EX-1.01 2 exhibit_1-01.htm EXHIBIT 1.01

Exhibit 1.01


Conflict Minerals Report

This is the Conflict Minerals Report for Senstar Technologies Corporation (as successor to Senstar Technologies Ltd.) (“Senstar”, “the Company”, “we”, “us” or “our”), filed with the SEC pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1, 2023 to December 31, 2023. The Rule was adopted by the SEC to implement reporting and disclosure requirements related to Conflict Minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on Securities and Exchange Commission (theSEC”) registrants whose manufactured or contracted to manufacture products contain, or likely contain, Conflict Minerals that are necessary for the functionality or production of those products. “Conflict Minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”) for the purposes of this assessment.
 
If a registrant cannot establish with complete certainty that the Conflict Minerals that are necessary for the manufacture or functionality of its products originated or likely originated from sources other than the Democratic Republic of the Congo or the adjoining countries (together referred to as “Covered Countries”), or that they originate from entirely recycled or scrap sources, the registrant must submit a specialized disclosure report under the Form SD that describes the steps that the registrant took to determine the origin or likely country of origin of the Conflict Minerals in its products.  As part of the company's desire to take responsibility for and concern themselves with human rights issues, we decided to review the company's supply chain according to the EU regulation's guidance as well, and within that have included conflict-affected or high-risk areas ("CAHRAs") when approaching suppliers for information.

If a registrant has reason to believe that the Conflict Minerals in its supply chain may have originated in Covered Countries, or if the registrant is unable to determine the likely country of origin of those Conflict Minerals, then the registrant must exercise due diligence on the Conflict Minerals’ source and chain of custody, and the registrant must annually submit a Conflict Minerals Report (a “CMR”) as an exhibit to its Form SD to the SEC that includes a description of those due diligence measures.

Our goal in designing and implementing our Conflict Minerals risk management strategy is not to eliminate sourcing from Covered Countries, but to encourage participation with the Responsible Minerals Initiative ("RMI") and other relevant independent third-party auditing bodies, where possible.

As permitted by the Rule and the SEC, this report has not been subject to an independent private sector audit.


1.
Company Overview

      We are a leading international provider of comprehensive physical, video, and access control security products and solutions. We offer comprehensive solutions for critical sites, which leverage our broad portfolio of homegrown PIDS (Perimeter Intrusion Detection Systems), advanced VMS (Video Management Software) with native IVA (Intelligent Video Analytics) security solutions, as well as access control products and technologies.

       Effective March 18, 2024, Senstar Technologies Ltd. redomiciled from the State of Israel to the Province of Ontario, Canada. Senstar Technologies Corporation is the successor company to Senstar Technologies Ltd. . Accordingly, the historical results of Senstar Technologies Ltd. for the periods prior to redomestication are considered to be the historical financial statements of the Company.




2.
Supply Chain and Product Overview

      Based on our multi-decade industry experience and interaction with customers, we have developed a comprehensive set of solutions and products, optimized for perimeter, outdoor, and general security applications. Our broad portfolio of critical infrastructure protection and site protection technologies includes a variety of fences, fence mounted sensors, buried and concealed detection systems, and sophisticated sensors for sub-surface intrusion such as to secure pipelines, as well as advanced video analytics software and video management systems. We have successfully installed customized solutions and products in more than 100 countries worldwide.

       Our products often require the use of tin, tantalum and gold, or 3TG, as defined, which fall under the definition of Conflict Minerals, per the Rule.

       Our supply chain is global and complex, and there are multiple tiers between our Company and the sources or mines of the Conflict Minerals that are necessary to the functionality or production of our products. Therefore, the Company or its suppliers purchase 3TG-related materials after processing by Smelters or Refiners (“SoRs”). Accordingly, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components that are included in our products.


3.
Reasonable Country of Origin Inquiry

In order to conduct a Reasonable Country of Origin Inquiry (“RCOI”) on the source or origin, or the likely country of origin, of Conflict Minerals that are necessary to the functionality or production of our products, we developed a risk-based approach that focuses on suppliers involved in manufacturing the relevant abovementioned products that contain or use the necessary Conflict Minerals. We identified 20 relevant suppliers that we concluded provide us with products and components that contain or may contain 3TG necessary to functionality or production of our products, and which accounted for 90% of all applicable materials purchased by Senstar in 2023.

Utilizing the Responsible Minerals Initiative's (“RMI”), standard Conflict Minerals Reporting Template (“CMRT”) of, at a minimum version 6.22, and the services of a third-party data management provider, we surveyed the relevant suppliers that supply us, or likely supply us, with products or product components that contain, or likely contain the necessary Conflict Minerals. As noted, we do not purchase the necessary Conflict Minerals directly from the facilities that process the 3TG, given our constitution as a downstream company, and therefore we purchase the 3TG from our direct suppliers, who also purchase these minerals from their own upstream suppliers, or the SoRs themselves. Additionally, we sent letters to our relevant suppliers, informing them of the Rule and the Company's Conflict Minerals Policy. We reviewed the responses and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information or did not provide adequate responses per information compared against Third Party Audit bodies’, such as the RMI’s, lists of conformant and active SoRs. We received responses from 100% of the suppliers we approached.

The majority of suppliers from which we requested information indicated in their response that the information provided was at a company level (85%). Based on those responses, some of the suppliers and manufacturers were unable to accurately report the SoRs that were part of their supply chain and that were applicable to the components or products that were sold to us in 2023.

Based on information obtained in the RCOI, and considering the complexities of our supply chain, we do not have sufficient information from our suppliers to determine the country of origin, or likely country of origin, of the Conflict Minerals used in our products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in Covered Countries and are not from recycled or scrap sources.

In accordance with the Rule, Senstar undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of its products during 2023. There is significant overlap between the RCOI efforts and the due diligence measures employed.

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4.
Design of Our Due Diligence

Based on the findings of our RCOI, we designed our 3TG mineral supply chain due-diligence process in reference to the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance (2016) for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and its related Supplements for 3TG.
 
Senstar has processes in place for the purpose of exercising due diligence on its supply chain. The design of the due diligence processes conform with the OECD Guidance as it relates to downstream purchasers of products and components. The due diligence processes are described below under sub-headings corresponding to the five-step framework of the OECD Guidance.


5.
Due Diligence Performance

Step 1 - Establish strong company management systems:


-
Our Conflict Minerals Policy is publicly available on our website at the following link: https://senstartechnologies.com/corporate-governance/.

-
We have a team of individuals from various functions (Operations and Finance) within the organization to continually support the process of supply chain due diligence. The team meets, as needed, to assess identified risks and determine follow up actions.

-
Senstar maintains a system of controls and transparency over the 3TG mineral supply chain through use of the RMI's CMRT reporting template of, at a minimum, version 6.22 Due to the large size and global spread of our supply chain, we have also contracted a service provider to enhance the supplier data collection process and to help minimize sourcing risks.

-
We maintain records relating to our Conflict Minerals program for a period of at least 5 years.

-
We enable employees, suppliers and other stakeholders to report any concerns relating to our Conflict Minerals program through our grievance mechanism. Contact details for concerns or questions are provided in our Conflict Mineral Policy that is publicly available at our website under the heading “Corporate Governance” and at the following link: https://senstartechnologies.com/corporate-governance/.

Step 2 - Identify and assess risk in the supply chain:


-
We mapped and evaluated our family of products. Senstar mapped the relevant agents and suppliers, as well as the manufacturers that sell to these agents and suppliers in order to identify relevant suppliers for the supply chain inquiry.

-
We surveyed our suppliers using, at a minimum, version 6.22 of the CMRT (as detailed above in "Reasonable Country of Origin" section). We compared the SoRs identified by our suppliers against the lists of facilities that have received a conformant or active designation by the RMI's Responsible Minerals Assurance Process (“RMAP”) smelter or refiner validation program or other independent third-party audit programs. We contacted suppliers that did not respond or provided inadequate responses.

-
Due to our size, the breadth and complexity of our products and the constant evolution of our supply chain, it is difficult to identify the relevant SoRs in our supply chain. We do not purchase Conflict Minerals directly from mines or the SoRs, and there are many tiers in the supply chain between us and the original source of the Conflict Minerals.  As a result, we rely on our direct suppliers and manufacturers to provide information regarding the origin of any Conflict Minerals. This challenge brings us to engage a service provider to assist in certain aspects of the process.

3

 
Step 3 - Design and implementation of a strategy to respond to identified risks:


-
We reviewed the survey responses, assessed the risks identified and implemented a strategy to respond to those risks.

o
We followed up on inconsistent, incomplete, or inaccurate responses, as well as sent reminders to certain suppliers who did not respond to our requests for information.

o
Relevant senior management was briefed about our due diligence efforts, risk analysis results and mitigation efforts.

o
Our team, led by our CFO, assessed identified risks and determined follow up actions.

o
Some suppliers that source from uncertified SoRs or from uncertified SoRs from Covered Countries, according to Third Party Audit bodies, such as the RMAP, were contacted and were asked to submit more information about their sourcing practices, including a corrective action plan.


-
Supply chain due diligence is a dynamic process and requires on-going risk monitoring. To ensure the effectiveness of risk management, after implementation of our strategy, we review and address the identified risks.

Step 4 - Carry Out Independent Third-Party Audit of SoRs’ Due Diligence Practices:
 
Senstar, as a downstream company does not have a direct relationship with 3TG SoRs and is significantly removed from the SoRs that process the Conflict Minerals. As such, we do not perform direct audits of SoRs in our supply chain, but rather rely on due diligence performed by organizations such as the RMI and compare SoR data received with the RMI's Standard Smelter List of SoRs conformant or active in the RMAP program.
 
Step 5 - Report Annually on Supply Chain Due Diligence:

We currently, subject to SEC guidelines, report annually on our supply chain due diligence through Form SD. Our reports on Form SD are publicly available at https://senstartechnologies.com/sec-filings/.


6.
Results for the 2023 Calendar Year

Based on the results of our due diligence thus far, we believe it is likely that years of engagement and communication of expectations through many tiers of the supply chain will be necessary before information returned to downstream companies, such as ours, may be considered accurate and complete.

In addition, the following factors materially affect the results of our assessment:

 
 
We are dependent on information received from our direct suppliers to conduct our good faith RCOI process;
 
 
 
 
We do not have a direct relationship with 3TG SoRs, nor do we perform direct audits of the other entities in our supply chain;
 
We have a varied supplier base with differing levels of resources and sophistication, and many of our suppliers are not themselves subject to the Rule;
 
 
 
The information our suppliers provide us with is often incomplete and requires significant follow-up;
 
 
 
Many suppliers provided responses at a company or divisional level, and not at a product level specific to the materials and components we use in the subject products;
 
 
 
Certain suppliers were unable or unwilling to specify the SoRs used for materials and components supplied to us;
 
 
 
 
Our ability to influence cooperation from certain suppliers was limited as we were multiple tiers away from the SoRs in the supply chain; and
 
The information gathered from our suppliers is not obtained on a continuous, real-time basis.

We conducted a supply-chain survey of 20 of our direct suppliers that we identified may contribute necessary Conflict Minerals to our products. The overall response rate to this survey was 100%.

4


Response analysis:

Out of the total responses received, 20 responses were defined as complete responses and no responses were incomplete or inconsistent.

Declaration scope:
 
Based on the responses that we received, most of our suppliers delivered declaration in company level as shown below:

Company level
85%
User-defined
10%
Products list
5%

As such, Senstar was unable to identify the country of origin of the Conflict Minerals used in the Company’s products in 2023.
 
Based on the information provided by our suppliers, we believe that the facilities that may have been used to process the Conflict Minerals in our products may include the SoRs listed in Exhibit A below. Based on our due diligence efforts, we do not have sufficient information to determine the countries of origin, or likely countries of origin, of the Conflict Minerals in our products or whether the Conflict Minerals in our products are from entirely recycled or scrap sources, see Exhibit B below. Pursuant to the Rule, this report is not subject to an independent private sector audit.


7.
Conclusion

Due to the breadth and scope of our product categories, the resulting complexity of our supply chain, and the human and financial resources available to us, we acknowledge that the process of successfully tracing all of the Conflict Minerals used in our manufactured or contracted to manufacture products to their country of origin will take additional time and resources. Moving forward, subject to the legal requirements and any changes to the Rule, we will continue to implement commercially reasonable processes to improve the quantity and quality of supplier responses.
 
Failure to obtain reliable information from any level of our supply chain could materially impact our future ability to report on the presence of Conflict Minerals with any degree of certainty. There can be no assurance that our suppliers will continue to cooperate with diligence inquiries and requests for certifications or provide documentation or other evidence that we consider reliable or provided to us within a time frame sufficient to allow us to make our own assessment following appropriate further diligence measures, if any. The information provided in this Conflict Mineral Report speaks only as of its date. Subsequent events, including future guidelines by the SEC, and the inability or unwillingness of participants in our supply chain to provide complete and accurate information requested, may affect our future determinations under the Rule.
 
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8.
Continuous Improvement Efforts to Mitigate Risk
 
The company will continue working with its global supply chain to ensure responsible sourcing and assure compliance with international regulations. As we continue to implement our due diligence program, we intend to take measures to continue to mitigate any possible risk that the necessary Conflict Minerals in our products could directly or indirectly fund or benefit armed groups in the DRC or Covered Countries, as well as conflict-affected or high-risk areas ("CAHRAs").
 
Cautionary Statement about Forward-Looking Statements

Statements in this Conflict Minerals Report, which express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other things, our customers’ requirements to use certain suppliers, our suppliers’ responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our Conflict Minerals program, our ability to identify and mitigate related risks in our supply chain, our ability to constructively work with our suppliers to achieve compliance, our ability to obtain complete and accurate information from our suppliers, our ability to improve the efficiency and effectiveness of our due diligence measures, our ability to identify and constructively engage with SORs in our supply chain, changes in our supply chain, changes to the parts or materials used by or supplied to us, changes in SORs, changes in country of origin information of the necessary Conflict Minerals received from our suppliers, and changes in the Rule and other political and regulatory developments relating to the sourcing of Conflict Minerals, whether in the Covered Countries or elsewhere. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of risk factors, see our other filings with the SEC, including our Annual Report on Form 20-F for the year ended December 31, 2023. We caution that undue reliance should not be placed on these forward-looking statements, which speak only as of the date of this report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by federal securities laws.

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Exhibit A
 
List of identified certified SoRs
 
Metal
Smelter or Refiner (SoR) Name
Smelter or Refiner (SoR) Country
Gold
8853 S.p.A.
ITALY
Gold
ABC Refinery Pty Ltd.
AUSTRALIA
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
African Gold Refinery*
UGANDA
Gold
Agosi AG
GERMANY
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
Albino Mountinho Lda.
PORTUGAL
Gold
Alexy Metals
UNITED STATES OF AMERICA
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Asahi Pretec Corp.
JAPAN
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
AU Traders and Refiners
SOUTH AFRICA
Gold
Augmont Enterprises Private Limited
INDIA
Gold
Aurubis AG
GERMANY
Gold
Bangalore Refinery
INDIA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Boliden AB
SWEDEN
Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
C.I Metales Procesados Industriales SAS
COLOMBIA
Gold
Caridad
MEXICO
Gold
CCR Refinery – Glencore Canada Corporation
CANADA
Gold
Cendres + Metaux S.A.
SWITZERLAND
Gold
CGR Metalloys Pvt Ltd.
INDIA
Gold
Chimet S.p.A.
ITALY
Gold
Chugai Mining
JAPAN
Gold
Coimpa Industrial LTDA
BRAZIL
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
Gold
Dongwu Gold Group
CHINA


7



Gold
Dowa
JAPAN
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
Gold
Emerald Jewel Industry India Limited (Unit 1)
INDIA
Gold
Emerald Jewel Industry India Limited (Unit 2)
INDIA
Gold
Emerald Jewel Industry India Limited (Unit 3)
INDIA
Gold
Emerald Jewel Industry India Limited (Unit 4)
INDIA
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
Fujairah Gold FZC
UNITED ARAB EMIRATES
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
GGC Gujrat Gold Centre Pvt. Ltd.
INDIA
Gold
Gold by Gold Colombia
COLOMBIA
Gold
Gold Coast Refinery
GHANA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Gold
Great Wall Precious Metals Co., Ltd. Of CBPM
CHINA
Gold
Guangdong Jinding Gold Limited
CHINA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Germany GmbH Co. KG
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Gold
Industrial Refining Company
BELGIUM
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Italpreziosi
ITALY
Gold
JALAN & Company
INDIA
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
JSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
K.A. Rasmussen
NORWAY
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES


8



Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
Kundan Care Products Ltd.
INDIA
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Gold
Lingbao Gold Co., Ltd.
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
L'Orfebre S.A.
ANDORRA
Gold
LS MnM Inc.
KOREA, REPUBLIC OF
Gold
LT Metal Ltd.
KOREA, REPUBLIC OF
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
Marsam Metals
BRAZIL
Gold
Materion
UNITED STATES OF AMERICA
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
MD Overseas
INDIA
Gold
Metal Concentrators SA (Pty) Ltd.
SOUTH AFRICA
Gold
Metallix Refining Inc.
UNITED STATES OF AMERICA
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalor Technologies S.A.
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
MKS PAMP SA
SWITZERLAND
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
Modeltech Sdn Bhd
MALAYSIA
Gold
Morris and Watson
NEW ZEALAND
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
Pease & Curren
UNITED STATES OF AMERICA
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
Planta Recuperadora de Metales SpA
CHILE
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Precinox S.A.
SWITZERLAND

9



Gold
QG Refining, LLC
UNITED STATES OF AMERICA
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Gold
REMONDIS PMR B.V.
NETHERLANDS
Gold
Royal Canadian Mint
CANADA
Gold
SAAMP
FRANCE
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Gold
Safimet S.p.A
ITALY
Gold
SAFINA A.S.
CZECHIA
Gold
Sai Refinery
INDIA
Gold
Sam Precious Metals
UNITED ARAB EMIRATES
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Gold
Sancus ZFS (L’Orfebre, SA)
COLOMBIA
Gold
Sellem Industries Ltd.
MAURITANIA
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
Shandong Gold Smelting Co., Ltd.
CHINA
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Shenzhen CuiLu Gold Co., Ltd.
CHINA
Gold
Shenzhen Zhonghenglong Real Industry Co., Ltd.
CHINA
Gold
Shirpur Gold Refinery Ltd.
INDIA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Sovereign Metals
INDIA
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Gold
Sudan Gold Refinery
SUDAN
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
Super Dragon Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
T.C.A S.p.A
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Valcambi S.A.
SWITZERLAND
Gold
WEEEREFINING
FRANCE


10


Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Tantalum
5D Production OU
ESTONIA
Tantalum
AMG Brasil
BRAZIL
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
F&X Electro-Materials Ltd.
CHINA
Tantalum
FIR Metals & Resource Ltd.
CHINA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET de Mexico
MEXICO
Tantalum
Materion Newton Inc.
UNITED STATES OF AMERICA
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineracao Taboca S.A.
BRAZIL
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
NPM Silmet AS
ESTONIA
Tantalum
Plansee SE Reutte
AUSTRIA
Tantalum
PowerX Ltd.
RWANDA
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
RFH Metals & Chemicals Co., Ltd.
CHINA
Tantalum
RFH Yancheng Jinye New Material Technology Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
TANIOBIS Co., Ltd.
THAILAND
Tantalum
TANIOBIS GmbH
GERMANY
Tantalum
TANIOBIS Japan Co., Ltd.
JAPAN
Tantalum
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
V&D New Materials (Jiangsu) Co., Ltd.
CHINA

11



Tantalum
XIMEI RESOURCES (GUANGDONG) LIMITED
CHINA
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
CHINA
Tin
Alpha
UNITED STATES OF AMERICA
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
Aurubis Beerse
BELGIUM
Tin
Aurubis Berango
SPAIN
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
BRAZIL
Tin
CRM Synergies
SPAIN
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
Tin
Dragon Silver Holdings Limited
CHINA
Tin
DS Myanmar
MYANMAR
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Estanho de Rondonia S.A.
BRAZIL
Tin
Fabrica Auricchio Industria e Comercio Ltda.
BRAZIL
Tin
Feinhutte Halsbrucke GmbH
GERMANY
Tin
Fenix Metals
POLAND
Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
Luna Smelter, Ltd.
RWANDA
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Melt Metais e Ligas S.A.
BRAZIL
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA


12


Tin
Mining Minerals Resources SARL
CONGO, DEMOCRATIC REPUBLIC OF THE
Tin
Minsur
PERU
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
Novosibirsk Tin Combine
RUSSIAN FEDERATION
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Pongpipat Company Limited
MYANMAR
Tin
Precious Minerals and Smelting Limited
INDIA
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
PT Babel Inti Perkasa
INDONESIA
Tin
PT Babel Surya Alam Lestari
INDONESIA
Tin
PT Bangka Prima Tin
INDONESIA
Tin
PT Bangka Serumpun
INDONESIA
Tin
PT Bangka Tin Industry
INDONESIA
Tin
PT Belitung Industri Sejahtera
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT Cipta Persada Mulia
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Mitra Sukses Globalindo
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Premium Tin Indonesia
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Putera Sarana Shakti (PT PSS)
INDONESIA
Tin
PT Rajawali Rimba Perkasa
INDONESIA
Tin
PT Rajehan Ariq
INDONESIA
Tin
PT Refined Bangka Tin
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
PT Timah Nusantara
INDONESIA
Tin
PT Timah Tbk Kundur
INDONESIA
Tin
PT Timah Tbk Mentok
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
PT Tirus Putra Mandiri
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
Rian Resources SDN. BHD.
MALAYSIA
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Soft Metais Ltda.
BRAZIL
Tin
Super Ligas
BRAZIL
Tin
Thaisarco
THAILAND
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.
CHINA
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
TRATHO Metal Quimica
BRAZIL
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM

13



Tin
VQB Mineral and Trading Group JSC
VIET NAM
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
Tungsten
A.L.M.T. Corp.
JAPAN
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
Tungsten
Artek LLC
RUSSIAN FEDERATION
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Avon Specialty Metals Ltd
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND
Tungsten
China Molybdenum Tungsten Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tungsten
Cronimet Brasil Ltda
BRAZIL
Tungsten
DONGKUK INDUSTRIES CO., LTD.
KOREA, REPUBLIC OF
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Tungsten
Fujian Xinlu Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
Ganzhou Sunny Non-Ferrous Metals Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
HANNAE FOR T Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Hubei Green Tungsten Co., Ltd.
CHINA
Tungsten
Hunan Jintai New Material Co., Ltd.
CHINA
Tungsten
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
CHINA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Tungsten
LLC Vostok
RUSSIAN FEDERATION
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Masan High-Tech Materials
VIET NAM
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
Nam Viet Cromit Joint Stock Company
VIET NAM

14



Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
NPP Tyazhmetprom LLC
RUSSIAN FEDERATION
Tungsten
OOO “Technolom” 1
RUSSIAN FEDERATION
Tungsten
OOO “Technolom” 2
RUSSIAN FEDERATION
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
Shinwon Tungsten (Fujian Shanghang) Co., Ltd.
CHINA
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
YUDU ANSHENG TUNGSTEN CO., LTD.
CHINA

* 1 Gold smelter (African Gold Refinery, CID003185, Uganda) has been identified in our supply chain, that is included in OFAC (U.S. Department of the Treasury, Office of Foreign Assets Control) sanctioned entities lists. Senstar has no direct business with the refinery. Through our due diligence examination, we identified our direct suppliers who reported utilizing this smelter in their supply chain. We are in communication with the direct suppliers who listed this refinery to confirm if the refinery actually exists in our supply chain.
 
15

 
Exhibit B
 
Countries of Origin of the Conflict Minerals
 
Based on Senstar's Conflict Minerals due diligence efforts, the SoRs listed above may process Conflict Minerals in one or more of the following countries of origin:
 
Gold
Tantalum
Tin
Tungsten
ANDORRA
AUSTRIA
BELGIUM
AUSTRIA
AUSTRALIA
BRAZIL
BOLIVIA (PLURINATIONAL STATE OF)
BRAZIL
AUSTRIA
CHINA
BRAZIL
CHINA
BELGIUM
ESTONIA
CHINA
GERMANY
BRAZIL
GERMANY
CONGO, DEMOCRATIC REPUBLIC OF THE
JAPAN
CANADA
INDIA
GERMANY
KOREA, REPUBLIC OF
CHILE
JAPAN
INDIA
PHILIPPINES
CHINA
KAZAKHSTAN
INDONESIA
RUSSIAN FEDERATION
COLOMBIA
MEXICO
MALAYSIA
TAIWAN, PROVINCE OF CHINA
CZECHIA
RUSSIAN FEDERATION
MYANMAR
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND
FRANCE
RWANDA
PERU
UNITED STATES OF AMERICA
GERMANY
THAILAND
PHILIPPINES
VIET NAM
GHANA
UNITED STATES OF AMERICA
POLAND
 
INDIA
 
RUSSIAN FEDERATION
 
INDONESIA
 
RWANDA
 
ITALY
 
SPAIN
 
JAPAN
 
TAIWAN, PROVINCE OF CHINA
 
KAZAKHSTAN
 
THAILAND
 
KOREA, REPUBLIC OF
 
UNITED STATES OF AMERICA
 
KYRGYZSTAN
 
VIET NAM
 
LITHUANIA
 
 
 
MALAYSIA
 
 
 
MAURITANIA
 
 
 
MEXICO
 
 
 
NETHERLANDS
 
 
 
NEW ZEALAND
 
 
 
NORWAY
 
 
 
PHILIPPINES
 
 
 
POLAND
 
 
 
PORTUGAL
 
 
 
RUSSIAN FEDERATION
 
 
 
SAUDI ARABIA
 
 
 
SINGAPORE
 
 
 
SOUTH AFRICA
 
 
 
SPAIN
 
 
 
SUDAN
 
 
 
SWEDEN
 
 
 
SWITZERLAND
 
 
 
TAIWAN, PROVINCE OF CHINA
 
 
 
THAILAND
 
 
 
TURKEY
 
 
 
UGANDA
 
 
 
UNITED ARAB EMIRATES
 
 
 
UNITED STATES OF AMERICA
 
 
 
UZBEKISTAN
 
 
 
ZIMBABWE
 
 
 
 
16