EX-1.01 2 a2020exhibit101.htm EX-1.01 Document

Exhibit 1.01
 
Regal Beloit Corporation
Conflict Minerals Report
For the Year Ended December 31, 2020
 
This Conflict Minerals Report (the “Report”) of Regal Beloit Corporation (the “Company,” “we,” “Regal,” “us,” “our”) has been prepared pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Rule”), for the reporting period January 1, 2020 to December 31, 2020.
 
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the conflict minerals specified in the Rule are intentionally added and necessary to the functionality or production of those products. Conflict Minerals are defined in section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The specified minerals, which we collectively refer to in this Report as the “3TGs,” are gold, tantalum, tin and tungsten, respectively. The “Covered Countries” for the purposes of this Report are the DRC and the adjoining countries. As described in this Report, during the reporting period between January 1, 2020 and December 31, 2020, certain of the Company’s operations manufactured, or contracted to manufacture, products for which the 3TGs are intentionally added and necessary to the functionality or production.
 
Cautionary Statement
 
Certain statements made in this Conflict Minerals Report on Form SD are forward-looking statements, including statements relating to our compliance efforts and expected actions identified under the “Process Improvement Considerations” section of this Report, intended to qualify for the safe harbor from liability established by the Private Securities Litigation Reform Act of 1995. This report contains forward-looking statements, within the meaning of Section 21E of the Securities Exchange Act of 1934, as amended, which reflect the Company’s current estimates, expectations and projections about the Company’s future results, performance, prospects and opportunities. Such forward-looking statements may include, among other things, statements about the Company’s future operations, anticipated business levels, future earnings, planned activities, anticipated growth, market opportunities, strategies, competition and other expectations and estimates for future periods. Forward-looking statements include statements that are not historical facts and can be identified by forward-looking words such as “anticipate,” “believe,” “could,” “estimate,” “expect,” “intend,” “plan,” “may,” “should,” “will,” “would,” “project,” “forecast,” and similar expressions. These forward-looking statements are based upon information currently available to the Company and are subject to a number of risks, uncertainties, and other factors that could cause the performance, prospects, or opportunities to differ materially from those expressed in, or implied by, these forward-looking statements. Shareholders, potential investors, and other readers are cautioned not to place undue reliance on such forward-looking statements. The forward-looking statements included in this Report are made only as of the date of this Report, and the Company undertakes no obligation to update any forward-looking information contained in this Report or with respect to the announcements described herein to reflect subsequent events or circumstances. Additional information regarding the risks, uncertainties, and other factors that could cause the performance, prospects, or opportunities to differ materially from those expressed in, or implied by, the forward-looking statements contained in this Report is included in "Part I - Item 1A - Risk Factors" in our Annual Report on Form 10-K filed with the SEC on March 2, 2021 and from time to time in other filed reports.
 
Summary
 
Through our Reasonable Country of Origin Inquiry (“RCOI”) and due diligence efforts, we identified 25 smelters and/or refiners (“SORs”) as either sourcing Conflict Minerals from the Covered Countries or giving us reason to believe they are sourcing Conflict Minerals from the Covered Countries. Each of those 25 smelters is recognized as conformant with the Responsible Minerals Assurance Process (“RMAP”). The following sections describe in detail our RCOI, our due diligence framework, and the results of our due diligence efforts.

Company Overview
 
Regal is a leading manufacturer of electric motors, electrical motion controls, power generation and power transmission products serving markets throughout the world. Our four operating segments are: Commercial Systems, Industrial Systems, Climate Solutions, and Power Transmission Solutions.

 
1


Description of the Company’s Products Covered by this Report
 
This Report relates to products: (i) for which the 3TGs are intentionally added and necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2020.

These products, which are referred to in this Report collectively as the “Covered Products,” are the following:

1.Electric motors and controls (may contain tin and tin and gold respectively)
2.Electric generators and controls (may contain tin and tin and gold respectively)
3.Gear reducers (may contain tin)
4.Electronic switchgears (may contain tin and gold)
5.Actuators (may contain tin, gold, tantalum and tungsten)
6.Servo systems (may contain tin, gold, tantalum and tungsten)
7.Conveyor systems (may contain tin, gold, tantalum and tungsten)
8.Power transmission products including couplings, bearings, gearboxes, transfer cases, transmissions, worm gears and other gears (may contain tin)
9.Loadbanks (may contain tin, gold, tantalum and tungsten)
10.Other electrical/electronic components (may contain tin, gold, tantalum and tungsten)

Reasonable Country of Origin Inquiry
 
Our supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between us as the manufacturer of the Covered Products and the original sources of 3TGs. In this regard, we do not typically purchase Conflict Minerals directly from mines, smelters or refiners. We must therefore rely on our suppliers to provide information regarding the origin of 3TGs that are included in the Covered Products. Moreover, we believe that the smelters and refiners of the 3TGs are best situated to identify the sources of 3TGs, and therefore have taken steps to identify the applicable smelters and refiners of 3TGs in our supply chain.

To determine whether 3TGs necessary to our products originated in the Covered Countries, we retained a third-party service provider to assist us in reviewing and surveying our supply chain. We believe that we conducted a good faith RCOI to provide a reasonable basis for us to determine whether we source 3TGs from the Covered Countries. This good faith RCOI was designed to determine whether any of the 3TGs originated in the Covered Countries and whether any of the 3TGs may be from recycled or scrap sources. We are utilizing the supplier engagement approach outlined by the Responsible Minerals Initiative (“RMI”), including the utilization of their Conflict Minerals Reporting Template version 6.01 and higher (“CMRT”).

As the first step in our RCOI, we determined which of our products would most likely contain the 3TGs. After review, it was decided that substantially all of the products that we manufacture are Covered Products. Using our supply chain data systems, we refined our list of suppliers by filtering out service providers, indirect materials suppliers, and inactive suppliers. We further refined this list to filter out suppliers who, based on our knowledge of our parts, supply us with parts that do not contain any 3TGs. Based on these steps, we identified 1145 direct suppliers as in-scope for our 2020 RCOI. When key contact information for in-scope suppliers was not available in our systems, we initiated a process to gather that information.

Once supplier contact information was obtained, that information as well as the applicable part information was uploaded into our third-party service provider’s web-based compliance tool. We then conducted the supplier survey portion of the RCOI. Our in-scope suppliers were contacted via our third-party provider’s Software as a Service (“SaaS”) platform that enables its users to complete and track supplier communications, and request that suppliers complete and upload a CMRT directly to the platform for assessment and management for the products they provide to us. Included in the supplier requests was a link to our Conflict Minerals Policy (“Policy”) to reinforce our commitment to sourcing responsibly and to make clear the responsibility of each of our suppliers to support us to fulfill this commitment.

As indicated in our Policy, we require suppliers to provide their Conflict Minerals information using the CMRT. To provide suppliers flexibility, we allowed them to provide their responses to the CMRT by submitting their completed CMRT via e-mail or by uploading the CMRT directly to our service provider’s software portal.

During our review and analysis of the submitted CMRTs, it was clear that many suppliers erroneously assumed that the country of operation of the smelter as listed in the CMRT was the country of origin of the Conflict Minerals. This led to incorrect and inconsistent responses to many of the questions in the submitted CMRTs.

2


Supplier communications were tracked and all non-responsive suppliers were contacted a minimum of four times. Our third-party service provider also included automated data validation on all submitted CMRTs. The goal of this step is to increase the accuracy and validity of submission and identify contradictory answers. Any invalid responses were flagged and those suppliers were contacted and encouraged to resubmit a valid form. As of May 6, 2021, 70.65% of our in scope suppliers submitted a valid CMRT. All final CMRT submissions were then reviewed to identify smelters or refiners in our supply chain, which list of smelters and refiners was then cross-referenced with the RMI data in order to conduct the RCOI. The overall supplier response rate to our RCOI was approximately 71.17%.

Conflict Minerals Policy
 
We developed our Policy and initially published it on our website in April 2013. Our Policy is reviewed annually and updated as needed to reflect our commitment to sourcing responsibly and to make clear the responsibility of each of our suppliers to support us to fulfill this commitment. Our Policy can be viewed at http://investors.regalbeloit.com/investors/corporate-governance/integrity-and-compliance/default.aspx. Further, Regal supports conflict-free minerals trade in the DRC and Covered Countries and will not avoid sourcing from conflict-free organizations in the region.
 
Design of Due Diligence
 
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 Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”). We utilize all five steps of the OECD Guidance for downstream companies.

Establish Strong Company Management Systems

Control Systems

Regal is committed to sourcing conflict-free minerals from the DRC and Covered Countries, and as such, we have communicated our Policy to our suppliers and customers. Our Policy was provided to suppliers during our RCOI process. Our Policy is provided to customers requesting Conflict Minerals information. This Policy is publicly available on our website as discussed above.

In addition to our efforts directly related to Conflict Minerals, Regal maintains a strong company commitment to conducting business in an ethical manner as detailed in our Code of Business Conduct & Ethics as well as our Global Anti-Corruption Policy, both of which are also available on our website (http://investors.regalbeloit.com/investors/corporate-governance/integrity-and-compliance/default.aspx).

Internal Team

Consistent with the OECD Guidance, we formed an internal team tasked with supporting supply chain due diligence. This team consists of vice presidents from the following functional groups: Legal, Supply Chain, Technology, and Environmental, Health, Safety and Sustainability (EHSS). Additional members of the committee included the Director of Supplier Quality and Development and our materials compliance manager.

Supplier Engagement

We utilized the RMI’s RMAP as a compliance standard for upstream due diligence. We have implemented an RCOI process. As a part of our Standard Terms and Conditions of Purchase, companies selling products to Regal are required to implement a policy regarding conflict minerals, to exercise due diligence in investigating the source of these minerals, and to respond in a timely manner to Regal’s requests for evidence of their compliance with these requirements. Conflict minerals compliance is also included as a requirement in our Supplier Quality Manual. Conflict minerals compliance process and documentation review are requirements of our Supplier Audit Assessment and Production Part Approval Process.

Grievance Mechanisms

We have an Integrity Alert line through which suppliers, customers, company employees or any interested stakeholder can communicate their thoughts, concerns and grievances regarding Conflict Minerals or, more generally, any of our business practices. Information about our Integrity Alert Line can be accessed at http://investors.regalbeloit.com/investors/corporate-governance/integrity-and-compliance/default.aspx.





3


Maintain Records

All responses from suppliers and source smelters are recorded and stored for a minimum of five years.

Identify and Assess Risk in the Supply Chain
 
For upstream due diligence, we have adopted the processes and protocols of the RMAP. Risks are identified automatically in our third-party provider’s system based on criteria established for supplier responses in the system. The primary risk that we identified with respect to reporting year 2020 was with respect to the nature of the responses we received. A large number of the responses we received provided data at a company or divisional level rather than at a specific product level.

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 third-party provider compared the facilities listed in the responses to the list of smelters and refiners maintained by the RMI and, if a supplier indicated that the facility was certified as “Conflict-Free,” confirmed that the name was listed by the RMI. As of May 6, 2021, we have identified 333 legitimate smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primarily company-level CMRTs, we cannot definitively determine their connection to our products.

We believe that all 3TGs “necessary to the functionality of the products” have been identified, the suppliers of those 3TGs have been identified, and smelter data has been collected from those that responded to our RCOI. Responses provided by suppliers have undergone a review for accuracy.

Design and Implement a Strategy to Respond to Identified Risks
 
We have implemented a plan to report Conflict Minerals findings to Robert J. Rehard (the “CFO”), Vice President, Chief Financial Officer, who is the member of senior management appointed for this role. A process has been adopted to aggregate and update the list of smelters. Furthermore, a process has been adopted to review supplier responses, follow up with delinquent suppliers, and update supplier information. A risk management process has been adopted that manages smelters that cannot provide country of origin information, identifies red-flag smelters, tracks and records compliance information for individual smelters, and communicates these results back to the CFO. We require new suppliers to complete a CMRT as part of becoming an approved supplier to Regal.

Carry out an Independent Third Party Audit of Refiner’s Due Diligence Practices
 
We have utilized the risk management and due diligence processes of the RMAP and the RMAP’s independent third party audit process performed on smelters that source from the Covered Countries. This includes other programs accepted by the RMAP, including the certification processes of the London Bullion Market Association (LBMA), The Responsible Jewellery Council (RJC), and the Tungsten Industry - Conflict Minerals Council (TI-CMC). To be identified as conflict free, we require smelters to be compliant with the requirements of the RMAP if they are sourcing from the Covered Countries.
 
Report on Supply Chain Due Diligence

In accordance with the OECD Guidance and the Conflict Minerals Rule, this Conflict Minerals Report is also available on our website ( http://investors.regalbeloit.com/investors/financial-information/sec-filings/default.aspx). Through our participation with the RMI, we encouraged smelters or refiners to participate in the RMI Responsible Minerals Assurance Process. Any smelters or refiners that were reported by our suppliers who were not part of the RMAP were also contacted directly to encourage them to participate in the RMAP.
 
 
Due Diligence Results
 
For all responses that indicated a smelter, our third-party provider compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as "Conflict-Free," our vendor confirmed that the name was listed by the RMI as a validated conflict-free smelter. As of May 6, 2021, we have identified 333 smelters or refiners that were reported by our suppliers via the CMRT. Annex I lists, to the best of our knowledge, the majority of the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Annex I any smelters or refiners that we have not been able to validate. Annex II includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI.

4


Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 237 smelters that are deemed RMAP Conformant – this indicates these smelters or refiners are conformant with the RMAP assessment protocols. There are 23 more smelters or refiners that are deemed RMAP Active - smelters and refiners on the Active list have committed to undergo a RMAP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewellry Program Chain-of-Custody Certification. There are an additional eight smelters or refiners that are deemed non-conformant. The remaining 65 smelters listed have not yet been confirmed as Conflict-Free. We have assessed these facilities and determined that most of these are of low risk due to their geographic location.

All of the 25 smelters either identified as sourcing conflict minerals from Covered Countries or those which Regal has reason to believe source conflict minerals from the Covered Countries were compliant with the RMAP assessment.

Risk Mitigation Process

The following is an outline of the process we have developed and are currently working relative to the suppliers who have indicated that red flag smelters are in their supply chains - and, thus, Regal’s.
 
Since the suppliers provided company or divisional level information during our RCOI rather than part specific information, we will conduct a review of engineering drawings and material specifications and conduct chemical analysis as appropriate to identify which if any of the parts supplied by the suppliers contain gold. If described information is inconclusive, engage with the supplier to confirm the presence of gold in accordance with the requirements of the SEC rules, in the parts being supplied to Regal.
For parts where gold is confirmed intentionally added and necessary to functionality, request smelter information specific to the gold or tin used in those parts.
If the smelters so identified are linked to the gold used in the parts, ensure that suppliers are actively trying to remove these smelters from their supply chains and will communicate with Regal the results of their activities.
For suppliers failing to actively remove or failing to communicate their progress to remove these smelters from their supply chains, Regal will initiate further escalation steps with the supplier up to removing these suppliers from our supply chain.

Facility and Mine Information
 
Based on the information provided by our suppliers and our own due diligence efforts, we believe that, to the best of our knowledge, the majority of the smelters that may have been used to process the Conflict Minerals in our products include the smelters listed in Annex 1 below. Information regarding the mines from which minerals processed at these smelters were sourced is not always publicly available and was not disclosed by these smelters. Accordingly, we are not able to identify with certainty all of the countries of origin of the conflict minerals processed at the indicated smelters.

5


Additional Risk Factors
 
The statements above are based on the RCOI process and due diligence performed in good faith by Regal.  A number of factors could introduce errors or otherwise affect our conclusion.  These factors include, but are not limited to the following:
 
1.Gaps in supplier data
2.Gaps in knowledge of the chemistry of the component parts and materials provided by suppliers
3.Gaps in smelter data and the source of their conflict minerals
4.Errors or omissions in survey responses provided by suppliers
5.Errors or omissions by smelters
6.Gaps in supplier education and knowledge
7.Supplier uncertainty regarding country of operation of the smelter and/or refiner versus country of origin of the conflict minerals
8.Not all instances of conflict minerals necessary to the functionality or production of our Covered Products were identified
9.Timeliness of data
10.Public information not discovered during a reasonable search
11.Errors in public data
12.Language barriers and translation
13.Supplier and smelter unfamiliarity with the protocol relating to the Rule
14.Oversights or errors in conflict free smelter audits
15.DRC-sourced materials being declared secondary materials
16.Companies going out of business in 2020
17.Certification programs not being equally advanced for all industry segments and metals
18.Smuggling of DRC conflict minerals to countries beyond the Covered Countries

Process Improvement Considerations

We intend to take the following steps to improve our processes surrounding conflict minerals to further mitigate any risk that the necessary conflict minerals in our Covered Products could benefit armed groups in the Covered Countries:

1.Engage with suppliers and direct them to training resources to attempt to increase the response rate and to improve the quality of the content of suppliers’ conflict minerals information, especially smelter information.
2.Identify those suppliers who do not have a conflict minerals program and work with the suppliers to set up a program.
3.Engage with suppliers to encourage them to implement responsible sourcing and to have them encourage smelters and refiners to obtain a “conflict-free” designation from an independent third-party auditor.
4.For suppliers found to be using smelters sourcing from, or for which we have reason to believe are sourcing from, the Covered Countries and who are not conformant with the requirements of the RMAP, we encourage them to use RMAP compliant smelters.
5.
Expand our knowledge of the chemistry of the component parts and materials contained in our Covered Products by conducting chemical analysis and/or requesting specific chemical information from our suppliers on each component part or material used in the Covered Products to further identify those suppliers providing conflict minerals and their derivatives. To date we have conducted analysis of over 20,000 materials used in over 8,500 component parts.







6


Annex I

List of Smelters and Refiners Identified in Regal Beloit Corporation’s Supply Chain

Subject MineralStandard Smelter NameCountry
Gold8853 S.p.A.ITALY
GoldAbington Reldan Metals, LLCUNITED STATES
GoldAdvanced Chemical CompanyUNITED STATES
GoldAfrican Gold RefineryUGANDA
GoldAida Chemical Industries Co., Ltd.JAPAN
GoldAl Etihad Gold LLCUNITED ARAB EMIRATES
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANY
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTAN
GoldAngloGold Ashanti Córrego do Sítio MineraçãoBRAZIL
GoldArgor-Heraeus S.A.SWITZERLAND
GoldAsahi Pretec Corp.JAPAN
GoldAsahi Refining Canada Ltd.CANADA
GoldAsahi Refining USA Inc.UNITED STATES
GoldAsaka Riken Co., Ltd.JAPAN
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEY
GoldAU Traders and RefinersSOUTH AFRICA
GoldAurubis AGGERMANY
GoldBangalore RefineryINDIA
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINES
GoldBoliden ABSWEDEN
GoldC. Hafner GmbH + Co. KGGERMANY
GoldCaridadMEXICO
GoldCCR Refinery - Glencore Canada CorporationCANADA
GoldCendres + Métaux S.A.SWITZERLAND
GoldChimet S.p.A.ITALY
GoldChugai MiningJAPAN
GoldDaejin Indus Co., Ltd.KOREA, REPUBLIC OF
GoldDaye Non-Ferrous Metals Mining Ltd.CHINA
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANY
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATES
GoldDODUCO Contacts and Refining GmbHGERMANY
GoldDowaJAPAN
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OF
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OF
GoldEco-System Recycling Co., Ltd.JAPAN
GoldEmirates Gold DMCCUNITED ARAB EMIRATES
GoldFidelity Printers and Refiners Ltd.ZIMBABWE
GoldFujairah Gold FZEUNITED ARAB EMIRATES
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIA
GoldGeib Refining CorporationUNITED STATES



GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINA
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINA
GoldGuangdong Jinding Gold LimitedCHINA
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINA
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINA
GoldHeeSungKOREA, REPUBLIC OF
GoldHeimerle + Meule GmbHGERMANY
GoldHeraeus Metals Hong Kong Ltd.CHINA
GoldHeraeus Precious Metals GmbH & Co. KGGERMANY
GoldHunan Chenzhou Mining Co., Ltd.CHINA
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINA
GoldHwasung CJ Co., Ltd.KOREA, REPUBLIC OF
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINA
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATES
GoldIshifuku Metal Industry Co., Ltd.JAPAN
GoldIstanbul Gold RefineryTURKEY
GoldItalpreziosiITALY
GoldJapan MintJAPAN
GoldJiangxi Copper Co., Ltd.CHINA
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATION
GoldJSC UralelectromedRUSSIAN FEDERATION
GoldJX Nippon Mining & Metals Co., Ltd.JAPAN
GoldKaloti Precious MetalsUNITED ARAB EMIRATES
GoldKazakhmys Smelting LLCKAZAKHSTAN
GoldKazzincKAZAKHSTAN
GoldKennecott Utah Copper LLCUNITED STATES
GoldKGHM Polska Miedz Spolka AkcyjnaPOLAND
GoldKojima Chemicals Co., Ltd.JAPAN
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OF
GoldKyrgyzaltyn JSCKYRGYZSTAN
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATION
GoldL'azurde Company For JewelrySAUDI ARABIA
GoldLingbao Gold Co., Ltd.CHINA
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINA
GoldL'Orfebre S.A.ANDORRA
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OF
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINA
GoldMarsam MetalsBRAZIL
GoldMaterionUNITED STATES
GoldMatsuda Sangyo Co., Ltd.JAPAN
GoldMetalor Technologies (Hong Kong) Ltd.CHINA
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORE
GoldMetalor Technologies (Suzhou) Ltd.CHINA
GoldMetalor Technologies S.A.SWITZERLAND
GoldMetalor USA Refining CorporationUNITED STATES
GoldMetalúrgica Met-Mex Peñoles S.A. De C.V.MEXICO
GoldMitsubishi Materials CorporationJAPAN



GoldMitsui Mining and Smelting Co., Ltd.JAPAN
GoldMMTC-PAMP India Pvt., Ltd.INDIA
GoldModeltech Sdn BhdMALAYSIA
GoldMorris and WatsonNEW ZEALAND
GoldMorris and Watson Gold CoastAUSTRALIA
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATION
GoldNadir Metal Rafineri San. Ve Tic. A.Ş.TURKEY
GoldNavoi Mining and Metallurgical CombinatUZBEKISTAN
GoldNH Recytech CompanyKOREA, REPUBLIC OF
GoldNihon Material Co., Ltd.JAPAN
GoldÖgussa Österreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIA
GoldOhura Precious Metal Industry Co., Ltd.JAPAN
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATION
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATION
GoldPAMP S.A.SWITZERLAND
GoldPease & CurrenUNITED STATES
GoldPenglai Penggang Gold Industry Co., Ltd.CHINA
GoldPlanta Recuperadora de Metales SpACHILE
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATION
GoldPT Aneka Tambang (Persero) TbkINDONESIA
GoldPX Précinox S.A.SWITZERLAND
GoldQG Refining, LLCUNITED STATES OF AMERICA
GoldRand Refinery (Pty) Ltd.SOUTH AFRICA
GoldRefinery of Seemine Gold Co., Ltd.CHINA
GoldRemondis Argentia B.V.NETHERLANDS
GoldRepublic Metals CorporationUNITED STATES
GoldRoyal Canadian MintCANADA
GoldSAAMPFRANCE
GoldSabin Metal Corp.UNITED STATES
GoldSafimet S.p.AITALY
GoldSAFINA A.S.CZECH REPUBLIC
GoldSai RefineryINDIA
GoldSamduck Precious MetalsKOREA, REPUBLIC OF
GoldSAMWON Metals Corp.KOREA, REPUBLIC OF
GoldSAXONIA Edelmetalle GmbHGERMANY
GoldSEMPSA Joyería Platería S.A.SPAIN
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINA
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINA
GoldShangdong Humon Smelting Co., Ltd.CHINA
GoldSichuan Tianze Precious Metals Co., Ltd.CHINA
GoldSingway Technology Co., Ltd.TAIWAN
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATION
GoldSolar Applied Materials Technology Corp.TAIWAN
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIA
GoldSudan Gold RefinerySUDAN
GoldSumitomo Metal Mining Co., Ltd.JAPAN
GoldSungEel HiTechKOREA, REPUBLIC OF



GoldT.C.A S.p.AITALY
GoldTanaka Kikinzoku Kogyo K.K.JAPAN
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINA
GoldTokuriki Honten Co., Ltd.JAPAN
GoldTongling Nonferrous Metals Group Co., Ltd.CHINA
GoldTony Goetz NVBELGIUM
GoldTOO Tau-Ken-AltynKAZAKHSTAN
GoldTorecomKOREA, REPUBLIC OF
GoldUmicore Brasil Ltda.BRAZIL
GoldUmicore Precious Metals ThailandTHAILAND
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUM
GoldUnited Precious Metal Refining, Inc.UNITED STATES
GoldUniversal Precious Metals Refining ZambiaZAMBIA
GoldValcambi S.A.SWITZERLAND
GoldWestern Australian Mint trading as The Perth MintAUSTRALIA
GoldWIELAND Edelmetalle GmbHGERMANY
GoldYamamoto Precious Metal Co., Ltd.JAPAN
GoldYokohama Metal Co., Ltd.JAPAN
GoldYunnan Copper Industry Co., Ltd.CHINA
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINA
TantalumAsaka Riken Co., Ltd.JAPAN
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINA
TantalumD Block Metals, LLCUNITED STATES
TantalumExotech Inc.UNITED STATES
TantalumF&X Electro-Materials Ltd.CHINA
TantalumFIR Metals & Resource Ltd.CHINA
TantalumGlobal Advanced Metals AizuJAPAN
TantalumGlobal Advanced Metals BoyertownUNITED STATES
TantalumGuangdong Rising Rare Metals-EO Materials Ltd.CHINA
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINA
TantalumH.C. Starck Co., Ltd.THAILAND
TantalumH.C. Starck Hermsdorf GmbHGERMANY
TantalumH.C. Starck Inc.UNITED STATES
TantalumH.C. Starck Ltd.JAPAN
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANY
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANY
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINA
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINA
TantalumJiangxi Tuohong New Raw MaterialCHINA
TantalumJiujiang Janny New Material Co., Ltd.CHINA
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINA
TantalumJiujiang Tanbre Co., Ltd.CHINA
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINA
TantalumKEMET Blue MetalsMEXICO
TantalumKEMET Blue PowderUNITED STATES
TantalumLSM Brasil S.A.BRAZIL
TantalumMetallurgical Products India Pvt., Ltd.INDIA



TantalumMineracao Taboca S.A.BRAZIL
TantalumMitsui Mining and Smelting Co., Ltd.JAPAN
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINA
TantalumNPM Silmet ASESTONIA
TantalumPower Resources Ltd.MACEDONIA
TantalumQuantumCleanUNITED STATES
TantalumResind Industria e Comercio Ltda.BRAZIL
TantalumRFH Tantalum Smeltry Co., Ltd.CHINA
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATION
TantalumTaki ChemicalsJAPAN
TantalumTelex MetalsUNITED STATES
TantalumUlba Metallurgical Plant JSCKAZAKHSTAN
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINA
TinAlphaUNITED STATES
TinAn Vinh Joint Stock Mineral Processing CompanyVIETNAM
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINA
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINA
TinChina Tin Group Co., Ltd.CHINA
TinCV Ayi JayaINDONESIA
TinCV Dua SekawanINDONESIA
TinCV Gita PesonaINDONESIA
TinCV Tiga SekawanINDONESIA
TinCV United SmeltingINDONESIA
TinCV Venus Inti PerkasaINDONESIA
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINA
TinDowaJAPAN
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIETNAM
TinEM VintoBOLIVIA
TinEstanho de Rondônia S.A.BRAZIL
TinFenix MetalsPOLAND
TinGejiu Fengming Metallurgy Chemical PlantCHINA
TinGejiu Kai Meng Industry and Trade LLCCHINA
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINA
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINA
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINA
TinGuangdong Hanhe Non-ferrous Metal Limited CompanyCHINA
TinGuanyang Guida Nonferrous Metal Smelting PlantCHINA
TinHuiChang Hill Tin Industry Co., Ltd.CHINA
TinHuichang Jinshunda Tin Co., Ltd.CHINA
TinJiangxi New Nanshan Technology Ltd.CHINA
TinMagnu's Minerais Metais e Ligas Ltda.BRAZIL
TinMalaysia Smelting Corporation (MSC)MALAYSIA
TinMelt Metais e Ligas S.A.BRAZIL
TinMetallic Resources, Inc.UNITED STATES
TinMetallo Belgium N.V.BELGIUM
TinMetallo Spain S.L.U.SPAIN



TinMineracao Taboca S.A.BRAZIL
TinMinsurPERU
TinMitsubishi Materials CorporationJAPAN
TinModeltech Sdn BhdMALAYSIA
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIETNAM
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILAND
TinO.M. Manufacturing Philippines, Inc.PHILIPPINES
TinOperaciones Metalurgical S.A.BOLIVIA
TinPongpipat Company LimitedMYANMAR
TinPT Aries Kencana SejahteraINDONESIA
TinPT Artha Cipta LanggengINDONESIA
TinPT ATD Makmur Mandiri JayaINDONESIA
TinPT Babel Inti PerkasaINDONESIA
TinPT Babel Surya Alam LestariINDONESIA
TinPT Bangka Prima TinINDONESIA
TinPT Bangka SerumpunINDONESIA
TinPT Bangka Tin IndustryINDONESIA
TinPT Belitung Industri SejahteraINDONESIA
TinPT Bukit TimahINDONESIA
TinPT DS Jaya AbadiINDONESIA
TinPT Inti Stania PrimaINDONESIA
TinPT Karimun MiningINDONESIA
TinPT Kijang Jaya MandiriINDONESIA
TinPT Menara Cipta MuliaINDONESIA
TinPT Mitra Stania PrimaINDONESIA
TinPT Panca Mega PersadaINDONESIA
TinPT Premium Tin IndonesiaINDONESIA
TinPT Prima Timah UtamaINDONESIA
TinPT Rajawali Rimba PerkasaINDONESIA
TinPT Refined Bangka TinINDONESIA
TinPT Sariwiguna BinasentosaINDONESIA
TinPT Stanindo Inti PerkasaINDONESIA
TinPT Sukses Inti MakmurINDONESIA
TinPT Sumber Jaya IndahINDONESIA
TinPT Timah (Persero) Tbk KundurINDONESIA
TinPT Timah (Persero) Tbk MentokINDONESIA
TinPT Tinindo Inter NusaINDONESIA
TinPT Tirus Putra MandiriINDONESIA
TinPT Tommy UtamaINDONESIA
TinResind Industria e Comercio Ltda.BRAZIL
TinRui Da HungTAIWAN
TinSoft Metais Ltda.BRAZIL
TinSuper LigasBRAZIL
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIETNAM
TinThaisarcoTHAILAND
TinTin Technology & RefiningUNITED STATES OF AMERICA
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIETNAM



TinWhite Solder Metalurgia e Mineração Ltda.BRAZIL
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINA
TinYunnan Tin Company LimitedCHINA
TungstenA.L.M.T. TUNGSTEN Corp.JAPAN
TungstenACL Metais EireliBRAZIL
TungstenAsia Tungsten Products Vietnam Ltd.VIETNAM
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINA
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINA
TungstenFujian Jinxin Tungsten Co., Ltd.CHINA
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINA
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINA
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINA
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINA
TungstenGanzhou Yatai Tungsten Co., Ltd.CHINA
TungstenGlobal Tungsten & Powders Corp.UNITED STATES
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINA
TungstenH.C. Starck Smelting GmbH & Co.KGGERMANY
TungstenH.C. Starck Tungsten GmbHGERMANY
TungstenHunan Chenzhou Mining Co., Ltd.CHINA
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiCHINA
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINA
TungstenHunan Litian Tungsten Industry Co., Ltd.CHINA
TungstenHydrometallurg, JSCRUSSIAN FEDERATION
TungstenJapan New Metals Co., Ltd.JAPAN
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINA
TungstenJiangxi Dayu Longxintai Tungsten Co., Ltd.CHINA
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINA
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINA
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINA
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINA
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINA
TungstenKennametal FallonUNITED STATES
TungstenKennametal HuntsvilleUNITED STATES
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINA
TungstenMoliren LtdRUSSIAN FEDERATION
TungstenNiagara Refining LLCUNITED STATES
TungstenNui Phao H.C. Starck Tungsten Chemicals Manufacturing LLCVIETNAM
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINES
TungstenSouth-East Nonferrous Metal Company Limited of Hengyang CityCHINA
TungstenTejing (Vietnam) Tungsten Co., Ltd.VIETNAM
TungstenUnecha Refractory metals plantRUSSIAN FEDERATION
TungstenWolfram Bergbau und Hütten AGAUSTRIA
TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OF
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINA
TungstenXiamen Tungsten Co., Ltd.CHINA
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINA
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.CHINA





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.

Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Djibouti, Dominican Republic, DRC or an adjoining country (Covered Countries), Ecuador, Egypt, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic, Republic Of Korea, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, USA, Uzbekistan, Viet Nam, Zambia, Zimbabwe    

 






























* Information from suppliers CMRTs identified JSC Ekaterinburg Non-Ferrous Metal Processing Plant (“JSC Ekaterinburg”) as a potential source of metals used by the Company’s third-party suppliers. JSC Ekaterinburg is owned by a sanctioned Russian party. The Company does not knowingly source metals directly or indirectly from sanctioned countries or parties, does not conduct transactions with sanctioned countries or parties, and has robust economic sanctions screening procedures designed to prevent business with sanctioned countries or parties before it occurs. To the extent the Company might have knowingly received metals from JSC Ekaterinburg, these materials would have been substantially transformed before being sold to the Company or otherwise incorporated into finished products.