UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
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NU SKIN ENTERPRISES, INC.
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(Exact name of registrant as specified in its charter)
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Delaware
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001-12421
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87-0565309
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(State or other jurisdiction of incorporation)
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(Commission File Number)
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(IRS Employer Identification Number)
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75 West Center Street
Provo, Utah 84601
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(Address of principal executive offices and zip code)
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Gregory Belliston, (801) 345-1000
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(Name and telephone number, including area code, of the person to contact in connection with this report)
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Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information applies:
| ☑ |
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.
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Section 1 – Conflict Minerals Disclosure
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Item 1.01
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Conflict Minerals Disclosure and Report
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Conflict Minerals Disclosure
A copy of our Conflict Minerals Report for the year ended December 31, 2018, filed as Exhibit 1.01 hereto, is publicly available on our Investor
Relations website, ir.nuskin.com. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
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Item 1.02
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Exhibit
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See Item 2.01.
Section 2 – Exhibits
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Item 2.01
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Exhibits
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Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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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.
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NU SKIN ENTERPRISES, INC.
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(Registrant)
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Date: May 29, 2019
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/s/ Mark H. Lawrence
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Mark H. Lawrence
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Chief Financial Officer
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EXHIBIT 1.01
NU SKIN ENTERPRISES, INC.
2018 CONFLICT MINERALS REPORT
May 29, 2019
We prepared this 2018 Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”), which was
promulgated in accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 to impose reporting, disclosure and other requirements on registrants that manufacture, or contract the manufacture of, products for which any of
the following minerals are necessary to their functionality or production: columbite-tantalite (coltan), cassiterite, wolframite or gold, or derivatives of these minerals, which include tantalum, tin and tungsten (collectively, the “3TG Minerals”).
If a registrant has reason to believe that any of the 3TG Minerals necessary to the functionality or production of its products may have
originated in certain “Covered Countries,” consisting of the Democratic Republic of the Congo and its adjoining countries, or if a registrant is unable to determine the country of origin of such 3TG Minerals, then the registrant must exercise due
diligence on the source and chain of custody of such 3TG Minerals.
Products
We develop and distribute innovative consumer products, offering a comprehensive line of premium-quality beauty and wellness solutions under our
two category brands: our beauty and personal care category brand known as Nu Skin® and our nutritional products category brand, Pharmanex®. We have also leveraged our scientific expertise in the area of anti-aging to develop our ageLOC® brand,
which features innovative products in both of these categories. We reviewed our products in each of our product categories to identify the products for which 3TG Minerals are necessary to their functionality or production (the “Covered Products”).
We determined that our Covered Products for 2018 consisted of our home-use skin care treatment devices, our Pharmanex BioPhotonic Scanner, a water purifier product that we sell in our Southeast Asia region, and certain cosmetics products that we
sell in South Korea. We contracted with six suppliers to manufacture these products in 2018.
Results of Supplier Inquiries
The six suppliers of our Covered Products were asked to complete and submit the Conflict Minerals Reporting Template (the “Reporting Template”)
developed by the Responsible Minerals Initiative (“RMI”). The Reporting Template is a standardized questionnaire that requests, among other things, information regarding the country of origin of the 3TG Minerals contained in the products and/or
components that are supplied to us and the suppliers in our supply chain. We received responses from all six suppliers. Four of the suppliers indicated that the 3TG Minerals that they use do not originate from any of the Covered Countries. The
other two suppliers indicated that they are unable to state that the 3TG Minerals they use do not originate from the Covered Countries.
Our suppliers source directly from smelters, refiners or other suppliers. As a result, our efforts to identify the origins of the 3TG Minerals
in our supply chain were based on the information we received from the suppliers. The suppliers’ information-gathering process, in turn, consists of their own efforts to retrieve information from their smelters, refiners or other suppliers. We must
rely on the suppliers to provide information regarding the origin of the 3TG Minerals that are included in the Covered Products. We recognize that this process may result in inaccurate or incomplete information.
1
Based on our efforts and those of our suppliers, we do not have conclusive information regarding the specific countries of origin of the 3TG
Minerals in our Covered Products for 2018. However, all six suppliers of our Covered Products provided a list of the smelters and refiners supplying 3TG Minerals to their respective supply chains. Based on our review of these smelters and refiners,
129 of the 133 unique smelters and refiners identified by our suppliers were conformant with RMI’s Responsible Minerals Assurance Process (“RMAP”) assessment standards. According to RMI’s website, the RMAP program identifies, through independent,
third-party audits, smelters and refiners that have systems in place to responsibly source minerals in line with current global standards.
A consolidated list of the smelters and refiners used by the six suppliers of our Covered Products is included in Exhibit A.
Due Diligence
We designed a program to exercise due diligence on the source and chain of custody of the 3TG Minerals that are necessary to the functionality
or production of our Covered Products. We designed our due diligence program based on the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the related Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (the “OECD Framework”).
In accordance with the OECD Framework, our due diligence measures include the following steps:
| 1. |
Establish strong company management systems.
|
| • |
We have adopted a Conflict Minerals Policy and have communicated it to the suppliers of our Covered Products. This policy states the following:
|
In response to violence and human rights violations related to the mining of certain minerals in the
Democratic Republic of the Congo (the “DRC”), Congress enacted Section 1502 of the Dodd‐Frank Wall Street Reform and Consumer Protection Act, which directed the U.S. Securities and Exchange Commission (the “SEC”) to adopt a rule requiring reporting
on “conflict minerals” (the “Conflict Minerals Rule”). Conflict minerals include gold, tantalum, tin, and tungsten, which are used in many electronic components and computer products. The Conflict Minerals Rule requires companies that are
required to file reports with the SEC to report annually on their products that may contain conflict minerals sourced from mines in the DRC or adjoining countries.
Nu Skin Enterprises, Inc. (the “Company”) supports the goal of ending violence and human rights
violations in the DRC and adjoining countries. The Company is committed to the responsible sourcing of conflict minerals throughout its supply chain and to continuing to comply with the Conflict Minerals Rule.
The Company does not directly source minerals from smelters or mines. Therefore, the Company relies on
the information provided by its raw material or product suppliers regarding their sourcing of minerals. The Company expects its suppliers to source minerals from socially responsible suppliers and to provide all necessary declarations to the
Company to support the Company’s compliance with the Conflict Minerals Rule. The Company expects suppliers to pass this requirement on to their supply chain to the extent necessary to determine the source of the specified minerals. The Company
may reconsider its relationship with suppliers that do not comply with this policy.
2
The Company is committed to ethical practices and compliance with applicable laws and regulations
wherever it does business. The Company will regularly survey its suppliers and will perform due diligence as appropriate to verify compliance with this policy.
| • |
We established a diligence team to oversee and support a supply-chain survey, perform due diligence and provide periodic updates to our management.
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| • |
We sought to enhance transparency with the suppliers of our Covered Products by asking the suppliers to complete the Reporting Template.
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| • |
We have established a grievance mechanism; our whistleblower hotline and online whistleblower intake form are available for employees to report behavior that
is illegal, unethical or otherwise in violation of our corporate policies, including our Conflict Minerals Policy.
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| • |
We have provided background information and training on the Rule to employees involved in our conflict minerals compliance efforts.
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| 2. |
Identify and assess risks in the supply chain.
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We take the following steps to identify and assess risks in our supply chain:
| • |
We obtain information from the suppliers of our Covered Products to seek to verify the country of origin of necessary 3TG Minerals in our supply chain by
asking the suppliers to complete the Reporting Template, which requests this information, and through additional communications with the suppliers regarding the Reporting Template and the Rule.
|
| • |
We also endeavor to identify the smelters and refiners in our supply chain. We do so by asking our suppliers to complete the Reporting Template, which
requests this information, and through additional communications with the suppliers as needed. We then consider whether the smelters and refiners are in conformance with RMI’s RMAP assessment standards.
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| • |
The Reporting Template also requests information about our suppliers’ due diligence measures; the due diligence measures of our suppliers’ upstream suppliers,
smelters and refiners; and the policies and standards our suppliers impose on such upstream suppliers, smelters and refiners.
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| • |
We review the information our suppliers provide in the Reporting Template and other communications, and we assess whether the responses raise any potential
risks.
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| 3. |
Design and implement a strategy to respond to identified risks.
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After identifying and assessing risks in our supply chain, we design and implement a strategy to respond to any identified risks. This strategy
includes the following:
| • |
We advise the appropriate members of management of our findings in the risk assessment. Depending on the severity of the risks, we may advise our senior
management of the findings.
|
| • |
As provided in our Conflict Minerals Policy, we also reconsider our relationship with suppliers that do not comply with the policy. We assess whether to (a)
continue doing business with such suppliers; (b) temporarily suspend doing business with such suppliers while pursuing ongoing measurable risk mitigation; or (c) disengage with such suppliers after failed attempts at mitigation or where
we deem risk mitigation not feasible or unacceptable. In making this assessment, we consider the amount of leverage we have over upstream suppliers, the feasibility of using a different supplier, and the supplier’s values and standards.
|
3
| 4. |
Carry out independent third-party audit of supply chain due diligence at
identified points in the supply chain.
|
We do not have direct relationships with the mines, smelters or refiners of any minerals, including 3TG Minerals, and we do not perform or
direct audits of these entities within our supply chain. However, we leverage the audit work conducted by third parties to comply with the OECD Framework to conduct independent third-party audits.
| 5. |
Report on supply chain due diligence.
|
We report on our efforts to understand the sourcing of the 3TG Minerals in our supply chain by annually filing a Form SD with the SEC. We also
provide a CMR, which describes our supply chain due diligence policies and practices, when required.
Risk Mitigation Efforts
To mitigate the risk that the 3TG Minerals that are necessary to the functionality or production of our products benefit armed groups, and to
improve our due diligence, we have taken or intend to take the following steps:
| • |
Communicate our Conflict Minerals Policy to the suppliers of our Covered Products; and
|
| • |
Coordinate with our suppliers to consider alternative component sources if a current source is unable to supply components that are free of 3TG Minerals that
benefit armed groups in the DRC or adjoining countries.
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4
Exhibit A
Smelters and Refiners Used by Suppliers of Covered Products
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Mineral
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Smelter/Refiner Name
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Smelter/Refiner
Location
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RMAP
Conformant(1)
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|
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Gold
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Advanced Chemical Company
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United States
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Yes
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Gold
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Aida Chemical Industries Co., Ltd.
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Japan
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Yes
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Gold
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Al Etihad Gold Refinery DMCC
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United Arab Emirates
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Yes
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Gold
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Allgemeine Gold-und Silberscheideanstalt A.G.
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Germany
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Yes
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Gold
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Almalyk Mining and Metallurgical Complex (AMMC)
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Uzbekistan
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Yes
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Gold
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Argor-Heraeus S.A.
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Switzerland
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Yes
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Gold
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Asahi Refining USA Inc.
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United States
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Yes
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Gold
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Asaka Riken Co., Ltd.
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Japan
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Yes
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Gold
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AU Traders and Refiners
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South Africa
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Yes
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|
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Gold
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|
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
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Philippines
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Yes
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Gold
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Dowa
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Japan
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Yes
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Gold
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Eco-System Recycling Co., Ltd.
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Japan
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Yes
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Gold
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Heraeus Metals Hong Kong Ltd.
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China
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Yes
|
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Gold
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Heraeus Precious Metals GmbH & Co. KG
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Germany
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Yes
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Gold
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Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
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China
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Yes
|
|
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Gold
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Ishifuku Metal Industry Co., Ltd.
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Japan
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Yes
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Gold
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Istanbul Gold Refinery
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Turkey
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Yes
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|
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Gold
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Japan Mint
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Japan
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Yes
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Gold
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Jiangxi Copper Co., Ltd.
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China
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Yes
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Gold
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JSC Uralelectromed
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Russian Federation
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Yes
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Gold
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JX Nippon Mining & Metals Co., Ltd.
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Japan
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Yes
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Gold
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Kojima Chemicals Co., Ltd.
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Japan
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Yes
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Gold
|
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Korea Zinc Co., Ltd.
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South Korea
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Yes
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Gold
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Kyrgyzaltyn JSC
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Kyrgyzstan
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Yes
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Gold
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LS-NIKKO Copper Inc.
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South Korea
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Yes
|
|
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Gold
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Metalor Technologies (Hong Kong) Ltd.
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China
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Yes
|
|
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Gold
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Metalor Technologies (Suzhou) Ltd.
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China
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Yes
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Gold
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Metalor Technologies S.A.
|
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Switzerland
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Yes
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Gold
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Metalor USA Refining Corporation
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United States
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Yes
|
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Gold
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Metalurgica Met-Mex Penoles S.A. De C.V.
|
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Mexico
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Yes
|
|
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Gold
|
|
Mitsubishi Materials Corporation
|
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Japan
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Yes
|
|
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Gold
|
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Mitsui Mining and Smelting Co., Ltd.
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Japan
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Yes
|
|
|
Gold
|
|
MMTC-PAMP India Pvt., Ltd.
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India
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Yes
|
|
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Gold
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Nadir Metal Rafineri San. Ve Tic. A.S.
|
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Turkey
|
Yes
|
|
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Gold
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OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)
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Russian Federation
|
Yes
|
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Gold
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OJSC Novosibirsk Refinery
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Russian Federation
|
Yes
|
5
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Mineral
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Smelter/Refiner Name
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Smelter/Refiner
Location
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RMAP
Conformant(1)
|
|
|
Gold
|
|
PAMP S.A.
|
|
Switzerland
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Yes
|
|
|
Gold
|
|
PT Aneka Tambang (Persero) Tbk
|
|
Indonesia
|
Yes
|
|
|
Gold
|
|
PX Precinox S.A.
|
|
Switzerland
|
Yes
|
|
|
Gold
|
|
Republic Metals Corporation
|
|
United States
|
No
|
|
|
Gold
|
|
Royal Canadian Mint
|
|
Canada
|
Yes
|
|
|
Gold
|
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
|
China
|
Yes
|
|
|
Gold
|
|
Solar Applied Materials Technology Corp.
|
|
Taiwan
|
Yes
|
|
|
Gold
|
|
Sumitomo Metal Mining Co., Ltd.
|
|
Japan
|
Yes
|
|
|
Gold
|
|
T.C.A S.p.A
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Italy
|
Yes
|
|
|
Gold
|
|
Tanaka Kikinzoku Kogyo K.K.
|
|
Japan
|
Yes
|
|
|
Gold
|
|
The Refinery of Shandong Gold Mining Co., Ltd.
|
|
China
|
Yes
|
|
|
Gold
|
|
Umicore S.A. Business Unit Precious Metals Refining
|
|
Belgium
|
Yes
|
|
|
Gold
|
|
United Precious Metal Refining, Inc.
|
|
United States
|
Yes
|
|
|
Gold
|
|
Western Australian Mint (T/a The Perth Mint)
|
|
Australia
|
Yes
|
|
|
Gold
|
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
|
China
|
Yes
|
|
|
Tantalum
|
|
Asaka Riken Co., Ltd.
|
|
Japan
|
Yes
|
|
|
Tantalum
|
|
Changsha South Tantalum Niobium Co., Ltd.
|
|
China
|
Yes
|
|
|
Tantalum
|
|
D Block Metals, LLC
|
|
United States
|
Yes
|
|
|
Tantalum
|
|
Exotech Inc.
|
|
United States
|
Yes
|
|
|
Tantalum
|
|
Global Advanced Metals Aizu
|
|
Japan
|
Yes
|
|
|
Tantalum
|
|
Global Advanced Metals Boyertown
|
|
United States
|
Yes
|
|
|
Tantalum
|
|
Guangdong Rising Rare Metals-EO Materials Ltd.
|
|
China
|
Yes
|
|
|
Tantalum
|
|
H.C. Starck Co., Ltd.
|
|
Thailand
|
Yes
|
|
|
Tantalum
|
|
H.C. Starck Hermsdorf GmbH
|
|
Germany
|
Yes
|
|
|
Tantalum
|
|
H.C. Starck Inc.
|
|
United States
|
Yes
|
|
|
Tantalum
|
|
H.C. Starck Ltd.
|
|
Japan
|
Yes
|
|
|
Tantalum
|
|
H.C. Starck Smelting GmbH & Co. KG
|
|
Germany
|
Yes
|
|
|
Tantalum
|
|
H.C. Starck Tantalum and Niobium GmbH
|
|
Germany
|
Yes
|
|
|
Tantalum
|
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
|
China
|
Yes
|
|
|
Tantalum
|
|
Jiujiang Janny New Material Co., Ltd.
|
|
China
|
Yes
|
|
|
Tantalum
|
|
LSM Brasil S.A.
|
|
Brazil
|
Yes
|
|
|
Tantalum
|
|
Metallurgical Products India Pvt., Ltd.
|
|
India
|
Yes
|
|
|
Tantalum
|
|
Mitsui Mining and Smelting Co., Ltd.
|
|
Japan
|
Yes
|
|
|
Tantalum
|
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
|
China
|
Yes
|
|
|
Tantalum
|
|
Solikamsk Magnesium Works OAO
|
|
Russian Federation
|
Yes
|
|
|
Tantalum
|
|
Taki Chemical Co., Ltd.
|
|
Japan
|
Yes
|
|
|
Tantalum
|
|
Ulba Metallurgical Plant JSC
|
|
Kazakhstan
|
Yes
|
|
|
Tin
|
|
Alpha
|
|
United States
|
Yes
|
|
|
Tin
|
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
|
|
China
|
Yes
|
6
|
|
Mineral
|
|
Smelter/Refiner Name
|
|
Smelter/Refiner
Location
|
RMAP
Conformant(1)
|
|
|
Tin
|
|
China Tin Group Co., Ltd.
|
|
China
|
Yes
|
|
|
Tin
|
|
CNMC (Guangxi) PGMA Co., Ltd.
|
|
China
|
No
|
|
|
Tin
|
|
CV Ayi Jaya
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
CV United Smelting
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
CV Venus Inti Perkasa
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
Dowa
|
|
Japan
|
Yes
|
|
|
Tin
|
|
EM Vinto
|
|
Bolivia
|
Yes
|
|
|
Tin
|
|
Fenix Metals
|
|
Poland
|
Yes
|
|
|
Tin
|
|
Gejiu Non-Ferrous Metal Processing Co., Ltd.
|
|
China
|
Yes
|
|
|
Tin
|
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
|
|
China
|
Yes
|
|
|
Tin
|
|
Malaysia Smelting Corporation (MSC)
|
|
Malaysia
|
Yes
|
|
|
Tin
|
|
Metallo Belgium N.V.
|
|
Belgium
|
Yes
|
|
|
Tin
|
|
Mineracao Taboca S.A.
|
|
Brazil
|
Yes
|
|
|
Tin
|
|
Minsur
|
|
Peru
|
Yes
|
|
|
Tin
|
|
Mitsubishi Materials Corporation
|
|
Japan
|
Yes
|
|
|
Tin
|
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
|
Thailand
|
Yes
|
|
|
Tin
|
|
O.M. Manufacturing Philippines, Inc.
|
|
Philippines
|
Yes
|
|
|
Tin
|
|
Operaciones Metalurgicas S.A.
|
|
Bolivia
|
Yes
|
|
|
Tin
|
|
PT Artha Cipta Langgeng
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Bangka Prima Tin
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Bangka Tin Industry
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Bukit Timah
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT DS Jaya Abadi
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Eunindo Usaha Mandiri
|
|
Indonesia
|
No
|
|
|
Tin
|
|
PT Menara Cipta Mulia
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Mitra Stania Prima
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Prima Timah Utama
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Rajehan Ariq
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Sariwiguna Binasentosa
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Stanindo Inti Perkasa
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Timah Tbk Kundur
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Timah Tbk Mentok
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
PT Tinindo Inter Nusa
|
|
Indonesia
|
Yes
|
|
|
Tin
|
|
Rui Da Hung
|
|
Taiwan
|
Yes
|
|
|
Tin
|
|
Thaisarco
|
|
Thailand
|
Yes
|
|
|
Tin
|
|
White Solder Metalurgia e Mineracao Ltda.
|
|
Brazil
|
Yes
|
|
|
Tin
|
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
|
China
|
Yes
|
|
|
Tin
|
|
Yunnan Tin Company Limited
|
|
China
|
Yes
|
|
|
Tungsten
|
|
A.L.M.T. Corp.
|
|
Japan
|
Yes
|
7
|
|
Mineral
|
|
Smelter/Refiner Name
|
|
Smelter/Refiner
Location
|
RMAP
Conformant(1)
|
|
|
Tungsten
|
|
ACL Metais Eireli
|
|
Brazil
|
Yes
|
|
|
Tungsten
|
|
Asia Tungsten Products Vietnam Ltd.
|
|
Vietnam
|
Yes
|
|
|
Tungsten
|
|
Chenzhou Diamond Tungsten Products Co., Ltd.
|
|
China
|
Yes
|
|
|
Tungsten
|
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
|
China
|
Yes
|
|
|
Tungsten
|
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
|
China
|
Yes
|
|
|
Tungsten
|
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
|
China
|
Yes
|
|
|
Tungsten
|
|
Global Tungsten & Powders Corp.
|
|
United States
|
Yes
|
|
|
Tungsten
|
|
H.C. Starck Smelting GmbH & Co. KG
|
|
Germany
|
Yes
|
|
|
Tungsten
|
|
H.C. Starck Tungsten GmbH
|
|
Germany
|
Yes
|
|
|
Tungsten
|
|
Hunan Chunchang Nonferrous Metals Co., Ltd.
|
|
China
|
Yes
|
|
|
Tungsten
|
|
Japan New Metals Co., Ltd.
|
|
Japan
|
Yes
|
|
|
Tungsten
|
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
|
China
|
Yes
|
|
|
Tungsten
|
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
|
China
|
Yes
|
|
|
Tungsten
|
|
Kennametal Huntsville
|
|
United States
|
Yes
|
|
|
Tungsten
|
|
Masan Tungsten Chemical LLC (MTC)
|
|
Vietnam
|
Yes
|
|
|
Tungsten
|
|
Philippine Chuangxin Industrial Co., Inc.
|
|
Philippines
|
Yes
|
|
|
Tungsten
|
|
Vietnam Youngsun Tungsten Industry Co., Ltd.
|
|
Vietnam
|
No
|
|
|
Tungsten
|
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
|
China
|
Yes
|
|
|
Tungsten
|
|
Xiamen Tungsten Co., Ltd.
|
|
China
|
Yes
|
| (1) |
The entries in this column indicate whether the smelter or refiner is conformant with RMAP assessment standards, based on a list of RMAP-conformant smelters
and refiners that was downloaded from RMI’s website on May 22, 2019.
|
8