DocumentBloom Energy Corporation
Conflict Minerals Report
For Year Ended December 31, 2020
This Conflict Minerals Report (“Report”) for the year ended December 31, 2020 has been prepared by the management of Bloom Energy Corporation (herein referred to as “Bloom Energy”). The information includes the activities of all majority-owned subsidiaries and variable interest entities that are consolidated.
As used in this Report, “3TGs” means tin, tungsten, tantalum and/or gold or its derivatives and “Covered Countries” means the Democratic Republic of the Congo (“DRC”) and its nine adjoining countries; Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
INTRODUCTION
Product Covered by This Report
Pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), the 2020 calendar year is the second year that Bloom Energy is filing a Conflict Minerals Report.
Bloom Energy has determined that only one product manufactured or contracted to be manufactured contained tin, tungsten, tantalum and/or gold or its derivatives (“3TGs”) that were necessary to its functionality or production: the Bloom Energy Server, a stationary power generation platform (the “Covered Product”).
Bloom Energy conducted in good faith a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TGs in the Covered Product originated in the Covered Countries by engaging with certain suppliers who provided materials that may contain 3TG that was used in the Covered Product (“In-Scope Suppliers”). Based on Bloom Energy’s RCOI, Bloom Energy had reason to believe that its Covered Product could contain 3TGs that originated in the Covered Countries. Therefore, in accordance with Section 1502 of the Dodd-Frank Act, Bloom Energy performed due diligence on the source and chain of custody of the 3TGs.
Reasonable Country of Origin Inquiry
To assist Bloom Energy with its determination whether 3TGs, necessary for its Covered Product originated in Covered Countries, Bloom Energy engaged a third-party service provider, Source Intelligence (“SI”). SI provided Bloom Energy with access to its platform that tracks supplier communications and provides additional tools that support the internationally recognized due diligence framework set forth in the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements on Tin, Tantalum and Tungsten, and on Gold (the “OECD Guidance”). For example, the SI platform has functionality that evaluates the quality of each supplier’s response and assigns a health score based on the supplier’s declaration. 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 the SI platform.
Bloom Energy provided a list of In-Scope Suppliers to SI for upload to the SI platform. SI assisted with the evaluation of Bloom Energy’s supply chain information regarding 3TGs, identification of potential risks, and development and implementation of additional due diligence steps. Bloom Energy communicated regularly with SI services team concerning program status. SI’s team members are trained in conflict minerals compliance and understand the intricacies of the CMRT, conflict minerals reporting, and generally, Section 1502 of the Dodd-Frank Act.
Bloom Energy’s RCOI process included conducting an inquiry of its In-Scope Suppliers using the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”). Bloom Energy does not have direct supply contracts with the providers of raw materials used in the Covered Product and Bloom Energy does not directly source 3TGs. Bloom Energy sources components and materials from suppliers, which in turn, source materials, components and products from their suppliers.
Bloom Energy used SI’s platform to request that the In-Scope Suppliers complete the CMRT to collect data on the sources of origin of the materials necessary for the Covered Product. Suppliers then uploaded their completed CMRTs directly to the platform for validation, assessment and management. SI monitored and tracked all communications in its platform for future reporting and transparency. Bloom Energy directly contacted suppliers that were unresponsive to SI’s communications and requested that they complete and submit the CMRT.
Bloom Energy’s program includes 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 to understand the due diligence efforts of the In-Scope Suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the In-Scope Suppliers to support their understanding of areas that need their clarification or improvement.
All submitted CMRT forms were accepted and classified as valid or invalid. The “invalid” classification can be the result of a number of factors, including incomplete tabs and can also occur when the supplier uses an obsolete template instead of the current version. A supplier who submits an invalid form is contacted and encouraged to submit a valid form. Suppliers receive feedback on their submissions and guidance on correcting validation errors and may seek assistance from SI’s multilingual Supplier Experience team or on-line training. Data concerning suppliers who remain unresponsive to feedback is tracked as a program gap for future improvement.
As of March 1, 2021, Bloom Energy had 177 In-Scope Suppliers. 155 (or ~88%) of the In-Scope Suppliers completed a valid CMRT. This helped us determine the countries of origin for nearly all of the 3TGs in the Covered Product.
DUE DILIGENCE
Bloom Energy designed its due diligence measures to conform with the OECD Guidance in all material respects and endeavored to align its program with the five steps for due diligence described in the OECD Guidance. Bloom Energy continues to evaluate market expectations for data collection and reporting to make improvements to its program.
Bloom Energy is a downstream consumer of 3TGs and does not purchase raw minerals directly from any mines, smelters or refiners or any of the Covered Countries. Bloom Energy’s supply chain is extensive and complex with many layers of suppliers positioned between ourselves and 3TG smelters and refiners. Therefore, to execute due diligence, Bloom Energy must rely on data from its direct suppliers and third-party audit programs. As Bloom Energy does not solely control these processes, there is a risk of incomplete or inaccurate data. However, multiple supplier-outreach efforts and process validation steps help mitigate this risk. Bloom Energy believes this due diligence process aligns with industry standards and market expectations for downstream companies.
Step One: Establish Strong Company Management Systems
Internal Compliance Team
Bloom Energy established a cross-functional Conflict Minerals Team led by the Executive Vice President, Chief Operations Officer. The Conflict Minerals Team is responsible for implementing Bloom Energy’s responsible sourcing strategy and for briefing senior management on the results of due diligence.
Conflict Minerals Policy
In May 2020, Bloom Energy adopted a Policy on Responsible Sourcing of Minerals articulating the due diligence process and Bloom Energy’s commitment to reporting obligations regarding 3TGs originating in the Covered Countries. The Policy is publicly available at bloomenergy.com/supplychain.
Control Systems
Bloom Energy relies on its direct suppliers to provide information on the origin of the 3TGs contained in components and materials that they supply to Bloom Energy, such as sources of 3TGs that the suppliers purchase from their lower-tier suppliers. However, Bloom Energy expects all suppliers to have policies and procedures in place that work toward ensuring that all 3TGs used in the production of the products sold to Bloom Energy are sourced from smelters or refiners that conform with an independent responsible mineral sourcing validation program.
Supplier Engagement
Bloom Energy has a strong relationship with its In-Scope Suppliers. Bloom Energy engages directly with its In-Scope Suppliers to request a valid CMRT for the products that they supply to Bloom Energy. To strengthen supplier education and training, Bloom Energy provides In-Scope Suppliers with access to the SI platform, at no-charge, to upload their CMRTs as well as to seek help-desk support in their native language from SI’s team of supplier support specialists. Suppliers can also participate in SI’s online library of conflict minerals training.
Grievance Mechanisms
Bloom Energy has established multiple grievance mechanisms whereby employees, suppliers and other third parties can report violations of its policies. In Bloom Energy’s Policy on Responsible Sourcing. Suppliers, Bloom Energy has published a dedicated email address for suppliers to contact the Bloom Energy Supplier Team to ask questions regarding the collection of CMRTs and to report any violations of this policy within the supply chain. In addition, employees and third parties have access to the Bloom Energy Helpline to ask questions, communicate concerns or report potential violations of applicable law or company policies, which is publicly available at BloomEnergy.ethicspoint.com.
In the event that employees and suppliers wish to contact Bloom Energy’s Board of Directors, Bloom Energy also publishes the Board’s address in its Global Code of Business Conduct and Ethics, available
on Bloom Energy’s website under the Investors section. Finally, violations or grievances at the industry level can be reported directly to RMI at: www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.
Records Management
SI’s platform also includes a document retention policy to retain any conflict minerals-related documents, including supplier responses to CMRTs and the sources for each reporting period. Bloom Energy stores all of the information and findings from this process in a database that can be audited by internal or external parties.
Step Two: Identify and Assess Risks in the Supply Chain
Risks associated with supplier CMRT content are identified by SI based on criteria established for supplier responses. Supplier responses were evaluated for plausibility, consistency and gaps. If any of the foregoing quality control flags were raised, were automatically contacted by the SI platform to correct any inconsistencies.
Risks at the supplier level may include non-responsive suppliers down the supply chain, incomplete CMRTs, or CMRTs that are submitted that are not specific to the Covered Product. Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their own suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers who listed smelters and refiners on their CMRT declarations. To determine if the facilities met the recognized definition of a 3TG processing facility that was operational during the 2020 calendar year, SI compared these facilities to the RMI list of smelters and refiners. SI relied on the RMI audit standard, including cross-recognition of the London Bullion Market Association (“LBMA”) Good Delivery Program and the Responsible Jewelry Council (“RJC”) Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance.
SI determined if the smelter or refiner had been audited against a standard that conforms to the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). As discussed earlier, Bloom Energy does not have a direct relationship with smelters and refiners, and does not perform direct audits of these entities within the supply chain. In cases where a smelter’s due diligence practices have not been audited against RMAP or a similar independent standard, or RMAP considers a smelter to be non-conforming, Bloom Energy followed-up with suppliers reporting those facilities. Smelters are then assessed for potential sourcing risk.
Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed using the red-flag indicators in the OECD Guidance. SI uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
•Geographic proximity to the Covered Countries;
•Known mineral source country of origin;
•RMAP or a similar independent audit status that is cross-recognized by RMI;
•Credible evidence of unethical or conflict sourcing; and
•Peer assessments conducted by credible third-party sources.
Risk mitigation activities are initiated when a supplier’s CMRT reports smelters of concern. Suppliers with submissions that include smelters or refiners of concern are provided with feedback instructing that supplier to take their own independent risk mitigation actions. Additional escalation may be necessary to address any continued sourcing from these smelters of concern. In addition, In-Scope Suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.
In-Scope Suppliers are also evaluated on program strength, which will assist Bloom Energy with making key risk mitigation decisions as its program progresses. The criteria used to evaluate the strength of the program is based on questions in the CMRT related to the suppliers’ conflict minerals practices and policies.
Step Three: Design and Implement a Strategy to Respond to Identified Risks
Bloom Energy has developed a process to assess and respond to the risks identified in the supply chain as well as to manage and monitor risk. Communications were sent to non-responsive suppliers to communicate the importance of their completion of the CMRT and their support of Bloom Energy’s compliance with the Rule and Bloom Energy’s expectations.
Suppliers received feedback on their submissions as well as educational resources regarding corrective action methods and potential improvements for their internal programs. Bloom Energy encouraged suppliers that may be supplying 3TGs from sources that may support conflict in the Covered Countries to endeavor to seek an alternative source of 3TGs that does not support such conflict, as provided in the OECD Guidance. SI also communicates directly with smelters that have not yet been determined to be conformant with the RMAP to seek data on sourcing and to encourage their involvement with the RMI program.
In cases where suppliers have continuously been non-responsive or do not appear to be committed to corrective action plans, Bloom Energy assesses internally if replacing that supplier is feasible. The results of the program and risk assessment are shared with both the Conflict Minerals Team and senior management to support transparency within Bloom Energy.
Step Four: Support the Development and Implementation of Independent Third-Party Audits
As discussed above, Bloom Energy does not have a direct relationship with any 3TG smelters or refiners and does not perform or direct audits of these entities within the supply chain. Instead, Bloom Energy relies on third-party audits of smelters and refiners conducted as part of the RMAP. The RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.
SI 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.
Step Five: Report Annually on Supply Chain Due Diligence
Bloom Energy has filed this Report and a Form SD for the year ended December 31, 2020 with the United States Securities and Exchange Commission (“SEC”). As indicated in the Form SD, this Report is publicly available at investor.bloomenergy.com/. Bloom Energy’s Policy on Responsible Sourcing of Minerals is also publicly available at bloomenergy.com/supplychain.
RCOI AND DUE DILIGENCE RESULTS
Supply Chain Outreach Results
Supply chain outreach is required to identify the upstream sources of origin of 3TG. In accordance with industry standards, CMRTs are sent to and requested from In-Scope Suppliers, who are expected to follow this process until the smelter and refiner sources are identified. For the 2020 reporting year, Table 1 sets out the result of Bloom Energy’s supply chain outreach.
Table 1
SUPPLY CHAIN OUTREACH METRICS
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| | | | | | | |
| Number of In-Scope Suppliers | Change in Number of In-Scope Suppliers From 2019 | Response Rate | |
| 177 | 31 | ~88% (155 out of 177) | |
Upstream Data Transparency
As mentioned above, Bloom Energy is a downstream consumer of 3TGs and does not purchase raw minerals directly from any mines, smelters or refiners or any of the Covered Countries. Bloom Energy’s supply chain is extensive and complex with many layers of suppliers positioned between ourselves and 3TG smelters and refiners. Therefore, to execute due diligence, Bloom Energy must rely on data from its direct suppliers and third-party audit programs. As Bloom Energy does not solely control these processes, there is a risk of incomplete or inaccurate data. However, multiple supplier-outreach efforts and process validation steps help mitigate this risk. Bloom Energy believes this due diligence process aligns with industry standards and market expectations for downstream companies.
All known smelters and refiners listed by suppliers in completed CMRTs (which appear on the RMI-maintained smelters list as of May 1, 2021) are set out in Appendix A. As is a common practice when requests are sent upstream in the supply chain, those companies who purchase materials from smelters may not be able to discern exactly which of their products contain the materials. As a result, those companies who provide a list of smelters and refiners tend to list all smelters and refiners from which they may purchase within the reporting period. Although the potential for over-reporting is understood, Bloom Energy has taken measures to validate these sources of origin against validated audit programs intended to verify the material types and mine sources of origin for these smelters and refiners. Therefore, the smelters or refiners listed in Appendix A as sources are likely to be more comprehensive than the list of smelters or refiners that actually processed the 3TGs in the Covered Product.
In accordance with OECD Guidance, suppliers that identified specific smelters or refiners of concern in their CMRT were contacted to communicate the potential for risk and to evaluate whether or not these smelters or refiners could be connected to the Covered Product. Bloom Energy obtained RCOI data through the SI platform and with the help of SI this data was used to determine the 3TG country of origin for the 320 smelters and refiners identified in Bloom Energy’s supply chain. The RMAP classifies smelters and refiners audit status in the following manner:
•Conformant: Smelters or refiners has been audited and found to conform with a relevant, third-party audit protocol, including RMAP, LBMA, or RJC;
•RMAP-Active: The active lists represent smelters and refiners that have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment; and
•Non-Conformant or Not Enrolled: The smelter or refiner is listed on the Smelter Look-up tab of the CMRT but is not Conformant or RMAP-Active.
| | | | | |
| Status | Number of Identified Smelters or Refiners |
| RMAP/LBMA/RJC Conformant | 246 |
| RMAP-Active | 18 |
| Non-Conformant or Not Enrolled | 64 |
| Total Number | 320 |
As Bloom Energy does not directly purchase from any mines, smelters or refiners, nor does the majority of its In-Scope Suppliers, Bloom Energy has very little influence over their sourcing. Bloom Energy relies, to a large extent, on the information provided by independent third-party audit programs. Such sources of information may contain incomplete or inaccurate data, and may be subject to fraud.
Bloom Energy has determined that a portion of the 3TGs contained in the Covered Product originated from the Covered Countries, but we were unable to determine the origin of all the 3TG in the Covered Product. As of the date of this Report and for the reporting period covered by this Report, Bloom Energy has not identified a supplier, smelter or refiner that Bloom Energy has reason to believe is sourcing 3TG contained in the Covered Product that is directly or indirectly financing or benefiting an armed group. However, given that Bloom Energy has received insufficient information with respect to certain smelters and refiners that may have provided 3TG for the Covered Product, Bloom Energy has not determined that the Covered Product is “DRC conflict-free.”
Due Diligence Improvement Efforts
Bloom Energy will continue to communicate its expectations and information requirements to its In-Scope Suppliers and continue to work towards a conflict-free supply chain. In addition, Bloom Energy will continue to make inquiries of its In-Scope Suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If Bloom Energy becomes aware of a supplier whose due diligence process or reporting needs improvement, Bloom Energy currently intends to continue the trade relationship while that supplier improves its compliance program. Bloom Energy expects its In-Scope Suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
In addition to the plans described above, Bloom Energy will undertake the following steps during the next reporting period:
•Continue to collect responses from suppliers using the CMRT, including the collection of more product-level responses specific to the Covered Product.
•Work with In-Scope Suppliers to reduce the number of non-conformant smelters and refiners within Bloom Energy’s supply chain.
•Continue to work directly with its suppliers to provide more complete responses as a number of suppliers have been unable to determine the origin of the 3TG in products or components supplied to Bloom Energy or to determine whether they come from recycled or scrap sources.
•Continue to allow verified conflict-free material from the Covered Countries to enter Bloom Energy’s supply chain.
Additional Information
The statements above are based on the RCOI process and due diligence performed in good faith by Bloom Energy. These statements are based on information available at the time. A number of factors could introduce errors or otherwise affect Bloom Energy’s status with respect to this Report. These factors include, but are not limited to, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources, all instances of conflict minerals necessary to the functionality or manufacturing of the Covered Product possibly not yet having been identified, gaps in supplier education and knowledge, timeliness of data, public information not discovered during a reasonable search, language barriers and translation, oversights or errors in conflict free smelter audits, Covered Countries sourced materials being declared secondary materials, companies in Bloom Energy’s supply chain going out of business, certification programs being not equally advanced for all industry segments and metals, updated guidance regarding the SEC final rules, and smuggling of conflict minerals from the Covered Countries to countries beyond the Covered Countries.
The information contained on any website referred to in this Report does not form any part of this Report or Form SD and is not incorporated by reference herein unless expressly noted.
Countries of Origin
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs. This list is based on information provided through the CMRT data collection process from direct smelter outreach and the RMAP. As mentioned above, it is understood that many responses may provide more data than can be directly linked to the sale of the Covered Product by Bloom Energy, therefore, Appendix B may contain more countries than those from which the Covered Product is sourced.
APPENDIX A: SMELTER LIST
| | | | | |
| Metal | Official Smelter Name |
| Gold | 8853 S.p.A. |
| Gold | Abington Reldan Metals, LLC |
| Gold | Advanced Chemical Company |
| Gold | African Gold Refinery |
| Gold | Aida Chemical Industries Co., Ltd. |
| Gold | Al Etihad Gold Refinery DMCC |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao |
| Gold | Argor-Heraeus S.A. |
| Gold | Asahi Pretec Corp. |
| Gold | Asahi Refining Canada Ltd. |
| Gold | Asahi Refining USA Inc. |
| Gold | Asaka Riken Co., Ltd. |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Gold | AU Traders and Refiners |
| Gold | Augmont Enterprises Private Limited |
| Gold | Aurubis AG |
| Gold | Bangalore Refinery |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold | Boliden AB |
| Gold | C. Hafner GmbH + Co. KG |
| Gold | C.I Metales Procesados Industriales SAS |
| Gold | Caridad |
| Gold | CCR Refinery - Glencore Canada Corporation |
| Gold | Cendres + Metaux S.A. |
| Gold | CGR Metalloys Pvt Ltd. |
| Gold | Chimet S.p.A. |
| Gold | Chugai Mining |
| Gold | Daye Non-Ferrous Metals Mining Ltd. |
| Gold | Degussa Sonne / Mond Goldhandel GmbH |
| Gold | Dijllah Gold Refinery FZC |
| Gold | DODUCO Contacts and Refining GmbH |
| Gold | Dowa |
| Gold | DS PRETECH Co., Ltd. |
| Gold | DSC (Do Sung Corporation) |
| Gold | Eco-System Recycling Co., Ltd. East Plant |
| Gold | Eco-System Recycling Co., Ltd. North Plant |
| Gold | Eco-System Recycling Co., Ltd. West Plant |
| Gold | Emirates Gold DMCC |
| | | | | |
| Gold | Fidelity Printers and Refiners Ltd. |
| Gold | Fujairah Gold FZC |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. |
| Gold | Geib Refining Corporation |
| Gold | Gold Coast Refinery |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM |
| Gold | Guangdong Jinding Gold Limited |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold | Heimerle + Meule GmbH |
| Gold | Heraeus Metals Hong Kong Ltd. |
| Gold | Heraeus Precious Metals GmbH & Co. KG |
| Gold | Hunan Chenzhou Mining Co., Ltd. |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| Gold | HwaSeong CJ CO., LTD. |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| Gold | International Precious Metal Refiners |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Gold | Istanbul Gold Refinery |
| Gold | Italpreziosi |
| Gold | JALAN & Company |
| Gold | Japan Mint |
| Gold | Jiangxi Copper Co., Ltd. |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| Gold | JSC Uralelectromed |
| Gold | JX Nippon Mining & Metals Co., Ltd. |
| Gold | K.A. Rasmussen |
| Gold | Kaloti Precious Metals |
| Gold | Kazakhmys Smelting LLC |
| Gold | Kazzinc |
| Gold | Kennecott Utah Copper LLC |
| Gold | KGHM Polska Miedz Spolka Akcyjna |
| Gold | Kojima Chemicals Co., Ltd. |
| Gold | Korea Zinc Co., Ltd. |
| Gold | Kundan Care Products Ltd. |
| Gold | Kyrgyzaltyn JSC |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO |
| Gold | L'azurde Company For Jewelry |
| Gold | L'Orfebre S.A. |
| Gold | Lingbao Gold Co., Ltd. |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| Gold | LS-NIKKO Copper Inc. |
| Gold | LT Metal Ltd. |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| | | | | |
| Gold | Marsam Metals |
| Gold | Materion |
| Gold | Matsuda Sangyo Co., Ltd. |
| Gold | Metalor Technologies (Hong Kong) Ltd. |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. |
| Gold | Metalor Technologies (Suzhou) Ltd. |
| Gold | Metalor Technologies S.A. |
| Gold | Metalor USA Refining Corporation |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. |
| Gold | Mitsubishi Materials Corporation |
| Gold | Mitsui Mining and Smelting Co., Ltd. |
| Gold | MMTC-PAMP India Pvt., Ltd. |
| Gold | Modeltech Sdn Bhd |
| Gold | Morris and Watson |
| Gold | Moscow Special Alloys Processing Plant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. |
| Gold | Navoi Mining and Metallurgical Combinat |
| Gold | NH Recytech Company |
| Gold | Nihon Material Co., Ltd. |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
| Gold | Ohura Precious Metal Industry Co., Ltd. |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
| Gold | OJSC Novosibirsk Refinery |
| Gold | PAMP S.A. |
| Gold | Pease & Curren |
| Gold | Penglai Penggang Gold Industry Co., Ltd. |
| Gold | Planta Recuperadora de Metales SpA |
| Gold | Prioksky Plant of Non-Ferrous Metals |
| Gold | PT Aneka Tambang (Persero) Tbk |
| Gold | PX Precinox S.A. |
| Gold | QG Refining, LLC |
| Gold | Rand Refinery (Pty) Ltd. |
| Gold | Refinery of Seemine Gold Co., Ltd. |
| Gold | REMONDIS PMR B.V. |
| Gold | Royal Canadian Mint |
| Gold | SAAMP |
| Gold | Sabin Metal Corp. |
| Gold | Safimet S.p.A |
| Gold | SAFINA A.S. |
| Gold | Sai Refinery |
| Gold | Samduck Precious Metals |
| Gold | SAMWON METALS Corp. |
| Gold | SAXONIA Edelmetalle GmbH |
| Gold | SEMPSA Joyeria Plateria S.A. |
| | | | | |
| Gold | Shandong Humon Smelting Co., Ltd. |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. |
| Gold | Shirpur Gold Refinery Ltd. |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. |
| Gold | Singway Technology Co., Ltd. |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals |
| Gold | Solar Applied Materials Technology Corp. |
| Gold | Sovereign Metals |
| Gold | State Research Institute Center for Physical Sciences and Technology |
| Gold | Sudan Gold Refinery |
| Gold | Sumitomo Metal Mining Co., Ltd. |
| Gold | SungEel HiMetal Co., Ltd. |
| Gold | T.C.A S.p.A |
| Gold | Tanaka Kikinzoku Kogyo K.K. |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. |
| Gold | Tokuriki Honten Co., Ltd. |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. |
| Gold | Tony Goetz NV |
| Gold | TOO Tau-Ken-Altyn |
| Gold | Torecom |
| Gold | Umicore Brasil Ltda. |
| Gold | Umicore Precious Metals Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining |
| Gold | United Precious Metal Refining, Inc. |
| Gold | Valcambi S.A. |
| Gold | Western Australian Mint (T/a The Perth Mint) |
| Gold | WIELAND Edelmetalle GmbH |
| Gold | Yamakin Co., Ltd. |
| Gold | Yokohama Metal Co., Ltd. |
| Gold | Yunnan Copper Industry Co., Ltd. |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Tantalum | Asaka Riken Co., Ltd. |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. |
| Tantalum | D Block Metals, LLC |
| Tantalum | Exotech Inc. |
| Tantalum | F&X Electro-Materials Ltd. |
| Tantalum | FIR Metals & Resource Ltd. |
| Tantalum | Global Advanced Metals Aizu |
| Tantalum | Global Advanced Metals Boyertown |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. |
| Tantalum | H.C. Starck Hermsdorf GmbH |
| | | | | |
| Tantalum | H.C. Starck Inc. |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| Tantalum | Jiangxi Tuohong New Raw Material |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| Tantalum | Jiujiang Tanbre Co., Ltd. |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| Tantalum | KEMET Blue Metals |
| Tantalum | LSM Brasil S.A. |
| Tantalum | Meta Materials |
| Tantalum | Metallurgical Products India Pvt., Ltd. |
| Tantalum | Mineracao Taboca S.A. |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum | NPM Silmet AS |
| Tantalum | QuantumClean |
| Tantalum | Resind Industria e Comercio Ltda. |
| Tantalum | Solikamsk Magnesium Works OAO |
| Tantalum | Taki Chemical Co., Ltd. |
| Tantalum | TANIOBIS Co., Ltd. |
| Tantalum | TANIOBIS GmbH |
| Tantalum | TANIOBIS Japan Co., Ltd. |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG |
| Tantalum | Telex Metals |
| Tantalum | Ulba Metallurgical Plant JSC |
| Tantalum | XinXing Haorong Electronic Material Co., Ltd. |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| Tin | Alpha |
| Tin | An Vinh Joint Stock Mineral Processing Company |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. |
| Tin | China Tin Group Co., Ltd. |
| Tin | CRM Synergies |
| Tin | CV Ayi Jaya |
| Tin | CV Venus Inti Perkasa |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| Tin | Dowa |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| Tin | EM Vinto |
| Tin | Estanho de Rondonia S.A. |
| Tin | Fenix Metals |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. |
| Tin | Gejiu Fengming Metallurgy Chemical Plant |
| Tin | Gejiu Kai Meng Industry and Trade LLC |
| | | | | |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. |
| Tin | Huichang Jinshunda Tin Co., Ltd. |
| Tin | Jiangxi New Nanshan Technology Ltd. |
| Tin | Luna Smelter, Ltd. |
| Tin | Ma'anshan Weitai Tin Co., Ltd. |
| Tin | Magnu's Minerais Metais e Ligas Ltda. |
| Tin | Malaysia Smelting Corporation (MSC) |
| Tin | Melt Metais e Ligas S.A. |
| Tin | Metallic Resources, Inc. |
| Tin | Metallo Belgium N.V. |
| Tin | Metallo Spain S.L.U. |
| Tin | Mineracao Taboca S.A. |
| Tin | Minsur |
| Tin | Mitsubishi Materials Corporation |
| Tin | Modeltech Sdn Bhd |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Tin | Novosibirsk Processing Plant Ltd. |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin | O.M. Manufacturing Philippines, Inc. |
| Tin | Operaciones Metalurgicas S.A. |
| Tin | Pongpipat Company Limited |
| Tin | Precious Minerals and Smelting Limited |
| Tin | PT Aries Kencana Sejahtera |
| Tin | PT Artha Cipta Langgeng |
| Tin | PT ATD Makmur Mandiri Jaya |
| Tin | PT Babel Inti Perkasa |
| Tin | PT Babel Surya Alam Lestari |
| Tin | PT Bangka Serumpun |
| Tin | PT Bukit Timah |
| Tin | PT Lautan Harmonis Sejahtera |
| Tin | PT Menara Cipta Mulia |
| Tin | PT Mitra Stania Prima |
| Tin | PT Mitra Sukses Globalindo |
| Tin | PT Prima Timah Utama |
| Tin | PT Rajawali Rimba Perkasa |
| Tin | PT Rajehan Ariq |
| Tin | PT Refined Bangka Tin |
| Tin | PT Stanindo Inti Perkasa |
| Tin | PT Timah Nusantara |
| Tin | PT Timah Tbk Kundur |
| | | | | |
| Tin | PT Timah Tbk Mentok |
| Tin | PT Tinindo Inter Nusa |
| Tin | Resind Industria e Comercio Ltda. |
| Tin | Rui Da Hung |
| Tin | Soft Metais Ltda. |
| Tin | Super Ligas |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. |
| Tin | Thaisarco |
| Tin | Tin Technology & Refining |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| Tin | VQB Mineral and Trading Group JSC |
| Tin | White Solder Metalurgia e Mineracao Ltda. |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tin | Yunnan Tin Company Limited |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
| Tungsten | A.L.M.T. TUNGSTEN Corp. |
| Tungsten | ACL Metais Eireli |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
| Tungsten | Asia Tungsten Products Vietnam Ltd. |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. |
| Tungsten | China Molybdenum Co., Ltd. |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. |
| Tungsten | Cronimet Brasil Ltda |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten | GEM Co., Ltd. |
| Tungsten | Global Tungsten & Powders Corp. |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten | H.C. Starck Tungsten GmbH |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. |
| Tungsten | Hydrometallurg, JSC |
| Tungsten | Japan New Metals Co., Ltd. |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| | | | | |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" |
| Tungsten | Kennametal Fallon |
| Tungsten | Kennametal Huntsville |
| Tungsten | KGETS CO., LTD. |
| Tungsten | Lianyou Metals Co., Ltd. |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten | Masan Tungsten Chemical LLC (MTC) |
| Tungsten | Moliren Ltd. |
| Tungsten | Niagara Refining LLC |
| Tungsten | NPP Tyazhmetprom LLC |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. |
| Tungsten | Unecha Refractory Metals Plant |
| Tungsten | Wolfram Bergbau und Hutten AG |
| Tungsten | Woltech Korea Co., Ltd. |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
| Tungsten | Xiamen Tungsten Co., Ltd. |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
APPENDIX B: COUNTRIES OF ORIGIN
This Appendix B includes the countries from which the declared are known to source material.
| | | | | | | | |
| ANGOLA | HONG KONG | PHILIPPINES |
| ARGENTINA | HUNGARY | POLAND |
| ARMENIA | INDIA | PORTUGAL |
| AUSTRALIA | INDONESIA | RUSSIAN FEDERATION |
| AUSTRIA | IRELAND | RWANDA |
| BELARUS | ISRAEL | SAUDI ARABIA |
| BELGIUM | ITALY | SIERRA LEONE |
| BERMUDA | IVORY COAST | SINGAPORE |
| BOLIVIA | JAPAN | SLOVAKIA |
| BRAZIL | JERSEY | SOUTH AFRICA |
| BURUNDI | KAZAKHSTAN | SOUTH SUDAN |
| CAMBODIA | KENYA | SPAIN |
| CANADA | KOREA, REPUBLIC OF | SURINAME |
| CENTRAL AFRICAN REPUBLIC | KYRGYZSTAN | SWEDEN |
| CHILE | LAOS | SWITZERLAND |
| CHINA | LUXEMBOURG | TAIWAN |
| COLOMBIA | MADAGASCAR | TAJIKISTAN |
| CONGO (BRAZZAVILLE) | MALAYSIA | TANZANIA |
| CZECH REPUBLIC | MALI | THAILAND |
| DJIBOUTI | MEXICO | TURKEY |
| DRC CONGO (KINSHASA) | MONGOLIA | UGANDA |
| ECUADOR | MOROCCO | UNITED ARAB EMIRATES |
| EGYPT | MOZAMBIQUE | UNITED KINGDOM |
| ESTONIA | MYANMAR | UNITED STATES |
| ETHIOPIA | NAMIBIA | UZEBEKISTAN |
| FINLAND | NETHERLANDS | VIET NAM |
| FRANCE | NEW ZEALAND | ZAMBIA |
| GERMANY | NIGER | ZIMBABWE |
| GHANA | NIGERIA | |
| GUINEA | PAPUA NEW GUINEA | |
| GUYANA | PERU | |
