EX-1.01 2 conflictmineralsfy2022-ex1.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, 2022. 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), transport refrigeration and custom refrigeration solutions. 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, cooling and ventilation 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, cooling and ventilation systems, services and solutions for commercial buildings and industrial processing, 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, cooling and ventilation 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, 2022 included the following:
Air conditioners    Package heating and cooling systems
Air exchangers    Parts and supplies (aftermarket and OEM)
Air handlers    Rail refrigeration systems
Airside and terminal devices    Rate chambers
Air-sourced heat pumps    Refrigerant reclamation
Auxiliary power units (electric and diesel)    Renewable energy projects
Building management systems    Repair and maintenance services
Bus air purification systems    Rental services
Bus and rail HVAC systems    Residential Air Filtration System
Chillers    Residential Hybrid Heating Solutions
Coils and condensers    Self-powered truck refrigeration systems
Container refrigeration systems and gensets    Service agreements
Control systems    Telematics Solutions
Cryogenic refrigeration systems     Temporary heating and cooling systems
Dehumidifiers    Thermal energy storage
Ductless    Thermostats/controls & associated digital solutions
Energy efficiency programs    Trailer refrigeration systems (diesel, electric and hybrid)
Energy infrastructure programs    Transport heater products
Energy management services    Truck refrigeration systems (diesel, electric and hybrid)
Energy performance contracting    Ultra-low temperature freezers
Furnaces    Unitary systems (light and large)
Geothermal systems    Variable refrigerant flow
Home automation    Vehicle-powered truck refrigeration systems
Humidifiers    Ventilation
HVAC Performance-monitoring applications    Water source heat pumps
Indoor air quality assessments and related     
products for HVAC and Transport solutions    
Industrial refrigeration    
Installation contracting    
Large commercial unitary
Light commercial unitary    
Multi-pipe HVAC systems    
image_0a.jpg    
    
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.


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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 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 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 2022, the Company continued to communicate the policy to suppliers and the public through its website, through Assent, a third-party company engaged to assist the Company with its conflict minerals due diligence process, and through telephone calls, when necessary.
Internal Management Systems.
The Company’s conflict minerals compliance program for the fiscal year ended December 31, 2022 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. In 2022, the Company enhanced its internal custom conflict minerals training course for suppliers, which it plans to begin implementing with suppliers in 2023.

3




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 2022, this group represented, 80% 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 2022, the Company distributed the CMRT to Targeted Suppliers using Assent to assist in our survey and diligence process. Assent’s conflict minerals due diligence program actively identifies and manages supply chain risks. It also helps gather, store, and validate conflict mineral data while streamlining supply chain communications with stakeholders in accordance with the OECD Due Diligence Guidance. 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 2022, 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.
Grievance Mechanism
The Company has an e-mail address for receiving conflict minerals communications internally or externally and an external reporting 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. As noted above, in 2022, the Company engaged a third-party provider, Assent, to assist in the Company’s survey and diligence process. Assent’s conflict minerals due diligence program is designed to actively identify and manage supply chain risks. It also helps gather, store, and validate conflict mineral data while streamlining supply chain communications with stakeholders in accordance with the OECD Due Diligence Guidance. The Company then reviews the data collected by Assent, follows up with suppliers as needed, and catalogs 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.
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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. The Company continued to implement steps using available industry data to conduct a review of summary smelter information to determine if the smelter has conducted a source of origin verification.
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.
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 after investigation some of these names were proven not to be smelters but rather other sub-tier suppliers. Based on the information provided by the Targeted Suppliers, the Company has identified 389 smelters and refiners, 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 our supplier engagement and training through the launch of the enhanced custom conflict minerals course to suppliers, 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.





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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,” “expand,” “expect,” “recur,” “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 NameCountry
Gold
Advanced Chemical CompanyUnited States of America
Gold
Gold
Aida Chemical Industries Co., Ltd.Japan
Gold
Agosi AGGermany
Gold
Almalyk Mining and Metallurgical Complex (AMMC)Uzbekistan
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
Brazil
Gold
Argor-Heraeus S.A.Switzerland
Gold
Asahi Pretec Corp.Japan
Gold
Asaka Riken Co., Ltd.Japan
Gold
Aurubis AGGermany
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)Philippines
Gold
Boliden ABSweden
Gold
C. Hafner GmbH + Co. KGGermany
Gold
CCR Refinery - Glencore Canada CorporationCanada
Gold
Chimet S.p.A.Italy
Gold
Chugai MiningJapan
Gold
DSC (Do Sung Corporation)Korea, Republic of
Gold
DowaJapan
Gold
Eco-System Recycling Co., Ltd. East PlantJapan
Gold
LT Metal Ltd.Korea, Republic of
Gold
Heimerle + Meule GmbHGermany
Gold
Heraeus Metals Hong Kong Ltd.China
Gold
Heraeus Germany GmbH Co. KGGermany
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.China
Gold
Ishifuku Metal Industry Co., Ltd.Japan
Gold
Istanbul Gold RefineryTurkey
Gold
Japan MintJapan
Gold
Jiangxi Copper Co., Ltd.China
Gold
Asahi Refining USA Inc.United States of America
Gold
Asahi Refining Canada Ltd.Canada
Gold
JX Nippon Mining & Metals Co., Ltd.Japan
Gold
KazzincKazakhstan
Gold
Kennecott Utah Copper LLCUnited States of America
Gold
Kojima Chemicals Co., Ltd.Japan
Gold
LS-NIKKO Copper Inc.Korea, Republic of
Gold
MaterionUnited States of America
Gold
Matsuda Sangyo Co., Ltd.Japan
Gold
Metalor Technologies (Suzhou) Ltd.China
Gold
Metalor Technologies (Hong Kong) Ltd.China
Gold
Metalor Technologies (Singapore) Pte., Ltd.Singapore
Gold
Metalor Technologies S.A.Switzerland
Gold
Metalor USA Refining CorporationUnited States of America
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.Mexico
Gold
Mitsubishi Materials CorporationJapan
Gold
Mitsui Mining and Smelting Co., Ltd.Japan
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.Turkey



Gold
Navoi Mining and Metallurgical CombinatUzbekistan
Gold
Nihon Material Co., Ltd.Japan
Gold
Ohura Precious Metal Industry Co., Ltd.Japan
Gold
MKS PAMP SASwitzerland
Gold
PT Aneka Tambang (Persero) TbkIndonesia
Gold
PX Precinox S.A.Switzerland
Gold
Rand Refinery (Pty) Ltd.South Africa
Gold
Royal Canadian MintCanada
Gold
SEMPSA Joyeria Plateria S.A.Spain
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.China
Gold
Sichuan Tianze Precious Metals Co., Ltd.China
Gold
Solar Applied Materials Technology Corp.Taiwan, Province of China
Gold
Sumitomo Metal Mining Co., Ltd.Japan
Gold
Tanaka Kikinzoku Kogyo K.K.Japan
Gold
Shandong Gold Smelting Co., Ltd.China
Gold
Tokuriki Honten Co., Ltd.Japan
Gold
TorecomKorea, Republic of
Gold
Umicore S.A. Business Unit Precious Metals RefiningBelgium
Gold
United Precious Metal Refining, Inc.United States of America
Gold
Valcambi S.A.Switzerland
Gold
Western Australian Mint (T/a The Perth Mint)Australia
Gold
Yamakin Co., Ltd.Japan
Gold
Yokohama Metal Co., Ltd.Japan
Gold
Zhongyuan Gold Smelter of Zhongjin Gold CorporationChina
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.China
Gold
Geib Refining CorporationUnited States of America
Gold
MMTC-PAMP India Pvt., Ltd.India
Gold
KGHM Polska Miedz Spolka AkcyjnaPoland
Gold
Emirates Gold DMCCUnited Arab Emirates
Gold
T.C.A S.p.AItaly
Gold
REMONDIS PMR B.V.Netherlands
Gold
Korea Zinc Co., Ltd.Korea, Republic of
Gold
TOO Tau-Ken-AltynKazakhstan
Gold
Abington Reldan Metals, LLCUnited States of America
Gold
SAAMPFrance
Gold
L'Orfebre S.A.Andorra
Gold
ItalpreziosiItaly
Gold
WIELAND Edelmetalle GmbHGermany
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustria
Gold
Bangalore RefineryIndia
Gold
SungEel HiMetal Co., Ltd.Korea, Republic of
Gold
Planta Recuperadora de Metales SpAChile
Gold
NH Recytech CompanyKorea, Republic of
Gold
Eco-System Recycling Co., Ltd. West PlantJapan
Gold
Sancus ZFS (L’Orfebre, SA)Colombia
Gold
Metal Concentrators SA (Pty) Ltd.South Africa
Gold
SAFINA A.S.Czechia



Gold
Al Etihad Gold Refinery DMCCUnited Arab Emirates
Gold
Eco-System Recycling Co., Ltd. North PlantJapan
Gold
Gold by Gold ColombiaColombia
TantalumChangsha South Tantalum Niobium Co., Ltd.China
TantalumF&X Electro-Materials Ltd.China
Tantalum
Tantalum
XIMEI RESOURCES (GUANGDONG) LIMITEDChina
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.China
TantalumJiujiang Tanbre Co., Ltd.China
TantalumAMG BrasilBrazil
TantalumMetallurgical Products India Pvt., Ltd.India
TantalumMineracao Taboca S.A.Brazil
Tantalum
Tantalum
Mitsui Mining and Smelting Co., Ltd.Japan
TantalumNPM Silmet ASEstonia
TantalumNingxia Orient Tantalum Industry Co., Ltd.China
TantalumQuantumCleanUnited States of America
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.China
TantalumTaki Chemical Co., Ltd.Japan
TantalumTelex MetalsUnited States of America
TantalumUlba Metallurgical Plant JSCKazakhstan
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.China
TantalumD Block Metals, LLCUnited States of America
TantalumFIR Metals & Resource Ltd.China
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.China
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.China
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.China
Tantalum
KEMET de MexicoMexico
Tantalum
TANIOBIS Co., Ltd.Thailand
Tantalum
TANIOBIS GmbHGermany
Tantalum
Materion Newton Inc.United States of America
Tantalum
TANIOBIS Japan Co., Ltd.Japan
Tantalum
TANIOBIS Smelting GmbH & Co. KGGermany
Tantalum
Global Advanced Metals BoyertownUnited States of America
Tantalum
Global Advanced Metals AizuJapan
Tantalum
Resind Industria e Comercio Ltda.Brazil
Tantalum
Jiangxi Tuohong New Raw MaterialChina
Tantalum
RFH Yancheng Jinye New Material Technology Co., Ltd.China
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.China
Tin
AlphaUnited States of America
Tin
DowaJapan
Tin
EM VintoBolivia (Plurinational State Of)
Tin
Fenix MetalsPoland
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.China
Tin
China Tin Group Co., Ltd.China
Tin
Malaysia Smelting Corporation (MSC)Malaysia
Tin
Metallic Resources, Inc.United States of America
Tin
Mineracao Taboca S.A.Brazil
Tin
MinsurPeru



Tin
Mitsubishi Materials CorporationJapan
Tin
Jiangxi New Nanshan Technology Ltd.China
Tin
O.M. Manufacturing (Thailand) Co., Ltd.Thailand
Tin
Operaciones Metalurgicas S.A.Bolivia (Plurinational State Of)
Tin
PT Mitra Stania PrimaIndonesia
Tin
PT Refined Bangka TinIndonesia
Tin
PT Timah Tbk KundurIndonesia
Tin
PT Timah Tbk MentokIndonesia
Tin
Rui Da HungTaiwan, Province of China
Tin
ThaisarcoThailand
Tin
White Solder Metalurgia e Mineracao Ltda.Brazil
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.China
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.China
Tin
Magnu's Minerais Metais e Ligas Ltda.Brazil
Tin
O.M. Manufacturing Philippines, Inc.Philippines
Tin
Resind Industria e Comercio Ltda.Brazil
Tin
Aurubis BeerseBelgium
Tin
Aurubis BerangoSpain
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.China
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.China
Tin
PT Bangka SerumpunIndonesia
Tin
Tin Technology & RefiningUnited States of America
Tin
PT Mitra Sukses GlobalindoIndonesia
Tin
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBrazil
Tin
CRM SynergiesSpain
Tin
Estanho de Rondonia S.A.Brazil
Tin
PT Artha Cipta LanggengIndonesia
Tin
PT Babel Inti PerkasaIndonesia
Tin
PT Babel Surya Alam LestariIndonesia
Tin
PT Bukit TimahIndonesia
Tin
PT Prima Timah UtamaIndonesia
Tin
PT Sariwiguna BinasentosaIndonesia
Tin
PT Stanindo Inti PerkasaIndonesia
Tin
CV Venus Inti PerkasaIndonesia
Tin
PT ATD Makmur Mandiri JayaIndonesia
Tin
CV Ayi JayaIndonesia
Tin
PT Rajehan AriqIndonesia
Tin
PT Cipta Persada MuliaIndonesia
Tin
PT Sukses Inti MakmurIndonesia
Tin
PT Menara Cipta MuliaIndonesia
Tin
PT Rajawali Rimba PerkasaIndonesia
Tin
Luna Smelter, Ltd.Rwanda
TungstenFabrica Auricchio Industria e Comercio Ltda.Brazil
TungstenPT Aries Kencana SejahteraIndonesia
TungstenPT Premium Tin IndonesiaIndonesia
TungstenPT Tommy UtamaIndonesia



TungstenPT Bangka Prima TinIndonesia
TungstenDS Myanmar
 Myanmar
TungstenPT Putera Sarana Shakti (PT PSS)Indonesia
TungstenA.L.M.T. Corp.Japan
TungstenKennametal HuntsvilleUnited States of America
TungstenGuangdong Xianglu Tungsten Co., Ltd.China
TungstenChongyi Zhangyuan Tungsten Co., Ltd.China
TungstenGlobal Tungsten & Powders LLCUnited States of America
TungstenHunan Chenzhou Mining Co., Ltd.China
TungstenHunan Jintai New Material Co., Ltd.China
TungstenJapan New Metals Co., Ltd.Japan
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.China
TungstenKennametal FallonUnited States of America
TungstenWolfram Bergbau und Hutten AGAustria
TungstenXiamen Tungsten Co., Ltd.China
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.China
TungstenJiangxi Yaosheng Tungsten Co., Ltd.China
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.China
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.China
TungstenMalipo Haiyu Tungsten Co., Ltd.China
TungstenXiamen Tungsten (H.C.) Co., Ltd.China
TungstenJiangxi Gan Bei Tungsten Co., Ltd.China
TungstenGanzhou Seadragon W & Mo Co., Ltd.China
TungstenAsia Tungsten Products Vietnam Ltd.Viet Nam
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchChina
TungstenH.C. Starck Tungsten GmbHGermany
TungstenTANIOBIS Smelting GmbH & Co. KGGermany
TungstenMasan High-Tech MaterialsViet Nam
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.China
TungstenNiagara Refining LLC
 United States of America
TungstenChina Molybdenum Tungsten Co., Ltd.China
TungstenGanzhou Haichuang Tungsten Co., Ltd.China
TungstenPhilippine Chuangxin Industrial Co., Inc.Philippines
TungstenHubei Green Tungsten Co., Ltd.China
TungstenCronimet Brasil LtdaBrazil
TungstenFujian Ganmin RareMetal Co., Ltd.China
TungstenLianyou Metals Co., Ltd.Taiwan, Province of China
TungstenFujian Xinlu Tungsten Co., Ltd.China

* The Company does not source directly from Russia. Furthermore, when Russia invaded Ukraine in February 2022, we immediately halted new orders and shipments into and out of Russia and Belarus. As of December 31, 2022, we have exited all business activity within these markets. The inclusion of a country on the list from RMI is not a final indicator that the Company utilized materials sourced from this country.