UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
___________________________________________________________________________
FORM SD
Specialized Disclosure Report
___________________________________________________________________________
A10 NETWORKS, INC.
(Exact name of the registrant as specified in its charter)
___________________________________________________________________________
| | | | | | | | |
| Delaware | 001-36343 | 20-1446869 |
| (State or Other Jurisdiction of Incorporation or Organization) | (Commission File Number) | (I.R.S. Employer Identification Number) |
2300 Orchard Parkway
San Jose, CA 95131
(Address of principal executive offices, including zip code)
Scott Weber (408) 325-8668
(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:
| | | | | |
x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
The Company has filed a Conflict Minerals Report filed as Exhibit 1.01 hereto and it is publicly available at https://investors.a10networks.com/corporate-governance/governance-documents/default.aspx. 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.
Conflict Minerals Disclosures
(a)The Company conducted a Reasonable Country of Origin Inquiry (“RCOI”) as required by Item 1.01(a) of Form SD. The RCOI began with a multi-department initiative that scoped and evaluated the Company’s product line to determine which suppliers provide the Company with manufactured or contracted to be manufactured products. The Company then looked on a product-by-product level to determine which of these products were most likely to contain Conflict Minerals (as defined by the U.S. Securities and Exchange Commission) that are “necessary to the functionality or production” of the product, or are otherwise sourced from recycled or scrap materials. Suppliers of such products (other than those sourced from recycled or scrap materials) were next identified and surveyed using the basic EICC/GeSI Conflict Minerals Reporting Template or, where appropriate, a custom-designed form. Follow-up was undertaken with those suppliers who provided incomplete forms or were otherwise non-responsive. The Company then evaluated the information provided from suppliers to assess completeness and reliability of the data collected. On the basis of this inquiry and evaluation, the Company has no reason to believe that the Conflict Minerals contained in its products originated in the Democratic Republic of Congo or adjoining countries (the “Covered Countries”).
(b)On the basis of its RCOI undertaking, the Company has no reason to believe that its necessary Conflict Minerals may have originated in the Covered Countries. Given that the results of its RCOI efforts were inconclusive, the Company proceeded to the due diligence stage of the inquiry as required by Form SD and has filed herewith a Conflict Minerals Report, which is attached as Exhibit 1.01 to this Form SD.
Item 1.02 Exhibits
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto.
Section 2 - Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit 1.01 - Conflict Minerals Report for the reporting period January 1, 2023 through December 31, 2023, as required by Items 1.01 and 1.02 of this Form.
EXHIBIT INDEX
Exhibit No. Description
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
May 29, 2024 | | | | | |
| By: /s/ Scott Weber |
| Scott Weber |
| General Counsel |
Exhibit 1.01
Conflict Minerals Report of A10 Networks, Inc.
in Accordance with Rule 13p-1 under the Securities Exchange Act of 1934
This Conflict Minerals Report of A10 Networks, Inc. (the “Company”, “us”, “our” or “we”) for calendar year 2023 is provided in accordance with Rule 13p-1 (“Rule 13p-1,” published at 17 CFR § 240.13p-1) under the Securities Exchange Act of 1934 (the “1934 Act”), 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 “SEC Statement”). The Company notes the Updated Statement on the Effect of the Court of Appeals Decision on the Conflict Minerals Rule issued by the SEC Division of Corporation Finance on April 7, 2017. Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 for definitions to the terms used in this Report, unless otherwise defined herein.
This Report outlines the steps we undertook in accordance with Rule 13p-1, Form SD, and the SEC Statement in connection with the existence of Conflict Minerals in products we manufacture or contract to manufacture. Our diligence measures were designed to adhere, in all material respects, with the nationally recognized due diligence framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplement on Tin, Tantalum and Tungsten and the Gold Supplement (Third Edition OECD 2016) (the “OECD Framework”).
Introduction
We provide security and infrastructure solutions for on-premises, hybrid cloud, and edge-cloud environments. Our 7000+ customers span global large enterprises and communications, cloud and web service providers who want business-critical applications and networks that are secure, available, and efficient. Our portfolio of software and hardware solutions combines industry-leading performance and scale with data driven analytics, and threat intelligence to enhance security and availability of customer applications across their multi-cloud and mobile infrastructure networks, including on-premises, private and public clouds. Our portfolio includes application delivery controllers (ADC) for secure application delivery; a carrier-grade network address translation (CGNAT) solution to help service providers preserve IPv4 address investments while transitioning to IPv6-based networks; distributed denial of service (DDoS) attack detection and mitigation solutions; and convergent firewall (CFW) appliances for protecting data centers, service provider networks and mobile infrastructures. We deliver these solutions via software, on optimized hardware appliances or as virtual appliances.
We outsource the manufacturing of our hardware products to original equipment manufacturers (“OEMs”). These companies manufacture, assemble and test our hardware products using design specifications, quality assurance programs and standards that we establish. The component parts incorporated into our hardware products are sourced either by our manufacturing OEMs or directly by us.
Our position in the supply chain is as a remote downstream purchaser and supplier, several levels removed from the actual mining of the minerals used in the components of our products. We do not directly make purchases of raw ore or unrefined minerals from the Covered Countries and we do not directly source any products or components from the Covered Countries. In light of our remote position in the supply chain, we must rely upon our suppliers (and their multiple sub-suppliers and intermediaries) for information on and verification of the chain of custody of Conflict Minerals contained in our products.
Enumerated paragraphs set out below conform to the Instructions set forth in Item 1.01(c) of Form SD.
(1) Due Diligence
After conducting a reasonable country of origin inquiry (“RCOI”) in accordance with the instructions to Item 1.01 of Form SD (and as disclosed in our Report on Form SD for the year ended December 31, 2023), the Company was unable to conclude, without further diligence, that none of the minerals in its products, that were not sourced from recycled or scrap materials, did not originate in the Covered Countries.
(i) Conformity with OECD Framework. In accordance with Rule 13p-1, we designed our Conflict Mineral Compliance Program to conform, in all material respects, with the five-step process outlined in the OECD Framework. In addition, our diligence measures relied upon information and templates obtained from the Responsible Minerals Initiative (“RMI”) with the smelters and refiners of Conflict Minerals. The five-step process identified within the OECD Framework includes: (1) establishing strong company management systems; (2) identifying and assessing supply chain risk; (3) designing and implementing a risk response strategy; (4) third party auditing of our due diligence practices; and (5) reporting annually on supply chain due diligence. This Conflict Minerals Report outlines the measures taken by us in accordance with the OECD Framework during the reporting period.
(1) Established Strong Company Management Systems
We established an interdepartmental committee (the “Committee”) to develop the Company’s assessment and compliance process, with oversight from senior management (including members of the Company’s Legal, Finance and Global Supply Chain departments).
•Through the Committee, we identified and educated relevant internal departments or personnel affected, including in Sourcing, Legal and Compliance, Finance/Internal Audit, and Supplier Relations.
•We adopted A10 Networks Conflict Minerals Supply Chain Policy (the “Policy”) relating to responsible sourcing, see https://s201.q4cdn.com/775649631/files/doc_downloads/gov_docs/Conflict-Mineral-Policy-November-2023.pdf.
•Through our Supplier Relations personnel, we communicated with our suppliers and prospective suppliers via direct correspondence and telephone calls to inform them of (i) our Policy, and (ii) our intent to continue to work with them as reasonably practicable given our supply chain position and market leverage for increased understanding of the use of Conflict Minerals within our supply chain and to obtain wherever possible their commitment to facilitate our compliance with applicable law.
•We confirmed that purchase order terms and conditions should be conformed where practicable to the Policy, recognizing that many of our suppliers demand terms and conditions and use standard forms with respect to which we have no leverage or ability to alter.
•We established a process to evaluate the chain of custody of Conflict Minerals within our supply chain, including:
◦Analyzing our existing product offerings annually for scoping within the context of the Rule.
◦Maintaining an internal process to evaluate new products as developed to minimize the introduction of Conflict Minerals into our supply chain where possible.
•We maintained a feedback mechanism through the Company’s Supplier Relations team to work with suppliers.
(2) Identified and Assessed Supply Chain Risk through Due Diligence
Step 1 The Company’s Environmental Compliance Engineer reviewed our product offerings to determine which suppliers provide the Company with manufactured or contracted to be manufactured products. We determined that 12 suppliers were relevant to this process.
Step 2 Our Supplier Relations team then determined which manufactured and contracted to be manufactured products may contain Conflict Minerals that are “necessary to the functionality or production” of the product.
Step 3 Under the Committee’s direction, our Supplier Relations team conducted a due diligence assessment of relevant product suppliers in accordance with the following:
•We designed and implemented a due diligence program for supplier outreach and engagement that involved (i) developing a contact list of relevant suppliers and (ii) communicating with them to obtain information on the chain of custody and source of origin of minerals in supplied products. Our due diligence consisted of providing each supplier with the RMI’s Conflict Minerals Reporting Template (the “Template”) to obtain the necessary information and certifications from our suppliers. For certain suppliers that found the Template unwieldy, we provided a custom form to elicit the same information. We received responses from our suppliers for the reporting period.
Step 4 Our Supplier Relations team, with guidance from the Committee, analyzed the results of the Supplier survey forms that were returned to us. We reviewed the survey responses from each supplier to determine whether the data provided was complete or whether further follow-up was required. Follow-up was conducted by phone calls and emails, as necessary. Our staff compared the smelters and refiners identified by the suppliers on the survey forms with the list of facilities that have received a “conflict free” designation from the RMI’s Responsible Minerals Assurance Process (“RMAP”). The results of that comparison are set forth on Appendix A to this Conflict Mineral Report.
(3) Designed and Implemented a Risk Response Strategy
In analyzing the results from our supply chain diligence, we recognized that certain risks exist in our supply chain that require further follow-up and mitigation efforts. We have established the following plan for risk mitigation, which we review periodically for relevance and effectiveness.
•Conduct baseline analysis of responses from our suppliers.
•Identify gaps in the data collection and high-risk suppliers and continue to follow-up with suppliers as practicable.
•To monitor and track performance of risk management efforts, the Company uses data reported by suppliers in CMRT and updates the RMAP conformant smelter list. The status is discussed and reviewed annually.
•Follow-up on remediation efforts to obtain complete and accurate chain of custody information where possible to identify smelters/refiners of origin.
•Develop and implement a progressive performance plan for suppliers on an as needed basis.
•Address incomplete, inconsistent, unsatisfactory responses received from our suppliers, through an escalation process.
(4) Third Party Audit of Due Diligence Practices
This Report has not been subject to an independent private sector audit in accordance with the SEC Statement.
(5) Report Annually on Supply Chain Due Diligence
The Company's Form SD and Conflict Mineral Report for calendar year 2023, together with our Supply Chain Policy Statement, are posted on our website at: http://investors.a10networks.com
(ii) Independent Third-Party Audit
This Report has not been subject to an independent private sector audit in accordance with the SEC Statement.
(iii) Summary of Diligence Results; Risk Mitigation Efforts
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. Our position as a remote downstream purchaser and supplier requires us to depend substantially on the cooperation of our suppliers and their numerous sub-suppliers, many of which are not subject to SEC reporting requirements and with whom we have limited leverage due to our size, market position and available resources. As a result, we expect it may take us several years before we are able to identify all smelters and refiners in our supply chain.
In conducting our diligence, we have adopted methodology outlined by the RMI’s joint industry programs and outreach initiatives and have encouraged our suppliers to conform with the standards set forth in the OECD Framework and report to us using the Template or, where appropriate, our custom-designed form. We conducted follow-up calls and correspondence with suppliers where information was incomplete, unreliable or unverifiable. We identified 238 smelters and refiners of minerals in our supply chain, and the related countries of origin, as set forth on Appendix A.
We are continuing our efforts to determine the smelters and refiners used by our supply chain and to verify the most reasonable known mine of origin information available. Through this effort, we have made a reasonable determination of certain of the mines or locations of origin of certain of the Conflict Minerals in our supply chain as indicated on Appendix A. We have also requested that all of our suppliers support the industry-wide initiative by adopting policies and procedures consistent with the RMI and by working to align their sources with the lists of conflict-free sourced metals.
The RMAP program audits smelters and refineries to ensure that all certified smelters and refineries only use the ones that are conflict-free from the Covered Countries. Of the suppliers we surveyed, 100% fully responded to our due diligence survey. We are continuing to compile the names of smelters and refineries identified by those vendors who did respond and are working to verify the information provided. Certain of our vendors indicated that not all smelters and refineries have been certified as conflict-free and we are continuing our diligence to verify this information.
(iv) See disclosure under paragraph (ii) above.
(v) Not applicable.
(vi) Not applicable.
(2) Product Description
The Company’s relevant product categories for products containing tin, tungsten, tantalum and gold, other than those sourced from scrap or recycled materials, are as follows:
•Thunder Series appliances
•aGalaxy appliances
•Harmony Controller appliances
The Company’s efforts to determine the smelters, refiners, mines and locations of origin of the Conflict Minerals in its products is described above under paragraphs (i) and (iii).
Conclusion
Due to the breadth and scope of the Company’s product categories, the resulting complexity of its supply chain, and the human and financial resources available to the Company, the Company acknowledges that the process of successfully tracing all of the minerals used (and the absence of Conflict Minerals) in its manufactured or contracted to manufacture products to their country of origin is an ongoing activity that
requires continued diligence. Moving forward, the Company will continue to implement commercially reasonable processes to improve the quantity and quality of supplier responses, verify supplier responses provided, and evaluate new product lines as developed to avoid the introduction of Conflict Minerals into the supply chain where practicable.
The success of A10 Networks, Inc. in making determinations about the presence and source of Conflict Minerals in its products depends upon various factors including, but not limited to, the respective due diligence efforts of its suppliers and their supply chain and their respective willingness, whether public or private entities, to disclose such information to the Company, and the ability of the involved entities in making their determinations in accordance with nationally or internationally recognized standards, including the OECD Framework and other initiatives or guidance that may develop over time. The failure to obtain reliable information from any level of our supply chain could have a material impact on our future ability to report on the presence of Conflict Minerals with any degree of certainty. There can be no assurance that our suppliers will continue to cooperate with diligence inquiries and requests for certifications or provide documentation or other evidence that we consider reliable or provided to us within a time frame sufficient to allow us to make our own assessment following appropriate further diligence measures, if any.
The information provided in this Conflict Mineral Report speaks only as of its date. Subsequent events, including the inability or unwillingness of participants in our supply chain to comply with our Policy or provide complete and accurate information requested, may affect our future determinations under Rule 13p-1.
APPENDIX A
List of Smelters and Refiners in Our Supply Chain
| | | | | | | | | | | | | | |
| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | RMAP |
| Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 | Audited |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 | |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 | Audited |
| Gold | Agosi AG | GERMANY | CID000035 | Audited |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | Audited |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 | Audited |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | Audited |
| Gold | Asahi Pretec Corp. | JAPAN | CID000082 | Audited |
| Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 | Audited |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 | Audited |
| Gold | Aurubis AG | GERMANY | CID000113 | Audited |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | Audited |
| Gold | Boliden AB | SWEDEN | CID000157 | Audited |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | Audited |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 | Audited |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 | |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 | Audited |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | Audited |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 | Audited |
| Gold | Chimet S.p.A. | ITALY | CID000233 | Audited |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | Audited |
| Gold | Chugai Mining | JAPAN | CID000264 | Audited |
| Tin | Alpha | UNITED STATES OF AMERICA | CID000292 | Audited |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 | Audited |
| Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 | Audited |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 | Audited |
| Gold | Dowa | JAPAN | CID000401 | Audited |
| Tin | Dowa | JAPAN | CID000402 | Audited |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 | Audited |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 | Audited |
| Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 | Audited |
| | | | | | | | | | | | | | |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | Audited |
| Tin | Fenix Metals | POLAND | CID000468 | Audited |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | Audited |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 | Audited |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | CID000616 | Audited |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 | Audited |
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 | Audited |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 | Audited |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | CID000711 | Audited |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | Audited |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA | CID000769 | |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | Audited |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | Audited |
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 | Audited |
| Gold | Japan Mint | JAPAN | CID000823 | Audited |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | Audited |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | Audited |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 | |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | Audited |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | Audited |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 | Audited |
| Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | Audited |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | Audited |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | |
| Gold | Kazzinc | KAZAKHSTAN | CID000957 | Audited |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 | Audited |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 | Audited |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 | Audited |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | |
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 | Audited |
| Tantalum | AMG Brasil | BRAZIL | CID001076 | Audited |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | Audited |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | Audited |
| Gold | Materion | UNITED STATES OF AMERICA | CID001113 | Audited |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | Audited |
| | | | | | | | | | | | | | |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 | Audited |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | Audited |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | Audited |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | Audited |
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | Audited |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 | Audited |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 | Audited |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | Audited |
| Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 | Audited |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 | Audited |
| Tin | Minsur | PERU | CID001182 | Audited |
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | Audited |
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 | Audited |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 | Audited |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | Audited |
| Tantalum | NPM Silmet AS | ESTONIA | CID001200 | Audited |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 | Audited |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 | Audited |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | Audited |
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | Audited |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | Audited |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 | Audited |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 | Audited |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 | Audited |
| Gold | MKS PAMP SA | SWITZERLAND | CID001352 | Audited |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | Audited |
| Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 | Audited |
| Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 | Audited |
| Tin | PT Babel Surya Alam Lestari | INDONESIA | CID001406 | Audited |
| Tin | PT Bukit Timah | INDONESIA | CID001428 | Audited |
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 | Audited |
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 | Audited |
| Tin | PT Refined Bangka Tin | INDONESIA | CID001460 | Audited |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 | Audited |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 | Audited |
| Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 | Audited |
| Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 | Audited |
| | | | | | | | | | | | | | |
| Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 | Audited |
| Tin | PT Tommy Utama | INDONESIA | CID001493 | Audited |
| Gold | PX Precinox S.A. | SWITZERLAND | CID001498 | Audited |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 | Audited |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | Audited |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 | Audited |
| Gold | Royal Canadian Mint | CANADA | CID001534 | Audited |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 | Audited |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 | Audited |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | Audited |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | Audited |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 | Audited |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | Audited |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 | Audited |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | Audited |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 | Audited |
| Tin | Thaisarco | THAILAND | CID001898 | Audited |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 | |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | CID001916 | Audited |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | Audited |
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 | Audited |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | Audited |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | Audited |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 | Audited |
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 | Audited |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 | Audited |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 | Audited |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 | Audited |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | Audited |
| Gold | Yamakin Co., Ltd. | JAPAN | CID002100 | Audited |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 | Audited |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 | Audited |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | CID002180 | Audited |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | Audited |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 | Audited |
| | | | | | | | | | | | | | |
| Gold | SAFINA A.S. | CZECHIA | CID002290 | Audited |
| Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 | Audited |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | Audited |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 | Audited |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 | Audited |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 | Audited |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | Audited |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | Audited |
| Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 | Audited |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 | |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | Audited |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | Audited |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | Audited |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 | |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | Audited |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | Audited |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 | Audited |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | Audited |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 | Audited |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 | Audited |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | Audited |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 | Audited |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | Audited |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | CID002513 | Audited |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 | |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | Audited |
| Tantalum | KEMET de Mexico | MEXICO | CID002539 | Audited |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 | Audited |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002542 | Audited |
| Tungsten | Masan High-Tech Materials | VIET NAM | CID002543 | Audited |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | CID002544 | Audited |
| Tantalum | TANIOBIS GmbH | GERMANY | CID002545 | Audited |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | CID002548 | Audited |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | CID002549 | Audited |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002550 | Audited |
| | | | | | | | | | | | | | |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 | Audited |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 | Audited |
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | Audited |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 | |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | |
| Tin | CV Ayi Jaya | INDONESIA | CID002570 | Audited |
| Gold | T.C.A S.p.A | ITALY | CID002580 | Audited |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 | Audited |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 | Audited |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 | Audited |
| Gold | Marsam Metals | BRAZIL | CID002606 | |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | Audited |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | CID002641 | Audited |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 | |
| Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 | Audited |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 | Audited |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 | Audited |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 | Audited |
| Tin | Super Ligas | BRAZIL | CID002756 | Audited |
| Gold | SAAMP | FRANCE | CID002761 | |
| Gold | L'Orfebre S.A. | ANDORRA | CID002762 | Audited |
| Gold | 8853 S.p.A. | ITALY | CID002763 | |
| Gold | Italpreziosi | ITALY | CID002765 | Audited |
| Tin | Aurubis Beerse | BELGIUM | CID002773 | Audited |
| Tin | Aurubis Berango | SPAIN | CID002774 | Audited |
| Tin | PT Bangka Prima Tin | INDONESIA | CID002776 | Audited |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 | Audited |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | Audited |
| Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 | Audited |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 | Audited |
| Tungsten | ACL Metais Eireli | BRAZIL | CID002833 | |
| Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 | Audited |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | Audited |
| Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 | |
| Gold | Bangalore Refinery | INDIA | CID002863 | |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 | Audited |
| | | | | | | | | | | | | | |
| Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 | Audited |
| Gold | Safimet S.p.A | ITALY | CID002973 | |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 | Audited |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 | Audited |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 | Audited |
| Tin | PT Bangka Serumpun | INDONESIA | CID003205 | Audited |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 | Audited |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | CID003381 | Audited |
| Tin | Luna Smelter, Ltd. | RWANDA | CID003387 | Audited |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 | Audited |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | CID003401 | |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 | Audited |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | CID003417 | Audited |
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | CID003421 | |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 | Audited |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 | Audited |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 | |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | CID003449 | Audited |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | CID003468 | Audited |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | CID003486 | Audited |
| Tin | CRM Synergies | SPAIN | CID003524 | Audited |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | CID003575 | Audited |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | CID003582 | Audited |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | CID003583 | Audited |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA | CID003609 | Audited |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | CID003868 | Audited |
* “Audited” means in accordance with and as reported by the RMAP.
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