UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
CLEAN ENERGY FUELS CORP.
(Exact Name of Registrant as Specified in Charter)
| Delaware | 001-33480 | 33-0968580 | ||
| (State or Other Jurisdiction of Incorporation or Organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
| 4675 MacArthur Court, Suite 800 Newport Beach, California |
92660 | |
| (Address of Principal Executive Offices) | (Zip Code) |
J. Nathan Jensen
Senior Vice President, Corporate Transactions and Chief Legal Officer
Clean Energy Fuels Corp.
4675 MacArthur Court, Suite 800
Newport Beach, California 92660
(949) 437-1000
(Name and Telephone Number, including Area Code,
of the Person to Contact in Connection with This Report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017. |
Section 1 — Conflict Minerals Disclosure
| Item 1.01 | Conflict Minerals Disclosure and Report. |
Conflict Minerals Disclosure
This Form SD of Clean Energy Fuels Corp. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934 for the reporting period from January 1, 2017 to December 31, 2017 (the “Reporting Period”).
A copy of the Company’s Conflict Minerals Report for the Reporting Period is filed as Exhibit 1.01 to this Form SD, is hereby incorporated by reference herein, and is publicly available at http://investors.cleanenergyfuels.com/corporate-governance.cfm. The foregoing website reference is intended to be an inactive textual reference, and the contents of the Company’s website are not incorporated into this Form SD.
| Item 1.02 | Exhibit. |
The Conflict Minerals Report required by Item 1.01 of Form SD is filed as Exhibit 1.01 to this Form SD.
Section 2 — Exhibits
| Item 2.01 | Exhibits |
| Exhibit No. |
Description | |
| 1.01 | Conflict Minerals Report for the reporting period January 1, 2017 to December 31, 2017 as required by Items 1.01 and 1.02 of this Form. | |
1
EXHIBIT INDEX
| Exhibit No. |
Description | |
| 1.01 | Conflict Minerals Report for the reporting period January 1, 2017 to December 31, 2017 as required by Items 1.01 and 1.02 of this Form. | |
2
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| Clean Energy Fuels Corp. | ||||||||
| By: | /s/ Andrew J. Littlefair | Date: May 30, 2018 | ||||||
| Name: Andrew J. Littlefair Title: President and Chief Executive Officer |
||||||||
3
Exhibit 1.01
CLEAN ENERGY FUELS CORP.
Conflict Minerals Report
For the Reporting Period from January 1, 2017 to December 31, 2017
This Conflict Minerals Report (the “Report”) of Clean Energy Fuels Corp. (together with its consolidated subsidiaries, the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2017 to December 31, 2017 (the “Reporting Period”). As permitted by applicable guidance of the Securities and Exchange Commission, the Company did not obtain an independent private sector audit within the meaning of the Rule.
Overview of the Company and the Rule
The Company is the leading provider of natural gas as an alternative fuel for vehicle fleets in the United States and Canada, based on the number of stations operated and the amount of gasoline gallon equivalents (“GGEs”) of renewable natural gas (“RNG”), compressed natural gas (“CNG”) and liquefied natural gas (“LNG”) delivered. The Company’s principal business is supplying RNG, CNG and LNG (RNG can be delivered in the form of CNG or LNG) for light, medium and heavy-duty vehicles and providing operation and maintenance (“O&M”) services for vehicle fleet customer stations. As a comprehensive solution provider, the Company also designs, builds, operates and maintains fueling stations; sells and services natural gas fueling compressors and other equipment used in CNG stations and LNG stations; offers assessment, design and modification solutions to provide operators with code-compliant service and maintenance facilities for natural gas vehicle fleets; transports and sells CNG and LNG via “virtual” natural gas pipelines and interconnects; procures and sells RNG; sells tradable credits it generates by selling RNG and conventional natural gas as a vehicle fuel, including Renewable Identification Numbers under the federal Renewable Fuel Standard Phase 2 and credits under the California and Oregon Low Carbon Fuel Standards; helps its customers acquire and finance natural gas vehicles; and obtains federal, state and local tax credits, grants and incentives. In addition, before March 31, 2017, the Company produced RNG at its own production facilities (which the Company sold, along with certain of its other RNG production assets), and before December 29, 2017, the Company manufactured, sold and serviced natural gas fueling compressors and other equipment used in CNG stations (which it combined with another company’s natural gas fueling compressor business in a newly formed joint venture, in a transaction the Company refers to as the “CEC Combination”). The Company serves fleet vehicle operators in a variety of markets, including heavy-duty trucking, airports, refuse, public transit, industrial and institutional energy users, and government fleets. As of March 31, 2018, the Company served nearly 1,000 fleet customers operating over 46,000 natural gas vehicles, and the Company owned, operated or supplied over 530 natural gas fueling stations in 41 states in the United States and four provinces in Canada.
The Rule requires disclosure of certain information if a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of the products. The Rule also requires such companies to conduct certain inquiries reasonably designed to determine whether such minerals originated in the countries specified in the Rule. The minerals specified in the Rule, which are collectively referred to in this Report as the “Conflict Minerals,” consist of gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The countries specified in the Rule, which are collectively referred to in this Report as the “Covered Countries,” consist of the Democratic Republic of the Congo and all countries that share an international border with the Democratic Republic of the Congo, which presently consists of the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain aspects of the Company’s operations involve the manufacture, or contracting for manufacture, of products for which the Conflict Minerals are necessary to the functionality or production of the products.
When this Report uses the term “Compliant,” it means the applicable mine, smelter or refiner has been verified as complying with the Responsible Minerals Assurance Process (“RMAP,” formerly the Conflict-Free Smelter Program or CFSP) of the Responsible Mining Initiative (“RMI,” formerly the Conflict-Free Sourcing Initiative or CFSI) or an equivalent third-party audit program, and when this Report uses the term “Active,” it means the applicable mine, smelter or refiner has agreed to participate in the RMAP but has not yet completed the program to become Compliant.
The Company’s Products Covered by this Report
This Report covers products: (i) for which one or more Conflict Minerals is necessary to the functionality or production of the product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during the Reporting Period. These products, which are collectively referred to in this Report as the “Covered Products,” consist of the following:
| • | CNG Compressors – This product category includes products that create CNG by compressing natural gas, as well as replacement parts for such products. Products in this category ceased to be Covered Products upon consummation of the CEC Combination, because these products are not manufactured or contracted to be manufactured by the Company after such date. |
| • | CNG Dispensers – This product category includes products that dispense CNG into vehicles, as well as replacement parts for such products. Products in this category ceased to be Covered Products upon consummation of the CEC Combination, because these products are not manufactured or contracted to be manufactured by the Company after such date. |
| • | CNG Pressure Reduction Systems – This product category includes systems that reduce the pressure of the natural gas that is supplied to a location, as well as replacement parts for such products. Products in this category ceased to be Covered Products upon consummation of the CEC Combination, because these products are not manufactured or contracted to be manufactured by the Company after such date. |
| • | LNG Pumps – This product category includes products that offload LNG from cryogenic tanker trailers into storage tanks at LNG fueling stations and deliver LNG to dispensers from storage tanks, as well as replacement parts for such products. |
| • | LNG Dispensers – This product category includes products that dispense LNG into vehicles, as well as replacement parts for such products. |
| • | Fueling Station Support Panels – This product category includes electrical storage panels used in natural gas fueling stations, as well as replacement parts for such products. A fueling station support panel houses the point of sale system that tracks dispenser transactions, the communications system, purge fans, a digital video recorder and camera to record activities at the station and power circuits for station lighting and electrical control. |
Third-party products the Company sells at retail but does not manufacture or contract to manufacture are outside the scope of this Report.
Overview of the Company’s Supply Chain
The Company’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the original sources of Conflict Minerals and the ultimate manufacture of the Covered Products. In this regard, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of Conflict Minerals that are necessary to the functionality or production of the Covered Products. Moreover, the Company believes the mines, smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and therefore the Company has sought to identify the applicable mines, smelters and refiners of Conflict Minerals in the Company’s supply chain.
The Company’s Conflict Minerals Policy
The Company maintains a policy relating to the sourcing of Conflict Minerals (the “Company Policy”), which provides as follows:
| • | The Company is guided by its core beliefs and values as stated in the Company’s Code of Ethics. The Company is committed to ethical practices and compliance with applicable laws and regulations wherever it does business. The Company believes that its commitment to integrity and citizenship extends to its worldwide supply base. The Company is committed to sourcing its products responsibly, and it expects its suppliers to also source materials from responsible suppliers. |
| • | The Company expects its suppliers to partner with it to comply with the Rule. The Company expects its suppliers to: |
| o | Complete the Company’s Conflict Minerals survey, identifying whether any Conflict Mineral is present in the material that they sell to the Company and the smelter, refiner or mine that originally provided it (for this purpose, the Company’s direct suppliers may have to require successive upstream suppliers to complete the Company’s Conflict Minerals survey until the applicable smelter, refiner or mine is identified); |
| o | Agree to cooperate fully with the Company in connection with any due diligence that the Company chooses to perform with respect to its inquiries; and |
| o | When the Company deems it necessary, to provide reasonable proof of the due diligence performed by the supplier to support the information provided by the supplier to the Company. |
| • | The Company evaluates its relationships with its suppliers on an ongoing basis, and reserves the right to consider the extent to which a supplier has failed to reasonably comply with the Company Policy in the course of such evaluation. |
The Company has designed its Conflict Minerals reporting efforts, including the design and implementation of the Company Policy, to align and comply with the Rule. The full text of the Company Policy is available at http://investors.cleanenergyfuels.com/corporate-governance.cfm. The foregoing website reference and all other such references in this Report are intended to be inactive textual references, and the contents of the Company’s website are not intended to be incorporated into this Report.
The Company’s Reasonable Country of Origin Inquiry
The Company has conducted in good faith a reasonable country of origin inquiry (“RCOI”) regarding the Conflict Minerals. This RCOI was reasonably designed to determine whether any of the Conflict Minerals necessary to the functionality or production of a Covered Product originated in the Covered Countries or may be from recycled or scrap sources. Based on the RCOI, the Company has reason to believe that some of the necessary Conflict Minerals contained in the Covered Products may have originated from the Covered Countries or may not be from recycled or scrap sources. As a result, the Company exercised due diligence on the source and chain of custody of such Conflict Minerals, as described below.
Due Diligence Process
Due diligence process design
The Company’s due diligence measures have been designed to conform, in all material respects, to the framework 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), including the related supplements on gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”).
Due diligence performed
Below is a summary of the Company’s due diligence process performed in the Reporting Period regarding the sourcing of the necessary Conflict Minerals contained in the Covered Products. The description below is intended to provide a summary of the Company’s due diligence process, and thus the measures described below are not the only measures the Company took in the Reporting Period in furtherance of the Company Policy or pursuant to the Rule and the OECD Guidance.
OECD Guidance Step 1: Maintain a management system
| • | The Company continued to make the Company Policy publicly available. |
| • | The Company maintained a working group that oversaw its due diligence process (the “Working Group”). The Working Group was led by the Company’s Senior Vice President, Corporate Transactions and Chief Legal Officer, and also included the Company’s Director, Supply Chain; the Supplier Development Specialist of the Company’s former consolidated subsidiary Clean Energy Compression (which the Company no longer consolidates following consummation of the CEC Combination), the Supply Chain Manager of the Company’s subsidiary Clean Energy Cryogenics; and the Company’s Director, Legal Affairs. The Company also engaged an external service provider to support the due diligence process. |
| • | The Company continued to use RMI’s Conflict Minerals Reporting Template (the “Template”) as a means for collecting information related to the use and origin of Conflict Minerals (including smelter data) in the Company’s supply chain. |
OECD Guidance Step 2: Identify and assess risks
| • | The Company contacted its 82 identified in-scope suppliers and provided them with a summary of the Rule, links to the Template and the Company Policy, and contact information for the Company. |
| • | To aid in the identification and assessment of potentially adverse impacts, the Company defined several “Red Flags,” or indicators that one or more items in a supplier’s completed Template or other response to the Company’s due diligence inquiries are worthy of further action by the Company. The Red Flags were designed to ensure that the Template has been completed in full, and also to capture (i) the reasonableness of responses using logic checks; (ii) whether a supplier has initiated its own due diligence on minerals sourcing; (iii) whether any Conflict Minerals are sourced from one of the Covered Countries, and (iv) whether the mines, smelters or refiners identified by suppliers are Compliant or Active. |
| • | Suppliers that did not submit the Template by the requested deadline or presented Red Flags were contacted by members of the Working Group. |
OECD Guidance Step 3: Design and implement strategy to respond to risk
| • | The Working Group reported the findings of the due diligence process to the Company’s senior management and Board of Directors. |
| • | The Company maintained a risk management plan that establishes supplier risk management strategies, and followed up with suppliers as needed in accordance with this plan. |
OECD Guidance Step 4: Carry out independent third-party audits of the supply chain
| • | The Company relied on the RMI and that organization’s RMAP for independent third-party audits of the mines, smelters and refiners in its supply chain. |
| • | As noted above, and in accordance with applicable guidance, the Company did not obtain an independent private sector audit within the meaning of the Rule. |
OECD Guidance Step 5: Report on supply chain due diligence
| • | The Company is reporting the results of the due diligence it performed by providing this Report as Exhibit 1.01 to a Form SD filed with the Securities and Exchange Commission. The Company also has made this Report publicly available on its website. |
Results of Due Diligence Performed
The Company’s efforts to determine the mine or location of origin of the necessary Conflict Minerals contained in the Covered Products with the greatest possible specificity consisted primarily of the due diligence measures described in this Report. The Company received responses from 76% of its identified in-scope suppliers, which is an increase in supplier participation from 69% for the prior reporting period (the 2016 calendar year).
Based on the information provided by the Company’s suppliers, and taking into account the supplier responses described in the preceding paragraph, the Company believes the facilities that may have been used to process the necessary Conflict Minerals contained in the Covered Products include the processing facilities listed in Tables 1, 2 and 3 in Appendix A to this Report. Of the 322 processing facilities identified by the Company’s suppliers as being in the supply chain for the Covered Products, 252 have been validated as Compliant, eight have been confirmed as Active, and 62 have not been confirmed as Compliant or Active.
Based on its due diligence efforts, the Company does not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals in the Covered Products. Based on the information provided by the Company’s suppliers, however, the Company has reason to believe that some of the necessary Conflict Minerals contained in the Covered Products may have originated from the Covered Countries or may not be from recycled or scrap sources.
Additional Future Measures
The Company aims to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Covered Products finance or benefit armed groups (perpetrators of serious human rights abuses) in the Covered Countries:
| • | Continue to enhance its employee training relating to the Rule, the Company Policy and the Company’s procedures to identify and work with in-scope suppliers. |
| • | Continue to engage with suppliers to help them better understand the Rule and the Company Policy and to obtain accurate and complete information about the origin of Conflict Minerals in the Company’s supply chain, including improving the quality of the processing facility data provided by suppliers. |
| • | Seek opportunities to assist suppliers in building capabilities with a view to improving due diligence performance. |
| • | Continue its initiative to include language in its new supply contracts that requires suppliers to comply with the Company Policy. |
| • | Continue to engage in industry initiatives that encourage Compliant supply chains. |
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of products that contain Conflict Minerals, the Company’s due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals contained in the Covered Products. The supply chain of commodities such as the Conflict Minerals is a complex and multi-step process that involves a number of different parties. Because the Company does not have direct contractual relationships with mines, smelters and refiners, its due diligence processes must rely on information provided by its direct suppliers, as well as similar information provided to those suppliers within their supply chains, to identify the original sources of the necessary Conflict Minerals contained in the Covered Products. The results of the Company’s due diligence efforts could contain inaccuracies or incomplete information due to this process of collecting information. Further, many suppliers’ responses represent the supply chain at a company-level rather than being product-specific, and as a result, the list of processing facilities disclosed in this Report may contain facilities that did not actually process the
Conflict Minerals contained in the Covered Products. In addition, the Company relies on information collected and provided by independent third-party audit programs, such as the RMAP of the RMI, and these sources of information may yield unreliable, inaccurate or incomplete information due to a variety of factors, including human or other errors or fraudulent actions.
Forward-Looking Statements
This Report contains forward-looking statements regarding the Company’s business, products and Conflict Minerals efforts, including steps the Company intends to take to improve its due diligence measures. Words such as “expects,” “believes,” “aims” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this Report. All statements made in this Report concerning future matters that are not historical in nature are forward-looking statements. Although forward-looking statements in this Report reflect the Company’s good faith judgment, such statements can only be based on facts and assumptions currently known by the Company. Consequently, forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated or implied by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include, among others: the risk that information reported to the Company by its suppliers, or other industry information used by the Company, may be inaccurate; the risk that mines, smelters or refiners may not participate in the RMAP or equivalent third-party audit programs, which are voluntary initiatives; and risks related to the Company’s compliance with government regulations and policies, which, among other risks, are discussed under “Risk Factors” in the Company’s most recent annual report on Form 10-K and the other filings it makes with the U.S. Securities and Exchange Commission from time to time, including any subsequently filed quarterly and current reports. Forward-looking statements are not predictions of future events, and readers should not rely on them as such. All forward-looking statements included in this Report speak only as of the date of this Report, and the Company undertakes no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this Report.
Appendix A
Tables of Our Conflict Minerals Processing Facilities
Table 1. Compliant processing facilities as of May 15, 2018.
The following processing facilities that were reported as being in the Company’s supply chain have been validated as Compliant:
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Gold |
Advanced Chemical Company |
UNITED STATES OF AMERICA | ||
| Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN | ||
| Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. |
GERMANY | ||
| Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
UZBEKISTAN | ||
| Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
BRAZIL | ||
| Gold |
Argor-Heraeus S.A. |
SWITZERLAND | ||
| Gold |
Asahi Pretec Corp. |
JAPAN | ||
| Gold |
Asaka Riken Co., Ltd. |
JAPAN | ||
| Gold |
Aurubis AG |
GERMANY | ||
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES | ||
| Gold |
Boliden AB |
SWEDEN | ||
| Gold |
C. Hafner GmbH + Co. KG |
GERMANY | ||
| Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA | ||
| Gold |
Cendres + Metaux S.A. |
SWITZERLAND | ||
| Gold |
Chimet S.p.A. |
ITALY | ||
| Gold |
Daejin Indus Co., Ltd. |
KOREA, REPUBLIC OF | ||
| Gold |
DSC (Do Sung Corporation) |
KOREA, REPUBLIC OF | ||
| Gold |
DODUCO Contacts and Refining GmbH |
GERMANY | ||
| Gold |
Dowa |
JAPAN | ||
| Gold |
Eco-System Recycling Co., Ltd. |
JAPAN | ||
| Gold |
OJSC Novosibirsk Refinery |
RUSSIAN FEDERATION | ||
| Gold |
HeeSung Metal Ltd. |
KOREA, REPUBLIC OF | ||
| Gold |
Heimerle + Meule GmbH |
GERMANY | ||
| Gold |
Heraeus Ltd. Hong Kong |
CHINA | ||
| Gold |
Heraeus Precious Metals GmbH & Co. KG |
GERMANY | ||
| Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CHINA | ||
| Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN | ||
| Gold |
Istanbul Gold Refinery |
TURKEY | ||
| Gold |
Japan Mint |
JAPAN | ||
| Gold |
Jiangxi Copper Co., Ltd. |
CHINA | ||
| Gold |
Asahi Refining USA Inc. |
UNITED STATES OF AMERICA | ||
| Gold |
Asahi Refining Canada Ltd. |
CANADA | ||
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
RUSSIAN FEDERATION | ||
| Gold |
JSC Uralelectromed |
RUSSIAN FEDERATION | ||
| Gold |
JX Nippon Mining & Metals Co., Ltd. |
JAPAN | ||
| Gold |
Kazzinc |
KAZAKHSTAN |
A-1
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Gold |
Kennecott Utah Copper LLC |
UNITED STATES OF AMERICA | ||
| Gold |
Kojima Chemicals Co., Ltd. |
JAPAN | ||
| Gold |
Kyrgyzaltyn JSC |
KYRGYZSTAN | ||
| Gold |
LS-NIKKO Copper Inc. |
KOREA, REPUBLIC OF | ||
| Gold |
Materion |
UNITED STATES OF AMERICA | ||
| Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN | ||
| Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA | ||
| Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA | ||
| Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE | ||
| Gold |
Metalor Technologies S.A. |
SWITZERLAND | ||
| Gold |
Metalor USA Refining Corporation |
UNITED STATES OF AMERICA | ||
| Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. |
MEXICO | ||
| Gold |
Mitsubishi Materials Corporation |
JAPAN | ||
| Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN | ||
| Gold |
Moscow Special Alloys Processing Plant |
RUSSIAN FEDERATION | ||
| Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. |
TURKEY | ||
| Gold |
Nihon Material Co., Ltd. |
JAPAN | ||
| Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN | ||
| Gold |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
RUSSIAN FEDERATION | ||
| Gold |
PAMP S.A. |
SWITZERLAND | ||
| Gold |
Prioksky Plant of Non-Ferrous Metals |
RUSSIAN FEDERATION | ||
| Gold |
PT Aneka Tambang (Persero) Tbk |
INDONESIA | ||
| Gold |
PX Precinox S.A. |
SWITZERLAND | ||
| Gold |
Rand Refinery (Pty) Ltd. |
SOUTH AFRICA | ||
| Gold |
Royal Canadian Mint |
CANADA | ||
| Gold |
Samduck Precious Metals |
KOREA, REPUBLIC OF | ||
| Gold |
SEMPSA Joyeria Plateria S.A. |
SPAIN | ||
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CHINA | ||
| Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
CHINA | ||
| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
RUSSIAN FEDERATION | ||
| Gold |
Solar Applied Materials Technology Corp. |
TAIWAN, PROVINCE OF CHINA | ||
| Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN | ||
| Gold |
Tanaka Kikinzoku Kogyo K.K |
JAPAN | ||
| Gold |
The Refinery of Shandong Gold Mining Co., Ltd. |
CHINA | ||
| Gold |
Tokuriki Honten Co., Ltd. |
JAPAN | ||
| Gold |
Torecom |
KOREA, REPUBLIC OF | ||
| Gold |
Umicore Brasil Ltda. |
BRAZIL | ||
| Gold |
Umicore S.A. Business Unit Precious Metals Refining |
BELGIUM | ||
| Gold |
United Precious Metal Refining, Inc. |
UNITED STATES OF AMERICA | ||
| Gold |
Valcambi S.A. |
SWITZERLAND |
A-2
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Gold |
Western Australian Mint (T/a The Perth Mint) |
AUSTRALIA | ||
| Gold |
Yamakin Co., Ltd. |
JAPAN | ||
| Gold |
Yokohama Metal Co., Ltd. |
JAPAN | ||
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA | ||
| Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
CHINA | ||
| Gold |
SAFINA A.S. |
CZECH REPUBLIC | ||
| Gold |
Umicore Precious Metals Thailand |
THAILAND | ||
| Gold |
Geib Refining Corporation |
UNITED STATES OF AMERICA | ||
| Gold |
MMTC-PAMP India Pvt., Ltd. |
INDIA | ||
| Gold |
Republic Metals Corporation |
UNITED STATES OF AMERICA | ||
| Gold |
Al Etihad Gold LLC |
UNITED ARAB EMIRATES | ||
| Gold |
Emirates Gold DMCC |
UNITED ARAB EMIRATES | ||
| Gold |
T.C.A S.p.A |
ITALY | ||
| Gold |
Korea Zinc Co., Ltd. |
KOREA, REPUBLIC OF | ||
| Gold |
Marsam Metals |
BRAZIL | ||
| Gold |
SAAMP |
FRANCE | ||
| Gold |
Italpreziosi |
ITALY | ||
| Gold |
SAXONIA Edelmetalle GmbH |
GERMANY | ||
| Gold |
WIELAND Edelmetalle GmbH |
GERMANY | ||
| Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
AUSTRIA | ||
| Gold |
AU Traders and Refiners |
SOUTH AFRICA | ||
| Gold |
SungEel HiMetal Co., Ltd. |
KOREA, REPUBLIC OF | ||
| Gold |
Planta Recuperadora de Metales SpA |
CHILE | ||
| Gold |
Safimet S.p.A |
ITALY | ||
| Tantalum |
Asaka Riken Co., Ltd. |
JAPAN | ||
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
CHINA | ||
| Tantalum |
Conghua Tantalum and Niobium Smeltry |
CHINA | ||
| Tantalum |
Exotech Inc. |
UNITED STATES OF AMERICA | ||
| Tantalum |
F&X Electro-Materials Ltd. |
CHINA | ||
| Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. |
CHINA | ||
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA | ||
| Tantalum |
Jiujiang Nonferrous Metals Smelting Company Limited |
CHINA | ||
| Tantalum |
LSM Brasil S.A. |
BRAZIL | ||
| Tantalum |
Metallurgical Products India Pvt., Ltd. |
INDIA | ||
| Tantalum |
Mineracao Taboca S.A. |
BRAZIL | ||
| Tantalum |
Mitsui Mining & Smelting |
JAPAN | ||
| Tantalum |
NPM Silmet AS |
ESTONIA | ||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA | ||
| Tantalum |
QuantumClean |
UNITED STATES OF AMERICA | ||
| Tantalum |
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. |
CHINA |
A-3
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Tantalum |
Solikamsk Magnesium Works OAO |
RUSSIAN FEDERATION | ||
| Tantalum |
Taki Chemical Co., Ltd. |
JAPAN | ||
| Tantalum |
Telex Metals |
UNITED STATES OF AMERICA | ||
| Tantalum |
Ulba Metallurgical Plant JSC |
KAZAKHSTAN | ||
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA | ||
| Tantalum |
D Block Metals, LLC |
UNITED STATES OF AMERICA | ||
| Tantalum |
FIR Metals & Resource Ltd. |
CHINA | ||
| Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CHINA | ||
| Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. |
CHINA | ||
| Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CHINA | ||
| Tantalum |
KEMET Blue Metals |
MEXICO | ||
| Tantalum |
H.C. Starck Co., Ltd. |
THAILAND | ||
| Tantalum |
H.C. Starck Tantalum and Niobium GmbH |
GERMANY | ||
| Tantalum |
H.C. Starck Hermsdorf GmbH |
GERMANY | ||
| Tantalum |
H.C. Starck Inc. |
UNITED STATES OF AMERICA | ||
| Tantalum |
H.C. Starck Ltd. |
JAPAN | ||
| Tantalum |
H.C. Starck Smelting GmbH & Co. KG |
GERMANY | ||
| Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES OF AMERICA | ||
| Tantalum |
Global Advanced Metals Aizu |
JAPAN | ||
| Tantalum |
KEMET Blue Powder |
UNITED STATES OF AMERICA | ||
| Tantalum |
Resind Industria e Comercio Ltda. |
BRAZIL | ||
| Tantalum |
Jiangxi Tuohong New Raw Material |
CHINA | ||
| Tantalum |
Power Resources Ltd. |
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | ||
| Tantalum |
Jiujiang Janny New Material Co., Ltd. |
CHINA | ||
| Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA | ||
| Tin |
Jiangxi Ketai Advanced Material Co., Ltd. |
CHINA | ||
| Tin |
Alpha |
UNITED STATES OF AMERICA | ||
| Tin |
CV Gita Pesona |
INDONESIA | ||
| Tin |
PT Aries Kencana Sejahtera |
INDONESIA | ||
| Tin |
CV Serumpun Sebalai |
INDONESIA | ||
| Tin |
CV United Smelting |
INDONESIA | ||
| Tin |
Dowa |
JAPAN | ||
| Tin |
EM Vinto |
BOLIVIA (PLURINATIONAL STATE OF) | ||
| Tin |
Fenix Metals |
POLAND | ||
| Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA | ||
| Tin |
Huichang Jinshunda Tin Co., Ltd. |
CHINA | ||
| Tin |
Gejiu Kai Meng Industry and Trade LLC |
CHINA |
A-4
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Tin |
China Tin Group Co., Ltd. |
CHINA | ||
| Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA | ||
| Tin |
Metallic Resources, Inc. |
UNITED STATES OF AMERICA | ||
| Tin |
Mineracao Taboca S.A. |
BRAZIL | ||
| Tin |
Minsur |
PERU | ||
| Tin |
Mitsubishi Materials Corporation |
JAPAN | ||
| Tin |
Nankang Nanshan Tin Manufactory Co., Ltd. |
CHINA | ||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND | ||
| Tin |
Operaciones Metalurgical S.A. |
BOLIVIA (PLURINATIONAL STATE OF) | ||
| Tin |
PT Artha Cipta Langgeng |
INDONESIA | ||
| Tin |
PT Babel Inti Perkasa |
INDONESIA | ||
| Tin |
PT Bangka Tin Industry |
INDONESIA | ||
| Tin |
PT Belitung Industri Sejahtera |
INDONESIA | ||
| Tin |
PT Bukit Timah |
INDONESIA | ||
| Tin |
PT DS Jaya Abadi |
INDONESIA | ||
| Tin |
PT Eunindo Usaha Mandiri |
INDONESIA | ||
| Tin |
PT Karimun Mining |
INDONESIA | ||
| Tin |
PT Mitra Stania Prima |
INDONESIA | ||
| Tin |
PT Panca Mega Persada |
INDONESIA | ||
| Tin |
PT Prima Timah Utama |
INDONESIA | ||
| Tin |
PT Refined Bangka Tin |
INDONESIA | ||
| Tin |
PT Sariwiguna Binasentosa |
INDONESIA | ||
| Tin |
PT Stanindo Inti Perkasa |
INDONESIA | ||
| Tin |
PT Sumber Jaya Indah |
INDONESIA | ||
| Tin |
PT Tambang Timah |
INDONESIA | ||
| Tin |
PT Timah (Persero) Tbk Mentok |
INDONESIA | ||
| Tin |
PT Tinindo Inter Nusa |
INDONESIA | ||
| Tin |
PT Tommy Utama |
INDONESIA | ||
| Tin |
Rui Da Hung |
TAIWAN, PROVINCE OF CHINA | ||
| Tin |
Soft Metais Ltda. |
BRAZIL | ||
| Tin |
Thaisarco |
THAILAND | ||
| Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CHINA | ||
| Tin |
White Solder Metalurgia e Mineracao Ltda. |
BRAZIL | ||
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CHINA | ||
| Tin |
Yunnan Tin Company Limited |
CHINA | ||
| Tin |
CV Venus Inti Perkasa |
INDONESIA | ||
| Tin |
Magnu’s Minerais Metais e Ligas Ltda. |
BRAZIL | ||
| Tin |
Melt Metais e Ligas S.A. |
BRAZIL | ||
| Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA | ||
| Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
A-5
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Tin |
PT Inti Stania Prima |
INDONESIA | ||
| Tin |
CV Ayi Jaya |
INDONESIA | ||
| Tin |
CV Dua Sekawan |
INDONESIA | ||
| Tin |
CV Tiga Sekawan |
INDONESIA | ||
| Tin |
Resind Industria e Comercio Ltda. |
BRAZIL | ||
| Tin |
Metallo Belgium N.V. |
BELGIUM | ||
| Tin |
Metallo Spain S.L.U. |
SPAIN | ||
| Tin |
PT Bangka Prima Tin |
INDONESIA | ||
| Tin |
PT Sukses Inti Makmur |
INDONESIA | ||
| Tin |
PT Kijang Jaya Mandiri |
INDONESIA | ||
| Tin |
PT Menara Cipta Mulia |
INDONESIA | ||
| Tin |
HuiChang Hill Tin Industry Co., Ltd. |
CHINA | ||
| Tin |
Gejiu Fengming Metallurgy Chemical Plant |
CHINA | ||
| Tin |
Guanyang Guida Nonferrous Metal Smelting Plant |
CHINA | ||
| Tin |
Gejiu Jinye Mineral Company |
CHINA | ||
| Tin |
PT Lautan Harmonis Sejahtera |
INDONESIA | ||
| Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
CHINA | ||
| Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
CHINA | ||
| Tin |
PT Bangka Serumpun |
INDONESIA | ||
| Tungsten |
A.L.M.T. TUNGSTEN Corp. |
JAPAN | ||
| Tungsten |
Kennametal Huntsville |
UNITED STATES OF AMERICA | ||
| Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Global Tungsten & Powders Corp. |
UNITED STATES OF AMERICA | ||
| Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
CHINA | ||
| Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. |
CHINA | ||
| Tungsten |
Japan New Metals Co., Ltd. |
JAPAN | ||
| Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
CHINA | ||
| Tungsten |
Kennametal Fallon |
UNITED STATES OF AMERICA | ||
| Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. |
VIETNAM | ||
| Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd. |
VIETNAM | ||
| Tungsten |
Wolfram Bergbau und Hutten AG |
AUSTRIA | ||
| Tungsten |
Xiamen Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA | ||
| Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA | ||
| Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
CHINA |
A-6
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA | ||
| Tungsten |
Asia Tungsten Products Vietnam Ltd. |
VIETNAM | ||
| Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. |
CHINA | ||
| Tungsten |
H.C. Starck Tungsten GmbH |
GERMANY | ||
| Tungsten |
H.C. Starck Smelting GmbH & Co. KG |
GERMANY | ||
| Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
VIETNAM | ||
| Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA | ||
| Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
CHINA | ||
| Tungsten |
Niagara Refining LLC |
UNITED STATES OF AMERICA | ||
| Tungsten |
Hydrometallurg, JSC |
RUSSIAN FEDERATION | ||
| Tungsten |
Unecha Refractory metals plant |
RUSSIAN FEDERATION | ||
| Tungsten |
South-East Nonferrous Metal Company Limited of Hengyang City |
CHINA | ||
| Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
PHILIPPINES | ||
| Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
CHINA | ||
| Tungsten |
ACL Metais Eireli |
BRAZIL | ||
| Tungsten |
Woltech Korea Co., Ltd. |
KOREA, REPUBLIC OF | ||
| Tungsten |
Moliren Ltd. |
RUSSIAN FEDERATION |
Table 2. Active processing facilities as of May 15, 2018.
The following processing facilities that were reported as being in the Company’s supply chain have been confirmed as Active:
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Gold |
KGHM Polska Miedz Spolka Akcyjna |
POLAND | ||
| Gold |
Remondis Argentia B.V. |
NETHERLANDS | ||
| Gold |
L’Orfebre S.A. |
ANDORRA | ||
| Gold |
Modeltech Sdn Bhd |
MALAYSIA | ||
| Gold |
Bangalore Refinery |
INDIA | ||
| Gold |
NH Recytech Company |
KOREA, REPUBLIC OF | ||
| Gold |
DS PRETECH Co., Ltd. |
KOREA, REPUBLIC OF | ||
| Tin |
Modeltech Sdn Bhd |
MALAYSIA |
Table 3. Processing facilities not Compliant or Active as of May 15, 2018.
The following processing facilities that were reported as being in the Company’s supply chain have not been confirmed as Compliant or Active:
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
TURKEY | ||
| Gold |
Caridad |
MEXICO | ||
| Gold |
Yunnan Copper Industry Co., Ltd. |
CHINA | ||
| Gold |
Chugai Mining |
JAPAN |
A-7
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Gold |
Daye Non-Ferrous Metals Mining Ltd. |
CHINA | ||
| Gold |
Refinery of Seemine Gold Co., Ltd. |
CHINA | ||
| Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
CHINA | ||
| Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
CHINA | ||
| Gold |
Hunan Chenzhou Mining Co., Ltd. |
CHINA | ||
| Gold |
HwaSeong CJ CO., LTD. |
KOREA, REPUBLIC OF | ||
| Gold |
Kazakhmys Smelting LLC |
KAZAKHSTAN | ||
| Gold |
L’azurde Company For Jewelry |
SAUDI ARABIA | ||
| Gold |
Lingbao Gold Co., Ltd. |
CHINA | ||
| Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
CHINA | ||
| Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
CHINA | ||
| Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN | ||
| Gold |
Elemetal Refining, LLC |
UNITED STATES OF AMERICA | ||
| Gold |
Penglai Penggang Gold Industry Co., Ltd. |
CHINA | ||
| Gold |
Sabin Metal Corp. |
UNITED STATES OF AMERICA | ||
| Gold |
Samwon Metals Corp. |
KOREA, REPUBLIC OF | ||
| Gold |
Schone Edelmetaal B.V. |
NETHERLANDS | ||
| Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
CHINA | ||
| Gold |
So Accurate Group, Inc. |
UNITED STATES OF AMERICA | ||
| Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
CHINA | ||
| Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
CHINA | ||
| Gold |
Morris and Watson |
NEW ZEALAND | ||
| Gold |
Guangdong Jinding Gold Limited |
CHINA | ||
| Gold |
Fidelity Printers and Refiners Ltd. |
ZIMBABWE | ||
| Gold |
Singway Technology Co., Ltd. |
TAIWAN, PROVINCE OF CHINA | ||
| Gold |
Kaloti Precious Metals |
UNITED ARAB EMIRATES | ||
| Gold |
Sudan Gold Refinery |
SUDAN | ||
| Gold |
Tony Goetz NV |
BELGIUM | ||
| Gold |
TOO Tau-Ken-Altyn |
KAZAKHSTAN | ||
| Gold |
Abington Reldan Metals, LLC |
UNITED STATES OF AMERICA | ||
| Gold |
GCC Gujrat Gold Centre Pvt. Ltd. |
INDIA | ||
| Gold |
Sai Refinery |
INDIA | ||
| Gold |
Universal Precious Metals Refining Zambia |
ZAMBIA | ||
| Gold |
Kyshtym Copper-Electrolytic Plant ZAO |
RUSSIAN FEDERATION | ||
| Gold |
Morris and Watson Gold Coast |
AUSTRALIA | ||
| Gold |
Degussa Sonne / Mond Goldhandel GmbH |
GERMANY | ||
| Gold |
Pease & Curren |
UNITED STATES OF AMERICA | ||
| Gold |
State Research Institute Center for Physical Sciences and Technology |
LITHUANIA |
A-8
| Metal |
Processing Facility Name |
Processing Facility Location | ||
| Gold |
African Gold Refinery |
UGANDA | ||
| Tantalum |
Duoluoshan |
CHINA | ||
| Tantalum |
King-Tan Tantalum Industry Ltd. |
CHINA | ||
| Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd. |
CHINA | ||
| Tin |
CNMC (Guangxi) PGMA Co., Ltd. |
CHINA | ||
| Tin |
Estanho de Rondonia S.A. |
BRAZIL | ||
| Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CHINA | ||
| Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
VIETNAM | ||
| Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
VIETNAM | ||
| Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
VIETNAM | ||
| Tin |
An Vinh Joint Stock Mineral Processing Company |
VIETNAM | ||
| Tin |
Super Ligas |
BRAZIL | ||
| Tin |
PT O.M. Indonesia |
INDONESIA | ||
| Tin |
Pongpipat Company Limited |
MYANMAR | ||
| Tungsten |
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
CHINA | ||
| Tungsten |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
CHINA | ||
| Tungsten |
Ganzhou Yatai Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Ganzhou Haichuang Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
CHINA | ||
| Tungsten |
Hunan Litian Tungsten Industry Co., Ltd. |
CHINA |
A-9