EX-1.01 2 bax2024_formsdxex101.htm EX-1.01 Document
Exhibit 1.01
Baxter International Inc.
Conflict Minerals Report
For The Year Ended December 31, 2023


This Conflict Minerals Report for the year ended December 31, 2023 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (Rule 13p-1). Rule 13p-1 imposes certain reporting obligations on Securities and Exchange Commission (SEC) registrants whose manufactured products contain minerals specified in Rule 13p-1 that are necessary to the functionality or production of their products. These minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively 3TG) for the purposes of Rule 13p-1. These requirements apply to registrants regardless of the geographic origin of the 3TGs and whether or not they fund armed conflict.

Certain products manufactured by Baxter International Inc. and its consolidated subsidiaries (collectively, the Company, Baxter, we, our, or us, unless the context otherwise requires) are comprised of materials and components that contain 3TG that are necessary to the functionality and/or production of such product (see “Product Description” below). Due to the depth of its supply chain, the Company is far removed from the sources of ore from which these metals are produced and the smelters and refiners that process those ores. Additionally, the amount of information available globally on the traceability and sourcing of these ores is extremely limited, which is a situation that is not unique to the Company. As a result, the efforts undertaken by the Company to identify the countries of origin of those ores reflect the Company’s respective position in the supply chain and the challenge presented to it by the limited availability of information. The Company has taken steps to identify the applicable smelters and refiners of the 3TG in its supply chain and their respective source, but in general, the Company believes that these smelters and refiners are best situated to identify the sources and countries of origin of these metals. The efforts described herein were undertaken on the products manufactured by the Company (as described below) during the year ended December 31, 2023.

Product Description

The Company, through its subsidiaries, provides a broad portfolio of essential healthcare products, including acute and chronic dialysis therapies; sterile intravenous solutions; infusion systems and devices; parenteral nutrition therapies; inhaled anesthetics; generic injectable pharmaceuticals; surgical hemostat and sealant products; advanced surgical equipment; smart bed systems; patient monitoring and diagnostic technologies; and respiratory health devices.

For the year ended December 31, 2023, this Conflict Minerals Report covers products manufactured, directly or indirectly, by the Company in that year. Company products that are subject to disclosure under Rule 13p-1 include, but are not limited to: hemodialysis machines, monitors, infusion pumps, smart bed systems, patient monitoring and diagnostic technologies and respiratory heath devices. The table below provides examples of where 3TG may be present in the Company’s products:

MetalIndustry ApplicationsApplications in the Company Products
Tantalum
Refined from Columbite-tantalite (coltan)
Capacitors, resistorsTantalum Capacitors, Alloys
Tin
Refined from Cassiterite
Chemical solutions, capacitors, electrodes, Tin alloys, dioxide, electroplatingIntegrated circuits, pins, resistors, capacitors, printed circuit boards, and soldering
Tungsten
Refined from Wolframite
Tungsten Carbide, Alloy, light bulb, heating elements, and Tungsten Inert Gas WeldingElectrodes, welding
GoldElectrical wiring, connectors, contact, and gold platingContacts, pins, connectors, cable harness, wire harness, gold plating




Reasonable Country of Origin Inquiry (RCOI)

Direct suppliers of materials reasonably believed by the Company to contain 3TG were asked to provide answers to the Responsible Minerals Initiative’s (RMI) Conflict Mineral Reporting Template (CMRT) reflecting the Company’s position in the supply chain as described above. The RMI CMRT is generally regarded as the preferred reporting tool for 3TG content and sourcing information worldwide.

The Company, in conjunction with a third-party vendor, reviewed the CMRTs received for completeness and consistency of answers. Suppliers were asked to provide corrections and clarifications where needed. As a result, the Company believes that its RCOI process was reasonably designed and performed in good faith.

In 2023, the Company surveyed 200 significant suppliers, of which 70% responded. However, these responses reflect the supplier’s overall supply chain and do not specify whether the 3TG was used in materials supplied to the Company.

Due Diligence

Design of due diligence

The Company’s overall Conflict Minerals Program is designed to conform to the five-step framework of the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the relevant supplements on 3TG, as applicable to the Company’s circumstances and position in the supply chain as a “downstream” company with no direct influence on smelters and refiners. The Company designed its due diligence measures to conform in all material respects with the due diligence framework relevant to 3TGs provided by the OECD.

The large majority of the responses received provided data at the supplier company level or a division or segment level relative to the supplier, rather than at a level directly relating to a product supplied to us, or were otherwise unable to specify the smelters or refiners used for components supplied to us. We were therefore unable to determine whether the 3TG that these suppliers reported were contained in components or parts that the suppliers supplied to us or to validate that any of these smelters or refiners are actually in our supply chain.

Due diligence performed

Establish strong Company management systems

Conflict minerals policy

The Company’s position on 3TGs is publicly posted at https://www.baxter.com/policies-positions/conflict-minerals-policy-position-statement.

Internal team

In 2023, the internal Conflict Minerals Core Team (Core Team) consisted of representatives from the Company’s procurement, environmental compliance, and legal functions. The Core Team governs our conflict minerals compliance effort and is responsible for providing guidance and direction for the implementation of our Conflict Minerals Program.

We have also taken on other management systems that include the use of a third-party vendor. Through our vendor’s tool, we are able to collect and store supplier data and CMRTs, communicate with suppliers, and monitor certain risks in our supply chain. The use of these tools and services has allowed us to assist our suppliers in understanding our expectations and requirements and generally increase the rate of responses we have received from our suppliers to our survey requests.






Control systems and grievance mechanism

The Company's controls include a Code of Conduct (Code) that outlines expected behaviors for all employees, contractors, agents and third parties. This Code is publicly available on our website at https://www.baxter.com/our-story/our-governance/code-conduct. To this end, anyone can utilize our Ethics and Compliance Hotline as detailed in our Code to proactively report a violation of our Code or other policies, including our Conflict Minerals Policy and related program efforts.

Maintain records

We maintain company-wide document retention policies. These policies extend to the documentation accumulated in performing our due diligence procedures and provides for the maintenance of documentation for a period of up to 10 years depending on the type and nature of the document.

Supplier engagement

With respect to the OECD objective to strengthen engagement with suppliers, we have utilized the CMRT version 6.1 or higher and a third-party vendor’s web-based reporting tool for collecting conflict minerals declarations from our supply base. The use of these tools has helped us to assist our suppliers in understanding our expectations and requirements.

We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and related compliance efforts, as identified through our RCOI process, and our expectation that they assist us in complying with our efforts related to our Conflict Minerals Program. This includes obtaining information to support chain of custody of the 3TG identified in our products. We have provided suppliers access to our Conflict Minerals Policy through our website or upon request.

We continue to emphasize supplier education and training. To accomplish this, we utilize a third-party vendor’s learning management system and provide all in-scope suppliers access to the third-party vendor's conflict minerals training course. All suppliers are encouraged to complete all modules within this course and we generally monitor the status of their training activities.

Identify and assess risks in the supply chain

Due to the complexity of our products and the depth, breadth, and constant changes to our supply chain, it is difficult to identify sub-tier suppliers from our direct suppliers. We have relied on supplier responses to provide us with the information about the source of conflict minerals contained in the parts and components they supply to us.

Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to evolving industry practices, as appropriate.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. The basis of this understanding stems from smelter or refiner (SOR) information. Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assigned by the RMI a risk of high, medium or low based on three scoring criteria:
1.geographic proximity to the Democratic Republic of the Congo (DRC) or an adjoining country (the Covered Countries);
2.Responsible Minerals Assurance Process (RMAP) audit status; and
3.known or plausible evidence of unethical or conflict sourcing.

We also calculate overall supplier risk based on the risk ratings of the smelters declared by that supplier on their CMRT.




Additionally, we evaluate suppliers on the perceived strength of their programs (further identifying risk in the supply chain). Evaluating and tracking the strength of a supplier's program meets the OECD Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria (items A, E, G and H from the CMRT) used to evaluate the strength of the program are:

A. Have you established a conflict minerals sourcing policy?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Do you review due diligence information received from your suppliers against your company’s expectations?
H. Does your review process include corrective action management?

When suppliers meet or exceed the above criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weaker program.

As a member of the RMI (Member Company ID: 5456), we support engagement by the RMI with SOR(s) and the obtainment of information on country of mineral origin, transit and transportation routes used between mine and smelters and refiners. We also support the RMI’s RMAP, which includes an assessment of whether SORs have carried out all five steps of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas framework, as discussed above, for responsible supply chains of 3TG from the Covered Countries and contribute directly to the RMI’s RMAP, which uses an independent third-party audit to identify smelters and refiners that have systems in place to help assure sourcing of only conflict-free materials.

We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TG in our covered products, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable and as we are able.

Design and implement a strategy to respond to identified risks

We report our findings annually to the Core Team prior to the issuance of Form SD and this Conflict Minerals Report. We also report any significant due diligence findings to the Core Team as they arise. For example, if we find that we source 3TG in a manner that we believe directly or indirectly finances or benefits armed groups in the Covered Countries, Baxter will assess the supplier relationship and encourage the supplier in question to establish an alternative source of 3TG that does not support such conflict. We have found no instance where it was necessary to implement risk mitigation efforts as a result of a supplier’s response to our information request.

Based on the smelter or refiner risk criteria noted above, risk mitigation activities are initiated for facilities identified as being of highest concern to the supply chain as reported on a CMRT by any of the suppliers surveyed. Through our third-party vendor, submissions that include any of these high risk facilities 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 Baxter, and potentially escalating up to removal of these high risk smelters from their supply chain.

As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given performance objectives and reasonable implementation or remediation timeframes with the ultimate goal of progressive elimination of these risks from the supply chain. Furthermore, suppliers are guided to our third-party vendor’s learning management system to engage in educational materials on mitigating the risk of smelters or refiners in the supply chain.

As a member of the RMI, we work with upstream suppliers as the RMI provides in-region components of risk assessment and mitigation. Additionally, through this membership, we support the RMI’s efforts to monitor whether SOR(s) demonstrate significant and measurable improvement within six months from the adoption of their risk management plans and, as noted above, we support the RMI’s independent third party audits of the SOR’s due diligence practices through the RMAP.




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

We do not have a direct relationship with smelters and refiners and therefore do not perform or direct audits of these entities. However, as noted above, we support the independent third-party audits of the SOR’s due diligence practices through the RMI's RMAP.

Report on supply chain due diligence

This Conflict Minerals Report, which constitutes our annual report on our due diligence efforts, is available on our website at https://www.baxter.com/policies-positions/conflict-minerals-policy-position-statement.

Results of Due Diligence

Survey results

As described above, the Company actively surveys our supply chain and reviews the responses against criteria developed to determine whether further engagement is required. These criteria include: untimely responses, incomplete responses and inconsistencies within the data reported in the CMRT.

As of May 13, 2024, we received responses from 70% of surveyed suppliers for the 2023 year.

Efforts to determine mine or location of origin

Given that we do not have relationships with the ultimate smelters and refiners from which the 3TG in our products is sourced, we have determined that requesting our suppliers to complete the RMI Template and supporting the RMI programs and initiatives represent our good faith effort to determine the mines or locations of origin of 3TG in our supply chain.

Smelters and refiners

Of the suppliers surveyed, many completed the RMI template at the company, business unit or entity level and are unable to represent that 3TG from the processing facilities they listed had actually been included in components that they supplied to us. The quality of the responses that we received from our surveyed suppliers continues to be varied. Many of the responses provided by supplier via the CMRT included the names of facilities listed by the suppliers as smelters or refiners. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our third-party provider follows up on these, urging suppliers to resubmit the form and include smelter information. There are still suppliers that are unable to provide SORs used for the materials supplied to us.

Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 225 smelters that are deemed RMAP Conformant – this indicates our determination that these smelters or refiners are compliant with the RMAP assessment protocols.

As detailed above, risk mitigation activities were initiated on the suppliers submitting high risk entries in their CMRT, including certain smelters subject to U.S. or other relevant sanctions. These smelters or refiners, however, may not be present in the Baxter supply chain as these Baxter suppliers were only able to provide company-level CMRTs which do not directly link those smelters or refiners to the products they provide to Baxter. In addition, with respect to sanctioned smelters, the products that Baxter purchases from its suppliers would have been substantially transformed multiple times after any inputs of such sanctioned parties.

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 smelters or refiners that our third-party has not been able to validate. Appendix B includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals based on information provided by suppliers and the RMI.




Steps to Be Taken

We are committed to complying with the provisions of Rule 13p-1 and Form SD and expect to continue our Conflict Minerals Program and related due diligence. Our next steps may include, but are not limited to the following:
engage with suppliers to continue addressing their compliance requirements, including due diligence regarding sanctions, and direct them to training resources in an effort to increase the number of suppliers that utilize our third-party vendor’s learning management system, with a goal of increasing our response rate and improving the content of responses, thereby helping us to enhance our RCOI process and efforts to determine the processing facilities for, and country of origin of, our 3TG with the greatest specificity possible;
via our third-party vendor, increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program; and
via our third-party vendor, encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.

Forward-Looking Statements

This report includes "forward-looking statements," as defined in the Private Securities Litigation Reform Act of 1995, concerning the Company’s conflict mineral policies and related activities. These forward-looking statements provide current expectations of future events and are based on assumptions about many important factors, including the following, which could cause actual results to differ materially from those in the forward-looking statements: our ability to execute and complete strategic initiatives, asset dispositions, and other transactions, including the proposed separation of our Kidney Care business, our plans to simplify our manufacturing footprint and the timing for such transactions, the ability to satisfy any applicable conditions, and the expected proceeds, consideration, and benefits; the continuity, availability, and pricing of acceptable raw materials and component parts, our ability to pass some or all of these costs to our customers through price increases or otherwise, and the related continuity of our manufacturing and distribution and those of our suppliers; inability to create additional production capacity in a timely manner or the occurrence of other manufacturing, sterilization, or supply difficulties, including as a result of natural disaster, war, terrorism, global public health crises and epidemics/pandemics, regulatory actions, or otherwise; loss of key employees, the occurrence of labor disruptions (including as a result of labor disagreements under bargaining agreements or national trade union agreements or disputes with works councils), or the inability to attract, develop, retain, and engage employees; product quality or patient safety issues leading to product recalls, withdrawals, launch delays, warning letters, import bans, sanctions, seizures, litigation, or declining sales, including the focus on evaluating product portfolios for the potential presence or formation of nitrosamines; breaches, including by cyber-attack, data leakage, unauthorized access or theft, or failures of or vulnerabilities in, our information technology systems, or products; failures with respect to our quality, compliance, or ethics programs; global regulatory, trade, and tax policies, including with respect to climate change and other sustainability matters; and other risks identified in Baxter’s most recent filings on Form 10-K and Form 10-Q and other SEC filings, all of which are available on Baxter’s website. Baxter assumes no obligation, and expressly disclaims any obligation, to update or revise any of its forward-looking statements, whether as a result of new information or future events, unless otherwise required by the federal securities laws.









Appendix A:

The following smelters and refiners were reported by our suppliers as being in their supply chains.
MetalSmelter NameSmelter Facility Location
GoldJX Nippon Mining & Metals Co., Ltd.Japan
GoldMatsuda Sangyo Co., Ltd.Japan
GoldMetalor USA Refining CorporationUnited States Of America
GoldMitsubishi Materials CorporationJapan
GoldMitsui Mining and Smelting Co., Ltd.Japan
GoldNihon Material Co., Ltd.Japan
GoldRoyal Canadian MintCanada
GoldSumitomo Metal Mining Co., Ltd.Japan
GoldTokuriki Honten Co., Ltd.Japan
GoldAsahi Pretec Corp.Japan
GoldDowaJapan
GoldEco-System Recycling Co., Ltd. East PlantJapan
GoldHeraeus Metals Hong Kong Ltd.China
GoldIshifuku Metal Industry Co., Ltd.Japan
GoldKojima Chemicals Co., Ltd.Japan
GoldSolar Applied Materials Technology Corp.Taiwan, Province Of China
GoldTanaka Kikinzoku Kogyo K.K.Japan
GoldAdvanced Chemical CompanyUnited States Of America
GoldAlmalyk Mining and Metallurgical Complex (AMMC)Uzbekistan
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazil
GoldArgor-Heraeus S.A.Switzerland
GoldAsaka Riken Co., Ltd.Japan
GoldAurubis AGGermany
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)Philippines
GoldBoliden ABSweden
GoldC. Hafner GmbH + Co. KGGermany
GoldCCR Refinery - Glencore Canada CorporationCanada
GoldChimet S.p.A.Italy
GoldChugai MiningJapan
GoldDSC (Do Sung Corporation)Korea, Republic Of
GoldLT Metal Ltd.Korea, Republic Of
GoldHeimerle + Meule GmbHGermany
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.China
GoldIstanbul Gold RefineryTurkey
GoldJapan MintJapan
GoldJiangxi Copper Co., Ltd.China
GoldAsahi Refining USA Inc.United States Of America



GoldAsahi Refining Canada Ltd.Canada
GoldKazzincKazakhstan
GoldKennecott Utah Copper LLCUnited States Of America
GoldLS-NIKKO Copper Inc.Korea, Republic Of
GoldMaterionUnited States Of America
GoldMetalor Technologies (Suzhou) Ltd.China
GoldMetalor Technologies (Hong Kong) Ltd.China
GoldMetalor Technologies (Singapore) Pte., Ltd.Singapore
GoldMetalor Technologies S.A.Switzerland
GoldMetalurgica Met-Mex Penoles S.A. De C.V.Mexico
GoldNadir Metal Rafineri San. Ve Tic. A.S.Turkey
GoldOhura Precious Metal Industry Co., Ltd.Japan
GoldMKS PAMP SASwitzerland
GoldPT Aneka Tambang (Persero) TbkIndonesia
GoldPX Precinox S.A.Switzerland
GoldRand Refinery (Pty) Ltd.South Africa
GoldSEMPSA Joyeria Plateria S.A.Spain
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.China
GoldSichuan Tianze Precious Metals Co., Ltd.China
GoldShandong Gold Smelting Co., Ltd.China
GoldTorecomKorea, Republic Of
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgium
GoldUnited Precious Metal Refining, Inc.United States Of America
GoldValcambi S.A.Switzerland
GoldYamakin Co., Ltd.Japan
GoldYokohama Metal Co., Ltd.Japan
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChina
GoldGold Refinery of Zijin Mining Group Co., Ltd.China
GoldMMTC-PAMP India Pvt., Ltd.India
GoldKGHM Polska Miedz Spolka AkcyjnaPoland
GoldEmirates Gold DMCCUnited Arab Emirates
GoldT.C.A S.p.AItaly
GoldREMONDIS PMR B.V.Netherlands
GoldKorea Zinc Co., Ltd.Korea, Republic Of
GoldSAAMPFrance
GoldL'Orfebre S.A.Andorra
GoldItalpreziosiItaly
GoldWIELAND Edelmetalle GmbHGermany
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustria
GoldBangalore RefineryIndia
GoldSungEel HiMetal Co., Ltd.Korea, Republic Of



GoldPlanta Recuperadora de Metales SpAChile
GoldAida Chemical Industries Co., Ltd.Japan
GoldAgosi AGGermany
GoldCendres + Metaux S.A.Switzerland
GoldJSC Novosibirsk RefineryRussian Federation
GoldHeraeus Germany GmbH Co. KGGermany
GoldJSC UralelectromedRussian Federation
GoldKyrgyzaltyn JSCKyrgyzstan
GoldMoscow Special Alloys Processing PlantRussian Federation
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)Russian Federation
GoldPrioksky Plant of Non-Ferrous MetalsRussian Federation
GoldSamduck Precious MetalsKorea, Republic Of
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian Federation
GoldWestern Australian Mint (T/a The Perth Mint)Australia
GoldUmicore Precious Metals ThailandThailand
GoldSingway Technology Co., Ltd.Taiwan, Province Of China
GoldAl Etihad Gold Refinery DMCCUnited Arab Emirates
GoldMarsam MetalsBrazil
GoldAU Traders and RefinersSouth Africa
GoldSafimet S.p.AItaly
GoldNH Recytech CompanyKorea, Republic Of
GoldHangzhou Fuchunjiang Smelting Co., Ltd.China
GoldHunan Chenzhou Mining Co., Ltd.China
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.Turkey
GoldCaridadMexico
GoldYunnan Copper Industry Co., Ltd.China
GoldDaye Non-Ferrous Metals Mining Ltd.China
GoldRefinery of Seemine Gold Co., Ltd.China
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.China
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.China
GoldHwaSeong CJ CO., LTD.Korea, Republic Of
GoldKazakhmys Smelting LLCKazakhstan
GoldL'azurde Company For JewelrySaudi Arabia
GoldLingbao Gold Co., Ltd.China
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.China
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.China
GoldNavoi Mining and Metallurgical CombinatUzbekistan
GoldPenglai Penggang Gold Industry Co., Ltd.China
GoldSabin Metal Corp.United States Of America
GoldSamwon Metals Corp.Korea, Republic Of
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.China



GoldSuper Dragon Technology Co., Ltd.Taiwan, Province Of China
GoldGreat Wall Precious Metals Co., Ltd. of CBPMChina
GoldTongling Nonferrous Metals Group Co., Ltd.China
GoldMorris and WatsonNew Zealand
GoldSAFINA A.S.Czechia
GoldGuangdong Jinding Gold LimitedChina
GoldShandong Humon Smelting Co., Ltd.China
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.China
GoldInternational Precious Metal RefinersUnited Arab Emirates
GoldKaloti Precious MetalsUnited Arab Emirates
GoldSudan Gold RefinerySudan
GoldFujairah Gold FZCUnited Arab Emirates
GoldIndustrial Refining CompanyBelgium
GoldShirpur Gold Refinery Ltd.India
GoldTOO Tau-Ken-AltynKazakhstan
GoldAbington Reldan Metals, LLCUnited States Of America
GoldShenzhen CuiLu Gold Co., Ltd.China
Gold8853 S.p.A.Italy
GoldGGC Gujrat Gold Centre Pvt. Ltd.India
GoldSai RefineryIndia
GoldModeltech Sdn BhdMalaysia
GoldDegussa Sonne / Mond Goldhandel GmbHGermany
GoldPease & CurrenUnited States Of America
GoldJALAN & CompanyIndia
GoldABC Refinery Pty Ltd.Australia
GoldState Research Institute Center for Physical Sciences and TechnologyLithuania
GoldGold Coast RefineryGhana
GoldQG Refining, LLCUnited States Of America
GoldDijllah Gold Refinery FZCUnited Arab Emirates
GoldCGR Metalloys Pvt Ltd.India
GoldSovereign MetalsIndia
GoldEco-System Recycling Co., Ltd. North PlantJapan
GoldEco-System Recycling Co., Ltd. West PlantJapan
GoldAugmont Enterprises Private LimitedIndia
GoldKundan Care Products Ltd.India
GoldEmerald Jewel Industry India Limited (Unit 1)India
GoldEmerald Jewel Industry India Limited (Unit 2)India
GoldEmerald Jewel Industry India Limited (Unit 3)India
GoldEmerald Jewel Industry India Limited (Unit 4)India
GoldK.A. RasmussenNorway
GoldAlexy MetalsUnited States Of America



GoldMD OverseasIndia
GoldMetallix Refining Inc.United States Of America
GoldMetal Concentrators SA (Pty) Ltd.South Africa
GoldWEEEREFININGFrance
GoldGold by Gold ColombiaColombia
GoldDongwu Gold GroupChina
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRussian Federation
GoldFidelity Printers and Refiners Ltd.Zimbabwe
GoldKyshtym Copper-Electrolytic Plant ZAORussian Federation
GoldAfrican Gold RefineryUganda
GoldAlbino Mountinho Lda.Portugal
GoldSam Precious MetalsUnited Arab Emirates
GoldCoimpa Industrial LTDABrazil
GoldGG Refinery Ltd.Tanzania, United Republic Of
GoldImpala Refineries – Base Metals Refinery (BMR)South Africa
GoldImpala RustenburgSouth Africa
TantalumTANIOBIS GmbHGermany
TantalumF&X Electro-Materials Ltd.China
TantalumGuangdong Rising Rare Metals-EO Materials Ltd.China
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDChina
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.China
TantalumJiujiang Tanbre Co., Ltd.China
TantalumJiangxi Tuohong New Raw MaterialChina
TantalumAMG BrasilBrazil
TantalumMetallurgical Products India Pvt., Ltd.India
TantalumMitsui Mining and Smelting Co., Ltd.Japan
TantalumNPM Silmet ASEstonia
TantalumNingxia Orient Tantalum Industry Co., Ltd.China
TantalumQuantumCleanUnited States Of America
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.China
TantalumSolikamsk Magnesium Works OAORussian Federation
TantalumTaki Chemical Co., Ltd.Japan
TantalumTelex MetalsUnited States Of America
TantalumUlba Metallurgical Plant JSCKazakhstan
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.China
TantalumD Block Metals, LLCUnited States Of America
TantalumFIR Metals & Resource Ltd.China
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.China
TantalumXinXing HaoRong Electronic Material Co., Ltd.China
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.China
TantalumKEMET de MexicoMexico



TantalumTANIOBIS Co., Ltd.Thailand
TantalumMaterion Newton Inc.United States Of America
TantalumTANIOBIS Japan Co., Ltd.Japan
TantalumTANIOBIS Smelting GmbH & Co. KGGermany
TantalumGlobal Advanced Metals BoyertownUnited States Of America
TantalumGlobal Advanced Metals AizuJapan
TantalumRFH Yancheng Jinye New Material Technology Co., Ltd.China
Tantalum5D Production OUEstonia
TantalumPowerX Ltd.Rwanda
TinMalaysia Smelting Corporation (MSC)Malaysia
TinMetallic Resources, Inc.United States Of America
TinPT Timah Tbk MentokIndonesia
TinEM VintoBolivia (Plurinational State Of)
TinGejiu Non-Ferrous Metal Processing Co., Ltd.China
TinMineracao Taboca S.A.Brazil
TinMinsurPeru
TinPT Mitra Stania PrimaIndonesia
TinPT Refined Bangka TinIndonesia
TinPT Timah Tbk KundurIndonesia
TinThaisarcoThailand
TinAurubis BeerseBelgium
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.China
TinAlphaUnited States Of America
TinDowaJapan
TinChina Tin Group Co., Ltd.China
TinMitsubishi Materials CorporationJapan
TinO.M. Manufacturing (Thailand) Co., Ltd.Thailand
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)
TinPT Artha Cipta LanggengIndonesia
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.China
TinMagnu's Minerais Metais e Ligas Ltda.Brazil
TinPT ATD Makmur Mandiri JayaIndonesia
TinO.M. Manufacturing Philippines, Inc.Philippines
TinResind Industria e Comercio Ltda.Brazil
TinAurubis BerangoSpain
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.China
TinChifeng Dajingzi Tin Industry Co., Ltd.China
TinTin Technology & RefiningUnited States Of America
TinWhite Solder Metalurgia e Mineracao Ltda.Brazil
TinTin Smelting Branch of Yunnan Tin Co., Ltd.China
TinPT Aries Kencana SejahteraIndonesia



TinFenix MetalsPoland
TinGejiu Kai Meng Industry and Trade LLCChina
TinPT Babel Inti PerkasaIndonesia
TinPT Belitung Industri SejahteraIndonesia
TinPT Bukit TimahIndonesia
TinPT Panca Mega PersadaIndonesia
TinPT Prima Timah UtamaIndonesia
TinPT Sariwiguna BinasentosaIndonesia
TinPT Stanindo Inti PerkasaIndonesia
TinPT Tinindo Inter NusaIndonesia
TinPT Tommy UtamaIndonesia
TinRui Da HungTaiwan, Province Of China
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.China
TinCV Venus Inti PerkasaIndonesia
TinMelt Metais e Ligas S.A.Brazil
TinPT Sukses Inti MakmurIndonesia
TinPT Menara Cipta MuliaIndonesia
TinModeltech Sdn BhdMalaysia
TinPT Bangka SerumpunIndonesia
TinPT Premium Tin IndonesiaIndonesia
TinEstanho de Rondonia S.A.Brazil
TinGejiu Zili Mining And Metallurgy Co., Ltd.China
TinJiangxi New Nanshan Technology Ltd.China
TinPT Babel Surya Alam LestariIndonesia
TinCV Ayi JayaIndonesia
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyViet Nam
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyViet Nam
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyViet Nam
TinAn Vinh Joint Stock Mineral Processing CompanyViet Nam
TinSuper LigasBrazil
TinPT Bangka Prima TinIndonesia
TinPongpipat Company LimitedMyanmar
TinDongguan CiEXPO Environmental Engineering Co., Ltd.China
TinPT Rajawali Rimba PerkasaIndonesia
TinLuna Smelter, Ltd.Rwanda
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.China
TinPrecious Minerals and Smelting LimitedIndia
TinGejiu City Fuxiang Industry and Trade Co., Ltd.China
TinPT Mitra Sukses GlobalindoIndonesia
TinNovosibirsk Tin CombineRussian Federation
TinPT Timah NusantaraIndonesia



TinVQB Mineral and Trading Group JSCViet Nam
TinPT Tirus Putra MandiriIndonesia
TinPT Rajehan AriqIndonesia
TinPT Cipta Persada MuliaIndonesia
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBrazil
TinCRM SynergiesSpain
TinFabrica Auricchio Industria e Comercio Ltda.Brazil
TinPT Putera Sarana Shakti (PT PSS)Indonesia
TinPT Bangka Tin IndustryIndonesia
TinDS MyanmarMyanmar
TinHuiChang Hill Tin Industry Co., Ltd.China
TinMa'anshan Weitai Tin Co., Ltd.China
TinMining Minerals Resources SARLCongo, Democratic Republic Of The
TinTakehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.Japan
TinMalaysia Smelting Corporation Berhad (Port Klang)Malaysia
TungstenChongyi Zhangyuan Tungsten Co., Ltd.China
TungstenHunan Jintai New Material Co., Ltd.China
TungstenXiamen Tungsten Co., Ltd.China
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.China
TungstenGanzhou Seadragon W & Mo Co., Ltd.China
TungstenA.L.M.T. Corp.Japan
TungstenKennametal HuntsvilleUnited States Of America
TungstenGuangdong Xianglu Tungsten Co., Ltd.China
TungstenGlobal Tungsten & Powders LLCUnited States Of America
TungstenHunan Chenzhou Mining Co., Ltd.China
TungstenJapan New Metals Co., Ltd.Japan
TungstenKennametal FallonUnited States Of America
TungstenWolfram Bergbau und Hutten AGAustria
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.China
TungstenJiangxi Yaosheng Tungsten Co., Ltd.China
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.China
TungstenMalipo Haiyu Tungsten Co., Ltd.China
TungstenXiamen Tungsten (H.C.) Co., Ltd.China
TungstenJiangxi Gan Bei Tungsten Co., Ltd.China
TungstenAsia Tungsten Products Vietnam Ltd.Viet Nam
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchChina
TungstenH.C. Starck Tungsten GmbHGermany
TungstenTANIOBIS Smelting GmbH & Co. KGGermany
TungstenMasan High-Tech MaterialsViet Nam
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.China



TungstenNiagara Refining LLCUnited States Of America
TungstenHydrometallurg, JSCRussian Federation
TungstenUnecha Refractory metals plantRussian Federation
TungstenPhilippine Chuangxin Industrial Co., Inc.Philippines
TungstenACL Metais EireliBrazil
TungstenMoliren Ltd.Russian Federation
TungstenCNMC (Guangxi) PGMA Co., Ltd.China
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.China
TungstenChina Molybdenum Tungsten Co., Ltd.China
TungstenLianyou Metals Co., Ltd.Taiwan, Province Of China
TungstenJSC "Kirovgrad Hard Alloys Plant"Russian Federation
TungstenNPP Tyazhmetprom LLCRussian Federation
TungstenHubei Green Tungsten Co., Ltd.China
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.Brazil
TungstenCronimet Brasil LtdaBrazil
TungstenOOO “Technolom” 2Russian Federation
TungstenOOO “Technolom” 1Russian Federation
TungstenArtek LLCRussian Federation
TungstenFujian Xinlu Tungsten Co., Ltd.China
TungstenLLC VostokRussian Federation
TungstenYUDU ANSHENG TUNGSTEN CO., LTD.China
TungstenHANNAE FOR T Co., Ltd.Korea, Republic Of
TungstenTungsten Vietnam Joint Stock CompanyViet Nam
TungstenDONGKUK INDUSTRIES CO., LTD.Korea, Republic Of
TungstenNam Viet Cromit Joint Stock CompanyViet Nam
TungstenLianyou Resources Co., Ltd.Taiwan, Province Of China
TungstenShinwon Tungsten (Fujian Shanghang) Co., Ltd.China
TungstenKenee Mining Corporation VietnamViet Nam
TungstenMALAMET SMELTING SDN. BHD.Malaysia






Appendix B:

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

Baxter list of potential countries of origin:

Albania, Andorra, Angola, Argentina, Armenia, Australia, Austria, Azerbaijan, Belarus, Belgium, Benin, Bermuda, Bolivia (Plurinational State of), Botswana, Brazil, Bulgaria, Burkina Faso, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo, Cyprus, Democratic Republic of Congo, Democratic Republic of the Congo, Djibouti, Dominica, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Ethiopia, Fiji, Finland, France, Georgia, Germany, Ghana, Guam, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Jersey, Kazakhstan, Kenya, Korea, Kyrgyzstan, Liberia, Liechtenstein, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Norway, Oman, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Solomon Islands, South Africa, South Sudan, Spain, Sudan, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Togo, Turkey, Uganda, United Arab Emirates, United Kingdom, United States of America, Uruguay, Uzbekistan, Viet Nam, and Zambia.