Document

EX-1.01 2 a2025trscmreport.htm EX-1.01 Document

Exhibit 1.01

TriMas Corporation

Conflict Minerals Report

For the Reporting Period January 1, 2024 to December 31, 2024

TriMas Corporation (TriMas or the Company) is filing this Conflict Minerals Report (CMR) for the reporting period January 1, 2024 to December 31, 2024 (the Reporting Period) as an exhibit to its Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). TriMas manufactures or contracts to manufacture "products" that may contain conflict minerals, as defined by the Rule, present in its supply chain that may have originated in the Democratic Republic of the Congo or an adjoining country (the Covered Countries) and may not be from recycled or scrap sources. Accordingly, TriMas is filing this CMR as an exhibit to Form SD to describe the due diligence measures taken to determine the source and chain of custody of the conflict minerals used in its products during the Reporting Period.

Reasonable Country of Origin Inquiry

In accordance with the Rule and Form SD, TriMas conducted a good faith reasonable country of origin inquiry (RCOI) regarding the conflict minerals included in its products during the Reporting Period to determine whether any of such conflict minerals originated in the Covered Countries and/or whether any of such conflict minerals may be from recycled or scrap sources.

To determine whether tin, tantalum, tungsten or gold (3TG) necessary to the functionality or production of supplier products originated in Covered Countries, TriMas retained ComplianceXL, a third-party service provider, to assist in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers associated with the in-scope products to ComplianceXL for upload to the SustainHub (SH) platform provided by iPoint.

To collect data on the materials' sources of origin procured by the supply chain, TriMas utilized the Conflict Minerals Reporting Template (CMRT) version 6.4 or higher to conduct a survey of all in-scope suppliers.

During the supplier survey, the Company contacted suppliers via the SH platform, enabling users to complete and track supplier communications, and allowing suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. SH also provides functionality that meets the Organization for Economic Cooperation and Development's (OECD) Guidance process expectations by evaluating the quality of each supplier response. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.

Via SH and the ComplianceXL team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. ComplianceXL monitored and tracked all communications in SH for future reporting and transparency. TriMas directly contacted suppliers that were unresponsive to ComplianceXL's communications during the diligence process and requested these suppliers complete the CMRT and submit it to ComplianceXL.

The Company's program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of in-scope suppliers. The results of this data validation are shared with the suppliers to ensure they understand areas that require clarification or improvement.

All submitted forms are accepted and classified as valid or invalid. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct validation errors in their CMRT submission and direct engagement help through ComplianceXL. Since some suppliers may remain unresponsive to feedback, TriMas tracks program gaps to account for future improvement opportunities. TriMas also continued to perform further due diligence on the source and chain of custody of the minerals in question.

Due Diligence

Design of Due Diligence

TriMas' due diligence process is based on OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements. The OECD Guidance applies to both upstream1 and downstream2 companies in the supply chain. As TriMas is a downstream company in the supply chain, TriMas' tailored its due diligence practices accordingly. Due diligence measures undertaken by TriMas included those described below.

Due Diligence Performed

Establish Strong Company Management Systems

Adopt a Conflict Minerals Policy

TriMas' policies and practices, including our Responsible Sourcing and Conflict Minerals Policy (Conflict Minerals Policy), reflect our commitment to responsible sourcing and our values around human rights, ethics and environmental responsibility. Our Conflicts Minerals Policy is available on the TriMas website at www.trimas.com/policies. Our responsible sourcing efforts include supplier acknowledgment of the Company's Supplier Code of Conduct, which may be viewed at www.trimas.com/suppliers. The content on any website referred to in this CMR is not incorporated by reference into this CMR unless expressly noted.

Assemble an Internal Team to Support Supply Chain Due Diligence

TriMas' senior management identified individuals representing multiple TriMas departments and business units to oversee and drive conflict minerals compliance. Together with ComplianceXL, TriMas' General Counsel and Secretary worked with the Company's business units to complete tasks associated with the supplier due diligence process. Individual leads within the business units further facilitated the diligence process to collect information regarding the presence and sourcing of conflict minerals in the products supplied to TriMas.

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1 Upstream companies refer to those between the mine and smelters or refiners (SOR). As such, the companies typically include miners, local traders, or exporters from the country of mineral origin, international concentrate traders, and SORs.

2 Downstream companies refer to those entities between the SOR and retailer. As such, the companies typically include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers, and retailers.

Establish a System of Controls and Transparency Over The Supply Chain

To provide better transparency within TriMas' supply chain and to facilitate communication of policies and expectations, TriMas engaged ComplianceXL to complement internal management processes. The ComplianceXL and SH online system and processes are used to identify suppliers in TriMas' supply chain and to collect, store, and review information on conflict minerals sourcing practices, track information on SORs, and flag risks based on SOR sourcing practices. This system is designed to allow collection and housing of data on supply chain circumstances, which can be updated to reflect changes within the supply chain, such as new customer-supplier relationships and new products.

TriMas mandated compliance in its supply chain with TriMas' Conflict Minerals Policy through its contractual terms and conditions.

TriMas maintains an ethics hotline accessible at https://ir.trimas.com/employee-ethics-hotline-information through which a party, including TriMas employees and suppliers, may submit reports or concerns regarding compliance, including with respect to conflict minerals.

Supplier Engagement

TriMas has increased its supply chain transparency by identifying risks within its supply chain. TriMas is committed to conducting business in a socially responsible manner and partnering with suppliers who are similarly committed. TriMas’ supplier compliance process requires that suppliers comply with various contract provisions, legal requirements and industrial standards under local, regional and national laws and regulations of the countries in which the suppliers conduct business. Through this process, TriMas remains engaged with its supply base from a compliance perspective.

During this reporting period, we utilized the CMRT to collect conflict minerals declarations from our in-scope suppliers. These declarations were uploaded into the SH web-based reporting platform. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements, and increase the rate of responses we have received from our suppliers to our survey requests. ComplianceXL followed-up with suppliers to ensure proper completion of the CMRT, and all communication with suppliers has been documented to reflect the degree of success of these efforts.

To complete the RCOI, TriMas' in-scope suppliers were requested to provide information regarding the presence and sourcing of conflict minerals used in the products supplied to TriMas. The program utilized the CMRT version 6.4 or higher to conduct a survey of all in-scope suppliers.

Suppliers were offered two options to submit the required information, either by uploading a completed CMRT or through direct submission to ComplianceXL.

During the supplier survey, suppliers were contacted via the SH platform, operated by ComplianceXL, enabling its users to complete and track supplier communications as well as allowing suppliers to upload completed CMRT forms directly to the platform for risk assessment and management. In their responses, suppliers specified whether the information provided was at the company level or the product level. Non-responsive suppliers were contacted a minimum of 18 times by ComplianceXL. For the 2024 reporting period, TriMas received responses from 663 or 88% of its 753 surveyed suppliers. Of the 663 suppliers that provided a response, approximately 151 reported that their products contained 3TG necessary to the functionality or production of their products.

Automated data validation on all submitted CMRTs is included in the program. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. For the 2024 reporting period, TriMas had 14 invalid CMRTs, that could not be corrected.

As mentioned above, the CMRTs received allowed TriMas to collect and compile, via SH, all answers from the CMRT with respect to smelter information reflected in the CMRTs. With respect to smelter information reflected in the CMRTs, there were suppliers who did not provide smelter lists. Without having full smelter information for TriMas products from all suppliers in-scope, TriMas is unable to determine whether there is sourcing from the Covered Countries. In connection with its evaluation of the CMRTs, TriMas and ComplianceXL undertook due diligence to validate supplier reports.

Grievance Mechanism

We have established reporting mechanisms whereby employees and suppliers can report violations of the Company's policies, including our Conflict Minerals Policy through the ethics hotline on our website at https://ir.trimas.com/employee-ethics-hotline-information.

Records Maintenance

Under our Records Retention Policy, compliance records are maintained for 10 years.

Identify and Assess Risk in Our Supply Chain

We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. We believe many of our largest suppliers are suppliers to other SEC registrants that are subject to the Rule.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as DRC-conflict free by third-party sources such as Responsible Minerals Initiative (RMI) or the London Bullion Market Association (LBMA) Responsible Gold Programme, may pose a risk. Where a smelter is not identified as conflict free by such sources, we rate the risk as high, medium or low. This rating is based on various factors, including whether the smelter/refiner has been identified as a valid smelter/refiner and has an associated Smelter Identification Number (under the RMI, this is known as a CID), and the smelter's geographic location, including proximity to the Covered Countries.

We calculate supplier risk based on the chance that a supplier provides 3TGs that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.

Additionally, each supplier is evaluated on the strength of its conflict minerals program (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of a supplier's program are:

•Do you have a policy in place that includes Covered Countries conflict-free sourcing?

•Have you implemented due diligence measures for conflict-free sourcing?

•Do you verify due diligence information received from your suppliers?

•Does your review process include corrective action management?

The more positive the responses to these questions indicate a stronger conflict sourcing initiative.

As part of our risk management plan and to ensure suppliers understand our expectations, we have, through ComplianceXL, written training on conflict minerals and the CMRT. This includes instructions on completing the form and one-on-one email and phone discussions with supplier personnel.

In accordance with our Conflict Minerals Policy, if a supplier gives us reason to believe that it may be supplying us with 3TG from sources that may support conflict in a Covered Country, we encourage the supplier to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we may initiate steps to find replacement suppliers.

Once surveys were returned, ComplianceXL reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the RMI Responsible Minerals Assurance Process (RMAP). If an SOR was not validated by the RMAP, ComplianceXL attempted to contact the SOR to gather more information about its sourcing practices.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not certified Covered Country-Conflict Free may pose a risk to the supply chain. Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the OECD Guidance.

As part of our risk management plan under the OECD Guidance, when facilities with red flags are reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through ComplianceXL, submissions that include any red flag facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to TriMas, and escalating up to removal of these red flag smelters from their supply chain.

As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier's specific context.

Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG smelters and refiners in our supply chain represents an appropriate effort to determine the mines or locations of origin of the 3TGs in our supply chain. This was done by adopting methodology outlined by the RMI's joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this industry joint effort, we made a reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict Free” lists of sourced metals.

Design and Implement a Strategy to Respond to Risks

As part of TriMas' strategy to mitigate risk and to ensure suppliers understand our expectations, we have provided documented instructions through ComplianceXL. Responses to the reporting CMRT were reviewed with specific suppliers where clarification was needed. As described in our Conflict Minerals Policy, we intend to engage any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in Covered Countries to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.

Suppliers that may expose the Company to unacceptable risks, either due to unacceptable responses to our inquiries or a refusal to respond, may be evaluated by the Company.

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

TriMas does not have a direct relationship with conflict minerals smelters or refiners and as a result, TriMas does not perform direct audits of these entities in its supply chain. TriMas relies on the efforts of the industry associations that administer independent third-party smelter and refinery audit programs and encourages suppliers with more direct relationships with smelters to participate in comparable due diligence validation activities.

ComplianceXL conducts outreach to all smelters and refineries that are not enrolled in the RMI's RMAP on behalf of TriMas. The purpose of this outreach is to encourage participation in the RMAP and to inquire about the facility's sourcing practices and infrastructure.

Report Annually on Supply Chain Due Diligence

TriMas' Form SD and CMR are publicly available at www.trimas.com and meet the OECD recommendation to report annually on supply chain due diligence.

Due Diligence Results

For the 2024 reporting period, TriMas received responses from 663 or 88% of its 753 surveyed suppliers. Of the 663 suppliers that provided a response, approximately 151 reported that their products contained 3TG necessary to the functionality or production of their products. Based on the RCOI and the due diligence measures described in this CMR, specifically that most CMRTs are at the company level and not the product level pertaining to TriMas products, TriMas was unable to determine if any of the specific SORs identified by suppliers are in its supply chain.

The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the SORs identified by our direct suppliers may contain SORs that processed conflict minerals that our direct suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the SORs were used to process the conflict minerals necessary to the functionality or production of our products during 2024. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin identified were the country of origin of conflict minerals in our products during 2024, and therefore we were also unable to determine the source and chain of custody of those conflict minerals. In addition, the third-party audits conducted by the RMI, the LBMA and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMI RMAP or the LBMA Responsible Gold Programme and, as a result, are not responsible for the quality of these audits or the audit findings.

In connection with our reasonable country of origin inquiry and due diligence, as applicable, our suppliers identified to us certain smelters and refiners as potentially having processed the necessary 3TG contained in our products in 2024. For all responses that indicated a smelter, ComplianceXL compared the facilities listed to the list of smelters maintained by the RMI. For the 2024 reporting period, we have validated 304 SORs. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any SORs that we have not been able to validate. If a supplier indicated that the facility was certified as "Conflict-Free," ComplianceXL confirmed that the name was listed by RMI as a certified smelter.

Steps to Improve Due Diligence and Mitigate Risk

TriMas will work to continuously improve its supply chain due diligence efforts through the following measures:


a)			Continue supply chain due diligence efforts and engagement with suppliers to identify sources of conflict minerals;
b)			Continue to clearly communicate expectations with regard to supplier compliance, transparency and sourcing;
c)			Continue to engage with suppliers that provided incomplete or uncertain smelter information or did not respond to our survey request;
d)			Continue to compare RCOI results to information collected via independent conflict free smelter validation programs; and
e)			Contact smelters identified as a result of the RCOI process and request their participation in obtaining a "conflict free" designation from an industry program.

Smelters and Refiners

Appendix A includes an aggregated list of smelters and refiners that our suppliers identified to us as potentially having processed the necessary 3TG contained in our products in 2024 based on information provided through the CMRT data collection process. As mentioned previously, it is understood that many supplier responses may provide more data than can be directly linked to products sold by TriMas, therefore, Appendix A may contain more smelters and refiners than those that the Company's products are being sourced from.

Smelter and Refiner Risk Evaluation

Understanding the risks associated with the smelters and refiners potentially providing material into TriMas' supply chain is an important part of the due diligence process.

The following risk categories are used for smelter evaluation and risk determination:

▪Geo-Risk

◦Did the mineral originate from or has been transported through a Covered Country?

•Audit Status

◦Has the refiner's due diligence practices been audited against a standard in conformance with the OECD Guidance?

◦ComplianceXL relies on the RMI audit standard, including cross-recognition of the LBMA Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance.

•Sourcing Risk

◦Has evidence of any other red flag that is supported by credible sources been identified?

Forward-Looking Statements

This report may contain forward-looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934, including statements related to our compliance efforts. These forward-looking statements can be identified by the use of forward-looking words, such as “may,” “could,” “should,” “estimate,” “project,” “forecast,” “intend,” “expect,” “anticipate,” “believe,” “target,” “plan” or other comparable words, or by discussions of strategy that may involve risks and uncertainties.

These forward-looking statements are subject to various risks, uncertainties, and assumptions, including, among other matters, our customers' requirements to use certain suppliers, our suppliers' responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our conflict minerals program and our ability to identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed in or implied by the forward-looking statements. For a more complete discussion of these and other risk factors, see our other filings with the Securities and Exchange Commission (SEC), including our Annual Report on Form 10-K for the year ended December 31, 2024. We caution you not to place undue reliance on these forward-looking statements, which speak only as of the date of this report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.

The cautionary statements set forth above should be considered in connection with any subsequent written or oral forward-looking statements that we or persons acting on our behalf may issue. We caution readers not to place undue reliance on the statements, which speak only as of the date of this report. We do not undertake any obligation to review or confirm analysts' expectations or estimates or to release publicly any revisions to any forward-looking statement to reflect events or circumstances after the date of this report or to reflect the occurrence of unanticipated events, except as required by law.

APPENDIX A

Metal

Standard Smelter Name

Smelter ID

Smelter Country

Status

Gold

8853 S.p.A.

ITALY

CID002763

Gold

Abington Reldan Metals, LLC

UNITED STATES OF AMERICA

CID002708

Gold

Advanced Chemical Company

UNITED STATES OF AMERICA

CID000015

Gold

Agosi AG

GERMANY

CID000035

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

CID000019

Gold

Al Etihad Gold Refinery DMCC

UNITED ARAB EMIRATES

CID002560

Gold

Alexy Metals

UNITED STATES OF AMERICA

CID003500

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

CID000041

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

BRAZIL

CID000058

Gold

Argor-Heraeus S.A.

SWITZERLAND

CID000077

Gold

Asahi Pretec Corp.

JAPAN

CID000082

Gold

Asahi Refining Canada Ltd.

CANADA

CID000924

Gold

Asahi Refining USA Inc.

UNITED STATES OF AMERICA

CID000920

Gold

Asaka Riken Co., Ltd.

JAPAN

CID000090

Gold

AU Traders and Refiners

SOUTH AFRICA

CID002850

Gold

Augmont Enterprises Private Limited

INDIA

CID003461

Gold

Aurubis AG

GERMANY

CID000113

Gold

Bangalore Refinery

INDIA

CID002863

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

CID000128

Gold

Boliden Ronnskar

SWEDEN

CID000157

Gold

C. Hafner GmbH + Co. KG

GERMANY

CID000176

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

CID000185

Gold

Cendres + Metaux S.A.

SWITZERLAND

CID000189

Gold

Chimet S.p.A.

ITALY

CID000233

Gold

Chugai Mining

JAPAN

CID000264

Gold

Coimpa Industrial LTDA

BRAZIL

CID004010

Gold

Dowa

JAPAN

CID000401

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

CID000359

Gold

Eco-System Recycling Co., Ltd. East Plant

JAPAN

CID000425

Gold

Eco-System Recycling Co., Ltd. North Plant

JAPAN

CID003424

Gold

Eco-System Recycling Co., Ltd. West Plant

JAPAN

CID003425

Gold

Elite Industech Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID004755

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

CID002561

Gold

GG Refinery Ltd.

TANZANIA, UNITED REPUBLIC OF

CID004506

Gold

GGC Gujrat Gold Centre Pvt. Ltd.

INDIA

CID002852

Gold

Gold by Gold Colombia

COLOMBIA

CID003641

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

CID002243

Gold

Heimerle + Meule GmbH

GERMANY

CID000694

Gold

Heraeus Germany GmbH Co. KG

GERMANY

CID000711

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

CID000707

Gold

Impala Refineries – Base Metals Refinery (BMR)

SOUTH AFRICA

CID004604

Gold

Impala Refineries – Platinum Metals Refinery (PMR)

SOUTH AFRICA

CID004714

Gold

Impala Rustenburg

SOUTH AFRICA

CID004610

Gold

Inca One (Chala One Plant)

PERU

CID004704

Gold

Inca One (Koricancha Plant)

PERU

CID004705

Gold

Industrial Refining Company

BELGIUM

CID002587

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

CID000801

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

CID000807

Gold

Istanbul Gold Refinery

TURKEY

CID000814

Gold

Italpreziosi

ITALY

CID002765

Gold

Japan Mint

JAPAN

CID000823

Gold

Jiangxi Copper Co., Ltd.

CHINA

CID000855

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

CID000937

Gold

Kazzinc

KAZAKHSTAN

CID000957

Gold

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

CID000969

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

CID002511

Gold

Kojima Chemicals Co., Ltd.

JAPAN

CID000981

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

CID002605

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

CID001029

Gold

L'Orfebre S.A.

ANDORRA

CID002762

Gold

LS MnM Inc.

KOREA, REPUBLIC OF

CID001078

Gold

LT Metal Ltd.

KOREA, REPUBLIC OF

CID000689

Gold

Marsam Metals

BRAZIL

CID002606

Gold

Materion

UNITED STATES OF AMERICA

CID001113

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

CID001119

Gold

Metal Concentrators SA (Pty) Ltd.

SOUTH AFRICA

CID003575

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

CID001149

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

CID001152

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

CID001147

Gold

Metalor Technologies S.A.

SWITZERLAND

CID001153

Gold

Metalor USA Refining Corporation

UNITED STATES OF AMERICA

CID001157

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

MEXICO

CID001161

Gold

Minera Titan del Peru SRL (MTP) - Belen Plant

PERU

CID005014

Gold

Mitsubishi Materials Corporation

JAPAN

CID001188

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001193

Gold

MKS PAMP SA

SWITZERLAND

CID001352

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

CID002509

Gold

Modeltech Sdn Bhd

MALAYSIA

CID002857

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

TURKEY

CID001220

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

CID001236

Gold

NH Recytech Company

KOREA, REPUBLIC OF

CID003189

Gold

Nihon Material Co., Ltd.

JAPAN

CID001259

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

CID002779

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

CID001325

Gold

Planta Recuperadora de Metales SpA

CHILE

CID002919

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

CID001397

Gold

PX Precinox S.A.

SWITZERLAND

CID001498

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

CID001512

Gold

REMONDIS PMR B.V.

NETHERLANDS

CID002582

Gold

Royal Canadian Mint

CANADA

CID001534

Gold

SAAMP

FRANCE

CID002761

Gold

Safimet S.p.A

ITALY

CID002973

Gold

SAFINA A.S.

CZECHIA

CID002290

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

CID001555

Gold

SEMPSA Joyeria Plateria S.A.

SPAIN

CID001585

Gold

Shandong Gold Smelting Co., Ltd.

CHINA

CID001916

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

CID001622

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

CID001736

Gold

Singway Technology Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID002516

Gold

Solar Applied Materials Technology Corp.

TAIWAN, PROVINCE OF CHINA

CID001761

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

CID001798

Gold

SungEel HiMetal Co., Ltd.

KOREA, REPUBLIC OF

CID002918

Gold

T.C.A S.p.A

ITALY

CID002580

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

CID001875

Gold

TITAN COMPANY LIMITED, JEWELLERY DIVISION

INDIA

CID004491

Gold

Tokuriki Honten Co., Ltd.

JAPAN

CID001938

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

CID002615

Gold

Torecom

KOREA, REPUBLIC OF

CID001955

Gold

Umicore Precious Metals Thailand

THAILAND

CID002314

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

CID001980

Gold

United Precious Metal Refining, Inc.

UNITED STATES OF AMERICA

CID001993

Gold

Valcambi S.A.

SWITZERLAND

CID002003

Gold

WEEEREFINING

FRANCE

CID003615

Gold

Western Australian Mint (T/a The Perth Mint)

AUSTRALIA

CID002030

Gold

WIELAND Edelmetalle GmbH

GERMANY

CID002778

Gold

Yamakin Co., Ltd.

JAPAN

CID002100

Gold

Yokohama Metal Co., Ltd.

JAPAN

CID002129

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

CID002224

Tantalum

AMG Brasil

BRAZIL

CID001076

Tantalum

Avon Specialty Metals Ltd.

UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND

CID002705

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

CID000211

Tantalum

CMT Rare Metal Advanced Materials (Hunan) Co., Ltd.

CHINA

CID004431

Tantalum

D Block Metals, LLC

UNITED STATES OF AMERICA

CID002504

Tantalum

F&X Electro-Materials Ltd.

CHINA

CID000460

Tantalum

FIR Metals & Resource Ltd.

CHINA

CID002505

Tantalum

Global Advanced Metals Aizu

JAPAN

CID002558

Tantalum

Global Advanced Metals Boyertown

UNITED STATES OF AMERICA

CID002557

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

CHINA

CID000291

Tantalum

H.C. Starck Tungsten GmbH

UNKNOWN

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

CID002492

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

CID002512

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

CID002842

Tantalum

Jiujiang Janny New Material Co., Ltd.

CHINA

CID003191

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

CID000914

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

CID000917

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002506

Tantalum

KEMET de Mexico

MEXICO

CID002539

Tantalum

Materion Newton Inc.

UNITED STATES OF AMERICA

CID002548

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

CID001163

Tantalum

Mineracao Taboca S.A.

BRAZIL

CID001175

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001192

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

CID001277

Tantalum

NPM Silmet AS

ESTONIA

CID001200

Tantalum

Plansee SE Reutte

AUSTRIA

CID002556

Tantalum

PowerX Ltd.

RWANDA

CID004054

Tantalum

QSIL Metals Hermsdorf GmbH

GERMANY

CID002547

Tantalum

QuantumClean

UNITED STATES OF AMERICA

CID001508

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

CID002707

Tantalum

RFH Recycling Metals Co., Ltd.

CHINA

CID003159

Tantalum

RFH Yancheng Jinye New Material Technology Co., Ltd.

CHINA

CID003583

Tantalum

Taki Chemical Co., Ltd.

JAPAN

CID001869

Tantalum

TANIOBIS Co., Ltd.

THAILAND

CID002544

Tantalum

TANIOBIS GmbH

GERMANY

CID002545

Tantalum

TANIOBIS Japan Co., Ltd.

JAPAN

CID002549

Tantalum

TANIOBIS Smelting GmbH & Co. KG

GERMANY

CID002550

Tantalum

Telex Metals

UNITED STATES OF AMERICA

CID001891

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

CID001969

Tantalum

V&D New Materials (Jiangsu) Co., Ltd.

CHINA

CID003498

Tantalum

XIMEI RESOURCES (GUANGDONG) LIMITED

CHINA

CID000616

Tantalum

XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD.

CHINA

CID003973

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

CID002508

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

CHINA

CID001522

Tantalum

Zhuzhou Cemented Carbide Group Co., Ltd.

CHINA

CID002232

Tin

Alpha

UNITED STATES OF AMERICA

CID000292

Tin

Aurubis Beerse

BELGIUM

CID002773

Tin

Aurubis Berango

SPAIN

CID002774

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

CID000228

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

CID003190

Tin

China Tin Group Co., Ltd.

CHINA

CID001070

Tin

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

BRAZIL

CID003486

Tin

CRM Synergies

SPAIN

CID003524

Tin

CV Ayi Jaya

INDONESIA

CID002570

Tin

CV Venus Inti Perkasa

INDONESIA

CID002455

Tin

Dongguan Best Alloys Co., Ltd.

CHINA

CID000377

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

CHINA

CID003356

Tin

Dowa

JAPAN

CID000402

Tin

DS Myanmar

MYANMAR

CID003831

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy
Joint Stock Company

VIETNAM

CID002572

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

CID000438

Tin

Estanho de Rondonia S.A.

BRAZIL

CID000448

Tin

Fabrica Auricchio Industria e Comercio Ltda.

BRAZIL

CID003582

Tin

Feinhütte Halsbrücke GmbH

GERMANY

CID000466

Tin

Fenix Metals

POLAND

CID000468

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

CID000942

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

CID000538

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

CID001908

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

CID000555

Tin

Global Advanced Metals Greenbushes Pty Ltd.

AUSTRALIA

CID004754

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

CHINA

CID003116

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

CID002844

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

CID001231

Tin

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

Tin

Luna Smelter, Ltd.

RWANDA

CID003387

Tin

Ma'anshan Weitai Tin Co., Ltd.

CHINA

CID003379

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

CID002468

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

CID001105

Tin

Malaysia Smelting Corporation Berhad (Port Klang)

MALAYSIA

CID004434

Tin

Melt Metais e Ligas S.A.

BRAZIL

CID002500

Tin

Metallic Resources, Inc.

UNITED STATES OF AMERICA

CID001142

Tin

Metallurgical Products India Pvt., Ltd.

INDIA

Tin

Mineracao Taboca S.A.

BRAZIL

CID001173

Tin

Mining Minerals Resources SARL

CONGO, DEMOCRATIC REPUBLIC OF THE

CID004065

Tin

Minsur

PERU

CID001182

Tin

Minsur

PERU

CID001182

Tin

Mitsubishi Materials Corporation

JAPAN

CID001191

Tin

Modeltech Sdn Bhd

MALAYSIA

CID002858

Tin

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

THAILAND

CID001314

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID002517

Tin

Operaciones Metalurgicas S.A.

BOLIVIA (PLURINATIONAL STATE OF)

CID001337

Tin

P Kay Metal, Inc

UNITED STATES OF AMERICA

CID005189

Tin

Precious Minerals and Smelting Limited

INDIA

CID003409

Tin

PT Aries Kencana Sejahtera

INDONESIA

CID000309

Tin

PT Arsed Indonesia

INDONESIA

CID005067

Tin

PT Artha Cipta Langgeng

INDONESIA

CID001399

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

CID002503

Tin

PT Babel Inti Perkasa

INDONESIA

CID001402

Tin

PT Babel Surya Alam Lestari

INDONESIA

CID001406

Tin

PT Bangka Prima Tin

INDONESIA

CID002776

Tin

PT Bangka Serumpun

INDONESIA

CID003205

Tin

PT Bangka Tin Industry

INDONESIA

CID001419

Tin

PT Belitung Industri Sejahtera

INDONESIA

CID001421

Tin

PT Bukit Timah

INDONESIA

CID001428

Tin

PT Cipta Persada Mulia

INDONESIA

CID002696

Tin

PT Masbro Alam Stania

INDONESIA

CID003380

Tin

PT Menara Cipta Mulia

INDONESIA

CID002835

Tin

PT Mitra Stania Prima

INDONESIA

CID001453

Tin

PT Mitra Sukses Globalindo

INDONESIA

CID003449

Tin

PT Premium Tin Indonesia

INDONESIA

CID000313

Tin

PT Prima Timah Utama

INDONESIA

CID001458

Tin

PT Putera Sarana Shakti (PT PSS)

INDONESIA

CID003868

Tin

PT Rajawali Rimba Perkasa

INDONESIA

CID003381

Tin

PT Rajehan Ariq

INDONESIA

CID002593

Tin

PT Refined Bangka Tin

INDONESIA

CID001460

Tin

PT Sariwiguna Binasentosa

INDONESIA

CID001463

Tin

PT Stanindo Inti Perkasa

INDONESIA

CID001468

Tin

PT Sukses Inti Makmur (SIM)

INDONESIA

CID002816

Tin

PT Timah Nusantara

INDONESIA

CID001486

Tin

PT Timah Tbk Kundur

INDONESIA

CID001477

Tin

PT Timah Tbk Mentok

INDONESIA

CID001482

Tin

PT Tinindo Inter Nusa

INDONESIA

CID001490

Tin

PT Tommy Utama

INDONESIA

CID001493

Tin

Resind Industria e Comercio Ltda.

BRAZIL

CID002706

Tin

Rian Resources SDN. BHD.

MALAYSIA

CID003581

Tin

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

CID001539

Tin

Soft Metais Ltda.

BRAZIL

CID001758

Tin

Super Ligas

BRAZIL

CID002756

Tin

Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.

JAPAN

CID004403

Tin

Thaisarco

THAILAND

CID001898

Tin

Tin Smelting Branch of Yunnan Tin Co., Ltd.

CHINA

CID002180

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

CID003325

Tin

TRATHO METAL QUIMICA

BRAZIL

Tin

White Solder Metalurgia e Mineracao Ltda.

BRAZIL

CID002036

Tin

Woodcross Smelting Company Limited

UGANDA

CID004724

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

CID002158

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

CHINA

CID003397

Tungsten

A.L.M.T. Corp.

JAPAN

CID000004

Tungsten

ACL Metais Eireli

BRAZIL

CID002833

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

BRAZIL

CID003427

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIETNAM

CID002502

Tungsten

Avon Specialty Metals Ltd

UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND

CID002704

Tungsten

Avon Specialty Metals Ltd.

UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND

CID002704

Tungsten

China Molybdenum Tungsten Co., Ltd.

CHINA

CID002641

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID000258

Tungsten

Cronimet Brasil Ltda

BRAZIL

CID003468

Tungsten

Fujian Xinlu Tungsten Co., Ltd.

CHINA

CID003609

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

CID002315

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

CID002494

Tungsten

Ganzhou Sunny Non-Ferrous Metals Co., Ltd.

CHINA

CID003580

Tungsten

Global Tungsten & Powders LLC

UNITED STATES OF AMERICA

CID000568

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

CID000218

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

CID002541

Tungsten

Hubei Green Tungsten Co., Ltd.

CHINA

CID003417

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000766

Tungsten

Hunan Jintai New Material Co., Ltd.

CHINA

CID000769

Tungsten

Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch

CHINA

CID002513

Tungsten

Japan New Metals Co., Ltd.

JAPAN

CID000825

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

CID002551

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

CID002321

Tungsten

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

CHINA

CID002318

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

CID002317

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

CID002316

Tungsten

Kenee Mining Corporation Vietnam

VIETNAM

CID004619

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

CID000966

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

CID000105

Tungsten

LAOS SOUTHERN MINING SMELTING SOLE CO.,LTD

LAO PEOPLE'S DEMOCRATIC REPUBLIC

CID005017

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID003407

Tungsten

Lianyou Resources Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID004397

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002319

Tungsten

Masan High-Tech Materials

VIET NAM

CID002543

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

CID002589

Tungsten

Philippine Bonway Manufacturing Industrial Corporation

PHILIPPINES

CID004797

Tungsten

Philippine Carreytech Metal Corp.

PHILIPPINES

CID004438

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

CID002827

Tungsten

Plansee Composite Materials GmbH

GERMANY

CID004068

Tungsten

Sanher Tungsten Vietnam Co., Ltd.

VIETNAM

CID002538

Tungsten

Shinwon Tungsten (Fujian Shanghang) Co., Ltd.

CHINA

CID004430

Tungsten

TANIOBIS Smelting GmbH & Co. KG

GERMANY

CID002542

Tungsten

Telex Metals

UNITED STATES OF AMERICA

Tungsten

Tungsten Vietnam Joint Stock Company

VIETNAM

CID003993

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

CID002724

Tungsten

Wolfram Bergbau und Hutten AG

AUSTRIA

CID002044

Tungsten

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

CHINA

CID002320

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

CID002082

Tungsten

Zhuzhou Cemented Carbide Group Co., Ltd.

CHINA

* = Conformant or actively participating in the RMI Responsible Minerals Assurance Process (as reported by RMI as of April 30, 2025).