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, 2022

This Conflict Minerals Report for the year ended December 31, 2022 (this "Report") has been prepared by Radware Ltd. (“Radware,” the “Company”, “our” 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, tungsten and Gold (“conflict minerals” or “3TG”).

In general, if a 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”) and that such conflict minerals may not originate entirely from recycled or scrap sources, 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 as well as measures to address and analyze risks in its supply chain.

This Report relates to the process undertaken for Radware's products that were manufactured or contracted to be manufactured during the calendar year 2022 and that may contain 3TG minerals that are necessary to the functionality or production of such products manufactured or to the products contracted to be manufactured.

A copy of this Report, as well as the Form SD that we filed with the SEC, are 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 to comply with Radware’s Conflict Minerals Policy or Radware’s other relevant policies for suppliers and contractors, such as our Supplier Code of Conduct, may affect Radware’s future determinations under Rule 13p-1.

As part of Radware's Labor Practice and Human Rights Policy, Radware respects the protection of human rights, including the basic human rights of employees and workers, and supports and recognizes relevant international frameworks and agreements, such as the United Nations’ Declaration of Human Rights and the International Labor Organization’s Declaration of Fundamental Principles. The Company aims to uphold the human rights of those affected by its business activities, and in particular, of the workers engaged in its supply chain. Accordingly, the Company aspires to source components and materials from suppliers that share our values regarding respect for human rights, integrity and environmental responsibility, and that comply with applicable legal standards and requirements. To that end, the Company upholds a Code of Conduct for Suppliers that addresses issues associated with mineral sourcing and/or conflict minerals. By upholding standards for its suppliers, Radware expresses its commitment to using minerals in its products that do not directly or indirectly finance armed conflict in the DRC or one of the other Covered Countries, or that benefit, directly or indirectly, armed groups in those countries.


1.                Overview

Company Overview
 
We are a provider of cyber security and application delivery solutions for  cloud, on-premise  and software defined data centers (SDDC). Our solutions secure the digital experience by providing infrastructure, application, and network protection and availability services to enterprises globally. Our solutions are deployed by, among others, enterprises, carriers and cloud service providers. Our solutions are offered in two main categories: products and customer services. Our product offering includes a range of physical, software-based products, product subscriptions and cloud-based subscriptions (or a combination of these) for enterprise and carrier data centers, as part of their IT and application infrastructure. Our customer services offering includes technical support, professional services, managed services and training and certification to our customers. We sell through sales channels such as resellers and distributors whereas most of our direct sales are 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.

Responsible Sourcing Efforts in Our Supply Chain

We conducted an analysis of our products and found that small quantities of 3TG could potentially be found in our products that were manufactured or contracted to be manufactured in 2022, and that the 3TG is or could be necessary to the functionality or production of our products.

The products that we manufacture are highly complex, typically containing thousands of parts that are sourced from direct suppliers. In general, as a downstream company (as further explained under Section 2.1 below), 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 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 so that they may provide us with accurate information regarding the origin, or likely origin, of 3TG in the components we purchase from them and that is necessary to the production or functionality of our products. 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. However, as we enter into supplier contracts or renew existing supplier contracts, we seek to add, where feasible, a conflict minerals contract clause that requires relevant suppliers to provide us with information on the likely source and chain of custody of 3TG and relevant smelters or refiners. In attempting to determine the source of the 3TG content in our products, i.e., through our supply chain due diligence, we do not seek to eliminate sourcing from the DRC or other Covered Countries, but rather to ensure that our suppliers responsibly source the necessary minerals in a fashion that does not directly or indirectly fund or support the armed conflict ongoing in that region.

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Reasonable Country of Origin Inquiry (RCOI)
 
We have determined that requesting our direct suppliers to complete the standard Conflict Minerals Reporting Template (“CMRT”) 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 the suppliers that represented as of December 31, 2022, in aggregate, at least 90% of our spend on the manufacturing costs of our finished products that were shipped in 2022. Under this approach, we identified in total three (3) relevant suppliers (the “In-Scope Suppliers”). We collected all relevant data from our In-Scope Suppliers who were requested to submit CMRT of at least version 6.01 or higher published by the Responsible Minerals Initiatives' ("RMI")  in order to monitor the due diligence process and to gather and assess information from all such In-Scope Suppliers in a standardized format that is approved by an independent third party audit body, such as the RMI or the London Bullion Market Association  (“LBMA”).
 
We sent letters to our In-Scope Suppliers to explain the Rule and to refer them to online training materials and instructions.
 
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. Out of the three In-Scope Suppliers, all of the suppliers (100%) completed and returned to us a CMRT.
 
Based on these efforts, we have reason to believe that some of our products may contain necessary conflict minerals that potentially originated in the DRC or one of the Covered Countries and are not entirely 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.
 
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 internationally recognized due diligence framework prescribed by the Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016)" and related Supplements (the “OECD Guidance”). The OECD Guidance distinguishes between the roles of, and the corresponding due diligence recommendations addressed to upstream companies and downstream companies in the supply chain, whereby “upstream” generally means the mineral supply chain from the mine to smelters or refineries, and “downstream” generally means the minerals supply chain from smelters/refiners to retailers. We designed our due diligence measures according to the recommendations of the OECD Guidance for downstream companies that have no direct relationships to smelters or refiners as we believe that we are a “downstream” company.

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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") that is aimed at achieving responsible sourcing of the necessary conflict minerals. The Policy is publicly available on our website at https://www.radware.com/corporategovernance/conflictminerals.

Internal Team

We have established a management system to implement our responsible sourcing practices, to assist in the completion of the RCOI inquiry, and to further enable our supply chain due diligence related to the necessary 3TG. Our management system includes a steering committee headed by the Company's Legal Department (the “CM Steering Committee”), and a team of subject matter functions such as supplier management, operations and legal.

Supply Chain Control Systems and Transparency

We requested that all In-Scope Suppliers provide information to us regarding 3TG and relevant smelters or refiners using the CMRT of at least version 6.01 or higher. We collect and analyze all relevant data submitted to us through the CMRT to maintain a smelter or refiner database for Radware. This database of records is compared against the list of smelters or refiners that have received 'conformant' or 'active' designation according to the RMI's independent smelter or refiner audit program, namely the Responsible Minerals Assurance Process ("RMAP") or the LBMA.

We adopted, and communicated to our suppliers and to the public through our website and direct letters, our Policy for the sourcing of minerals originating from conflict-affected and high-risk areas that are under scrutiny for human right abuses, namely from the DRC or other Covered Countries, as per the stipulations of the Rule.

Grievance Mechanism

Our Conflict Minerals Policy is available to the public on our website at https://www.radware.com/corporategovernance/conflictminerals and provides the contact details for reporting concerns or questions regarding the Policy or violations thereof. 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 grievance in relation to our Conflict Minerals Policy.

Maintaining Records

We maintain data records relating to our due diligence efforts for the five-year duration recommended by the OECD Guidance. Radware stores current and former CMRTs received from suppliers to maintain traceability and transparency.

Supplier Engagement

We maintain an electronic portal that directs suppliers to resources related to conflict minerals, including FAQs from the SEC.

We established a conflict minerals webpage to host our Conflict Minerals Policy and our conflict minerals reports along with their related Form SDs. Our webpage is hosted at https://www.radware.com/corporategovernance/conflictminerals.

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We also provide guidance on the topic for relevant suppliers and engage in on-going outreach to our suppliers in order to collect, validate and archive supplier responses that relate to our conflict minerals due diligence process and supply chain inquiry.

As we enter into supplier contracts or renew existing supplier contracts, we seek to add, where feasible, a conflict minerals contract clause that requires suppliers to provide us with information on the likely source of the necessary 3TG they provide us, and relevant smelters or refiners.

Our internal controls also include a company-wide Code of Conduct and Ethics that outlines expected behaviors from all of our employees, contractors and consultants in engaging with suppliers. We have also adopted a Supplier Code of Conduct in which we convey to our suppliers, contractors and relevant third parties our expectations regarding, among other topics, responsible sourcing practices. The full text of our Code of Conduct and Ethics and our Supplier Code of Conduct is available on our website at https://www.radware.com/corporategovernance.

2.2.2           Identify and Assess Risks in the Supply Chain
 
We approached all of the In-Scope Suppliers and received responses from all (100%) of the In-Scope Suppliers as described in the RCOI. We reviewed and analyzed the respective CMRTs of our In-Scope Suppliers and compared the information provided therein against the Standard Smelter List of Compliant and Active Smelters from the RMAP - a list issued by RMI that aims to identify smelters or refiners that have systems in place to assure the responsible sourcing of conflict minerals, including those conflict minerals originating from the DRC or other Covered Countries. We rely on these In-Scope Suppliers, whose components may contain 3TG, to provide us with information on the likely  source and chain of custody of conflict minerals contained in the components supplied to us that are necessary to the production and/or to the functionality of our products. Our In-Scope Suppliers are similarly reliant upon information provided by their suppliers.
 
 2.2.3          Design and Implement a Strategy to Respond to Risks

We implemented the following strategy to address the results of our risk assessment described in Section 2.2.2 above. The goal of the design and implementation of our risk management strategy is not to eliminate sourcing from the DRC or other Covered Countries, but rather to encourage participation with the RMI and other relevant third party audit bodies, where possible. The following steps were taken to implement a strategy to help us assess potential risks:


The CM Steering Committee held periodic meetings to review progress and assess the risks identified.


We reviewed the responses that we received from In-Scope Suppliers and followed up on what we perceived to be inconsistent, incomplete, or inaccurate responses, as well as sent reminders to In-Scope Suppliers that did not respond to our requests for information.


We sent, where applicable, follow up letters to unresponsive In-Scope Suppliers and to In-Scope Suppliers who declared they sourced conflict minerals from the DRC or other Covered Countries, asking them to complete their supply chain due diligence process in order to validate that all smelters or refiners from the DRC or other Covered Countries are compliant with the RMI or other independent conflict-free smelter validation programs, such as the London Bullion Market (LBMA) or the Responsible Jewelry Council (RJC).


Engaged relevant senior management, including our Vice President and General Counsel, who were briefed on our due diligence efforts, risk analysis results and mitigation efforts.


We approached In-Scope Suppliers that we identified as possibly sourcing from smelters or refiners located in the DRC or other Covered Countries that did not receive a conformant or active designation from the RMI or LBMA, and asked for a corrective action plan.

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

We rely on industry-wide initiatives, such as RMI, to conduct risk assessments 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

Our supply chain conflict mineral due diligence efforts are described in this report. This Conflict Minerals Report is available on our website https://www.radware.com/corporategovernance/conflictminerals and is filed with the SEC.

3.                Results of Assessment

Based on information provided by our In-Scope Suppliers as well as by RMI, the results of our due diligence investigation on the dates covered by this Report, are as follows:


We were successful in approaching all In-Scope Suppliers.


Out of the three (3) In-Scope Suppliers, all (100%) completed and returned the CMRTs to us. Based on the CMRTs we received from these In-Scope Suppliers:


o
100% of the responses received provided data at the following levels.

Category of RMI CMRT Filed
Percentage of Responsive In-Scope Suppliers
Company level
67% (2 out of 3 suppliers)
User defined
0% (0 out of 3 suppliers)
Product list
33% (1 out of 3 suppliers)


o
We identified that 86% of the 262 reported smelters or refiners (“SoRs”), as of the publication of this Report, are conformant or active in the RMI’s RMAP audit program, as detailed below:

SoR RMI Status (Conformant, Active and Undocumented):

Conformant
222 Smelters or Refiners, 85% of Smelters or Refiners
Active
3 Smelters or Refiners, 1% of Smelter or Refiners
Undocumented
37 Smelters or Refiners, 14% of Smelters or Refiners
Total
262 Smelters or Refiners, 100% of Smelters or Refiners

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Based on the information provided by the In-Scope Suppliers as well as by RMI, 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 or refiners listed in Annex I below.

Based on the information provided by the In-Scope Suppliers as well as by RMI, as of the date of this Report, Radware believes that the 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 In-Scope Suppliers is not collected on a continuous, real-time basis.

In addition, Radware can only provide reasonable and good faith, yet not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals, since the information is provided from direct suppliers as well as from independent third party audit programs such as the RMI and the LBMA.

4. Future Risk Mitigation Efforts

We currently intend to continue working with our global supply chain to achieve the responsible sourcing of minerals from conflict areas and to comply with applicable regulations to the extent that they are required:


Continue implementing risk management measures and follow up processes with regard to non-responsive suppliers or suppliers working with undocumented suppliers according to current information from the RMI’s RMAP program.


As described in our Conflict Minerals Policy, to the extent that we have reason to believe that any of our 3TG suppliers source, or potentially source, such minerals from facilities that may, directly or indirectly, support the on-going conflict in the DRC or the other Covered Countries, we encourage such suppliers to establish an alternative source of 3TG sourcing that does not support such conflict, as outlined in the OECD Guidance. This engagement is important to us as we are committed to discouraging the propagation of human rights abuses in our supply chain.


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 with the goal of maintaining a 100% response rate and improving the content of the supplier’s survey responses.


Request suppliers to procure materials through validated smelters or refiners pursuant to the RMI or other approved resources and request suppliers to take mitigating actions in case they do not.


Continue to validate supplier responses using information collected via independent conflict-free smelter or refiner validation programs, such RMI's RMAP program.


Continue to engage in regular and ongoing risk assessment through our suppliers’ annual data submissions.

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Annex I – List of Smelters and/or Refiners
 
Metal (*)
Smelter Name Look-up
Smelter Country (*)
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Bangalore Refinery
INDIA
Gold
Chugai Mining
JAPAN
Gold
Dowa
JAPAN
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
Heraeus Germany GmbH Co. KG
GERMANY
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
L'Orfebre S.A.
ANDORRA
Gold
LT Metal Ltd.
KOREA, REPUBLIC OF
Gold
Materion
UNITED STATES OF AMERICA
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
Planta Recuperadora de Metales SpA
CHILE
Gold
REMONDIS PMR B.V.
NETHERLANDS
Gold
SAFINA A.S.
CZECHIA
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
Torecom
KOREA, REPUBLIC OF
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Agosi AG
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Asahi Pretec Corp.
JAPAN
Gold
Aurubis AG
GERMANY

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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 + Metaux S.A.
SWITZERLAND
Gold
Chimet S.p.A.
ITALY
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
Lingbao Gold Co., Ltd.
CHINA
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor Technologies S.A.
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN

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Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
PAMP S.A.
SWITZERLAND
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Precinox S.A.
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Royal Canadian Mint
CANADA
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
Valcambi S.A.
SWITZERLAND
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Gold
Shenzhen Zhonghenglong Real Industry Co., Ltd.
CHINA
Gold
T.C.A S.p.A
ITALY
Gold
Shirpur Gold Refinery Ltd.
INDIA
Gold
Marsam Metals
BRAZIL
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
SAAMP
FRANCE
Gold
8853 S.p.A.
ITALY
Gold
Italpreziosi
ITALY

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Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
AU Traders and Refiners
SOUTH AFRICA
Gold
Safimet S.p.A
ITALY
Gold
Metal Concentrators SA (Pty) Ltd.
SOUTH AFRICA
Gold
WEEEREFINING
FRANCE
Gold
Value Trading
BELGIUM
Gold
Shandong Gold Smelting Co., Ltd.
CHINA
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
AMG Brasil
BRAZIL
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
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 OF AMERICA
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Jiangxi Tuohong New Raw Material
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 de Mexico
MEXICO
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineracao Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
NPM Silmet AS
ESTONIA
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
TANIOBIS Co., Ltd.
THAILAND
Tantalum
TANIOBIS GmbH
GERMANY

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Tantalum
TANIOBIS Japan Co., Ltd.
JAPAN
Tantalum
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
XIMEI RESOURCES (GUANGDONG) LIMITED
CHINA
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
RFH Yancheng Jinye New Material Technology Co., Ltd.
CHINA
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
PT Refined Bangka Tin
INDONESIA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
PT Timah Tbk Kundur
INDONESIA
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.
CHINA
Tin
Alent plc
UNITED STATES OF AMERICA
Tin
Metallo Belgium N.V.
BELGIUM
Tin
Metallo Spain S.L.U.
SPAIN
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
Dowa
JAPAN
Tin
Fabrica Auricchio Industria e Comercio Ltda.
BRAZIL
Tin
Fenix Metals
POLAND
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
Mineracao Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES

12

Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
PT Babel Inti Perkasa
INDONESIA
Tin
PT Babel Surya Alam Lestari
INDONESIA
Tin
PT Bangka Serumpun
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT Cipta Persada Mulia
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Rajawali Rimba Perkasa
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Timah Tbk Mentok
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Thaisarco
THAILAND
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
PT Rajehan Ariq
INDONESIA
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
PT Mitra Sukses Globalindo
INDONESIA
Tin
CRM Synergies
SPAIN
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
Estanho de Rondonia S.A.
BRAZIL
Tin
PT Tommy Utama
INDONESIA
Tin
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
BRAZIL
Tin
PT Putera Sarana Shakti (PT PSS)
INDONESIA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Timah Nusantara
INDONESIA
Tin
Soft Metais Ltda.
BRAZIL

13

Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
VQB Mineral and Trading Group JSC
VIET NAM
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
PT Tirus Putra Mandiri
INDONESIA
Tin
Melt Metais e Ligas S.A.
BRAZIL
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
Tin
Luna Smelter, Ltd.
RWANDA
Tungsten
A.L.M.T. Corp.
JAPAN
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
China Molybdenum Tungsten Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
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 Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA

14

Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Masan High-Tech Materials
VIET NAM
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Tungsten
KGETS Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Fujian Xinlu Tungsten
CHINA
Tungsten
OOO “Technolom” 1
RUSSIAN FEDERATION

15

Annex II – Country of Origin Inquiry (COO)

Gold
Tantalum
Tin
Tungsten
ANDORRA
BRAZIL
BELGIUM
AUSTRIA
AUSTRALIA
CHINA
BOLIVIA (PLURINATIONAL STATE OF)
BRAZIL
AUSTRIA
ESTONIA
BRAZIL
CHINA
BELGIUM
GERMANY
CHINA
GERMANY
BRAZIL
INDIA
INDONESIA
JAPAN
CANADA
JAPAN
JAPAN
KOREA, REPUBLIC OF
CHILE
KAZAKHSTAN
MALAYSIA
PHILIPPINES
CHINA
MEXICO
PERU
RUSSIAN FEDERATION
CZECHIA
THAILAND
PHILIPPINES
TAIWAN, PROVINCE OF CHINA
FRANCE
UNITED STATES OF AMERICA
POLAND
UNITED STATES OF AMERICA
GERMANY
 
RWANDA
VIET NAM
INDIA
 
SPAIN
 
INDONESIA
 
TAIWAN, PROVINCE OF CHINA
 
ITALY
 
THAILAND
 
JAPAN
 
UNITED STATES OF AMERICA
 
KAZAKHSTAN
 
VIET NAM
 
KOREA, REPUBLIC OF
 
 
 
KYRGYZSTAN
 
 
 
MEXICO
 
 
 
NETHERLANDS
 
 
 
PHILIPPINES
 
 
 
POLAND
 
 
 
SINGAPORE
 
 
 
SOUTH AFRICA
 
 
 
SPAIN
 
 
 
SWEDEN
 
 
 
SWITZERLAND
 
 
 
TAIWAN, PROVINCE OF CHINA
 
 
 
THAILAND
 
 
 
TURKEY
 
 
 
UNITED ARAB EMIRATES
 
 
 
UNITED STATES OF AMERICA
 
 
 
UZBEKISTAN
 
 
 

16