UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
__________________________________________________________
FORM SD
Specialized Disclosure Report
____________________________________________________
Roku, Inc.
(Exact Name of Registrant as Specified in its Charter)
___________________________________________________
| | | | | |
Delaware | 001-38211 |
(State or Other Jurisdiction of Incorporation) | (Commission File Number) |
| |
1173 Coleman Ave San Jose, California | 95110 |
(Address of Principal Executive Offices) | (Zip Code) |
Stephen Kay
Senior Vice President,
General Counsel and Secretary
(408) 556-9040
(Name and telephone number, including area code, of the person to contact in connection with this report)
_______________________________________________________________
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
☐ 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
Conflict Minerals Disclosure
This Form SD of Roku, Inc. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934 for the reporting period January 1, 2023 to December 31, 2023 (the “Reporting Period”). A copy of the Company’s Conflict Minerals Report for the Reporting Period is filed as Exhibit 1.01 hereto and is publicly available at https://www.roku.com/investor/sec-filings.1
Item 1.02 Exhibit
The Company’s Conflict Minerals Report for the Reporting Period is filed as Exhibit 1.01 hereto.
Section 3 – Exhibits
Item 3.01 Exhibits
__________________________________________________________________________
1 The reference to the Company’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD and the Conflict Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.
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.
| | | | | | | | | | | |
| | Roku, Inc. |
| | | |
Date: May 23, 2024 | | By: | /s/ Stephen H. Kay |
| | | Stephen H. Kay |
| | | Senior Vice President, General Counsel and Secretary |
Exhibit 1.01
Roku, Inc.
Conflict Minerals Report
For the period January 1, 2023 to December 31, 2023
This Conflict Minerals Report (the “Report”) of Roku, Inc. (the “Company”) has been prepared pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended, for the period January 1, 2023 to December 31, 2023 (the “Current Period”).
The Rule requires disclosure of certain information when gold, columbite-tantalite (coltan), cassiterite and wolframite, and their derivatives, tantalum, tin and tungsten (“Conflict Minerals”) are necessary to the functionality or production of the products that the company manufactures or contracts to manufacture. The Rule relates to the sourcing of Conflict Minerals from certain “Covered Countries,” which are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, Conflict Minerals are necessary to the functionality or production of certain of the Company’s products.
References to our websites and information available through these websites are not intended to incorporate the websites or that information into the Report.
The Company does not manufacture any products. Instead, the Company contracts with its direct suppliers, which are contract manufacturers and original design manufacturers, to manufacture or design its products to the Company’s specifications. During the Current Period, all of the hardware products that the Company contracted to manufacture contained Conflict Minerals necessary to the functionality or production of those products, including Roku-branded TVs, players, remotes, audio equipment, smart home products, and other electronics (collectively, the “Covered Products”). This Report applies to Covered Products the manufacture of which was completed during the Current Period.
Forward-Looking Statements
This Report may contain forward-looking statements that reflect our expectations with respect to our Conflict Minerals program. Statements in this Report that are not strictly historical statements, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts, strategy, and future reporting constitute forward-looking statements. Any statements contained in this Report that are not statements of historical fact may also be deemed to be forward-looking statements. For example, the words “could,” “may,” “will,” and similar expressions are intended to identify forward-looking statements. These forward-looking statements are not a guarantee of performance and are subject to a number of risks and uncertainties, some of which may be outside of our control, and which could cause actual events to differ materially from those expressed or implied by the statements made herein. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers, third-party audit programs or others as well as the possibility of future statutory and regulatory changes.
Reasonable Country of Origin Inquiry
For the Current Period, the Company conducted a good faith reasonable country-of-origin inquiry (“RCOI”) regarding the Conflict Minerals necessary to the Covered Products. The RCOI was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources. The RCOI consisted principally of requesting that our direct suppliers of Covered Products (“Suppliers”) provide us with country-of-origin information on the Conflict Minerals used in Covered Products. Based on the information we received, we have reason to believe that some of the Conflict Minerals contained in the Covered Products may have originated from Covered Countries.
Conflict Minerals Due Diligence Program Design
We designed our Conflict Minerals due diligence program to conform, in all material respects, to 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 and the related Supplement on Gold and Supplement on Tin, Tantalum and Tungsten, consistent with the Company’s position as a downstream company.
OECD Guidance Step 1: Maintain Strong Company Management Systems
•We have adopted a written policy statement on Conflict Minerals which is publicly available on our website at https://ir.roku.com/corporate-governance/governance-overview.
•We have organized an internal team, which includes members from our operations, legal, and finance organizations, that is responsible for overseeing our Conflict Minerals program.
•Our Conflict Minerals team reports its findings to our Chief Accounting Officer and our General Counsel.
•We request that our Suppliers report to us on an annual basis on the use of Conflict Minerals in their products using the Conflict Minerals Reporting Template (the “CMRT”) published by the Responsible Minerals Initiative (the “RMI”).
•We maintain a grievance hotline for reporting policy violations.
OECD Guidance Step 2: Identify and Assess Risks in the Supply Chain
•We send a request for our Suppliers to submit to us a completed CMRT.
•We follow up with Suppliers on incomplete or inconsistent CMRT submissions.
•We attempt to identify high-risk smelters and refiners in our supply chain by comparing the smelters and refiners identified by Suppliers as potentially supplying Conflict Minerals for use in the Covered Products against the list of smelters and refiners that are identified as “conformant” or “active” with the RMI’s Responsible Minerals Assurance Process (“RMAP”) assessment protocols, as well as against the list of refiners identified on the current Good Delivery List of the London Bullion Market Association (“LBMA”), as applicable.
OECD Guidance Step 3: Design and Implement a Strategy to Respond to Identified Risks
•We contact our Suppliers that report the use of smelters or refiners that may not be identified by RMAP as “conformant” or “active” or on the LBMA Good Delivery List to confirm whether they have discontinued use of such smelter or refiner.
•We ask our Suppliers to encourage smelters or refiners that are not conformant with RMAP to participate in the RMAP.
•If we determine that a Supplier is sourcing Conflict Minerals that may be financing armed conflict or human rights abuses in the Covered Countries, we will determine an appropriate course of action to engage with that Supplier, which may include requesting that the Supplier remove a red-flag smelter or refiner from its supply chain.
OECD Guidance Step 4: Support the Development and Implementation of Independent Third-Party Audits
•We do not have a direct relationship with the smelters and refiners, and we rely on the independent audits of smelters and refiners that the RMI (and similar organizations) conduct through the RMAP or that are coordinated through the Responsible Sourcing Programme of the LBMA.
OECD Guidance Step 5: Report on Supply Chain Due Diligence
•We publish our Conflict Minerals Report on an annual basis. This Report is available on our website at https://www.roku.com/investor/sec-filings.
Due Diligence Results
Smelters and Refiners Identified
We received a CMRT from each of our Suppliers. Based on the information provided by our Suppliers for the Current Period, we have reason to believe that some of the Conflict Minerals used in the Covered Products originated from Covered Countries. In certain cases, information provided by our Suppliers was incomplete or unverifiable and may not have included responses from all of their suppliers. Further, we were unable to determine the country of origin of all of the Conflict Minerals necessary to the manufacture of the Covered Products. In addition, some of our Suppliers provided us with smelter and refiner information on a company-wide basis and not on a product-specific basis, and as a result some of the smelters or refiners identified may not actually have supplied Conflict Minerals for use in the Covered Products.
The Suppliers identified 215 smelters and refiners, and we evaluated each of them based on the RMAP audit and the LBMA Good Delivery List. All of these smelters and refiners were identified by RMAP as “conformant” for the Current Period.
The results of our due diligence on the Conflict Minerals used in Covered Products for the Current Period, based on the information provided by our Suppliers, are as set forth below:
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| Tin | | Tantalum | | Tungsten | | Gold | | Total |
Total number of smelters or refiners.................. | 65 | | 32 | | 31 | | 87 | | 215 |
| Total number (%) of smelters or refiners identified by RMAP as “Conformant” or “Active” | 65 (100 %) | | 32 (100 %) | | 31 (100 %) | | 87 (100%) | | 215 (100%) |
Total number (%) of “Conformant” smelters or refiners............................................................ | 65 (100 %) | | 32 (100 %) | | 31 (100 %) | | 87 (100 %) | | 215 (100 %) |
Total number (%) of “Active” smelters or refiners................................................................ | 0 | | 0 | | 0 | | 0 | | 0 |
Our supply chain with respect to the Covered Products is complex, and, as a downstream purchaser, we are many steps removed from the mining and smelting or refining of the Conflict Minerals. Accordingly, we do not have direct relationships with smelters and refiners of Conflict Minerals. We believe the smelters and refiners are in the best position in the supply chain to determine the origin of the ores, and tracing these minerals to their sources is a challenge that requires us to enlist our Suppliers in our efforts to achieve supply chain transparency, including our effort to obtain information regarding the origin of the Conflict Minerals. The information provided by Suppliers may be inaccurate or incomplete or subject to other irregularities. Because of our relative location within the supply chain in relation to the actual extraction, transport, smelting, and refinement of Conflict Minerals, our ability to verify the accuracy of information reported by Suppliers is limited. We also rely on third-party organizations to determine the accuracy of representations that upstream producers are “conflict-free,” and are not in a position to independently determine the “conflict-free” nature of Conflict Minerals used in the Covered Products for the Current Period. Attached as Appendix A is a list of the smelters and refiners reported to us by our Suppliers for the Current Period.
Efforts to Determine Mine or Location of Origin
We requested mine or location of origin information from each of our Suppliers in order to determine the country of origin of the Conflict Minerals in our supply chain. Based on country-of-origin information provided by our Suppliers:
•The Conflict Minerals contained in Covered Products that may have originated from the Covered Countries may have come from Burundi, the Democratic Republic of the Congo, and Rwanda. In some cases, the locations of the mines were unknown and not identified in the CMRT. In other cases, the responses indicated that the minerals were from the Covered Countries but did not identify specific countries.
•The Conflict Minerals contained in Covered Products that may have originated outside the Covered Countries may have come from one or more of the following: Australia, Belgium, Bolivia, Brazil, Canada, Chile, China, Indonesia, Japan, Malaysia, Peru, Portugal, Russia, Singapore, Spain, Switzerland, Vietnam, or United States.
•Some of the Conflict Minerals contained in Covered Products may have come from recycled and scrap sources.
•Some of the Conflict Minerals contained in Covered Products may have originated from the conflict-affected and high-risk areas.
We do not have privity of contract with any verifiable smelter or refiner or control over the origin or the sourcing of any Conflict Minerals processed by any verifiable smelter or refiner. We do not source any conflict minerals directly from smelters or refiners in Russia.
We note that the country-of-origin information provided by our Suppliers was incomplete. While we contacted our Suppliers to obtain more complete country-of-origin information, as of the date of this Report, we have been unable to obtain complete country-of-origin information. In addition, as with the list of smelters and refiners, many responses were provided at the company level and, therefore, this list of countries may identify more countries of origin than were actually the source of the Conflict Minerals in the Covered Products.
Steps to be Taken to Mitigate Risk
Following the Current Period, we have taken, or intend to take, the following actions to mitigate the risk that the Conflict Minerals in the Covered Products could finance armed groups in the Covered Countries:
•We will continue to engage with our Suppliers to obtain additional visibility into the sourcing of Conflict Minerals in our supply chain.
•We will encourage our Suppliers to engage with their upstream smelters and refiners to ensure that they become or remain RMAP-conformant.
•We intend to develop strategies to address incidents and allegations concerning the Conflict Minerals used in our supply chain as they arise.
Appendix A
List of Smelters and Refiners
| | | | | | | | | | | | | | |
| Metal (*) | | Name of Smelter or Refiner | | Smelter or Refiner Country |
| Gold | | Advanced Chemical Company | | United States of America |
| Gold | | Aida Chemical Industries Co., Ltd. | | Japan |
| Gold | | Agosi AG | | Germany |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | Uzbekistan |
| Gold | | AngloGold Ashanti Corrego do Sitio Mineracao | | Brazil |
| Gold | | Argor-Heraeus S.A. | | Switzerland |
| Gold | | Asahi Pretec Corp. | | Japan |
| Gold | | Asaka Riken Co., Ltd. | | Japan |
| Gold | | Aurubis AG | | Germany |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | Philippines |
| Gold | | Boliden Ronnskar | | Sweden |
| Gold | | C. Hafner GmbH + Co. KG | | Germany |
| Gold | | CCR Refinery - Glencore Canada Corporation | | Canada |
| Gold | | Chimet S.p.A. | | Italy |
| Gold | | Chugai Mining | | Japan |
| Gold | | DSC (Do Sung Corporation) | | Korea, Republic of |
| Gold | | Dowa | | Japan |
| Gold | | Eco-System Recycling Co., Ltd. East Plant | | Japan |
| Gold | | LT Metal Ltd. | | Korea, Republic of |
| Gold | | Heimerle + Meule GmbH | | Germany |
| Gold | | Heraeus Metals Hong Kong Ltd. | | China |
| Gold | | Heraeus Germany GmbH Co. KG | | Germany |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | China |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | Japan |
| Gold | | Istanbul Gold Refinery | | Turkey |
| Gold | | Japan Mint | | Japan |
| Gold | | Jiangxi Copper Co., Ltd. | | China |
| Gold | | Asahi Refining USA Inc. | | United States of America |
| Gold | | Asahi Refining Canada Ltd. | | Canada |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | Japan |
| Gold | | Kazzinc | | Kazakhstan |
| Gold | | Kennecott Utah Copper LLC | | United States of America |
| Gold | | Kojima Chemicals Co., Ltd. | | Japan |
| Gold | | LS MnM Inc. | | Korea, Republic of |
| Gold | | Materion | | United States of America |
| Gold | | Matsuda Sangyo Co., Ltd. | | Japan |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | China |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | China |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | Singapore |
| Gold | | Metalor Technologies S.A. | | Switzerland |
| Gold | | Metalor USA Refining Corporation | | United States of America |
| Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | Mexico |
| Gold | | Mitsubishi Materials Corporation | | Japan |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | Japan |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.S. | | Turkey |
| | | | | | | | | | | | | | |
| Metal (*) | | Name of Smelter or Refiner | | Smelter or Refiner Country |
| Gold | | Navoi Mining and Metallurgical Combinat | | Uzbekistan |
| Gold | | Nihon Material Co., Ltd. | | Japan |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | Japan |
| Gold | | MKS PAMP S.A. | | Switzerland |
| Gold | | PT Aneka Tambang (Persero) Tbk | | Indonesia |
| Gold | | PX Precinox S.A. | | Switzerland |
| Gold | | Rand Refinery (Pty) Ltd. | | South Africa |
| Gold | | Royal Canadian Mint | | Canada |
| Gold | | SEMPSA Joyeria Plateria S.A. | | Spain |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | China |
| Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | China |
| Gold | | Solar Applied Materials Technology Corp. | | Taiwan, Province of China |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | Japan |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | Japan |
| Gold | | Shandong Gold Smelting Co., Ltd. | | China |
| Gold | | Tokuriki Honten Co., Ltd. | | Japan |
| Gold | | Torecom | | Korea, Republic of |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | Belgium |
| Gold | | United Precious Metal Refining, Inc. | | United States of America |
| Gold | | Valcambi S.A. | | Switzerland |
| Gold | | Western Australian Mint (T/a The Perth Mint) | | Australia |
| Gold | | Yamakin Co., Ltd. | | Japan |
| Gold | | Yokohama Metal Co., Ltd. | | Japan |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | China |
| Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | China |
| Gold | | SAFINA A.S. | | Czechia |
| Gold | | MMTC-PAMP India Pvt., Ltd. | | India |
| Gold | | KGHM Polska Miedz Spolka Akcyjna | | Poland |
| Gold | | T.C.A S.p.A | | Italy |
| Gold | | REMONDIS PMR B.V. | | Netherlands |
| Gold | | Korea Zinc Co., Ltd. | | Korea, Republic of |
| Gold | | TOO Tau-Ken-Altyn | | Kazakhstan |
| Gold | | Abington Reldan Metals, LLC | | United States of America |
| Gold | | L'Orfebre S.A. | | Andorra |
| Gold | | Italpreziosi | | Italy |
| Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | Austria |
| Gold | | SungEel HiMetal Co., Ltd. | | Korea, Republic of |
| Gold | | Planta Recuperadora de Metales SpA | | Chile |
| Gold | | NH Recytech Company | | Korea, Republic of |
| Gold | | Eco-System Recycling Co., Ltd. North Plant | | Japan |
| Gold | | Eco-System Recycling Co., Ltd. West Plant | | Japan |
| Gold | | Metal Concentrators SA (Pty) Ltd. | | South Africa |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | China |
| Tantalum | | F&X Electro-Materials Ltd. | | China |
| Tantalum | | XIMEI RESOURCES (GUANGDONG) LIMITED | | China |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | China |
| | | | | | | | | | | | | | |
| Metal (*) | | Name of Smelter or Refiner | | Smelter or Refiner Country |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | China |
| Tantalum | | AMG Brasil | | Brazil |
| Tantalum | | Metallurgical Products India Pvt., Ltd. | | India |
| Tantalum | | Mineracao Taboca S.A. | | Brazil |
| Tantalum | | Mitsui Mining and Smelting Co., Ltd. | | Japan |
| Tantalum | | NPM Silmet AS | | Estonia |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | China |
| Tantalum | | QuantumClean | | United States of America |
| Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | China |
| Tantalum | | Taki Chemical Co., Ltd. | | Japan |
| Tantalum | | Telex Metals | | United States of America |
| Tantalum | | Ulba Metallurgical Plant JSC | | Kazakhstan |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | China |
| Tantalum | | D Block Metals, LLC | | United States of America |
| Tantalum | | FIR Metals & Resource Ltd. | | China |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | China |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | China |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | China |
| Tantalum | | KEMET de Mexico | | Mexico |
| Tantalum | | TANIOBIS Co., Ltd. | | Thailand |
| Tantalum | | Materion Newton Inc. | | United States of America |
| Tantalum | | TANIOBIS Japan Co., Ltd. | | Japan |
| Tantalum | | TANIOBIS Smelting GmbH & Co. KG | | Germany |
| Tantalum | | Global Advanced Metals Boyertown | | United States of America |
| Tantalum | | Global Advanced Metals Aizu | | Japan |
| Tantalum | | Resind Industria e Comercio Ltda. | | Brazil |
| Tantalum | | Jiangxi Tuohong New Raw Material | | China |
| Tantalum | | RFH Yancheng Jinye New Material Technology Co., Ltd. | | China |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | China |
| Tin | | Alpha | | United States of America |
| Tin | | PT Aries Kencana Sejahtera | | Indonesia |
| Tin | | PT Premium Tin Indonesia | | Indonesia |
| Tin | | Dowa | | Japan |
| Tin | | EM Vinto | | Bolivia (Plurinational State of) |
| Tin | | Estanho de Rondonia S.A. | | Brazil |
| Tin | | Fenix Metals | | Poland |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | China |
| Tin | | China Tin Group Co., Ltd. | | China |
| Tin | | Malaysia Smelting Corporation (MSC) | | Malaysia |
| Tin | | Metallic Resources, Inc. | | United States of America |
| Tin | | Mineracao Taboca S.A. | | Brazil |
| Tin | | Minsur | | Peru |
| Tin | | Mitsubishi Materials Corporation | | Japan |
| Tin | | Jiangxi New Nanshan Technology Ltd. | | China |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | Thailand |
| Tin | | Operaciones Metalurgicas S.A. | | Bolivia (Plurinational State of) |
| Tin | | PT Artha Cipta Langgeng | | Indonesia |
| Tin | | PT Babel Inti Perkasa | | Indonesia |
| | | | | | | | | | | | | | |
| Metal (*) | | Name of Smelter or Refiner | | Smelter or Refiner Country |
| Tin | | PT Babel Surya Alam Lestari | | Indonesia |
| Tin | | PT Bukit Timah | | Indonesia |
| Tin | | PT Mitra Stania Prima | | Indonesia |
| Tin | | PT Prima Timah Utama | | Indonesia |
| Tin | | PT Refined Bangka Tin | | Indonesia |
| Tin | | PT Sariwiguna Binasentosa | | Indonesia |
| Tin | | PT Stanindo Inti Perkasa | | Indonesia |
| Tin | | PT Timah Tbk Kundur | | Indonesia |
| Tin | | PT Timah Tbk Mentok | | Indonesia |
| Tin | | PT Tinindo Inter Nusa | | Indonesia |
| Tin | | PT Tommy Utama | | Indonesia |
| Tin | | Rui Da Hung | | Taiwan, Province of China |
| Tin | | Soft Metais Ltda. | | Brazil |
| Tin | | Thaisarco | | Thailand |
| Tin | | White Solder Metalurgia e Mineracao Ltda. | | Brazil |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | China |
| Tin | | Tin Smelting Branch of Yunnan Tin Co., Ltd. | | China |
| Tin | | CV Venus Inti Perkasa | | Indonesia |
| Tin | | Magnu's Minerais Metais e Ligas Ltda. | | Brazil |
| Tin | | PT ATD Makmur Mandiri Jaya | | Indonesia |
| Tin | | O.M. Manufacturing Philippines, Inc. | | Philippines |
| Tin | | CV Ayi Jaya | | Indonesia |
| Tin | | PT Rajehan Ariq | | Indonesia |
| Tin | | PT Cipta Persada Mulia | | Indonesia |
| Tin | | Resind Industria e Comercio Ltda. | | Brazil |
| Tin | | Super Ligas | | Brazil |
| Tin | | Aurubis Beerse | | Belgium |
| Tin | | Aurubis Berango | | Spain |
| Tin | | PT Bangka Prima Tin | | Indonesia |
| Tin | | PT Sukses Inti Makmur (SIM) | | Indonesia |
| Tin | | PT Menara Cipta Mulia | | Indonesia |
| Tin | | HuiChang Hill Tin Industry Co., Ltd. | | China |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | China |
| Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | China |
| Tin | | PT Bangka Serumpun | | Indonesia |
| Tin | | Tin Technology & Refining | | United States of America |
| Tin | | PT Rajawali Rimba Perkasa | | Indonesia |
| Tin | | Luna Smelter, Ltd. | | Rwanda |
| Tin | | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | | China |
| Tin | | PT Mitra Sukses Globalindo | | Indonesia |
| Tin | | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | | Brazil |
| Tin | | CRM Synergies | | Spain |
| Tin | | Fabrica Auricchio Industria e Comercio Ltda. | | Brazil |
| Tin | | DS Myanmar | | Myanmar |
| Tin | | PT Putera Sarana Shakti (PT PSS) | | Indonesia |
| Tungsten | | A.L.M.T. Corp. | | Japan |
| Tungsten | | Kennametal Huntsville | | United States of America |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | China |
| | | | | | | | | | | | | | |
| Metal (*) | | Name of Smelter or Refiner | | Smelter or Refiner Country |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | China |
| Tungsten | | Global Tungsten & Powders LLC | | United States of America |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | China |
| Tungsten | | Hunan Jintai New Material Co, Ltd. | | China |
| Tungsten | | Japan New Metals Co., Ltd. | | Japan |
| Tungsten | | Kennametal Fallon | | United States of America |
| Tungsten | | Wolfram Bergbau und Hutten AG | | Austria |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | China |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | China |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | China |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | China |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | China |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | China |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | China |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | China |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | China |
| Tungsten | | Asia Tungsten Products Vietnam Ltd. | | Viet Nam |
| Tungsten | | Hunan Shizhuyuan Nonferrous Matals Co., Ltd. Chenzhou Tungsten Products Branch | | China |
| Tungsten | | H.C. Starck Tungsten GmbH | | Germany |
| Tungsten | | TANIOBIS Smelting GmbH & Co. KG | | Germany |
| Tungsten | | Masan High-Tech Materials | | Vietnam |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | China |
| Tungsten | | Niagara Refining LLC | | United States of America |
| Tungsten | | China Molybdenum Tungsten Co., Ltd. | | China |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | Philippines |
| Tungsten | | Lianyou Metals Co., Ltd. | | Taiwan, Province of China |
| Tungsten | | Hubei Green Tungstern Co., Ltd. | | China |
| Tungsten | | Cronimet Brasil Ltda | | Brazil |
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