EX-1.01 2 hd_exx101xsdx123114.htm CONFLICT MINERALS REPORT HD_EX_1.01_SD_12.31.14


Exhibit 1.01



Conflict Minerals Report of The Home Depot, Inc.
for the Calendar Year Ended December 31, 2014


This is the Conflict Minerals Report (“CMR”) of The Home Depot, Inc. for the reporting period from January 1 to December 31, 2014, in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”). When we refer to "The Home Depot," the "Company," "we," "us" or "our" in this report, we are referring to The Home Depot, Inc. and its consolidated subsidiaries.

Overview

We conducted a due diligence process based on the Organization for Economic Cooperation and Development’s (“OECD’s”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements1 (the “OECD Guidance”). Notwithstanding our due diligence process described herein, we are unable to determine the source of all gold, tantalum, tin and tungsten (“conflict minerals” or “3TG”) that are necessary to the functionality or production of products we contract to manufacture or whether these conflict minerals directly or indirectly financed or benefited armed groups in the Democratic Republic of the Congo and adjoining countries (the “Covered Countries”). The products that we contract to manufacture (the “Covered Products”) are: Kitchen, Indoor Garden, Paint, Outdoor Garden, Lumber, Flooring, Building Materials, Plumbing, Electrical, Tools, Hardware, Millwork, Bath, Lighting, and Décor.

Reasonable Country of Origin Inquiry

Introduction

We engaged a third-party service provider to assist us with data collection and aggregation. Together, we worked with our suppliers to collect information about the presence and sourcing of 3TG used in the Covered Products. Information regarding the presence of 3TG in a supplier’s products and the source of such 3TG, if present, was collected and stored using an online platform that utilized the Conflict Minerals Reporting Template (the “Template”) developed by the Conflict-Free Sourcing Initiative (“CFSI”), which was founded by the Electronics Industry Citizenship Coalition and Global e-Sustainability Initiative.

Products in Scope

We compiled a list of all Covered Products and worked with our third-party service provider to determine which Covered Products were in scope for potential use of 3TG and therefore required a Reasonable Country of Origin Inquiry (“RCOI”). If there was any doubt regarding the material content or the possible use of 3TG, the Covered Products were included in the RCOI process.

Supplier Engagement

We identified the suppliers with whom we contract directly (“Tier 1 Suppliers”) for the in-scope Covered Products and contacted them as a part of the RCOI process.

The RCOI began with an introduction email on October 1, 2014, from us to the Tier 1 Suppliers describing our Conflict Minerals Compliance Program (the “CMCP”) requirements. The Tier 1 Suppliers then were sent a follow-up email containing registration information and a request to complete the Template and were directed to a Conflict
______________________________
1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Supplement on Tin, Tantalum and Tungsten and Supplement on Gold, 2013; http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf.






Minerals Supplier Resource Center. The Conflict Minerals Supplier Resource Center provides an educational primer on the CMCP and includes frequently asked questions concerning 3TG mineral tracing.

Non-responsive Tier 1 Suppliers received several follow-up contacts to encourage completion of the Template. The Tier 1 Suppliers that remained non-responsive were contacted and offered assistance. This assistance included, but was not limited to, further information about the CMCP, an explanation of why the information was being collected, a review of how the information would be used, and clarification regarding how the required information could be provided. Tier 1 Suppliers who failed to respond to our earlier contacts received a re-invitation to the platform. They were also contacted by our managers who maintain direct relationships with these suppliers and were further urged to respond in a timely manner.

Due Diligence Program Design

Following completion of the RCOI, we proceeded to the due diligence process to determine the source of any 3TG in the Covered Products. Our due diligence process was based on OECD Guidance.

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. This framework consists of the following elements:

1.    Establish strong company management systems ("Step One");
2.    Identify and assess risk in the supply chain ("Step Two");
3.    Design and implement a strategy to respond to identified risks ("Step Three");
4.    Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain ("Step Four"); and
5.    Report on supply chain due diligence ("Step Five").

Due Diligence Program Execution

In furtherance of our Conflict Minerals due diligence for 2014, we performed the following measures.

OECD Guidance Step One: Establish strong company management systems

(a)
We maintained a policy relating to conflict minerals in our supply chain (“Conflict Minerals Policy”). Our Conflict Minerals Policy is publicly available at https://corporate.homedepot.com/CorporateResponsibility/Pages/Conflict-Minerals.aspx. It states:

The Home Depot Conflict Minerals Policy

The Home Depot is committed to ensuring compliance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to trade in conflict minerals.

The conflict minerals law was enacted to address the exploitation and trade of certain minerals that contribute to violence and human rights abuses in the Democratic Republic of the Congo and its neighboring countries in Africa (“Covered Countries”). The law requires public companies to report to the U.S. Securities and Exchange Commission and disclose information annually about whether the defined conflict minerals – gold, columbite-tantalite (tantalum), cassiterite (tin), and wolframite (tungsten) – are necessary to the functionality or production of products they manufacture or contract to manufacture, and, if so, whether those conflict minerals originate from conflict mines in the Covered Countries.

The Home Depot is committed to the responsible sourcing of materials for our products, and we expect that our suppliers are likewise committed to responsible sourcing. We expect all suppliers manufacturing our products to partner with us to provide appropriate information and conduct necessary due diligence in order to facilitate our compliance with the conflict minerals law. We further expect all suppliers manufacturing

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our products to adopt sourcing practices to obtain products and materials from suppliers not involved in funding conflict in the Covered Countries.

The Home Depot provides a Supplier AlertLine for the exclusive use of suppliers to report violations of company policies, including the Conflict Minerals Policy. Suppliers may contact the Supplier AlertLine at https://tnw.reportlineweb.com/custom/HDVendorRelations or by using the following toll-free numbers:
United States and Canada: 1-800-435-3152
Mexico: 001-888-765-8153
China: 10-800-711-0714 or 10-800-110-0654

(b)
We added the Conflict Minerals Policy to our Supplier Buying Agreement, the contract used with each of our Tier 1 Suppliers. As such, our Tier 1 Suppliers are obligated to comply with the policy.

OECD Guidance Step Two: Identify and assess risk in the supply chain

(a)
After completion of the RCOI, as described above, Tier 1 Suppliers who indicated that 3TG was necessary to the functionality or production of Covered Products supplied to us were asked to provide information through the Template regarding the sourcing and origin of the 3TG (i.e., the 3TG smelters or refiners, or “SORs”). Where a Tier 1 Supplier was unable to provide detailed information about the SORs in its supply chain, we contacted the applicable suppliers of the Tier 1 Suppliers (“Tier 2 Suppliers”), and subsequent tiers of suppliers as needed to obtain the necessary information, using the contact procedures explained above. Collectively, the Tier 1 Suppliers, Tier 2 Suppliers and any suppliers working backward from the Tier 2 Suppliers are referred to as “Suppliers”.

(b)
Based on information provided by the Suppliers, we used the following criteria to determine which Covered Products that contained 3TG necessary to the functionality or production of such product to include in the due diligence process:

a.
The Suppliers reported sourcing from the Covered Countries (“yes” response to Question 2 of the Template);
b.
The SOR data indicated sourcing from a mine located in the Covered Countries;
c.
The SOR reportedly sourced from a mine located in the Covered Countries (based on information contained within the third-party service provider’s system, from independent certification programs, or from internet research/available public reports);
d.
There was an indication that the SOR sourced from a Covered Country or a country that is known for smuggling or exporting 3TG out of a Covered Country (a “Level 2 country”); or
e.
Information provided about a SOR indicated the origin of the materials was not from a known reserve for the given metal.

(c)
We evaluated the responses we received from Suppliers for plausibility and consistency. Suppliers were contacted to address issues including implausible statements regarding no presence of 3TG; incomplete data on their Templates; responses that did not identify SORs; responses that indicated sourcing location without complete supporting information from the supply chain; and organizations that were identified as SORs, but not verified as such through further analysis and research.

(d)
When SOR data was obtained, we used the existing SOR database of the third-party service provider, the CFSI’s list of SORs, internet research, and other resources (e.g., government databases and industry and trade organization lists) to verify whether entities identified as SORs are actually 3TG SORs. Where we found that an entity named as a SOR was not directly involved in the smelting or recycling of the relevant metal, the Supplier that provided this information was contacted to attempt to obtain additional information about the origin of the materials or information about its direct suppliers. If contact information was provided, or could be obtained, for the entity listed as a SOR, the listed entity was also contacted to obtain additional information about the origin of materials used. We also investigated Supplier statements that a

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SOR did not source from the Covered Countries when the stated sourcing location (country of mine origin) was not a known reserve for the given metal.

OECD Guidance Step Three: Design and implement a strategy to respond to identified risks

(a)
We reported the findings of our supply chain risk assessment as outlined in this CMR to our General Counsel and supply chain senior leadership.

(b)
We took such risk mitigation efforts as we deemed to be appropriate based on the findings of our supply chain risk assessment. Our risk mitigation efforts with respect to our 2014 supply chain were determined by the particular facts and circumstances and risks identified.

(c)
To mitigate the risk that our necessary 3TG benefit armed groups, we intend to engage in the additional measures discussed under “Addressing Identified Risks” below.

OECD Guidance Step Four: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain

In connection with our due diligence, we utilized information made available by the CFSI, London Bullion Market Association, and Responsible Jewellery Council concerning independent third-party audits of smelters and refiners.

OECD Guidance Step 5: Report on supply chain due diligence

We filed a Form SD and this Conflict Minerals Report with the Securities and Exchange Commission and made available on our website this Conflict Minerals Report and the Form SD.

Summary of Findings

A total of 557 Tier 1 Suppliers were identified as in-scope for conflict mineral regulatory purposes and contacted as part of the RCOI process. The response rate among these Suppliers was 100%. 24% of the Suppliers indicated one or more of the conflict minerals as necessary to the functionality or production of the Covered Products.

Based on the information provided by our Tier 1 Suppliers and our own due diligence efforts with known smelters and refiners through December 31, 2014, we believe that the facilities that may have been used to process the conflict minerals in the Covered Products include the 294 verified SORs listed in Annex I. Based on review of certain SOR databases, there was an indication of DRC sourcing for 36 out of the 294 verified SORs. Of the 36 SORs with an indication of sourcing in the Covered Countries, 31 were certified as DRC Conflict Free by CFSI.

Notwithstanding the due diligence process described above, we do not have sufficient information from Tier 1 Suppliers or other sources to conclusively determine whether any 3TG originating in the Covered Countries was included in our Covered Products and, if so, whether the 3TG was from recycled or scrap sources, and whether or not these conflict minerals directly or indirectly financed or benefited armed groups in the Covered Countries. However, based on the information provided by our Tier 1 Suppliers and SORs, as well as from the CFSI and other sources, we believe that the countries of origin of the conflict minerals contained in our Covered Products include the countries listed in Annex II below, as well as recycled and scrap sources.

Addressing Identified Risks

In 2014, our efforts continued to be focused on collecting and disseminating information from our Tier 1 Suppliers on their sourcing practices using the Template and creating a database for that information.


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In the 2015 reporting year, we will continue our supplier engagement process with an aim to decrease the number of Covered Products with 3TG of indeterminate origin. We expect that our 2015 efforts will include:

Reviewing and updating the list of Covered Products and associated Tier 1 Suppliers designated as in-scope as needed;
Re-engaging each in-scope Tier 1 Supplier to verify and update sourcing information as needed; and
Continuing to work with Suppliers to gain information about supply chain actors closer upstream to the smelter or refiner to facilitate the exchange of information on the origin of 3TG.

We intend to undertake the following steps during the 2015 reporting year to further mitigate the risk that our Covered Products contain conflict minerals that benefit armed groups in the Covered Countries:

Continuing to engage with Tier 1 Suppliers to obtain current, accurate and complete information about the supply chain;
Encouraging Tier 1 Suppliers to implement responsible sourcing and to encourage their smelters and refiners to obtain a “conflict-free” certification from an independent, third-party auditor; and
Engaging in industry initiatives encouraging “conflict-free” supply chains.



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ANNEX I

Metal
Smelter or Refiner Name
Gold
Advanced Chemical Company
Gold
Aida Chemical Industries Co. Ltd.*
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Gold
AngloGold Ashanti Córrego do Sítio Minerção*
Gold
Argor-Heraeus SA*
Gold
Asahi Pretec Corporation*
Gold
Asaka Riken Co Ltd
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. *
Gold
Aurubis AG*
Gold
Baiyin Nonferrous Group Co., Ltd.
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold
Bauer Walser AG
Gold
Boliden AB*
Gold
C. Hafner GmbH + Co. KG*
Gold
CCR Refinery - Glencore Canada Corporation*
Gold
Caridad
Gold
Cendres + Métaux SA
Gold
Chimet S.p.A.*
Gold
China National Gold Group Corporation
Gold
China Nonferrous Metal Mining (Group) Co., Ltd.
Gold
Chugai Mining
Gold
Codelco
Gold
Colt Refining
Gold
Daejin Indus Co. Ltd
Gold
Daye Non-Ferrous Metals Mining Ltd.
Gold
Do Sung Corporation
Gold
Doduco
Gold/Tin
Dowa Mining Co., Ltd.*
Gold
Eco-System Recycling Co., Ltd.*
Gold
Eldorado Gold Corporation
Gold
FSE Novosibirsk Refinery
Gold
Faggi S.p.A.
Gold
Gansu Seemine Material Hi-Tech Co Ltd
Gold
Geib Refining Corp
Gold
Guangdong Jinding Gold Limited
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold
Heimerle + Meule GmbH*
Gold
Heraeus Ltd. Hong Kong*
Gold
Heraeus Precious Metals GmbH & Co. KG*
Gold/Tungsten
Hunan Chenzhou Mining Group Co., Ltd.
Gold
Hwasung CJ Co. Ltd
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited

6



Metal
Smelter or Refiner Name
Gold
Ishifuku Metal Industry Co., Ltd.*
Gold
Istanbul Gold Refinery*
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
Gold
JSC Uralelectromed*
Gold/Tin
JX Nippon Mining & Metals Co., Ltd.*
Gold
Japan Mint*
Gold
Jiangxi Copper Company Limited
Gold
Johnson Matthey Inc*
Gold
Johnson Matthey Ltd*
Gold
Kazakhmys plc
Gold
Kazzinc Inc.*
Gold
Kennecott Utah Copper LLC*
Gold
Kojima Chemicals Co., Ltd*
Gold
Korea Metal Co. Ltd
Gold
Kyrgyzaltyn JSC
Gold
L' azurde Company For Jewelry*
Gold
LS-NIKKO Copper Inc.*
Gold
Lingbao Gold Company Ltd.
Gold
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
Gold
Luoyang Zijin Yinhui Metal Smelt Co Ltd
Gold
Materion*
Gold
Matsuda Sangyo Co., Ltd.*
Gold
Met-Mex Peñoles, S.A.*
Gold
Metalor Technologies (Hong Kong) Ltd*
Gold
Metalor Technologies (Singapore) Pte. Ltd.*
Gold
Metalor Technologies SA*
Gold
Metalor USA Refining Corporation*
Gold/Tin
Mitsubishi Materials Corporation*
Gold/Tantalum
Mitsui Mining and Smelting Co., Ltd.*
Gold
Moscow Special Alloys Processing Plant
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.*
Gold
Navoi Mining and Metallurgical Combinat
Gold
Nihon Material Co. LTD*
Gold
OJSC Kolyma Refinery
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
Gold
Ohio Precious Metals, LLC*
Gold
Ohura Precious Metal Industry Co., Ltd*
Gold
PAMP SA*
Gold
PT Aneka Tambang (Persero) Tbk*
Gold
PX Précinox SA*
Gold
Penglai Penggang Gold Industry Co Ltd
Gold
Prioksky Plant of Non-Ferrous Metals
Gold
Rand Refinery (Pty) Ltd*
Gold
Royal Canadian Mint*
Gold
SAMWON METALS Corp.

7



Metal
Smelter or Refiner Name
Gold
SEMPSA Joyería Platería SA*
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Gold
Sabin Metal Corp.
Gold
Samduck Precious Metals
Gold
Schöne Edelmetaal B.V.*
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd*
Gold
Sichuan Tianze Precious Metals Co., Ltd*
Gold
So Accurate Group, Inc.
Gold
Solar Applied Materials Technology Corp.*
Gold/Tungsten
Sumitomo Metal Mining Co., Ltd.*
Gold
Super Dragon Technology Co., Ltd.
Gold
Tanaka Kikinzoku Kogyo K.K.*
Gold
The Great Wall Gold and Silver Refinery of China
Gold
The Refinery of Shandong Gold Mining Co. Ltd*
Gold
Tokuriki Honten Co., Ltd*
Gold
TongLing Nonferrous Metals Group Holdings Co., Ltd.
Gold
Torecom
Gold
Umicore Brasil Ltda*
Gold
Umicore Precious Metals Thailand*
Gold
Umicore SA Business Unit Precious Metals Refining*
Gold
United Precious Metal Refining, Inc.*
Gold
Valcambi SA*
Gold
Western Australian Mint trading as The Perth Mint*
Gold
Yamamoto Precious Metal Co., Ltd.
Gold
Yantai Guodasafina High-tech Environmental Refinery CO., Ltd.
Gold
Yokohama Metal Co Ltd
Gold
Yunnan Copper Industry Co Ltd
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
Gold
Zijin Mining Group Co. Ltd*
Tantalum
AMG Advanced Metallurgical Group
Tantalum
Changsha South Tantalum Niobium Co., Ltd.*
Tantalum
Conghua Tantalum and Niobium Smeltry*
Tantalum
D Block Metals, LLC*
Tantalum
Duoluoshan Sapphire Rare Metal Co., Ltd.*
Tantalum
Exotech Inc.*
Tantalum
F&X Electro-Materials Ltd.*
Tantalum
Global Advanced Metals Aizu*
Tantalum
Global Advanced Metals Boyertown*
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
Tantalum
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch*
Tantalum
H.C. Starck Co., Ltd.*
Tantalum
H.C. Starck GmbH Goslar*
Tantalum
H.C. Starck GmbH Laufenburg*
Tantalum
H.C. Starck Hermsdorf GmbH*
Tantalum
H.C. Starck Inc.*

8



Metal
Smelter or Refiner Name
Tantalum
H.C. Starck Ltd.*
Tantalum/Tungsten
H.C. Starck Smelting GmbH & Co.KG*
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.*
Tantalum
Hi-Temp Specialty Metals, Inc.*
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., LTD*
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Tantalum
Jiujiang Tanbre Co., Ltd.*
Tantalum
KEMET Blue Metals*
Tantalum
Kemet Blue Powder*
Tantalum
King-Tan Tantalum Industry Ltd*
Tantalum
LSM Brasil S.A.*
Tantalum
Metallurgical Products India (Pvt.) Ltd.*
Tantalum/Tin
Mineração Taboca S.A.*
Tantalum
Molycorp Silmet A.S.*
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.*
Tantalum
Plansee SE Liezen*
Tantalum
Plansee SE Reutte*
Tantalum
QuantumClean*
Tantalum
RFH Tantalum Smeltry Co., Ltd*
Tantalum
Shanghai Jiangxi Metals Co., Ltd.
Tantalum
Solikamsk Metal Works*
Tantalum
Taki Chemicals*
Tantalum
Telex*
Tantalum
Ulba*
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd*
Tantalum
Zhuzhou Cement Carbide*
Tin
Alpha*
Tin
CNMC (Guangxi) PGMA Co. Ltd.
Tin
CV Duta Putra Bangka*
Tin
CV Gita Pesona
Tin
CV Makmur Jaya
Tin
CV Nurjanah
Tin
CV Serumpun Sebalai
Tin
CV United Smelting
Tin
China Rare Metal Materials Company*
Tin
China Tin Group Co., Ltd.
Tin
Cooper Santa
Tin
Empresa Metallurgica Vinto*
Tin
Estanho de Rondônia S.A.
Tin
Feinhutte Halsbrucke GmbH
Tin
Fenix Metals
Tin
Foshan Nanhai Tong Ding Metal Company. Ltd.
Tin
Gejiu Kai Meng Industry and Trade LLC
Tin
Gejiu Non-Ferrous Metal Processing Co. Ltd.*
Tin
Gejiu Zi-Li

9



Metal
Smelter or Refiner Name
Tin
Huichang Jinshunda Tin Co. Ltd
Tin
Jean Goldschmidt International SA
Tin
Jiangxi Nanshan
Tin
Kai Unita Trade Limited Liability Company
Tin
Kovohutì Pøíbram
Tin
Linwu Xianggui Smelter Co
Tin
Magnu's Minerais Metais e Ligas LTDA*
Tin
Malaysia Smelting Corporation (MSC)*
Tin
Materials Eco-Refining CO., LTD
Tin
Melt Metais e Ligas S/A*
Tin
Metallo Chimique*
Tin
Minsur*
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin
Novosibirsk Integrated Tin Works
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Tin
O.M. Manufacturing Philippines, Inc.
Tin
Operaciones Metalurgical S.A.*
Tin
POSCO
Tin
PT ATD Makmur Mandiri Jaya*
Tin
PT Alam Lestari Kencana
Tin
PT Artha Cipta Langgeng
Tin
PT Babel Inti Perkasa*
Tin
PT Babel Surya Alam Lestari
Tin
PT Bangka Kudai Tin
Tin
PT Bangka Putra Karya*
Tin
PT Bangka Timah Utama Sejahtera
Tin
PT Bangka Tin Industry*
Tin
PT Belitung Industri Sejahtera*
Tin
PT BilliTin Makmur Lestari
Tin
PT Bukit Timah*
Tin
PT DS Jaya Abadi*
Tin
PT Donna Kembara Jaya
Tin
PT Eunindo Usaha Mandiri*
Tin
PT Fang Di MulTindo
Tin
PT HANJAYA PERKASA METALS
Tin
PT HP Metals Indonesia
Tin
PT Inti Stania Prima
Tin
PT Justindo
Tin
PT Karimun Mining
Tin
PT Koba Tin
Tin
PT Mitra Stania Prima*
Tin
PT Panca Mega Persada*
Tin
PT Pelat Timah Nusantara Tbk
Tin
PT Prima Timah Utama*
Tin
PT Refined Banka Tin*

10



Metal
Smelter or Refiner Name
Tin
PT Sariwiguna Binasentosa*
Tin
PT Seirama Tin investment
Tin
PT Stanindo Inti Perkasa*
Tin
PT Sumber Jaya Indah
Tin
PT Supra Sukses Trinusa
Tin
PT Tambang Timah*
Tin
PT Timah (Persero), Tbk*
Tin
PT Tinindo Inter Nusa*
Tin
PT Tommy Utama
Tin
PT WAHANA PERKIT JAYA*
Tin
PT Yinchendo Mining Industry
Tin
Poongsan Corporation
Tin
RUI DA HUNG
Tin
Senju Metal Industry Co., Ltd.
Tin
Shangrao Xuri Smelting Factory
Tin
Soft Metais, Ltda.
Tin
Thaisarco*
Tin
VQB Mineral and Trading Group JSC
Tin
White Solder Metalurgia e Mineração Ltda.*
Tin
Xianghualing Tin Co., Ltd.
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin
Yunnan Tin Company Limited*
Tungsten
A.L.M.T. Corp.
Tungsten
Beijing Tian-Long Tungsten & Molybdenum Co., Ltd.
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten
Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
Ganxian Shirui New Material Co., Ltd.
Tungsten
Ganzhou Haichuang Tungsten Industry Co., Ltd.
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.*
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.*
Tungsten
Global Tungsten & Powders Corp.*
Tungsten
Golden Egret Special Alloy Co. Ltd
Tungsten
Guangdong Xianglu Tungsten Industry Co., Ltd.
Tungsten
H.C. Starck GmbH
Tungsten
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.*
Tungsten
Japan New Metals Co., Ltd.*
Tungsten
Jiangsu Hetian Technological Material Co., Ltd
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.*
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten
Jiangxi Rare Earth & Rare Metals Tungsten Group Corp

11



Metal
Smelter or Refiner Name
Tungsten
Jiangxi Richsea New Materials Co., Ltd.
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten
Jiangxi Tungsten Industry Group Co Ltd
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten
Kennametal Fallon
Tungsten
Kennametal Huntsville
Tungsten
Malipo Haiyu Tungsten Co., Ltd.*
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.*
Tungsten
Voss Metals Company, Inc.
Tungsten
Wolfram Bergbau und Hütten AG*
Tungsten
Wolfram Company CJSC
Tungsten
Xiamen Honglu Tungsten Molybdenum Industry Co.Ltd
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
Tungsten
Xiamen Tungsten Co., Ltd.*
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.

*Smelter or refiner certified by the Conflict-Free Sourcing Initiative
Smelter or refiner certified by the London Bullion Market Association



12



ANNEX II
Countries of Origin

Angola
Morocco
Argentina
Mozambique
Armenia
Myanmar
Australia
Namibia
Austria
Netherlands
Belarus
Niger
Belgium
Nigeria
Bermuda
Papua New Guinea
Bolivia
Peru
Brazil
Philippines
Burundi
Poland
Canada
Portugal
Chile
Romania
China
Russia
Democratic Republic of the Congo
Rwanda
Estonia
Saudi Arabia
Ethiopia
Sierra Leone
France
Singapore
Germany
South Africa
Ghana
South Korea
Greece
Spain
Guinea
Suriname
Guyana
Sweden
Hong Kong
Switzerland
India
Taiwan
Indonesia
Tajikistan
Italy
Tanzania
Japan
Thailand
Jersey
Turkey
Kazakhstan
United Arab Emirates
Kyrgyzstan
United Kingdom
Laos
United States
Malaysia
Uzbekistan
Mali
Vietnam
Mexico
Zambia
Mongolia
Zimbabwe




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