EX-1.01 2 ex_525713.htm EXHIBIT 1.01 ex_525713.htm

EX-1.01 (Exhibit 1.01)

 

Conflict Minerals Report of Ormat Technologies, Inc.

For the Year Ended December 31, 2022

 

 

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 energy power business. Ormat is leveraging its core capabilities and global presence to expand its activity in recovered energy generation and 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, 2022 to December 31, 2022, which has been prepared in accordance with Rule 13p-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 Ormat's sustainability approach, our Supplier Code of Conduct and Code of Business Conduct and Ethics 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 Organization for Economic Co-operation and Development (“OECD”) guidance, and we implement a comprehensive Conflict Minerals program aimed to ensure responsible sourcing. Our Conflict Minerals Policy is available at https://www.ormat.com/en/company/engagement/view/?ContentID=9199.

 

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 provide services relating to the engineering, procurement and construction of geothermal, and recovered energy-based power plants.

 

Energy Storage Segment: In this segment, we own and operate grid connected In Front of the Meter (IFM) BESS facilities, which provide capacity, energy and ancillary services directly to the electric grid.

 

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 Segment because neither of these segments involves the offer of products by the Company to third parties for consideration.

 

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 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 6.01 or 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 2022 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 2022, 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. For calendar year 2022, the list included a total of 1,001 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 2022 expenditures on procurement for the Product Segment. On that basis, Ormat's final direct Tier 1 suppliers list ("relevant suppliers") included a total of 103 suppliers for the calendar year 2022 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.

 

 

 

 

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 (2016) and related Supplements (the “OECD Due Diligence Guidance”). We design our due diligence measures according to the recommendations of the OECD Due Diligence 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, 2022 to December 31, 2022 included the following steps as prescribed by the OECD Due Diligence Guidance:

 

4.1

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

 

The Company implemented the following measures:

 

 

Continued operating 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, or Covered Countries. 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: https://www.ormat.com/en/company/engagement/view/?ContentID=9199.

 

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, 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 2022. We have determined that, out of the responses received, 64.7% 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 2022. 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 is considered RMAP “conformant” if the audited smelter or refiner has successfully completed an RMAP audit and maintains good standing in the program, through a continual validation process. These smelters or refiners have the systems and processes in place to support responsible sourcing of raw materials and can provide evidence to support their sourcing activities.

 

 

Smelters and refiners labeled as RMAP “active” by the RMI represent smelters and refiners that have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment. These may be in the pre-assessment, assessment or corrective-action phases of the assessment. The RMI notes on the active smelters list the names of any smelters or refiners that have left the “active” or “conformant” list and intend to re-enter the program.

 

 

Downstream 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, President Head of Products and Operations, EVP Electricity Segment, EVP Energy Storage and Business Development, and the Legal Counsel and Chief Compliance Officer, were 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 smelters or refiners 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://investor.ormat.com/sec-filings/documents/default.aspx

 

5

The Companys Due Diligence Findings and Conclusions

 

We conducted a supply-chain survey of the 103 relevant suppliers that we identified as potentially contributing the necessary Conflict Minerals contained in our products in 2022. The overall response rate to this survey was approximately 53%. 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 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 Conflict Minerals contained in components that are supplied to us to be included in our products.

 

 

 

We also rely, to a large extent, on information collected and provided by responsible mineral sourcing validation programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.

 

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 calendar year covered by the Report, 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 conclusively determine all of the specific smelters or refiners that were part of the supply chain of the components sold to Ormat in 2022. 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. The below shows the RMAP status of smelters or refiners our suppliers identified in response to our due diligence, with the location of such smelters or refiners included in Annex 1. The Company cannot be certain that these smelters and refiners were in fact in the Company’s supply chain during the period covered by this Report.

 

Smelters or refiners verified as RMAP Conformant or Active:

 

Tantalum

33 of 37 (89.2%)

Tin

62 of 83 (74.7%)

Tungsten

36 of 52 (69.2%)

Gold

100 of 178 (56.2%)

Total

231 of 350 (66.0%)

 

 

 

Status of identified smelters or refiners:

 

RMAP Status

Number

RMAP “Conformant” 

223

RMAP “Active”

8

Not RMAP “Conformant” or “Active”

119

Total

350

 

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 and continue to communicate the expectation that they steer their supply chain towards conformant smelters as defined by the RMI's RMAP or other equivalent programs.

 

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 24, 2023 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

Gold

Advanced Chemical Company

UNITED STATES OF AMERICA

Gold

Aida Chemical Industries 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

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 + Metaux S.A.

SWITZERLAND

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

Gold

Chimet S.p.A.

ITALY

Gold

Chugai Mining

JAPAN

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

Gold

DODUCO Contacts and Refining GmbH

GERMANY

Gold

Dowa

JAPAN

Gold

Eco-System Recycling Co., Ltd. East Plant

JAPAN

Gold

JSC Novosibirsk Refinery

RUSSIAN FEDERATION

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

Gold

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

CHINA

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

Gold

LT Metal Ltd.

KOREA, REPUBLIC OF

Gold

Heimerle + Meule GmbH

GERMANY

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

Gold

Heraeus Germany GmbH Co. KG

GERMANY

Gold

Hunan Chenzhou Mining Co., 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

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

Gold

Kazzinc

KAZAKHSTAN

Gold

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

Gold

Kojima Chemicals Co., Ltd.

JAPAN

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

Gold

Lingbao Gold Co., Ltd.

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 OF AMERICA

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

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

Gold

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

TURKEY

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

Gold

Nihon Material Co., Ltd.

JAPAN

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

Gold

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

RUSSIAN FEDERATION

Gold

PAMP S.A.

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 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

Samduck Precious Metals

KOREA, REPUBLIC OF

Gold

Samwon Metals Corp.

KOREA, REPUBLIC OF

Gold

SEMPSA Joyeria Plateria S.A.

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

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

Gold

Solar Applied Materials Technology Corp.

TAIWAN, PROVINCE OF CHINA

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

Gold

Super Dragon Technology Co., Ltd.

TAIWAN, PROVINCE OF CHINA

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

Gold

Shandong Gold Smelting Co., Ltd.

CHINA

Gold

Tokuriki Honten Co., Ltd.

JAPAN

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

Gold

Torecom

KOREA, REPUBLIC OF

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

Gold

United Precious Metal Refining, Inc.

UNITED STATES OF AMERICA

Gold

Valcambi S.A.

SWITZERLAND

Gold

Western Australian Mint (T/a The Perth Mint)

AUSTRALIA

Gold

Yamakin Co., Ltd.

JAPAN

Gold

Yokohama Metal Co., Ltd.

JAPAN

 

 

 

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

Gold

Morris and Watson

NEW ZEALAND

Gold

SAFINA A.S.

CZECHIA

Gold

Guangdong Jinding Gold Limited

CHINA

Gold

Umicore Precious Metals Thailand

THAILAND

Gold

Geib Refining Corporation

UNITED STATES OF AMERICA

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

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

Al Etihad Gold Refinery DMCC

UNITED ARAB EMIRATES

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

Gold

International Precious Metal Refiners

UNITED ARAB EMIRATES

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

Gold

Sudan Gold Refinery

SUDAN

Gold

T.C.A S.p.A

ITALY

Gold

REMONDIS PMR B.V.

NETHERLANDS

Gold

Fujairah Gold FZC

UNITED ARAB EMIRATES

Gold

Industrial Refining Company

BELGIUM

Gold

Shirpur Gold Refinery Ltd.

INDIA

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

Gold

Marsam Metals

BRAZIL

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

Gold

Abington Reldan Metals, LLC

UNITED STATES OF AMERICA

Gold

Shenzhen CuiLu Gold Co., Ltd.

CHINA

Gold

Albino Mountinho Lda.

PORTUGAL

Gold

SAAMP

FRANCE

Gold

L'Orfebre S.A.

ANDORRA

Gold

8853 S.p.A.

ITALY

Gold

Italpreziosi

ITALY

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

GGC Gujrat Gold Centre Pvt. Ltd.

INDIA

Gold

Sai Refinery

INDIA

Gold

Modeltech Sdn Bhd

MALAYSIA

Gold

Bangalore Refinery

INDIA

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

Gold

Pease & Curren

UNITED STATES OF AMERICA

Gold

JALAN & Company

INDIA

Gold

SungEel HiMetal Co., Ltd.

KOREA, REPUBLIC OF

Gold

Planta Recuperadora de Metales SpA

CHILE

Gold

ABC Refinery Pty Ltd.

AUSTRALIA

Gold

Safimet S.p.A

ITALY

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

Gold

African Gold Refinery+

UGANDA

Gold

Gold Coast Refinery

GHANA

Gold

NH Recytech Company

KOREA, REPUBLIC OF

Gold

QG Refining, LLC

UNITED STATES OF AMERICA

Gold

Dijllah Gold Refinery FZC

UNITED ARAB EMIRATES

Gold

CGR Metalloys Pvt Ltd.

INDIA

Gold

Sovereign Metals

INDIA

Gold

C.I Metales Procesados Industriales SAS

COLOMBIA

Gold

Eco-System Recycling Co., Ltd. North Plant

JAPAN

Gold

Eco-System Recycling Co., Ltd. West Plant

JAPAN

Gold

Augmont Enterprises Private Limited

INDIA

Gold

Kundan Care Products Ltd.

INDIA

Gold

Emerald Jewel Industry India Limited (Unit 1)

INDIA

Gold

Emerald Jewel Industry India Limited (Unit 2)

INDIA

Gold

Emerald Jewel Industry India Limited (Unit 3)

INDIA

Gold

Emerald Jewel Industry India Limited (Unit 4)

INDIA

Gold

K.A. Rasmussen

NORWAY

Gold

Alexy Metals

UNITED STATES OF AMERICA

Gold

Sancus ZFS (L’Orfebre, SA)

COLOMBIA

Gold

Sellem Industries Ltd.

MAURITANIA

Gold

MD Overseas

INDIA

Gold

Metallix Refining Inc.

UNITED STATES OF AMERICA

Gold

Metal Concentrators SA (Pty) Ltd.

SOUTH AFRICA

+ On March 17, 2022, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) sanctioned this gold refinery in Uganda. Ormat has no direct business with the refinery. Through our due diligence examination, we identified our direct suppliers who reported utilizing the Ugandan refinery in their supply chain. We are in communication with the direct suppliers who listed this refinery to confirm if the refinery actually exists in our supply chain and will continue as necessary to follow-up to have this refinery removed from our supply chain.

 

 

 

Gold

WEEEREFINING

FRANCE

Gold

Value Trading

BELGIUM

Gold

Gold by Gold Colombia

COLOMBIA

Gold

Dongwu Gold Group

CHINA

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

Tantalum

Exotech Inc.

UNITED STATES OF AMERICA

Tantalum

F&X Electro-Materials Ltd.

CHINA

Tantalum

XIMEI RESOURCES (GUANGDONG) LIMITED

CHINA

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

Tantalum

AMG Brasil

BRAZIL

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

Tantalum

Mineracao Taboca S.A.

BRAZIL

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

Tantalum

NPM Silmet AS

ESTONIA

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

Tantalum

QuantumClean

UNITED STATES OF AMERICA

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

CHINA

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

Tantalum

Taki Chemical Co., Ltd.

JAPAN

Tantalum

Telex Metals

UNITED STATES OF AMERICA

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

Tantalum

D Block Metals, LLC

UNITED STATES OF AMERICA

Tantalum

FIR Metals & Resource Ltd.

CHINA

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

Tantalum

KEMET de Mexico

MEXICO

Tantalum

TANIOBIS Co., Ltd.

THAILAND

Tantalum

TANIOBIS GmbH

GERMANY

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

Tantalum

H.C. Starck Inc.

UNITED STATES OF AMERICA

Tantalum

TANIOBIS Japan Co., Ltd.

JAPAN

Tantalum

TANIOBIS Smelting GmbH & Co. KG

GERMANY

Tantalum

Global Advanced Metals Boyertown

UNITED STATES OF AMERICA

Tantalum

Global Advanced Metals Aizu

JAPAN

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

Tantalum

RFH Yancheng Jinye New Material Technology Co., Ltd.

CHINA

Tantalum

5D Production OU

ESTONIA

 

 

 

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

Tin

Alpha

UNITED STATES OF AMERICA

Tin

PT Aries Kencana Sejahtera

INDONESIA

Tin

Dowa

JAPAN

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

Tin

Estanho de Rondonia S.A.

BRAZIL

Tin

Fenix Metals

POLAND

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

Tin

China Tin Group Co., Ltd.

CHINA

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

Tin

Metallic Resources, Inc.

UNITED STATES OF AMERICA

Tin

Mineracao Taboca S.A.

BRAZIL

Tin

Minsur

PERU

Tin

Mitsubishi Materials Corporation

JAPAN

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

Tin

Novosibirsk Processing Plant Ltd.

RUSSIAN FEDERATION

Tin

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

THAILAND

Tin

Operaciones Metalurgicas S.A.

BOLIVIA (PLURINATIONAL STATE OF)

Tin

PT Artha Cipta Langgeng

INDONESIA

Tin

PT Babel Inti Perkasa

INDONESIA

Tin

PT Babel Surya Alam Lestari

INDONESIA

Tin

PT Belitung Industri Sejahtera

INDONESIA

Tin

PT Bukit Timah

INDONESIA

Tin

PT Mitra Stania Prima

INDONESIA

Tin

PT Panca Mega Persada

INDONESIA

Tin

PT Prima Timah Utama

INDONESIA

Tin

PT Refined Bangka Tin

INDONESIA

Tin

PT Sariwiguna Binasentosa

INDONESIA

Tin

PT Stanindo Inti Perkasa

INDONESIA

Tin

PT Timah Tbk Kundur

INDONESIA

Tin

PT Timah Tbk Mentok

INDONESIA

Tin

PT Timah Nusantara

INDONESIA

Tin

PT Tinindo Inter Nusa

INDONESIA

Tin

PT Tommy Utama

INDONESIA

Tin

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

Tin

Soft Metais Ltda.

BRAZIL

Tin

Thaisarco

THAILAND

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

Tin

VQB Mineral and Trading Group JSC

VIETNAM

 

 

 

Tin

White Solder Metalurgia e Mineracao Ltda.

BRAZIL

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

Tin

Tin Smelting Branch of Yunnan Tin Co., Ltd.

CHINA

Tin

CV Venus Inti Perkasa

INDONESIA

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

Tin

PT Tirus Putra Mandiri

INDONESIA

Tin

Melt Metais e Ligas S.A.

BRAZIL

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

Tin

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

VIETNAM

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIETNAM

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIETNAM

Tin

PT Cipta Persada Mulia

INDONESIA

Tin

An Vinh Joint Stock Mineral Processing Company

VIETNAM

Tin

Resind Industria e Comercio Ltda.

BRAZIL

Tin

Super Ligas

BRAZIL

Tin

Metallo Belgium N.V.

BELGIUM

Tin

Metallo Spain S.L.U.

SPAIN

Tin

PT Sukses Inti Makmur

INDONESIA

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

VIETNAM

Tin

PT Menara Cipta Mulia

INDONESIA

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

Tin

Modeltech Sdn Bhd

MALAYSIA

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

CHINA

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

Tin

PT Bangka Serumpun

INDONESIA

Tin

Pongpipat Company Limited

MYANMAR

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

CHINA

Tin

Ma'anshan Weitai Tin Co., Ltd.

CHINA

Tin

PT Masbro Alam Stania

INDONESIA

Tin

PT Rajawali Rimba Perkasa

INDONESIA

Tin

Luna Smelter, Ltd.

RWANDA

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

CHINA

Tin

Precious Minerals and Smelting Limited

INDIA

Tin

Gejiu City Fuxiang Industry and Trade Co., Ltd.

CHINA

Tin

PT Mitra Sukses Globalindo

INDONESIA

Tin

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

BRAZIL

Tin

CRM Synergies

SPAIN

 

 

 

Tin

Fabrica Auricchio Industria e Comercio Ltda.

BRAZIL

Tin

DS Myanmar

MYANMAR

Tin

PT Putera Sarana Shakti (PT PSS)

INDONESIA

Tungsten

A.L.M.T. Corp.

JAPAN

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES OF AMERICA

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

Tungsten

Japan New Metals Co., Ltd.

JAPAN

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

Tungsten

Wolfram Bergbau und Hutten AG

AUSTRIA

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

Tungsten

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

CHINA

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

Tungsten

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

CHINA

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

Tungsten

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

CHINA

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIETNAM

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

Tungsten

TANIOBIS Smelting GmbH & Co. KG

GERMANY

Tungsten

Masan High-Tech Materials

VIETNAM

Tungsten

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

CHINA

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

Tungsten

China Molybdenum Tungsten Co., Ltd.

CHINA

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

Tungsten

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

CHINA

Tungsten

ACL Metais Eireli

BRAZIL

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

 

 

 

Tungsten

KGETS Co., Ltd.

KOREA, REPUBLIC OF

Tungsten

Fujian Ganmin RareMetal Co., Ltd.

CHINA

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF CHINA

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

RUSSIAN FEDERATION

Tungsten

NPP Tyazhmetprom LLC

RUSSIAN FEDERATION

Tungsten

Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd.

CHINA

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

BRAZIL

Tungsten

Cronimet Brasil Ltda

BRAZIL

Tungsten

Artek LLC

RUSSIAN FEDERATION

Tungsten

Fujian Xinlu Tungsten

CHINA

Tungsten

OOO “Technolom” 2

RUSSIAN FEDERATION

Tungsten

OOO “Technolom” 1

RUSSIAN FEDERATION

Tungsten

LLC Vostok

RUSSIAN FEDERATION

Tungsten

YUDU ANSHENG TUNGSTEN CO., LTD.

CHINA

Tungsten

HANNAE FOR T Co., Ltd.

KOREA, REPUBLIC OF

 

 

 

 

Annex 2-Reasonable Country of Origin (RCOI) 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

MEXICO

MALAYSIA

RUSSIAN FEDERATION

COLOMBIA

RUSSIAN FEDERATION

MYANMAR

TAIWAN, PROVINCE OF CHINA

CZECHIA

THAILAND

PERU

UNITED STATES OF AMERICA

FRANCE

UNITED STATES OF AMERICA

PHILIPPINES

VIETNAM

GERMANY

 

POLAND

 

GHANA

 

RUSSIAN FEDERATION

 

INDIA

 

RWANDA

 

INDONESIA

 

SPAIN

 

ITALY

 

TAIWAN, PROVINCE OF CHINA

 

JAPAN

 

THAILAND

 

KAZAKHSTAN

 

UNITED STATES OF AMERICA

 

KOREA, REPUBLIC OF

 

VIETNAM

 

KYRGYZSTAN

     

LITHUANIA

     

MALAYSIA

     

MAURITANIA

     

MEXICO

     

NETHERLANDS

     

NEW ZEALAND

     

NORWAY

     

PHILIPPINES

     

POLAND

     

PORTUGAL

     

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 smelters or refiners 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 RCOI the closest indication provided as to the source of Conflict Minerals (i.e. the smelter or refiner country as reported in our relevant suppliers' CMRT declarations, if provided).