UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Textron Inc.
(Exact name of registrant as specified in its charter)
| Delaware | 1-5480 | 05-0315468 | ||
(State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
| 40 Westminster Street, Providence, RI | 02903 | |
| (Address of principal executive offices) | (Zip Code) |
E. Robert Lupone
Executive Vice President, General Counsel and Secretary
(401) 457-2555
(Name and telephone number, including area code, of the
person to contact in connection with this report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
þ |
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of Textron Inc.’s Conflict Minerals Report filed for the calendar year ended December 31, 2022 is publicly available at http://investor.textron.com/investors/corporate-governance/default.aspx.
Item 1.02 Exhibit
Textron Inc.’s Conflict Minerals Report for the calendar year ended December 31, 2022 is filed as Exhibit 1.01 hereto.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 Textron Inc. Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| textron INC. | ||
| BY: | /s/ E. Robert Lupone | |
| E. Robert Lupone, | ||
| Executive Vice President, | ||
| General Counsel and Secretary | ||
Date: May 30, 2023
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Exhibit 1.01
TEXTRON INC.
Conflict Minerals Report
For the Year Ended December 31, 2022
Introduction
Textron Inc. is providing this report for the year ended December 31, 2022 to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on SEC registrants that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of those products. The term “conflict mineral” means columbite-tantalite, also known as coltan, cassiterite, gold and wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (collectively, “3TGs”).
Company and Product Overview
Textron is a $12.9 billion multi-industry company operating in numerous countries around the world. Our businesses manufacture a variety of complex products including business jets, turboprop and piston aircraft, helicopters and tiltrotor aircraft, unmanned aircraft systems, electronic systems and solutions, advanced marine craft, piston aircraft engines, weapons and related components, armored vehicles, fuel systems and functional components, specialized vehicles such as golf cars, recreational and utility vehicles, aviation ground support equipment and professional mowers. References to “Textron”, “we” and “our” in this Report refer to Textron Inc. and its consolidated subsidiaries.
Covered Products
We conducted a review of the products that we manufacture or contract to be manufactured and found that our products contain 3TGs within numerous components, such as jet engines, circuit boards, electronics, brake components and wiring, and 3TGs generally are required for the products’ functionality or production as specified under the Rule.
Reasonable Country of Origin Inquiry
We conducted a Reasonable Country of Origin Inquiry (“RCOI”) to seek to ascertain whether the 3TGs in our products originated from the Democratic Republic of the Congo or an adjoining country (known collectively as the “Covered Countries”) or are from recycled or scrap sources.
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our worldwide supply chain, it is difficult to identify suppliers in our supply chain which are multiple steps removed from our direct (first-tier) suppliers, and we have no direct relationships with mines, smelters or refiners of 3TGs. Accordingly, we rely on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us by them – including sources of 3TGs that are supplied to them from lower tier suppliers.
To implement our RCOI, we established enterprise-wide conflict minerals procedures directing each business unit to take a number of steps to identify suppliers (“in-scope suppliers”) of components or materials potentially containing 3TGs included in products we manufactured or contracted to manufacture during 2022. As in prior years, in 2022 we retained a third-party service provider to assist us in reviewing our supply chain and identifying risks.
Our third-party service provider conducted a supply chain survey with over 2,100 in-scope suppliers using the Conflict Minerals Reporting Template (“CMRT”), version 6.2 or higher. As part of the supplier survey, in-scope suppliers were contacted via our service provider’s software platform that enables users to complete and track supplier communications and allows suppliers to upload completed CMRT forms directly to the platform for assessment and management. Communications sent to in-scope suppliers through the platform included training and education on the completion of the CMRT form.
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Non-responsive in-scope suppliers were contacted a number of times through the platform and then were also contacted by our service provider’s team. Certain suppliers were also contacted by a representative of the applicable Textron business unit. Our program for 2022 continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. The survey responses were reviewed for completeness and consistency and our service provider followed up with suppliers who provided incomplete or inconsistent responses. Ultimately, we received complete and validated responses to our supply chain survey from approximately 70% of the in-scope suppliers, an increase of approximately 8% over the previous year.
Although approximately 70% of Textron’s in-scope suppliers responded to the RCOI, there are many suppliers that have not yet provided any smelter or refiner information or have provided incomplete smelter or refiner data. For the suppliers that responded and provided smelter or refiner data, our service provider reviewed all supplier responses that claimed in the declaration section of the CMRT to have known DRC-sourced material.
Because the results of our RCOI indicated that some of our products contain 3TGs which may have originated from the Covered Countries, in an effort to locate mines with the greatest possible specificity, we performed due diligence measures on the source and chain of custody of the 3TGs as described below.
Due Diligence
Design of Our Due Diligence Framework
Our due diligence measures have been designed to conform, in all material respects, with the framework in The Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold and for tin, tantalum and tungsten (OECD Guidance).
Due Diligence Process
In conformity with the OECD’s five step process, we conducted the following activities during the 2022 reporting period:
Step 1. Company Management Systems
We have established a management system to support supply chain due diligence related to 3TGs which includes maintaining an internal conflict minerals team coordinated by our Senior Executive Counsel, with representatives from each of our business units. The team follows our documented procedures for our conflict minerals compliance program. These procedures cover the identification of suppliers to be surveyed and escalation procedures, as described above, records retention, updating supplier lists and integrating acquired businesses into the program. The team leader reports to our senior management on the status of our program as appropriate.
In addition, the team has agreed upon a recommended conflict minerals contractual provision which our businesses seek to include in any new or amended contracts with suppliers that may be relevant for our conflict minerals compliance program. This contractual provision requires suppliers to provide us with the necessary 3TG information and to adopt a supply chain policy and procedure to conduct, and require its suppliers to conduct, a reasonable country of origin inquiry and, if necessary, to perform due diligence to identify the facilities used to process the 3TGs and make efforts to identify the location of each mine or location of origin of the 3TGs with the greatest possible specificity.
Textron has adopted a Conflict Minerals Policy Statement which can be found at http://investor.textron.com/investors/corporate-governance/default.aspx.
To improve supplier education and training, we utilized our third-party service provider’s learning management system which provided all in-scope suppliers access to our service provider’s Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
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In addition, we maintain an enterprise-wide grievance mechanism, including an employee helpline, as described in our Business Conduct Guidelines, that enables employees to report suspected or known violations of our Business Conduct Guidelines, law or company policy.
Step 2. Identification and Assessment of Supply Chain Risks
We have worked to identify and assess our supply chain risk through the CMRT survey process. There are a variety of risks identified throughout the survey process, including the risk presented by the lack of sourcing information due to non-responsive suppliers and suppliers providing incomplete or inconsistent responses. The smelter and refiner data collected through the CMRT highlights actual sourcing risk, such as a smelter or refiner sourcing from the Covered Countries and not yet certified as in conformance with third-party standards for responsible minerals procurement, or of even higher risk, a smelter or refiner which has not yet begun the audit process to receive certification.
Step 3. Strategy to Respond to Identified Risks
While many risks exist in the search for the origin of the conflict minerals used in components and materials supplied to Textron, as noted above, one of our identified risks is the inability to obtain complete and accurate information from our suppliers in order to make determinations about our products. There are numerous initiatives working to improve transparency and accountability at the smelter and refinery levels of the supply chain, however, we can only benefit from the information being developed by these initiatives if our suppliers are able to trace back the conflict minerals in their products to a specific smelter or refiner.
In our new or amended contractual agreements with our direct suppliers, we have requested the inclusion of a contractual provision which requires suppliers to provide us with the necessary 3TG information and to adopt a supply chain policy and procedure to conduct, and require its suppliers to conduct, a reasonable country of origin inquiry and, if necessary, to perform due diligence to identify the facilities used to process the 3TGs and make efforts to identify the location of each mine or location of origin of the 3TGs with the greatest possible specificity. This objective also is reflected in our Conflict Minerals Policy Statement, which indicates that we encourage our suppliers to undertake reasonable due diligence with their supply chains in an effort to assure their conflict minerals are being sourced from mines and smelters/refiners which have been certified by an independent third party as “conflict free” if sourced within the Covered Countries. Our Policy Statement further states that “if we determine that any of our products or components contain 3TG from a mine or facility in a Covered Country that is not “conflict free”, we will evaluate our options, including but not limited to reassessment of the supplier relationship.”
If, over time, we obtain more detailed information from our suppliers with regard to the origin of the 3TGs contained in components and materials supplied to us by them, we will evaluate how to respond to identified risks in our supply chain, including, if appropriate, escalating identified risks to management for consideration of further action. During 2022, we did not identify any instances where it was necessary to escalate identified risks to management for further action.
Step 4. Independent Third-Party Audit of Facilities’ Due Diligence Practices
As discussed above, we do not have direct relationships with smelters or refiners, and we do not perform direct audits of these entities’ supply chains. We intend to rely on the development and implementation of independent third-party audits of smelters’ and refiners’ sourcing, such as the Responsible Minerals Assurance Process.
Step 5. Report on Supply Chain Due Diligence
This Report is submitted to the SEC annually and is publicly available at http://investor.textron.com/investors/corporate-governance/default.aspx.
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Due Diligence Results
Many of the responses received from suppliers which indicated that they source 3TGs from a Covered Country provided data at the company or divisional level, rather than at the part or component level. As a result, we have been unable to determine whether the 3TGs reported by these suppliers were contained in components supplied to us (as opposed to other components supplied by our suppliers but not purchased by us). We are therefore unable to directly link, based on the due diligence measures described in this Report, 3TGs contained in Textron products to 3TGs originating from a Covered Country.
Facilities Used to Process the 3TGs
Certain of the supplier responses in the CMRT included the names of facilities listed as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Our service provider compared the facilities listed in the responses in the CMRT to the list of smelters maintained by the Responsible Minerals Initiative (“RMI”) to ensure that the facilities met the RMI definition of a 3TGs processing facility that was operational during the 2022 calendar year. As of May 17, 2022, we have validated in this manner that 343 smelters or refiners provided in our supplier CMRTs are included on these lists.
If a supplier indicated that a facility was certified as “RMAP Conformant”, meaning in conformance with RMI’s Responsible Minerals Assurance Process standards, our service provider confirmed that it was listed as such by RMI. Of the smelters and refiners listed by suppliers via the CMRTs which have been validated as described, 222 have been confirmed as RMAP Conformant and 7 have actively begun the process to be validated as Conformant. The CMRTs in the aggregate claim that 87 of the RMAP Conformant smelters source 3TGs from the Covered Countries, however we cannot confirm this information. Many of the CMRTs did not provide information regarding the country of origin of 3TGs, and such information is generally not available through public information sources related to the smelters and refiners.
Schedule A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains, along with the facility location. However, we understand that those who purchase materials from smelters/refiners may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing information on smelters and refiners often have the practice to list all smelters/refiners they may purchase from within the reporting period. Therefore, the list on Schedule A is likely to be more comprehensive than the list of smelters and refiners which actually processed the 3TGs contained in our products. We have not included in Schedule A any smelters or refiners that we have not been able to validate.
Many suppliers are still unable to provide the smelters or refiners used for components supplied by them to us and, even where facilities were identified, the suppliers did not always provide complete information on the facility, including smelter identification numbers, so that we were unable to immediately validate the smelter as described above and, as previously noted, many of the responses indicated an “unknown” status in terms of determining the origin of 3TGs.
Efforts to Determine Mine or Location of Origin
For the reasons explained above, we rely on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials they supply to us. As noted above, our program has initially focused on gathering smelter and refiner information via the CMRT survey process and, as the program progresses, we intend to work toward obtaining from our suppliers all necessary smelter and refiner identification information. This information will facilitate the validation and disclosure of the smelters and refiners as well as the tracing of the 3TGs to their location of origin. However, to date we only have smelter and facility information and no information with regard to the mine or specific location of origin of the 3TGs in our products or whether they come from recycled or scrap sources, as we understand that generally that information is kept confidential by the refiners and smelters.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products, including seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT and verifying those smelters and refiners with the expanding RMI lists to the extent possible.
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Steps to be Taken to Mitigate Risk
We intend to take and continue the following actions to mitigate the risk that our necessary 3TGs benefit armed groups:
| · | Direct each of our business units to request our recommended contractual provision requiring our suppliers to conduct due diligence on their supply chains and to provide information to us about the source of their 3TGs, as described above. This provision is intended to be included in new and renewed supplier contracts on a going forward basis. |
| · | Establish a screening process for new suppliers to our businesses so that new suppliers will be added to our in-scope supplier list if appropriate as they begin a relationship with the business. |
| · | Direct suppliers to training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
| · | Work toward obtaining from our suppliers additional smelter and refiner identification information. |
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Schedule A
| Metal | Smelter Name | Smelter Facility Location |
| Tantalum | 5D Production OU | Estonia |
| Gold | 8853 S.p.A. | Italy |
| A.L.M.T. Corp. | Japan | |
| Gold | ABC Refinery Pty Ltd. | Australia |
| Gold | Abington Reldan Metals, LLC | United States Of America |
| Tungsten | ACL Metais Eireli | Brazil |
| 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 |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil |
| Gold | Albino Mountinho Lda. | Portugal |
| Gold | Alexy Metals | United States Of America |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Tin | Alpha | United States Of America |
| Tantalum | AMG Brasil | Brazil |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Tungsten | Artek LLC | Russian Federation |
| 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 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam |
| 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 |
| Tin | Aurubis Beerse | Belgium |
| Tin | Aurubis Berango | Spain |
| Gold | Bangalore Refinery | India |
Page 1 of 10
| 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 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China |
| Gold | Chimet S.p.A. | Italy |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China |
| Tin | China Tin Group Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Gold | Chugai Mining | Japan |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil |
| Tin | CRM Synergies | Spain |
| Tungsten | Cronimet Brasil Ltda | Brazil |
| Tin | CV Ayi Jaya | Indonesia |
| Tin | CV Venus Inti Perkasa | Indonesia |
| Tantalum | D Block Metals, LLC | United States Of America |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of |
| Gold | Dongwu Gold Group | China |
| Gold | Dowa | Japan |
| Tin | Dowa | Japan |
| Tin | DS Myanmar | Myanmar |
| 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 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam |
Page 2 of 10
| Tin | EM Vinto | Bolivia (Plurinational State Of) |
| 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 |
| Tin | Estanho de Rondonia S.A. | Brazil |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil |
| Tin | Fenix Metals | Poland |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Gold | Fujairah Gold FZC | United Arab Emirates |
| 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 |
| Gold | Geib Refining Corporation | United States Of America |
| 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 |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | Global Advanced Metals Boyertown | United States Of America |
| Tungsten | Global Tungsten & Powders LLC | United States Of America |
| 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 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
| Gold | Guangdong Jinding Gold Limited | China |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
Page 3 of 10
| Tungsten | H.C. Starck Tungsten GmbH | Germany |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic Of |
| Gold | Heimerle + Meule GmbH | Germany |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Gold | Heraeus Germany GmbH Co. KG | Germany |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of |
| Tungsten | Hydrometallurg, JSC | Russian Federation |
| 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 |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | China |
| Tin | Jiangxi New Nanshan Technology Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
Page 4 of 10
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tungsten | JSC “Kirovgrad Hard Alloys Plant” | Russian Federation |
| 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 |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Kazzinc | Kazakhstan |
| Tantalum | KEMET de Mexico | Mexico |
| Tungsten | Kennametal Fallon | United States Of America |
| Tungsten | Kennametal Huntsville | United States Of America |
| 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 |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Tungsten | LLC Vostok | Russian Federation |
| Gold | L’Orfebre S.A. | Andorra |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of |
| Gold | LT Metal Ltd. | Korea, Republic Of |
| Tin | Luna Smelter, Ltd. | Rwanda |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | Brazil |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Gold | Marsam Metals | Brazil |
Page 5 of 10
| Tungsten | Masan High-Tech Materials | Viet Nam |
| Gold | Materion | United States Of America |
| Tantalum | Materion Newton Inc. | United States Of America |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | MD Overseas | India |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa |
| Tin | Metallic Resources, Inc. | United States Of America |
| Gold | Metallix Refining Inc. | United States Of America |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| 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 |
| Tin | Mineracao Taboca S.A. | Brazil |
| Tantalum | Mineracao Taboca S.A. | Brazil |
| Tin | Minsur | Peru |
| Gold | Mitsubishi Materials Corporation | Japan |
| Tin | Mitsubishi Materials Corporation | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | MKS PAMP SA | Switzerland |
| Gold | MMTC-PAMP India Pvt., Ltd. | India |
| Gold | Modeltech Sdn Bhd | Malaysia |
| Tin | Modeltech Sdn Bhd | Malaysia |
| Tungsten | Moliren Ltd. | Russian Federation |
| 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 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam |
| Gold | NH Recytech Company | Korea, Republic Of |
| Tungsten | Niagara Refining LLC | United States Of America |
| Gold | Nihon Material Co., Ltd. | Japan |
Page 6 of 10
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tin | Novosibirsk Tin Combine | Russian Federation |
| Tantalum | NPM Silmet AS | Estonia |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| 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 |
| Tungsten | OOO “Technolom” 1 | Russian Federation |
| Tungsten | OOO “Technolom” 2 | Russian Federation |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) |
| Gold | Pease & Curren | United States Of America |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Gold | Planta Recuperadora de Metales SpA | Chile |
| Tin | Pongpipat Company Limited | Myanmar |
| Tin | Precious Minerals and Smelting Limited | India |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| 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 |
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| 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 |
| Gold | PX Precinox S.A. | Switzerland |
| Gold | QG Refining, LLC | United States Of America |
| Tantalum | QuantumClean | 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 |
| Tin | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China |
| Gold | Royal Canadian Mint | Canada |
| Tin | Rui Da Hung | Taiwan, Province Of China |
| 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 | 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 |
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| 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 |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| 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 |
| Tin | Super Ligas | Brazil |
| Gold | T.C.A S.p.A | Italy |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Tantalum | TANIOBIS Co., Ltd. | Thailand |
| Tantalum | TANIOBIS GmbH | Germany |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany |
| Tantalum | Telex Metals | United States Of America |
| Tin | Thaisarco | Thailand |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China |
| Tin | Tin Technology & Refining | United States Of America |
| 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 |
Page 9 of 10
| Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Gold | United Precious Metal Refining, Inc. | United States Of America |
| Gold | Valcambi S.A. | Switzerland |
| Tin | VQB Mineral and Trading Group JSC | Viet Nam |
| Gold | WEEEREFINING | France |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Gold | Yamakin Co., Ltd. | Japan |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
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