EX-1.01 2 exhibit_1-01.htm EXHIBIT 1.01


Exhibit 1.01
 

Conflict Minerals Report of
ReWalk Robotics Ltd.
For the year ended December 31, 2019

Introduction
 
This is the Conflict Minerals Report (the “CMR”) of ReWalk Robotics Ltd. (the “Company,” “we” or “us”) for calendar year 2019 in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “1934 Act”). The Rule requires disclosure of certain information when a registrant manufactures or contracts to manufacture products that contain, or likely contain, the “Conflict Minerals” specified in the Rule, which are necessary to the functionality or production of products (the “Covered Products”).

“Conflict Minerals” are defined as gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. Tantalum, tin, tungsten and gold are collectively referred to as “3TG” for the purposes of this assessment. According to the Rule, if a registrant, based on a good faith reasonable country of origin inquiry regarding the Conflict Minerals, has reason to believe that: (i) the Conflict Minerals contained in its Covered Products may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively with the DRC, the “Covered Countries”) or (ii) such Conflict Minerals may not be from entirely recycled or scrap sources, then the registrant must exercise due diligence on the source and chain of custody of the Conflict Minerals, and submit a conflict minerals report describing those due diligence measures.

Reasonable Country of Origin Inquiry

During the year ended December 31, 2019, we conducted a Reasonable Country of Origin Inquiry (“RCOI”) to determine, using good faith and reasonable best efforts, whether any of the necessary 3TG that was necessary to the production or functionality of our Covered Products in 2019 originated, or likely originated, from the  DRC or Covered Countries or whether the 3TG originated, or likely originated, from entirely recycled or scrap sources. We held meetings with management from various departments to discuss the applicable definitions of “manufacturer” and/or “contract to manufacture.” By way of this process, we identified specific types of product parts that contain within them 3TG that is necessary to their production or functionality and mapped them to their respective suppliers.
 
We developed a risk-based approach that focuses on our key suppliers involved in the manufacturing the majority of our finished products. We identified 17 relevant suppliers. We requested that all identified suppliers provide information regarding the origin of the Conflict Minerals contained in products supplied using version 5.10, or higher, of the Conflict Minerals Reporting Template (“CMRT”) of the Responsible Business Alliance and created by the Responsible Minerals Initiative (“RMI”).
 
We reviewed the responses received, checked for inconsistencies, incomplete forms, and inaccurate responses, and sent reminders to suppliers who did not respond to our requests for information. One of the relevant suppliers noted that they do not provide us with Conflict Minerals. We compared the Conflict Minerals smelters or refiners reported in the surveys by the remaining 16 suppliers against the lists of facilities that received a conformant or active designation by the RMI’s Responsible Minerals Assurance Process (“RMAP”). In accordance with the Rule, we concluded in good faith that during the year ended December 31, 2019:
 

certain of our operations manufactured, or contracted to manufacture, products for which Conflict Minerals are necessary to the functionality or production of those products; and

based on our good faith reasonable country of origin inquiry regarding the Conflict Minerals, which was designed to determine whether any of the Conflict Minerals contained in our Covered Products originated in the DRC or Covered Countries and whether any of the Conflict Minerals contained in the Covered Products are or may be from entirely recycled or scrap sources, we had reason to believe that: (i) the Conflict Minerals contained in our Covered Products may have originated in the DRC or Covered Countries and (ii) such Conflict Minerals may not be from entirely recycled or scrap sources.

As a result, we exercised due diligence on the Conflict Minerals’ source and chain of custody and are filing this CMR with our Form SD to comply with the requirements of the Rule. This CMR has not been subject to an independent private sector audit. The due diligence measures performed by the Company are discussed below.
 

Part I. Company Overview and Description of the Company’s Products Covered by This Report

            We are an innovative medical device company that is designing, developing and commercializing robotic exoskeletons that allow individuals with mobility impairments or other medical conditions the ability to stand and walk once again. We have developed and are continuing to commercialize our ReWalk Personal and ReWalk Rehabilitation devices for individuals with Spinal Cord Injury (“SCI Products”), which are exoskeletons designed for individuals with paraplegia that use our patented tilt-sensor technology and an on-board computer and motion sensors to drive motorized legs that power movement. We have also developed and began commercializing our ReStore device in June 2019, following receipt of CE mark and FDA clearance in the second quarter of 2019. ReStore is a powered, lightweight soft exo-suit intended for use in the rehabilitation of individuals with lower limb disability due to stroke. Our principal markets are the United States and Europe. .

Part II. The Company’s Due Diligence Process
 
Design of Due Diligence
 
We have adopted due diligence processes in accordance with Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016), including the related Supplements on Tin, Tantalum and Tungsten and on Gold published by the Organization for Economic Co-Operation and Development (collectively, the “OECD Guidance”).

The design of our Conflict Minerals program is in conformity with the OECD Guidance, specifically as it relates to our position in the minerals supply chain as a company that is several levels removed from the actual mining of Conflict Minerals (i.e., a “downstream company”). We do not make direct purchases of raw ore or unrefined Conflict Minerals and instead rely on our direct suppliers to provide us with the information regarding the likely source and chain of custody of the 3TG minerals supplied to us. Summarized below are the design components of our Conflict Minerals program as they relate to the five-step framework set forth in the OECD Guidance:

Due Diligence Performed
 
Step 1. Establish Strong Company Management Systems
 
Adopt, communicate and commit to a supply chain policy for minerals from conflict-affected and high-risk areas.

We have adopted our Conflict Minerals Policy (the “Policy”) related to our sourcing of 3TG. Our Policy outlines our commitment to responsible sourcing and the requirements imposed on participants in our supply chain, and is available on the “Corporate Governance” page in the “Investor Relations” section of our website at http://ir.rewalk.com/static-files/6ab6976a-0ab5-4021-b61f-682f26dc74b4. Information contained on, or that can be accessed through, our website does not constitute a part of this CMR and is not incorporated by reference herein.


Structure internal management systems to support supply chain due diligence.

We provide, from time to time as necessary, training on the relevant Rule and process for relevant employees (e.g., purchasing, legal and finance).

Establish a System of Controls and Transparency over the Conflict Minerals Supply Chain.

We have implemented a supply chain system of controls and transparency through the use of due diligence tools created by the RMI. These tools include, as discussed in “Step 2” below, accepting at a minimum version 5.10, or higher, of the CMRT, which is designed to identify and verify information regarding the smelters or refiners that process the necessary Conflict Minerals contained in our products. We have also adopted a process to maintain business records relating to 3TG due diligence, including retention of records of our due diligence processes, findings and resulting decisions for a period of five years.

Strengthen the Company’s Engagement with Suppliers

The Company informs its in-scope manufacturers and suppliers of its disclosure requirements, including its compliance with the OECD Guidance and the Rule.

Establish a Company-level Grievance Mechanism.
 
Our Policy includes a grievance procedure by which suppliers and other external parties may contact us should they wish to seek guidance or report concerns regarding Conflict Minerals. Concerns or grievances reported through this procedure are reviewed by the relevant staff members and follow-up activities are conducted, as appropriate.
 
Step 2. Identify and Assess Risks in the Supply Chain
 
Identify Risks in the Supply Chain by Identifying Company Suppliers.
 
Identify Company Suppliers.
 
As explained above, we do not buy raw ore or unrefined Conflict Minerals directly from refiners, smelters or mines. Our supply chain with respect to the Covered Products is complex, with multiple intermediaries and third parties in the supply chain between the manufacturing of the Covered Products and the original sources of the necessary Conflict Minerals. Because we believe that the smelters or refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us.

As discussed above under “Reasonable Country of Origin Inquiry” and “Part I. Company Overview and Description of the Company’s Products Covered by This Report,” we identified our Covered Products falling within the scope of the Rule (i.e., products which were manufactured or contracted to be manufactured by us) during the 2019 calendar year. Based on these Covered Products, we were able to identify the suppliers from which we purchase components or materials for the Covered Products that may include Conflict Minerals. We identified 17 relevant suppliers whose products may contain 3TG. One supplier reported that it does not provide the Company with Conflict Minerals, and therefore the number of relevant suppliers for the 2019 supply chain inquiry was limited to 16 suppliers that provided us with products or product components containing Conflict Minerals.
 

Request Conflict Minerals Reporting Templates (CMRTs) from suppliers.

We surveyed 17 suppliers to identify the 3TG contained in the products they supply us with, the smelters or refiners that process the 3TG and the country of origin, or likely country of origin, of such 3TG. The survey was conducted by utilizing version 5.10, or higher, of the CMRT. We utilize this RMI reporting template to collect data and information from our suppliers in order to identify the origins of 3TG in our supply chain. We received responses from 10 out of 17 suppliers (59%).

Assess Risks in the Supply Chain.

Analyze surveys for RMAP “conformant” and “active” smelters or refiners.
 
We compared smelters or refiners identified in the supply chain survey against the RMI’s “conformant” smelter or refiner list, which lists all facilities that have received a RMAP “conformant” designation from the RMI. We reviewed all of the responses to determine whether smelters or refiners identified in our supply chain obtained a designation of “conformant” or “active” from the RMI.
 
Of the CMRT responses we received from suppliers, some included incomplete responses as well as inconsistencies and inaccuracies within the reported data. In such cases, we contacted the suppliers directly in an effort to secure revised responses. Through this process, we have identified, to the best of our efforts, the smelters or refiners in our supply chain and country of origin, or likely country of origin, information for the smelters or refiners identified in the supply chain survey.
 
Understand and define RMAP “conformant” and “active” statuses.

To compile its list, the RMI employs independent third-party auditors to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters or refiners which agree to undergo an audit. A smelter or refiner receives a RMAP “conformant” designation from the RMI if the smelter or refiner (i) completes an independent third-party audit, (ii) adheres to the RMAP’s assessment protocols by disclosing to auditors the identities and locations of the mines from which it sources Conflict Minerals, (iii) has been found by its independent third-party auditor to possess the systems and processes to support responsible sourcing of Conflict Minerals and can provide evidence to support its sourcing activities and (iv) maintains good standing in the program, through a continual validation process. The RMI’s RMAP “conformant” list provides the names, locations and links to Conflict Minerals policies of all smelters or refiners deemed compliant with the RMAP’s assessment protocols. Smelters or refiners with a “re-audit in progress” are still considered to be RMAP “conformant.”

Smelters or refiners labeled as “active” have committed to undergo an audit, which may be in progress, or are participating in one of the cross-recognized certification programs, namely, the London Bullion Market Association Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. These “active” smelters or refiners may be at various stages of the audit cycle, anywhere from completing the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase. Smelters or refiners may not retain their “active” status if they are unresponsive to requests for re-audit or corrective action past a certain time. Companies that have been determined to be downstream of smelters or refiners may not take part in the RMAP. However, they may participate in the RMI’s Downstream Audit Program, an independent validation of companies’ sourcing practices outside of the RMAP audit process.


 
Step 3. Design and Implement a Strategy to Respond to Identified Risks
 
We are working to improve our due diligence processes with respect to 3TG. Our risk mitigation efforts during 2019 included those discussed in this section.
 
Participate in Existing Industry Conflict Minerals Initiatives.
 
In light of the complexity of our and our suppliers’ supply chains, we are currently unable to assess adequately all of the risks in our supply chain. However, we continue to engage with suppliers to obtain current, accurate and complete information about our supply chain through the use of version 5.10, or higher, of the CMRT and to improve due diligence efforts to ensure responsible sourcing in compliance with our Policy.

Report Findings to Designated Senior Management.
 
The Company’s senior management, including our Chief Executive Officer and Chief Financial Officer, is briefed periodically about our supply chain due diligence efforts, risk analysis results and mitigation efforts.

Devise, Adopt and Implement a Risk Management Plan and Monitor Risk Mitigation Efforts.

The Company’s Policy seeks to encourage suppliers to responsibly source Conflict Minerals, but does not necessarily seek to eliminate sourcing from the DRC or Covered Countries. We also periodically review our progress, assess identified risks and determine follow-up action, as follows:
 

We follow up on inconsistent, incomplete, or inaccurate responses, and send reminders to suppliers who have not responded to our requests for information.
 

Suppliers that source from smelters or refiners from the DRC or Covered Countries, where such smelters or refiners are not certified by the RMAP, are contacted and are asked to submit more information about their sourcing practices, including a corrective action plan.
 
Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
 
Due to our downstream position in the supply chain, we do not have a direct relationship with 3TG smelters or refiners. Therefore, we do not perform direct audits of these entities within our supply chain, but instead rely on the efforts of organizations such as the RMI to influence smelters or refiners to undergo audits and become certified through the RMAP.
 
Step 5. Report Annually on Supply Chain Due Diligence
 
Our supply chain due diligence efforts are described in this CMR. We have filed this CMR in accordance with the Rule by submitting to the U.S. Securities and Exchange Commission a Form SD attaching this CMR. This CMR is also available on our website at http://ir.rewalk.com/sec-filings.
 
Part III. The Company’s Due Diligence Findings and Conclusions

Our Conflict Minerals process, as described above, allowed us to identify in-scope products and the corresponding suppliers. These 17 identified suppliers were surveyed using version 5.10, or higher, of the CMRT. One of the relevant suppliers noted that they do not provide us with Conflict Minerals. We received survey responses from 59% of our suppliers. The results of the survey do not allow us to make definitive conclusions as to the source or likely source of any potential Conflict Minerals that were necessary to the production or functionality of our products that were manufactured, or contracted to manufacture, in 2019.

Facilities Used to Process the Conflict Minerals in the Covered Products

Based on the information obtained by the Company during the minerals supply chain due diligence process, the Company was unable to conclusively determine the origin or likely origin of all the Conflict Minerals contained in the Covered Products. Based on the information provided by our suppliers as well as by the RMI, as of the date of this CMR, we believe that the facilities that may have been used to process the Conflict Minerals in our products during the reporting period in the 2019 calendar year may include the smelters or refiners listed in Annex I hereto.


Countries of Origin of the Conflict Minerals in the Covered Products

Based on the information provided by our suppliers as well as by RMI, as of the date of this CMR, we believe that the facilities for processing of the Conflict Minerals countries of origin, or likely countries of origin of the Conflict Minerals contained in our products may include one or more of the countries listed in Annex II hereto.

We can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals in our Covered Products, since the information comes from direct and secondary suppliers and the RMI. Information gathered from our suppliers is not on a continuous, real-time basis. Despite our efforts to follow up with certain suppliers, we did not receive responses from all suppliers, and the suppliers who responded showed varying degrees of cooperation with our inquiries.

Part IV. Implementation of Strategies to Respond to Identified Risks and Future Steps

We have taken, and intend to continue taking, steps to improve our due diligence processes and to minimize the risk that our necessary Conflict Minerals benefit, or likely benefit, armed groups in the DRC or Covered Countries. Going forward, we will continue working with our global supply chain to ensure responsible sourcing and assure compliance with applicable regulations through the following steps:


1.
Contacting from time to time, as is reasonably required, direct suppliers that do not respond to the supply chain survey by a specified date, requesting their responses.

2.
Comparing, as is reasonably required, applicable smelters or refiners identified in the supply chain survey against the list of facilities that have received a RMAP “conformant” or “active” designation from the RMI’s RMAP.

3.
Making a good faith effort to enact terms and conditions related to Conflict Minerals in supplier contracts.

4.
Continuing to implement the Company’s Conflict Minerals Policy.

5.
Engaging with suppliers to encourage them to provide requested information for 2020.

Forward-Looking Statements
 
In addition to historical facts, this CMR contains forward-looking statements within the meaning of Section 27A of the U.S. Securities Act of 1933, as amended, Section 21E of the 1934 Act, and the safe harbor provisions of the U.S. Private Securities Litigation Reform Act of 1995. We have based these forward-looking statements on our current expectations and projections about future events. Forward-looking statements include information regarding further supplier engagement, due diligence and risk mitigation efforts and strategy, and involve certain risks and uncertainties. Actual results could differ materially from the forward-looking statements. Words such as “expects,” “anticipates,” “intends,” “seeks,” “believes,” “may,” “will,” variations of these words, and similar expressions are intended to identify such 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 our ability to verify the accuracy or completeness of any supply chain information provided by suppliers and other factors discussed under the heading “Risk Factors” in our annual report on Form 10-K for the year ended December 31, 2019, filed with the U.S. Securities and Exchange Commission and other documents subsequently filed with or furnished to the U.S. Securities and Exchange Commission. Any forward-looking statement made in this CMR speaks only as of the date hereof. Except as otherwise required by law, the Company undertakes no obligation to update publicly the information contained in this CMR, or any forward looking statements, to reflect new information, events or circumstances after the date they were made, or to reflect the occurrence of unanticipated events.
 

Annex I
 
List of Identified Smelters or Refiners
 
Metal (*)
Smelter Reference List (*)
Smelter Country (*)
Smelter status by ID
Gold
8853 S.p.A.
ITALY
Conformant
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Not certified
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Conformant
Gold
African Gold Refinery
UNITED STATES OF AMERICA
Not certified
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Conformant
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Conformant
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Conformant
Gold
Argor-Heraeus S.A.
SWITZERLAND
Conformant
Gold
Asahi Pretec Corp.
JAPAN
Conformant
Gold
Asahi Refining Canada Ltd.
CANADA
Conformant
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Conformant
Gold
Asaka Riken Co., Ltd.
JAPAN
Conformant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Not certified
Gold
AU Traders and Refiners
SOUTH AFRICA
Conformant
Gold
Aurubis AG
GERMANY
Conformant
Gold
Bangalore Refinery
INDIA
Conformant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Conformant
Gold
Boliden AB
SWEDEN
Conformant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Conformant
Gold
C.I Metales Procesados Industriales SAS
COLOMBIA
Active
Gold
Caridad
MEXICO
Not certified
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Conformant
Gold
Cendres + Metaux S.A.
SWITZERLAND
Conformant
Gold
CGR Metalloys Pvt Ltd.
INDIA
Not certified
Gold
Chimet S.p.A.
ITALY
Conformant
Gold
Chugai Mining
JAPAN
Conformant
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Not certified
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Not certified
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Not certified
Gold
Dijllah Gold Refinery FZC
GERMANY
Not certified
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Conformant
Gold
Dowa
JAPAN
Conformant
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Conformant




Gold
Eco-System Recycling Co., Ltd.
JAPAN
Conformant
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Conformant
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
Conformant
Gold
Elemetal Refining, LLC
UNITED STATES OF AMERICA
Not certified
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Conformant
Gold
Fidelity Printers and Refiners Ltd.
RUSSIAN FEDERATION
Not certified
Gold
Fujairah Gold FZC
RUSSIAN FEDERATION
Not certified
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Not certified
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Conformant
Gold
Gold Coast Refinery
GHANA
Not certified
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Not certified
Gold
Guangdong Jinding Gold Limited
CHINA
Not certified
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Not certified
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Not certified
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Heimerle + Meule GmbH
GERMANY
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Conformant
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Not certified
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Not certified
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Conformant
Gold
International Precious Metal Refiners
CHINA
Not certified
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
Istanbul Gold Refinery
TURKEY
Conformant
Gold
Italpreziosi
ITALY
Conformant
Gold
JALAN & Company
INDIA
Not certified
Gold
Japan Mint
JAPAN
Conformant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Conformant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CANADA
Not certified
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Conformant





Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Conformant
Gold
Kaloti Precious Metals
JAPAN
Not certified
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Not certified
Gold
Kazzinc
KAZAKHSTAN
Conformant
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Conformant
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Conformant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Conformant
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Not certified
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Not certified
Gold
Lingbao Gold Co., Ltd.
CHINA
Not certified
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Not certified
Gold
L'Orfebre S.A.
ANDORRA
Conformant
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Conformant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Not certified
Gold
Marsam Metals
BRAZIL
Conformant
Gold
Materion
UNITED STATES OF AMERICA
Conformant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Conformant
Gold
Metalor Technologies S.A.
SWITZERLAND
Conformant
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Conformant
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Conformant
Gold
Mitsubishi Materials Corporation
JAPAN
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Conformant
Gold
Modeltech Sdn Bhd
INDIA
Not certified
Gold
Morris and Watson
NEW ZEALAND
Not certified
Gold
Morris and Watson Gold Coast
AUSTRALIA
Not certified
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Conformant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Not certified
Gold
NH Recytech Company
UZBEKISTAN
Not certified
Gold
Nihon Material Co., Ltd.
JAPAN
Conformant
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Conformant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Conformant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Conformant
Gold
PAMP S.A.
SWITZERLAND
Conformant
Gold
Pease & Curren
UNITED STATES OF AMERICA
Not certified
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Not certified
Gold
Planta Recuperadora de Metales SpA
CHILE
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Conformant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Conformant
Gold
PX Precinox S.A.
SWITZERLAND
Conformant
Gold
QG Refining, LLC
SWITZERLAND
Not certified
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Conformant
Gold
Refinery of Seemine Gold Co., Ltd.
KOREA, REPUBLIC OF
Not certified
Gold
REMONDIS PMR B.V.
NETHERLANDS
Conformant




Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
Not certified
Gold
Royal Canadian Mint
CANADA
Conformant
Gold
SAAMP
FRANCE
Conformant
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Not certified
Gold
Safimet S.p.A
ITALY
Conformant
Gold
SAFINA A.S.
ITALY
Active
Gold
Sai Refinery
INDIA
Not certified
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Conformant
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Not certified
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Conformant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Not certified
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Conformant
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Not certified
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Not certified
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Conformant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Conformant
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Conformant
Gold
So Accurate Group, Inc.
UNITED STATES OF AMERICA
Not certified
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Conformant
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Conformant
Gold
Sovereign Metals
INDIA
Not certified
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Not certified
Gold
Sudan Gold Refinery
LITHUANIA
Not certified
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Conformant
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
T.C.A S.p.A
ITALY
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Conformant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Conformant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Not certified
Gold
Tony Goetz NV
CHINA
Not certified
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Conformant
Gold
Torecom
KOREA, REPUBLIC OF
Conformant
Gold
Umicore Brasil Ltda.
BRAZIL
Conformant
Gold
Umicore Precious Metals Thailand
THAILAND
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Conformant
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Conformant
Gold
Universal Precious Metals Refining Zambia
UNITED STATES OF AMERICA
Not certified




Gold
Valcambi S.A.
SWITZERLAND
Conformant
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Conformant
Gold
WIELAND Edelmetalle GmbH
GERMANY
Conformant
Gold
Yamakin Co., Ltd.
JAPAN
Conformant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Conformant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Not certified
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Conformant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Conformant
Tantalum
CP Metals Inc.
UNITED STATES OF AMERICA
Conformant
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Conformant
Tantalum
Duoluoshan
CHINA
Not certified
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Conformant
Tantalum
F&X Electro-Materials Ltd.
CHINA
Conformant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Conformant
Tantalum
Global Advanced Metals
UNITED STATES
Not certified
Tantalum
Global Advanced Metals Aizu
JAPAN
Conformant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Conformant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Conformant
Tantalum
H.C. Starck Group
GERMANY
Not certified
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Conformant
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Conformant
Tantalum
H.C. Starck Ltd.
JAPAN
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Conformant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Conformant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
KEMET Blue Metals
MEXICO
Conformant
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Conformant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Not certified
Tantalum
LSM Brasil S.A.
BRAZIL
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Conformant
Tantalum
Mineracao Taboca S.A.
BRAZIL
Conformant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Conformant
Tantalum
NPM Silmet AS
ESTONIA
Conformant




Tantalum
Plansee SE Liezen
AUSTRIA
Not certified
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Conformant
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Conformant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Conformant
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Conformant
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Conformant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Conformant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Not certified
Tin
Alpha
UNITED STATES OF AMERICA
Conformant
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Not certified
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Conformant
Tin
China Tin Group Co., Ltd.
CHINA
Conformant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Not certified
Tin
CV Ayi Jaya
INDONESIA
Conformant
Tin
CV Dua Sekawan
INDONESIA
Conformant
Tin
CV Gita Pesona
INDONESIA
Conformant
Tin
CV Tiga Sekawan
INDONESIA
Conformant
Tin
CV United Smelting
INDONESIA
Conformant
Tin
CV Venus Inti Perkasa
INDONESIA
Conformant
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
Not certified
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Not certified
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
Tin
Estanho de Rondonia S.A.
BRAZIL
Not certified
Tin
Fenix Metals
POLAND
Conformant
Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.”
CHINA
Not certified
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Conformant
Tin
Gejiu Jinye Mineral Company
CHINA
Not certified
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Conformant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Conformant
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Conformant




Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Not certified
Tin
Jiangxi Nanshan
CHINA
Not certified
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Conformant
Tin
Linwu Xianggui Smelter Co
CHINA
Not certified
Tin
Luna Smelter, Ltd.
RWANDA
Conformant
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Conformant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Conformant
Tin
Melt Metais e Ligas S.A.
BRAZIL
Conformant
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Conformant
Tin
Metallo Belgium N.V.
BELGIUM
Conformant
Tin
Metallo Spain S.L.U.
SPAIN
Conformant
Tin
Minmetals Ganzhou Tin Co. Ltd.
CHINA
Not certified
Tin
Minsur
PERU
Conformant
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Not certified
Tin
Novosibirsk Integrated Tin Works
RUSSIAN FEDERATION
Not certified
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Conformant
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
Tin
Precious Minerals and Smelting Limited
INDIA
Active
Tin
PT Aries Kencana Sejahtera
INDONESIA
Conformant
Tin
PT Artha Cipta Langgeng
INDONESIA
Conformant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Conformant
Tin
PT Babel Inti Perkasa
INDONESIA
Conformant
Tin
PT Bangka Prima Tin
INDONESIA
Conformant
Tin
PT Bangka Putra Karya
INDONESIA
Not certified
Tin
PT Bangka Serumpun
INDONESIA
Conformant
Tin
PT Bangka Tin Industry
INDONESIA
Conformant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Conformant
Tin
PT Bukit Timah
INDONESIA
Conformant
Tin
PT DS Jaya Abadi
INDONESIA
Conformant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Not certified
Tin
PT Inti Stania Prima
INDONESIA
Conformant
Tin
PT Karimun Mining
INDONESIA
Conformant
Tin
PT Kijang Jaya Mandiri
INDONESIA
Conformant
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Conformant
Tin
PT Menara Cipta Mulia
INDONESIA
Conformant
Tin
PT Mitra Stania Prima
INDONESIA
Conformant
Tin
PT O.M. Indonesia
INDONESIA
Not certified
Tin
PT Panca Mega Persada
INDONESIA
Conformant
Tin
PT Premium Tin Indonesia
INDONESIA
Conformant




Tin
PT Prima Timah Utama
INDONESIA
Conformant
Tin
PT Refined Bangka Tin
INDONESIA
Conformant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Conformant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Conformant
Tin
PT Sukses Inti Makmur
INDONESIA
Conformant
Tin
PT Sumber Jaya Indah
INDONESIA
Conformant
Tin
PT Timah Tbk Kundur
INDONESIA
Conformant
Tin
PT Timah Tbk Mentok
INDONESIA
Conformant
Tin
PT Tinindo Inter Nusa
INDONESIA
Conformant
Tin
PT Tommy Utama
INDONESIA
Conformant
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Conformant
Tin
Soft Metais Ltda.
BRAZIL
Conformant
Tin
Super Ligas
BRAZIL
Not certified
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
Conformant
Tin
Thaisarco
THAILAND
Conformant
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Conformant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Not certified
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Conformant
Tin
Yunnan Tin Company Limited
CHINA
Conformant
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
Conformant
Tungsten
A.L.M.T. Corp.
JAPAN
Conformant
Tungsten
ACL Metais Eireli
BRAZIL
Conformant
Tungsten
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
Active
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
China Molybdenum Tungsten Co., Ltd.
CHINA
Not certified
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Not certified
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Conformant
Tungsten
HC Starck GmbH
GERMANY
Not certified
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Conformant




Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
Conformant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Conformant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Active
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Not certified
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Not certified
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Active
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Conformant
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Conformant
Tungsten
KGETS Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
Conformant
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Conformant
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Not certified
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Conformant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Conformant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Not certified
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Conformant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Zhuzhou Cemented Carbide Group Co Ltd
CHINA
Not certified



 
Annex II
 
List of Countries of Origin of Conflict Minerals*

Based on our due diligence, the above smelters or refiners reported by our relevant suppliers may process Conflict Minerals from one or more of the following reported countries of origin:*
 
Conflict Mineral
Country of Origin May Include the Following
Gold
ANDORRA
AUSTRALIA
AUSTRIA
BELGIUM
BRAZIL
CANADA
CHILE
CHINA
COLOMBIA
FRANCE
GERMANY
GHANA
INDIA
INDONESIA
ITALY
JAPAN
KAZAKHSTAN
KOREA, REPUBLIC OF
KYRGYZSTAN
LITHUANIA
MEXICO
NETHERLANDS
NEW ZEALAND
PHILIPPINES
POLAND
RUSSIAN FEDERATION
SAUDI ARABIA
SINGAPORE
SOUTH AFRICA
SPAIN
SWEDEN
SWITZERLAND
TAIWAN, PROVINCE OF CHINA
THAILAND
TURKEY
UNITED ARAB EMIRATES
UNITED STATES OF AMERICA
UZBEKISTAN



Tantalum
AUSTRIA
BRAZIL
CHINA
ESTONIA
GERMANY
INDIA
JAPAN
KAZAKHSTAN
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
MEXICO
RUSSIAN FEDERATION
THAILAND
UNITED STATES OF AMERICA
Tin
BELGIUM
BOLIVIA (PLURINATIONAL STATE OF)
BRAZIL
CHINA
INDIA
INDONESIA
MALAYSIA
PERU
PHILIPPINES
POLAND
RUSSIAN FEDERATION
RWANDA
SPAIN
TAIWAN, PROVINCE OF CHINA
THAILAND
UNITED STATES OF AMERICA
VIET NAM
Tungsten
AUSTRIA
BRAZIL
CHINA
GERMANY
JAPAN
KOREA, REPUBLIC OF
PHILIPPINES
RUSSIAN FEDERATION
TAIWAN, PROVINCE OF CHINA
UNITED STATES OF AMERICA
VIET NAM

 
*As our suppliers’ Smelters or Refiners (“SOR”) did not provide complete information on the location of mine in their CMRTs, and the Company was not able to establish the exact country of origin of the from the sourcing information reported regarding their Conflict Minerals. Therefore, the Company has indicated the countries of origin information as reported in our suppliers’ CMRTs, in the relevant “Smelter or Refiner Country” field of the CMRT declaration.