Form Specialized Disclosure (Form SD)
 
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
FORM SD
SPECIALIZED DISCLOSURE REPORT*
 
SolarEdge Technologies Inc.
(Exact name of registrant as specified in its charter)
 
Commission File No. 001-36894
 
Delaware
 
20-5338862
(State or other jurisdiction of
incorporation or organization)
 
(IRS Employer Identification No.)
 
1 HaMada Street
Herziliya Pituach 4673335, Israel
 (Address of principal executive offices)

972 (9) 957-6620
(Name and telephone number, including area code, of the person to contact in connection with this report)
 
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
 
  Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.
 

 
Section 1 - Conflict Minerals Disclosures
 
Item 1.01 and 1.02 Conflict Minerals Disclosure and Report

SolarEdge Technologies, Inc. (the “Company”) evaluated its current products and determined that certain products it manufactures or contracts to manufacture contain conflict minerals originating in the Democratic Republic of the Congo or adjoining countries. As a result, the Company has prepared, and is filing with this Form, a Conflict Minerals Report. A copy of the Company’s Conflict Minerals Report for the calendar year ended December 31, 2015 is provided as Exhibit 1.01 to the Specialized Disclosure Report and is publicly available on the Company’s corporate website at http://investors.solaredge.com/phoenix.zhtml?c=253935&p=irol-govHighlights

Section 2 - Exhibits
 
Item 2.01 Exhibits
 
Exhibit
Number
  
Description
   
1.01
  
Conflicts Minerals Report for the reporting period January 1, 2015 to December 31, 2015.



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

 
SolarEdge Technologies Inc.
 
/s/ Rachel Prishkolnik
By:     Rachel Prishkolnik
VP General Counsel & Corporate Secretary 

May 31, 2016
 



Exhibit 1.01


 
SolarEdge Technologies, Inc.
 
Conflict Minerals Report
For the calendar year ended December 31, 2015
 
1.  Introduction
 
SolarEdge Technologies, Inc., together with its wholly-owned subsidiaries (“SolarEdge” or the “Company,” “we,” “our” or “us”), has prepared this Conflict Minerals Report pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and the requirements of Form SD (collectively, the “Rule”).

We have invented an intelligent inverter solution that has changed the way power is harvested and managed in a solar PV system. Our direct current (“DC”) optimized inverter system maximizes power generation at the individual PV module level while lowering the cost of energy produced by the solar PV system and providing comprehensive and advanced safety features. Our system consists of our power optimizers, inverters and cloud based monitoring platform and addresses a broad range of solar market segments, from residential solar installations to commercial and small utility  scale solar installations. Since we began commercial shipments in 2010, we have shipped approximately 2.9 gigawatts (“GW”) of our DC optimized inverter systems and our products have been installed in solar PV systems in 91countries, as of March 31, 2016.

Our systems allow for superior power harvesting and module management relative to traditional inverter systems by deploying power optimizers at each PV module while maintaining a competitive system cost by keeping the AC inversion and grid interaction centralized using a simplified DC AC inverter. The entire system is monitored through our cloud based monitoring platform that enables reduced system operation and maintenance (“O&M”) costs. Our system enables each PV module to operate at its own maximum power point (“MPP”), rather than a system wide average, enabling dynamic response to real world conditions, such as atmospheric conditions, PV module aging, soiling and shading and offering improved energy yield relative to traditional inverter systems. In addition to higher efficiency, our system’s installed cost per watt is competitive with traditional inverter systems of leading manufacturers and generally lower than comparable microinverter systems of leading manufacturers. Furthermore, our architecture allows for complex rooftop system designs and enhanced safety and reliability. Our technology and system architecture were protected by 69 awarded patents and 107 patent applications filed worldwide as of March 31, 2016.

We were founded in 2006 and began commercial shipments in 2010. As of March 31, 2016, we have shipped approximately 11 million power optimizers and 450,000 inverters. We estimate that more than 231,000 installations, many of which may include multiple inverters, are currently connected to, and monitored through, our cloud based monitoring platform.
 
2.  Overview; Applicability of Conflict Minerals Rule to SolarEdge

SolarEdge has performed an internal assessment and determined that certain Conflict Minerals are necessary to the functionality or production of our products. Accordingly, for the purposes of this assessment, all of the products that were in production in the calendar year 2015 were considered (the “Covered Products”).

SolarEdge is several levels removed from the mining of minerals (Conflict Minerals or otherwise). We also do not make purchases of raw ore or unrefined minerals and make no purchases in the Democratic Republic of Congo (“DRC”) or an adjoining country (together, the “covered countries”). SolarEdge therefore has limited influence over the sourcing of the necessary Conflict Minerals in the products that it manufactures or contracts to manufacture (we sometimes refer herein to these products that contain necessary Conflict Minerals as “in-scope products”). In addition, due to its position in the supply chain, SolarEdge depends upon its suppliers for information concerning the origin of the Conflict Minerals contained in its in-scope products. However, through the efforts described in this Conflict Minerals Report, SolarEdge seeks to ensure that its suppliers source responsibly. Minerals including tantalum, tin, tungsten and gold (“3TG”) are classified as “Conflict Minerals” and are necessary to the functionality or production of certain products that we manufacture or contract to manufacture. As such, we are subject to the Rule with respect to those necessary Conflict Minerals. The Rule requires us to conduct in good faith a reasonable country of origin inquiry (“RCOI”) into those necessary Conflict Minerals to determine whether they originated in the covered countries or are from recycled or scrap sources. If, as a result of our RCOI procedures, we know that any of our necessary Conflict Minerals originated in a covered country and are not from recycled or scrap materials, or if we have reason to believe that our necessary Conflict Minerals may have originated in a covered country and have reason to believe that they may not be from recycled or scrap sources, then we are required to exercise due diligence to determine the source and chain of custody of such Conflict Minerals to conclude if they are DRC conflict free or not.



3.  Description of Product Identification and RCOI Processes
 
We have concluded that, during the 2015 calendar year, we have manufactured and contracted to manufacture products containing certain Conflict Minerals. As such, we conducted an RCOI process to determine whether any of the Conflict Minerals originated, or may have originated, in the covered countries and whether such Conflict Minerals originated from recycled or scrap sources.
 
We conducted an assessment to determine which of our direct suppliers may be providing components of our products that are likely to contain Conflict Minerals. We employed a collaborative process to identify the applicable list of components and suppliers to focus our efforts, consulting with members of our supply chain department including suppliers, senior management and other individuals familiar with the manufacturing and component sourcing processes. We verified with such personnel that the population of components and suppliers was complete and comprehensive for our 2015 products. We then identified the list of suppliers that we directly procured materials from (“tier one” or “direct” suppliers) to survey. This list includes suppliers that supplied components to our third-party equipment manufacturers on our behalf and those suppliers from whom we purchased components directly, all between January 1, 2015 and December 31, 2015.

We used a Conflict Minerals Reporting Template (the “CMRT” or the “Template”), which was developed by Conflict-Free Sourcing Initiative’s (CFSI) to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. Our RCOI consisted of surveying tier one suppliers confirmed to have supplied products or components to us that contain Conflict Minerals that are used to manufacture our products.

SolarEdge identified 290 suppliers (the “Suppliers”) that provided components for products manufactured during the calendar year 2015. Of those Suppliers, SolarEdge’s outreach was to 266 Suppliers that provided components, parts or products that SolarEdge determined contained or potentially contained necessary Conflict Minerals. In connection with its scoping determination, SolarEdge reviewed product specifications, supply chain records and bills of material, made internal engineering and supplier inquiries, commissioned an independent third-party consultant and made use of other information known to it regarding the materials composition of its products.
 
4.  Reasonable Country of Origin Inquiry (RCOI)

As required by the Rule, SolarEdge conducted a “reasonable country of origin inquiry” with respect to calendar year 2015. Our outreach included 266 suppliers (the “Suppliers”) that provided components, parts or products that SolarEdge determined contained or potentially contained necessary Conflict Minerals incorporated into products manufactured by us. In connection with this examination, SolarEdge reviewed product specifications, supply chain records and bills of material, made internal engineering and supplier inquiries and utilized other information known to us regarding the materials composition of our products.

In order to identify the source of those components, parts and products, SolarEdge sent letters to its suppliers, informing them of the Rule and SolarEdge's policy on Conflict Minerals, asking them to comply with the Rule. We also requested suppliers to use the last CMRT revision for their compliance declaration (version 4.01) as a method to query and transmit sourcing information along the supply chain. The CMRT includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. The total number of Suppliers who delivered satisfactory CMRT was 129.
 
2


We compared the smelters and refiners identified in the surveys against the lists of facilities which have received a conflict free designation by the Conflict-Free Smelter Program (“CFSP”), a program of CFSI, or other independent third-party audit program. We rely on the CFSP as an independent third-party audit solution through which mineral sources are identified and independently evaluated.

When Suppliers provided us with chain surveys containing incomplete or potentially inaccurate information, we followed up with such Suppliers to seek additional clarifying information. Unresponsive suppliers were contacted on a regular basis both by email and manual outreach.

For 2015, SolarEdge identified 516 smelters and refiners that processed or may have processed the necessary Conflict Minerals contained in our in-scope products, as described in the Smelter and Refiner list attached as Annex A, as well as in the Country of Origin Information attached as Annex B.

Pursuant to the Conflict Minerals Rule, based on the results of its reasonable country of origin inquiry, SolarEdge was required to conduct due diligence for 2015. Because we were unable to identify the source of all products in our supply chain, our reasonable country of origin inquiry utilized the same processes and procedures as our due diligence. These processes and procedures are described below.
 
Due Diligence
 
Design of Due Diligence
 
SolarEdge utilizes due diligence measures relating to Conflict Minerals that are intended to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Second Edition 2013) (the “OECD Guidance”). The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Our Conflict Minerals due diligence process includes: the development of a Conflict Minerals Policy, establishment of a governance charter with cross-functional team members and senior executives, communication to, and engagement of, suppliers, due diligence compliance process and measurement, record-keeping and escalation procedures. We report to the Audit Committee and the Board of Directors with respect to our due diligence process and compliance obligations. Selected elements of our program design are discussed below.

Due Diligence Performed
 
Step 1: Establish Strong Company Management Systems
 
SolarEdge's Code of Conduct defines the company's overall principles and commitment towards legal compliance, ethical conduct, human rights, anti-corruption work and environmental protection. These high expectations extend to SolarEdge's partners, subcontractors and suppliers, whom we encourage to strive beyond merely fulfilling legal compliance. SolarEdge has adopted a conflict mineral policy which provides further clarification to the principles of the Code of Conduct and SolarEdge's human rights approach regarding illegal trade of natural resources.

As part of our policy, SolarEdge is committed to respect human rights and the environment in accordance with accepted international conventions and practices, and we strive to ensure that all materials used in our products come from socially and environmentally responsible sources.

We communicate our policy to our suppliers and it is available at: http://media.corporate-ir.net/media_files/IROL/25/253935/SolarEdge_CM%20Policy_comments_%20v7%20clean.pdf (the “Conflict Mineral Policy”). In addition, in support of our compliance efforts, we have established a steering committee for enforcement of this Conflict Mineral Policy. The steering committee team consists of senior staff under SolarEdge’s legal department, supply chain management group and core technologies. The team members have been made aware of the Conflict Minerals Rule, the OECD Guidance, SolarEdge’s Conflict Minerals Policy and governance charter and have established SolarEdge’s procedures for reviewing and validating supplier responses to its inquiries.
 
3


The SolarEdge Conflict Minerals policy includes a grievance mechanism whereby employees and suppliers can report suspected violations of the policy.

SolarEdge also utilizes an outside consultant to advise it on certain aspects of its compliance, as well as a third-party software provider to enhanced supplier data collection process and help minimize responsible sourcing risks.
 
The following steps have also been adopted:
1.         Implementing a system of controls and transparency over the mineral supply chain through the use of the CFSI reporting template.
2.          Maintaining records relating to our Conflict Minerals program for 5 years.
3.          Implementing standard contract language requiring suppliers to agree to timely respond to answer, and conduct an appropriate due diligence inquiry following, any request by SolarEdge for information on any goods delivered containing Conflict Minerals, as defined under the Rule.
 
Step 2. Identify and Assess Risks in the Supply Chain
 
To assist us with our supply chain due diligence, we engaged a third-party consultant for conducing outreach to our Suppliers and archiving responses from Suppliers. We conducted a supply chain survey requesting direct suppliers to identify smelters and refiners and country of origin, through use of the Template.

We, in conjunction with our third-party consultant, reviewed our entire known component and outsourced manufacturing supply chain for the calendar year 2015, which consisted of approximately 290 suppliers. Our outreach included 266 Suppliers that provided components, parts or products that were determined by SolarEdge to contain or potentially contain necessary Conflict Minerals and that were incorporated into products manufactured by us. The responses were reviewed against criteria developed internally and, where necessary, we reached out for further engagement and to receive additional information from our suppliers. These criteria included untimely or incomplete responses, as well as inconsistencies within the data reported in the Template. We worked directly with these suppliers to receive revised responses.

We compared the CFSI validated smelter list against those smelters identified by our suppliers and, as described in our Conflict Minerals Policy, SolarEdge does not purchase Conflict Minerals directly from mines, smelters or refiners. Tracing minerals to their sources is a challenge that requires us to rely on our suppliers in our efforts to achieve supply chain transparency, including for obtaining information regarding the origin of the Conflict Minerals.
 
Step 3. Design and Implement a Strategy to Respond to Identified Risks
 
We work with a significant number of suppliers and they are diverse in terms of size. Based on our research from publicly available data, sixty-two of our suppliers, which represent 23.3% (62 out of 266 suppliers) are also SEC registrants and subject to the Rule. After SolarEdge receives CMRT responses from Suppliers, it reviews the responses. SolarEdge follows up with Suppliers whose CMRT appears to be incomplete or contain errors or inaccuracies, requesting that the Supplier submit a revised response.  For illustration purposes, following some of SolarEdge steps: 1) verifying smelters according to CFSI smelters list; 2) validating questions in the CMRT file and insuring that there is logical in line with the answers, and 3) verifying and cross checking between the smelter location and the CFSI smelter approved list. Any smelter’s location in the DRC which is not CFSI approved is flagged for further review.

If a completed CMRT indicates a smelter or refiner, SolarEdge reviews this information against the Standard Smelter Names tab of the CMRT and the lists of “compliant” and “active” smelters and refiners published by the CFSI. If an indicated smelter or refiner is not listed on the Standard Smelter Names tab or the Commerce Department List or listed as compliant by the CFSI, SolarEdge requests the assistance of the supplier or contacts the listed entity to attempt to determine whether that entity is actually a smelter or refiner, the mine or location of origin of the Conflict Minerals processed by the smelter or refiner and whether it is known to obtain Conflict Minerals from sources that directly or indirectly finance or benefit armed groups in any of the Covered Countries.
 
SolarEdge reports back to senior management, summarizing our risk mitigation efforts.
 
4

 
Step 4. Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
 
SolarEdge does not have a direct relationship with 3TG smelters and refiners. As a result, SolarEdge does not perform direct audits of these entities within its supply chain, but rather relies on due diligence performed by organizations such as the CFSI.
 
Step 5.  Report Annually on Supply Chain Due Diligence
 
SolarEdge files a Form SD and, to the extent required, a Conflict Minerals Report, with the Securities and Exchange Commission and makes these filings publicly available on the Company’s corporate website at http://investors.solaredge.com/phoenix.zhtml?c=253935&p=irol-govHighlights.

Results of Assessment
 
Based on the information obtained through the due diligence process described above, we do not have sufficient information to determine the products containing Conflict Minerals and/or the country of origin of the Conflict Minerals in those products and/or the facilities used to process Conflict Minerals in those products.

Tracing minerals back to the mine of origin is a complex aspect of responsible sourcing in our supply chain. By adopting methodology outlined by the CFSI’s joint industry programs and outreach initiatives and requiring that our Suppliers conform with standards that meet the OECD guidelines and report to us using the Template, we have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or location of origin of the 3TG in our supply chain and responses to such inquiries represent the most reasonable source information available. Through this industry joint effort, we have made reasonable efforts to make a reasonable determination of the mines or locations of origin of the 3TG in our supply chain. We were unable, however, to ascertain the specific country of origin and/or chain of custody of all necessary Conflict Minerals processed by the facilities that contributed to our Covered Products.
 
SolarEdge approached 266 suppliers.  Out of these:
 
-   Number of suppliers who replied (response rate): 129 (48%). Out of these:
-   Number of suppliers who provided data at a company level: 94 (72%)
-   Number of suppliers who provided data at a product level: 36 (28%)
-   Number of suppliers which were classified as “Free no 3TG”: 23 (17%)
-   Number of suppliers which were classified as "DRC conflict free" (from DRC, all SORs are certified): 8 (6%)
-   Number of suppliers which were classified as DRC, due diligence not yet completed: 39 (30%)  
-   Number of suppliers which were classified as Not from DRC due diligence not yet completed: 16 (12.5%)
                -   Number of suppliers which were classified as "Not from DRC not all smelters are certified": 33 (25.5%)  
 
Smelter and Refiner list attached as Annex A as well as in the Country of Origin Information attached as Annex B.

5

Smelters and refiners verified as conflict free or in the audit process (230):
 
 
Comply & Active
Total
Tin
59 (27%)
216
Tantalum
46 (70%)
66
Tungstan
30 (55%)
55
Gold
95 (53%)
179
Total
230
516
 
Status of identified smelters and refiners:

Comply - Verified Conflict Free
215 (42%)
Active - Participating in an audit process
15 (3%)
Listed but not active
103 (20%)
Outreach required
183 (35%)
Total
516
 
Improvement to Mitigate Risks
 
As we further develop our due diligence program, we intend to enhance supplier communication and escalation processes to improve due diligence data accuracy and completion and continue to influence additional smelters to be designated as “conflict-free”, where possible. To the extent we are not able to determine in the future that we are sourcing from non-conflict free smelters we plan to move toward using Conflict Free smelters within a reasonable time frame. We also intend to request of any of our suppliers that we have reason to believe are supplying us with 3TG from sources that may support conflict in the Covered Countries, that they establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.
 
We understand that supply chain Due Diligence is a dynamic process and requires on-going risk monitoring. Therefore, after implementing our risk mitigation strategy, SolarEdge intends to go back to Step 2 of the OECD guidelines to ensure effective management of risks.
 
Cautionary Note on Forward-Looking Statements
 
This Report contains forward-looking statements within the meaning of Section 21E of the Securities Exchange Act of 1934, as amended, and other federal securities laws. Investors are cautioned that statements in this Report that are not strictly historical statements, including without limitation, SolarEdge’s intentions and expectations and future results regarding further supplier engagement and risk mitigation efforts and strategy, constitute forward-looking statements that involve risks and uncertainties. Actual results could differ materially from the forward-looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on SolarEdge’s ability to verify the accuracy or completeness of any information received from Suppliers or others.
 
6

Annex A
 
Smelter and Refiner list
 
Smelter Identification
Smelter Name
Metal
Status
CID000019
Aida Chemical Industries Co., Ltd.
Gold
Comply
CID000035
Allgemeine Gold-und Silberscheideanstalt A.G.
Gold
Comply
CID000058
AngloGold Ashanti Córrego do Sítio Mineração
Gold
Comply
CID000077
Argor-Heraeus SA
Gold
Comply
CID000082
Asahi Pretec Corporation
Gold
Comply
CID000090
Asaka Riken Co., Ltd.
Gold
Comply
CID000103
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold
Comply
CID000113
Aurubis AG
Gold
Comply
CID000128
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold
Comply
CID000157
Boliden AB
Gold
Comply
CID000176
C. Hafner GmbH + Co. KG
Gold
Comply
CID000185
CCR Refinery - Glencore Canada Corporation
Gold
Comply
CID000233
Chimet S.p.A.
Gold
Comply
CID000362
DODUCO GmbH
Gold
Comply
CID000401
Dowa
Gold
Comply
CID000425
Eco-System Recycling Co., Ltd.
Gold
Comply
CID000493
OJSC Novosibirsk Refinery
Gold
Comply
CID000694
Heimerle + Meule GmbH
Gold
Comply
CID000707
Heraeus Ltd. Hong Kong
Gold
Comply
CID000711
Heraeus Precious Metals GmbH & Co. KG
Gold
Comply
CID000807
Ishifuku Metal Industry Co., Ltd.
Gold
Comply
CID000814
Istanbul Gold Refinery
Gold
Comply
CID000823
Japan Mint
Gold
Comply
CID000855
Jiangxi Copper Company Limited
Gold
Comply
CID000920
Asahi Refining USA Inc.
Gold
Comply
CID000924
Asahi Refining Canada Limited
Gold
Comply
CID000927
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold
Comply
CID000929
JSC Uralelectromed
Gold
Comply
CID000937
JX Nippon Mining & Metals Co., Ltd.
Gold
Comply
CID000957
Kazzinc
Gold
Comply
CID000969
Kennecott Utah Copper LLC
Gold
Comply
CID000981
Kojima Chemicals Co., Ltd.
Gold
Comply
CID001032
L' azurde Company For Jewelry
Gold
Comply
CID001078
LS-NIKKO Copper Inc.
Gold
Comply
CID001113
Materion
Gold
Comply
CID001119
Matsuda Sangyo Co., Ltd.
Gold
Comply
CID001149
Metalor Technologies (Hong Kong) Ltd.
Gold
Comply
CID001152
Metalor Technologies (Singapore) Pte., Ltd.
Gold
Comply
CID001153
Metalor Technologies SA
Gold
Comply
CID001157
Metalor USA Refining Corporation
Gold
Comply
CID001161
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
Gold
Comply
CID001188
Mitsubishi Materials Corporation
Gold
Comply
CID001193
Mitsui Mining and Smelting Co., Ltd.
Gold
Comply
CID001204
Moscow Special Alloys Processing Plant
Gold
Comply
 
7

 
Smelter Identification
Smelter Name
Metal
Status
CID001220
Nadir Metal Rafineri San. Ve Tic. A.Ş.
Gold
Comply
CID001259
Nihon Material Co., Ltd.
Gold
Comply
CID001322
Elemetal Refining, LLC
Gold
Comply
CID001325
Ohura Precious Metal Industry Co., Ltd.
Gold
Comply
CID001326
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Gold
Comply
CID001352
PAMP SA
Gold
Comply
CID001386
Prioksky Plant of Non-Ferrous Metals
Gold
Comply
CID001397
PT Aneka Tambang (Persero) Tbk
Gold
Comply
CID001498
PX Précinox SA
Gold
Comply
CID001512
Rand Refinery (Pty) Ltd.
Gold
Comply
CID001534
Royal Canadian Mint
Gold
Comply
CID001573
Schone Edelmetaal B.V.
Gold
Comply
CID001585
SEMPSA Joyería Platería SA
Gold
Comply
CID001622
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold
Comply
CID001736
Sichuan Tianze Precious Metals Co., Ltd.
Gold
Comply
CID001756
SOE Shyolkovsky Factory of Secondary Precious Metals
Gold
Comply
CID001761
Solar Applied Materials Technology Corp.
Gold
Comply
CID001798
Sumitomo Metal Mining Co., Ltd.
Gold
Comply
CID001875
Tanaka Kikinzoku Kogyo K.K.
Gold
Comply
CID001916
The Refinery of Shandong Gold Mining Co., Ltd.
Gold
Comply
CID001938
Tokuriki Honten Co., Ltd.
Gold
Comply
CID001977
Umicore Brasil Ltda.
Gold
Comply
CID001980
Umicore SA Business Unit Precious Metals Refining
Gold
Comply
CID001993
United Precious Metal Refining, Inc.
Gold
Comply
CID002003
Valcambi SA
Gold
Comply
CID002030
Western Australian Mint trading as The Perth Mint
Gold
Comply
CID002100
Yamamoto Precious Metal Co., Ltd.
Gold
Comply
CID002129
Yokohama Metal Co., Ltd.
Gold
Comply
CID002224
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Gold
Comply
CID002243
Zijin Mining Group Co., Ltd. Gold Refinery
Gold
Comply
CID002314
Umicore Precious Metals Thailand
Gold
Comply
CID002509
MMTC-PAMP India Pvt., Ltd.
Gold
Comply
CID002510
Republic Metals Corporation
Gold
Comply
CID002516
Singway Technology Co., Ltd.
Gold
Comply
CID002580
T.C.A S.p.A
Gold
Comply
CID002779
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
Gold
Comply
CID000211
Changsha South Tantalum Niobium Co., Ltd.
Tantalum
Comply
CID000291
Conghua Tantalum and Niobium Smeltry
Tantalum
Comply
CID000410
Duoluoshan
Tantalum
Comply
CID000456
Exotech Inc.
Tantalum
Comply
 
8

 
 
Smelter Identification
Smelter Name
Metal
Status
CID000460
F&X Electro-Materials Ltd.
Tantalum
Comply
CID000616
Guangdong Zhiyuan New Material Co., Ltd.
Tantalum
Comply
CID000731
Hi-Temp Specialty Metals, Inc.
Tantalum
Comply
CID000914
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum
Comply
CID000917
Jiujiang Tanbre Co., Ltd.
Tantalum
Comply
CID000973
King-Tan Tantalum Industry Ltd.
Tantalum
Comply
CID001076
LSM Brasil S.A.
Tantalum
Comply
CID001163
Metallurgical Products India Pvt., Ltd.
Tantalum
Comply
CID001175
Mineração Taboca S.A.
Tantalum
Comply
CID001192
Mitsui Mining & Smelting
Tantalum
Comply
CID001200
Molycorp Silmet A.S.
Tantalum
Comply
CID001277
Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum
Comply
CID001508
QuantumClean
Tantalum
Comply
CID001522
RFH Tantalum Smeltry Co., Ltd.
Tantalum
Comply
CID001769
Solikamsk Magnesium Works OAO
Tantalum
Comply
CID001869
Taki Chemicals
Tantalum
Comply
CID001891
Telex Metals
Tantalum
Comply
CID001969
Ulba Metallurgical Plant JSC
Tantalum
Comply
CID002232
Zhuzhou Cemented Carbide
Tantalum
Comply
CID002307
Yichun Jin Yang Rare Metal Co., Ltd.
Tantalum
Comply
CID002492
Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum
Comply
CID002501
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
Tantalum
Comply
CID002504
D Block Metals, LLC
Tantalum
Comply
CID002505
FIR Metals & Resource Ltd.
Tantalum
Comply
CID002506
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Tantalum
Comply
CID002508
XinXing HaoRong Electronic Material Co., Ltd.
Tantalum
Comply
CID002512
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum
Comply
CID002539
KEMET Blue Metals
Tantalum
Comply
CID002540
Plansee SE Liezen
Tantalum
Comply
CID002544
H.C. Starck Co., Ltd.
Tantalum
Comply
CID002545
H.C. Starck GmbH Goslar
Tantalum
Comply
CID002546
H.C. Starck GmbH Laufenburg
Tantalum
Comply
CID002547
H.C. Starck Hermsdorf GmbH
Tantalum
Comply
CID002548
H.C. Starck Inc.
Tantalum
Comply
CID002549
H.C. Starck Ltd.
Tantalum
Comply
CID002550
H.C. Starck Smelting GmbH & Co.KG
Tantalum
Comply
CID002556
Plansee SE Reutte
Tantalum
Comply
CID002557
Global Advanced Metals Boyertown
Tantalum
Comply
CID002558
Global Advanced Metals Aizu
Tantalum
Comply
CID002568
KEMET Blue Powder
Tantalum
Comply
 
9

Smelter Identification
Smelter Name
Metal
Status
CID002571
Tranzact, Inc.
Tantalum
Comply
CID002707
Resind Indústria e Comércio Ltda.
Tantalum
Comply
CID000244
Jiangxi Ketai Advanced Material Co., Ltd.
Tin
Comply
CID000292
Alpha
Tin
Comply
CID000295
Cooperativa Metalurgica de Rondônia Ltda.
Tin
Comply
CID000306
CV Gita Pesona
Tin
Comply
CID000307
PT Justindo
Tin
Comply
CID000309
PT Aries Kencana Sejahtera
Tin
Comply
CID000313
CV Serumpun Sebalai
Tin
Comply
CID000315
CV United Smelting
Tin
Comply
CID000402
Dowa
Tin
Comply
CID000438
EM Vinto
Tin
Comply
CID000468
Fenix Metals
Tin
Comply
CID000538
Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin
Comply
CID001070
China Tin Group Co., Ltd.
Tin
Comply
CID001105
Malaysia Smelting Corporation (MSC)
Tin
Comply
CID001142
Metallic Resources, Inc.
Tin
Comply
CID001173
Mineração Taboca S.A.
Tin
Comply
CID001182
Minsur
Tin
Comply
CID001191
Mitsubishi Materials Corporation
Tin
Comply
CID001314
O.M. Manufacturing (Thailand) Co., Ltd.
Tin
Comply
CID001337
Operaciones Metalurgical S.A.
Tin
Comply
CID001399
PT Artha Cipta Langgeng
Tin
Comply
CID001402
PT Babel Inti Perkasa
Tin
Comply
CID001419
PT Bangka Tin Industry
Tin
Comply
CID001421
PT Belitung Industri Sejahtera
Tin
Comply
CID001424
PT BilliTin Makmur Lestari
Tin
Comply
CID001428
PT Bukit Timah
Tin
Comply
CID001434
PT DS Jaya Abadi
Tin
Comply
CID001438
PT Eunindo Usaha Mandiri
Tin
Comply
CID001453
PT Mitra Stania Prima
Tin
Comply
CID001457
PT Panca Mega Persada
Tin
Comply
CID001458
PT Prima Timah Utama
Tin
Comply
CID001460
PT Refined Bangka Tin
Tin
Comply
CID001463
PT Sariwiguna Binasentosa
Tin
Comply
CID001468
PT Stanindo Inti Perkasa
Tin
Comply
CID001471
PT Sumber Jaya Indah
Tin
Comply
CID001477
PT Timah (Persero) Tbk Kundur
Tin
Comply
CID001482
PT Timah (Persero) Tbk Mentok
Tin
Comply
CID001490
PT Tinindo Inter Nusa
Tin
Comply
 
10

Smelter Identification
Smelter Name
Metal
Status
CID001493
PT Tommy Utama
Tin
Comply
CID001539
Rui Da Hung
Tin
Comply
CID001758
Soft Metais Ltda.
Tin
Comply
CID001898
Thaisarco
Tin
Comply
CID002015
VQB Mineral and Trading Group JSC
Tin
Comply
CID002036
White Solder Metalurgia e Mineração Ltda.
Tin
Comply
CID002180
Yunnan Tin Group (Holding) Company Limited
Tin
Comply
CID002455
CV Venus Inti Perkasa
Tin
Comply
CID002468
Magnu's Minerais Metais e Ligas Ltda.
Tin
Comply
CID002479
PT Wahana Perkit Jaya
Tin
Comply
CID002500
Melt Metais e Ligas S/A
Tin
Comply
CID002503
PT ATD Makmur Mandiri Jaya
Tin
Comply
CID002517
O.M. Manufacturing Philippines, Inc.
Tin
Comply
CID002530
PT Inti Stania Prima
Tin
Comply
CID002570
CV Ayi Jaya
Tin
Comply
CID002696
PT Cipta Persada Mulia
Tin
Comply
CID002706
Resind Indústria e Comércio Ltda.
Tin
Comply
CID002773
Metallo-Chimique N.V.
Tin
Comply
CID002774
Elmet S.L.U. (Metallo Group)
Tin
Comply
CID002776
PT Bangka Prima Tin
Tin
Comply
CID002816
PT Sukses Inti Makmur
Tin
Comply
CID000004
A.L.M.T. TUNGSTEN Corp.
Tungsten
Comply
CID000105
Kennametal Huntsville
Tungsten
Comply
CID000218
Guangdong Xianglu Tungsten Co., Ltd.
Tungsten
Comply
CID000258
Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten
Comply
CID000499
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
Comply
CID000568
Global Tungsten & Powders Corp.
Tungsten
Comply
CID000766
Hunan Chenzhou Mining Co., Ltd.
Tungsten
Comply
CID000769
Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten
Comply
CID000825
Japan New Metals Co., Ltd.
Tungsten
Comply
CID000875
Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten
Comply
CID001889
Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten
Comply
CID002011
Vietnam Youngsun Tungsten Industry Co., Ltd.
Tungsten
Comply
CID002044
Wolfram Bergbau und Hütten AG
Tungsten
Comply
CID002082
Xiamen Tungsten Co., Ltd.
Tungsten
Comply
CID002095
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
Tungsten
Comply
CID002315
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten
Comply
CID002319
Malipo Haiyu Tungsten Co., Ltd.
Tungsten
Comply
CID002320
Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten
Comply
CID002321
Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten
Comply
 
11

Smelter Identification
Smelter Name Metal Status
CID002494
Ganzhou Grand Sea W & Mo Group Co Ltd
Tungsten
Comply
CID002502
Asia Tungsten Products Vietnam Ltd.
Tungsten
Comply
CID002513
Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten
Comply
CID002535
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
Tungsten
Comply
CID002536
Ganzhou Yatai Tungsten Co., Ltd.
Tungsten
Comply
CID002541
H.C. Starck GmbH
Tungsten
Comply
CID002542
H.C. Starck Smelting GmbH & Co.KG
Tungsten
Comply
CID002543
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Tungsten
Comply
CID002578
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin
Tungsten
Comply
CID002589
Niagara Refining LLC
Tungsten
Comply
CID002649
Hydrometallurg, JSC
Tungsten
Comply
CID000015
Advanced Chemical Company
Gold
Active
CID000041
Almalyk Mining and Metallurgical Complex (AMMC)
Gold
Active
CID000189
Cendres + Métaux SA
Gold
Active
CID000328
Daejin Indus Co., Ltd.
Gold
Active
CID000359
DSC (Do Sung Corporation)
Gold
Active
CID001147
Metalor Technologies (Suzhou) Ltd.
Gold
Active
CID001236
Navoi Mining and Metallurgical Combinat
Gold
Active
CID001555
Samduck Precious Metals
Gold
Active
CID001955
Torecom
Gold
Active
CID002355
Faggi Enrico S.p.A.
Gold
Active
CID002459
Geib Refining Corporation
Gold
Active
CID002511
KGHM Polska Miedź Spółka Akcyjna
Gold
Active
CID002605
Korea Zinc Co. Ltd.
Gold
Active
CID002777
SAXONIA Edelmetalle GmbH
Gold
Active
CID002778
WIELAND Edelmetalle GmbH
Gold
Active
CID000028
Aktyubinsk Copper Company TOO
Gold
Listed but not active
CID000141
Bauer Walser AG
Gold
Listed but not active
CID000180
Caridad
Gold
Listed but not active
CID000197
Yunnan Copper Industry Co., Ltd.
Gold
Listed but not active
CID000236
China Golddeal
Gold
Listed but not active
CID000242
China National Gold Group Corporation
Gold
Listed but not active
CID000264
Chugai Mining
Gold
Listed but not active
CID000282
Colt refining
Gold
Listed but not active
CID000284
Codelco
Gold
Listed but not active
 
12

 
Smelter Identification
Smelter Name Metal Status
CID000288
Colt Refining
Gold
Listed but not active
CID000333
DaeryongENC
Gold
Listed but not active
CID000343
Daye Non-Ferrous Metals Mining Ltd.
Gold
Listed but not active
CID000465
Feinhütte Halsbrücke GmbH
Gold
Listed but not active
CID000522
Gansu Seemine Material Hi-Tech Co., Ltd.
Gold
Listed but not active
CID000651
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold
Listed but not active
CID000671
Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold
Listed but not active
CID000767
Hunan Chenzhou Mining Co., Ltd.
Gold
Listed but not active
CID000778
Hwasung CJ Co., Ltd.
Gold
Listed but not active
CID000801
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
Gold
Listed but not active
CID000956
Kazakhmys Smelting LLC
Gold
Listed but not active
CID000988
Korea Metal Co., Ltd.
Gold
Listed but not active
CID001029
Kyrgyzaltyn JSC
Gold
Listed but not active
CID001056
Lingbao Gold Company Limited
Gold
Listed but not active
CID001058
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold
Listed but not active
CID001093
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Gold
Listed but not active
CID001328
OJSC Kolyma Refinery
Gold
Listed but not active
CID001362
Penglai Penggang Gold Industry Co., Ltd.
Gold
Listed but not active
CID001546
Sabin Metal Corp.
Gold
Listed but not active
CID001562
SAMWON Metals Corp.
Gold
Listed but not active
CID001619
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold
Listed but not active
CID001754
So Accurate Group, Inc.
Gold
Listed but not active
CID001909
Great Wall Precious Metals Co., Ltd. of CBPM
Gold
Listed but not active
CID001947
Tongling Nonferrous Metals Group Co., Ltd.
Gold
Listed but not active
 
13

 
Smelter Identification
Smelter Name Metal Status
CID002282
Morris and Watson
Gold
Listed but not active
CID002312
Guangdong Jinding Gold Limited
Gold
Listed but not active
CID002515
Fidelity Printers and Refiners Ltd.
Gold
Listed but not active
CID002559
Yantai Zhaojinlufu
Gold
Listed but not active
CID002560
Al Etihad Gold Refinery DMCC
Gold
Listed but not active
CID002821
Metahub Industries Sdn. Bhd.
Gold
Listed but not active
CID001634
Shanghai Jiangxi Metals Co. Ltd
Tantalum
Listed but not active
CID001879
Tantalite Resources
Tantalum
Listed but not active
CID000169
Brinkmann Chemie AG
Tin
Listed but not active
CID000196
CFC Cooperativa dos Fundidores de Cassiterita da Amazônia Ltda.
Tin
Listed but not active
CID000278
CNMC (Guangxi) PGMA Co., Ltd.
Tin
Listed but not active
CID000304
CV Duta Putra Bangka
Tin
Listed but not active
CID000308
CV Makmur Jaya
Tin
Listed but not active
CID000448
Estanho de Rondônia S.A.
Tin
Listed but not active
CID000466
Feinhütte Halsbrücke GmbH
Tin
Listed but not active
CID000553
Gejiu YunXin Colored Electrolysis Ltd
Tin
Listed but not active
CID000555
Gejiu Zili Mining And Metallurgy Co., Ltd.
Tin
Listed but not active
CID000572
Gold Bell Group
Tin
Listed but not active
CID000760
Huichang Jinshunda Tin Co., Ltd.
Tin
Listed but not active
CID000864
Jiangxi Nanshan
Tin
Listed but not active
CID000942
Gejiu Kai Meng Industry and Trade LLC
Tin
Listed but not active
CID001063
Linwu Xianggui Ore Smelting Co., Ltd.
Tin
Listed but not active
CID001136
Metahub Industries Sdn. Bhd.
Tin
Listed but not active
CID001143
Metallo Chimique
Tin
Listed but not active
 
14

 
Smelter Identification
Smelter Name Metal Status
CID001179
Tin Co. Ltd, Minmetals Ganzhou
Tin
Listed but not active
CID001231
Nankang Nanshan Tin Manufactory Co., Ltd.
Tin
Listed but not active
CID001305
Novosibirsk Processing Plant Ltd.
Tin
Listed but not active
CID001343
Operaciones Metalugicas SA.
Tin
Listed but not active
CID001393
PT Alam Lestari Kencana
Tin
Listed but not active
CID001406
PT Babel Surya Alam Lestari
Tin
Listed but not active
CID001409
PT Bangka Kudai Tin
Tin
Listed but not active
CID001412
PT Bangka Putra Karya
Tin
Listed but not active
CID001416
PT Bangka Timah Utama Sejahtera
Tin
Listed but not active
CID001442
PT Fang Di MulTindo
Tin
Listed but not active
CID001445
PT HP Metals Indonesia
Tin
Listed but not active
CID001448
PT Karimun Mining
Tin
Listed but not active
CID001449
PT Koba Tin
Tin
Listed but not active
CID001466
PT Seirama Tin Investment
Tin
Listed but not active
CID001476
PT Supra Sukses Trinusa
Tin
Listed but not active
CID001486
PT Pelat Timah Nusantara Tbk
Tin
Listed but not active
CID001494
PT Yinchendo Mining Industry
Tin
Listed but not active
CID001908
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin
Listed but not active
CID002042
Westmetall GmbH & Co.KG
Tin
Listed but not active
CID002121
Yifeng Tin Industry (Chenzhou) Co Ltd
Tin
Listed but not active
CID002158
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin
Listed but not active
CID002287
PT HANJAYA PERKASA METALS
Tin
Listed but not active
CID002476
PT Singkep Times Utama
Tin
listed but not Active
CID002478
PT Tirus Putra Mandiri
Tin
Listed but not active
 
15

 
Smelter Identification
Smelter Name Metal Status
CID002507
Phoenix Metal Ltd.
Tin
Listed but not active
CID002572
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin
Listed but not active
CID002573
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin
Listed but not active
CID002574
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tin
Listed but not active
CID002592
CV Dua Sekawan
Tin
Listed but not active
CID002703
An Vinh Joint Stock Mineral Processing Company
Tin
Listed but not active
CID002825
An Thai Minerals Company Limited
Tin
Listed but not active
CID000345
Dayu Weiliang Tungsten Co., Ltd.
Tungsten
Listed but not active
CID000868
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten
Listed but not active
CID000966
Kennametal Fallon
Tungsten
Listed but not active
CID002047
Wolfram Company CJSC
Tungsten
Listed but not active
CID002313
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten
Listed but not active
CID002316
Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten
Listed but not active
CID002317
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten
Listed but not active
CID002318
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten
Listed but not active
CID002493
Jiangxi Richsea New Materials Co., Ltd.
Tungsten
Listed but not active
CID002518
Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten
Listed but not active
CID002531
Ganxian Shirui New Material Co., Ltd.
Tungsten
Listed but not active
CID002532
Pobedit, JSC
Tungsten
Listed but not active
CID002538
Sanher Tungsten Vietnam Co., Ltd.
Tungsten
Listed but not active
CID002551
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten
Listed but not active
CID002579
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten
Listed but not active
0
Alpha Metals Korea
Gold
Outreach required
0
Atotech
Gold
Outreach required
 
16

 
Smelter Identification
Smelter Name Metal Status
AURA-II
Gold
Outreach required
BALORE REFINERSGA
Gold
Outreach required
Bangalore Refinary
Gold
Outreach required
BANGALORE REFINERY P
Gold
Outreach required
Bangalore Refinery Pvt Ltd
Gold
Outreach required
China Golddeal
Gold
Outreach required
China National Gold Group Corp.
Gold
Outreach required
Codelco
Gold
Outreach required
Colt Refining
Gold
Outreach required
DaeryongENC
Gold
Outreach required
electro metals
Gold
Outreach required
ENTHONE OMI
Gold
Outreach required
ERCEI
Gold
Outreach required
Feinhütte Halsbrücke GmbH
Gold
Outreach required
 0 
Hawkins Inc
Gold
Outreach required
Heesung Catalysts
Gold
Outreach required
Heimerdinger
Gold
Outreach required
HON HAI PRECISION IN
Gold
Outreach required
Hutti Gold Mines Co.
Gold
Outreach required
inovan gmbh
Gold
Outreach required
K.A Rasmussen as
Gold
Outreach required
Mead Metals
Gold
Outreach required
Metalor Technologies
Gold
Outreach required
MPF
Gold
Outreach required
Remondis Argentia B.V.
Gold
Outreach required

17

Annex B
 
Mineral
Countries of origin
Tin
Philippines, Poland, Brazil, China, Indonesia, Bangka Island
Tantalum
Australia, Bolivia, Brazil, Ethiopia, India, Mozambique, Namibia, Rwanda, Sierra Leone, Zimbabwe, Russia
Tungsten
China
Gold
Australia, Belgium, Canada, , Chile, Brazil, China, Germany, Hong Kong, Japan, South Africa, Switzerland, U.S.A.
 
18