EX-1.01 2 a12312018formsdcmr.htm EXHIBIT 1.01 Exhibit
Exhibit 1.01

Vista Outdoor Inc.
Conflict Minerals Report

For the reporting period from January 1, 2018 to December 31, 2018


This report (the “Report”) of Vista Outdoor Inc. (together with our consolidated subsidiaries, “Vista Outdoor,” “we,” “our,” and “us”), for the year ended December 31, 2018 is presented to comply with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”), which require public companies, including Vista Outdoor, to make certain disclosures if the company manufactures or contracts to manufacture products for which “conflict minerals” (as defined below) are necessary to the functionality or production of such products (“Covered Products”) and the company determines (after conducting a reasonable country of origin inquiry) that the conflicts minerals included in such Covered Products may have originated in the Democratic Republic of the Congo or an “adjoining country” (as defined in Form SD) and are not solely from scrap or recycled sources. “Conflict minerals,” or “3TG,” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten.

This Conflict Minerals Report relates to products: (i) for which conflict minerals are necessary to the functionality or production of the product; (ii) that were manufactured, or contracted to be manufactured, by Vista Outdoor; and (iii) for which manufacturing was completed during the 2018 calendar year (the “Reporting Period”).

I.
Company and Product Overview

Vista Outdoor is a leading global designer, manufacturer and marketer of consumer products in the outdoor sports and recreation markets. Vista Outdoor is headquartered in Anoka, Minnesota and has 18 manufacturing and distribution facilities in the United States, Canada, Mexico, and Puerto Rico along with international customer service, sales and sourcing operations in Asia, Canada, and Europe.

Certain products we manufacture or contract to manufacture (“Covered Products”) contain materials and components that contain 3TG that are necessary to the functionality and/or production of such products. Due to the depth of the supply chain, we are far removed from the mining of 3TG ores and the smelters/refiners that process those ores; the efforts we undertook to identify the countries of origin of those ores reflect our circumstances and downstream position in the supply chain. Further, the amount of information available globally on the traceability and sourcing of these ores is limited at this time, and this situation is not unique to us. We have taken steps to identify the applicable smelters and refiners of 3TG in our supply chain; however, we believe that the smelters and refiners of the 3TG contained in the Covered Products are best situated to identify the sources and countries of origin of the 3TG metals they use. We rely on our suppliers to provide us with information on the origin of any conflict minerals contained in components and materials supplied to us.

II.
Reasonable Country of Origin Inquiry

Our conflict minerals due diligence process began with a reasonable country of origin inquiry (“RCOI”) for all conflict minerals known to be contained in products that we manufactured or contracted to be manufactured during the Reporting Period. To implement the RCOI, the companies that provide relevant parts, materials and finished goods directly to Vista Outdoor (our “first tier suppliers”) were engaged to collect information regarding the presence and sourcing of conflict minerals used in those products. Information was collected, stored and evaluated largely using an online platform provided by a third party vendor.

Our supplier engagement included the following steps:




An introductory email was sent to all of our first tier suppliers and those of our licensees (hereinafter, collectively referred to as “suppliers”) describing our Conflict Minerals Compliance Program and requesting information concerning the presence of conflict minerals in the products sold to Vista Outdoors by the supplier.
Following that introductory email, a subsequent email was sent to suppliers containing registration information and a survey request link for the online data collection platform, which utilized the Conflict Minerals Reporting Template (the “CMRT”) developed by the Conflict Free Sourcing Initiative (the “CFSI”).
Our suppliers were also provided access to a Conflict Minerals Supplier Resource Center (https://conflictmineralsresources.com) sponsored by the third party vendor as an educational tool to facilitate a deeper understanding of our Conflict Minerals Compliance Program, supporting regulation and frequently asked questions concerning conflict minerals tracing.
Up to five additional reminder emails were sent to any non-responsive supplier from whom we requested survey completion.
Suppliers who remained non-responsive to email reminders were contacted by telephone and offered assistance. This assistance included, but was not limited to, providing further information about our Conflict Minerals Compliance Program, explaining why the information was being collected, explaining how the information would be used and clarifying how the needed information could be provided.

The third party vendor assisted in evaluating supplier responses for plausibility, consistency and gaps, both in terms of information on the products that were stated to contain or not contain necessary conflict minerals and information on the origin of those conflict minerals. The third party vendor also followed up with suppliers to address issues including implausible statements regarding the presence of conflict minerals, incomplete data on CMRTs, responses that did not identify smelters or refiners (“SORs”) and responses that indicated sourcing location without complete supporting information from the supply chain.

A total of 405 suppliers were contacted as part of our RCOI process. The response rate among these suppliers was 39%. Of these responding suppliers, 13% indicated that certain components they produce contain one or more conflict minerals.

We believe our RCOI process was reasonably designed and performed in good faith, but there are inherent limitations in the information provided to us by third parties, including the possibility of information being inaccurate, incomplete or falsified despite our efforts to validate and confirm the information. The Company does not purchase conflict minerals directly from SORs and, therefore, must rely on its suppliers to provide information regarding the origin of the conflict minerals that are included in the Covered Products. Based on the results of our RCOI, which indicated that one or more of our product components contained conflict minerals that may have originated in the Covered Countries and may not be from recycled or scrap sources, we exercised due diligence on the source and chain of custody of those conflict minerals as described below.

III.
Due Diligence Measures Performed by Vista Outdoor

We designed our conflict minerals due diligence process to conform, in all material respects, with the Organization for Economic Cooperation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements on Tin, Tantalum and Tungsten and on Gold (the “OECD Guidance”). The design of our due diligence process took into account the recommendations of the OECD Guidance for “downstream” companies (those entities in the minerals supply chain from the SORs to retailers).

In accordance with the OECD Guidance, our due diligence measures included the following:

Establishing Strong Company Management Systems
We maintain a multi-disciplinary internal team to implement our due diligence measures. Our Conflict Minerals project team is headed by our Supply Chain Council, consisting of supply chain leadership, and includes other members of our supply chain, engineering, finance and legal departments. The team met



regularly to discuss the due diligence process and progress. We also engaged a third party vendor to support our Conflict Minerals Program.
We have adopted a Conflict Minerals Policy, which details the standards by which our supply chain due diligence will be conducted. We communicated the Conflict Minerals Policy to our direct suppliers.
We employ a system of controls and transparency over our mineral supply chain through the use of the due diligence tools developed by the CFSI, including the CMRT, which is designed to identify the smelters and refiners that process the conflict minerals in a company’s supply chain.
We maintain a company-level grievance mechanism, as described in our Code of Business Ethics, which enables employees and others to report concerns.

Identifying and Assessing Risk in Our Supply Chain
For the Reporting Period, we identified and assessed risks in our supply chain through engagement with suppliers as discussed in Section II of this Report, including through the CMRT survey process and by evaluating suppliers’ responses to the CMRT.

Designing and Implementing a Strategy to Respond to Supply Chain Risks
In order to assess the due diligence practices of the SORs reported to us by suppliers that were known or reasonably believed to have sourced from a Covered Country or that had unknown sourcing, the third party vendor attempted to match each SOR on the list to available lists of SORs that have been certified, or are in the process of being certified, by internationally recognized third party audit programs, such as the CFSI’s Conflict-Free Smelter Program, the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain of Custody Certification program.
If the SOR is not certified by any of these internationally recognized programs, the third party vendor attempted to contact the SOR to gain more information about the SOR’s sourcing practices, including countries of origin, as well as whether the SOR uses any internal due diligence procedures or other processes to track the chain of custody of its mineral ores. In addition, Internet research was also performed to determine whether there are any additional sources of information regarding the SOR’s sourcing practices.
We are in the process of developing a risk management plan to assist us in evaluating supplier relationships and avoiding the use of conflict minerals which could directly or indirectly finance or benefit armed groups in the Covered Countries.
The Conflict Minerals project team reports to senior management on the status of our survey and due diligence processes.

Carrying out Independent Third-Party Audits of Supply Chain Due Diligence
We do not have direct relationships with SORs and we do not perform direct audits of SORs’ supply chains for conflict minerals. However, we support the development and implementation of, and SORs’ participation in, independent third-party audits of SORs’ sourcing practices, such as the CFSI’s Conflict-Free Smelter Program.

Reporting on Supply Chain Due Diligence
We file a Form SD and Conflict Minerals Report with the Securities and Exchange Commission.
Our Conflict Minerals Report is publicly available on our website at http://vistaoutdoor.com/social-responsibility/.

IV.
Smelters or Refiners and Country of Origin of Conflict Minerals

Based on our due diligence efforts, we do not have conclusive information regarding the country of origin of, or SORs used to process, the necessary conflict minerals in the Covered Products for the Reporting Period. Annex A below includes a list of the SORs that our suppliers reported as being in their supply chains, as well as an aggregated list of the countries of origin from which we believe the reported SORs collectively source conflict minerals, based on our review data from several sources, including information provided by suppliers and information the third party



vendor has obtained through engagement with SORs. In many cases, the SOR information provided to us by our suppliers was produced at a company or divisional level based on all of their products as a whole, rather than being limited to the specific products supplied to Vista Outdoor. In addition, many of the supplier responses were incomplete as all minerals supply chain participants continue to map their upstream supply chains. As a result, we are unable to determine whether all of the SORs listed below actually processed conflict minerals used in the Covered Products for the Reporting Period.

Our efforts to determine the mine or location of origin of the conflict minerals in the Covered Products with the greatest possible specificity consisted of the due diligence measures described in this Report, including our efforts to seek information from suppliers using the CMRT.

V.
Future Measures to Mitigate Risk
We continue to evaluate our supplier relationships to promote compliance with our Conflict Minerals Policy and mitigate the risk that the conflict minerals contained in our products could benefit armed groups in the Covered Countries. We are committed to continuously improving our supply chain due diligence efforts using the following measures:

Continuing to assess the presence of conflict minerals in our supply chain;
Continuing to communicate expectations to our suppliers with regard to sourcing of conflict minerals, supplier performance, and transparency;
Continuing engagement with suppliers and working to increase the response rate to the CMRT;
Continuing to develop our risk management plan to assist us in evaluating supplier relationships and avoiding the use of conflict minerals which could directly or indirectly finance or benefit armed groups in the Covered Countries;
Working to establish a system of controls and transparency over our mineral supply chain through our work with our third party vendor;
Implementing internal measures to strengthen our engagement with suppliers on these issues; and
Continuing to compare RCOI results to information collected through independent conflict free smelter validation programs such as the CFSI Conflict Free Smelter Program.





Annex A
Tungsten
*
A.L.M.T. TUNGSTEN Corp.
Tungsten
*
ACL Metais Eireli
Gold
*
Advanced Chemical Company
Gold
*
Aida Chemical Industries Co., Ltd.
Gold
*
Al Etihad Gold Refinery DMCC
Gold
*
Allgemeine Gold-und Silberscheideanstalt A.G.
Gold
*
Almalyk Mining and Metallurgical Complex (AMMC)
Tin
*
Alpha
Tin
 
An Vinh Joint Stock Mineral Processing Company
Gold
*
AngloGold Ashanti Corrego do Sitio Mineracao
Gold
*
Argor-Heraeus S.A.
Gold
*
Asahi Pretec Corp.
Gold
*
Asahi Refining Canada Ltd.
Gold
*
Asahi Refining USA Inc.
Gold, Tantalum
*
Asaka Riken Co., Ltd.
Tungsten
*
Asia Tungsten Products Vietnam Ltd.
Gold
 
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold
*
AU Traders and Refiners
Gold
*
Aurubis AG
Gold
*
Bangalore Refinery
Gold
*
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold
*
Boliden AB
Gold
*
C. Hafner GmbH + Co. KG
Gold
 
Caridad
Gold
*
CCR Refinery - Glencore Canada Corporation
Gold
*
Cendres + Metaux S.A.
Tantalum
*
Changsha South Tantalum Niobium Co., Ltd.
Tungsten
*
Chenzhou Diamond Tungsten Products Co., Ltd.
Tin
*
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin
*
Chifeng Dajingzi Tin Industry Co., Ltd.
Gold
*
Chimet S.p.A.
Tin
*
China Tin Group Co., Ltd.
Tungsten
*
Chongyi Zhangyuan Tungsten Co., Ltd.
Gold
*
Chugai Mining
Tin
*
CV Ayi Jaya
Tin
*
CV Dua Sekawan
Tin
*
CV Gita Pesona
Tin
*
CV United Smelting
Tin
*
CV Venus Inti Perkasa
Tantalum
*
D Block Metals, LLC
Gold
*
Daejin Indus Co., Ltd.



Gold
 
Daye Non-Ferrous Metals Mining Ltd.
Gold
 
Degussa Sonne / Mond Goldhandel GmbH
Gold
*
DODUCO Contacts and Refining GmbH
Gold, Tin
*
Dowa
Gold
*
DSC (Do Sung Corporation)
Gold
*
Eco-System Recycling Co., Ltd.
Tin
 
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin
*
EM Vinto
Gold
*
Emirates Gold DMCC
Tin
 
Estanho de Rondonia S.A.
Tantalum
*
Exotech Inc.
Tantalum
*
F&X Electro-Materials Ltd.
Tin
*
Fenix Metals
Tantalum
*
FIR Metals & Resource Ltd.
Tungsten
*
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
*
Ganzhou Haichuang Tungsten Co., Ltd.
Tungsten
*
Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten
*
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten
*
Ganzhou Seadragon W & Mo Co., Ltd.
Gold
 
GCC Gujrat Gold Centre Pvt. Ltd.
Gold
*
Geib Refining Corporation
Tin
*
Gejiu Fengming Metallurgy Chemical Plant
Tin
*
Gejiu Kai Meng Industry and Trade LLC
Tin
*
Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin
*
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin
*
Gejiu Zili Mining And Metallurgy Co., Ltd.
Tantalum
*
Global Advanced Metals Aizu
Tantalum
*
Global Advanced Metals Boyertown
Tungsten
*
Global Tungsten & Powders Corp.
Gold
*
Gold Refinery of Zijin Mining Group Co., Ltd.
Gold
 
Great Wall Precious Metals Co., Ltd. of CBPM
Tin
*
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
Gold
 
Guangdong Jinding Gold Limited
Tantalum
*
Guangdong Rising Rare Metals-EO Materials Ltd.
Tungsten
*
Guangdong Xianglu Tungsten Co., Ltd.
Tantalum
*
Guangdong Zhiyuan New Material Co., Ltd.
Tin
*
Guanyang Guida Nonferrous Metal Smelting Plant
Gold
 
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Tantalum
*
H.C. Starck Co., Ltd.
Tantalum
*
H.C. Starck Hermsdorf GmbH
Tantalum
*
H.C. Starck Inc.
Tantalum
*
H.C. Starck Ltd.



Tantalum, Tungsten
*
H.C. Starck Smelting GmbH & Co. KG
Tantalum
*
H.C. Starck Tantalum and Niobium GmbH
Tungsten
*
H.C. Starck Tungsten GmbH
Gold
 
Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold
*
HeeSung Metal Ltd.
Gold
*
Heimerle + Meule GmbH
Tantalum
*
Hengyang King Xing Lifeng New Materials Co., Ltd.
Gold
*
Heraeus Metals Hong Kong Ltd.
Gold
*
Heraeus Precious Metals GmbH & Co. KG
Tin
 
HuiChang Hill Tin Industry Co., Ltd.
Tin
*
Huichang Jinshunda Tin Co., Ltd.
Gold, Tungsten
*
Hunan Chenzhou Mining Co., Ltd.
Tungsten
*
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten
*
Hunan Chunchang Nonferrous Metals Co., Ltd.
Gold
 
HwaSeong CJ CO., LTD.
Tungsten
*
Hydrometallurg, JSC
Gold
*
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold
*
Ishifuku Metal Industry Co., Ltd.
Gold
*
Istanbul Gold Refinery
Gold
*
Italpreziosi
Gold
*
Japan Mint
Tungsten
*
Japan New Metals Co., Ltd.
Tungsten
*
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Gold
*
Jiangxi Copper Co., Ltd.
Tantalum
*
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tungsten
*
Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten
 
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tin
*
Jiangxi New Nanshan Technology Ltd.
Tungsten
*
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tantalum
*
Jiangxi Tuohong New Raw Material
Tungsten
*
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten
*
Jiangxi Yaosheng Tungsten Co., Ltd.
Tantalum
*
Jiujiang Janny New Material Co., Ltd.
Tantalum
*
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum
*
Jiujiang Tanbre Co., Ltd.
Tantalum
*
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Gold
 
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold
*
JSC Uralelectromed
Gold
*
JX Nippon Mining & Metals Co., Ltd.
Gold
 
Kazakhmys Smelting LLC
Gold
*
Kazzinc
Tantalum
*
KEMET Blue Metals
Tantalum
*
Kemet Blue Powder



Tungsten
*
Kennametal Fallon
Tungsten
*
Kennametal Huntsville
Gold
*
Kennecott Utah Copper LLC
Gold
 
KGHM Polska Miedz Spolka Akcyjna
Gold
*
Kojima Chemicals Co., Ltd.
Gold
*
Korea Zinc Co., Ltd.
Gold
*
Kyrgyzaltyn JSC
Gold
 
Kyshtym Copper-Electrolytic Plant ZAO
Gold
 
L'azurde Company For Jewelry
Gold
 
Lingbao Gold Co., Ltd.
Gold
 
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold
*
L'Orfebre S.A.
Tantalum
*
LSM Brasil S.A.
Gold
*
LS-NIKKO Copper Inc.
Gold
 
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Tin
*
Magnu's Minerais Metais e Ligas Ltda.
Tin
*
Malaysia Smelting Corporation (MSC)
Tungsten
*
Malipo Haiyu Tungsten Co., Ltd.
Gold
*
Marsam Metals
Tungsten
*
Masan Tungsten Chemical LLC (MTC)
Gold
*
Materion
Gold
*
Matsuda Sangyo Co., Ltd.
Tin
*
Melt Metais e Ligas S.A.
Tin
*
Metallic Resources, Inc.
Tin
*
Metallo Belgium N.V.
Tin
*
Metallo Spain S.L.U.
Tantalum
*
Metallurgical Products India Pvt., Ltd.
Gold
*
Metalor Technologies (Hong Kong) Ltd.
Gold
*
Metalor Technologies (Singapore) Pte., Ltd.
Gold
*
Metalor Technologies (Suzhou) Ltd.
Gold
*
Metalor Technologies S.A.
Gold
*
Metalor USA Refining Corporation
Gold
*
Metalurgica Met-Mex Penoles S.A. De C.V.
Tantalum, Tin
*
Mineracao Taboca S.A.
Tin
*
Minsur
Gold, Tin
*
Mitsubishi Materials Corporation
Gold, Tantalum
*
Mitsui Mining and Smelting Co., Ltd.
Gold
*
MMTC-PAMP India Pvt., Ltd.
Gold, Tin
 
Modeltech Sdn Bhd
Tungsten
*
Moliren Ltd.
Gold
 
Morris and Watson
Gold
 
Morris and Watson Gold Coast
Gold
*
Moscow Special Alloys Processing Plant



Gold
*
Nadir Metal Rafineri San. Ve Tic. A.S.
Gold
 
Navoi Mining and Metallurgical Combinat
Tin
 
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tungsten
*
Niagara Refining LLC
Gold
*
Nihon Material Co., Ltd.
Tantalum
*
Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum
*
NPM Silmet AS
Tin
*
O.M. Manufacturing (Thailand) Co., Ltd.
Tin
*
O.M. Manufacturing Philippines, Inc.
Gold
*
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Gold
*
Ohura Precious Metal Industry Co., Ltd.
Gold
*
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Gold
*
OJSC Novosibirsk Refinery
Tin
*
Operaciones Metalurgical S.A.
Gold
*
PAMP S.A.
Gold
 
Pease & Curren
Gold
 
Penglai Penggang Gold Industry Co., Ltd.
Tungsten
*
Philippine Chuangxin Industrial Co., Inc.
Gold
*
Planta Recuperadora de Metales SpA
Tantalum
*
Power Resources Ltd.
Gold
*
Prioksky Plant of Non-Ferrous Metals
Gold
*
PT Aneka Tambang (Persero) Tbk
Tin
*
PT Aries Kencana Sejahtera
Tin
*
PT Artha Cipta Langgeng
Tin
*
PT ATD Makmur Mandiri Jaya
Tin
*
PT Babel Inti Perkasa
Tin
*
PT Bangka Prima Tin
Tin
*
PT Bangka Serumpun
Tin
*
PT Bangka Tin Industry
Tin
*
PT Belitung Industri Sejahtera
Tin
*
PT Bukit Timah
Tin
*
PT DS Jaya Abadi
Tin
*
PT Inti Stania Prima
Tin
*
PT Karimun Mining
Tin
*
PT Kijang Jaya Mandiri
Tin
*
PT Menara Cipta Mulia
Tin
*
PT Mitra Stania Prima
Tin
*
PT Panca Mega Persada
Tin
*
PT Premium Tin Indonesia
Tin
*
PT Prima Timah Utama
Tin
*
PT Rajehan Ariq
Tin
*
PT Refined Bangka Tin



Tin
*
PT Sariwiguna Binasentosa
Tin
*
PT Stanindo Inti Perkasa
Tin
*
PT Sukses Inti Makmur
Tin
*
PT Sumber Jaya Indah
Tin
*
PT Timah (Persero) Tbk Kundur
Tin
*
PT Timah (Persero) Tbk Mentok
Tin
*
PT Tinindo Inter Nusa
Tin
*
PT Tommy Utama
Gold
*
PX Precinox S.A.
Tantalum
*
QuantumClean
Gold
*
Rand Refinery (Pty) Ltd.
Gold
 
Refinery of Seemine Gold Co., Ltd.
Gold
*
REMONDIS PMR B.V.
Tantalum, Tin
*
Resind Industria e Comercio Ltda.
Gold
*
Royal Canadian Mint
Tin
*
Rui Da Hung
Gold
*
SAAMP
Gold
 
Sabin Metal Corp.
Gold
*
Safimet S.p.A
Gold
 
Sai Refinery
Gold
*
Samduck Precious Metals
Gold
 
SAMWON METALS Corp.
Gold
*
SAXONIA Edelmetalle GmbH
Gold
*
SEMPSA Joyeria Plateria S.A.
Gold
 
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold
*
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold
*
Sichuan Tianze Precious Metals Co., Ltd.
Gold
*
Singway Technology Co., Ltd.
Gold
*
SOE Shyolkovsky Factory of Secondary Precious Metals
Tin
*
Soft Metais Ltda.
Gold
*
Solar Applied Materials Technology Corp.
Tantalum
*
Solikamsk Magnesium Works OAO
Tungsten
*
South-East Nonferrous Metal Company Limited of Hengyang City
Gold
 
State Research Institute Center for Physical Sciences and Technology
Gold
*
Sumitomo Metal Mining Co., Ltd.
Gold
*
SungEel HiMetal Co., Ltd.
Tin
 
Super Ligas
Gold
*
T.C.A S.p.A
Tantalum
*
Taki Chemical Co., Ltd.
Gold
*
Tanaka Kikinzoku Kogyo K.K.
Tungsten
*
Tejing (Vietnam) Tungsten Co., Ltd.
Tantalum
*
Telex Metals
Tin
*
Thaisarco



Gold
*
The Refinery of Shandong Gold Mining Co., Ltd.
Gold
*
Tokuriki Honten Co., Ltd.
Gold
 
Tongling Nonferrous Metals Group Co., Ltd.
Gold
 
TOO Tau-Ken-Altyn
Gold
*
Torecom
Tin
 
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tantalum
*
Ulba Metallurgical Plant JSC
Gold
*
Umicore Brasil Ltda.
Gold
*
Umicore Precious Metals Thailand
Gold
*
Umicore S.A. Business Unit Precious Metals Refining
Tungsten
*
Unecha Refractory Metals Plant
Gold
*
United Precious Metal Refining, Inc.
Gold
*
Valcambi S.A.
Gold
*
Western Australian Mint (T/a The Perth Mint)
Tin
*
White Solder Metalurgia e Mineracao Ltda.
Gold
*
WIELAND Edelmetalle GmbH
Tungsten
*
Wolfram Bergbau und Hutten AG
Tungsten
*
Woltech Korea Co., Ltd.
Tungsten
*
Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten
*
Xiamen Tungsten Co., Ltd.
Tungsten
*
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
Tungsten
*
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
Tantalum
*
XinXing Haorong Electronic Material Co., Ltd.
Gold
*
Yamakin Co., Ltd.
Tantalum
*
Yanling Jincheng Tantalum & Niobium Co., Ltd.
Gold
*
Yokohama Metal Co., Ltd.
Tin
*
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Gold
 
Yunnan Copper Industry Co., Ltd.
Tin
*
Yunnan Tin Company Limited
Gold
*
Zhongyuan Gold Smelter of Zhongjin Gold Corporation

*Denotes SORs that have received a “conflict free” designation from an independent third party audit program as of May 15, 2019.

We believe that the countries of origin for the conflict minerals processed by these SORs include Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo (Brazzaville), Czech Republic, Djibouti, DRC- Congo (Kinshasa), Ecuador, Egypt, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Jersey, Kazakhstan, Kenya, Republic of Korea, Kyrgyzstan, Laos, Luxembourg, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia, and Zimbabwe.