EX-1.01 2 ex101.htm EXHIBIT 1.01
EXHIBIT 1.01

DXP Enterprises, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2016

Introduction

This Conflict Minerals Report has been prepared by management of DXP for the period from January 1, 2016 to December 31, 2016 (the "Reporting Period"). Unless the context otherwise indicates, "DXP," "we," "us," the "Company" and "our" mean DXP Enterprises, Inc. and its consolidated and combined subsidiaries.

This Report is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule"). This Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines "conflict minerals" as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold ("3TGs") that are necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.

As described in this report, DXP has reason to believe that some of the 3TGs present in its supply chain may have originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (the "Covered Countries"). Therefore, we performed a reasonable country of origin inquiry ("RCOI") to determine whether any of the 3TGs in our products originated from the Covered Countries and were not from recycled or scrap sources.  Based on the RCOI, we determined that we may have some suppliers that sourced 3TG from the DRC Region and proceeded to conduct due diligence on our supplier base. The results of this are covered below.

Company Overview

Our business

DXP is engaged in the business of distributing maintenance, repair, and operating products, equipment and services to energy and industrial customers. DXP is organized into three business segments: Service Centers, Innovative Pumping Solutions and Supply Chain Services. The Service Centers segment is engaged in providing maintenance, MRO products and equipment, including logistics capabilities, to industrial customers. The Service Centers segment provides a wide range of MRO products in the rotating equipment, bearing, power transmission, hose, fluid power, metal working, fastener, industrial supply, safety products and safety services categories. The Innovative Pumping Solutions segment fabricates and assembles custom-made pump packages, remanufactures pumps and manufactures branded private label pumps. The Supply Chain Services segment manages all or part of a customer's MRO products supply chain, including warehouse and inventory management.

We have become customer driven experts in five key product categories. As such, our three business segments are supported by the following five key product categories: rotating equipment, bearings & power transmission, industrial supplies, metal working and safety products & services. Each business segment tailors its inventory and leverages product experts to meet the needs of its local customers.

Key product categories that we offer include:

·
Rotating Equipment. Our rotating equipment products include a full line of centrifugal pumps for transfer and process service applications, such as petrochemicals, refining and crude oil production; rotary gear pumps for low- to- medium pressure service applications, such as pumping lubricating oils and other viscous liquids; plunger and piston pumps for high-pressure service applications such as disposal of produced water and crude oil pipeline service; and air-operated diaphragm pumps. We also provide a large variety of pump accessories.

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·
Bearings & Power Transmission. Our bearing products include several types of mounted and un-mounted bearings for a variety of applications. The power transmission products we distribute include speed reducers, flexible-coupling drives, chain drives, sprockets, gears, conveyors, clutches, brakes and hoses.

·
Industrial Supplies. We offer a broad range of industrial supplies, such as abrasives, tapes and adhesive products, coatings and lubricants, fasteners, hand tools, janitorial products, pneumatic tools, welding supplies and welding equipment.

·
Metal Working. Our metal working products include a broad range of cutting tools, abrasives, coolants, gauges, industrial tools and machine shop supplies.

·
Safety Products & Services. We sell a broad range of safety products including eye and face protection, first aid, hand protection, hazardous material handling, instrumentation and respiratory protection products. Additionally, we provide safety services including hydrogen sulfide (H2S) gas protection and safety, specialized and standby fire protection, safety supervision, training, monitoring, equipment rental and consulting. Our safety services include safety supervision, medic services, safety audits, instrument repair and calibration, training, monitoring, equipment rental and consulting.


Our Covered Products


We conducted an analysis of our products to determine which of our products were likely to contain 3TG.We have identified tungsten in certain of our rotating equipment products within our segments that are necessary to the functionality or production of products that we manufactured or contracted to manufacture during the Reporting Period ("Covered Products"). DXP was unsure of further presence of 3TGs in their products however, through the RCOI, via supplier responses using the CMRT, the presence of all 3TGs were claimed by suppliers. Of the suppliers surveyed, many completed their CMRTs at the company, business unit or entity level. Due to this we are unable to definitively conclude which 3TGs are present in the parts or products that they supplied to us however we did continue with the RCOI and due diligence as applicable based on the information supplied.


Description of RCOI

DXP began our scoping process by extracting a list of our suppliers that provide us with Covered Products that may contain one or more of the 3TGs. Once the filtering was completed, we populated the list with contact information and provided the list to our third-party service provider. This supplier list was then uploaded to our third-party provider's software platform that allows us to store and manage supplier responses and documentation.

From there, we defined our scoping process even further by removing service providers, indirect materials suppliers, and suppliers who are inactive. This ensures that all suppliers surveyed provided items to DXP that were used in final products in the year 2016.

Our service provider then conducted the supplier survey portion of the RCOI. Utilizing the CFSI Conflict Minerals Reporting Template (the "CMRT"), version 4.10 or higher, the suppliers identified through the procedures above were surveyed on their sourcing of the 3TG that we identified in our products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company's supply chain. It includes questions regarding a direct supplier's conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TG used by those facilities.

During the supplier survey, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in the software platform. Non-responsive suppliers were contacted a minimum of three times and then were also managed by our service provider's Supply Chain Team in one-on-one communications. This included at least two follow ups in order to encourage their response via CMRTs. To ensure that our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party consultant have provided training to suppliers though webinars, videos, documentation, and one-on-one discussions.

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The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. All suppliers who submitted CMRTs that were flagged as "invalid" were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our service provider's system for future reporting and transparency. As of May 2, 2017, there were 37 invalid submissions that were not corrected by suppliers.

Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we proceeded to conduct due diligence on our supplier base.

Due Diligence

Design of due diligence

We have designed our due diligence procedures to conform, in all material respects, with the due diligence framework presented by the Organisation for Economic Co-operation and Development ("OECD") in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing and the related Supplements for gold and for tin, tantalum and tungsten.

DXP's conflict minerals due diligence process includes the five steps as defined by the Guidance: 1) establishing strong company management systems, 2) identifying and assessing risks in our supply chain, 3) designing and implementing a strategy to respond to identified risks, 4) utilizing independent third-party audits, and 5) publicly reporting on our supply chain due diligence. A summary of the due diligence measures undertaken by the Company is outlined below.


Due diligence performed

Establish Strong Company Management Systems

Internal team

We have organized a Conflict Minerals Committee comprised of individuals in management positions across multiple departments such as legal, finance, and procurement. The Conflict Minerals Committee leads our conflict minerals compliance effort and is responsible for implementing our conflict minerals compliance strategy and overseeing the 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 risks in our supply chain. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.

Control systems

Controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all DXP employees and third parties doing business with DXP, and our Policy regarding Conflict Minerals. We established a conflict minerals policy related to our sourcing of 3TGs as described in full in the "Conflict Minerals Policy" posted on our website at www.dxpe.com within the "Investor Relations" section under "Corporate Governance."

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Supplier engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 4.10 or higher and a third-party vendor's software reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.

We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process 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.

Grievance Mechanism

For concerns regarding potential violations, the "Conflict Minerals Policy" includes contact information for DXP's third party conduct helpline and means to make a report using dxpe.ethicspoint.com.

Maintain records

We have maintained company-wide document retention policies. These policies extend to the documentation accumulated in performing our due diligence procedures and requires that documentation will be retained for a period of not less than three years.

Identify and Assess Risks in the Supply Chain
It is important to note that DXP has relied on supplier responses to provide us with the information about the source of 3TGs 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 the recognized industry best practices.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
1.
Geographic proximity to the DRC and covered countries;
2.
Conflict-Free Smelter Program (CFSP) audit status;
3.
Known or plausible evidence of unethical or conflict sourcing.

Based on this criteria the following facilities have been identified as being of highest concern to the supply chain:
·
Tony Goetz NV - CID002587
·
Kaloti Precious Metals - CID002563
·
Phoenix Metals - CID002507
·
Universal Precious Metals Refining Zambia - CID002854
·
Fidelity Printers and Refiners - CID002515
·
Sudan Gold Refinery - CID002567

When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to DXP, and 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 clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.  

In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

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We also calculate supplier risk based on the chances that the supplier provides 3TG that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have "unknown" as some of the answers. It has been decided that penalizing or failing them for working through the process is likely not the best approach for the initial years of compliance, it does not meet the goals or spirit of the Rule, however evaluating and tracking the strength of the program does meet the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are:

A. Do you have a policy in place that includes DRC conflict-free sourcing?
E. Have you implemented due diligence measures for conflict-free sourcing? .
H. Do you verify due diligence information received from your suppliers?
I. Does your verification process include corrective action management?

When suppliers meet or exceed the above criteria, by answering yes to all four questions, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. We store all of this information and will continue to assess our suppliers' program strength and monitor any improvements or changes.


Design and Implement a Strategy to Respond to Identified Risks

DXP has established a Conflict Minerals Policy that outlines our expectations for suppliers. If these expectations are not met, the business relationship between that supplier will be evaluated. For example, if we find that we source 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries, DXP will assess the supplier relationship and encourage that supplier to establish an alternative source of the minerals that does not support such conflict. If an alternative source cannot be found or the supplier chooses not to respond to this risk, we will assess whether or not that supplier can be replaced.

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 of Conflict Minerals and therefore do not perform or direct audits of these entities.  In connection with our due diligence, we utilized information made available by the CFSI concerning independent third-party audits of smelters and refiners.

Report on Supply Chain Due Diligence
This Report, which constitutes our annual report on our due diligence efforts, is available on our website at www.dxpe.com within the "Investor Relations" section under "Investors Home > SEC Filings > Documents" and is filed with the SEC.

Results of Due Diligence
Survey results

As of May 2, 2017, we received responses from 36%, we received valid CMRTs from 34% and invalid CMRTs from 3% of our surveyed suppliers for the 2016 year.

As described above, DXP surveys our supply chain and reviews all responses against set criteria that has been developed to determine whether further communication is needed. These criteria include: nonresponsiveness, incomplete responses and overall inconsistencies. Those that provided us with a CMRT were also asked to submit SOR information. The results of this are discussed the Smelters and Refiners section below.


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Smelters and refiners

Of the suppliers surveyed, many completed their CMRTs at the company, business unit or entity level. Due to this we are unable to conclude that which 3TGs from which of the processing facilities they listed have actually been included in parts or products that they supplied to us.  Many of the responses provided by a supplier via the CMRT included the names of facilities listed by the suppliers as smelters or refiners (SORs). 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. That being said, there are still suppliers that are unable to provide SORs used for the materials supplied to us.

For all responses that indicated a smelter, our third party consultant compared the facilities listed to the list of smelters maintained by the Conflict-Free Sourcing Initiative ("CFSI"). If a supplier indicated that the facility was certified as "Conflict-Free," our vendor confirmed that the name was listed by CFSI as a certified smelter. No violations were identified. As of May 2, 2017, we have validated 317 smelters or refiners and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. 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 we have not been able to validate. Appendix A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and CFSI.

As our suppliers are largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to provide additional smelter and refiner names and country of origin of the necessary 3TG in this report at this time. We will continue to work with our suppliers to obtain smelter information at the product level.

Future Steps to be Taken

We are committed to complying with the provisions of the Rule and Form SD and expect to continue our efforts to improve our conflict minerals program and related due diligence. As we further develop our program and procedures, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to the following:

·
Engage with suppliers and direct them to training resources to attempt to increase our response rate and improve the content of responses to assist in our RCOI process and our efforts to determine the processing facilities for and country of origin of our 3TG with the greatest specificity possible;
·
Engage suppliers and encourage them to provide responses at the product level
·
Continue to invest in Conflict Minerals due diligence tools
·
Continue to respond to industry trends and legal requirements to further improve the traceability of 3TGs in our supply chain.

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Appendix A:

The table below lists, as of May 2, 2017, the smelters or refiners identified by our responsive Direct Suppliers that may have been used to process the conflict minerals necessary to the functionality or production of our Covered Products during 2016. As described above, this list may contain more facilities than are actually linked to the Company's Covered Products. Alternatively, this list may not include all applicable facilities as not all of our suppliers were able to provide SOR information at this time. Those that have been validated as compliant under the CFSP (Conflict Free Smelter Protocol) by the CFSI, have been noted as such in the final column on the right.

Metal
 Standard Smelter Name
 Smelter Facility Location
 CFSI Audit Status
Gold
Abington Reldan Metals, LLC
UNITED STATES
Active
Gold
Advanced Chemical Company
UNITED STATES
Compliant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Compliant
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Compliant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Compliant
Gold
Argor-Heraeus S.A.
SWITZERLAND
Compliant
Gold
Asahi Pretec Corp.
JAPAN
Compliant
Gold
Asahi Refining Canada Ltd.
CANADA
Compliant
Gold
Asahi Refining USA Inc.
UNITED STATES
Compliant
Gold
Asaka Riken Co., Ltd.
JAPAN
Compliant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Not Enrolled
Gold
AU Traders and Refiners
SOUTH AFRICA
Compliant
Gold
AURA-II
UNITED STATES
Not Enrolled
Gold
Aurubis AG
GERMANY
Compliant
Gold
Bangalore Refinery
INDIA
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Compliant
Gold
Boliden AB
SWEDEN
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Compliant
Gold
Caridad
MEXICO
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Compliant
Gold
Cendres + Métaux S.A.
SWITZERLAND
Active
Gold
Chimet S.p.A.
ITALY
Compliant
Gold
Chugai Mining
JAPAN
Not Enrolled
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Compliant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Not Enrolled
Gold
DODUCO GmbH
GERMANY
Compliant
 
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Gold
Dowa
JAPAN
Compliant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Compliant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Compliant
Gold
Elemetal Refining, LLC
UNITED STATES
Compliant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Compliant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Not Enrolled
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Not Enrolled
Gold
Geib Refining Corporation
UNITED STATES
Active
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CHINA
Not Enrolled
Gold
Gujarat Gold Centre
INDIA
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Not Enrolled
Gold
Heimerle + Meule GmbH
GERMANY
Compliant
Gold
Heraeus Ltd. Hong Kong
CHINA
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Compliant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Compliant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
Istanbul Gold Refinery
TURKEY
Compliant
Gold
Japan Mint
JAPAN
Compliant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Compliant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Not Enrolled
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Not Enrolled
Gold
Kazzinc
KAZAKHSTAN
Compliant
Gold
Kennecott Utah Copper LLC
UNITED STATES
Compliant
Gold
KGHM Polska Miedź Spółka Akcyjna
POLAND
Active
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Compliant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Compliant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Compliant
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Not Enrolled
 
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Gold
Lingbao Gold Co., Ltd.
CHINA
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
L'Orfebre S.A.
ANDORRA
Not Enrolled
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Compliant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
Materion
UNITED STATES
Compliant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Compliant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Compliant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Compliant
Gold
Metalor Technologies S.A.
SWITZERLAND
Compliant
Gold
Metalor USA Refining Corporation
UNITED STATES
Compliant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
Compliant
Gold
Mitsubishi Materials Corporation
JAPAN
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Compliant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Compliant
Gold
Modeltech Sdn Bhd
MALAYSIA
Not Enrolled
Gold
Morris and Watson
NEW ZEALAND
Not Enrolled
Gold
Morris and Watson Gold Coast
AUSTRALIA
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Compliant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Active
Gold
Nihon Material Co., Ltd.
JAPAN
Compliant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Compliant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Compliant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Compliant
Gold
PAMP S.A.
SWITZERLAND
Compliant
Gold
Pease & Curren
UNITED STATES
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Not Enrolled
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Compliant
Gold
PX Précinox S.A.
SWITZERLAND
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Compliant
 
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Gold
Remondis Argentia B.V.
NETHERLANDS
Not Enrolled
Gold
Republic Metals Corporation
UNITED STATES
Compliant
Gold
Royal Canadian Mint
CANADA
Compliant
Gold
SAAMP
FRANCE
Not Enrolled
Gold
Sabin Metal Corp.
UNITED STATES
Not Enrolled
Gold
SAFINA A.S.
CZECH REPUBLIC
Not Enrolled
Gold
Sai Refinery
INDIA
Not Enrolled
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Compliant
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Compliant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Compliant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
Compliant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Not Enrolled
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Compliant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Compliant
Gold
Singway Technology Co., Ltd.
TAIWAN
Compliant
Gold
So Accurate Group, Inc.
UNITED STATES
Not Enrolled
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Compliant
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Compliant
Gold
Sudan Gold Refinery
SUDAN
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Compliant
Gold
SungEel HiTech
KOREA, REPUBLIC OF
Active
Gold
T.C.A S.p.A
ITALY
Compliant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Compliant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Compliant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Not Enrolled
Gold
Tony Goetz NV
BELGIUM
Active
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Not Enrolled
Gold
Torecom
KOREA, REPUBLIC OF
Compliant
Gold
Umicore Brasil Ltda.
BRAZIL
Compliant
Gold
Umicore Precious Metals Thailand
THAILAND
Compliant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Compliant
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Compliant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Not Enrolled
Gold
Valcambi S.A.
SWITZERLAND
Compliant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Compliant
Gold
WIELAND Edelmetalle GmbH
GERMANY
Compliant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Compliant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Compliant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Compliant
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
Compliant
 
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Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Compliant
Tantalum
D Block Metals, LLC
UNITED STATES
Compliant
Tantalum
Duoluoshan
CHINA
Compliant
Tantalum
Exotech Inc.
UNITED STATES
Compliant
Tantalum
F&X Electro-Materials Ltd.
CHINA
Compliant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Compliant
Tantalum
Global Advanced Metals Aizu
JAPAN
Compliant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Compliant
Tantalum
H.C. Starck GmbH Goslar
GERMANY
Compliant
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
Not Enrolled
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Compliant
Tantalum
H.C. Starck Inc.
UNITED STATES
Compliant
Tantalum
H.C. Starck Ltd.
JAPAN
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Compliant
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
KEMET Blue Metals
MEXICO
Compliant
Tantalum
KEMET Blue Powder
UNITED STATES
Compliant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Compliant
Tantalum
LSM Brasil S.A.
BRAZIL
Compliant
 
11

Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Compliant
Tantalum
Mineração Taboca S.A.
BRAZIL
Compliant
Tantalum
Mitsui Mining & Smelting
JAPAN
Compliant
Tantalum
Molycorp Silmet A.S.
ESTONIA
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Compliant
Tantalum
Plansee SE Liezen
AUSTRIA
Not Enrolled
Tantalum
Plansee SE Reutte
AUSTRIA
Compliant
Tantalum
Power Resources Ltd.
MACEDONIA
Compliant
Tantalum
QuantumClean
UNITED STATES
Compliant
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Compliant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Compliant
Tantalum
Taki Chemicals
JAPAN
Compliant
Tantalum
Telex Metals
UNITED STATES
Compliant
Tantalum
Tranzact, Inc.
UNITED STATES
Compliant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Compliant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Compliant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Compliant
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
CHINA
Compliant
Tin
Alpha
UNITED STATES
Compliant
Tin
An Thai Minerals Co., Ltd.
VIET NAM
Not Enrolled
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Compliant
Tin
China Tin Group Co., Ltd.
CHINA
Compliant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Not Enrolled
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Compliant
Tin
CV Ayi Jaya
INDONESIA
Compliant
Tin
CV Dua Sekawan
INDONESIA
Compliant
Tin
CV Gita Pesona
INDONESIA
Compliant
Tin
CV Serumpun Sebalai
INDONESIA
Compliant
Tin
CV Tiga Sekawan
INDONESIA
Compliant
Tin
CV United Smelting
INDONESIA
Compliant
Tin
CV Venus Inti Perkasa
INDONESIA
Compliant
Tin
Dowa
JAPAN
Compliant
 
12

Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Active
Tin
Elmet S.L.U.
SPAIN
Compliant
Tin
EM Vinto
BOLIVIA
Compliant
Tin
Estanho de Rondônia S.A.
BRAZIL
Not Enrolled
Tin
Fenix Metals
POLAND
Compliant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Compliant
Tin
Gejiu Jinye Mineral Company
CHINA
Compliant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Active
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Compliant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Active
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Not Enrolled
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Compliant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Compliant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Not Enrolled
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Compliant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Compliant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Compliant
Tin
Melt Metais e Ligas S.A.
BRAZIL
Compliant
Tin
Metallic Resources, Inc.
UNITED STATES
Compliant
Tin
Metallo-Chimique N.V.
BELGIUM
Compliant
Tin
Mineração Taboca S.A.
BRAZIL
Compliant
Tin
Minsur
PERU
Compliant
Tin
Mitsubishi Materials Corporation
JAPAN
Compliant
Tin
Modeltech Sdn Bhd
MALAYSIA
Not Enrolled
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Compliant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Compliant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Compliant
Tin
Phoenix Metal Ltd.
RWANDA
Not Enrolled
Tin
PT Aries Kencana Sejahtera
INDONESIA
Compliant
Tin
PT Artha Cipta Langgeng
INDONESIA
Compliant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Compliant
Tin
PT Babel Inti Perkasa
INDONESIA
Compliant
Tin
PT Bangka Prima Tin
INDONESIA
Compliant
Tin
PT Bangka Tin Industry
INDONESIA
Compliant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Compliant
Tin
PT Bukit Timah
INDONESIA
Compliant
 
13

Tin
PT Cipta Persada Mulia
INDONESIA
Compliant
Tin
PT DS Jaya Abadi
INDONESIA
Compliant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Compliant
Tin
PT Inti Stania Prima
INDONESIA
Compliant
Tin
PT Justindo
INDONESIA
Not Enrolled
Tin
PT Karimun Mining
INDONESIA
Compliant
Tin
PT Kijang Jaya Mandiri
INDONESIA
Compliant
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Compliant
Tin
PT Mitra Stania Prima
INDONESIA
Compliant
Tin
PT O.M. Indonesia
INDONESIA
Compliant
Tin
PT Panca Mega Persada
INDONESIA
Compliant
Tin
PT Prima Timah Utama
INDONESIA
Compliant
Tin
PT Refined Bangka Tin
INDONESIA
Compliant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Compliant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Compliant
Tin
PT Sukses Inti Makmur
INDONESIA
Compliant
Tin
PT Sumber Jaya Indah
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Compliant
Tin
PT Tinindo Inter Nusa
INDONESIA
Compliant
Tin
PT Tommy Utama
INDONESIA
Compliant
Tin
PT Wahana Perkit Jaya
INDONESIA
Compliant
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tin
Rui Da Hung
TAIWAN
Compliant
Tin
Soft Metais Ltda.
BRAZIL
Compliant
Tin
Thaisarco
THAILAND
Compliant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Not Enrolled
Tin
VQB Mineral and Trading Group JSC
VIET NAM
Compliant
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Compliant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Active
Tin
Yunnan Tin Company Limited
CHINA
Compliant
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Compliant
Tungsten
ACL Metais Eireli
BRAZIL
Not Enrolled
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Compliant
 
14

Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Not Enrolled
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Not Enrolled
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
H.C. Starck GmbH
GERMANY
Compliant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Compliant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Compliant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Compliant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Not Enrolled
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Kennametal Fallon
UNITED STATES
Compliant
Tungsten
Kennametal Huntsville
UNITED STATES
Compliant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
Compliant
Tungsten
Niagara Refining LLC
UNITED STATES
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Compliant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Compliant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Compliant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Compliant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Compliant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Compliant
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Compliant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Compliant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Compliant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Compliant

15


Country of Origin List:
This list below sets out possible countries of origin of 3TGs used in the manufacture of products containing conflict minerals that are necessary to the functionality or production of our products. The list is based on publicly available information, our reasonable country of origin investigation, and other due diligence. For the reasons described in the Report, however, these possible countries of origin cannot necessarily be linked to our products.
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Columbia, Cote D'Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. 

16