Form SD and Conflict Minerals Report

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

__________________________________________

ILLINOIS TOOL WORKS INC.

(Exact name of registrant as specified in its charter)

__________________________________________

Delaware
1-4797
36-1258310
(State or other jurisdiction of incorporation or organization)
(Commission File Number)
(I.R.S. Employer Identification No.)

155 Harlem Avenue, Glenview, IL  60025
(Address of principal executive offices)

(Zip Code)
Maria C. Green (847-724-7500)

Name and telephone number, including area code, of the person to contact in connection with this report

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

[ X ] Rule 13p-1 under the Securities Exchange Act (17CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.

Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

As required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report is provided as an Exhibit to this Form SD and is available on our website at www.itw.com .

Item 1.02 Exhibits

The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 2 – Exhibits

Item 2.01    Exhibits

1.01    Conflict Minerals Report for the calendar year ended December 31, 2014.

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.

ILLINOIS TOOL WORKS INC.

Dated: June 1, 2015
By: /s/ Maria C. Green

Maria C. Green

Senior Vice President, General Counsel & Secretary
EXHIBIT INDEX

Exhibit

Description
1.01

Conflict Minerals Report for the calendar year ended December 31, 2014.
Exhibit 1.01

Conflict Minerals Report

This Conflict Minerals Report of Illinois Tool Works Inc. for calendar year 2014 has been prepared in accordance with the requirements of Rule 13p-1 (“Rule 13p-1”) and Form SD (together referred to as the “Conflict Minerals Rule”) of the United States Securities and Exchange Commission (“SEC”). Unless the context indicates otherwise, the terms “Company,” “ITW,” “we,” “its,” “us” and “our” refer to Illinois Tool Works Inc. and its consolidated subsidiaries.

“Conflict minerals” or “3TG” as used in this report, refers to cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and/or gold, without regard to their location of origin.

Applicability of the Conflict Minerals Rule to Our Company

ITW, founded in 1912 and incorporated in 1915, is a global manufacturer of a diversified range of industrial products and equipment. As of December 31, 2014, the Company has approximately 90 divisions in 57 countries. All of our segments manufacture products that contain conflict minerals that are necessary to the functionality or production of the products (which we sometimes refer to herein as “in-scope” products).

Most of our businesses are many levels removed from 3TG mining, smelting and processing facilities, and we have no relationships with mines. In addition, our operations are global in scope and, because our individual businesses independently make sourcing decisions from suppliers in local markets, our supplier base is numerous and greatly diverse, both in terms of supplier type and geographic location. Because of our size, the breadth and complexity of our products, and the constant evolution of our supply chain, it is difficult to identify stakeholders upstream from our direct suppliers. We rely on our direct suppliers to provide information on smelters and refiners as well as the origin of 3TG contained in our in-scope products. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our suppliers responsibly source conflict minerals.

For 2014, each of our in-scope products contained at least some conflict minerals content for which we were unable to determine the origin. In-scope product, smelter and refiner information in respect of 2014 is described under “Product Information” and “Smelters and Refiners; Country of Origin” below and on Annex A. We have not found for 2014 that any of the necessary conflict minerals contained in our in-scope products directly or indirectly financed or benefited armed groups in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”). However, we did not conclude that any of our products were “DRC conflict free.” The terms “adjoining country,” “armed group,” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.

ITW Conflict Minerals Policy

ITW has adopted a company-wide conflict minerals policy (the “Policy”), which is available on our website at  www.itw.com . The Policy is accessible by clicking on “About ITW” on the home page, and then the “Suppliers” link. Our Policy states that we support the aims and objectives of the U.S. legislation on the supply of conflict minerals, and we do not knowingly procure conflict minerals that originate from the Covered Countries unless they originate from mines or smelters that are certified as “conflict free.” Pursuant to our Policy, we ask our suppliers to undertake reasonable due diligence with their supply chains to determine whether products containing conflict minerals used in the manufacture of our products originate from a Covered Country and, if they do originate from a Covered Country, that the mines or smelters be certified as “conflict free” by an independent third party. If we discover that any conflict minerals procured by us are produced in a Covered Country from facilities that are not certified as “conflict free,” we will request that our supplier ask the facility to become certified as “conflict free” or use our best efforts to transition the product to be conflict free.

Reasonable Country of Origin Inquiry Information

As required by the Conflict Minerals Rule, for 2014, we conducted a “reasonable country of origin inquiry” (“RCOI”). We designed our RCOI in good faith to determine the origin of conflict minerals that are necessary to the functionality or production of products we manufacture or contract to manufacture.

Our outreach included all suppliers (the “Suppliers”) that we identified as having provided us with components, parts or products that contain conflict minerals or that we believe may contain conflict minerals. In 2014 we sought to improve our communications with our businesses and with our Suppliers in order to make the process simpler and easier to follow, with the goal being to increase Supplier response rates and the quality of information received. Our RCOI excluded our Industrial Packaging segment, which we sold on May 1, 2014. We determined that it was impractical to seek to obtain information from suppliers for the portion of the year that we owned that business, since our outreach to suppliers would have occurred following the sale and we believed that suppliers were unlikely to provide a response limited to our period of ownership.

Our Supplier responses identified 107 smelters certified by the Conflict-Free Sourcing Initiative (“CFSI”) as conflict free; we determined that 87 of these compliant smelters were sourced from outside the Covered Countries. Our determination was based on country of origin information made available by the CFSI to its members.

Pursuant to the Conflict Minerals Rule, based on the results of our RCOI, we were required to conduct due diligence for 2014. These due diligence efforts are discussed below.

For our RCOI, to the extent applicable, we utilized the same processes and procedures as for our due diligence.

Due Diligence Program Design

Design Framework

ITW´s due diligence processes and efforts utilize the Organisation for Economic Co-operation and Development ‘s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected And High-Risk Areas  (Second Edition, 2013) (the “OECD Guidance”), an internationally recognized due diligence framework as required by the SEC.

Selected Elements of Design Framework

The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our program design are discussed below. However, these are not all of the discrete elements of the program that we have put in place to help ensure that the conflict minerals contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the five steps. Selected due diligence measures that we took in respect of 2014 are discussed under “Due Diligence Program Execution.”

OECD Step 1 – Establish strong management systems

● ITW’s Policy, approved by our Chief Executive Officer, has been circulated to selected personnel and suppliers and is accessible on our website.

● ITW has a cross-functional conflict minerals committee (the “Committee”). The Committee is headed by ITW’s Vice President of Strategic Sourcing, who reports to ITW’s Vice Chairman, and includes dedicated employees and representatives from legal, environmental and chemical compliance, sustainability and environmental, strategic sourcing, internal audit, IT, and selected personnel from various operations. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets on a regular basis to discuss the conflict minerals compliance process and developments. Senior management is briefed on the results of our due diligence efforts on a regular basis.

● We use a third party software vendor to coordinate and track RCOI and due diligence interactions between ITW businesses, their customers and suppliers through use of a cloud-based conflict minerals tracking tool (the “CM System”).

● We maintain an intranet conflict minerals website which contains educational information on the Conflict Minerals Rule, resource materials, and guidance on the RCOI and due diligence process for businesses that have or may have in-scope products. The site also contains step-by-step instructions for making supplier inquiries, including a link to a training video regarding our CM System, and can be accessed by all ITW businesses for reference.

● Our conflict minerals intranet provides information and guidance to assist our businesses in their determination of whether any conflict minerals are contained in their products.

● ITW businesses use the Conflict Minerals Reporting Template developed by the CFSI to request information from suppliers, and require that their suppliers utilize the CM System to respond to their inquiries. The reporting template requests information regarding conflict minerals included in the suppliers’ products, smelter identity and location, and other information about the suppliers’ conflict minerals policies and practices.

● ITW is a member of the CFSI.

● ITW educates key suppliers through presentations regarding our conflict minerals compliance program during supplier conferences and other interactions.

● ITW has included wording in its supplier contract “Terms and Conditions” that reflects the Policy and obligates suppliers to take such actions as requested by ITW to enable us to comply with our conflict minerals disclosure requirements.

● ITW maintains a web- and telephone-based reporting system (Helpline), providing employees with a confidential reporting mechanism by which they can communicate issues and concerns associated with violations of ITW’s Principles of Conduct, which requires all employees to comply with all applicable laws and Company policies, including the Policy. The Helpline is also available to external stakeholders and suppliers through a public domain website.

● ITW retains the conflict minerals related records for at least five years.

OECD Step 2 – Identify and assess risk in the supply chain

● Our businesses are directed to determine, by inquiring of relevant personnel, whether any conflict minerals are contained in their products. Resources and instructions for making this determination are included on our intranet site described under Step 1 above.

● Our businesses are instructed to send out conflict mineral inquiry requests to our direct in-scope suppliers through our CM System, directing each supplier to complete the CFSI Conflict Minerals Reporting Template.

● We conduct follow-up (including email and phone communications), pursuant to internally developed written procedures, to the extent that a response is not received or otherwise triggers specified “red flags.” In 2014 we strengthened our internal procedures for Supplier inquiries by simplifying our written communications and giving our businesses specific written instructions for Supplier follow-up.

● Smelter and refiner information provided by suppliers is reviewed against the Standard Smelter Names tab of the Conflict Minerals Reporting Template.

● Smelter and refiner information also is reviewed against the lists of “compliant” and “active” smelters and refiners and country of origin information published by the CFSI and contained in the CM System.
OECD Step 3 – Design and implement a strategy to respond to identified risks

● Findings are discussed by our strategic sourcing personnel, and a listing of suppliers identified as using conflict minerals from a Covered Country is provided to management in our strategic sourcing and legal departments.

● If an individual business receives a response from a supplier indicating the presence of conflict minerals from a Covered Country, communications with that supplier are escalated, and the business is instructed to review the supplier’s response with the supplier.

● To the extent that conflict minerals are confirmed by a supplier as not being from a CFSI compliant source in a Covered Country, our businesses are instructed to work with the supplier, where possible, to seek certification of the processor as a compliant smelter or refiner or to source from a compliant source. These supplier situations are reviewed on a case-by-case basis, and the communications take place outside of the CM System.
OECD Step 4 – Carry out independent third party audit of supply chain diligence at identified points in the supply chain

● In connection with our due diligence, we rely on the CFSI’s Conflict-Free Smelter Program to perform third-party audits of smelters and refiners.

● We support independent third-party audits by being a member of the CFSI.

OECD Step 5 – Report annually on supply chain due diligence

● We file a Form SD and a Conflict Minerals Report with the SEC and make these documents available on our website. We also include a discussion of our efforts in the area of conflict minerals in our annual Corporate Social Responsibility Report.

Due Diligence Program Execution

We performed the following due diligence measures in respect of the 2014 compliance period. These are not all of the measures that we took in furtherance of our conflict minerals compliance program or pursuant to the OECD Guidance. For a discussion of the design of our due diligence measures, please see “Due Diligence Program Design.”

●    We joined the CFSI.

● We sent 4,874 requests to Suppliers to provide us with a completed CFSI Conflict Minerals Reporting Template. A number of our businesses source different products from the same supplier, and each business sends inquiries to all suppliers of in-scope products; accordingly, the total number of unique suppliers is less than the number of Suppliers queried. We followed up by email or phone with the Suppliers that did not provide a response within the time frame specified in the request. We received 1,622 Conflict Minerals Reporting Templates from the Suppliers.

● We reviewed the completed responses received from the Suppliers based on our internal written review criteria to identify incomplete or inaccurate responses or responses that triggered a “red flag.”

● We reviewed the smelters and refiners identified to us by the Suppliers against those contained on the Standard Smelter Names tab of the CFSI Conflict Minerals Reporting Template.

● To the extent that a completed response identified a smelter or refiner, we also reviewed that information against the list of smelters and refiners in the CM System that have been verified as compliant by the CFSI and those that have committed to actively pursue compliant status.

● Our Conflict Minerals compliance team reported the findings of its compliance efforts in respect of 2014 to our Vice President of Strategic Sourcing.

Product Information

For 2014, our in-scope products required to be described in this Conflict Minerals Report included products in each of the categories below:

Arc welding and cutting equipment and consumables Inspection equipment
Commercial ovens LEDs, LCDs
Commercial refrigerators Marking and coding equipment
Electrical devices mixers
Electronic equipment Industrial warewashers
Equipment and consumables for testing and measuring of materials Printers and dispensers
Fastening tools Sealing equipment
Flow control meters Switches, capacitors and electronics
Hot stamp machines Testing equipment
Industrial equipment Various automotive component assemblies
Industrial ovens Warehouse equipment

Identified Smelters and Refiners

Our Supplier responses identified 107 smelters and refiners that were on the CFSI compliant list, 12 that were listed as active and 154 that were on the Standard Smelter List but not compliant or active. These facilities are listed on Annex A. The information in Annex A includes only the information and entities identified by our Suppliers as smelters and refiners on the Standard Smelter List contained in the CM System as of May 28, 2015, which are those entities identified to us that we were able to determine were smelters or refiners. Entities identified by our Suppliers that are not on Annex A will be submitted to the CFSI to support their ongoing effort to identify and audit all 3TG smelters and refiners.

Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our suppliers for accurate smelter and refiner information, and our due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary conflict minerals contained in our in-scope products.

Annex A also includes information concerning the identified countries of origin of the smelters and refiners listed on Annex A. Due to the challenges of tracing a multi-tier supply chain, for 2014, we were unable to determine the origin of at least a portion of the conflict minerals in each of our in-scope products. We have not found for 2014 that any of our in-scope products contained necessary Conflict Minerals that directly or indirectly financed or benefited an armed group in a Covered Country. An “armed group” under the Conflict Minerals Rule is an armed group that is identified as a perpetrator of serious human rights abuses in annual Country Reports on Human Rights Practices under sections 116(d) and 502B(b) of the Foreign Assistance Act of 1961 relating to a Covered Country. However, we did not conclude that any of our products were “DRC conflict free.”

We endeavored to determine the mine or location of origin of the conflict minerals contained in our in-scope products by requesting that the Suppliers provide us with a completed CFSI Conflict Minerals Reporting Template. Where a smelter or refiner was identified, we also reviewed information made available by the CFSI to its members to try to determine the mine or location of origin.

Additional Risk Mitigation

We intend to take the following additional steps in respect of our 2015 compliance to mitigate the risk that the necessary conflict minerals in our in-scope products benefit armed groups:

● Use Revision 4.0 of the Conflict Minerals Reporting Template for our 2015 supplier outreach.

● Continue to analyze and review our current processes to improve their effectiveness and efficiency.

● Continue to enhance supplier communication and training to improve due diligence data accuracy and completion.

● Through our direct suppliers, continue to influence additional smelters in our supply chain to obtain conflict free certification, where possible.

● Continue our membership in the CFSI and support the CFSI’s certification of conflict free smelters.

● Submit to the CFSI facilities identified by our Suppliers that are not on the Standard Smelter List, to support the CFSI’s ongoing effort to identify and audit all 3TG smelters and refiners.

● Communicate ITW’s expectations regarding conflict-free sourcing in our internal Strategic Sourcing meetings and, in turn, with our suppliers.

Annex A to Exhibit 1.01

 

CFSI Compliant Smelters
Name Country Smelter ID
Alpha UNITED STATES CID000292
AngloGold Ashanti Córrego do Sítio Minerçăo BRAZIL CID000058
Argor-Heraeus SA SWITZERLAND CID000077
Asahi Pretec Corporation JAPAN CID000082
Asia Tungsten Products Vietnam Ltd. VIETNAM CID002502
Aurubis AG GERMANY CID000113
CCR Refinery – Glencore Canada Corporation CANADA CID000185
Chimet S.p.A. ITALY CID000233
Conghua Tantalum and Niobium Smeltry CHINA CID000291
CV United Smelting INDONESIA CID000315
D Block Metals, LLC UNITED STATES CID002504
Dowa JAPAN CID000401
Dowa JAPAN CID000402
Duoluoshan CHINA CID000410
Exotech Inc. UNITED STATES CID000456
F&X Electro-Materials Ltd. CHINA CID000460
Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA CID000875
Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA CID002315
Gejiu Non-Ferrous Metal Processing Co. Ltd. CHINA CID000538
Global Advanced Metals Boyertown UNITED STATES CID002557
Global Tungsten & Powders Corp. UNITED STATES CID000568
Guangdong Zhiyuan New Material Co., Ltd. CHINA CID000616
H.C. Starck Co., Ltd. THAILAND CID002544
H.C. Starck GmbH Goslar GERMANY CID002545
H.C. Starck GmbH Laufenburg GERMANY CID002546
H.C. Starck Smelting GmbH & Co.KG GERMANY CID002542
H.C. Starck Smelting GmbH & Co.KG GERMANY CID002550
Heimerle + Meule GmbH GERMANY CID000694
Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA CID002492
Heraeus Ltd. Hong Kong HONG KONG CID000707
Heraeus Precious Metals GmbH & Co. KG GERMANY CID000711
Hi-Temp UNITED STATES CID000731
Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA CID000769
Ishifuku Metal Industry Co., Ltd. JAPAN CID000807
Istanbul Gold Refinery TURKEY CID000814
JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA CID000914
Jiujiang Tanbre Co., Ltd. CHINA CID000917
Jiujiang Zhongao Tantalum & Niobium Co, Ltd CHINA CID002506
Johnson Matthey Inc UNITED STATES CID000920
Johnson Matthey Ltd CANADA CID000924
JX Nippon Mining & Metals Co., Ltd. JAPAN CID000937
KEMET Blue Metals MEXICO CID002539
KEMET Blue Powder UNITED STATES CID002568
Kennecott Utah Copper LLC UNITED STATES CID000969
Kojima Chemicals Co., Ltd JAPAN CID000981
LSM Brasil S.A. BRAZIL CID001076
LS-NIKKO Copper Inc. KOREA, REPUBLIC OF CID001078
Magnu’s Minerais Metais e Ligas LTDA BRAZIL CID002468
Malaysia Smelting Corporation (MSC) MALAYSIA CID001105
Malipo Haiyu Tungsten Co., Ltd. CHINA CID002319
Materion UNITED STATES CID001113
Matsuda Sangyo Co., Ltd. JAPAN CID001119
Metallurgical Products India (Pvt.) Ltd. INDIA CID001163
Metalor Technologies (Hong Kong) Ltd HONG KONG CID001149
Metalor Technologies SA SWITZERLAND CID001153
Metalor USA Refining Corporation UNITED STATES CID001157
Mineraçăo Taboca S.A. BRAZIL CID001173
Mineraçăo Taboca S.A. BRAZIL CID001175
Minsur PERU CID001182
Mitsubishi Materials Corporation JAPAN CID001188
Mitsubishi Materials Corporation JAPAN CID001191
Mitsui Mining & Smelting JAPAN CID001192
Mitsui Mining and Smelting Co., Ltd. JAPAN CID001193
MMTC-PAMP India Pvt. Ltd INDIA CID002509
Molycorp Silmet A.S. ESTONIA CID001200
Nihon Material Co. LTD JAPAN CID001259
Ningxia Orient Tantalum Industry Co., Ltd. CHINA CID001277
Ohio Precious Metals, LLC UNITED STATES CID001322
Ohura Precious Metal Industry Co., Ltd JAPAN CID001325
OMSA BOLIVIA CID001337
PAMP SA SWITZERLAND CID001352
PT Bangka Tin Industry INDONESIA CID001419
PT Bukit Timah INDONESIA CID001428
PT DS Jaya Abadi INDONESIA CID001434
PT Eunindo Usaha Mandiri INDONESIA CID001438
PT REFINED BANGKA TIN INDONESIA CID001460
PT Stanindo Inti Perkasa INDONESIA CID001468
PT Tambang Timah INDONESIA CID001477
PT Timah (Persero), Tbk INDONESIA CID001482
QuantumClean UNITED STATES CID001508
Rand Refinery (Pty) Ltd SOUTH AFRICA CID001512
Republic Metals Corporation UNITED STATES CID002510
RFH Tantalum Smeltry Co., Ltd CHINA CID001522
Royal Canadian Mint CANADA CID001534
SEMPSA Joyería Platería SA SPAIN CID001585
Singway Technology Co., Ltd. TAIWAN CID002516
Solar Applied Materials Technology Corp. TAIWAN CID001761
Solikamsk Magnesium Works OAO RUSSIAN FEDERATION CID001769
Sumitomo Metal Mining Co., Ltd. JAPAN CID001798
Taki Chemicals JAPAN CID001869
Tanaka Kikinzoku Kogyo K.K. JAPAN CID001875
Telex UNITED STATES CID001891
Tokuriki Honten Co., Ltd JAPAN CID001938
Ulba KAZAKHSTAN CID001969
Umicore Brasil Ltda BRAZIL CID001977
Umicore SA Business Unit Precious Metals Refining BELGIUM CID001980
United Precious Metal Refining, Inc. UNITED STATES CID001993
Valcambi SA SWITZERLAND CID002003
Vietnam Youngsun Tungsten Industry Co., Ltd VIETNAM CID002011
Western Australian Mint trading as The Perth Mint AUSTRALIA CID002030
White Solder Metalurgia e Mineraçăo Ltda. BRAZIL CID002036
Wolfram Bergbau und Hütten AG AUSTRIA CID002044
Xiamen Tungsten (H.C.) Co., Ltd. CHINA CID002320
Xiamen Tungsten Co., Ltd. CHINA CID002082
Yichun Jin Yang Rare Metal Co., Ltd CHINA CID002307
Yunnan Tin Company, Ltd. CHINA CID002180
Zhuzhou Cement Carbide CHINA CID002232

 

Other Smelters
Name Country Smelter ID Active
A.L.M.T. Corp. JAPAN CID000004
Advanced Chemical Company UNITED STATES CID000015
Aida Chemical Industries Co. Ltd. JAPAN CID000019
Aktyubinsk RUSSIAN FEDERATION CID000028
Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY CID000035
Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN CID000041
Asaka Riken Co Ltd JAPAN CID000090 Active
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY CID000103
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES CID000128
Bauer Walser AG GERMANY CID000141
Boliden AB SWEDEN CID000157
C. Hafner GmbH + Co. KG GERMANY CID000176
Caridad MEXICO CID000180
Cendres + Métaux SA SWITZERLAND CID000189 Active
Changsha South Tantalum Niobium Co., Ltd. CHINA CID000211
Chenzhou Diamond Tungsten Products Co., Ltd. CHINA CID002513
China National Gold Group Corporation CHINA CID000242
China Rare Metal Materials Company CHINA CID000244
China Tin Group Co., Ltd. CHINA CID001070
Chongyi Zhangyuan Tungsten Co., Ltd. CHINA CID000258
Chugai Mining JAPAN CID000264
CNMC (Guangxi) PGMA Co. Ltd. CHINA CID000278
Colt Refining UNITED STATES CID000288
Cooper Santa BRAZIL CID000295
CV Gita Pesona INDONESIA CID000306
CV JusTindo INDONESIA CID000307
CV Makmur Jaya INDONESIA CID000308
CV Nurjanah INDONESIA CID000309
CV Serumpun Sebalai INDONESIA CID000313
CV Venus Inti Perkasa INDONESIA CID002455
Daejin Indus Co. Ltd KOREA, REPUBLIC OF CID000328
Daye Non-Ferrous Metals Mining Ltd. CHINA CID000343
Dayu Jincheng Tungsten Industry Co., Ltd. CHINA CID002518
Dayu Weiliang Tungsten Co., Ltd. CHINA CID000345
Do Sung Corporation KOREA, REPUBLIC OF CID000359
Doduco GERMANY CID000362 Active
Eco-System Recycling Co., Ltd. JAPAN CID000425
EM Vinto BOLIVIA CID000438
Fenix Metals POLAND CID000468 Active
FIR Metals & Resource., Ltd. CHINA CID002505
FSE Novosibirsk Refinery RUSSIAN FEDERATION CID000493
Fujian Jinxin Tungsten Co., Ltd. CHINA CID000499
Gansu Seemine Material Hi-Tech Co Ltd CHINA CID000522
Ganxian Shirui New Material Co., Ltd. CHINA CID002531
Ganzhou Non-ferrous Metals Smelting Co., Ltd. CHINA CID000868
Ganzhou Seadragon W & Mo Co., Ltd. CHINA CID002494
Ganzhou Yatai Tungsten Co., Ltd. CHINA CID002536
Gejiu Kai Meng Industry and Trade LLC CHINA CID000942
Gejiu Zi-Li CHINA CID000555
Global Advanced Metals Aizu JAPAN CID002558
Guangdong Jinding Gold Limited CHINA CID002312
Guangdong Xianglu Tungsten Co., Ltd. CHINA CID000218
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch CHINA CID002501
H.C. Starck GmbH GERMANY CID002541
H.C. Starck Hermsdorf GmbH GERMANY CID002547
H.C. Starck Inc. UNITED STATES CID002548
H.C. Starck Ltd. JAPAN CID002549
Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA CID000671
Huichang Jinshunda Tin Co. Ltd CHINA CID000760
Hunan Chenzhou Mining Group Co., Ltd. CHINA CID000766
Hunan Chenzhou Mining Group Co., Ltd. CHINA CID000767
Hwasung CJ Co. Ltd KOREA, REPUBLIC OF CID000778
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited CHINA CID000801
Japan Mint JAPAN CID000823
Japan New Metals Co., Ltd. JAPAN CID000825
Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA CID002551
Jiangxi Copper Company Limited CHINA CID000855
Jiangxi Dinghai Tantalum & Niobium Co., LTD CHINA CID002512
Jiangxi Gan Bei Tungsten Co., Ltd. CHINA CID002321
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. CHINA CID002313
Jiangxi Nanshan CHINA CID000864
Jiangxi Richsea New Materials Co., Ltd. CHINA CID002493
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA CID002318
Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA CID002317
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CHINA CID002535
Jiangxi Yaosheng Tungsten Co., Ltd. CHINA CID002316
JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION CID000927
JSC Uralelectromed RUSSIAN FEDERATION CID000929
Kazzinc Ltd KAZAKHSTAN CID000957
Kennametal Fallon UNITED STATES CID000966
Kennametal Huntsville UNITED STATES CID000105
KGHM Polska Miedź Spółka Akcyjna POLAND CID002511
King-Tan Tantalum Industry Ltd CHINA CID000973
Korea Metal Co. Ltd KOREA, REPUBLIC OF CID000988
Kyrgyzaltyn JSC KYRGYZSTAN CID001029
L’ azurde Company For Jewelry SAUDI ARABIA CID001032
Lingbao Gold Company Limited CHINA CID001056
Lingbao Jinyuan Tonghui Refinery Co. Ltd. CHINA CID001058
Linwu Xianggui Smelter Co CHINA CID001063
Luoyang Zijin Yinhui Metal Smelt Co Ltd CHINA CID001093
Melt Metais e Ligas S/A BRAZIL CID002500
Metallo Chimique BELGIUM CID001143
Metalor Technologies (Singapore) Pte. Ltd. SINGAPORE CID001152
Met-Mex Peñoles, S.A. MEXICO CID001161
Moscow Special Alloys Processing Plant RUSSIAN FEDERATION CID001204
Nadir Metal Rafineri San. Ve Tic. A.Ş. TURKEY CID001220
Navoi Mining and Metallurgical Combinat UZBEKISTAN CID001236
Novosibirsk Integrated Tin Works RUSSIAN FEDERATION CID001305
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC VIETNAM CID002543
O.M. Manufacturing (Thailand) Co., Ltd. THAILAND CID001314 Active
O.M. Manufacturing Philippines, Inc. PHILIPPINES CID002517
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) RUSSIAN FEDERATION CID001326
OJSC Kolyma Refinery RUSSIAN FEDERATION CID001328
Penglai Penggang Gold Industry Co Ltd CHINA CID001362
Phoenix Metal Ltd RWANDA CID002507 Active
Plansee SE Liezen AUSTRIA CID002540
Plansee SE Reutte AUSTRIA CID002556
Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION CID001386
PT Alam Lestari Kencana INDONESIA CID001393
PT Aneka Tambang (Persero) Tbk INDONESIA CID001397
PT Artha Cipta Langgeng INDONESIA CID001399
PT ATD Makmur Mandiri Jaya INDONESIA CID002503
PT Babel Inti Perkasa INDONESIA CID001402
PT Babel Surya Alam Lestari INDONESIA CID001406
PT Bangka Putra Karya INDONESIA CID001412
PT Belitung Industri Sejahtera INDONESIA CID001421
PT BilliTin Makmur Lestari INDONESIA CID001424 Active
PT Donna Kembara Jaya INDONESIA CID002473
PT Fang Di MulTindo INDONESIA CID001442
PT HP Metals Indonesia INDONESIA CID001445
PT Inti Stania Prima INDONESIA CID002530
PT Karimun Mining INDONESIA CID001448
PT Koba Tin INDONESIA CID001449
PT Mitra Stania Prima INDONESIA CID001453
PT Panca Mega Persada INDONESIA CID001457
PT Pelat Timah Nusantara Tbk INDONESIA CID001486
PT Prima Timah Utama INDONESIA CID001458
PT Rajwa International INDONESIA CID002475
PT Sariwiguna Binasentosa INDONESIA CID001463
PT Seirama Tin investment INDONESIA CID001466
PT Singkep Times Utama INDONESIA CID002476
PT Sumber Jaya Indah INDONESIA CID001471
PT Supra Sukses Trinusa INDONESIA CID001476
PT Tinindo Inter Nusa INDONESIA CID001490
PT Tirus Putra Mandiri INDONESIA CID002478
PT Tommy Utama INDONESIA CID001493
PT Wahana Parkit Jaya INDONESIA CID002479
PT Yinchendo Mining Industry INDONESIA CID001494
PT.HANJAYA PERKASA METALS INDONESIA CID002287
PX Précinox SA SWITZERLAND CID001498
Rui Da Hung TAIWAN CID001539 Active
Sabin Metal Corp. UNITED STATES CID001546
Samduck Precious Metals KOREA, REPUBLIC OF CID001555
SAMWON METALS Corp. KOREA, REPUBLIC OF CID001562
Sanher Tungsten Vietnam Co., Ltd. VIETNAM CID002538
Schone Edelmetaal NETHERLANDS CID001573
Shandong Zhaojin Gold & Silver Refinery Co. Ltd CHINA CID001622
Shanghai Jiangxi Metals Co. Ltd CHINA CID001634
Sichuan Tianze Precious Metals Co., Ltd CHINA CID001736
So Accurate Group, Inc. UNITED STATES CID001754
SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION CID001756 Active
Soft Metais, Ltda. BRAZIL CID001758
Tejing (Vietnam) Tungsten Co., Ltd. VIETNAM CID001889
The Great Wall Gold and Silver Refinery of China CHINA CID001909
The Refinery of Shandong Gold Mining Co. Ltd CHINA CID001916
Tongling nonferrous Metals Group Co.,Ltd CHINA CID001947
Torecom KOREA, REPUBLIC OF CID001955 Active
Wolfram Company CJSC RUSSIAN FEDERATION CID002047
Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA CID002095
XinXing HaoRong Electronic Material CO.,LTD CHINA CID002508
YAMAMOTO PRECIOUS METAL CO., LTD. JAPAN CID002100
Yokohama Metal Co Ltd JAPAN CID002129 Active
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. CHINA CID002158 Active
Yunnan Copper Industry Co Ltd CHINA CID000197
Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA CID002224
Zijin Mining Group Co. Ltd CHINA CID002243
Active smelters have committed to undergo a Conflict Free Smelter Program audit by the CFSI.