QUALCOMM Incorporated
Conflict Minerals Report
Reporting Period: January 1, 2021 – December 31, 2021
We are a global leader in the development and commercialization of foundational technologies for the wireless industry. Our technologies and products1 are used in mobile devices and other wireless products, including those used in the internet of things (IoT) and automotive systems for telematics, connectivity and digital cockpit (also known as infotainment). Our inventions have helped power the growth in smartphones, which have connected billions of people. We are a leader in 3G (third generation), 4G (fourth generation) and 5G (fifth generation) wireless technologies. We derive revenues principally from sales of integrated circuit products (products), including our Snapdragon® family of highly-integrated, system-based solutions, and licensing of our intellectual property, including patents and other rights.
Qualcomm Incorporated includes our licensing business and the vast majority of our patent portfolio. Qualcomm Technologies, Inc., a subsidiary of Qualcomm Incorporated, operates, along with its subsidiaries, substantially all of our engineering and research and development functions, and substantially all of our products and services businesses, including our integrated circuit business. In this document, the words “we,” “our” and “us” refer only to Qualcomm Incorporated, Qualcomm Technologies, Inc. and/or their subsidiaries.
This Conflict Minerals Report (this Report) contains forward-looking statements regarding our business, products and our efforts to mitigate the risk that conflict minerals (as defined below) in our products directly or indirectly finance or benefit armed groups (identified as a perpetrator of serious human rights abuses) in the Democratic Republic of the Congo (the DRC) or an adjoining country (a country that shares an internationally recognized border with the DRC). The DRC and adjoining countries are collectively referred to as the “Covered Countries.” The Covered Countries include Angola, Burundi, Central Africa Republic, Congo, Democratic Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia. Words such as “expects,” “intends,” “believes,” “strives” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this Report. Additionally, statements concerning future matters that are not historical are forward-looking statements.
Although forward-looking statements in this Report reflect our good faith judgment, such statements can only be based on facts and factors currently known by us. Consequently, forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include without limitation: the risk that information reported to us by our suppliers from which we directly procure finished goods, components, materials and/or services for our products (direct suppliers), or industry information used by us, may be inaccurate or incomplete; and the risk that smelters or refiners (processing facilities) may not participate in the Responsible Minerals Assurance Process (RMAP), which is a voluntary initiative in which independent third parties audit processing facilities’ procurement and processing activities and determine if the processing facilities maintain sufficient documentation to reasonably demonstrate conflict free sourcing; as well as risks discussed under the heading “Risk Factors” in our most recent Quarterly Report on Form 10-Q, including those related to our dependence on a limited number of third-party suppliers, the operation and control of our manufacturing facilities, and our being subject to government regulations and policies. Readers are urged not to place undue reliance on forward-looking statements, which speak only as of the date of this
1 All of our products referenced herein, including but not limited to Qualcomm Snapdragon, Qualcomm Hexagon and Qualcomm Adreno, are products of Qualcomm Technologies, Inc. and/or its subsidiaries.
Report. We undertake no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this Report. Throughout this Report, whenever a reference is made to our website, such reference does not incorporate information from the website by reference into this Report unless specifically identified as such.
Background
Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act, the United States Securities and Exchange Commission (SEC) promulgated a rule (the Final Rule) requiring certain companies with conflict minerals (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 a product manufactured by or for that company to, among other things, disclose annually whether any of those conflict minerals originated in the Covered Countries; and if so, to submit a report to the SEC that includes a description of the measures it took to exercise due diligence on the conflict minerals’ source and chain of custody.
The Responsible Business Alliance (RBA) and the Global e-Sustainability Initiative (GeSI) established an initiative that is known as the Responsible Minerals Initiative (RMI). The RMI, which is comprised of over 430 companies from multiple industries, together with the RBA and GeSI, strive to provide companies with tools and resources to make sourcing decisions that improve regulatory compliance and support responsible sourcing from conflict-affected and high-risk areas.
We are a full member of the RBA, have adopted the RBA Code of Conduct and expect all of our direct suppliers to act in accordance with this Code of Conduct. By employing RBA tools and working collaboratively with our peers, we are working to improve transparency and sustainability in the global electronics supply chain. We actively participate in and support responsible sourcing initiatives of the RMI.
We, along with many other companies, rely on the RMI’s RMAP to verify processing facilities as not directly or indirectly financing or benefiting armed groups in the Covered Countries (RMAP-Conformant). The RMI also recognizes responsible sourcing practices of processing facilities that have been accredited by the London Bullion Market Association (LBMA) or certified by the Responsible Jewellery Council (RJC).
Summary
In accordance with the Final Rule, we conducted in good faith a reasonable country of origin inquiry (RCOI) that was reasonably designed to determine whether any of the necessary conflict minerals in our products originated in the Covered Countries or were from recycled or scrap sources.
Based on our RCOI, we believe that some of the necessary conflict minerals used in our products originated in one or more of the Covered Countries (and are not from recycled or scrap sources). Accordingly, we exercised due diligence to determine the source and chain of custody of these conflict minerals. Our due diligence was designed to conform to an internationally recognized due diligence framework, specifically the Organisation for Economic Co-operation and Development (OECD) “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas,” 3rd edition (2016) (OECD Guidance).
Following the exercise of our due diligence (which is inherently subject to and limited by our ability to obtain reliable mine or location of origin information for conflict minerals that are used specifically in our products), we have not identified any instances in which our sourcing of necessary conflict minerals directly or indirectly financed or benefitted armed groups in the Covered Countries.
Product Description
Our products are sold to manufacturers that use our products in a broad range of devices, from low-tier, entry-level devices primarily for emerging regions to premium-tier devices, including but not limited to mobile devices (primarily smartphones), tablets, laptops, XR headsets, data modules, gaming devices, voice and music devices, wearable devices, wireless access points and routers, broadband gateway equipment, data cards and infrastructure equipment, sensor hubs and other industrial equipment and automotive systems for telematics, connectivity and digital cockpit.
The Snapdragon family of highly-integrated, system-based solutions include the Snapdragon® mobile, compute, sound and automotive platforms. Each platform consists of application processors and wireless connectivity capabilities, including our cellular modem that provides core baseband modem functionality for voice and data communications, non-cellular wireless connectivity (such as Wi-Fi and Bluetooth®) and global positioning functions. Our Snapdragon application processor functions include CPU security, graphics, display, audio, video, camera and artificial intelligence (AI). Our CPUs are designed based on the ARM architecture and are designed to deliver high levels of compute performance with optimized power consumption. Our Qualcomm® Hexagon™ processors are designed to support a variety of signal processing applications, including AI, audio and sensor processing. Our Qualcomm® Adreno™ graphics processing units are designed to deliver high quality graphics performance for visually rich 3D gaming and user interfaces. In addition to the highly integrated core SoC (system on chip), we also design and supply supporting components, including the RF (radio frequency) transceiver, PM (power management), audio, codecs, speaker amps and additional wireless connectivity integrated circuits. Our portfolio of RF products includes Qualcomm® radio frequency front-end (RFFE) components that are designed to simplify the RF design for 5G front-end, LTE multimode and multiband mobile devices, including sub-6 GHz and millimeter wave devices, to reduce power consumption and to improve radio performance.
Our wireless connectivity products also consist of integrated circuits and system software products for Wi-Fi, Bluetooth and frequency modulation (FM), as well as technologies that support location data and services, including GPS, GLONASS, Galileo, NavIC and BeiDou. Our wireless connectivity products provide additional connectivity for mobile devices, tablets, laptops, XR headsets, voice and music devices, wearable devices, automotive telematics, digital cockpit, utility meters, logistic trackers and industrial sensors, in addition to other IoT devices and applications.
Description of Supply Chain
During the reporting period, other than for certain of our RFFE modules and RF filter products, we utilized a fabless production model in the manufacturing of our integrated circuits, which means that we did not own or operate foundries for the production of silicon wafers from which our integrated circuits were made. Therefore, we primarily rely on third parties to perform the manufacturing and assembly, and most of the testing, of our integrated circuits based primarily on our proprietary designs and test programs. Our suppliers also are responsible for the procurement of most of the raw materials used in the production of our integrated circuits. Integrated circuits are die cut from silicon wafers that have completed the package assembly and test manufacturing processes. The semiconductor package supports the electrical contacts that connect the integrated circuit to a circuit board. Die cut from silicon wafers are the essential components of all of our integrated circuits and a significant portion of the total integrated circuit cost. We employ both turnkey and two-stage manufacturing models to purchase our integrated circuits. Under the turnkey model, our foundry suppliers are responsible for delivering fully assembled and tested integrated circuits. Under the two-stage manufacturing model, we purchase die in singular or wafer form from semiconductor manufacturing foundries and contract with separate third parties for manufacturing services such as wafer bump, probe, assembly and the majority of our final test requirements.
We primarily used internal fabrication facilities to manufacture certain RFFE modules and RF filter products, and our manufacturing operations consist of front-end and back-end processes. The front-end processes primarily take place at our manufacturing facilities located in Germany and Singapore and involve the imprinting of substrate wafers with the structure and circuitry required for the products to function (also known as wafer fabrication). The back-end processes include the assembly, packaging and test of RFFE modules and RF filter products and their preparation for distribution. Our back-end manufacturing facilities are located in China and Singapore.
Certain materials purchased by our direct suppliers may come directly or indirectly from processing facilities that treat ores, concentrates, slags or secondary materials. Because we do not purchase any materials directly from these processing facilities, we must rely on the information provided by our direct suppliers and the RMI or other industry organizations in order to prepare this Report.
Policy on Responsible Sourcing of Minerals
Our policy on responsible sourcing of minerals communicates the expectation that our direct suppliers obtain materials from environmentally and socially responsible sources, including conflict free sources within the Covered Countries (available at: https://www.qualcomm.com/company/corporate-responsibility/responsible-business/sustainable-product-design/conflict-free-minerals).
Reasonable Country of Origin Inquiry
To conduct our RCOI and obtain sourcing information from our direct suppliers, we used the RMI Conflict Minerals Reporting Template (CMRT). We requested this information from 100% of our direct suppliers that may provide necessary conflict minerals in our products to determine whether any of these materials originated in the Covered Countries. We received CMRT responses from 100% of the direct suppliers of our products.
Our RCOI considered the countries of origin information obtained from our direct suppliers as well as RMAP-Conformant processing facilities’ country of origin data available to RMI members. Based on these sources of country of origin information, approximately 7% (17) of the processing facilities reported by our direct suppliers were confirmed as sourcing conflict minerals from the Covered Countries.
Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, to the framework provided by the OECD Guidance.
OECD Step 1: Establish Strong Company Management Systems
•We publicly communicate our policy on responsible sourcing of materials on our website.
•We maintain a conflict minerals working group with representation from our finance, government affairs, internal audit, legal, regulatory, quality and supply chain departments, which report on compliance activities to executive management and the Audit Committee of our Board of Directors.
•We include conflict free minerals requirements in purchasing documents to direct suppliers.
•We maintain a public contact form on our website for general inquiries and grievances regarding our conflict minerals program (available at:
https://assets.qualcomm.com/Q220-WB-Contact-Us-Corporate-Responsibility.html?corporate alert=conflictfree).
OECD Step 2: Identify and Assess Risk in the Supply Chain
•We use the CMRT to review our direct suppliers’ due diligence activities, such as whether they have a conflict minerals policy, require their own suppliers to source from RMAP-Conformant processing facilities and have a review process that includes corrective action management.
•We use the CMRT to identify conflict minerals processing facilities when reported in our supply chain by our direct suppliers.
•We obtain countries of origin information (when available) for RMAP-Conformant processing facilities by relying on data provided by our direct suppliers and the RMI.
•We conduct periodic on-site and remote assessments of select direct suppliers’ due diligence activities to validate CMRT responses and ensure our supplier requirements are being met.
OECD Step 3: Design and Implement a Strategy to Respond to Risk
•We maintain a conflict minerals risk management plan that sets forth direct supplier risk management strategies ranging from continued procurement to disengagement at the discretion of management.
•We support the development of due diligence practices through participation in RMI working groups.
•We report information on the source and chain of custody of conflict minerals in our supply chain to our conflict minerals working group, executive management and the Audit Committee of our Board of Directors.
OECD Step 4: Third-Party Audit of Processing Facilities’ Due Diligence Practices
•We use the publicly available results of the RMAP, LBMA and RJC third-party audits to validate the responsible sourcing practices of processing facilities in our supply chain.
•We support independent third-party audits of processing facilities through our RMI membership.
OECD Step 5: Report Annually on Supply Chain Due Diligence
•We file a Specialized Disclosure Report on Form SD and Conflict Minerals Report with the SEC on an annual basis. Our Form SD and Conflict Minerals Report are also available on our website.
•We provide information regarding our conflict minerals program on our website.
Description of Due Diligence Performed
Below is a description of the measures we performed for this reporting period to exercise due diligence on the source and chain of custody of the necessary conflict minerals in our products that may have originated in the Covered Countries.
•We conducted our supply chain survey on 100% of our direct suppliers that may use necessary conflict minerals in our products to determine whether any of these minerals originated in the Covered Countries or were from recycled or scrap sources.
•We determined if the processing facilities reported to us by our direct suppliers adhere to responsible sourcing practices by verifying whether they are RMAP-Conformant.
•We communicated and addressed, with our direct suppliers, instances identified in the CMRT in which our requirements were not met or quality issues were apparent. This communication reinforced our requirements to support the sourcing of materials from conflict free sources within the Covered Countries.
•We were members of non-profit and industry initiatives, including the RMI and the International Tin Research Institute Supply Chain Initiative (iTSCi) Programme.
•We reported on program activities to members of executive management and the Audit Committee of our Board of Directors.
Facilities Used to Process the Necessary Conflict Minerals in Our Products
We rely on the good faith efforts of our direct suppliers to provide us with reasonable representations of the processing facilities used to supply the necessary conflict minerals in our products. In the reporting period, 35% of our direct supplier responses represented their supply chain at a company level, 45% at a product level and 20% at a supplier-defined level (e.g., at a divisional or subsidiary level). As such, the list of processing facilities disclosed at the end of this Report may over-represent the number of processing facilities that process the conflict minerals actually contained in our products.
All processing facilities listed in this Report are reported by RMAP status in Table 1 in the section “Table of Conflict Minerals Processing Facilities” at the end of this Report.
Country of Origin of the Necessary Conflict Minerals in Our Products
Based on country of origin information provided by the RMI for RMAP-Conformant processing facilities, countries of origin of the necessary conflict minerals in our products may include: Andorra, Angola, Antigua and Barbuda, Argentina, Armenia, Australia, Austria, Azerbaijan, Bahamas, Bahrain, Bangladesh, Barbados, Belarus, Belgium, Benin, Bolivia, Bosnia & Herzegovina, Botswana, Brazil, Bulgaria, Burkina Faso, Burundi, Cameroon, Canada, Cayman Islands, Chile, China, Colombia, Costa Rica, Côte d'Ivoire, Croatia, Cuba*, Curacao, Cyprus, Czechia, Democratic Republic of the Congo, Denmark, Dominica, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Eswatini, Ethiopia, Fiji, Finland, France, French Guiana, Gabon, Georgia, Germany, Ghana, Greece, Grenada, Guatemala, Guernsey, Guinea, Guyana, Haiti, Honduras, Hong Kong, Hungary, Iceland, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Kenya, Kuwait, Kyrgyzstan, Laos, Latvia, Lebanon, Liberia, Libya, Liechtenstein, Lithuania, Luxembourg, Macau, Macedonia, Madagascar, Malaysia, Mali, Malta, Mauritania, Mexico, Monaco, Mongolia, Montenegro, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Norway, Oman, Pakistan, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Puerto Rico, Qatar, Republic of Korea, Romania, Russian Federation, Rwanda, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and Grenadines, San Marino, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Sint Maarten, Slovakia, Slovenia, Solomon Islands, South Africa, Spain, Sri Lanka, Sudan, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Turks and Caicos, Uganda, Ukraine, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Virgin Islands, Yemen, Zambia and Zimbabwe.
* Minerals from this country were substantially transformed before being incorporated into finished products. Such substantial transformation of the minerals happened outside of the United States by a person other than a United States person.
Our Efforts to Determine the Mine or Location of Origin of the Necessary Conflict Minerals in Our Products
We requested location of mine and location of origin information for the necessary conflict minerals contained in our products from each of our direct suppliers using the CMRT. In some instances, our direct suppliers reported the name or location of the mine. However, many of our direct suppliers were unable to obtain reliable mine or location of origin data for the necessary conflict minerals used in our products.
Steps We Have Taken to Mitigate the Risk that the Necessary Conflict Minerals in Our Products Benefit Armed Groups
We have worked with our direct suppliers on responsible sourcing and have actively participated in responsible sourcing initiatives of the RMI, as we continue to strive towards our goal of having the processing facilities that may supply conflict minerals contained in our products be 100% RMAP-Conformant. Additional information regarding the steps we have taken to mitigate the risk that conflict minerals that may be contained in our products benefit armed groups in the Covered Countries can be found under the sections “Design of Due Diligence” and “Description of Due Diligence Performed” above.
Figure 1 displays the RMAP status of processing facilities for our products in our supply chain from reporting years 2019 through 2021.
Figure 1: 2019-2021 Processing Facilities by RMAP Status
Note: RMAP-Conformant processing facilities are audited and found conformant with the relevant RMAP standard and include processing facilities currently undergoing a re-audit or processing facilities certified by the LBMA or RJC. RMAP-Active processing facilities have committed to undergo an RMAP audit but are not yet conformant. Non-Participating processing facilities meet or have met the definition of a smelter or refiner under the relevant RMAP standard but are not participating in the RMAP.
Steps We Will Take to Mitigate the Risk that the Necessary Conflict Minerals in Our Products Benefit Armed Groups
During reporting year 2022, we intend to conduct the following due diligence activities to continue to mitigate the risk that the necessary conflict minerals in our products directly or indirectly finance or benefit armed groups in the Covered Countries:
1.Engage with direct suppliers, processing facilities and the RMI to encourage Non-Participating processing facilities to become RMAP-Conformant;
2.Strive to use only direct suppliers that source from RMAP-Conformant processing facilities for our products;
3.Conduct on-site verification assessments of certain suppliers’ due diligence activities;
4.Conduct due diligence on new businesses acquired to assess the risk of conflict minerals in the acquired businesses’ supply chain; and
5.Participate in the following industry coalitions’ and non-governmental organizations’ efforts to support the responsible sourcing of minerals: RBA, RMI and ITRI (International Tin Research Institute).
Table of Conflict Minerals Processing Facilities
The processing facilities listed in Table 1 are processing facilities reported by our direct suppliers during the reporting period.
Table 1. Processing Facilities as of January 31, 2022
| | | | | | | | | | | |
| Metal | Processing Facility Name | Processing Facility Country | RMAP Status |
| Gold | Advanced Chemical Company | UNITED STATES | Conformant |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
| Gold | Asahi Pretec Corp. | JAPAN | Conformant |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Gold | Norddeutsche Affinererie AG | GERMANY | Conformant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
| Gold | Boliden AB | SWEDEN | Conformant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | Active |
| Gold | CCR | CANADA | Conformant |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant |
| Gold | Chimet S.p.A. | ITALY | Conformant |
| Gold | Chugai Mining | JAPAN | Conformant |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
| Gold | DODUCO GmbH | GERMANY | Conformant |
| Gold | Dowa Kogyo k.k. | JAPAN | Conformant |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant |
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
| | | | | | | | | | | |
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
| Gold | Heraeus Precious Metals GmbH & Co. KG* | GERMANY | Conformant |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | Istanbul Gold Refinery | TURKEY | Conformant |
| Gold | Japan Mint | JAPAN | Conformant |
| Gold | JCC | CHINA | Conformant |
| Gold | Johnson Matthey Inc. | UNITED STATES | Conformant |
| Gold | Johnson Matthey Limited | CANADA | Conformant |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant |
| Gold | Pan Pacific Copper Co Ltd. | JAPAN | Conformant |
| Gold | Kazzinc | KAZAKHSTAN | Conformant |
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Conformant |
| Gold | Kojima Kagaku Yakuhin Co., Ltd | JAPAN | Conformant |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
| Gold | Materion | UNITED STATES | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
| Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
| Gold | Metalor USA Refining Corporation | UNITED STATES | Conformant |
| Gold | Metalurgica Met-Mex Penoles, S.A. De C.V. | MEXICO | Conformant |
| Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Gold | Mitsui Kinzoku Co., Ltd. | JAPAN | Conformant |
| Gold | Federal State Unitary Enterprise Moscow Special Processing Plant (FSUE MZSS) | RUSSIAN FEDERATION | Conformant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant |
| Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | OJSC Krastsvetmet | RUSSIAN FEDERATION | Conformant |
| Gold | Produits Artistiques de Métaux | SWITZERLAND | Conformant |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
| Gold | PX Precinox S.A. | SWITZERLAND | Conformant |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | Royal Canadian Mint | CANADA | Conformant |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant |
| | | | | | | | | | | |
| Gold | Sempsa JP (Cookson Sempsa) | SPAIN | Conformant |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
| Gold | Shyolkovsky | RUSSIAN FEDERATION | Conformant |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Conformant |
| Gold | Niihama Toyo Smelter & Refinery | JAPAN | Conformant |
| Gold | Tanaka Electronics (Hong Kong) Pte. Ltd. | JAPAN | Conformant |
| Gold | Shandong Gold Mine(Laizhou) Smelter Co., Ltd. | CHINA | Conformant |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
| Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
| Gold | Metallurgie Hoboken Overpelt | BELGIUM | Conformant |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Conformant |
| Gold | Valcambi S.A. | SWITZERLAND | Conformant |
| Gold | AGR (Perth Mint Australia) | AUSTRALIA | Conformant |
| Gold | Yamamoto Precision Metals | JAPAN | Conformant |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
| Gold | Henan Zhongyuan Gold Refinery Co., Ltd. | CHINA | Conformant |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
| Gold | SAFINA A.S. | CZECH REPUBLIC | Conformant |
| Gold | Umicore Precious Metals Thailand | THAILAND | Conformant |
| Gold | Geib Refining Corporation | UNITED STATES | Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
| Gold | KGHM Polska Miedz S.A. | POLAND | Conformant |
| Gold | Singway Technology Co., Ltd. | TAIWAN | Conformant |
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Conformant |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
| Gold | T.C.A S.p.A | ITALY | Conformant |
| Gold | Remondis Argentia B.V. | NETHERLANDS | Conformant |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Marsam Metals | BRAZIL | Conformant |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant |
| Gold | SAAMP | FRANCE | Conformant |
| Gold | L'Orfebre S.A. | ANDORRA | Conformant |
| Gold | 8853 S.p.A. | ITALY | Conformant |
| Gold | Italpreziosi | ITALY | Conformant |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
| Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant |
| | | | | | | | | | | |
| Gold | BALORE REFINERSGA | INDIA | Conformant |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
| Gold | Safimet S.p.A | ITALY | Conformant |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | Conformant |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | Conformant |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Active |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | Conformant |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Tantalum | Changsha Southern | CHINA | Conformant |
| Tantalum | Exotech Inc. | UNITED STATES | Conformant |
| Tantalum | F & X | CHINA | Conformant |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | CHINA | Conformant |
| Tantalum | LSM Brasil S.A. | BRAZIL | Conformant |
| Tantalum | Metallurgical Products India Pvt. Ltd. (MPIL) | INDIA | Conformant |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Tantalum | NPM Silmet AS | ESTONIA | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
| Tantalum | QuantumClean | UNITED STATES | Conformant |
| Tantalum | Yanling Jincheng Tantalum Co., Ltd. | CHINA | Conformant |
| Tantalum | Solikamsk | RUSSIAN FEDERATION | Conformant |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
| Tantalum | Telex Metals | UNITED STATES | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
| Tantalum | D Block Metals, LLC | UNITED STATES | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | KEMET Blue Metals | MEXICO | Conformant |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant |
| | | | | | | | | | | |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
| Tantalum | H.C. Starck Inc. | UNITED STATES | Conformant |
| Tantalum | H.C. Starck Ltd. | JAPAN | Conformant |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Conformant |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
| Tantalum | Power Resources Ltd. | MACEDONIA (the former Yugoslav Republic of) | Conformant |
| Tin | Estanho de Rondonia S.A. | BRAZIL | Active |
| Tin | Yunnan Tin Company Limited | CHINA | Conformant |
| Tin | CV Venus Inti Perkasa | INDONESIA | Active |
| Tin | Super Ligas | BRAZIL | Active |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | Active |
| Tin | Chenzhou Yun Xiang mining limited liability company | CHINA | Conformant |
| Tin | Alent plc | UNITED STATES | Conformant |
| Tin | Dowa Metaltech Co., Ltd. | JAPAN | Conformant |
| Tin | Empresa Metalúrgica Vinto | BOLIVIA | Conformant |
| Tin | Fenix Metals | POLAND | Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
| Tin | Yunnan Geiju Zili Metallurgy Co. Ltd. | CHINA | Conformant |
| Tin | Kai Union Industry and Trade Co., Ltd. (China) | CHINA | Conformant |
| Tin | China Tin (Hechi) | CHINA | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
| Tin | Metallic Resources, Inc. | UNITED STATES | Conformant |
| Tin | Toboca/ Paranapenema | BRAZIL | Conformant |
| Tin | Minsur | PERU | Conformant |
| Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Tin | Nanshan Tin Co. Ltd. | CHINA | Conformant |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
| Tin | OMSA | BOLIVIA | Conformant |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
| Tin | PT Babel Surya Alam Lestari | INDONESIA | Conformant |
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
| Tin | PT Prima Timah Utama | INDONESIA | Conformant |
| Tin | Brand RBT | INDONESIA | Conformant |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
| Tin | Kundur Smelter | INDONESIA | Conformant |
| Tin | Mentok Smelter | INDONESIA | Conformant |
| Tin | Rui Da Hung | TAIWAN | Conformant |
| | | | | | | | | | | |
| Tin | Soft Metais Ltda. | BRAZIL | Conformant |
| Tin | Thailand Smelting & Refining Co Ltd | THAILAND | Conformant |
| Tin | The Gejiu cloud new colored electrolytic | CHINA | Conformant |
| Tin | White Solder Metalurgica | BRAZIL | Conformant |
| Tin | Yunnan Adventure Co., Ltd. | CHINA | Conformant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
| Tin | CV Tiga Sekawan | INDONESIA | Conformant |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
| Tin | Metallo Spain S.L.U. | SPAIN | Conformant |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | Conformant |
| Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | PT Bangka Serumpun | INDONESIA | Conformant |
| Tin | Tin Technology & Refining | UNITED STATES | Conformant |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | Conformant |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | Conformant |
| Tin | Luna Smelter, Ltd. | RWANDA | Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | Conformant |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | Active |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Conformant |
| Tungsten | Kennametal Huntsville | UNITED STATES | Conformant |
| Tungsten | Chaozhou Xianglu Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | Kennametal Fallon | UNITED STATES | Conformant |
| Tungsten | WBH | AUSTRIA | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Han River Pelican State Alloy Co., Ltd. | CHINA | Conformant |
| | | | | | | | | | | |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Xiamen H.C. | CHINA | Conformant |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | Niagara Refining LLC | UNITED STATES | Conformant |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant |
| Tungsten | ACL Metais Eireli | BRAZIL | Conformant |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Conformant |
| Tungsten | KGETS CO., LTD. | KOREA, REPUBLIC OF | Conformant |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | Conformant |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN | Conformant |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | Conformant |
