EX-1.01 2 exhibit101-conflictmineral.htm EX-1.01 Document

Exhibit 1.01

CONFLICT MINERALS REPORT OF HEWLETT PACKARD ENTERPRISE PURSUANT TO RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934

Hewlett Packard Enterprise Company (“HPE”) presents this Conflict Minerals Report for the reporting period of January 1, 2021 to December 31, 2021 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission.

Unless otherwise specified or unless the context otherwise requires, references to “we,” “us,” or “our” refer to HPE and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear in this report have the meanings given in Item 1.01 of Form SD. References to our websites and information available through these websites are not incorporated by reference into this Conflict Minerals Disclosure and Report.

HPE Company Overview

We are a global technology leader focused on developing intelligent solutions that allow customers to capture, analyze, and act upon data seamlessly from edge to cloud. We enable customers to accelerate business outcomes by driving new business models, creating new customer and employee experiences, and increasing operational efficiency today and into the future. Our customers range from small- and medium-sized businesses to large global enterprises and governmental entities. Our legacy dates back to a partnership founded in 1939 by William R. Hewlett and David Packard, and we strive every day to uphold and enhance that legacy through our dedication to providing innovative technological solutions to our customers.

Our Responsible Minerals Program

HPE is committed to the responsible sourcing of minerals used in its products and expects its suppliers to conduct their worldwide operations in a socially and environmentally responsible and sustainable manner, pursuant to HPE’s Supply Chain Social and Environmental Responsibility Policy1 and HPE’s General Specification for the Environment.2 Both policies contain a section on the responsible sourcing of minerals.

We firmly believe that all people are entitled to basic freedoms and standards of treatment, and we embed respect for internationally recognized human rights within our Responsible Minerals Program. We commit to align our approach with the United Nations Guiding Principles on Business and Human Rights, as described in HPE’s Global Human Rights Policy.3 Likewise, we expect our suppliers to uphold and respect human rights, guided by best practice set out in these standards.

1 HPE’s Supply Chain Social and Environmental Responsibility Policy is available at https://www.hpe.com/h20195/v2/Getdocument.aspx?docname=c04797673.
2 HPE’s General Specification for the Environment is available at https://www.hpe.com/h20195/v2/Getdocument.aspx?docname=c04862211&ENW.
3 HPE’s Global Human Rights Policy is available at https://h20195.www2.hpe.com/V2/getpdf.aspx/A00001847ENW.pdf.



As outlined in HPE’s Supply Chain Responsibility: Our Approach guide,4 HPE takes a systematic approach to sensing, understanding, and addressing risk. We re-examine and refine our program each year in light of our experience and emerging best practices.

HPE has been recognized as an industry leader for the company’s efforts to advance the use of responsibly sourced minerals. In February 2021, partly in recognition of HPE’s focus on the responsible sourcing of minerals, the Thomson Reuters Foundation awarded HPE the Stop Slavery Award for the second time in five years. Our goal is to improve the transparency of mineral sourcing within our supply chain, while striving to ensure that the tin, tantalum, tungsten, and gold (collectively, “3TG”) used in our products have not benefited armed groups in the Democratic Republic of the Congo (“DRC”) and the DRC adjoining countries (collectively, the “Covered Countries”). Ultimately, we aim to improve conditions in and around mining communities in the Covered Countries and other Conflict-Affected and High-Risk Areas identified by the presence of armed conflict, widespread violence, or other human rights abuses. Because we believe it is important to avoid the economic and humanitarian impacts associated with an embargo of a particular region, we continue to source – and do not prohibit our suppliers from sourcing – from the Covered Countries and other Conflict-Affected and High-Risk Areas.

Since 2008, HPE has been a member of the Responsible Minerals Initiative (“RMI”), an organization instrumental in developing and advancing programs and shared industry tools such as the Responsible Minerals Assurance Process (“RMAP”),5 the Conflict Minerals Reporting Template (the “CMRT”), and the accompanying CMRT Completion Guide. HPE is an active member of RMI. We participate in RMI workgroups in order to listen, learn, partner, and co- design shared solutions to address challenges and emerging issues in the area of responsible minerals sourcing. Consistent with past years, HPE participates in RMI’s workgroups including the Smelter Engagement Team, Multi-Stakeholder group, Due Diligence Practices Team, Artisanal and Small-Scale Mining Team, and Gold Team. In 2021, we interacted with RMI, representatives from fellow RMI member organizations, and other business, government, non-profit, and supply chain stakeholders on the topic of responsible minerals sourcing in various forums. In April 2021, an HPE representative spoke at the OECD Forum for Responsible Mineral Supply Chains on the topic of shared costs of due diligence throughout the supply chain. At these forums and at other times, we engaged in a series of one-on-one conversations with direct suppliers of materials, parts, components, or products containing necessary conflict minerals (“3TG Direct Suppliers”) and indirect smelters and refiners (“SORs”) to help drive improvement throughout the supply chain. We also met with representatives from peer companies, civil society stakeholders, and RMI to discuss opportunities to continually improve the industry’s approach to responsible minerals sourcing. We provided feedback to RMI and other OECD-aligned, independent assessment programs (such as London Bullion Market Association’s (“LBMA”) Responsible Gold Programme) on opportunities to strengthen the audit protocol and ways to strengthen industry tools, including the CMRT and CMRT Completion
4 HPE’s Supply Chain Responsibility – Our approach is available at https://www.hpe.com/us/en/collaterals/collateral.a00001852enw.HPE-supply-chain-responsibility-E2-80-93-Our-approach-solution-guide.html?rpv=cpf&parentPage=/us/en/about/human-progress/supply-chain-responsibility.
5 RMAP is an RMI program that uses an independent third-party audit of smelter and refiner (“SOR”) management systems and sourcing practices to validate conformance with RMAP protocols and current global standards. The audit employs a risk-based approach to validate SORs’ company level management processes for responsible mineral procurement. RMAP has a cross-recognition policy with other OECD- aligned independent assessment programs in order to reduce audit duplication and support the implementation of the OECD Due Diligence Guidance. Currently these include the Responsible Jewellery Coalition’s (“RJC”) Chain-of-Custody and Code of Practices Program, and the London Bullion Market Association’s (“LBMA”) Responsible Gold Programme.



Guide. We continue to encourage the overall strengthening of audit program requirements such as enhanced integration of human rights and environmental concerns and increased transparency throughout the supply chain.

Our approach to responsible minerals sourcing prioritizes engagement and outreach with 3TG facilities;6 this year we facilitated direct outreach to more than 50 facilities to encourage their involvement in RMAP or another OECD- aligned, independent assessment program. In line with our previous years’ efforts, we also made a financial contribution to RMI funds that enable SORs to undertake audits and conduct risk-based enhanced due diligence. We contributed to the Upstream Due Diligence Fund, which we previously helped launch, to support SORs in conducting mine-level assessments in Conflict-Affected and High-Risk Areas. We also contributed to the Audit Fund for Participating Smelters, to support SORs with the costs of RMAP audits. In our communications with SORs, we encouraged their use of these funds to undertake appropriate supply chain due diligence in accordance with international standards (as described below).

Investing in the social development of mining communities is an important aspect of responsible sourcing. In 2018, HPE became one of the first donors outside of the DRC region to make a financial contribution to KEMET Corporation’s Friends of Kisengo organization, a nonprofit dedicated to effectively and sustainably improving the lives of people in the DRC through an integrated rural development program focused on infrastructure, health, education, and environmental development. HPE has continued to support the mission of Friends of Kisengo by making financial contributions to support the costs of childhood education for approximately 1,500 children in the Kisengo tantalum mining community, located in the DRC. In 2021, we funded over two months of school expenses in Kisengo. Consistent with our disclosure for calendar year 2020, all tantalum smelters reported to be in the supply chain were conformant with RMAP in 2021.

In 2021, HPE joined the Public-Private Alliance for Responsible Minerals Trade, which supports collaborative 3TG initiatives in the DRC region with peer companies and the U.S. government. In addition, in 2021, HPE financially supported the RMI-Pact Partnership for supporting Alternative Livelihoods through a Vocational training program located in cobalt mining communities in the DRC. Further, in 2021, we co-sponsored supplier responsibility trainings with key industry partners to train suppliers on the Responsible Business Alliance (“RBA”) Code of Conduct, including how to meet new expectations for responsible sourcing of minerals. HPE’s Supplier Code of Conduct is based on the RBA Code of Conduct. The training reached over 470 representatives throughout our extended, global value chain, and was facilitated by experts from the RBA and RMI.

HPE Products and Supply Chain

Conflict minerals in the form of 3TG were necessary to the functionality or production of our 2021 products (i.e., were “necessary conflict minerals”). The products containing necessary conflict minerals that HPE manufactured or contracted to manufacture during 2021 are: 1) server, storage, and networking products and 2) certain accessories.

6 3TG facilities are those entities reported by our 3TG Direct Suppliers that are also identified by RMI to be smelters, refiners, recyclers, or scrap processors of conflict minerals.



HPE does not directly purchase 3TG from raw material providers such as smelting or refining facilities nor raw materials from mine sites. Due to our position as a “downstream”7 company several tiers removed from raw materials providers, we set robust standards for our suppliers and engage with a variety of industry members, including RMI, to influence responsible sourcing.

Design of our Due Diligence Measures

We designed our due diligence measures to conform with applicable portions of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition, OECD 2016) and the related Supplements (collectively, the “OECD Guidance”), which is a nationally or internationally recognized due diligence framework. The design of our due diligence measures reflects our individual facts and circumstances, our downstream position in the minerals supply chain, and the OECD recommendations for downstream actors with no direct relationships to SORs. This design also includes the use of OECD-aligned independent assessment programs to provide information about SORs.

1.Establishment of strong internal company management systems, including a Responsible Minerals Policy;8 a Responsible Minerals Program team with senior management support that reports to the Audit Committee of the Board of Directors; a Supply Chain Transparency System;9 engagement with 3TG Direct Suppliers10 to communicate and reinforce our expectations with respect to necessary conflict minerals; a requirement that 3TG Direct Suppliers immediately begin transitioning all 3TG supply chains to 3TG facilities listed as participating in or successfully completing RMAP or another OECD-aligned independent assessment program or encouraging their known 3TG facilities to participate in such a program; integration of supplier responsible minerals performance, including response timeliness and quality, into sourcing decisions through the use of supplier Social and Environmental Responsibility Scorecards and feedback during business unit reviews with key suppliers; use of internal performance metrics such as the number of supplier responses received and our progress toward internal goals; and a corporate grievance mechanism that is available internally and externally to report concerns, including
7 The OECD Guidance distinguishes between “upstream” and “downstream” actors. Upstream refers to the minerals supply chain from the mine to the smelter or refiner, and upstream companies include miners, local traders or exporters, international concentrate traders, and mineral re-processors. Downstream refers to the minerals supply chain from smelters and refiners to retailers and includes companies like HPE; it also includes metal traders, component manufacturers, product manufacturers, original equipment manufacturers and retailers.
8 HPE’s Supply Chain Social and Environmental Responsibility Policy and HPE’s General Specification for the Environment Standards both contain sections on responsible minerals, and collectively serve as HPE’s Responsible Minerals Policy. HPE’s Supplier Code of Conduct also includes a section on responsible sourcing, alongside the topics of labor, health and safety, environment, ethics, and management systems.
9 The OECD Guidance sets forth specific recommendations for all downstream companies to establish a system of controls and transparency over the mineral supply chain: “Introduce a supply chain transparency system that allows the identification of the smelters/refiners in the company’s mineral supply chain through which the following information on the supply chain of minerals from “red flag locations of mineral origin and transit” should be obtained: the identification of all countries of origin, transport and transit for the minerals in the supply chains of each smelter/refiner.”
10 3TG Direct Suppliers are direct suppliers of materials, parts, components, or products containing necessary conflict minerals.



those related to the responsible sourcing of minerals. We encourage anyone with a concern to raise it, and provide multiple channels to raise concerns.11 Reports are confidential and can be made anonymously where local law allows. We take each and every report seriously, review every concern raised, respond promptly, and investigate alleged violations as appropriate. We also encourage the use of the global, cross-industry Minerals Grievance Platform, a platform developed in collaboration by RMI, the LBMA, and the Responsible Jewellery Coalition (“RJC”) to screen and address grievances linked to SORs present in minerals supply chains. Any member of the public or representative from an organization can submit an attributed or anonymous grievance, which is reviewed by C4ADS, an independent third-party non-profit organization. C4ADS compiles the grievances (including those from public sources, such as news articles, reports, and blogs), prepares investigative dossiers on the grievances, supports analysis of such grievances, tracks the mitigation progress, and shares a summary of the outcome with relevant platform participants. HPE has participated in the platform by submitting grievances based on potential concerns raised through various channels, analyzing and tracking grievances, and suggesting opportunities for the platform’s continual improvement. In 2021, in an attempt to further increase the use of the Minerals Grievance Platform, we added a web link to the platform to our Living Progress, Supply Chain Responsibility Website. HPE assesses its suppliers on their responsible minerals company management systems by commissioning third-party audits of certain 3TG Direct Suppliers to assess conformance with HPE’s Supplier Code of Conduct, which includes an assessment on the responsible sourcing of minerals, alongside the topics of labor, health and safety, environment, ethics, and management systems. Beginning in 2021, HPE uses a specialized third party platform to support supplier data management and verification. Over the past two years, we updated HPE’s Supply Chain Social and Environmental Responsibility Policy, HPE’s Global Human Rights Policy, HPE’s General Specification for the Environment Standards, and HPE’s Supplier Code of Conduct to align with our expectations and the OECD Guidance.12

2.Identification and assessment of risks in the supply chain, including through the Supply Chain Transparency System, the mechanism by which risks are identified and assessed in the supply chain. The system is designed to support the Responsible Minerals Program team in systematically surveying, collecting, and analyzing information relating to 3TG facilities.

3.Design and implementation of a strategy to respond to such risks as they are identified, including assessment of information on facilities’ due diligence practices, formulation of a risk management plan, and reporting to senior management. If suppliers fail to meet HPE standards, we engage with suppliers to support their improvement, in accordance with the framework of progressive improvement under the OECD Guidance. We also directly contact 3TG facilities to request their participation in RMAP or another OECD-aligned, independent assessment program and recommend they leverage technical assistance and financial support resources through RMI, including the financial support funds to which HPE contributes.

4.Support of industry organizations to carry out independent third-party audits of facilities’ due diligence practices, including through our membership and active participation in RMI (member ID HPE), the industry initiative that conducts audits and assessments of facilities’ due diligence activities. We rely on the RMI program and OECD-aligned independent assessment programs cross-recognized by RMI to determine if 3TG facilities reported by our suppliers are conformant with audit
11 HPE’s Report Ethics Concerns website is available at https://www.hpe.com/us/en/about/governance/report-ethics-concerns.html.
12 HPE’s Supplier Code of Conduct is available at https://psnow.ext.hpe.com/doc/c04797632.



standards. To further the mission of RMI and support the cost-sharing of due diligence throughout the supply chain, HPE contributes to RMI’s Audit Fund for Participating Smelters and the Upstream Due Diligence Fund, which supports SORs with the costs of RMAP audits and the costs associated with enhanced, upstream due diligence. We also provide feedback to industry audit programs related to increased transparency and continual improvement.

5.Annual reporting through this Conflict Minerals Report and in our Living Progress Report.13

Description of Our Due Diligence Measures Performed

In 2021, we undertook the following due diligence measures with respect to the source and chain of custody of necessary conflict minerals contained in our products:

compared reported 3TG facilities to the facilities that are listed by RMI as either RMAP conformant or active;14
reached out (either directly or through a third party) to 3TG facilities with unknown sourcing to provide responsible minerals sourcing education, collect information (such as country of origin of necessary conflict minerals related to the supply chain for HPE’s products), or encourage participation in RMAP;
if any 3TG Direct Supplier reported to us a facility for which we had information that identified a relevant concern, then we asked the supplier to investigate whether or not that facility contributed 3TG to our products, and, if so, to take steps to remove the facility from our supply chain;
supported RMAP through our membership and participation in RMI;
encouraged 3TG facilities to join RMAP and leverage available financial and technical assistance resources, as applicable;
asked HPE’s 3TG Direct Suppliers to encourage the facilities in their supply chain to join RMAP;
participated in the Minerals Grievance Platform (see detailed description above), which enables stakeholders to share information and resources to address grievances relating to SORs present in minerals supply chains, and regularly provided feedback to the platform developers on suggested platform improvements to drive efficiencies and transparency; and
proactively considered information outside of the audit program from credible external sources such as government agency and NGO reports.

We reviewed the results of our due diligence with senior management, including the Senior Vice President & Chief Ethics and Compliance Officer.

Results

Below we set forth the results of our due diligence as well as our progress toward DRC conflict free products. We provide both a snapshot of our total progress as well as our progress with respect to each 3TG metal. Our suppliers reported 334 total 3TG facilities in 2021, over 99% of which (as of the 2022 Cut-Off Date)15 are conformant with or active with an OECD- aligned independent assessment program, are believed to source from outside the Covered Countries, or
13 HPE’s Living Progress Report is available at https://www.hpe.com/us/en/living-progress.html.
14 RMI lists as “active” those smelters or refiners that are engaged in RMAP and progressing toward an audit but not yet conformant.
15 The “2022 Cut-Off Date” is the date, March 31, 2022, by which HPE stops accepting new conflict minerals data from its 3TG Direct Suppliers for purposes of identifying the RMAP status of smelters or refiners that have been identified in our supply chain.



are exclusively providing conflict minerals from recycled or scrap sources. Additional information on the status of individual 3TG facilities is provided in Attachment B.

Due Diligence Results for 3TG Facilities

Our approach prioritizes engagement and outreach with 3TG facilities, and when we learn of 3TG facilities that are not yet participating in an OECD-aligned independent assessment program, we seek out and consider other credible sources of information on these facilities. Due to our position as a downstream company several tiers removed from smelters or refiners, our direct suppliers often cannot provide information on 3TG sourcing that is specific to HPE products; therefore, our ability to trace 3TG in our products to the smelter or mine level has limits; conversely, as further explained in Attachment B, the reported presence of a 3TG facility in our suppliers’ supply chain does not necessarily mean that 3TG from that facility was used in HPE products. Our results, accordingly, may fluctuate depending on the resources and abilities of our suppliers (and their suppliers), the economic leverage we can exercise in a particular scenario, and the quality of information available to us, among other factors. In 2021, we continued to focus on obtaining data relevant to the manufacturing of HPE products, requesting HPE-specific submissions from our 3TG Direct Suppliers.

We measure our results in part based on the number of all 3TG facilities reported to us by our supply chain that are listed as participating in, or that have successfully completed an OECD-aligned independent assessment program. Because participation in an audit program, such as RMAP, provides us (a downstream company) with a level of assurance of an upstream facility’s sourcing practices, we track and report on this participation. Where additional information is available to us as a result of our due diligence or RCOI efforts, we also consider whether any of the 3TG facilities not yet participating in an audit program may nonetheless be providing minerals that are DRC conflict free because they are sourced from outside the Covered Countries or are exclusively derived from recycled or scrap sources. Because many of our 3TG Direct Suppliers continued to submit company level reporting templates, we are unable to confirm whether several non-conformant 3TG facilities are active in our supply chain; we continue to engage with our suppliers to improve due diligence efforts and transparency.

Attachment A to this Conflict Minerals Report includes (to the extent information was available) the countries from which the supplier-reported SORs may have sourced necessary conflict minerals.

Attachment B to this Conflict Minerals Report sets forth the name and status of the supplier-reported 3TG facilities.

Progress toward DRC Conflict Free by Metal

We also measure our progress toward DRC conflict free products by metal. Chart 1 further expands on our results by providing for each metal the number and percentage (as of the 2022 Cut-Off Date) of all supplier-reported 3TG facilities that were either RMAP conformant or active (or cross-recognized by RMI), and/or that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries.




Chart 1 Progress toward DRC Conflict Free by Metal

Supplier- Reported 3TG Facilities
Progress toward DRC Conflict Free
Percentage
Tantalum Facilities3838100%
Tin Facilities8282100%
Tungsten Facilities5050100%
Gold Facilities164163 1699%
Total334333>99%
Participation in RMAP

RMAP is an OECD- aligned, independent assessment program that uses an independent third-party audit of SOR management systems and sourcing practices to validate conformance with RMAP protocols and current global standards. The audit employs a risk-based approach to validate SORs’ company level management processes for responsible mineral procurement. The RMAP standards are developed to meet the requirements of the OECD Due Diligence Guidance, the Regulation (EU) 2017/821 of the European Parliament and the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. Facilities that are either RMAP conformant or active are considered participating in RMAP. Chart 2 provides, for each metal, the RMAP participation by number and percentage (as of the 2022 Cut-Off Date) of all supplier-reported 3TG facilities. Again in 2021, all of the tantalum smelters reported to be in our supply chain are conformant with RMAP. The RMAP status of individual 3TG facilities is set forth in Attachment B.

Chart 2 Overall Participation in RMAP

Total
RMAP Conformant
RMAP Active
Percentage RMAP Participating
Tantalum Facilities
38
38
0
100%
Tin Facilities
82
53
13
80%
Tungsten Facilities
50
42
5
94%
Total
334
241
24
79%

Efforts to Determine the Mine or Location of Origin with Greatest Possible Specificity

As a downstream actor, we rely upon independent assessment programs to collect and review the majority of the upstream information, such as the mine or location of origin of necessary conflict minerals. Consistent with the key role set forth by the OECD Guidance for a downstream actor like us, our efforts to facilitate upstream mine or location of origin determinations were focused on support of OECD-aligned independent assessment programs such as RMAP.

To determine the mine or location of origin of necessary conflict minerals, or to facilitate such determinations by audit programs, we:

surveyed 3TG Direct Suppliers during the reporting period of this Conflict Minerals Report using the CMRT (which included questions about the mine or location of origin)
16 One reported 3TG facility is listed as active with RMAP, however, additional information from our due diligence suggests that the facility sources from the Covered Countries and that it may not become RMAP conformant. Thus, we have not included it in the progress toward DRC conflict free category.




and required those suppliers to make similar efforts to survey their supply chains using the CMRT;
reviewed information obtained through those surveys on 3TG facilities, and any mine or location of origin information if it was provided; and
assessed any information on countries of origin available through our membership in RMI for 3TG facilities (As part of the RMAP audit protocol, the independent auditor makes an examination of the countries of origin and the location of the mine, even if the specific mine or location of origin for these minerals within a given country is not provided to RMI members).

Steps to Further Mitigate Risk and Improve Due Diligence in 2022

In our journey to responsibly source minerals used in our products, we plan to continue the activities described in the “Design of Our Due Diligence Measures” section of this Conflict Minerals Report. Additionally, we will continue to explore opportunities to improve our approach and execution in order to better mitigate any risk that necessary conflict minerals in our products finance or benefit an armed group or further negatively impact communities or the environment. To this end, we will:

engage with 3TG Direct Suppliers to update information provided to us and engage potentially new in- scope suppliers to understand our responsible sourcing expectations, including our Responsible Minerals Policy;
encourage 3TG Direct Suppliers that provided company level information in 2021 to provide HPE-specific information for 2022;
repeat our request that 3TG Direct Suppliers encourage facilities they have identified in their supply chains to join the RMAP and encourage their transition to exclusively source from conformant and active 3TG facilities, and monitor their progress toward that objective;
support the development of RMAP, including outreach efforts to encourage participation in the program;
strengthen internal and external partnerships to identify and mitigate minerals risks, investigate the materiality and social, environmental, and human rights impact of minerals in our products beyond 3TG, and enhance HPE’s due diligence capabilities;
continue to monitor best practices and work with stakeholders to contribute to the development of novel and impactful solutions in Conflict- Affected and High-Risk Areas; and
explore opportunities to further HPE’s mission to advance the way people live and work as it relates to the responsible sourcing of minerals.





Attachment A
Countries of Origin
Based on information available from RMI as of the 2022 Cut-Off Date and additional research by our external expert consultant, we believe that the countries of origin of the necessary conflict minerals from supplier-reported SORs may include the following countries.


Covered Countries
Outside Covered Countries
BurundiAustralia
Congo, Democratic Republic of theBelgium
RwandaBolivia
TanzaniaBrazil
Burkina Faso
Canada
China
Colombia

Côte d'Ivoire

Egypt

French Guinea

Germany

Ghana

Guyana

Honduras

Indonesia

Japan

Kazakhstan

Korea, Republic of

Kyrgyzstan

Laos

Mali

Mexico

Mozambique

Myanmar

Namibia

New Zealand

Nigeria

Papua New Guinea

Peru

Philippines

Poland

Russia

Serbia

South Africa

Sweden

Tajikistan



Covered Countries
Outside Covered Countries

Thailand

Turkey

United States of America

Uzbekistan

Vietnam

Zimbabwe




Attachment B
3TG Facility List
This 3TG Facility List sets forth the name, location, and status of all 334 of the 3TG facilities our suppliers reported to us. It is the result of our review of data from several sources, including information reported to us by 3TG Direct Suppliers, obtained through supplemental engagement with certain 3TG facilities, and from RMI. Inclusion on this list is not necessarily an indication that any particular facility supplies materials that are ultimately incorporated into HPE products. In many cases facility information was provided to us for the entire supply chain of 3TG Direct Suppliers, and did not identify with specificity those 3TG facilities believed to contribute necessary conflict minerals to any of our products.

Metal
Facility Name1
Facility Location2
Status3
Gold8853 S.p.A.ITALYConformant
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICANon Conformant
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICAConformant
GoldAida Chemical Industries Co., Ltd.JAPANConformant
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESConformant
GoldAlexy MetalsUNITED STATES OF AMERICAActive
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYConformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANConformant
GoldAngloGold Ashanti Córrego do Sítio MineraçãoBRAZILConformant
GoldArgor-Heraeus S.A.SWITZERLANDConformant
GoldAsahi Pretec Corp.JAPANConformant
GoldAsahi Refining Canada Ltd.CANADAConformant
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICAConformant
GoldAsaka Riken Co., Ltd.JAPANConformant
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYNot yet participating
GoldAU Traders and RefinersSOUTH AFRICANon Conformant
GoldAugmont Enterprises Private LimitedINDIAActive
GoldAurubis AGGERMANYConformant
GoldBangalore RefineryINDIAConformant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESConformant
GoldBoliden ABSWEDENConformant
GoldC. Hafner GmbH + Co. KGGERMANYConformant
GoldC.I Metales Procesados Industriales SASCOLOMBIAActive
GoldCaridadMEXICONot yet participating
GoldCCR Refinery - Glencore Canada CorporationCANADAConformant
GoldCendres + Métaux S.A.SWITZERLANDConformant
GoldCGR Metalloys Pvt Ltd.INDIANot yet participating
GoldChimet S.p.A.ITALYConformant
GoldChugai MiningJAPANConformant
GoldDaye Non-Ferrous Metals Mining Ltd.CHINANot yet participating
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYNot yet participating
GoldDODUCO Contacts and Refining GmbHGERMANYConformant



Metal
Facility Name1
Facility Location2
Status3
GoldDowaJAPANConformant
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFConformant
GoldEco-System Recycling Co., Ltd. East PlantJAPANConformant
GoldEco-System Recycling Co., Ltd. North PlantJAPANConformant
GoldEco-System Recycling Co., Ltd. West PlantJAPANConformant
GoldEmerald Jewel Industry India Limited (Unit 1)INDIANot yet participating
GoldEmerald Jewel Industry India Limited (Unit 2)INDIANot yet participating
GoldEmerald Jewel Industry India Limited (Unit 3)INDIANot yet participating
GoldEmerald Jewel Industry India Limited (Unit 4)INDIANot yet participating
GoldEmirates Gold DMCCUNITED ARAB EMIRATESConformant
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIAActive
GoldGeib Refining CorporationUNITED STATES OF AMERICAConformant
GoldGold Coast RefineryGHANANot yet participating
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINAConformant
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINANot yet participating
GoldGuangdong Jinding Gold LimitedCHINANon Conformant
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINANot yet participating
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINANot yet participating
GoldHeimerle + Meule GmbHGERMANYConformant
GoldHenan Yuguang Gold & Lead Co., Ltd.CHINANot yet participating
GoldHeraeus Germany GmbH Co. KGGERMANYConformant
GoldHeraeus Metals Hong Kong Ltd.CHINAConformant
GoldHunan Chenzhou Mining Co., Ltd.CHINANot yet participating
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINANot yet participating
GoldHwaSeong CJ Co., Ltd.KOREA, REPUBLIC OFNot yet participating
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINAConformant
GoldIshifuku Metal Industry Co., Ltd.JAPANConformant
GoldIstanbul Gold RefineryTURKEYConformant
GoldItalpreziosiITALYConformant
GoldJALAN & CompanyINDIANot yet participating
GoldJapan MintJAPANConformant
GoldJiangxi Copper Co., Ltd.CHINAConformant
GoldJSC Novosibirsk RefineryRUSSIAN FEDERATIONConformant
GoldJSC UralelectromedRUSSIAN FEDERATIONConformant
GoldJX Nippon Mining & Metals Co., Ltd.JAPANConformant
GoldK.A. RasmussenNORWAYNot yet participating
GoldKazakhmys Smelting LLCKAZAKHSTANNot yet participating



Metal
Facility Name1
Facility Location2
Status3
GoldKazzincKAZAKHSTANConformant
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICAConformant
GoldKGHM Polska Miedź Spółka AkcyjnaPOLANDConformant
GoldKojima Chemicals Co., Ltd.JAPANConformant
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFConformant
GoldKundan Care Products Ltd.INDIANot yet participating
GoldKyrgyzaltyn JSCKYRGYZSTANNon Conformant
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONNot yet participating
GoldL'azurde Company For JewelrySAUDI ARABIANot yet participating
GoldL'Orfebre S.A.ANDORRAConformant
GoldLingbao Gold Co., Ltd.CHINANot yet participating
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINANot yet participating
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFConformant
GoldLT Metal Ltd.KOREA, REPUBLIC OFConformant
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINANot yet participating
GoldMarsam MetalsBRAZILConformant
GoldMaterionUNITED STATES OF AMERICAConformant
GoldMatsuda Sangyo Co., Ltd.JAPANConformant
GoldMD OverseasINDIANot yet participating
GoldMetal Concentrators SA (Pty) Ltd.SOUTH AFRICAConformant
GoldMetallix Refining Inc.UNITED STATES OF AMERICANot yet participating
GoldMetalor Technologies (Hong Kong) Ltd.CHINAConformant
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPOREConformant
GoldMetalor Technologies (Suzhou) Ltd.CHINAConformant
GoldMetalor Technologies S.A.SWITZERLANDConformant
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICAConformant
GoldMetalúrgica Met-Mex Peñoles S.A. De C.V.MEXICOConformant
GoldMitsubishi Materials CorporationJAPANConformant
GoldMitsui Mining and Smelting Co., Ltd.JAPANConformant
GoldMMTC-PAMP India Pvt., Ltd.INDIAConformant
GoldModeltech Sdn BhdMALAYSIANon Conformant
GoldMorris and WatsonNEW ZEALANDNot yet participating
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONConformant
GoldNadir Metal Rafineri San. Ve Tic. A.Ş.TURKEYConformant
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANConformant
GoldNH Recytech CompanyKOREA, REPUBLIC OFConformant
GoldNihon Material Co., Ltd.JAPANConformant
GoldÖgussa Österreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIAConformant
GoldOhura Precious Metal Industry Co., Ltd.JAPANConformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONConformant



Metal
Facility Name1
Facility Location2
Status3
GoldPAMP S.A.SWITZERLANDConformant
GoldPease & CurrenUNITED STATES OF AMERICANot yet participating
GoldPenglai Penggang Gold Industry Co., Ltd.CHINANot yet participating
GoldPlanta Recuperadora de Metales SpACHILEConformant
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONConformant
GoldPT Aneka Tambang (Persero) TbkINDONESIAConformant
GoldPX Précinox S.A.SWITZERLANDConformant
GoldQG Refining, LLCUNITED STATES OF AMERICANot yet participating
GoldRand Refinery (Pty) Ltd.SOUTH AFRICAConformant
GoldRefinery of Seemine Gold Co., Ltd.CHINANot yet participating
GoldREMONDIS PMR B.V.NETHERLANDSConformant
GoldRoyal Canadian MintCANADAConformant
GoldSAAMPFRANCEConformant
GoldSabin Metal Corp.UNITED STATES OF AMERICAConformant
GoldSafimet S.p.AITALYConformant
GoldSAFINA A.S.CZECHIAConformant
GoldSai RefineryINDIANot yet participating
GoldSamduck Precious MetalsKOREA, REPUBLIC OFConformant
GoldSAMWON Metals Corp.KOREA, REPUBLIC OFNot yet participating
GoldSancus ZFS (L’Orfebre, SA)COLOMBIAActive
GoldSAXONIA Edelmetalle GmbHGERMANYConformant
GoldSellem Industries Ltd.MAURITANIANot yet participating
GoldSEMPSA Joyería Platería S.A.SPAINConformant
GoldShandong Gold Smelting Co., Ltd.CHINAConformant
GoldShandong Humon Smelting Co., Ltd.CHINANot yet participating
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINANot yet participating
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINAConformant
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CHINANot yet participating
GoldSichuan Tianze Precious Metals Co., Ltd.CHINAConformant
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINAConformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONConformant
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINAConformant
GoldSovereign MetalsINDIANot yet participating
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIANot yet participating
GoldSumitomo Metal Mining Co., Ltd.JAPANConformant
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFConformant
GoldSuper Dragon Technology Co., Ltd.TAIWAN, PROVINCE OF CHINANot yet participating
GoldT.C.A S.p.AITALYConformant
GoldTanaka Kikinzoku Kogyo K.K.JAPANConformant
GoldTokuriki Honten Co., Ltd.JAPANConformant



Metal
Facility Name1
Facility Location2
Status3
GoldTongling Nonferrous Metals Group Co., Ltd.CHINANot yet participating
GoldTOO Tau-Ken-AltynKAZAKHSTANConformant
GoldTorecomKOREA, REPUBLIC OFConformant
GoldUmicore Precious Metals ThailandTHAILANDConformant
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMConformant
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICAConformant
GoldValcambi S.A.SWITZERLANDConformant
GoldWEEEREFININGFRANCEActive
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIAConformant
GoldWIELAND Edelmetalle GmbHGERMANYConformant
GoldYamakin Co., Ltd.JAPANConformant
GoldYokohama Metal Co., Ltd.JAPANConformant
GoldYunnan Copper Industry Co., Ltd.CHINANot yet participating
GoldZhongkuang Gold Industry Co., Ltd.CHINANot yet participating
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINAConformant
TantalumAsaka Riken Co., Ltd.JAPANConformant
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINAConformant
TantalumD Block Metals, LLCUNITED STATES OF AMERICAConformant
TantalumExotech Inc.UNITED STATES OF AMERICAConformant
TantalumF&X Electro-Materials Ltd.CHINAConformant
TantalumFIR Metals & Resource Ltd.CHINAConformant
TantalumGlobal Advanced Metals AizuJAPANConformant
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICAConformant
TantalumH.C. Starck Hermsdorf GmbHGERMANYConformant
TantalumH.C. Starck Inc.UNITED STATES OF AMERICAConformant
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINAConformant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumJiangxi Tuohong New Raw MaterialCHINAConformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINAConformant
TantalumJiujiang Tanbre Co., Ltd.CHINAConformant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumKEMET de MexicoMEXICOConformant
TantalumLSM Brasil S.A.BRAZILConformant
TantalumMeta MaterialsNORTH MACEDONIA, REPUBLIC OFConformant
TantalumMetallurgical Products India Pvt., Ltd.INDIAConformant
TantalumMineração Taboca S.A.BRAZILConformant
TantalumMitsui Mining & SmeltingJAPANConformant
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINAConformant



Metal
Facility Name1
Facility Location2
Status3
TantalumNPM Silmet ASESTONIAConformant
TantalumQuantumCleanUNITED STATES OF AMERICAConformant
TantalumResind Indústria e Comércio Ltda.BRAZILConformant
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONConformant
TantalumTaki Chemical Co., Ltd.JAPANConformant
TantalumTANIOBIS Co., Ltd.THAILANDConformant
TantalumTANIOBIS GmbHGERMANYConformant
TantalumTANIOBIS Japan Co., Ltd.JAPANConformant
TantalumTANIOBIS Smelting GmbH & Co. KGGERMANYConformant
TantalumTelex MetalsUNITED STATES OF AMERICAConformant
TantalumUlba Metallurgical Plant JSCKAZAKHSTANConformant
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDCHINAConformant
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINAConformant
TantalumYancheng Jinye New Material Technology Co., Ltd.CHINAConformant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINAConformant
TinAlphaUNITED STATES OF AMERICAConformant
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAMNot yet participating
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINAConformant
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINAConformant
TinChina Tin Group Co., Ltd.CHINAConformant
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBRAZILActive
TinCRM SynergiesSPAINActive
TinCV Ayi JayaINDONESIANot yet participating
TinCV Venus Inti PerkasaINDONESIAActive
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINANon Conformant
TinDowaJAPANConformant
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAMNon Conformant
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)Conformant
TinEstanho de Rondônia S.A.BRAZILActive
TinFabrica Auricchio Industria e Comercio Ltda.BRAZILConformant
TinFenix MetalsPOLANDConformant
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINANot yet participating
TinGejiu Kai Meng Industry and Trade LLCCHINANon Conformant
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINAConformant



Metal
Facility Name1
Facility Location2
Status3
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINAConformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINAConformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINAConformant
TinHuiChang Hill Tin Industry Co., Ltd.CHINAConformant
TinJiangxi New Nanshan Technology Ltd.CHINAConformant
TinLuna Smelter, Ltd.RWANDAConformant
TinMa'anshan Weitai Tin Co., Ltd.CHINAConformant
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILConformant
TinMalaysia Smelting Corporation (MSC)MALAYSIAConformant
TinMelt Metais e Ligas S.A.BRAZILConformant
TinMetallic Resources, Inc.UNITED STATES OF AMERICAConformant
TinMetallo Belgium N.V.BELGIUMConformant
TinMetallo Spain S.L.U.SPAINConformant
TinMineração Taboca S.A.BRAZILConformant
TinMinsurPERUConformant
TinMitsubishi Materials CorporationJAPANConformant
TinModeltech Sdn BhdMALAYSIANon Conformant
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAMNot yet participating
TinNovosibirsk Processing Plant Ltd.RUSSIAN FEDERATIONActive
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDConformant
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESConformant
TinOperaciones Metalúrgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)Conformant
TinPongpipat Company LimitedMYANMARNot yet participating
TinPrecious Minerals and Smelting LimitedINDIANon Conformant
TinPT Aries Kencana SejahteraINDONESIANot yet participating
TinPT Artha Cipta LanggengINDONESIAConformant
TinPT ATD Makmur Mandiri JayaINDONESIAConformant
TinPT Babel Inti PerkasaINDONESIAConformant
TinPT Babel Surya Alam LestariINDONESIAConformant
TinPT Bangka SerumpunINDONESIAConformant
TinPT Belitung Industri SejahteraINDONESIANot yet participating
TinPT Bukit TimahINDONESIAActive
TinPT Cipta Persada MuliaINDONESIAConformant
TinPT Lautan Harmonis SejahteraINDONESIANot yet participating
TinPT Masbro Alam StaniaINDONESIAActive
TinPT Menara Cipta MuliaINDONESIAConformant
TinPT Mitra Stania PrimaINDONESIAConformant
TinPT Mitra Sukses GlobalindoINDONESIAActive
TinPT Panca Mega PersadaINDONESIANot yet participating
TinPT Prima Timah UtamaINDONESIAConformant
TinPT Rajawali Rimba PerkasaINDONESIAConformant



Metal
Facility Name1
Facility Location2
Status3
TinPT Rajehan AriqINDONESIAConformant
TinPT Refined Bangka TinINDONESIAConformant
TinPT Sariwiguna BinasentosaINDONESIAConformant
TinPT Stanindo Inti PerkasaINDONESIAConformant
TinPT Sukses Inti MakmurINDONESIAActive
TinPT Timah NusantaraINDONESIAActive
TinPT Timah Tbk KundurINDONESIAConformant
TinPT Timah Tbk MentokINDONESIAConformant
TinPT Tinindo Inter NusaINDONESIAConformant
TinResind Indústria e Comércio Ltda.BRAZILConformant
TinRui Da HungTAIWAN, PROVINCE OF CHINAConformant
TinSoft Metais Ltda.BRAZILConformant
TinSuper LigasBRAZILActive
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMConformant
TinThaisarcoTHAILANDConformant
TinTin Technology & RefiningUNITED STATES OF AMERICAConformant
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAMNot yet participating
TinVQB Mineral and Trading Group JSCVIET NAMNot yet participating
TinWhite Solder Metalurgia e Mineração Ltda.BRAZILConformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINAConformant
TinYunnan Tin Company LimitedCHINAActive
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINANon Conformant
TungstenA.L.M.T. Corp.JAPANConformant
TungstenACL Metais EireliBRAZILConformant
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILActive
TungstenArtek LLCRUSSIAN FEDERATIONNot yet participating
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMConformant
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINAConformant
TungstenChina Molybdenum Co., Ltd.CHINAConformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINAConformant
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINANot yet participating
TungstenCronimet Brasil LtdaBRAZILConformant
TungstenFujian Ganmin RareMetal Co., Ltd.CHINAConformant
TungstenFujian Xinlu TungstenCHINAConformant
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINAConformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINAConformant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINAConformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINAConformant



Metal
Facility Name1
Facility Location2
Status3
TungstenGEM Co., Ltd.CHINAActive
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICAConformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINAConformant
TungstenH.C. Starck Tungsten GmbHGERMANYConformant
TungstenHunan Chenzhou Mining Co., Ltd.CHINAConformant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINAConformant
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONConformant
TungstenJapan New Metals Co., Ltd.JAPANConformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINAConformant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINAConformant
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINANot yet participating
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINAConformant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINAConformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINAConformant
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONConformant
TungstenKennametal FallonUNITED STATES OF AMERICAConformant
TungstenKennametal HuntsvilleUNITED STATES OF AMERICAConformant
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OFConformant
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINAConformant
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINAConformant
TungstenMasan High-Tech MaterialsVIET NAMConformant
TungstenMoliren Ltd.RUSSIAN FEDERATIONConformant
TungstenNiagara Refining LLCUNITED STATES OF AMERICAConformant
TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATIONActive
TungstenOOO “Technolom” 1RUSSIAN FEDERATIONActive
TungstenOOO “Technolom” 2RUSSIAN FEDERATIONActive
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESConformant
TungstenTANIOBIS Smelting GmbH & Co. KGGERMANYConformant
TungstenUnecha Refractory Metals PlantRUSSIAN FEDERATIONConformant
TungstenWolfram Bergbau und Hütten AGAUSTRIAConformant
TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OFConformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINAConformant
TungstenXiamen Tungsten Co., Ltd.CHINAConformant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINAConformant

1.Entities that have been reported to us by our 3TG Direct Suppliers as part of their supply chain for conflict minerals and that are recognized by RMI (as of the 2022 Cut-Off Date) to be smelters, refiners, recyclers or scrap processors of conflict minerals (i.e., the “3TG facilities”). The facility names are listed as they appear on the RMI Facility Database. A company appears more than once if it was reported to us for more than one facility (i.e., smelter, refiner, recycler, or scrap processor) that is processing different types of minerals or metals.
2.The facility locations are listed as they appear for each of the 3TG facilities on the RMI Facility Database.
3.Conformant refers to 3TG facilities that are listed by RMI (as of the 2022 Cut-Off Date) as (a) conformant with RMAP protocols or (b) certified or accredited by a similar independent assessment program such as the RJC Chain-of-Custody and Code of Practices Program, or the LBMA Responsible Gold Programme. Active refers to smelter or refiner facilities that are engaged in RMAP but not



yet conformant (as of the 2022 Cut-Off Date). Non-conformant refers to facilities that are non-conformant to the RMAP standard (as of the 2021 Cut-Off Date). Not yet participating refers to 3TG facilities that are not engaged with an audit program.