UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT*
Kornit Digital Ltd.
(Exact name of registrant as specified in its charter)
Israel | 001-36903 |
Not Applicable | ||
(State or other jurisdiction of | (Commission file number) | (IRS Employer | ||
incorporation or organization) | Identification No.) |
12 Ha`Amal St., Afek Park, Rosh-Ha`Ayin 4809246, Israel
(Address of principal executive offices)
Guy Avidan, Chief Financial Officer, +972-3-908-5866
(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, 2018.
Section 1 - Conflict Minerals Disclosures
Item 1.01 Conflict Minerals Disclosure and Report
A copy of the Kornit Digital Ltd. (“Kornit” or the “Company”) Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD and is publicly available at: http://www.kornit.com/conflict-minerals-policy/.
Section 2- Exhibits
Exhibit 1.01 - Conflict Minerals Report is attached per Section 1. |
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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.
Kornit Digital Ltd.
(Registrant)
/s/ Guy Avidan | May 29th, 2019 | |
By: Guy Avidan | ||
Chief Financial Officer |
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Exhibit 1.01
Conflict Minerals Report of Kornit Digital Ltd.
Introduction
Kornit develops, manufactures and markets industrial and commercial printing solutions for the garment, apparel and textile industries. Leading the digital textile printing industry with our revolutionary NeoPigmentTM process including an integrated pretreatment solution, Kornit caters directly to the needs of both designers and manufacturers.
Founded in 2002 by seasoned professionals with extensive experience in the digital printing industry, we are the only company to provide our customers with a complete digital printing solution, from start to finish. We insist that customers should enjoy the best of the best – software, support and high-end technology, all in an environmentally sustainable way.
Based on our proprietary ground-breaking technology and our in-house chemistry development, Kornit introduces the Kornit's line of high-speed DTG printers, known to be the first industrial digital printers offering direct to garment printing. With our immense experience in the direct to garment market, we are revolutionizing the roll fabric industry with our single step solution that enables printing with one ink set on all types of fabric and with no additional finishing process.
Our product portfolio consists of two series of systems and the consumables used in those systems. These series are the DTG printers and the Roll to Roll printer. Collectively, this portfolio offers a variety of performance options for our customers, depending on their desired application, as well as on the nature and size of the designs. Our wide range of systems allows us to offer our customers systems at a number of different price points, depending on the features that our customers desire.
As an SEC-registered issuer that offers products that include tin, tungsten, tantalum and gold (“Conflict Minerals”) that are necessary to the production and/or functionality of our manufactured products, we are subject to Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 Section 1502 reporting requirements associated with Conflict Minerals, and the SEC’s Rule 13p-1 (the “Rule”).
Rule overview and scope:
The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products.
If a registrant cannot establish that the conflict minerals in its products originated from sources other than the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”), or originate solely from recycled and/or scrap sources, the registrant must submit a specialized disclosure report under the Form SD that describes the steps that the registrant took to determine the origin of the necessary conflict minerals in its products or necessary to the manufacture of its products.
If a registrant has reason to believe that any of the conflict minerals in its supply chain may have originated in the DRC and/or a Covered Country, or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody, and the registrant must annually submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
The goal of the due diligence process is not to eliminate sourcing from the DRC and the Covered Countries, but rather to ascertain, to our best possible knowledge and per the requirements of the Rule, the most reasonable country of origin of the necessary conflict minerals, as detailed in the reasonable country of origin inquiry (RCOI) section below.
Reasonable Country of Origin Inquiry (RCOI)
Kornit is committed to ethical practices and compliance with all applicable laws and regulations. We are committed to working with our customers and suppliers to responsibly source the materials and components that we use to manufacture our products that may contain the necessary conflict minerals.
In accordance with our Conflict Minerals Policy, which can be viewed at:
http://www.kornit.com/conflict-minerals-policy/, Kornit has concluded in good faith that during the 2018 calendar year, we manufactured and contracted to manufacture products containing all four Conflict Minerals and have determined that the use of these minerals is necessary to the functionality or production of our products.
We performed a reasonable country of origin inquiry (“RCOI”) simultaneously with the due diligence phase in which we engaged to determine whether the Conflict Minerals necessary to the functionality or production of our products did or did not received a conformant or active designation from the Responsible Minerals Initiative's (“RMI”) independent smelter and refiner validation program, i.e., the Responsible Minerals Assurance Process (“RMAP”). This was conducted simultaneously due to the large number of applicable suppliers from which we source materials that we surveyed and the time frame in which we needed to complete both the RCOI and due diligence efforts. Our RCOI employed several methods to assess whether the necessary Conflict Minerals in our products originated from the Democratic Republic of the Congo or a country that shares an internationally recognized border with the Democratic Republic of the Congo.
The following steps were performed to determine the applicable suppliers list:
a) | A suppliers list, which Kornit purchased from during the calendar year 2018, was issued using the ERP Priority system by the purchasing department manager. As part of our risk-based approach we identified suppliers from which we purchased goods directly (“Tier 1 Suppliers”), as well as electronic manufacturers that our Tier 1 Suppliers contracted in order to supply us the goods. In order to reduce the risk of not getting full information we decided not to rely solely on our Tier 1 Suppliers to provide information on their entire supply chain, and to directly approach also the electronic manufacturers, even though we have not purchased from them directly. The total number of the suppliers and manufacturers in the list was 334. The list was then segmented according to the type of material the supplier provides. Some of the categories were excluded since they were not necessary to the functionality or production of the products. The categories that were excluded are: “Papers”, “Chemicals”, “Plastic”, “Metal”, “Motion”, “Software” and “Rubber”. |
The final list included 228 suppliers and manufacturers related to the “Electronics” category.
Since our supply chain is multiple tiers removed from the relevant smelters and refiners, we rely on our direct suppliers and manufacturers to provide information on the origin of the conflict minerals contained in the components that are included in our products.
b) | Solicited survey responses using the Conflict Minerals Reporting Template (CMRT) versions 5.01 and above, designed by the Responsible Minerals Initiative (RMI). We engaged our supply chain to respond to the Conflict Minerals Reporting Template by referring suppliers to training materials that included an overview of the law and instructions on how to complete the Conflict Minerals Reporting Template. |
c) | Assessment of responses received for information that would identify as inconsistent, incomplete, or inaccurate responses. Responses that failed any of the “red flag” review tests were identified for additional follow up. |
d) | To non-responsive suppliers, we sent periodic reminders to provide surveys or updated responses. |
Based on the RCOI conducted, Kornit has reason to believe that a portion of the Conflict Minerals necessary to the functionality of its products originated in the Democratic Republic of the Congo or Covered Countries and knows, or has reason to believe, that those necessary Conflict Minerals may not be from recycled or scrap sources. Kornit does not seek to eliminate the sourcing of Conflict Minerals originating the in DRC and/or the Covered Countries, but rather to source the necessary minerals from sources that do not directly or indirectly finance or benefit armed groups in those locations. Based on this result, Kornit conducted due diligence activities and details these efforts in this Conflict Minerals Report.
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Due Diligence
Design of Due Diligence
In accordance with Rule 13p-1 and Form SD, we undertook due diligence to determine whether the Conflict Minerals necessary to the functionality or production of our products did or did not receive a conformant or active designation from the RMI's RMAP program for the validation of smelters and refiners. We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD, 2016) (“OECD Framework” http://www.oecd.org/corporate/mne/mining.htm) and related supplements for Conflict Minerals.
The five steps defined in the OECD Due Diligence Guidance are: (1) establishment of strong internal company management systems; (2) identification and assessment of risks in the supply chain; (3) design and implementation of a strategy to respond to risks as they are identified; (4) carry out independent third-party audits of smelters’ and refiners’ due diligence practices; and (5) report annually on supply chain due diligence.
Due Diligence Performed
The due diligence measures we undertook consisted primarily of:
a. Established strong company management systems
We reviewed and maintained the company management systems previously established through the following actions:
● | As part of our policy, Kornit strives to only use 3TG minerals from smelters that have been audited and verified as conflict free conformant and active by the Responsible Minerals Assurance Process (RMAP) and requires its suppliers to only source 3TG minerals from verified smelters and refiners. More information on our sourcing expectations of suppliers can be found in our Conflict Minerals Policy, which is available at the following link: http://www.kornit.com/conflict-minerals-policy/. |
● | Updated the Conflict Minerals Governance Charter to set the Conflict Minerals annual work plan including: Kornit's steps for compliance, objectives, time lines, internal management and cross functional team with identified roles and responsibilities, all to support supply chain due diligence. |
● | Established a process whereby we engage with suppliers and refer them to training materials online, materials that include an overview of the relevant Conflict Minerals regulations and provide instructions on how to respond to the due diligence survey (that was based on the Conflict Minerals Reporting Template of at least version 5.01 and above). |
● | Maintained a Conflict Minerals provision to our standard Terms and Conditions of Purchase to require suppliers to comply with our Conflict Minerals Policy and requirements. |
● | Maintained a process whereby we communicate the due diligence efforts to customers, suppliers and other relevant functions in our organization, as applicable. |
● | Maintained a grievance mechanism whereby concerns and violations of the Conflict Minerals Policy should be reported to Kornit's Chief Financial Officer and/or Director of global product compliance (at kornit@kornit.com). |
● | Maintaining relevant records for a minimum of five years. |
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b. Identified and assessed risks in the supply chain
As part of our risk-based approach we have decided to focus on suppliers and electronics manufactures. We assessed two primary risks in our supply chain: (1) the risk of not receiving timely and accurate information from the supplier; and (2) the risk of not being able to replace a supplier while trying to move towards the goal of responsibly sourcing all of the minerals and/or materials used in our products.
Based on this assessment method, we segmented our suppliers into three risk levels (high, medium and low). In order to allow us to invest our risk management efforts according to the supplier level of risk, we referred to Conflict Minerals-related risks based on supplier's characteristics, such as: the volume of spending during 2018 and the extent to which the company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers.
As part of the risk assessment phase, we have identified that from the responses received, 66.2% of Kornit's level 1 suppliers and manufacturers listed have a policy in place which addresses the conflict minerals sourcing.
We sent periodic reminders to non-responsive in scope suppliers to provide surveys or updated responses. We have identified, to the best of our efforts, the smelters/refiners in the supply chain by conducting a supply chain survey using the CMRT version 5.01 and above, which requests suppliers and manufactures to identify smelters and refiners and the country of origin of the conflict minerals in the products that they supply to Kornit. In addition, Kornit compared smelters and refiners identified by the supply chain survey against the list of facilities that have received a conformant or active designation from the Responsible Minerals Assurance Process (“RMAP”), or other independent third-party audit programs. We documented country of origin information for the smelters and refiners identified by the supply chain survey as provided from the different sources.
c. Designed and implemented a strategy to respond to identified risks
The findings of the supply chain risk assessment are reported to designated members of our company's senior management team, who are updated regarding major findings and/or red flags, as they arise.. As part of our risk management strategy we continue to conduct business with the red flagged suppliers while Kornit investigates the supplier's sourcing practices.
Kornit contacts suppliers whose responses are identified as incomplete, inconsistent or inaccurate. Kornit also reviews supplier responses to track smelters and refiners in our supply chain that supply us with Conflict Minerals and have not received a conformant or active designation based on the RMI's RMAP or other independent third party validation programs.
Kornit referred suppliers to training materials online that included an overview of the Rule and instructions on how to complete the Conflict Minerals Reporting Template. We also sent follow up letters to non-response suppliers as well as those suppliers who declared the existence of Conflict Minerals in their supply chain from the DRC or adjoining countries from non-certified smelters and refiners, according to the RMI's Standard Smelter List that provides an indication of all of the smelters and refiners that are conformant or active according to the RMAP audit. These are suppliers that we classify as having high risk.
Kornit's supply chain Due Diligence is a dynamic process and requires ongoing risk monitoring. Therefore, after implementing our risk mitigation strategy, Kornit then repeats Step 2 of the OECD guidelines to ensure effective management of risks.
d. Reviewed independent third-party audit of smelter/refiner due diligence practices
Kornit is a downstream company that is multiple layers removed from the smelters and refiners that provide the minerals and mineral ores that are essential to the production or functionality of our products, i.e. the necessary Conflict Minerals, and is many steps removed from smelters and refiners who provide minerals and ores. Therefore, Kornit does not perform audits of smelters and refiners within the supply chain. As a result, Kornit's due diligence efforts relied on reviewing cross-industry initiatives such as those led by the RMI RMAP audit program to conduct smelter and refiner due diligence.
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e. Prepared an annual report on supply chain due diligence
Kornit's Conflict Mineral Policy states that we will comply with Section 1502 of the Dodd Frank Act, which includes filing a Form SD and this Conflict Minerals report with the SEC and posting publicly on the Internet at: http://www.kornit.com/conflict-minerals-policy/.
Results of Assessment
We conducted a supply-chain survey of the 228 direct suppliers and manufacturers that we identified as contributing the necessary conflict minerals to our products. The overall response rate to this survey was approximately 66.2% containing the names and locations of smelters and refiners (see Annex 1) and the reasonable countries of origin see (Annex 2) that process Conflict Minerals.
Of this response rate (of the relevant suppliers that responded):
● | 66.2% suppliers delivered completed CMRT - (151 from 228 total suppliers) |
● | 11.3% suppliers were classified as “DRC conflict free” - (117 from 151 suppliers) |
● | 10.6% suppliers were classified as “Free no 3TG” - (16 from 151 suppliers) |
● | 0% suppliers were classified as “Undefined from DRC” – (0 from 151 suppliers) |
● | 2.6% suppliers were classified as “Undetermined not from DRC” - (4 from 151 suppliers) |
● | 72.2% suppliers were classified as “Undetermined from DRC” - (109 from 151 suppliers) |
● | 3.3% suppliers were classified as “Not from DRC” - (5 from 151 suppliers) |
The terms above have the following meaning as part of our due diligence efforts:
● | “DRC conflict free” indicates that the in-scope suppliers that reported that the Conflict Minerals being used in. the products provided to Kornit originate from the DRC or the Covered Countries, but the smelters are approved by the RMI RMAP Program (Responsible Minerals Assurance Process). |
● | “Free no 3TG” indicates that the in-scope suppliers that reported that Conflict Minerals are not contained in the product, or are not necessary for the functionality or are not included in the production of the products provided to Kornit. |
● | “Undefined from DRC” indicates that the in-scope suppliers that reported the Conflict Minerals being used in the products are originate from the DRC or an adjoining country. The smelters are not approved by the CFS program. |
● | “Undetermined not from DRC” indicates that the in-scope suppliers that reported the Conflict Minerals being used in the products do not originate from the DRC or the Covered Countries, but that they have not yet concluded their due diligence process so this determination could potentially change. Due diligence for these in scope suppliers will continue until the status changes or is confirmed. |
● | “Undetermined from DRC” indicates that the in scope suppliers that reported the Conflict Minerals being used originate from the DRC or the Covered Countries and the smelters are approved by the RMI RMAP program, but they have not yet concluded their due diligence process, so this determination can potentially change. Due diligence for these in scope suppliers will continue until the status changes or is confirmed. |
● | “Not from DRC” indicates that the in-scope suppliers that reported that they were sourcing Conflict Minerals but from countries other than the DRC or the Covered Countries. |
We cannot assert with absolute certainty that our conclusions regarding the source and chain of custody of the necessary conflict minerals as the information comes from our direct and secondary suppliers. However we do work to verify and assess their answers based on the conclusions of an independent third party audit program, i.e. the RMI's RMAP validation program for smelters and refiners.
Despite the fact that some suppliers indicated that they source from the DRC and the Covered Countries, these suppliers were unable to accurately report which specific smelters and/or refiners were part of the supply chain for the components that were sold and that are necessary to the production and/or functionality of Kornit's products in 2018. As a result of this lack of information, Kornit is unable to determine the full list of facilities used to process those necessary Conflict Minerals or their country of origin and to conclude whether or not the Conflict Minerals used in its products may or may not have directly or indirectly financed armed groups in the DRC and the Covered Countries. Kornit's efforts to determine the mine(s) or location of origin included the use of the due diligence measures described above.
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Smelters and refiners verified as conflict free or in the audit process:
Tin | 72 of 83 (86.7%) – (71 compliant and 1 active smelters) | |
Tantalum | 40 of 42 (95.20%) – (40 compliant and 0 active smelters) | |
Tungsten | 40 of 46 (70.0%) – (39 compliant and 1 active smelters) | |
Gold | 104 of 151 (68.9%) – (100 compliant and 4 active smelters) | |
Total | 256 of 322 (79.5%) – (250 compliant and 6 active smelters) |
Status of identified smelters and refiners YoY:
2015 | 2016 | 2017 | 2018 | |||||||||||||
Verified Conflict Free | 216 (66.3 | )% | 242 (69.7 | )% | 254 (78.88 | )% | 250 (77.6 | )% | ||||||||
Participating in an audit process | 28 (8.5 | )% | 14 (4 | )% | 9 (2.8 | )% | 6 (1.9 | )% | ||||||||
Not Participating | 82 (25.2 | )% | 91 (26.3 | )% | 59 (18.32 | )% | 66 (20.5 | )% | ||||||||
Total | 326 (100 | )% | 347 (100 | )% | 322 (100 | )% | 322 (100 | )% |
Count of Smelter Identification RY2018:
Count of all Smelter Identification | Count of compliant Smelter Identification | Count of active Smelter Identification | Count of not approved by RMI Smelter Identification | |||||||||||||
Gold | 151 | 100 | 4 | 47 | ||||||||||||
Tantalum | 42 | 40 | 0 | 2 | ||||||||||||
Tin | 83 | 71 | 1 | 11 | ||||||||||||
Tungsten | 46 | 39 | 1 | 6 | ||||||||||||
Grand Total | 322 | 250 | 6 | 66 |
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Kornit. These statements are based on the infrastructure and information available at the time of the writing and publication of this report. A number of factors could introduce errors or otherwise affect our conclusions.
These factors include, but are not limited to, gaps in product or product content information, gaps in supplier data, errors or omissions by or of suppliers, confusion over requirements of the Rule, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered through a reasonable search, errors in public data, language barriers and translation, supplier unfamiliarity with the Rule, conflict-area sourced materials declared secondary materials, companies that went out of business in 2018, and smuggling of Conflict Minerals to countries beyond the DRC and the Covered Countries.
We do not collect information from our suppliers on a continuous and real-time basis, but rather in the context of the CMRTs provided by the suppliers at the time of the publication of this report. We cannot be certain about our conclusions regarding the source and chain of custody of the necessary Conflict Minerals as the information comes from direct and secondary suppliers though we do verify their declarations against the conclusions of independent third party audit programs, such as the RMI's RMAP program.
Continuous improvement efforts to mitigate risk
Kornit will continue working with its global supply chain to ensure responsible sourcing and to assure compliance with international regulations.
● | Continue to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals, as required by Rule 13p-1. |
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● | Work with suppliers that did not respond to Kornit's 2018 survey to help them understand the importance of this initiative to Kornit and to encourage their participation in the 2019 survey. |
● | Attempt to validate supplier responses using information collected via independent, conflict-free smelter validation programs such as the Responsible Minerals Initiative's (RMI) RMAP smelter and refiner validation program. |
● | Send follow-up letters to high risk non-responsive suppliers, and to suppliers with Conflict Minerals from the DRC and Covered Countries from non-certified smelters. |
● | Continue to implement the company's CM policy. |
● | Enhance use of tools for improved supplier responses. |
Annex 1
Names and Locations of Smelters and Refiners
METAL | SMELTER OR REFINER NAME | SMELTER OR REFINER COUNTRY | ||
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 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||
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 | Caridad | MEXICO | ||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||
Gold | Cendres + Metaux S.A. | SWITZERLAND | ||
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||
Gold | Chimet S.p.A. | ITALY | ||
Gold | Chugai Mining | JAPAN | ||
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||
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 | 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 | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | ||
Gold | Heimerle + Meule GmbH | GERMANY | ||
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | ||
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||
Gold | Istanbul Gold Refinery | TURKEY |
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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 | Kazakhmys Smelting LLC | KAZAKHSTAN | ||
Gold | Kazzinc | KAZAKHSTAN | ||
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | ||
Gold | Lingbao Gold Co., Ltd. | CHINA | ||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||
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 | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||
Gold | Nihon Material Co., Ltd. | JAPAN | ||
Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | ||
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 | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||
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 | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||
Gold | Schone Edelmetaal B.V. | NETHERLANDS | ||
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||
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 |
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Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||
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 | ||
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 | Morris and Watson | NEW ZEALAND | ||
Gold | SAFINA A.S. | CZECH REPUBLIC | ||
Gold | Guangdong Jinding Gold Limited | CHINA | ||
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 | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | ||
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||
Gold | Sudan Gold Refinery | SUDAN | ||
Gold | T.C.A S.p.A | ITALY | ||
Gold | Remondis Argentia B.V. | NETHERLANDS | ||
Gold | Tony Goetz NV | BELGIUM | ||
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | Marsam Metals | BRAZIL | ||
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||
Gold | SAAMP | FRANCE | ||
Gold | L'Orfebre S.A. | ANDORRA | ||
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 | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||
Gold | Sai Refinery | INDIA | ||
Gold | Universal Precious Metals Refining Zambia | ZAMBIA | ||
Gold | Modeltech Sdn Bhd | MALAYSIA | ||
Gold | Bangalore Refinery | INDIA | ||
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 | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | Planta Recuperadora de Metales SpA | CHILE | ||
Gold | Safimet S.p.A | ITALY |
9
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||
Gold | African Gold Refinery | UGANDA | ||
Gold | NH Recytech Company | KOREA, REPUBLIC OF | ||
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | ||
Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | ||
Tantalum | Duoluoshan | 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 Tanbre Co., Ltd. | CHINA | ||
Tantalum | LSM Brasil S.A. | BRAZIL | ||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||
Tantalum | Mineracao Taboca S.A. | BRAZIL | ||
Tantalum | Mitsui Mining and Smelting Co., Ltd. | 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 | ||
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 | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | ||
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 | ||
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 | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||
Tin | Alpha | UNITED STATES OF AMERICA | ||
Tin | CV Gita Pesona | INDONESIA |
10
Tin | PT Aries Kencana Sejahtera | INDONESIA | ||
Tin | PT Premium Tin Indonesia | INDONESIA | ||
Tin | CV United Smelting | INDONESIA | ||
Tin | Dowa | JAPAN | ||
Tin | EM Vinto | BOLIVIA | ||
Tin | Estanho de Rondonia S.A. | BRAZIL | ||
Tin | Fenix Metals | POLAND | ||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||
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 | Jiangxi New Nanshan Technology Ltd. | CHINA | ||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||
Tin | Operaciones Metalurgical S.A. | BOLIVIA | ||
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 Timah (Persero) Tbk Kundur | 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 | ||
Tin | PT Inti Stania Prima | INDONESIA | ||
Tin | CV Ayi Jaya | INDONESIA | ||
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 |
11
Tin | CV Dua Sekawan | INDONESIA | ||
Tin | CV Tiga Sekawan | INDONESIA | ||
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM | ||
Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||
Tin | Super Ligas | 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 | Modeltech Sdn Bhd | MALAYSIA | ||
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 | ||
Tin | Pongpipat Company Limited | MYANMAR | ||
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | ||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||
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 | Jiangxi Minmetals Gao'an Non-ferrous Metals 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 | ||
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 | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Yatai Tungsten 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 | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | ||
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 | ||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
12
Annex 2
Country of Origin
GOLD | TANTALUM | TIN | TUNGSTEN | |||
ANDORRA | BRAZIL | BELGIUM | AUSTRIA | |||
AUSTRALIA | CHINA | BOLIVIA | BRAZIL | |||
AUSTRIA | ESTONIA | BRAZIL | CHINA | |||
BELGIUM | GERMANY | CHINA | GERMANY | |||
BRAZIL | INDIA | INDONESIA | JAPAN | |||
CANADA | JAPAN | JAPAN | KOREA, REPUBLIC OF | |||
CHILE | KAZAKHSTAN | MALAYSIA | PHILIPPINES | |||
CHINA | MACEDONIA | MYANMAR | RUSSIAN FEDERATION | |||
CZECH REPUBLIC | MEXICO | PERU | UNITED STATES OF AMERICA | |||
FRANCE | RUSSIAN FEDERATION | PHILIPPINES | VIETNAM | |||
GERMANY | THAILAND | POLAND | ||||
INDIA | UNITED STATES OF AMERICA | SPAIN | ||||
INDONESIA | TAIWAN, PROVINCE OF CHINA | |||||
ITALY | THAILAND | |||||
JAPAN | UNITED STATES OF AMERICA | |||||
KAZAKHSTAN | VIETNAM | |||||
KOREA | ||||||
KYRGYZSTAN | ||||||
LITHUANIA | ||||||
MALAYSIA | ||||||
MEXICO | ||||||
NETHERLANDS | ||||||
NEW ZEALAND | ||||||
PHILIPPINES | ||||||
POLAND | ||||||
RUSSIAN FEDERATION | ||||||
SAUDI ARABIA | ||||||
SINGAPORE | ||||||
SOUTH AFRICA | ||||||
SPAIN | ||||||
SUDAN | ||||||
SWEDEN | ||||||
SWITZERLAND | ||||||
TAIWAN, PROVINCE OF CHINA | ||||||
THAILAND | ||||||
TURKEY | ||||||
UGANDA | ||||||
UNITED ARAB EMIRATES | ||||||
UNITED STATES OF AMERICA | ||||||
UZBEKISTAN | ||||||
ZAMBIA | ||||||
ZIMBABWE |
13