EX-1.01 2 exhibit101-x2018conflictmi.htm EXHIBIT 1.01 Exhibit
Exhibit 1.01

Cardinal Health, Inc.
Conflict Minerals Report
For the 2018 Reporting Period
Introduction
As used in this report, "Cardinal Health," "we," "our," "us" and similar pronouns refer to Cardinal Health, Inc. and its consolidated subsidiaries, unless the context requires otherwise. "Conflict minerals" (or “3TG”) are defined as columbite-tantalite (coltan), cassiterite, gold and wolframite and the derivatives tantalum, tin and tungsten.
Cardinal Health is a global, integrated healthcare services and products company providing customized solutions for hospitals, healthcare systems, pharmacies, ambulatory surgery centers, clinical laboratories and physician offices. We provide medical products and pharmaceuticals and cost-effective solutions that enhance supply chain efficiency.
We manage our business in two segments: Pharmaceutical and Medical. Our Pharmaceutical segment distributes branded and generic pharmaceutical, specialty pharmaceutical and over-the-counter healthcare and consumer products in the United States and also provides services to pharmaceutical manufacturers and healthcare providers. This segment also provides services to pharmaceutical manufacturers and healthcare providers for specialty pharmaceutical products, operates nuclear pharmacies and radiopharmaceutical manufacturing facilities and provides pharmacy management services to hospitals. It also provides medication therapy management and patient outcomes services to hospitals, other healthcare providers and payers, and repackages generic pharmaceuticals and over-the-counter healthcare products.
Our Medical segment manufactures, sources and distributes Cardinal Health branded medical, surgical and laboratory products. This segment also distributes a broad range of national brand products and provides supply chain services and solutions to hospitals, ambulatory surgery centers, clinical laboratories and other healthcare providers. It also distributes medical products to patients’ homes.
Our Pharmaceutical segment, which generated approximately 89% of our consolidated revenue for our fiscal year ended June 30, 2018, does not have any in-scope products under the 3TG Rule (as defined below). Accordingly, most of our business activities do not come within the scope of the 3TG Rule.
Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and Form SD (together, the "3TG Rule"), this Conflict Minerals Report describes, for the period from January 1, 2018 to December 31, 2018 (the "2018 Reporting Period"), the measures we have taken to conduct due diligence on the source and chain of custody of the 3TG contained in, and necessary to the functionality or production of, the products that we manufactured or contracted to manufacture during the 2018 Reporting Period.
In-Scope Products and Our Supply Chain
We assessed all product lines manufactured or contracted to be manufactured by us in the 2018 Reporting Period to determine whether they potentially contained necessary 3TG. Through the assessment process, our product teams determined that the following product lines manufactured or contracted to be manufactured by our Medical segment (collectively, the "Products") contained necessary 3TG for the 2018 Reporting Period: radio frequency identification enabled inventory management cabinets and wands; ureteral stone retrieval devices; certain balloon catheters; certain negative pressure wound therapy devices; and certain enteral feeding, electrode and thermometry product lines.
Our supply chains are complex and fragmented. As a “downstream” company, we are many tiers removed in the minerals supply chain from smelters and refiners (collectively, "SORs") that process the 3TG found in the Products, with many intervening third parties between the original sources of 3TG and us.
Reasonable Country of Origin Inquiry
As required by the 3TG Rule, we conducted a good faith, reasonable country of origin inquiry ("RCOI") regarding the 3TG in materials, components and finished goods supplied to us that relate to the Products. The RCOI was designed to determine whether any of the 3TG originated in the Democratic Republic of the Congo or its adjoining countries (collectively, the “Covered Countries”) and was not from recycled or scrap sources. Selected elements of our RCOI process are described below.
With the assistance of a third-party vendor with expertise in supply chain due diligence (the “Vendor”), we engaged 33 potentially in-scope suppliers to collect information regarding the presence and source of 3TG in the Products. These suppliers were asked to complete the Conflict Minerals Reporting Template (v.5.11 or higher) (the “CMRT”) and return it to the Vendor for assessment and management. The CMRT is an internationally-recognized standardized reporting form developed by the Responsible Minerals Initiative ("RMI") that requests, among other things, information regarding the SORs that processed the 3TG in the supplier’s





products, the country of origin of that 3TG and the supplier’s compliance program. Any suppliers that provided information on the CMRT at the company level are encouraged to re-submit at the product level.
The Vendor followed up with all unresponsive suppliers using both automated and personalized emails and offered assistance and further information about the requirements of the 3TG Rule and our expectations.
The Vendor also identified and followed up on incomplete or contradictory answers in each CMRT submitted and encouraged suppliers to re-submit a corrected CMRT.
Where suppliers identified SORs in their completed CMRTs, the Vendor verified whether the listed entities were SORs of 3TG by comparing the entities’ names to the CMRT’s smelter list. The Vendor also checked whether the SOR was listed by the RMI as being conformant with the RMI's Responsible Minerals Assurance Process (the “RMAP”) assessment protocols. The RMAP uses an independent third-party assessment of SOR management systems and sourcing practices to validate conformance with RMAP standards and current global standards. Our suppliers identified a total of 313 SORs, of which 252 SORs were listed by the RMI as of May 1, 2019 as being “conformant” and five were listed as being “active” in the conformance assessment process. Many of the CMRTs we received were prepared at a company level, meaning that they covered all of the supplier’s products and not just those that the supplier sold to us. As a result, we were not able to determine whether the identified SORs actually processed the 3TG contained in the Products. In addition, the suppliers may not have identified all of the SORs in their supply chains.
The Vendor researched and reviewed mine information for the SORs to try to determine the mine and country of origin of the 3TG processed by the SORs.
Based on our RCOI, we have reason to believe that at least some of the 3TG contained in the Products may have originated in the Covered Countries and may not be from recycled or scrap sources. Accordingly, we conducted due diligence on the source and chain of custody of the 3TG.
Due Diligence
The due diligence measures described below were designed to conform, in all material respects, with the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplements for tin, tantalum and tungsten and gold (Third Edition) (the "OECD Guidance"). The OECD Guidance identifies five steps for due diligence that should be implemented and provides specific guidance with respect to each step. We developed our due diligence measures to address each of these five steps and to help ensure that the 3TG in the Products is responsibly sourced. These measures took into account the OECD Guidance’s recommendations for companies in the downstream segments of the supply chain, which typically are several tiers removed from, and have no direct relationships with, SORs. The following discussion addresses each of the five steps in turn.
1.
Establish Company Management Systems
We have implemented a 3TG compliance program (the “Program”) with the following attributes:
Policy Statement
We have adopted a Conflict Minerals Policy (the "Policy") that sets forth the expectation that our suppliers source materials from suppliers that also source responsibly, including from conflict-free mines in the Covered Countries. The Policy is available on our website at https://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html. Information contained on our website is not incorporated by reference into this report or the Form SD.
The Policy states that we expect suppliers to be aware of the requirements of the 3TG Rule and other 3TG legislation and to respond in a timely manner to our requests for information. As stated in the Policy, we do not embargo sourcing from the Covered Countries and encourage our suppliers to continue to source responsibly from those countries.
Steering Committee
We have a 3TG steering committee to provide cross-functional oversight for the Program, including representatives from sourcing, manufacturing, legal, quality and regulatory, and internal audit. Our Senior Vice President, Strategic Sourcing Global Products is the executive leader of the steering committee. The steering committee reports on the Program to the Environmental, Social and Governance ("ESG") Coordinating Committee, the ESG Working Group of our Disclosure Committee and the Chief Legal and Compliance Officer.

2



Control Systems and Supply Chain Transparency
As discussed above, the Vendor facilitates supplier engagement and assists us in collecting, analyzing, verifying and storing supplier-provided data and performing due diligence for the Program. With the assistance of the Vendor, we contacted and solicited information from suppliers concerning the usage and source of 3TG, using the CMRT.
To further strengthen the Program, in 2016, we became a member of the RMI, a cross-industry organization that provides resources, tools and information to help companies source conflict-free minerals, including a list of confirmed SORs, and the RMI’s RMAP.
Our Vendor Code of Conduct requires suppliers to comply with the Policy, including working with their suppliers to identify the source and chain of custody of any 3TG contained in their products. Suppliers must agree to cooperate with us in connection with any inquiries or due diligence that we choose to perform with respect to such 3TG. The Vendor Code of Conduct is available on our website at https://www.cardinalhealth.com/content/dam/corp/web/documents/Policy/cardinal-health-vendor-code-of-conduct-policy.pdf.
The Vendor maintains records of product and supply chain information collected through the due diligence activities carried out under the Program. Documentation is retained for at least five years in an electronic database.
Supplier Engagement
In support of our Policy, we have incorporated 3TG compliance provisions into the standard terms of our Medical segment's supplier agreement template. As discussed above, we also address 3TG compliance in the Policy and the Vendor Code of Conduct. Both of these instruments are distributed to suppliers and publicly available on our website.
To further ensure suppliers understand and meet our expectations, we have, through the Vendor, provided suppliers of the Products with access to video and written training materials and courses and other compliance support on 3TG compliance and completing the CMRT. We encourage all suppliers to complete these courses and track training based on completion.
Grievance Mechanism
We have a dedicated email address for reporting questions or concerns relating to our Policy or Program to a Cardinal Health representative. The email address is conflict_minerals@cardinalhealth.com. In addition, we have a business conduct line that provides a mechanism for anyone to anonymously report conduct they know or believe is in violation of Cardinal Health guidelines or policies, including any concerns related to the 3TG supply chain. The contact information for this mechanism is found in our Standards of Business Conduct, which is available on our website at https://www.cardinalhealth.com/en/about-us/who-we-are/ethics-and-compliance.html.
2.
Risk Identification and Assessment in the Supply Chain
Risks are identified by the Vendor's software based on “red flags” criteria established for supplier responses, including the submission of a CMRT with incomplete or contradictory answers. These risks are addressed in the first instance by the Vendor's staff, who contact the supplier, gather pertinent data and perform an assessment of the supplier’s 3TG sourcing risk. Risks are communicated to our 3TG steering committee and our Chief Legal and Compliance Officer.
Possible sourcing risks were identified by assessing the due diligence practices of SORs listed on CMRT declarations. The Vendor determined whether each SOR identified in a CMRT response was conformant by reviewing the identified SORs against the lists of conformant SORs published by the RMI. SORs classified as actively pursuing conformant status under the RMAP also were identified. In addition, the Vendor uses other factors to assess possible SOR risk, including geographic proximity to the Covered Countries, known 3TG source country of origin, credible evidence of unethical or conflict sourcing and peer assessments conducted by third-party sources believed to be reliable by the Vendor.
Additionally, through the Vendor, we evaluated the strength of our suppliers' 3TG due diligence and supply chain control programs, further assisting us in identifying supply chain risk. The criteria used to evaluate the program strength of our suppliers included reviewing whether the supplier has a 3TG policy, whether it has implemented due diligence measures for conflict-free sourcing, whether it verifies due diligence information from its suppliers and whether its verification process includes corrective action management. If a supplier is determined to have a weak program as a result of this evaluation, it receives a communication from the Vendor informing it of this rating.

3



3.
Risk Response Strategy
Together with the Vendor, we developed processes to assess and respond to risks in 3TG sourcing.
As the Program progresses, the Vendor makes escalating contacts with suppliers that have not responded to our CMRT requests, emphasizing the importance of their response and their required cooperation for compliance with the 3TG Rule. When SORs determined to be of higher risk are reported on a CMRT by one of the suppliers surveyed, we seek to mitigate risk by requesting, through the Vendor, that the supplier take its own risk mitigation actions, including the submission of a product-specific CMRT to better identify the connection of the SORs to products that the supplier supplied to us.
If we have reason to believe that a supplier is using 3TG from sources that may support conflict in the Covered Countries, we will seek to encourage it to establish an alternative source of 3TG that does not support such conflict. In addition, suppliers are guided to the Vendor's learning platform for educational materials on mitigating the risk of SORs on the supply chain.
The Vendor also directly contacts SORs that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each SOR's sourcing practices.
In addition, under our Vendor Code of Conduct, if we determine or believe at any time that a supplier has failed to comply with the standards set forth in the Vendor Code of Conduct, including those with respect to 3TG, we have the right to cease the purchase of the supplier's products without liability or obligation.
We address identified risks on a case-by-case basis. This flexible approach enables us to tailor the response to the risks identified.
4.
Audits of Due Diligence Practices of SORs
We do not have a direct relationship with SORs and do not perform or direct SOR audits. Instead, as a member of the RMI, we rely on internationally-recognized assessment programs, such as the RMAP, that facilitate and confirm independent third-party audits of SORs’ supply chain due diligence practices. Any SOR that has not been validated as conformant with such an audit protocol receives a communication from the Vendor encouraging the SOR to participate in a conflict-free assessment program such as the RMAP.
5.
Annual Public Reporting on Supply Chain Due Diligence
We report annually on our supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the U.S. Securities and Exchange Commission. We have published our Conflict Minerals Report for the 2018 Reporting Period our website at https://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html.
Due Diligence Results
Survey Results
For the 2018 Reporting Period, we received responses from approximately 82% of all surveyed suppliers. CMRT submissions were reviewed and validated as discussed earlier in this report.
Smelters and Refiners
Notwithstanding our due diligence efforts, because many of the suppliers provided information in their CMRTs at a company level, we were unable to conclusively determine the country of origin of, or facilities used to process, the necessary 3TG in the Products for the 2018 Reporting Period. Thus, SOR information we received from our suppliers may not be relevant to any of the Products and may identify SORs that are not actually in our supply chain. In addition, some suppliers indicated that they received incomplete information from their suppliers and, therefore, could not provide a comprehensive list of all SORs in their supply chains.
Annex A contains a list of the SORs reported by the suppliers. A total of 313 SORs were identified. As of May 1, 2019, 252 of these SORs, or 81%, were listed as conformant and five, or 2%, were listed as active by the RMI. Annex B provides an aggregated list of potential countries of origin of the 3TG processed by the conformant SORs.
Cardinal Health's efforts to determine the mine or location of origin of the necessary 3TG in the Products with the greatest possible specificity consisted of the implementation of the Program and due diligence measures described above in this Conflict Minerals Report.

4



Risk Mitigation Steps
We took the following actions to improve our Program following the filing of our Conflict Minerals Report for the period from January 1, 2017 to December 31, 2017:
Improved Supplier Engagement. We have continued to engage a Vendor, through which we have reached out to suppliers, communicated our expectations under the Program and offered education and training for suppliers. The Vendor has encouraged suppliers to access extensive resources on due diligence and risk mitigation on the Vendor's platform and website to improve the suppliers' knowledge and practices.
Enhanced Due Diligence Processes. We have continued to utilize the Vendor's expertise in supplier surveys and supply chain due diligence, which considers improvements in broader industry practice.
Supported Efforts to Encourage SOR Participation in Conflict-Free Validation Programs. We have continued to participate as a member of the RMI to support programs like the RMAP that facilitate and validate independent third-party audits of SORs’ supply chain due diligence practices. The Vendor has conducted independent outreach on our behalf to SORs not currently participating in these programs to encourage participation and to gather additional information on these SORs' sourcing practices.
Forward-Looking Statements
This report includes forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, that involve risks and uncertainties, such as whether industry organizations and initiatives remain effective as a source of external support to us in the 3TG compliance process. Forward-looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. Forward-looking statements can also be identified by words such as “expects,” “plans,” “intends,” “will,” “may,” and similar terms and include statements reflecting future results or guidance and statements of outlook. These matters are subject to risks and uncertainties that could cause actual results to differ materially from those projected, anticipated or implied. Forward-looking statements are not guarantees of future performance. We assume no obligation to revise or update any forward-looking statements for any reason, except as required by law. Subsequent events may affect our future determinations under the 3TG Rule.


5



ANNEX A
Identified SORs
The following is a list of SORs reported in suppliers' CMRTs. SORs that are listed as conformant by the RMI as of May 1, 2019, or that are listed by the RMI as having committed to undergo an RMAP assessment, are indicated as noted by an asterisk below.
As discussed in our Conflict Minerals Report, we are unable to determine whether any of the SORs listed in this Annex A processed the 3TG in the Products. As a result, the presence of a SOR on the list does not mean that the Products necessarily contained 3TG processed by that SOR. In addition, because the suppliers may not have identified all of the SORs in their supply chains, the products may contain 3TG processed by other SORs not listed below.
Mineral
SOR Name
SOR Location
Gold
Abington Reldan Metals, LLC
UNITED STATES
Gold
Advanced Chemical Company*
UNITED STATES
Gold
African Gold Refinery
UGANDA
Gold
Aida Chemical Industries Co., Ltd.*
JAPAN
Gold
Al Etihad Gold LLC*
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.*
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)*
UZBEKISTAN
Gold
AngloGold Ashanti Córrego do Sítio Mineração*
BRAZIL
Gold
Argor-Heraeus S.A.*
SWITZERLAND
Gold
Asahi Pretec Corp.*
JAPAN
Gold
Asahi Refining Canada Ltd.*
CANADA
Gold
Asahi Refining USA Inc.*
UNITED STATES
Gold
Asaka Riken Co., Ltd.*
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
AU Traders and Refiners*
SOUTH AFRICA
Gold
Aurubis AG*
GERMANY
Gold
Bangalore Refinery*
INDIA
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 + Métaux S.A.*
SWITZERLAND
Gold
Chimet S.p.A.*
ITALY
Gold
Chugai Mining*
JAPAN
Gold
Daejin Indus Co., Ltd.*
REPUBLIC OF KOREA
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Gold
DODUCO Contacts and Refining GmbH*
GERMANY
Gold
Dowa*
JAPAN
Gold
DS PRETECH Co., Ltd.*
REPUBLIC OF KOREA
Gold
DSC (Do Sung Corporation)*
REPUBLIC OF KOREA
Gold
Eco-System Recycling Co., Ltd.*
JAPAN
Gold
Emirates Gold DMCC*
UNITED ARAB EMIRATES

A-1



Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Gold
Geib Refining Corporation*
UNITED STATES
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.*
CHINA
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Gold
Guangdong Jinding Gold Limited
CHINA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
HeeSung*
REPUBLIC OF KOREA
Gold
Heimerle + Meule GmbH*
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.*
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG*
GERMANY
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
Hunan Guiyang Yinxing Nonferrous Smelting Co., Ltd.
CHINA
Gold
Hwasung CJ Co., Ltd.
REPUBLIC OF KOREA
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
Italpreziosi*
ITALY
Gold
Japan Mint*
JAPAN
Gold
Jiangxi Copper Co., Ltd.*
CHINA
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
JSC Uralelectromed*
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.*
JAPAN
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc*
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC*
UNITED STATES
Gold
KGHM Polska Miedz Spolka Akcyjna*
POLAND
Gold
Kojima Chemicals Co., Ltd.*
JAPAN
Gold
Korea Zinc Co., Ltd.*
REPUBLIC OF KOREA
Gold
Kyrgyzaltyn JSC*
KYRGYZSTAN
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Gold
Lingbao Gold Co., Ltd.
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
L'Orfebre S.A.*
ANDORRA
Gold
LS-NIKKO Copper Inc.*
REPUBLIC OF KOREA
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
Marsam Metals*
BRAZIL
Gold
Materion*
UNITED STATES
Gold
Matsuda Sangyo Co., Ltd.*
JAPAN
Gold
Metalor Technologies (Hong Kong) Ltd.*
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.*
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.*
CHINA
Gold
Metalor Technologies S.A.*
SWITZERLAND

A-2



Gold
Metalor USA Refining Corporation*
UNITED STATES
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.*
MEXICO
Gold
Mitsubishi Materials Corporation*
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.*
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.*
INDIA
Gold
Modeltech Sdn Bhd
MALAYSIA
Gold
Morris and Watson
NEW ZEALAND
Gold
Morris and Watson Gold Coast
AUSTRALIA
Gold
Moscow Special Alloys Processing Plant*
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.*
TURKEY
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
NH Recytech Company *
REPUBLIC OF KOREA
Gold
Nihon Material Co., Ltd.*
JAPAN
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.*
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)*
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery*
RUSSIAN FEDERATION
Gold
PAMP S.A.*
SWITZERLAND
Gold
Pease & Curren
UNITED STATES
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
Planta Recuperadora de Metales SpA*
CHILE
Gold
Prioksky Plant of Non-Ferrous Metals*
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk*
INDONESIA
Gold
PX Précinox S.A.*
SWITZERLAND
Gold
QG Refining, LLC
UNITED STATES
Gold
Rand Refinery (Pty) Ltd.*
SOUTH AFRICA
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Gold
Remondis Argentia B.V.*
NETHERLANDS
Gold
Republic Metals Corporation*
UNITED STATES
Gold
Royal Canadian Mint*
CANADA
Gold
SAAMP*
FRANCE
Gold
Sabin Metal Corp.
UNITED STATES
Gold
Safimet S.p.A*
ITALY
Gold
SAFINA A.S.
CZECH REPUBLIC
Gold
Sai Refinery
INDIA
Gold
Samduck Precious Metals
REPUBLIC OF KOREA
Gold
SAMWON Metals Corp.
REPUBLIC OF KOREA
Gold
SAXONIA Edelmetalle GmbH*
GERMANY
Gold
SEMPSA Joyería Platería S.A.*
SPAIN
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*
CHINA
Gold
Shangdong Humon Smelting Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.*
CHINA
Gold
Singway Technology Co., Ltd.*
TAIWAN
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals*
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.*
TAIWAN

A-3



Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Gold
Sudan Gold Refinery
SUDAN
Gold
Sumitomo Metal Mining Co., Ltd.*
JAPAN
Gold
SungEel HiTech*
REPUBLIC OF KOREA
Gold
T.C.A S.p.A*
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.*
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.*
CHINA
Gold
Tokuriki Honten Co., Ltd.*
JAPAN
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
Tony Goetz NV
BELGIUM
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
Torecom*
REPUBLIC OF KOREA
Gold
Umicore Brasil Ltda.*
BRAZIL
Gold
Umicore Precious Metals Thailand*
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining*
BELGIUM
Gold
United Precious Metal Refining, Inc.*
UNITED STATES
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Gold
Valcambi S.A.*
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint*
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH*
GERMANY
Gold
Yamamoto Precious Metal Co., Ltd.*
JAPAN
Gold
Yokohama Metal Co., Ltd.*
JAPAN
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
CHINA
Tantalum
Asaka Riken Co., Ltd.*
JAPAN
Tantalum
Changsha South Tantalum Niobium Co., Ltd.*
CHINA
Tantalum
D Block Metals, LLC*
UNITED STATES
Tantalum
Exotech Inc.*
UNITED STATES
Tantalum
F&X Electro-Materials Ltd.*
CHINA
Tantalum
FIR Metals & Resource Ltd.*
CHINA
Tantalum
Global Advanced Metals Aizu*
JAPAN
Tantalum
Global Advanced Metals Boyertown*
UNITED STATES
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.*
CHINA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
CHINA
Tantalum
H.C. Starck Co., Ltd.*
THAILAND
Tantalum
H.C. Starck Hermsdorf GmbH*
GERMANY
Tantalum
H.C. Starck Inc.*
UNITED STATES
Tantalum
H.C. Starck Ltd.*
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG*
GERMANY
Tantalum
H.C. Starck Tantalum and Niobium GmbH*
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.*
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*
CHINA
Tantalum
Jiangxi Tuohong New Raw Material*
CHINA
Tantalum
Jiujiang Janny New Material Co., Ltd.*
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.*
CHINA

A-4



Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
CHINA
Tantalum
KEMET Blue Metals*
MEXICO
Tantalum
KEMET Blue Powder*
UNITED STATES
Tantalum
LSM Brasil S.A.*
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.*
INDIA
Tantalum
Mineracao Taboca S.A.*
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.*
JAPAN
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.*
CHINA
Tantalum
NPM Silmet AS*
ESTONIA
Tantalum
Power Resources Ltd.*
MACEDONIA
Tantalum
QuantumClean*
UNITED STATES
Tantalum
Resind Industria e Comercio Ltda.*
BRAZIL
Tantalum
RFH Tantalum Smeltry Co., Ltd.*
CHINA
Tantalum
Solikamsk Magnesium Works OAO*
RUSSIAN FEDERATION
Tantalum
Taki Chemicals*
JAPAN
Tantalum
Telex Metals*
UNITED STATES
Tantalum
Ulba Metallurgical Plant JSC*
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.*
CHINA
Tin
Alpha*
UNITED STATES
Tin
An Vinh Joint Stock Mineral Processing Company
VIETNAM
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.*
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.*
CHINA
Tin
China Tin Group Co., Ltd.*
CHINA
Tin
CV Ayi Jaya*
INDONESIA
Tin
CV Dua Sekawan*
INDONESIA
Tin
CV Gita Pesona*
INDONESIA
Tin
CV Tiga Sekawan*
INDONESIA
Tin
CV United Smelting*
INDONESIA
Tin
CV Venus Inti Perkasa*
INDONESIA
Tin
Dowa*
JAPAN
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIETNAM
Tin
EM Vinto*
BOLIVIA
Tin
Estanho de Rondônia S.A.
BRAZIL
Tin
Fenix Metals*
POLAND
Tin
Gejiu Fengming Metallurgy Chemical Plant*
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC*
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.*
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.*
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.*
CHINA
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company*
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant*
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.*
CHINA
Tin
Jiangxi New Nanshan Technology Ltd.*
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.*
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)*
MALAYSIA

A-5



Tin
Melt Metais e Ligas S.A.*
BRAZIL
Tin
Metallic Resources, Inc.*
UNITED STATES
Tin
Metallo Belgium N.V.*
BELGIUM
Tin
Metallo Spain S.L.U.*
SPAIN
Tin
Mineracao Taboca S.A.*
BRAZIL
Tin
Minsur*
PERU
Tin
Mitsubishi Materials Corporation*
JAPAN
Tin
Modeltech Sdn Bhd*
MALAYSIA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.*
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.*
PHILIPPINES
Tin
Operaciones Metalurgical S.A.*
BOLIVIA
Tin
Pongpipat Company Limited
MYANMAR
Tin
PT Aries Kencana Sejahtera*
INDONESIA
Tin
PT Aries Artha Cipta Langgeng*
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya*
INDONESIA
Tin
PT Babel Inti Perkasa*
INDONESIA
Tin
PT Babel Surya Alam Lestari*
INDONESIA
Tin
PT Bangka Prima Tin*
INDONESIA
Tin
PT Bangka Serumpun*
INDOENSIA
Tin
PT Bangka Tin Industry*
INDONESIA
Tin
PT Belitung Industri Sejahtera*
INDONESIA
Tin
PT Bukit Timah*
INDONESIA
Tin
PT DS Jaya Abadi*
INDONESIA
Tin
PT Inti Stania Prima*
INDONESIA
Tin
PT Karimun Mining*
INDONESIA
Tin
PT Kijang Jaya Mandiri*
INDONESIA
Tin
PT Menara Cipta Mulia*
INDONESIA
Tin
PT Mitra Stania Prima*
INDONESIA
Tin
PT Panca Mega Persada*
INDONESIA
Tin
PT Premium Tin Indonesia*
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 Sukses Inti Makmur*
INDONESIA
Tin
PT Sumber Jaya Indah*
INDONESIA
Tin
PT Timah (Persero) Tbk Kundur*
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok*
INDONESIA
Tin
PT Tinindo Inter Nusa*
INDONESIA
Tin
PT Tirus Putra Mandiri*
INDONESIA
Tin
PT Tommy Utama*
INDONESIA
Tin
Resind Industria e Comercio Ltda.*
BRAZIL
Tin
Rui Da Hung*
TAIWAN
Tin
Soft Metais Ltda.*
BRAZIL
Tin
Super Ligas
BRAZIL

A-6



Tin
Thaisarco*
THAILAND
Tin
Tin Technology & Refining*
UNITED STATES
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
White Solder Metalurgia e Mineração Ltda.*
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*
CHINA
Tin
Yunnan Tin Company Limited*
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.*
JAPAN
Tungsten
ACL Metais Eireli*
BRAZIL
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.*
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.*
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.*
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.*
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.*
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.*
CHINA
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.*
UNITED STATES
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.*
CHINA
Tungsten
H.C. Starck Smelting GmbH & Co. KG*
GERMANY
Tungsten
H.C. Starck Tungsten GmbH*
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.*
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.*
CHINA
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.*
CHINA
Tungsten
Hydrometallurg, JSC*
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.*
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.*
CHINA
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.*
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.*
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.*
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.*
CHINA
Tungsten
Kennametal Fallon*
UNITED STATES
Tungsten
Kennametal Huntsville*
UNITED STATES
Tungsten
Malipo Haiyu Tungsten Co., Ltd.*
CHINA
Tungsten
Moliren Ltd*
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC*
UNITED STATES
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC*
VIETNAM
Tungsten
Philippine Chuangxin Industrial Co., Inc.*
PHILIPPINES
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City*
CHINA
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.*
VIETNAM
Tungsten
Unecha Refractory metals plant*
RUSSIAN FEDERATION
Tungsten
Wolfram Bergbau und Hütten AG*
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.*
REPUBLIC OF KOREA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
CHINA

A-7



Tungsten
Xiamen Tungsten Co., Ltd.*
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.*
CHINA


A-8



ANNEX B
Countries of Origin
Below is an aggregated list of countries of origin from which the conformant SORs listed in Annex A are believed to have potentially sourced 3TG (which also may include other countries). The countries of origin listed below are derived from information made available by the RMI to its members. Some of the identified SORs also may have sourced in whole or in part from recycled or scrap sources.
Argentina
Mauritania
Armenia
Mauritius
Australia
Mexico
Austria
Mongolia
Azerbaijan
Morocco
Benin
Mozambique
Plurinational State of Bolivia
Myanmar
Botswana
Namibia
Brazil
Nicaragua
Burkina Faso
Niger
Burundi
Nigeria
Canada
Papua New Guinea
Chile
Peru
China
Philippines
Colombia
Portugal
Cyprus
Russian Federation
Democratic Republic of the Congo
Rwanda
Dominican Republic
Saudi Arabia
Ecuador
Senegal
Egypt
Sierra Leone
Eritrea
Slovakia
Ethiopia
Solomon Islands
Finland
South Africa
Georgia
Spain
Ghana
Suriname
Guatemala
Swaziland
Guinea
Sweden
Guyana
Taiwan
Honduras
Tanzania
India
Thailand
Indonesia
Togo
Ivory Coast
Turkey
Kazakhstan
Uganda
Kenya
United Kingdom
Kyrgyzstan
United States
Laos
Uruguay
Lebanon
Uzbekistan
Madagascar
Venezuela
Malaysia
Zambia
Mali
Zimbabwe

B-1