |
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INDONESIA |
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Gold |
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CID001498 |
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PX Precinox S.A. |
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SWITZERLAND |
|
Gold |
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CID001512 |
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Rand Refinery (Pty) Ltd. |
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SOUTH AFRICA |
|
Gold |
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CID002582 |
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REMONDIS PMR B.V. |
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NETHERLANDS |
|
Gold |
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CID001534 |
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Royal Canadian Mint |
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CANADA |
|
Gold |
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CID002761 |
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SAAMP |
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FRANCE |
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Gold |
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CID002973 |
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Safimet S.p.A |
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ITALY |
|
Gold |
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CID001555 |
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Samduck Precious Metals |
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KOREA, REPUBLIC OF |
|
Gold |
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CID001585 |
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SEMPSA Joyeria Plateria S.A. |
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SPAIN |
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Gold |
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CID001622 |
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Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
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CHINA |
|
Gold |
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CID001736 |
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Sichuan Tianze Precious Metals Co., Ltd. |
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CHINA |
|
Gold |
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CID002516 |
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Singway Technology Co., Ltd. |
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TAIWAN (PROVINCE OF CHINA) |
|
Gold |
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CID001761 |
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Solar Applied Materials Technology Corp. |
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TAIWAN (PROVINCE OF CHINA) |
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Gold |
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CID001798 |
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Sumitomo Metal Mining Co., Ltd. |
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JAPAN |
|
Gold |
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CID002918 |
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SungEel HiMetal Co., Ltd. |
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KOREA, REPUBLIC OF |
|
Gold |
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CID002580 |
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T.C.A S.p.A |
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ITALY |
|
Gold |
|
CID001875 |
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Tanaka Kikinzoku Kogyo K.K. |
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JAPAN |
|
Gold |
|
CID001916 |
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The Refinery of Shandong Gold Mining Co., Ltd. |
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CHINA |
|
Gold |
|
CID001938 |
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Tokuriki Honten Co., Ltd. |
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JAPAN |
|
Gold |
|
CID002615 |
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TOO Tau-Ken-Altyn |
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KAZAKHSTAN |
|
Gold |
|
CID001955 |
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Torecom |
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KOREA, REPUBLIC OF |
|
Gold |
|
CID002314 |
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Umicore Precious Metals Thailand |
|
THAILAND |
|
Gold |
|
CID001980 |
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Umicore S.A. Business Unit Precious Metals Refining |
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BELGIUM |
|
Gold |
|
CID001993 |
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United Precious Metal Refining, Inc. |
|
UNITED STATES OF AMERICA |
|
Gold |
|
CID002003 |
|
Valcambi S.A. |
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SWITZERLAND |
|
Gold |
|
CID002030 |
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Western Australian Mint (T/a The Perth Mint) |
|
AUSTRALIA |
|
Gold |
|
CID002778 |
|
WIELAND Edelmetalle GmbH |
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GERMANY |
|
Gold |
|
CID002100 |
|
Yamakin Co., Ltd. |
|
JAPAN |
|
Gold |
|
CID002129 |
|
Yokohama Metal Co., Ltd. |
|
JAPAN |
|
Gold |
|
CID002224 |
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
|
CHINA |
|
Tantalum |
|
CID000211 |
|
Changsha South Tantalum Niobium Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID002504 |
|
D Block Metals, LLC |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
CID000460 |
|
F&X Electro-Materials Ltd. |
|
CHINA |
|
Tantalum |
|
CID002505 |
|
FIR Metals & Resource Ltd. |
|
CHINA |
|
Tantalum |
|
CID002558 |
|
Global Advanced Metals Aizu |
|
JAPAN |
|
Tantalum |
|
CID002557 |
|
Global Advanced Metals Boyertown |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
CID000616 |
|
Guangdong Zhiyuan New Material Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID002544 |
|
H.C. Starck Co., Ltd. |
|
THAILAND |
|
Tantalum |
|
CID002547 |
|
H.C. Starck Hermsdorf GmbH |
|
GERMANY |
|
Tantalum |
|
CID002548 |
|
H.C. Starck Inc. |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
CID002549 |
|
H.C. Starck Ltd. |
|
JAPAN |
|
Tantalum |
|
CID002550 |
|
H.C. Starck Smelting GmbH & Co. KG |
|
GERMANY |
|
Tantalum |
|
CID002545 |
|
H.C. Starck Tantalum and Niobium GmbH |
|
GERMANY |
|
Tantalum |
|
CID002492 |
|
Hengyang King Xing Lifeng New Materials Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID002512 |
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID002842 |
|
Jiangxi Tuohong New Raw Material |
|
CHINA |
|
Tantalum |
|
CID000914 |
|
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID000917 |
|
Jiujiang Tanbre Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID002506 |
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID002539 |
|
KEMET Blue Metals |
|
MEXICO |
|
Tantalum |
|
CID001076 |
|
LSM Brasil S.A. |
|
BRAZIL |
|
Tantalum |
|
CID001163 |
|
Metallurgical Products India Pvt., Ltd. |
|
INDIA |
|
Tantalum |
|
CID001175 |
|
Mineracao Taboca S.A. |
|
BRAZIL |
|
Tantalum |
|
CID001192 |
|
Mitsui Mining and Smelting Co., Ltd. |
|
JAPAN |
|
Tantalum |
|
CID001277 |
|
Ningxia Orient Tantalum Industry Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID001200 |
|
NPM Silmet AS |
|
ESTONIA |
|
Tantalum |
|
CID001508 |
|
QuantumClean |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
CID002707 |
|
Resind Industria e Comercio Ltda. |
|
BRAZIL |
|
Tantalum |
|
CID001769 |
|
Solikamsk Magnesium Works OAO |
|
RUSSIA |
|
Tantalum |
|
CID001869 |
|
Taki Chemical Co., Ltd. |
|
JAPAN |
|
Tantalum |
|
CID001891 |
|
Telex Metals |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
CID001969 |
|
Ulba Metallurgical Plant JSC |
|
KAZAKHSTAN |
|
Tantalum |
|
CID002508 |
|
XinXing HaoRong Electronic Material Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID003583 |
|
Yancheng Jinye New Material Technology Co., Ltd. |
|
CHINA |
|
Tantalum |
|
CID001522 |
|
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Tin |
|
CID000292 |
|
Alpha |
|
UNITED STATES OF AMERICA |
|
Tin |
|
CID000228 |
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
|
CHINA |
|
Tin |
|
CID003190 |
|
Chifeng Dajingzi Tin Industry Co., Ltd. |
|
CHINA |
|
Tin |
|
CID001070 |
|
China Tin Group Co., Ltd. |
|
CHINA |
|
Tin |
|
CID003524 |
|
CRM Synergies |
|
SPAIN |
|
Tin |
|
CID000402 |
|
Dowa |
|
JAPAN |
|
Tin |
|
CID000438 |
|
EM Vinto |
|
BOLIVIA (PLURINATIONAL STATE OF) |
|
Tin |
|
CID000448 |
|
Estanho de Rondonia S.A. |
|
BRAZIL |
|
Tin |
|
CID000468 |
|
Fenix Metals |
|
POLAND |
|
Tin |
|
CID000538 |
|
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
|
CHINA |
|
Tin |
|
CID001908 |
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
|
CHINA |
|
Tin |
|
CID000555 |
|
Gejiu Zili Mining And Metallurgy Co., Ltd. |
|
CHINA |
|
Tin |
|
CID003116 |
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
|
CHINA |
|
Tin |
|
CID001231 |
|
Jiangxi New Nanshan Technology Ltd. |
|
CHINA |
|
Tin |
|
CID003379 |
|
Maanshan Weitai Tin Co., Ltd. |
|
CHINA |
|
Tin |
|
CID002468 |
|
Magnus Minerais Metais e Ligas Ltda. |
|
BRAZIL |
|
Tin |
|
CID001105 |
|
Malaysia Smelting Corporation (MSC) |
|
MALAYSIA |
|
Tin |
|
CID001142 |
|
Metallic Resources, Inc. |
|
UNITED STATES OF AMERICA |
|
Tin |
|
CID002773 |
|
Metallo Belgium N.V. |
|
BELGIUM |
|
Tin |
|
CID002774 |
|
Metallo Spain S.L.U. |
|
SPAIN |
|
Tin |
|
CID001173 |
|
Mineracao Taboca S.A. |
|
BRAZIL |
|
Tin |
|
CID001182 |
|
Minsur |
|
PERU |
|
Tin |
|
CID001191 |
|
Mitsubishi Materials Corporation |
|
JAPAN |
|
Tin |
|
CID001314 |
|
O.M. Manufacturing (Thailand) Co., Ltd. |
|
THAILAND |
|
Tin |
|
CID002517 |
|
O.M. Manufacturing Philippines, Inc. |
|
PHILIPPINES |
|
Tin |
|
CID001337 |
|
Operaciones Metalurgicas S.A. |
|
BOLIVIA (PLURINATIONAL STATE OF) |
|
Tin |
|
CID001399 |
|
PT Artha Cipta Langgeng |
|
INDONESIA |
|
Tin |
|
CID003205 |
|
PT Bangka Serumpun |
|
INDONESIA |
|
Tin |
|
CID001453 |
|
PT Mitra Stania Prima |
|
INDONESIA |
|
Tin |
|
CID001460 |
|
PT Refined Bangka Tin |
|
INDONESIA |
|
Tin |
|
CID001477 |
|
PT Timah Tbk Kundur |
|
INDONESIA |
|
Tin |
|
CID001482 |
|
PT Timah Tbk Mentok |
|
INDONESIA |
|
Tin |
|
CID001490 |
|
PT Tinindo Inter Nusa |
|
INDONESIA |
|
Tin |
|
CID002706 |
|
Resind Industria e Comercio Ltda. |
|
BRAZIL |
|
Tin |
|
CID001539 |
|
Rui Da Hung |
|
TAIWAN (PROVINCE OF CHINA) |
|
Tin |
|
CID001758 |
|
Soft Metais Ltda. |
|
BRAZIL |
|
Tin |
|
CID002834 |
|
Thai Nguyen Mining and Metallurgy Co., Ltd. |
|
VIETNAM |
|
Tin |
|
CID001898 |
|
Thaisarco |
|
THAILAND |
|
Tin |
|
CID003325 |
|
Tin Technology & Refining |
|
UNITED STATES OF AMERICA |
|
Tin |
|
CID002036 |
|
White Solder Metalurgia e Mineracao Ltda. |
|
BRAZIL |
|
Tin |
|
CID002158 |
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
|
CHINA |
|
Tin |
|
CID002180 |
|
Yunnan Tin Company Limited |
|
CHINA |
|
Tungsten |
|
CID000004 |
|
A.L.M.T. Corp. |
|
JAPAN |
|
Tungsten |
|
CID002833 |
|
ACL Metais Eireli |
|
BRAZIL |
|
Tungsten |
|
CID002502 |
|
Asia Tungsten Products Vietnam Ltd. |
|
VIETNAM |
|
Tungsten |
|
CID002513 |
|
Chenzhou Diamond Tungsten Products Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002641 |
|
China Molybdenum Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID000258 |
|
Chongyi Zhangyuan Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID003468 |
|
Cronimet Brasil Ltda |
|
BRAZIL |
|
Tungsten |
|
CID002645 |
|
Ganzhou Haichuang Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID000875 |
|
Ganzhou Huaxing Tungsten Products Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002315 |
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002494 |
|
Ganzhou Seadragon W & Mo Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID000568 |
|
Global Tungsten & Powders Corp. |
|
UNITED STATES OF AMERICA |
|
Tungsten |
|
CID000218 |
|
Guangdong Xianglu Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002542 |
|
H.C. Starck Smelting GmbH & Co. KG |
|
GERMANY |
|
Tungsten |
|
CID002541 |
|
H.C. Starck Tungsten GmbH |
|
GERMANY |
|
Tungsten |
|
CID000766 |
|
Hunan Chenzhou Mining Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID000769 |
|
Hunan Chunchang Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002649 |
|
Hydrometallurg, JSC |
|
RUSSIA |
|
Tungsten |
|
CID000825 |
|
Japan New Metals Co., Ltd. |
|
JAPAN |
|
Tungsten |
|
CID002551 |
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002321 |
|
Jiangxi Gan Bei Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002318 |
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002317 |
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002316 |
|
Jiangxi Yaosheng Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID000966 |
|
Kennametal Fallon |
|
UNITED STATES OF AMERICA |
|
Tungsten |
|
CID000105 |
|
Kennametal Huntsville |
|
UNITED STATES OF AMERICA |
|
Tungsten |
|
CID003388 |
|
KGETS Co., Ltd. |
|
KOREA, REPUBLIC OF |
|
Tungsten |
|
CID002319 |
|
Malipo Haiyu Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002543 |
|
Masan Tungsten Chemical LLC (MTC) |
|
VIETNAM |
|
Tungsten |
|
CID002845 |
|
Moliren Ltd. |
|
RUSSIA |
|
Tungsten |
|
CID002589 |
|
Niagara Refining LLC |
|
UNITED STATES OF AMERICA |
|
Tungsten |
|
CID002827 |
|
Philippine Chuangxin Industrial Co., Inc. |
|
PHILIPPINES |
|
Tungsten |
|
CID002724 |
|
Unecha Refractory metals plant |
|
RUSSIA |
|
Tungsten |
|
CID002044 |
|
Wolfram Bergbau und Hutten AG |
|
AUSTRIA |
|
Tungsten |
|
CID002320 |
|
Xiamen Tungsten (H.C.) Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002082 |
|
Xiamen Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID002830 |
|
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
|
CHINA |
Table 2. RMAP-participating processing facilities as listed by RMI as of May 6, 2022
Processing facilities and their locations reported in our supply chain that are reported by RMI as active with the RMAP.
|
Mineral |
|
Facility ID |
|
Processing Facility Name |
|
Country |
|
Gold |
|
CID003500 |
|
Alexy Metals |
|
UNITED STATES OF AMERICA |
|
Gold |
|
CID003461 |
|
Augmont Enterprises Private Limited |
|
INDIA |
|
Gold |
|
CID003529 |
|
Sancus ZFS (LOrfebre, SA) |
|
COLOMBIA |
|
Tin |
|
CID003486 |
|
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
|
BRAZIL |
|
Tin |
|
CID003449 |
|
PT Mitra Sukses Globalindo |
|
INDONESIA |
|
Tin |
|
CID002756 |
|
Super Ligas |
|
BRAZIL |
|
Tungsten |
|
CID003427 |
|
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
|
BRAZIL |
Table 3. RMAP-non-participating processing facilities as of May 6, 2022
Processing facilities and their locations reported in our supply chain that are not reported as either compliant with or participating in the RMAP.
|
Mineral |
|
Facility ID |
|
Processing Facility Name |
|
Country |
|
Gold |
|
CID000197 |
|
Yunnan Copper Industry Co., Ltd. |
|
CHINA |
|
Gold |
|
CID000522 |
|
Refinery of Seemine Gold Co., Ltd. |
|
CHINA |
|
Gold |
|
CID000671 |
|
Hangzhou Fuchunjiang Smelting Co., Ltd. |
|
CHINA |
|
Gold |
|
CID000767 |
|
Hunan Chenzhou Mining Co., Ltd. |
|
CHINA |
|
Gold |
|
CID000773 |
|
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
|
CHINA |
|
Gold |
|
CID001056 |
|
Lingbao Gold Co., Ltd. |
|
CHINA |
|
Gold |
|
CID001058 |
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
|
CHINA |
|
Gold |
|
CID001093 |
|
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
|
CHINA |
|
Gold |
|
CID001362 |
|
Penglai Penggang Gold Industry Co., Ltd. |
|
CHINA |
|
Gold |
|
CID001619 |
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
|
CHINA |
|
Gold |
|
CID001909 |
|
Great Wall Precious Metals Co., Ltd. of CBPM |
|
CHINA |
|
Gold |
|
CID001947 |
|
Tongling Nonferrous Metals Group Co., Ltd. |
|
CHINA |
|
Gold |
|
CID002312 |
|
Guangdong Jinding Gold Limited |
|
CHINA |
|
Gold |
|
CID002525 |
|
Shandong Humon Smelting Co., Ltd. |
|
CHINA |
|
Gold |
|
CID002527 |
|
Shenzhen Zhonghenglong Real Industry Co., Ltd. |
|
CHINA |
|
Gold |
|
CID000343 |
|
Daye Non-Ferrous Metals Mining Ltd. |
|
CHINA |
|
Gold |
|
CID002867 |
|
Degussa Sonne / Mond Goldhandel GmbH |
|
GERMANY |
|
Gold |
|
CID002588 |
|
Shirpur Gold Refinery Ltd. |
|
INDIA |
|
Gold |
|
CID002853 |
|
Sai Refinery |
|
INDIA |
|
Gold |
|
CID002893 |
|
JALAN & Company |
|
INDIA |
|
Gold |
|
CID003382 |
|
CGR Metalloys Pvt Ltd. |
|
INDIA |
|
Gold |
|
CID003383 |
|
Sovereign Metals |
|
INDIA |
|
Gold |
|
CID003463 |
|
Kundan Care Products Ltd. |
|
INDIA |
|
Gold |
|
CID003487 |
|
Emerald Jewel Industry India Limited (Unit 1) |
|
INDIA |
|
Gold |
|
CID003488 |
|
Emerald Jewel Industry India Limited (Unit 2) |
|
INDIA |
|
Gold |
|
CID003489 |
|
Emerald Jewel Industry India Limited (Unit 3) |
|
INDIA |
|
Gold |
|
CID003490 |
|
Emerald Jewel Industry India Limited (Unit 4) |
|
INDIA |
|
Gold |
|
CID003548 |
|
MD Overseas |
|
INDIA |
|
Gold |
|
CID000956 |
|
Kazakhmys Smelting LLC |
|
KAZAKHSTAN |
|
Gold |
|
CID003153 |
|
State Research Institute Center for Physical Sciences and Technology |
|
LITHUANIA |
|
Gold |
|
CID003540 |
|
Sellem Industries Ltd. |
|
MAURITANIA |
|
Gold |
|
CID000180 |
|
Caridad |
|
MEXICO |
|
Gold |
|
CID002282 |
|
Morris and Watson |
|
NEW ZEALAND |
|
Gold |
|
CID003497 |
|
K.A. Rasmussen |
|
NORWAY |
|
Gold |
|
CID002865 |
|
Kyshtym Copper-Electrolytic Plant ZAO |
|
RUSSIA |
|
Gold |
|
CID000493 |
|
OJSC Novosibirsk Refinery |
|
RUSSIA |
|
Gold |
|
CID000929 |
|
JSC Uralelectromed |
|
RUSSIA |
|
Gold |
|
CID001204 |
|
Moscow Special Alloys Processing Plant |
|
RUSSIA |
|
Gold |
|
CID001326 |
|
OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) |
|
RUSSIA |
|
Gold |
|
CID001386 |
|
Prioksky Plant of Non-Ferrous Metals |
|
RUSSIA |
|
Gold |
|
CID001756 |
|
SOE Shyolkovsky Factory of Secondary Precious Metals |
|
RUSSIA |
|
Gold |
|
CID001546 |
|
Sabin Metal Corp. |
|
UNITED STATES OF AMERICA |
|
Gold |
|
CID002872 |
|
Pease & Curren |
|
UNITED STATES OF AMERICA |
|
Gold |
|
CID003324 |
|
QG Refining, LLC |
|
UNITED STATES OF AMERICA |
|
Gold |
|
CID003557 |
|
Metallix Refining Inc. |
|
UNITED STATES OF AMERICA |
|
Tin |
|
CID002500 |
|
Melt Metais e Ligas S.A. |
|
BRAZIL |
|
Tin |
|
CID000942 |
|
Gejiu Kai Meng Industry and Trade LLC |
|
CHINA |
|
Tin |
|
CID003397 |
|
Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
|
CHINA |
|
Tin |
|
CID003208 |
|
Pongpipat Company Limited |
|
MYANMAR |
|
Tin |
|
CID002573 |
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
|
VIETNAM |
|
Tin |
|
CID002574 |
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
|
VIETNAM |
|
Tin |
|
CID002703 |
|
An Vinh Joint Stock Mineral Processing Company |
|
VIETNAM |
|
Tungsten |
|
CID000281 |
|
CNMC (Guangxi) PGMA Co., Ltd. |
|
CHINA |
|
Tungsten |
|
CID003553 |
|
Artek LLC |
|
RUSSIA |