EX-1.01 2 exhibit1012021formsd.htm EX-1.01 Document

Exhibit 1.01
Conflict Minerals Disclosure
Introduction
Trane Technologies plc has conducted a reasonable country of origin inquiry ("RCOI") regarding the minerals specified by Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “conflict minerals”) necessary to the functionality or production of products manufactured by the Company for the fiscal year ended December 31, 2021. The Company exercised due diligence on the source and chain of custody of its conflict minerals using the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”).

Company Overview
The Company is a global climate innovator. The Company brings sustainable and efficient solutions to buildings, homes and transportation through the Company's strategic brands, Trane® and Thermo King®, and its environmentally responsible portfolio of products, services and connected intelligent controls. The Company generates revenue and cash primarily through the design, manufacture, sale and service of solutions for Heating, Ventilation and Air Conditioning (HVAC) and transport refrigeration. As an industry leader with an extensive global install base, the Company’s growth strategy includes expanding recurring revenue through services and rental options. The Company’s unique business operating system, uplifting culture and highly engaged team around the world are also central to its earnings and cash flow growth.

Starting in 2022, the Company operates under four regional operating segments designed to create deep customer focus and relevance in markets around the world. The Company determined that its two Europe, Middle East and Africa (EMEA) operating segments meet the aggregation criteria based on similar operating and economic characteristics, resulting in one reportable segment. Therefore, the Company has three regional reportable segments, Americas, EMEA and Asia Pacific. Intercompany sales between segments are immaterial.

The Company's Americas segment innovates for customers in North America and Latin America. The Americas segment encompasses commercial heating and cooling systems, building controls, and energy services and solutions; residential heating and cooling; and transport refrigeration systems and solutions.

The Company's EMEA segment innovates for customers in the Europe, Middle East and Africa region. The EMEA segment encompasses heating and cooling systems, services and solutions for commercial buildings, and transport refrigeration systems and solutions.

The Company's Asia Pacific segment innovates for customers throughout the Asia Pacific region. The Asia Pacific segment encompasses heating and cooling systems, services and solutions for commercial buildings and transport refrigeration systems and solutions.



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Product Overview
Our principal products and services as of December 31, 2021 included the following:

Air conditioners
Indoor air quality assessments and related products for HVAC and Transport solutions
Air exchangers
Industrial refrigeration
Air handlers
Installation contracting
Airside and terminal devices
Large commercial unitary
Auxiliary power units (electric and diesel)
Light commercial unitary
Building management systems
Motor replacements
Bus air purification systems
Multi-pipe HVAC systems
Chillers
Package heating and cooling systems
Coils and condensers
Parts and supplies (aftermarket and OEM)
Container refrigeration systems and gensets
Performance contracting
Control systems
Rail refrigeration systems
Cryogenic refrigeration systems
Rate chambers
Diesel-powered refrigeration systems
Refrigerant reclamation
Ductless systems
Repair and maintenance services
Electric-powered trailer refrigeration systems
Rental services
Electric-powered truck refrigeration systems
Self-powered truck refrigeration systems
Energy management services
Service agreements
Facility management services
Temporary heating and cooling systems
Furnaces
Thermostats/controls
Geothermal systems
Trailer refrigeration systems
Heat pumps
Transport heater products
Home automation
Ultra-low temperature freezers
Humidifiers
Unitary systems (light and large)
Hybrid and non-diesel transport refrigeration solutions
Variable refrigerant flow
Hybrid-powered trailer refrigeration
Vehicle-powered truck refrigeration systems
Ice energy storage solutions
Water source heat pumps

These products are sold primarily under our tradenames including Trane® and Thermo King®.

Description of Reasonable Country of Origin Inquiry     
We conducted a Reasonable Country of Origin Inquiry (an “RCOI”) regarding the conflict minerals by utilizing the conflict minerals reporting template (“CMRT”) developed by the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”). We also performed due diligence work on the source and chain of custody of our conflict minerals using the OECD Framework, an internationally recognized due diligence framework. We primarily rely on the conflict-free smelter program designed and managed by the Responsible Minerals Initiative (“RMI”) (formerly known as the Conflict-Free Sourcing Initiative) to conduct our risk assessment.
Determination
We were unable to determine that all the conflict minerals contained in our products do not originate from the Covered Countries due to, among other things, the following:

Many of our suppliers submitted responses that were declared on a company-wide basis (i.e., representing the smelters and refiners associated with all product offerings of the supplier that contained conflict minerals) and not specific to the materials supplied to the Company. Therefore, in combination with multiple layers in our supply chain, we believe that these declarations might include smelters and refiners that do not provide the conflict minerals that are in our products.

A number of our suppliers identified smelters/refiners that do not participate in the Responsible Minerals Assurance Process (“RMAP”) or a similar program and other suppliers failed to identify any smelter/refiner in their responses to
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us. Furthermore, we were unable to obtain responses from all of our suppliers and other suppliers provided incomplete or inconsistent data.
    
As a result, we do not have sufficient information to conclusively determine the country of origin of all of the conflict minerals in our products and, if such conflict minerals did originate in the Covered Countries, whether such conflict minerals were from recycled or scrap sources or were from other conflict free sources. Accordingly, the Company conducted the due diligence measures described below.
Due Diligence

In accordance with Rule 13p-1, the Company performed due diligence to determine the source and chain of custody necessary to determine the presence of conflict minerals in the Company’s products. The Company designed its due diligence measures to conform in all material respects with the OECD Framework and related supplements for each of the conflict minerals.

The Company, as a purchaser, is many steps removed from the mining of conflict minerals and does not purchase raw ore or unrefined conflict minerals. Identifying the presence and 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. Although the smelters and refiners are consolidating points for raw ore and are in the best position in the supply chain to know the origin of the ores, the Company focused its efforts on its suppliers in an effort to build conflict minerals awareness and assess the transparency of its supply chain and make initial identification, where possible, of the smelters/refiners in its supply chain.

The discussion below provides the applicable OECD Framework recommendation (in bold/italics) followed by a summary of the Company’s activities in line with the OECD Framework.

1.     Management Systems.

The Company adopted a Conflict Minerals Policy in 2013. The policy requires suppliers to perform due diligence and outlines the Company’s expectation of suppliers. During 2014, the Company revised and strengthened the policy. During 2021, the Company continued to communicate the policy to suppliers and the public through its website, letters sent to suppliers and customers and telephone calls.
Internal Management Systems.

The Company’s conflict minerals compliance program for the fiscal year ended December 31, 2021 was managed by a cross-functional team lead by procurement and including representatives from procurement, legal and finance. This team discussed conflict minerals compliance issues and reviewed the status of the diligence process.

Control System and Supply Chain Transparency

The Company implemented a process to evaluate commodities and suppliers in the supply chain for potential conflict minerals risk and an internal process map for the conflict minerals process that is subject to periodic reviews. Supplier agreement templates require suppliers and licensees to provide information on their use and source of conflict minerals. Given the size and complexity of the Company's global supply chain, the Company focused on its largest suppliers, ranked by the amount the Company spends with each such supplier, and suppliers that had the highest probability of supplying the Company with materials or components containing conflict minerals (the “Targeted Suppliers”). For 2021, this group represented, greater than 82% of the Company's in-scope suppliers by spend. The Company requested supply chain information from Targeted Suppliers utilizing templates developed by the EICC and GeSI. During 2021, the Company distributed the CMRT to Targeted Suppliers using Gensuite, a third party vendor, tracked responses and followed up with unresponsive suppliers. The Company maintains records relating to its annual supplier survey.
Supplier Engagement

The Company's standard global terms and conditions include a conflict minerals clause. The Company's standard procurement contracts also contain a conflict minerals clause. In 2021, the Company maintained its preferred supplier program. In order to be designated as a preferred supplier of the Company, a supplier must supply any required conflict minerals information to the Company and comply with other required criteria.



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Grievance Mechanism

The Company has an e-mail address for receiving conflict minerals communications internally and an external e-mail mechanism through the Company’s public website. The Company intends to treat grievances as red flags for purposes of the due diligence process.

2.     Identify and assess risk in the supply chain.

The Company works with its commodity team and engineering team as appropriate to review the commodities necessary for the manufacture of its products to determine the associated level of risk of containing conflict minerals focusing its due diligence efforts on commodities at the highest risk.

Following the identification of the commodities, the Company requires Targeted Suppliers to complete a survey using the EICC-GeSI template at a company and parts level. The Company reviews survey responses for completeness and compiles aggregate survey responses. The Company follows up with suppliers when responses are incomplete or other questions are raised by the responses. The Company tracks response rates and red flags as part of its conflict minerals reporting process.

3.     Design and implement a strategy to respond to identified risks.

The Company developed a strategy to systematically reduce the extent of exposure to certain risk and the likelihood of its occurrence. Steps taken include communicating a policy to Targeted Suppliers noting that suppliers must thoroughly document their efforts to determine the source of any conflict minerals or derivatives and be prepared to provide the Company with evidence of the origin of any conflict minerals contained in products supplied to the Company. The strategy uses a documented escalation process for suppliers who fail to respond, which may result in termination of the supplier’s relationship with the Company and/or failure to be considered for future projects with the Company.

The Company has created a standard due diligence process, has engaged in a gap analysis regarding its conflict minerals process, and has monitored and tracked responses to its conflict minerals requests as well as its escalation efforts. Senior management is updated as needed. Additional fact finding, risk assessments and evaluations of changes in circumstances take place as part of the Company’s annual review of processes and procedures.
    
4.    Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain. Companies at identified points in the supply chain should have their due diligence practices audited by independent third parties.

In 2014, the Company engaged an independent third party to provide a review of the Company’s conflict minerals compliance program including review of its existing conflict minerals policy and due diligence process. The Company implemented enhancements to the program in 2014 and 2015 as a result of this review. In 2021, the Company continued its membership in the RMI. The Company continued to implement steps using information from the RMI to conduct a review of summary smelter information to determine if the smelter is certified as conflict free or presents a “red flag” as defined by the OECD Guidance as part of its diligence related to 2021 supplier survey responses.

5.     Report on supply chain due diligence.

The Company has complied with its SEC filing requirement regarding its conflict minerals program and due diligence by the filing of this report. The Company has made this report available on its external website at https://www.tranetechnologies.com/en/index/company/doing-business-with-us/conflict-minerals.html and has included its conflict minerals policy and other resources at that web address. The Company continues to refine and improve its conflict minerals policy, questionnaire and processes, and to expand awareness regarding its conflict minerals policies.

Results of Due Diligence

After performing the due diligence described above, we are unable to determine that all the conflict minerals contained in the products described above did not originate from the Covered Countries. For the reasons stated in this report, we also do not have sufficient information to conclusively determine the country of origin of all of the conflict minerals in our products described below and, if such conflict minerals did originate in the Covered Countries, whether such conflict minerals were from recycled or scrap sources or were from other conflict free sources.

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We have provided this information as of the date of this report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to provide us with complete information, may affect our future determinations under the Rule.

Information on Smelters or Refiners
The CMRT requested that the Targeted Suppliers provide the Company with information on the smelters or refiners that the Targeted Suppliers and its suppliers use to supply conflict minerals to the Company. Because the Company does not typically have a direct relationship with the facilities used to process conflict minerals, we must rely on information provided by the Targeted Suppliers. Some responses from the Targeted Suppliers indicated that they were unable to provide smelter or refiner information at this time. Other Targeted Suppliers provided information on all smelters or refiners used by the Targeted Supplier but could not provide information linking specific smelters or refiners used to process conflict minerals with products provided to the Company. Some Targeted Suppliers provided names that the suppliers described as “smelters” but such names could not be linked to smelters on the RMI list, and may not, in fact, be smelters. Based on the information provided by the Targeted Suppliers, the Company has identified 389 smelters from the RMI list, of which 230 have been validated as audited and found conformant with the relevant RMAP standard. These smelters are included in the list attached as Annex 1 to this report.
Steps to Improve Due Diligence

The Company continues to identify opportunities to improve its due diligence and mitigate risk relating to conflict minerals. Below are some of the steps that the Company is considering taking:

Continuation of supplier engagement;
Continuation of company membership in RMI;
Continuation of our supplier engagement and training and encouraging suppliers to use training resources available through industry associations and the RMI; and
Encouraging supplier and other company membership and participation in RMI.
Cautionary Statement about Forward-Looking Statements
Certain statements in this report, other than purely historical information, are “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995, Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These forward-looking statements generally are identified by the words “believe,” “project,” “expect,” “anticipate,” “estimate,” “forecast,” “outlook,” “intend,” “strategy,” “plan,” “may,” “should,” “will,” "could," “would,” “will be,” “will continue,” “will likely result,” or the negative thereof or variations thereon or similar terminology generally intended to identify forward-looking statements.

Forward-looking statements are based on currently available information and our current assumptions, expectations and projections about future events. While we believe that our assumptions, expectations and projections are reasonable in view of the currently available information, you are cautioned not to place undue reliance on our forward-looking statements. You are advised to review any further disclosures we make on related subjects in materials we file with or furnish to the SEC. Forward-looking statements speak only as of the date they are made and are not guarantees of future performance. They are subject to future events, risks and uncertainties - many of which are beyond our control - as well as potentially inaccurate assumptions, that could cause actual results to differ materially from our expectations and projections. We do not undertake to update any forward-looking statements.











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Annex 1

Metal
Smelter Name
Country
Gold
NH Recytech Company
Korea, Republic of
Gold
Safimet S.p.A
Italy
Gold
PAMP S.A.
Switzerland
Gold
Planta Recuperadora de Metales SpA
Chile
Gold
PT Aneka Tambang (Persero) Tbk
Indonesia
Gold
Ohura Precious Metal Industry Co., Ltd.
Japan
Gold
Materion
United States
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
Gold
Western Australian Mint (T/a The Perth Mint)
Australia
Gold
Torecom
Korea, Republic of
Gold
Umicore S.A. Business Unit Precious Metals Refining
Belgium
Gold
United Precious Metal Refining, Inc.
United States
Gold
Valcambi S.A.
Switzerland
Gold
Shandong Gold Smelting Co., Ltd.
China
Gold
Tokuriki Honten Co., Ltd.
Japan
Gold
Sumitomo Metal Mining Co., Ltd.
Japan
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
Gold
Sichuan Tianze Precious Metals Co., Ltd.
China
Gold
PX Precinox S.A.
Switzerland
Gold
Rand Refinery (Pty) Ltd.
South Africa
Gold
Royal Canadian Mint
Canada
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
Turkey
Gold
Navoi Mining and Metallurgical Combinat
Uzbekistan
Gold
Nihon Material Co., Ltd.
Japan
Gold
Matsuda Sangyo Co., Ltd.
Japan
Gold
Mitsubishi Materials Corporation
Japan
Gold
Mitsui Mining and Smelting Co., Ltd.
Japan
Gold
LS-NIKKO Copper Inc.
Korea, Republic of
Gold
Asahi Refining USA Inc.
United States
Gold
Asahi Refining Canada Ltd.
Canada
Gold
Marsam Metals
Brazil
Gold
LT Metal Ltd.
Korea, Republic of
Gold
8853 S.p.A.
Italy
Gold
Italpreziosi
Italy
Gold
Metal Concentrators SA (Pty) Ltd.
South Africa
Gold
Eco-System Recycling Co., Ltd. North Plant
Japan
Gold
Eco-System Recycling Co., Ltd. West Plant
Japan
Gold
Metalor Technologies (Hong Kong) Ltd.
China
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Singapore
Gold
Metalor Technologies S.A.
Switzerland
Gold
Metalor USA Refining Corporation
United States
Gold
Samduck Precious Metals
Korea, Republic of
Gold
SEMPSA Joyeria Plateria S.A.
Spain
Gold
Metalor Technologies (Suzhou) Ltd.
China
Gold
Kazzinc
Kazakhstan
Gold
Kennecott Utah Copper LLC
United States
6


Gold
Kojima Chemicals Co., Ltd.
Japan
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
China
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
Gold
Istanbul Gold Refinery
Turkey
Gold
Japan Mint
Japan
Gold
Heimerle + Meule GmbH
Germany
Gold
Heraeus Metals Hong Kong Ltd.
China
Gold
Heraeus Germany GmbH Co. KG
Germany
Gold
DSC (Do Sung Corporation)
Korea, Republic of
Gold
Dowa
Japan
Gold
Eco-System Recycling Co., Ltd. East Plant
Japan
Gold
Aurubis AG
Germany
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
Gold
Boliden AB
Sweden
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
China
Gold
Solar Applied Materials Technology Corp.
Taiwan
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
Brazil
Gold
Argor-Heraeus S.A.
Switzerland
Gold
Asahi Pretec Corp.
Japan
Gold
Advanced Chemical Company
United States
Gold
Aida Chemical Industries Co., Ltd.
Japan
Gold
Agosi AG
Germany
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Uzbekistan
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
Mexico
Gold
Chimet S.p.A.
Italy
Gold
Chugai Mining
Japan
Gold
C. Hafner GmbH + Co. KG
Germany
Gold
Jiangxi Copper Co., Ltd.
China
Gold
CCR Refinery - Glencore Canada Corporation
Canada
Gold
Cendres + Metaux S.A.
Switzerland
Gold
Asaka Riken Co., Ltd.
Japan
Gold
SungEel HiMetal Co., Ltd.
Korea, Republic of
Gold
Bangalore Refinery
India
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Austria
Gold
L'Orfebre S.A.
Andorra
Gold
WIELAND Edelmetalle GmbH
Germany
Gold
TOO Tau-Ken-Altyn
Kazakhstan
Gold
SAAMP
France
Gold
Korea Zinc Co., Ltd.
Korea, Republic of
Gold
T.C.A S.p.A
Italy
Gold
REMONDIS PMR B.V.
Netherlands
Gold
Emirates Gold DMCC
United Arab Emirates
Gold
Al Etihad Gold Refinery DMCC
United Arab Emirates
Gold
Singway Technology Co., Ltd.
Taiwan
Gold
MMTC-PAMP India Pvt., Ltd.
India
Gold
KGHM Polska Miedz Spolka Akcyjna
Poland
Gold
Geib Refining Corporation
United States
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
China
Gold
SAFINA A.S.
Czech Republic
7


Gold
Umicore Precious Metals Thailand
Thailand
Gold
Yamakin Co., Ltd.
Japan
Gold
Yokohama Metal Co., Ltd.
Japan
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Tantalum
RFH Yancheng Jinye New Material Technology Co., Ltd.
China
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
China
Tantalum
Jiujiang Tanbre Co., Ltd.
China
Tantalum
Resind Industria e Comercio Ltda.
Brazil
Tantalum
Mineracao Taboca S.A.
Brazil
Tantalum
Metallurgical Products India Pvt., Ltd.
India
Tantalum
QuantumClean
United States
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
China
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China
Tantalum
Mitsui Mining and Smelting Co., Ltd.
Japan
Tantalum
NPM Silmet AS
Estonia
Tantalum
AMG Brasil
Brazil
Tantalum
Ulba Metallurgical Plant JSC
Kazakhstan
Tantalum
Solikamsk Magnesium Works OAO
Russian Federation*
Tantalum
Taki Chemical Co., Ltd.
Japan
Tantalum
Telex Metals
United States
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
China
Tantalum
FIR Metals & Resource Ltd.
China
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
China
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
China
Tantalum
D Block Metals, LLC
United States
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
China
Tantalum
H.C. Starck Hermsdorf GmbH
Germany
Tantalum
TANIOBIS Japan Co., Ltd.
Japan
Tantalum
TANIOBIS Smelting GmbH & Co. KG
Germany
Tantalum
TANIOBIS Co., Ltd.
Thailand
Tantalum
KEMET de Mexico
Mexico
Tantalum
H.C. Starck Inc.
United States
Tantalum
Global Advanced Metals Boyertown
United States
Tantalum
Global Advanced Metals Aizu
Japan
Tantalum
TANIOBIS GmbH
Germany
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
China
Tantalum
Jiangxi Tuohong New Raw Material
China
Tantalum
XIMEI RESOURCES (GUANGDONG) LIMITED
China
Tantalum
F&X Electro-Materials Ltd.
China
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
China
Tin
PT Bangka Serumpun
Indonesia
Tin
Ma'anshan Weitai Tin Co., Ltd.
China
Tin
PT Rajawali Rimba Perkasa
Indonesia
Tin
Tin Technology & Refining
United States
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
China
Tin
Novosibirsk Processing Plant Ltd.
Russian Federation*
Tin
PT Babel Surya Alam Lestari
Indonesia
Tin
Operaciones Metalurgicas S.A.
Bolivia
Tin
EM Vinto
Bolivia
8


Tin
PT Artha Cipta Langgeng
Indonesia
Tin
PT Babel Inti Perkasa
Indonesia
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
Tin
Malaysia Smelting Corporation (MSC)
Malaysia
Tin
White Solder Metalurgia e Mineracao Ltda.
Brazil
Tin
Thaisarco
Thailand
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
China
Tin
Soft Metais Ltda.
Brazil
Tin
Rui Da Hung
Taiwan
Tin
Jiangxi New Nanshan Technology Ltd.
China
Tin
Mitsubishi Materials Corporation
Japan
Tin
China Tin Group Co., Ltd.
China
Tin
Resind Industria e Comercio Ltda.
Brazil
Tin
PT Cipta Persada Mulia
Indonesia
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
Viet Nam
Tin
Fabrica Auricchio Industria e Comercio Ltda.
Brazil
Tin
Luna Smelter, Ltd.
Rwanda
Tin
CRM Synergies
Spain
Tin
PT Stanindo Inti Perkasa
Indonesia
Tin
PT Timah Tbk Kundur
Indonesia
Tin
PT Timah Tbk Mentok
Indonesia
Tin
PT Tinindo Inter Nusa
Indonesia
Tin
PT Prima Timah Utama
Indonesia
Tin
PT Sariwiguna Binasentosa
Indonesia
Tin
PT Refined Bangka Tin
Indonesia
Tin
Mineracao Taboca S.A.
Brazil
Tin
Metallic Resources, Inc.
United States
Tin
Minsur
Peru
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
China
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
China
Tin
Estanho de Rondonia S.A.
Brazil
Tin
Fenix Metals
Poland
Tin
Dowa
Japan
Tin
PT Mitra Stania Prima
Indonesia
Tin
Alpha
United States
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
China
Tin
PT Menara Cipta Mulia
Indonesia
Tin
Metallo Belgium N.V.
Belgium
Tin
Metallo Spain S.L.U.
Spain
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
Tin
PT ATD Makmur Mandiri Jaya
Indonesia
Tin
Magnu's Minerais Metais e Ligas Ltda.
Brazil
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
China
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.
China
Tungsten
KGETS Co., Ltd.
Korea, Republic of
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
China
Tungsten
Lianyou Metals Co., Ltd.
Taiwan
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
Russian Federation*
Tungsten
Wolfram Bergbau und Hutten AG
Austria
9


Tungsten
Xiamen Tungsten Co., Ltd.
China
Tungsten
China Molybdenum Tungsten Co., Ltd.
China
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
China
Tungsten
Fujian Xinlu Tungsten Co., Ltd.
China
Tungsten
Hubei Green Tungsten Co., Ltd.
China
Tungsten
Cronimet Brasil Ltda
Brazil
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
China
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
China
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
China
Tungsten
Kennametal Fallon
United States
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
China
Tungsten
Japan New Metals Co., Ltd.
Japan
Tungsten
Hunan Chenzhou Mining Co., Ltd.
China
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
China
Tungsten
Global Tungsten & Powders Corp.
United States
Tungsten
Kennametal Huntsville
United States
Tungsten
A.L.M.T. Corp.
Japan
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China
Tungsten
Moliren Ltd.
Russian Federation*
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
China
Tungsten
ACL Metais Eireli
Brazil
Tungsten
Philippine Chuangxin Industrial Co., Inc.
Philippines
Tungsten
Hydrometallurg, JSC
Russian Federation*
Tungsten
Unecha Refractory metals plant
Russian Federation*
Tungsten
Niagara Refining LLC
United States
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
China
Tungsten
TANIOBIS Smelting GmbH & Co. KG
Germany
Tungsten
Masan High-Tech Materials
Viet Nam
Tungsten
H.C. Starck Tungsten GmbH
Germany
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
China
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China
Tungsten
Asia Tungsten Products Vietnam Ltd.
Viet Nam
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
China
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China

* The Company does not source directly from Russia. Furthermore, since Russia invaded Ukraine in February 2022, we have halted new orders and shipments into and out of Russia and Belarus until further notice and in alignment with international sanctions. RMI provides the Company with a list of potential countries of origin which includes all countries of origin compiled from RMI’s member participants. The inclusion of a country on the list from RMI is not a final indicator that the Company utilized materials sourced from this country.

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