EX-1.01 2 exhibit1012024conflictmi.htm EX-1.01 exhibit1012024conflictmi
Exhibit 1.01 LivaNova PLC Conflict Minerals Report For the Year Ended December 31, 2023 This Conflict Minerals Report (this “Report”) of LivaNova PLC has been prepared for the reporting period from January 1, 2023 to December 31, 2023, pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement disclosure and reporting requirements pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). The Act defines conflict minerals as cassiterite, columbite-tantalite (coltan), gold, wolframite or their derivatives, tin, tantalum, and tungsten (“3TGs”). The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo (“DRC”), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola. The Rule imposes certain reporting requirements on SEC registrants who manufacture or contract to manufacture products that include 3TGs if such 3TGs are necessary to the functionality or production of the products. 1. Company Overview This Report has been prepared by the management of LivaNova PLC (“LivaNova,” “registrant,” or the “Company”). It does not include the activities of variable interest entities that are not required to be consolidated. This Report reports the reasonable country of origin inquiry (“RCOI”) conducted in good faith to determine whether any of the necessary 3TGs in LivaNova’s product offerings originated from Conflict-Affected and High-Risk Areas (CAHRAs), such as the Covered Countries, or came from recycled or scrap sources for the year ended December 31, 2023, and subsequent due diligence measures. In fiscal year 2023, LivaNova operated as three reportable segments: • Cardiopulmonary (CP): The Company’s Cardiopulmonary segment is engaged in the design, development, manufacture, marketing and selling of cardiopulmonary products including oxygenators, heart-lung machines, autotransfusion systems, perfusion tubing systems, cannulae and other related accessories. • Neuromodulation (NM): The Company’s Neuromodulation segment is engaged in the design, development, manufacture, marketing, and selling of products that deliver neuromodulation therapy to treat drug-resistant epilepsy and difficult-to-treat depression. It also encompasses the development and management of clinical testing of the Company’s aura6000 System for treating obstructive sleep apnea, as well as the Company’s VITARIA System for treating heart failure. (The Company announced in February 2023 that it is stopping enrollment in the heart failure study, beginning the process to close the clinical study and winding down the heart failure program.) • Advanced Circulatory Support (ACS): The Company’s ACS segment was engaged in the development, production and sale of leading-edge temporary life support products, including cardiopulmonary and respiratory support solutions consisting of temporary life support controllers and product kits that can include a combination of pumps, oxygenators, and cannulae. In January 2024, the Board of Directors of LivaNova approved a plan to enhance the Company’s focus on its core Cardiopulmonary and Neuromodulation segments. The main component of this plan is to wind down the ACS segment, which the Company anticipates will be substantially complete by the end of 2024. LivaNova’s broad and complex product offerings may contain 3TGs within the following components: • Tantalum, used in capacitors; • Tin, used in electrical components, printed circuit board assembly, hardware and equipment; • Tungsten, used in coatings, alloys, heating elements and electrodes; and • Gold, used in circuit boards, electrodes, coatings, and electronic components. Additional information on LivaNova is available at livanova.com. Information on the Company’s website is not incorporated into this Report. 2. General Policy and Team LivaNova embraces the key principles of the International Labour Organization’s fundamental conventions. LivaNova believes that the Company’s business can only succeed where the rights of all workers involved in the value chain of the Company’s businesses are protected and respected, and the Company aims to conduct business with third parties including consultants, suppliers and other business partners (“Third Parties”) who share LivaNova’s commitment to operating in a responsible and ethical manner. LivaNova strives to conduct the Company’s activities in a manner that reflects the Company’s mission and Code of Ethics and Business Conduct – which includes being a good corporate citizen, dealing fairly in business, behaving ethically, supporting a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. LivaNova is committed to ensuring that the Company’s supply chain reflects LivaNova’s values and beliefs, including adherence to principles of responsible sourcing for materials for the Company’s products. As part of the Company’s commitment, LivaNova supports the goals and objectives of Section 1502 of the Dodd Frank Act and seeks to uphold responsible sourcing practices. LivaNova expects the Company’s suppliers to support the Company’s efforts to comply with the Dodd Frank Act and to proactively identify and work towards eliminating the use of any minerals that fund or benefit armed groups from within the Company’s supply chain. In addition, LivaNova expects the Company’s suppliers to conduct business operations in an ethical manner and to comply with the Company’s Third Party Code of Ethics and Business Conduct (“Third Party Code of


 
Conduct”) (livanova.com/en-us/about-us/ethics) and all applicable laws related to environmental responsibility, workplace health and safety, and human resources. Through the Nominating and Corporate Governance Committee of the Board of Directors, the Board oversees the Company’s sustainability efforts, which are led by the Senior Director of Sustainability. The Company’s sustainability governance structure includes regular executive team engagement with a Steering Committee body (sponsored by the CFO) and the cross-functional Environmental, Social, and Governance (ESG) Task Force. The ESG Task Force is comprised of vice presidents and key stakeholders who lead ESG focus areas or whose work is informed by ESG. This global stakeholder team also monitors relevant regulations in global markets to enable LivaNova to meet or surpass ESG and Sustainability performance expectations and requirements. 3. Reasonable Country of Origin Inquiry In collaboration with LivaNova’s partners at Assent Inc. (“Assent”), a supply chain sustainability management provider, the Company determined which of the Company’s products potentially contain 3TGs necessary to the functionality or production of such products. LivaNova then conducted a good faith RCOI designed to determine whether any necessary 3TGs contained in the Company’s products originated CAHRAs or came from recycled or scrap sources. LivaNova does not purchase minerals directly from mines, smelters or refiners (“SORs”) and therefore must rely on the Company’s direct suppliers to provide information on the origin of the minerals contained in components and materials supplied to the Company or products manufactured for the Company. LivaNova begins the supplier scoping process by: • Determining which commercially distributed products in 2023 potentially contained one or more of the 3TGs necessary to the functionality or production of such products; • Identifying suppliers or contract manufacturers that provide LivaNova components, subassemblies, or finished products which may contain these necessary 3TGs within these commercially distributed products (in-scope suppliers); and • Providing this list composed of these potential in-scope suppliers and the associated LivaNova part identifiers to Assent for upload to the Assent Compliance Manager (“ACM”), a platform to complete and track supplier communications. The supply chain survey and the related LivaNova conflict minerals process, has been developed and implemented in cooperation with Assent. To collect data on the sources of origin of the necessary 3TG procured by the supply chain, LivaNova utilized the Conflict Minerals Reporting Template (“CMRT”) version 6.2 or higher to conduct a survey of all in-scope suppliers. During the supplier survey, LivaNova contacted 313 suppliers via ACM, a software-as-a-service (SaaS) platform provided by Assent that enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment, and management. The ACM also provides functionality that meets the Organization for Economic Co-Operation and Development (“OECD”) Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. The metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations, are managed through this platform. Via the ACM and Assent team, LivaNova requested that all potential in-scope suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the ACM for future reporting and transparency. LivaNova directly contacted suppliers that were unresponsive to Assent’s repeated communication attempts during the diligence process and requested these suppliers complete the CMRT and submit it to Assent. LivaNova’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement. All submitted forms are accepted and classified as valid or invalid so that data is retained. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, LivaNova tracks program gaps to account for future improvement opportunities. As of May 9, 2024, there were 313 suppliers in scope of the conflict minerals program. Of those 313 suppliers in scope, 241 suppliers provided a completed CMRT. As of May 9, 2024, there were 5 invalid or incomplete supplier submissions that could not be corrected. LivaNova’s total response rate for this reporting year was 77%. Based on the Company’s RCOI, LivaNova has reason to believe that some of the necessary 3TG in the Company’s products may have originated in the Covered Countries and did not come from recycled or scrap sources. Accordingly, LivaNova conducted additional due diligence as described below. 4. Design of Due Diligence LivaNova designed its due diligence process to be in conformity, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance, and LivaNova continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.


 
Due diligence requires LivaNova to rely on data provided by direct suppliers and third party audit programs. There is a risk of incomplete or inaccurate data as the process cannot fully be owned by LivaNova. However, through continued outreach and process validation, in collaboration with Assent, LivaNova believes that the Company’s process aligns with industry standards and market expectations for downstream companies’ due diligence. a. Establish Strong Company Management and Control Systems i. Internal Team LivaNova has established a management team responsible for the conflict minerals program. In 2023, the Company’s management team was overseen by the Vice President of Neuromodulation Operations, who is also a member of LivaNova’s ESG task force, and a team of subject matter experts from relevant functions such as supply chain, sourcing, operations, and legal. The team of subject matter experts is responsible for implementing the Company’s conflict minerals compliance strategy. ii. Control Systems and Company Policies LivaNova’s controls include, but are not limited to, the Company’s Code of Ethics and Business Conduct which outlines certain expected behaviors for all employees. In addition, LivaNova’s Third Party Code of Conduct, which is published externally (in multiple languages) as well as in a majority of the Company’s indirect purchase order terms and conditions, defines the standards that the Company requires of all LivaNova Third Parties to comply with when doing business with us, in addition to all applicable laws, regulations and industry standards. Compliance with LivaNova’s Third Party Code of Conduct informs an important part of LivaNova’s Third Party selection and evaluation. LivaNova requires Third Parties to meet the Company’s requirements and to pass on these requirements to their respective supply chains. If an audit conducted by or on behalf of LivaNova reveals non-alignment with the Company’s Third Party Code of Conduct, LivaNova has the right to take corrective measures that, in the event of significant non-compliance, may also include immediate termination of the business relationship. In addition, LivaNova relies on the Company’s direct in-scope suppliers to provide information on the origin of the necessary 3TGs contained in components and materials supplied to us, including sources of necessary 3TGs that are supplied to them from lower tier suppliers. LivaNova’s General Terms and Conditions for the Purchase of Products and Services included with the Company’s purchase orders specify that, in order to conduct business with LivaNova, a supplier may be required to complete a questionnaire designed to identify the potential presence of 3TGs in any products it sells to LivaNova, and if necessary, perform appropriate due diligence. iii. Supplier Engagement As LivaNova does not have a direct relationship with 3TGs SORs, the Company is engaged and actively cooperates with other manufacturers in the Company’s industry and other sectors. The Company relies primarily on the Company’s Tier 1 direct suppliers to provide information on the origin of the necessary 3TGs contained in components and materials supplied to us, including sources of necessary 3TGs that are supplied to them from lower tier suppliers. The Company engages with suppliers directly to request a valid CMRT for the products that they supply to LivaNova. With respect to the OECD requirement to strengthen engagement with suppliers, LivaNova has developed an internal process that includes steps of supplier engagement escalation such as in-person meetings and corrective actions. iv. Grievance Mechanism LivaNova proactively promotes ethical behavior and encourages all of its stakeholders to Speak Up and report violations of laws, regulations, and/or the Company’s policies and procedures, including the Company’s Code of Ethics and Business Conduct and the Company’s Third Party Code of Conduct. While LivaNova encourages employees to raise issues with their managers, the Company also maintain an Ethics and Integrity Helpline where concerns can be reported confidentially and anonymously. All reports received are triaged to ensure timely and effective follow up. Violations or grievances at the industry level can be reported to the RMI directly as well. This can be done at responsiblemineralsinitiative.org/ responsible-minerals-assurance-process/grievance-mechanism/. v. Records Maintenance LivaNova has retained relevant documentation from the Company’s RCOI and due diligence process. Through Assent, a document retention policy to retain conflict minerals related documents for up to five years, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. b. Identify and Assess Risk in LivaNova’s Supply Chain The ACM provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by- step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform. Risks associated with supplier CMRT content are identified automatically in the ACM based on criteria established for supplier responses. These risks are addressed by Assent staff and members of the internal Conflict Minerals Team, who contact the supplier, gather pertinent data, and perform an assessment of the supplier’s conflict minerals status.


 
Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, LivaNova is unable to determine if all of the specified smelters/ refiners were used for 3TGs in the components or products supplied. Assent’s supplier risk assessment (flagging suppliers’ risk as high, medium, low) identifies problematic suppliers in a company’s supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis that takes into account multiple conflict minerals factors. Risks were identified by assessing the due diligence practices and status of SORs identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent’s smelter validation program compared listed facilities into the list of smelters/refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TG processing facility that was operational during the 2023 calendar year. Assent determined if the smelter or refiner had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). LivaNova does not have a direct relationship with SORs and does not perform direct audits of these entities within their supply chain. SORs that are conformant to RMAP audit standards are considered to have their sourcing validated as “conflict free or responsibly sourced.” In cases where the SOR’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, follow-ups are made to suppliers reporting those facilities. SORs are then assessed for the potential for sourcing risk. Risk mitigation activities are initiated whenever a supplier’s CMRT reported facilities of concern. Through Assent, suppliers with submissions that included any SORs of concern were immediately provided with feedback instructing the flagged supplier to take its own independent risk mitigation actions. Additional escalation may have been necessary to address any continued sourcing from these SORs of concern. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these SORs of concern from the supply chain. In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process. c. Design and Implement a Strategy to Respond to Risks Together with Assent, LivaNova developed processes to assess and respond to the risks identified in the supply chain. LivaNova has a plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non- responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and LivaNova’s expectations. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, LivaNova assesses if replacement of such supplier is feasible. d. Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain LivaNova does not have a direct relationship with SORs of 3TGs and as a result, LivaNova does not perform direct audits of these entities in its supply chain. LivaNova relies on the efforts of the industry associations that administer independent third party SOR audit programs and encourages suppliers with more direct relationships with SORs to participate in comparable due diligence validation activities. Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. e. Report on Supply Chain Due Diligence This Conflict Minerals Report is being filed with the SEC as an exhibit to LivaNova’s specialized disclosure report on Form SD and is available on the Company’s website at investor.livanova.com/financial-information/sec-filings. LivaNova has also considered impacts from the European Union Conflict Minerals Regulation when disclosing details with regards to due diligence efforts. The Company continues to expand efforts to increase transparency through the Company’s data collection process and risk evaluation, as well as for disclosure by way of public reporting tools. 5. Due Diligence Results During the Company’s due diligence efforts, members of Assent and/or members of the LivaNova supply chain team made several follow-up inquiries to each “non-responsive” supplier who did not respond to the Company’s initial survey, by phone or email. Assent reviewed the responses against criteria developed to determine which required further engagement with the Company’s suppliers. These criteria included incomplete responses as well as inconsistencies within the data reported in the CMRT. Assent worked directly with those suppliers to provide revised responses. The large majority of the received responses provided data at the supplier company level or a division/segment level relative to the supplier, rather than at a level directly relating to a part number that the supplier supplies to us or were otherwise unable to specify the SORs used for components supplied to us. The Company was therefore unable to determine whether any of the necessary 3TGs that these suppliers reported were contained in components or parts supplied directly to us. As noted above, LivaNova received 241 responses from the Company’s in-scope suppliers as of May 9, 2024. Based on these responses, for all responses that indicated a SOR, the Company’s third party consultant compared the facilities listed to the list of SORs maintained by the RMI. If a supplier indicated that the facility was certified as “Conflict-Free,” Assent confirmed that the name was listed by RMI as RMAP


 
Conformant. As of May 9, 2024, LivaNova validated 350 SORs, and the Company is working to validate the additional SOR entries from the submitted CMRTs. Appendix A lists all validated smelters and refiners that the suppliers the Company surveyed reported as being in their supply chains. LivaNova has not listed in Appendix A any smelters or refiners that the Company has not been able to validate. Appendix B includes an aggregated list of the potential countries of origin from which the reported SORs collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. It is understood that many responses may provide more data than can be directly linked to LivaNova products, and therefore, Appendices A and B may contain more SORs and/or countries than those that the necessary 3TGs in the Company’s products are being sourced from. Based on the smelter lists provided by suppliers via the CMRTs and publicly available information, LivaNova has identified 225 SORs that are RMAP Conformant and an additional 6 that are RMAP Active (meaning they have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment) as defined by the RMI smelter data. The remaining 119 have been identified as Non-Conformant or Not Enrolled. a. Efforts to Determine Mine or Location of Origin By requesting that the Company’s suppliers complete the CMRT, and, as the program progresses, requiring full completion of all necessary smelter identification information, which will enable the validation and disclosure of the SORs as well as the tracing of the 3TGs to their location of origin, LivaNova has determined that seeking information about 3TGs SORs in the Company’s supply chain represents the most reasonable effort the Company can make to determine the mines or locations of origin of the necessary 3TGs in the Company’s supply chain. 6. Planned Process Improvements to Mitigate Risks LivaNova intends to take the following steps to improve the Company’s conflict minerals program: • Track and add new suppliers who provide components containing necessary 3TGs to the conflict minerals program. • Engage with suppliers and direct them to training resources to increase the response rate and improve the content of the supplier survey responses. • Continue to consider the European Union Conflict Minerals Regulation within the Company’s conflict mineral program and when applicable to LivaNova, comply with the relevant requirements. • Continue to evaluate the Company’s conflict mineral program and, if necessary, implement relevant updates, e.g., if cobalt becomes a mandatory regulation compliance requirement.


 
Appendix A: 2023 Smelter or Refiner (SOR) List The following smelters and refiners were reported by LivaNova’s suppliers as being in their supply chains. Only those validated as being legitimate are provided. The validation process involves cross-referencing incoming data from the Company’s suppliers with the Assent database, as well as the latest publicly available Responsible Minerals Initiative (RMI) smelter data. As noted in the report, it is relevant to note that overreporting might occur which could result in this Appendix containing more SORs than those potentially relevant to the Company’s products. Metal Smelter Name Smelter Facility Location Smelter ID Gold L'Orfebre S.A. Andorra CID002762 Gold Western Australian Mint (T/a The Perth Mint) Australia CID002030 Gold ABC Refinery Pty Ltd. Australia CID002920 Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria CID002779 Gold Umicore S.A. Business Unit Precious Metals Refining Belgium CID001980 Gold Industrial Refining Company Belgium CID002587 Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil CID000058 Gold Marsam Metals Brazil CID002606 Gold Coimpa Industrial LTDA Brazil CID004010 Gold CCR Refinery - Glencore Canada Corporation Canada CID000185 Gold Asahi Refining Canada Ltd. Canada CID000924 Gold Royal Canadian Mint Canada CID001534 Gold Planta Recuperadora de Metales SpA Chile CID002919 Gold Yunnan Copper Industry Co., Ltd. China CID000197 Gold Daye Non-Ferrous Metals Mining Ltd. China CID000343 Gold Refinery of Seemine Gold Co., Ltd. China CID000522 Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. China CID000651 Gold Hangzhou Fuchunjiang Smelting Co., Ltd. China CID000671 Gold Heraeus Metals Hong Kong Ltd. China CID000707 Gold Hunan Chenzhou Mining Co., Ltd. China CID000767 Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China CID000773 Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China CID000801 Gold Jiangxi Copper Co., Ltd. China CID000855 Gold Lingbao Gold Co., Ltd. China CID001056 Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. China CID001058 Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China CID001093 Gold Metalor Technologies (Suzhou) Ltd. China CID001147 Gold Metalor Technologies (Hong Kong) Ltd. China CID001149 Gold Penglai Penggang Gold Industry Co., Ltd. China CID001362 Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China CID001619 Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China CID001622 Gold Sichuan Tianze Precious Metals Co., Ltd. China CID001736 Gold Great Wall Precious Metals Co., Ltd. of CBPM China CID001909 Gold Shandong Gold Smelting Co., Ltd. China CID001916 Gold Tongling Nonferrous Metals Group Co., Ltd. China CID001947 Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation China CID002224


 
Metal Smelter Name Smelter Facility Location Smelter ID Gold Gold Refinery of Zijin Mining Group Co., Ltd. China CID002243 Gold Guangdong Jinding Gold Limited China CID002312 Gold Shandong Humon Smelting Co., Ltd. China CID002525 Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China CID002527 Gold Shenzhen CuiLu Gold Co., Ltd. China CID002750 Gold Dongwu Gold Group China CID003663 Gold Gold by Gold Colombia Colombia CID003641 Gold SAFINA A.S. Czechia CID002290 Gold SAAMP France CID002761 Gold WEEEREFINING France CID003615 Gold Agosi AG Germany CID000035 Gold Aurubis AG Germany CID000113 Gold C. Hafner GmbH + Co. KG Germany CID000176 Gold Heimerle + Meule GmbH Germany CID000694 Gold Heraeus Germany GmbH Co. KG Germany CID000711 Gold WIELAND Edelmetalle GmbH Germany CID002778 Gold Degussa Sonne / Mond Goldhandel GmbH Germany CID002867 Gold Gold Coast Refinery Ghana CID003186 Gold MMTC-PAMP India Pvt., Ltd. India CID002509 Gold Shirpur Gold Refinery Ltd. India CID002588 Gold GGC Gujrat Gold Centre Pvt. Ltd. India CID002852 Gold Sai Refinery India CID002853 Gold Bangalore Refinery India CID002863 Gold JALAN & Company India CID002893 Gold CGR Metalloys Pvt Ltd. India CID003382 Gold Sovereign Metals India CID003383 Gold Augmont Enterprises Private Limited India CID003461 Gold Kundan Care Products Ltd. India CID003463 Gold Emerald Jewel Industry India Limited (Unit 1) India CID003487 Gold Emerald Jewel Industry India Limited (Unit 2) India CID003488 Gold Emerald Jewel Industry India Limited (Unit 3) India CID003489 Gold Emerald Jewel Industry India Limited (Unit 4) India CID003490 Gold MD Overseas India CID003548 Gold PT Aneka Tambang (Persero) Tbk Indonesia CID001397 Gold Chimet S.p.A. Italy CID000233 Gold T.C.A S.p.A Italy CID002580 Gold 8853 S.p.A. Italy CID002763 Gold Italpreziosi Italy CID002765 Gold Safimet S.p.A Italy CID002973 Gold Aida Chemical Industries Co., Ltd. Japan CID000019 Gold Asahi Pretec Corp. Japan CID000082 Gold Asaka Riken Co., Ltd. Japan CID000090 Gold Chugai Mining Japan CID000264 Gold Dowa Japan CID000401 Gold Eco-System Recycling Co., Ltd. East Plant Japan CID000425


 
Metal Smelter Name Smelter Facility Location Smelter ID Gold Ishifuku Metal Industry Co., Ltd. Japan CID000807 Gold Japan Mint Japan CID000823 Gold JX Nippon Mining & Metals Co., Ltd. Japan CID000937 Gold Kojima Chemicals Co., Ltd. Japan CID000981 Gold Matsuda Sangyo Co., Ltd. Japan CID001119 Gold Mitsubishi Materials Corporation Japan CID001188 Gold Mitsui Mining and Smelting Co., Ltd. Japan CID001193 Gold Nihon Material Co., Ltd. Japan CID001259 Gold Ohura Precious Metal Industry Co., Ltd. Japan CID001325 Gold Sumitomo Metal Mining Co., Ltd. Japan CID001798 Gold Tanaka Kikinzoku Kogyo K.K. Japan CID001875 Gold Tokuriki Honten Co., Ltd. Japan CID001938 Gold Yamakin Co., Ltd. Japan CID002100 Gold Yokohama Metal Co., Ltd. Japan CID002129 Gold Eco-System Recycling Co., Ltd. North Plant Japan CID003424 Gold Eco-System Recycling Co., Ltd. West Plant Japan CID003425 Gold Kazakhmys Smelting LLC Kazakhstan CID000956 Gold Kazzinc Kazakhstan CID000957 Gold TOO Tau-Ken-Altyn Kazakhstan CID002615 Gold DSC (Do Sung Corporation) Korea, Republic of CID000359 Gold LT Metal Ltd. Korea, Republic of CID000689 Gold HwaSeong CJ CO., LTD. Korea, Republic of CID000778 Gold LS-NIKKO Copper Inc. Korea, Republic of CID001078 Gold Samduck Precious Metals Korea, Republic of CID001555 Gold Samwon Metals Corp. Korea, Republic of CID001562 Gold Torecom Korea, Republic of CID001955 Gold Korea Zinc Co., Ltd. Korea, Republic of CID002605 Gold SungEel HiMetal Co., Ltd. Korea, Republic of CID002918 Gold NH Recytech Company Korea, Republic of CID003189 Gold Kyrgyzaltyn JSC Kyrgyzstan CID001029 Gold State Research Institute Center for Physical Sciences and Technology Lithuania CID003153 Gold Modeltech Sdn Bhd Malaysia CID002857 Gold Caridad Mexico CID000180 Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico CID001161 Gold REMONDIS PMR B.V. Netherlands CID002582 Gold Morris and Watson New Zealand CID002282 Gold K.A. Rasmussen Norway CID003497 Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines CID000128 Gold KGHM Polska Miedz Spolka Akcyjna Poland CID002511 Gold Albino Mountinho Lda. Portugal CID002760 Gold JSC Novosibirsk Refinery Russian Federation CID000493 Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation CID000927


 
Metal Smelter Name Smelter Facility Location Smelter ID Gold JSC Uralelectromed Russian Federation CID000929 Gold Prioksky Plant of Non-Ferrous Metals Russian Federation CID001386 Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation CID001756 Gold Moscow Special Alloys Processing Plant Russian Federation CID001204 Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation CID001326 Gold Kyshtym Copper-Electrolytic Plant ZAO Russian Federation CID002865 Gold L'azurde Company For Jewelry Saudi Arabia CID001032 Gold Metalor Technologies (Singapore) Pte., Ltd. Singapore CID001152 Gold Rand Refinery (Pty) Ltd. South Africa CID001512 Gold AU Traders and Refiners South Africa CID002850 Gold Metal Concentrators SA (Pty) Ltd. South Africa CID003575 Gold SEMPSA Joyeria Plateria S.A. Spain CID001585 Gold Sudan Gold Refinery Sudan CID002567 Gold Boliden AB Sweden CID000157 Gold Argor-Heraeus S.A. Switzerland CID000077 Gold Cendres + Metaux S.A. Switzerland CID000189 Gold Metalor Technologies S.A. Switzerland CID001153 Gold MKS PAMP SA Switzerland CID001352 Gold PX Precinox S.A. Switzerland CID001498 Gold Valcambi S.A. Switzerland CID002003 Gold Solar Applied Materials Technology Corp. Taiwan, Province of China CID001761 Gold Super Dragon Technology Co., Ltd. Taiwan, Province of China CID001810 Gold Singway Technology Co., Ltd. Taiwan, Province of China CID002516 Gold GG Refinery Ltd. Tanzania, United Republic of CID004506 Gold Umicore Precious Metals Thailand Thailand CID002314 Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey CID000103 Gold Istanbul Gold Refinery Turkey CID000814 Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey CID001220 Gold African Gold Refinery Uganda CID003185 Gold Al Etihad Gold Refinery DMCC United Arab Emirates CID002560 Gold Emirates Gold DMCC United Arab Emirates CID002561 Gold International Precious Metal Refiners United Arab Emirates CID002562 Gold Fujairah Gold FZC United Arab Emirates CID002584 Gold Dijllah Gold Refinery FZC United Arab Emirates CID003348 Gold Sam Precious Metals United Arab Emirates CID003666 Gold Kaloti Precious Metals United Arab Emirates CID002563 Gold Advanced Chemical Company United States of America CID000015 Gold Asahi Refining USA Inc. United States of America CID000920 Gold Kennecott Utah Copper LLC United States of America CID000969 Gold Materion United States of America CID001113 Gold Metalor USA Refining Corporation United States of America CID001157 Gold Sabin Metal Corp. United States of America CID001546 Gold United Precious Metal Refining, Inc. United States of America CID001993


 
Metal Smelter Name Smelter Facility Location Smelter ID Gold Abington Reldan Metals, LLC United States of America CID002708 Gold Pease & Curren United States of America CID002872 Gold QG Refining, LLC United States of America CID003324 Gold Alexy Metals United States of America CID003500 Gold Metallix Refining Inc. United States of America CID003557 Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan CID000041 Gold Navoi Mining and Metallurgical Combinat Uzbekistan CID001236 Gold Fidelity Printers and Refiners Ltd. Zimbabwe CID002515 Tantalum AMG Brasil Brazil CID001076 Tantalum Mineracao Taboca S.A. Brazil CID001175 Tantalum Resind Industria e Comercio Ltda. Brazil CID002707 Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. China CID000291 Tantalum F&X Electro-Materials Ltd. China CID000460 Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED China CID000616 Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. China CID000914 Tantalum Jiujiang Tanbre Co., Ltd. China CID000917 Tantalum Ningxia Orient Tantalum Industry Co., Ltd. China CID001277 Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China CID001522 Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China CID002492 Tantalum FIR Metals & Resource Ltd. China CID002505 Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China CID002506 Tantalum XinXing HaoRong Electronic Material Co., Ltd. China CID002508 Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China CID002512 Tantalum Jiangxi Tuohong New Raw Material China CID002842 Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. China CID003583 Tantalum NPM Silmet AS Estonia CID001200 Tantalum 5D Production OU Estonia CID003926 Tantalum TANIOBIS GmbH Germany CID002545 Tantalum TANIOBIS Smelting GmbH & Co. KG Germany CID002550 Tantalum Metallurgical Products India Pvt., Ltd. India CID001163 Tantalum Mitsui Mining and Smelting Co., Ltd. Japan CID001192 Tantalum Taki Chemical Co., Ltd. Japan CID001869 Tantalum TANIOBIS Japan Co., Ltd. Japan CID002549 Tantalum Global Advanced Metals Aizu Japan CID002558 Tantalum Ulba Metallurgical Plant JSC Kazakhstan CID001969 Tantalum KEMET de Mexico Mexico CID002539 Tantalum Solikamsk Magnesium Works OAO Russian Federation CID001769 Tantalum PowerX Ltd. Rwanda CID004054 Tantalum TANIOBIS Co., Ltd. Thailand CID002544 Tantalum QuantumClean United States of America CID001508 Tantalum Telex Metals United States of America CID001891 Tantalum D Block Metals, LLC United States of America CID002504


 
Metal Smelter Name Smelter Facility Location Smelter ID Tantalum Materion Newton Inc. United States of America CID002548 Tantalum Global Advanced Metals Boyertown United States of America CID002557 Tin Aurubis Beerse Belgium CID002773 Tin EM Vinto Bolivia (Plurinational State of) CID000438 Tin Operaciones Metalurgicas S.A. Bolivia (Plurinational State of) CID001337 Tin Estanho de Rondonia S.A. Brazil CID000448 Tin Mineracao Taboca S.A. Brazil CID001173 Tin White Solder Metalurgia e Mineracao Ltda. Brazil CID002036 Tin Magnu's Minerais Metais e Ligas Ltda. Brazil CID002468 Tin Melt Metais e Ligas S.A. Brazil CID002500 Tin Resind Industria e Comercio Ltda. Brazil CID002706 Tin Super Ligas Brazil CID002756 Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil CID003486 Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil CID003582 Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China CID000228 Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. China CID000538 Tin Gejiu Zili Mining And Metallurgy Co., Ltd. China CID000555 Tin Gejiu Kai Meng Industry and Trade LLC China CID000942 Tin China Tin Group Co., Ltd. China CID001070 Tin Jiangxi New Nanshan Technology Ltd. China CID001231 Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China CID001908 Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China CID002158 Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. China CID002180 Tin HuiChang Hill Tin Industry Co., Ltd. China CID002844 Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China CID003116 Tin Chifeng Dajingzi Tin Industry Co., Ltd. China CID003190 Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China CID003356 Tin Ma'anshan Weitai Tin Co., Ltd. China CID003379 Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China CID003397 Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China CID003410 Tin Mining Minerals Resources SARL Congo, Democratic Republic of The CID004065 Tin Precious Minerals and Smelting Limited India CID003409 Tin PT Aries Kencana Sejahtera Indonesia CID000309 Tin PT Premium Tin Indonesia Indonesia CID000313 Tin PT Artha Cipta Langgeng Indonesia CID001399 Tin PT Babel Inti Perkasa Indonesia CID001402 Tin PT Babel Surya Alam Lestari Indonesia CID001406 Tin PT Bangka Tin Industry Indonesia CID001419 Tin PT Belitung Industri Sejahtera Indonesia CID001421 Tin PT Bukit Timah Indonesia CID001428 Tin PT Mitra Stania Prima Indonesia CID001453 Tin PT Panca Mega Persada Indonesia CID001457


 
Metal Smelter Name Smelter Facility Location Smelter ID Tin PT Prima Timah Utama Indonesia CID001458 Tin PT Refined Bangka Tin Indonesia CID001460 Tin PT Sariwiguna Binasentosa Indonesia CID001463 Tin PT Stanindo Inti Perkasa Indonesia CID001468 Tin PT Timah Tbk Kundur Indonesia CID001477 Tin PT Timah Tbk Mentok Indonesia CID001482 Tin PT Timah Nusantara Indonesia CID001486 Tin PT Tinindo Inter Nusa Indonesia CID001490 Tin PT Tommy Utama Indonesia CID001493 Tin CV Venus Inti Perkasa Indonesia CID002455 Tin PT Tirus Putra Mandiri Indonesia CID002478 Tin PT ATD Makmur Mandiri Jaya Indonesia CID002503 Tin CV Ayi Jaya Indonesia CID002570 Tin PT Rajehan Ariq Indonesia CID002593 Tin PT Cipta Persada Mulia Indonesia CID002696 Tin PT Bangka Prima Tin Indonesia CID002776 Tin PT Sukses Inti Makmur Indonesia CID002816 Tin PT Menara Cipta Mulia Indonesia CID002835 Tin PT Bangka Serumpun Indonesia CID003205 Tin PT Rajawali Rimba Perkasa Indonesia CID003381 Tin PT Mitra Sukses Globalindo Indonesia CID003449 Tin PT Putera Sarana Shakti (PT PSS) Indonesia CID003868 Tin Dowa Japan CID000402 Tin Mitsubishi Materials Corporation Japan CID001191 Tin Malaysia Smelting Corporation (MSC) Malaysia CID001105 Tin Modeltech Sdn Bhd Malaysia CID002858 Tin Malaysia Smelting Corporation Berhad (Port Klang) Malaysia CID004434 Tin Pongpipat Company Limited Myanmar CID003208 Tin DS Myanmar Myanmar CID003831 Tin Minsur Peru CID001182 Tin O.M. Manufacturing Philippines, Inc. Philippines CID002517 Tin Fenix Metals Poland CID000468 Tin Novosibirsk Tin Combine Russian Federation CID001305 Tin Luna Smelter, Ltd. Rwanda CID003387 Tin Aurubis Berango Spain CID002774 Tin CRM Synergies Spain CID003524 Tin Rui Da Hung Taiwan, Province of China CID001539 Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand CID001314 Tin Thaisarco Thailand CID001898 Tin Alpha United States of America CID000292 Tin Metallic Resources, Inc. United States of America CID001142 Tin Tin Technology & Refining United States of America CID003325 Tin VQB Mineral and Trading Group JSC Vietnam CID002015


 
Metal Smelter Name Smelter Facility Location Smelter ID Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Vietnam CID002572 Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company Vietnam CID002573 Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company Vietnam CID002574 Tin An Vinh Joint Stock Mineral Processing Company Vietnam CID002703 Tungsten Wolfram Bergbau und Hutten AG Austria CID002044 Tungsten ACL Metais Eireli Brazil CID002833 Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil CID003427 Tungsten Cronimet Brasil Ltda Brazil CID003468 Tungsten Guangdong Xianglu Tungsten Co., Ltd. China CID000218 Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China CID000258 Tungsten CNMC (Guangxi) PGMA Co., Ltd. China CID000281 Tungsten Hunan Chenzhou Mining Co., Ltd. China CID000766 Tungsten Hunan Jintai New Material Co., Ltd. China CID000769 Tungsten Xiamen Tungsten Co., Ltd. China CID002082 Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China CID002313 Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China CID002315 Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China CID002316 Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China CID002317 Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China CID002318 Tungsten Malipo Haiyu Tungsten Co., Ltd. China CID002319 Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China CID002320 Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China CID002321 Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China CID002494 Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch China CID002513 Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China CID002551 Tungsten China Molybdenum Tungsten Co., Ltd. China CID002641 Tungsten Hubei Green Tungsten Co., Ltd. China CID003417 Tungsten Fujian Xinlu Tungsten Co., Ltd. China CID003609 Tungsten YUDU ANSHENG TUNGSTEN CO., LTD. China CID003662 Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. China CID004430 Tungsten H.C. Starck Tungsten GmbH Germany CID002541 Tungsten TANIOBIS Smelting GmbH & Co. KG Germany CID002542 Tungsten A.L.M.T. Corp. Japan CID000004 Tungsten Japan New Metals Co., Ltd. Japan CID000825 Tungsten HANNAE FOR T Co., Ltd. Korea, Republic of CID003978 Tungsten DONGKUK INDUSTRIES CO., LTD. Korea, Republic of CID004060 Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines CID002827 Tungsten Hydrometallurg, JSC Russian Federation CID002649 Tungsten Unecha Refractory metals plant Russian Federation CID002724 Tungsten Moliren Ltd. Russian Federation CID002845


 
Metal Smelter Name Smelter Facility Location Smelter ID Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation CID003408 Tungsten NPP Tyazhmetprom LLC Russian Federation CID003416 Tungsten OOO “Technolom” 2 Russian Federation CID003612 Tungsten OOO “Technolom” 1 Russian Federation CID003614 Tungsten Artek LLC Russian Federation CID003553 Tungsten LLC Vostok Russian Federation CID003643 Tungsten Lianyou Metals Co., Ltd. Taiwan, Province of China CID003407 Tungsten Lianyou Resources Co., Ltd. Taiwan, Province of China CID004397 Tungsten Kennametal Huntsville United States of America CID000105 Tungsten Global Tungsten & Powders LLC United States of America CID000568 Tungsten Kennametal Fallon United States of America CID000966 Tungsten Niagara Refining LLC United States of America CID002589 Tungsten Asia Tungsten Products Vietnam Ltd. Vietnam CID002502 Tungsten Masan High-Tech Materials Vietnam CID002543 Tungsten Tungsten Vietnam Joint Stock Company Vietnam CID003993 Tungsten Nam Viet Cromit Joint Stock Company Vietnam CID004034 Tungsten Kenee Mining Corporation Vietnam Vietnam CID004619


 
Appendix B: 2023 Countries of Origin List This list includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on reasonable identification of country of origin data obtained via Assent’s supply chain database. As noted in the report, it is relevant to note that overreporting might occur which could result in this Appendix containing more countries of origin than those from which the Company’s components are potentially originated. Country of Origin Country of Origin Country of Origin Albania Germany Norway Andorra Ghana Oman Angola Guam Panama Argentina Guatemala Papua New Guinea Armenia Guinea Peru Australia Guyana Philippines Austria Honduras Poland Azerbaijan Hong Kong Portugal Belarus Hungary Russian Federation Belgium India Rwanda Benin Indonesia Saudi Arabia Bermuda Ireland Senegal Bolivia (Plurinational State of) Israel Serbia Botswana Italy Sierra Leone Brazil Ivory Coast Singapore Bulgaria Japan Slovakia Burkina Faso Jersey Solomon Islands Burundi Kazakhstan South Africa Cambodia Kenya South Sudan Canada Korea Spain Central African Republic Kyrgyzstan Sudan Chile Liberia Suriname China Liechtenstein Sweden Colombia Lithuania Switzerland Congo Luxembourg Taiwan Cyprus Madagascar Tajikistan Democratic Republic of Congo Malaysia Tanzania Djibouti Mali Thailand Dominica Mauritania Togo Dominican Republic Mexico Turkey Ecuador Mongolia Uganda Egypt Morocco United Arab Emirates El Salvador Mozambique United Kingdom Eritrea Myanmar United States of America Estonia Namibia Uruguay Ethiopia Netherlands Uzbekistan Fiji New Zealand Vietnam Finland Nicaragua Zambia France Niger   Georgia Nigeria