UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM SD

Specialized Disclosure Report

 

 

SEALED AIR CORPORATION

(Exact Name of Registrant as Specified in its Charter)

 

 

 

Delaware		1-12139		65-0654331
(State or Other Jurisdiction of Incorporation)		(Commission File Number)		(IRS Employer Identification No.)

 

2415 Cascade Pointe Boulevard Charlotte, North Carolina		28208
(Address of Principal Executive Offices)		(Zip Code)

Thomas C. Lagaly

Vice President, Acting General Counsel & Secretary

980-221-3235

(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, 2016.

 

 

 

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Section 1 – Conflict Minerals Disclosure

 

Item 1.01

Conflict Minerals Disclosure and Report

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”), Sealed Air Corporation (“Sealed Air” or the “Company”) is filing this Form SD to disclose information relating to the Company’s use and sourcing of columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (“3TG” or “Conflict Minerals”).

The Company has determined that during the reporting period January 1, 2016 to December 31, 2016, certain of the products the Company manufactures or contracts to manufacture contained 3TG that was necessary to the functionality or production of those products. Sealed Air conducted a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the 3TG originated in the Democratic Republic of the Congo or an adjoining country (together, a “Covered Country”) and whether any of the 3TG originated from recycled or scrap sources. Based on this RCOI, Sealed Air determined that certain of the 3TG likely originated in the Covered Countries and did not originate from recycled or scrap sources. Accordingly, Sealed Air exercised due diligence on the source and chain of custody of such 3TG and has filed a Conflict Minerals Report for calendar year 2016 (the “2016 Conflict Minerals Report”). The Company’s 2016 Conflict Minerals Report is attached hereto as Exhibit 1.01 and is publicly available at www.sealedair.com/investors.

 

Item 1.02

Exhibit

The Company’s 2016 Conflict Minerals Report, as required by Item 1.02, is attached as Exhibit 1.01 to this Form SD.

Section 2 – Exhibits

 

Item 2.01

Exhibits

Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2016 to December 31, 2016.

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SIGNATURE

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.

 

Dated: May 26, 2017

Exhibit 1.01

Sealed Air Corporation

Conflict Minerals Report

for the Year Ended December 31, 2016

Introduction

This Conflict Minerals Report has been prepared pursuant to Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “Rule”), for the reporting period from January 1 to December 31, 2016. This Conflict Minerals Report describes Sealed Air Corporation’s (“Sealed Air,” the “Company,” “we,” “our,” or “us”) reasonable country of origin inquiry (“RCOI”) and due diligence on the source and chain of custody of gold, columbite-tantalite (coltan), cassiterite, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (“3TG” or “Conflict Minerals”) that are necessary to the production or functionality of products that Sealed Air manufactured or contracted to manufacture during calendar year 2016 (the “2016 Report Year”). We are several steps removed from the mining and processing of the 3TG used in the components for our products. Accordingly, our due diligence process focused on our suppliers, and we rely on them to assist with both our RCOI and due diligence process, including the identification of smelters or refiners (“SORs”) in the supply chain and the countries of origin of 3TG sourced by the identified SORs.

The information in this report covers the activities of Sealed Air and all of its consolidated subsidiaries.

Company Overview

Sealed Air, a corporation organized under the laws of Delaware, is a global leader in food safety and security, facility hygiene and product protection. The Company serves an array of end markets including food and beverage processing, food service, retail, healthcare and industrial, and commercial and consumer applications. Our focus is on achieving quality sales growth through leveraging our geographic footprint, technological know-how and leading market positions to bring measurable, sustainable value to our customers and investors.

Product Description

This Conflict Minerals Report relates to products (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2016. Through a screening process, the Company determined that, to the best of our knowledge, customer equipment and other select products from the Company’s three divisions, Food Care, Product Care and Diversey Care, referred to collectively as the “Covered Products,” contain 3TG or have a high likelihood of containing 3TG, as these products contain electronic components. More specifically, the “Covered Products” may contain necessary Conflict Minerals as follows:

 

•

Tantalum, used in capacitors and certain alloys;

 

•

Tin, used in soldered components;

 

•

Tungsten, used in coatings and certain alloys; and

 

•

Gold, used in circuit boards and electronic components.

Supply Chain

Our supply chain includes 507 different in-scope suppliers. Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is challenging to identify actors upstream from our direct suppliers. There are many tiers of suppliers and sub-suppliers between the Company and the SORs that process the 3TG that is contained in each particular product manufactured or contracted to be manufactured by Sealed Air. Therefore, it is inherently difficult to determine the ultimate source of 3TG in the products we manufacture. As a result, we rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers.

We have revised contract terms applicable to the majority of our suppliers with regard to 3TG. Those terms require suppliers to certify that, unless otherwise specified in writing, the products do not contain any 3TG, and further require that the suppliers respond to reasonable requests from the Company in connection with its compliance with Section 1502 of the Dodd-Frank Act.

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Reasonable Country of Origin Inquiry

We conducted a RCOI reasonably designed to determine whether the 3TG in our products in the 2016 Report Year originated from the Covered Countries or are from recycled or scrap sources in accordance with the requirements of the Rule. The Covered Countries are the Democratic Republic of the Congo and its adjoining countries (Angola, Burundi, Republic of the Congo, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda and Zambia). As part of its RCOI, and with the assistance of a third-party consultant, Assent Compliance, Inc. (“Assent”), the Company engaged its potential 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products. Suppliers were asked to complete and submit, within a certain time frame, the joint Electronic Industry Citizen Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”) EICC-GeSI Conflict Minerals Reporting Template v. 4.1 or higher (“CMRT”). The CMRT is a standardized reporting template developed by the Conflict-Free Sourcing Initiative (“CFSI”) that requests, among other things, information regarding country of origin of 3TG supplied to the Company and the SORs in the supply chain. Assent followed up with all unresponsive suppliers through a defined process via both automated emails and one-on-one emails, including offering assistance and further information to suppliers about the requirements of the Rule and the Company’s expectations. Based on the RCOI, Sealed Air determined that certain of our 3TG originated in the Covered Countries and did not originate from recycled or scrap sources. Accordingly, Sealed Air exercised due diligence on the source and chain of custody of such 3TG and is filing this Conflict Minerals Report for the 2016 Report Year.

Due Diligence

Design of Due Diligence

Sealed Air designed its due diligence process to conform with the due diligence framework in the Organization of Economic Co-operation and Development Due Diligence (“OECD”) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively the “OECD Guidance”).

Step One – Establish Strong Company Management Systems

Conflict Minerals Policy

We have adopted a Conflict Minerals policy, which is posted on our website at www.sealedair.com/investors.

Internal Team and Training

The Company has established an internal management team responsible for executing our Conflict Minerals due diligence process and reporting compliance. Our Conflict Minerals team is overseen by the General Counsel and Chief Supply Chain Officer and a team of subject matter experts from relevant functions such as quality, supply chain, operations, finance and legal. The team of subject matter experts is responsible for implementing our Conflict Minerals compliance strategy. Senior management is briefed about the results of our due diligence efforts on a regular basis.

We, in cooperation with Assent, have developed internal training programs to educate anyone within the Company that is a potential contact point for suppliers or other external parties regarding the Company’s Conflict Minerals compliance efforts. We intend to review our training programs at least annually to make sure they are continuously aligned with current regulations, our initiatives, and the tools we use.

Control Systems

As previously noted, the Company engaged Assent to facilitate supplier engagement and assist the Company in collecting, analyzing, verifying, and storing supplier-provided data and performing due diligence for the Conflict Minerals program. Data regarding the presence and sourcing of 3TG in materials, goods and components supplied to the Company was collected from suppliers utilizing the CMRT, a standardized reporting template developed by the CFSI.

Our controls also include our Code of Business Conduct and Ethics, which outlines expected behaviors for all our employees.

Supplier Engagement

We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers.

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In accordance with the OECD requirement to strengthen engagement with suppliers, we have, in cooperation with Assent, provided educational materials to suppliers on the Conflict Minerals regulations as well as relevant SEC reporting requirements (as discussed further below). In addition, we have leveraged our existing communications framework, specifically through our procurement personnel, to encourage supplier interactions with Assent and to impress on our suppliers the importance of completing the Conflict Minerals surveys. It has also allowed for our supplier communications to be more focused and to ensure expectations are clear.

Additionally, as noted, the majority of our supplier contracts require suppliers to certify that, unless otherwise specified in writing, the products do not contain any 3TG, and further require that the suppliers respond to reasonable requests from the Company in connection with its compliance with Section 1502 of the Dodd-Frank Act.

This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized Assent’s Learning Management System, Assent University, and provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.

Grievance Mechanism

We have in place a grievance mechanism whereby employees and suppliers can report violations of the Company’s policies, including concerns with regard to Conflict Minerals. Employees and suppliers can raise concerns by emailing at contact.us@sealedair.com.

Records Maintenance

We have retained all relevant documentation from our RCOI and due diligence. Our policy related to relevant documentation of our Conflict Minerals compliance process requires that documentation be retained for a period of at least five years.

Step Two – Identify and Assess Risk in Our Supply Chain

Supplier Risk Assessment

Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is challenging for us to identify suppliers other than our direct suppliers. After conducting a risk-based assessment of our direct suppliers, we identified over 500 different in-scope direct suppliers. We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. Many of the largest suppliers either are SEC registrants and subject to the Rule or are suppliers to other SEC registrants that are subject to the Rule.

We calculate supplier risk based on the chances that a supplier provides 3TG that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the SORs declared by that supplier on their CMRT. Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:

 

•

Does the supplier have a policy in place that includes DRC conflict-free sourcing?

 

•

Has the supplier implemented due diligence measures for conflict-free sourcing?

 

•

Does the supplier verify due diligence information received from its suppliers?

 

•

Does the supplier’s verification process include corrective action management?

When a supplier meets these criteria, the supplier is deemed to have a strong program. When a supplier does not meet these criteria, the supplier is deemed to have a weak program.

As part of our risk management plan and to ensure suppliers understand our expectations, we have, through Assent, provided video and written training on Conflict Minerals and the CMRT. This training includes instructions on completing the form and one-on-one email and phone discussions with supplier personnel.

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Supplier Surveys

Tracing materials back to their mine or location of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG SORs in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.

Our primary means of determining the origin of our 3TG for the 2016 Report Year was by conducting a supply chain survey with direct suppliers using the CMRT. This supply chain survey, and Sealed Air’s Conflict Minerals program as a whole, has been developed and implemented in cooperation with Assent.

Assent provided each supplier a copy of the EICC-GeSI reporting CMRT to complete for purposes of Conflict Minerals tracking. Assent and/or members of the Sealed Air supply chain team made at least three follow-up inquiries to each supplier that did not respond to our initial survey, either by phone or email or both. The Assent software platform automatically reviewed the responses against criteria developed to determine which required further engagement with our suppliers. These criteria included incomplete responses as well as inconsistencies within the data reported in the CMRT. Assent worked directly with those suppliers to provide revised responses.

Once surveys were returned, Assent reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the CFSI Conflict-Free Smelter Program (“CFSP”). If a SOR was not validated by the CFSP, Assent either attempted to contact the SOR to gather more information about its sourcing practices or conducted Internet research to determine whether there are any additional publicly available sources of information regarding the SOR’s sourcing practices.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free pose a significant risk to the Supply Chain. Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on three scoring criteria:

 

•

Geographic proximity to the DRC and covered countries;

 

•

CFSP audit status; and

 

•

Known or plausible evidence of unethical or conflict sourcing.

Per these criteria the following facilities have been identified as being of highest concern to the supply chain:

 

•

Tony Goetz NV – CID002587

 

•

Kaloti Precious Metals – CID002563

 

•

Phoenix Metals – CID002507

 

•

Universal Precious Metals Refining Zambia – CID002854

 

•

Fidelity Printers and Refiners – CID002515

 

•

Sudan Gold Refinery – CID002567

When these facilities are reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through, Assent, submissions that include any of the above 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 Sealed Air, up to removal of these high risk smelters from their 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 goal of progressive elimination of these risks from the supply chain. In addition, suppliers are guided to the Assent University learning platform to view educational materials on mitigating the risk of smelters or refiners to the supply chain.

Step Three – Design and Implement a Strategy to Respond to Risks

The Company maintains a risk management plan to respond to risks identified in the above-described risk assessment. The Company’s Conflict Minerals program is implemented, managed and monitored in accordance with this risk management plan.

The Company’s Conflict Minerals team provides updates to senior management of the Company in connection with the Conflict Minerals Program, including with regard to risk assessment and results of the annual due diligence process.

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As described in our Conflict Minerals policy, we expect our suppliers to fully support our compliance efforts, including in connection with our due diligence efforts to trace the source and chain of custody of our 3TG. As part of our risk management plan, to ensure suppliers understand our expectations, we provided both video recorded training and documented instructions through Assent, and answered all questions that suppliers requiring further clarification presented to us.

Step Four – Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

Sealed Air does not have a direct relationship with Conflict Minerals SORs and, accordingly, we do not perform direct audits of these entities in our supply chain. Rather, Sealed Air relies on independent third-parties to audit and validate SORs.

Step Five – Report on Supply Chain Due Diligence

This Conflict Minerals Report is being filed with the SEC as an exhibit to our specialized disclosure report on Form SD and is available on our website at www.sealedair.com/investors.

Due Diligence Results

As a result of the due diligence efforts described above, we received completed CMRTs from 88% of our in-scope direct suppliers as of April 21, 2017. Appendix A lists the SORs identified by our direct suppliers that may have been used to process Conflict Minerals necessary to the functionality or production of our products during 2016. For all responses that indicated a SOR, Assent compared the facilities listed to the list of SORs maintained by the CFSI. If a supplier indicated that the facility was “Conflict-Free,” Assent confirmed that the name was listed by CFSI as such. We have validated 317 SORs to date and we are working to validate the additional SOR entries from the submitted CMRTs. We have not listed in Appendix A any potential SORs that we have not been able to validate. Based on the SOR lists provided by suppliers via the CMRTs and publicly available information regarding the results of sourcing audits by the CFSI, we have identified 246 Conflict-Free SORs. 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 our suppliers.

The information that we received from a majority of our direct suppliers was at a company-wide level. Therefore, the SORs identified by our direct suppliers contained in Appendix A may include SORs that processed 3TGs that our direct suppliers supplied to their other customers rather than to us. As a result, we are unable to conclusively determine whether the SORs included in Appendix A were used to process the 3TGs necessary to the functionality or production of our products during 2016. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed in Appendix B was a country of origin of 3TGs in our products during 2016, and therefore are unable to conclusively determine the source and chain of custody of those 3TGs. In addition, the third-party audits conducted by the CFSI, and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete Conflict Minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the CFSI Conflict-Free Smelter Program and, as a result, are not responsible for the quality of these audits or the audit findings.

Risk Mitigation Efforts

We have taken, and intend to continue to take, the following steps to mitigate the risk that 3TG contained in products we manufacture or contract to manufacture benefit armed groups:

 

•

Track and add new suppliers as they enter Sealed Air’s supply chain to the Company’s Conflict Minerals program;

 

•

Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses;

 

•

Begin a targeted engagement plan with suppliers that do not reply or that reply with inaccurate or invalid responses; and

 

•

Encourage suppliers to use conflict-free SORs in the supply chain.

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Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements that express certain beliefs, expectations or intentions, including with regard to our compliance efforts and expected actions in this regard. The words “expect,” “intend,” “plan,” “believe,” and “anticipate” and similar expressions may be used to identify these forward-looking statements. These statements are not guarantees of future actions or performance and are subject to various risks, uncertainties and assumptions. Undue reliance should be not be placed on these statements, which are only effective as of the date of this report. Sealed Air undertakes no obligation to publicly update or revise any forward-looking statement, other than as required by law.

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Appendix A

Sealed Air Corporation

Conflict Minerals Report

For the Year Ended December 31, 2016

 

Metal		Standard Smelter Name		Smelter Facility Location		Smelter ID		CFSI Audit Status
Gold		Abington Reldan Metals, LLC		UNITED STATES		CID002708		Active
Gold		Advanced Chemical Company		UNITED STATES		CID000015		Compliant
Gold		Aida Chemical Industries Co., Ltd.		JAPAN		CID000019		Compliant
Gold		Al Etihad Gold Refinery DMCC		UNITED ARAB EMIRATES		CID002560		Compliant
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		GERMANY		CID000035		Compliant
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		UZBEKISTAN		CID000041		Compliant
Gold		AngloGold Ashanti Córrego do Sítio Mineração		BRAZIL		CID000058		Compliant
Gold		Argor-Heraeus S.A.		SWITZERLAND		CID000077		Compliant
Gold		Asahi Pretec Corp.		JAPAN		CID000082		Compliant
Gold		Asahi Refining Canada Ltd.		CANADA		CID000924		Compliant
Gold		Asahi Refining USA Inc.		UNITED STATES		CID000920		Compliant
Gold		Asaka Riken Co., Ltd.		JAPAN		CID000090		Compliant
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		TURKEY		CID000103		Not Enrolled
Gold		AU Traders and Refiners		SOUTH AFRICA		CID002850		Compliant
Gold		AURA-II		UNITED STATES		CID002851		Not Enrolled
Gold		Aurubis AG		GERMANY		CID000113		Compliant
Gold		Bangalore Refinery		INDIA		CID002863		Active
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		PHILIPPINES		CID000128		Compliant
Gold		Boliden AB		SWEDEN		CID000157		Compliant
Gold		C. Hafner GmbH + Co. KG		GERMANY		CID000176		Compliant
Gold		Caridad		MEXICO		CID000180		Not Enrolled
Gold		CCR Refinery – Glencore Canada Corporation		CANADA		CID000185		Compliant
Gold		Cendres + Métaux S.A.		SWITZERLAND		CID000189		Active
Gold		Chimet S.p.A.		ITALY		CID000233		Compliant
Gold		Chugai Mining		JAPAN		CID000264		Not Enrolled
Gold		Daejin Indus Co., Ltd.		KOREA, REPUBLIC OF		CID000328		Compliant
Gold		Daye Non-Ferrous Metals Mining Ltd.		CHINA		CID000343		Not Enrolled
Gold		Degussa Sonne / Mond Goldhandel GmbH		GERMANY		CID002867		Not Enrolled
Gold		DODUCO GmbH		GERMANY		CID000362		Compliant
Gold		Dowa		JAPAN		CID000401		Compliant

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Gold		DSC (Do Sung Corporation)		KOREA, REPUBLIC OF		CID000359		Compliant
Gold		Eco-System Recycling Co., Ltd.		JAPAN		CID000425		Compliant
Gold		Elemetal Refining, LLC		UNITED STATES		CID001322		Compliant
Gold		Emirates Gold DMCC		UNITED ARAB EMIRATES		CID002561		Compliant
Gold		Fidelity Printers and Refiners Ltd.		ZIMBABWE		CID002515		Not Enrolled
Gold		Gansu Seemine Material Hi-Tech Co., Ltd.		CHINA		CID000522		Not Enrolled
Gold		Geib Refining Corporation		UNITED STATES		CID002459		Active
Gold		Great Wall Precious Metals Co., Ltd. of CBPM		CHINA		CID001909		Not Enrolled
Gold		Guangdong Jinding Gold Limited		CHINA		CID002312		Not Enrolled
Gold		Gujarat Gold Centre		INDIA		CID002852		Not Enrolled
Gold		Guoda Safina High-Tech Environmental Refinery Co., Ltd.		CHINA		CID000651		Not Enrolled
Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.		CHINA		CID000671		Not Enrolled
Gold		Heimerle + Meule GmbH		GERMANY		CID000694		Compliant
Gold		Heraeus Ltd. Hong Kong		CHINA		CID000707		Compliant
Gold		Heraeus Precious Metals GmbH & Co. KG		GERMANY		CID000711		Compliant
Gold		Hunan Chenzhou Mining Co., Ltd.		CHINA		CID000767		Not Enrolled
Gold		Hwasung CJ Co., Ltd.		KOREA, REPUBLIC OF		CID000778		Not Enrolled
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.		CHINA		CID000801		Compliant
Gold		Ishifuku Metal Industry Co., Ltd.		JAPAN		CID000807		Compliant
Gold		Istanbul Gold Refinery		TURKEY		CID000814		Compliant
Gold		Japan Mint		JAPAN		CID000823		Compliant
Gold		Jiangxi Copper Co., Ltd.		CHINA		CID000855		Compliant
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		RUSSIAN FEDERATION		CID000927		Compliant
Gold		JSC Uralelectromed		RUSSIAN FEDERATION		CID000929		Compliant
Gold		JX Nippon Mining & Metals Co., Ltd.		JAPAN		CID000937		Compliant
Gold		Kaloti Precious Metals		UNITED ARAB EMIRATES		CID002563		Not Enrolled
Gold		Kazakhmys Smelting LLC		KAZAKHSTAN		CID000956		Not Enrolled
Gold		Kazzinc		KAZAKHSTAN		CID000957		Compliant
Gold		Kennecott Utah Copper LLC		UNITED STATES		CID000969		Compliant
Gold		KGHM Polska Miedź Spółka Akcyjna		POLAND		CID002511		Active
Gold		Kojima Chemicals Co., Ltd.		JAPAN		CID000981		Compliant
Gold		Korea Zinc Co., Ltd.		KOREA, REPUBLIC OF		CID002605		Compliant
Gold		Kyrgyzaltyn JSC		KYRGYZSTAN		CID001029		Compliant
Gold		L’azurde Company For Jewelry		SAUDI ARABIA		CID001032		Not Enrolled
Gold		Lingbao Gold Co., Ltd.		CHINA		CID001056		Not Enrolled

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Gold		Lingbao Jinyuan Tonghui Refinery Co., Ltd.		CHINA		CID001058		Not Enrolled
Gold		L’Orfebre S.A.		ANDORRA		CID002762		Not Enrolled
Gold		LS-NIKKO Copper Inc.		KOREA, REPUBLIC OF		CID001078		Compliant
Gold		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.		CHINA		CID001093		Not Enrolled
Gold		Materion		UNITED STATES		CID001113		Compliant
Gold		Matsuda Sangyo Co., Ltd.		JAPAN		CID001119		Compliant
Gold		Metalor Technologies (Hong Kong) Ltd.		CHINA		CID001149		Compliant
Gold		Metalor Technologies (Singapore) Pte., Ltd.		SINGAPORE		CID001152		Compliant
Gold		Metalor Technologies (Suzhou) Ltd.		CHINA		CID001147		Compliant
Gold		Metalor Technologies S.A.		SWITZERLAND		CID001153		Compliant
Gold		Metalor USA Refining Corporation		UNITED STATES		CID001157		Compliant
Gold		Metalúrgica Met-Mex Peñoles S.A. De C.V.		MEXICO		CID001161		Compliant
Gold		Mitsubishi Materials Corporation		JAPAN		CID001188		Compliant
Gold		Mitsui Mining and Smelting Co., Ltd.		JAPAN		CID001193		Compliant
Gold		MMTC-PAMP India Pvt., Ltd.		INDIA		CID002509		Compliant
Gold		Modeltech Sdn Bhd		MALAYSIA		CID002857		Not Enrolled
Gold		Morris and Watson		NEW ZEALAND		CID002282		Not Enrolled
Gold		Morris and Watson Gold Coast		AUSTRALIA		CID002866		Not Enrolled
Gold		Moscow Special Alloys Processing Plant		RUSSIAN FEDERATION		CID001204		Compliant
Gold		Nadir Metal Rafineri San. Ve Tic. A.Ş.		TURKEY		CID001220		Compliant
Gold		Navoi Mining and Metallurgical Combinat		UZBEKISTAN		CID001236		Active
Gold		Nihon Material Co., Ltd.		JAPAN		CID001259		Compliant
Gold		Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH		AUSTRIA		CID002779		Compliant
Gold		Ohura Precious Metal Industry Co., Ltd.		JAPAN		CID001325		Compliant
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)		RUSSIAN FEDERATION		CID001326		Compliant
Gold		OJSC Novosibirsk Refinery		RUSSIAN FEDERATION		CID000493		Compliant
Gold		PAMP S.A.		SWITZERLAND		CID001352		Compliant
Gold		Pease & Curren		UNITED STATES		CID002872		Not Enrolled
Gold		Penglai Penggang Gold Industry Co., Ltd.		CHINA		CID001362		Not Enrolled
Gold		Prioksky Plant of Non-Ferrous Metals		RUSSIAN FEDERATION		CID001386		Compliant
Gold		PT Aneka Tambang (Persero) Tbk		INDONESIA		CID001397		Compliant
Gold		PX Précinox S.A.		SWITZERLAND		CID001498		Compliant
Gold		Rand Refinery (Pty) Ltd.		SOUTH AFRICA		CID001512		Compliant
Gold		Remondis Argentia B.V.		NETHERLANDS		CID002582		Not Enrolled
Gold		Republic Metals Corporation		UNITED STATES		CID002510		Compliant

---

Gold		Royal Canadian Mint		CANADA		CID001534		Compliant
Gold		SAAMP		FRANCE		CID002761		Not Enrolled
Gold		Sabin Metal Corp.		UNITED STATES		CID001546		Not Enrolled
Gold		SAFINA A.S.		CZECH REPUBLIC		CID002290		Not Enrolled
Gold		Sai Refinery		INDIA		CID002853		Not Enrolled
Gold		Samduck Precious Metals		KOREA, REPUBLIC OF		CID001555		Compliant
Gold		SAMWON Metals Corp.		KOREA, REPUBLIC OF		CID001562		Not Enrolled
Gold		SAXONIA Edelmetalle GmbH		GERMANY		CID002777		Compliant
Gold		Schone Edelmetaal B.V.		NETHERLANDS		CID001573		Compliant
Gold		SEMPSA Joyería Platería S.A.		SPAIN		CID001585		Compliant
Gold		Shandong Tiancheng Biological Gold Industrial Co., Ltd.		CHINA		CID001619		Not Enrolled
Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.		CHINA		CID001622		Compliant
Gold		Sichuan Tianze Precious Metals Co., Ltd.		CHINA		CID001736		Compliant
Gold		Singway Technology Co., Ltd.		TAIWAN		CID002516		Compliant
Gold		So Accurate Group, Inc.		UNITED STATES		CID001754		Not Enrolled
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		RUSSIAN FEDERATION		CID001756		Compliant
Gold		Solar Applied Materials Technology Corp.		TAIWAN		CID001761		Compliant
Gold		Sudan Gold Refinery		SUDAN		CID002567		Not Enrolled
Gold		Sumitomo Metal Mining Co., Ltd.		JAPAN		CID001798		Compliant
Gold		SungEel HiTech		KOREA, REPUBLIC OF		CID002918		Active
Gold		T.C.A S.p.A		ITALY		CID002580		Compliant
Gold		Tanaka Kikinzoku Kogyo K.K.		JAPAN		CID001875		Compliant
Gold		The Refinery of Shandong Gold Mining Co., Ltd.		CHINA		CID001916		Compliant
Gold		Tokuriki Honten Co., Ltd.		JAPAN		CID001938		Compliant
Gold		Tongling Nonferrous Metals Group Co., Ltd.		CHINA		CID001947		Not Enrolled
Gold		Tony Goetz NV		BELGIUM		CID002587		Active
Gold		TOO Tau-Ken-Altyn		KAZAKHSTAN		CID002615		Not Enrolled
Gold		Torecom		KOREA, REPUBLIC OF		CID001955		Compliant
Gold		Umicore Brasil Ltda.		BRAZIL		CID001977		Compliant
Gold		Umicore Precious Metals Thailand		THAILAND		CID002314		Compliant
Gold		Umicore S.A. Business Unit Precious Metals Refining		BELGIUM		CID001980		Compliant
Gold		United Precious Metal Refining, Inc.		UNITED STATES		CID001993		Compliant
Gold		Universal Precious Metals Refining Zambia		ZAMBIA		CID002854		Not Enrolled
Gold		Valcambi S.A.		SWITZERLAND		CID002003		Compliant
Gold		Western Australian Mint trading as The Perth Mint		AUSTRALIA		CID002030		Compliant

---

Gold		WIELAND Edelmetalle GmbH		GERMANY		CID002778		Compliant
Gold		Yamamoto Precious Metal Co., Ltd.		JAPAN		CID002100		Compliant
Gold		Yokohama Metal Co., Ltd.		JAPAN		CID002129		Compliant
Gold		Yunnan Copper Industry Co., Ltd.		CHINA		CID000197		Not Enrolled
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		CHINA		CID002224		Compliant
Gold		Zijin Mining Group Co., Ltd. Gold Refinery		CHINA		CID002243		Compliant
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		CHINA		CID000211		Compliant
Tantalum		Conghua Tantalum and Niobium Smeltry		CHINA		CID000291		Compliant
Tantalum		D Block Metals, LLC		UNITED STATES		CID002504		Compliant
Tantalum		Duoluoshan		CHINA		CID000410		Compliant
Tantalum		Exotech Inc.		UNITED STATES		CID000456		Compliant
Tantalum		F&X Electro-Materials Ltd.		CHINA		CID000460		Compliant
Tantalum		FIR Metals & Resource Ltd.		CHINA		CID002505		Compliant
Tantalum		Global Advanced Metals Aizu		JAPAN		CID002558		Compliant
Tantalum		Global Advanced Metals Boyertown		UNITED STATES		CID002557		Compliant
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		CHINA		CID000616		Compliant
Tantalum		H.C. Starck Co., Ltd.		THAILAND		CID002544		Compliant
Tantalum		H.C. Starck GmbH Goslar		GERMANY		CID002545		Compliant
Tantalum		H.C. Starck GmbH Laufenburg		GERMANY		CID002546		Not Enrolled
Tantalum		H.C. Starck Hermsdorf GmbH		GERMANY		CID002547		Compliant
Tantalum		H.C. Starck Inc.		UNITED STATES		CID002548		Compliant
Tantalum		H.C. Starck Ltd.		JAPAN		CID002549		Compliant
Tantalum		H.C. Starck Smelting GmbH & Co. KG		GERMANY		CID002550		Compliant
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		CHINA		CID002492		Compliant
Tantalum		Hi-Temp Specialty Metals, Inc.		UNITED STATES		CID000731		Compliant
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		CHINA		CID002512		Compliant
Tantalum		Jiangxi Tuohong New Raw Material		CHINA		CID002842		Compliant
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		CHINA		CID000914		Compliant
Tantalum		Jiujiang Tanbre Co., Ltd.		CHINA		CID000917		Compliant
Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		CHINA		CID002506		Compliant
Tantalum		KEMET Blue Metals		MEXICO		CID002539		Compliant
Tantalum		KEMET Blue Powder		UNITED STATES		CID002568		Compliant
Tantalum		King-Tan Tantalum Industry Ltd.		CHINA		CID000973		Compliant
Tantalum		LSM Brasil S.A.		BRAZIL		CID001076		Compliant
Tantalum		Metallurgical Products India Pvt., Ltd.		INDIA		CID001163		Compliant

---

Tantalum		Mineração Taboca S.A.		BRAZIL		CID001175		Compliant
Tantalum		Mitsui Mining & Smelting		JAPAN		CID001192		Compliant
Tantalum		Molycorp Silmet A.S.		ESTONIA		CID001200		Compliant
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		CHINA		CID001277		Compliant
Tantalum		Plansee SE Liezen		AUSTRIA		CID002540		Not Enrolled
Tantalum		Plansee SE Reutte		AUSTRIA		CID002556		Compliant
Tantalum		Power Resources Ltd.		MACEDONIA		CID002847		Compliant
Tantalum		QuantumClean		UNITED STATES		CID001508		Compliant
Tantalum		Resind Indústria e Comércio Ltda.		BRAZIL		CID002707		Compliant
Tantalum		RFH Tantalum Smeltry Co., Ltd.		CHINA		CID001522		Compliant
Tantalum		Solikamsk Magnesium Works OAO		RUSSIAN FEDERATION		CID001769		Compliant
Tantalum		Taki Chemicals		JAPAN		CID001869		Compliant
Tantalum		Telex Metals		UNITED STATES		CID001891		Compliant
Tantalum		Tranzact, Inc.		UNITED STATES		CID002571		Compliant
Tantalum		Ulba Metallurgical Plant JSC		KAZAKHSTAN		CID001969		Compliant
Tantalum		XinXing HaoRong Electronic Material Co., Ltd.		CHINA		CID002508		Compliant
Tantalum		Yichun Jin Yang Rare Metal Co., Ltd.		CHINA		CID002307		Compliant
Tantalum		Zhuzhou Cemented Carbide Group Co., Ltd.		CHINA		CID002232		Compliant
Tin		Alpha		UNITED STATES		CID000292		Compliant
Tin		An Thai Minerals Co., Ltd.		VIET NAM		CID002825		Not Enrolled
Tin		An Vinh Joint Stock Mineral Processing Company		VIET NAM		CID002703		Not Enrolled
Tin		Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.		CHINA		CID000228		Compliant
Tin		China Tin Group Co., Ltd.		CHINA		CID001070		Compliant
Tin		CNMC (Guangxi) PGMA Co., Ltd.		CHINA		CID000278		Not Enrolled
Tin		Cooperativa Metalurgica de Rondônia Ltda.		BRAZIL		CID000295		Compliant
Tin		CV Ayi Jaya		INDONESIA		CID002570		Compliant
Tin		CV Dua Sekawan		INDONESIA		CID002592		Compliant
Tin		CV Gita Pesona		INDONESIA		CID000306		Compliant
Tin		CV Serumpun Sebalai		INDONESIA		CID000313		Compliant
Tin		CV Tiga Sekawan		INDONESIA		CID002593		Compliant
Tin		CV United Smelting		INDONESIA		CID000315		Compliant
Tin		CV Venus Inti Perkasa		INDONESIA		CID002455		Compliant
Tin		Dowa		JAPAN		CID000402		Compliant
Tin		Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company		VIET NAM		CID002572		Active
Tin		Elmet S.L.U.		SPAIN		CID002774		Compliant

---

Tin		EM Vinto		BOLIVIA		CID000438		Compliant
Tin		Estanho de Rondônia S.A.		BRAZIL		CID000448		Not Enrolled
Tin		Fenix Metals		POLAND		CID000468		Compliant
Tin		Gejiu Fengming Metallurgy Chemical Plant		CHINA		CID002848		Compliant
Tin		Gejiu Jinye Mineral Company		CHINA		CID002859		Compliant
Tin		Gejiu Kai Meng Industry and Trade LLC		CHINA		CID000942		Active
Tin		Gejiu Non-Ferrous Metal Processing Co., Ltd.		CHINA		CID000538		Compliant
Tin		Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.		CHINA		CID001908		Active
Tin		Gejiu Zili Mining And Metallurgy Co., Ltd.		CHINA		CID000555		Not Enrolled
Tin		Guanyang Guida Nonferrous Metal Smelting Plant		CHINA		CID002849		Compliant
Tin		HuiChang Hill Tin Industry Co., Ltd.		CHINA		CID002844		Compliant
Tin		Huichang Jinshunda Tin Co., Ltd.		CHINA		CID000760		Not Enrolled
Tin		Jiangxi Ketai Advanced Material Co., Ltd.		CHINA		CID000244		Compliant
Tin		Magnu’s Minerais Metais e Ligas Ltda.		BRAZIL		CID002468		Compliant
Tin		Malaysia Smelting Corporation (MSC)		MALAYSIA		CID001105		Compliant
Tin		Melt Metais e Ligas S.A.		BRAZIL		CID002500		Compliant
Tin		Metallic Resources, Inc.		UNITED STATES		CID001142		Compliant
Tin		Metallo-Chimique N.V.		BELGIUM		CID002773		Compliant
Tin		Mineração Taboca S.A.		BRAZIL		CID001173		Compliant
Tin		Minsur		PERU		CID001182		Compliant
Tin		Mitsubishi Materials Corporation		JAPAN		CID001191		Compliant
Tin		Modeltech Sdn Bhd		MALAYSIA		CID002858		Not Enrolled
Tin		Nankang Nanshan Tin Manufactory Co., Ltd.		CHINA		CID001231		Active
Tin		Nghe Tinh Non-Ferrous Metals Joint Stock Company		VIET NAM		CID002573		Not Enrolled
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		THAILAND		CID001314		Compliant
Tin		O.M. Manufacturing Philippines, Inc.		PHILIPPINES		CID002517		Compliant
Tin		Operaciones Metalurgical S.A.		BOLIVIA		CID001337		Compliant
Tin		Phoenix Metal Ltd.		RWANDA		CID002507		Not Enrolled
Tin		PT Aries Kencana Sejahtera		INDONESIA		CID000309		Compliant
Tin		PT Artha Cipta Langgeng		INDONESIA		CID001399		Compliant
Tin		PT ATD Makmur Mandiri Jaya		INDONESIA		CID002503		Compliant
Tin		PT Babel Inti Perkasa		INDONESIA		CID001402		Compliant
Tin		PT Bangka Prima Tin		INDONESIA		CID002776		Compliant
Tin		PT Bangka Tin Industry		INDONESIA		CID001419		Compliant
Tin		PT Belitung Industri Sejahtera		INDONESIA		CID001421		Compliant

---

Tin		PT Bukit Timah		INDONESIA		CID001428		Compliant
Tin		PT Cipta Persada Mulia		INDONESIA		CID002696		Compliant
Tin		PT DS Jaya Abadi		INDONESIA		CID001434		Compliant
Tin		PT Eunindo Usaha Mandiri		INDONESIA		CID001438		Compliant
Tin		PT Inti Stania Prima		INDONESIA		CID002530		Compliant
Tin		PT Justindo		INDONESIA		CID000307		Not Enrolled
Tin		PT Karimun Mining		INDONESIA		CID001448		Compliant
Tin		PT Kijang Jaya Mandiri		INDONESIA		CID002829		Compliant
Tin		PT Lautan Harmonis Sejahtera		INDONESIA		CID002870		Compliant
Tin		PT Mitra Stania Prima		INDONESIA		CID001453		Compliant
Tin		PT O.M. Indonesia		INDONESIA		CID002757		Compliant
Tin		PT Panca Mega Persada		INDONESIA		CID001457		Compliant
Tin		PT Prima Timah Utama		INDONESIA		CID001458		Compliant
Tin		PT Refined Bangka Tin		INDONESIA		CID001460		Compliant
Tin		PT Sariwiguna Binasentosa		INDONESIA		CID001463		Compliant
Tin		PT Stanindo Inti Perkasa		INDONESIA		CID001468		Compliant
Tin		PT Sukses Inti Makmur		INDONESIA		CID002816		Compliant
Tin		PT Sumber Jaya Indah		INDONESIA		CID001471		Compliant
Tin		PT Timah (Persero) Tbk Kundur		INDONESIA		CID001477		Compliant
Tin		PT Timah (Persero) Tbk Mentok		INDONESIA		CID001482		Compliant
Tin		PT Tinindo Inter Nusa		INDONESIA		CID001490		Compliant
Tin		PT Tommy Utama		INDONESIA		CID001493		Compliant
Tin		PT Wahana Perkit Jaya		INDONESIA		CID002479		Compliant
Tin		Resind Indústria e Comércio Ltda.		BRAZIL		CID002706		Compliant
Tin		Rui Da Hung		TAIWAN		CID001539		Compliant
Tin		Soft Metais Ltda.		BRAZIL		CID001758		Compliant
Tin		Thaisarco		THAILAND		CID001898		Compliant
Tin		Tuyen Quang Non-Ferrous Metals Joint Stock Company		VIET NAM		CID002574		Not Enrolled
Tin		VQB Mineral and Trading Group JSC		VIET NAM		CID002015		Compliant
Tin		White Solder Metalurgia e Mineração Ltda.		BRAZIL		CID002036		Compliant
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		CHINA		CID002158		Active
Tin		Yunnan Tin Company Limited		CHINA		CID002180		Compliant
Tungsten		A.L.M.T. TUNGSTEN Corp.		JAPAN		CID000004		Compliant
Tungsten		ACL Metais Eireli		BRAZIL		CID002833		Not Enrolled
Tungsten		Asia Tungsten Products Vietnam Ltd.		VIET NAM		CID002502		Compliant

---

Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		CHINA		CID002513		Compliant
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		CHINA		CID000258		Compliant
Tungsten		Dayu Weiliang Tungsten Co., Ltd.		CHINA		CID000345		Not Enrolled
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		CHINA		CID000499		Compliant
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		CHINA		CID000875		Compliant
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		CHINA		CID002315		Compliant
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		CHINA		CID002494		Compliant
Tungsten		Ganzhou Yatai Tungsten Co., Ltd.		CHINA		CID002536		Not Enrolled
Tungsten		Global Tungsten & Powders Corp.		UNITED STATES		CID000568		Compliant
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		CHINA		CID000218		Compliant
Tungsten		H.C. Starck GmbH		GERMANY		CID002541		Compliant
Tungsten		H.C. Starck Smelting GmbH & Co.KG		GERMANY		CID002542		Compliant
Tungsten		Hunan Chenzhou Mining Co., Ltd.		CHINA		CID000766		Compliant
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		CHINA		CID002579		Compliant
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		CHINA		CID000769		Compliant
Tungsten		Hydrometallurg, JSC		RUSSIAN FEDERATION		CID002649		Compliant
Tungsten		Japan New Metals Co., Ltd.		JAPAN		CID000825		Compliant
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		CHINA		CID002551		Compliant
Tungsten		Jiangxi Dayu Longxintai Tungsten Co., Ltd.		CHINA		CID002647		Not Enrolled
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		CHINA		CID002321		Compliant
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		CHINA		CID002313		Not Enrolled
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		CHINA		CID002318		Compliant
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		CHINA		CID002317		Compliant
Tungsten		Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.		CHINA		CID002535		Compliant
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		CHINA		CID002316		Compliant
Tungsten		Kennametal Fallon		UNITED STATES		CID000966		Compliant
Tungsten		Kennametal Huntsville		UNITED STATES		CID000105		Compliant
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		CHINA		CID002319		Compliant
Tungsten		Moliren Ltd		RUSSIAN FEDERATION		CID002845		Compliant
Tungsten		Niagara Refining LLC		UNITED STATES		CID002589		Compliant
Tungsten		Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC		VIET NAM		CID002543		Compliant
Tungsten		Philippine Chuangxin Industrial Co., Inc.		PHILIPPINES		CID002827		Compliant
Tungsten		South-East Nonferrous Metal Company Limited of Hengyang City		CHINA		CID002815		Compliant
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		VIET NAM		CID001889		Compliant

---

Tungsten		Unecha Refractory metals plant		RUSSIAN FEDERATION		CID002724		Compliant
Tungsten		Vietnam Youngsun Tungsten Industry Co., Ltd.		VIET NAM		CID002011		Compliant
Tungsten		Wolfram Bergbau und Hütten AG		AUSTRIA		CID002044		Compliant
Tungsten		Woltech Korea Co., Ltd.		KOREA, REPUBLIC OF		CID002843		Compliant
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		CHINA		CID002320		Compliant
Tungsten		Xiamen Tungsten Co., Ltd.		CHINA		CID002082		Compliant
Tungsten		Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.		CHINA		CID002830		Compliant
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		CHINA		CID002095		Compliant

---

Appendix B

Sealed Air Corporation

Conflict Minerals Report

For the Year Ended December 31, 2016

Angola, Argentina, Australia, Austria, Belgium, Brazil, Burundi, Canada, Central Africa Republic, Chile, China, Columbia, Cote D’Ivoire, Czech Republic, the Democratic Republic of the Congo, Djibouti, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungry, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Lao People’s Democratic Republic, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Plurinational State of Bolivia, Portugal, Republic of Korea, Republic of the Congo, Russian Federation, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Switzerland, Taiwan, Thailand, Uganda, United Kingdom of Great Britain, United Republic of Tanzania, United States of America, Vietnam, Zambia and Zimbabwe.