FREQUENCY ELECTRONICS INC — Regulatory Filings 2026

May 29, 2026

SD 1 feimsd052726.htm FORM SD

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

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FORM SD

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Specialized disclosure report

FREQUENCY ELECTRONICS, INC.

(Exact name of Registrant as specified in its charter)

Delaware	1-8061	11-1986657
(State
or other jurisdiction of Incorporation
or organization)	(Commission
File Number)	(I.R.S.
Employer Identification
No.)

| 55
CHARLES LINDBERGH BLVD., MITCHEL FIELD, N.Y. | 11553 |
| --- | --- |
| (Address
of principal executive offices) | (Zip
Code) |

| Steven
Bernstein |
| --- |
| (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 submitted, 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, 2025.

☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ____.

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Section 1. Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

(c) Conflict Minerals Report

Frequency Electronics, Inc. (the “Company”) evaluated its current product lines and determined that certain products we manufacture contain tin, tungsten, tantalum and/or gold (3TG) necessary to the production or functionality of such products.

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, the instructions to Form SD, and the Public Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued by the Director of the Division of Corporation Finance of the Securities and Exchange Commission on April 29, 2014, the Company is filing herewith a Conflict Minerals Report, which is attached as Exhibit 1.01 and incorporated herein by reference.

The Company’s Conflict Minerals Policy is publicly available at the Company’s website: https://freqelec.com/vendors/. This Form SD, including the Company’s Conflict Minerals Report provided as Exhibit 1.01 hereto, is publicly available at the Company’s website: www.freqelec.com under Investor Relations/Financial/SEC Filings. The content of our website as referred to in this Form SD is included for general information only and is not incorporated by reference into this Form SD.

Item 1.02 Exhibits

Exhibit 1.01 Conflict Minerals Report

Section 2. Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable

Item 3.01 Exhibits

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD.

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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.

| /s/ Steven
L. Bernstein |
| --- |
| Steven
L. Bernstein |
| Chief
Financial Officer, Secretary and Treasurer |

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Conflict Minerals Report

Frequency Electronics Inc. - For the Year Ended December 31, 2025

This Conflict Minerals Report for the year ended December 31, 2025 has been prepared by Frequency Electronics, Inc. (“Frequency” or the “Company,” “we,” “us,” or “our”) and is filed with the Securities and Exchange Commission (“SEC”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”), on a consolidated basis, in accordance with the instructions to Form SD, as modified by the Public Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued by the Director of the Division of Corporation Finance of the SEC on April 29, 2014 (the “SEC Statement”).

In accordance with the instructions to Form SD, as modified by the SEC Statement, this Report outlines the diligence measures undertaken by the Company to assess the source and chain of custody of necessary conflict minerals in its supply chain. This Report is not subject to an independent private sector audit in accordance with the instructions to Form SD and the guidance set forth in the SEC Statement.

Company Overview

Frequency designs, develops and manufactures high precision timing, frequency control and synchronization products for space and terrestrial applications. Frequency’s products are used in satellite payloads and in other commercial, government and military systems including C4ISR (“Command, Control, Communication, Computer, Intelligence, Security and Reconnaissance”), missiles, aircraft, GPS, secure radios, energy exploration and wireline and wireless communication networks. Frequency has received over 100 awards of excellence for achievements in providing high performance electronic assemblies for over 150 space and Department of Defense programs. The Company invests significant resources in research and development and strategic acquisitions world-wide to expand its capabilities and markets.

Introduction

For the 2025 calendar year, Frequency determined that tin, tungsten, tantalum, and/or gold (3TGs) were necessary to the functionality or production of products that were manufactured or contracted to be manufactured. Therefore, Frequency conducted a reasonable country of origin inquiry to determine whether any of the 3TGs in its products originated from Conflict-Affected and High-Risk Areas (CAHRAs), such as the Democratic Republic of the Congo (DRC) or an adjoining country (collectively referred to as the “Covered Countries”).

Based on the country of origin data, Frequency believes its products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), due diligence was performed on the source and chain of custody of the 3TGs in question. The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework of 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 and the related supplements for gold, tin, tantalum, and tungsten (the “OECD Guidance”).

Frequency is committed to complying with the requirements of the Rule and upholding responsible sourcing practices. As such, the Company has put into place a robust due diligence program to ensure its contributions to uphold responsible practices across the supply chain.

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Conflict Minerals Program & Policy

The Company has actively engaged with its customers and suppliers for several years with respect to the use of conflict minerals. Frequency adopted a conflict minerals policy articulating the conflict minerals supply chain due diligence process and the Company’s commitments to reporting obligations regarding conflict minerals. The policy is available online and can be found on our website https://freqelec.com/vendors/ .

Description of Products

The Company’s largest business area is satellite payloads. We provide master timing systems, power converters, and frequency generation, synthesis and distribution systems. Frequency’s products are also incorporated into a variety of C4ISR, secure communications and electronic warfare systems, on ground-based, sea-borne and air-borne platforms.

Our commercial markets also include network infrastructure and other industrial uses. The Company’s products provide precise time distribution for communication networks. Based upon Frequency’s internal assessment, most of the electronic system and subsystem products that we manufacture contain one or more of the 3TGs that are necessary to their functionality or production (“Covered Products”).

Reasonable Country of Origin Inquiry

To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Frequency retained Assent Inc. (“Assent”), a third-party service provider, to assist us in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager.

To trace materials, and demonstrate transparency procured by the supply chain, Frequency utilized the Conflict Minerals Reporting Template (CMRT) Version 6. 5 or higher to conduct a survey of all in-scope suppliers.

During the supplier survey, the Company contacted suppliers via the Assent Compliance Manager, a software-as-a-service (SaaS) platform provided by Assent that enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management.

Through the Assent Compliance Manager and the Assent team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the Assent Compliance Manager for future reporting and transparency. Frequency directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to Assent.

The Company’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which helps identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

Suppliers are contacted regarding invalid forms and are encouraged to correct validated errors to resubmit a valid form. Suppliers are provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses, and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback Frequency tracks program gaps to account for future improvement opportunities.

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For 2025, there were 271 suppliers in scope of the conflict minerals program and 180 provided a completed CMRT. Frequency’s total response rate 2025 was 66.42% . These metrics are summarized in the table below in order to assess progress over time:

Year — 2021	447	61.97 %
2022	545	63.3 %
2023	291	69.42 %
2024	269	70.63 %
2025	271	66.42 %

Through reasonable due diligence practices, Frequency was able to take advantage of a broader set of country of origin data to complement efforts in establishing transparency in the supply chain. Based on the findings, Frequency was unable to determine all the possible countries that the 3TGs used in its products originated from. As such, Frequency performed further due diligence on the source and chain of custody of the minerals in question.

Due Diligence

Design of Due Diligence

Frequency designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance, and the Company continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.

Due diligence requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot be fully controlled by the Company. However, through active risk identification, and risk assessment, as well as continued outreach and process validation, risk gaps have been mitigated. This aligns with industry standards and market expectations for downstream companies’ due diligence.

Due Diligence Performed

1) Establish Strong Company Management Systems

Internal Compliance Team

Frequency established a cross-functional Conflict Minerals Compliance Team led by Dave Tobias Vice President of Manufacturing, also comprising representatives from our purchasing, contracts, and finance teams. Subject matter experts from relevant functions such as purchasing, subcontracts, and engineering support this team. The Conflict Minerals Compliance Team is responsible for implementing our conflict minerals compliance strategy and briefing senior management about the results of our due diligence efforts.

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The Company also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that the Company may undertake with suppliers and/or respective stakeholders in regard to conflict minerals.

The Company leverages Assent’s Managed Services in order to work with dedicated program specialists who support Frequency’s conflict minerals program. The Company communicates regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of reporting templates such as CMRT and CMRs, as well as Section 1502 of the Dodd-Frank Act.

Control Systems

The Company expects all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Frequency are “conflict free or responsibly sourced.” This means that the products should not contain minerals (3TGs) sourced from areas that have been identified to be in the presence of widespread human rights abuses and violations of law either directly or indirectly. The Company expects direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.

Frequency’s Supplier Code of Conduct applies to all direct suppliers and outlines certain expected behaviours and practices. This code of conduct is based on industry and internationally accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. The Supplier Code of Conduct is provided to all direct suppliers. If a supplier does not meet the Company’s requirements, the relationship with this supplier will be evaluated. The Supplier Code of Conduct is reviewed annually to ensure it continues to align with industry best practices.

Supplier Engagement

Frequency has strong relationships with Tier 1 direct suppliers. Frequency has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support, and other multilingual resources. Frequency’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly complete a CMRT. Suppliers are provided guidance in their native language, if needed.

The Company engages with suppliers directly to request a valid (free of validated errors) CMRT for the products that they supply to the Company. With respect to the OECD requirement to strengthen engagement with suppliers, the Company has developed an internal procedure that includes supplier risk identification process that then leads to further steps of supplier engagement in the form of escalations, such as in-person meetings and/or corrective actions. Feedback from this engagement process has allowed the Company to oversee improvements in supplier responses and supplier compliance for this initiative.

Additionally, the Company’s Conflict Minerals Policy is included in supplier contracts, requiring new suppliers to read and accept the policy as a requirement of doing business with Frequency.

The Company continues to place a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources. Also, Assent’s automated feedback process that notifies suppliers of risks associated with their CMRT submission serves to educate suppliers of certain conflict minerals’ risks.

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The Company believes that the combination of the Supplier Code of Conduct, Conflict Minerals Policy, and direct engagement with suppliers for conflict minerals training and support constitute a strong supplier engagement program.

Grievance Mechanisms

The Company established multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Frequency’s policies, including conflict minerals. Suppliers and others outside of Frequency may contact the Conflict Minerals Team.

Violations or grievances at the industry level can be reported to the Responsible Minerals Initiative (RMI) directly as well. This can be done at https://www.responsiblemineralsinitiative.org/minerals-due-diligence-container/risk-management/rmi-grievance-mechanism/

Maintain Records

The Company has adopted a policy to retain relevant documentation for a period of five years. Through Assent, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented by the Company. The Company stores all of the information and findings from this process in a database that can be audited by internal or external parties.

2) Identifying & Assessing Risk in the Supply Chain

Supplier Risk Evaluation

Risks associated with Tier 1 suppliers’ due diligence processes were assessed by their declaration responses on a CMRT, which the Assent Compliance Manager identifies automatically based on established criteria. These risks are addressed by Assent staff and members of the Company’s internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier’s conformity status, which is referred to as “conflict minerals status.”

Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT, rather than a product level CMRT is submitted, Frequency is unable to identify which smelters or refiners actually processed the 3TGs contained in the products.

Assent’s supplier risk assessment (flagging suppliers’ risk as high, medium, low) identifies problematic suppliers in a company’s supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis that takes into account multiple conflict minerals factors.

Smelter/Refiners Risk Evaluation

Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters/refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent’s Smelter validation program compared listed facilities to the list of smelters/refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TGs processing facility that was operational during the 2025 calendar year.

Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (RMAP). Frequency does not have a direct relationship with smelters/refiners, and does not perform direct audits of the entities within its pre-supply chain. Smelters/refiners that are conformant to RMAP audit standards are considered to have their sourcing validated as “conflict free or responsibly sourced.” In cases where the smelter/refiner’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, further due diligence steps are followed to notify suppliers reporting these facilities. Smelters/refiners are actively monitored to proactively identify other risks pertaining to conflict minerals.

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Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

● Geographic proximity to Conflict-Affected and High-Risk Areas

● Known mineral source country of origin

● RMAP audit status

● Credible evidence of unethical or conflict sourcing

● Peer assessments conducted by credible third-party sources

● Sanctions risks

Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through Assent, suppliers with submissions that included any smelters/refiners of concern were immediately provided with feedback instructing suppliers to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to Frequency. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters/refiners of concern from the supply chain.

In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.

Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.

3) Design & Implement A Strategy to Respond to Risks

Together with Assent, Frequency developed processes to assess and respond to the risks identified in the supply chain. Frequency has a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and the Company’s expectations.

Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, the Company will assess if replacing that supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Team and the Frequency’s leadership team to ensure transparency within the Company.

4) Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

Frequency does not have a direct relationship with any 3TG smelters/refiners and does not perform or direct audits of these entities within the supply chain. Instead, the Company relies on third-party audits of smelters/refiners (industry-recognized audit/assessment programs). As an example, RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters/refiners that agree to participate in the program.

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Assent directly engages smelters/refiners that are not currently enrolled in an industry-recognized audit/assessment program to encourage their participation Frequency is a signatory of these communications in accordance with the requirements of downstream companies detailed in the OECD Guidance.

5) Report Annually on Supply Chain Due Diligence

Frequency has published the Form SD for the year ended December 31, 2025. This report is available on Company’s website: www.freqelec.com under Investor Relations/Financial/SEC Filings. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein.

The Company will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public report.

Due Diligence Results

Supply Chain Outreach Results

Supply chain outreach is required to identify the upstream sources of origin of 3TGs. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified.

Upstream Data Transparency

Appendix A includes all smelters/refiners that suppliers listed in completed CMRTs that met the recognized definition of a 3TGs processing facility and were operational during the 2025 calendar year. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters/refiners may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing the smelters/refiners have the practice to list all smelters/refiners they may purchase from within the reporting period. Therefore, the smelters/refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters/refiners that actually processed the 3TGs contained in the Company’s products.

Although the potential for over-reporting is understood, Frequency has taken measures to validate all smelter/refiner data against validated audit programs and databases intended to verify the material types and mine sources of origin. From the gathered responses, 36 smelters that potentially posed a risk due to the presence of some red flag indicators were identified.

Suppliers that identified these specific smelters of concern on their CMRT were contacted in accordance with the OECD Guidance, as stipulated in the previous sections. The following chart outlines the number of smelters/refiners on Appendix A that are RMAP conformant, RMAP active, not enrolled or non-conformant.

Categories of Smelters/Refiners
RMAP Conformant	206
RMAP Active	10
Not Enrolled	78
Non-Conformant	38

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Country of Origin

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on reasonable identification of country-of-origin data obtained via Assent’s supply chain database or alternative RCOI data obtained by Frequency. As mentioned in the above section, it is understood that overreporting might occur which could result in Appendix B having more countries than those strictly relevant to the Company’s products.

Steps to Be Taken to Mitigate Risk

For 2026, Frequency intends to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in the Company’s products could originate from Conflict-Affected and High-Risk Areas:

● Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to:

● Using a comprehensive smelter/refiner library with detailed status and notes for each entity.

● Scanning for verifiable media sources on each smelter/refiner to flag risk issues.

● Comparing the list of smelters/refiners against government watch and denied parties lists.

● Engage with suppliers more closely and provide more information and training resources regarding responsible sourcing of 3TGs.

● Encourage suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.

● Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts, as well as included in the terms and conditions of each purchase order issued.

● Following the OECD Guidance process, increase the emphasis on clean and validated smelter/refiner information from the supply chain through feedback and detailed smelter/refiner analysis.

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Appendix A: Smelter List

| Metal | Smelter
Name | Smelter
Facility Location | Smelter
ID | RMAP
Audit Status |
| --- | --- | --- | --- | --- |
| Tin | Minsur | Peru | CID001182 | Conformant |
| Gold | Royal
Canadian Mint | Canada | CID001534 | Conformant |
| Gold | Umicore
S.A. Business Unit Precious Metals Refining | Belgium | CID001980 | Conformant |
| Tin | EM
Vinto | Bolivia
(Plurinational State Of) | CID000438 | Conformant |
| Tin | Mineracao
Taboca S.A. | Brazil | CID001173 | Conformant |
| Tin | Operaciones
Metalurgicas S.A. | Bolivia
(Plurinational State Of) | CID001337 | Conformant |
| Tin | PT
Timah Tbk Kundur | Indonesia | CID001477 | Conformant |
| Tin | PT
Timah Tbk Mentok | Indonesia | CID001482 | Conformant |
| Gold | Solar
Applied Materials Technology Corp. | Taiwan,
Province Of China | CID001761 | Conformant |
| Tin | Thaisarco | Thailand | CID001898 | Conformant |
| Tin | White
Solder Metalurgia e Mineracao Ltda. | Brazil | CID002036 | Conformant |
| Tin | Aurubis
Beerse | Belgium | CID002773 | Conformant |
| Tin | Tin
Technology & Refining | United
States Of America | CID003325 | Conformant |
| Gold | Agosi
AG | Germany | CID000035 | Conformant |
| Gold | AngloGold
Ashanti Corrego do Sitio Mineracao | Brazil | CID000058 | Conformant |
| Gold | Argor-Heraeus
S.A. | Switzerland | CID000077 | Conformant |
| Gold | Aurubis
AG | Germany | CID000113 | Conformant |
| Gold | Boliden
Ronnskar | Sweden | CID000157 | Conformant |
| Gold | C.
Hafner GmbH + Co. KG | Germany | CID000176 | Conformant |
| Gold | Chimet
S.p.A. | Italy | CID000233 | Conformant |

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| Tin | Alpha
Assembly Solutions Inc | United
States Of America | CID000292 | Conformant |
| --- | --- | --- | --- | --- |
| Gold | Dowa | Japan | CID000401 | Conformant |
| Tin | Fenix
Metals | Poland | CID000468 | Conformant |
| Gold | Heimerle
+ Meule GmbH | Germany | CID000694 | Conformant |
| Gold | Heraeus
Metals Hong Kong Ltd. | China | CID000707 | Conformant |
| Gold | Istanbul
Gold Refinery | Turkey | CID000814 | Conformant |
| Gold | Asahi
Refining USA Inc. | United
States Of America | CID000920 | Conformant |
| Gold | Asahi
Refining Canada Ltd. | Canada | CID000924 | Conformant |
| Tin | China
Tin Group Co., Ltd. | China | CID001070 | Conformant |
| Tin | Metallic
Resources, Inc. | United
States Of America | CID001142 | Conformant |
| Gold | Metalor
Technologies (Hong Kong) Ltd. | China | CID001149 | Conformant |
| Gold | Metalor
Technologies S.A. | Switzerland | CID001153 | Conformant |
| Gold | Metalor
USA Refining Corporation | United
States Of America | CID001157 | Conformant |
| Tin | Mitsubishi
Materials Corporation | Japan | CID001191 | Conformant |
| Gold | MKS
PAMP SA | Switzerland | CID001352 | Conformant |
| Tin | PT
Mitra Stania Prima | Indonesia | CID001453 | Conformant |
| Tin | Rui
Da Hung | Taiwan,
Province Of China | CID001539 | Conformant |
| Gold | Tanaka
Kikinzoku Kogyo K.K. | Japan | CID001875 | Conformant |
| Gold | United
Precious Metal Refining, Inc. | United
States Of America | CID001993 | Conformant |
| Tin | PT
ATD Makmur Mandiri Jaya | Indonesia | CID002503 | Conformant |
| Tin | Aurubis
Berango | Spain | CID002774 | Conformant |
| Gold | Advanced
Chemical Company | United
States Of America | CID000015 | Conformant |
| Gold | Aida
Chemical Industries Co., Ltd. | Japan | CID000019 | Conformant |

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| Gold | Asaka
Riken Co., Ltd. | Japan | CID000090 | Conformant |
| --- | --- | --- | --- | --- |
| Tungsten | Guangdong
Xianglu Tungsten Co., Ltd. | China | CID000218 | Conformant |
| Tin | Chenzhou
Yunxiang Mining and Metallurgy Co., Ltd. | China | CID000228 | Conformant |
| Gold | Chugai
Mining | Japan | CID000264 | Conformant |
| Tin | PT
Premium Tin Indonesia | Indonesia | CID000313 | Conformant |
| Gold | DSC
(Do Sung Corporation) | Korea,
Republic Of | CID000359 | Conformant |
| Tin | Dowa | Japan | CID000402 | Conformant |
| Gold | Eco-System
Recycling Co., Ltd. East Plant | Japan | CID000425 | Conformant |
| Gold | LT
Metal Ltd. | Korea,
Republic Of | CID000689 | Conformant |
| Tungsten | Japan
New Metals Co., Ltd. | Japan | CID000825 | Conformant |
| Gold | Materion | United
States Of America | CID001113 | Conformant |
| Gold | Metalor
Technologies (Singapore) Pte., Ltd. | Singapore | CID001152 | Conformant |
| Gold | Metalurgica
Met-Mex Penoles S.A. De C.V. | Mexico | CID001161 | Conformant |
| Gold | Mitsui
Mining and Smelting Co., Ltd. | Japan | CID001193 | Conformant |
| Gold | Ohura
Precious Metal Industry Co., Ltd. | Japan | CID001325 | Conformant |
| Tin | PT
Prima Timah Utama | Indonesia | CID001458 | Conformant |
| Gold | SEMPSA
Joyeria Plateria S.A. | Spain | CID001585 | Conformant |
| Gold | Shandong
Zhaojin Gold & Silver Refinery Co., Ltd. | China | CID001622 | Conformant |
| Gold | Shandong
Gold Smelting Co., Ltd. | China | CID001916 | Conformant |
| Tungsten | Wolfram
Bergbau und Hutten AG | Austria | CID002044 | Conformant |
| Gold | Yamakin
Co., Ltd. | Japan | CID002100 | Conformant |

Field: Page; Sequence: 14; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 14 Field: /Sequence

Field: /Page

| Gold | Yokohama
Metal Co., Ltd. | Japan | CID002129 | Conformant |
| --- | --- | --- | --- | --- |
| Tin | Yunnan
Chengfeng Non-ferrous Metals Co., Ltd. | China | CID002158 | Non
Conformant |
| Tin | Tin
Smelting Branch of Yunnan Tin Co., Ltd. | China | CID002180 | Conformant |
| Gold | SAFINA
A.S. | Czechia | CID002290 | Conformant |
| Tin | Magnu's
Minerais Metais e Ligas Ltda. | Brazil | CID002468 | Conformant |
| Tungsten | H.C.
Starck Tungsten GmbH | Germany | CID002541 | Conformant |
| Tungsten | TANIOBIS
Smelting GmbH & Co. KG | Germany | CID002542 | Conformant |
| Tungsten | Masan
High-Tech Materials | Viet
Nam | CID002543 | Conformant |
| Tungsten | Jiangwu
H.C. Starck Tungsten Products Co., Ltd. | China | CID002551 | Conformant |
| Gold | REMONDIS
PMR B.V. | Netherlands | CID002582 | Conformant |
| Tin | PT
Rajehan Ariq | Indonesia | CID002593 | Conformant |
| Tin | PT
Cipta Persada Mulia | Indonesia | CID002696 | Conformant |
| Tin | Super
Ligas | Brazil | CID002756 | Conformant |
| Tin | PT
Bangka Prima Tin | Indonesia | CID002776 | Conformant |
| Gold | WIELAND
Edelmetalle GmbH | Germany | CID002778 | Conformant |
| Tin | Guangdong
Hanhe Non-Ferrous Metal Co., Ltd. | China | CID003116 | Conformant |
| Tin | Chifeng
Dajingzi Tin Industry Co., Ltd. | China | CID003190 | Conformant |
| Tin | PT
Mitra Sukses Globalindo | Indonesia | CID003449 | Conformant |
| Tin | CRM
Synergies | Spain | CID003524 | Conformant |
| Tin | PT
Putera Sarana Shakti (PT PSS) | Indonesia | CID003868 | Conformant |
| Tin | Malaysia
Smelting Corporation Berhad (Port Klang) | Malaysia | CID004434 | Conformant |

Field: Page; Sequence: 15; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 15 Field: /Sequence

Field: /Page

| Gold | Almalyk
Mining and Metallurgical Complex (AMMC) | Uzbekistan | CID000041 | Conformant |
| --- | --- | --- | --- | --- |
| Gold | Asahi
Pretec Corp. | Japan | CID000082 | Conformant |
| Tungsten | Kennametal
Huntsville | United
States Of America | CID000105 | Conformant |
| Gold | Bangko
Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | CID000128 | Conformant |
| Gold | CCR
Refinery - Glencore Canada Corporation | Canada | CID000185 | Conformant |
| Tungsten | Chongyi
Zhangyuan Tungsten Co., Ltd. | China | CID000258 | Conformant |
| Tin | Estanho
de Rondonia S.A. | Brazil | CID000448 | Conformant |
| Tin | Gejiu
Non-Ferrous Metal Processing Co., Ltd. | China | CID000538 | Conformant |
| Tungsten | Global
Tungsten & Powders LLC | United
States Of America | CID000568 | Conformant |
| Gold | Heraeus
Germany GmbH Co. KG | Germany | CID000711 | Conformant |
| Gold | Inner
Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | CID000801 | Conformant |
| Gold | Ishifuku
Metal Industry Co., Ltd. | Japan | CID000807 | Conformant |
| Gold | Japan
Mint | Japan | CID000823 | Conformant |
| Gold | Jiangxi
Copper Co., Ltd. | China | CID000855 | Conformant |
| Gold | JX
Nippon Mining & Metals Co., Ltd. | Japan | CID000937 | Conformant |
| Gold | Kazzinc | Kazakhstan | CID000957 | Conformant |
| Gold | Kennecott
Utah Copper LLC | United
States Of America | CID000969 | Conformant |
| Gold | Kojima
Chemicals Co., Ltd. | Japan | CID000981 | Conformant |
| Gold | LS
MnM Inc. | Korea,
Republic Of | CID001078 | Conformant |
| Gold | Matsuda
Sangyo Co., Ltd. | Japan | CID001119 | Conformant |

Field: Page; Sequence: 16; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 16 Field: /Sequence

Field: /Page

| Gold | Metalor
Technologies (Suzhou) Ltd. | China | CID001147 | Conformant |
| --- | --- | --- | --- | --- |
| Gold | Mitsubishi
Materials Corporation | Japan | CID001188 | Conformant |
| Gold | Nadir
Metal Rafineri San. Ve Tic. A.S. | Turkey | CID001220 | Conformant |
| Gold | Navoi
Mining and Metallurgical Combinat | Uzbekistan | CID001236 | Conformant |
| Gold | Nihon
Material Co., Ltd. | Japan | CID001259 | Conformant |
| Tin | O.M.
Manufacturing (Thailand) Co., Ltd. | Thailand | CID001314 | Conformant |
| Gold | PT
Aneka Tambang (Persero) Tbk | Indonesia | CID001397 | Conformant |
| Gold | PX
Precinox S.A. | Switzerland | CID001498 | Conformant |
| Gold | Rand
Refinery (Pty) Ltd. | South
Africa | CID001512 | Conformant |
| Gold | Sichuan
Tianze Precious Metals Co., Ltd. | China | CID001736 | Conformant |
| Gold | Sumitomo
Metal Mining Co., Ltd. | Japan | CID001798 | Conformant |
| Gold | Tokuriki
Honten Co., Ltd. | Japan | CID001938 | Conformant |
| Gold | Valcambi
S.A. | Switzerland | CID002003 | Conformant |
| Gold | Western
Australian Mint (T/a The Perth Mint) | Australia | CID002030 | Conformant |
| Tungsten | Xiamen
Tungsten Co., Ltd. | China | CID002082 | Conformant |
| Gold | Zhongyuan
Gold Smelter of Zhongjin Gold Corporation | China | CID002224 | Conformant |
| Tungsten | Xiamen
Tungsten (H.C.) Co., Ltd. | China | CID002320 | Conformant |
| Gold | MMTC-PAMP
India Pvt., Ltd. | India | CID002509 | Conformant |
| Gold | KGHM
Polska Miedz Spolka Akcyjna | Poland | CID002511 | Conformant |
| Tin | O.M.
Manufacturing Philippines, Inc. | Philippines | CID002517 | Conformant |

Field: Page; Sequence: 17; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 17 Field: /Sequence

Field: /Page

| Tin | CV
Ayi Jaya | Indonesia | CID002570 | Conformant |
| --- | --- | --- | --- | --- |
| Gold | T.C.A
S.p.A | Italy | CID002580 | Conformant |
| Tungsten | Niagara
Refining LLC | United
States Of America | CID002589 | Conformant |
| Gold | Korea
Zinc Co., Ltd. | Korea,
Republic Of | CID002605 | Conformant |
| Gold | TOO
Tau-Ken-Altyn | Kazakhstan | CID002615 | Conformant |
| Tin | Resind
Industria e Comercio Ltda. | Brazil | CID002706 | Conformant |
| Gold | Abington
Reldan Metals, LLC | United
States Of America | CID002708 | Conformant |
| Gold | Italpreziosi | Italy | CID002765 | Conformant |
| Gold | SungEel
HiMetal Co., Ltd. | Korea,
Republic Of | CID002918 | Conformant |
| Gold | Planta
Recuperadora de Metales SpA | Chile | CID002919 | Conformant |
| Gold | NH
Recytech Company | Korea,
Republic Of | CID003189 | Conformant |
| Tin | Yunnan
Yunfan Non-ferrous Metals Co., Ltd. | China | CID003397 | Conformant |
| Gold | Eco-System
Recycling Co., Ltd. North Plant | Japan | CID003424 | Conformant |
| Gold | Eco-System
Recycling Co., Ltd. West Plant | Japan | CID003425 | Conformant |
| Tin | CRM
Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | CID003486 | Active |
| Gold | Metal
Concentrators SA (Pty) Ltd. | South
Africa | CID003575 | Conformant |
| Gold | Gold
by Gold Colombia | Colombia | CID003641 | Conformant |
| Gold | Coimpa
Industrial LTDA | Brazil | CID004010 | Conformant |

Field: Page; Sequence: 18; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 18 Field: /Sequence

Field: /Page

| Tin | Takehara
PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | Japan | CID004403 | Conformant |
| --- | --- | --- | --- | --- |
| Gold | Impala
Platinum - Platinum Metals Refinery (PMR) | South
Africa | CID004714 | Conformant |
| Gold | Elite
Industech Co., Ltd. | Taiwan,
Province Of China | CID004755 | Conformant |
| Tungsten | A.L.M.T.
Corp. | Japan | CID000004 | Conformant |
| Gold | Caridad | Mexico | CID000180 | Outreach
Required |
| Gold | Cendres
+ Metaux S.A. | Switzerland | CID000189 | Non
Conformant |
| Gold | Yunnan
Copper Industry Co., Ltd. | China | CID000197 | Outreach
Required |
| Tantalum | Guangdong
Rising Rare Metals-EO Materials Ltd. | China | CID000291 | Conformant |
| Tin | PT
Aries Kencana Sejahtera | Indonesia | CID000309 | In
Communication |
| Gold | Daye
Non-Ferrous Metals Mining Ltd. | China | CID000343 | Outreach
Required |
| Tantalum | F&X
Electro-Materials Ltd. | China | CID000460 | Conformant |
| Gold | JSC
Novosibirsk Refinery | Russian
Federation | CID000493 | RMI
Due Diligence Review - Unable to Proceed |
| Tin | Gejiu
Zili Mining And Metallurgy Co., Ltd. | China | CID000555 | Non
Conformant |
| Tantalum | XIMEI
RESOURCES (GUANGDONG) LIMITED | China | CID000616 | Conformant |
| Gold | Hangzhou
Fuchunjiang Smelting Co., Ltd. | China | CID000671 | Outreach
Required |
| Gold | Hunan
Chenzhou Mining Co., Ltd. | China | CID000767 | Outreach
Required |
| Tungsten | Hunan
Jintai New Material Co., Ltd. | China | CID000769 | Non
Conformant |

Field: Page; Sequence: 19; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 19 Field: /Sequence

Field: /Page

| Gold | Hunan
Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | CID000773 | Outreach
Required |
| --- | --- | --- | --- | --- |
| Gold | HwaSeong
CJ CO., LTD. | Korea,
Republic Of | CID000778 | Communication
Suspended - Not Interested |
| Tantalum | JiuJiang
JinXin Nonferrous Metals Co., Ltd. | China | CID000914 | Conformant |
| Tantalum | Jiujiang
Tanbre Co., Ltd. | China | CID000917 | Conformant |
| Gold | JSC
Ekaterinburg Non-Ferrous Metal Processing Plant | Russian
Federation | CID000927 | RMI
Due Diligence Review - Unable to Proceed |
| Gold | JSC
Uralelectromed | Russian
Federation | CID000929 | RMI
Due Diligence Review - Unable to Proceed |
| Tin | Gejiu
Kai Meng Industry and Trade LLC | China | CID000942 | Non
Conformant |
| Gold | Kazakhmys
Smelting LLC | Kazakhstan | CID000956 | Outreach
Required |
| Tungsten | Kennametal
Fallon | United
States Of America | CID000966 | Conformant |
| Gold | Kyrgyzaltyn
JSC | Kyrgyzstan | CID001029 | Non
Conformant |
| Gold | Lingbao
Gold Co., Ltd. | China | CID001056 | Outreach
Required |
| Tantalum | AMG
Brasil | Brazil | CID001076 | Conformant |
| Gold | Luoyang
Zijin Yinhui Gold Refinery Co., Ltd. | China | CID001093 | Outreach
Required |
| Tantalum | Metallurgical
Products India Pvt., Ltd. | India | CID001163 | Conformant |
| Tantalum | Mineracao
Taboca S.A. | Brazil | CID001175 | Conformant |
| Tantalum | Mitsui
Mining and Smelting Co., Ltd. | Japan | CID001192 | Conformant |
| Tantalum | NPM
Silmet AS | Estonia | CID001200 | Conformant |
| Gold | Moscow
Special Alloys Processing Plant | Russian
Federation | CID001204 | RMI
Due Diligence Review - Unable to Proceed |
| Tin | Jiangxi
New Nanshan Technology Ltd. | China | CID001231 | Active |

Field: Page; Sequence: 20; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 20 Field: /Sequence

Field: /Page

| Tantalum | Ningxia
Orient Tantalum Industry Co., Ltd. | China | CID001277 | Conformant |
| --- | --- | --- | --- | --- |
| Tin | Novosibirsk
Tin Combine | Russian
Federation | CID001305 | RMI
Due Diligence Review - Unable to Proceed |
| Gold | OJSC
"The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian
Federation | CID001326 | RMI
Due Diligence Review - Unable to Proceed |
| Gold | Penglai
Penggang Gold Industry Co., Ltd. | China | CID001362 | Outreach
Required |
| Gold | Prioksky
Plant of Non-Ferrous Metals | Russian
Federation | CID001386 | RMI
Due Diligence Review - Unable to Proceed |
| Tin | PT
Artha Cipta Langgeng | Indonesia | CID001399 | Active |
| Tantalum | Yanling
Jincheng Tantalum & Niobium Co., Ltd. | China | CID001522 | Conformant |
| Gold | Sabin
Metal Corp. | United
States Of America | CID001546 | Communication
Suspended - Not Interested |
| Gold | Samduck
Precious Metals | Korea,
Republic Of | CID001555 | Non
Conformant |
| Gold | Samwon
Metals Corp. | Korea,
Republic Of | CID001562 | Communication
Suspended - Not Interested |
| Gold | Shandong
Tiancheng Biological Gold Industrial Co., Ltd. | China | CID001619 | Outreach
Required |
| Gold | SOE
Shyolkovsky Factory of Secondary Precious Metals | Russian
Federation | CID001756 | RMI
Due Diligence Review - Unable to Proceed |
| Tantalum | Solikamsk
Magnesium Works OAO | Russian
Federation | CID001769 | RMI
Due Diligence Review - Unable to Proceed |
| Gold | Super
Dragon Technology Co., Ltd. | Taiwan,
Province Of China | CID001810 | Outreach
Required |

Field: Page; Sequence: 21; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 21 Field: /Sequence

Field: /Page

| Tantalum | Taki
Chemical Co., Ltd. | Japan | CID001869 | Conformant |
| --- | --- | --- | --- | --- |
| Tantalum | Telex
Metals | United
States Of America | CID001891 | Conformant |
| Tin | Gejiu
Yunxin Nonferrous Electrolysis Co., Ltd. | China | CID001908 | Non
Conformant |
| Gold | Great
Wall Precious Metals Co., Ltd. of CBPM | China | CID001909 | Outreach
Required |
| Gold | Tongling
Nonferrous Metals Group Co., Ltd. | China | CID001947 | Outreach
Required |
| Gold | Torecom | Korea,
Republic Of | CID001955 | Non
Conformant |
| Tantalum | Ulba
Metallurgical Plant JSC | Kazakhstan | CID001969 | Conformant |
| Tin | VQB
Mineral and Trading Group JSC | Viet
Nam | CID002015 | Outreach
Required |
| Gold | Gold
Refinery of Zijin Mining Group Co., Ltd. | China | CID002243 | Conformant |
| Gold | Morris
and Watson | New
Zealand | CID002282 | Outreach
Required |
| Tungsten | Jiangxi
Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | CID002313 | Communication
Suspended - Not Interested |
| Gold | Umicore
Precious Metals Thailand | Thailand | CID002314 | Non
Conformant |
| Tungsten | Ganzhou
Jiangwu Ferrotungsten Co., Ltd. | China | CID002315 | Non
Conformant |
| Tungsten | Jiangxi
Yaosheng Tungsten Co., Ltd. | China | CID002316 | Conformant |
| Tungsten | Jiangxi
Xinsheng Tungsten Industry Co., Ltd. | China | CID002317 | Conformant |
| Tungsten | Malipo
Haiyu Tungsten Co., Ltd. | China | CID002319 | Conformant |
| Tungsten | Jiangxi
Gan Bei Tungsten Co., Ltd. | China | CID002321 | Conformant |
| Tantalum | Hengyang
King Xing Lifeng New Materials Co., Ltd. | China | CID002492 | Conformant |

Field: Page; Sequence: 22; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 22 Field: /Sequence

Field: /Page

| Tungsten | Ganzhou
Seadragon W & Mo Co., Ltd. | China | CID002494 | Conformant |
| --- | --- | --- | --- | --- |
| Tin | Melt
Metais e Ligas S.A. | Brazil | CID002500 | Non
Conformant |
| Tungsten | Asia
Tungsten Products Vietnam Ltd. | Viet
Nam | CID002502 | Conformant |
| Tantalum | D
Block Metals, LLC | United
States Of America | CID002504 | Conformant |
| Tantalum | FIR
Metals & Resource Ltd. | China | CID002505 | Conformant |
| Tantalum | Jiujiang
Zhongao Tantalum & Niobium Co., Ltd. | China | CID002506 | Conformant |
| Tantalum | XinXing
HaoRong Electronic Material Co., Ltd. | China | CID002508 | Conformant |
| Tantalum | Jiangxi
Dinghai Tantalum & Niobium Co., Ltd. | China | CID002512 | Conformant |
| Tungsten | Hunan
Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | CID002513 | Non
Conformant |
| Gold | Fidelity
Printers and Refiners Ltd. | Zimbabwe | CID002515 | RMI
Due Diligence Review - Unable to Proceed |
| Gold | Singway
Technology Co., Ltd. | Taiwan,
Province Of China | CID002516 | Non
Conformant |
| Gold | Shandong
Humon Smelting Co., Ltd. | China | CID002525 | Outreach
Required |
| Gold | Shenzhen
Zhonghenglong Real Industry Co., Ltd. | China | CID002527 | Outreach
Required |
| Tantalum | KEMET
de Mexico | Mexico | CID002539 | Conformant |
| Tantalum | TANIOBIS
Co., Ltd. | Thailand | CID002544 | Conformant |
| Tantalum | TANIOBIS
GmbH | Germany | CID002545 | Conformant |
| Tantalum | Materion
Newton Inc. | United
States Of America | CID002548 | Conformant |
| Tantalum | TANIOBIS
Japan Co., Ltd. | Japan | CID002549 | Conformant |

Field: Page; Sequence: 23; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 23 Field: /Sequence

Field: /Page

| Tantalum | TANIOBIS
Smelting GmbH & Co. KG | Germany | CID002550 | Conformant |
| --- | --- | --- | --- | --- |
| Tantalum | Global
Advanced Metals Boyertown | United
States Of America | CID002557 | Conformant |
| Tantalum | Global
Advanced Metals Aizu | Japan | CID002558 | Conformant |
| Gold | Al
Etihad Gold Refinery DMCC | United
Arab Emirates | CID002560 | Non
Conformant |
| Gold | Emirates
Gold DMCC | United
Arab Emirates | CID002561 | Non
Conformant |
| Gold | International
Precious Metal Refiners | United
Arab Emirates | CID002562 | Outreach
Required |
| Tin | Electro-Mechanical
Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet
Nam | CID002572 | Non
Conformant |
| Tin | Nghe
Tinh Non-Ferrous Metals Joint Stock Company | Viet
Nam | CID002573 | Outreach
Required |
| Gold | Fujairah
Gold FZC | United
Arab Emirates | CID002584 | Outreach
Required |
| Gold | Shirpur
Gold Refinery Ltd. | India | CID002588 | Outreach
Required |
| Gold | Marsam
Metals | Brazil | CID002606 | Non
Conformant |
| Tungsten | China
Molybdenum Tungsten Co., Ltd. | China | CID002641 | Conformant |
| Tungsten | Hydrometallurg,
JSC | Russian
Federation | CID002649 | RMI
Due Diligence Review - Unable to Proceed |
| Tin | An
Vinh Joint Stock Mineral Processing Company | Viet
Nam | CID002703 | Outreach
Required |
| Tantalum | Resind
Industria e Comercio Ltda. | Brazil | CID002707 | Conformant |
| Tungsten | Unecha
Refractory metals plant | Russian
Federation | CID002724 | Non
Conformant |
| Gold | Shenzhen
CuiLu Gold Co., Ltd. | China | CID002750 | Outreach
Required |
| Gold | Albino
Mountinho Lda. | Portugal | CID002760 | Outreach
Required |
| Gold | SAAMP | France | CID002761 | Non
Conformant |
| Gold | L'Orfebre
S.A. | Andorra | CID002762 | Non
Conformant |

Field: Page; Sequence: 24; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 24 Field: /Sequence

Field: /Page

| Gold | 8853
S.p.A. | Italy | CID002763 | Non
Conformant |
| --- | --- | --- | --- | --- |
| Gold | Ogussa
Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | CID002779 | Active |
| Tantalum | Jiangxi
Tuohong New Raw Material | China | CID002842 | Conformant |
| Tungsten | Moliren
Ltd. | Russian
Federation | CID002845 | RMI
Due Diligence Review - Unable to Proceed |
| Gold | AU
Traders and Refiners | South
Africa | CID002850 | Non
Conformant |
| Gold | GGC
Gujrat Gold Centre Pvt. Ltd. | India | CID002852 | Non
Conformant |
| Gold | Modeltech
Sdn Bhd | Malaysia | CID002857 | Non
Conformant |
| Tin | Modeltech
Sdn Bhd | Malaysia | CID002858 | Non
Conformant |
| Gold | Bangalore
Refinery | India | CID002863 | Conformant |
| Gold | Kyshtym
Copper-Electrolytic Plant ZAO | Russian
Federation | CID002865 | RMI
Due Diligence Review - Unable to Proceed |
| Gold | Degussa
Sonne / Mond Goldhandel GmbH | Germany | CID002867 | Outreach
Required |
| Gold | Pease
& Curren | United
States Of America | CID002872 | Communication
Suspended - Not Interested |
| Gold | JALAN
& Company | India | CID002893 | Outreach
Required |
| Gold | ABC
Refinery Pty Ltd. | Australia | CID002920 | Outreach
Required |
| Gold | Safimet
S.p.A | Italy | CID002973 | Non
Conformant |
| Gold | State
Research Institute Center for Physical Sciences and Technology | Lithuania | CID003153 | Outreach
Required |
| Gold | African
Gold Refinery | Uganda | CID003185 | RMI
Due Diligence Review - Unable to Proceed |
| Gold | Gold
Coast Refinery | Ghana | CID003186 | Outreach
Required |
| Gold | QG
Refining, LLC | United
States Of America | CID003324 | Outreach
Required |
| Gold | Dijllah
Gold Refinery FZC | United
Arab Emirates | CID003348 | Outreach
Required |

Field: Page; Sequence: 25; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 25 Field: /Sequence

Field: /Page

| Tin | Dongguan
CiEXPO Environmental Engineering Co., Ltd. | China | CID003356 | Non
Conformant |
| --- | --- | --- | --- | --- |
| Tin | Ma'anshan
Weitai Tin Co., Ltd. | China | CID003379 | Non
Conformant |
| Tin | PT
Masbro Alam Stania | Indonesia | CID003380 | Non
Conformant |
| Gold | CGR
Metalloys Pvt Ltd. | India | CID003382 | Outreach
Required |
| Gold | Sovereign
Metals | India | CID003383 | Outreach
Required |
| Tin | Luna
Smelter, Ltd. | Rwanda | CID003387 | Conformant |
| Tungsten | Lianyou
Metals Co., Ltd. | Taiwan,
Province Of China | CID003407 | Conformant |
| Tungsten | JSC
"Kirovgrad Hard Alloys Plant" | Russian
Federation | CID003408 | RMI
Due Diligence Review - Unable to Proceed |
| Tin | Precious
Minerals and Smelting Limited | India | CID003409 | Non
Conformant |
| Tin | Gejiu
City Fuxiang Industry and Trade Co., Ltd. | China | CID003410 | Outreach
Required |
| Tungsten | NPP
Tyazhmetprom LLC | Russian
Federation | CID003416 | RMI
Due Diligence Review - Unable to Proceed |
| Tungsten | Hubei
Green Tungsten Co., Ltd. | China | CID003417 | Conformant |
| Tungsten | Albasteel
Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | CID003427 | Non
Conformant |
| Gold | Augmont
Enterprises Private Limited | India | CID003461 | Non
Conformant |
| Gold | Kundan
Care Products Ltd. | India | CID003463 | Outreach
Required |
| Tungsten | Cronimet
Brasil Ltda | Brazil | CID003468 | Conformant |
| Gold | Emerald
Jewel Industry India Limited (Unit 1) | India | CID003487 | Outreach
Required |
| Gold | Emerald
Jewel Industry India Limited (Unit 2) | India | CID003488 | Outreach
Required |

Field: Page; Sequence: 26; Value: 2

Field: Sequence; Type: Arabic; Name: PageNo 26 Field: /Sequence

Field: /Page

| Gold | Emerald
Jewel Industry India Limited (Unit 3) | India | CID003489 | Outreach
Required |
| --- | --- | --- | --- | --- |
| Gold | Emerald
Jewel Industry India Limited (Unit 4) | India | CID003490 | Outreach
Required |
| Gold | K.A.
Rasmussen | Norway | CID003497 | Outreach
Required |
| Gold | Alexy
Metals | United
States Of America | CID003500 | Non
Conformant |
| Gold | MD
Overseas | India | CID003548 | Outreach
Required |
| Gold | Metallix
Refining Inc. | United
States Of America | CID003557 | Outreach
Required |
| Tin | Fabrica
Auricchio Industria e Comercio Ltda. | Brazil | CID003582 | Conformant |
| Tungsten | Fujian
Xinlu Tungsten Co., Ltd. | China | CID003609 | Non
Conformant |
| Tungsten | OOO
“Technolom” 2 | Russian
Federation | CID003612 | RMI
Due Diligence Review - Unable to Proceed |
| Tungsten | OOO
“Technolom” 1 | Russian
Federation | CID003614 | RMI
Due Diligence Review - Unable to Proceed |
| Gold | WEEEREFINING | France | CID003615 | Non
Conformant |
| Tungsten | YUDU
ANSHENG TUNGSTEN CO., LTD. | China | CID003662 | Outreach
Required |
| Gold | Dongwu
Gold Group | China | CID003663 | Outreach
Required |
| Gold | Sam
Precious Metals | United
Arab Emirates | CID003666 | Outreach
Required |
| Gold | NOBLE
METAL SERVICES | United
States Of America | CID003690 | Outreach
Required |
| Tantalum | 5D
Production OU | Estonia | CID003926 | Outreach
Required |
| Tungsten | Tungsten
Vietnam Joint Stock Company | Viet
Nam | CID003993 | Conformant |
| Tungsten | Nam
Viet Cromit Joint Stock Company | Viet
Nam | CID004034 | Outreach
Required |
| Tantalum | PowerX
Ltd. | Rwanda | CID004054 | Conformant |
| Tin | Mining
Minerals Resources SARL | Congo,
Democratic Republic Of The | CID004065 | Conformant |
| Tungsten | Lianyou
Resources Co., Ltd. | Taiwan,
Province Of China | CID004397 | Conformant |

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| Tungsten | Shinwon
Tungsten (Fujian Shanghang) Co., Ltd. | China | CID004430 | Conformant |
| --- | --- | --- | --- | --- |
| Gold | SHENZHEN
JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | China | CID004435 | Outreach
Required |
| Tungsten | Philippine
Carreytech Metal Corp. | Philippines | CID004438 | Non
Conformant |
| Gold | GG
Refinery Ltd. | Tanzania,
United Republic Of | CID004506 | Conformant |
| Tin | RIKAYAA
GREENTECH PRIVATE LIMITED | India | CID004692 | Outreach
Required |
| Gold | Attero
Recycling Pvt Ltd | India | CID004697 | Outreach
Required |
| Gold | SOLEIL
METALS (Chala One Plant) | Peru | CID004704 | Active |
| Gold | SOLEIL
METALS (YAKARI Plant) | Peru | CID004705 | Active |
| Tin | Woodcross
Smelting Company Limited | Uganda | CID004724 | Conformant |
| Tin | Global
Advanced Metals Greenbushes Pty Ltd. | Australia | CID004754 | Conformant |
| Tin | Longnan
Chuangyue Environmental Protection Technology Development Co., Ltd | China | CID004796 | Outreach
Required |
| Tungsten | Philippine
Bonway Manufacturing Industrial Corporation | Philippines | CID004797 | Conformant |
| Tantalum | Jiangxi
Sanshi Nonferrous Metals Co., Ltd | China | CID004813 | Active |
| Tin | Dongguan
Best Alloys Co., Ltd. | China | CID000377 | Conformant |
| Tungsten | Uzbek
Refractory and Heat-Resistant Metals | Uzbekistan | CID002660 | Active |
| Tin | Conecsus
LLC | United
States Of America | CID003504 | Active |
| Gold | TITAN
COMPANY LIMITED, JEWELLERY DIVISION | India | CID004491 | Non
Conformant |
| Tungsten | KENEE
MINING VIETNAM COMPANY LIMITED | Viet
Nam | CID004619 | Conformant |
| Gold | Gasabo
Gold Refinery Ltd | Rwanda | CID005006 | RMI
Due Diligence Review - Unable to Proceed |
| Tungsten | Jing
Yuan Tungsten Technology Co., Ltd. | Taiwan,
Province Of China | CID005012 | Conformant |
| Gold | Minera
Titán del Perú SRL (MTP) - Belen Plant | Peru | CID005014 | Active |
| Tungsten | S.P.T.
spol.s r.o. | Czechia | CID005068 | Conformant |
| Tin | P
Kay Metal, Inc | United
States Of America | CID005189 | Conformant |
| Tungsten | Tungamoy
Metals Inc. | Korea,
Republic Of | CID005248 | Conformant |

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Appendix B: Countries of Origin

China	Nigeria	Madagascar	Italy	Finland
Brazil	United
Kingdom	Netherlands	Ghana	Dominica
Australia	Guyana	Rwanda	South
Sudan	Kyrgyzstan
Japan	Kazakhstan	Hong
Kong	Sweden	Benin
Canada	Hungary	Mozambique	Eritrea	Dominican
Republic
United
States	Ecuador	Slovakia	Saudi
Arabia	Liberia
Indonesia	Cambodia	Panama	Papua
New Guinea	Bulgaria
Peru	Myanmar	South
Africa	United
Arab Emirates	Mauritania
Germany	Luxembourg	Burundi	Belarus	Central
African Republic
Malaysia	Ireland	Congo	Poland	Georgia
Chile	Switzerland	Bolivia
(Plurinational State of)	Mali	Senegal
India	France	Suriname	El
Salvador	Tajikistan
Austria	Ethiopia	Philippines	Burkina
Faso	Serbia
Korea	Singapore	Andorra	New
Zealand	Fiji
Argentina	Namibia	Tanzania	Guatemala	Lithuania
Mongolia	Mexico	Zimbabwe	Liechtenstein	Oman
Thailand	Israel	Guinea	Armenia	Botswana
Colombia	Estonia	Zambia	Nicaragua	Kenya
Spain	Taiwan	Djibouti	Honduras	Cyprus
Portugal	Democratic
Republic of Congo	Sudan	Morocco	Uruguay
Niger	Sierra
Leone	Turkey	Uganda	Bermuda
Belgium	Viet
Nam	Angola	Azerbaijan	Albania
Russian
Federation	Egypt	Uzbekistan	Jersey	Solomon
Islands
Norway

29

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