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ORMAT TECHNOLOGIES, INC. Regulatory Filings 2016

Jun 1, 2017

6968_rns_2017-06-01_0a817456-074e-44e6-8381-46eec6a3417d.pdf

Regulatory Filings

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SD 1 ora20170528_sd.htm FORM SD

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

FORM SD SPECIALIZED DISCLOSURE REPORT

Ormat Technologies, Inc. (Exact name of registrant as specified in its charter)

State or other jurisdiction of incorporation or organization)

Delaware 001-32347 88-0326081 (Commission file number) (IRS Employer

Identification No.)

6225 Neil Road, Reno, Nevada 89511-1136
(Address of principal executive (Zip Code)
offices)

Doron Blachar, CFO (775) 356-9029

(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, 2016.

Section 1 – Conflict Minerals Disclosure

1.01 – Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

This Specialized Disclosure Report on Form SD (this "Form SD") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the year ended December 31, 2016 is presented to comply with Rule 13p-1 ("Rule 13p-1") promulgated under the Exchange Act of 1934, as amended (the "Exchange Act"). In accordance with Rule 13p-1 and our Conflict Minerals Policy, published on: http://www.ormat.com/social-responsibility-and-sustainability we have concluded that during the 2016 calendar year, (i) we have manufactured and contracted to manufacture products containing conflict minerals and (ii) the use of these minerals is necessary to the functionality or production of our products.

Copies of this Form SD and the Conflict Minerals Report are also posted to a publically available Internet site at http://www.ormat.com/social-responsibility-and-sustainability. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference herein.

Item 1.02 – Exhibit See Exhibit 1.01 – Conflict Minerals Report.

Section 2 – Exhibits Item 2.01 Exhibits

List below the following exhibit filed as part of this report.

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

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.

ORMAT TECHNOLOGIES, INC. By: /s/Doron Blachar Name: Doron Blachar Title: CFO Date: May 30, 2017

EX-1.01 2 ex1-01.htm EXHIBIT 1.01

EX-1.01 (Exhibit 1.01)

Conflict Minerals Report of Ormat Technologies, Inc. For The Year Ended December 31, 2016

Introduction:

We are a Delaware corporation, whose shares of common stock are listed on the New York Stock Exchange and on the Tel Aviv Stock Exchange and are registered with the Securities and Exchange Commission (the "SEC").

We are a leading vertically integrated company, currently engaged primarily in the geothermal and recovered energy power business, with the objective of becoming a leading global provider of renewable energy. This is the Conflict Minerals Report (this "Report") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for calendar year 2016 in accordance with Rule13p- 1, as Amended ("Rule 13p- 1") every registrant that (i) files reports with the Securities and Exchange Commission ("SEC") under Sections 13(a) or 15 (d) of the Exchange Act and (ii) has "conflict minerals" that are necessary to the functionality or production of a product manufactured or contracted by that registrant to be manufactured, is required to file a Conflict Minerals Report within the period specified therein. "Conflict Minerals" are defined as cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG").

As part of Ormat's sustainability approach our Code of Conduct defines the company's overall principles and commitment towards legal compliance, ethical conduct, human rights, anti-corruption work and environmental protection. These high expectations extend to Ormat partners, subcontractors and suppliers. In connection with Rule 13p-1, we have adopted a policy with respect to our sourcing of conflict minerals which is in compliance with the OECD guidance and implemented a comprehensive conflict minerals program, aimed to ensure responsible sourcing and not to eliminate sourcing from DRC.

Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in Rule 13p- 1, Form SD, and the 1934 Act Release No. 34- 67716 (August 22, 2012).

1. Overview

Company Overview

Ormat and its subsidiaries currently conduct business activities in the following two business segments:

  • Electricity Segment in this segment, we develop, build, own and operate geothermal and recovered energy- based power plants in the United States and geothermal power plants in other countries around the world and sell the electricity they generate and in the future, we plan to include services and other revenues derived from activity in the demand response and storage market; and
  • Product Segment in this segment, we design, manufacture and sell equipment for geothermal and recovered energy- based electricity generation, remote power units and other power generating units and provide services relating to the engineering, procurement, construction, operation and maintenance of geothermal and recovered energy- based power plants and in the future, other power generating units such as Solar PV and energy storage.

Our customers for the Product segment are contractors, geothermal power plant owners and geothermal power plant developers and operators.

For more information about Ormat, please visit www.ormat.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein.

Supply Chain

In accordance with applicable SEC rules, we conducted due diligence on the source and chain of custody of those conflict minerals used in our Product Segment. We concluded that no such examination is necessary with respect to the Electricity Segment because this segment does not involve the sale of products by the Company.

In connection with our manufacturing activities in the Product Segment, we identified certain conflict minerals that are used by us and are necessary to the functionality and production of our products in the following raw materials or components used by us: steel (low and high grade), electronic cards and electronic cables (including tin plating). All of such raw materials are being purchased from various suppliers. We also use subcontractors to manufacture some of our products' components and for construction activities of power plants. We work with a large number of suppliers throughout the world and often there are multiple tiers between the gold, tin, tantalum and tungsten (3TG) mines and our direct suppliers. Therefore, we have to rely on our Tier 1 suppliers to cooperate with us and work with their own upstream suppliers or sub-contractors in order for them to provide us with accurate information about the origin of the 3TG in the components we purchase from them that are included in our products. In order to overcome the difficulties of receiving accurate information from a complex supply chain, Ormat has communicated its Conflict Minerals policy and activities to its suppliers, and has adopted the CFSI's reporting template (CMRT) for suppliers' survey.

2. Reasonable Country of Origin Inquiry (RCOI)

Ormat has conducted in good faith a reasonable country of origin inquiry ("RCOI") to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo or an "adjoining country" (together, the "Covered Countries") or are from "recycled or scrap sources" (as such terms are defined in Rule 13p-1). In parallel, we conducted due diligence on the source and chain of custody of those conflict minerals to the large number of suppliers we identified as ones from whom we source materials or components that may contain 3TG.

As part of our RCOI, we employed several methods to assess whether the necessary conflict minerals in our products originated from any of the Covered Countries, including the following:

  • Internal assessment and analysis of our products to determine which products contain or may contain conflict minerals that are necessary to the functionality or production of these products.
  • Compiled a list of suppliers based on the applicable suppliers list which Ormat purchased from during the calendar year 2016, which was issued using the Ormat Management System (OMS) by IT developers and according to the criterions defined by the OMS manager and the Purchasing manager. The list includes a total of 1,218 suppliers. Each supplier has a "Purchase Types" field, which contains one of the following values: Services, BOM, Office supplier, Goods and Capital Expenditure. Only the suppliers with "BOM" values in "Purchase Types" field were applicable to the conflict minerals rule. In order to identify and assess risk in the supply chain, we undertook a risk- based approach and engaged the suppliers representing approximately 90% of our 2016 expenditures on procurement for the product segment. Therefore, Ormat's finalized level 1 suppliers list ("relevant suppliers") includes a total of 124 suppliers after the removal of 6 duplicates.
  • Contracted a third party service provider to assist us with the suppliers' survey. Through this third party, we sent letters to our relevant suppliers to explain the rule and to refer the suppliers to online training materials and instructions. We solicited information from our relevant suppliers of raw materials and components of products, using the standard template managed by Conflict Free Sourcing Initiative ("CFSI") known as the Conflict Minerals Reporting Template ("CMRT") version 4.2.
  • Reviewed the responses that we received and followed up on inconsistent, incomplete, and inaccurate responses, and we sent reminders to suppliers who did not respond to our requests for information.
  • Compared smelters or refiners that were identified by our suppliers against the list of facilities, which have received a DRC conflict free designation from the Conflict Free Smelter Program (CFSP) (The complete list can be found in Annex 1), and documented country of origin information as appears in Annex 2.

Currently, we do not have sufficient information from our suppliers to determine the complete list of the country of origin of the conflict minerals used in our products or the facilities used to process those conflict minerals. Therefore, we cannot exclude the possibility that some of these conflict minerals may have originated in the Democratic Republic of the Congo or an adjoining country and are not from recycled or scrap sources.

Based on this result, Ormat conducted due diligence activities and described these in this Report.

3. Due Diligence Framework

We designed the due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the OECD (2016) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing and the related supplements for gold, tin, tantalum and tungsten.

4. Due Diligence Measures

Our due diligence efforts for 2016 included the following steps:

4.1 Establish management and control systems.

  • Established a cross- functional conflict minerals steering committee comprised of representatives from procurement and finance departments to direct the overall efforts of the conflict minerals compliance program, with VP finance and accounting as the process owner. Continue to implement our Conflict Minerals Policy with respect to sourcing of minerals from the DRC and its adjoining countries. In an effort to be compliant with the Conflict Minerals Rule, our Policy provides further clarification to the principles of the Code of Conduct and Ormat's Human Rights Approach regarding illegal trade of natural resources and promote the procurement of minerals from credible and conflict-free sources. As part of our Conflict Minerals policy, we strive to ensure that purchased metals originate only from smelters validated as being Conflict Mineral free. In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and encourage them to define, implement and communicate to their sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. The policy is available at: http://www.ormat.com/social-responsibility-andsustainability. Maintained a grievance mechanism, in which concerns and violations of this Policy can be reported to Ormat:
    • Online via our website www.ormat.com; or
    • By electronic mail to the following address [email protected]
  • Strengthened Ormat's engagement with its suppliers by:
    • Referring suppliers to training materials which include an overview of the applicable SEC rules and instructions on how to respond to the survey.
  • Ormat has incorporated a conflict minerals clause in its master purchasing agreements for all new contracts, requiring our suppliers to cooperate with us and provide us the information required to perform our analysis on conflict minerals. .
  • Maintaining record retention for a minimum of five years.

4.2 Identify and assess risks in the supply chain.

To identify risks in our supply chain, we undertook the following measures:

  • We assessed two risks in the supply chain: (1) the risk of not receiving on time 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 being a conflict free company. We have segmented our suppliers into three risk levels (high, medium and low) by referring to Conflict Minerals-related risks based on suppliers characteristics, such as: the geographical location of the supplier, whether or not the supplier is a SEC registrant, volume of expenditures during 2016 and the extent to which the company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers. This segmentation allowed us to invest our risk mitigation efforts according to the supplier level of risk.
  • As part of the risk assessment phase, Ormat decided to focus on the top 90% of the purchasing spend in 2016. We have identified that out of the responses received, 37% of Ormat's relevant suppliers have policy in place which addresses the conflict minerals sourcing, 70% do not provide Ormat with products containing Conflict Minerals.
  • Responses received were subject to a "red flag" review. Responses that we identified as incomplete or inconsistent based on the red flag review process were identified for follow up.
  • We have identified, to the best of our efforts, the smelters and refiners in the supply chain by conducting a supply chain survey using the CMRT, requesting suppliers to identify smelters and refiners and country of origin of the Conflict Minerals in products supplied to Ormat. In addition, we have compared smelters and refiners identified by the supply chain survey against the list of facilities that have received a "conflict free" designation from the Conflict Free Smelter Program ("CFSP") or other independent third party audit program.

4.3 Design and implement a strategy to respond to identified risks

to address the risks in our supply chain, Ormat maintains a risk mitigation plan, which includes: :

  • Ormat expects its suppliers to define, implement and communicate to sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. We also ask suppliers to work with sub-suppliers to ensure traceability of these materials at least to smelter level, e.g. by using the CMRT.
  • Ormat's senior management , including the CEO, CFO, EVP Electricity, EVP Products, EVP Business Development and Marketing, EVP Projects, EVP Engineering and EVP Operations, was updated with the risk analysis and risk management actions and outcomes.
  • Suppliers who provided incomplete or inconsistent responses were sent a follow- up corrective action letter asking for clarification.
  • Suppliers that did not respond to our initial survey request were sent follow up letters requesting that they provide the information requested.

Supply chain due diligence is a dynamic process that requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process and update the risk mitigation strategy accordingly.

4.4 Carry out independent third- party audit of smelter/refiner due diligence practices.

We do not typically have a direct relationship with 3TG smelters and refiners and therefore do not perform direct audits of these entities. As a result, our due diligence efforts relied on cross- industry initiatives such as those led by the CFSI to conduct smelter and refiner due diligence.

4.5 Report annually on supply chain due diligence.

Our Conflict Minerals Policy states that we will comply with Section 1502 of the Dodd Frank Act which includes filing Form SD and this Report with the SEC and posting it publicly on the internet. See the following link: http://www.ormat.com/social-responsibility-and-sustainability.

5. Conclusion

We conducted a supply-chain survey of the 124 relevant suppliers that we identified which may contribute necessary conflict minerals to our products. The overall response rate to this survey was approximately 41% compared to 34% last year. The responses included the names and locations of smelters and refiners (see Annex 1) and country of origin see (Annex 2) which process Conflict Minerals.

Of this response rate:

● 70% suppliers were classified as "Free no 3TG"1

1 "Free no 3TG", Suppliers that reported that 3TG minerals are not necessary for the functionality or production of the products provided to Ormat

  • 10% suppliers were classified as "Undetermined not from DRC"2
  • 20% suppliers were classified as "Undetermined from DRC"3

Our supply chain is complex and there are multiple tiers between the Company and the mine. Accordingly, we rely, to a large extent, on our suppliers to provide information on the origin of the conflict minerals contained in components which are supplied to us to be included in our products.

Despite receiving responses from suppliers listing smelter or refiner names in their supply, the suppliers were unable to accurately report which specific smelters were part of the supply chain of the components that were sold to Ormat in 2016.

In light of this lack of conclusive information, we are unable to determine and to describe the full list of facilities used to process those necessary conflict minerals or their country of origin. In addition, the information gathered from our suppliers is not on a continuous real-time basis.

Smelters or refiners verified as conflict-free or in the audit process

Tantalum 44 of 48 (91.7%)
Tin 74 of 97 (76.3%)
Tungsten 40 of 51 (78.4%)
Gold 101 of 143 (70.6%)
Total 259 of 339 (76.4%)

2 "Undetermined not from DRC", Suppliers that reported that the 3TG being used in the products supplied to Ormat do not originate from Covered Countries but they have not yet concluded their due diligence process so this determination can potentially change (and our due diligence for these Relevant Suppliers is still ongoing)

3 "Undetermined from DRC", Suppliers that reported that the 3TG being used in the products supplied to Ormat originate from Covered Countries and the smelters are approved by the CFSI program, but they have not yet concluded their due diligence process so this determination can potentially change (and our due diligence for these Relevant Suppliers is still ongoing)

Status of identified smelters and refiners:

2016
Verified Conflict Free 245
Participating in an audit process 14
Not Participating 80
Total 339

6. Steps to be taken to mitigate risk

We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the DRC or adjoining countries:

  • Ormat will continue working with its global supply chain to ensure responsible sourcing and assure compliance with international regulations
  • Strengthening communications with suppliers in order to improve the number of suppliers that respond to the company's supply chain surveys.

Caution Concerning Forward- Looking Statements

Information provided in this Report may contain statements relating to current expectations and plans that are "forward- looking statements" as defined in the Private Securities Litigation Reform Act of 1995. These forwardlooking statements generally relate to Ormat's plans, objectives and expectations for future plans and events and are based upon its management's current estimates. These statements are subject to risks and uncertainties and may not prove to be accurate. For a discussion of such risks and uncertainties, see "Risk Factors" as described in Ormat Technologies, Inc.'s Annual Report on Form 10- K filed with the Securities and Exchange Commission on March 1, 2017 and its other filings. These forward- looking statements are made only as of the date hereof, and, except as required by applicable law, we undertake no obligation to update or revise the forward- looking statements, whether as a result of new information, future events or otherwise.

smelter_metal smelter_name smelter_country
Gold ?gussa ?sterreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA
Gold Abington Reldan Metals, LLC UNITED
STATES OF
AMERICA
Gold Advanced Chemical Company UNITED
STATES
Gold Aida Chemical Industries Co., Ltd. JAPAN
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 C?rrego do S?tio Minera??o 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
Gold Asaka Riken Co., Ltd. JAPAN
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY
Gold AU Traders and Refiners SOUTH
AFRICA
Gold AURA-II UNITED
STATES OF
AMERICA
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 Caridad MEXICO
Gold CCR Refinery - Glencore Canada Corporation CANADA
Gold Cendres + M?taux S.A. SWITZERLAND
Gold Chimet S.p.A. ITALY
Gold Chugai Mining JAPAN
Gold Daejin Indus Co., Ltd. KOREA,
REPUBLIC OF
Gold Daye Non-Ferrous Metals Mining Ltd. CHINA

Annex 1- listing smelter or refiner names in supply chain

Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY
Gold DODUCO GmbH GERMANY
Gold Dowa JAPAN
Gold DSC (Do Sung Corporation) KOREA,
REPUBLIC OF
Gold Eco-System Recycling Co., Ltd. JAPAN
Gold Elemetal Refining, LLC UNITED
STATES
Gold Emirates Gold DMCC UNITED ARAB
EMIRATES
Gold Faggi Enrico S.p.A. ITALY
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE
Gold Gansu Seemine Material Hi-Tech Co., Ltd. CHINA
Gold Geib Refining Corporation UNITED
STATES
Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA
Gold Guangdong Jinding Gold Limited CHINA
Gold Gujarat Gold Centre INDIA
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA
Gold Heimerle + Meule GmbH GERMANY
Gold Heraeus Ltd. Hong Kong CHINA
Gold Heraeus Precious Metals GmbH & Co. KG GERMANY
Gold Hunan Chenzhou Mining Co., Ltd. CHINA
Gold HwaSeong CJ Co., Ltd. KOREA
(REPUBLIC OF)
Gold Hwasung CJ Co., Ltd. KOREA,
REPUBLIC OF
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA
Gold Ishifuku Metal Industry Co., Ltd. JAPAN
Gold Istanbul Gold Refinery TURKEY
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
Gold Kennecott Utah Copper LLC UNITED
STATES
Gold KGHM Polska Mied? Sp??ka Akcyjna POLAND
Gold Kojima Chemicals Co., Ltd. JAPAN
Gold Korea Metal Co., Ltd. KOREA,
REPUBLIC OF
Gold Korea Zinc Co., Ltd. KOREA,
REPUBLIC OF
Gold Kyrgyzaltyn JSC KYRGYZSTAN
Gold L'azurde Company For Jewelry SAUDI
ARABIA
Gold L'Orfebre S.A. ANDORRA
Gold Lingbao Gold Co., Ltd. CHINA
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA
Gold LS-NIKKO Copper Inc. KOREA,
REPUBLIC OF
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA
Gold Materion UNITED
STATES
Gold Matsuda Sangyo Co., Ltd. JAPAN
Gold Metal?rgica Met-Mex Pe?oles S.A. De C.V. MEXICO
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
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 Morris and Watson Gold Coast AUSTRALIA
Gold Moscow Special Alloys Processing Plant RUSSIAN
FEDERATION
Gold Nadir Metal Rafineri San. Ve Tic. A.?. TURKEY
Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN
Gold Nihon Material Co., Ltd. JAPAN
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC RUSSIAN
Krastsvetmet) 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 Prioksky Plant of Non-Ferrous Metals RUSSIAN
FEDERATION
Gold PT Aneka Tambang (Persero) Tbk INDONESIA
Gold PX Pr?cinox S.A. SWITZERLAND
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA
Gold Remondis Argentia B.V. NETHERLANDS
Gold Republic Metals Corporation UNITED
STATES
Gold Royal Canadian Mint CANADA
Gold SAAMP FRANCE
Gold Sabin Metal Corp. UNITED
STATES
Gold SAFINA A.S. CZECH
REPUBLIC
Gold Sai Refinery INDIA
Gold Samduck Precious Metals KOREA,
REPUBLIC OF
Gold SAMWON Metals Corp. KOREA,
REPUBLIC OF
Gold SAXONIA Edelmetalle GmbH GERMANY
Gold Schone Edelmetaal B.V. NETHERLANDS
Gold SEMPSA Joyer?a Plater?a S.A. SPAIN
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA
Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA
Gold Singway Technology Co., Ltd. TAIWAN
Gold So Accurate Group, Inc. UNITED
STATES
Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN
FEDERATION
Gold Solar Applied Materials Technology Corp. TAIWAN
Gold Sudan Gold Refinery SUDAN
Gold Sumitomo Metal Mining Co., Ltd. JAPAN
Gold SungEel HiTech 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
Gold Universal Precious Metals Refining Zambia ZAMBIA
Gold Valcambi S.A. SWITZERLAND
Gold Western Australian Mint trading as The Perth Mint AUSTRALIA
Gold WIELAND Edelmetalle GmbH GERMANY
Gold Yamamoto Precious Metal 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
Gold Zijin Mining Group Co., Ltd. Gold Refinery CHINA
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA
Tantalum Conghua Tantalum and Niobium Smeltry CHINA
Tantalum D Block Metals, LLC UNITED
STATES
Tantalum Duoluoshan CHINA
Tantalum E.S.R. Electronics UNITED
STATES
Tantalum Exotech Inc. UNITED
STATES
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
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA
Tantalum H.C. Starck GmbH Goslar GERMANY
Tantalum H.C. Starck GmbH Laufenburg GERMANY
Tantalum H.C. Starck Hermsdorf GmbH GERMANY
Tantalum H.C. Starck Ltd. JAPAN
Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA
Tantalum Hi-Temp Specialty Metals, Inc. UNITED
STATES
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 KEMET Blue Powder UNITED
STATES
Tantalum King-Tan Tantalum Industry Ltd. CHINA
Tantalum LSM Brasil S.A. BRAZIL
Tantalum Metallurgical Products India Pvt., Ltd. INDIA
Tantalum Minera??o Taboca S.A. BRAZIL
Tantalum Mitsui Mining & Smelting JAPAN
Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN
Tantalum Molycorp Silmet A.S. ESTONIA
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA
Tantalum Plansee SE Liezen AUSTRIA
Tantalum Plansee SE Reutte AUSTRIA
Tantalum Power Resources Ltd. MACEDONIA
(THE FORMER
YUGOSLAV
REPUBLIC OF)
Tantalum QuantumClean UNITED
STATES
Tantalum RFH Tantalum Smeltry Co., Ltd. CHINA
Tantalum Solikamsk Magnesium Works OAO RUSSIAN
FEDERATION
Tantalum Taki Chemical Co., Ltd. JAPAN
Tantalum Taki Chemicals JAPAN
Tantalum Telex Metals UNITED
STATES
Tantalum Tranzact, Inc. UNITED
STATES
Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA
Tantalum Yichun Jin Yang Rare Metal Co., Ltd. CHINA
Tantalum Zhuzhou Cemented Carbide CHINA
Tantalum Zhuzhou Cemented Carbide Group Co., Ltd. CHINA
Tin Alpha UNITED
STATES
Tin An Thai Minerals Co., Ltd. VIET NAM
Tin An Vinh Joint Stock Mineral Processing Company VIET NAM
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA
Tin Chenzhou Yunxiang Mining and Metallurgy Company Limited CHINA
Tin China Tin Group Co., Ltd. CHINA
Tin CNMC (Guangxi) PGMA Co., Ltd. CHINA
Tin Cooperativa Metalurgica de Rond?nia Ltda. BRAZIL
Tin CV Ayi Jaya INDONESIA
Tin CV Dua Sekawan INDONESIA
Tin CV Gita Pesona INDONESIA
Tin CV Serumpun Sebalai INDONESIA
Tin CV Tiga Sekawan INDONESIA
Tin CV United Smelting INDONESIA
Tin CV Venus Inti Perkasa INDONESIA
Tin Dowa JAPAN
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock VIET NAM
Company
Tin Elmet S.L.U. SPAIN
Tin EM Vinto BOLIVIA
Tin Estanho de Rond?nia S.A. BRAZIL
Tin Feinh?tte Halsbr?cke GmbH GERMANY
Tin Fenix Metals POLAND
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA
Tin Gejiu Jinye Mineral Company 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
Tin Gejiu Zi-Li CHINA
Tin Gejiu Zili Mining And Metallurgy 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 Ketai Advanced Material Co., Ltd. CHINA
Tin Jiangxi Nanshan CHINA
Tin Kai Unita Trade Limited Liability Company CHINA
Tin Linwu Xianggui Ore Smelting 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 Metahub Industries Sdn. Bhd. MALAYSIA
Tin Metallic Resources, Inc. UNITED
STATES
Tin Metallo-Chimique N.V. BELGIUM
Tin Minera??o Taboca S.A. BRAZIL
Tin Minsur PERU
Tin Mitsubishi Materials Corporation JAPAN
Tin Modeltech Sdn Bhd MALAYSIA
Tin Nankang Nanshan Tin Manufactory Co., Ltd. CHINA
Tin Nghe Tinh Non-Ferrous Metal VIET NAM
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 Metalurgical S.A. BOLIVIA
Tin Phoenix Metal Ltd. RWANDA
Tin PT Alam Lestari Kencana INDONESIA
Tin PT Aries Kencana Sejahtera INDONESIA
Tin PT Artha Cipta Langgeng INDONESIA
Tin PT ATD Makmur Mandiri Jaya INDONESIA
Tin PT Babel Inti Perkasa INDONESIA
Tin PT Bangka Kudai Tin INDONESIA
Tin PT Bangka Prima Tin INDONESIA
Tin PT Bangka Timah Utama Sejahtera INDONESIA
Tin PT Bangka Tin Industry INDONESIA
Tin PT Belitung Industri Sejahtera INDONESIA
Tin PT BilliTin Makmur Lestari INDONESIA
Tin PT Bukit Timah INDONESIA
Tin PT Cipta Persada Mulia INDONESIA
Tin PT DS Jaya Abadi INDONESIA
Tin PT Eunindo Usaha Mandiri INDONESIA
Tin PT Fang Di MulTindo INDONESIA
Tin PT Inti Stania Prima INDONESIA
Tin PT Justindo INDONESIA
Tin PT Karimun Mining INDONESIA
Tin PT Kijang Jaya Mandiri INDONESIA
Tin PT Lautan Harmonis Sejahtera INDONESIA
Tin PT Menara Cipta Mulia INDONESIA
Tin PT Mitra Stania Prima INDONESIA
Tin PT O.M. Indonesia INDONESIA
Tin PT Panca Mega Persada INDONESIA
Tin PT Pelat Timah Nusantara Tbk INDONESIA
Tin PT Prima Timah Utama INDONESIA
Tin PT Refined Bangka Tin INDONESIA
Tin PT Sariwiguna Binasentosa INDONESIA
Tin PT Seirama Tin Investment INDONESIA
Tin PT Stanindo Inti Perkasa INDONESIA
Tin PT Sukses Inti Makmur INDONESIA
Tin PT Sumber Jaya Indah INDONESIA
Tin PT Timah (Persero) Tbk Kundur INDONESIA
Tin PT Timah (Persero) Tbk Mentok INDONESIA
Tin PT Tinindo Inter Nusa INDONESIA
Tin PT Tirus Putra Mandiri INDONESIA
Tin PT Tommy Utama INDONESIA
Tin PT Wahana Perkit Jaya INDONESIA
Tin Resind Ind?stria e Com?rcio Ltda. BRAZIL
Tin Rui Da Hung TAIWAN
Tin Soft Metais Ltda. BRAZIL
Tin Thaisarco THAILAND
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIET NAM
Tin Unknown Unknown
Tin VQB Mineral and Trading Group JSC VIET NAM
Tin White Solder Metalurgia e Minera??o Ltda. BRAZIL
Tin Yunnan Chengfeng CHINA
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA
Tin Yunnan Tin Company Limited CHINA
Tin Yunnan Tin Group (Holding) Company Limited CHINA
Tungsten A.L.M.T. TUNGSTEN Corp. JAPAN
Tungsten ACL Metais Eireli BRAZIL
Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd. CHINA
Tungsten Dayu Weiliang Tungsten Co., Ltd. CHINA
Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA
Tungsten Ganxian Shirui New Material Co., Ltd. CHINA
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd. CHINA
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA
Tungsten Ganzhou Yatai Tungsten Co., Ltd. CHINA
Tungsten Global Tungsten & Powders Corp. UNITED
STATES
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA
Tungsten H.C. Starck GmbH GERMANY
Tungsten H.C. Starck Smelting GmbH & Co.KG GERMANY
Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin CHINA
Tungsten Hunan Chunchang Nonferrous Metals 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 Dayu Longxintai Tungsten 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 Xinsheng Tungsten Industry Co., Ltd. CHINA
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CHINA
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA
Tungsten Kennametal Fallon UNITED
STATES
Tungsten Kennametal Huntsville UNITED
STATES
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA
Tungsten Moliren Ltd RUSSIAN
FEDERATION
Tungsten Niagara Refining LLC UNITED
STATES
Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC VIET NAM
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES
Tungsten Pobedit, JSC RUSSIAN
FEDERATION
Tungsten Sanher Tungsten Vietnam Co., Ltd. VIET NAM
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 Vietnam Youngsun Tungsten Industry Co., Ltd. VIET NAM
Tungsten Wolfram Bergbau und H?tten 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

Annex 2- country of origin

Gold Tin Tantalum Tungsten
Andora Belgium Austria Austria
Australia Bolivia Brazil Brazil
Austria Brazil China China
Belgium China Estonia Germany
Brazil Germany Germany Japan
Canada Indonesia India Korea
China Japan Japan Philippines
Czech Republic Malaysia Kazakhstan Russia
France Peru Macedonia USA
Germany Philippines Mexico Vietnam
India Poland Russia
Indonesia Rwanda USA
Italy Spain
Japan Taiwan
Kazakhstan Thailand
Korea USA
Kyrgystan Vietnam
Malaysia
Mexico
Netherlands
New Zealand
Philippines
Poland
Russia
Saudi Arabia
Singapore
South Africa
Spain
Sudan
Sweden
Switzerland
Taiwan
Thailand
Turkey
United Arab Emirates
USA
Uzbekistan
Zambia
Zimbabwe