SD

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

TRIMBLE INC.

(Exact name of registrant as specified in its charter)

Delaware	001-14845	94-2802192
(State or other jurisdiction of incorporation)	(Commission File Number)	(IRS. Employer Identification No.)

935 Stewart Drive

Sunnyvale, CA 94085

(Address of principal executive offices)

James A. Kirkland

Senior Vice President, General Counsel and Secretary

(408) 481-8000

(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:
x	Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.

Section 1 - Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit

A copy of Trimble Inc.’s Conflict Minerals Report is provided as Exhibit 1.01 to this Report and is available at the following address:

http://www.trimble.com/Corporate/Compliance/compliance_resources.aspx

Section 2 - Exhibits

Item 2.0.1 Exhibits

Exhibit No.	Description
1.01	Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

SIGNATURES

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 duly authorized undersigned.

	TRIMBLE INC.
	/s/ James A. Kirkland
By:	James A. Kirkland, Senior Vice President, General Counsel and Secretary
Date:	May 31, 2019

EX-1.01

Exhibit 1.01

Trimble Inc.

Conflict Minerals Report for the Year Ended December 31, 2018

The following conflict minerals report contains forward-looking statements about our plans to take additional actions or to implement additional policies or procedures with respect to our due diligence efforts to determine the origin of conflict minerals contained in our products. We undertake no obligation to publicly update or revise any forward-looking statement, whether as a result of new information, future events or otherwise. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report.

This is the Conflict Minerals Report of Trimble Inc. for the 2018 calendar year in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.

Rule 13p-1 requires that all public companies report annually on the presence of certain minerals, characterized as conflict minerals, including tin, tantalum, tungsten or gold (“3TG” or “conflict minerals”), in the products that they manufacture or contract to manufacture, and demonstrate the proper level of due diligence in determining whether these minerals originated from the Democratic Republic of the Congo or an adjoining country (collectively, “Covered Countries”) or from scrap or recycled sources, and whether they directly or indirectly finance or benefit armed groups in the Covered Countries.

Introduction

Trimble provides technology solutions that enable professionals and field mobile workers to improve or transform their work processes. Our solutions, which can include a combination of hardware, software and services, are used across a range of industries including agriculture, architecture, civil engineering, survey and land administration, construction, geospatial, government, natural resources, transportation and utilities. Representative Trimble customers include engineering and construction firms, contractors, surveying companies, farmers and agricultural companies, enterprise firms with large-scale fleets, energy, mining and utility companies, and state, federal and municipal governments.

We design and manufacture, or have manufactured on our behalf, thousands of different hardware products ranging across multiple business divisions within our key business segments of Buildings and Infrastructure, Geospatial, Resources and Utilities, and Transportation. Many of these hardware products, which are typically based upon positioning or location technologies, including Global Navigation Satellite Systems (GNSS), lasers and optics, are built by our contract manufacturing partners.

Our contract manufacturing partners are responsible for significant material procurement, assembly, and testing. We generally manage product design and are involved in qualifying suppliers and key components used in our products. We are many levels removed from the mining or processing of minerals in our supply chain, however, and we do not directly source, or manage the sourcing of, raw materials, including conflict minerals.

Many of our hardware products are designed with printed circuit boards, connectors, sheet metal and other electrical mechanical assemblies that may contain conflict minerals. The components used in our products that contain these metals are required for the functionality of our products.

Trimble’s Conflict Minerals Program

Trimble is committed to sourcing components and materials from companies that share our values concerning human rights, ethics and environmental responsibility. Our Conflict Minerals Policy Statement, as well as our current Conflict Minerals Report, are published on our public website and available at:

www.trimble.com/Corporate/Compliance/compliance_resources

We focus our due diligence efforts on determining the source and chain of custody of conflict minerals in the components and materials that are supplied to us. Tracing conflict minerals back to their country of origin, though, is a complex task that requires, among other things, screening for the possible presence of 3TG in parts or materials provided by our contract manufacturers and direct suppliers (which we refer to as “in-scope suppliers”), and then surveying such in-scope suppliers to understand what programs they have in place for tracing the source of minerals included in products or components supplied to us. Suppliers are deemed out-of-scope and not surveyed if they only provide software, plastic, packaging materials or other items that do not contain 3TG.

Trimble uses as its standard reporting template, and requires its in-scope suppliers to use, the Responsible Minerals Initiative’s (“RMI”) reporting template to identify whether in-source suppliers source 3TG from the Covered Countries or from recycled or scrap sources. The RMI reporting template is a key part of our due diligence efforts and is used to determine the source and chain of custody of 3TG in the components and materials that are supplied to us. We rely on the information provided through the RMI reporting template by our supply chain, as well as smelter information provided by the RMI and other industry organizations, to complete our Conflict Minerals Report.

As part of our supplier risk assessment, we require new suppliers to go through a screening and approval process so we can assess their use of 3TG and determine whether they are in-scope suppliers. We provide an initial survey to assess their use of 3TG and to understand their business processes. We also inform new suppliers of our “Supplier Requirements for the Sourcing of Conflict Minerals,” which further describe our Conflict Minerals Program goals and expectations. Additionally, we have established a Supplier Code of Conduct, which is based upon the Responsible Business Alliance’s Code of Conduct.

Trimble requires in-scope suppliers to source from smelters that are either conformant with the Responsible Minerals Assurance Process (“RMAP”), have undergone another recognized third-party audit program (such as the London Bullion Market Association (LBMA) or the Responsible Jewellery Council (RJC)), or are in the process of achieving audit conformance. In the event of non-conformance by an in-scope supplier, we require the supplier to pursue corrective actions, and, in the event of continued non-conformance, we may consider termination of the supplier.

Reasonable Country of Origin Inquiry (“RCOI”)

Since conflict minerals are necessary to the functionality of many of our hardware products, we conducted an RCOI to determine the origin of the 3TG present in our products delivered to customers.

Given the complex nature of our supply chain and our extensive parts inventory, we assess our in-scope suppliers in three separate phases: (i) we first assess suppliers of parts containing 3TG that are used in the bill of materials for products that we are actively producing; (ii) we then review those suppliers that manufacture and sell to us their parts and components; and (iii) finally, we review suppliers of the companies and businesses that we acquire.

After conducting our three-phase assessment, we requested in-scope suppliers to provide us with information using the RMI reporting template. We received a 95% response rate, which is similar to our previous year’s response rate. Based on the responses from our in-scope suppliers and a review and analysis of the responses against RMI’s RMAP Conformant Smelters & Refiners list, which provides sourcing information and audit status for certified smelters, we concluded that, of the identified smelters:

81% were identified as being Conformant (i.e. smelters that have completed an audit and conform with RMAP or another third-party program); and

19% did not disclose their sourcing information.

Of the 81% Conformant smelters, 7% reported sourcing from Covered Countries.

Based on our internal assessment of in-scope suppliers and the RMI reporting template information we received back from our in-scope suppliers, we determined that it was necessary to exercise due diligence to determine the source and chain of custody of the conflict minerals contained in our products.

Trimble Due Diligence

We have designed our due diligence program to conform, in all material respects, with the framework in the “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition),” and the related supplements, published by the Organisation for Economic Co-operation and Development. The following describes Trimble’s due diligence activities for the 2018 reporting year.

Step 1: Establish Strong Company Management Systems

• We have made our Conflict Minerals Policy, described above, publicly available on our website.

• We have established a team that is responsible for administering our Conflict Minerals Program. Our team is supported by, and works closely with, our third-party vendor, MetricStream. Our team consists of personnel from our corporate operation’s group, including representatives from our quality, internal audit and global commodity management departments, and works closely with our specific business area buyers and product managers to address supplier risks and disclosure issues.

• If suppliers are unresponsive or do not provide the requested information, we have a process for escalating the matter to increasingly senior levels of management and considering corrective actions for suppliers that do not meet our stated expectations.

• We have established “Supplier Requirements for the Sourcing of Conflict Minerals,” which we communicate to our suppliers and require them to follow. We also engage suppliers by providing conflict minerals training and orientation materials to assist our suppliers in completing the RMI reporting template and provide support to answer suppliers’ questions. We maintain a conflict minerals resource page with links to resources about the conflict minerals law, the reporting template and our contact information for conflict minerals related inquiries: www.trimble.com/Corporate/Compliance/compliance_resources.

• Our template terms of purchase require suppliers to assist us in complying with applicable provisions of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act such as notifying us of their use of conflict minerals.

• We report on the status and progress of our Conflict Minerals Program during our operation group’s quarterly business and executive-level review meetings.

• Our Conflict Minerals Program, as an established internal process, is subject to oversight by our internal audit group.

Step 2: Identify and Assess Risk in the Supply Chain

• We requested each in-scope supplier to complete and return a reporting template so that we could survey our supply chain and obtain information about the smelters and refiners (which we collectively refer to as “smelters” throughout this report), and mines or locations of origin, of the 3TG used in our products. We identified the standardized reporting template developed by RMI as the best method for collecting information about Trimble’s suppliers to identify and assess risks.

• We tracked responses from in-scope suppliers and initially categorized suppliers according to whether they provided in their responses: (i) legitimate smelter information, or (ii) inconsistent or incomplete information about smelters that required further investigation.

• We used RMI’s smelters and refiners database to obtain conflict minerals sourcing information for the smelters identified on the completed reporting templates from our in-scope suppliers.

• We followed a defined process for reviewing and evaluating reporting template responses, including procedures to address incomplete or vague answers and to follow up with suppliers, as necessary.

• We identified any “high risk” suppliers that require additional attention by focusing on suppliers that: (i) list smelters that are in the Covered Countries and are not found on the RMAP Conformant Smelters & Refiners list (ii) list smelters that have been found to be non-conformant with the RMAP or similar third-party audit programs (iii) list unresponsive smelters that are unwilling to undertake compliance with the RMAP or another third-party audit program; or (iv) list smelters that we identified through our trade compliance screening as smelters that may be financed by a U.S.-embargoed or -sanctioned country, or that are identified as potentially supporting armed conflict or human rights violations.

Step 3: Design and Implement a Strategy to Respond to Identified Risks

• We obtained updated smelter status data from RMI’s smelters and refiners database and compared supplier provided information against such data. Smelters found not in conformance with the RMAP or other independent third-party audit programs (such as the Tin Supply Chain Initiative List and the London Bullion Market Good Delivery Lists) were flagged for further due diligence.

• Any supplier that Trimble identified as “high risk” underwent further investigation and was subject to additional risk mitigation requests by Trimble.

• We informed our in-scope suppliers of identified high risk smelters and requested our suppliers to conduct further due diligence and to work with their supply chains to ensure compliance, such as by requesting impacted suppliers to utilize RMI’s smelter outreach letter in reaching out to non- certified smelters and press them for compliance, or to find substitute smelters.

• We require high risk suppliers to commit to and implement a corrective action plan within a reasonable time frame, and if such plan is deemed ineffective or there is no progress made, at the discretion of management, the supplier is subject to suspension or termination.

• We participate in and support RMI’s working groups on smelter due diligence practices for risk mitigation.

Step 4: Carry Out Independent Third-party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

• We are a member of RMI and rely on RMI’s data to validate the audit status and sourcing information of smelters.

• We conduct our own due diligence through publicly available information regarding identified high risk smelters to validate the existence and assess the conflict status of smelters.

• We address conflict minerals in our general supplier audits, focusing on supplier reporting template responses and due diligence programs.

Step 5: Report on supply chain due diligence

• Our annual Conflict Minerals Report is publicly accessible on our website.

• We remind “high risk” suppliers of our expectations for the upcoming 2018 conflict minerals reporting period and emphasize our requirements and goals.

Results of Due Diligence

Based on the responses received from suppliers, we identified a total of 319 smelters within our supply chain that were potential sources of 3TG for our suppliers.

We utilized RMI’s smelters database to obtain recent smelter audit status as of March 18, 2019. The table below summarizes the status of smelters that were identified through the information provided by our in-scope suppliers. Trimble has adopted the same audit status designations utilized by RMI to categorize audit compliance status. “Conformant” smelters are those that have completed an audit and conform with RMAP or other third party programs. “Active” smelters are those that are engaging with RMAP or other third party auditors to achieve compliance. “In Communication” refers to smelters that are not certified, but which demonstrate interest in participating in an audit program. “Alleged” are smelters that are not certified and have not yet even been verified to be a true smelter or still in business. “Non- Conformant” are those smelters that have been identified as having non-conformant audit results.

Schedule A lists all of the verified smelters reported by our in-scope suppliers that we believe processed 3TG which may have been used in Trimble products during the 2018 reporting period.

2018 Trimble Smelters or Refiners Audit Status
Metal:	Smelter Status:
	Conformant Smelters	Active Smelters	In Communication Smelters	Alleged Smelters	Non-Conformant Smelters
Gold	102	4	4	40	3
Tantalum	40	—	—	—	—
Tin	75	1	—	6	1
Tungsten	40	1	—	2	—
Total	257	6	4	48	4

Of the 319 entities identified as smelters or alleged smelters, 177 smelters had associated mine disclosure information that was provided to us by RMI. From this information, we determined that 159 of those smelters did not source 3TG from the Covered Countries. For the 18 smelters that sourced 3TG from Covered Countries, we determined that they were certified as Conformant by RMI.

Trimble identified certain smelters as potentially high risk in its supply chain, and issued corrective actions to all 70 in-scope suppliers that listed at least one of the smelters identified as high risk. Of those, 48 suppliers have either completed due diligence follow-up action or responded with remedial action plans. The remaining 22 suppliers have acknowledged Trimble’s requests for corrective actions but have not yet provided definitive remedial plans. Trimble continues to closely monitor the progress of these suppliers and will consider additional corrective action if warranted.

Determination

Based on the measures we have taken, as described above, we do not have sufficient information to determine the country of origin of all of the 3TG contained in our products. Not all of the RMAP Conformant smelters disclosed the origin of their minerals. In addition, the information provided by some suppliers was incomplete and unverifiable, and certain smelters identified by suppliers were not recognized by RMI or were unknown to us so we were unable to determine the origin of minerals processed by such smelters.

However, based on the information provided by our suppliers, as well as information from RMI and other third party sources, we believe the origin of 3TG processed by smelters known to us and contained in our products include the countries listed in Schedule B. As discussed above, the known smelters for which we had mine disclosure information, and that we believe processed 3TG originating from the Covered Countries, were all certified Conformant by RMI. In addition, we are not aware of any instance where 3TG sourced from the Covered Countries directly or indirectly financed or benefited armed groups.

Future Due Diligence Measures

We intend to take the following measures in 2019 to further mitigate the risk that conflict minerals in our products could directly or indirectly finance or benefit armed groups in the Covered Countries:

• Encourage our suppliers to adopt best practices for the responsible sourcing of materials.

• Continue to work to increase the response rate and quality of supplier responses by: working directly with our suppliers on the completion of their RMI reporting templates including direct engagement of our strategic key suppliers and providing additional conflict minerals training to suppliers who have been unable to provide sufficient response quality.

• Continue to encourage our suppliers to source from smelters that are RMAP conformant, or are engaged with RMI to undergo an audit.

• Monitor the progress of suppliers with high risk smelters identified within their supply chains.

• Continue to communicate with our suppliers regarding Trimble’s Conflict Minerals Policy and Supplier Requirements for the Sourcing of Conflict Minerals to ensure that suppliers appropriately assess their supply chains, in keeping with the principles of responsible sourcing and corporate social responsibility underlying Trimble’s Conflict Minerals Program.

• Review our supplier risk mitigation process to assess remedial and corrective actions that we may take to address situations where suppliers are unresponsive, provide incomplete information or continue to source from unknown smelters.

• Continue monitoring our supply chain activities, keep current with changes or updates in relevant laws and guidance, and update our related policies and procedures as appropriate.

Schedule A

Verified Smelters and Refiners

Metal	Smelter Name	Country
Gold	Abington Reldan Metals, Llc	UNITED STATES OF AMERICA
Gold	Advanced Chemical Company	UNITED STATES OF AMERICA
Gold	Aida Chemical Industries Co., Ltd.	JAPAN
Gold	Al Etihad Gold Llc	UNITED ARAB EMIRATES
Gold	Allgemeine Gold-Und Silberscheideanstalt A.G.	GERMANY
Gold	Almalyk Mining And Metallurgical Complex (Ammc)	UZBEKISTAN
Gold	Anglogold Ashanti Corrego Do Sitio Mineracao	BRAZIL
Gold	Argor-Heraeus Sa	SWITZERLAND
Gold	Asahi Pretec Corp.	JAPAN
Gold	Asaka Riken Co., Ltd.	JAPAN
Gold	Au Traders And Refiners	SOUTH AFRICA
Gold	Aurubis Ag	GERMANY
Gold	Balore Refinersga	INDIA
Gold	Bangko Sentral Ng Pilipinas (Central Bank Of The Philippines)	PHILIPPINES
Gold	Boliden Ab	SWEDEN
Gold	C. Hafner Gmbh + Co. Kg	GERMANY
Gold	Ccr Refinery - Glencore Canada Corporation	CANADA
Gold	Cendres + Metaux S.A.	SWITZERLAND
Gold	Chimet S.P.A.	ITALY
Gold	China'S Shandong Gold Mining Co., Ltd	CHINA
Gold	Chugai Mining	JAPAN
Gold	Daejin Industry	KOREA, REPUBLIC OF
Gold	Daye Non-Ferrous Metals Mining Ltd.	CHINA
Gold	Doduco	GERMANY
Gold	Dosung Metal	KOREA, REPUBLIC OF
Gold	Dowa Metals & Mining Co. Ltd	JAPAN
Gold	Ds Pretech Co., Ltd.	KOREA, REPUBLIC OF
Gold	Eco-System Recycling Co., Ltd.	JAPAN
Gold	Emirates Gold Dmcc	UNITED ARAB EMIRATES
Gold	Federal State Unitary Enterprise Moscow Special Processing Plant (Fsue Mzss)	RUSSIAN FEDERATION
Gold	Fse Novosibirsk Refinery	RUSSIAN FEDERATION
Gold	Fujian Zijin Mining Stock Company Gold Smelter	CHINA
Gold	Geib Refining Corporation	UNITED STATES OF AMERICA
Gold	Heesung Metal Ltd.	KOREA, REPUBLIC OF
Gold	Heimerle + Meule Gmbh	GERMANY
Gold	Heraeus Ltd. Hong Kong	CHINA
Gold	Heraeus Precious Metals Gmbh & Co. Kg	GERMANY
Gold	Inner Mongolia Qiankun Gold And Silver Refinery Share Co., Ltd.	CHINA
Gold	Ishifuku Metal Industry Co., Ltd.	JAPAN
Gold	Istanbul Gold Refinery	TURKEY
Gold	Italpreziosi	ITALY
Gold	Japan Mint	JAPAN
Gold	Jiangxi Copper Co., Ltd.	CHINA
Gold	Johnson Matthey Inc.	UNITED STATES OF AMERICA
Gold	Johnson Matthey Limited	CANADA
Gold	Jsc Uralelectromed	RUSSIAN FEDERATION

Gold	Jx Nippon Mining & Metals Co., Ltd.	JAPAN
Gold	Kazakhmys Smelting Llc	KAZAKHSTAN
Gold	Kazzinc	KAZAKHSTAN
Gold	Kennecott Utah Copper Llc	UNITED STATES OF AMERICA
Gold	Kghm Polska Miedz S.A.	POLAND
Gold	Kojima Chemicals Co., Ltd	JAPAN
Gold	Korea Zinc Co., Ltd.	KOREA, REPUBLIC OF
Gold	Kyrgyzaltyn Jsc	KYRGYZSTAN
Gold	L'Orfebre S.A.	ANDORRA
Gold	Marsam Metals	BRAZIL
Gold	Materion	UNITED STATES OF AMERICA
Gold	Matsuda Sangyo Co., Ltd.	JAPAN
Gold	Metalor Switzerland	SWITZERLAND
Gold	Metalor Technologies (Hong Kong) Ltd.	CHINA
Gold	Metalor Technologies (Singapore) Pte., Ltd.	SINGAPORE
Gold	Metalor Technologies (Suzhou) Ltd.	CHINA
Gold	Metalor Usa Refining Corporation	UNITED STATES OF AMERICA
Gold	Met-Mex Pe?Oles, S.A.	MEXICO
Gold	Mitsubishi Materials Corporation	JAPAN
Gold	Mitsui Kinzoku Co., Ltd.	JAPAN
Gold	Mmtc-Pamp India Pvt., Ltd.	INDIA
Gold	Modeltech Sdn Bhd	MALAYSIA
Gold	Nadir Metal Rafineri San. Ve Tic. A.S.	TURKEY
Gold	Nh Recytech Company	KOREA, REPUBLIC OF
Gold	Nihon Material Co. Ltd	JAPAN
Gold	Ogussa Osterreichische Gold- Und Silber-Scheideanstalt Gmbh	AUSTRIA
Gold	Ohura Precious Metal Industry Co., Ltd.	JAPAN
Gold	Ojsc "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (Ojsc Krastsvetmet)	RUSSIAN FEDERATION
Gold	Pamp S.A.	SWITZERLAND
Gold	Planta Recuperadora De Metales Spa	CHILE
Gold	Prioksky Plant Of Non-Ferrous Metals	RUSSIAN FEDERATION
Gold	Pt Aneka Tambang (Persero) Tbk	INDONESIA
Gold	Px Precinox S.A.	SWITZERLAND
Gold	Rand Refinery (Pty) Ltd.	SOUTH AFRICA
Gold	Refinery Ls-Nikko Copper Inc.	KOREA, REPUBLIC OF
Gold	Remondis Argentia B.V.	NETHERLANDS
Gold	Royal Canadian Mint	CANADA
Gold	Saamp	FRANCE
Gold	Safimet S.P.A	ITALY
Gold	Samdok Metal	KOREA, REPUBLIC OF
Gold	Saxonia Edelmetalle Gmbh	GERMANY
Gold	Sempsa Joyeria Plateria S.A.	SPAIN
Gold	Shandong Zhaojin Gold & Silver Refinery Co. Ltd	CHINA
Gold	Sichuan Tianze Precious Metals Co., Ltd.	CHINA
Gold	Singway Technology Co., Ltd.	TAIWAN, PROVINCE OF CHINA
Gold	Smelter Not Listed	ITALY
Gold	Smelter Not Listed	UNITED ARAB EMIRATES
Gold	Soe Shyolkovsky Factory Of Secondary Precious Metals	RUSSIAN FEDERATION
Gold	Solar Applied Materials Technology Corp.	TAIWAN, PROVINCE OF CHINA

Gold	Sumitomo Metal Mining Co., Ltd.	JAPAN
Gold	Sungeel Hitech	KOREA, REPUBLIC OF
Gold	T.C.A S.P.A	ITALY
Gold	Tanaka Kikinzoku Kogyo K.K	JAPAN
Gold	Tokuriki Honten Co., Ltd.	JAPAN
Gold	Tony Goetz Nv	BELGIUM
Gold	Too Tau-Ken-Altyn	KAZAKHSTAN
Gold	Torecom	KOREA, REPUBLIC OF
Gold	Umicore Brasil Ltda.	BRAZIL
Gold	Umicore Precious Metals Thailand	THAILAND
Gold	Umicore S.A. Business Unit Precious Metals Refining	BELGIUM
Gold	United Precious Metal Refining, Inc.	UNITED STATES OF AMERICA
Gold	Valcambi S.A.	SWITZERLAND
Gold	Western Australian Mint (T/A The Perth Mint)	AUSTRALIA
Gold	Wieland Edelmetalle Gmbh	GERMANY
Gold	Yamamoto Precision Metals	JAPAN
Gold	Yokohama Metal Co., Ltd.	JAPAN
Gold	Zhongyuan Gold Smelter Of Zhongjin Gold Corporation	CHINA
Tantalum	Asaka Riken Co., Ltd.	JAPAN
Tantalum	Changsha South Tantalum Niobium Co., Ltd.	CHINA
Tantalum	Conghua Tantalum And Niobium Smeltry	CHINA
Tantalum	D Block Metals, Llc	UNITED STATES OF AMERICA
Tantalum	Exotech Inc.	UNITED STATES OF AMERICA
Tantalum	F&X Electro-Materials Ltd.	CHINA
Tantalum	Fir Metals & Resource Ltd.	CHINA
Tantalum	Global Advanced Metals Aizu	JAPAN
Tantalum	Global Advanced Metals Boyertown	UNITED STATES OF AMERICA
Tantalum	Guangdong Zhiyuan New Material Co., Ltd.	CHINA
Tantalum	H.C. Starck Co., Ltd.	THAILAND
Tantalum	H.C. Starck Hermsdorf Gmbh	GERMANY
Tantalum	H.C. Starck Inc.	UNITED STATES OF AMERICA
Tantalum	H.C. Starck Ltd.	JAPAN
Tantalum	H.C. Starck Smelting Gmbh & Co. Kg	GERMANY
Tantalum	H.C. Starck Tantalum And Niobium Gmbh	GERMANY
Tantalum	Hengyang King Xing Lifeng New Materials Co., Ltd.	CHINA
Tantalum	Jiangxi Dinghai Tantalum & Niobium Co., Ltd.	CHINA
Tantalum	Jiangxi Tuohong New Raw Material	CHINA
Tantalum	Jiujiang Janny New Material Co., Ltd.	CHINA
Tantalum	Jiujiang Jinxin Nonferrous Metals Co., Ltd.	CHINA
Tantalum	Jiujiang Nonferrous Metals Smelting Company Limited	CHINA
Tantalum	Jiujiang Zhongao Tantalum & Niobium Co., Ltd.	CHINA
Tantalum	Kemet Blue Metals	MEXICO
Tantalum	Kemet Blue Powder	UNITED STATES OF AMERICA
Tantalum	Lsm Brasil S.A.	BRAZIL
Tantalum	Metallurgical Products India Pvt. Ltd. (Mpil)	INDIA
Tantalum	Mineração Taboca S.A.	BRAZIL
Tantalum	Mitsui Mining And Smelting Co., Ltd.	JAPAN
Tantalum	Molycorp Silmet A.S.	ESTONIA
Tantalum	Ningxia Orient Tantalum Industry Co., Ltd.	CHINA

Tantalum	Power Resources Ltd.	MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Tantalum	Quantumclean	UNITED STATES OF AMERICA
Tantalum	Resind Ind E Com Ltda.	BRAZIL
Tantalum	Rfh	CHINA
Tantalum	Solikamsk Magnesium Works Oao	RUSSIAN FEDERATION
Tantalum	Taki Chemicals	JAPAN
Tantalum	Telex Metals	UNITED STATES OF AMERICA
Tantalum	Ulba	KAZAKHSTAN
Tantalum	Xinxing Haorong Electronic Material Co., Ltd.	CHINA
Tin	Alpha	UNITED STATES OF AMERICA
Tin	Chenzhou Yun Xiang Mining Limited Liability Company	CHINA
Tin	Chifeng Dajingzi Tin Industry Co., Ltd.	CHINA
Tin	China Tin Group Co., Ltd.	CHINA
Tin	Cv Ayi Jaya	INDONESIA
Tin	Cv Dua Sekawan	INDONESIA
Tin	Cv Gita Pesona	INDONESIA
Tin	Cv Serumpun Sebalai	INDONESIA
Tin	Cv Tiga Sekawan	INDONESIA
Tin	Cv United Smelting	INDONESIA
Tin	Cv Venus Inti Perkasa	INDONESIA
Tin	Dowa Metaltech Co., Ltd.	JAPAN
Tin	Electro-Mechanical Facility Of The Cao Bang Minerals & Metallurgy Joint Stock Company	VIET NAM
Tin	Em Vinto	BOLIVIA (PLURINATIONAL STATE OF)
Tin	Fenix Metals	POLAND
Tin	Gejiu Fengming Metallurgy Chemical Plant	CHINA
Tin	Gejiu Jinye Mineral Company	CHINA
Tin	Gejiu Kai Meng Industry And Trade Llc	CHINA
Tin	Gejiu Non-Ferrous Metal Processing Co. Ltd.	CHINA
Tin	Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.	CHINA
Tin	Gejiu Zi-Li	CHINA
Tin	Guangdong Hanhe Non-Ferrous Metal Co., Ltd.	CHINA
Tin	Guanyang Guida Nonferrous Metal Smelting Plant	CHINA
Tin	Huichang Hill Tin Industry Co., Ltd.	CHINA
Tin	Huichang Shun Tin Kam Industries, Ltd.	CHINA
Tin	Jiangxi Nanshan	CHINA
Tin	Magnu'S Minerais Metais E Ligas Ltda.	BRAZIL
Tin	Malaysia Smelting Corporation (Msc)	MALAYSIA
Tin	Melt Metais E Ligas S.A.	BRAZIL
Tin	Metallic Resources, Inc.	UNITED STATES OF AMERICA
Tin	Metallo Belgium N.V.	BELGIUM
Tin	Metallo Spain S.L.U.	SPAIN
Tin	Mineração Taboca S.A.	BRAZIL
Tin	Minsur	PERU
Tin	Mitsubishi Materials Corporation	JAPAN
Tin	Modeltech Sdn Bhd	MALAYSIA
Tin	O.M. Manufacturing (Thailand) Co., Ltd.	THAILAND
Tin	O.M. Manufacturing Philippines, Inc.	PHILIPPINES

Tin	Operaciones Metalurgical S.A.	BOLIVIA (PLURINATIONAL STATE OF)
Tin	Pt Aries Kencana Sejahtera	INDONESIA
Tin	Pt Artha Cipta Langgeng	INDONESIA
Tin	Pt Atd Makmur Mandiri Jaya	INDONESIA
Tin	Pt Babel Inti Perkasa	INDONESIA
Tin	Pt Bangka Prima Tin	INDONESIA
Tin	Pt Bangka Serumpun	INDONESIA
Tin	Pt Bangka Tin Industry	INDONESIA
Tin	Pt Belitung Industri Sejahtera	INDONESIA
Tin	Pt Bukit Timah	INDONESIA
Tin	Pt Ds Jaya Abadi	INDONESIA
Tin	Pt Inti Stania Prima	INDONESIA
Tin	Pt Karimun Mining	INDONESIA
Tin	Pt Kijang Jaya Mandiri	INDONESIA
Tin	Pt Lautan Harmonis Sejahtera	INDONESIA
Tin	Pt Menara Cipta Mulia	INDONESIA
Tin	Pt Mitra Stania Prima	INDONESIA
Tin	Pt Panca Mega Persada	INDONESIA
Tin	Pt Prima Timah Utama	INDONESIA
Tin	Pt Refined Bangka Tin	INDONESIA
Tin	Pt Sariwiguna Binasentosa	INDONESIA
Tin	Pt Stanindo Inti Perkasa	INDONESIA
Tin	Pt Sukses Inti Makmur	INDONESIA
Tin	Pt Sumber Jaya Indah	INDONESIA
Tin	Pt Tambang Timah	INDONESIA
Tin	Pt Timah (Persero) Tbk Mentok	INDONESIA
Tin	Pt Tinindo Inter Nusa	INDONESIA
Tin	Pt Tirus Putra Mandiri	INDONESIA
Tin	Pt Tommy Utama	INDONESIA
Tin	Resind Ind E Com Ltda.	BRAZIL
Tin	Rui Da Hung	TAIWAN, PROVINCE OF CHINA
Tin	Smelter Not Listed	INDONESIA
Tin	Soft Metais Ltda.	BRAZIL
Tin	Thai Nguyen Mining And Metallurgy Co., Ltd.	VIET NAM
Tin	Thailand Smelting & Refining Co Ltd	THAILAND
Tin	Tin Technology & Refining	UNITED STATES OF AMERICA
Tin	White Solder Metalurgia E Mineracao Ltda.	BRAZIL
Tin	Yunnan Chengfeng Non-Ferrous Metals Co., Ltd.	CHINA
Tin	Yunnan Tin Company, Ltd.	CHINA
Tungsten	A.L.M.T. Tungsten Corp.	JAPAN
Tungsten	Acl Metais Eireli	BRAZIL
Tungsten	Chenzhou Diamond Tungsten Products Co., Ltd.	CHINA
Tungsten	Chongyi Zhangyuan Tungsten Co Ltd	CHINA
Tungsten	Fujian Jinxin Tungsten Co., Ltd.	CHINA
Tungsten	Ganzhou Haichuang Tungsten Co., Ltd.	CHINA
Tungsten	Ganzhou Huaxing Tungsten Products Co., Ltd.	CHINA
Tungsten	Ganzhou Jiangwu Ferrotungsten Co., Ltd.	CHINA
Tungsten	Ganzhou Seadragon W & Mo Co., Ltd.	CHINA
Tungsten	Gtp	UNITED STATES OF AMERICA

Tungsten	Guangdong Xianglu Tungsten Co., Ltd.	CHINA
Tungsten	H.C. Starck Smelting Gmbh & Co. Kg	GERMANY
Tungsten	H.C. Starck Tungsten Gmbh	GERMANY
Tungsten	Hunan Chenzhou Mining Group Co., Ltd.	CHINA
Tungsten	Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji	CHINA
Tungsten	Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.	CHINA
Tungsten	Hunan Litian Tungsten Industry Co., Ltd.	CHINA
Tungsten	Hydrometallurg, Jsc	RUSSIAN FEDERATION
Tungsten	Japan New Metals Co., Ltd.	JAPAN
Tungsten	Jiangwu H.C. Starck Tungsten Products Co., Ltd.	CHINA
Tungsten	Jiangxi Gan Bei Tungsten Co., Ltd.	CHINA
Tungsten	Jiangxi Tonggu Non-Ferrous Metallurgical & Chemical Co., Ltd.	CHINA
Tungsten	Jiangxi Xinsheng Tungsten Industry Co., Ltd.	CHINA
Tungsten	Jiangxi Yaosheng Tungsten Co., Ltd.	CHINA
Tungsten	Kennametal Fallon	UNITED STATES OF AMERICA
Tungsten	Kennametal Huntsville	UNITED STATES OF AMERICA
Tungsten	Kgets Co., Ltd.	KOREA, REPUBLIC OF
Tungsten	Malipo Haiyu Tungsten Co., Ltd.	CHINA
Tungsten	Moliren Ltd.	RUSSIAN FEDERATION
Tungsten	Niagara Refining Llc	UNITED STATES OF AMERICA
Tungsten	Nui Phao H.C. Starck Tungsten Chemicals Manufacturing Llc	VIET NAM
Tungsten	Philippine Chuangxin Industrial Co., Inc.	PHILIPPINES
Tungsten	Shaoguan Xinhai Rendan Tungsten Industry Co. Ltd	CHINA
Tungsten	South-East Nonferrous Metal Company Limited Of Hengyang City	CHINA
Tungsten	Tejing (Vietnam) Tungsten Co., Ltd.	VIET NAM
Tungsten	Unecha Refractory Metals Plant	RUSSIAN FEDERATION
Tungsten	Wbh	AUSTRIA
Tungsten	Woltech Korea Co., Ltd.	KOREA, REPUBLIC OF
Tungsten	Xiamen Tungsten (H.C.) Co., Ltd.	CHINA
Tungsten	Xiamen Tungsten Co., Ltd	CHINA
Tungsten	Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.	CHINA

Schedule B

Countries of Origin List

Australia	Malaysia
Austria	Mali
Benin	Mauritania
Bolivia	Mongolia
Bolivia (Plurinational State of)	Mozambique
Brazil	Myanmar
Burundi	Nicaragua
Chile	Niger
China	Nigeria
Colombia	Peru
Congo, Democratic Republic of the	Portugal
Ecuador	Russian Federation
Eritrea	Rwanda
Ethiopia	Sierra Leone
Ghana	South Africa
Guinea	Swaziland
Guyana	Taiwan
India	Thailand
Indonesia	Togo
Laos	United Kingdom of Great Britain and Northern Ireland
Madagascar	Venezuela