SD

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, DC 20549

FORM SD

Specialized Disclosure Report

Mercury Systems, Inc.

(Exact Name of Registrant as Specified in Charter)

Massachusetts	000-23599	04-2741391
(State or Other Jurisdiction of Incorporation)	(Commission File Number)	(IRS Employer Identification No.)

50 Minuteman Road, Andover, Massachusetts 01810

(Address of Principal Executive Offices) (Zip Code)

Stuart H. Kupinsky, (978) 256-1300

(Name and telephone number, including area code, of the person to contact in connection with this report)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

[X]    Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.

[ ]    Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended _________.

1

Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

For calendar year 2023, Mercury Systems, Inc. (“we,” “us,” or “our”) conducted a reasonable country of origin inquiry and supply chain due diligence to determine whether our products contained any conflict minerals that originated from the Democratic Republic of the Congo or an adjoining country. A summary of our reasonable country of origin inquiry and due diligence is contained in our conflict minerals report filed as exhibit 1.01 to this report and is incorporated herein by reference.

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, we have filed this Specialized Disclosure Report on Form SD, and the conflict minerals report exhibit hereto, with the U.S. Securities and Exchange Commission and have posted such report on our website at https://www.mrcy.com/company/environmental-social-and-governance/responsible-sourcing under the heading of Conflict Minerals. Information contained on our website does not constitute part of this report.

Forward-Looking Statements

This report contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “believe,” “intend,” “expect,” “will” or the use of future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include but are not limited to: the risk that information reported to us by our direct or indirect suppliers from which we procure finished goods, components, and/or materials for our products, or industry information used by us, may be inaccurate; the risk that smelters or refiners may not participate in the Responsible Minerals Assurance Process, which is a voluntary initiative in which independent third parties audit processing facilities’ procurement and processing activities and determine if the processing facilities maintain sufficient documentation to reasonably demonstrate conflict-free sourcing; the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers, on a timely basis or at all; whether market participants responsibly source conflict minerals; and changes in the conflict minerals regulations and other political and regulatory developments, whether in the Democratic Republic of the Congo and its adjoining countries, the United States, or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which apply only as of the date of filing of this report. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this report or to reflect the occurrence of unanticipated events. These risks and uncertainties also include such additional risk factors as are discussed in our filings with the U.S. Securities and Exchange Commission, including our Annual Report on Form 10-K for the fiscal year ended June 30, 2023, and subsequent Quarterly Reports on Form 10-Q and Current Reports on Form 8-K.

Item 1.02 Exhibit

A conflict minerals report covering calendar year 2023 has been filed as exhibit 1.01 to this Form SD.

Section 2 – Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

Section 3 – Exhibits

Item 3.01 Exhibits

Exhibit 1.01 – Mercury Systems, Inc. Conflict Minerals Report for the Year Ended December 31, 2023

2

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

Dated: May 30, 2024

	MERCURY SYSTEMS, INC.
By:	/s/ Stuart H. Kupinsky
	Stuart H. Kupinsky
	Executive Vice President, Chief Legal Officer, and Corporate Secretary

3

EX-1.01

1 Exhibit 1.01 Mercury Systems, 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. This report has been prepared based on Rule 13p-1 as further clarified by the Securities and Exchange Commission (“SEC”) guidance issued on April 7, 2017, in its Updated Statement on the Effect of the Court of Appeals Decision on the Conflict Minerals Rule. References in this report to “DRC” are to the Democratic Republic of the Congo and its nine adjoining countries (Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia). References in this report to “conflict minerals” are to cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which based on regulations from the SEC are limited to tin, tantalum, tungsten, and gold (“3TG”). Our Products Mercury Systems, Inc. (collectively with its subsidiaries, “we,” “us,” or “our”) is a technology company that delivers mission-critical processing power to the edge, making advanced technologies profoundly more accessible for today’s most challenging aerospace and defense missions. The Mercury Processing Platform allows customers to tap into innovative capabilities from silicon to system scale, turning data into decisions on timelines that matter. Headquartered in Andover, Massachusetts, our products and solutions are deployed in more than 300 programs and across 35 countries, enabling a broad range of applications in mission computing, sensor processing, command and control, and communications. Processing technologies that comprise our platform include signal solutions, display, software applications, networking, storage, and secure processing. Our innovative solutions are mission- ready, trusted and secure, software-defined and open and modular (our differentiators), to meet customers’ most-pressing high-tech needs, including those specific to the defense community. During calendar year 2023, we manufactured and sold products as well as provided software and services. Manufacturing operations include manufacturing at our own facilities and by contract manufacturers using our design specifications. We provide products in the fields of radio frequency, analog-to-digital and digital to analog conversion, advanced multi- and many-core sensor processing systems, embedded security, digital storage, and digital radio frequency memory solutions, software defined communications capabilities, and advanced security technologies and capabilities. Examples of our products include: power amplifiers and limiters; switches; oscillators; filters; equalizers; digital and analog converters; chips; MMICs (monolithic microwave integrated circuits); memory and storage devices; embedded processing modules; embedded processing boards; switch fabric boards; high speed input/output boards; digital receiver boards; graphics and video processing and Ethernet and IO (input- output) boards; multi-chip modules; integrated radio frequency and microwave multi-function assemblies; tuners; transceivers; rack-mount servers; display head assemblies; and integrated subsystems that include multiple modules and/or subassemblies. 3TG are essential to the functionality of most electronic devices and their use is extensive in the electronics industry. Examples of the use of 3TG in electronics include tin solder for joining circuits; tantalum in capacitors; tungsten in metal wires, electrodes, and electrical contacts; and gold in electric plating and circuit boards. We performed a review of our products considering the SEC’s conflict minerals regulations and the vendors supplying the components and materials incorporated into our products. Components and connectors incorporated into our products could contain conflict minerals as defined by the SEC, regardless of the country of origin of those minerals.

2 Our Calendar Year 2023 Reasonable Country of Origin Inquiry and Supply Chain Due Diligence We do not engage in the extraction, transportation, handling, trading, processing, smelting, refining, or alloying of 3TG and we do not acquire 3TG directly from any mine, smelter, or refiner, regardless of country of origin. We believe that we are many layers removed in the supply chain from the extraction and smelting of 3TG. To the extent that 3TG may be incorporated into our products, they are acquired through our supply chain in the form of components, connectors, solder, and other materials that we or our contract manufacturers incorporate into our finished products. We designed our conflict minerals reasonable country of origin inquiry and supply chain due diligence around our product manufacturing supply chain. We defined the scope of our conflict minerals inquiry by identifying and contacting the suppliers on our approved vendor list that provide components or other materials that may contain 3TG. We rely upon our suppliers to provide information on the origin of the 3TG contained in materials supplied to us, including sources of 3TG that are supplied to them from sub-tier suppliers. We expect our suppliers to provide us with sourcing information per our conflict minerals policy. In general, we encountered the following challenges in obtaining responses from our suppliers:  we are dependent on information received from our direct suppliers to conduct our reasonable country of origin inquiry process; and  we have a varied supplier base with differing levels of resources and sophistication, and many of our suppliers are not themselves subject to Rule 13p-1 of the Securities Exchange Act of 1934, as amended. Our Approved Vendor List Our supply chain approved vendor list (“AVL”) contained 819 tier 1 suppliers identified as in- scope for conflict mineral regulatory purposes and which were contacted as part of our reasonable country of origin inquiry. In many cases, for a given component in one of our products, we have multiple vendors as a source for that component and each of those vendors is listed on our AVL. Our procedures for adding a vendor to our AVL include a review of the vendor’s conflict minerals reporting as part of the approval process. Our Conflict Minerals Policy Statement and Supplier Outreach Our conflict minerals policy statement is posted on our corporate website, www.mrcy.com, under the heading “Company,” then “Environmental, Social and Governance,” and then “Responsible Sourcing.” Our conflict minerals due diligence process included the development of a conflict minerals policy, establishment of a cross-functional team, engagement of a third-party vendor to conduct supply chain due diligence, communication with suppliers, gathering compliance data, and measuring and internally reporting our due diligence progress. We distributed supplier notices summarizing our conflict minerals policy to the suppliers on our AVL. For our calendar year 2023 Reasonable Country of Origin Inquiry (“RCOI”), we engaged Source Intelligence to enhance our conflict minerals compliance program. The suppliers on our AVL were included in the RCOI performed by Source Intelligence. Prior to being asked to provide conflict minerals data, suppliers were asked a series of questions to determine whether the products they supply to us contain 3TG which is necessary to the functionality or production of our products. This information was used to determine which suppliers were in scope for regulatory purposes and thus asked to provide additional conflict minerals information. We engaged with Source Intelligence to develop a list of suppliers determined to be in-scope for regulatory purposes based on our influence over the manufacturing process (i.e., meeting the manufacture or contract to manufacture definitions in SEC Rule 13p-1) and potential use of 3TG. Source Intelligence contacted our suppliers to collect information about the presence and sourcing of the 3TG used in the products and components supplied to us. This program utilized the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (“CMRT”). Suppliers were offered two options to submit the

3 required information, either by uploading the CMRT in Excel format or by completing an online survey version of this template directly in the Source Intelligence platform. Source Intelligence sent an email to suppliers containing a registration and survey request link for the on-line data collection platform. Following the initial introductions to the program and information request, one email reminder was sent to each non-responsive supplier requesting survey completion. In recognition that the information requested can take time to collect and aggregate, suppliers were given a final deadline of March 31, 2024, to provide information about the metal processors present in their supply chains for the calendar 2023 reporting year. Suppliers were asked to provide information regarding the sourcing of their materials with the goal of identifying the 3TG smelters or refiners and associated mine countries of origin. Suppliers who had already performed a RCOI using the CMRT were asked to upload this document into the Source Intelligence system or to provide this information in the online survey version. We chose to give our suppliers the ability to share information at a level with which they were most comfortable, i.e. company, product or user-defined, but the declaration scope had to be specified. Suppliers were requested to provide an electronic signature before submitting their data to verify that all answers submitted were accurate to the best of the supplier’s knowledge, but the suppliers were not required to provide an electronic signature to submit their data. Source Intelligence evaluated the supplier responses for plausibility, consistency, and gaps. If any of the following quality control flags were raised, suppliers were automatically contacted by Source Intelligence on a bi-weekly basis up to three times:  one or more smelters or refiners were listed for an unused metal;  smelter or refiner information was not provided for a used metal, or such information provided was not a verified metal processor;  the supplier answered yes to sourcing from the Democratic Republic of the Congo or adjoining countries, but none of the smelters or refiners listed are known to source from the region;  the supplier indicated that they have not received conflict minerals data for each metal from all relevant suppliers;  the supplier indicated they have not identified all of the smelters or refiners used for the products included in the declaration scope;  the supplier indicated they have not provided all applicable smelter or refiner information received; and  the supplier indicated 100% of the 3TG for products covered by the declaration originates from scrap/recycled sources, but one or more smelters or refiners listed are not known to be exclusive recyclers. For supply chains with smelters or refiners that are known or thought to be sourcing from the Democratic Republic of the Congo or adjoining countries, additional investigation was conducted to determine the source and chain-of-custody of the regulated metals. Source Intelligence relies on the following internationally accepted audit standards to determine which smelters or refiners are considered “DRC Conflict Free”: the Responsible Minerals Assurance Process (“RMAP”); the London Bullion Market Association Good Delivery Program (“LBMA”); and the Responsible Jewellery Council Chain- of-Custody Certification (“RJC”). Source Intelligence is an official vendor member of the Responsible Minerals Initiative (“RMI”) to further facilitate the exchange of supply chain data and technical information in the quest for global ethical sourcing of materials. If the smelter or refiner is not certified by these internationally recognized standards, Source Intelligence attempts to contact them to gain more information about their sourcing practices, including countries of origin and transfer, and whether there are any internal due diligence procedures in place or other processes they undertake to track the chain-of-custody on the source of their mineral ores. Relevant information reviewed includes whether the smelter or refiner has a documented, effective, and communicated conflict-free policy; an accounting system to support a mass balance of materials

4 processed; and traceability documentation. Source Intelligence also performs internet research to determine whether there are any outside sources of information regarding the smelter or refiners sourcing practices. Source Intelligence attempts up to three contacts to smelters or refiners to gather information on mine country of origin and sourcing practices. A total of 819 tier 1 suppliers were identified as in-scope for conflict mineral regulatory purposes and contacted as part of the RCOI process. The response rate among these suppliers was 35%. Of these responding suppliers, 49% indicated one or more of the regulated metals (3TG) as necessary to the functionality or production of the products they supply to us. We did not conclude that any of our products were “DRC conflict free” per the meaning of that term in the conflict minerals regulations promulgated by the SEC. Appendix A to this report contains each unique smelter-metal combination reported to be in our supply chain with additional information from the Source Intelligence smelter database, including metal, smelter name, smelter country, and conflict-free certifications. Steps To Be Taken To Mitigate Risk Through Enhanced Due Diligence Efforts We will continue to take the following steps to improve our due diligence conducted to further mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the DRC and its adjoining countries:  continue to include a conflict minerals flow-down clause in new or renewed supplier contracts;  continue robust engagement with suppliers and direct them to training resources designed to increase the response rate and improve the content and accuracy of the supplier survey responses; and  further refine and improve best practices while continuing to build leverage over our supply chain in accordance with the OECD Guidance. We have a means for the anonymous reporting of any concerns about compliance, legal, and ethical matters. Any employee, supplier, customer, shareholder, or other interested party can submit a concern regarding our conflict minerals process via the following anonymous methods:  by telephone voicemail at 866-277-5739; or  by submitting a complaint via the internet at www.whistleblowerservices.com/mrcy. Independent Audit Pursuant to SEC regulations, this report is not subject to an independent private sector audit.

5 Appendix A Certification Status: 1. Responsible Minerals Assurance Process: Responsible Minerals Initiative (RMI)  RMAP: The smelter has an active certification or is in the process of renewing their certification.  RMAP-Active: The smelter is actively moving through the certification process.  TICMC-Progressing: Tungsten smelters that have committed to obtain a RMAP certification within 2 years of membership with the Tungsten Industry-Conflict Minerals Committee (TI-CMC). 2. Responsible Gold Certificate: London Bullion Market Association (LBMA)  LBMA: The smelter has obtained a Responsible Gold Certification. 3. Chain of Custody Certificate: Responsible Jewellery Council (RJC)  RJC: The smelter has obtained a Chain-of-Custody Certification. The smelters listed in the table were identified by the suppliers as being part of our calendar year 2023 supply chain. Some of the suppliers may have reported to us smelters that were not in our supply chain (i) since they reported at a “company level,” meaning that they reported to us the 3TG contained in all of their products, not just the products that they sold to us, or (ii) due to over-inclusiveness in the information received from their suppliers. In addition, the smelters reflected below may not be all of the smelters in our 2023 supply chain, since many of the suppliers were unable to identify all of the smelters used to process the necessary 3TG content contained in our products and because not all of the suppliers responded to our inquiries. Metal Official Smelter Name Smelter Country Conflict-Free Certifications Gold Matsuda Sangyo Co., Ltd. Japan LBMA, RMAP Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria RJC, RMAP Gold Singway Technology Co., Ltd. Taiwan Gold 8853 S.p.A. Italy Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico LBMA, RMAP Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation Gold Solar Applied Materials Technology Corp. Taiwan LBMA, RMAP Gold Metal Concentrators SA (Pty) Ltd. South Africa RMAP Gold Refinery of Seemine Gold Co., Ltd. China Gold Advanced Chemical Company United States RMAP - Active Gold Metalor Technologies (Hong Kong) Ltd. China LBMA, RJC, RMAP Gold Metalor Technologies (Singapore) Pte., Ltd. Singapore LBMA, RJC, RMAP Gold Metalor Technologies (Suzhou) Ltd. China RJC, RMAP Gold Metalor Technologies S.A. Switzerland LBMA, RJC, RMAP Gold Metalor USA Refining Corporation United States LBMA, RJC, RMAP Gold Asahi Refining Canada Ltd. Canada LBMA, RMAP Gold Aida Chemical Industries Co., Ltd. Japan RMAP Gold Geib Refining Corporation United States Gold Degussa Sonne / Mond Goldhandel GmbH Germany

6 Gold L'Orfebre S.A. Andorra RMAP Gold Al Etihad Gold Refinery DMCC United Arab Emirates Gold Pease & Curren United States Gold SAAMP France Gold Agosi AG Germany LBMA, RJC, RMAP Gold Industrial Refining Company Belgium Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan LBMA, RMAP Gold Sudan Gold Refinery Sudan Gold Mitsubishi Materials Corporation Japan LBMA, RMAP Gold Mitsui Mining and Smelting Co., Ltd. Japan LBMA, RMAP Gold MMTC-PAMP India Pvt., Ltd. India LBMA, RMAP Gold Sumitomo Metal Mining Co., Ltd. Japan LBMA, RMAP Gold Morris and Watson New Zealand Gold Super Dragon Technology Co., Ltd. Taiwan Gold Moscow Special Alloys Processing Plant Russian Federation Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil LBMA, RMAP Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey LBMA, RMAP Gold Guangdong Jinding Gold Limited China Gold T.C.A S.p.A Italy LBMA, RMAP Gold African Gold Refinery Uganda Gold Argor-Heraeus S.A. Switzerland LBMA, RMAP Gold Asahi Pretec Corp. Japan LBMA, RMAP Gold Asaka Riken Co., Ltd. Japan RMAP Gold Bangalore Refinery India RMAP - Active Gold Navoi Mining and Metallurgical Combinat Uzbekistan RMAP Gold Tanaka Kikinzoku Kogyo K.K. Japan LBMA, RMAP Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey Gold GGC Gujrat Gold Centre Pvt. Ltd. India RMAP - Active Gold Aurubis AG Germany LBMA, RMAP Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China Gold Nihon Material Co., Ltd. Japan LBMA, RMAP Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines LBMA, RMAP Gold Hangzhou Fuchunjiang Smelting Co., Ltd. China Gold Great Wall Precious Metals Co., Ltd. of CBPM China LBMA Gold Shandong Gold Smelting Co., Ltd. China LBMA, RMAP Gold International Precious Metal Refiners United Arab Emirates Gold QG Refining, LLC United States Gold LT Metal Ltd. Korea, Republic of RMAP Gold Heimerle + Meule GmbH Germany LBMA, RMAP Gold Planta Recuperadora de Metales SpA Chile RMAP Gold Heraeus Metals Hong Kong Ltd. China LBMA, RJC, RMAP

7 Gold Boliden AB Sweden LBMA, RMAP Gold Heraeus Germany GmbH Co. KG Germany RMAP Gold Tokuriki Honten Co., Ltd. Japan LBMA, RMAP Gold Tongling Nonferrous Metals Group Co., Ltd. China Gold TOO Tau-Ken-Altyn Kazakhstan RMAP Gold K.A. Rasmussen Norway Gold Torecom Korea, Republic of RMAP Gold C. Hafner GmbH + Co. KG Germany LBMA, RJC, RMAP Gold Ohura Precious Metal Industry Co., Ltd. Japan RMAP Gold JSC Novosibirsk Refinery Russian Federation Gold Caridad Mexico Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation Gold CCR Refinery - Glencore Canada Corporation Canada LBMA, RMAP Gold Cendres + Metaux S.A. Switzerland Gold Umicore Precious Metals Thailand Thailand Gold Umicore S.A. Business Unit Precious Metals Refining Belgium LBMA, RMAP Gold Hunan Chenzhou Mining Co., Ltd. China Gold MKS PAMP SA Switzerland LBMA, RMAP Gold United Precious Metal Refining, Inc. United States RMAP Gold Penglai Penggang Gold Industry Co., Ltd. China Gold HwaSeong CJ CO., LTD. Korea, Republic of Gold Chimet S.p.A. Italy LBMA, RMAP Gold Valcambi S.A. Switzerland LBMA, RJC, RMAP Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China LBMA, RMAP Gold Prioksky Plant of Non-Ferrous Metals Russian Federation Gold Chugai Mining Japan RMAP Gold PT Aneka Tambang (Persero) Tbk Indonesia LBMA, RMAP Gold Western Australian Mint (T/a The Perth Mint) Australia LBMA, RMAP Gold Ishifuku Metal Industry Co., Ltd. Japan LBMA, RMAP Gold Istanbul Gold Refinery Turkey LBMA, RMAP Gold White Solder Metalurgia e Mineracao Ltda. Brazil Gold Italpreziosi Italy RJC, RMAP Gold WIELAND Edelmetalle GmbH Germany RMAP Gold JALAN & Company India Gold Japan Mint Japan LBMA, RMAP Gold CGR Metalloys Pvt Ltd. India Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China Gold Dijllah Gold Refinery FZC United Arab Emirates Gold Gold Coast Refinery Ghana Gold Sovereign Metals India Gold Jiangxi Copper Co., Ltd. China LBMA, RMAP

8 Gold PX Precinox S.A. Switzerland LBMA, RMAP Gold Daye Non-Ferrous Metals Mining Ltd. China Gold Yamakin Co., Ltd. Japan RMAP Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. China Gold Rand Refinery (Pty) Ltd. South Africa LBMA, RMAP Gold NH Recytech Company Korea, Republic of RMAP Gold Eco-System Recycling Co., Ltd. North Plant Japan RMAP Gold Eco-System Recycling Co., Ltd. West Plant Japan RMAP Gold DSC (Do Sung Corporation) Korea, Republic of RMAP Gold Asahi Refining USA Inc. United States LBMA, RMAP Gold Yokohama Metal Co., Ltd. Japan RMAP Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation Gold Kundan Care Products Ltd. India Gold JSC Uralelectromed Russian Federation Gold JX Nippon Mining & Metals Co., Ltd. Japan LBMA, RMAP Gold Shirpur Gold Refinery Ltd. India Gold ABC Refinery Pty Ltd. Australia Gold AU Traders and Refiners South Africa Gold Kaloti Precious Metals United Arab Emirates Gold Yunnan Copper Industry Co., Ltd. China Gold Augmont Enterprises Private Limited India RMAP - Active Gold Kazakhmys Smelting LLC Kazakhstan Gold Emerald Jewel Industry India Limited (Unit 1) India Gold Kazzinc Kazakhstan LBMA, RMAP Gold Royal Canadian Mint Canada LBMA, RMAP Gold Emerald Jewel Industry India Limited (Unit 2) India Gold Emerald Jewel Industry India Limited (Unit 3) India Gold Emerald Jewel Industry India Limited (Unit 4) India Gold REMONDIS PMR B.V. Netherlands RMAP Gold Sai Refinery India Gold Sabin Metal Corp. United States Gold Modeltech Sdn Bhd Malaysia Gold Safimet S.p.A Italy Gold Kyshtym Copper-Electrolytic Plant ZAO Russian Federation Gold SAFINA A.S. Czech Republic RMAP Gold Kennecott Utah Copper LLC United States LBMA, RMAP Gold KGHM Polska Miedz Spolka Akcyjna Poland RMAP Gold Dowa Japan RMAP Gold Samduck Precious Metals Korea, Republic of Gold Alexy Metals United States Gold SAMWON METALS Corp. Korea, Republic of

9 Gold Kojima Chemicals Co., Ltd. Japan RMAP Gold Abington Reldan Metals, LLC United States RMAP Gold Metallix Refining Inc. United States Gold Korea Zinc Co., Ltd. Korea, Republic of RMAP Gold Shandong Humon Smelting Co., Ltd. China Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation China LBMA, RMAP Gold MD Overseas India Gold Gold Refinery of Zijin Mining Group Co., Ltd. China LBMA, RMAP Gold WEEEREFINING France RMAP Gold Eco-System Recycling Co., Ltd. East Plant Japan RMAP Gold SEMPSA Joyeria Plateria S.A. Spain LBMA, RMAP Gold Kyrgyzaltyn JSC Kyrgyzstan Gold L'azurde Company For Jewelry Saudi Arabia Gold Emirates Gold DMCC United Arab Emirates Gold SungEel HiMetal Co., Ltd. Korea, Republic of RMAP Gold Shenzhen CuiLu Gold Co., Ltd. China Gold Albino Mountinho Lda. Portugal Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China Gold Dongwu Gold Group China Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China LBMA, RMAP Gold Lingbao Gold Co., Ltd. China Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. China Gold Gold by Gold Colombia Colombia RMAP Gold LS-NIKKO Copper Inc. Korea, Republic of LBMA, RMAP Gold Coimpa Industrial LTDA Brazil RMAP Gold Sam Precious Metals United Arab Emirates Gold Fidelity Printers and Refiners Ltd. Zimbabwe Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China Gold State Research Institute Center for Physical Sciences and Technology Lithuania Gold Marsam Metals Brazil Gold GG Refinery Ltd. Tanzania RMAP - Active Gold Sichuan Tianze Precious Metals Co., Ltd. China LBMA, RMAP Gold Fujairah Gold FZC United Arab Emirates Gold Materion United States RMAP Tantalum Solikamsk Magnesium Works OAO Russian Federation Tantalum Metallurgical Products India Pvt., Ltd. India RMAP Tantalum Jiangxi Tuohong New Raw Material China RMAP Tantalum Global Advanced Metals Aizu Japan RMAP Tantalum Global Advanced Metals Boyertown United States RMAP Tantalum Molycorp Silmet A.S. Estonia RMAP Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED China RMAP

10 Tantalum TANIOBIS Co., Ltd. Thailand RMAP Tantalum TANIOBIS GmbH Germany RMAP Tantalum Materion Newton Inc. United States RMAP Tantalum TANIOBIS Japan Co., Ltd. Japan RMAP Tantalum Telex Metals United States RMAP Tantalum Ningxia Orient Tantalum Industry Co., Ltd. China RMAP Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China RMAP Tantalum Ulba Metallurgical Plant JSC Kazakhstan RMAP Tantalum Changsha South Tantalum Niobium Co., Ltd. China RMAP Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. China RMAP - Active Tantalum D Block Metals, LLC United States RMAP Tantalum XinXing Haorong Electronic Material Co., Ltd. China RMAP Tantalum QuantumClean United States RMAP Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. China RMAP Tantalum Jiujiang Tanbre Co., Ltd. China RMAP Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China RMAP Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China RMAP Tantalum KEMET de Mexico Mexico RMAP Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. China RMAP Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China RMAP Tantalum Taki Chemical Co., Ltd. Japan RMAP Tantalum 5D Production OU Estonia Tantalum F&X Electro-Materials Ltd. China RMAP Tantalum AMG Brasil Brazil RMAP Tantalum FIR Metals & Resource Ltd. China RMAP Tantalum PowerX Ltd. Rwanda RMAP Tin Melt Metais e Ligas S.A. Brazil Tin Metallic Resources, Inc. United States RMAP Tin Aurubis Beerse Belgium RMAP Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China RMAP Tin PT Rajehan Ariq Indonesia RMAP Tin HuiChang Hill Tin Industry Co., Ltd. China RMAP Tin Gejiu Kai Meng Industry and Trade LLC China Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. China RMAP Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China Tin Mineracao Taboca S.A. Brazil RMAP Tin Minsur Peru RMAP Tin Alpha United States RMAP Tin An Vinh Joint Stock Mineral Processing Company Viet Nam Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China RMAP Tin Jiangxi New Nanshan Technology Ltd. China RMAP

11 Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company Viet Nam Tin Thaisarco Thailand RMAP Tin PT Bangka Serumpun Indonesia RMAP Tin Pongpipat Company Limited Myanmar Tin Tin Technology & Refining United States RMAP Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China Tin PT Rajawali Rimba Perkasa Indonesia RMAP Tin Novosibirsk Tin Combine Russian Federation Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand RMAP Tin O.M. Manufacturing Philippines, Inc. Philippines RMAP Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company Viet Nam Tin Operaciones Metalurgicas S.A. Bolivia RMAP Tin Ma'anshan Weitai Tin Co., Ltd. China Tin China Tin Group Co., Ltd. China RMAP Tin VQB Mineral and Trading Group JSC Viet Nam Tin PT Aries Kencana Sejahtera Indonesia RMAP Tin PT Artha Cipta Langgeng Indonesia RMAP Tin PT ATD Makmur Mandiri Jaya Indonesia RMAP Tin PT Babel Inti Perkasa Indonesia RMAP Tin PT Babel Surya Alam Lestari Indonesia RMAP Tin PT Bangka Prima Tin Indonesia RMAP Tin PT Bangka Tin Industry Indonesia RMAP - Active Tin PT Belitung Industri Sejahtera Indonesia RMAP Tin PT Bukit Timah Indonesia RMAP Tin PT Cipta Persada Mulia Indonesia RMAP Tin CRM Synergies Spain RMAP Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China RMAP Tin PT Mitra Stania Prima Indonesia RMAP Tin PT Panca Mega Persada Indonesia Tin CV Ayi Jaya Indonesia RMAP Tin PT Prima Timah Utama Indonesia RMAP Tin PT Refined Bangka Tin Indonesia RMAP Tin PT Sariwiguna Binasentosa Indonesia RMAP Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China Tin PT Premium Tin Indonesia Indonesia RMAP Tin CV Venus Inti Perkasa Indonesia RMAP Tin PT Stanindo Inti Perkasa Indonesia RMAP Tin PT Sukses Inti Makmur Indonesia RMAP Tin Precious Minerals and Smelting Limited India RMAP - Active Tin Luna Smelter, Ltd. Rwanda RMAP Tin PT Timah Tbk Mentok Indonesia RMAP

12 Tin PT Timah Tbk Kundur Indonesia RMAP Tin PT Tinindo Inter Nusa Indonesia RMAP Tin PT Tirus Putra Mandiri Indonesia Tin PT Tommy Utama Indonesia RMAP Tin Chifeng Dajingzi Tin Industry Co., Ltd. China RMAP Tin PT Mitra Sukses Globalindo Indonesia RMAP Tin Resind Industria e Comercio Ltda. Brazil RMAP Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China RMAP Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. China RMAP Tin Rui Da Hung Taiwan RMAP Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil RMAP Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil RMAP Tin PT Menara Cipta Mulia Indonesia RMAP Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Viet Nam Tin Super Ligas Brazil RMAP Tin Aurubis Berango Spain RMAP Tin EM Vinto Bolivia RMAP Tin DS Myanmar Myanmar RMAP Tin PT Putera Sarana Shakti (PT PSS) Indonesia RMAP Tin Estanho de Rondonia S.A. Brazil RMAP Tin Fenix Metals Poland RMAP Tin Mining Minerals Resources SARL DRC- Congo (Kinshasa) RMAP Tin Magnu's Minerais Metais e Ligas Ltda. Brazil RMAP Tin Gejiu Zili Mining And Metallurgy Co., Ltd. China Tin Malaysia Smelting Corporation (MSC) Malaysia RMAP Tin Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. Taiwan RMAP - Active Tin Malaysia Smelting Corporation Berhad (Port Klang) Malaysia RMAP - Active Tungsten A.L.M.T. TUNGSTEN Corp. Japan RMAP Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China RMAP Tungsten ACL Metais Eireli Brazil Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China RMAP Tungsten Moliren Ltd. Russian Federation Tungsten Global Tungsten & Powders LLC United States RMAP Tungsten Guangdong Xianglu Tungsten Co., Ltd. China RMAP Tungsten Asia Tungsten Products Vietnam Ltd. Viet Nam RMAP Tungsten H.C. Starck Tungsten GmbH Germany RMAP Tungsten Niagara Refining LLC United States RMAP Tungsten TANIOBIS Smelting GmbH & Co. KG Germany RMAP Tungsten Masan High-Tech Materials Viet Nam RMAP Tungsten Hunan Jintai New Material Co., Ltd. China

13 Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch China RMAP Tungsten Hydrometallurg, JSC Russian Federation Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China RMAP Tungsten CNMC (Guangxi) PGMA Co., Ltd. China Tungsten Japan New Metals Co., Ltd. Japan RMAP Tungsten China Molybdenum Co., Ltd. China RMAP Tungsten Wolfram Bergbau und Hutten AG Austria RMAP Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation Tungsten Lianyou Metals Co., Ltd. Taiwan RMAP Tungsten Hubei Green Tungsten Co., Ltd. China RMAP Tungsten NPP Tyazhmetprom LLC Russian Federation Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China RMAP Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China RMAP Tungsten Xiamen Tungsten Co., Ltd. China RMAP Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China RMAP Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China RMAP Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China RMAP Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China RMAP Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil Tungsten Cronimet Brasil Ltda Brazil RMAP Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines RMAP Tungsten Kennametal Fallon United States RMAP Tungsten Kennametal Huntsville United States RMAP Tungsten Unecha Refractory Metals Plant Russian Federation Tungsten Artek LLC Russian Federation Tungsten OOO “Technolom” 1 Russian Federation Tungsten OOO “Technolom” 2 Russian Federation Tungsten Fujian Xinlu Tungsten Co., Ltd. China RMAP Tungsten LLC Vostok Russian Federation Tungsten YUDU ANSHENG TUNGSTEN CO., LTD. China Tungsten HANNAE FOR T Co., Ltd. Korea, Republic of Tungsten Tungsten Vietnam Joint Stock Company Viet Nam RMAP Tungsten Nam Viet Cromit Joint Stock Company Viet Nam Tungsten DONGKUK INDUSTRIES CO., LTD. Korea, Republic of TICMC - Progressing Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. China RMAP Tungsten Lianyou Resources Co., Ltd. Taiwan RMAP Tungsten Malipo Haiyu Tungsten Co., Ltd. China RMAP Tungsten Kenee Mining Corporation Vietnam Viet Nam RMAP - Active