EX-1.01 2 exhibit_1-01.htm EXHIBIT 1.01

 
Exhibit 1.01

Radware Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2015

This Conflict Minerals Report for the year ended December 31, 2015 (this "Report") has been prepared by Radware Ltd. (“Radware,” the “Company” or “we”) pursuant to Rule 13p-1(the "Rule" or "Rule 13p-1") promulgated under the Securities Exchange Act of 1934, as amended, and Form SD thereunder.

The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten (“conflict minerals” or “3TG”).

In general, if an SEC registrant, like Radware, has reason to believe that any of the conflict minerals in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”), or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody, and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.

This Report relates to the process undertaken for Radware products that were manufactured or contracted to be manufactured, during calendar year 2015 and that may contain 3TG minerals.

A copy of this Report as well as the Form SD that we filed with the SEC is available on our website at https://www.radware.com/corporategovernance/conflictminerals/.

Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in the Rule and Form SD as well as SEC Release No. 34-67716 issued by the SEC on August 22, 2012.

Except as set forth otherwise in this Report, Radware has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with Radware’s Conflict Minerals Policy, may affect Radware’s future determinations under Rule 13p-1.

1.  Overview

Company Overview
 
We are a leading provider of cyber security and application delivery solutions designed to ensure optimal service level for applications in virtual, cloud and software defined data centers. We offer a set of products and solutions that address data center application service level challenges and are designed to solve key challenges with applications’ availability, applications’ response time and data center availability. Our solutions provide application layer service on top of the enterprise or carrier network front ending the applications and, in general, address three primary target markets and challenges: the Distributed Denial of Service (DDoS) protection market; the Application Delivery Controllers (ADCs) market; and the Web application firewall (WAF) market. We sell our products primarily to independent distributors, including value added resellers (VARs), original equipment manufacturers (OEMs) and system integrators, with most of our direct sales being to strategic customers.
 
For more information about Radware, please visit www.radware.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein.



Supply Chain

We conducted an analysis of our products and found that small quantities of 3TG could potentially be found in our products.

The products that we manufacture are highly complex, typically containing thousands of parts from many direct suppliers. In general, we primarily rely on third-party assembly and manufacturing vendors to provide our finished products and, in this respect, these vendors typically receive components and subassemblies included in our products from other suppliers and subcontractors.

We have relationships with a vast network of suppliers throughout the world and there are generally multiple tiers between the 3TG mines and our direct suppliers. Therefore, we must rely on our direct suppliers to cooperate with us and work with their own upstream suppliers or sub-contractors in order that they may provide us with accurate information about the origin of 3TG in the components we purchase from them. In particular, many of our supplier contracts have fixed durations and we cannot unilaterally impose new contract terms or flow-down requirements that would otherwise compel these suppliers to support our due diligence efforts with respect to 3TG content.

Efforts to Determine Mine or Location of Origin
 
We have determined that requesting our suppliers to complete the CMRT (as defined below) as well as following the steps described under Section 2 below (Due Diligence Process), represent our reasonable efforts to determine the mines or locations of origin of 3TG in our supply chain.
 
We developed a risk-based approach (pareto analysis) that focuses on all suppliers involved in the manufacture of the majority of our finished products that were shipped in 2015. We identified in total 193 relevant suppliers (the “Relevant Suppliers”) and engaged a third party data collection and software vendor (the "Third Party Vendor") to monitor the due diligence process and the gathering of information from all such Relevant Suppliers.
 
We sent letters to our Relevant Suppliers to explain the Rule and to refer them to online training materials and instructions. We also solicited information from our Relevant Suppliers using the most up to date Conflict Minerals Reporting Template (“CMRT”), an industry-standard template for conflict mineral reporting developed by the Conflict-Free Sourcing Initiative (the "CFSI").
 
We reviewed the responses that we received and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information.
 
Based on these efforts, we already know that some of our products may contain conflict minerals that originated in Covered Countries and are not from recycled or scrap sources. Therefore, according to the Rule, we have engaged in the Due Diligence Process described in detail in Section 2 below.
 
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2.
Due Diligence Process

2.1
Design of Due Diligence

Our due diligence measures have been designed to conform, in all material respects, with the due diligence framework presented by The Organisation for Economic Co-operation and Development (OECD) in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing (OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten.

2.2
Due Diligence Performed

2.2.1
Establish Strong Management Systems

Corporate Policy

We have adopted a conflict minerals policy (our "Policy" or our "Conflict Minerals Policy") which is publicly available on our website at https://www.radware.com/corporategovernance/conflictminerals/.

Internal Team

We have established a management system to support supply chain due diligence related to 3TG. Our management system includes an executive steering committee headed by the Company’s VP Finance, and a team of subject matter experts from functions such as supplier management, engineering, finance and legal.

Control systems

We adopted, and communicated to our suppliers and to the public through our website and direct letters, our Policy for the supply chain of minerals originating from conflict affected and high-risk areas.

During 2015, we reviewed our internal and external communication plan from 2014 and updated it as we deemed required.

Controls include a company-wide code of conduct that outlines expected behaviors for all our employees and as we enter into new supply contracts or renew existing supply contracts, we are adding (where feasible) a conflict minerals contract clause that requires suppliers to provide us with information about the source of 3TG and smelters.

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Grievance Mechanism

Our Conflict Minerals Policy is available to the public on our website and provides the contact details for reporting concerns or questions regarding the Policy or violations thereof, and suppliers and other external parties are encouraged to contact their regular sourcing channel if they wish to seek guidance on the application of this approach, or if they wish to report a suspected abuse.

Maintain records

We maintain data records relating to our due diligence efforts in the Third Party Vendor’s Conflict Minerals Reporting Dashboard Software (“CMR Dashboard”) for the duration recommended by the OECD Guidance. The CMR Dashboard stores current and former CMRT’s from suppliers to maintain traceability.

Supplier Engagement

We requested that all Relevant Suppliers provide information to us regarding 3TG and smelters using the CMRT.

We maintain an electronic portal which directs suppliers to resources related to Conflict Minerals, including FAQs from the SEC.

We established a Conflict Minerals webpage to host our CMRT, our Conflict Minerals Policy and our conflict minerals reports along with their related Form SDs.

We have also engaged the Third Party Vendor to provide training and outreach to suppliers, as well as to conduct, collect, validate and archive supplier responses.

2.2.2
Identify and assess risk in the supply chain

We reviewed and analyzed the respective CMRT’s of our Relevant Suppliers and compared the information provided therein with the Compliant Smelter List of the Conflict Free Smelter Program, a list issued by the CFSI which aims to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. We rely on these Relevant Suppliers, whose components contain 3TG, to provide us with information about the source of conflict minerals contained in the components supplied to us. Our Relevant Suppliers are similarly reliant upon information provided by their suppliers.

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We identified and assessed two primary risks in our supply chain relating to our suppliers:
 
· The risk of not receiving on time accurate information from the suppliers with respect to their sourcing of Conflict Minerals.

· The risk of not being able to replace a supplier, should we determine that there exists a risk of the supplier sourcing Conflict Minerals from sources that contribute to human rights abuses.

The result of such risk assessment was the segmentation of our Relevant Suppliers into 3 levels of risks: high, medium and low to assist us with our risk mitigation efforts described in Section 2.2.3 below.

2.2.3
Design and Implement a Strategy to Respond to Risks

We implemented the following strategy. In so doing we focused our efforts based on the results of our risk assessment described in Section 2.2.2 above:

· We reviewed the responses that we received and followed up on what we perceived to be inconsistent, incomplete, or inaccurate responses, as well as sent reminders to Relevant Suppliers who did not respond to our requests for information.
· We sent follow up letters to non-responding Relevant Suppliers and to Relevant Suppliers who declared they are sourcing conflict minerals from Covered Countries, asking them to complete their due diligence process in order to validate that all smelters in Covered Countries are compliant with the CFSI or other independent conflict free smelter validation program.
· Relevant senior management is briefed about our due diligence efforts, risk analysis results and mitigation efforts on a regular basis.

2.2.4
Carry out Independent Third Party Audit of Smelters/Refiners Due Diligence Practices

We rely on industry-wide initiatives, such as the CFSI, to conduct risk assessment at the upstream level.

Since we do not have direct sourcing relationships with conflict mineral smelters or refiners, we did not perform direct audits of these entities within our supply chain.

2.2.5
Report on supply chain due diligence

This Conflict Minerals Report is available on our website https://www.radware.com/corporategovernance/conflictminerals/ and is filed with the SEC.

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3.
Results of Assessment

Based on information provided by our Relevant Suppliers as well as by CFSI, the results of our due diligence investigation as of the date of this Report are as follows:

· We were successful in approaching almost all Relevant Suppliers.

· Out of the 193 Relevant Suppliers, 143 Relevant Suppliers (74.1%) completed and returned the CMRT’s to us. Based on the CMRT’s we received from these Relevant Suppliers (the "Responsive Relevant Suppliers"):
 
· Approximately 84.60% of the responses received provided data at a company or divisional level. All of the remaining Responsive Relevant Suppliers declared that information was provided at a product level, as shown in the following table:
 
Category
Percentage of Responsive Relevant Suppliers
Company level
69.2% (99 from 143 suppliers)
User defined
15.4% (22 from 143 suppliers)
Product list
15.4% (22 from 143 suppliers)
 
· Most of our Responsive Relevant Suppliers were classified as "DD in Process from DRC" (see comment  (e) below, based on an analysis of the returned CMRT’s, as shown in the following table:
 
Category
Percentage of Responsive Relevant Suppliers
Suppliers which were classified as “Not from DRC” (a)
11.2% (16 from 143 suppliers)
Suppliers which were classified as “DRC CFSP Compliant” (b)
16.8% (24 from 143 suppliers)
Suppliers which were classified as “Free no 3TG” (c)
5.6% (8 from 143 suppliers)
Suppliers which were classified as “DD in Process not from DRC” (d)
11.2% (16 from 143 suppliers)
Suppliers which were classified as “DD in Process from DRC” (e)
55.2% (79 from 143 suppliers)
 
(a) Generally means that these suppliers were sourcing minerals from countries other than the Covered Countries.
(b) Generally means that  the 3TG minerals being used in the products provided originate from Covered Countries but the smelters are approved by the CFSI Conflict Free Smelter Program
(c) Generally means that 3TG minerals are not necessary for the functionality or production of the products provided by these Responsive Relevant Suppliers.
(d) Generally means that, as of the date of this Report, the 3TG being used in the products supplied to Radware by these manufacturers do not originate from Covered Countries but such Responsive Relevant Suppliers have not yet concluded their due diligence process so this determination can potentially change.
(e) Generally means that, as of the date of this Report, such Responsive Relevant Suppliers discovered that 3TG they use in the products they provide Radware originate from Covered Countries and the smelters are approved by the CFSI program, but such Responsive Relevant Suppliers have not yet concluded their due diligence process so this determination can potentially change.

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· At least 45.50% of our Responsive Relevant Suppliers are also SEC registrants and are generally subject to the Rule themselves.

· Approximately 76.80% of our Responsive Relevant Suppliers stated to us that they implemented due diligence measures consistent with the OECD Guidance.
 
· Approximately 90.2% of our Responsive Relevant Suppliers stated to us that they have a policy in place that addresses conflict minerals sourcing.

Based on the information provided by the Responsive Relevant Suppliers as well as by CFSI, as of the date of this Report, Radware believes that the facilities that may have been used to process the conflict minerals in Radware’s products may include the smelters and refiners listed in Annex I below.

Based on the information provided by the Responsive Relevant Suppliers as well as by CFSI, as of the date of this Report, Radware believes that the mine countries of origin of the conflict minerals contained in its products may include the countries listed in Annex II below.

The information gathered from our Responsive Relevant Suppliers is not on a continuous, real-time basis.

In addition, Radware can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals, since the information comes primarily from direct and secondary suppliers as well as from independent third party audit programs.

Lastly, given that most of our Responsive Relevant Suppliers were unable to provide information at product level, Radware cannot clearly identify the source of origin of the 3TG included in its products.

4.
Steps to be taken to mitigate risk

We intend taking the following steps to improve the due diligence conducted to further mitigate the risk that the 3TG in our products finance or benefit armed groups in the Covered Countries:

· Continue implementing follow up processes with regard to high-risk, non-responsive or non-compliant suppliers.
· As described in our Conflict Minerals Policy, to the extent we will have reason to believe that any of our suppliers who are supplying us with 3TG, receive such minerals from sources that may support conflict in the DRC or any adjoining country, we would encourage such suppliers to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD Guidance.
· Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts.
· Continue to direct our suppliers through our website and direct communications to information and training resources to attempt to increase the response rate and improve the content of the supplier survey responses.
· Request suppliers to procure materials through validated smelters and take mitigating actions in case they do not.
· Continue to validate supplier responses using information collected via independent conflict free smelter validation programs, such as the CFSI.
· Continue to engage in regular ongoing risk assessment through our suppliers’ annual data submissions.
· Respond to risks based on the level of risk of the Relevant Supplier according to the segmentation we performed in the step described in Section 2.2.2 above.

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Annex I – List of Smelters
 
Metal
Smelter Name
Smelter Country
Gold
Advanced Chemical Company
UNITED STATES
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Aktyubinsk Copper Company TOO
KAZAKHSTAN
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
Argor-Heraeus SA
SWITZERLAND
Gold
Asahi Pretec Corporation
JAPAN
Gold
Asahi Refining Canada Limited
CANADA
Gold
Asahi Refining USA Inc.
UNITED STATES
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
Aurubis AG
GERMANY
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Boliden AB
SWEDEN
Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
Caridad
MEXICO
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Cendres + Métaux SA
SWITZERLAND
Gold
Chimet S.p.A.
ITALY
Gold
Chugai Mining
JAPAN
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
DODUCO GmbH
GERMANY
Gold
Dowa
JAPAN
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Elemetal Refining, LLC
UNITED STATES
 
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Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Faggi Enrico S.p.A.
ITALY
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Gold
Geib Refining Corporation
UNITED STATES
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Gold
Guangdong Jinding Gold Limited
CHINA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Ltd. Hong Kong
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Company Limited
CHINA
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES
Gold
KGHM Polska Miedź Spółka Akcyjna
POLAND
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Korea Metal Co., Ltd.
KOREA, REPUBLIC OF
Gold
Korea Zinc Co. Ltd.
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
L' azurde Company For Jewelry
SAUDI ARABIA
Gold
Lingbao Gold Company Limited
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
Materion
UNITED STATES
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
 
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Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalor Technologies SA
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES
Gold
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
Morris and Watson
NEW ZEALAND
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
PAMP SA
SWITZERLAND
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Précinox SA
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Republic Metals Corporation
UNITED STATES
Gold
Royal Canadian Mint
CANADA
Gold
Sabin Metal Corp.
UNITED STATES
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Gold
SEMPSA Joyería Platería SA
SPAIN
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway Technology Co., Ltd.
TAIWAN
Gold
So Accurate Group, Inc.
UNITED STATES
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
 
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Gold
T.C.A S.p.A
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.
BRAZIL
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Umicore SA Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Gold
Valcambi SA
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Tantalum
D Block Metals, LLC
UNITED STATES
Tantalum
Duoluoshan
CHINA
Tantalum
Exotech Inc.
UNITED STATES
Tantalum
F&X Electro-Materials Ltd.
CHINA
Tantalum
FIR Metals & Resource Ltd.
CHINA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck GmbH Goslar
GERMANY
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES
Tantalum
H.C. Starck Ltd.
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
KEMET Blue Powder
UNITED STATES
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Tantalum
LSM Brasil S.A.
BRAZIL
 
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Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineração Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining & Smelting
JAPAN
Tantalum
Molycorp Silmet A.S.
ESTONIA
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
Plansee SE Liezen
AUSTRIA
Tantalum
Plansee SE Reutte
AUSTRIA
Tantalum
QuantumClean
UNITED STATES
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
Taki Chemicals
JAPAN
Tantalum
Telex Metals
UNITED STATES
Tantalum
Tranzact, Inc.
UNITED STATES
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Tantalum
Zhuzhou Cemented Carbide
CHINA
Tin
Alpha
UNITED STATES
Tin
An Thai Minerals Company Limited
VIET NAM
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
Chenzhou Yunxiang Mining and Metallurgy Company Limited
CHINA
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Dua Sekawan
INDONESIA
Tin
CV Gita Pesona
INDONESIA
Tin
PT Justindo
INDONESIA
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
CV Serumpun Sebalai
INDONESIA
Tin
CV United Smelting
INDONESIA
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Dowa
JAPAN
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Tin
Elmet S.L.U. (Metallo Group)
SPAIN
Tin
EM Vinto
BOLIVIA
Tin
Estanho de Rondônia S.A.
BRAZIL
Tin
Feinhütte Halsbrücke GmbH
GERMANY
Tin
Fenix Metals
POLAND
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
12

 
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
Linwu Xianggui Ore Smelting Co., Ltd.
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Melt Metais e Ligas S/A
BRAZIL
Tin
Metallic Resources, Inc.
UNITED STATES
Tin
Metallo-Chimique N.V.
BELGIUM
Tin
Mineração Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Tin
Phoenix Metal Ltd.
RWANDA
Tin
PT Alam Lestari Kencana
INDONESIA
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
PT Babel Inti Perkasa
INDONESIA
Tin
PT Bangka Kudai Tin
INDONESIA
Tin
PT Bangka Prima Tin
INDONESIA
Tin
PT Bangka Timah Utama Sejahtera
INDONESIA
Tin
PT Bangka Tin Industry
INDONESIA
Tin
PT Belitung Industri Sejahtera
INDONESIA
Tin
PT BilliTin Makmur Lestari
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT Cipta Persada Mulia
INDONESIA
Tin
PT DS Jaya Abadi
INDONESIA
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Tin
PT Fang Di MulTindo
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA
Tin
PT Karimun Mining
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Pelat Timah Nusantara Tbk
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Refined Bangka Tin
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Seirama Tin Investment
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
PT Sumber Jaya Indah
INDONESIA
 
13

Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
PT Tirus Putra Mandiri
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
PT Wahana Perkit Jaya
INDONESIA
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN
Tin
Soft Metais Ltda.
BRAZIL
Tin
Thaisarco
THAILAND
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
VQB Mineral and Trading Group JSC
VIET NAM
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Tin Group (Holding) Company Limited
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Dayu Jincheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Ganxian Shirui New Material Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck GmbH
GERMANY
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
 
14

Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
Kennametal Fallon
UNITED STATES
Tungsten
Kennametal Huntsville
UNITED STATES
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Niagara Refining LLC
UNITED STATES
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Tungsten
Pobedit, JSC
RUSSIAN FEDERATION
Tungsten
Sanher Tungsten Vietnam Co., Ltd.
VIET NAM
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Gold
OJSC Kolyma Refinery
RUSSIAN FEDERATION

15

Annex II – List of Mine Countries of Origin
 
Gold
Tantalum
Tin
Tungsten
Australia
Australia
Bangka Island
China
Belgium
Brazil
Bolivia
 
Canada
Canada
Brazil
 
Chile
China
China
 
China
Ethiopia
Indonesia
 
Germany
Japan
Malaysia
 
Hong Kong
Mozambique
Peru
 
Japan
Russia
USA
 
Korea, Republic of
Rwanda
   
Mexico
USA
   
South Africa
Zimbabwe
   
Switzerland
     
Taiwan
     
 
16