EX-1.01 2 ex_254031.htm EXHIBIT 1.01 ex_254031.htm

EX-1.01 (Exhibit 1.01)

 

Conflict Minerals Report of Ormat Technologies, Inc.

For the Year Ended December 31, 2020

 

 

Introduction:

 

We are a Delaware corporation, whose shares of common stock are listed on the New York Stock Exchange and on the Tel Aviv Stock Exchange and are registered with the Securities and Exchange Commission (the "SEC").

 

We are a leading vertically integrated company, that is primarily engaged in the geothermal and recovered energy-based power businesses. Ormat leveraged its core capabilities and global presence to expand its activity into different energy storage services and solar photovoltaic (PV) (including hybrid geothermal and solar PV as well as energy storage plus Solar PV).

Ormat aims to become a leading global provider of renewable energy and has adopted a strategic plan to focus on several key initiatives to expand its business.

 

 

This is the Conflict Minerals Report (this "Report") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the reporting period from January 1, 2020 to December 31, 2020, which has been prepared in accordance with Rule13p-1 (“Rule 13p-1”), promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Rule 13p-1 requires every registrant that files reports with the SEC under Sections 13(a) or 15 (d) of the Exchange Act to disclose certain information when the registrant manufactures or contracts to manufacture products and when the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The specified minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, the “Conflict Minerals” or “3TG”), that originate, or are likely originate, in the Democratic Republic of the Congo (the “DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”). As part of the Company's desire to take responsibility for and concern itself with human rights issues, the Company decided to review its supply chain according to the EU regulation's guidance, and within that have included conflict-affected or high-risk areas ("CAHRAs") when approaching suppliers for information.

 

As part of Ormat's sustainability approach, our Code of Conduct outlines the Company‘s overall principles and commitments to legal compliance, ethical conduct, human rights, anti-corruption, labor rights and environmental protection. These high expectations extend to Ormat's partners, subcontractors and suppliers. We have adopted a policy (the “Conflict Minerals Policy”) with respect to our sourcing of Conflict Minerals, which was developed in accordance with the OECD guidance, and we implement a comprehensive Conflict Minerals program aimed to ensure responsible sourcing. Our Conflict Minerals Policy is available at http://www.ormat.com/social-responsibility-and-sustainability.

 

 

 

Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in Rule 13p-1 and Form SD.

 

 

1.

Overview

 

Company Overview

 

Ormat and its subsidiaries currently conduct business activities in the following three business segments:

 

 

Electricity Segment: In this segment, we develop, build, own and operate geothermal, solar PV and recovered energy-based power plants in the United States and geothermal power plants in other countries around the world and sell the electricity they generate.

 

Product Segment: In this segment, we design, manufacture and sell equipment for geothermal and recovered energy-based electricity generation and remote power units and provide services relating to the engineering, procurement, and construction of geothermal, and recovered energy-based power plants.

 

Energy Storage Segment: In this segment, we mainly provide energy storage, related services, as well as services relating to the engineering, procurement, construction, operation and maintenance of energy storage units.

 

Our customers for the Product segment are contractors, geothermal power plant owners and geothermal power plant developers and operators.

 

For more information about Ormat, please visit www.ormat.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

 

In accordance with applicable SEC rules, we conducted due diligence on the source and chain of custody of the Conflict Minerals used in our Product Segment. We concluded that no such examination is necessary with respect to the Electricity Segment or the Energy Storage and Management Services Segment because neither of these segments involves the sale of products by the Company.

 

 

 

In connection with our manufacturing activities in the Product Segment, we identified certain Conflict Minerals that are used by us and that are necessary to the functionality and production of our products with regards to the following raw materials or components: steel (low and high grade), electronic cards and electronic cables (including tin plating). These materials are purchased from our network of suppliers. As a downstream company that does not work directly with the smelters or refiners of the necessary Conflict Minerals, we work with our large network of international suppliers to obtain information on the likely source and chain of custody of those necessary Conflict Minerals and often there are multiple tiers between the gold, tin, tantalum and tungsten (“3TG”) mines and our direct suppliers. Therefore, we rely on our direct Tier 1 suppliers to cooperate with us and work with their own upstream suppliers or subcontractors to provide us with information on the origin of the 3TG in the components we purchase from them that are necessary to the functionality or production of our products. In order to overcome certain challenges in receiving accurate information from a complex supply chain, Ormat has communicated its Conflict Minerals Policy to our suppliers, and has adopted the Responsible Minerals Initiative's ("RMI") reporting template for surveying suppliers, i.e. the Conflict Minerals Reporting Template ("CMRT") of at least version 6.01or above.

 

 

2.

Reasonable Country of Origin Inquiry (RCOI)

 

Ormat has conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the necessary Conflict Minerals originated, or likely originated, in the DRC or Covered Countries or originated entirely from "recycled or scrap sources" (as such terms are defined in Rule 13p-1). In parallel, we conduct due diligence on our mineral supply chain in order to investigate, to a reasonable degree of accuracy, the likely source and chain of custody of the necessary Conflict Minerals used in our products or product components that is sourced from our global network of suppliers.

 

As part of our RCOI, we employed several methods to assess whether the necessary Conflict Minerals in our products originated, or likely originated, in the DRC or the Covered Countries, including the following:

 

 

Conducted an internal assessment and analysis of our products manufactured or contracted to manufacture in 2020 to determine which products contain or may contain Conflict Minerals that are necessary to the functionality or production of those products.

 

Compiled a list of applicable suppliers based on relevant product categories that Ormat purchased from during the calendar year 2020, which list was issued using the Ormat Management System (“OMS”) by information technology developers and according to the criteria defined by the OMS manager and the purchasing manager. The list include[d?] a total of 1,296 suppliers. Each supplier has a "Purchase Types" field, which contains one of the following values: Services, BOM, Office supplier, Goods and Capital Expenditure. Only the suppliers with "BOM" values in the "Purchase Types" field were applicable for the RCOI under Rule 13p-1.

 

In order to identify and assess risks in the supply chain, we undertook a risk-based approach and engaged the suppliers representing approximately 90% of our 2020 expenditures on procurement for the Product Segment. On that basis, Ormat's final direct Tier 1 suppliers list ("relevant suppliers") include[d?] a total of 122 suppliers, from which duplicate suppliers were removed to arrive at a total of 115 relevant suppliers for the calendar year 2020 supply chain inquiry.

 

 

 

 

Contracted a third-party service provider to assist us with the survey of suppliers. Through this third-party service provider, we sent letters to our relevant suppliers to explain Rule 13p-1 and to refer the suppliers to online training materials and instructions.

 

Solicited information from our relevant suppliers of raw materials and components of products using the standard template of the independent third-party audit body, the Responsible Minerals Initiative (“RMI”), known as the Conflict Minerals Reporting Template (“CMRT”). We requested that our suppliers provide at least version 6.01 of the CMRT. The CMRT is designed to facilitate the transfer of information through the supply chain regarding each mineral’s country of origin, or likely country of origin, and the relevant smelters or refiners. The CMRT requires suppliers to make representations regarding: (i) the country of origin, or likely country of origin, for the Conflict Minerals contained in the components or products it provides to the Company; (ii) all of the smelters or refiners in the supplier’s supply chain for such Conflict Minerals; (iii) whether such smelters or refiners have been validated as being in compliance with the RMI’s Responsible Minerals Assurance Process (the “RMAP”); (iv) whether the supplier has its own Conflict Minerals Policy that requires its own direct suppliers to be “DRC conflict-free”; and (v) whether the supplier collects Conflict Minerals information in a standardized format, such as the CMRT, from its own suppliers. Communications from the Company to its suppliers and responses received from the suppliers are stored electronically by the Company, together with copies of internal communications that relate to the Company’s due diligence, for a period of up to five years, as recommended by the relevant OECD Guidance.

 

Reviewed the responses that we received and followed up on inconsistent, incomplete, and inaccurate responses. We sent reminders to suppliers who did not respond to our requests for information or to suppliers whose responses required further clarification, as per the expectations noted above. We compared information received from our direct suppliers on their relevant smelters or refiners against the list of facilities that have been validated by RMAP, receiving a "conformant" or "active" status, as well as the documented country of origin information as provided in the declarations from the suppliers. The complete list of smelters or refiners identified in the scope of our supply chain inquiry is included as Annex 1 hereto and the complete list of counties of origin, or likely countries of origin, to the best of our knowledge, is included in Annex 2 hereto.

 

Currently, we do not have sufficient information from our suppliers to determine the complete list of countries of origin of the Conflict Minerals used in our products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the DRC or Covered Countries or are not entirely from recycled or scrap sources.

 

Based on these results, Ormat conducted due diligence activities and described these activities in this Report.

 

 

 

 

3.

Due Diligence Framework

 

We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten We design our due diligence measures according to the recommendations of the OECD Guidance for downstream companies that have no direct relationships to smelters or refiners.

 

 

4.

Due Diligence Measures

 

Our due diligence efforts for the reporting period from January 1, 2020 to December 31, 2020 included the following steps:

 

 

4.1

 Establish strong Company management systems for Conflict Minerals supply chain due diligence and reporting compliance

 

The Company implemented the following measures:

 

 

Established a cross-functional Conflict Minerals steering committee comprised of representatives from procurement, legal and finance departments to direct the overall efforts of the Conflict Minerals compliance program, with the Senior Vice President of Finance as the process owner.

 

Continued to implement our Conflict Minerals Policy with respect to sourcing of minerals from the DRC and the Covered Countries. Our Conflict Minerals Policy provides further clarification to the principles of the Code of Conduct and Ormat's Human Rights Approach, as outlined in our Human Rights & Labor Policy, regarding illegal trade of natural resources and promotes the procurement of minerals from credible and conflict-free sources. Pursuant to our Conflict Minerals Policy, we strive to ensure that purchased metals originate only from smelters or refiners that have been validated as being “conformant” or “active” by the RMI's RMAP; however the Company does not seek to eliminate sourcing from the DRC, Covered Countries or CAHRAs. In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and encourage them to define, implement and communicate to their sub-suppliers their own policies outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. The Company's Conflict Minerals Policy is available at: http://www.ormat.com/social-responsibility-and-sustainability.

 

Maintain a grievance mechanism through which concerns and violations of the Conflict Minerals Policy can be reported to Ormat:

 

online via our website www.ormat.com; or

 

by electronic mail to the following address: ormat@ormat.com.

 

Strengthened our engagement with suppliers by referring suppliers to training materials that included an overview of the applicable SEC rules and instructions on how to respond to the survey.

 

 

 

 

Required our suppliers to provide us the information required to perform our analysis of Conflict Minerals.

 

Implemented a requirement to maintain records relating to Conflict Minerals due diligence and responsible mineral sourcing for a minimum of five years.

 

 

4.2

 Identify and assess risks in the supply chain

 

To identify risks in our supply chain, we undertook the following measures:

 

 

We identified two risks in the supply chain: (i) the risk of not receiving timely and accurate information from the supplier; and (ii) the risk of not being able to replace a supplier, when aiming to move towards the goal of responsible sourcing of Conflict Minerals to ensure that the purchase and sourcing of such minerals does not benefit or fund the armed conflict and human rights abuses on-going in the DRC, Covered Countries, CAHRAs or in other conflict-affected areas. We have segmented our suppliers into three risk levels (high, medium and low) by referring to Conflict Minerals-related risks based on suppliers’ characteristics, including the extent to which the Company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers. This segmentation allowed us to focus our risk mitigation efforts according to the supplier level of risk.

 

As part of the risk assessment phase, Ormat decided to focus on the top approximately 90% of the purchasing spend in 2020. We have determined that, out of the responses received, 61.7% of Ormat's relevant suppliers have a policy in place that addresses the sourcing of Conflict Minerals.

 

Responses received were subject to a "red flag" review. Responses that we identified as incomplete or inconsistent based on the red flag review process were marked for follow up. We identified the smelters or refiners that are likely a part of our mineral supply chain by conducting a supply chain survey using the CMRT (at least version 6.01 or higher), requesting suppliers to identify relevant smelters or refiners and country of origin, or likely country of origin, of the Conflict Minerals in products supplied to Ormat in 2020. In addition, we compared smelters and refiners identified by the supply chain survey against the list of facilities that received RMAP’s “conformant” and “active” designations. The RMAP is a program in which the RMI works with independent third-party auditors or cross-certification programs to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters and refiners that agree to undergo an audit or to take part in a cross-certification program.

 

 

A smelter or refiner receives an RMAP “conformant” designation from the RMI if the smelter or refiner (i) completes an independent third-party audit, (ii) adheres to the RMAP’s assessment protocols by disclosing to auditors the identities and locations of the mines from which it sources Conflict Minerals, (iii) has been found by its independent third-party auditor to possess the systems and processes to support responsible sourcing of Conflict Minerals and can provide evidence to support its sourcing activities and (iv) maintains good standing in the program, through a continual validation process. The RMI’s RMAP “conformant” list provides the names, locations and links to Conflict Minerals policies of all smelters and refiners deemed compliant with the RMAP’s assessment protocols. Smelters and refiners with a “re-audit in progress” are still considered to be RMAP “conformant.” 

 

 

 

 

Smelters and refiners labeled as RMAP “active” by the RMI have committed to undergo an audit, which may be in progress, or are participating in one of the cross-recognized certification programs, namely, the London Bullion Market Association Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. “Active” smelters and refiners may be at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase. They may not retain their “active” status if, among other things, they are unresponsive to requests for re-audit or corrective action past a certain time.

 

Companies that have been determined to be downstream of smelters or refiners may not take part in the RMAP. However, they may participate in the RMI’s Downstream Audit Program, an independent validation of companies’ sourcing practices outside of the RMAP audit process.

 

 

4.3

 Design and implement a strategy to respond to identified risks

 

To address the risks in our supply chain, Ormat maintains a risk mitigation plan, which includes the following:

 

 

Ormat expects its suppliers to define, implement and communicate to sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, and legal compliance and measures for implementation. We also ask suppliers to work with sub-tier suppliers to ensure traceability of these materials at least to the smelter or refiner level (e.g., by using a recent version of the CMRT).

 

Ormat's senior management, including the CEO, CFO and Chief Compliance Officer, President Head of Products and Operations, EVP Electricity Segment, EVP Energy Storage and Business Development, and the Legal Counsel , was updated with the risk analysis and risk management actions and outcomes.

 

Suppliers who provided incomplete or inconsistent responses were sent a corrective action letter for follow up, requesting clarification.

 

Suppliers that did not respond to our initial survey request were sent follow-up letters requesting that they provide the necessary information.

 

Should the Company find uncertified SoRs in its suppliers’ responses, it will follow up with the supplier and ask for further clarifications or corrective action plans

 

Supply chain due diligence is a dynamic process that requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process and update the risk mitigation strategy accordingly.

 

 

 

 

4.4 Carry out independent third-party audit of smelter/refiners due diligence practices

 

We do not typically have direct relationships with 3TG smelters or refiners of Conflict Minerals and therefore do not perform direct audits of these entities. As a result, our due diligence efforts relied on independent third-party audit body and cross- industry initiatives, such as those led by the RMI, to conduct smelter or refiner due diligence.

 

4.5 Report annually on supply chain due diligence

 

Our Conflict Minerals Policy was adopted with a view to assuring compliance with Section 1502 of the Dodd Frank Act, which requires the filing of a Form SD and this Report with the SEC and disclosure of them on its publicly available Internet website. The Company's Conflict Minerals Reports can be viewed at: https://d18rn0p25nwr6d.cloudfront.net/CIK-0001296445/f4ff3164-7606-4d15-ac83-7643b36391cd.pdf

 

 

5

The Companys Due Diligence Findings and Conclusions

 

We conducted a supply-chain survey of the 115 relevant suppliers that we identified as potentially contributing the necessary Conflict Minerals contained in our products in 2020. The overall response rate to this survey was approximately 50%. The responses included the names and locations of smelters or refiners (see Annex 1) and possible countries of origin, according to the information provided in our suppliers' declarations (see Annex 2).

 

As a downstream purchaser of products which contain conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. Our supply chain is complex and there are multiple tiers between the Company and the mines or facilities that process the necessary Conflict Minerals. Accordingly, we rely on our suppliers to provide information on the origin of the 3TG contained in components that are supplied to us to be included in our products.

 

Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers and the entire supply chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners. We ask that the data cover the entire reporting year, and we seek to use contract provisions requiring the suppliers to promptly update us in the event that the sourcing data changes.

 

 

 

Despite receiving responses from suppliers listing smelter or refiner names in their supply chain, the suppliers were unable to conclusive determine the specific smelters or refiners that were part of the supply chain of the components sold to Ormat in 2020.

 

In light of inconclusive information, we are unable to determine and to describe the full list of facilities used to process 3TG in the Covered Products or their countries of origin.

 

Smelters or refiners verified as RMAP Conformant or Active:

 

Tantalum

37 of 38 (97.4%)

 

Tin

48 of 58 (82.75%)

 

Tungsten

43 of 49 (87.75%)

 

Gold

108 of 153 (70.59%)

 

Total

 236 of 298 (79.19%)

 

 

Status of identified smelters or refiners:

 

 

2020

 

“RMAP Conformant”

229

 

“RMAP Active”

7

 

“Not RMAP Conformant or Active”

62

 

Total

298

 

 

 

 

6. Steps to be taken to mitigate risk

 

The Company has taken, and intends to continue to take, steps to improve its due diligence processes. Due diligence is an ongoing, proactive and reactive process, and the Company is continually working to improve its methods and processes for identifying the source or likely source of the Conflict Minerals contained in its Covered Products. The Company plans to continue to inform suppliers of their role in the Company’s Conflict Minerals compliance program and to engage its suppliers to obtain current, accurate and complete information regarding their mineral supply chains. The Company intends to monitor the performance and efficiency of its due diligence efforts to ensure responsible sourcing in compliance with its Conflict Minerals Policy and increase transparency in its supply chain.

 

Specific steps the Company has taken and continues to take to manage risks include:

 

Continue to work with our global supply chain to obtain current, accurate and complete information about the supply chain, ensure responsible sourcing, while also assuring compliance with certain international regulations.

 

Continue to strengthen communications with suppliers in order to improve the number of suppliers that respond to the company's supply chain surveys and requests for information.

 

Continue to improve due diligence efforts to ensure responsible sourcing in compliance with the Conflict Minerals Policy.

 

Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts.

 

 

 

 

Cautionary Note Concerning Forward- Looking Statements

 

Information provided in this Report may contain statements relating to current expectations and plans that are "forward- looking statements" as defined in the Private Securities Litigation Reform Act of 1995. These forward- looking statements generally relate to Ormat's plans, objectives and expectations for future plans and events and are based upon its management's current estimates. These statements are subject to risks and uncertainties and may not prove to be accurate. These risks and uncertainties include those associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on our ability to verify the accuracy or completeness of any supply chain information provided by suppliers and other factors discussed under the heading "Risk Factors" as described in Ormat Technologies, Inc.'s Annual Report on Form 10- K filed with the Securities and Exchange Commission on February 26, 2021 and other documents subsequently filed with or furnished to the U.S. Securities and Exchange Commission. These forward- looking statements are made only as of the date hereof, and, except as required by applicable law, we undertake no obligation to update or revise the forward- looking statements, whether as a result of new information, future events or otherwise.

 

 

 

Annex 1- Smelter or Refiner Names in Supply Chain

 

Metal

Smelter Name

Smelter Country

Smelter Status

Gold

8853 S.p.A.

ITALY

Conformant

Gold

Abington Reldan Metals, LLC

UNITED STATES OF AMERICA

Not certified

Gold

Advanced Chemical Company

UNITED STATES OF AMERICA

Conformant

Gold

African Gold Refinery

UGANDA

Not certified

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

Conformant

Gold

Al Etihad Gold Refinery DMCC

UNITED ARAB EMIRATES

Conformant

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

Conformant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

Conformant

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

BRAZIL

Conformant

Gold

Argor-Heraeus S.A.

SWITZERLAND

Conformant

Gold

Asahi Pretec Corp.

JAPAN

Conformant

Gold

Asahi Refining Canada Ltd.

CANADA

Conformant

Gold

Asahi Refining USA Inc.

UNITED STATES OF AMERICA

Conformant

Gold

Asaka Riken Co., Ltd.

JAPAN

Conformant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

Not certified

Gold

AU Traders and Refiners

SOUTH AFRICA

Conformant

Gold

Augmont Enterprises Private Limited

INDIA

Active

Gold

Aurubis AG

GERMANY

Conformant

Gold

Bangalore Refinery

INDIA

Conformant

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

Conformant

Gold

Boliden AB

SWEDEN

Conformant

Gold

C. Hafner GmbH + Co. KG

GERMANY

Conformant

Gold

Caridad

MEXICO

Not certified

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

Conformant

Gold

Cendres + Metaux S.A.

SWITZERLAND

Conformant

Gold

CGR Metalloys Pvt Ltd.

INDIA

Not certified

Gold

Chimet S.p.A.

ITALY

Conformant

Gold

Chugai Mining

JAPAN

Conformant

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

Not certified

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

Not certified

Gold

Dijllah Gold Refinery FZC

UNITED ARAB EMIRATES

Not certified

Gold

DODUCO Contacts and Refining GmbH

GERMANY

Conformant

Gold

Dowa

JAPAN

Conformant

Gold

DS PRETECH Co., Ltd.

KOREA, REPUBLIC OF

Conformant

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

Conformant

 

 

 

Gold

Eco-System Recycling Co., Ltd.

JAPAN

Conformant

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

Conformant

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

Not certified

Gold

Fujairah Gold FZC

UNITED ARAB EMIRATES

Not certified

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

Not certified

Gold

Geib Refining Corporation

UNITED STATES OF AMERICA

Conformant

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

Conformant

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

Not certified

Gold

Guangdong Jinding Gold Limited

CHINA

Not certified

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

Not certified

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

Not certified

Gold

HeeSung Metal Ltd.

KOREA, REPUBLIC OF

Conformant

Gold

Heimerle + Meule GmbH

GERMANY

Conformant

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

Conformant

Gold

Heraeus Precious Metals GmbH & Co. KG

GERMANY

Active

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

Conformant

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

CHINA

Not certified

Gold

HwaSeong CJ CO., LTD.

KOREA, REPUBLIC OF

Not certified

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

Conformant

Gold

International Precious Metal Refiners

UNITED ARAB EMIRATES

Active

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

Conformant

Gold

Istanbul Gold Refinery

TURKEY

Conformant

Gold

Italpreziosi

ITALY

Conformant

Gold

Japan Mint

JAPAN

Conformant

Gold

Jiangxi Copper Co., Ltd.

CHINA

Conformant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

Not certified

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

Conformant

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

Conformant

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

Not certified

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

Not certified

Gold

Kazzinc

KAZAKHSTAN

Conformant

Gold

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

Conformant

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

Conformant

Gold

Kojima Chemicals Co., Ltd.

JAPAN

Conformant

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

Conformant

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

Conformant

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

Not certified

 

 

 

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

Not certified

Gold

Lingbao Gold Co., Ltd.

CHINA

Not certified

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

Not certified

Gold

L'Orfebre S.A.

ANDORRA

Conformant

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

Conformant

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

Not certified

Gold

Marsam Metals

BRAZIL

Conformant

Gold

Materion

UNITED STATES OF AMERICA

Conformant

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

Conformant

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

Conformant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

Conformant

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

Conformant

Gold

Metalor Technologies S.A.

SWITZERLAND

Conformant

Gold

Metalor USA Refining Corporation

UNITED STATES OF AMERICA

Conformant

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

MEXICO

Conformant

Gold

Mitsubishi Materials Corporation

JAPAN

Conformant

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

Conformant

Gold

Modeltech Sdn Bhd

MALAYSIA

Not certified

Gold

Morris and Watson

NEW ZEALAND

Not certified

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

Conformant

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

TURKEY

Conformant

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

Conformant

Gold

NH Recytech Company

KOREA, REPUBLIC OF

Not certified

Gold

Nihon Material Co., Ltd.

JAPAN

Conformant

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

Conformant

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

Conformant

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

RUSSIAN FEDERATION

Conformant

Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

Conformant

Gold

PAMP S.A.

SWITZERLAND

Conformant

Gold

Pease & Curren

UNITED STATES OF AMERICA

Not certified

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

Not certified

Gold

Planta Recuperadora de Metales SpA

CHILE

Conformant

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

Conformant

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

Conformant

Gold

PX Precinox S.A.

SWITZERLAND

Conformant

Gold

QG Refining, LLC

UNITED STATES OF AMERICA

Not certified

 

 

 

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

Conformant

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

Not certified

Gold

REMONDIS PMR B.V.

NETHERLANDS

Conformant

Gold

Royal Canadian Mint

CANADA

Conformant

Gold

SAAMP

FRANCE

Conformant

Gold

Sabin Metal Corp.

UNITED STATES OF AMERICA

Not certified

Gold

Safimet S.p.A

ITALY

Conformant

Gold

SAFINA A.S.

CZECHIA

Conformant

Gold

Sai Refinery

INDIA

Not certified

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

Conformant

Gold

Samwon Metals Corp.

KOREA, REPUBLIC OF

Not certified

Gold

SAXONIA Edelmetalle GmbH

GERMANY

Conformant

Gold

SEMPSA Joyeria Plateria S.A.

SPAIN

Conformant

Gold

Shandong Humon Smelting Co., Ltd.

CHINA

Not certified

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

Not certified

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

Conformant

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

Conformant

Gold

Singway Technology Co., Ltd.

TAIWAN, PROVINCE OF CHINA

Conformant

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

Conformant

Gold

Solar Applied Materials Technology Corp.

TAIWAN, PROVINCE OF CHINA

Conformant

Gold

Sovereign Metals

INDIA

Not certified

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

Not certified

Gold

Sudan Gold Refinery

SUDAN

Not certified

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

Conformant

Gold

SungEel HiMetal Co., Ltd.

KOREA, REPUBLIC OF

Conformant

Gold

T.C.A S.p.A

ITALY

Conformant

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

Conformant

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

Conformant

Gold

Tokuriki Honten Co., Ltd.

JAPAN

Conformant

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

Not certified

Gold

Tony Goetz NV

BELGIUM

Not certified

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

Conformant

Gold

Torecom

KOREA, REPUBLIC OF

Conformant

Gold

Umicore Brasil Ltda.

BRAZIL

Not certified

Gold

Umicore Precious Metals Thailand

THAILAND

Conformant

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

Conformant

 

 

 

Gold

United Precious Metal Refining, Inc.

UNITED STATES OF AMERICA

Conformant

Gold

Valcambi S.A.

SWITZERLAND

Conformant

Gold

Western Australian Mint (T/a The Perth Mint)

AUSTRALIA

Conformant

Gold

WIELAND Edelmetalle GmbH

GERMANY

Conformant

Gold

Yamakin Co., Ltd.

JAPAN

Conformant

Gold

Yokohama Metal Co., Ltd.

JAPAN

Conformant

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

Not certified

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

Conformant

Tantalum

Asaka Riken Co., Ltd.

JAPAN

Conformant

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

Conformant

Tantalum

CP Metals Inc.

UNITED STATES OF AMERICA

Not certified

Tantalum

D Block Metals, LLC

UNITED STATES OF AMERICA

Conformant

Tantalum

Exotech Inc.

UNITED STATES OF AMERICA

Conformant

Tantalum

F&X Electro-Materials Ltd.

CHINA

Conformant

Tantalum

FIR Metals & Resource Ltd.

CHINA

Conformant

Tantalum

Global Advanced Metals Aizu

JAPAN

Conformant

Tantalum

Global Advanced Metals Boyertown

UNITED STATES OF AMERICA

Conformant

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

Conformant

Tantalum

H.C. Starck Co., Ltd.

THAILAND

Conformant

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

Conformant

Tantalum

H.C. Starck Inc.

UNITED STATES OF AMERICA

Conformant

Tantalum

H.C. Starck Ltd.

JAPAN

Conformant

Tantalum

H.C. Starck Smelting GmbH & Co. KG

GERMANY

Conformant

Tantalum

H.C. Starck Tantalum and Niobium GmbH

GERMANY

Conformant

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

Conformant

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

Conformant

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

Conformant

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

Conformant

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

Conformant

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

Conformant

Tantalum

KEMET Blue Metals

MEXICO

Conformant

Tantalum

LSM Brasil S.A.

BRAZIL

Conformant

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

Conformant

Tantalum

Mineracao Taboca S.A.

BRAZIL

Conformant

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

Conformant

 

 

 

Tantalum

NPM Silmet AS

ESTONIA

Conformant

Tantalum

Power Resources Ltd.

MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF

Conformant

Tantalum

QuantumClean

UNITED STATES OF AMERICA

Conformant

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

Conformant

Tantalum

RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.

CHINA

Conformant

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

Conformant

Tantalum

Taki Chemical Co., Ltd.

JAPAN

Conformant

Tantalum

Telex Metals

UNITED STATES OF AMERICA

Conformant

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

Conformant

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

Conformant

Tin

Alpha

UNITED STATES OF AMERICA

Conformant

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

Not certified

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

Conformant

Tin

China Tin Group Co., Ltd.

CHINA

Conformant

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

CHINA

Not certified

Tin

Dowa

JAPAN

Conformant

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

VIET NAM

Not certified

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

Conformant

Tin

Estanho de Rondonia S.A.

BRAZIL

Active

Tin

Fenix Metals

POLAND

Conformant

Tin

Gejiu City Fuxiang Industry and Trade Co., Ltd.”

CHINA

Not certified

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

Conformant

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

Conformant

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

Conformant

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

Conformant

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

CHINA

Conformant

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

CHINA

Conformant

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

Conformant

Tin

Huichang Jinshunda Tin Co., Ltd.

CHINA

Conformant

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

Conformant

Tin

Ma'anshan Weitai Tin Co., Ltd.

CHINA

Conformant

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

Conformant

 

 

 

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

Conformant

Tin

Melt Metais e Ligas S.A.

BRAZIL

Conformant

Tin

Metallic Resources, Inc.

UNITED STATES OF AMERICA

Conformant

Tin

Metallo Belgium N.V.

BELGIUM

Conformant

Tin

Metallo Spain S.L.U.

SPAIN

Conformant

Tin

Mineracao Taboca S.A.

BRAZIL

Conformant

Tin

Minsur

PERU

Conformant

Tin

Mitsubishi Materials Corporation

JAPAN

Conformant

Tin

Modeltech Sdn Bhd

MALAYSIA

Not certified

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

Not certified

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

Conformant

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

Conformant

Tin

Operaciones Metalurgicas S.A.

BOLIVIA (PLURINATIONAL STATE OF)

Conformant

Tin

Pongpipat Company Limited

MYANMAR

Not certified

Tin

Precious Minerals and Smelting Limited

INDIA

Not certified

Tin

PT Artha Cipta Langgeng

INDONESIA

Conformant

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

Conformant

Tin

PT Bangka Serumpun

INDONESIA

Conformant

Tin

PT Mitra Stania Prima

INDONESIA

Conformant

Tin

PT Mitra Sukses Globalindo

INDONESIA

Not certified

Tin

PT Refined Bangka Tin

INDONESIA

Conformant

Tin

PT Timah Tbk Kundur

INDONESIA

Conformant

Tin

PT Timah Tbk Mentok

INDONESIA

Conformant

Tin

Resind Industria e Comercio Ltda.

BRAZIL

Conformant

Tin

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

Conformant

Tin

Soft Metais Ltda.

BRAZIL

Conformant

Tin

Super Ligas

BRAZIL

Active

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

VIET NAM

Conformant

Tin

Thaisarco

THAILAND

Conformant

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

Conformant

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIET NAM

Not certified

Tin

White Solder Metalurgia e Mineracao Ltda.

BRAZIL

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

Conformant

Tin

Yunnan Tin Company Limited

CHINA

Conformant

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

CHINA

Conformant

Tungsten

A.L.M.T. Corp.

JAPAN

Conformant

Tungsten

ACL Metais Eireli

BRAZIL

Conformant

 

 

 

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

Conformant

Tungsten

China Molybdenum Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

Not certified

Tungsten

Cronimet Brasil Ltda

BRAZIL

Active

Tungsten

Fujian Ganmin RareMetal Co., Ltd.

CHINA

Conformant

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

CHINA

Not certified

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

Conformant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

Conformant

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

Conformant

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES OF AMERICA

Conformant

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

H.C. Starck Smelting GmbH & Co. KG

GERMANY

Conformant

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

Conformant

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

Conformant

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CHINA

Conformant

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

Conformant

Tungsten

Hunan Litian Tungsten Industry Co., Ltd.

CHINA

Conformant

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

Conformant

Tungsten

Japan New Metals Co., Ltd.

JAPAN

Conformant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

Conformant

Tungsten

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

CHINA

Not certified

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

Not certified

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

Conformant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

Conformant

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

RUSSIAN FEDERATION

Active

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

Conformant

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

Conformant

Tungsten

KGETS Co., Ltd.

KOREA, REPUBLIC OF

Conformant

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF CHINA

Conformant

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Masan Tungsten Chemical LLC (MTC)

VIET NAM

Conformant

 

 

 

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

Conformant

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

Conformant

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

Conformant

Tungsten

South-East Nonferrous Metal Company Limited of Hengyang City

CHINA

Not certified

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

VIET NAM

Conformant

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

Conformant

Tungsten

Wolfram Bergbau und Hutten AG

AUSTRIA

Conformant

Tungsten

Woltech Korea Co., Ltd.

KOREA, REPUBLIC OF

Conformant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CHINA

Conformant

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CHINA

Not certified

 

 

 

 

 

Annex 2- Country of Origin (COO) Inquiry Results*

 

 

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

INDIA

JAPAN

CANADA

JAPAN

INDONESIA

KOREA, REPUBLIC OF

CHILE

KAZAKHSTAN

JAPAN

PHILIPPINES

CHINA

MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF

MALAYSIA

RUSSIAN FEDERATION

CZECHIA

MEXICO

MYANMAR

TAIWAN, PROVINCE OF CHINA

FRANCE

RUSSIAN FEDERATION

PERU

UNITED STATES OF AMERICA

GERMANY

THAILAND

PHILIPPINES

VIET NAM

INDIA

UNITED STATES OF AMERICA

POLAND

 

INDONESIA

 

SPAIN

 

ITALY

 

TAIWAN, PROVINCE OF CHINA

 

JAPAN

 

THAILAND

 

KAZAKHSTAN

 

UNITED STATES OF AMERICA

 

KOREA, REPUBLIC OF

 

Vietnam

 

KYRGYZSTAN

     

LITHUANIA

     

 

 

 

MALAYSIA

     

MEXICO

     

NETHERLANDS

     

NEW ZEALAND

     

PHILIPPINES

     

POLAND

     

RUSSIAN FEDERATION

     

SAUDI ARABIA

     

SINGAPORE

     

SOUTH AFRICA

     

SPAIN

     

SUDAN

     

SWEDEN

     

SWITZERLAND

     

TAIWAN, PROVINCE OF CHINA

     

THAILAND

     

TURKEY

     

UGANDA

     

UNITED ARAB EMIRATES

     

UNITED STATES OF AMERICA

     

UZBEKISTAN

     

ZIMBABWE

     

 

 

 

 

* As some SORs did not provide complete information on the Location of Mine in their CMRTs, and the Company was not able to establish with complete certainty, based on the suppliers’ 3TG sourcing information, the exact location for the processing of the minerals. Therefore, we have listed in the COO the closest indication provided as to the source of Conflict Minerals, i.e. the Smelter Country as reported in our relevant suppliers' CMRT declarations, if provided.