EX-1.01 2 exhibit101-2022cmr.htm EX-1.01 Document
Exhibit 1.01
Pentair plc
Conflict Minerals Report
For the reporting period from January 1, 2022 to December 31, 2022
This Conflict Minerals Report (the “Report”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (the “Rule”). The Rule was adopted to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Rule imposes reporting obligations on Securities and Exchange Commission (“SEC”) registrants whose manufactured products contain certain minerals that are necessary to the functionality or production of their respective products.

If a registrant determines that any columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten (the “Subject Minerals”), are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured, the registrant must conduct in good faith a Reasonable Country of Origin Inquiry (“RCOI”) regarding those Subject Minerals that is reasonably designed to determine whether any of the Subject Minerals originated in the Democratic Republic of the Congo or an adjoining country (the “Covered County” or “Covered Countries”) or are from recycled or scrap sources.

If, following the completion of the RCOI, a registrant knows that any of the necessary Subject Minerals originated in a Covered Country and are not from recycled or scrap sources, or has reason to believe that any of its necessary Subject Minerals may have originated in the Covered Countries and has reason to believe that its necessary Subject Minerals did not come from recycled or scrap sources, then the registrant must exercise due diligence on the source and chain of custody of the Subject Minerals that conforms to a nationally or internationally recognized due diligence framework and describe such due diligence in this separate Conflict Minerals Report.

In accordance with the Organisation for Economic Co-operation and Development Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, the related supplements on tin, tungsten, tantalum and gold (the “Guidance”) and the Rule, this Conflict Minerals Report is available on the Company’s website at https://www.pentair.com/en-us/legal/partner-supplier-info.html.

Consistent with the provisions of the Rule, the SEC’s Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule, dated April 29, 2014; the SEC’s Order Issuing Stay, dated May 2, 2014; and the SEC’s Updated Statement on the Effect of the Court of Appeals Decision on the Conflict Minerals Rule, dated April 7, 2017, this Conflict Minerals Report has not been audited by a third party.

As previously disclosed, Pentair has exited its business activity and sales in Russia. This Report covers the period from January 1, 2022 to December 31, 2022 and Pentair’s review of the conflict minerals surveys received from its suppliers and related conflict minerals reports for that



time period found information indicating that some of the smelters in its supply chain identified Russia as a possible sourcing location. The information regarding these Russian-origin metals came from third-party suppliers, which in turn obtained the information through their own suppliers in these highly-attenuated, multi-tiered global supply chains. Pentair remains committed to compliance with U.S. and other applicable trade law and sanctions programs, including those targeting Russian parties.

1.Company Overview
At Pentair, we believe the health of our world depends on reliable access to clean water. We deliver a comprehensive range of smart, sustainable water solutions to homes, businesses and industries around the world. Our industry-leading and proven portfolio of solutions enables our customers to access clean, safe water; reduce water consumption; and recover and reuse water. Whether it’s improving, moving or helping people enjoy water, we help manage the world’s most precious resource. Pentair is comprised of three reporting segments: Industrial & Flow Technologies, Water Solutions and Pool.

Industrial & Flow Technologies
The focus of this segment is to deliver water where it is needed, when it is needed and more efficiently and transforming waste into value. This segment designs, manufactures and sells a variety of fluid treatment and pump products and systems, including pressure vessels, gas recovery solutions, membrane bioreactors, wastewater reuse systems and advanced membrane filtration, separation systems, water disposal pumps, water supply pumps, fluid transfer pumps, turbine pumps, solid handling pumps, and agricultural spray nozzles, while serving the global residential, commercial and industrial markets. These products and systems are used in a range of applications, fluid delivery, ion exchange, desalination, food and beverage, separation technologies for the oil and gas industry, residential and municipal wells, water treatment, wastewater solids handling, pressure boosting, circulation and transfer, fire suppression, flood control, agricultural irrigation and crop spray.

Water Solutions
The focus of this segment is to provide great tasting, higher-quality water and ice while helping end-users use water more productively. This segment designs, manufactures and sells commercial and residential water treatment products and systems including pressure tanks, control valves, activated carbon products, commercial ice machines, conventional filtration products, and point-of-entry and point-of-use water treatment systems. These water treatment products and systems are used in residential whole home water filtration, drinking water filtration and water softening solutions in addition to commercial total water management and filtration in foodservice operations. In addition, our water solutions business also provides installation and preventative services for water management solutions for commercial operators.

Pool
The focus of this segment is to provide innovative, energy efficient pool solutions to help end-users more sustainably enjoy water. This segment designs, manufactures and sells a complete line of energy-efficient residential and commercial pool equipment and accessories including
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pumps, filters, heaters, lights, automatic controls, automatic cleaners, maintenance equipment and pool accessories. Applications for our pool products include residential and commercial pool maintenance, pool repair, renovation, service and construction and aquaculture solutions.

The Company conducted an analysis of all of its products and its entire supply chain, and, accordingly, the Company did not limit its review to those products that may have contained Subject Minerals. This Conflict Minerals Report relates to all products (which are collectively referred to as the “Covered Products”): (i) that were manufactured, or contracted to be manufactured, by the Company; and (ii) for which the manufacture was completed during calendar year 2022. Based on its initial analysis, the Company estimates that approximately 24% of its surveyed suppliers make use of one or more of the Subject Minerals with respect to the Covered Products.

The Company has adopted a Conflict Minerals Policy that emphasizes the Company’s commitment to complying with the Rule and to identifying the source of the Subject Minerals contained in the Company’s products. The Company also indicates in its Global Supplier Guide (the “Supplier Guide”) that it expects all suppliers doing business with the Company to cooperate with the conflict minerals due diligence process. The Company also has participated in groups and forums focused on responsible sourcing of Subject Minerals, including the Responsible Minerals Initiative (the “RMI”) and industry association groups such as the Twin Cities Conflict Minerals Task Force.

Unless the context otherwise indicates, references herein to “Pentair,” the “Company,” and such words as “we,” “us,” and “our” include Pentair plc and its consolidated subsidiaries.

2.    Conflict Minerals Compliance Process
2.1    Compliance Framework Overview
The Company designed its due diligence measures to conform in all material respects to the Guidance.
2.2    Reasonable Country of Origin Inquiry
The Company designed its RCOI to provide a reasonable basis for it to determine whether the Company sources Subject Minerals from Covered Countries and whether any of the Subject Minerals may be from recycled or scrap sources.

The Company began by analyzing its supplier base and designating certain suppliers as outside the scope of the RCOI process if they met one or more of the following criteria:

The supplier provides the Company with packaging only (excluding labels).
The supplier provides the Company with items that are not included in our finished products, such as the equipment used to manufacture our products.
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The supplier is a test lab or other service provider.
After removing these out-of-scope suppliers, the Company then conducted a survey of its remaining suppliers using the template maintained by the RMI, known as the Conflict Minerals Reporting Template version 6.22 (the “CMRT Form”). The CMRT Form was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. The CMRT Form includes questions regarding a direct supplier’s conflict minerals policy, engagement with its direct suppliers, origin of Subject Minerals included in its products, supplier due diligence and a listing of the smelters that the direct supplier and its suppliers use. Written instructions and recorded training illustrating the use of the tool are available on the RMI’s website. Many companies are using the CMRT Form in their RCOI and due diligence processes related to Subject Minerals.

The Company’s inquiry process included multiple rounds of communication and follow-up, including mail, email and telephone calls, with over 3,680 direct suppliers spanning eight enterprise resource planning systems. The Company received, reviewed and processed responses from 59.7% of the suppliers surveyed, which represented approximately 95% of total calendar year 2022 supplier expenditures.

The Company reviewed the responses against risk-based criteria developed to determine which responses required further engagement with the relevant suppliers. These criteria included inconsistencies within the data reported in the CMRT Form and other risk-based criteria. The Company worked directly with these suppliers to obtain a revised response and/or additional clarity regarding their submission.

As part of this year’s program, the Company also conducted automated data validation on all submitted supplier responses. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers provided by suppliers. Following the data validation process, the Company classified submitted forms as either valid or invalid and contacted suppliers regarding forms classified as invalid to encourage such suppliers to resubmit a valid form. As of May 5, 2023, the Company still had 40 (1.1%) invalid supplier submissions that were not yet corrected. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

Among the supplier responses received by the Company that were classified as valid, the Company received the following information:

Approximately 74.8% of supplier responses indicated that such supplier did not use Subject Minerals in the materials and components that it supplied to the Company during 2022.
Approximately 8.5% of supplier responses indicated that, to the best of such supplier’s knowledge, the Subject Minerals in the components and materials that it supplied to the Company during 2022 did not originate from a Covered Country.
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Approximately 3.4% of supplier responses indicated that, to the best of such supplier’s knowledge, the Subject Minerals in the components and materials that it supplied to the Company during 2022 may have originated in a Covered Country from sources verified as conflict-free by third parties such as the RMI and others.
Approximately 13.3% of the Company’s suppliers indicated that the Subject Minerals in some of the components and materials supplied to the Company may have originated from a Covered Country, but those suppliers could not determine whether such Subject Minerals were conflict-free.
After reviewing the results of the RCOI, the Company could not conclusively determine that it had no reason to believe that Subject Minerals necessary for the functionality or production of its products may have originated from a Covered Country during 2022. The Company conducted its RCOI in good faith, and the Company believes that such inquiry was reasonable to allow it to make the determination. Accordingly, the Company proceeded to exercise due diligence on the source and chain of custody of the Subject Minerals.

2.3    The Company’s Due Diligence Process
We designed our due diligence measures to conform, in all material respects, with the framework in the Guidance. The Guidance describes the five aspects of a robust due diligence program and provides guidelines for implementing each aspect. We developed our due diligence process to address each of these five aspects, namely:

1.Establishing strong company management systems regarding conflict minerals;

2.Identifying and assessing risks in our supply chain;

3.Designing and implementing a strategy to respond to identified risks in our supply chain;

4.Utilizing independent third-party audits of supply chain diligence; and

5.Publicly reporting on our supply chain due diligence.

We are a downstream supplier, many steps removed from the mines and companies that produce the Subject Minerals. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, Pentair does not purchase raw ore or unrefined conflict minerals or make purchases directly from the Covered Countries. The origin of Subject Minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other Subject Mineral-containing derivatives. The smelters and refiners consolidate raw ore and therefore have the most direct knowledge of the origin of the Subject Minerals they procure.

The Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of
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due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1,” or direct, suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.

2.3.1    Establish Strong Company Management Systems
Internal Team
The Company developed cross-functional teams to set its conflict minerals strategy and ensure timely implementation and execution of the due diligence program. The Company’s Supply Chain Group has primary responsibility for program execution. Guidance on the overall strategy and implementation is provided by the Legal Department, Accounting Department and Internal Audit Department. Senior management is briefed about the results of the due diligence program on a regular basis.

The Company has developed internal training processes to educate anyone within the Company that is a potential contact point for suppliers or other external parties regarding the Company’s conflict minerals compliance efforts. In addition, the Company has either independently, or in cooperation with a third-party service provider, developed tailored training programs to train the Company’s employees with respect to the potential impact of conflict minerals.

The Company leverages a team of dedicated program specialists through our third-party service provider who support the Company’s conflict minerals program and associated teams.

Ethics HelpLine

The Company has long-standing grievance mechanisms, including an Ethics HelpLine, whereby the Company’s employees can report violations of the Company’s Code of Business Conduct and Ethics, policy or law, including its procedures related to conflict minerals and the conflict minerals reporting process.

Control Systems and Supplier Engagement

Due to its position in the supply chain, the Company does not have a direct relationship with Subject Minerals smelters and refiners. The Company engages with its suppliers and relies on information provided through the CMRT Form, to gather information on the source and chain of custody of the Subject Minerals in its products.

In 2014, the Company updated its Supplier Guide to address, among other things, the Subject Minerals and the requirement of its suppliers to provide information on their use of these minerals. The Company also continues to update its supplier contracts by including a requirement that the supplier comply with the Supplier Guide whenever a new contract is entered
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into or an outstanding contract is renewed. In 2016, Pentair’s Terms and Conditions were updated to include compliance with laws including a broad reference to all business integrity- related laws and regulations.

Beginning in 2016 and continuing through this year, we have put a stronger emphasis on supplier education and training. To accomplish this, we utilized a third-party learning management system from Assent Compliance Inc. (“Assent”), known as Assent University, to provide all in- scope suppliers access to its Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.

In addition, the Company’s Conflict Minerals Policy is available on its website, and provides assistance to suppliers in their efforts to comply with the Company’s Conflict Minerals Policy, including video training, recorded training and written instructions as well as supplemental assistance through email and telephone contact as necessary. If the Company discovers that a direct supplier is not in compliance with the Company’s Conflict Minerals Policy, the Company may take certain actions to mitigate any potential risk, as described in Section 2.3.3, below.

Records Retention

The Company will retain documentation related to its conflict minerals compliance program according to the Company’s Document Retention Policy.

2.3.2    Identify and Assess Risk in the Supply Chain

The Company’s supply chain with respect to the Covered Products is complex. During 2022, the Company had over 3,680 direct suppliers with respect to the Covered Products, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of the Subject Minerals. In this regard, the Company does not purchase Subject Minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of Subject Minerals that are included in the Covered Products.

Based on this information, and in an effort to conform its due diligence measures to the Guidance, the Company assesses the risk in its supply chain in several ways. For example, the Company considers the potential risk presented by the smelters or refiners in its supply chain, as reported by the Company’s direct suppliers. Smelters or refiners that source the Subject Minerals from a Covered Country and are not certified as conflict-free by third-party audit programs such as the RMI’s Responsible Minerals Assurance Process (“RMAP”) pose a significant risk.

The Company assesses the risk in its supply chain by reviewing its direct suppliers’ responses to the CMRT Form, including whether such suppliers have established due diligence programs with respect to the Subject Minerals. The Company uses its direct suppliers’ responses to the CMRT Form to determine the extent to which it may be necessary for the Company to allocate
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additional due diligence resources. Through Assent, the Company has also provided video and written training on compliance with the Rule, supply chain due diligence and the CMRT Form.

This includes instructions on completing the CMRT Form, and one-on-one email and phone discussions with supplier personnel. In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners in the supply chain.

After the Company receives CMRT Forms completed by its direct suppliers, the Company, with the assistance of Assent, assesses each facility that meets the RMI definition of a smelter or refiner of a Subject Mineral and that is reported as being in the Company’s supply chain by the Company’s direct suppliers according to “red flag” indicators defined in the Guidance. Assent uses five factors to determine the level of risk that each smelter poses to the supply chain and reviews each for potential red flags:

The smelter or refiner’s geographic proximity to the Democratic Republic of the Congo and the other Covered Countries;
Known mineral sources in the country of origin;
The smelter or refiner’s audit status with respect to the RMAP;
Credible evidence of unethical or conflict-related sourcing practices associated with the smelter or refiner; and
Peer assessments of the smelter or refiner conducted by credible third-party sources.
Based on these factors, the Company has determined that the following smelter or refiner facilities, which were reported as being in the Company’s supply chain by the Company’s direct suppliers, have red flag risks (“Red-Flagged Facilities”):

JSC Novosibirsk RefineryCID000493
JSC Ekaterinburg Non-Ferrous Metal Processing PlantCID000927
JSC UralelectromedCID000929
Moscow Special Alloys Processing PlantCID001204
Novosibirsk Tin CombineCID001305
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)CID001326
Prioksky Plant of Non-Ferrous MetalsCID001386
SOE Shyolkovsky Factory of Secondary Precious MetalsCID001756
Solikamsk Magnesium Works OAOCID001769
Fidelity Printers and Refiners Ltd.CID002515
Kaloti Precious MetalsCID002563
Sudan Gold RefineryCID002567
Industrial Refining CompanyCID002587
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Hydrometallurg, JSCCID002649
Unecha Refractory metals plantCID002724
Moliren Ltd.CID002845
Kyshtym Copper-Electrolytic Plant ZAOCID002865
African Gold RefineryCID003185
JSC "Kirovgrad Hard Alloys Plant"CID003408
NPP Tyazhmetprom LLCCID003416
Artek LLCCID003553
OOO “Technolom” 2CID003612
OOO “Technolom” 1CID003614
LLC VostokCID003643
Whenever a Red-Flagged Facility is reported as being in the Company’s supply chain, the Company implements risk mitigation activities that are described in specific detail in Section 2.3.3, below. Generally, in designing and implementing the Company’s strategy to respond to the supply chain risks that it has identified, the Company analyzed various third-party approaches and consulted with other companies in our industry. The Company has concluded that tracing the Subject Minerals back to their mine of origin directly is an exceedingly complex task, given the breadth and depth of the Company’s supply chain. Instead, the Company has determined that seeking information about smelters and refiners in the Company’s supply chain represents the most reasonable effort the Company can make to determine the mines or origin of the Subject Minerals in its supply chain. To this end, the Company has adopted methods outlined by the RMI’s joint industry programs and outreach initiatives, and the Company has required its suppliers to conform with the same standards and to report on their efforts using the CMRT Form. Through these methods, the Company has made a reasonable determination of the origin of the Subject Minerals in its supply chain.

Additionally, the Company evaluates its suppliers on the strength of their own compliance programs (which further assist the Company in identifying risk in its supply chain). Evaluating and tracking the strength of the Company’s suppliers’ compliance programs is recommended by the Guidance and can help the Company to make key risk mitigation decisions. The criteria the Company uses to evaluate the strength of a supplier’s program is based on the following four questions in the CMRT Form:

Have you established a conflict minerals sourcing policy?
Have you implemented due diligence measures for conflict-free sourcing?
Do you review due diligence information received from your suppliers against your company’s expectations?
Does your review process include corrective action management?
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When a supplier meets or exceeds those criteria (by answering “yes” to all four questions), the Company considers that supplier to have a strong compliance program. At this time, 218 of our 2,200 responsive suppliers, or 10%, have been identified as having a weak program.

2.3.3    Design and Implement a Strategy to Respond to Risks
In conjunction with the Company’s risk assessment process, the Company has developed a risk management plan for responding to risks identified in its supply chain, including Red-Flagged Facilities. Through the Company’s due diligence process, the Company attempts to determine the source and chain of custody of the necessary Subject Minerals the Company knows, or has reason to believe, originated in a Covered Country. Since the Company does not have a direct relationship with smelters and/or refiners, most of the work toward this aspect of the Guidance is carried out indirectly through the Company’s suppliers or through the Company’s involvement with industry working groups/coalitions. Due to its position in the supply chain, the Company largely focuses on the accuracy and quality of the representations the Company’s direct suppliers make regarding the source and chain of custody of their Subject Minerals. The Company evaluates its direct suppliers’ responses to RCOI and due diligence inquiries based on the risk or likelihood that they are giving an incorrect response or that a non-response may indicate the supplier is purchasing from a known conflict source and does not wish to disclose this fact.

With respect to the Red-Flagged Facilities, upon receiving a CMRT Form from a direct supplier that identifies a Red-Flagged Facility as being present in the Company’s supply chain, the Company immediately initiates risk mitigation activities. Through a third-party vendor, the Company directs any supplier reporting a Red-Flagged Facility to implement its own risk mitigation actions. These actions include submitting a product-specific CMRT Form to the Company, to better identify the connection between the Red-Flagged Facility and the materials or components the Company purchases from the supplier, and requesting that the supplier begin the process to remove any Red-Flagged Facility from the supplier’s supply chain.

As per the Guidance, specific risk mitigation procedures depend on the suppliers’ specific situation. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.

As part of the Company’s risk management plan, and to ensure its suppliers understood the Company’s expectations, the Company has provided video training, recorded training and documented instructions to its direct suppliers through Assent. The Company also provided additional direct assistance to suppliers that required further clarification on the Company’s expectations. The Company then provided each supplier with a copy of the CMRT Form to complete as part of the Company’s due diligence process. Furthermore, as described above, the Company reviewed responses with specific suppliers where the responses suggested inaccuracies, inconsistencies or otherwise warranted further inquiry.

Finally, in accordance with the Company’s Conflict Minerals Policy, the Company engages any of its suppliers that it has reason to believe may be supplying the Company with Subject Minerals from sources that may support conflict in any of the Covered Countries to request that
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such suppliers establish an alternate source of Subject Minerals that does not support armed conflict in the Covered Countries.

The Company’s global supplier development team responds to suppliers that may potentially expose the Company to unacceptable risks, due to unacceptable responses to the Company’s inquiries or a refusal to respond. If the global supplier development team determines that a supplier is non-responsive, or is not satisfied with a supplier’s risk mitigation efforts, the global supplier development team may ultimately recommend that the Company take steps to find replacement suppliers as soon as is practicable.

2.3.4    Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
The Company does not have a direct relationship with Subject Minerals smelters and refiners and does not perform or direct audits of these entities within the Company’s supply chain. The Company supports audits by engaging its partners who are closer to the source and, as a member of the RMI, by promoting the smelter and refiner verification procedures and protocols of the RMAP.

Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facility’s sourcing practices on behalf of its compliance partners. The Company is a signatory of this communication in accordance with the requirements of downstream companies detailed in the Guidance.
2.3.5    Report on Supply Chain Due Diligence
This Conflict Minerals Report is being filed with the SEC as an exhibit to the Company’s specialized disclosure report on Form SD and is available on our website at https://www.pentair.com/en-us/legal/partner-supplier-info.html.

Due Diligence Results

Attached as Annex I to this Conflict Minerals Report is a list of all of the smelters and refiners listed by our suppliers in their completed CMRT Forms that appear on the list of smelters maintained by the RMI. Because most of the CMRT Forms we received were made on a company- or division-level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed on Annex I actually processed the Subject Minerals contained in our products. Therefore, our list of processing smelters and refiners in Annex I may contain more facilities than those that actually processed the Subject Minerals in our products. The Company does not have sufficient information, with respect to the Covered Products, to conclusively determine the country of origin of the Subject Minerals in the Covered Products or to conclusively determine whether the Subject Minerals in the Covered Products are from recycled or scrap sources. However, based on the information provided by the Company’s suppliers, smelters and refiners, as well as from the RMI and other sources, the Company believes the countries of origin of the Subject Minerals contained in the Covered Products include the
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countries listed in Annex II to this Conflict Minerals Report, as well as recycled and scrap sources.

Suppliers that identified any specific smelters or refiners of concern on their CMRT Form were contacted in accordance with the Guidance, as discussed in Section 2.3.3 above.

StatusNumber of identified smelters/refiners
RMAP Conformant345
RMAP Active8
Not Enrolled89
Non-Conformant24

3.    Conflict Minerals Compliance Process
The Company has taken and intends to take, the following steps to improve the due diligence conducted to further mitigate any risk that the necessary Subject Minerals in the Company’s products could originate from Covered Countries:

Continue our work with our suppliers to help them understand our expectations regarding the Subject Minerals in our supply chain and our suppliers’ due diligence of their own supply chains, including their ability to confirm the conflict-free status of identified smelters and refiners.

Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to:
Using a comprehensive smelter and refiner library with detailed status and notes for each entity.
Scanning for verifiable media sources on each smelter and refiner to flag risk issues.
Comparing the list of smelters against government watch and denied parties lists.

Continue to emphasize to suppliers our expectation that they move toward sourcing exclusively from conflict-free smelters and refiners verified by the RMAP.

For suppliers unable to immediately source from conflict-free smelters and refiners verified by the RMAP, requested that those suppliers develop, share and implement a mitigation plan to source exclusively from conflict-free smelters and refiners.

Continue our engagement with industry groups, including the RMI, that support the adoption and improvement of relevant programs, tools and standards.
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Enable a real-time CMRT Form validation tool to identify problems with a supplier CMRT Form and communicate this clearly to suppliers to enable them to fix their submission before providing to the Company.

Following the Guidance process, increase the emphasis on clean and validated smelter information from the supply chain through feedback and detailed smelter analysis.

The Company plans to continue to refine the implementation of its 2022 initiatives to further improve the quality of its due diligence.

4.    Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements intended to qualify for the safe harbor from liability established by the Private Securities Litigation Reform Act of 1995. All statements, other than statements of historical fact, included in this Conflict Minerals Report, including, without limitation, statements regarding our conflict mineral compliance plans, are forward-looking statements. These forward-looking statements generally are identified by the words “targets,” “plans,” “believes,” “expects,” “intends,” “will,” “likely,” “may,” “anticipates,” “estimates,” “projects,” “should,” “would,” “positioned,” “strategy,” “future” or phrases or terms of similar substance or the negative thereof or similar terminology generally intended to identify forward-looking statements. These forward-looking statements are not guarantees of future performance and are subject to risks, uncertainties, assumptions and other factors, some of which are beyond our control. Numerous important factors described in this Conflict Minerals Report, including, among others, our ability to implement new software systems, our suppliers’ willingness and ability to comply with our conflict minerals-related compliance requests, the degree to which we are able to determine our suppliers’ use of conflict-free smelters and refiners, the impact of industry-wide initiatives such as the RMAP, smelters’ and refiners’ willingness and ability to comply with the RMAP, our effectiveness in managing the conflict minerals RCOI and due diligence processes, and the costs of our compliance, could affect these statements and could cause actual results to differ materially from our expectations. All forward-looking statements speak only as of the date of this Conflict Minerals Report. We assume no obligation, and disclaim any duty, to update or revise publicly any forward-looking statements, whether as a result of new information, future events or otherwise.



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Annex I
List of Smelters and Refiners
Metal
Smelter Name
Smelter Facility Location
Smelter ID
RMAP Audit Status
TungstenA.L.M.T. Corp.JapanCID000004Conformant
GoldAdvanced Chemical CompanyUnited States Of AmericaCID000015Conformant
GoldAida Chemical Industries Co., Ltd.JapanCID000019Conformant
GoldAgosi AGGermanyCID000035Conformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UzbekistanCID000041Conformant
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazilCID000058Conformant
GoldArgor-Heraeus S.A.SwitzerlandCID000077Conformant
GoldAsahi Pretec Corp.JapanCID000082Conformant
GoldAsaka Riken Co., Ltd.JapanCID000090Conformant
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TurkeyCID000103Outreach Required
TungstenKennametal HuntsvilleUnited States Of AmericaCID000105Conformant
GoldAurubis AGGermanyCID000113Conformant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PhilippinesCID000128Conformant
GoldBoliden ABSwedenCID000157Conformant
GoldC. Hafner GmbH + Co. KGGermanyCID000176Conformant
GoldCaridadMexicoCID000180Outreach Required
GoldCCR Refinery - Glencore Canada CorporationCanadaCID000185Conformant
GoldCendres + Metaux S.A.SwitzerlandCID000189Non Conformant
GoldYunnan Copper Industry Co., Ltd.ChinaCID000197Outreach Required
TantalumChangsha South Tantalum Niobium Co., Ltd.ChinaCID000211Conformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.ChinaCID000218Conformant
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaCID000228Conformant
GoldChimet S.p.A.ItalyCID000233Conformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaCID000258Conformant
GoldChugai MiningJapanCID000264Conformant
TungstenCNMC (Guangxi) PGMA Co., Ltd.ChinaCID000281Outreach Required
TinAlphaUnited States Of AmericaCID000292Conformant
TinPT Aries Kencana SejahteraIndonesiaCID000309Conformant
GoldDaye Non-Ferrous Metals Mining Ltd.ChinaCID000343In Communication
GoldDSC (Do Sung Corporation)Korea, Republic OfCID000359Conformant
GoldDowaJapanCID000401Conformant
TinDowaJapanCID000402Conformant
GoldEco-System Recycling Co., Ltd. East PlantJapanCID000425Conformant
TinEM VintoBolivia (Plurinational State Of)CID000438Conformant
TinEstanho de Rondonia S.A.BrazilCID000448Conformant
TantalumF&X Electro-Materials Ltd.ChinaCID000460Conformant
14


TinFenix MetalsPolandCID000468Conformant
GoldJSC Novosibirsk RefineryRussian FederationCID000493RMI Due Diligence Review - Unable to Proceed
GoldRefinery of Seemine Gold Co., Ltd.ChinaCID000522Outreach Required
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaCID000538Conformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaCID000555Non Conformant
TungstenGlobal Tungsten & Powders LLCUnited States Of AmericaCID000568Conformant
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDChinaCID000616Conformant
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.ChinaCID000651Outreach Required
GoldHangzhou Fuchunjiang Smelting Co., Ltd.ChinaCID000671Outreach Required
GoldLT Metal Ltd.Korea, Republic OfCID000689Conformant
GoldHeimerle + Meule GmbHGermanyCID000694Conformant
GoldHeraeus Metals Hong Kong Ltd.ChinaCID000707Conformant
GoldHeraeus Germany GmbH Co. KGGermanyCID000711Conformant
TungstenHunan Chenzhou Mining Co., Ltd.ChinaCID000766Conformant
GoldHunan Chenzhou Mining Co., Ltd.ChinaCID000767Outreach Required
TungstenHunan Jintai New Material Co., Ltd.ChinaCID000769Conformant
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.ChinaCID000773Outreach Required
GoldHwaSeong CJ CO., LTD.Korea, Republic OfCID000778Communication Suspended - Not Interested
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.ChinaCID000801Conformant
GoldIshifuku Metal Industry Co., Ltd.JapanCID000807Conformant
GoldIstanbul Gold RefineryTurkeyCID000814Conformant
GoldJapan MintJapanCID000823Conformant
TungstenJapan New Metals Co., Ltd.JapanCID000825Conformant
GoldJiangxi Copper Co., Ltd.ChinaCID000855Conformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.ChinaCID000875Conformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaCID000914Conformant
TantalumJiujiang Tanbre Co., Ltd.ChinaCID000917Conformant
GoldAsahi Refining USA Inc.United States Of AmericaCID000920Conformant
GoldAsahi Refining Canada Ltd.CanadaCID000924Conformant
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRussian FederationCID000927RMI Due Diligence Review - Unable to Proceed
GoldJSC UralelectromedRussian FederationCID000929RMI Due Diligence Review - Unable to Proceed
GoldJX Nippon Mining & Metals Co., Ltd.JapanCID000937Conformant
TinGejiu Kai Meng Industry and Trade LLCChinaCID000942Non Conformant
GoldKazakhmys Smelting LLCKazakhstanCID000956In Communication
15


GoldKazzincKazakhstanCID000957Conformant
TungstenKennametal FallonUnited States Of AmericaCID000966Conformant
GoldKennecott Utah Copper LLCUnited States Of AmericaCID000969Conformant
GoldKojima Chemicals Co., Ltd.JapanCID000981Conformant
GoldKyrgyzaltyn JSCKyrgyzstanCID001029Non Conformant
GoldL'azurde Company For JewelrySaudi ArabiaCID001032RMI Due Diligence Review - Unable to Proceed
GoldLingbao Gold Co., Ltd.ChinaCID001056Outreach Required
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.ChinaCID001058Outreach Required
TinChina Tin Group Co., Ltd.ChinaCID001070Conformant
TantalumAMG BrasilBrazilCID001076Conformant
GoldLS-NIKKO Copper Inc.Korea, Republic OfCID001078Conformant
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.ChinaCID001093Outreach Required
TinMalaysia Smelting Corporation (MSC)MalaysiaCID001105Conformant
GoldMaterionUnited States Of AmericaCID001113Conformant
GoldMatsuda Sangyo Co., Ltd.JapanCID001119Conformant
TinMetallic Resources, Inc.United States Of AmericaCID001142Conformant
GoldMetalor Technologies (Suzhou) Ltd.ChinaCID001147Conformant
GoldMetalor Technologies (Hong Kong) Ltd.ChinaCID001149Conformant
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeCID001152Conformant
GoldMetalor Technologies S.A.SwitzerlandCID001153Conformant
GoldMetalor USA Refining CorporationUnited States Of AmericaCID001157Conformant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MexicoCID001161Conformant
TantalumMetallurgical Products India Pvt., Ltd.IndiaCID001163Conformant
TinMineracao Taboca S.A.BrazilCID001173Conformant
TantalumMineracao Taboca S.A.BrazilCID001175Conformant
TinMinsurPeruCID001182Conformant
GoldMitsubishi Materials CorporationJapanCID001188Conformant
TinMitsubishi Materials CorporationJapanCID001191Conformant
TantalumMitsui Mining and Smelting Co., Ltd.JapanCID001192Conformant
GoldMitsui Mining and Smelting Co., Ltd.JapanCID001193Conformant
TantalumNPM Silmet ASEstoniaCID001200Conformant
GoldMoscow Special Alloys Processing PlantRussian FederationCID001204RMI Due Diligence Review - Unable to Proceed
GoldNadir Metal Rafineri San. Ve Tic. A.S.TurkeyCID001220Conformant
TinJiangxi New Nanshan Technology Ltd.ChinaCID001231Conformant
GoldNavoi Mining and Metallurgical CombinatUzbekistanCID001236Conformant
GoldNihon Material Co., Ltd.JapanCID001259Conformant
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaCID001277Conformant
TinNovosibirsk Tin CombineRussian FederationCID001305RMI Due Diligence Review - Unable to Proceed
16


TinO.M. Manufacturing (Thailand) Co., Ltd.ThailandCID001314Conformant
GoldOhura Precious Metal Industry Co., Ltd.JapanCID001325Conformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)Russian FederationCID001326RMI Due Diligence Review - Unable to Proceed
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)CID001337Conformant
GoldMKS PAMP SASwitzerlandCID001352Conformant
GoldPenglai Penggang Gold Industry Co., Ltd.ChinaCID001362Outreach Required
GoldPrioksky Plant of Non-Ferrous MetalsRussian FederationCID001386RMI Due Diligence Review - Unable to Proceed
GoldPT Aneka Tambang (Persero) TbkIndonesiaCID001397Conformant
TinPT Artha Cipta LanggengIndonesiaCID001399Conformant
TinPT Babel Surya Alam LestariIndonesiaCID001406Conformant
TinPT Mitra Stania PrimaIndonesiaCID001453Conformant
TinPT Prima Timah UtamaIndonesiaCID001458Conformant
TinPT Refined Bangka TinIndonesiaCID001460Conformant
TinPT Stanindo Inti PerkasaIndonesiaCID001468Conformant
TinPT Timah Tbk KundurIndonesiaCID001477Conformant
TinPT Timah Tbk MentokIndonesiaCID001482Conformant
TinPT Timah NusantaraIndonesiaCID001486Active
TinPT Tinindo Inter NusaIndonesiaCID001490Non Conformant
GoldPX Precinox S.A.SwitzerlandCID001498Conformant
TantalumQuantumCleanUnited States Of AmericaCID001508Conformant
GoldRand Refinery (Pty) Ltd.South AfricaCID001512Conformant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaCID001522Conformant
GoldRoyal Canadian MintCanadaCID001534Conformant
TinRui Da HungTaiwan, Province Of ChinaCID001539Conformant
GoldSabin Metal Corp.United States Of AmericaCID001546Communication Suspended - Not Interested
GoldSamduck Precious MetalsKorea, Republic OfCID001555Non Conformant
GoldSamwon Metals Corp.Korea, Republic OfCID001562Communication Suspended - Not Interested
GoldSEMPSA Joyeria Plateria S.A.SpainCID001585Conformant
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.ChinaCID001619Outreach Required
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaCID001622Conformant
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaCID001736Conformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian FederationCID001756RMI Due Diligence Review - Unable to Proceed
GoldSolar Applied Materials Technology Corp.Taiwan, Province Of ChinaCID001761Conformant
TantalumSolikamsk Magnesium Works OAORussian FederationCID001769RMI Due Diligence Review - Unable to Proceed
17


GoldSumitomo Metal Mining Co., Ltd.JapanCID001798Conformant
TantalumTaki Chemical Co., Ltd.JapanCID001869Conformant
GoldTanaka Kikinzoku Kogyo K.K.JapanCID001875Conformant
TantalumTelex MetalsUnited States Of AmericaCID001891Conformant
TinThaisarcoThailandCID001898Conformant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.ChinaCID001908Non Conformant
GoldGreat Wall Precious Metals Co., Ltd. of CBPMChinaCID001909Outreach Required
GoldShandong Gold Smelting Co., Ltd.ChinaCID001916Conformant
GoldTokuriki Honten Co., Ltd.JapanCID001938Conformant
GoldTongling Nonferrous Metals Group Co., Ltd.ChinaCID001947Outreach Required
GoldTorecomKorea, Republic OfCID001955Conformant
TantalumUlba Metallurgical Plant JSCKazakhstanCID001969Conformant
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgiumCID001980Conformant
GoldUnited Precious Metal Refining, Inc.United States Of AmericaCID001993Conformant
GoldValcambi S.A.SwitzerlandCID002003Conformant
TinVQB Mineral and Trading Group JSCViet NamCID002015Outreach Required
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaCID002030Conformant
TinWhite Solder Metalurgia e Mineracao Ltda.BrazilCID002036Conformant
TungstenWolfram Bergbau und Hutten AGAustriaCID002044Conformant
TungstenXiamen Tungsten Co., Ltd.ChinaCID002082Conformant
GoldYamakin Co., Ltd.JapanCID002100Conformant
GoldYokohama Metal Co., Ltd.JapanCID002129Conformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaCID002158Conformant
TinTin Smelting Branch of Yunnan Tin Co., Ltd.ChinaCID002180Conformant
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaCID002224Conformant
GoldGold Refinery of Zijin Mining Group Co., Ltd.ChinaCID002243Conformant
GoldMorris and WatsonNew ZealandCID002282In Communication
GoldSAFINA A.S.CzechiaCID002290Conformant
GoldGuangdong Jinding Gold LimitedChinaCID002312Outreach Required
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.ChinaCID002313Communication Suspended - Not Interested
GoldUmicore Precious Metals ThailandThailandCID002314Non Conformant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.ChinaCID002315Conformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaCID002316Conformant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.ChinaCID002317Conformant
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.ChinaCID002318Conformant
18


TungstenMalipo Haiyu Tungsten Co., Ltd.ChinaCID002319Conformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaCID002320Conformant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.ChinaCID002321Conformant
TinCV Venus Inti PerkasaIndonesiaCID002455Conformant
GoldGeib Refining CorporationUnited States Of AmericaCID002459Conformant
TinMagnu's Minerais Metais e Ligas Ltda.BrazilCID002468Conformant
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaCID002492Conformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaCID002494Conformant
TinMelt Metais e Ligas S.A.BrazilCID002500Non Conformant
TungstenAsia Tungsten Products Vietnam Ltd.Viet NamCID002502Conformant
TinPT ATD Makmur Mandiri JayaIndonesiaCID002503Conformant
TantalumD Block Metals, LLCUnited States Of AmericaCID002504Conformant
TantalumFIR Metals & Resource Ltd.ChinaCID002505Conformant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaCID002506Conformant
TantalumXinXing HaoRong Electronic Material Co., Ltd.ChinaCID002508Conformant
GoldMMTC-PAMP India Pvt., Ltd.IndiaCID002509Conformant
GoldKGHM Polska Miedz Spolka AkcyjnaPolandCID002511Conformant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.ChinaCID002512Conformant
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchChinaCID002513Conformant
GoldFidelity Printers and Refiners Ltd.ZimbabweCID002515RMI Due Diligence Review - Unable to Proceed
GoldSingway Technology Co., Ltd.Taiwan, Province Of ChinaCID002516Non Conformant
TinO.M. Manufacturing Philippines, Inc.PhilippinesCID002517Conformant
GoldShandong Humon Smelting Co., Ltd.ChinaCID002525Outreach Required
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.ChinaCID002527Outreach Required
TantalumKEMET de MexicoMexicoCID002539Conformant
TungstenH.C. Starck Tungsten GmbHGermanyCID002541Conformant
TungstenTANIOBIS Smelting GmbH & Co. KGGermanyCID002542Conformant
TungstenMasan High-Tech MaterialsViet NamCID002543Conformant
TantalumTANIOBIS Co., Ltd.ThailandCID002544Conformant
TantalumTANIOBIS GmbHGermanyCID002545Conformant
TantalumMaterion Newton Inc.United States Of AmericaCID002548Conformant
TantalumTANIOBIS Japan Co., Ltd.JapanCID002549Conformant
TantalumTANIOBIS Smelting GmbH & Co. KGGermanyCID002550Conformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.ChinaCID002551Conformant
TantalumGlobal Advanced Metals BoyertownUnited States Of AmericaCID002557Conformant
TantalumGlobal Advanced Metals AizuJapanCID002558Conformant
GoldAl Etihad Gold Refinery DMCCUnited Arab EmiratesCID002560Conformant
GoldEmirates Gold DMCCUnited Arab EmiratesCID002561Conformant
19


GoldInternational Precious Metal RefinersUnited Arab EmiratesCID002562In Communication
GoldKaloti Precious MetalsUnited Arab EmiratesCID002563RMI Due Diligence Review - Unable to Proceed
GoldSudan Gold RefinerySudanCID002567Outreach Required
TinCV Ayi JayaIndonesiaCID002570Conformant
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyViet NamCID002572Non Conformant
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyViet NamCID002573Outreach Required
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyViet NamCID002574Outreach Required
GoldT.C.A S.p.AItalyCID002580Conformant
GoldREMONDIS PMR B.V.NetherlandsCID002582Conformant
GoldFujairah Gold FZCUnited Arab EmiratesCID002584Outreach Required
GoldIndustrial Refining CompanyBelgiumCID002587Non Conformant
GoldShirpur Gold Refinery Ltd.IndiaCID002588Outreach Required
TungstenNiagara Refining LLCUnited States Of AmericaCID002589Conformant
TinPT Rajehan AriqIndonesiaCID002593Conformant
GoldKorea Zinc Co., Ltd.Korea, Republic OfCID002605Conformant
GoldMarsam MetalsBrazilCID002606Non Conformant
GoldTOO Tau-Ken-AltynKazakhstanCID002615Conformant
TungstenChina Molybdenum Tungsten Co., Ltd.ChinaCID002641Conformant
TungstenGanzhou Haichuang Tungsten Co., Ltd.ChinaCID002645Conformant
TungstenHydrometallurg, JSCRussian FederationCID002649RMI Due Diligence Review - Unable to Proceed
TinAn Vinh Joint Stock Mineral Processing CompanyViet NamCID002703Outreach Required
TinResind Industria e Comercio Ltda.BrazilCID002706Conformant
TantalumResind Industria e Comercio Ltda.BrazilCID002707Conformant
GoldAbington Reldan Metals, LLCUnited States Of AmericaCID002708Conformant
TungstenUnecha Refractory metals plantRussian FederationCID002724Non Conformant
TinSuper LigasBrazilCID002756Active
GoldSAAMPFranceCID002761Conformant
GoldL'Orfebre S.A.AndorraCID002762Conformant
Gold8853 S.p.A.ItalyCID002763Non Conformant
GoldItalpreziosiItalyCID002765Conformant
TinAurubis BeerseBelgiumCID002773Conformant
TinAurubis BerangoSpainCID002774Conformant
GoldWIELAND Edelmetalle GmbHGermanyCID002778Conformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustriaCID002779Conformant
TungstenPhilippine Chuangxin Industrial Co., Inc.PhilippinesCID002827Conformant
TungstenACL Metais EireliBrazilCID002833Non Conformant
TinPT Menara Cipta MuliaIndonesiaCID002835Conformant
20


TantalumJiangxi Tuohong New Raw MaterialChinaCID002842Conformant
TungstenMoliren Ltd.Russian FederationCID002845RMI Due Diligence Review - Unable to Proceed
GoldAU Traders and RefinersSouth AfricaCID002850Non Conformant
GoldGGC Gujrat Gold Centre Pvt. Ltd.IndiaCID002852Active
GoldSai RefineryIndiaCID002853Outreach Required
GoldModeltech Sdn BhdMalaysiaCID002857Non Conformant
TinModeltech Sdn BhdMalaysiaCID002858Non Conformant
GoldBangalore RefineryIndiaCID002863Conformant
GoldKyshtym Copper-Electrolytic Plant ZAORussian FederationCID002865RMI Due Diligence Review - Unable to Proceed
GoldDegussa Sonne / Mond Goldhandel GmbHGermanyCID002867Outreach Required
GoldPease & CurrenUnited States Of AmericaCID002872Communication Suspended - Not Interested
GoldJALAN & CompanyIndiaCID002893Outreach Required
GoldSungEel HiMetal Co., Ltd.Korea, Republic OfCID002918Conformant
GoldPlanta Recuperadora de Metales SpAChileCID002919Conformant
GoldSafimet S.p.AItalyCID002973Non Conformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaCID003116Conformant
GoldState Research Institute Center for Physical Sciences and TechnologyLithuaniaCID003153Outreach Required
GoldAfrican Gold RefineryUgandaCID003185RMI Due Diligence Review - Unable to Proceed
GoldGold Coast RefineryGhanaCID003186Outreach Required
GoldNH Recytech CompanyKorea, Republic OfCID003189Conformant
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaCID003190Conformant
TinPT Bangka SerumpunIndonesiaCID003205Conformant
TinPongpipat Company LimitedMyanmarCID003208Outreach Required
GoldQG Refining, LLCUnited States Of AmericaCID003324Outreach Required
TinTin Technology & RefiningUnited States Of AmericaCID003325Conformant
GoldDijllah Gold Refinery FZCUnited Arab EmiratesCID003348Outreach Required
TinDongguan CiEXPO Environmental Engineering Co., Ltd.ChinaCID003356Non Conformant
TinPT Rajawali Rimba PerkasaIndonesiaCID003381Conformant
GoldCGR Metalloys Pvt Ltd.IndiaCID003382Outreach Required
GoldSovereign MetalsIndiaCID003383Outreach Required
TinLuna Smelter, Ltd.RwandaCID003387Conformant
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.ChinaCID003397Non Conformant
TungstenFujian Ganmin RareMetal Co., Ltd.ChinaCID003401Conformant
TungstenLianyou Metals Co., Ltd.Taiwan, Province Of ChinaCID003407Conformant
21


TungstenJSC "Kirovgrad Hard Alloys Plant"Russian FederationCID003408RMI Due Diligence Review - Unable to Proceed
TinPrecious Minerals and Smelting LimitedIndiaCID003409Non Conformant
TinGejiu City Fuxiang Industry and Trade Co., Ltd.ChinaCID003410Outreach Required
TungstenNPP Tyazhmetprom LLCRussian FederationCID003416RMI Due Diligence Review - Unable to Proceed
TungstenHubei Green Tungsten Co., Ltd.ChinaCID003417Conformant
GoldC.I Metales Procesados Industriales SASColombiaCID003421Active
GoldEco-System Recycling Co., Ltd. North PlantJapanCID003424Conformant
GoldEco-System Recycling Co., Ltd. West PlantJapanCID003425Conformant
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BrazilCID003427Non Conformant
TinPT Mitra Sukses GlobalindoIndonesiaCID003449Conformant
GoldAugmont Enterprises Private LimitedIndiaCID003461Active
GoldKundan Care Products Ltd.IndiaCID003463In Communication
TungstenCronimet Brasil LtdaBrazilCID003468Conformant
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBrazilCID003486Conformant
GoldEmerald Jewel Industry India Limited (Unit 1)IndiaCID003487In Communication
GoldEmerald Jewel Industry India Limited (Unit 2)IndiaCID003488In Communication
GoldEmerald Jewel Industry India Limited (Unit 3)IndiaCID003489In Communication
GoldEmerald Jewel Industry India Limited (Unit 4)IndiaCID003490In Communication
GoldK.A. RasmussenNorwayCID003497Outreach Required
GoldAlexy MetalsUnited States Of AmericaCID003500Active
TinCRM SynergiesSpainCID003524Conformant
GoldSancus ZFS (L’Orfebre, SA)ColombiaCID003529Conformant
GoldSellem Industries Ltd.MauritaniaCID003540Communication Suspended - Not Interested
GoldMD OverseasIndiaCID003548In Communication
TungstenArtek LLCRussian FederationCID003553RMI Due Diligence Review - Unable to Proceed
GoldMetallix Refining Inc.United States Of AmericaCID003557In Communication
GoldMetal Concentrators SA (Pty) Ltd.South AfricaCID003575Conformant
TinFabrica Auricchio Industria e Comercio Ltda.BrazilCID003582Conformant
TantalumRFH Yancheng Jinye New Material Technology Co., Ltd.ChinaCID003583Conformant
TinPT Sariwiguna BinasentosaIndonesiaCID001463Conformant
TinPT Premium Tin IndonesiaIndonesiaCID000313Conformant
TinPT Babel Inti PerkasaIndonesiaCID001402Conformant
22


TinPT Belitung Industri SejahteraIndonesiaCID001421Active
TinPT Bukit TimahIndonesiaCID001428Conformant
TinPT Tirus Putra MandiriIndonesiaCID002478In Communication
TinPT Cipta Persada MuliaIndonesiaCID002696Conformant
TinPT Sukses Inti MakmurIndonesiaCID002816Conformant
TungstenOOO “Technolom” 2Russian FederationCID003612RMI Due Diligence Review - Unable to Proceed
TungstenOOO “Technolom” 1Russian FederationCID003614RMI Due Diligence Review - Unable to Proceed
TinPT Bangka Tin IndustryIndonesiaCID001419In Communication
TinPT Panca Mega PersadaIndonesiaCID001457In Communication
GoldSuper Dragon Technology Co., Ltd.Taiwan, Province Of ChinaCID001810Outreach Required
TungstenFujian Xinlu Tungsten Co., Ltd.ChinaCID003609Conformant
GoldWEEEREFININGFranceCID003615Active
TinPT Tommy UtamaIndonesiaCID001493Conformant
TinPT Bangka Prima TinIndonesiaCID002776Conformant
TinPT Putera Sarana Shakti (PT PSS)IndonesiaCID003868Conformant
GoldGold by Gold ColombiaColombiaCID003641Conformant
GoldABC Refinery Pty Ltd.AustraliaCID002920Outreach Required
TungstenLLC VostokRussian FederationCID003643RMI Due Diligence Review - Unable to Proceed
GoldShenzhen CuiLu Gold Co., Ltd.ChinaCID002750Outreach Required
GoldAlbino Mountinho Lda.PortugalCID002760Outreach Required
TungstenYUDU ANSHENG TUNGSTEN CO., LTD.ChinaCID003662Outreach Required
GoldDongwu Gold GroupChinaCID003663Outreach Required
TinDS MyanmarMyanmarCID003831Conformant
Tantalum5D Production OUEstoniaCID003926Outreach Required
TungstenHANNAE FOR T Co., Ltd.Korea, Republic OfCID003978Outreach Required
TungstenDONGKUK INDUSTRIES CO., LTD.Korea, Republic OfCID004060In Communication
TungstenTungsten Vietnam Joint Stock CompanyViet NamCID003993Conformant












23


Annex II

List of Countries of Origin for Subject Minerals
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company-level responses and therefore, it is not certain which of these countries of origin can be linked to our products.
Country List
Afghanistan
Ãland Islands
Albania
American Samoa
Andorra
Angola
Argentina
Armenia
Aruba
Australia
Austria
Azerbaijan
Bahamas
Barbados
Belarus
Belgium
Benin
Bermuda
Bolivia (Plurinational State of)
Brazil
Bulgaria
Burkina Faso
Burundi
Cambodia
Canada
Central African Republic
Chile
China
Colombia
Congo
Czechia
24


Democratic Republic of Congo
Djibouti
Dominica
Dominican Republic
Ecuador
Egypt
Eritrea
Estonia
Ethiopia
Finland
France
Georgia
Germany
Ghana
Guam
Guatemala
Guinea
Guyana
Honduras
Hong Kong
Hungary
India
Indonesia
Ireland
Israel
Italy
Japan
Jersey
Kazakhstan
Kenya
Korea
Kyrgyzstan
Liberia
Liechtenstein
Lithuania
Luxembourg
Madagascar
Malaysia
Mali
25


Mauritania
Mexico
Mongolia
Morocco
Mozambique
Myanmar
Namibia
Netherlands
New Zealand
Nicaragua
Niger
Nigeria
Norway
Panama
Papua New Guinea
Peru
Philippines
Poland
Portugal
Russian Federation
Rwanda
Samoa
Saudi Arabia
Senegal
Sierra Leone
Singapore
Slovakia
Slovenia
South Africa
South Sudan
Spain
Sudan
Suriname
Sweden
Switzerland
Taiwan
Tajikistan
Tanzania
Thailand
26


Turkey
Uganda
United Arab Emirates
United Kingdom
United States
Uzbekistan
Viet Nam
Zambia
Zimbabwe


27