UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
HURCO COMPANIES, INC.
(Exact name of registrant as specified in its charter)
| Indiana | 000-09143 | 35-1150732 |
| (State or other | (Commission | (IRS Employer |
| jurisdiction of | File Number) | Identification No.) |
| incorporation) |
One Technology Way
Indianapolis, IN 46268
(Address of principal executive offices) (Zip Code)
|
Sonja K. McClelland Vice President, Secretary, Treasurer and Chief Financial Officer (317) 293-5309 |
| (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:
| þ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Form SD of Hurco Companies, Inc. (“Hurco,” the “Company,” “we,” “our” or “us”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Conflict Mineral Rule”), for the reporting period January 1, 2015 to December 31, 2015. The scope of this report includes all of Hurco’s products, except those manufactured and sold under the Milltronics and Takumi brands of CNC machine tools, which brands were acquired by Hurco in July 2015 when it acquired substantially all of the assets of Milltronics Manufacturing Company, Inc. and Takumi Machinery Co., Ltd. In accordance with the Conflict Minerals Rule, we are delaying reporting on these products until the Form SD for the calendar year 2017 reporting period.
We design, manufacture and sell computerized (i.e., Computer Numeric Control) machine tools, consisting primarily of vertical machining centers (mills) and turning centers (lathes), to companies in the metal cutting industry through a worldwide sales, service and distribution network. Although our computer control systems and software products are proprietary, they predominantly use industry standard personal computer components. Our computer control systems and software products are primarily sold as integral components of our computerized machine tool products.
We have determined that certain of our products contain columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten, that are necessary to the functionality or production of those products (such minerals are referred to as “necessary conflict minerals”).
We conducted a good faith inquiry that was reasonably designed to determine whether any necessary conflict minerals contained in our products originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”), or were from recycled or scrap sources. As part of this inquiry, we conducted a supply chain survey of our direct suppliers using the Conflict Minerals Reporting Template created by the Electronics Industry Citizenship Coalition/Global e-Sustainability Initiative and a customized conflict minerals questionnaire to collect sourcing information related to necessary conflict minerals in our products.
Conflict Minerals Disclosure
With respect to necessary conflict minerals in our products, based on the results of our inquiry, we had reason to believe that such conflict minerals may have originated in the Covered Countries and may not be from recycled or scrap sources. Accordingly, we exercised due diligence on the source and chain of custody of such necessary conflict minerals, as described in the Conflict Minerals Report attached as Exhibit 1.01 to this Form SD.
A copy of this Form SD, including the Conflict Minerals Report attached hereto as Exhibit 1.01, is publicly available on our website at www.hurco.com under the “Investors” section.
Item 1.02 Exhibits
As specified in Section 2, Item 2.01, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.
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Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this Form SD.
| Exhibit No. | Description | |
| 1.01 | Conflict Minerals Report of Hurco Companies, Inc. |
| 3 |
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.
Date: May 31, 2016
| HURCO COMPANIES, INC. | ||
| By: | /s/ Sonja K. McClelland | |
| Name: | Sonja K. McClelland | |
| Title: | Vice President, Secretary, Treasurer and Chief Financial Officer | |
| 4 |
EXHIBIT INDEX
| Exhibit | Description | |
| 1.01 | Conflict Minerals Report of Hurco Companies, Inc. |
| 5 |
Exhibit 1.01
Hurco Companies, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2015
Overview
This conflict minerals report for the year ended December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products (“necessary conflict minerals”). “Conflict minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten. These requirements apply to registrants whatever the geographic origin of the necessary conflict minerals.
If a registrant can establish that the necessary conflict minerals in its products originated from sources other than the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”), or from recycled and scrap sources, the registrant must submit a specialized disclosure report under Form SD that describes the steps that the registrant took to determine the origin of the necessary conflict minerals in its products.
If a registrant knows or has reason to believe that any of the necessary conflict minerals in its products may have originated in the DRC or an adjoining country, or knows or has reason to believe that the necessary conflict minerals may not be solely from recycled or scrap sources, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody, and the registrant must annually submit a conflict minerals report to the SEC that includes a description of those due diligence measures.
Company and Supply Chain Description
This disclosure has been prepared by management of Hurco Companies, Inc. (herein referred to as “Hurco” the “Company”, “we,” “us,” or “our”). Hurco is an industrial technology company that designs, manufactures and sells computerized (i.e., Computer Numeric Control) machine tools, consisting primarily of vertical machining centers (mills) and turning centers (lathes), to companies in the metal cutting industry. The scope of this report includes all of Hurco’s products, except those manufactured and sold under the Milltronics and Takumi brands of CNC machine tools, which brands were acquired by Hurco in July 2015 when it acquired substantially all of the assets of Milltronics Manufacturing Company, Inc. and Takumi Machinery Co., Ltd. In accordance with the Rule, we are delaying reporting on these products until the Form SD for the calendar year 2017 reporting period.
Our products, such as our proprietary control systems that include printed circuit boards, connectors, liquid crystal displays, touch screens, and keypads, may contain necessary conflict minerals. In addition, various components of our products, such as motors and drives and encoders, contain electronic components that may contain conflict minerals. We determined that during the 2015 calendar year, we manufactured and sub-contracted to manufacture products that use purchased components containing conflict minerals and that the use of these minerals is necessary to the functionality or production of those products.
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We are a downstream consumer of necessary conflict minerals. In most cases, there are several layers of third parties in the supply chain between the original source of the minerals and us. The majority of our direct suppliers are several steps removed from smelters and mines, purchasing their components and products from suppliers who are also removed from direct interaction with smelters, refiners and mines. Many of our suppliers and sub-suppliers also supply to other manufacturers of machine tools and accessories. Since we do not purchase necessary conflict minerals directly from mines, smelters or refiners, we rely on our direct suppliers to provide information regarding the origin of these minerals.
Reasonable Country of Origin Inquiry
We conducted in good faith a reasonable country of origin inquiry (“RCOI”) to determine whether or not any of the necessary conflict minerals in our products originated in the Covered Countries or were from recycled or scrap sources. The methods we employed to determine the origin of necessary conflict minerals in our products were:
| · | Identifying relevant suppliers whom we believed were likely to provide us with components and raw materials containing necessary conflict minerals; |
| · | Sending letters to our direct suppliers explaining the Rule and our disclosure obligations; |
| · | Soliciting survey responses from direct suppliers of components of our products, using the Conflict Minerals Reporting Template created by the Electronics Industry Citizenship Coalition (“EICC”)/Global e-Sustainability Initiative (“GeSI”) (the “EICC/GeSI Conflict Mineral Reporting Template”) and a customized conflict minerals questionnaire to identify the smelters and refiners of necessary conflict minerals in our supply chain; |
| · | Sending reminders and following up with suppliers that did not respond to our requests for information; and |
| · | Reviewing responses that we received from our suppliers and following up by email and telephone with those whose responses appeared to be incomplete, incorrect, or not reliable. |
Due Diligence Program
Pursuant to the Company’s Conflict Minerals policy, we developed a due diligence framework utilizing the Organisation for Economic Co-operation and Development (the “OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements for gold and for tin, tantalum and tungsten. We work closely with our direct suppliers to determine the potential use of conflict minerals in our supply chain and request our suppliers to conduct the necessary due diligence to provide us with proper verification of the source and chain of custody of the materials used in their products. We have also adopted and communicated to the public a company policy on conflict minerals. This policy can be found at the following website: http://www.hurco.com/en-us/about-hurco/investors/Documents/Conflict_Minerals_Policy.pdf.
The due diligence measures performed for the reporting year ended December 31, 2015 are summarized below.
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Establish Strong Company Management Systems.
We have structured a task force comprised of individuals from the Supply Chain Management, Procurement, Engineering, and Finance departments within the Company to support the process of supply chain due diligence. We have held meetings with management from various departments to identify products that are affected by the conflict minerals and mapped them to their respective suppliers. From the risks identified in our supply chain, we established a strategy to respond to those risks by strengthening governance and communication with suppliers.
Identify and Assess Risk in the Supply Chain.
We developed a risk-based approach that focused on our direct suppliers that we believed were likely to provide us with components and raw materials containing necessary conflict minerals. This was accomplished by members of the task force reviewing the listing of components and raw materials provided by our direct suppliers and identifying those components and raw materials that may contain necessary conflict minerals. As a result, we developed a customized conflict minerals questionnaire using the template developed by the EICC and the GeSI as guidance.
We sent these customized questionnaires and a survey using the EICC/GeSI Conflict Minerals Reporting Template to our eight identified direct suppliers and requested information about the source of conflict minerals contained in the components supplied to us. All eight of our direct suppliers responded to our inquiries, of which seven suppliers responded “yes” to the presence of conflict minerals in their products. However, these seven suppliers provided their responses to us at a company-wide level, rather than at a product level specific to the materials they supplied to us. Therefore, for necessary conflict minerals sourced from these direct suppliers, we were unable to determine which, if any, of the smelters and countries of origin listed in their responses were the actual source of necessary conflict minerals they supplied. We intend to continue to work with our direct suppliers in the future to obtain and validate the names of smelters/refiners and related countries of origin that supply conflict minerals for our products. Using our supply chain due diligence processes, we hope to further develop transparency into our supply chain.
Design and Implement a Strategy to Respond to Identified Risks.
As part of our risk management plan, to ensure that our suppliers understand our expectations, we have described our intention to source responsibly in our policy on conflict minerals, which can be found at http://www.hurco.com/en-us/about-hurco/investors/Documents/Conflict_Minerals_Policy.pdf. In addition, the Company has taken and continues to take steps to manage risks, including: engaging with manufacturers and suppliers to obtain current, accurate and complete information about the Company’s supply chains; encouraging manufacturers and suppliers to implement responsible sourcing and asking manufacturers and suppliers to encourage smelters and refiners to obtain a “conflict-free” designation from an independent, third-party auditor and taking part in industry initiatives promoting “conflict-free” supply chains.
Reliance on Independent Third-Party Audit of Supply Chain Due Diligence at the Smelter/ Refiner Level.
As mentioned above in the Company and Supply Chain Description, we conducted a survey of our eight direct suppliers using a customized questionnaire and the EICC/GeSI Conflict Minerals Reporting Template. However, we do not have direct relationships with conflict minerals smelters and refiners in our supply chain; thus, we do not perform direct audits of the entities that provide our supply chain with the necessary conflict minerals. We do rely upon the published results of audits conducted by the Conflict-Free Sourcing Initiative and other recognized certification programs in order to comply with OECD guidance to conduct independent third party audits. We also rely upon industry efforts to influence smelters and refineries to participate in the EICC/GeSI Conflict-Free Smelter Program (“CFSP”).
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Report on Supply Chain Due Diligence.
The Company has filed with the SEC its specialized disclosure report on Form SD, which includes this Conflict Minerals Report as Exhibit 1.01, for the reporting period from January 1, 2015 to December 31, 2015. In accordance with OECD Guidance and the Rule, the Company has also made these disclosures available on its website at www.hurco.com under the “Investors” section.
Due Diligence Results
As described above, components of our products contain conflict minerals that are necessary to the functionality or production of those products. Based on the information we have obtained pursuant to our good faith reasonable country of origin inquiry and due diligence process, our direct suppliers provided us with the 344 smelters (listed in Exhibit A) as potentially having processed the necessary conflict minerals used in our products during 2015.
The below table summarizes certain information pertaining to 344 smelters identified as of May 16, 2016:
| Total number of smelters identified by direct suppliers | 344 | |||
| Number of smelters determined to be “Compliant” by the CFSP | 201 | |||
| Number of “Active/In progress” smelters ** | 44 | |||
| Number for which further information is needed to determine status (“Unclassified" smelters) | 99 |
**“Active/In progress” smelters are those who have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs.
Although we request that our direct suppliers provide responses at the product-level, as stated above, all of our direct suppliers that responded “yes” to the presence of conflict minerals in their products provided responses at the company-level, meaning that they reported the smelter information for all of their products, not just for the products sold to us. As such, our list of smelters disclosed in Exhibit A contains more smelters than those that actually process or refine the necessary conflict minerals contained in our products.
| 9 |
Continuous Improvement Efforts to Mitigate Risk
The due diligence discussed above is an ongoing process. For 2016, we intend to take the following steps to refine procedures to meet the goals and adhere to values set forth in our Conflict Minerals policy:
| · | Continue to conduct and report annually on supply chain due diligence for the applicable conflict minerals; |
| · | Continue to enhance our supplier validation program intended to promote supplier engagements and enhance supplier knowledge of responsible sourcing from the Covered Countries; |
| · | Continue to encourage our suppliers to establish an alternative source of conflict minerals, if any are found to be supplying the Company with conflict minerals from sources that support armed conflict in the Covered Countries; |
| · | Continue to work with our suppliers who have indicated the presence of conflict minerals at a company-wide level to obtain product-level declarations in order to refine the smelter list to include only actual verified smelters within our supply chain; and |
| · | Continue to work to improve the accuracy of the smelter list. |
Independent Private Sector Audit
Not applicable.
| 10 |
Exhibit A
| Subject Mineral | Smelter or Refiner Name |
Country Location of Smelter or Refiner |
CFSI Status as of May 16, 2016 |
| Gold | Advanced Chemical Company | UNITED STATES | Active |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant |
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | Unclassified |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Unclassified |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Active |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant |
| Gold | Argor-Heraeus SA | SWITZERLAND | Unclassified |
| Gold | Asahi Pretec Corporation | JAPAN | Unclassified |
| Gold | Asahi Refining Canada Limited | CANADA | Unclassified |
| Gold | Asahi Refining USA Inc. | UNITED STATES | Compliant |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Unclassified |
| Gold | Aurubis AG | GERMANY | Compliant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant |
| Gold | Bauer Walser AG | GERMANY | Unclassified |
| Gold | Boliden AB | SWEDEN | Compliant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant |
| Gold | Caridad | MEXICO | Unclassified |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Compliant |
| Gold | Cendres + Métaux SA | SWITZERLAND | Unclassified |
| Gold | Chimet S.p.A. | ITALY | Compliant |
| Gold | China National Gold Group Corporation | CHINA | Unclassified |
| Gold | Chugai Mining | JAPAN | Unclassified |
| Gold | Colt Refining | UNITED STATES | Unclassified |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Active |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Unclassified |
| Gold | DODUCO GmbH | GERMANY | Compliant |
| Gold | Dowa | JAPAN | Compliant |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Active |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant |
| Gold | Elemetal Refining, LLC | UNITED STATES | Compliant |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Compliant |
| Gold | Faggi Enrico S.p.A. | ITALY | Active |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Unclassified |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Unclassified |
| Gold | Geib Refining Corporation | UNITED STATES | Active |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Unclassified |
| Gold | Guangdong Jinding Gold Limited | CHINA | Unclassified |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Unclassified |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Unclassified |
| Gold | Heimerle + Meule GmbH | GERMANY | Compliant |
| Gold | Heraeus Ltd. Hong Kong | CHINA | Compliant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant |
| 11 |
| Subject Mineral | Smelter or Refiner Name |
Country Location of Smelter or Refiner |
CFSI Status as of May 16, 2016 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Unclassified |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Unclassified |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant |
| Gold | Istanbul Gold Refinery | TURKEY | Compliant |
| Gold | Japan Mint | JAPAN | Compliant |
| Gold | Jiangxi Copper Company Limited | CHINA | Unclassified |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Compliant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Unclassified |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Unclassified |
| Gold | Kazzinc | KAZAKHSTAN | Compliant |
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Compliant |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | Active |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Compliant |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | Unclassified |
| Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF | Unclassified |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Unclassified |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA | Unclassified |
| Gold | Lingbao Gold Company Limited | CHINA | Unclassified |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Unclassified |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Unclassified |
| Gold | Materion | UNITED STATES | Compliant |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant |
| Gold | Metahub Industries Sdn. Bhd. | MALAYSIA | Unclassified |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Active |
| Gold | Metalor Technologies SA | SWITZERLAND | Unclassified |
| Gold | Metalor USA Refining Corporation | UNITED STATES | Compliant |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Unclassified |
| Gold | Mitsubishi Materials Corporation | JAPAN | Compliant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant |
| Gold | Morris and Watson | NEW ZEALAND | Unclassified |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Compliant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Active |
| Gold | Nihon Material Co., Ltd. | JAPAN | Compliant |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | Unclassified |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant |
| Gold | PAMP SA | SWITZERLAND | Unclassified |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Unclassified |
| 12 |
| Subject Mineral | Smelter or Refiner Name |
Country Location of Smelter or Refiner |
CFSI Status as of May 16, 2016 |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Compliant |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant |
| Gold | PX Précinox SA | SWITZERLAND | Unclassified |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant |
| Gold | Republic Metals Corporation | UNITED STATES | Compliant |
| Gold | Royal Canadian Mint | CANADA | Compliant |
| Gold | SAAMP | FRANCE | Unclassified |
| Gold | Sabin Metal Corp. | UNITED STATES | Unclassified |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Active |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Unclassified |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Active |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Compliant |
| Gold | SEMPSA Joyería Platería SA | SPAIN | Unclassified |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Unclassified |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant |
| Gold | Singway Technology Co., Ltd. | TAIWAN | Compliant |
| Gold | So Accurate Group, Inc. | UNITED STATES | Unclassified |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Compliant |
| Gold | Sudan Gold Refinery | SUDAN | Unclassified |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant |
| Gold | T.C.A S.p.A | ITALY | Compliant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Compliant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Unclassified |
| Gold | Tony Goetz NV | BELGIUM | Unclassified |
| Gold | Torecom | KOREA, REPUBLIC OF | Active |
| Gold | Umicore Brasil Ltda. | BRAZIL | Compliant |
| Gold | Umicore Precious Metals Thailand | THAILAND | Compliant |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Unclassified |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Compliant |
| Gold | Valcambi SA | SWITZERLAND | Unclassified |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Compliant |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Active |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Compliant |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Compliant |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Unclassified |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Compliant |
| Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM | Unclassified |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Compliant |
| Tantalum | D Block Metals, LLC | UNITED STATES | Compliant |
| Tantalum | Duoluoshan | CHINA | Compliant |
| Tantalum | E.S.R. Electronics | UNITED STATES | Active |
| Tantalum | Exotech Inc. | UNITED STATES | Compliant |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Compliant |
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| Subject Mineral | Smelter or Refiner Name |
Country Location of Smelter or Refiner |
CFSI Status as of May 16, 2016 |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Compliant |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | Unclassified |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Compliant |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Compliant |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Compliant |
| Tantalum | H.C. Starck Inc. | UNITED STATES | Compliant |
| Tantalum | H.C. Starck Ltd. | JAPAN | Compliant |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Compliant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Compliant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Compliant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
| Tantalum | KEMET Blue Metals | MEXICO | Compliant |
| Tantalum | KEMET Blue Powder | UNITED STATES | Compliant |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Compliant |
| Tantalum | LSM Brasil S.A. | BRAZIL | Compliant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Compliant |
| Tantalum | Mineração Taboca S.A. | BRAZIL | Compliant |
| Tantalum | Mitsui Mining & Smelting | JAPAN | Compliant |
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Compliant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant |
| Tantalum | Plansee SE Liezen | AUSTRIA | Compliant |
| Tantalum | Plansee SE Reutte | AUSTRIA | Compliant |
| Tantalum | QuantumClean | UNITED STATES | Compliant |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Compliant |
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | CHINA | Unclassified |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant |
| Tantalum | Taki Chemicals | JAPAN | Compliant |
| Tantalum | Telex Metals | UNITED STATES | Compliant |
| Tantalum | Tranzact, Inc. | UNITED STATES | Compliant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Compliant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant |
| Tantalum | Zhuzhou Cemented Carbide | CHINA | Compliant |
| Tin | Alpha | UNITED STATES | Compliant |
| Tin | An Thai Minerals Company Limited | VIET NAM | Unclassified |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Active |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | CHINA | Unclassified |
| Tin | China Tin Group Co., Ltd. | CHINA | Compliant |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Unclassified |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Compliant |
| Tin | CV Ayi Jaya | INDONESIA | Compliant |
| Tin | CV Dua Sekawan | INDONESIA | Active |
| 14 |
| Subject Mineral | Smelter or Refiner Name |
Country Location of Smelter or Refiner |
CFSI Status as of May 16, 2016 |
| Tin | CV Gita Pesona | INDONESIA | Compliant |
| Tin | CV Makmur Jaya | INDONESIA | Unclassified |
| Tin | CV Serumpun Sebalai | INDONESIA | Compliant |
| Tin | CV Tiga Sekawan | INDONESIA | Active |
| Tin | CV United Smelting | INDONESIA | Compliant |
| Tin | CV Venus Inti Perkasa | INDONESIA | Compliant |
| Tin | Dowa | JAPAN | Compliant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Active |
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Unclassified |
| Tin | EM Vinto | BOLIVIA | Compliant |
| Tin | Estanho de Rondônia S.A. | BRAZIL | Unclassified |
| Tin | Feinhütte Halsbrücke GmbH | GERMANY | Unclassified |
| Tin | Fenix Metals | POLAND | Compliant |
| Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | Unclassified |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Active |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Active |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Unclassified |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Active |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Active |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Unclassified |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Compliant |
| Tin | Jiangxi Nanshan | CHINA | Unclassified |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | Unclassified |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Compliant |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant |
| Tin | Melt Metais e Ligas S/A | BRAZIL | Unclassified |
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA | Unclassified |
| Tin | Metallic Resources, Inc. | UNITED STATES | Compliant |
| Tin | Metallo Chimique | BELGIUM | Unclassified |
| Tin | Metallo-Chimique N.V. | BELGIUM | Compliant |
| Tin | Mineração Taboca S.A. | BRAZIL | Compliant |
| Tin | Minsur | PERU | Compliant |
| Tin | Mitsubishi Materials Corporation | JAPAN | Compliant |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Unclassified |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Active |
| Tin | Novosibirsk Integrated Tin Works | RUSSIAN FEDERATION | Unclassified |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Compliant |
| Tin | Phoenix Metal Ltd. | RWANDA | Active |
| Tin | PT Alam Lestari Kencana | INDONESIA | Unclassified |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Compliant |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Compliant |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant |
| Tin | PT Babel Inti Perkasa | INDONESIA | Compliant |
| Tin | PT Babel Surya Alam Lestari | INDONESIA | Unclassified |
| Tin | PT Bangka Kudai Tin | INDONESIA | Unclassified |
| Tin | PT Bangka Prima Tin | INDONESIA | Compliant |
| Tin | PT Bangka Putra Karya | INDONESIA | Unclassified |
| 15 |
| Subject Mineral | Smelter or Refiner Name |
Country Location of Smelter or Refiner |
CFSI Status as of May 16, 2016 |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | Unclassified |
| Tin | PT Bangka Tin Industry | INDONESIA | Compliant |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Compliant |
| Tin | PT BilliTin Makmur Lestari | INDONESIA | Compliant |
| Tin | PT Bukit Timah | INDONESIA | Compliant |
| Tin | PT Cipta Persada Mulia | INDONESIA | Compliant |
| Tin | PT Donna Kembara Jaya | INDONESIA | Unclassified |
| Tin | PT DS Jaya Abadi | INDONESIA | Compliant |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Compliant |
| Tin | PT Fang Di MulTindo | INDONESIA | Unclassified |
| Tin | PT HANJAYA PERKASA METALS | INDONESIA | Unclassified |
| Tin | PT HP Metals Indonesia | INDONESIA | Unclassified |
| Tin | PT Inti Stania Prima | INDONESIA | Compliant |
| Tin | PT Justindo | INDONESIA | Compliant |
| Tin | PT Karimun Mining | INDONESIA | Active |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Active |
| Tin | PT Koba Tin | INDONESIA | Unclassified |
| Tin | PT Mitra Stania Prima | INDONESIA | Compliant |
| Tin | PT Panca Mega Persada | INDONESIA | Compliant |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | Unclassified |
| Tin | PT Prima Timah Utama | INDONESIA | Compliant |
| Tin | PT Rajwa International | INDONESIA | Unclassified |
| Tin | PT Refined Bangka Tin | INDONESIA | Compliant |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Compliant |
| Tin | PT Seirama Tin Investment | INDONESIA | Unclassified |
| Tin | PT Singkep Times Utama | INDONESIA | Unclassified |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Compliant |
| Tin | PT Sukses Inti Makmur | INDONESIA | Compliant |
| Tin | PT Sumber Jaya Indah | INDONESIA | Compliant |
| Tin | PT Supra Sukses Trinusa | INDONESIA | Unclassified |
| Tin | PT Tambang Timah | INDONESIA | Unclassified |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Compliant |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Compliant |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Compliant |
| Tin | PT Tirus Putra Mandiri | INDONESIA | Unclassified |
| Tin | PT Tommy Utama | INDONESIA | Compliant |
| Tin | PT Wahana Perkit Jaya | INDONESIA | Compliant |
| Tin | PT Yinchendo Mining Industry | INDONESIA | Unclassified |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant |
| Tin | Rui Da Hung | TAIWAN | Compliant |
| Tin | Soft Metais Ltda. | BRAZIL | Compliant |
| Tin | Thaisarco | THAILAND | Compliant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Active |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Compliant |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Compliant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Active |
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Unclassified |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Compliant |
| Tungsten | ACL Metais Eireli | BRAZIL | Active |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Compliant |
| 16 |
| Subject Mineral | Smelter or Refiner Name |
Country Location of Smelter or Refiner |
CFSI Status as of May 16, 2016 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | In Progress |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | In Progress |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | Unclassified |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | In Progress |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Compliant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | H.C. Starck GmbH | GERMANY | Compliant |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant |
| Tungsten | HC Starck GmbH | GERMANY | Unclassified |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Compliant |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA | Unclassified |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | In Progress |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Active |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Active |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Unclassified |
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | CHINA | Unclassified |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | In Progress |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | In Progress |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | In Progress |
| Tungsten | Kennametal Fallon | UNITED STATES | In Progress |
| Tungsten | Kennametal Huntsville | UNITED STATES | Compliant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Active |
| Tungsten | Niagara Refining LLC | UNITED STATES | Compliant |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Compliant |
| Tungsten | Philippine Chuangin Industrial Co., Inc. | PHILIPPINES | Unclassified |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | In Progress |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM | Unclassified |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | In Progress |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Compliant |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | VIET NAM | Unclassified |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Compliant |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Compliant |
| Tungsten | Wolfram Company CJSC | RUSSIAN FEDERATION | Unclassified |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | In Progress |
| 17 |
| Subject Mineral | Smelter or Refiner Name |
Country Location of Smelter or Refiner |
CFSI Status as of May 16, 2016 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | In Progress |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant |
| 18 |