EX-1.01 2 a2021conflictmineralsreport.htm EX-1.01 Document


Exhibit 1.01

nVent Electric plc

Conflict Minerals Report
for the year ended December 31, 2020

Introduction and Summary

This Conflict Minerals Report (this “Report”) for the year ended December 31, 2020, is presented by nVent Electric plc (“nVent,” “we,” “our” or “us”) to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements pursuant to Section 13(p) of the Securities and Exchange Act of 1934 (“Section 13(p)”). The Rule imposes certain reporting obligations on SEC registrants who manufactured or contracted to manufacture products containing conflict minerals that are necessary to the functionality or production of those products. The term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are limited by the Rule to tin, tantalum and tungsten (“Subject Minerals”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The adjoining countries are the Republic of the Congo, the Central African Republic, South Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania and Angola (collectively with the DRC, the “Covered Countries”).

Following a determination that Subject Minerals were necessary to the functionality or production of products that we manufactured or contracted to be manufactured during the calendar year 2020, we conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the Subject Minerals in our products originated in the Covered Countries. Based on our RCOI, we believe it is possible that our products could contain Subject Minerals that may have originated in the Covered Countries and, therefore, in accordance with the Rule, we performed due diligence on the source and chain of custody of the Subject Minerals in question. We designed our due diligence measures to conform, in all material respects, with the nationally recognized due diligence framework in the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, and the related supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”).

Company Overview

This Report reflects the activities of nVent and all of its majority-owned subsidiaries and variable interest entities that are required to be consolidated.

nVent is a leading global provider of electrical connection and protection solutions. We believe our inventive electrical solutions enable safer systems and ensure a more secure world. We design, manufacture, market, install and service high performance products and solutions that connect and protect some of the world’s most sensitive equipment, buildings and critical processes. We offer a comprehensive range of enclosures, electrical connections and fastening and thermal management solutions across industry-leading brands that are recognized globally for quality, reliability and innovation.




Our broad range of products and solutions connect and protect our customers’ mission-critical equipment from hazardous conditions, improving their utilization, lowering costs and minimizing downtime. The cost of our products typically represents a small proportion of the total cost of our customers’ end systems. We also are a small cost relative to the potential cost of failure that our products help avoid. We have a portfolio of premier, industry-leading brands, including nVent CADDY, ERICO, ERIFLEX, HOFFMAN, LENTON, NUHEAT, PYROTENAX, RAYCHEM, SCHROFF and TRACER, some of which have a history spanning over 100 years, that cover a wide range of verticals, including Industrial, Commercial & Residential, Energy and Infrastructure.

Conflict Minerals Program & Policy

We have actively engaged with our customers and suppliers with respect to the use of Subject Minerals in the products we manufacture or contract to be manufactured.

In addition, we have adopted a Conflict Minerals Policy articulating our supply chain due diligence process and our commitment to our reporting obligations regarding Subject Minerals. Our policy is available on our website at https://www.nvent.com/en-us/supplier-conduct.

Reasonable Country of Origin Inquiry

To determine whether the necessary Subject Minerals in our products originated in one or more of the Covered Countries, we retained Assent Compliance (“Assent”), a third-party service provider, to assist us in reviewing our supply chain. We provided a list of suppliers to Assent for upload to the Assent Compliance Manager tool (“ACM”). We deemed it impractical to filter this list to exclude some possibly irrelevant suppliers because we could not determine definitively the presence or absence of Subject Minerals in all components and materials supplied to us for our products.

We utilized the Responsible Minerals Initiative (“RMI”)’s Conflict Minerals Reporting Template (“CMRT”), version 6.1 or higher, to conduct a survey of all in-scope suppliers. During the supplier survey, we contacted suppliers via the ACM, a web-based platform provided by Assent that enabled us to complete and track supplier communications and allowed our suppliers to upload completed CMRTs directly to the platform for assessment and management. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, Question 1 of the CMRT asks suppliers whether any Subject Minerals are intentionally added or used in their products or are used in their production processes. Question 2 also asks if any Subject Minerals remain in their products. We also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process. For example, we determined that any supplier that met one or more of the following criteria was out of scope:

The company supplies packaging only (excluding labels).

The company supplies us with items that do not end up in our products (including equipment used to make our products).

The company is a test lab.

The company is a service provider only.

The company supplies us with polymers, gasketing, glass or plastic windows or air filters.

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Assent requested that all remaining suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of the CMRT. Assent monitored and tracked all communications in the ACM for future reporting and transparency. We directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested that those suppliers complete the CMRT and submit their response to Assent.

Our program includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. For example:

Question 3 in the CMRT asks whether any of the supplier’s Subject Minerals originate from the Covered Countries. If a supplier provides related smelter or refiner information indicating that its Subject Minerals originated from a Covered Country, its response to this question must be “Yes.”

Question 6 in the CMRT asks whether the supplier has received information from all of its relevant Subject Mineral suppliers. If the supplier does not answer “Yes” to Question 6, then it cannot provide definitive responses to certain other questions in the CMRT.

Question 7 in the CMRT asks whether the supplier has identified all smelters and refiners in its supply chain. If the supplier answers “Yes” to Question 7, then the answer to Question 6 must also be “Yes.”

All submitted forms are accepted and classified as either valid or invalid so that data is still retained. Suppliers are contacted regarding invalid CMRT responses and are encouraged to resubmit a valid response. Suppliers are also provided with guidance on how to correct validation errors.

Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the RMI and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on the RMI’s list of validated conflict-free smelters and refiners of Subject Minerals. Our suppliers identified a total of 332 smelters and refiners that appear on the lists maintained by RMI. Of these 332 smelters and refiners, 260 have been validated as conflict-free by the RMI or a cross-recognized initiative and, based on information provided by the RMI, a further five smelters or refiners have agreed to undergo or are currently undergoing a third-party audit. Most of the CMRTs we received were made on a company- or division-level basis that did not allow us to identify which smelters or refiners listed by our suppliers actually processed the Subject Minerals contained in our products (if any).

Based on the results of this RCOI, we had reason to believe that some of the Subject Minerals in our products may have originated from the Covered Countries. As a result, in accordance with the Rule, we performed due diligence on the source and chain of custody of the Subject Minerals in question.

Design of Due Diligence

Our due diligence measures are designed to conform, in all material respects, with the framework in the OECD Guidance. The OECD Guidance identifies five aspects of due diligence that should be implemented and provides guidance as to how to implement each aspect. Our due diligence process design is intended to address each of these five aspects, namely:

1.Establishing strong company management systems regarding Subject Minerals.
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2.Identifying and assessing risks in our supply chain.

3.Designing and implementing a strategy to respond to identified risks in our supply chain.

4.Utilizing independent third-party audits of supply chain diligence.

5.Publicly reporting on our supply chain due diligence.

We are a downstream supplier, many steps removed from the mining of Subject Minerals. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, we do not purchase raw ore or unrefined Subject Minerals or make purchases directly from the Covered Countries. The origin of the Subject Minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other Subject Mineral-containing derivatives. The smelters and refiners consolidate raw ore and therefore have the most direct knowledge of the origin of the ores they procure.

The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1,” or direct, suppliers to provide information with respect to the origin of the Subject Minerals contained in the components and materials supplied to us.

Due Diligence Performed

1. Establish Strong Company Management Systems

Internal Compliance Team

We established a cross-functional conflict minerals compliance team that includes representatives from supply chain and material compliance, supported by the legal and finance teams. This team is responsible for implementing our Subject Mineral compliance strategy and briefing management about the results of our due diligence efforts.

We also use a third-party service provider, Assent, to assist us with evaluating supply chain information regarding Subject Minerals, identifying potential risks and in the development and implementation of additional due diligence steps that we will undertake with suppliers in regards to Subject Minerals.

Control Systems and Supplier Engagement

We expect all of our suppliers to have policies and procedures in place to ensure that any Subject Minerals used in the production of the products sold to us do not directly or indirectly finance or benefit armed groups in the Covered Countries. We rely on our direct suppliers to provide information on the origin of the Subject Minerals contained in components and materials supplied to us, including sources of Subject Minerals that are supplied to them from lower-tier suppliers.
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Our Supplier Code of Conduct applies to all direct suppliers and outlines certain expected behaviors and practices. We publicly post our Supplier Code of Conduct on our website, and if a supplier does not comply with its requirements, we take measures to evaluate whether to continue an ongoing relationship with that supplier. We review our Supplier Code of Conduct periodically to ensure it continues to align with industry best practices.

We also engage with suppliers directly to request that they complete a valid CMRT for the products that they supply to us. With respect to the recommendation in the OECD Guidance to strengthen engagement with suppliers, we have developed an internal procedure to engage with suppliers who do not provide valid CMRT responses.

Grievance Mechanisms

We have established grievance mechanisms, including an ethics hotline, whereby employees as well as suppliers and others outside of nVent can report violations of our policies, including with respect to Subject Mineral sourcing.

Maintain Records

We will retain documentation related to our Subject Mineral compliance program according to our corporate document retention policy.

2. Identifying and Assessing Risk in the Supply Chain

Due to our size, the complexity of our products and the depth, breadth and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in ACM based on criteria established for supplier responses in the system. These risks are addressed by Assent and members of our internal conflict minerals compliance team who contact the supplier, gather pertinent data and perform an assessment of the supplier’s Subject Mineral status.

One risk we identified with respect to the calendar year 2020 reporting period related to the nature of the responses received. A large number of the responses received provided data at a company or divisional level, or suppliers were unable to specify the smelters or refiners used for the Subject Minerals in the components and materials supplied to us. Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.

In accordance with OECD Guidance, it is important to identify and assess risks associated with Subject Minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified as being in our supply chain by suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a Subject Mineral processing facility that was operational during the 2020 calendar year.

In order to assess the risk that any of these smelters or refiners posed to our supply chain, Assent determined whether the smelter or refiner had been audited against a standard in conformance with the OECD Guidance, such as the RMI’s Responsible Minerals Assurance Process (“RMAP”). We do not typically have a direct relationship with Subject Mineral smelters and refiners and do not perform or
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direct audits of these entities within our supply chain. In cases where the smelter’s or refiner’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.

As of May 14, 2021, we have validated 336 smelters or refiners as being in our supply chain. Because the vast majority of our suppliers submitted company- or divisional-level CMRTs, we cannot definitely determine the connection between any of those 336 smelters or refiners and the products we manufactured or contracted to be manufactured during calendar year 2020.

Each facility that meets the RMI definition of a smelter or refiner of Subject Minerals is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

Geographic proximity to the DRC and Covered Countries.

Limited known reserves or stocks of the applicable Subject Mineral in the country of origin.

RMAP audit status.

Credible evidence of unethical or conflict-related sourcing.

Peer assessments conducted by credible third-party sources.

As part of our risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed, we initiate risk mitigation activities. Through Assent, submissions that include any red-flag facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submitting a product-specific CMRT to us to better identify the connection between the red-flagged facility and the components and materials they supply to nVent and potentially removing the red-flagged smelter or refiner from their supply chain. Pursuant to the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to Assent’s training platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

Additionally, suppliers are evaluated by Assent on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Guidance and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:

Question A – Have you established a conflict minerals sourcing policy?

Question D – Have you implemented due diligence measures for conflict-free sourcing?

Question F – Do you review due diligence information received from your suppliers against your company’s expectations?

Question G – Does your review process include corrective action management?

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When suppliers meet or exceed those criteria (by answering “Yes” to at least those four questions), we consider them to have a strong Subject Mineral compliance program. When suppliers do not meet those criteria, we consider them to have a weak Subject Mineral compliance program. At this time, we have identified 51 of our 486 suppliers, or 10.5%, who submitted a valid CMRT response as having a weak program. In 2021, we will further review weak submissions and continue to work with our Suppliers to reinforce our expectations under the nVent Supplier Code of Conduct.

3. Design and Implement a Strategy to Respond to Risks

Together with Assent, we developed processes to assess and respond to the risks identified in our supply chain. We send a series of escalating communications to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the Rule.

4. Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

We do not have a direct relationship with any Subject Mineral smelters or refiners and do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private-sector auditors to audit the source, including the mines of origin and the chain of custody of the Subject Minerals used by smelters and refiners that agree to participate in the program. Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners.

5. Public Reporting on Supply Chain Due Diligence

We have published our Form SD for the year ended December 31, 2020 and this Report in the Investor Relations section of our website at https://investors.nvent.com/financial-information/sec-filings/default.aspx. Information found on or accessed through our website is not considered part of this Report and is not incorporated by reference herein. We have also publicly filed our Form SD and this Report with the SEC.

Due Diligence Results

Survey Results

For the calendar year 2020, we received CMRT responses from 73% of suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found.

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Smelters and Refiners

Attached as Appendix A is a list of all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Since many of the CMRTs we received from our suppliers were made on a company- or division-level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed on Appendix A actually processed the Subject Minerals contained in our products. Therefore, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that actually processed the Subject Minerals contained in our products.

From the responses that we received, we identified five smelters that potentially pose a risk due to the presence of some red-flag indicators. For suppliers that identified these specific smelters of concern on their CMRT, we created a new escalation plan. Assent contacted those suppliers to evaluate whether the red-flagged smelters and refiners could be connected to nVent products. The suppliers were asked to complete a product-level CMRT, rather than a company-level CMRT, to better identify the connection to products that they supply to us. Other suppliers were evaluated internally to determine whether they were in fact still active suppliers. If not, they were removed from the scope of data collection.

Countries of Origin

Attached as Appendix B is a list of potential countries of origin for the Subject Minerals contained in the products covered by this Report. We do not have sufficient information to conclusively determine the country of origin of the Subject Minerals contained in the products covered by this Report or to conclusively determine whether our Subject Minerals are from recycled or scrap sources. However, based on the information provided by our suppliers and the smelters and refiners in our supply chain, as well as from the RMI and other sources, we believe the countries of origin of the Subject Minerals contained in our products may potentially include the countries listed in Appendix B to this Report, as well as recycled or scrap sources.

Steps to be Taken to Mitigate Risk

Since becoming an independent, publicly traded company on April 30, 2018, we have taken the following steps to improve our due diligence efforts, to further mitigate any risk that the necessary Subject Minerals in our products could benefit armed groups in the DRC or the other Covered Countries:

Work more closely with our third-party service provider to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process the Subject Minerals contained in our products.

Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of Subject Minerals.

Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.

Continue to include a Subject Mineral flow-down clause in new or renewed supplier contracts as well as included in the terms and conditions of each purchase order issued.

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Increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program.

Forward-Looking Statements
This Report contains statements that we believe to be "forward-looking statements" within the meaning of the Private Securities Litigation Reform Act of 1995. All statements, other than statements of historical fact, included in this Report, including, without limitation, statements regarding our Subject Mineral compliance plans, are forward-looking statements. These forward-looking statements generally are identified by the words "targets," "plans," "believes," "expects," "intends," "will," "likely," "may," "anticipates," "estimates," "projects," "forecasts," "should," "would," "positioned," "strategy," "future," "are confident," or words, phrases or terms of similar substance or the negative thereof. These forward-looking statements are not guarantees of future performance and are subject to risks, uncertainties, assumptions and other factors, some of which are beyond our control. Numerous important factors described in this Report, including, among others, our ability to implement new software systems, our suppliers’ willingness and ability to comply with our Subject Mineral-related compliance requests, the degree to which we are able to determine our suppliers’ use of conflict-free smelters and refiners, the impact of industry-wide initiatives such as the RMAP, smelters’ and refiners’ willingness and ability to comply with the RMAP, our effectiveness in managing the Subject Mineral RCOI and due diligence processes and the costs of our compliance, could affect these statements and could cause actual results to differ materially from our expectations. All forward-looking statements speak only as of the date of this Report. We assume no obligation, and disclaim any duty, to update or revise publicly any forward-looking statements, whether as a result of new information, future events or otherwise.

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Appendix A

List of Smelters and Refiners
MetalSmelter NameSmelter Facility LocationSmelter ID
Gold8853 S.p.A.ITALYCID002763
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICACID002708
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICACID000015
GoldAfrican Gold RefineryUGANDACID003185
GoldAida Chemical Industries Co., Ltd.JAPANCID000019
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESCID002560
GoldAlexy MetalsUNITED STATES OF AMERICACID003500
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYCID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILCID000058
GoldArgor-Heraeus S.A.SWITZERLANDCID000077
GoldAsahi Pretec Corp.JAPANCID000082
GoldAsahi Refining Canada Ltd.CANADACID000924
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICACID000920
GoldAsaka Riken Co., Ltd.JAPANCID000090
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYCID000103
GoldAU Traders and RefinersSOUTH AFRICACID002850
GoldAugmont Enterprises Private LimitedINDIACID003461
GoldAurubis AGGERMANYCID000113
GoldBangalore RefineryINDIACID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESCID000128
GoldBoliden ABSWEDENCID000157
GoldC. Hafner GmbH + Co. KGGERMANYCID000176
GoldC.I Metales Procesados Industriales SASCOLOMBIACID003421
GoldCaridadMEXICOCID000180
GoldCCR Refinery - Glencore Canada CorporationCANADACID000185
GoldCendres + Metaux S.A.SWITZERLANDCID000189
GoldCGR Metalloys Pvt Ltd.INDIACID003382
GoldChimet S.p.A.ITALYCID000233
GoldChugai MiningJAPANCID000264
GoldDaye Non-Ferrous Metals Mining Ltd.CHINACID000343
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYCID002867
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATESCID003348
GoldDODUCO Contacts and Refining GmbHGERMANYCID000362
GoldDowaJAPANCID000401
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OFCID003195
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFCID000359
A-1


MetalSmelter NameSmelter Facility LocationSmelter ID
GoldEco-System Recycling Co., Ltd. East PlantJAPANCID000425
GoldEco-System Recycling Co., Ltd. North PlantJAPANCID003424
GoldEco-System Recycling Co., Ltd. West PlantJAPANCID003425
GoldEmerald Jewel Industry India Limited (Unit 1)INDIACID003487
GoldEmerald Jewel Industry India Limited (Unit 2)INDIACID003488
GoldEmerald Jewel Industry India Limited (Unit 3)INDIACID003489
GoldEmerald Jewel Industry India Limited (Unit 4)INDIACID003490
GoldEmirates Gold DMCCUNITED ARAB EMIRATESCID002561
GoldFidelity Printers and Refiners Ltd.ZIMBABWECID002515
GoldFujairah Gold FZCUNITED ARAB EMIRATESCID002584
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIACID002852
GoldGeib Refining CorporationUNITED STATES OF AMERICACID002459
GoldGold Coast RefineryGHANACID003186
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINACID002243
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINACID001909
GoldGuangdong Jinding Gold LimitedCHINACID002312
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINACID000651
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINACID000671
GoldHeimerle + Meule GmbHGERMANYCID000694
GoldHeraeus Metals Hong Kong Ltd.CHINACID000707
GoldHeraeus Precious Metals GmbH & Co. KGGERMANYCID000711
GoldHunan Chenzhou Mining Co., Ltd.CHINACID000767
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINACID000773
GoldHwaSeong CJ CO., LTD.KOREA, REPUBLIC OFCID000778
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINACID000801
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATESCID002562
GoldIshifuku Metal Industry Co., Ltd.JAPANCID000807
GoldIstanbul Gold RefineryTURKEYCID000814
GoldItalpreziosiITALYCID002765
GoldJALAN & CompanyINDIACID002893
GoldJapan MintJAPANCID000823
GoldJiangxi Copper Co., Ltd.CHINACID000855
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATIONCID000927
GoldJSC UralelectromedRUSSIAN FEDERATIONCID000929
GoldJX Nippon Mining & Metals Co., Ltd.JAPANCID000937
GoldK.A. RasmussenNORWAYCID003497
GoldKaloti Precious MetalsUNITED ARAB EMIRATESCID002563
GoldKazakhmys Smelting LLCKAZAKHSTANCID000956
GoldKazzincKAZAKHSTANCID000957
A-2


MetalSmelter NameSmelter Facility LocationSmelter ID
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICACID000969
GoldKGHM Polska Miedz Spolka AkcyjnaPOLANDCID002511
GoldKojima Chemicals Co., Ltd.JAPANCID000981
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFCID002605
GoldKundan Care Products Ltd.INDIACID003463
GoldKyrgyzaltyn JSCKYRGYZSTANCID001029
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONCID002865
GoldL'azurde Company For JewelrySAUDI ARABIACID001032
GoldLingbao Gold Co., Ltd.CHINACID001056
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINACID001058
GoldL'Orfebre S.A.ANDORRACID002762
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFCID001078
GoldLT Metal Ltd.KOREA, REPUBLIC OFCID000689
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINACID001093
GoldMarsam MetalsBRAZILCID002606
GoldMaterionUNITED STATES OF AMERICACID001113
GoldMatsuda Sangyo Co., Ltd.JAPANCID001119
GoldMD OverseasINDIACID003548
GoldMetal Concentrators SA (Pty) Ltd.SOUTH AFRICACID003575
GoldMetallix Refining Inc.UNITED STATES OF AMERICACID003557
GoldMetalor Technologies (Hong Kong) Ltd.CHINACID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORECID001152
GoldMetalor Technologies (Suzhou) Ltd.CHINACID001147
GoldMetalor Technologies S.A.SWITZERLANDCID001153
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICACID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOCID001161
GoldMitsubishi Materials CorporationJAPANCID001188
GoldMitsui Mining and Smelting Co., Ltd.JAPANCID001193
GoldMMTC-PAMP India Pvt., Ltd.INDIACID002509
GoldModeltech Sdn BhdMALAYSIACID002857
GoldMorris and WatsonNEW ZEALANDCID002282
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYCID001220
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANCID001236
GoldNH Recytech CompanyKOREA, REPUBLIC OFCID003189
GoldNihon Material Co., Ltd.JAPANCID001259
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIACID002779
GoldOhura Precious Metal Industry Co., Ltd.JAPANCID001325
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONCID001326
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATIONCID000493
GoldPAMP S.A.SWITZERLANDCID001352
A-3


MetalSmelter NameSmelter Facility LocationSmelter ID
GoldPease & CurrenUNITED STATES OF AMERICACID002872
GoldPenglai Penggang Gold Industry Co., Ltd.CHINACID001362
GoldPlanta Recuperadora de Metales SpACHILECID002919
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONCID001386
GoldPT Aneka Tambang (Persero) TbkINDONESIACID001397
GoldPX Precinox S.A.SWITZERLANDCID001498
GoldQG Refining, LLCUNITED STATES OF AMERICACID003324
GoldRand Refinery (Pty) Ltd.SOUTH AFRICACID001512
GoldRefinery of Seemine Gold Co., Ltd.CHINACID000522
GoldREMONDIS PMR B.V.NETHERLANDSCID002582
GoldRoyal Canadian MintCANADACID001534
GoldSAAMPFRANCECID002761
GoldSabin Metal Corp.UNITED STATES OF AMERICACID001546
GoldSafimet S.p.AITALYCID002973
GoldSAFINA A.S.CZECH REPUBLICCID002290
GoldSai RefineryINDIACID002853
GoldSamduck Precious MetalsKOREA, REPUBLIC OFCID001555
GoldSamwon Metals Corp.KOREA, REPUBLIC OFCID001562
GoldSancus ZFS (L’Orfebre, SA)COLOMBIACID003529
GoldSAXONIA Edelmetalle GmbHGERMANYCID002777
GoldSellem Industries Ltd.MAURITANIACID003540
GoldSEMPSA Joyeria Plateria S.A.SPAINCID001585
GoldShandong Humon Smelting Co., Ltd.CHINACID002525
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINACID001619
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACID001622
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CHINACID002527
GoldShirpur Gold Refinery Ltd.INDIACID002588
GoldSichuan Tianze Precious Metals Co., Ltd.CHINACID001736
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINACID002516
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONCID001756
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINACID001761
GoldSovereign MetalsINDIACID003383
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIACID003153
GoldSudan Gold RefinerySUDANCID002567
GoldSumitomo Metal Mining Co., Ltd.JAPANCID001798
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFCID002918
GoldT.C.A S.p.AITALYCID002580
GoldTanaka Kikinzoku Kogyo K.K.JAPANCID001875
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINACID001916
A-4


MetalSmelter NameSmelter Facility LocationSmelter ID
GoldTokuriki Honten Co., Ltd.JAPANCID001938
GoldTongling Nonferrous Metals Group Co., Ltd.CHINACID001947
GoldTony Goetz NVBELGIUMCID002587
GoldTOO Tau-Ken-AltynKAZAKHSTANCID002615
GoldTorecomKOREA, REPUBLIC OFCID001955
GoldUmicore Precious Metals ThailandTHAILANDCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMCID001980
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICACID001993
GoldValcambi S.A.SWITZERLANDCID002003
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIACID002030
GoldWIELAND Edelmetalle GmbHGERMANYCID002778
GoldYamakin Co., Ltd.JAPANCID002100
GoldYokohama Metal Co., Ltd.JAPANCID002129
GoldYunnan Copper Industry Co., Ltd.CHINACID000197
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACID002224
TantalumAsaka Riken Co., Ltd.JAPANCID000092
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINACID000211
TantalumD Block Metals, LLCUNITED STATES OF AMERICACID002504
TantalumExotech Inc.UNITED STATES OF AMERICACID000456
TantalumF&X Electro-Materials Ltd.CHINACID000460
TantalumFIR Metals & Resource Ltd.CHINACID002505
TantalumGlobal Advanced Metals AizuJAPANCID002558
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICACID002557
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINACID000616
TantalumH.C. Starck Co., Ltd.THAILANDCID002544
TantalumH.C. Starck Hermsdorf GmbHGERMANYCID002547
TantalumH.C. Starck Inc.UNITED STATES OF AMERICACID002548
TantalumH.C. Starck Ltd.JAPANCID002549
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANYCID002550
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANYCID002545
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINACID002492
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACID002512
TantalumJiangxi Tuohong New Raw MaterialCHINACID002842
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACID000914
TantalumJiujiang Tanbre Co., Ltd.CHINACID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACID002506
TantalumKEMET Blue MetalsMEXICOCID002539
TantalumLSM Brasil S.A.BRAZILCID001076
TantalumMetallurgical Products India Pvt., Ltd.INDIACID001163
TantalumMineracao Taboca S.A.BRAZILCID001175
A-5


MetalSmelter NameSmelter Facility LocationSmelter ID
TantalumMitsui Mining and Smelting Co., Ltd.JAPANCID001192
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINACID001277
TantalumNPM Silmet ASESTONIACID001200
TantalumPRG DooelNORTH MACEDONIA, REPUBLIC OFCID002847
TantalumQuantumCleanUNITED STATES OF AMERICACID001508
TantalumResind Industria e Comercio Ltda.BRAZILCID002707
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONCID001769
TantalumTaki Chemical Co., Ltd.JAPANCID001869
TantalumTelex MetalsUNITED STATES OF AMERICACID001891
TantalumUlba Metallurgical Plant JSCKAZAKHSTANCID001969
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINACID002508
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINACID001522
TinAlphaUNITED STATES OF AMERICACID000292
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAMCID002703
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINACID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINACID003190
TinChina Tin Group Co., Ltd.CHINACID001070
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBRAZILCID003486
TinCRM SynergiesSPAINCID003524
TinCV Ayi JayaINDONESIACID002570
TinCV Venus Inti PerkasaINDONESIACID002455
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINACID003356
TinDowaJAPANCID000402
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAMCID002572
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)CID000438
TinEstanho de Rondonia S.A.BRAZILCID000448
TinFenix MetalsPOLANDCID000468
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINACID003410
TinGejiu Fengming Metallurgy Chemical PlantCHINACID002848
TinGejiu Kai Meng Industry and Trade LLCCHINACID000942
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINACID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINACID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINACID000555
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACID003116
TinHuiChang Hill Tin Industry Co., Ltd.CHINACID002844
TinJiangxi New Nanshan Technology Ltd.CHINACID001231
TinLuna Smelter, Ltd.RWANDACID003387
TinMa'anshan Weitai Tin Co., Ltd.CHINACID003379
A-6


MetalSmelter NameSmelter Facility LocationSmelter ID
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILCID002468
TinMalaysia Smelting Corporation (MSC)MALAYSIACID001105
TinMelt Metais e Ligas S.A.BRAZILCID002500
TinMetallic Resources, Inc.UNITED STATES OF AMERICACID001142
TinMetallo Belgium N.V.BELGIUMCID002773
TinMetallo Spain S.L.U.SPAINCID002774
TinMineracao Taboca S.A.BRAZILCID001173
TinMinsurPERUCID001182
TinMitsubishi Materials CorporationJAPANCID001191
TinModeltech Sdn BhdMALAYSIACID002858
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002573
TinNovosibirsk Processing Plant Ltd.RUSSIAN FEDERATIONCID001305
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDCID001314
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESCID002517
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)CID001337
TinPongpipat Company LimitedMYANMARCID003208
TinPrecious Minerals and Smelting LimitedINDIACID003409
TinPT Aries Kencana SejahteraINDONESIACID000309
TinPT Artha Cipta LanggengINDONESIACID001399
TinPT ATD Makmur Mandiri JayaINDONESIACID002503
TinPT Babel Inti PerkasaINDONESIACID001402
TinPT Babel Surya Alam LestariINDONESIACID001406
TinPT Bangka SerumpunINDONESIACID003205
TinPT Bukit TimahINDONESIACID001428
TinPT Cipta Persada MuliaINDONESIACID002696
TinPT Lautan Harmonis SejahteraINDONESIACID002870
TinPT Menara Cipta MuliaINDONESIACID002835
TinPT Mitra Stania PrimaINDONESIACID001453
TinPT Mitra Sukses GlobalindoINDONESIACID003449
TinPT Prima Timah UtamaINDONESIACID001458
TinPT Rajawali Rimba PerkasaINDONESIACID003381
TinPT Rajehan AriqINDONESIACID002593
TinPT Refined Bangka TinINDONESIACID001460
TinPT Stanindo Inti PerkasaINDONESIACID001468
TinPT Sukses Inti MakmurINDONESIACID002816
TinPT Timah NusantaraINDONESIACID001486
TinPT Timah Tbk KundurINDONESIACID001477
TinPT Timah Tbk MentokINDONESIACID001482
TinPT Tinindo Inter NusaINDONESIACID001490
TinResind Industria e Comercio Ltda.BRAZILCID002706
TinRui Da HungTAIWAN, PROVINCE OF CHINACID001539
A-7


MetalSmelter NameSmelter Facility LocationSmelter ID
TinSoft Metais Ltda.BRAZILCID001758
TinSuper LigasBRAZILCID002756
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMCID002834
TinThaisarcoTHAILANDCID001898
TinTin Technology & RefiningUNITED STATES OF AMERICACID003325
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002574
TinVQB Mineral and Trading Group JSCVIET NAMCID002015
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACID002158
TinYunnan Tin Company LimitedCHINACID002180
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINACID003397
TungstenA.L.M.T. Corp.JAPANCID000004
TungstenACL Metais EireliBRAZILCID002833
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILCID003427
TungstenArtek LLCRUSSIAN FEDERATIONCID003553
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMCID002502
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINACID002513
TungstenChina Molybdenum Co., Ltd.CHINACID002641
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINACID000258
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINACID000281
TungstenCronimet Brasil LtdaBRAZILCID003468
TungstenFujian Ganmin RareMetal Co., Ltd.CHINACID003401
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINACID002645
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINACID000875
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINACID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINACID002494
TungstenGEM Co., Ltd.CHINACID003417
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICACID000568
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINACID000218
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANYCID002542
TungstenH.C. Starck Tungsten GmbHGERMANYCID002541
TungstenHunan Chenzhou Mining Co., Ltd.CHINACID000766
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINACID000769
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONCID002649
TungstenJapan New Metals Co., Ltd.JAPANCID000825
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINACID002551
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINACID002321
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINACID002313
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINACID002318
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINACID002317
A-8


MetalSmelter NameSmelter Facility LocationSmelter ID
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINACID002316
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONCID003408
TungstenKennametal FallonUNITED STATES OF AMERICACID000966
TungstenKennametal HuntsvilleUNITED STATES OF AMERICACID000105
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OFCID003388
A-9


Appendix B

List of Countries of Origin for Subject Minerals

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company- or division-level responses and therefore we cannot be certain whether all of these countries of origin can be linked to our products.
AfghanistanGermanyNigeria
AlbaniaGhanaNorway
AngolaGuineaPapua New Guinea
ArgentinaGuyanaPeru
ArmeniaHungaryPhilippines
AustraliaIndiaPoland
AustriaIndonesiaPortugal
BelarusIrelandRepublic of Korea
BelgiumIsraelRussia
BermudaItalyRwanda
BoliviaIvory CoastSaudi Arabia
BrazilJapanSierra Leone
BulgariaKazakhstanSingapore
BurundiKenyaSlovakia
CambodiaKyrgyzstanSlovenia
CanadaLaosSouth Africa
Central African RepublicLiberiaSpain
ChileLithuaniaSudan
ChinaLuxembourgSuriname
ColombiaMadagascarSweden
Czech RepublicMalaysiaSwitzerland
DjiboutiMaliTanzania
Dominican RepublicMauritaniaThailand
DRC or an adjoining country (Covered Countries)MexicoTurkey
MongoliaUganda
EcuadorMoroccoUnited Arab Emirates
EgyptMozambiqueUnited Kingdom
EnglandMyanmarUSA
EstoniaNamibiaUzbekistan
EthiopiaNetherlandsViet Nam
FinlandNew ZealandZambia
FranceNigerZimbabwe

B-1