EX-1.01 2 exhibit101-cmr.htm EX-1.01 Document

Exhibit 1.01

Pentair plc
Conflict Minerals Report
For the reporting period from January 1, 2019 to December 31, 2019

This Conflict Minerals Report for the period from January 1, 2019 to December 31, 2019 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (the “Rule”). The Rule was adopted to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Rule imposes reporting obligations on Securities and Exchange Commission (“SEC”) registrants whose manufactured products contain certain minerals that are necessary to the functionality or production of their respective products.

If a registrant determines that any columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten (the “Subject Minerals”), are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured, the registrant must conduct in good faith a Reasonable Country of Origin Inquiry (“RCOI”) regarding those Subject Minerals that is reasonably designed to determine whether any of the Subject Minerals originated in the Democratic Republic of the Congo or an adjoining country (the “Covered County” or “Covered Countries”) or are from recycled or scrap sources.

If, following the completion of the RCOI, a registrant knows that any of the necessary Subject Minerals originated in a Covered Country and are not from recycled or scrap sources, or has reason to believe that any of its necessary Subject Minerals may have originated in the Covered Countries and has reason to believe that its necessary Subject Minerals did not come from recycled or scrap sources, then the registrant must exercise due diligence on the source and chain of custody of the Subject Minerals that conforms to a nationally or internationally recognized due diligence framework and describe such due diligence in this separate Conflict Minerals Report.

In accordance with the Organisation for Economic Co-operation and Development Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, the related supplements on tin, tungsten, tantalum and gold (the “Guidance”) and the Rule, this Conflict Minerals Report is available on the Company’s website at https://www.pentair.com/en/partner-supplier-info.html.

Consistent with the provisions of the Rule, the SEC’s Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule, dated April 29, 2014, the SEC’s Order Issuing Stay, dated May 2, 2014, and the SEC’s Updated Statement on the Effect of the Court of Appeals Decision on the Conflict Minerals Rule, dated April 7, 2017, this Conflict Minerals Report has not been audited by a third party.

1.Company Overview

At Pentair, we believe the health of our world depends on reliable access to clean water. We deliver a comprehensive range of smart, sustainable water solutions to homes, business and industry around the world. Our industry leading and proven portfolio of solutions enables our customers to access clean, safe water, reduce water consumption, and recover and reuse it. Whether it’s improving, moving or helping people enjoy water, we help manage the world’s most precious resource.




At the end of calendar year 2019, the Company was comprised of three reporting segments:

The Aquatic Systems segment, which manufactured and sold a complete line of energy-efficient residential and commercial pool equipment and accessories including pumps, filters, heaters, lights, automatic controls, automatic cleaners, maintenance equipment and pool accessories.
The Filtration Solutions segment, which designed, manufactured, marketed and serviced innovative water solutions to meet filtration and separation challenges across residential, commercial, food & beverage and industrial applications.
The Flow Technologies segment, which manufactured and sold products ranging from light duty diaphragm pumps to high-flow turbine pumps and solid handling pumps while serving the global residential, commercial and industrial markets.

During the first quarter of 2020, the Company reorganized its reporting segments to reflect a new operating structure. As part of this reorganization, the legacy Aquatic Systems reporting segment was combined with the Residential and Commercial Systems and Components businesses of the legacy Filtrations Solutions reporting segment to form the Consumer Solutions reporting segment. In addition, the Industrial Filtration and Food and Beverage businesses of the legacy Filtration Solutions reporting segment were combined with the legacy Flow Technologies reporting segment to form the Industrial & Flow Technologies reporting segment.

The Company conducted an analysis of all of its products and its entire supply chain, and, accordingly, the Company did not limit its review to those products that may have contained Subject Minerals. This Conflict Minerals Report relates to all products (which are collectively referred to as the “Covered Products”): (i) that were manufactured, or contracted to be manufactured, by the Company; and (ii) for which the manufacture was completed during calendar year 2019.

The Company has adopted a Conflict Minerals Policy that emphasizes the Company’s commitment to complying with the Rule and to identifying the source of the Subject Minerals contained in the Company’s products. The Company also indicates in its Global Supplier Guide (the “Supplier Guide”) that it expects all suppliers doing business with the Company to cooperate with the conflict minerals due diligence process. The Company also has participated in groups and forums focused on responsible sourcing of Subject Minerals, including the Responsible Minerals Initiative (the “RMI”) and industry association groups such as the Twin Cities Conflict Minerals Task Force.

Unless the context otherwise indicates, references herein to “Pentair,” the “Company,” and such words as “we,” “us,” and “our” include Pentair plc and its consolidated subsidiaries.

2.Conflict Minerals Compliance Process
2.1 Compliance Framework Overview
The Company designed its due diligence measures to conform in all material respects to the Guidance.
2.2 Reasonable Country of Origin Inquiry
The Company designed its RCOI to provide a reasonable basis for it to determine whether the Company sources Subject Minerals from Covered Countries and whether any of the Subject Minerals may be from recycled or scrap sources.

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The Company began by analyzing its supplier base and designating certain suppliers as outside the scope of the RCOI process if they met one or more of the following criteria:

The supplier provides the Company with packaging only (excluding labels).
The supplier provides the Company with items that are not included in our finished products, such as the equipment used to manufacture our products.
The supplier is a test lab or other service provider.

After removing these out-of-scope suppliers, the Company then conducted a survey of its remaining suppliers using the template maintained by the RMI, known as the Conflict Minerals Reporting Template version 5.12 (the “CMRT Form”). The CMRT Form was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. The CMRT Form includes questions regarding a direct supplier’s conflict minerals policy, engagement with its direct suppliers, origin of Subject Minerals included in its products, supplier due diligence and a listing of the smelters that the direct supplier and its suppliers use. Written instructions and recorded training illustrating the use of the tool are available on the RMI’s website.

The Company’s inquiry process included multiple rounds of communication and follow-up, including mail, email and telephone calls, with over 4,300 direct suppliers spanning five enterprise resource planning systems. The Company received, reviewed and processed responses from 60% of the suppliers surveyed, which represented approximately 95% of total calendar year 2019 supplier expenditures.

The Company reviewed the responses against risk-based criteria developed to determine which responses required further engagement with the relevant suppliers. These criteria included inconsistencies within the data reported in the CMRT Form and other risk-based criteria. The Company worked directly with these suppliers to obtain revised responses and/or additional clarity regarding their submissions.

As part of this year’s program, the Company also conducted automated data validation on all submitted supplier responses. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers provided by suppliers. Following the data validation process, the Company classified submitted forms as either valid or invalid and contacted suppliers regarding forms classified as invalid to encourage such suppliers to resubmit valid forms. As of May 10, 2020, the Company still had 30 (1%) invalid supplier submissions that were not yet corrected. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

Among the supplier responses received by the Company that were classified as valid, the Company received the following information:

Approximately 75% of supplier responses indicated that such supplier did not use Subject Minerals in the materials and components that it supplied to the Company during 2019.
Approximately 2% of supplier responses indicated that, to the best of such supplier’s knowledge, the Subject Minerals in the components and materials that it supplied to the Company during 2019 did not originate from a Covered Country.
Approximately 4% of supplier responses indicated that, to the best of such supplier’s knowledge, the Subject Minerals in the components and materials that it supplied to the Company during 2019 may have originated in a Covered Country from sources verified as conflict-free by third parties such as the RMI and others.
Approximately 19% of the Company’s suppliers indicated that the Subject Minerals in some of the components and materials supplied to the Company may have originated from a Covered Country, but those suppliers could not determine whether such Subject Minerals were conflict-free.
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After reviewing the results of the RCOI, the Company could not conclusively determine that it had no reason to believe that Subject Minerals necessary for the functionality or production of its products may have originated from a Covered Country during 2019. The Company conducted its RCOI in good faith, and the Company believes that such inquiry was reasonable to allow it to make the determination. Accordingly, the Company proceeded to exercise due diligence on the source and chain of custody of the Subject Minerals.

2.3 The Company’s Due Diligence Process
Design of Due Diligence
We designed our due diligence measures to conform, in all material respects, with the framework in the Guidance. The Guidance describes the five aspects of a robust due diligence program and provides guidelines for implementing each aspect. We developed our due diligence process to address each of these five aspects, namely:

1.Establishing strong company management systems regarding conflict minerals;
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; and
5.Publicly reporting on our supply chain due diligence
        
We are a downstream supplier, many steps removed from the mines and companies that produce the Subject Minerals. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, Pentair does not purchase raw ore or unrefined conflict minerals or make purchases directly from the Covered Countries. The origin of 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 Subject Minerals they procure.

The Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the 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 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 conflict minerals contained in the components and materials supplied to us.

2.3.1 Establish Strong Company Management Systems
Internal Team
The Company developed cross-functional teams to set its conflict minerals strategy and ensure timely implementation and execution of the due diligence program. The Company’s Supply, Quality & Development Group has primary responsibility for program execution. Guidance on the overall strategy and implementation is provided by the Legal Department, Accounting Department and Internal Audit Department. Senior management is briefed about the results of the due diligence program on a regular basis.

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The Company has developed internal training processes to educate anyone within the Company that is a potential contact point for suppliers or other external parties regarding the Company’s conflict minerals compliance efforts. In addition, the Company has either independently, or in cooperation with a third-party service provider, developed tailored training programs to train the Company’s employees with respect to the potential impact of conflict minerals. The Company leverages a team of dedicated program specialists through our third-party service provider, Assent Compliance Inc. (“Assent”), who supports the Company’s conflict minerals program and associated teams.

Ethics HelpLine
The Company has long-standing grievance mechanisms, including an Ethics HelpLine, whereby the Company’s employees can report violations of the Company’s Code of Business Conduct and Ethics, policy or law, including its procedures related to conflict minerals and the conflict minerals reporting process.

Control Systems and Supplier Engagement
Due to its position in the supply chain, the Company does not have a direct relationship with any Subject Minerals smelters and refiners. The Company engages with its suppliers and relies on information provided through the CMRT Form to gather information on the source and chain of custody of the Subject Minerals in its products.

In 2014, the Company updated its Supplier Guide to address, among other things, the Subject Minerals and the requirement of its suppliers to provide information on their use of these minerals. The Company also continues to update its supplier contracts by including a requirement that the supplier comply with the Supplier Guide whenever a new contract is entered into or an outstanding contract is renewed. In 2016, Pentair’s Terms and Conditions were updated to include compliance with laws including a broad reference to all business integrity-related laws and regulations.

Beginning in 2016, we have put a stronger emphasis on supplier education and training. To accomplish this, we utilized a third-party learning management system from Assent, known as Assent University, to provide all in-scope suppliers access to Assent’s Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.

In addition, the Company’s Conflict Minerals Policy is available on its website, and provides assistance to suppliers in their efforts to comply with the Company’s Conflict Minerals Policy, including video training, recorded training and written instructions as well as supplemental assistance through email and telephone contact as necessary. If the Company discovers that a direct supplier is not in compliance with the Company’s Conflict Minerals Policy, the Company may take certain actions to mitigate any potential risk, as described in Section 2.3.3, below.
Records Retention
The Company will retain documentation related to its conflict minerals compliance program according to the Company’s Document Retention Policy.
2.3.2 Identify and Assess Risk in the Supply Chain
The Company’s supply chain with respect to the Covered Products is complex. During 2019, the Company had over 4,300 direct suppliers with respect to the Covered Products, and there are many third
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parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of the Subject Minerals. In this regard, the Company does not purchase Subject Minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of Subject Minerals that are included in the Covered Products.

Based on this information, and in an effort to conform its due diligence measures to the Guidance, the Company assesses the risk in its supply chain in several ways. For example, the Company considers the potential risk presented by the smelters or refiners in its supply chain, as reported by the Company’s direct suppliers. Smelters or refiners that source the Subject Minerals from a Covered Country and are not certified as conflict-free by third-party audit programs such as the RMI’s Responsible Minerals Assurance Process (“RMAP”) pose a significant risk.

The Company assesses the risk in its supply chain by reviewing its direct suppliers’ responses to the CMRT Form, including whether such suppliers have established due diligence programs with respect to the Subject Minerals. The Company uses its direct suppliers’ responses to the CMRT Form to determine the extent to which it may be necessary for the Company to allocate additional due diligence resources.

Through Assent, the Company has also provided video and written training on compliance with the Rule, supply chain due diligence and the CMRT Form. This includes instructions on completing the CMRT Form, and one-on-one email and phone discussions with supplier personnel. In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners in the supply chain.

After the Company receives CMRT Forms completed by its direct suppliers, the Company, with the assistance of Assent, assesses each facility that meets the RMI definition of a smelter or refiner of a Subject Mineral and that is reported as being in the Company’s supply chain by the Company’s direct suppliers according to “red flag” indicators defined in the Guidance. Assent uses five factors to determine the level of risk that each smelter poses to the supply chain and reviews each for potential red flags:

The smelter or refiner’s geographic proximity to the Democratic Republic of the Congo and the other Covered Countries;
Known mineral sources in the country of origin;
The smelter or refiner’s audit status with respect to the RMAP;
Credible evidence of unethical or conflict-related sourcing practices associated with the smelter or refiner; and
Peer assessments of the smelter or refiner conducted by credible third-party sources.

Based on these factors, the Company has determined that the following smelter or refiner facilities, which were reported as being in the Company’s supply chain by the Company’s direct suppliers, have red flag risks (“Red-Flagged Facilities”):

Tony Goetz NV - CID002587
African Gold Refinery Limited (AGR) - CID003185
Kaloti Precious Metals - CID002563
Fidelity Printers and Refiners - CID002515
Sudan Gold Refinery - CID002567

Whenever a Red-Flagged Facility is reported as being in the Company’s supply chain, the Company implements risk mitigation activities that are described in specific detail in Section 2.3.3, below.

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Generally, in designing and implementing the Company’s strategy to respond to the supply chain risks that it has identified, the Company analyzed various third-party approaches and consulted with other companies in our industry. The Company has concluded that tracing the Subject Minerals back to their mine of origin directly is an exceedingly complex task, given the breadth and depth of the Company’s supply chain. Instead, the Company has determined that seeking information about smelters and refiners in the Company’s supply chain represents the most reasonable effort the Company can make to determine the mines or origin of the Subject Minerals in its supply chain. To this end, the Company has adopted methods outlined by the RMI’s joint industry programs and outreach initiatives, and the Company has required its suppliers to conform with the same standards and to report on their efforts using the CMRT Form. Through these methods, the Company has made a reasonable determination of the origin of the Subject Minerals in its supply chain.

Additionally, the Company evaluates its suppliers on the strength of their own compliance programs (which further assist the Company in identifying risk in its supply chain). Evaluating and tracking the strength of the Company’s suppliers’ compliance programs is recommended by the Guidance and can help the Company to make key risk mitigation decisions. The criteria the Company uses to evaluate the strength of a supplier’s program is based on the following four questions in the CMRT Form:

Have you established a conflict minerals sourcing policy?
Have you implemented due diligence measures for conflict-free sourcing?
Do you review due diligence information received from your suppliers against your company’s expectations?
Does your review process include corrective action management?
When a supplier meets or exceeds those criteria (by answering “yes” to all four questions), the

Company considers that supplier to have a strong compliance program. At this time, 1,809 of our 2,575 responsive suppliers, or 70%, have been identified as having a strong program.

2.3.3 Design and Implement a Strategy to Respond to Risks
In conjunction with the Company’s risk assessment process, the Company has developed a risk management plan for responding to risks identified in its supply chain, including Red-Flagged Facilities. Through the Company’s due diligence process, the Company attempts to determine the source and chain of custody of the necessary Subject Minerals the Company knows, or has reason to believe, originated in a Covered Country. Since the Company does not have a direct relationship with smelters and/or refiners, most of the work toward this aspect of the Guidance is carried out indirectly through the Company’s suppliers or through the Company’s involvement with industry working groups/coalitions. Due to its position in the supply chain, the Company largely focuses on the accuracy and quality of the representations the Company’s direct suppliers make regarding the source and chain of custody of their Subject Minerals. The Company evaluates its direct suppliers’ responses to RCOI and due diligence inquiries based on the risk or likelihood that they are giving an incorrect response or that a non-response may indicate the supplier is purchasing from a known conflict source and does not wish to disclose this fact.

With respect to the Red-Flagged Facilities, upon receiving a CMRT Form from a direct supplier that identifies a Red-Flagged Facility as being present in the Company’s supply chain, the Company immediately initiates risk mitigation activities. Through a third-party vendor, the Company directs any supplier reporting a Red-Flagged Facility to implement its own risk mitigation actions. These actions include submitting a product-specific CMRT Form to the Company, to better identify the connection between the Red-Flagged Facility and the materials or components the Company purchases from the
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supplier, and requesting that the supplier begin the process to remove any Red-Flagged Facility from the supplier’s supply chain.

As per the OECD Due Diligence Guidance, specific risk mitigation procedures depend on the suppliers’ specific situation. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.

As part of the Company’s risk management plan, and to ensure its suppliers understood the Company’s expectations, the Company has provided video training, recorded training and documented instructions to its direct suppliers through Assent. The Company also provided additional direct assistance to suppliers that required further clarification on the Company’s expectations. The Company then provided each supplier with a copy of the CMRT Form to complete as part of the Company’s due diligence process. Furthermore, as described above, the Company reviewed responses with specific suppliers where the responses suggested inaccuracies, inconsistencies or otherwise warranted further inquiry.

Finally, in accordance with the Company’s Conflict Minerals Policy, the Company engages any of its suppliers that it has reason to believe may be supplying the Company with Subject Minerals from sources that may support conflict in any of the Covered Countries to request that such suppliers establish an alternate source of Subject Minerals that does not support armed conflict in the Covered Countries.

The Company’s global supplier development team responds to suppliers that may potentially expose the Company to unacceptable risks, due to unacceptable responses to the Company’s inquiries or a refusal to respond. If the global supplier development team determines that a supplier is non-responsive, or is not satisfied with a supplier’s risk mitigation efforts, the global supplier development team may ultimately recommend that the Company take steps to find replacement suppliers as soon as is practicable.
2.3.4 Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
The Company does not have a direct relationship with Subject Minerals smelters and refiners and does not perform or direct audits of these entities within the Company’s supply chain. The Company supports audits by engaging its partners who are closer to the source and, as a member of the RMI, by promoting the smelter and refiner verification procedures and protocols of the RMAP.

Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facility’s sourcing practices on behalf of its compliance partners. The Company is a signatory of this communication in accordance with the requirements of downstream companies detailed in the Guidance.
2.3.5 Report on Supply Chain Due Diligence
This Conflict Minerals Report is being filed with the SEC as an exhibit to the Company’s specialized disclosure report on Form SD and is available on our website at https://www.pentair.com/en/partner-supplier-info.html.
Due Diligence Results
Attached as Annex I to this Conflict Minerals Report is a list of all of the smelters and refiners listed by our suppliers in their completed CMRT Forms that appear on the list of smelters maintained by the RMI. Because most of the CMRT Forms we received 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 Annex I
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actually processed the Subject Minerals contained in our products. Therefore, our list of processing smelters and refiners in Annex I may contain more facilities than those that actually processed the Subject Minerals in our products. The Company does not have sufficient information, with respect to the Covered Products, to conclusively determine the country of origin of the Subject Minerals in the Covered Products or to conclusively determine whether the Subject Minerals in the Covered Products are from recycled or scrap sources. However, based on the information provided by the Company’s suppliers, smelters and refiners, as well as from the RMI and other sources, the Company believes the countries of origin of the Subject Minerals contained in the Covered Products include the countries listed in Annex II to this Conflict Minerals Report, as well as recycled and scrap sources.

After reviewing the information provided by its suppliers, the Company identified 303 legitimate smelters and refiners of the Subject Minerals in the Covered Products as being present in its supply chain for the calendar year 2019. Of the 303 legitimate smelters and refiners present in the Company’s supply chain for the calendar year 2019, 13 were identified as having sourced Subject Minerals from a Covered Country, all of which were verified as conformant with the RMAP. Of the remaining 290 legitimate smelters and refiners, the Company identified 222 as conformant with the RMAP and another 6 that were active with the RMAP (but not yet conformant). After following up with the relevant suppliers, to the best of its ability, the Company found that the remaining 62 valid smelters and refiners in its supply chain had not yet substantively engaged with the RMAP or other industry groups, but the Company found no reasonable basis to conclude these smelters and refiners may have sourced Subject Minerals from a Covered Country, that directly or indirectly financed or benefited armed groups.

3. Conflict Minerals Compliance Process

During calendar year 2019, the Company took the following steps to improve the quality of its due diligence:

Continued our work with our suppliers to help them understand our expectations regarding the Subject Minerals in our supply chain and our suppliers’ due diligence of their own supply chains, including their ability to confirm the conflict-free status of identified smelters and refiners.
Continued to emphasize to suppliers our expectation that they move toward sourcing exclusively from conflict-free smelters and refiners verified by the RMAP.
For suppliers unable to immediately source from conflict-free smelters and refiners verified by the RMAP, requested that those suppliers develop, share and implement a mitigation plan to source exclusively from conflict-free smelters and refiners.
Continued our engagement with industry groups, including the RMI, that support the adoption and improvement of relevant programs, tools and standards.
Enabled a real-time CMRT Form validation tool to identify problems with supplier CMRT Forms and communicate this clearly to suppliers to enable them to fix their submissions before providing to the Company.

During calendar year 2020, the Company plans to continue to refine the implementation of its 2019 initiatives to further improve the quality of its due diligence.
 
4. Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements intended to qualify for the safe harbor from liability established by the Private Securities Litigation Reform Act of 1995. All statements, other than statements of historical fact, included in this Conflict Minerals Report, including, without limitation, statements regarding our conflict mineral compliance plans, are forward-looking statements. These forward-looking statements generally are identified by the words “targets,” “plans,” "believes," "expects,"
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"intends," "will," "likely," "may," "anticipates," "estimates," "projects," "should," "would," positioned," "strategy," "future" or phrases or terms of similar substance or the negative thereof or similar terminology generally intended to identify forward-looking statements. 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 Conflict Minerals Report, including, among others, our ability to implement new software systems, our suppliers' willingness and ability to comply with our conflict minerals-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 conflict minerals 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 Conflict Minerals 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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Annex I
List of Smelters and Refiners
METAL
STANDARD SMELTER NAME
SMELTER FACILITY LOCATION
RMI AUDIT STATUS
GOLD
8853 S.p.A.
ITALY
Conformant
GOLD
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Non Conformant
GOLD
Advanced Chemical Company
UNITED STATES OF AMERICA
Conformant
GOLD
African Gold Refinery
UGANDA
Outreach Required
GOLD
Aida Chemical Industries Co., Ltd.
JAPAN
Conformant
GOLD
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Conformant
GOLD
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Conformant
GOLD
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Conformant
GOLD
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Conformant
GOLD
Argor-Heraeus S.A.
SWITZERLAND
Conformant
GOLD
Asahi Pretec Corp.
JAPAN
Conformant
GOLD
Asahi Refining Canada Ltd.
CANADA
Conformant
GOLD
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Conformant
GOLD
Asaka Riken Co., Ltd.
JAPAN
Conformant
GOLD
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Due Diligence Vetting Process
GOLD
AU Traders and Refiners
SOUTH AFRICA
Conformant
GOLD
Aurubis AG
GERMANY
Conformant
GOLD
Bangalore Refinery
INDIA
Conformant
GOLD
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Conformant
GOLD
Boliden AB
SWEDEN
Conformant
GOLD
C. Hafner GmbH + Co. KG
GERMANY
Conformant
GOLD
C.I Metales Procesados Industriales SAS
COLOMBIA
In Communication
GOLD
Caridad
MEXICO
Communication Suspended - Not Interested
GOLD
CCR Refinery - Glencore Canada Corporation
CANADA
Conformant
GOLD
Cendres + Metaux S.A.
SWITZERLAND
Conformant
GOLD
CGR Metalloys Pvt Ltd.
INDIA
Outreach Required
GOLD
Chimet S.p.A.
ITALY
Conformant
GOLD
Chugai Mining
JAPAN
Conformant
GOLD
Daye Non-Ferrous Metals Mining Ltd.
CHINA
In Communication
GOLD
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Outreach Required
GOLD
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
In Communication
GOLD
DODUCO Contacts and Refining GmbH
GERMANY
Conformant
GOLD
Dowa
JAPAN
Conformant
GOLD
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Conformant
GOLD
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Conformant
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GOLD
Eco-System Recycling Co., Ltd. East Plant
JAPAN
Conformant
GOLD
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Conformant
GOLD
Eco-System Recycling Co., Ltd. West Plant
JAPAN
Conformant
GOLD
Emirates Gold DMCC
UNITED ARAB EMIRATES
Conformant
GOLD
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Due Diligence Vetting Process
GOLD
Fujairah Gold FZC
UNITED ARAB EMIRATES
Outreach Required
GOLD
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
In Communication
GOLD
Geib Refining Corporation
UNITED STATES OF AMERICA
Conformant
GOLD
Gold Coast Refinery
GHANA
Outreach Required
GOLD
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Conformant
GOLD
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Outreach Required
GOLD
Guangdong Jinding Gold Limited
CHINA
Outreach Required
GOLD
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Outreach Required
GOLD
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Outreach Required
GOLD
Heimerle + Meule GmbH
GERMANY
Conformant
GOLD
Heraeus Metals Hong Kong Ltd.
CHINA
Conformant
GOLD
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Conformant
GOLD
Hunan Chenzhou Mining Co., Ltd.
CHINA
Outreach Required
GOLD
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Outreach Required
GOLD
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Communication Suspended - Not Interested
GOLD
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Conformant
GOLD
International Precious Metal Refiners
UNITED ARAB EMIRATES
Outreach Required
GOLD
Ishifuku Metal Industry Co., Ltd.
JAPAN
Conformant
GOLD
Istanbul Gold Refinery
TURKEY
Conformant
GOLD
Italpreziosi
ITALY
Conformant
GOLD
JALAN & Company
INDIA
Outreach Required
GOLD
Japan Mint
JAPAN
Conformant
GOLD
Jiangxi Copper Co., Ltd.
CHINA
Conformant
GOLD
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
RMI Due Diligence Review - Unable to Proceed
GOLD
JSC Uralelectromed
RUSSIAN FEDERATION
Conformant
GOLD
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Conformant
GOLD
Kaloti Precious Metals
UNITED ARAB EMIRATES
RMI Due Diligence Review - Unable to Proceed
GOLD
Kazakhmys Smelting LLC
KAZAKHSTAN
In Communication
GOLD
Kazzinc
KAZAKHSTAN
Conformant
GOLD
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Conformant
GOLD
KGHM Polska Miedz Spolka Akcyjna
POLAND
Conformant
GOLD
Kojima Chemicals Co., Ltd.
JAPAN
Conformant
GOLD
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Conformant
12


GOLD
Kyrgyzaltyn JSC
KYRGYZSTAN
Conformant
GOLD
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Outreach Required
GOLD
L'azurde Company For Jewelry
SAUDI ARABIA
RMI Due Diligence Review - Unable to Proceed
GOLD
Lingbao Gold Co., Ltd.
CHINA
Outreach Required
GOLD
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Outreach Required
GOLD
L'Orfebre S.A.
ANDORRA
Conformant
GOLD
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Conformant
GOLD
LT Metal Ltd.
KOREA, REPUBLIC OF
Conformant
GOLD
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Outreach Required
GOLD
Marsam Metals
BRAZIL
Conformant
GOLD
Materion
UNITED STATES OF AMERICA
Conformant
GOLD
Matsuda Sangyo Co., Ltd.
JAPAN
Conformant
GOLD
Metalor Technologies (Hong Kong) Ltd.
CHINA
Conformant
GOLD
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Conformant
GOLD
Metalor Technologies (Suzhou) Ltd.
CHINA
Conformant
GOLD
Metalor Technologies S.A.
SWITZERLAND
Conformant
GOLD
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Conformant
GOLD
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Conformant
GOLD
Mitsubishi Materials Corporation
JAPAN
Conformant
GOLD
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
GOLD
MMTC-PAMP India Pvt., Ltd.
INDIA
Conformant
GOLD
Modeltech Sdn Bhd
MALAYSIA
Non Conformant
GOLD
Morris and Watson
NEW ZEALAND
Communication Suspended - Not Interested
GOLD
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Conformant
GOLD
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Conformant
GOLD
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Outreach Required
GOLD
NH Recytech Company
KOREA, REPUBLIC OF
Non Conformant
GOLD
Nihon Material Co., Ltd.
JAPAN
Conformant
GOLD
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Conformant
GOLD
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Conformant
GOLD
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Conformant
GOLD
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Conformant
GOLD
PAMP S.A.
SWITZERLAND
Conformant
GOLD
Pease & Curren
UNITED STATES OF AMERICA
Outreach Required
GOLD
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Outreach Required
GOLD
Planta Recuperadora de Metales SpA
CHILE
Conformant
GOLD
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Conformant
GOLD
PT Aneka Tambang (Persero) Tbk
INDONESIA
Conformant
GOLD
PX Precinox S.A.
SWITZERLAND
Conformant
GOLD
QG Refining, LLC
UNITED STATES OF AMERICA
Outreach Required
GOLD
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Conformant
GOLD
Refinery of Seemine Gold Co., Ltd.
CHINA
Outreach Required
GOLD
REMONDIS PMR B.V.
NETHERLANDS
Conformant
GOLD
Royal Canadian Mint
CANADA
Conformant
GOLD
SAAMP
FRANCE
Conformant
GOLD
Sabin Metal Corp.
UNITED STATES OF AMERICA
Outreach Required
13


GOLD
Safimet S.p.A
ITALY
Conformant
GOLD
SAFINA A.S.
CZECH REPUBLIC
Active
GOLD
Sai Refinery
INDIA
Outreach Required
GOLD
Samduck Precious Metals
KOREA, REPUBLIC OF
Conformant
GOLD
Samwon Metals Corp.
KOREA, REPUBLIC OF
Communication Suspended - Not Interested
GOLD
SAXONIA Edelmetalle GmbH
GERMANY
Conformant
GOLD
SEMPSA Joyeria Plateria S.A.
SPAIN
Conformant
GOLD
Shandong Humon Smelting Co., Ltd.
CHINA
Outreach Required
GOLD
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Outreach Required
GOLD
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Conformant
GOLD
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Conformant
GOLD
Singway Technology Co., Ltd.
TAIWAN
Conformant
GOLD
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Conformant
GOLD
Solar Applied Materials Technology Corp.
TAIWAN
Conformant
GOLD
Sovereign Metals
INDIA
Outreach Required
GOLD
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Outreach Required
GOLD
Sudan Gold Refinery
SUDAN
Outreach Required
GOLD
Sumitomo Metal Mining Co., Ltd.
JAPAN
Conformant
GOLD
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Conformant
GOLD
T.C.A S.p.A
ITALY
Conformant
GOLD
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Conformant
GOLD
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Conformant
GOLD
Tokuriki Honten Co., Ltd.
JAPAN
Conformant
GOLD
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Outreach Required
GOLD
Tony Goetz NV
BELGIUM
Non Conformant
GOLD
TOO Tau-Ken-Altyn
KAZAKHSTAN
Conformant
GOLD
Torecom
KOREA, REPUBLIC OF
Conformant
GOLD
Umicore Brasil Ltda.
BRAZIL
Conformant
GOLD
Umicore Precious Metals Thailand
THAILAND
Conformant
GOLD
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Conformant
GOLD
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Conformant
GOLD
Valcambi S.A.
SWITZERLAND
Conformant
GOLD
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Conformant
GOLD
WIELAND Edelmetalle GmbH
GERMANY
Conformant
GOLD
Yamakin Co., Ltd.
JAPAN
Conformant
GOLD
Yokohama Metal Co., Ltd.
JAPAN
Conformant
GOLD
Yunnan Copper Industry Co., Ltd.
CHINA
Outreach Required
GOLD
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Conformant
TANTALUM
Asaka Riken Co., Ltd.
JAPAN
Conformant
TANTALUM
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Conformant
TANTALUM
CP Metals Inc.
UNITED STATES OF AMERICA
Conformant
TANTALUM
D Block Metals, LLC
UNITED STATES OF AMERICA
Conformant
TANTALUM
Exotech Inc.
UNITED STATES OF AMERICA
Conformant
TANTALUM
F&X Electro-Materials Ltd.
CHINA
Conformant
TANTALUM
FIR Metals & Resource Ltd.
CHINA
Conformant
TANTALUM
Global Advanced Metals Aizu
JAPAN
Conformant
TANTALUM
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Conformant
14


TANTALUM
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Conformant
TANTALUM
H.C. Starck Co., Ltd.
THAILAND
Conformant
TANTALUM
H.C. Starck Hermsdorf GmbH
GERMANY
Conformant
TANTALUM
H.C. Starck Inc.
UNITED STATES OF AMERICA
Conformant
TANTALUM
H.C. Starck Ltd.
JAPAN
Conformant
TANTALUM
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Conformant
TANTALUM
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Conformant
TANTALUM
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Conformant
TANTALUM
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Conformant
TANTALUM
Jiangxi Tuohong New Raw Material
CHINA
Conformant
TANTALUM
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Conformant
TANTALUM
Jiujiang Tanbre Co., Ltd.
CHINA
Conformant
TANTALUM
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Conformant
TANTALUM
KEMET Blue Metals
MEXICO
Conformant
TANTALUM
LSM Brasil S.A.
BRAZIL
Conformant
TANTALUM
Metallurgical Products India Pvt., Ltd.
INDIA
Conformant
TANTALUM
Mineracao Taboca S.A.
BRAZIL
Conformant
TANTALUM
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
TANTALUM
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Conformant
TANTALUM
NPM Silmet AS
ESTONIA
Conformant
TANTALUM
PRG Dooel
NORTH MACEDONIA, REPUBLIC OF
Conformant
TANTALUM
QuantumClean
UNITED STATES OF AMERICA
Conformant
TANTALUM
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
TANTALUM
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Conformant
TANTALUM
Taki Chemical Co., Ltd.
JAPAN
Conformant
TANTALUM
Telex Metals
UNITED STATES OF AMERICA
Conformant
TANTALUM
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Conformant
TANTALUM
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Conformant
TANTALUM
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Conformant
TIN
Alpha
UNITED STATES OF AMERICA
Conformant
TIN
An Vinh Joint Stock Mineral Processing Company
VIETNAM
Outreach Required
TIN
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Conformant
TIN
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Conformant
TIN
China Tin Group Co., Ltd.
CHINA
Conformant
TIN
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
Non Conformant
TIN
Dowa
JAPAN
Conformant
TIN
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIETNAM
Non Conformant
TIN
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
TIN
Estanho de Rondonia S.A.
BRAZIL
In Communication
TIN
Fenix Metals
POLAND
Conformant
TIN
Gejiu City Fuxiang Industry and Trade Co., Ltd.
CHINA
Outreach Required
TIN
Gejiu Kai Meng Industry and Trade LLC
CHINA
Conformant
TIN
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Conformant
TIN
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Conformant
TIN
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Conformant
TIN
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Conformant
TIN
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Conformant
15


TIN
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Conformant
TIN
Huichang Jinshunda Tin Co., Ltd.
CHINA
Conformant
TIN
Jiangxi New Nanshan Technology Ltd.
CHINA
Conformant
TIN
Luna Smelter, Ltd.
RWANDA
Conformant
TIN
Ma'anshan Weitai Tin Co., Ltd.
CHINA
Conformant
TIN
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Conformant
TIN
Malaysia Smelting Corporation (MSC)
MALAYSIA
Conformant
TIN
Melt Metais e Ligas S.A.
BRAZIL
Conformant
TIN
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Conformant
TIN
Metallo Belgium N.V.
BELGIUM
Conformant
TIN
Metallo Spain S.L.U.
SPAIN
Conformant
TIN
Mineracao Taboca S.A.
BRAZIL
Conformant
TIN
Minsur
PERU
Conformant
TIN
Mitsubishi Materials Corporation
JAPAN
Conformant
TIN
Modeltech Sdn Bhd
MALAYSIA
Non Conformant
TIN
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIETNAM
Outreach Required
TIN
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Conformant
TIN
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Conformant
TIN
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
TIN
Pongpipat Company Limited
MYANMAR
Outreach Required
TIN
Precious Minerals and Smelting Limited
INDIA
Active
TIN
PT Artha Cipta Langgeng
INDONESIA
Conformant
TIN
PT ATD Makmur Mandiri Jaya
INDONESIA
Conformant
TIN
PT Menara Cipta Mulia
INDONESIA
Conformant
TIN
PT Mitra Stania Prima
INDONESIA
Conformant
TIN
PT Refined Bangka Tin
INDONESIA
Conformant
TIN
PT Timah Tbk Kundur
INDONESIA
Conformant
TIN
PT Timah Tbk Mentok
INDONESIA
Conformant
TIN
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
TIN
Rui Da Hung
TAIWAN
Conformant
TIN
Soft Metais Ltda.
BRAZIL
Conformant
TIN
Super Ligas
BRAZIL
Outreach Required
TIN
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIETNAM
Conformant
TIN
Thaisarco
THAILAND
Conformant
TIN
Tin Technology & Refining
UNITED STATES OF AMERICA
Conformant
TIN
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIETNAM
Outreach Required
TIN
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Conformant
TIN
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Conformant
TIN
Yunnan Tin Company Limited
CHINA
Conformant
TIN
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
Conformant
TUNGSTEN
A.L.M.T. Corp.
JAPAN
Conformant
TUNGSTEN
ACL Metais Eireli
BRAZIL
Conformant
16


TUNGSTEN
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
Active
TUNGSTEN
Asia Tungsten Products Vietnam Ltd.
VIETNAM
Conformant
TUNGSTEN
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Conformant
TUNGSTEN
China Molybdenum Co., Ltd.
CHINA
In Communication
TUNGSTEN
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Conformant
TUNGSTEN
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Outreach Required
TUNGSTEN
CP Metals Inc.
UNITED STATES OF AMERICA
Active
TUNGSTEN
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Conformant
TUNGSTEN
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Conformant
TUNGSTEN
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Conformant
TUNGSTEN
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Conformant
TUNGSTEN
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Conformant
TUNGSTEN
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Conformant
TUNGSTEN
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Conformant
TUNGSTEN
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Conformant
TUNGSTEN
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Conformant
TUNGSTEN
H.C. Starck Tungsten GmbH
GERMANY
Conformant
TUNGSTEN
Hunan Chenzhou Mining Co., Ltd.
CHINA
Conformant
TUNGSTEN
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Conformant
TUNGSTEN
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Conformant
TUNGSTEN
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
Conformant
TUNGSTEN
Hydrometallurg, JSC
RUSSIAN FEDERATION
Conformant
TUNGSTEN
Japan New Metals Co., Ltd.
JAPAN
Conformant
TUNGSTEN
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Conformant
TUNGSTEN
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Conformant
TUNGSTEN
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Communication Suspended - Not Interested
TUNGSTEN
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Conformant
TUNGSTEN
Jiangxi Xianglu Tungsten Co., Ltd.
CHINA
Active
TUNGSTEN
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Conformant
TUNGSTEN
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Conformant
TUNGSTEN
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Active
TUNGSTEN
Kennametal Fallon
UNITED STATES OF AMERICA
Conformant
TUNGSTEN
Kennametal Huntsville
UNITED STATES OF AMERICA
Conformant
TUNGSTEN
KGETS Co., Ltd.
KOREA, REPUBLIC OF
Conformant
TUNGSTEN
Lianyou Metals Co., Ltd.
TAIWAN
Conformant
TUNGSTEN
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Conformant
TUNGSTEN
Masan Tungsten Chemical LLC (MTC)
VIETNAM
Conformant
TUNGSTEN
Moliren Ltd.
RUSSIAN FEDERATION
Conformant
TUNGSTEN
Niagara Refining LLC
UNITED STATES OF AMERICA
Conformant
TUNGSTEN
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Conformant
17


TUNGSTEN
Tejing (Vietnam) Tungsten Co., Ltd.
VIETNAM
Conformant
TUNGSTEN
Unecha Refractory metals plant
RUSSIAN FEDERATION
Conformant
TUNGSTEN
Wolfram Bergbau und Hutten AG
AUSTRIA
Conformant
TUNGSTEN
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Conformant
TUNGSTEN
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Conformant
TUNGSTEN
Xiamen Tungsten Co., Ltd.
CHINA
Conformant
TUNGSTEN
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Conformant
TUNGSTEN
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Conformant

18


Annex II
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-level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia (Plurinational State of), Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Djibouti, Dominican Republic, Democratic Republic of the Congo, Ecuador, Egypt, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic of Korea, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zambia, Zimbabwe
19