EX-1.01 2 hd_exx101xsdx123119.htm CONFLICT MINERALS REPORT Exhibit


Exhibit 1.01

Conflict Minerals Report of The Home Depot, Inc.
for the Calendar Year Ended December 31, 2019

This is the Conflict Minerals Report (“CMR”) of The Home Depot, Inc. for the reporting period from January 1 to December 31, 2019, in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”). When we refer to “The Home Depot,” the “Company,” “we,” “us” or “our” in this report, we are referring to The Home Depot, Inc. and its consolidated subsidiaries.

Overview

This CMR provides a description of the measures that The Home Depot has taken to determine the origin of the gold, tantalum, tin and tungsten (“conflict minerals” or “3TG”) that were necessary to the functionality or production of products that the Company contracted to manufacture in 2019. The products that we contracted to manufacture (the “Covered Products”) during the reporting period are: Flooring, Paint, Hardware, Tools, Electrical/Lighting, Indoor Garden, Outdoor Garden, Appliances, Kitchen and Bath, and Décor/Storage.

Notwithstanding our due diligence process described herein, we are unable to determine the source of all conflict minerals that are necessary to the functionality or production of the Covered Products or whether these conflict minerals directly or indirectly financed or benefited armed groups in the Democratic Republic of the Congo and adjoining countries (the “Covered Countries”).

Reasonable Country of Origin Inquiry

Introduction
We engaged a third-party service provider, Source Intelligence, to assist us with data collection and aggregation. Together, we worked with our suppliers to collect information about the presence and sourcing of 3TG used in the Covered Products. Information regarding the presence of 3TG in a supplier’s products and the source of such 3TG, if present, was collected and stored using an online platform that utilized the Conflict Minerals Reporting Template (the “Template”) developed by the Responsible Minerals Initiative (“RMI”, formerly known as the Conflict-Free Sourcing Initiative), which was founded by members of the Responsible Business Alliance and the Global e-Sustainability Initiative.






Products in Scope
We compiled a list of all Covered Products and worked with our third-party service provider to determine which Covered Products were in scope for potential use of 3TG and therefore required a Reasonable Country of Origin Inquiry (“RCOI”). If there was any doubt regarding the material content or the possible use of 3TG, the Covered Products were included in the RCOI process.

Supplier Engagement
We identified the suppliers with whom we contract directly (“Tier 1 Suppliers”) for the in-scope Covered Products and contacted them as a part of the RCOI process.

The RCOI began with an introduction email on September 30, 2019, from us to the Tier 1 Suppliers describing our Conflict Minerals Compliance Program (the “CMCP”) requirements. The Tier 1 Suppliers then were sent a follow-up email containing registration information and a request to complete the Template and were directed to a Conflict Minerals Supplier Resource Center. The Conflict Minerals Supplier Resource Center provides an educational primer on the CMCP and includes frequently asked questions concerning 3TG mineral tracing.

Non-responsive Tier 1 Suppliers received several follow-up contacts to encourage completion of the Template. The Tier 1 Suppliers that remained non-responsive were contacted and offered assistance. This assistance included, but was not limited to, further information about the CMCP, an explanation of why the information was being collected, a review of how the information would be used, and clarification regarding how the required information could be provided. Tier 1 Suppliers who failed to respond to our earlier contacts received a re-invitation to the platform. They were also contacted by our managers who maintain direct relationships with these suppliers and were further urged to respond in a timely manner.

Due Diligence Program Design
Following completion of the RCOI, we proceeded to the due diligence process to determine the source of any 3TG in the Covered Products. We conducted a due diligence process based on the Organization for Economic Cooperation and Development’s (“OECD’s”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements1 (the “OECD Guidance”).
_____________________________
1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Supplement on Tin, Tantalum and Tungsten and Supplement on Gold, 2016; http://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf.

2



The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. This framework consists of the following elements:
1.
Establish strong company management systems (“Step One”);
2.
Identify and assess risk in the supply chain (“Step Two”);
3.
Design and implement a strategy to respond to identified risks (“Step Three”);
4.
Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain (“Step Four”); and
5.
Report on supply chain due diligence (“Step Five”).

Due Diligence Program Execution

Consistent with the framework above and in furtherance of our Conflict Minerals due diligence for 2019, we performed the following measures:

OECD Guidance Step One: Establish strong company management systems

(a)
We maintained a policy relating to conflict minerals in our supply chain (“Conflict Minerals Policy”). Our Conflict Minerals Policy is publicly available at https://corporate.homedepot.com/conflictminerals. It states:

The Home Depot Conflict Minerals Policy

The Home Depot is committed to ensuring compliance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to trade in conflict minerals.

The conflict minerals law was enacted to address the exploitation and trade of certain minerals that contribute to violence and human rights abuses in the Democratic Republic of the Congo and its neighboring countries in Africa (“Covered Countries”). The law requires public companies to report to the U.S. Securities and Exchange Commission and disclose information annually about whether the defined conflict minerals – gold, columbite-tantalite (tantalum), cassiterite (tin), and wolframite (tungsten) – are necessary to the functionality or production of products they manufacture or contract to manufacture, and, if so, whether those conflict minerals are sourced from smelters or refiners that have been certified as “DRC conflict free”.

The Home Depot is committed to the responsible sourcing of materials for our products, and we expect that our suppliers are likewise committed to responsible sourcing. We expect all suppliers manufacturing our products to partner with us to provide appropriate information

3



and conduct necessary due diligence in order to facilitate our compliance with the conflict minerals law. We further expect all suppliers manufacturing our products to adopt sourcing practices to obtain products and materials from suppliers not involved in funding conflict in the Covered Countries.

The Home Depot provides a Supplier AlertLine for the exclusive use of suppliers to report violations of company policies, including the Conflict Minerals Policy. Suppliers may contact the Supplier AlertLine at THDsupplieralertline.com or by using the following toll-free numbers:
United States and Canada: 1-800-435-3152
Mexico: 001-888-765-8153
China: 400-8-801-045
India: (Access Code) 000-117, (Dial) 800-435-3152
Vietnam: (Access Code) 1-201-0288, (Dial) 800-435-3152

(b)
We continued to include the Conflict Minerals Policy in our current Supplier Buying Agreement.

OECD Guidance Step Two: Identify and assess risk in the supply chain

(a)
After completion of the RCOI, as described above, Tier 1 Suppliers who indicated that 3TG was necessary to the functionality or production of Covered Products supplied to us were asked to provide information through the Template regarding the sourcing and origin of the 3TG (i.e., the 3TG smelters or refiners, or “SORs”). To the extent applicable, where a Tier 1 Supplier did not provide detailed information about the SORs in its supply chain, we contacted the applicable suppliers of the Tier 1 Suppliers (“Tier 2 Suppliers”), and subsequent tiers of suppliers as needed to obtain the necessary information, using the contact procedures explained above. Collectively, the Tier 1 Suppliers, Tier 2 Suppliers and any suppliers working backward from the Tier 2 Suppliers are referred to in this report as “Suppliers”.

(b)
Based on information provided by the Suppliers, we used the following criteria to determine which Covered Products that contained 3TG necessary to the functionality or production of such product to include in the due diligence process:

a.
The Suppliers reported sourcing from the Covered Countries (“yes” response to Question 2 of the Template);
b.
The SOR data indicated sourcing from a mine located in the Covered Countries;
c.
The SOR reportedly sourced from a mine located in the Covered Countries (based on information contained within the third-party service provider’s system, from independent certification programs, or from internet research/available public reports);

4



d.
There was an indication that the SOR sourced from a Covered Country or a country that is known for smuggling or exporting 3TG out of a Covered Country; or
e.
Information provided about a SOR indicated the origin of the materials was not from a known reserve for the given metal.

(c)
We evaluated the responses we received from Suppliers. Suppliers were contacted to address issues, including: implausible statements regarding no presence of 3TG; incomplete data on their Templates; responses that did not identify SORs; responses that indicated sourcing location without complete supporting information from the supply chain; and organizations that were identified as SORs, but not verified as such through further analysis and research.

(d)
When SOR data was obtained, we used the existing SOR database of Source Intelligence, the RMI’s list of SORs, internet research, and other resources (e.g., government databases and industry and trade organization lists) to verify whether entities identified as SORs are actually 3TG SORs. Where we found that an entity named as a SOR was not directly involved in the smelting or recycling of the relevant metal, the Supplier that provided this information was contacted to attempt to obtain additional information about the origin of the materials or information about its direct suppliers. If contact information was provided, or could be obtained, for the entity listed as a SOR, the listed entity was also contacted to obtain additional information about the origin of materials used. We also investigated Supplier statements that a SOR did not source from the Covered Countries when the stated sourcing location (country of mine origin) was not a known reserve for the given metal.

OECD Guidance Step Three: Design and implement a strategy to respond to identified risks

(a)
We reported the findings of our supply chain risk assessment as outlined in this CMR to our General Counsel and supply chain senior leadership.

(b)
We took such risk mitigation efforts as we deemed to be appropriate based on the findings of our supply chain risk assessment. These risk mitigation efforts were determined by taking into account the particular facts, circumstances and risks identified with respect to our supply chain over the course of 2019.

(c)
To mitigate the risk that our necessary 3TG benefit armed groups, we intend to engage in the additional measures discussed under “Addressing Identified Risks” below.


5



OECD Guidance Step Four: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain

In connection with our due diligence, we utilized information made available by the RMI (which administers the Responsible Minerals Assurance Process), the London Bullion Market Association (“LBMA”), and the Responsible Jewellery Council (“RJC”) concerning independent third-party audits of smelters and refiners.

OECD Guidance Step 5: Report on supply chain due diligence

We filed a Form SD and this Conflict Minerals Report with the Securities and Exchange Commission and made available on our website this Conflict Minerals Report and the Form SD.

Summary of Findings

A total of 71 Tier 1 Suppliers were identified as in-scope for conflict mineral regulatory purposes and contacted as part of the RCOI process. The response rate among these Suppliers was one hundred percent (100%). Forty-four percent (44%) of the Suppliers indicated one or more of the conflict minerals as necessary to the functionality or production of the Covered Products.

Based on the information provided by our Tier 1 Suppliers and our own due diligence efforts with known smelters and refiners through December 31, 2019, we believe that the facilities that may have been used to process the conflict minerals in the Covered Products include the 289 SORs listed in Annex I. Of the 289 SORs, nine are listed in Annex I for processing multiple different metals; only 280 were uniquely identified. Based on review of certain SOR databases, there was an indication of sourcing from the Covered Countries for 45 out of the 280 uniquely identified SORs. Of the 45 SORs with an indication of sourcing in the Covered Countries, 44 were certified as DRC Conflict Free by either the RMI, LBMA or RJC.

In 2019, we were successful in obtaining a 100% survey response rate from our Tier 1 Suppliers. However, a small number of our Suppliers below the Tier 1 level were unable to complete chain-of-custody surveys back to the level of the SORs. As a result, we do not have sufficient information to conclusively determine whether any 3TG originating in the Covered Countries was included in our Covered Products and, if so, whether the 3TG was from recycled or scrap sources, and whether or not these conflict minerals directly or indirectly financed or benefited armed groups in the Covered Countries. Based on the information provided by our Tier 1 Suppliers and SORs, as well as from the RMI and other sources, however, we believe that the countries of origin of the conflict minerals contained in our Covered Products include the countries listed in Annex II below, as well as recycled and scrap sources.

6




Addressing Identified Risks

In 2019, our efforts continued to be focused on collecting and disseminating information from our Tier 1 Suppliers on their sourcing practices using the Template and creating a database for that information. Each year since the Company began the process of assessing the origin of conflict minerals necessary for the functionality or production of products that the Company has contracted to manufacture, the Company has continually made enhancements to its Supplier review processes. In 2019, the Company continued to further refine our review process and exclude any supplier of products where the supplier merely affixed Company brands, trademarks, logos, or labels to generic products manufactured by a third party, as permitted by Securities and Exchange Commission guidance. As a result, the total number of Tier 1 Suppliers decreased to 71 in 2019, from 153 in 2018.

In the 2020 reporting year, we will continue our Supplier engagement process with an aim to decrease the number of Covered Products with 3TG of indeterminate origin. We expect that our 2020 efforts will include:

Reviewing and updating the list of Covered Products and associated Tier 1 Suppliers designated as in-scope as needed;
Re-engaging each in-scope Tier 1 Supplier to verify and update sourcing information as needed; and
Continuing to work with Suppliers to gain information about supply chain actors closer upstream to the smelter or refiner to facilitate the exchange of information on the origin of 3TG.

We intend to undertake the following steps during the 2020 reporting year to further mitigate the risk that our Covered Products contain conflict minerals that benefit armed groups in the Covered Countries:

Continuing to engage with Tier 1 Suppliers to obtain current, accurate and complete information about the supply chain;
Encouraging Tier 1 Suppliers to implement responsible sourcing and to encourage their smelters and refiners to obtain a “conflict-free” certification from an independent, third-party auditor; and
Engaging in industry initiatives encouraging “conflict-free” supply chains.



7



ANNEX I

Metal
Smelter or Refiner Name
Gold
8853 S.p.A.*
Tungsten
A.L.M.T. TUNGSTEN Corp.*
Gold
Abington Reldan Metals, LLC
Tungsten
ACL Metais Eireli*
Gold
Advanced Chemical Company*
Gold
African Gold Refinery
Gold
Aida Chemical Industries Co., Ltd.*
Gold
Al Etihad Gold Refinery DMCC*
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold
Almalyk Mining and Metallurgical Complex (AMMC)*
Tin
Alpha*
Gold
AngloGold Ashanti Corrego do Sitio Mineracao*
Tin
An Vinh Joint Stock Mineral Processing Company
Gold
Argor-Heraeus S.A.*
Gold
Asahi Pretec Corp.*
Gold
Asahi Refining Canada Ltd.*
Gold
Asahi Refining USA Inc.*
Gold/Tantalum
Asaka Riken Co., Ltd.*
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold
AU Traders and Refiners*
Gold
Aurubis AG*
Gold
Bangalore Refinery*
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*
Gold
Boliden AB*
Gold
C. Hafner GmbH + Co. KG*
Gold
Caridad
Gold
CCR Refinery - Glencore Canada Corporation*
Gold
Cendres + Metaux S.A.*
Gold
CGR Metalloys Pvt Ltd.
Tantalum
Changsha South Tantalum Niobium Co., Ltd.*
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.*
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.*
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.*
Gold
Chimet S.p.A.*
Tin
China Tin Group Co., Ltd.*
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.*
Gold
Chugai Mining*
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
Tantalum
CP Metals Inc.*
Gold
Daye Non-Ferrous Metals Mining Ltd.
Tantalum
D Block Metals, LLC*
Gold
Degussa Sonne / Mond Goldhandel GmbH
Gold
Dijllah Gold Refinery FZC

8



Metal
Smelter or Refiner Name
Gold
DODUCO Contacts and Refining GmbH*
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
Gold/Tin
Dowa*
Gold
DS PRETECH Co., Ltd.*
Gold
DSC (Do Sung Corporation)*
Gold
Eco-System Recycling Co., Ltd.*
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Gold
Emirates Gold DMCC*
Tin
EM Vinto*
Tin
Estanho de Rondonia S.A.
Tantalum
Exotech Inc.*
Tantalum
F&X Electro-Materials Ltd.*
Tin
Fenix Metals*
Gold
Fidelity Printers and Refiners Ltd.
Tantalum
FIR Metals & Resource Ltd.*
Gold
Fujairah Gold FZC
Tungsten
Fujian Ganmin RareMetal Co., Ltd.*
Tungsten
Fujian Jinxin Tungsten Co., Ltd.*
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.*
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.*
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.*
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
Gold
Geib Refining Corporation*
Tin
Gejiu Kai Meng Industry and Trade LLC*
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.*
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.*
Tin
Gejiu Zili Mining and Metallurgy Co., Ltd.*
Tantalum
Global Advanced Metals Aizu*
Tantalum
Global Advanced Metals Boyertown*
Tungsten
Global Tungsten & Powders Corp.*
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.*
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.*
Gold
Guangdong Jinding Gold Limited
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.*
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
Tin
Guanyang Guida Nonferrous Metal Smelting Plant*
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Tantalum
H.C. Starck Co., Ltd.*
Tantalum
H.C. Starck Hermsdorf GmbH*
Tantalum
H.C. Starck Inc.*
Tantalum
H.C. Starck Ltd.*
Tantalum/Tungsten
H.C. Starck Smelting GmbH & Co. KG*
Tantalum
H.C. Starck Tantalum and Niobium GmbH*

9



Metal
Smelter or Refiner Name
Tungsten
H.C. Starck Tungsten GmbH*
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold
Heimerle + Meule GmbH*
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.*
Gold
Heraeus Metals Hong Kong Ltd.*
Gold
Heraeus Precious Metals GmbH & Co. KG*
Tin
HuiChang Hill Tin Industry Co., Ltd.*
Tin
Huichang Jinshunda Tin Co., Ltd.*
Gold
Hunan Chenzhou Mining Co., Ltd.
Tungsten
Hunan Chenzhou Mining Co., Ltd.*
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.*
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.*
Gold
HwaSeong CJ CO., LTD.
Tungsten
Hydrometallurg, JSC*
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.*
Gold
International Precious Metal Refiners
Gold
Ishifuku Metal Industry Co., Ltd.*
Gold
Istanbul Gold Refinery*
Gold
Italpreziosi*
Gold
Japan Mint*
Tungsten
Japan New Metals Co., Ltd.*
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.*
Gold
Jiangxi Copper Co., Ltd.*
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.*
Tungsten
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.
Tin
Jiangxi New Nanshan Technology Ltd.*
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.*
Tantalum
Jiangxi Tuohong New Raw Material*
Tungsten
Jiangxi Xianglu Tungsten Co., Ltd.*
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.*
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.*
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Tantalum
Jiujiang Tanbre Co., Ltd.*
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
Tungsten
JSC “Kirovgrad Hard Alloys Plant”*
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold
JSC Uralelectromed*
Gold
JX Nippon Mining & Metals Co., Ltd.*
Gold
Kaloti Precious Metals
Gold
Kazakhmys Smelting LLC
Gold
Kazzinc*
Tantalum
KEMET Blue Metals*

10



Metal
Smelter or Refiner Name
Tantalum
Kemet Blue Powder*
Tungsten
Kennametal Fallon*
Tungsten
Kennametal Huntsville*
Gold
Kennecott Utah Copper LLC*
Tungsten
KGETS CO., LTD.*
Gold
KGHM Polska Miedz Spolka Akcyjna*
Gold
Kojima Chemicals Co., Ltd.*
Gold
Korea Zinc Co., Ltd.*
Gold
Kyrgyzaltyn JSC*
Gold
Kyshtym Copper-Electrolytic Plant ZAO
Gold
L’azurde Company For Jewelry
Tungsten
Lianyou Metals Co., Ltd.*
Gold
Lingbao Gold Co., Ltd.
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold
L’Orfebre S.A.*
Tantalum
LSM Brasil S.A.*
Gold
LS-NIKKO Copper Inc.*
Gold
LT Metal Ltd.*
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Tin
Ma'anshan Weitai Tin Co., Ltd.*
Tin
Magnu’s Minerais Metais e Ligas Ltda.*
Tin
Malaysia Smelting Corporation (MSC)*
Tungsten
Malipo Haiyu Tungsten Co., Ltd.*
Gold
Marsam Metals*
Tungsten
Masan Tungsten Chemical LLC (MTC)*
Gold
Materion*
Gold
Matsuda Sangyo Co., Ltd.*
Tin
Melt Metais e Ligas S.A.*
Tin
Metallic Resources, Inc.*
Tin
Metallo Belgium N.V.*
Tin
Metallo Spain S.L.U.*
Tantalum
Metallurgical Products India Pvt., Ltd.*
Gold
Metalor Technologies (Hong Kong) Ltd.*
Gold
Metalor Technologies (Singapore) Pte., Ltd.*
Gold
Metalor Technologies (Suzhou) Ltd.*
Gold
Metalor Technologies S.A.*
Gold
Metalor USA Refining Corporation*
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.*
Tantalum/Tin
Minercao Taboca S.A.*
Tin
Minsur*
Gold/Tin
Mitsubishi Materials Corporation*
Gold/Tantalum
Mitsui Mining and Smelting Co., Ltd.*
Gold
MMTC-PAMP India Pvt., Ltd.*
Gold/Tin
Modeltech Sdn Bhd
Tungsten
Moliren Ltd.*

11



Metal
Smelter or Refiner Name
Gold
Morris and Watson
Gold
Moscow Special Alloys Processing Plant*
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.*
Gold
Navoi Mining and Metallurgical Combinat
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Gold
NH Recytech Company
Tungsten
Niagra Refining LLC*
Gold
Nihon Material Co., Ltd.*
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.*
Tantalum
NPM Silmet AS*
Tin
O.M. Manufacturing (Thailand) Co., Ltd.*
Tin
O.M. Manufacturing Philippines, Inc.*
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH*
Gold
Ohura Precious Metal Industry Co., Ltd.*
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)*
Gold
OJSC Novosibirsk Refinery*
Tin
Operaciones Metalurgical S.A.*
Gold
PAMP S.A.*
Gold
Pease & Curren
Gold
Penglai Penggang Gold Industry Co., Ltd.
Tungsten
Philippine Chuangxin Industrial Co., Inc.*
Gold
Planta Recuperadora de Metales SpA*
Tin
Pongpipat Company Limited
Tin
Precious Minerals and Smelting Limited*
Tantalum
PRG Dooel*
Gold
Prioksky Plant of Non-Ferrous Metals*
Gold
PT Aneka Tambang (Persero) Tbk*
Tin
PT Mitra Stania Prima*
Tin
PT Refined Bangka Tin*
Tin
PT Timah Tbk Kundur*
Tin
PT Timah Tbk Mentok*
Gold
PX Precinox S.A.*
Gold
QG Refining, LLC
Tantalum
QuantumClean*
Gold
Rand Refinery (Pty) Ltd.*
Gold
Refinery of Seemine Gold Co., Ltd.
Gold
REMONDIS PMR B.V.*
Tantalum/Tin
Resind Industria e Comercio Ltda.*
Gold
Royal Canadian Mint*
Tin
Rui Da Hung*
Gold
SAAMP*
Gold
Sabin Metal Corp.
Gold
Safimet S.p.A*
Gold
SAFINA A.S.*
Gold
Sai Refinery

12



Metal
Smelter or Refiner Name
Gold
Samduck Precious Metals*
Gold
SAXONIA Edelmetalle GmbH*
Gold
SEMPSA Joyeria Plateria S.A.*
Gold
Shandong Humon Smelting Co., Ltd.
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*
Gold
Sichuan Tianze Precious Metals Co., Ltd.*
Gold
Singway Technology Co., Ltd.*
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals*
Tin
Soft Metais Ltda.*
Gold
Solar Applied Materials Technology Corp.*
Tantalum
Solikamsk Magnesium Works OAO*
Gold
Sovereign Metals
Gold
State Research Institute Center for Physical Sciences and Technology
Gold
Sudan Gold Refinery
Gold
Sumitomo Metal Mining Co., Ltd.*
Gold
SungEel HiMetal Co., Ltd.*
Tin
Super Ligas
Gold
T.C.A S.p.A*
Tantalum
Taki Chemical Co., Ltd.*
Gold
Tanaka Kikinzoku Kogyo K.K.*
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.*
Tantalum
Telex Metals*
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.*
Tin
Thaisarco*
Gold
The Refinery of Shandong Gold Mining Co., Ltd.*
Tin
Tin Technology & Refining*
Gold
Tokuriki Honten Co., Ltd.*
Gold
Tongling Nonferrous Metals Group Co., Ltd.
Gold
Tony Goetz NV
Gold
TOO Tau-Ken-Altyn
Gold
Torecom*
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tantalum
Ulba Metallurgical Plant JSC*
Gold
Umicore Brasil Ltda.*
Gold
Umicore Precious Metals Thailand*
Gold
Umicore S.A. Business Unit Precious Metals Refining*
Tungsten
Unecha Refractory Metals Plant*
Gold
United Precious Metal Refining, Inc.*
Gold
Valcambi S.A.*
Gold
Western Australian Mint (T/a The Perth Mint)*
Tin
White Solder Metalurgia e Mineracao Ltda.*
Gold
WIELAND Edelmetalle GmbH*
Tungsten
Wolfram Bergbau und Hutten AG*
Tungsten
Woltech Korea Co., Ltd.*

13



Metal
Smelter or Refiner Name
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
Tungsten
Xiamen Tungsten Co., Ltd.*
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.*
Tantalum
XinXing Haorong Electronic Material Co., Ltd.*
Gold
Yamakin Co., Ltd.*
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.*
Gold
Yokohama Metal Co., Ltd.*
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*
Gold
Yunnan Copper Industry Co., Ltd.
Tin
Yunnan Tin Company Limited*
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.*
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*

*Smelter or refiner certified by the RMI, LBMA or RJC




14



ANNEX II
Countries of Origin

Angola
Argentina
Armenia
Australia
Austria
Belarus
Belgium
Bermuda
Bolivia
Brazil
Burundi
Cambodia
Canada
Central African Republic
Chile
China
Colombia
Congo (Brazzaville)
Czech Republic
Djibouti
DRC - Congo (Kinshasa)
Ecuador
Egypt
Estonia
Ethiopia
Finland
France
Germany
Ghana
Guinea
Guyana
Hong Kong
Hungary
India
Indonesia
Ireland
Israel
Italy
Ivory Coast
Japan
Jersey
Kazakhstan
Kenya
Korea, Republic of
Kyrgyzstan
Laos
Luxembourg
Madagascar
Malaysia
Mali
Mexico
Mongolia
Morocco
Mozambique
Myanmar
Namibia
Netherlands
New Zealand
Niger
Nigeria
Papua New Guinea
Peru
Philippines
Poland
Portugal
Russian Federation
Rwanda
Saudi Arabia
Sierra Leone
Singapore
Slovakia
South Africa
South Sudan
Spain
Suriname
Sweden
Switzerland
Taiwan
Tajikistan
Tanzania
Thailand
Turkey
Uganda
United Arab Emirates
United Kingdom
United States
Uzbekistan
Vietnam
Zambia
Zimbabwe

15