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 | Not Applicable | |||
|
(State or other jurisdiction of incorporation or organization) |
(Commission file number) | (IRS Employer Identification No.) |
Kornit Digital Ltd.
12 Ha`Amal St., Afek Park, Rosh-Ha`Ayin 4809246, Israel
Tel: +972.3.908.5800, Fax: +972.3.908.0280
Web : www.kornit.com , Email: legal@kornit.com
(Address of principal executive offices)
Alon Rozner, Chief Financial Officer , +97235148777
(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, 2020.
Section 1- Conflict Minerals Disclosures
Item 1.01 Conflict Minerals Disclosure and Report
A copy of Kornit Digital Ltd.’s (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/
The contents of the any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Item 1.02 Exhibit
The Company has filed its Conflict Minerals Report as Exhibit 1.01 hereto as required by Item 1.01 of Form SD.
Section 2- Exhibits
| Exhibit 1.01 - | Conflict Minerals Report is attached per Section 1 of this Form. |
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
Kornit Digital Ltd.
(Registrant)
| /s/ Alon Rozner | May 27, 2021 |
| By: Alon Rozner | |
| Chief Financial Officer |
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Exhibit 1.01
Conflict Minerals Report of Kornit Digital Ltd.
Introduction
Kornit Digital Ltd. (“Kornit,” “we,” the “Company” or “our company”) develops, designs and markets innovative digital printing solutions for the global printed textile industry, with a major focus on the fashion, apparel and home décor segments of the industry.
Our vision is to create a better world where everybody can bond, design and express their identities, one impression at a time.
Our mission is to revolutionize the fast-changing industry by facilitating and expediting the transition from analog processes that have not evolved for decades and are not fit for the rapidly changing business models and self-disruption needs of the industry, to digital methods of garment, apparel and home decor finished goods production and decoration that address the contemporary supply, demand, social and environmental needs of the industry in which we operate.
We focus on the rapidly growing high throughput, direct-to-garment, or DTG, and Direct-to-Fabric, or DTF, segments of the printed and decorated textile industry. Our solutions include our proprietary digital printing systems, ink and other consumables, associated software and value-added services that allow for quality and cost-effective large-scale printing of short runs of complex images and designs directly on finished garments and fabrics. Our solutions address the growing production gaps reflected in the need to shift to shorter runs, proximity production, proximity decoration, partial or full on-demand production, and microfactory models by enabling our customers to print and decorate high quality products in a time efficient, cost-effective and environmentally-friendly manner. This allows textile manufacturers to transition from their traditional business and operating models of supply based on demand predictions, to partial or full on-demand or made-to-order models, by which decoration of fabric and production of finished goods only takes place once a customer order has been issued.
Our solutions are differentiated from other digital methods of production because they eliminate the need to pre-treat fabrics prior to printing, thereby offering our customers the ability to digitally print high quality images and designs on a variety of fabrics in a streamlined and environmentally-friendly manner. When compared to analog methods of production, our solutions also significantly reduce production lead times and enable customers to more efficiently and cost-effectively produce smaller quantities of individually printed designs, thereby mitigating the risk of excess inventory, which is a significant challenge for the industry.
The success of evolving omni-channel apparel retail is dependent heavily on the ability to show a large variety of designs. Since it is more and more difficult to predict consumer preferences and demand, it is increasingly difficult to stock every possible design. Having digital capacity available allows printers, brands and retailers to offer unlimited design with minimal to no inventory risk. We believe we are well positioned to continue taking advantage of this trend.
Our DTG solutions utilize our patented wet-on-wet printing methodology that eliminates the common practice of separately coating and drying textiles prior to printing. This methodology also enables printing on a wide range of untreated natural, synthetic and man-made fabrics, including cotton, wool, polyester, lycra and denim. With throughputs ranging from 40 to 235 garments per hour, our entry level, industrial and mass production DTG solutions are suited to the needs of a variety of customers, from smaller industrial operators with limited budgets to mass producers with complex manufacturing requirements. Our patented NeoPigment ink and other consumables have been specially formulated to be compatible with our systems and overcome the quality-related challenges that pigment-based inks have traditionally faced when used in digital printing. Our software solutions simplify order to production workflows in the printing process, by offering a complete solution from web and traditional order intake through graphic job preparation and execution. We also offer customers maintenance and support services, as well as value-added services and application consulting, aimed at optimizing the number of impressions printed by our systems.
We have also recently (in April 2019) supplemented our original DTG printing technology with our Kornit NeoPoly Technology, which is our industry’s first digital, industrial process for high-quality printing on polyester, thereby opens the large sport and athleisure market to our digital printing solutions. The new Kornit NeoPoly Technology addresses existing challenges with a new process and ink set implemented in the Kornit NeoPigmentT process. Our new process handles polyester applications without having to compromise on design, run size, substrate or labor. The breakthrough technological innovation has been achieved by an innovative ink set and a physical and chemical process specifically developed for low-temperature curing, and polyester-enhancing functionalities developed to maintain fabric characteristics and provide superior fastness. This unique process overcomes dye migration on polyester. The inks are Eco-Passport certified, and do not contain PVCs or any other toxic ingredients. The first system equipped with our Kornit NeoPoly Technology is the Kornit Avalanche Poly Pro, a member of our industrial platform, which became commercially available in April 2019.
Building on the expertise and capabilities that we have accumulated in developing and offering differentiated solutions for the industrial DTG market, we also market an industrial digital printing solution, the Kornit Presto, which targets the on-demand DTF market. While the DTG market generally involves printing on finished garments, the DTF market is focused on printing on fabrics that are subsequently converted into finished garments, home or office décor, and other items. The Kornit Presto (like our predecessor DTF product, the Kornit Allegro) utilizes our proprietary wet-on-wet printing methodology and houses an integrated curing system. It offers the sole (following its predecessor, the Allegro) single-step, eco-friendly, stand-alone industrial DTF digital textile printing solution available on the market. We primarily market the Kornit Presto to businesses seeking horizontal or vertical expansions into fabric decoration, such as innovative web-based businesses operating on-demand business models that require a high degree of variety and limited quantity orders, as well as to fabric converters, which source large quantities of fabric and convert untreated fabrics into finished materials to be sold to garment and home décor manufacturers, and to sustainable fashion producers seeking a competitive edge in today’s changing supply chains. We believe that with the Presto we are well positioned to take advantage of the growing trend towards customized fashion, home décor and on-demand fabric printing, with increased focus on sustainable production. We began selling the Presto commercially in the second quarter of 2019 (after having introduced our initial DTF digital textile printing solution, the Kornit Allegro, four years earlier, in the second quarter of 2015).
Kornit Digital Ltd. was founded in 2002 in Israel, shipped its first system in 2005 and, as of December 31, 2020, had approximately 1,300 active customers globally. As of December 31, 2020, we had 672 employees located primarily across four regions: Israel, America, Europe and Asia Pacific. In the year ended December 31, 2020, we generated revenues of $193.3 million, representing an increase of 7.5% over the prior fiscal year. In the year ended December 31, 2020, we generated 68.7% of our revenues from the Americas region, 23.9% from the Europe, Middle East and Asia (“EMEA”) region, and 7.4% from the Asia Pacific region.
As an SEC-registered issuer that offers products that include tin, tungsten, tantalum and gold (“Conflict Minerals”) that are necessary for the production and/or functionality of those 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”). As part of our company’s desire to take responsibility for and concern ourselves with human rights issues, we decided to review our company’s supply chain according to the EU regulation’s guidance as well, and, based on that guidance, have included conflict-affected or high-risk areas (“CAHRAs”) when approaching suppliers for information. As such, we conduct due diligence on our minerals supply chain according to the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) and related Supplements (the “OECD Due Diligence Guidance”). It should be noted that our company does not directly purchase or procure raw materials from the mine sites, as we are a downstream company. Instead, we or our suppliers purchase cassiterite, columbite-tantalite (coltan), wolframite, gold, or their derivatives, which presently are limited to tin, tantalum, tungsten, and gold (collectively “3TG”) - related materials, after processing by smelters or refiners.
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.
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If a registrant cannot establish with absolute certainty that the necessary 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 Form SD that describes the steps that the registrant took to determine the origin, or likely origin, of the necessary conflict minerals in its products or in the manufacture of its products.
If a registrant has reason to believe that any of the conflict minerals in its mineral supply chain may have originated in the DRC and/or a Covered Country, or if the registrant is unable to determine the absolute 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.
Kornit is committed to responsible sourcing practices and ensuring that it does not benefit, directly or indirectly, from the propogation of armed conflict or human rights abuses in areas of conflict, such as the CAHARAs. The goal of the due diligence process is not to eliminate sourcing from the CAHARAs, 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, which were necessary to the functionality or production of our products manufactured or contracted to manufacture in 2020, 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 2020 calendar year, we have 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 an RCOI simultaneously with the due diligence phase in which we engaged to determine whether the Conflict Minerals necessary for the functionality or production of our products did or did not receive 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, or likely originated, from CAHRAs
The following steps were performed to determine the applicable suppliers list:
| a) | A suppliers list, which we purchased from during the calendar year 2020, was issued using the ERP system by the purchasing department manager. The total number of the suppliers in the list was 103 suppliers / 540 manufacturers with according to business activity in 2020. |
| b) | As part of our risk-based approach, we selected all suppliers above 10,000$ purchasing during FY2020. This resulted in a list of 53 suppliers and 389 manufacturers (AVL). |
| c) | In order to reduce the risk of not getting full and reliable information we have decided not to rely solely on our tier 1 suppliers to provide information on their entire supply chain, and to approach directly also the electronic manufacturers, even though we have not purchased from them directly. |
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| d) | The list of manufacturers was segmented into the following categories according to the type of material each manufacturer provides: (including non-AVL manufacturing) |
| i. | Electronics |
| ii. | Metal |
| iii. | Kit/Assy |
| iv. | Chemicals |
| v. | Plastic |
| vi. | Fasteners |
| vii. | Software |
| e) | Out of the 389 manufacturers identified, we categorized 303 manufacturers as relevant for our conflict minerals inquiry and 86 as irrelevant for the process. The following suppliers’ categories were excluded from the list by our project manager (engineering aspects), since the suppliers provide components which are either not necessary for the functionality or production of the products: “General”, or do not contain the 3TG: “Chemicals”, “Plastic”, “Fasteners” and “Software”, as defined by the Engineering & Procurement department. |
| f) | The total number of suppliers/ manufacturers was 303. |
Since our supply chain is multiple tiers removed from the relevant smelters or refiners, we rely on our direct suppliers and manufacturers to provide information on the origin of the conflict minerals contained, or likely contained, in the components that are included in our products.
| g) | We solicited survey responses using the Conflict Minerals Reporting Template (“CMRT”) versions 6.01 or 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. |
| h) | We assessed 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. |
| i) | 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 that are necessary for the functionality of its products originated, or likely originated, in the CAHRAs, and has reason to believe that those necessary Conflict Minerals may not be from entirely recycled or scrap sources. As part of our commitment to responsible sourcing we do not seek to eliminate the sourcing of Conflict Minerals from the CAHRAs, 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, we conducted due diligence activities and have detailed those efforts in this Conflict Minerals Report.
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 for the functionality or production of our products, which were manufactured, or contracted to manufacture in 2020, did or did not originate from smelters or refiners (“SoRs”) that have received a conformant or active designation from the RMI’s RMAP Third Party Audit program for smelters or 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”) and related supplements for Conflict Minerals.
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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) carrying out independent third-party audits of smelters’ and refiners’ due diligence practices; and (5) reporting annually on supply chain due diligence.
Due Diligence Performed
The due diligence measures we undertook consisted primarily of:
a. Establishing strong company management systems
We reviewed and maintained our management systems that had been previously established through the following actions:
| ● | As part of our policy, Kornit strives to only use 3TG minerals from smelters or refiners that have been audited and verified as conflict-free conformant or active by the Responsible Minerals Assurance Process (“RMAP”) and requires its suppliers to only source 3TG minerals from verified smelters or 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: our steps for compliance, objectives, time lines, internal management and cross functional team (such as supplier management, engineering, finance and legal) 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 6.01 or above). |
| ● | Maintained a Conflict Minerals provision in 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 Global Product Regulation and Sustainability Manager (at zach.teplitzki@kornit.com). |
| ● | Maintain 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 electronics suppliers and manufacturers. 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 2020 and the extent to which we are 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, 91.7% of our direct level 1 suppliers and manufacturers list 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 6.01 and above, which requests suppliers and manufactures to identify smelters or refiners and the country of origin, or likely country of origin, of the conflict minerals in the products that they supply to us. In addition, we compared smelters or refiners identified in 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, or likely country of origin, information for the smelters or refiners identified in the supply chain survey as provided from the different sources, as reported in Annex 2.
c. Designed and implemented a strategy to respond to identified risks
The findings of the supply chain risk assessment and due diligence process are reported to designated members of our senior management team— our CFO, EVP Operation, General Counsel and ESG Director, Supply Chain Director and CEO, 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 we investigate the suppliers’ sourcing practices.
We contact suppliers whose responses are identified as incomplete, inconsistent or inaccurate. We also review supplier responses to track smelters or 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.
We 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 unresponsive suppliers as well as those suppliers declaring the existence of Conflict Minerals in their supply chain from the CAHRAs from uncertified smelters or refiners, according to the RMI’s Standard Smelter List that provides an indication of all of the smelters or refiners that are conformant or active according to the RMAP audit. These are suppliers that we classify as high risk.
Our supply chain due diligence is a dynamic process and requires on-going risk monitoring. Therefore, after implementing our risk mitigation strategy, we repeat Step 2 of the OECD guidelines to ensure effective management of risks We have established procedures for employees, stakeholders, direct suppliers, and customers to communicate concerns about our responsible sourcing policies.
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d. Reviewed independent third-party audit of smelter/refiner due diligence practices
We are a downstream company and are multiple layers removed from the smelters or refiners that directly process the minerals and mineral ores that are essential to the production or functionality of our products, i.e., the necessary Conflict Minerals. Our constitution as a downstream company means that we do not directly perform audits of the smetlers or refiners in its mineral supply chain. As a result, our due diligence efforts relied on reviewing information on the status of smelters or refiners participating in Third Party Audit programs and cross-industry initiatives, such as those led by the RMI’s RMAP.
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: https://ir.kornit.com/financial-information/sec-filings?items_per_page=10&page=2
Results of Assessment
We conducted a supply-chain survey of the 303 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 59.74%, which responses contained the names and locations of smelters or refiners (see Annex 1) and the reasonable countries of origin see (Annex 2) that process Conflict Minerals. We have identified that, out of the responses received, 91.7% of Kornit’s relevant suppliers have a policy in place that addresses the sourcing of Conflict Minerals.
Of this response rate (i.e. the relevant suppliers that responded to the supply chain inquiry in 2020):
| ● | 59.74% of suppliers delivered a completed CMRT - (181 of 303 total suppliers) |
| ● | 3.90% of suppliers were classified as “DRC conflict free” – (7 of 181 responding suppliers) |
| ● | 19.35% of suppliers were classified as “Free no 3TG” – (35 of 181 responding suppliers) |
| ● | 11.00% of suppliers were classified as “Undefined from DRC” – (19 of 181 responding suppliers) |
| ● | 5.53% of suppliers were classified as “Undetermined not from DRC” – (10 of 181 responding suppliers) |
| ● | 60.22% of suppliers were classified as “Undetermined from DRC” – (109 of 181 responding suppliers) |
| ● | 0% of suppliers were classified as “Not from DRC” – (0 of 181 responding suppliers) |
The terms above have the following meaning as part of our due diligence efforts:
| ● | “DRC conflict free” indicates 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 or refiners are approved by the RMI RMAP Program (“Responsible Minerals Assurance Process”). |
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| ● | “Free no 3TG” indicates the in-scope suppliers that reported that Conflict Minerals are not contained in the product, nor are they necessary for the functionality or included in the production of the products provided to Kornit. |
| ● | “Undefined from DRC” indicates the in-scope suppliers that reported the Conflict Minerals being used in the products provided to Kornit originate, or likely originate from the DRC or the Covered Countries. The smelters or refiners are not approved by the RMI’s RMAP. |
| ● | “Undetermined not from DRC” indicates 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 the in-scope suppliers that reported that the Conflict Minerals being used in the products provided to Kornit originate, or likely originate, in the DRC or the Covered Countries and the smelters or refiners 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 the in-scope suppliers that reported 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, or likely source, and chain of custody of the necessary conflict minerals as the information comes from our direct 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 or refiners, or other relevant Third Party Audit bodies.
Despite the fact that some suppliers indicated that they source from the CAHRAs, these suppliers were unable to accurately report the specific smelters and/or refiners that were part of the supply chain for the components that were sold and which are necessary to the production and/or functionality of our products in 2020. Based on the lack of complete information from our suppliers, we are unable to determine with complete certainty 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 our products may or may not have directly or indirectly financed armed groups in the CAHRAs. Our efforts to determine the mine(s) or location of origin included the use of the due diligence measures described above.
Smelters or refiners verified as conflict free or in the audit process:
| Tin | 49 of 59 (83.05%) - (47 compliant and 2 active smelters or refiners) | |
| Tantalum | 37 of 38 (97.37%) - (37 compliant and 0 active smelters or refiners) | |
| Tungsten | 46 of 53 (86.79%) - (41 compliant and 5 active smelters or refiners) | |
| Gold | 109 of 158 (68.99%) - (105 compliant and 4 active smelters or refiners) | |
| Total | 241 of 308 (78.25%) - (230 compliant and 11 active smelters or refiners) |
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Smelters or refiners:
| 2020 | ||||
| Verified Conflict Free | 230 (74.67 | %) | ||
| Participating in an audit process | 11 (3.57 | %) | ||
| Not Participating | 67 (21.75 | %) | ||
| Total | 308 (100 | %) |
Additional Risk Factors
The statements above are based on the RCOI process and supply due diligence performed by us in good faith in 2020. 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 2020, and smuggling of Conflict Minerals to countries beyond the CAHRAs.
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 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
We will continue working with our global supply chain to ensure responsible sourcing and to assure compliance with international regulations, including the following actions:
| ● | Continue to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals, as required by Rule 13p-1. |
| ● | Work with suppliers that did not respond to our 2020 survey to help them understand the importance of this initiative to Kornit and to encourage their participation in the 2021 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 or refiner validation program. |
| ● | Send follow up letters to high risk unresponsive suppliers, and to suppliers with Conflict Minerals from the DRC and the CAHRAs from uncertified smelters. |
| ● | Continue to implement our CM policy. |
| ● | Enhance use of tools for improved supplier responses. |
| ● | Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts. |
| ● | Request suppliers to procure materials through validated smelters or refiners pursuant to the RMI or other approved resources and request suppliers to take mitigating actions in case they do not. |
| ● | Establishing a Conflict Minerals company procedure. |
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Annex 1
Reported Names and Locations of Smelters or Refiners
| Metal | Smelter or Refiner Name | Smelter or Refiner Country | ||
| Gold | 8853 S.p.A. | ITALY | ||
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||
| Gold | African Gold Refinery | UGANDA | ||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||
| 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 | Asahi Refining Canada Ltd. | CANADA | ||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||
| Gold | Asaka Riken Co., Ltd. | JAPAN | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||
| Gold | AU Traders and Refiners | SOUTH AFRICA | ||
| Gold | Augmont Enterprises Private Limited | INDIA | ||
| Gold | Aurubis AG | GERMANY | ||
| Gold | Bangalore Refinery | INDIA | ||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||
| Gold | Boliden AB | SWEDEN | ||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | ||
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | ||
| Gold | Caridad | MEXICO | ||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | ||
| Gold | CGR Metalloys Pvt Ltd. | INDIA | ||
| Gold | Chimet S.p.A. | ITALY | ||
| Gold | Chugai Mining | JAPAN | ||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||
| Gold | Dowa | JAPAN | ||
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
10
| Metal | Smelter or Refiner Name | Smelter or Refiner Country | ||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | ||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||
| Gold | Gold Coast Refinery | GHANA | ||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||
| Gold | Guangdong Jinding Gold Limited | CHINA | ||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||
| 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 | International Precious Metal Refiners | UNITED ARAB EMIRATES | ||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||
| Gold | Istanbul Gold Refinery | TURKEY | ||
| Gold | Italpreziosi | ITALY | ||
| Gold | JALAN & Company | INDIA | ||
| Gold | Japan Mint | JAPAN | ||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | ||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | ||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||
| Gold | Kazzinc | KAZAKHSTAN |
11
| Metal | Smelter or Refiner Name | Smelter or Refiner Country |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold | Kundan Care Products Ltd. | INDIA | ||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | ||
| Gold | Lingbao Gold Co., Ltd. | CHINA | ||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||
| Gold | L’Orfebre S.A. | ANDORRA | ||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||
| Gold | Marsam Metals | BRAZIL | ||
| Gold | Materion | UNITED STATES OF AMERICA | ||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||
| 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 | MMTC-PAMP India Pvt., Ltd. | INDIA | ||
| Gold | Modeltech Sdn Bhd | MALAYSIA | ||
| Gold | Morris and Watson | NEW ZEALAND | ||
| 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 | NH Recytech Company | KOREA, REPUBLIC OF | ||
| Gold | Nihon Material Co., Ltd. | JAPAN | ||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
12
| Metal | Smelter or Refiner Name | Smelter or Refiner Country |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||
| Gold | PAMP S.A. | SWITZERLAND | ||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | ||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||
| Gold | Planta Recuperadora de Metales SpA | CHILE | ||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||
| Gold | PX Precinox S.A. | SWITZERLAND | ||
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | ||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | ||
| Gold | REMONDIS PMR B.V. | NETHERLANDS | ||
| Gold | Royal Canadian Mint | CANADA | ||
| Gold | SAAMP | FRANCE | ||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||
| Gold | Safimet S.p.A | ITALY | ||
| Gold | SAFINA A.S. | CZECHIA | ||
| Gold | Sai Refinery | INDIA | ||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | ||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||
| Gold | Shirpur Gold Refinery Ltd. | INDIA | ||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||
| Gold | Sovereign Metals | INDIA | ||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||
| Gold | Sudan Gold Refinery | SUDAN |
13
| Metal | Smelter or Refiner Name | Smelter or Refiner Country | ||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold | T.C.A S.p.A | ITALY | ||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||
| 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 | Tony Goetz NV | BELGIUM | ||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||
| Gold | Torecom | KOREA, REPUBLIC OF | ||
| Gold | Umicore Brasil Ltda. | BRAZIL | ||
| Gold | Umicore Precious Metals Thailand | THAILAND | ||
| 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 | WIELAND Edelmetalle GmbH | GERMANY | ||
| Gold | Yamakin Co., Ltd. | JAPAN | ||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | ||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||
| Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA | ||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | ||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | ||
| Tantalum | Global Advanced Metals Aizu | JAPAN | ||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | ||
| 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 | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
14
| Metal | Smelter or Refiner Name | Smelter or Refiner Country |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | ||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||
| Tantalum | KEMET Blue Metals | MEXICO | ||
| 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 | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||
| Tantalum | NPM Silmet AS | ESTONIA | ||
| Tantalum | PRG Dooel | NORTH MACEDONIA | ||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||
| 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 | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||
| Tin | Alpha | UNITED STATES OF AMERICA | ||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||
| Tin | China Tin Group Co., Ltd. | CHINA | ||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||
| Tin | Dowa | JAPAN | ||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||
| Tin | Estanho de Rondonia S.A. | BRAZIL | ||
| Tin | Fenix Metals | POLAND | ||
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | ||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
15
| Metal | Smelter or Refiner Name | Smelter or Refiner Country |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||
| Tin | Luna Smelter, Ltd. | RWANDA | ||
| Tin | Ma’anshan Weitai Tin Co., Ltd. | CHINA | ||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | ||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | ||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||
| Tin | Metallo Belgium N.V. | BELGIUM | ||
| Tin | Metallo Spain S.L.U. | SPAIN | ||
| Tin | Mineracao Taboca S.A. | BRAZIL | ||
| Tin | Minsur | PERU | ||
| Tin | Mitsubishi Materials Corporation | JAPAN | ||
| Tin | Modeltech Sdn Bhd | MALAYSIA | ||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||
| Tin | Pongpipat Company Limited | MYANMAR | ||
| Tin | Precious Minerals and Smelting Limited | INDIA | ||
| Tin | PT Artha Cipta Langgeng | INDONESIA | ||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||
| Tin | PT Bangka Serumpun | INDONESIA | ||
| Tin | PT Mitra Stania Prima | INDONESIA | ||
| Tin | PT Mitra Sukses Globalindo | INDONESIA | ||
| Tin | PT Refined Bangka Tin | INDONESIA | ||
| Tin | PT Timah Tbk Kundur | INDONESIA | ||
| Tin | PT Timah Tbk Mentok | INDONESIA | ||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||
| Tin | Soft Metais Ltda. | BRAZIL | ||
| Tin | Super Ligas | BRAZIL | ||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||
| Tin | Thaisarco | THAILAND | ||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
16
| Metal | Smelter or Refiner Name | Smelter or Refiner Country |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||
| Tin | Yunnan Tin Company Limited | CHINA | ||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||
| Tungsten | ACL Metais Eireli | BRAZIL | ||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten | China Molybdenum Co., Ltd. | CHINA | ||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||
| Tungsten | CP Metals Inc. | UNITED STATES OF AMERICA | ||
| Tungsten | Cronimet Brasil Ltda | BRAZIL | ||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||
| Tungsten | GEM Co., Ltd. | CHINA | ||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||
| Tungsten | JSC “Kirovgrad Hard Alloys Plant” | RUSSIAN FEDERATION |
17
| Metal | Smelter or Refiner Name | Smelter or Refiner Country |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | ||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | ||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | ||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | ||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
18
Annex 2
Reported Country of Origin
| GOLD | TANTALUM | TIN | TUNGSTEN | |||
| ITALY | JAPAN | UNITED STATES OF AMERICA | BRAZIL | |||
| UNITED STATES OF AMERICA | CHINA | VIET NAM | VIET NAM | |||
| UGANDA | UNITED STATES OF AMERICA | CHINA | CHINA | |||
| UNITED ARAB EMIRATES | THAILAND | JAPAN | UNITED STATES OF AMERICA | |||
| GERMANY | GERMANY | BOLIVIA (PLURINATIONAL STATE OF) | GERMANY | |||
| UZBEKISTAN | MEXICO | BRAZIL | RUSSIAN FEDERATION | |||
| BRAZIL | BRAZIL | POLAND | JAPAN | |||
| SWITZERLAND | INDIA | RWANDA | KOREA, REPUBLIC OF | |||
| JAPAN | ESTONIA | MALAYSIA | TAIWAN, PROVINCE OF CHINA | |||
| CANADA | NORTH MACEDONIA | BELGIUM | PHILIPPINES | |||
| TURKEY | RUSSIAN FEDERATION | SPAIN | AUSTRIA | |||
| SOUTH AFRICA | KAZAKHSTAN | PERU | ||||
| INDIA | THAILAND | |||||
| PHILIPPINES | PHILIPPINES | |||||
| SWEDEN | MYANMAR | |||||
| COLOMBIA | INDIA | |||||
| MEXICO | INDONESIA | |||||
| CHINA | TAIWAN, PROVINCE OF CHINA | |||||
| KOREA, REPUBLIC OF | ||||||
| ZIMBABWE | ||||||
| GHANA | ||||||
| RUSSIAN FEDERATION | ||||||
| KAZAKHSTAN | ||||||
| POLAND | ||||||
| KYRGYZSTAN | ||||||
| SAUDI ARABIA | ||||||
| ANDORRA | ||||||
| SINGAPORE | ||||||
| MALAYSIA | ||||||
| NEW ZEALAND | ||||||
| AUSTRIA | ||||||
| CHILE | ||||||
| INDONESIA | ||||||
| NETHERLANDS | ||||||
| FRANCE | ||||||
| CZECHIA | ||||||
| SPAIN | ||||||
| TAIWAN, PROVINCE OF CHINA | ||||||
| LITHUANIA | ||||||
| SUDAN | ||||||
| BELGIUM | ||||||
| THAILAND | ||||||
| AUSTRALIA |
19