SD

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

STAPLES, INC.

(Exact name of registrant as specified in charter)

Delaware	0-17586	04-2896127
(State or other jurisdiction of incorporation)	(Commission File Number)	(IRS Employer Identification No.)

Five Hundred Staples Drive, Framingham, MA	01702
(Address of principal executive offices)	(Zip Code)

Michael T. Williams, Executive Vice President, General Counsel & Secretary	508-253-5000
(Name and telephone number, including area code, of the person to contact in connection with this report)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

þ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.

Introduction

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the "Conflict Minerals Rule”), Staples, Inc. ("Staples," the "Company" or "we") is filing this Form SD to disclose information relating to the use and sourcing of columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten ("3TG" or "Conflict Minerals") that are necessary to the functionality or production of products we manufacture or contract to manufacture, including whether such minerals originated in the Democratic Republic of the Congo ("DRC") or an Adjoining Country. For purposes of the Conflict Minerals Rule, this Form SD and the CMR (as defined below), Adjoining Countries include the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

(a) During the reporting period covering January 1, 2014 through December 31, 2014 (the "2014 Report Year"), Staples contracted to manufacture products for which 3TG is necessary to the functionality or production.

(b) Staples conducted a reasonable country of origin inquiry ("RCOI") designed to determine whether any 3TG originated in the DRC or an Adjoining Country, or from recycled or scrap sources. Based on this RCOI, Staples determined that it was required to exercise due diligence on the source and chain of custody of such 3TG and to file a Conflict Mineral Report ("CMR") for the 2014 Report Year. Our CMR for the 2014 Report Year is attached hereto as Exhibit 1.01.

This Form SD and the associated CMR for the 2014 Report Year are posted to a publicly available Internet site at http://www.staples.com/sbd/cre/marketing/about_us/ethical-sourcing.html. The content of any website referred to herein is included for general information only and is not incorporated by reference in this Form SD or the CMR.

Item 1.02 Exhibit

Our CMR for the 2014 Report Year, as required by Item 1.02., is attached hereto as Exhibit 1.01.

Item 2.01 Exhibits

Exhibit 1.02 – Conflict Minerals Report for the reporting period covering January 1, 2014 through December 31, 2014, as required by Items 1.01 and 1.02.

SIGNATURE

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

Date:	June 1, 2015	Staples, Inc.
		By:	/s/ Michael T. Williams
			Michael T. Williams
			Executive Vice President,
			General Counsel & Secretary

EX-1.01

Exhibit 1.01

Conflict Minerals Report of Staples, Inc

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934

This is the Conflict Minerals Report ("CMR") of Staples, Inc ("Staples," Company" or "we") for the reporting period covering January 1, 2014 through December 31, 2014 (the "2014 Report Year") in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”) and Form SD.

INTRODUCTION

Staples is a provider of products and services that serve the needs of business customers and consumers. We sell a wide variety of office supplies, business technology products, facility and breakroom supplies, computers and mobility products, copy and print services and office furniture. We have determined that we are subject to the Conflict Minerals Rule because we contracted to manufacture and exercised varying degrees of influence over the design and manufacture of certain of our proprietary branded products.

This CMR describes Staples' due diligence on the source and chain of custody of gold, columbite-tantalite (coltan), cassiterite, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten ("3TG" or "Conflict Minerals") that are necessary to the production or functionality of products that Staples contracted to manufacture during the 2014 Report Year. We are not a manufacturer and are several steps removed from the mining and processing of the 3TG used in the components for our products. Accordingly, our due diligence process focused on our suppliers and we rely on them to assist with our reasonable country of origin inquiry ("RCOI") and due diligence efforts, including the identification of smelters and refiners in the supply chain and the countries of origin of 3TG sourced by the identified smelters and refiners.

Capitalized terms used but not defined herein are as defined in the Conflict Minerals Rule and Form SD.

PRODUCT DESCRIPTION

The due diligence measures set forth below, including the RCOI, were undertaken with respect to suppliers of products that Staples contracted to manufacture in the product categories set forth on Annex A.

The products that were identified as in-scope for purposes of the Conflict Mineral Rule due to likely presence of 3TG were those that are electronic or electrical, solar powered, contained any kind of metal (e.g., metal covering

including alloys or metal hardware), or where there was uncertainty as to use of metals in the component parts. If there was uncertainty regarding the material content or possibility for 3TG used in the products that Staples contracted to manufacture in the 2014 Report Year, the suppliers of such products were included in the RCOI process. Based on this criteria, 299 direct suppliers were identified and contacted as part of the RCOI process. Of the participating suppliers, 26% indicated 3TG (one or more of the minerals) as necessary to the functionality or production of the products they supply to us.

DUE DILIGENCE

Staples designed its due diligence process to conform, in all material respects, with 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 Supplements as applicable for downstream companies.

In accordance with the OECD five-step framework, we undertook the following due diligence measures:

STEP 1: Establish strong company management systems.

• Adopted and Communicated a Conflict Minerals Policy. We established a Conflict Minerals Policy and externally communicated the policy on our Ethics/Ethical Sourcing page on our publicly available website at http://www.staples.com/sbd/cre/marketing/about_us/ethical-sourcing.html.

• Organized Resources to Support Supply Chain Due Diligence.

◦ We assembled an internal team to support our Conflict Minerals Policy and compliance strategy, including representatives from our Legal, Compliance, Environmental Affairs/Sustainability, Staples Brands Group (our "own brand" group within merchandising), Staples Promotional Products, Investor Relations, Internal Audit and Finance functions and business units. The team provides its recommendations, and reports its findings, to the General Counsel, Chief Financial Officer and other senior management.

◦ We retained external advisors to assist with our due diligence efforts. We engaged Source Intelligence, a third-party information management services provider, among other things, to: engage in supplier outreach; collect, process and store information about the presence and sourcing of 3TG from our suppliers; validate supplier responses; and provide quality assurance by identifying and resolving "quality control flags". We also communicated with outside legal counsel to advise on compliance with the Conflict Minerals Rule, and attended industry training.

◦ We provided information to our suppliers about the Conflict Minerals Rule, our RCOI and due diligence process and expectations for participation and support of our compliance program. In addition to direct communications with our suppliers, Source Intelligence maintained a "Supplier

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Resource Center" that included tools to facilitate a deeper understanding of the program and education about the requests for information.

• Established a company-level grievance mechanism. Suppliers and other external parties may contact us at conflict.minerals@staples.com if they wish to report concerns or seek guidance on our policy.

STEP 2: Identify and assess risk in the supply chain.

• Identified Risks.

◦ We worked with Source Intelligence to conduct our RCOI and due diligence, which was designed to determine whether any 3TG originated in the Democratic Republic of the Congo ("DRC") or Adjoining Countries and to solicit information about upstream suppliers. We utilized the Electronic Industry Citizenship Coalition (EICC) and Global e-Sustainability Initiative (GeSI) Conflict Minerals Reporting Template (CMRT) for data collection. The collection process included an introductory email from Staples to our direct suppliers describing the compliance requirements and identifying Source Intelligence as our service provider. Source Intelligence then provided instructions for accessing the online data collection platform, and requesting completion of the CMRT. Following the initial introductions to the program and information request, up to seven reminder emails were sent to non-responsive suppliers. Telephone calls and direct mail communications supplemented email reminders, as needed. Protocol then required escalation to Staples, and we engaged in direct outreach with our suppliers.

◦ We requested information from our suppliers regarding use of 3TG, identification of smelters and refiners and associated mine countries of origin. Source Intelligence reviewed the CMRT responses and validated the information against data maintained in its smelter and refiner database, which includes known metal processors, exclusive recyclers, mine country of origin information and DRC conflict-free status. Source Intelligence utilized supplier-provided information, and also relied on the lists published by independent third-party audit programs, specifically the Conflict Free Smelter Program (a program of the Conflict Free Sourcing Initiative ("CFSI")), the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain-of-Custody Certification. Internet research was also performed to determine whether there are any outside sources of information regarding sourcing practices. To the extent that a smelter or refiner was not designated by an independent third-party, Source Intelligence contacted, or attempted to contact, that smelter or refiner.

• Assessed and Responded to Identified Risk.

◦ The utilization of Source Intelligence's platform allowed us to have access to real-time information provided by our suppliers, and also to benefit from information available from sources beyond our own supply chains.

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◦ Supplier responses were evaluated by Source Intelligence for plausibility, consistency, and gaps both in terms of which products were stated to contain or not contain necessary 3TG, as well as the origin of those materials. Additional supplier contact and engagement was established to address "quality control flags" including but not limited to: one or more smelter or refiner was listed for an unused metal; information was not provided for a used metal, or the information provided was not a known metal processor; supplier indicated it had not received conflict minerals data for each metal from upstream suppliers; supplier indicated that it had not identified all of the smelters or refiners used for the products included in its CMRT response; supplier indicated 3TG products covered by CMRT originated 100% from scrap or recycled sources, but one or more smelters or refiners listed in the CMRT are not known to be exclusive recyclers; or supplier answered yes to sourcing from the DRC or Adjoining Countries but no smelter or refiner listed is known to source from the region.

STEP 3: Design and implement a strategy to respond to identified risks.

• Report to Senior Management. Our access to the data platform throughout the diligence process, as well as regularly scheduled meetings with Source Intelligence's representatives, enabled us to provide periodic reporting to our internal team supporting compliance, as well as the General Counsel, Chief Financial Officer and other senior management.

• Developed a Risk Management Plan. Throughout the due diligence process, we identified risks associated with our supply chain regarding 3TG used in our products. Our strategy for mitigating these risks are discussed below, under "Risk Mitigation Efforts".

STEP 4: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.

• Third-Party Audit. We relied on Source Intelligence, and on CFSI's Conflict Free Smelter Program, the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain-of-Custody Certification to conduct audits and validate smelters and refiners.

STEP 5: Report on supply chain due diligence.

• Report on Supply Chain Due Diligence. Staples' Form SD and CMR for the 2014 Report Year are publicly available at http://www.staples.com/sbd/cre/marketing/about_us/ethical-sourcing.html.

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RESULTS OF DUE DILIGENCE

As a result of the due diligence described above, our suppliers identified 279 smelters or refiners (after elimination of duplicates) that may have been the source of 3TG contained in products we contracted to manufacture during the 2014 Report Year, of which approximately 66% have been designated conflict-free or are currently participating in the audit process with one or more of the independent third-party audit programs. Annex B lists the smelters and refiners that the responding suppliers reported in their supply chains. 

Based on the CMRT responses of our suppliers and information collected by Source Intelligence, 70 countries of origin of 3TG were identified. The countries are listed on Annex C. There was an indication of sourcing from the DRC or Adjoining Countries for 35smelters or refiners. Of these 35, 32 are designated conflict-free, two are in the audit process and one is "CFSI known" but has not yet taken any steps to begin an independent third-party audit. As a result of direct outreach by Source Intelligence, the smelter has communicated that it does not source from the DRC or Adjoining Countries. For some smelters and refiners, no countries of origin were identified.

As a downstream company, we rely on the information provided by our suppliers. Some suppliers did not respond to our inquiry, some suppliers were unable to provide information regarding the smelters or refiners of the 3TG in their components and other suppliers identified certain of the smelters and refiners they used, but the suppliers provided company-wide, aggregate smelter information across all products, rather than information specific to our products. Because the data provided is incomplete, we are not able to definitively determine the countries of origin of 3TG used in the products we contracted to manufacture in the 2014 Report Year.

RISK MITIGATION EFFORTS

We have taken, and will continue to take the following steps to further enhance our due diligence process and results, and to mitigate the risk that necessary 3TG contained in products we manufacture benefit armed groups:

1. Increase direct outreach to suppliers to (a) address non-responsiveness and (b) drive more complete and detailed responses.

2. Communicate with key suppliers and continue to encourage the use of conflict-free smelters and refiners in the supply chain.

3. Enhance contract language to confirm suppliers with which we contract to manufacture comply with our Conflict Mineral Policy.

4. Continue to work with industry-wide initiatives to improve 3TG sourcing diligence and support engagement and conflict-free sourcing.

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Annex A

Product Categories

• Core office supplies

• Ink & toner

• Business technology

• Paper

• Facilities and breakroom

• Computers and mobility

• Office furniture

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Annex B

Smelter and Refiner List

Gold

Aida Chemical Industries Co. Ltd. *

Allgemeine Gold-und Silberscheideanstalt A.G. *

Almalyk Mining and Metallurgical Complex (AMMC)

AngloGold Ashanti Córrego do Sítio Minerção *

Argor-Heraeus SA *

Asahi Pretec Corporation *

Asaka Riken Co Ltd

Atasay Kuyumculuk Sanayi Ve Ticaret A.S *

Aurubis AG *

Bangko Sentral ng Pilipinas (Central Bank of the Philippines) *

Bauer Walser AG

BHP Billiton

Boliden AB *

C. Hafner GmbH + Co. KG

Caridad

CCR Refinery - Glencore Canada Corporation *

Cendres + Métaux SA

Chimet S.p.A. *

China National Gold Group Corporation

Chugai Mining

Codelco

Colt Refining

Daejin Indus Co. Ltd

Daye Non-Ferrous Metals Mining Ltd.

Do Sung Corporation

Doduco

Dowa Mining Co., Ltd.

Eco-System Recycling Co., Ltd. *

Faggi S.p.A.

FSE Novosibirsk Refinery

Gansu Seemine Material Hi-Tech Co Ltd

Geib Refining Corp

Guangdong Jinding Gold Limited

Hangzhou Fuchunjiang Smelting Co., Ltd.

Heimerle + Meule GmbH *

Heraeus Ltd. Hong Kong *

Heraeus Precious Metals GmbH & Co. KG *

Hunan Chenzhou Mining Group Co., Ltd.

Hwasung CJ Co. Ltd

Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited

Ishifuku Metal Industry Co., Ltd. *

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Istanbul Gold Refinery *

Japan Mint *

Jiangxi Copper Company Limited

Johnson Matthey Inc *

Johnson Matthey Ltd.*

JSC Ekaterinburg Non-Ferrous Metal Processing Plant *

JSC Uralelectromed *

JX Nippon Mining & Metals Co., Ltd. *

Kazzinc Inc. *

Kennecott Utah Copper LLC *

Kojima Chemicals Co., Ltd *

Korea Metal Co. Ltd

Kyrgyzaltyn JSC

L' azurde Company For Jewelry *

Lingbao Jinyuan Tonghui Refinery Co. Ltd.

LS-NIKKO Copper Inc. *

Luoyang Zijin Yinhui Metal Smelt Co Ltd

Materion *

Matsuda Sangyo Co., Ltd. *

Metalor Technologies (Hong Kong) Ltd *

Metalor Technologies (Singapore) Pte. Ltd. *

Metalor Technologies (Suzhou) Co Ltd *

Metalor Technologies SA *

Metalor USA Refining Corporation *

Met-Mex Peñoles, S.A. *

Mitsubishi Materials Corporation *

Mitsui Mining and Smelting Co., Ltd. *

Moscow Special Alloys Processing Plant

Nadir Metal Rafineri San. Ve Tic. A.Ş. *

Navoi Mining and Metallurgical Combinat

Nihon Material Co. LTD *

Ohio Precious Metals, LLC *

Ohura Precious Metal Industry Co., Ltd *

OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) *

OJSC Kolyma Refinery *

PAMP SA *

Penglai Penggang Gold Industry Co Ltd

Prioksky Plant of Non-Ferrous Metals *

PT Aneka Tambang (Persero) Tbk *

PX Précinox SA *

Rand Refinery (Pty) Ltd *

Republic Metals Corporation *

Royal Canadian Mint *

Sabin Metal Corp.

Samduck Precious Metals

SAMWON METALS Corp.

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Schöne Edelmetaal B.V. *

SEMPSA Joyería Platería SA *

Shandong Tarzan Bio-Gold Co Ltd

Shandong Zhaojin Gold & Silver Refinery Co. Ltd *

So Accurate Group, Inc.

SOE Shyolkovsky Factory of Secondary Precious Metals

Solar Applied Materials Technology Corp. *

Sumitomo Metal Mining Co., Ltd.*

Tanaka Kikinzoku Kogyo K.K. *

The Great Wall Gold and Silver Refinery of China

The Refinery of Shandong Gold Mining Co. Ltd

Tokuriki Honten Co., Ltd *

TongLing Nonferrous Metals Group Holdings Co., Ltd.

Torecom

Umicore Brasil Ltda *

Umicore Precious Metals Thailand *

Umicore SA Business Unit Precious Metals Refining *

United Precious Metal Refining, Inc. *

Valcambi SA *

Western Australian Mint trading as The Perth Mint *

Yamamoto Precious Metal Co., Ltd.

Yantai Guodasafina High-tech Environmental Refinery CO., Ltd.

Yokohama Metal Co Ltd

Yunnan Copper Industry Co Ltd

Zhongyuan Gold Smelter of Zhongjin Gold Corporation *

Zijin Mining Group Co. Ltd *

* Designated as conflict-free.

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Tantalum

Changsha South Tantalum Niobium Co., Ltd.*

Conghua Tantalum and Niobium Smeltry*

Duoluoshan Sapphire Rare Metal Co., Ltd.*

Ethiopian Minerals Development Share Company

Exotech Inc.*

F&X Electro-Materials Ltd.*

Global Advanced Metals Aizu*

Global Advanced Metals Boyertown*

Guangdong Zhiyuan New Material Co., Ltd.

H.C. Starck Co., Ltd.*

H.C. Starck GmbH Goslar*

H.C. Starck GmbH Laufenburg*

H.C. Starck Hermsdorf GmbH*

H.C. Starck Inc.*

H.C. Starck Ltd.*

H.C. Starck Smelting GmbH & Co.KG*

Hengyang King Xing Lifeng New Materials Co., Ltd.*

Hi-Temp Specialty Metals, Inc.*

JiuJiang JinXin Nonferrous Metals Co., Ltd.*

Jiujiang Tanbre Co., Ltd.*

KEMET Blue Metals*

Kemet Blue Powder*

King-Tan Tantalum Industry Ltd*

LSM Brasil S.A.*

Metallurgical Products India (Pvt.) Ltd.*

Mineração Taboca S.A.*

Mitsui Mining and Smelting Co., Ltd.*

Molycorp Silmet A.S.*

Ningxia Orient Tantalum Industry Co., Ltd.*

Plansee SE Liezen*

QuantumClean*

RFH Tantalum Smeltry Co., Ltd.*

Shanghai Jiangxi Metals Co., Ltd.

Solikamsk Metal Works*

Taki Chemicals*

Telex*

Ulba*

Yichun Jin Yang Rare Metal Co., Ltd*

Zhuzhou Cement Carbide*

* Designated as conflict-free.

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Tin

Alpha*

China Rare Metal Materials Company

China Tin Group Co., Ltd.

CNMC (Guangxi) PGMA Co. Ltd.

Cooper Santa

CV Duta Putra Bangka

CV Gita Pesona

CV Makmur Jaya

CV Nurjanah

CV Prima Timah Utama

CV Serumpun Sebalai

CV United Smelting*

Dowa Mining Co., Ltd.*

EFD INC.

Electroloy Metal Pte

Empresa Metallurgica Vinto*

Estanho de Rondônia S.A.

Feinhutte Halsbrucke GmbH

Fenix Metals

Gejiu Kai Meng Industry and Trade LLC

Gejiu Non-Ferrous Metal Processing Co. Ltd.*

Gejiu Zi-Li

Huichang Jinshunda Tin Co. Ltd

Jean Goldschmidt International SA

Jiangxi Nanshan

Kai Unita Trade Limited Liability Company

Kovohutě Příbram

Linwu Xianggui Smelter Co

Magnu's Minerais Metais e Ligas LTDA*

Malaysia Smelting Corporation (MSC)*

Melt Metais e Ligas S/A*

Metallo Chimique*

Mineração Taboca S.A.*

Minsur*

Mitsubishi Materials Corporation*

Novosibirsk Integrated Tin Works

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

O.M. Manufacturing Philippines, Inc.

Operaciones Metalurgical S.A.*

PBT

Poongsan Corporation

PT Alam Lestari Kencana

PT Artha Cipta Langgeng

PT ATD Makmur Mandiri Jaya*

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PT Babel Inti Perkasa*

PT Babel Surya Alam Lestari

PT Bangka Kudai Tin

PT Bangka Putra Karya*

PT Bangka Timah Utama Sejahtera

PT Bangka Tin Industry*

PT Belitung Industri Sejahtera

PT BilliTin Makmur Lestari

PT Bukit Timah*

PT DS Jaya Abadi*

PT Eunindo Usaha Mandiri*

PT Fang Di MulTindo

PT HP Metals Indonesia

PT Inti Stania Prima

PT Justindo

PT Karimun Mining

PT Koba Tin

PT Mitra Stania Prima*

PT Panca Mega Persada*

PT Pelat Timah Nusantara Tbk

PT Prima Timah Utama*

PT Refined Banka Tin*

PT Sariwiguna Binasentosa*

PT Seirama Tin investment

PT Singkep Times Utama

PT Stanindo Inti Perkasa*

PT Sumber Jaya Indah

PT Supra Sukses Trinusa

PT Tambang Timah*

PT Timah (Persero), Tbk*

PT Tinindo Inter Nusa*

PT Tommy Utama

PT Yinchendo Mining Industry

Pure Technology

RUI DA HUNG

Senju Metal Industry Co., Ltd.

Soft Metais, Ltda.

Thaisarco*

VQB Mineral and Trading Group JSC

White Solder Metalurgia e Mineração Ltda.*

Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.

Yunnan Tin Company Limited*

* Designated as conflict-free.

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Tungsten

A.L.M.T. Corp.

Chenzhou Diamond Tungsten Products Co., Ltd.

Chongyi Zhangyuan Tungsten Co., Ltd.

Dayu Weiliang Tungsten Co., Ltd.

Fujian Jinxin Tungsten Co., Ltd.

Ganzhou Huaxing Tungsten Products Co., Ltd.*

Ganzhou Jiangwu Ferrotungsten Co., Ltd.*

Ganzhou Non-ferrous Metals Smelting Co., Ltd.

Ganzhou Seadragon W & Mo Co., Ltd.

Global Tungsten & Powders Corp.*

Golden Egret Special Alloy Co. Ltd

Guangdong Xianglu Tungsten Industry Co., Ltd.

H.C. Starck GmbH

Hunan Chenzhou Mining Group Co., Ltd.

Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.*

Japan New Metals Co., Ltd.*

Jiangxi Gan Bei Tungsten Co., Ltd.*

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

Jiangxi Rare Earth & Rare Metals Tungsten Group Corp

Jiangxi Richsea New Materials Co., Ltd.

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

Jiangxi Tungsten Industry Group Co Ltd

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

Jiangxi Yaosheng Tungsten Co., Ltd.

JX Nippon Mining & Metals Co., Ltd.

Kennametal Fallon

Kennametal Huntsville

Malipo Haiyu Tungsten Co., Ltd.*

Materion

Mitsubishi Materials Corporation

North American Tungsten

Sumitomo Metal Mining Co., Ltd.

TaeguTec Ltd.

Tejing (Vietnam) Tungsten Co., Ltd.

Vietnam Youngsun Tungsten Industry Co., Ltd.

Wolfram Bergbau und Hütten AG

Wolfram Company CJSC*

Xiamen Honglu Tungsten Molybdenum Industry Co.Ltd

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

Xiamen Tungsten Co., Ltd.*

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

* Designated as conflict-free.

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Annex C

Countries of Origin

Angola

Argentina

Armenia

Australia

Austria

Belarus

Belgium

Bermuda

Bolivia

Brazil

Burundi

Canada

Chile

China

DRC- Congo (Kinshasa)

Estonia

Ethiopia

France

Germany

Ghana

Guinea

Guyana

Hong Kong

India

Indonesia

Italy

Japan

Jersey

Kazakhstan

Kyrgyzstan

Laos

Malaysia

Mali

Mexico

Mongolia

Morocco

Mozambique

Myanmar

Namibia

Netherlands

Niger

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Nigeria

Papua New Guinea

Peru

Philippines

Poland

Portugal

Russia

Rwanda

Saudi Arabia

Sierra Leone

Singapore

South Africa

South Korea

Spain

Suriname

Sweden

Switzerland

Taiwan

Tajikistan

Tanzania

Thailand

Turkey

United Arab Emirates

United Kingdom

United States

Uzbekistan

Vietnam

Zambia

Zimbabwe

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