Form SD Compass Diversified Hold (2023)

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

COMPASS DIVERSIFIED HOLDINGS

(Exact name of registrant as specified in its charter)

Delaware001-3492757-6218917
(State or other jurisdiction
of incorporation or organization)
(Commission
File Number)
(I.R.S. Employer
Identification No.)

COMPASS GROUP DIVERSIFIED

HOLDINGS LLC

(Exact name of registrant as specified in its charter)

Delaware001-3492620-3812051
(State or other jurisdiction
of incorporation or organization)
(Commission
File Number)
(I.R.S. Employer
Identification No.)

301 Riverside Avenue

Second Floor

Westport, CT 06880

(Address of principal executive offices, including zip code)

Carrie Ryan, (203)221-1703

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(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

xRule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

This Form SD of Compass Group Diversified Holdings LLC and Compass Diversified Holdings (NYSE: CODI) (collectively, “CODI” or the “Company”) is filed pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2021 through December 31, 2021.

The brief description of the Company’s reasonable country of origin inquiry (“RCOI”) process, the results of the Company’s inquiry, and the determination the Company reached as a result of its RCOI process are included in the Company’s Conflict Minerals Report attached as an exhibit to this Form SD.

A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD, and is publicly available at: http://ir.compassdiversified.com. The content of any website referred to in this Form SD is not incorporated by reference in this Form SD.

Item 1.02 Exhibit

The Company is hereby filing its Conflict Minerals Report for the calendar year ended December 31, 2021, as required by Item 1.01, as Exhibit 1.01 to this Form SD.

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

Date: May 31, 2022COMPASS DIVERSIFIED HOLDINGS
By:/s/ Ryan J. Faulkingham
Ryan J. Faulkingham
Regular Trustee

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

Date: May 31, 2022COMPASS GROUP DIVERSIFIED HOLDINGS LLC
By:/s/ Ryan J. Faulkingham
Ryan J. Faulkingham
Chief Financial Officer
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INDEX TO EXHIBITS

Exhibit 1.01

Conflict Minerals Report

For The Year Ended December 31, 2021

This Conflict Minerals Report for the reporting period from January 1, 2021 to December 31, 2021 is presented to comply with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended. Rule 13p-1 imposes certain reporting obligations on reporting companies whose manufactured or contracted to be manufactured products contain conflict minerals which are necessary to the functionality or production of their products. “Conflict minerals” are defined as gold, cassiterite, columbite-tantalite, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (“3TG”) for the purposes of this assessment. Please refer to Rule 13p-1, Form SD and the 1934 Act Release No.34-67716 for definitions to the terms used in this Report, unless otherwise defined herein.

1. Company Overview

Compass Group Diversified Holdings LLC and Compass Diversified Holdings (collectively, “CODI” or the “Company”) were formed to acquire and manage a group of small to middle market businesses and the Company was a controlling owner of ten businesses, or operating subsidiaries, at December 31, 2021. The subsidiaries are as follows: 5.11 Inc. ("5.11"), BOA Technology Inc. ("BOA"), The Ergo Baby Carrier, Inc. (“Ergobaby”), Lugano Diamonds & Jewelry, Inc. ("Lugano Diamonds" or "Lugano"), Marucci Sports, LLC ("Marucci Sports" or "Marucci"), Velocity Outdoor, Inc. ("Velocity Outdoor" or "Velocity"), Advanced Circuits, Inc. (“ACI” or “Advanced Circuits”), Arnold Magnetic Technologies, Inc. (“Arnold”), Foam Fabricators, Inc. d/b/a Altor Solutions ("Altor Solutions" or "Altor") (formerly "Foam Fabricators") and The Sterno Group Companies, LLC (“Sterno”).

The Company’s subsidiaries are engaged in the following lines of business:

5.11 is a leading provider of purpose-built technical apparel and gear for law enforcement, firefighters, EMS, and military special operations as well as outdoor and adventure enthusiasts. 5.11 is a brand known for innovation and authenticity, and works directly with end users to create purpose-built apparel and gear designed to enhance the safety, accuracy, speed and performance of tactical professionals and enthusiasts worldwide.Headquartered in Irvine, California, 5.11 operates sales offices and distribution centers globally, and 5.11 products are widely distributed in uniform stores, military exchanges, outdoor retail stores, its own retail stores and on511tactical.com.

BOA, creator of the revolutionary, award-winning, patented BOA Fit System, partners with market-leading brands to make the best gear even better. Delivering fit solutions purpose-built for performance, the BOA Fit System is featured in footwear across snow sports, cycling, hiking/trekking, golf, running, court sports, workwear as well as performance headwear and medical bracing. The system consists of three integral parts: a micro-adjustable dial, high-tensile lightweight laces, and low friction lace guides combined with unique configuration applications, which together create a superior alternative to laces, buckles, hook and loop (Velcro), and other traditional closure and fit systems. Each configuration is designed and engineered to deliver superior fit and performance, and is backed by The BOA Lifetime Guarantee. BOA is headquartered in Denver, Colorado and has offices in Austria, Greater China, South Korea, and Japan.

Ergobaby, headquartered in Torrance, California, is a designer, marketer and distributor of wearable baby carriers and accessories, blankets and swaddlers, nursing pillows, strollers and related products. Ergobaby primarily sells its Ergobaby and Baby Tula branded products through brick-and-mortar retailers, national chain stores, online retailers, its own websites and distributors and derives more than 50% of its sales from outside of the United States.

Lugano Diamonds is a leading designer, manufacturer and marketer of high-end, one-of-a-kind jewelry sought after by some of the world’s most discerning clientele. Lugano conducts sales via its own retail salons as well as pop-up showrooms at Lugano-hosted or sponsored events in partnership with influential organizations in the equestrian, art and philanthropic community. Lugano is headquartered in Newport Beach, California.

Marucci Sports is a leading designer, manufacturer, and marketer of premium wood and metal baseball bats, fielding gloves, batting gloves, bags, protective gear, sunglasses, on and off-field apparel, and other baseball and softball equipment used by professional and amateur athletes. Marucci also develops retail

and sports training facilities, both as a corporate owned entity as well as licensing these facilities as franchises. Marucci is headquartered in Baton Rouge, Louisiana.

Velocity Outdoor is a leading designer, manufacturer, and marketer of airguns, archery products, laser aiming devices and related accessories. Velocity Outdoor offers its products under the highly recognizable Crosman, Benjamin, Ravin, LaserMax and CenterPoint brands that are available through national retail chains, mass merchants, dealer and distributor networks. Velocity Outdoor is headquartered in Bloomfield, New York.

Advanced Circuits is an electronic components manufacturing company that provides small-run, quick-turn and volume production rigid printed circuit boards. ACI manufactures and delivers custom printed circuit boards to customers primarily in North America. ACI is headquartered in Aurora, Colorado.

Altor Solutions is a designer and manufacturer of custom molded protective foam solutions and original equipment manufacturer components made from expanded polystyrene and expanded polypropylene. Altor provides products to a variety of end markets, including appliances and electronics, pharmaceuticals, health and wellness, automotive, building and other products. Altor is headquartered in Scottsdale, Arizona and operates 17 molding and fabricating facilities across North America subsequent to the acquisition of Polyfoam.

Arnold is a global designer and manufacturer of engineered electric motor and magnetic solutions for a wide range of specialty applications and end-markets, including aerospace and defense, general industrial, motorsport/automotive, oil and gas, medical, energy, reprographics and advertising specialties. Arnold engineers solutions for and produces high performance permanent magnets (PMAG), stators, rotors and full electric motors ("Ramco"), precision foil products (Precision Thin Metals or "PTM"), and flexible magnets (Flexmag™) that are mission critical in motors, generators, sensors and other systems and components. Based on its long-term relationships, Arnold has built a diverse and blue-chip customer base totaling more than 2,000 clients worldwide. Arnold is headquartered in Rochester, New York.

Sterno is a manufacturer and marketer of portable food warming fuel and creative table lighting solutions for the foodservice industry and flameless candles, outdoor lighting products, scented wax cubes and warmer products for its consumers. Sterno's products include wick and gel chafing fuels, butane stoves and accessories, liquid and traditional wax candles, scented wax cubes and warmer products used for home decor and fragrance systems, catering equipment and outdoor lighting products. Sterno is headquartered in Corona, California.

2. Description of the Company'sProducts Covered by this Report

This Report relates to products: (i) for which 3TG are necessary to the functionality or production of that product; (ii) that were manufactured or contracted to be manufactured by the Company; and (iii) for which the manufacture was completed during calendar year 2021. The Company determined that component products at six (6) of its subsidiaries contain or may contain 3TG which are necessary to the functionality or production of their products. The seven subsidiaries and the applicable 3TG are Advanced Circuits (gold and tin), Arnold (gold, tantalum, tin and tungsten), Ergobaby (tin), Sterno (tin and gold), 5.11 (tin and gold), and Velocity Outdoor (tin).

The Company acquired Lugano Diamonds during the year ended December 31, 2021. As permitted by the instructions to the Form SD, the Company has not included Lugano Diamonds in our reporting for Form SD and the Conflict Mineral report for the year ended December 31, 2021.

3. Reasonable Country of Origin Inquiry

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The Company conducted an analysis of its subsidiaries’ products and found that small quantities of necessary 3TG are contained in some of its subsidiaries’ products. Therefore, for the reporting period from January 1, 2021 to December 31, 2021, the Company conducted a good faith reasonable country of origin inquiry (“RCOI”) which was designed to determine whether any of the necessary 3TG contained in its subsidiaries’ products originated in the Democratic Republic of the Congo or an adjoining country (collectively, the "Covered Countries") or came from recycled or scrap sources. “Necessary 3TG” are 3TG that are necessary to the functionality or production of products that the Company’s subsidiaries manufacture or that the Company’s subsidiaries contract with others to manufacture for us.

The Company used the Conflict Minerals Reporting Template (“CMRT”) developed by the Conflict-Free Sourcing Initiative to request information from its subsidiaries’ suppliers about their supply chain and to gather information about the country of origin of its necessary 3TG. The Company identified approximately 102 direct suppliers that potentially supplied the Company necessary 3TG and requested each of them to complete a CMRT. The Company received responses (by either a letter or completed CMRT) from approximately 92% of these suppliers and reviewed the responses for completeness and accuracy. When the Company determined that its suppliers’ CMRT responses contained information the Company believed to be incomplete or inaccurate, the Company followed up with those suppliers to seek additional information or clarification about those responses.

Based on the Company’s supplier responses, the Company does not have sufficient information to determine whether the products it manufactured or contracted for manufacture during the reporting period contain necessary 3TG that originated, or may have originated, in the Covered Countries and are not or may not be from recycled or scrap sources. Accordingly, and out of an abundance of caution, the Company performed due diligence in an effort to determine the source and chain of custody of these necessary 3TG.

4. Due Diligence

Due Diligence Design

With respect to the period covered, the design of the due diligence process conforms in all material respects with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas, Third Edition, 2016, as further set out in the specific guidance for downstream companies contained in the Supplement on Tin, Tantalum, and Tungsten and the Supplement for Gold (hereinafter, collectively, the “OECD Guidance”).

Due Diligence Measures Performed

The Company undertook due diligence at each of its subsidiaries that have component products that contain or may contain necessary 3TG to determine the source and chain of custody of the necessary 3TG contained in the products manufactured by or contracted for manufacture by the Company’s subsidiaries. Summarized below are the components of the 3TG due diligence program the Company undertook as they relate to the five-step framework set forth in the OECD Guidance:

1. OECD Step #1: Establish and maintain strong company management systems

Our operations are reported in multiple business segments, therefore, we established a single point of contact to assist in implementing a 3TG program. Each segment that manufactures or distributes products that contain necessary 3TG had its own designated specific personnel to coordinate the 3TG diligence, oversee the implementation and execution of a program and coordinate directly with its affected suppliers, if applicable. The affected segments used the CMRT developed by the Conflict-Free Sourcing Initiative as a mechanism to request that suppliers provide information about the source and chain of custody of the necessary 3TG contained in products supplied to each of the affected segments. For suppliers that did not respond to the Company's source and chain of custody inquiry (or provided limited response) for calendar year 2021, the Company submitted that supplier name to the executive management of the applicable subsidiary for review. The Company maintains a conflict minerals policy regarding the sourcing of conflict minerals, which is publicly available on the Company’s website at: http://ir.compassequity.com/corporate-governance.cfm. The content of any website referred to in this Report is not incorporated by reference in this Report.

2. OECD Step #2: Identifying and assessing risk in the supply chain

To identify risks related to necessary 3TG in its products, the Company took the following actions:

worked with suppliers to obtain more complete information;

followed up with suppliers that did not respond or provided inconsistent or incomplete responses;

sought information regarding the smelters or refiners or smelters that processed the conflict minerals in the suppliers’ products; and

analyzed the supplier’s responses against the Company's conflict minerals policy and against the list of smelters and refiners on the CFSI website to determine whether the smelters received a "compliant" or "active" designations from the Conflict Free Smelter Program ("CFSP").

3. OECD Step #3: Design and implement a strategy to respond to identified risks

Results of the Company’s supplier responses were reported to the senior management of the Company, specifically our Chief Financial Officer. The Company continued a risk management plan of attempting to disengage with a supplier where the Company deems risk mitigation unfeasible or unacceptable, and where, in the Company’s opinion, such disengagement would not likely harm the supply chain for a particular product.

4. OECD Step #4: Carry out an independent third party audit of smelter's/ refiner’s due diligence practices

As an owner of downstream companies, the Company relies on audits by independent third parties, including audits of smelters and refiners reported by the CFSP. The Company also relies on the certification processes of the London Bullion Market Association, The Responsible Jewellery Council, and the Tungsten Industry - Conflict Minerals Council.

5. OECD Step #5: Report annually on supply chain due diligence

The Company reports on our conflict minerals due diligence annually by making our Form SD and this Report publicly available on our Company website at: http://ir.compassequity.com/sec.cfm and filing the Form SD (with this Report) with the Securities and Exchange Commission ("SEC").

5. Results of Review

As an owner of downstream companies, the Company can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the 3TG contained in its subsidiaries’ products. The Company relies on the information collected and provided by its subsidiaries’ direct suppliers and publicly available information regarding independent third party audit programs.

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Facilities Used to Process the Necessary 3TG

The Company requested smelter information from the suppliers of each of its subsidiaries that were determined to have component products that contain or may contain 3TG which are necessary to the functionality or production of their products. Based on the responses from our direct suppliers, three (3) suppliers identified only one (1) tin smelter, resulting in a total of one (1) tin smelter being identified. Based on the responses from the three (3) suppliers with only one (1) smelter disclosed for tin, we determined that the following smelter processed the tin that is contained in certain of our products.

MetalOfficial Smelter NameCESI Smelter IDSmelter Country
TinBaoshan Iron & Steel Co., Ltd.UnknownCHINA

In the other responses received from our direct suppliers, each supplier named more than one (1) smelter or refiner in their response for each metal. This lack of detail from the rest of our suppliers prevented the Company from being able to determine whether a particular smelter or refiner named in their responses processed the necessary 3TG in the Company's products. Accordingly, the Company is unable to disclose any other facilities used to produce the necessary 3TG in its products. However, Table 1 attached to this Report lists the smelters and refiners provided to the Company by its other direct suppliers that may have processed necessary 3TG in its subsidiaries’ product lines.

Country of Origin

Based on the responses provided by the Company’s suppliers described directly above, the responses did not provide sufficiently detailed information for us to identify the country of origin of the necessary 3TG in the Company’s products. Accordingly, the Company is unable to disclose the country of origin of the necessary 3TG in its products.

Efforts to determine mine or location

The Company has determined that the most reasonable effort it can make to determine the mines or locations of origin of its necessary 3TG to the greatest possible specificity is to seek information from its direct suppliers about the smelters and refiners and the countries of origin of the necessary 3TG in its products and urge that its suppliers do the same with their direct suppliers. The Company must rely on its direct and indirect suppliers to provide the information about the mine or location of origin of the necessary 3TG in its products. As a result of the lack of information obtained from the Company’s subsidiaries’ suppliers, the Company was unable to determine the mine or location of the necessary conflict minerals in its subsidiaries’ product lines.

6. Risk Mitigation / Steps to Improve Due Diligence Measures

The Company currently intends to take steps to improve its due diligence and mitigate the risk that the Company’s necessary 3TG benefit or finance armed groups, including:

Evaluating current direct suppliers based on their responsiveness to the 2021 calendar year's data collection effort. We expect to submit the names of those suppliers who provide products with risk of possible 3TG content that required responses and whose responses were limited or non-existent for calendar year 2021 to the executive management of the applicable subsidiary for review.

Reaching out to suppliers earlier in the process and asking them to complete the CMRT.

Improving, to the extent possible, the percentage of supplier provided responses to the request to complete the CMRT.

7. Independent Private Sector Audit

Based on the existing guidance from the SEC, this report has not been audited, nor is an Independent Private Sector Audit required for this Report.

8. Forward-Looking Statements

This Report may contain certain forward-looking statements, including those made under the “Risk Mitigation / Steps to Improve Due Diligence Measures” section. Words such as “believes,” “expects,” “projects,” and “future” or similar expressions, are intended to identify forward-looking statements. These forward-looking statements are subject to the inherent uncertainties in predicting future results and conditions. These statements are subject to a variety of uncertainties, unknown risks and other factors concerning the Company’s operations and business environment, which are difficult to predict and are beyond the control of the Company. Factors that could adversely affect our future performance include (1) those described under the heading “Risk Factors” in Item 1A of Part I of our Annual Report on Form 10-K for the year ended December 31, 2021, (2) the responsible sourcing of 3TG in our supply chain by our direct and indirect suppliers and (3) the effectiveness of traceability systems used by our direct and indirect suppliers to determine the source and chain of custody of 3TG contained in our supply chain. Except as required by law, CODI undertakes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise.

Table 1 - List of smelters and refiners that may have processed necessary 3TG of the Company’s subsidiaries

MetalSmelter Reference ListSmelter Facility Location: Country
GoldAdvanced Chemical CompanyUNITED STATES
GoldAida Chemical Industries Co. Ltd.JAPAN
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANY
GoldAl Etihad Gold LLCUNITED ARAB EMIRATES
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTAN
GoldAngloGold Ashanti Córrego do Sítio MineraçãoBRAZIL
GoldArgor-Heraeus SASWITZERLAND
GoldAsahi Pretec Corp.JAPAN
GoldAsahi Refining Canada LimitedCANADA
GoldAsahi Refining USA Inc.UNITED STATES
GoldAsaka Riken Co., Ltd.JAPAN
GoldAurubis AGGERMANY
GoldBoliden ABSWEDEN
GoldC. Hafner GmbH + Co. KGGERMANY
GoldCCR Refinery - Glencore Canada CorporationCANADA
GoldChimet S.p.A.ITALY
GoldDo Sung CorporationKOREA, REPUBLIC OF
GoldDODUCO Contacts and Refining GmbHGERMANY
GoldDowaJAPAN
GoldEmirates Gold DMCCUNITED ARAB EMIRATES
GoldGeib Refining CorporationUNITED STATES
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINA
GoldHeimerle + Meule GmbHGERMANY
GoldHeraeus Metals Hong Kong Ltd.CHINA
GoldHeraeus Precious Metals GmbH & Co. KGGERMANY
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Company LimitedCHINA
GoldIshifuku Metal Industry Co., Ltd.JAPAN
GoldIstanbul Gold RefineryTURKEY
GoldItalpreziosiITALY
GoldJapan MintJAPAN
GoldJiangxi Copper Company LimitedCHINA
GoldJSC UralelectromedRUSSIAN FEDERATION
GoldJX Nippon Mining & Metals Co., Ltd.JAPAN
GoldKazzincKAZAKHSTAN
GoldKennecott Utah Copper LLCUNITED STATES
GoldKGHM Polska Miedz Spolka AkcyjnaPOLAND
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OF
GoldLAIZHOU SHANDONGCHINA
GoldL'Orfebre S.A.ANDORRA
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OF
MetalSmelter Reference ListSmelter Facility Location: Country
GoldMarsam MetalsBRAZIL
GoldMaterionUNITED STATES
GoldMatsuda Sangyo Co., Ltd.JAPAN
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICO
GoldMetalor Technologies (Hong Kong) Ltd.CHINA
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORE
GoldMetalor Technologies (Suzhou) Ltd.CHINA
GoldMetalor Technologies SASWITZERLAND
GoldMetalor USA Refining Corporation UNITED STATES
GoldMitsubishi Materials CorporationJAPAN
GoldMitsui Mining and Smelting Co., Ltd.JAPAN
GoldMMTC-PAMP India Pvt., Ltd.INDIA
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATION
GoldNadir Metal Rafineri San. Ve Tic. A.Ş.TURKEY
GoldNihon Material Co., Ltd.JAPAN
GoldOhura Precious Metal Industry Co., Ltd.JAPAN
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastvetmet)RUSSIAN FEDERATION
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATION
GoldPAMP S.A.SWITZERLAND
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATION
GoldPT Aneka Tambang (Persero) TbkINDONESIA
GoldPX Précinox SASWITZERLAND
GoldRand Refinery (Pty) Ltd.SOUTH AFRICA
GoldREMONDIS PMR B.V.NETHERLANDS
GoldRoyal Canadian MintCANADA
GoldSafimet S.p.A.ITALY
GoldSamduck Precious MetalsKOREA, REPUBLIC OF
GoldSAXONIA Edelmetalle GmbHGERMANY
GoldSEMPSA Joyeria Plateria S.A.SPAIN
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINA
GoldSichuan Tianze Precious Metals Co., Ltd.CHINA
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINA
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATION
GoldSolar Applied Materials Technology Corp.TAIWAN
GoldSumitomo Metal Mining Co., Ltd.JAPAN
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OF
GoldT.C.A. S.p.AITALY
GoldTanaka Kikinzoku Kogyo K.K.JAPAN
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINA
GoldTokuriki Honten Co., Ltd.JAPAN
GoldTOO Tau-Ken-AltynKAZAKHSTAN
GoldTorecomKOREA, REPUBLIC OF
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUM
GoldUnited Precious Metal Refining, Inc.UNITED STATES
MetalSmelter Reference ListSmelter Facility Location: Country
GoldValcambi SASWITZERLAND
GoldWestern Australian Mint trading as The Perth MintAUSTRALIA
GoldWIELAND Edelmetalle GmbHGERMANY
GoldYamakin Co., Ltd.JAPAN
GoldYokohama Metal Co., Ltd.JAPAN
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINA
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINA
TantalumConghua Tantalum and Niobium SmeltryCHINA
TantalumD Block Metals, LLCUNITED STATES
TantalumExotech Inc.UNITED STATES
TantalumF&X Electro-Materials Ltd.CHINA
TantalumFIR Metals & Resource Ltd.CHINA
TantalumGlobal Advanced Metals AizuJAPAN
TantalumGlobal Advanced Metals BoyertownUNITED STATES
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINA
TantalumH.C. Starck Co., Ltd.THAILAND
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANY
TantalumH.C. Starck Hermsdorf GmbHGERMANY
TantalumH.C. Starck Inc.UNITED STATES
TantalumH.C. Starck Ltd.JAPAN
TantalumH.C. Starck Smelting GmbH & Co.KGGERMANY
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINA
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINA
TantalumJiangxi Tuohong New Raw MaterialCHINA
TantalumJiuJiang Nonferrous Metals Smelting Co., Ltd.CHINA
TantalumJiujiang Tanbre Co., Ltd.CHINA
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINA
TantalumKEMET Blue MetalsMEXICO
TantalumLSM Brasil S.A.BRAZIL
TantalumMetallurgical Products India Pvt., Ltd.INDIA
TantalumMineração Taboca S.A.BRAZIL
TantalumMitsui Mining & SmeltingJAPAN
TantalumMolycorp Silmet A.S.ESTONIA
TantalumNPM Silmet ASESTONIA
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINA
TantalumQuantumCleanUNITED STATES
TantalumResind Industria e Comercio Ltda.BRAZIL
TantalumRFH Tantalum Smeltry Co., Ltd.CHINA
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATION
TantalumTaki Chemical Co., Ltd.JAPAN
TantalumTelex MetalsUNITED STATES
TantalumUlba Metallurgical Plant JSCKAZAKHSTAN
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINA
TinAlphaUNITED STATES
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINA
MetalSmelter Reference ListSmelter Facility Location: Country
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINA
TinChina Tin Group Co., Ltd.CHINA
TinDowaJAPAN
TinEM VintoBOLIVIA
TinFenix MetalsPOLAND
TinGejiu Kai Meng Industry and Trade LLCCHINA
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINA
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINA
TinHuiChang Hill Tin Industry Co., Ltd.CHINA
TinJiangxi New Nanshan Technology, Ltd.CHINA
TinMagnu's Minerais Metais e Ligas Ltda.BRAZIL
TinMalaysia Smelting Corporation (MSC)MALAYSIA
TinMelt Metais e Ligas S.A.BRAZIL
TinMetallic Resources, Inc.UNITED STATES
TinMetallo Belgium N.V.BELGIUM
TinMineração Taboca S.A.BRAZIL
TinMinsurPERU
TinMitsubishi Materials CorporationJAPAN
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILAND
TinO.M Manufacturing Philippines, Inc.PHILIPPINES
TinOperaciones Metalurgical S.A.BOLIVIA
TinPT ATD Makmur Mandiri JayaINDONESIA
TinPT Bangka SerumpunINDONESIA
TinPT Mitra Stania PrimaINDONESIA
TinPT Refined Bangka TinINDONESIA
TinPT Timah (Persero) Tbk KundurINDONESIA
TinPT Timah (Persero) Tbk MentokINDONESIA
TinResind Industria e Comercio Ltda.BRAZIL
TinRui Da HungTAIWAN
TinSoft Metais Ltda.BRAZIL
TinTin Technology & RefiningUNITED STATES
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIETNAM
TinThaisarcoTHAILAND
TinWhite Solder Metalurgia e Mineração Ltda.BRAZIL
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINA
TinYunnan Tin Company LimitedCHINA
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINA
TungstenACL Metais EireliBRAZIL
TungstenA.L.M.T. TUNGSTEN Corp.JAPAN
TungstenChaozhou Xianglu Tungsten Industry Co., Ltd.CHINA
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINA
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINA
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINA
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINA
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINA
MetalSmelter Reference ListSmelter Facility Location: Country
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINA
TungstenGlobal Tungsten & Powders Corp.UNITED STATES
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINA
TungstenHC Starck Tungsten GmBHGERMANY
TungstenH.C. Starck Smelting GmbH & Co.KGGERMANY
TungstenHunan Chenzhou Mining Co., Ltd.CHINA
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINA
TungstenHydrometallurg, JSCRUSSIAN FEDERATION
TungstenJapan New Metals Co., Ltd.JAPAN
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINA
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINA
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINA
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINA
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINA
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATION
TungstenKennametal FallonUNITED STATES
TungstenKennametal HuntsvilleUNITED STATES
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OF
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINA
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINA
TungstenMasan Tungsten Chemical LLC (MTC)VIETNAM
TungstenMoliren Ltd.RUSSIAN FEDERATION
TungstenNiagara Refining LLCUNITED STATES
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILLIPINES
TungstenUnecha Refractory metals plantRUSSIAN FEDERATION
TungstenWolfram Bergbau und Hütten AGAUSTRIA
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINA
TungstenXiamen Tungsten Co., Ltd.CHINA
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINA

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