freqelec20220524_sd.htm

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

 


 

FORM SD

Specialized disclosure report

 


 

FREQUENCY ELECTRONICS, INC.

(Exact name of Registrant as specified in its charter)

 

Delaware

1-8061

(State or other jurisdiction of

incorporation or organization)

Commission File No.

 

     

55 CHARLES LINDBERGH BLVD., MITCHEL FIELD, N.Y.

 

11553

(Address of principal executive offices)

 

(Zip Code)

     

 

Steven Bernstein

516-794-4500

(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:

 

☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

 

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

 

 

 

 

 

Section 1.   Conflict Minerals Disclosure

 

Item 1.01  Conflict Minerals Disclosure and Report

 

(c) Conflict Minerals Report

 

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

 

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

 

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

 

Item 1.02  Exhibits

 

Exhibit 1.01  Conflict Minerals Report

 

Section 2.  Resource Extraction Issuer Disclosure

 

Item 2.01  Resource Extraction Issuer Disclosure and Report

 

Not applicable

 

Item 3.01   Exhibits

 

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

 

 

 

 

 

 

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.

 

 

FREQUENCY ELECTRONICS, INC.

(Registrant)

 
       

Date: May 27, 2022

By:

/s/ Steven Bernstein

 
   

Steven Bernstein

 
   

Chief Financial Officer, Secretary and Treasurer

 
       

 

 

 
ex_379489.htm

 

Exhibit 1.01

 

Frequency Electronics, Inc.

Conflict Minerals Report

For the Year Ended December 31, 2021

 

This Conflict Minerals Report for the year ended December 31, 2021 has been prepared by Frequency Electronics, Inc. (“Frequency” or the “Company,” “we,” “us,” or “our”) and is filed with the Securities and Exchange Commission (“SEC”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”), on a consolidated basis, in accordance with the instructions to Form SD, as modified by the Public Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued by the Director of the Division of Corporation Finance of the SEC on April 29, 2014 (the “SEC Statement”).

 

The Rule was adopted by 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 (“Dodd-Frank Act”).  The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products.  Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (3TGs) for the purposes of this assessment.  These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict in the Democratic Republic of Congo or an adjoining country (collectively, the “Covered Countries”).

 

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

 

1. Company Overview

 

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

 

2. Products Overview

 

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

 

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

 

3. Conflict Minerals Program & Policy

 

The Company has actively engaged with our customers and suppliers for several years with respect to the use of conflict minerals.

 

We adopted a Conflict Minerals Policy articulating our conflict minerals supply chain due diligence process and our commitment to our reporting obligations regarding conflict minerals. Our policy is available on our website https://freqelec.com/vendors/.

 

 

 

 

Reasonable Country of Origin Inquiry

 

To determine whether necessary 3TGs in our products originated in Covered Countries, we retained Assent Compliance (“Assent”), our third party service provider, to assist us in reviewing our supply chain. We provided a list composed of suppliers associated with the Covered Products to Assent for upload to the Assent Compliance Manager tool (“ACM”). We deemed it impractical to filter this list further to exclude some possibly irrelevant suppliers because we could not determine definitively the presence or absence of conflict minerals in all parts supplied to Frequency for our products.

 

Frequency utilized the Responsible Minerals Initiative’s Conflict Minerals Reporting Template (“CMRT”) version 6.10 to conduct a survey of all in scope suppliers. During the supplier survey, we contacted suppliers via the ACM. Assent requested that all suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. Frequency directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested such suppliers to complete the CMRT form and submit such form to Assent. The use of the CMRT allowed for some elimination of irrelevant suppliers. We also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process.

 

Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on:

 

 

Questions 1 and 2 are minimum requirements for the CMRT

 

 

If suppliers state (via Q1 and Q2) that their products do not contain 3TGs necessary to the function or production of said products, then no further information is required and no further data validation is completed.

 

 

Question 3 – Do any of your 3TGs originate from the covered countries?

 

 

Any supplier that has any 3TGs from the covered countries, even 1 positive response from their supply chain must answer yes.

 

 

Question 4– Is 100% of the 3TGs in question from a recycled source?

 

 

Question 5 – Have you received info from all relevant 3TGs Suppliers?

 

 

If you are not at 100%, then you cannot make definitive statements for Questions 3, 4 and 6

 

 

Question 6 – Have you identified all your smelters and refiners?

 

   

○    If the answer here is yes, then question 5 must be yes. This also impacts question 3.

 

 

Question 7– Has all applicable smelter information received by your company been reported?

 

All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regards to invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors. As of April 24th, there were 447 suppliers in scope of the conflict minerals program and 277 suppliers provided a completed CMRT. There were an additional 6 (six) invalid supplier submissions that could not be corrected. Company’s total response rate for this reporting year is 62%, compared to 56% for 2020.

 

Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the Responsible Minerals Initiative (“RMI”) and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict-free smelters and refiners of 3TGs. Our suppliers identified a total of 339 smelters and refiners that appear on the lists maintained by RMI. Of these 339 smelters and refiners, 232 are validated as conflict-free by RMI or a cross-recognized initiative, and, based on information provided by RMI, a further 19 have agreed to undergo or are currently undergoing a third-party audit. Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TGs contained in our products.

 

Based on the reasonable country of origin inquiry (“RCOI”), we had reason to believe that some of the 3TGs may have originated from the Covered Countries, therefore, in accordance with the Rule, we performed due diligence on the source and chain of custody of the conflict minerals in question.

 

 

 

4.  Design of Our Due Diligence and Description of the Due Diligence Process

 

We designed our due diligence measures to conform, in all material respects, with the framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “Guidance”) and the related supplement on gold, and supplement on tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:

 

 

1.

Establishing strong company management systems;

 

 

2.

Identifying and assessing risks in our supply chain;

 

 

3.

Designing and implementing a strategy to respond to identified risks in our supply chain;

 

 

4.

Utilizing independent third-party audits of supply chain diligence; and

 

 

5.

Publicly reporting on our supply chain due diligence

 

We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, Frequency does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.

 

The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.

 

Due Diligence Performed

 

1) Establish Strong Company Management Systems

 

Internal Compliance Team

 

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

 

The Company also uses Assent to assist us with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that we undertake with suppliers in regards to conflict minerals.

 

Control Systems

 

The Company expects all of its suppliers to have policies and procedures in place to ensure that any 3TGs used in the production of the products sold to Frequency are Democratic Republic of Congo (“DRC”) conflict-free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. We rely on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us – including sources of 3TGs that are supplied to them from lower tier suppliers.

 

 

 

 

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

 

Supplier Engagement

 

The Company engages with suppliers directly to request that they complete a valid CMRT for the products that they supply to the Company. With respect to the OECD requirement to strengthen engagement with suppliers, the Company has developed an internal procedure that includes steps of supplier engagement escalation such as in-person meetings and corrective actions. Feedback from this engagement has allowed the Company to oversee improvements in supplier responses and supplier compliance for this initiative.

 

The Company believes that the combination of the Code of Conduct, our Conflict Minerals Policy, and direct engagement with suppliers for 3TGs training and requests constitute a strong program when it comes to supplier engagement.

 

Maintain Records

 

The Company has adopted a policy to retain relevant documentation for a period of 5 years. We implemented a document retention policy through Assent to retain conflict minerals related documents, including supplier responses to CMRTs. We store all of the information and findings from this process in a database that can be audited by internal or external parties.

 

2) Identifying and Assessing Risk in the Supply Chain

 

Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in the ACM system based on criteria established for supplier responses in the system. These risks are addressed by Assent staff and members of our Conflict Minerals Compliance Team who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.

 

One risk we identified with respect to the reporting period ended December 31st, 2021 related to the nature of the responses received. Approximately 91% (252 out of 276) of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TGs in the components supplied to Frequency. Additionally, 46 suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.

 

In accordance with OECD Guidelines, it is important to identify and assess risks associated with conflict minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared the facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TGs processing facility that was operational during the 2021 calendar year.

 

In order to assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). We do not typically have a direct relationship with 3TGs smelters and refiners and do not perform or direct audits of these entities within our supply chain. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.

 

As of May 27, 2022, we have validated 339 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primarily supplier-level CMRTs, we cannot definitely determine their connection to the Covered Products.

 

 

 

 

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

 

 

Geographic proximity to the DRC and covered countries;

 

 

Known mineral source country of origin;

 

 

RMAP audit status;

 

 

Credible evidence of unethical or conflict sourcing; and

 

 

Peer assessments conducted by credible third-party sources.

 

As part of our risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent, submissions that include any red flag facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Frequency, and escalating up to removal of these red flag smelters from the supply chain.

 

As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

 

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:

 

Have you established a conflict minerals sourcing policy?

 

Have you implemented due diligence measures for conflict-free sourcing?

 

Do you review due diligence information received from your suppliers against your company’s expectations?

 

Does your review process include corrective action management?

 

When suppliers meet or exceed those criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. At this time, 27 of our responsive suppliers have been identified as having a weak program. This was a slight increase from the prior year which had 26 supplies being identified as having weak programs.

 

3) Design and Implement a Strategy to Respond to Risks

 

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

 

We engage each of our suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD Guidance.

 

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

 

We do not have a direct relationship with any 3TGs smelters or refiners and do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.

 

 

 

 

Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. Frequency is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance.

 

5) Public Reporting on Supply Chain Due Diligence

 

We have published our Form SD for the year ended December 31, 2021 and this report is in the Investor Relations section of our website at www.freqelec.com under Investor Relations/Financial/SEC Filings. Information found on or accessed through our website is not considered part of this report and is not incorporated by reference herein. We have also publicly filed our Form SD and this report with the SEC.

 

Due Diligence Results

 

Survey Results

 

For the 2021 reporting year, Frequency received CMRT forms from 62% of the suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. Five of the suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions.

 

Smelters and Refiners

 

Attached as Appendix A is a list of all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Since many of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed on Appendix A actually processed the 3TGs contained in our products. Therefore, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that actually processed the 3TGs contained in the Covered Products.

 

From the responses that we received, we identified 19 smelters that potentially posed a risk due to the presence of some red flag indicators. For suppliers that identified these specific smelters of concern on their CMRT, we created a new escalation plan. These suppliers were contacted by Assent and Frequency to evaluate whether or not these smelters could be connected to Frequency products. The suppliers were asked to complete a product-level CMRT, rather than a company-level CMRT, to better identify the connection to products that they supply to Frequency. Other suppliers were evaluated internally to determine if they were in fact still active suppliers. If not, they were removed from the scope of data collection.

 

Countries of Origin

 

Appendix B includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI. As mentioned in the above section, many responses were provided at the company level, therefore, Appendix B may contain more countries than those that are actually the sources of the 3TGs in the Covered Products.

 

Steps to be Taken to Mitigate Risk

 

We have taken or intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in the Covered Products could benefit armed groups in the Covered Countries:

 

 

Work more closely with Assent to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TGs contained in our products.

 

 

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

 

 

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

 

 

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

 

 

Increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program.

 

 

 

 

Appendix A - Smelter list

 

 

Includes: metal, standard smelter name, smelter facility location, smelter ID

 

Metal

Standard Smelter Name

Smelter Facility Location

Smelter ID

Gold

8853 S.p.A.

Italy

CID002763

Gold

Abington Reldan Metals, LLC

United States Of America

CID002708

Gold

Advanced Chemical Company

United States Of America

CID000015

Gold

African Gold Refinery

Uganda

CID003185

Gold

Aida Chemical Industries Co., Ltd.

Japan

CID000019

Gold

Al Etihad Gold Refinery DMCC

United Arab Emirates

CID002560

Gold

Alexy Metals

United States Of America

CID003500

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

Germany

CID000035

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

Uzbekistan

CID000041

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

Brazil

CID000058

Gold

Argor-Heraeus S.A.

Switzerland

CID000077

Gold

Asahi Pretec Corp.

Japan

CID000082

Gold

Asahi Refining Canada Ltd.

Canada

CID000924

Gold

Asahi Refining USA Inc.

United States Of America

CID000920

Gold

Asaka Riken Co., Ltd.

Japan

CID000090

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

Turkey

CID000103

Gold

AU Traders and Refiners

South Africa

CID002850

Gold

Augmont Enterprises Private Limited

India

CID003461

Gold

Aurubis AG

Germany

CID000113

Gold

Bangalore Refinery

India

CID002863

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Philippines

CID000128

Gold

Boliden AB

Sweden

CID000157

Gold

C. Hafner GmbH + Co. KG

Germany

CID000176

Gold

C.I Metales Procesados Industriales SAS

Colombia

CID003421

Gold

Caridad

Mexico

CID000180

Gold

CCR Refinery - Glencore Canada Corporation

Canada

CID000185

Gold

Cendres + Metaux S.A.

Switzerland

CID000189

Gold

CGR Metalloys Pvt Ltd.

India

CID003382

Gold

Chimet S.p.A.

Italy

CID000233

Gold

Chugai Mining

Japan

CID000264

Gold

Daye Non-Ferrous Metals Mining Ltd.

China

CID000343

Gold

Degussa Sonne / Mond Goldhandel GmbH

Germany

CID002867

Gold

Dijllah Gold Refinery FZC

United Arab Emirates

CID003348

Gold

DODUCO Contacts and Refining GmbH

Germany

CID000362

Gold

Dowa

Japan

CID000401

Gold

DSC (Do Sung Corporation)

Korea, Republic Of

CID000359

Gold

Eco-System Recycling Co., Ltd. East Plant

Japan

CID000425

Gold

Eco-System Recycling Co., Ltd. North Plant

Japan

CID003424

Gold

Eco-System Recycling Co., Ltd. West Plant

Japan

CID003425

Gold

Emerald Jewel Industry India Limited (Unit 1)

India

CID003487

Gold

Emerald Jewel Industry India Limited (Unit 2)

India

CID003488

Gold

Emerald Jewel Industry India Limited (Unit 3)

India

CID003489

Gold

Emerald Jewel Industry India Limited (Unit 4)

India

CID003490

 

 

 

 

Gold

Emirates Gold DMCC

United Arab Emirates

CID002561

Gold

Fidelity Printers and Refiners Ltd.

Zimbabwe

CID002515

Gold

Fujairah Gold FZC

United Arab Emirates

CID002584

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

India

CID002852

Gold

Geib Refining Corporation

United States Of America

CID002459

Gold

Gold Coast Refinery

Ghana

CID003186

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

China

CID002243

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

China

CID001909

Gold

Guangdong Jinding Gold Limited

China

CID002312

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

China

CID000651

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

China

CID000671

Gold

Heimerle + Meule GmbH

Germany

CID000694

Gold

Heraeus Metals Hong Kong Ltd.

China

CID000707

Gold

Heraeus Precious Metals GmbH & Co. KG

Germany

CID000711

Gold

Hunan Chenzhou Mining Co., Ltd.

China

CID000767

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

China

CID000773

Gold

HwaSeong CJ CO., LTD.

Korea, Republic Of

CID000778

Gold

Industrial Refining Company

Belgium

CID002587

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

China

CID000801

Gold

International Precious Metal Refiners

United Arab Emirates

CID002562

Gold

Ishifuku Metal Industry Co., Ltd.

Japan

CID000807

Gold

Istanbul Gold Refinery

Turkey

CID000814

Gold

Italpreziosi

Italy

CID002765

Gold

JALAN & Company

India

CID002893

Gold

Japan Mint

Japan

CID000823

Gold

Jiangxi Copper Co., Ltd.

China

CID000855

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Russian Federation

CID000927

Gold

JSC Uralelectromed

Russian Federation

CID000929

Gold

JX Nippon Mining & Metals Co., Ltd.

Japan

CID000937

Gold

K.A. Rasmussen

Norway

CID003497

Gold

Kaloti Precious Metals

United Arab Emirates

CID002563

Gold

Kazakhmys Smelting LLC

Kazakhstan

CID000956

Gold

Kazzinc

Kazakhstan

CID000957

Gold

Kennecott Utah Copper LLC

United States Of America

CID000969

Gold

KGHM Polska Miedz Spolka Akcyjna

Poland

CID002511

Gold

Kojima Chemicals Co., Ltd.

Japan

CID000981

Gold

Korea Zinc Co., Ltd.

Korea, Republic Of

CID002605

Gold

Kundan Care Products Ltd.

India

CID003463

Gold

Kyrgyzaltyn JSC

Kyrgyzstan

CID001029

Gold

Kyshtym Copper-Electrolytic Plant ZAO

Russian Federation

CID002865

Gold

L'azurde Company For Jewelry

Saudi Arabia

CID001032

Gold

Lingbao Gold Co., Ltd.

China

CID001056

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

China

CID001058

Gold

L'Orfebre S.A.

Andorra

CID002762

Gold

LS-NIKKO Copper Inc.

Korea, Republic Of

CID001078

Gold

LT Metal Ltd.

Korea, Republic Of

CID000689

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

China

CID001093

Gold

Marsam Metals

Brazil

CID002606

Gold

Materion

United States Of America

CID001113

Gold

Matsuda Sangyo Co., Ltd.

Japan

CID001119

 

 

 

 

Gold

MD Overseas

India

CID003548

Gold

Metal Concentrators SA (Pty) Ltd.

South Africa

CID003575

Gold

Metallix Refining Inc.

United States Of America

CID003557

Gold

Metalor Technologies (Hong Kong) Ltd.

China

CID001149

Gold

Metalor Technologies (Singapore) Pte., Ltd.

Singapore

CID001152

Gold

Metalor Technologies (Suzhou) Ltd.

China

CID001147

Gold

Metalor Technologies S.A.

Switzerland

CID001153

Gold

Metalor USA Refining Corporation

United States Of America

CID001157

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

Mexico

CID001161

Gold

Mitsubishi Materials Corporation

Japan

CID001188

Gold

Mitsui Mining and Smelting Co., Ltd.

Japan

CID001193

Gold

MMTC-PAMP India Pvt., Ltd.

India

CID002509

Gold

Modeltech Sdn Bhd

Malaysia

CID002857

Gold

Morris and Watson

New Zealand

CID002282

Gold

Moscow Special Alloys Processing Plant

Russian Federation

CID001204

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

Turkey

CID001220

Gold

Navoi Mining and Metallurgical Combinat

Uzbekistan

CID001236

Gold

NH Recytech Company

Korea, Republic Of

CID003189

Gold

Nihon Material Co., Ltd.

Japan

CID001259

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

Austria

CID002779

Gold

Ohura Precious Metal Industry Co., Ltd.

Japan

CID001325

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

Russian Federation

CID001326

Gold

OJSC Novosibirsk Refinery

Russian Federation

CID000493

Gold

PAMP S.A.

Switzerland

CID001352

Gold

Pease & Curren

United States Of America

CID002872

Gold

Penglai Penggang Gold Industry Co., Ltd.

China

CID001362

Gold

Planta Recuperadora de Metales SpA

Chile

CID002919

Gold

Prioksky Plant of Non-Ferrous Metals

Russian Federation

CID001386

Gold

PT Aneka Tambang (Persero) Tbk

Indonesia

CID001397

Gold

PX Precinox S.A.

Switzerland

CID001498

Gold

QG Refining, LLC

United States Of America

CID003324

Gold

Rand Refinery (Pty) Ltd.

South Africa

CID001512

Gold

Refinery of Seemine Gold Co., Ltd.

China

CID000522

Gold

REMONDIS PMR B.V.

Netherlands

CID002582

Gold

Royal Canadian Mint

Canada

CID001534

Gold

SAAMP

France

CID002761

Gold

Sabin Metal Corp.

United States Of America

CID001546

Gold

Safimet S.p.A

Italy

CID002973

Gold

SAFINA A.S.

Czechia

CID002290

Gold

Sai Refinery

India

CID002853

Gold

Samduck Precious Metals

Korea, Republic Of

CID001555

Gold

Samwon Metals Corp.

Korea, Republic Of

CID001562

Gold

Sancus ZFS (L’Orfebre, SA)

Colombia

CID003529

Gold

SAXONIA Edelmetalle GmbH

Germany

CID002777

Gold

Sellem Industries Ltd.

Mauritania

CID003540

Gold

SEMPSA Joyeria Plateria S.A.

Spain

CID001585

Gold

Shandong Humon Smelting Co., Ltd.

China

CID002525

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

China

CID001619

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

China

CID001622

Gold

Shenzhen Zhonghenglong Real Industry Co., Ltd.

China

CID002527

 

 

 

 

Gold

Shirpur Gold Refinery Ltd.

India

CID002588

Gold

Sichuan Tianze Precious Metals Co., Ltd.

China

CID001736

Gold

Singway Technology Co., Ltd.

Taiwan, Province Of China

CID002516

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

Russian Federation

CID001756

Gold

Solar Applied Materials Technology Corp.

Taiwan, Province Of China

CID001761

Gold

Sovereign Metals

India

CID003383

Gold

State Research Institute Center for Physical Sciences and Technology

Lithuania

CID003153

Gold

Sudan Gold Refinery

Sudan

CID002567

Gold

Sumitomo Metal Mining Co., Ltd.

Japan

CID001798

Gold

SungEel HiMetal Co., Ltd.

Korea, Republic Of

CID002918

Gold

Super Dragon Technology Co., Ltd.

China

CID001810

Gold

T.C.A S.p.A

Italy

CID002580

Gold

Tanaka Kikinzoku Kogyo K.K.

Japan

CID001875

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

China

CID001916

Gold

Tokuriki Honten Co., Ltd.

Japan

CID001938

Gold

Tongling Nonferrous Metals Group Co., Ltd.

China

CID001947

Gold

TOO Tau-Ken-Altyn

Kazakhstan

CID002615

Gold

Torecom

Korea, Republic Of

CID001955

Gold

Umicore Precious Metals Thailand

Thailand

CID002314

Gold

Umicore S.A. Business Unit Precious Metals Refining

Belgium

CID001980

Gold

United Precious Metal Refining, Inc.

United States Of America

CID001993

Gold

Valcambi S.A.

Switzerland

CID002003

Gold

Value Trading

Belgium

CID003617

Gold

WEEEREFINING

France

CID003615

Gold

Western Australian Mint (T/a The Perth Mint)

Australia

CID002030

Gold

WIELAND Edelmetalle GmbH

Germany

CID002778

Gold

Yamakin Co., Ltd.

Japan

CID002100

Gold

Yokohama Metal Co., Ltd.

Japan

CID002129

Gold

Yunnan Copper Industry Co., Ltd.

China

CID000197

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

China

CID002224

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

China

CID000211

Tantalum

D Block Metals, LLC

United States Of America

CID002504

Tantalum

Exotech Inc.

United States Of America

CID000456

Tantalum

F&X Electro-Materials Ltd.

China

CID000460

Tantalum

FIR Metals & Resource Ltd.

China

CID002505

Tantalum

Global Advanced Metals Aizu

Japan

CID002558

Tantalum

Global Advanced Metals Boyertown

United States Of America

CID002557

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

China

CID000616

Tantalum

H.C. Starck Co., Ltd.

Thailand

CID002544

Tantalum

H.C. Starck Hermsdorf GmbH

Germany

CID002547

Tantalum

H.C. Starck Inc.

United States Of America

CID002548

Tantalum

H.C. Starck Ltd.

Japan

CID002549

Tantalum

H.C. Starck Smelting GmbH & Co. KG

Germany

CID002550

Tantalum

H.C. Starck Tantalum and Niobium GmbH

Germany

CID002545

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

China

CID002492

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

China

CID002512

Tantalum

Jiangxi Tuohong New Raw Material

China

CID002842

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

China

CID000914

Tantalum

Jiujiang Tanbre Co., Ltd.

China

CID000917

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

China

CID002506

 

 

 

 

Tantalum

KEMET Blue Metals

Mexico

CID002539

Tantalum

LSM Brasil S.A.

Brazil

CID001076

Tantalum

Metallurgical Products India Pvt., Ltd.

India

CID001163

Tantalum

Mineracao Taboca S.A.

Brazil

CID001175

Tantalum

Mitsui Mining and Smelting Co., Ltd.

Japan

CID001192

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

China

CID001277

Tantalum

NPM Silmet AS

Estonia

CID001200

Tantalum

QuantumClean

United States Of America

CID001508

Tantalum

Resind Industria e Comercio Ltda.

Brazil

CID002707

Tantalum

Solikamsk Magnesium Works OAO

Russian Federation

CID001769

Tantalum

Taki Chemical Co., Ltd.

Japan

CID001869

Tantalum

Telex Metals

United States Of America

CID001891

Tantalum

Ulba Metallurgical Plant JSC

Kazakhstan

CID001969

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

China

CID002508

Tantalum

Yancheng Jinye New Material Technology Co., Ltd.

China

CID003583

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

China

CID001522

Tin

Alpha

United States Of America

CID000292

Tin

An Vinh Joint Stock Mineral Processing Company

Viet Nam

CID002703

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

China

CID000228

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

China

CID003190

Tin

China Tin Group Co., Ltd.

China

CID001070

Tin

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

Brazil

CID003486

Tin

CRM Synergies

Spain

CID003524

Tin

CV Venus Inti Perkasa

Indonesia

CID002455

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

China

CID003356

Tin

Dowa

Japan

CID000402

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

Viet Nam

CID002572

Tin

EM Vinto

Bolivia (Plurinational State Of)

CID000438

Tin

Estanho de Rondonia S.A.

Brazil

CID000448

Tin

Fabrica Auricchio Industria e Comercio Ltda.

Brazil

CID003582

Tin

Fenix Metals

Poland

CID000468

Tin

Gejiu City Fuxiang Industry and Trade Co., Ltd.

China

CID003410

Tin

Gejiu Kai Meng Industry and Trade LLC

China

CID000942

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

China

CID000538

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

China

CID001908

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

China

CID000555

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

China

CID003116

Tin

HuiChang Hill Tin Industry Co., Ltd.

China

CID002844

Tin

Jiangxi New Nanshan Technology Ltd.

China

CID001231

Tin

Luna Smelter, Ltd.

Rwanda

CID003387

Tin

Ma'anshan Weitai Tin Co., Ltd.

China

CID003379

Tin

Magnu's Minerais Metais e Ligas Ltda.

Brazil

CID002468

Tin

Malaysia Smelting Corporation (MSC)

Malaysia

CID001105

Tin

Melt Metais e Ligas S.A.

Brazil

CID002500

Tin

Metallic Resources, Inc.

United States Of America

CID001142

Tin

Metallo Belgium N.V.

Belgium

CID002773

Tin

Metallo Spain S.L.U.

Spain

CID002774

 

 

 

 

Tin

Mineracao Taboca S.A.

Brazil

CID001173

Tin

Minsur

Peru

CID001182

Tin

Mitsubishi Materials Corporation

Japan

CID001191

Tin

Modeltech Sdn Bhd

Malaysia

CID002858

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

Viet Nam

CID002573

Tin

Novosibirsk Processing Plant Ltd.

Russian Federation

CID001305

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

Thailand

CID001314

Tin

O.M. Manufacturing Philippines, Inc.

Philippines

CID002517

Tin

Operaciones Metalurgicas S.A.

Bolivia (Plurinational State Of)

CID001337

Tin

Pongpipat Company Limited

Myanmar

CID003208

Tin

Precious Minerals and Smelting Limited

India

CID003409

Tin

PT Aries Kencana Sejahtera

Indonesia

CID000309

Tin

PT Artha Cipta Langgeng

Indonesia

CID001399

Tin

PT ATD Makmur Mandiri Jaya

Indonesia

CID002503

Tin

PT Babel Inti Perkasa

Indonesia

CID001402

Tin

PT Babel Surya Alam Lestari

Indonesia

CID001406

Tin

PT Bangka Serumpun

Indonesia

CID003205

Tin

PT Belitung Industri Sejahtera

Indonesia

CID001421

Tin

PT Bukit Timah

Indonesia

CID001428

Tin

PT Cipta Persada Mulia

Indonesia

CID002696

Tin

PT Masbro Alam Stania

Indonesia

CID003380

Tin

PT Menara Cipta Mulia

Indonesia

CID002835

Tin

PT Mitra Stania Prima

Indonesia

CID001453

Tin

PT Mitra Sukses Globalindo

Indonesia

CID003449

Tin

PT Panca Mega Persada

Indonesia

CID001457

Tin

PT Prima Timah Utama

Indonesia

CID001458

Tin

PT Rajawali Rimba Perkasa

Indonesia

CID003381

Tin

PT Refined Bangka Tin

Indonesia

CID001460

Tin

PT Sariwiguna Binasentosa

Indonesia

CID001463

Tin

PT Stanindo Inti Perkasa

Indonesia

CID001468

Tin

PT Sukses Inti Makmur

Indonesia

CID002816

Tin

PT Timah Nusantara

Indonesia

CID001486

Tin

PT Timah Tbk Kundur

Indonesia

CID001477

Tin

PT Timah Tbk Mentok

Indonesia

CID001482

Tin

PT Tinindo Inter Nusa

Indonesia

CID001490

Tin

PT Tirus Putra Mandiri

Indonesia

CID002478

Tin

PT Tommy Utama

Indonesia

CID001493

Tin

Resind Industria e Comercio Ltda.

Brazil

CID002706

Tin

Rui Da Hung

Taiwan, Province Of China

CID001539

Tin

Soft Metais Ltda.

Brazil

CID001758

Tin

Super Ligas

Brazil

CID002756

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

Viet Nam

CID002834

Tin

Thaisarco

Thailand

CID001898

Tin

Tin Technology & Refining

United States Of America

CID003325

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

Viet Nam

CID002574

Tin

VQB Mineral and Trading Group JSC

Viet Nam

CID002015

Tin

White Solder Metalurgia e Mineracao Ltda.

Brazil

CID002036

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

China

CID002158

Tin

Yunnan Tin Company Limited

China

CID002180

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

China

CID003397

Tungsten

A.L.M.T. Corp.

Japan

CID000004

Tungsten

ACL Metais Eireli

Brazil

CID002833

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

Brazil

CID003427

Tungsten

Artek LLC

Russian Federation

CID003553

 

 

 

 

Tungsten

Asia Tungsten Products Vietnam Ltd.

Viet Nam

CID002502

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

China

CID002513

Tungsten

China Molybdenum Co., Ltd.

China

CID002641

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

China

CID000258

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

China

CID000281

Tungsten

Cronimet Brasil Ltda

Brazil

CID003468

Tungsten

Fujian Ganmin RareMetal Co., Ltd.

China

CID003401

Tungsten

Fujian Xinlu Tungsten

China

CID003609

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

China

CID002645

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

China

CID000875

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

China

CID002315

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

China

CID002494

Tungsten

GEM Co., Ltd.

China

CID003417

Tungsten

Global Tungsten & Powders Corp.

United States Of America

CID000568

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

China

CID000218

Tungsten

H.C. Starck Smelting GmbH & Co. KG

Germany

CID002542

Tungsten

H.C. Starck Tungsten GmbH

Germany

CID002541

Tungsten

Hunan Chenzhou Mining Co., Ltd.

China

CID000766

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

China

CID000769

Tungsten

Hydrometallurg, JSC

Russian Federation

CID002649

Tungsten

Japan New Metals Co., Ltd.

Japan

CID000825

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

China

CID002551

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

China

CID002321

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

China

CID002313

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

China

CID002318

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

China

CID002317

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

China

CID002316

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

Russian Federation

CID003408

Tungsten

Kennametal Fallon

United States Of America

CID000966

Tungsten

Kennametal Huntsville

United States Of America

CID000105

Tungsten

KGETS Co., Ltd.

Korea, Republic Of

CID003388

Tungsten

Lianyou Metals Co., Ltd.

Taiwan, Province Of China

CID003407

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

China

CID002319

Tungsten

Masan Tungsten Chemical LLC (MTC)

Viet Nam

CID002543

Tungsten

Moliren Ltd.

Russian Federation

CID002845

Tungsten

Niagara Refining LLC

United States Of America

CID002589

Tungsten

NPP Tyazhmetprom LLC

Russian Federation

CID003416

Tungsten

OOO “Technolom” 1

Russian Federation

CID003614

Tungsten

OOO “Technolom” 2

Russian Federation

CID003612

Tungsten

Philippine Chuangxin Industrial Co., Inc.

Philippines

CID002827

Tungsten

Unecha Refractory metals plant

Russian Federation

CID002724

Tungsten

Wolfram Bergbau und Hutten AG

Austria

CID002044

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

China

CID002320

Tungsten

Xiamen Tungsten Co., Ltd.

China

CID002082

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

China

CID002830

 

 

 

 

Appendix B - Countries of origin

 

 

Includes: list of countries that declared smelters are known to source from

 

Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Djibouti, Dominican Republic, DRC or an adjoining country (Covered Countries), Ecuador, Egypt, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic Of Korea, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Suri, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, USA, Uzbekistan, Vietnam, Zambia, Zimbabwe.