EX-1.01 2 exhibit101-2020conflictmin.htm EX-1.01 Document

F5 Networks, Inc.
Conflict Minerals Report
Year Ended December 31, 2020
Introduction
This Conflict Minerals Report (the "Report") for F5 Networks, Inc. ("F5 Networks," "F5," the "Company," "we," "us," and "our") is presented for the reporting period from January 1, 2020 to December 31, 2020 to comply with Rule 13p-1 (the "Rule") under the Securities Exchange Act of 1934. For the purpose of the Reasonable Country of Origin Inquiry ("RCOI"), we initiated supply chain inquiries in December 2020 and continued to receive data through May 03, 2021. F5 maintains an ongoing data gathering and refresh program to ensure up-to-date data is captured throughout the year. For the purpose of this report, conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, "3TG").
This year, we received responses from 93% of our in-scope suppliers. After validation and removal of incomplete or invalid submissions, we received an acceptable, completed Conflict Minerals Reporting Template ("CMRT") from 90% of our in-scope suppliers, and were able to determine 13% of suppliers were not using any 3TG. 4% of the suppliers provided incomplete or invalid submissions.
As a downstream user of conflict minerals, we are dependent on our suppliers for information, and the list of smelters reported by F5 should be seen as a list of possible sources, rather than a complete record of known source locations. More information on how we determined which suppliers were in scope is available in this report.
A smelter list, CMRT form, conflict minerals policy, and other corporate social responsibility information is available online at https://support.f5.com/csp/article/K51230228.
Forward Looking Statements
This report includes forward looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, that involve risks and uncertainties. Forward looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. Forward looking statements can also be identified by words such as "expects," "plans," "intends," "will," "may," and similar terms. Forward looking statements are not guarantees of future performance. F5 assumes no obligation to revise or update any forward looking statements for any reason, except as required by law. Subsequent events may affect F5’s future determinations under Rule 13p-1.
About F5 Networks
F5 is a multi-cloud application security and delivery company that enables organizations to provide digital experiences to their customers faster, reliably, and at scale. Our cloud, software, and hardware offerings are designed to support, secure, and optimize applications in any type of environment, including on-premises and in multi-cloud architectures. In connection with our solutions, we provide a broad range of global services, including consulting, training, installation, maintenance, and other technical support services. Our customers include large enterprise businesses, public sector institutions, governments, and service providers around the globe.
Supply Chain Overview
F5 relies upon our suppliers to provide material declarations and information on the origin of 3TG contained in components and materials supplied to us, including materials and 3TG from sub-tier suppliers. As most suppliers provide company-level declarations, there are many smelters listed that may not actually be in the supply chain of the components used by F5.
We contracted with Assent Compliance ("Assent") to gather data from our suppliers as well as to provide our suppliers training on the reporting rules and guidance on completing the CMRT form. We utilized the standard Responsible Business Alliance Global e-Sustainability Initiative ("RBA-GeSI") Conflict Minerals Reporting Template version 6.01 developed by the Responsible Minerals Initiative ("RMI") and requested that all suppliers complete the form. Suppliers that are known or suspected to provide components that contain 3TG were considered undetermined unless a completed CMRT form was received. Suppliers known not to use metal in products sourced by F5 Networks were asked to provide a CMRT form, even if only to state no use. In cases where these suppliers did not provide a CMRT form, but a material declaration or comparable documentation is on file demonstrating no 3TG use, they were considered out of scope. Packaging suppliers are out of scope,



and though we have asked for CMRT forms for our own records they are excluded from this declaration and the data provided herein.
Reasonable Country of Origin Inquiry
To determine whether necessary 3TG in our products originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (the "Covered Countries"), we provided a list of suppliers associated with the Covered Products to Assent for upload to the Assent Compliance Manager tool ("ACM").
We utilized the RBA-GeSI CMRT version 6.01 to conduct a survey of all in scope suppliers. During the supplier survey, we contacted suppliers via the ACM, to which suppliers uploaded their completed CMRTs for assessment and management by Assent. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, Question 1 of the CMRT asks suppliers whether any of the 3TGs they use are necessary to the functionality or production of their products. We also periodically reviewed the supplier list to ensure that irrelevant or "out of scope" suppliers were removed from the survey process. We conducted this analysis based on the following criteria:
The company supplies packaging only (excluding labels)
The company supplies us with items that do not end up in our products (including equipment used to make our products or those used strictly on prototypes)
The company is a test lab
The company is a service provider only
The company is listed as a supplier, but no components were purchased for use in F5 products during the reporting period and preceding 12 months.
We requested that all suppliers complete a CMRT and included training and education (provided by Assent) to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. We directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested such suppliers to complete the CMRT form and submit their form to Assent.
For calendar year 2020 we 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. This data validation is based on:
Questions 1 and 2 are minimum requirements for the CMRT
If suppliers state (via Question 1 and Question 2) that their products do not contain 3TGs necessary to the function or production of said products, then no further information is required, and no further data validation is completed.
Question 3 - Do any of your 3TGs originate from the Covered Countries?
Any supplier that has any 3TGs from the Covered Countries, even one positive response from their supply chain must answer yes.
Question 4 - Do any of the smelters in your supply chain source the 3TG from conflict-affected and high-risk areas?
Question 5 - Have you received information from all relevant 3TG Suppliers?
If you are not at 100%, then you cannot make definitive statements for Questions 3 and 4.
Question 6 - What percentage of relevant suppliers have provided a response to your supply chain survey?
Question 7 - Have you identified all your Smelters and refiners?
If the answer here is yes, then question 5 must be yes. This also impacts question 3.
All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted with regards to invalid forms and are encouraged to submit a valid form. As of May 03, 2021, there were 6 invalid or incomplete supplier submissions that could not be corrected.



Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the RMI and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TG. Our suppliers identified a total of 318 smelters and refiners. Of those, 236 are currently conformant to the Responsible Minerals Audit Process ("RMAP") run by RMI. Based on information provided by RMI, a further 8 are in communication with RMI. Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TG contained in our products.
Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries. In accordance with the Rule, we performed due diligence on the source and chain of custody of the conflict minerals in question.
Design of Due Diligence
We designed our due diligence measures to conform, in all material respects, with the framework in the Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas (the "Guidance") and the related Supplements for gold, tin, tantalum, and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps:
1.Establishing strong company management systems regarding conflict minerals;
2.Identifying and assessing risks in our supply chain;
3.Designing and implementing a strategy to respond to identified risks in our supply chain;
4.Utilizing independent third-party audits of supply chain diligence; and
5.Publicly reporting on our supply chain due diligence.
Company Management System
Company Policies
All suppliers in our manufacturing supply chain are required to provide products that meet the requirements laid out in F5’s Conflict Minerals Policy which can be found here: https://support.f5.com/csp/article/K51230228.
Conflict Minerals Policy (as of May 03, 2021):
As a global company, we know the business of F5 has impacts throughout our world-wide value chain. The Dodd-Frank Consumer Protection and Wall Street Reform Act (the "Dodd-Frank Act") found that the exploitation and trade of Tin, Tantalum, Tungsten, and Gold ("conflict minerals") were helping to finance extreme levels of violence in the DRC. The Dodd-Frank Act requires public companies to conduct due diligence and make certain disclosures regarding use of the conflict minerals.
F5 requires suppliers using any of the four conflict minerals sourced from the DRC or an adjoining country to use only materials which are certified Conflict Free through the Conflict Free Smelter Initiative or a comparable process.
We are committed to eliminating conflict minerals from our manufacturing supply chain through use of widely adopted best practices, including:
Establishing a conflict minerals compliance program consistent with the OECD Due Diligence guidance for downstream companies
Determining which F5 suppliers use the above-mentioned conflict minerals and targeting our efforts accordingly
Requiring all affected suppliers to provide a Conflict Minerals Reporting Template to the social responsibility team for review
When instances of non-compliant suppliers arise, working with those suppliers through our manufacturing supply chain team to ensure corrective actions are undertaken promptly and effectively



Filing an annual Form SD with the Securities and Exchange Commission through our financial reporting group, which will include updates on progress towards being conflict free and details of any corrective actions taken in the reporting year
Developing total transparency in the supply chain takes time, and correcting suppliers’ use of non-certified conflict minerals as it arises requires commitment. We are confident our efforts, combined with the rest of the industry will result in substantive impacts for the people of the DRC and surrounding region.
Management Team
Management for the conflict minerals program at F5 is the supply chain team (within manufacturing). This team works closely with peers in manufacturing, manufacturing supply chain, and product design.
The corporate social responsibility team oversees gathering CMRTs, performing assessments of the CMRTs, following up with suppliers, filing the conflict minerals report, working with F5’s contract manufacturer to determine purchase history and supplier use, and maintaining up-to-date information on conflict minerals regulations. As discussed earlier in this report, some of those responsibilities have been outsourced to Assent.
The supply chain team (within manufacturing) is responsible for keeping up-to-date contacts with suppliers and managing contracts with suppliers with which F5 has contracts. F5 does not have contracts with all suppliers, but all contracts that are in place include conflict minerals requirements.
The product development team, particularly the team of component engineers, is responsible for maintaining up-to-date supplier lists and bills of materials. When a new supplier is added, they notify the corporate social responsibility team so due diligence can commence. When a supplier must be removed due to conflict minerals use, the corporate social responsibility team engages the component engineering and product development teams to develop and implement a phase-out plan including timeline and alternate supplier qualification.
Grievance Mechanism
Suppliers and other parties may contact us with conflict minerals questions or concerns.
Via email: rohscompliance@f5.com
Reports also may be made anonymously to the F5 Ethics Point portal.
Online at f5.ethicspoint.com
By telephone at +1 (855) 409-0947
Supplier Engagement
Design Process
F5 selects suppliers for a variety of performance criteria, including compliance. Initial screening of suppliers covers basic compliance criteria, including an ability to provide a CMRT to F5 though that CMRT is not reviewed as part of the new supplier process.
After selection, parts are integrated into prototype bills of materials and then integrated into regular, ongoing data collection performed by the corporate social responsibility team. This includes conflict minerals compliance and full material declarations.
Incorporation into Production Bill of Materials
Once listed on a prototype or production bill of materials, a supplier is added to our surveys of compliance information. It is at this point Assent is engaged to procure a CMRT from the supplier. Assent utilizes contact information provided by F5 as well as contacts from other downstream users to initiate contact with a supplier. In the event a supplier is unfamiliar with conflict minerals reporting, Assent provides training on how to properly fill out a CMRT and guidance on how that supplier can perform their own supply chain due diligence.
Maintenance of Data
After completion, F5 holds CMRTs in the ACM. These documents will be held, at a minimum, for the required period as dictated by the SEC.



As long as a supplier remains on a bill of materials for a product still in production and with an active purchase history within the prior two years, F5 will continue to gather a new CMRT every year. This ensures changes in suppliers’ practices have not resulted in a change in conflict mineral sourcing status.
Due Diligence for Calendar Year 2020
Risk Assessment
Of the suppliers deemed in scope, we found the majority to be responsive with continually improving data and coverage year over year.
Once received, a CMRT is reviewed for a variety of red flags including those listed in the OECD guidance for downstream companies. This includes, but is not limited to:
Determining the legitimacy of all smelters listed through a variety of validated smelter lists such as those maintained by the RMI.
Maintaining an up-to-date list of certified conflict-free smelters and checking reported smelters against that list.
Determining if a smelter, even if outside the Covered Countries, lists source material from the Covered Countries.
Flagging smelters and suppliers listing recycled, scrap, or bank sources of materials.
Flagging smelters and suppliers with unfixed inconsistencies in their forms.
Assent provides potential corrective action guidance to suppliers with data inconsistencies and errors; the average CMRT has been reviewed three times by Assent and the providing supplier prior to receipt of that CMRT by F5. F5 monitors this process through updates from Assent and advises on action for suppliers whose data has not met Assent’s basic threshold for trustworthiness.
Supplier Risk
Suppliers that have not improved the percent of their supply chain surveyed, provided data showing they are not conflict free, or provided metals from other sanctioned countries were considered high-risk.
High-risk suppliers have been contacted throughout calendar year 2020 so F5 can monitor progress on removing smelters not shown to be conflict free or sourcing material from sanctioned countries.
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 goal of progressive elimination of these risks from the supply chain.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. At this time, 6 of our suppliers have been identified as having a weak program.
Smelter Risk
Furthermore, smelters or refiners not being certified DRC Conflict Free pose a significant risk to the supply chain. Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
Geographic proximity to the DRC and Covered Countries;
Responsible Minerals Assurance Process (RMAP) audit status; and
Known or plausible evidence of unethical or conflict sourcing.
Based on these criteria, the following facilities have been identified with a red-flag risks of highest concern into their supply chain:
African Gold Refinery - CID003185
Fidelity Printers and Refiners Ltd. - CID002515



Sudan Gold Refinery - CID002567
Tony Goetz NV - CID002587
Kaloti Precious Metals - CID002563
When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our third-party vendor, Assent Compliance, submissions that include any facilities with the above conditions 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 F5, and escalating up to removal of these high-risk smelters from their supply chain.
Strategy to Respond to Risks
Together with Assent, we developed processes to assess and respond to the risks identified in our supply chain.
Non-Responsive Suppliers
As the conflict minerals due diligence progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the Conflict Minerals rules. Assent provides training on conflict minerals and filling out a CMRT.
Various reasons have been presented for why a supplier does not respond, but the most frequent is out of date contact information. In this case, F5's social responsibility team and supply chain team gather up-to-date supplier contact information. F5’s contract manufacturer, Flex, may be asked to provide their contact with suppliers. Working with Flex also helps eliminate some confusion with suppliers requiring purchase orders to provide information; Flex is typically the purchaser of record, even though F5 maintains design control.
Suppliers with Persistent Issues
When suppliers continue to provide CMRTs to Assent or F5 that list high risk, out of date, or other illegitimate smelters, F5 will follow up with that supplier and request that supplier work to remove those smelters from their supply chain. If a supplier submits a CMRT with issues and those issues persist over an 18 month period without being addressed, F5 will take corrective actions with that supplier up to and including removing them as an Approved Vendor from F5’s Approved Vendor List. For components that have multiple sources; preference will be given to suppliers that have submitted clear CMRTs.
Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facility's sourcing practices on behalf of its compliance partners. In the event after multiple attempts, a smelter does not engage in the RMAP, and a supplier continues to use metal from that smelter, F5 may entirely phase out the supplier.
While we were not successful in completely eliminating those smelters from our supply chain, we have seen a slight reduction in the number of suppliers claiming those smelters.
Public Reporting on Supply Chain Due Diligence
Results
During the reporting period, F5 had 214 actively purchased suppliers listed on our bills of materials. 138 of those in scope provided CMRTs that were accepted by F5, and an additional 59 were deemed out of scope. Six suppliers provided incomplete or invalid submissions. This represents a 93% percent response rate. With coverage above 90 percent, we feel we have met an acceptable threshold for F5 to consider the data gathering for the period to be complete and a success.
Attached as Appendix A is a list of all smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis. Because we rely on data from our suppliers and not all suppliers are in each product, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than contained in any one of our products.
Appendix B 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 the RMI. As mentioned in the above section, many responses were



provided at the company level, therefore, Appendix B may contain more countries than those that our products are being sourced from.
Determination of Conflict Status
For the reporting period ending December 31, 2020, F5 has not been found to be conflict free. This determination stems primarily from two sources of concern:
We still have smelters not listed as conflict free that are either located in or sourcing material in the conflict region.
We did not undergo an independent third-party audit for the reporting period, and thus cannot declare ourselves conflict free.
As a downstream user of materials, F5 does not purchase directly from smelters, or even directly from metals suppliers. As such, we are primarily reliant on entities in our supply chain to perform actual in-person audits of smelters. We search through listings on industry group sites, including the RMI and iTSCi and leverage the findings of those groups in our reporting.
Next Steps
During calendar year 2020, we experienced significant delays in response from suppliers due to the global COVID-19 crisis. This significantly adversely impacted our ability to follow up with suppliers regarding invalid or problematic submissions. However, we were still able to achieve above 90% response rate. During 2021, we will continue to improve our process, particularly focusing on timing of requests to ensure there is an ability to report complete data.



Appendix A
Below is the list of smelters listed on CMRTs of suppliers used by F5 during calendar year 2020.
Metal
Smelter Name
Smelter Country
Smelter ID
Gold8853 S.p.A.ITALYCID002763
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICACID002708
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICACID000015
GoldAfrican Gold RefineryUGANDACID003185
GoldAida Chemical Industries Co., Ltd.JAPANCID000019
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESCID002560
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYCID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILCID000058
GoldArgor-Heraeus S.A.SWITZERLANDCID000077
GoldAsahi Pretec Corp.JAPANCID000082
GoldAsahi Refining Canada Ltd.CANADACID000924
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICACID000920
GoldAsaka Riken Co., Ltd.JAPANCID000090
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYCID000103
GoldAU Traders and RefinersSOUTH AFRICACID002850
GoldAugmont Enterprises Private LimitedINDIACID003461
GoldAurubis AGGERMANYCID000113
GoldBangalore RefineryINDIACID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESCID000128
GoldBoliden ABSWEDENCID000157
GoldC. Hafner GmbH + Co. KGGERMANYCID000176
GoldC.I Metales Procesados Industriales SASCOLOMBIACID003421
GoldCaridadMEXICOCID000180
GoldCCR Refinery - Glencore Canada CorporationCANADACID000185
GoldCendres + Metaux S.A.SWITZERLANDCID000189
GoldCGR Metalloys Pvt Ltd.INDIACID003382
GoldChimet S.p.A.ITALYCID000233
GoldChugai MiningJAPANCID000264
GoldDaye Non-Ferrous Metals Mining Ltd.CHINACID000343
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYCID002867
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATESCID003348
GoldDODUCO Contacts and Refining GmbHGERMANYCID000362
GoldDowaJAPANCID000401
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OFCID003195
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFCID000359
GoldEco-System Recycling Co., Ltd. East PlantJAPANCID000425
GoldEco-System Recycling Co., Ltd. North PlantJAPANCID003424
GoldEco-System Recycling Co., Ltd. West PlantJAPANCID003425
GoldEmirates Gold DMCCUNITED ARAB EMIRATESCID002561
GoldFidelity Printers and Refiners Ltd.ZIMBABWECID002515
GoldFujairah Gold FZCUNITED ARAB EMIRATESCID002584
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIACID002852
GoldGeib Refining CorporationUNITED STATES OF AMERICACID002459
GoldGold Coast RefineryGHANACID003186
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINACID002243
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINACID001909
GoldGuangdong Jinding Gold LimitedCHINACID002312
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINACID000651



Metal
Smelter Name
Smelter Country
Smelter ID
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINACID000671
GoldHeimerle + Meule GmbHGERMANYCID000694
GoldHeraeus Metals Hong Kong Ltd.CHINACID000707
GoldHeraeus Precious Metals GmbH & Co. KGGERMANYCID000711
GoldHunan Chenzhou Mining Co., Ltd.CHINACID000767
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINACID000773
GoldHwaSeong CJ CO., LTD.KOREA, REPUBLIC OFCID000778
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINACID000801
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATESCID002562
GoldIshifuku Metal Industry Co., Ltd.JAPANCID000807
GoldIstanbul Gold RefineryTURKEYCID000814
GoldItalpreziosiITALYCID002765
GoldJALAN & CompanyINDIACID002893
GoldJapan MintJAPANCID000823
GoldJiangxi Copper Co., Ltd.CHINACID000855
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATIONCID000927
GoldJSC UralelectromedRUSSIAN FEDERATIONCID000929
GoldJX Nippon Mining & Metals Co., Ltd.JAPANCID000937
GoldKaloti Precious MetalsUNITED ARAB EMIRATESCID002563
GoldKazakhmys Smelting LLCKAZAKHSTANCID000956
GoldKazzincKAZAKHSTANCID000957
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICACID000969
GoldKGHM Polska Miedz Spolka AkcyjnaPOLANDCID002511
GoldKojima Chemicals Co., Ltd.JAPANCID000981
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFCID002605
GoldKundan Care Products Ltd.INDIACID003463
GoldKyrgyzaltyn JSCKYRGYZSTANCID001029
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONCID002865
GoldL'azurde Company For JewelrySAUDI ARABIACID001032
GoldLingbao Gold Co., Ltd.CHINACID001056
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINACID001058
GoldL'Orfebre S.A.ANDORRACID002762
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFCID001078
GoldLT Metal Ltd.KOREA, REPUBLIC OFCID000689
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINACID001093
GoldMarsam MetalsBRAZILCID002606
GoldMaterionUNITED STATES OF AMERICACID001113
GoldMatsuda Sangyo Co., Ltd.JAPANCID001119
GoldMetalor Technologies (Hong Kong) Ltd.CHINACID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORECID001152
GoldMetalor Technologies (Suzhou) Ltd.CHINACID001147
GoldMetalor Technologies S.A.SWITZERLANDCID001153
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICACID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOCID001161
GoldMitsubishi Materials CorporationJAPANCID001188
GoldMitsui Mining and Smelting Co., Ltd.JAPANCID001193
GoldMMTC-PAMP India Pvt., Ltd.INDIACID002509
GoldModeltech Sdn BhdMALAYSIACID002857
GoldMorris and WatsonNEW ZEALANDCID002282
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYCID001220
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANCID001236
GoldNH Recytech CompanyKOREA, REPUBLIC OFCID003189



Metal
Smelter Name
Smelter Country
Smelter ID
GoldNihon Material Co., Ltd.JAPANCID001259
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIACID002779
GoldOhura Precious Metal Industry Co., Ltd.JAPANCID001325
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONCID001326
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATIONCID000493
GoldPAMP S.A.SWITZERLANDCID001352
GoldPease & CurrenUNITED STATES OF AMERICACID002872
GoldPenglai Penggang Gold Industry Co., Ltd.CHINACID001362
GoldPlanta Recuperadora de Metales SpACHILECID002919
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONCID001386
GoldPT Aneka Tambang (Persero) TbkINDONESIACID001397
GoldPX Precinox S.A.SWITZERLANDCID001498
GoldQG Refining, LLCUNITED STATES OF AMERICACID003324
GoldRand Refinery (Pty) Ltd.SOUTH AFRICACID001512
GoldRefinery of Seemine Gold Co., Ltd.CHINACID000522
GoldREMONDIS PMR B.V.NETHERLANDSCID002582
GoldRoyal Canadian MintCANADACID001534
GoldSAAMPFRANCECID002761
GoldSabin Metal Corp.UNITED STATES OF AMERICACID001546
GoldSafimet S.p.AITALYCID002973
GoldSAFINA A.S.CZECH REPUBLICCID002290
GoldSai RefineryINDIACID002853
GoldSamduck Precious MetalsKOREA, REPUBLIC OFCID001555
GoldSamwon Metals Corp.KOREA, REPUBLIC OFCID001562
GoldSAXONIA Edelmetalle GmbHGERMANYCID002777
GoldSEMPSA Joyeria Plateria S.A.SPAINCID001585
GoldShandong Humon Smelting Co., Ltd.CHINACID002525
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINACID001619
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACID001622
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CHINACID002527
GoldShirpur Gold Refinery Ltd.INDIACID002588
GoldSichuan Tianze Precious Metals Co., Ltd.CHINACID001736
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINACID002516
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONCID001756
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINACID001761
GoldSovereign MetalsINDIACID003383
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIACID003153
GoldSudan Gold RefinerySUDANCID002567
GoldSumitomo Metal Mining Co., Ltd.JAPANCID001798
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFCID002918
GoldSuper Dragon Technology Co., LtdTAIWAN, PROVINCE OF CHINACID001810
GoldT.C.A S.p.AITALYCID002580
GoldTanaka Kikinzoku Kogyo K.K.JAPANCID001875
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINACID001916
GoldTokuriki Honten Co., Ltd.JAPANCID001938
GoldTongling Nonferrous Metals Group Co., Ltd.CHINACID001947
GoldTony Goetz NVBELGIUMCID002587
GoldTOO Tau-Ken-AltynKAZAKHSTANCID002615
GoldTorecomKOREA, REPUBLIC OFCID001955
GoldUmicore Precious Metals ThailandTHAILANDCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMCID001980
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICACID001993
GoldValcambi S.A.SWITZERLANDCID002003



Metal
Smelter Name
Smelter Country
Smelter ID
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIACID002030
GoldWIELAND Edelmetalle GmbHGERMANYCID002778
GoldYamakin Co., Ltd.JAPANCID002100
GoldYokohama Metal Co., Ltd.JAPANCID002129
GoldYunnan Copper Industry Co., Ltd.CHINACID000197
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACID002224
TantalumAsaka Riken Co., Ltd.JAPANCID000092
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINACID000211
TantalumD Block Metals, LLCUNITED STATES OF AMERICACID002504
TantalumExotech Inc.UNITED STATES OF AMERICACID000456
TantalumF&X Electro-Materials Ltd.CHINACID000460
TantalumFIR Metals & Resource Ltd.CHINACID002505
TantalumGlobal Advanced Metals AizuJAPANCID002558
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICACID002557
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINACID000616
TantalumH.C. Starck Co., Ltd.THAILANDCID002544
TantalumH.C. Starck Hermsdorf GmbHGERMANYCID002547
TantalumH.C. Starck Inc.UNITED STATES OF AMERICACID002548
TantalumH.C. Starck Ltd.JAPANCID002549
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANYCID002550
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANYCID002545
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINACID002492
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACID002512
TantalumJiangxi Tuohong New Raw MaterialCHINACID002842
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACID000914
TantalumJiujiang Tanbre Co., Ltd.CHINACID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACID002506
TantalumKEMET Blue MetalsMEXICOCID002539
TantalumLSM Brasil S.A.BRAZILCID001076
TantalumMetallurgical Products India Pvt., Ltd.INDIACID001163
TantalumMineracao Taboca S.A.BRAZILCID001175
TantalumMitsui Mining and Smelting Co., Ltd.JAPANCID001192
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINACID001277
TantalumNPM Silmet ASESTONIACID001200
TantalumPRG DooelNORTH MACEDONIA, REPUBLIC OFCID002847
TantalumQuantumCleanUNITED STATES OF AMERICACID001508
TantalumResind Industria e Comercio Ltda.BRAZILCID002707
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONCID001769
TantalumTaki Chemical Co., Ltd.JAPANCID001869
TantalumTelex MetalsUNITED STATES OF AMERICACID001891
TantalumUlba Metallurgical Plant JSCKAZAKHSTANCID001969
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINACID002508
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINACID001522
TinAlphaUNITED STATES OF AMERICACID000292
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAMCID002703
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINACID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINACID003190
TinChina Tin Group Co., Ltd.CHINACID001070
TinCV Ayi JayaINDONESIACID002570
TinCV Venus Inti PerkasaINDONESIACID002455
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINACID003356
TinDowaJAPANCID000402



Metal
Smelter Name
Smelter Country
Smelter ID
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAMCID002572
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)CID000438
TinEstanho de Rondonia S.A.BRAZILCID000448
TinFenix MetalsPOLANDCID000468
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINACID003410
TinGejiu Fengming Metallurgy Chemical PlantCHINACID002848
TinGejiu Kai Meng Industry and Trade LLCCHINACID000942
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINACID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINACID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINACID000555
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACID003116
TinHuiChang Hill Tin Industry Co., Ltd.CHINACID002844
TinJiangxi New Nanshan Technology Ltd.CHINACID001231
TinLuna Smelter, Ltd.RWANDACID003387
TinMa'anshan Weitai Tin Co., Ltd.CHINACID003379
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILCID002468
TinMalaysia Smelting Corporation (MSC)MALAYSIACID001105
TinMelt Metais e Ligas S.A.BRAZILCID002500
TinMetallic Resources, Inc.UNITED STATES OF AMERICACID001142
TinMetallo Belgium N.V.BELGIUMCID002773
TinMetallo Spain S.L.U.SPAINCID002774
TinMineracao Taboca S.A.BRAZILCID001173
TinMinsurPERUCID001182
TinMitsubishi Materials CorporationJAPANCID001191
TinModeltech Sdn BhdMALAYSIACID002858
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002573
TinNovosibirsk Processing Plant Ltd.RUSSIAN FEDERATIONCID001305
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDCID001314
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESCID002517
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)CID001337
TinPongpipat Company LimitedMYANMARCID003208
TinPrecious Minerals and Smelting LimitedINDIACID003409
TinPT Aries Kencana SejahteraINDONESIACID000309
TinPT Artha Cipta LanggengINDONESIACID001399
TinPT ATD Makmur Mandiri JayaINDONESIACID002503
TinPT Babel Inti PerkasaINDONESIACID001402
TinPT Babel Surya Alam LestariINDONESIACID001406
TinPT Bangka SerumpunINDONESIACID003205
TinPT Bukit TimahINDONESIACID001428
TinPT Cipta Persada MuliaINDONESIACID002696
TinPT Lautan Harmonis SejahteraINDONESIACID002870
TinPT Menara Cipta MuliaINDONESIACID002835
TinPT Mitra Stania PrimaINDONESIACID001453
TinPT Mitra Sukses GlobalindoINDONESIACID003449
TinPT Prima Timah UtamaINDONESIACID001458
TinPT Rajawali Rimba PerkasaINDONESIACID003381
TinPT Rajehan AriqINDONESIACID002593
TinPT Refined Bangka TinINDONESIACID001460
TinPT Stanindo Inti PerkasaINDONESIACID001468
TinPT Sukses Inti MakmurINDONESIACID002816
TinPT Timah NusantaraINDONESIACID001486



Metal
Smelter Name
Smelter Country
Smelter ID
TinPT Timah Tbk KundurINDONESIACID001477
TinPT Timah Tbk MentokINDONESIACID001482
TinPT Tinindo Inter NusaINDONESIACID001490
TinResind Industria e Comercio Ltda.BRAZILCID002706
TinRui Da HungTAIWAN, PROVINCE OF CHINACID001539
TinSoft Metais Ltda.BRAZILCID001758
TinSuper LigasBRAZILCID002756
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMCID002834
TinThaisarcoTHAILANDCID001898
TinTin Technology & RefiningUNITED STATES OF AMERICACID003325
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002574
TinVQB Mineral and Trading Group JSCVIET NAMCID002015
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACID002158
TinYunnan Tin Company LimitedCHINACID002180
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINACID003397
TungstenA.L.M.T. Corp.JAPANCID000004
TungstenACL Metais EireliBRAZILCID002833
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILCID003427
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMCID002502
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINACID002513
TungstenChina Molybdenum Co., Ltd.CHINACID002641
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINACID000258
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINACID000281
TungstenFujian Ganmin RareMetal Co., Ltd.CHINACID003401
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINACID002645
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINACID000875
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINACID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINACID002494
TungstenGEM Co., Ltd.CHINACID003417
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICACID000568
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINACID000218
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANYCID002542
TungstenH.C. Starck Tungsten GmbHGERMANYCID002541
TungstenHunan Chenzhou Mining Co., Ltd.CHINACID000766
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINACID000769
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONCID002649
TungstenJapan New Metals Co., Ltd.JAPANCID000825
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINACID002551
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINACID002321
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINACID002313
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINACID002318
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINACID002317
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINACID002316
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONCID003408
TungstenKennametal FallonUNITED STATES OF AMERICACID000966
TungstenKennametal HuntsvilleUNITED STATES OF AMERICACID000105
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OFCID003388
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINACID003407
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINACID002319
TungstenMasan Tungsten Chemical LLC (MTC)VIET NAMCID002543
TungstenMoliren Ltd.RUSSIAN FEDERATIONCID002845
TungstenNiagara Refining LLCUNITED STATES OF AMERICACID002589



Metal
Smelter Name
Smelter Country
Smelter ID
TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATIONCID003416
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESCID002827
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONCID002724
TungstenWolfram Bergbau und Hutten AGAUSTRIACID002044
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINACID002320
TungstenXiamen Tungsten Co., Ltd.CHINACID002082
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINACID002830



Appendix B – Countries of origin
This list of potential countries of origin is populated based on RMI validated smelters listed in our RCOI.
Afghanistan
Albania
Angola
Argentina
Armenia
Australia
Austria
Belarus
Belgium
Bermuda
Bolivia
Brazil
Bulgaria
Burundi
Cambodia
Canada
Central African Republic
Chile
China
Colombia
Czech Republic
Djibouti
Dominican Republic
DRC or an adjoining country (Covered Countries)
Ecuador
Egypt
England
Estonia
Ethiopia
Finland
France
Germany
Ghana
Guinea
Guyana
Hungary
India
Indonesia
Ireland
Israel
Italy
Ivory Coast
Japan



Kazakhstan
Kenya
Kyrgyzstan
Laos
Liberia
Lithuania
Luxembourg
Madagascar
Malaysia
Mali
Mauritania
Mexico
Mongolia
Morocco
Mozambique
Myanmar
Namibia
Netherlands
New Zealand
Niger
Nigeria
Papua New Guinea
Peru
Philippines
Poland
Portugal
Republic Of Korea
Russia
Rwanda
Saudi Arabia
Sierra Leone
Singapore
Slovakia
Slovenia
South Africa
Spain
Sudan
Suri
Suriname
Sweden
Switzerland
Tanzania
Thailand
Turkey
Uganda
United Arab Emirates
United Kingdom



USA
Uzbekistan
Viet Nam
Zambia
Zimbabwe