EX-1.01 2 ex101conflictmineralsrepor.htm EX-1.01 Document

EXHIBIT 1.01



STANLEY BLACK & DECKER, INC.
Conflict Minerals Report
For The Year Ended December 31, 2022

This report for the year ended December 31, 2022 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“the Rule”).

1.    Overview
Stanley Black & Decker, Inc. ("the Company") is a global provider of hand tools, power tools, outdoor products and related accessories, as well as a leading provider of engineered fastening solutions and attachment tools for infrastructure applications. The Company manufactures products for which tin, tantalum, tungsten and gold ("3TG minerals" or "conflict minerals") are necessary to the functionality or production of those products and which otherwise constitute products under the Rule.

In accordance with the Rule, the Company conducted a good faith reasonable country of origin inquiry ("RCOI") that was reasonably designed to determine whether any of the 3TG minerals in the Company's products originated in the Democratic Republic of the Congo (the "DRC") or Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia ("adjoining countries"), or were from recycled or scrap sources. Based on the Company's RCOI, the Company has reason to believe that some of the 3TG minerals used in the Company's products originated in the DRC or adjoining countries and may not have been from recycled or scrap sources. Accordingly, the Company exercised due diligence to determine the source and chain of custody of these 3TG minerals. The Company's due diligence was designed to materially conform to the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (2016) and the related Supplements for gold and for tin, tantalum and tungsten (collectively "the OECD Guidance"). A description of the Company's RCOI and due diligence measures is set forth in this report.

Product Description
The Company’s operations are classified into two reportable business segments: Tools & Outdoor and Industrial.

Tools & Outdoor

The Tools & Outdoor segment is comprised of the Power Tools Group ("PTG"), Hand Tools, Accessories & Storage ("HTAS"), and Outdoor Power Equipment ("Outdoor") businesses.
The PTG business includes both professional and consumer products. Professional products include professional grade corded and cordless electric power tools and equipment including drills, impact wrenches and drivers, grinders, saws, routers and sanders, as well as pneumatic tools and fasteners including nail guns, nails, staplers and staples, and concrete and masonry anchors. Consumer products include corded and cordless electric power tools sold primarily under the BLACK+DECKER® brand, and home products such as hand-held vacuums, paint tools and cleaning appliances.
The HTAS business sells hand tools, power tool accessories and storage products. Hand tools include measuring, leveling and layout tools, planes, hammers, demolition tools, clamps, vises, knives, saws, chisels and industrial and automotive tools. Power tool accessories include drill bits, screwdriver bits, router bits, abrasives, saw blades and threading products. Storage products include tool boxes, sawhorses, medical cabinets and engineered storage solution products.
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The Outdoor business primarily sells corded and cordless electric lawn and garden products, including hedge trimmers, string trimmers, lawn mowers, pressure washers and related accessories, and gas powered lawn and garden products, including lawn tractors, zero turn ride on mowers, walk behind mowers, snow blowers, residential robotic mowers, utility terrain vehicles (UTVs), hand-held outdoor power equipment, garden tools, and parts and accessories to professionals and consumers under the DEWALT®, CUB CADET®, BLACK+DECKER®, CRAFTSMAN®, TROY-BILT®, and HUSTLER® brand names.
On December 1, 2021, the Company acquired the remaining 80 percent ownership stake in MTD Holdings Inc. ("MTD"), a privately held global designer, manufacturer and distributor of lawn tractors, zero turn ride on mowers, walk behind mowers, snow blowers, residential robotic mowers, handheld outdoor power equipment and garden tools for both residential and professional consumers under well-known brands like CUB CADET® and TROY-BILT®. The Company previously acquired a 20 percent interest in MTD in January 2019. The results of this acquisition have been consolidated into the Company's Tools & Outdoor segment and were included in the Company's due diligence procedures in 2022.
On November 12, 2021, the Company acquired Excel Industries ("Excel"), a leading designer and manufacturer of premium commercial and residential turf-care equipment under the HUSTLER® brand. The results of this acquisition have been consolidated into the Company's Tools & Outdoor segment and were included in the Company's due diligence procedures in 2022.
Industrial
The Industrial segment is comprised of the Engineered Fastening and Infrastructure businesses.
The Engineered Fastening business primarily sells highly engineered components such as fasteners, fittings and various engineered products, which are designed for specific application across multiple verticals. The product lines include externally threaded fasteners, blind rivets and tools, blind inserts and tools, drawn arc weld studs and systems, engineered plastic and mechanical fasteners, self-piercing riveting systems, precision nut running systems, micro fasteners, high-strength structural fasteners, axel swage, latches, heat shields, pins, and couplings.
The Infrastructure business sells hydraulic tools and high quality, performance-driven heavy equipment attachment tools for off-highway applications.
Divestitures
On August 19, 2022, the Company sold its Oil & Gas business comprised of the pipeline services and equipment businesses to Pipeline Technique Limited.
On July 22, 2022, the Company sold its Convergent Security Solutions ("CSS") business comprised of the commercial electronic security and healthcare businesses to Securitas AB.
On July 5, 2022, the Company sold its Mechanical Access Solutions ("MAS") business comprised of the automatic doors business to Allegion plc.
This report primarily covers the businesses and their products described above except for those which were determined to be out-of-scope of the Rule, primarily CSS and Oil & Gas.

Supply Chain

The Company both manufactures and contracts to manufacture its products described above, as well as components and raw materials for those products. Some of those products may be manufactured using 3TG minerals which are procured globally and from multiple suppliers who are several tiers away from the origin of and smelters of their raw materials. As such, the Company does not typically have a direct relationship with smelters and refiners of 3TG minerals. Additionally, the Company’s size, complexity of its products, and the depth, breadth and constant evolution of its supply chain, make it difficult to identify sub-tier suppliers from its direct suppliers, and therefore, the Company is reliant upon its direct suppliers to provide information on the origin of 3TG minerals contained in components and materials purchased. The Company’s suppliers are similarly reliant upon information provided by their suppliers and therefore face similar challenges to obtaining origin information. Additionally, many of the Company’s suppliers and its suppliers’ suppliers are foreign and not directly subject to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“the Dodd-Frank Act”).

Conflict Minerals Policy

The Company has adopted the following Conflict Minerals Policy:

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Stanley Black & Decker is committed to conducting business in an ethical, law abiding manner. This includes our commitment to not only comply with all applicable laws and regulations but also to operate our business on a foundation of integrity, trust and respect throughout our supply chain. Along with governmental and non-governmental organizations, civil society and affected third parties, we are concerned about the potential human rights issues, such as forced labor, inhumane or cruel treatment, and child labor, associated with the mining of Conflict Minerals (defined as tin, tungsten, tantalum and gold) which are occurring in the Democratic Republic of Congo ("DRC") and adjoining countries (“DRC region”).

Stanley Black & Decker is cognizant of our obligations under Section 1502 of the Dodd-Frank Act and is working with our suppliers to meet the due diligence and reporting requirements of Section 1502. As part of this process, we are helping our suppliers understand the due diligence steps they can take to investigate the source of any Conflict Minerals in the products they sell us. If, based on our due diligence, we determine there is a reasonable risk that Conflict Minerals in our products may be directly or indirectly linked to the financing of conflict in the DRC region, we will determine an appropriate course of action based on the facts and circumstances relating to the affected products. Such action may include, but is not limited to, the suspension or termination of our relationship with particular suppliers.

Determining whether all products sold by Stanley Black & Decker are Conflict Free is a time consuming and difficult process. We manufacture and distribute thousands of products, many of which contain, or may contain, the minerals that have been defined as Conflict Minerals. We source the raw materials and component parts for the products we manufacture, as well as finished products, from thousands of other companies around the world. Stanley Black & Decker is and has been working with our suppliers to educate them regarding Stanley Black & Decker’s disclosure obligations under the Dodd-Frank Act and concerning steps they can take to obtain increased transparency regarding the origin of minerals contained in the products they supply to us.

Stanley Black & Decker has the following expectations of its suppliers:

suppliers should identify any products sold to Stanley Black & Decker that contain any Conflict Minerals which are not DRC Conflict Free;
suppliers should develop Conflict Minerals policies, due diligence frameworks, and management systems that are designed to prevent Conflict Minerals that are not DRC Conflict Free from being included in the products sold to Stanley Black & Decker; and
Stanley Black & Decker suppliers should source Conflict Minerals only from sources that are DRC Conflict Free.

In doing so, suppliers are expected to:

implement and communicate to their personnel and suppliers policies that are consistent with this policy, and require their direct and indirect suppliers to do the same;
put in place procedures for the traceability of Conflict Minerals, working with their direct and indirect suppliers as applicable;
use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being DRC Conflict Free, and require their direct and indirect suppliers to do the same;
advise Stanley Black & Decker of any determination that the supplier either has concluded or has a reasonable basis to believe the products it currently sells or has sold to Stanley Black & Decker are not DRC Conflict Free;
maintain reviewable business records supporting the source of Conflict Minerals; and
from time to time, at Stanley Black & Decker's request, provide Stanley Black & Decker with information concerning the origin of Conflict Minerals included in products sold to Stanley Black & Decker, which Stanley Black & Decker shall be entitled to use or disclose in satisfying any legal or regulatory requirements or in any customer or marketing communications, notwithstanding the terms of a confidentiality agreement that do not specifically reference this paragraph.

Suppliers also are encouraged to support industry efforts to enhance traceability and responsible practices in Conflict Minerals supply chains.

Consequences of Supplier Noncompliance

Stanley Black & Decker evaluates its relationships with its suppliers on an ongoing basis. Stanley Black & Decker reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this policy. Stanley Black & Decker also reserves the right to request additional documentation from suppliers regarding the origin of any Conflict Minerals included in any products sold to Stanley Black & Decker.
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Suppliers who do not reasonably comply with this policy shall be reviewed by Stanley Black & Decker’s Global Supply Management ("GSM") organization for future business.

In the event Stanley Black & Decker determines that the supplier’s efforts to comply with this policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Stanley Black & Decker reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier. Nothing in this policy is intended to in any way grant any additional rights or expectations to any Stanley Black & Decker supplier or in any way modify or otherwise limit in any way any of Stanley Black & Decker's contractual or legal rights.

Grievance Mechanism and Reporting

Our employees, suppliers and other parties can report concerns and alleged violations of this policy via the SBD Integrity Helpline ("Integrity Helpline"). The Integrity Helpline can be reached 24 hours/365 days a year, and translators are available.

Reports can be made anonymously and will be kept confidential to the fullest extent practicable and allowed by law.

We will not take any retaliatory action against our employees, suppliers or other parties who make a report in good faith. Our suppliers are encouraged to contact the Integrity Helpline if they wish to seek guidance on the application of this policy.

Conclusion

Stanley Black & Decker fully understands the importance of this issue to its customers and is committed to supply chain initiatives and overall corporate social responsibility and sustainability efforts that work towards a DRC Conflict Free supply chain. We encourage all of our suppliers to likewise support these efforts.

This policy is publicly available at www.stanleyblackanddecker.com/investors under the Governance section.

RCOI

Prior to conducting the Company's RCOI, the Company performed a risk-based assessment of its products for components and/or raw materials which were most likely to contain 3TG minerals. The Company required direct suppliers of those components and/or raw materials to complete a supply chain survey through a third-party compliance tool that uses the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template to determine whether any of those components and/or raw materials originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, to enable the identification of smelters and refiners that process the 3TG minerals.

The Company's escalation process for suppliers who were delinquent in responding to the Company's survey by the specified date included:
Two non-system generated emails
Direct phone call(s) from GSM supplier owner
Direct phone call(s) from Conflict Mineral Working Group member
Weekly pulsing calls between GSM supplier owners and Conflict Mineral Working group member to update on response status

Smelters and refiners identified in the survey responses were aggregated and then validated against the RMI's Standard Smelter List, and once validated, against the RMI's Responsible Minerals Assurance Process (“RMAP”) to determine conformance status. RMAP conformant smelters and refiners were then validated against the RMI’s RCOI Data Document to determine country of origin information for the minerals being processed by the smelters and refiners.

Based on the suppliers' responses to the RCOI, the Company has reason to believe that some of the 3TG minerals used in the Company's products may have originated in the DRC or adjoining countries and may not have been from recycled or scrap sources.

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2.    Due Diligence

2.1    Design of Due Diligence

The Company's due diligence measures are designed to materially conform with the OECD Guidance.

OECD Step 1: Establish Strong Company Management Systems

Company Policy

The Company has a Conflict Mineral Policy which is posted on its website at www.stanleyblackanddecker.com/investors under the Governance section.

Internal Team

The Company has a Steering Committee sponsored by the Company’s Executive Vice President and Chief Financial Officer, as well as a Working Group. Members of the Steering Committee and Working Group are subject matter experts from relevant functions such as Global Supply Management, Sustainability, Finance and Legal. The Steering Committee is responsible for oversight of the Company’s conflict minerals compliance strategy and due diligence process, monitoring the due diligence progress, ensuring communication of critical information reaches employees and suppliers, and ensuring the timely and accurate filing of this report. The Working Group is charged with implementation of the Company's policy, conducting due diligence, communications to suppliers and others, and reporting its progress to the Steering Committee on a regular basis.

System of Controls and Transparency Over the Supply Chain

The Company surveys its supply chain utilizing a third-party compliance tool that models the RMI's Conflict Minerals Reporting Template (“the CMRT”). The CMRT is a supply chain survey designed to gather information from a company's suppliers to determine whether any of the components and/or raw materials provided to the Company originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, to enable the identification of smelters and refiners that process the 3TG minerals.

Supplier Engagement

The Company's Conflict Mineral Policy is posted on its supplier portal for all suppliers to access. Additionally, the Company's supplier Master Purchase Agreements include a Conflict Minerals provision which requires its suppliers to provide information necessary to allow the Company and its customers to comply with the provisions of the Dodd-Frank Act and explicitly gives the Company the rights to audit the supply chain and terminate arrangements with suppliers who are unwilling or unable to comply. As the specific Conflict Minerals provision was introduced into supplier Master Purchase Agreements several years ago, the majority of the Company's agreements contain this provision. As older agreements come up for renewal, the Conflict Minerals provision is introduced into new agreements. While the Company cannot unilaterally impose new contract terms, including those that would compel its suppliers to support the Company's conflict minerals due diligence efforts, all Master Purchase Agreements contain a compliance with laws clause which provides for the Company’s suppliers to abide by directives from the Company to be in compliance with applicable laws. The Company does not knowingly engage new suppliers who are not in compliance with the Company's Conflict Mineral policy.

Grievance Mechanism

The Company has an established grievance mechanism for reporting violations of the Company’s policies.

Maintain Records

The Company maintains Conflict Mineral related information in accordance with its record retention policy.

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OECD Step 2: Identify and Assess Risk in the Supply Chain

The Company performs a risk-based assessment of its products for components and/or raw materials which are most likely to contain 3TG minerals and surveys suppliers of those components and/or raw materials using the CMRT to determine whether any of those components and/or raw materials originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, identify smelters and refiners in the Company's supply chain. Identified smelters and refiners are aggregated and validated against the RMI's Standard Smelter List, and once validated, against the RMI's Responsible Minerals Assurance Process (“RMAP”) to determine compliance status.

The Company reviews responses to the survey for red flags in order to identify areas of potential risk such as incomplete responses, insufficient due diligence or potentially higher risk sourcing based upon criteria internally defined.

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

Results of the supply chain assessment are reported to the Steering Committee which is responsible for monitoring any actual or potential risks identified in the supply chain and reporting findings to the Company's Executive Vice President and Chief Financial Officer.

The Company has a risk mitigation plan to manage its non-conformant suppliers towards conformity with the Company's Conflict Mineral policy. GSM is responsible for taking appropriate actions up to and including suspension or termination of the Company's relationship with non-conformant suppliers. The Company does not knowingly engage new suppliers who are not in compliance with the Company's Conflict Mineral policy.

The Company supports the RMI's RMAP which audits smelters' and refiners' due diligence activities. The data on which the Company relies for certain statements in this report is obtained through the Company's membership (member "SBDI") in the RMI, using the reasonable country of origin inquiry report for the Company, or based upon the information publicly available on the RMI's website.

The Company's new product introduction process includes a step to ensure information on the presence of 3TG minerals in new products is provided to the Working Group for integration into the Company's due diligence procedures. The Company has also revised its new product specifications to ensure that the use of 3TG is limited solely to the product's functionality.

The Company also integrates new acquisitions into its due diligence processes described herein.

OECD Step 4: Carry Out Independent Third Party Audit of Smelter/Refiner's Due Diligence Practices

The Company supports the RMAP's efforts to audit the due diligence practices of the smelters and refiners, through its active membership in the RMI. The Company utilizes information on the RMI's website (www.responsiblemineralsinitiative.org) to determine which smelters and refiners are RMAP conformant.

OECD Step 5: Report Annually on Supply Chain Due Diligence

This report is the Company’s annual report on its due diligence, is filed along with Form SD with the Securities and Exchange Commission, and is publicly available on the Company’s website (www.stanleyblackanddecker.com/investors) under the Financial Information section.

2.2    Due Diligence Performed

The Company performed the following due diligence for the reporting period:

Identified suppliers of components and/or raw materials which were most likely to contain 3TG minerals and surveyed those suppliers using a third-party compliance tool that utilizes the latest published CMRT. Those suppliers were engaged through direct electronic communication from the Vice President of GSM.
Identified suppliers providing 3TG minerals from the DRC or adjoining countries and compiled an aggregate list of smelters and refiners identified by those suppliers.
Utilized a third-party compliance tool to validate those smelters and refiners against the RMI list.
Compared those validated smelters and refiners against those identified by the RMI’s RMAP as RMAP conformant or RMAP active and for those that are RMAP conformant, against the RMI's RCOI Data Document to determine country of origin for the 3TG minerals processed by those smelters and refiners.
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Utilized a third-party compliance tool to identify non-responding suppliers and provide reports to GSM for follow-up, including direct phone call(s) from GSM supplier owner and/or Conflict Minerals Working Group member, as well as periodic pulsing calls between GSM and Conflict Minerals Working Group members to update on response status.
Reported status of due diligence progress, including identification of red flag suppliers, to the Company's Steering Committee and to the Company's Executive Vice President and Chief Financial Officer.
Supported the RMAP through maintenance of an active membership in the RMI.

3.    Due Diligence Results

The Company received responses from 90% of its suppliers surveyed, representing 94% of the supplier spend surveyed. The Company’s suppliers are generally several tiers away from the origin of and smelters of their raw materials, and are therefore faced with similar challenges in performing their due diligence. In some instances, the information provided by the Company's suppliers is incomplete or not verified, and the Company is therefore unable to verify with certainty the source and chain of custody of all the 3TG minerals in the Company's supply chain.

The Company identified 342 smelters and refiners, as reported by the Company's suppliers, as potentially having processed the 3TG minerals contained in the Company's products for the reporting period. Some of the Company's suppliers responded at a company-level rather than product-level; therefore, there may be more smelters and refiners included in the Company's results than those that actually processed the 3TG minerals contained in the Company's products. The Company has only included in its results those smelters and refiners that have been validated as smelters and refiners appearing on the RMI Standard Smelter List as of May 5, 2023. Other processing facilities were reported in the Company's supply chain; however, are not included in its results, as they have not yet been validated by the RMI. The identified smelters and refiners are further broken out as follows:
Smelters and RefinersGoldTantalumTinTungstenTotal
Number of RMI validated175348350342
Number of RMAP conformant*100326334229
% RMAP conformant57%94%76%68%67%
*Includes 8 smelters and refiners that are active in the RMAP but have not yet completed the program as of May 5, 2023.

The following tables list smelters and refiners identified by the Company's suppliers' survey responses.

Table 1. RMAP Conformant Smelters and Refiners

The following table lists smelters and refiners identified by the Company's suppliers' survey responses that have been validated as conformant according to the RMAP as of May 5, 2023.
MineralSmelter or Refiner Facility NameRMI Smelter IdentificationFacility Location
GoldL'Orfebre S.A.CID002762Andorra
GoldWestern Australian Mint (T/a The Perth Mint)CID002030Australia
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHCID002779Austria
GoldUmicore S.A. Business Unit Precious Metals RefiningCID001980Belgium
GoldAngloGold Ashanti Corrego do Sitio MineracaoCID000058Brazil
GoldAsahi Refining Canada Ltd.CID000924Canada
GoldCCR Refinery - Glencore Canada CorporationCID000185Canada
GoldRoyal Canadian MintCID001534Canada
GoldPlanta Recuperadora de Metales SpACID002919Chile
GoldGold Refinery of Zijin Mining Group Co., Ltd.CID002243China
GoldHeraeus Metals Hong Kong Ltd.CID000707China
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CID000801China
GoldJiangxi Copper Co., Ltd.CID000855China
GoldMetalor Technologies (Hong Kong) Ltd.CID001149China
GoldMetalor Technologies (Suzhou) Ltd.CID001147China
GoldShandong Gold Smelting Co., Ltd.CID001916China
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CID001622China
GoldSichuan Tianze Precious Metals Co., Ltd.CID001736China
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCID002224China
GoldGold by Gold ColombiaCID003641Colombia
GoldSancus ZFS (L’Orfebre, SA)CID003529Colombia
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MineralSmelter or Refiner Facility NameRMI Smelter IdentificationFacility Location
GoldSAFINA A.S.CID002290Czechia
GoldSAAMPCID002761France
GoldAgosi AGCID000035Germany
GoldAurubis AGCID000113Germany
GoldC. Hafner GmbH + Co. KGCID000176Germany
GoldHeimerle + Meule GmbHCID000694Germany
GoldHeraeus Germany GmbH Co. KGCID000711Germany
GoldWIELAND Edelmetalle GmbHCID002778Germany
GoldBangalore RefineryCID002863India
GoldMMTC-PAMP India Pvt., Ltd.CID002509India
GoldPT Aneka Tambang (Persero) TbkCID001397Indonesia
GoldChimet S.p.A.CID000233Italy
GoldItalpreziosiCID002765Italy
GoldT.C.A S.p.ACID002580Italy
GoldAida Chemical Industries Co., Ltd.CID000019Japan
GoldAsahi Pretec Corp.CID000082Japan
GoldAsaka Riken Co., Ltd.CID000090Japan
GoldChugai MiningCID000264Japan
GoldDowaCID000401Japan
GoldEco-System Recycling Co., Ltd. East PlantCID000425Japan
GoldEco-System Recycling Co., Ltd. North PlantCID003424Japan
GoldEco-System Recycling Co., Ltd. West PlantCID003425Japan
GoldIshifuku Metal Industry Co., Ltd.CID000807Japan
GoldJapan MintCID000823Japan
GoldJX Nippon Mining & Metals Co., Ltd.CID000937Japan
GoldKojima Chemicals Co., Ltd.CID000981Japan
GoldMatsuda Sangyo Co., Ltd.CID001119Japan
GoldMitsubishi Materials CorporationCID001188Japan
GoldMitsui Mining and Smelting Co., Ltd.CID001193Japan
GoldNihon Material Co., Ltd.CID001259Japan
GoldOhura Precious Metal Industry Co., Ltd.CID001325Japan
GoldSumitomo Metal Mining Co., Ltd.CID001798Japan
GoldTanaka Kikinzoku Kogyo K.K.CID001875Japan
GoldTokuriki Honten Co., Ltd.CID001938Japan
GoldYamakin Co., Ltd.CID002100Japan
GoldYokohama Metal Co., Ltd.CID002129Japan
GoldKazzincCID000957Kazakhstan
GoldTOO Tau-Ken-AltynCID002615Kazakhstan
GoldDSC (Do Sung Corporation)CID000359Korea, Republic of
GoldKorea Zinc Co., Ltd.CID002605Korea, Republic of
GoldLS-NIKKO Copper Inc.CID001078Korea, Republic of
GoldLT Metal Ltd.CID000689Korea, Republic of
GoldNH Recytech CompanyCID003189Korea, Republic of
GoldSungEel HiMetal Co., Ltd.CID002918Korea, Republic of
GoldTorecomCID001955Korea, Republic of
GoldMetalurgica Met-Mex Penoles S.A. De C.V.CID001161Mexico
GoldREMONDIS PMR B.V.CID002582Netherlands
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)CID000128Philippines
GoldKGHM Polska Miedz Spolka AkcyjnaCID002511Poland
GoldMetalor Technologies (Singapore) Pte., Ltd.CID001152Singapore
GoldMetal Concentrators SA (Pty) Ltd.CID003575South Africa
GoldRand Refinery (Pty) Ltd.CID001512South Africa
GoldSEMPSA Joyeria Plateria S.A.CID001585Spain
GoldBoliden ABCID000157Sweden
GoldArgor-Heraeus S.A.CID000077Switzerland
GoldMetalor Technologies S.A.CID001153Switzerland
GoldMKS PAMP SACID001352Switzerland
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MineralSmelter or Refiner Facility NameRMI Smelter IdentificationFacility Location
GoldPX Precinox S.A.CID001498Switzerland
GoldValcambi S.A.CID002003Switzerland
GoldSolar Applied Materials Technology Corp.CID001761Taiwan
GoldIstanbul Gold RefineryCID000814Turkey
GoldNadir Metal Rafineri San. Ve Tic. A.S.CID001220Turkey
GoldAl Etihad Gold Refinery DMCCCID002560United Arab Emirates
GoldEmirates Gold DMCCCID002561United Arab Emirates
GoldAbington Reldan Metals, LLCCID002708United States of America
GoldAdvanced Chemical CompanyCID000015United States of America
GoldAsahi Refining USA Inc.CID000920United States of America
GoldGeib Refining CorporationCID002459United States of America
GoldKennecott Utah Copper LLCCID000969United States of America
GoldMaterionCID001113United States of America
GoldMetalor USA Refining CorporationCID001157United States of America
GoldUnited Precious Metal Refining, Inc.CID001993United States of America
GoldAlmalyk Mining and Metallurgical Complex (AMMC)CID000041Uzbekistan
GoldNavoi Mining and Metallurgical CombinatCID001236Uzbekistan
TantalumAMG BrasilCID001076Brazil
TantalumMineracao Taboca S.A.CID001175Brazil
TantalumResind Industria e Comercio Ltda.CID002707Brazil
TantalumF&X Electro-Materials Ltd.CID000460China
TantalumFIR Metals & Resource Ltd.CID002505China
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CID002492China
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CID002512China
TantalumJiangxi Tuohong New Raw MaterialCID002842China
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CID000914China
TantalumJiujiang Tanbre Co., Ltd.CID000917China
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CID002506China
TantalumNingxia Orient Tantalum Industry Co., Ltd.CID001277China
TantalumRFH Yancheng Jinye New Material Technology Co., Ltd.CID003583China
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDCID000616China
TantalumXinXing HaoRong Electronic Material Co., Ltd.CID002508China
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CID001522China
TantalumNPM Silmet ASCID001200Estonia
TantalumTANIOBIS GmbHCID002545Germany
TantalumTANIOBIS Smelting GmbH & Co. KGCID002550Germany
TantalumMetallurgical Products India Pvt., Ltd.CID001163India
TantalumGlobal Advanced Metals AizuCID002558Japan
TantalumMitsui Mining and Smelting Co., Ltd.CID001192Japan
TantalumTaki Chemical Co., Ltd.CID001869Japan
TantalumTANIOBIS Japan Co., Ltd.CID002549Japan
TantalumUlba Metallurgical Plant JSCCID001969Kazakhstan
TantalumKEMET de MexicoCID002539Mexico
TantalumTANIOBIS Co., Ltd.CID002544Thailand
TantalumD Block Metals, LLCCID002504United States of America
TantalumGlobal Advanced Metals BoyertownCID002557United States of America
TantalumMaterion Newton Inc.CID002548United States of America
TantalumQuantumCleanCID001508United States of America
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MineralSmelter or Refiner Facility NameRMI Smelter IdentificationFacility Location
TantalumTelex MetalsCID001891United States of America
TinAurubis BeerseCID002773Belgium
TinEM VintoCID000438Bolivia
TinOperaciones Metalurgicas S.A.CID001337Bolivia
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaCID003486Brazil
TinEstanho de Rondonia S.A.CID000448Brazil
TinFabrica Auricchio Industria e Comercio Ltda.CID003582Brazil
TinMagnu's Minerais Metais e Ligas Ltda.CID002468Brazil
TinMineracao Taboca S.A.CID001173Brazil
TinResind Industria e Comercio Ltda.CID002706Brazil
TinWhite Solder Metalurgia e Mineracao Ltda.CID002036Brazil
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CID000228China
TinChifeng Dajingzi Tin Industry Co., Ltd.CID003190China
TinChina Tin Group Co., Ltd.CID001070China
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CID000538China
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CID003116China
TinJiangxi New Nanshan Technology Ltd.CID001231China
TinTin Smelting Branch of Yunnan Tin Co., Ltd.CID002180China
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CID002158China
TinCV Ayi JayaCID002570Indonesia
TinCV Venus Inti PerkasaCID002455Indonesia
TinPT Aries Kencana SejahteraCID000309Indonesia
TinPT Artha Cipta LanggengCID001399Indonesia
TinPT ATD Makmur Mandiri JayaCID002503Indonesia
TinPT Babel Inti PerkasaCID001402Indonesia
TinPT Babel Surya Alam LestariCID001406Indonesia
TinPT Bangka Prima TinCID002776Indonesia
TinPT Bangka SerumpunCID003205Indonesia
TinPT Bukit TimahCID001428Indonesia
TinPT Cipta Persada MuliaCID002696Indonesia
TinPT Menara Cipta MuliaCID002835Indonesia
TinPT Mitra Stania PrimaCID001453Indonesia
TinPT Mitra Sukses GlobalindoCID003449Indonesia
TinPT Premium Tin IndonesiaCID000313Indonesia
TinPT Prima Timah UtamaCID001458Indonesia
TinPT Putera Sarana Shakti (PT PSS)CID003868Indonesia
TinPT Rajawali Rimba PerkasaCID003381Indonesia
TinPT Rajehan AriqCID002593Indonesia
TinPT Refined Bangka TinCID001460Indonesia
TinPT Sariwiguna BinasentosaCID001463Indonesia
TinPT Stanindo Inti PerkasaCID001468Indonesia
TinPT Sukses Inti MakmurCID002816Indonesia
TinPT Timah Tbk KundurCID001477Indonesia
TinPT Timah Tbk MentokCID001482Indonesia
TinPT Tommy UtamaCID001493Indonesia
TinDowaCID000402Japan
TinMitsubishi Materials CorporationCID001191Japan
TinMalaysia Smelting Corporation (MSC)CID001105Malaysia
TinDS MyanmarCID003831Myanmar
TinMinsurCID001182Peru
TinO.M. Manufacturing Philippines, Inc.CID002517Philippines
TinFenix MetalsCID000468Poland
TinLuna Smelter, Ltd.CID003387Rwanda
TinAurubis BerangoCID002774Spain
TinCRM SynergiesCID003524Spain
TinRui Da HungCID001539Taiwan
TinO.M. Manufacturing (Thailand) Co., Ltd.CID001314Thailand
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MineralSmelter or Refiner Facility NameRMI Smelter IdentificationFacility Location
TinThaisarcoCID001898Thailand
TinAlphaCID000292United States of America
TinMetallic Resources, Inc.CID001142United States of America
TinTin Technology & RefiningCID003325United States of America
TungstenWolfram Bergbau und Hutten AGCID002044Austria
TungstenCronimet Brasil LtdaCID003468Brazil
TungstenChina Molybdenum Tungsten Co., Ltd.CID002641China
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CID000258China
TungstenFujian Xinlu Tungsten Co., Ltd.CID003609China
TungstenGanzhou Haichuang Tungsten Co., Ltd.CID002645China
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CID000875China
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CID002315China
TungstenGanzhou Seadragon W & Mo Co., Ltd.CID002494China
TungstenGuangdong Xianglu Tungsten Co., Ltd.CID000218China
TungstenHubei Green Tungsten Co., Ltd.CID003417China
TungstenHunan Chenzhou Mining Co., Ltd.CID000766China
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchCID002513China
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CID002551China
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CID002321China
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CID002318China
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CID002317China
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CID002316China
TungstenMalipo Haiyu Tungsten Co., Ltd.CID002319China
TungstenXiamen Tungsten (H.C.) Co., Ltd.CID002320China
TungstenXiamen Tungsten Co., Ltd.CID002082China
TungstenH.C. Starck Tungsten GmbHCID002541Germany
TungstenTANIOBIS Smelting GmbH & Co. KGCID002542Germany
TungstenA.L.M.T. Corp.CID000004Japan
TungstenJapan New Metals Co., Ltd.CID000825Japan
TungstenPhilippine Chuangxin Industrial Co., Inc.CID002827Philippines
TungstenLianyou Metals Co., Ltd.CID003407Taiwan
TungstenGlobal Tungsten & Powders LLCCID000568United States of America
TungstenKennametal FallonCID000966United States of America
TungstenKennametal HuntsvilleCID000105United States of America
TungstenNiagara Refining LLCCID002589United States of America
TungstenAsia Tungsten Products Vietnam Ltd.CID002502Vietnam
TungstenMasan High-Tech MaterialsCID002543Vietnam
TungstenTungsten Vietnam Joint Stock CompanyCID003993Vietnam

The Company requested both country of origin information and mine or location of origin information from its suppliers for purposes of determining the source and chain of custody of the 3TG minerals in the Company's supply chain. The Company relied on country of origin information provided by its suppliers (if known), as well as by the RMI's RMAP and RCOI Data Document. Some of the Company's suppliers provided mine or location of origin information, but many were unable to obtain such information for their 3TG minerals.

RMAP conformant gold smelters and refiners included in Table 1 have disclosed mineral sources as originating from recycled and scrap sources and/or from the following countries: Algeria, Andorra, Antigua and Barbuda, Argentina, Australia, Austria, Azerbaijan, Bahamas, Bangladesh, Barbados, Belarus, Belgium, Benin, Bolivia, Bosnia and Herzegovina, Botswana, Brazil, Bulgaria, Burkina Faso, Cambodia, Canada, Cayman Islands, Chile, China, Colombia, Costa Rica, Cote d'Ivoire, Croatia, Curacao, Cyprus, Czechia, Denmark, Dominican Republic, DRC and adjoining countries, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Fiji, Finland, France, Georgia, Germany, Ghana, Greece, Grenada, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, Iceland, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Kuwait,
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Kyrgyzstan, Lao People's Democratic Republic, Latvia, Lebanon, Liberia, Liechtenstein, Lithuania, Luxembourg, Macau, Malaysia, Mali, Malta, Mauritania, Mauritius, Mexico, Monaco, Mongolia, Morocco, Mozambique, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Norway, Oman, Pakistan, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Puerto Rico, Republic of Korea, Romania, Russian Federation, Saint Kitts and Nevis, Saudi Arabia, Senegal, Serbia, Singapore, Sint Maarten, Slovakia, Slovenia, South Africa, Spain, St Vincent and Grenadines, Sudan, Suriname, Swaziland, Sweden, Switzerland, Taiwan, Tajikistan, Thailand, Trinidad and Tobago, Tunisia, Turkey, Turks and Caicos, Ukraine, United Arab Emirates, United Kingdom, United States of America, Uruguay, Uzbekistan, Vietnam and Zimbabwe.

RMAP conformant tantalum, tin and tungsten smelters and refiners included in Table 1 have disclosed mineral sources as originating from recycled and scrap sources and/or from the following countries: Argentina, Australia, Austria, Bahrain, Bangladesh, Belarus, Belgium, Bolivia, Brazil, Bulgaria, Canada, Chile, China, Colombia, Croatia, Czechia, Denmark, DRC and adjoining countries, Egypt, El Salvador, Estonia, Ethiopia, Finland, France, Germany, Ghana, Greece, Guinea, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Kenya, Kyrgyzstan, Kuwait, Lao People's Democratic Republic, Latvia, Lebanon, Liberia, Lithuania, Malaysia, Malta, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Puerto Rico, Republic of Korea, Romania, Russian Federation, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States of America, Uruguay, Venezuela, Vietnam, Yemen and Zimbabwe.

Mineral sources are disclosed for all of the RMAP conformant smelters and refiners as of March 31, 2023. Twenty one of the smelters and refiners discussed above have disclosed mineral sources as originating from the DRC and adjoining countries.

Table 2. RMAP Participating Smelters and Refiners

The following table lists smelters and refiners identified by the Company's suppliers' survey responses that have agreed to participate in the RMAP but have not yet completed the program as of May 5, 2023.
MineralSmelter or Refiner Facility NameRMI Smelter IdentificationFacility Location
GoldC.I Metales Procesados Industriales SASCID003421Colombia
GoldWEEEREFININGCID003615France
GoldAugmont Enterprises Private LimitedCID003461India
GoldGGC Gujrat Gold Centre Pvt. Ltd.CID002852India
GoldAlexy MetalsCID003500United States of America
TinSuper LigasCID002756Brazil
TinPT Belitung Industri SejahteraCID001421Indonesia
TinPT Timah NusantaraCID001486Indonesia

Mineral sources for RMAP participating smelters and refiners are not available.

Table 3. Smelters and Refiners with No Known RMAP Participation
The following table lists smelters and refiners identified by the Company's suppliers' survey responses that have not been validated as conformant according to the RMAP as of May 5, 2023.
MineralSmelter or Refiner Facility NameRMI Smelter IdentificationFacility Location
GoldABC Refinery Pty Ltd.CID002920Australia
GoldIndustrial Refining CompanyCID002587Belgium
GoldMarsam MetalsCID002606Brazil
GoldDaye Non-Ferrous Metals Mining Ltd.CID000343China
GoldDongwu Gold GroupCID003663China
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCID001909China
GoldGuangdong Jinding Gold LimitedCID002312China
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CID000651China
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CID000671China
GoldHunan Chenzhou Mining Co., Ltd.CID000767China
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CID000773China
GoldLingbao Gold Co., Ltd.CID001056China
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CID001058China
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CID001093China
15


MineralSmelter or Refiner Facility NameRMI Smelter IdentificationFacility Location
GoldPenglai Penggang Gold Industry Co., Ltd.CID001362China
GoldRefinery of Seemine Gold Co., Ltd.CID000522China
GoldShandong Humon Smelting Co., Ltd.CID002525China
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CID001619China
GoldShenzhen CuiLu Gold Co., Ltd.CID002750China
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CID002527China
GoldTongling Nonferrous Metals Group Co., Ltd.CID001947China
GoldYunnan Copper Industry Co., Ltd.CID000197China
GoldDegussa Sonne / Mond Goldhandel GmbHCID002867Germany
GoldGold Coast RefineryCID003186Ghana
GoldCGR Metalloys Pvt Ltd.CID003382India
GoldEmerald Jewel Industry India Limited (Unit 1)CID003487India
GoldEmerald Jewel Industry India Limited (Unit 2)CID003488India
GoldEmerald Jewel Industry India Limited (Unit 3)CID003489India
GoldEmerald Jewel Industry India Limited (Unit 4)CID003490India
GoldJALAN & CompanyCID002893India
GoldKundan Care Products Ltd.CID003463India
GoldMD OverseasCID003548India
GoldSai RefineryCID002853India
GoldShirpur Gold Refinery Ltd.CID002588India
GoldSovereign MetalsCID003383India
Gold8853 S.p.A.CID002763Italy
GoldSafimet S.p.ACID002973Italy
GoldKazakhmys Smelting LLCCID000956Kazakhstan
GoldHwaSeong CJ CO., LTD.CID000778Korea, Republic of
GoldSamduck Precious MetalsCID001555Korea, Republic of
GoldSamwon Metals Corp.CID001562Korea, Republic of
GoldKyrgyzaltyn JSCCID001029Kyrgyzstan
GoldState Research Institute Center for Physical Sciences and TechnologyCID003153Lithuania
GoldModeltech Sdn BhdCID002857Malaysia
GoldSellem Industries Ltd.CID003540Mauritania
GoldCaridadCID000180Mexico
GoldMorris and WatsonCID002282New Zealand
GoldK.A. RasmussenCID003497Norway
GoldAlbino Mountinho Lda.CID002760Portugal
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantCID000927Russian Federation
GoldJSC Novosibirsk RefineryCID000493Russian Federation
GoldJSC UralelectromedCID000929Russian Federation
GoldKyshtym Copper-Electrolytic Plant ZAOCID002865Russian Federation
GoldMoscow Special Alloys Processing PlantCID001204Russian Federation
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)CID001326Russian Federation
GoldPrioksky Plant of Non-Ferrous MetalsCID001386Russian Federation
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsCID001756Russian Federation
GoldL'azurde Company For JewelryCID001032Saudi Arabia
GoldAU Traders and RefinersCID002850South Africa
GoldSudan Gold RefineryCID002567Sudan
GoldCendres + Metaux S.A.CID000189Switzerland
GoldSingway Technology Co., Ltd.CID002516Taiwan
GoldSuper Dragon Technology Co., Ltd.CID001810Taiwan
GoldUmicore Precious Metals ThailandCID002314Thailand
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.CID000103Turkey
GoldAfrican Gold RefineryCID003185Uganda
GoldDijllah Gold Refinery FZCCID003348United Arab Emirates
GoldFujairah Gold FZCCID002584United Arab Emirates
GoldInternational Precious Metal RefinersCID002562United Arab Emirates
GoldKaloti Precious MetalsCID002563United Arab Emirates
GoldMetallix Refining Inc.CID003557United States of America
16


MineralSmelter or Refiner Facility NameRMI Smelter IdentificationFacility Location
GoldPease & CurrenCID002872United States of America
GoldQG Refining, LLCCID003324United States of America
GoldSabin Metal Corp.CID001546United States of America
GoldFidelity Printers and Refiners Ltd.CID002515Zimbabwe
Tantalum5D Production OUCID003926Estonia
TantalumSolikamsk Magnesium Works OAOCID001769Russian Federation
TinMelt Metais e Ligas S.A.CID002500Brazil
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CID003356China
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CID003410China
TinGejiu Kai Meng Industry and Trade LLCCID000942China
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CID001908China
TinGejiu Zili Mining And Metallurgy Co., Ltd.CID000555China
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CID003397China
TinPrecious Minerals and Smelting LimitedCID003409India
TinPT Bangka Tin IndustryCID001419Indonesia
TinPT Panca Mega PersadaCID001457Indonesia
TinPT Tinindo Inter NusaCID001490Indonesia
TinPT Tirus Putra MandiriCID002478Indonesia
TinModeltech Sdn BhdCID002858Malaysia
TinPongpipat Company LimitedCID003208Myanmar
TinNovosibirsk Tin CombineCID001305Russian Federation
TinAn Vinh Joint Stock Mineral Processing CompanyCID002703Vietnam
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyCID002572Vietnam
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyCID002573Vietnam
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyCID002574Vietnam
TinVQB Mineral and Trading Group JSCCID002015Vietnam
TungstenACL Metais EireliCID002833Brazil
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.CID003427Brazil
TungstenCNMC (Guangxi) PGMA Co., Ltd.CID000281China
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CID002313China
TungstenYUDU ANSHENG TUNGSTEN CO., LTD.CID003662China
TungstenDONGKUK INDUSTRIES CO., LTD.CID004060Korea, Republic of
TungstenHANNAE FOR T Co., Ltd.CID003978Korea, Republic of
TungstenArtek LLCCID003553Russian Federation
TungstenHydrometallurg, JSCCID002649Russian Federation
TungstenJSC "Kirovgrad Hard Alloys Plant"CID003408Russian Federation
TungstenLLC VostokCID003643Russian Federation
TungstenMoliren Ltd.CID002845Russian Federation
TungstenNPP Tyazhmetprom LLCCID003416Russian Federation
TungstenOOO “Technolom” 1CID003614Russian Federation
TungstenOOO “Technolom” 2CID003612Russian Federation
TungstenUnecha Refractory metals plantCID002724Russian Federation

4.    Steps to be Taken to Mitigate Risk

The Company intends to take the following steps to mitigate the risk that 3TG minerals contained in the Company’s products could benefit armed groups in the DRC or adjoining countries:

Continue to encourage the Company's suppliers to improve response rates and the content of responses, including names, country of origin and mine or location of origin. Continue to use and encourage the Company's suppliers to use the Conflict Minerals Resources Center and other publicly available tools from the RMI. Engage suppliers to request their smelters and refiners participate in the RMAP or other independent third party audit programs.
Continue to provide non-validated processing facilities to the RMI for validation and potential participation in the RMAP.
17


Continue to support the RMI’s efforts to support the responsible sourcing of minerals.
Encourage the Company's suppliers to consider alternative sources for the 3TG minerals.
Continue to integrate Conflict Minerals contractual language in the Company’s new or renewed supplier contracts.
Determine an appropriate course of action which may include, but is not limited to, the suspension or termination of the Company's relationship with a non-conformant supplier.
Avoid engaging with new suppliers who are not in compliance with the Company's Conflict Mineral policy.

The Company recognizes that due diligence is a dynamic process and requires on-going risk monitoring. After implementing these risk mitigation strategies, the Company will reassess the effectiveness of its risk management plan, and may adapt further strategies or refine existing strategies to ensure effective risk mitigation. Furthermore, future acquisitions will be integrated into the Company's due diligence processes.


FORWARD-LOOKING STATEMENTS

Certain statements contained herein constitute “forward-looking statements” as defined in the Private Securities Litigation Reform Act of 1995. Forward-looking statements are based on currently available information and involve factors that are subject to change, assumptions, risk and uncertainties that could cause actual results to differ materially. Examples of forward-looking statements include statements relating to the Company’s ability to effectively continue its due diligence efforts on the conflict minerals in its supply chain, engagement with the Company’s suppliers to comply with the Company’s supplier policies and due diligence processes and the Company’s ability to implement future due diligence processes effectively. Except as required by law, the Company undertakes no obligation to update or revise its forward-looking statements. Further information on factors that could cause actual results to differ materially from those expressed or implied in the forward-looking statements is disclosed from time to time in our other filings with the SEC.
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