EX-1.01 2 exhibit101.htm EX-1.01 Document

EXHIBIT 1.01
CONFLICT MINERALS REPORT OF IRIDIUM COMMUNICATIONS INC.
For the year ended December 31, 2023

This Conflict Minerals Report (this “Report”) of Iridium Communications Inc. (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934 for the reporting period January 1, 2023 to December 31, 2023 (the “Reporting Period”). For purposes of this Report, “Conflict Minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, the Company contracts to manufacture products for which Conflict Minerals are necessary to their functionality or production.

Description of the Company’s Products Covered by this Report

The Company is a provider of mobile voice and data communications services via satellite. The Company also sells related voice and data equipment that it contracts to manufacture, including satellite handsets, Wi-Fi accessories, voice and data modems, broadband data devices and machine-to-machine data devices. The Company has determined that Conflict Minerals are necessary to the functionality or production of this equipment. These products are collectively referred to in this Report as the “Covered Products.” This Report relates to Covered Products the manufacture of which was completed during the Reporting Period.

Reasonable Country of Origin Inquiry

The Company has conducted a good faith reasonable country-of-origin inquiry (“RCOI”) regarding the Conflict Minerals necessary to the Covered Products that was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources. The RCOI consisted principally of identifying the suppliers of components that contain Conflict Minerals and circulating to them a supply-chain survey using the Conflict Minerals Reporting Template of the Responsible Minerals Initiative (“RMI template”). Among the purposes of this supplier survey was to identify, if possible, the supply chain, including smelters and refiners that contribute smelted or refined Conflict Minerals to the Company’s products, and to request information from those identified suppliers and refiners regarding whether any of the necessary Conflict Minerals in the components they provided originated from Covered Countries and whether the Conflict Minerals come from recycled or scrap sources.

The Company’s Due Diligence Process

The Company’s due diligence measures were based on multi-industry initiatives with the smelters and refiners of Conflict Minerals that provide those Conflict Minerals to the Company’s suppliers. The Company’s supply chain with respect to the Covered Products is complex, and the Company, as a purchaser, is many steps removed from the mining and smelting or refining of the Conflict Minerals. The Company does not purchase raw ore or unrefined Conflict Minerals and does no purchasing in the Covered Countries. The origin of Conflict Minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other Conflict Mineral-containing derivatives. Because the smelters and refiners are consolidating points for raw ore, the Company believes the smelters and refiners are in the best position in the total supply chain to know the origin of the ores. As a result, tracing these



minerals to their sources is a challenge that requires the Company to enlist its suppliers in its efforts to achieve supply chain transparency, including its efforts to obtain information regarding the origin of the Conflict Minerals. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. Because of the Company’s relative location within the supply chain in relation to the actual extraction, transport, smelting, and refinement of Conflict Minerals, its ability to verify the accuracy of information reported by suppliers is limited.

In addition, the Company has regular contact with only a limited number of suppliers – its first-tier suppliers – within its supply chain. The second-tier suppliers report to the Company’s direct suppliers and contract manufacturers, some of which, like the Company, are subject to the SEC’s Rule and file specialized disclosure reports on Form SD annually as required. The Company has chosen to directly survey all of its second-tier suppliers in lieu of relying only on the surveying efforts of contract manufacturers or other direct suppliers. These efforts include, but are not limited to, requesting and receiving supplier RMI templates.

A.Design of the Company’s due diligence framework

The design of the Company’s due diligence measures conforms, in material respects, with the internationally recognized due diligence framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (OECD 2016) (“OECD Framework”), including related Supplements for each of the Conflict Minerals, consistent with the Company’s position as a downstream company.

Establish Strong Company Management Systems

Conflict Minerals Team. The Company maintains a Conflict Minerals Team comprised of senior members of its legal, manufacturing, engineering and purchasing organizations under the oversight of the Chief Legal Officer. The reference to the Company’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD and the Conflict Minerals Report nor deemed filed with the SEC.
Policy. The Company has communicated to its suppliers and the public the Company’s DRC Conflict Free Sourcing Policy for the supply chain of minerals originating from Conflict-Affected and High-Risk Areas (the “Policy”). The Policy can be found here: https://www.iridium.com/resources/resource-download/?resource-id=394231.
System of controls and transparency. The Company maintains internal standard operating procedures to guide the Company’s due diligence efforts. These procedures establish a process to be followed in order to generate and maintain the information needed to comply with Section 1502 of the Dodd-Frank Act.
Strengthen engagement with suppliers. The Company maintains a standard provision in its supply chain contracts under which the supplier agrees that it shall not knowingly include Conflict Minerals in any Covered Products that it delivers to the Company that originate from the Covered Countries. The provision further states that the supplier agrees to cooperate in any audit and produce any information that may reasonably be required by the Company to ensure that it fully complies with its legal and regulatory obligations that govern the use of Conflict Minerals. This provision also requests that this clause be included in agreements that each contract manufacturer may have with its suppliers, vendors, or subcontractors. Where a supplier includes Conflict Minerals in Covered Products that it delivers to the Company that originate from the Covered Countries from a smelter or refiner that has been validated as conflict-free by organizations such as RMI, the Company has elected to take no enforcement action.



Establish a company grievance mechanism. The Company maintains a grievance mechanism for concerned parties who wish to report information regarding the Company’s use of Conflict Minerals. Communications may be sent to supplychain@iridium.com.

Identify and Assess Risks in the Supply Chain

Identify smelters and refiners in the supply chain. The Company assessed its Covered Products and its suppliers in order to identify Conflict Minerals scope and risk. The Company’s Covered Products and suppliers were reviewed throughout the year. The Company looked for supplier changes in its supply chain and evaluated new suppliers for use of Conflict Minerals through a review of internal documents, including bills of material, materials declarations, and purchasing contracts. New suppliers were assessed as part of the Company’s vendor due diligence and compliance assessment program, which was designed to assess transparency from its vendors and compliance with the Company’s Conflict Minerals policy. Suppliers identified as providing parts to the Company that included Conflict Minerals were tracked through an information system that captures and categorizes supplier and product information.

The Company surveyed the suppliers on the Company’s master supplier list. The Company also conducted a survey of its direct and second-tier suppliers used by its contract manufacturers, Benchmark Electronics, Inc. and Beam Communications Pty Ltd., unless it was explicitly known from the material description or internal review that the material purchased did not contain Conflict Minerals. Due to the Company’s location within the supply chain relative to the actual extraction, transport, smelting, and refinement of ore, its ability to verify the accuracy of information reported by suppliers is limited. The Company requested that sourcing information provided by suppliers apply to materials provided for products the manufacture of which was completed during the entire Reporting Period.

Assessment of risk. All suppliers’ responses were assessed by evaluating the reasonableness and consistency of responses within the RMI template and follow-up email correspondence, as well as information known about supplies and suppliers. To the extent that, based on data provided by its suppliers, the Company was able to identify smelters and refiners that might be in the Company’s supply chain, the Company took steps to assess the smelter’s or refiner’s due diligence to the extent practicable. To that end, the Company examined whether each smelter or refiner had been validated as conflict-free through industry group programs, such as the RMI’s Responsible Minerals Assurance Process (“RMAP”). The RMAP provides a list of smelters and refiners that an independent third-party audit has confirmed have systems in place that comply with the RMAP’s assessment protocols to ensure sourcing of only conflict-free minerals.

Design and Implement Strategy to Respond to Identified Risks

Strategy to respond to identified risks. The Company has developed a strategy to manage suppliers that cannot or will not provide sufficient component and supply chain information or are using minerals from smelters or refiners that have not received a “conflict free” designation. The specific supplier corrective actions taken will depend on factors such as vendor size, risk level and vendor capabilities, and may include actions ranging from encouraging the supplier to source responsibly to disengaging from the supplier.

Steps taken to implement strategy to mitigate risk. The Company has completed the following steps to improve its due diligence process, improve its supply chain transparency, and to further mitigate the risk that its necessary Conflict Minerals finance or benefit armed groups in the Covered Countries, including:




Encourage supplier participation in an industry initiative such as iPoint, to increase compliance and response rate to suppliers’ smelter surveys.
Provide training materials for suppliers, if requested, on responsible sourcing to increase the response rate and improve the content of the supplier survey responses.
Develop and communicate a policy whereby suppliers that do not improve their responses in a timely fashion will be evaluated for potential removal as a preferred supplier from the Company’s supply chain.
Conduct independent research to attempt to identify and respond to risks in the Company’s supply chain.

Carry Out Independent Third-Party Audit of Supply Chain

The Company does not have any direct relationships with smelters or refiners that process Conflict Minerals, and it does not perform or direct audits of these entities within its supply chain. As an alternative, the Company has considered information collected and provided by independent third-party audit programs, such as the RMAP.

Report Annually on Supply Chain Due Diligence

The Company expects to report annually, as required by the Rule, and has posted this Report on its website here:
https://www.iridium.com/company-info/corporate-social-responsibility/sustainability/#conflict-minerals

B. Description of the Company’s due diligence measures performed with respect to Covered Products the manufacture of which was completed during 2023

Because, as a result of its RCOI, the Company could not determine the country of origin of all its necessary Conflict Minerals, the Company also performed due diligence on the source and chain of custody to determine whether the Conflict Minerals directly or indirectly financed or benefitted armed groups in the Covered Countries.

The Company’s due diligence measures performed with respect to Covered Products the manufacture of which was completed during 2023 included:

Providing a briefing to members of supply chain management about results of the Company’s due diligence efforts on a monthly basis. A member of senior management was briefed about the results of the Company’s due diligence efforts on a quarterly basis.
Keeping an up-to-date Policy. Inquiries with regard to Conflict Minerals are communicated to the Company’s supply chain information team.
Maintaining a standard contract template with a standard provision regarding Conflict Minerals. Any changes to the Company’s contracts or contracts in progress are subject to negotiation and the Company’s review and approval process.
Requesting a full list of supplier information from the Company’s contract manufacturers that have direct contact with suppliers in the supply chain.
Analyzing the bill of materials for each product to confirm all identified suppliers are included within the Company’s due diligence efforts.
Conducting its due diligence using the RMI template, requesting country-of-origin information regarding the necessary Conflict Minerals and identification of smelters and refiners that process such minerals.



Completing follow-up inquiries to obtain as much needed information as possible from as many surveyed suppliers as possible.
Comparing survey results to information collected via independent third-party conflict-free smelter validation programs, such as RMAP, to determine if the identified smelters or refiners have been validated as conflict-free.
Discussing with contract manufacturers actions to be taken with regard to suppliers that do not comply with the Policy.
Filing the specialized disclosure report on Form SD and related conflict minerals report annually as required by the SEC.Providing a briefing to members of supply chain management about results of the Company’s due diligence efforts on a monthly basis. A member of senior management was briefed about the results of the Company’s due diligence efforts on a quarterly basis.
Keeping an up-to-date Policy. Inquiries with regard to Conflict Minerals are communicated to the Company’s supply chain information team.
Maintaining a standard contract template with a standard provision regarding Conflict Minerals. Any changes to the Company’s contracts or contracts in progress are subject to negotiation and the Company’s review and approval process.
Requesting a full list of supplier information from the Company’s contract manufacturers that have direct contact with suppliers in the supply chain.
Analyzing the bill of materials for each product to confirm all identified suppliers are included within the Company’s due diligence efforts.
Conducting its due diligence using the RMI template, requesting country-of-origin information regarding the necessary Conflict Minerals and identification of smelters and refiners that process such minerals.
Completing follow-up inquiries to obtain as much needed information as possible from as many surveyed suppliers as possible.
Comparing survey results to information collected via independent third-party conflict-free smelter validation programs, such as RMAP, to determine if the identified smelters or refiners have been validated as conflict-free.
Discussing with contract manufacturers actions to be taken with regard to suppliers that do not comply with the Policy.
Filing the specialized disclosure report on Form SD and related conflict minerals report annually as required by the SEC.

C. Results of the Company’s Due Diligence

Identified Smelters and Refiners. As a result of the Company’s due diligence efforts and based on information provided by most of the Company’s suppliers, the Company has identified and obtained completed RMI templates from most of its suppliers that provide components containing necessary Conflict Minerals. However, in most cases, the information provided by suppliers was not specific enough to identify the smelters and refiners that processed the Conflict Minerals in the specific components provided by the supplier to the Company, but instead included information regarding the smelters and refiners that processed Conflict Minerals used by the responding supplier only on a company-wide or general product basis. As a result, in those cases, the Company has not been able to reasonably or reliably determine whether the identified smelters and refiners have been used to process Conflict Minerals in the components actually furnished to the Company for use in the Covered Products and thus did not include the smelters or refiners below. However, when the supplier provided information that reasonably appeared to be specific product-level information, the Company has listed on Appendix A the smelters or refiners identified by the supplier. Based on the information that was provided by the Company’s suppliers through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that may have been



used to process the necessary Conflict Minerals contained in the Covered Products included the smelters and refiners identified on Appendix A.

Identified Countries of Origin. Based on the information provided by suppliers pursuant to the due diligence process, the Company does not have sufficient information with respect to the Covered Products to reliably determine the countries of origin of all of the Conflict Minerals in the Covered Products. However, as noted above, when the supplier provided information that reasonably appeared to be specific product-level information, the Company has listed on Appendix B the countries of origin of the necessary Conflict Minerals identified by the supplier. When the supplier provided only company-level or general product information, the Company determined that it did not have sufficient information to identify with any reasonable level of confidence the particular countries of origin of the necessary Conflict Minerals contained in the component in the Covered Products, and thus did not include the country of origin. Accordingly, based on the information that has been obtained, the Company believes, to the extent reasonably determinable by the Company, that the countries of origin of the Conflict Minerals include the countries listed on Appendix B.

Efforts to Determine Mine or Location of Origin. The Company’s efforts to determine the mine(s) or location of origin with the greatest possible specificity included the use of the due diligence measures described above.

The Company received responses from 76% of its suppliers that provide components containing necessary Conflict Minerals. On the basis of the due diligence measures performed, the Company believes, to the extent reasonably determinable, that of the responses received, including specific product level, supplier defined, and broader company level responses, 26.2% of the suppliers from which the Company obtained sourcing information provided materials that contained Conflict Minerals that are of uncertain origin and 73.8% either (i) provided materials that did not contain Conflict Minerals, (ii) believe they provided materials containing Conflict Minerals not originating in the Covered Countries, or (iii) believe they provided materials containing Conflict Minerals that do originate from the Covered Countries but were processed using certified conflict-free smelters or refiners or from smelters or refiners that were “active” or “conformant” (as defined on Appendix A).

D. Measures to Improve Due Diligence

The Company currently expects to continue to perform its supply chain due diligence measures with the goal of achieving greater accuracy and transparency into the Company’s supply chain by reviewing supplier contracts and their Conflict Minerals policies on an as-needed basis to verify that relevant Conflict Mineral provisions are in place, developing the Company’s Conflict Mineral guidelines and procedures as needed, creating further awareness within the organization to promote positive change, and continually identifying areas of improvement.

Forward-Looking Statements

Forward-looking statements in this Report are made pursuant to the safe harbor provisions of Section 21E of the Exchange Act and other federal securities laws. Investors are cautioned that statements in this Report that are not strictly historical statements, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts, strategy, and future reporting constitute forward-looking statements that involve risks and uncertainties. Actual results could differ materially from the forward-looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and



other supply chain transparency and smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers, third-party audit programs or others as well as the possibility of future statutory and regulatory changes.





Appendix A

Conformant - The conformant status represents the smelters and refiners that have successfully completed an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment as reported by RMAP
Active - The active status represents smelters and refiners that have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment as reported by RMAP. These may be in the pre-assessment, assessment, or corrective-action phases of the assessment.
MetalSmelter IdentificationSmelter Reference ListSmelter CountryRMI Smelter List
GoldCID000707Heraeus Metals Hong Kong Ltd.CHINAConformant
GoldCID001761Solar Applied Materials Technology Corp.TAIWANConformant
GoldCID000077Argor-Heraeus S.A.SWITZERLANDConformant
GoldCID001153Metalor Technologies S.A.SWITZERLANDConformant
GoldCID001352PAMP S.A.SWITZERLANDConformant
GoldCID002003Valcambi S.A.SWITZERLANDConformant
GoldCID002224Zhongyuan Gold Smelter of Zhongjin Gold CorporationCHINAConformant
GoldCID001512Rand Refinery (Pty) Ltd.SOUTH AFRICAConformant
GoldCID001875Tanaka Kikinzoku Kogyo K.K.JAPANConformant
GoldCID001188Mitsubishi Materials CorporationJAPANConformant
GoldCID000920Asahi Refining USA Inc.UNITED STATES OF AMERICAConformant
GoldCID001119Matsuda Sangyo Co., Ltd.JAPANConformant
GoldCID001259Nihon Material Co., Ltd.JAPANConformant
GoldCID000082Asahi Pretec Corp.JAPANConformant
GoldCID000425Eco-System Recycling Co., Ltd.JAPANConformant
GoldCID000807Ishifuku Metal Industry Co., Ltd.JAPANConformant
GoldCID000937JX Nippon Mining & Metals Co., Ltd.JAPANConformant
GoldCID001193Mitsui Mining and Smelting Co., Ltd.JAPANConformant
GoldCID001798Sumitomo Metal Mining Co., Ltd.JAPANConformant
GoldCID000401DowaJAPANConformant
GoldCID002030Western Australian Mint (T/a The Perth Mint)AUSTRALIAConformant
GoldCID000981Kojima Chemicals Co., Ltd.JAPANConformant
GoldCID001938Tokuriki Honten Co., Ltd.JAPANConformant
GoldCID000019Aida Chemical Industries Co., Ltd.JAPANConformant
GoldCID001078LS-NIKKO Copper Inc.KOREA, REPUBLIC OFConformant
GoldCID000090Asaka Riken Co., Ltd.JAPANConformant
GoldCID001622Shandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINAConformant
GoldCID001916The Refinery of Shandong Gold Mining Co., Ltd.CHINAConformant
GoldCID001993United Precious Metal Refining, Inc.UNITED STATES OF AMERICAConformant
GoldCID001152Metalor Technologies (Singapore) Pte., Ltd.SINGAPOREConformant



GoldCID000035Agosi AGGERMANYConformant
GoldCID000058AngloGold Ashanti Corrego do Sitio MineracaoBRAZILConformant
GoldCID000924Asahi Refining Canada Ltd.CANADAConformant
GoldCID000113Aurubis AGGERMANYConformant
GoldCID000157Boliden ABSWEDENConformant
GoldCID000176C. Hafner GmbH + Co. KGGERMANYConformant
GoldCID000233Chimet S.p.A.ITALYConformant
GoldCID000694Heimerle + Meule GmbHGERMANYConformant
GoldCID000801Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINAConformant
GoldCID000814Istanbul Gold RefineryTURKEYConformant
GoldCID000969Kennecott Utah Copper LLCUNITED STATES OF AMERICAConformant
GoldCID001149Metalor Technologies (Hong Kong) Ltd.CHINAConformant
GoldCID001147Metalor Technologies (Suzhou) Ltd.CHINAConformant
GoldCID001157Metalor USA Refining CorporationUNITED STATES OF AMERICAConformant
GoldCID001161Metalurgica Met-Mex Penoles S.A. De C.V.MEXICOConformant
GoldCID001220Nadir Metal Rafineri San. Ve Tic. A.S.TURKEYConformant
GoldCID001534Royal Canadian MintCANADAConformant
GoldCID001980Umicore S.A. Business Unit Precious Metals RefiningBELGIUMConformant
GoldCID002243Gold Refinery of Zijin Mining Group Co., Ltd.CHINAConformant
GoldCID000015Advanced Chemical CompanyUNITED STATES OF AMERICAActive
GoldCID000041Almalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANConformant
GoldCID000128Bangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESConformant
GoldCID000185CCR Refinery - Glencore Canada CorporationCANADAConformant
GoldCID000264Chugai MiningJAPANConformant
GoldCID000359DSC (Do Sung Corporation)KOREA, REPUBLIC OFConformant
GoldCID000689LT Metal Ltd.KOREA, REPUBLIC OFConformant
GoldCID000711Heraeus Germany GmbH Co. KGGERMANYConformant
GoldCID000823Japan MintJAPANConformant
GoldCID000855Jiangxi Copper Co., Ltd.CHINAConformant
GoldCID000957KazzincKAZAKHSTANConformant
GoldCID001113MaterionUNITED STATES OF AMERICAConformant
GoldCID001236Navoi Mining and Metallurgical CombinatUZBEKISTANConformant
GoldCID001325Ohura Precious Metal Industry Co., Ltd.JAPANConformant
GoldCID001397PT Aneka Tambang (Persero) TbkINDONESIAConformant
GoldCID001498PX Precinox S.A.SWITZERLANDConformant
GoldCID001585SEMPSA Joyeria Plateria S.A.SPAINConformant



GoldCID001736Sichuan Tianze Precious Metals Co., Ltd.CHINAConformant
GoldCID001955TorecomKOREA, REPUBLIC OFConformant
GoldCID002100Yamakin Co., Ltd.JAPANConformant
GoldCID002129Yokohama Metal Co., Ltd.JAPANConformant
GoldCID002290SAFINA A.S.CZECHIAConformant
GoldCID002314Umicore Precious Metals ThailandTHAILAND
GoldCID002459Geib Refining CorporationUNITED STATES OF AMERICA
GoldCID002509MMTC-PAMP India Pvt., Ltd.INDIAConformant
GoldCID002511KGHM Polska Miedz Spolka AkcyjnaPOLANDConformant
GoldCID002560Al Etihad Gold Refinery DMCCUNITED ARAB EMIRATES
GoldCID002561Emirates Gold DMCCUNITED ARAB EMIRATES
GoldCID002580T.C.A S.p.AITALYConformant
GoldCID002582REMONDIS PMR B.V.NETHERLANDSConformant
GoldCID002605Korea Zinc Co., Ltd.KOREA, REPUBLIC OFConformant
GoldCID002615TOO Tau-Ken-AltynKAZAKHSTANConformant
GoldCID002761SAAMPFRANCE
GoldCID002762L'Orfebre S.A.ANDORRAConformant
GoldCID0027638853 S.p.A.ITALYConformant
GoldCID002765ItalpreziosiITALYConformant
GoldCID002778WIELAND Edelmetalle GmbHGERMANYConformant
GoldCID002779Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIAConformant
GoldCID002863Bangalore RefineryINDIAActive
GoldCID002918SungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFConformant
GoldCID002919Planta Recuperadora de Metales SpACHILEConformant
GoldCID002973Safimet S.p.AITALY
GoldCID003424Eco-System Recycling Co., Ltd. North PlantJAPANConformant
GoldCID003425Eco-System Recycling Co., Ltd. West PlantJAPANConformant
GoldCID003575Metal Concentrators SA (Pty) Ltd.SOUTH AFRICAConformant
GoldCID003189NH Recytech CompanyKOREA, REPUBLIC OFConformant
TantalumCID002545H.C. Starck Tantalum and Niobium GmbHGERMANYConformant
TantalumCID001192Mitsui Mining and Smelting Co., Ltd.JAPANConformant
TantalumCID001869Taki Chemical Co., Ltd.JAPANConformant
TantalumCID000917Jiujiang Tanbre Co., Ltd.CHINAConformant
TantalumCID000291Guangdong Rising Rare Metals-EO Materials Ltd.CHINAActive
TantalumCID001277Ningxia Orient Tantalum Industry Co., Ltd.CHINAConformant
TantalumCID002557Global Advanced Metals BoyertownUNITED STATES OF AMERICAConformant
TantalumCID000460F&X Electro-Materials Ltd.CHINAConformant



TantalumCID002548H.C. Starck Inc.UNITED STATES OF AMERICAConformant
TantalumCID002558Global Advanced Metals AizuJAPANConformant
TantalumCID000211Changsha South Tantalum Niobium Co., Ltd.CHINAConformant
TantalumCID000616XIMEI RESOURCES (GUANGDONG) LIMITEDCHINAConformant
TantalumCID000914JiuJiang JinXin Nonferrous Metals Co., Ltd.CHINAConformant
TantalumCID001076AMG BrasilBRAZILConformant
TantalumCID001163Metallurgical Products India Pvt., Ltd.INDIAConformant
TantalumCID001175Mineracao Taboca S.A.BRAZILConformant
TantalumCID001200NPM Silmet ASESTONIAConformant
TantalumCID001508QuantumCleanUNITED STATES OF AMERICAConformant
TantalumCID001522Yanling Jincheng Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumCID001891Telex MetalsUNITED STATES OF AMERICAConformant
TantalumCID001969Ulba Metallurgical Plant JSCKAZAKHSTANConformant
TantalumCID002492Hengyang King Xing Lifeng New Materials Co., Ltd.CHINAConformant
TantalumCID002504D Block Metals, LLCUNITED STATES OF AMERICAConformant
TantalumCID002505FIR Metals & Resource Ltd.CHINAConformant
TantalumCID002506Jiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumCID002512Jiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumCID002539KEMET de MexicoMEXICOConformant
TantalumCID002544TANIOBIS Co., Ltd.THAILANDConformant
TantalumCID002549TANIOBIS Japan Co., Ltd.JAPANConformant
TantalumCID002550TANIOBIS Smelting GmbH & Co. KGGERMANYConformant
TantalumCID002707Resind Industria e Comercio Ltda.BRAZILConformant
TantalumCID002842Jiangxi Tuohong New Raw MaterialCHINAConformant
TantalumCID003583RFH Yancheng Jinye New Material Technology Co., Ltd.CHINAConformant
TinCID000228Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINAConformant
TinCID000292AlphaUNITED STATES OF AMERICAConformant
TinCID000309PT Aries Kencana SejahteraINDONESIAConformant
TinCID000402DowaJAPANConformant
TinCID000438EM VintoBOLIVIA (PLURINATIONAL STATE OF)Conformant
TinCID000468Fenix MetalsPOLANDConformant
TinCID000538Gejiu Non-Ferrous Metal Processing Co., Ltd.CHINAConformant
TinCID001070China Tin Group Co., Ltd.CHINAConformant
TinCID001105Malaysia Smelting Corporation (MSC)MALAYSIAConformant



TinCID001142Metallic Resources, Inc.UNITED STATES OF AMERICAConformant
TinCID001173Mineracao Taboca S.A.BRAZILConformant
TinCID001182MinsurPERUConformant
TinCID001191Mitsubishi Materials CorporationJAPANConformant
TinCID001231Jiangxi New Nanshan Technology Ltd.CHINAConformant
TinCID001314O.M. Manufacturing (Thailand) Co., Ltd.THAILANDConformant
TinCID001337Operaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)Conformant
TinCID001399PT Artha Cipta LanggengINDONESIAConformant
TinCID001402PT Babel Inti PerkasaINDONESIAConformant
TinCID001406PT Babel Surya Alam LestariINDONESIAConformant
TinCID001428PT Bukit TimahINDONESIAConformant
TinCID001453PT Mitra Stania PrimaINDONESIAConformant
TinCID001458PT Prima Timah UtamaINDONESIAConformant
TinCID001460PT Refined Bangka TinINDONESIAConformant
TinCID001463PT Sariwiguna BinasentosaINDONESIAConformant
TinCID001477PT Timah Tbk KundurINDONESIAConformant
TinCID001482PT Timah Tbk MentokINDONESIAConformant
TinCID001493PT Tommy UtamaINDONESIAConformant
TinCID001539Rui Da HungTAIWANConformant
TinCID001898ThaisarcoTHAILANDConformant
TinCID002158Yunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINAConformant
TinCID002180Tin Smelting Branch of Yunnan Tin Co., Ltd.CHINAConformant
TinCID002455CV Venus Inti PerkasaINDONESIAConformant
TinCID002503PT ATD Makmur Mandiri JayaINDONESIAConformant
TinCID002517O.M. Manufacturing Philippines, Inc.PHILIPPINESConformant
TinCID002696PT Cipta Persada MuliaINDONESIAConformant
TinCID002773Aurubis BeerseBELGIUMConformant
TinCID002774Aurubis BerangoSPAINConformant
TinCID002816PT Sukses Inti MakmurINDONESIAConformant
TinCID002835PT Menara Cipta MuliaINDONESIAConformant
TinCID003116Guangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINAConformant
TinCID003190Chifeng Dajingzi Tin Industry Co., Ltd.CHINAConformant
TinCID003205PT Bangka SerumpunINDONESIAConformant
TinCID003325Tin Technology & RefiningUNITED STATES OF AMERICAConformant
TinCID003381PT Rajawali Rimba PerkasaINDONESIAConformant
TinCID003387Luna Smelter, Ltd.RWANDAConformant
TinCID003449PT Mitra Sukses GlobalindoINDONESIAConformant
TinCID003524CRM SynergiesSPAINConformant
TinCID003582Fabrica Auricchio Industria e Comercio Ltda.BRAZILConformant



TinCID003868PT Putera Sarana Shakti (PT PSS)INDONESIAConformant
TinCID000315CV United SmeltingINDONESIA
TinCID001468PT Stanindo Inti PerkasaINDONESIAConformant
TinCID001434PT DS Jaya AbadiINDONESIA
TinCID002036White Solder Metalurgia e Mineracao Ltda.BRAZILConformant
TinCID001486PT Timah NusantaraINDONESIAConformant
TinCID002468Magnu's Minerais Metais e Ligas Ltda.BRAZILConformant
TinCID002706Resind Industria e Comercio Ltda.BRAZILConformant
TinCID000448Estanho de Rondonia S.A.BRAZILConformant
TinCID002570CV Ayi JayaINDONESIAConformant
TinCID001490PT Tinindo Inter NusaINDONESIAConformant
TungstenCID000568Global Tungsten & Powders Corp.UNITED STATES OF AMERICAConformant
TungstenCID002541H.C. Starck Tungsten GmbHGERMANYConformant
TungstenCID002513Chenzhou Diamond Tungsten Products Co., Ltd.CHINAConformant
TungstenCID002082Xiamen Tungsten Co., Ltd.CHINAConformant
TungstenCID000875Ganzhou Huaxing Tungsten Products Co., Ltd.CHINA
TungstenCID000769Hunan Chunchang Nonferrous Metals Co., Ltd.CHINA
TungstenCID002320Xiamen Tungsten (H.C.) Co., Ltd.CHINAConformant
TungstenCID000004A.L.M.T. Corp.JAPANConformant
TungstenCID000105Kennametal HuntsvilleUNITED STATES OF AMERICAConformant
TungstenCID000258Chongyi Zhangyuan Tungsten Co., Ltd.CHINAConformant
TungstenCID000825Japan New Metals Co., Ltd.JAPANConformant
TungstenCID000218Guangdong Xianglu Tungsten Co., Ltd.CHINAConformant
TungstenCID000766Hunan Chenzhou Mining Co., Ltd.CHINAConformant
TungstenCID000966Kennametal FallonUNITED STATES OF AMERICAConformant
TungstenCID002044Wolfram Bergbau und Hutten AGAUSTRIAConformant
TungstenCID002315Ganzhou Jiangwu Ferrotungsten Co., Ltd.CHINAConformant
TungstenCID002316Jiangxi Yaosheng Tungsten Co., Ltd.CHINAConformant
TungstenCID002317Jiangxi Xinsheng Tungsten Industry Co., Ltd.CHINAConformant
TungstenCID002318Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINAConformant
TungstenCID002319Malipo Haiyu Tungsten Co., Ltd.CHINAConformant
TungstenCID002321Jiangxi Gan Bei Tungsten Co., Ltd.CHINAConformant
TungstenCID002494Ganzhou Seadragon W & Mo Co., Ltd.CHINAConformant
TungstenCID002502Asia Tungsten Products Vietnam Ltd.VIET NAMConformant
TungstenCID002542TANIOBIS Smelting GmbH & Co. KGGERMANYConformant
TungstenCID002543Masan High-Tech MaterialsVIET NAMConformant
TungstenCID002551Jiangwu H.C. Starck Tungsten Products Co., Ltd.CHINAConformant



TungstenCID002589Niagara Refining LLCUNITED STATES OF AMERICAConformant
TungstenCID002641China Molybdenum Tungsten Co., Ltd.CHINAConformant
TungstenCID002645Ganzhou Haichuang Tungsten Co., Ltd.CHINA
TungstenCID002827Philippine Chuangxin Industrial Co., Inc.PHILIPPINESConformant
TungstenCID002833ACL Metais EireliBRAZIL
TungstenCID003407Lianyou Metals Co., Ltd.TAIWANConformant
TungstenCID003468Cronimet Brasil LtdaBRAZILConformant
TungstenCID003609Fujian Xinlu Tungsten Co., Ltd.CHINAConformant
TungstenCID003417Hubei Green Tungsten Co., Ltd.CHINAConformant

Appendix B

Country of Origin
China
Indonesia
Malaysia
Taiwan
Peru
Myanmar

Note: Based on RMAP information, the Conflict Minerals known to be sourced from the above countries of origin were from smelters or refiners that were either Active or Conformant during the Reporting Period.