DocumentExhibit 1.01
Regal Rexnord Corporation
Conflict Minerals Report
For the Reporting Period from
January 1 to December 31, 2022
This Conflict Minerals Report (this “Report”) of Regal Rexnord Corporation (the “Company,” “we,” “Regal Rexnord,” “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 to December 31, 2022.
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, 2022 and December 31, 2022, 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 Report 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 economic activity, business levels, credit ratings, 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,” “confident,” “estimate,” “expect,” “intend,” “plan,” “may,” “will,” “project,” “forecast,” “would,” “could,” “should,” 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 Company’s 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 urged to consider these factors in evaluating the forward-looking statements and 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 February 24, 2023 and from time to time in other filed reports including the Company's Quarterly Reports on Form 10-Q.
Summary
Through our Reasonable Country of Origin Inquiry (“RCOI”) and due diligence efforts, we identified 87 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. Out of those 87 smelters, 68 smelters are 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 Rexnord is a global leader in the engineering and manufacturing of industrial powertrain solutions, power transmission components, electric motors and electronic controls, air moving products and specialty electrical components and systems, serving markets throughout the world. Through longstanding technology leadership and an intentional focus on producing more energy-efficient products and systems, Regal Rexnord helps create a better tomorrow – for its customers and for the planet. Regal Rexnord is comprised of four operating segments: Industrial Powertrain Solutions, Power Efficiency Solutions, Automation & Motion Control and Industrial Systems.
As previously disclosed, on October 26, 2022, the Company entered into an Agreement and Plan of Merger (the “Altra Merger Agreement”) by and among the Company, Altra Industrial Motion Corp., a Delaware corporation (“Altra”), and Aspen Sub, Inc., a Delaware corporation and a wholly owned subsidiary of the Company (“Merger Sub”). On March 27, 2023, in accordance with the terms and conditions of the Altra Merger Agreement, Merger Sub merged with (the "Altra Merger") and into Altra, with Altra surviving the Altra Merger as a wholly owned
subsidiary of the Company. For purposes of this Report and the applicable reporting period, the disclosures made herein include those of the Altra business.
For purposes of this Report and the entire applicable reporting period, the disclosures made herein include those of the combined Company including the Altra business.
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 2022. These products are collectively referred to in this Report as the “Covered Products”. Covered Products are designed and produced be each of the Company's four operating segments and generally include the following:
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| 1. | Industrial Powertrain Solutions: mounted and unmounted bearings, couplings, mechanical power transmission drives and components, gearboxes and gear motors, clutches, brakes, special components products and industrial powertrain components and solutions. |
| 2. | Power Efficiency Solutions: fractional to approximately 5 horsepower AC and DC motors, electronic variable speed controls, fans and blowers, small motors, electronic variable speed controls and air moving solutions |
| 3. | Automation & Motion Control: conveyor products, conveying automation subsystems, aerospace components, rotary precision motion solutions, high-efficiency miniature motors and motion control products, automatic transfer switches, switchgears that enable and control the transition of rotary motion to linear motion. |
| 4. | Industrial Systems: integral motors, alternators, and aftermarket parts and kits to support such products. |
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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 6.22 and higher (“CMRT”).
Our RCOI utilizes a risk-based approach, targeting suppliers that, in the aggregate, were responsible for the majority of the Company’s total annual spending on materials, parts and components. 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 1,956 direct suppliers as in-scope for our 2022 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 (our “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.
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 16, 2023, 59% 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 79%.
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 https://investors.regalrexnord.com/investors/corporate-governance/integrity-and-compliance/default.aspx. Further, Regal Rexnord supports conflict-free minerals trade in the DRC and Covered Countries and will not avoid sourcing from conflict-free organizations in the region. In addition, Altra maintained its own substantially similar policy related to conflicts minerals for the applicable reporting period.
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 Rexnord 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 Rexnord 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 (https://investors.regalrexnord.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 contributors from: Legal, Sourcing, and Environmental, Health, Safety and Sustainability (EHSS). Further support is provided by key subject matter experts within the Company segments. Additional guidance and oversight is provided by the Global Supply Chain Director, the Global Risk and Compliance Leader and the Global 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 Rexnord 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 Rexnord’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. A link to our Integrity Alert Line is available here. (https://investors.regalrexnord.com/investors/corporate-governance/integrity-and-compliance/default.aspx)
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 2022 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 16, 2023, we have identified 342 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 majority of 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, Executive Vice President, Chief Financial Officer of the Company (the “CFO”), 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 Rexnord.
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 Rule, this Report is also available on our website (https://investors.regalrexnord.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 16, 2023, we have identified 342 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.
Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 222 smelters that are deemed RMAP Conformant – this indicates these smelters or refiners are conformant with the RMAP assessment protocols. There are 7 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 Jewellery Program Chain-of-Custody Certification. There are an additional 25 smelters or refiners that are deemed non-conformant. The remaining 88 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.
68 out of 87 smelters either identified as sourcing conflict minerals from Covered Countries or those which Regal Rexnord has reason to believe source conflict minerals from the Covered Countries were compliant with the RMAP assessment.
Risk Mitigation Process
The following details certain processes we have developed and are currently working relative to the suppliers who have indicated that red flag smelters are in their supply chains - and, consequently, Regal Rexnord’s.
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| • | 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 Rexnord. |
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| • | 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. |
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| • | 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 Rexnord the results of their activities. |
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| • | For suppliers failing to actively remove or failing to communicate their progress to remove these smelters from their supply chains, Regal Rexnord will initiate further escalation steps with the supplier up to removing these suppliers from our supply chain. |
In order to improve the transparency throughout its supply chain, the Company will routinely (i) monitor these risk mitigation efforts, (ii) report to senior management on the effectiveness of these efforts and (iii) make any adjustments to this strategy as may be necessary from time to time.
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.
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Regal Rexnord. A number of factors could introduce errors or otherwise affect our conclusion. These factors include, but are not limited to the following:
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| 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 2022 |
| 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 continue taking 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:
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| 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. |
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| 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 an analysis of over 179,950 component parts. |
Annex I
List of Smelters and Refiners Identified in Regal Rexnord Corporation’s Supply Chain
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| Subject Mineral | | Standard Smelter Name | | Country |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | Uzbekistan |
| Gold | | AngloGold Ashanti Corrego do Sitio Mineracao | | Brazil |
| Gold | | Aida Chemical Industries Co., Ltd. | | Japan |
| Gold | | Agosi AG | | Germany |
| Gold | | Argor-Heraeus S.A. | | Switzerland |
| Gold | | Asahi Pretec Corp. | | Japan |
| Gold | | Aurubis AG | | Germany |
| Gold | | CCR Refinery - Glencore Canada Corporation | | Canada |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | Turkey |
| Gold | | Boliden AB | | Sweden |
| Gold | | Asaka Riken Co., Ltd. | | Japan |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | Philippines |
| Gold | | Caridad | | Mexico |
| Gold | | Cendres + Metaux S.A. | | Switzerland |
| Gold | | Advanced Chemical Company | | United States Of America |
| Gold | | C. Hafner GmbH + Co. KG | | Germany |
| Gold | | DSC (Do Sung Corporation) | | Korea, Republic Of |
| Gold | | JSC Novosibirsk Refinery | | Russian Federation |
| Gold | | Dowa | | Japan |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | China |
| Gold | | Heraeus Metals Hong Kong Ltd. | | China |
| Gold | | Heraeus Germany GmbH Co. KG | | Germany |
| Gold | | Jiangxi Copper Co., Ltd. | | China |
| Gold | | LT Metal Ltd. | | Korea, Republic Of |
| Gold | | Heimerle + Meule GmbH | | Germany |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | Japan |
| Gold | | Yunnan Copper Industry Co., Ltd. | | China |
| Gold | | Chugai Mining | | Japan |
| Gold | | HwaSeong CJ CO., LTD. | | Korea, Republic Of |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | China |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | Japan |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | China |
| Gold | | Matsuda Sangyo Co., Ltd. | | Japan |
| Gold | | Eco-System Recycling Co., Ltd. East Plant | | Japan |
| Gold | | Refinery of Seemine Gold Co., Ltd. | | China |
| Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | China |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | | China |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | China |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | Singapore |
| Gold | | Asahi Refining Canada Ltd. | | Canada |
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| Gold | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | Russian Federation |
| Gold | | Kazakhmys Smelting LLC | | Kazakhstan |
| Gold | | Kazzinc | | Kazakhstan |
| Gold | | Metalor Technologies S.A. | | Switzerland |
| Gold | | Kojima Chemicals Co., Ltd. | | Japan |
| Gold | | Kyrgyzaltyn JSC | | Kyrgyzstan |
| Gold | | L'azurde Company For Jewelry | | Saudi Arabia |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | China |
| Gold | | Materion | | United States Of America |
| Gold | | LS-NIKKO Copper Inc. | | Korea, Republic Of |
| Gold | | Metalor USA Refining Corporation | | United States Of America |
| Gold | | Mitsubishi Materials Corporation | | Japan |
| Gold | | Moscow Special Alloys Processing Plant | | Russian Federation |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.S. | | Turkey |
| Gold | | Nihon Material Co., Ltd. | | Japan |
| Gold | | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | | Russian Federation |
| Gold | | Navoi Mining and Metallurgical Combinat | | Uzbekistan |
| Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | Mexico |
| Gold | | PX Precinox S.A. | | Switzerland |
| Gold | | Royal Canadian Mint | | Canada |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | Japan |
| Gold | | MKS PAMP SA | | Switzerland |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | Japan |
| Gold | | Prioksky Plant of Non-Ferrous Metals | | Russian Federation |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | | China |
| Gold | | Shandong Gold Smelting Co., Ltd. | | China |
| Gold | | PT Aneka Tambang (Persero) Tbk | | Indonesia |
| Gold | | Rand Refinery (Pty) Ltd. | | South Africa |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | Belgium |
| Gold | | Yokohama Metal Co., Ltd. | | Japan |
| Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | China |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | Japan |
| Gold | | Super Dragon Technology Co., Ltd. | | Taiwan, Province Of China |
| Gold | | Tongling Nonferrous Metals Group Co., Ltd. | | China |
| Gold | | Solar Applied Materials Technology Corp. | | Taiwan, Province Of China |
| Gold | | Torecom | | Korea, Republic Of |
| Gold | | United Precious Metal Refining, Inc. | | United States Of America |
| Gold | | Western Australian Mint (T/a The Perth Mint) | | Australia |
| Gold | | Guangdong Jinding Gold Limited | | China |
| Gold | | Fidelity Printers and Refiners Ltd. | | Zimbabwe |
| Gold | | MMTC-PAMP India Pvt., Ltd. | | India |
| Gold | | International Precious Metal Refiners | | United Arab Emirates |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | China |
| Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | China |
| Gold | | Morris and Watson | | New Zealand |
| Gold | | SAFINA A.S. | | Czechia |
| Gold | | T.C.A S.p.A | | Italy |
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| Gold | | REMONDIS PMR B.V. | | Netherlands |
| Gold | | Umicore Precious Metals Thailand | | Thailand |
| Gold | | Geib Refining Corporation | | United States Of America |
| Gold | | Fujairah Gold FZC | | United Arab Emirates |
| Gold | | Abington Reldan Metals, LLC | | United States Of America |
| Gold | | KGHM Polska Miedz Spolka Akcyjna | | Poland |
| Gold | | Shandong Humon Smelting Co., Ltd. | | China |
| Gold | | Shenzhen Zhonghenglong Real Industry Co., Ltd. | | China |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | | Germany |
| Gold | | SungEel HiMetal Co., Ltd. | | Korea, Republic Of |
| Gold | | Al Etihad Gold Refinery DMCC | | United Arab Emirates |
| Gold | | Singway Technology Co., Ltd. | | Taiwan, Province Of China |
| Gold | | Emirates Gold DMCC | | United Arab Emirates |
| Gold | | Sudan Gold Refinery | | Sudan |
| Gold | | SAAMP | | France |
| Gold | | Italpreziosi | | Italy |
| Gold | | Eco-System Recycling Co., Ltd. West Plant | | Japan |
| Gold | | Emerald Jewel Industry India Limited (Unit 4) | | India |
| Gold | | Sancus ZFS (L’Orfebre, SA) | | Colombia |
| Gold | | Gold by Gold Colombia | | Colombia |
| Gold | | AU Traders and Refiners | | South Africa |
| Gold | | GGC Gujrat Gold Centre Pvt. Ltd. | | India |
| Gold | | Modeltech Sdn Bhd | | Malaysia |
| Gold | | Planta Recuperadora de Metales SpA | | Chile |
| Gold | | ABC Refinery Pty Ltd. | | Australia |
| Gold | | NH Recytech Company | | Korea, Republic Of |
| Gold | | Kaloti Precious Metals | | United Arab Emirates |
| Gold | | Korea Zinc Co., Ltd. | | Korea, Republic Of |
| Gold | | Marsam Metals | | Brazil |
| Gold | | TOO Tau-Ken-Altyn | | Kazakhstan |
| Gold | | Augmont Enterprises Private Limited | | India |
| Gold | | Shenzhen CuiLu Gold Co., Ltd. | | China |
| Gold | | L'Orfebre S.A. | | Andorra |
| Gold | | 8853 S.p.A. | | Italy |
| Gold | | Kundan Care Products Ltd. | | India |
| Gold | | Pease & Curren | | United States Of America |
| Gold | | JALAN & Company | | India |
| Gold | | African Gold Refinery | | Uganda |
| Gold | | Gold Coast Refinery | | Ghana |
| Gold | | Dijllah Gold Refinery FZC | | United Arab Emirates |
| Gold | | CGR Metalloys Pvt Ltd. | | India |
| Gold | | Sovereign Metals | | India |
| Gold | | Chimet S.p.A. | | Italy |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | | China |
| Gold | | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | | China |
| Gold | | Istanbul Gold Refinery | | Turkey |
| Gold | | Japan Mint | | Japan |
| | | | | | | | | | | | | | |
| Gold | | Emerald Jewel Industry India Limited (Unit 1) | | India |
| Gold | | K.A. Rasmussen | | Norway |
| Gold | | MD Overseas | | India |
| Gold | | WEEEREFINING | | France |
| Gold | | Dongwu Gold Group | | China |
| Gold | | Asahi Refining USA Inc. | | United States Of America |
| Gold | | JSC Uralelectromed | | Russian Federation |
| Gold | | Kennecott Utah Copper LLC | | United States Of America |
| Gold | | Lingbao Gold Co., Ltd. | | China |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | China |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | Japan |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | China |
| Gold | | Sabin Metal Corp. | | United States Of America |
| Gold | | Samduck Precious Metals | | Korea, Republic Of |
| Gold | | Samwon Metals Corp. | | Korea, Republic Of |
| Gold | | SEMPSA Joyeria Plateria S.A. | | Spain |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | China |
| Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | China |
| Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | Russian Federation |
| Gold | | Tokuriki Honten Co., Ltd. | | Japan |
| Gold | | Valcambi S.A. | | Switzerland |
| Gold | | Yamakin Co., Ltd. | | Japan |
| Gold | | Industrial Refining Company | | Belgium |
| Gold | | Shirpur Gold Refinery Ltd. | | India |
| Gold | | Albino Mountinho Lda. | | Portugal |
| Gold | | WIELAND Edelmetalle GmbH | | Germany |
| Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | Austria |
| Gold | | Sai Refinery | | India |
| Gold | | Bangalore Refinery | | India |
| Gold | | Kyshtym Copper-Electrolytic Plant ZAO | | Russian Federation |
| Gold | | Safimet S.p.A | | Italy |
| Gold | | State Research Institute Center for Physical Sciences and Technology | | Lithuania |
| Gold | | QG Refining, LLC | | United States Of America |
| Gold | | C.I Metales Procesados Industriales SAS | | Colombia |
| Gold | | Eco-System Recycling Co., Ltd. North Plant | | Japan |
| Gold | | Emerald Jewel Industry India Limited (Unit 2) | | India |
| Gold | | Emerald Jewel Industry India Limited (Unit 3) | | India |
| Gold | | Alexy Metals | | United States Of America |
| Gold | | Sellem Industries Ltd. | | Mauritania |
| Gold | | Metallix Refining Inc. | | United States Of America |
| Gold | | Metal Concentrators SA (Pty) Ltd. | | South Africa |
| Tantalum | | XIMEI RESOURCES (GUANGDONG) LIMITED | | China |
| Tantalum | | F&X Electro-Materials Ltd. | | China |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | China |
| Tantalum | | AMG Brasil | | Brazil |
| Tantalum | | Mitsui Mining and Smelting Co., Ltd. | | Japan |
| Tantalum | | Mineracao Taboca S.A. | | Brazil |
| | | | | | | | | | | | | | |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | China |
| Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | China |
| Tantalum | | Solikamsk Magnesium Works OAO | | Russian Federation |
| Tantalum | | Telex Metals | | United States Of America |
| Tantalum | | QuantumClean | | United States Of America |
| Tantalum | | Ulba Metallurgical Plant JSC | | Kazakhstan |
| Tantalum | | D Block Metals, LLC | | United States Of America |
| Tantalum | | Taki Chemical Co., Ltd. | | Japan |
| Tantalum | | KEMET de Mexico | | Mexico |
| Tantalum | | Materion Newton Inc. | | United States Of America |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | China |
| Tantalum | | TANIOBIS Smelting GmbH & Co. KG | | Germany |
| Tantalum | | Global Advanced Metals Boyertown | | United States Of America |
| Tantalum | | FIR Metals & Resource Ltd. | | China |
| Tantalum | | TANIOBIS Co., Ltd. | | Thailand |
| Tantalum | | TANIOBIS GmbH | | Germany |
| Tantalum | | Global Advanced Metals Aizu | | Japan |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | China |
| Tantalum | | TANIOBIS Japan Co., Ltd. | | Japan |
| Tantalum | | RFH Yancheng Jinye New Material Technology Co., Ltd. | | China |
| Tantalum | | Resind Industria e Comercio Ltda. | | Brazil |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | China |
| Tantalum | | Metallurgical Products India Pvt., Ltd. | | India |
| Tantalum | | NPM Silmet AS | | Estonia |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | China |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | China |
| Tantalum | | Jiangxi Tuohong New Raw Material | | China |
| Tantalum | | 5D Production OU | | Estonia |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | China |
| Tin | | PT Aries Kencana Sejahtera | | Indonesia |
| Tin | | PT Premium Tin Indonesia | | Indonesia |
| Tin | | Dowa | | Japan |
| Tin | | EM Vinto | | Bolivia (Plurinational State Of) |
| Tin | | Fenix Metals | | Poland |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | China |
| Tin | | Alpha | | United States Of America |
| Tin | | China Tin Group Co., Ltd. | | China |
| Tin | | Mineracao Taboca S.A. | | Brazil |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | China |
| Tin | | Metallic Resources, Inc. | | United States Of America |
| Tin | | Jiangxi New Nanshan Technology Ltd. | | China |
| Tin | | Novosibirsk Tin Combine | | Russian Federation |
| Tin | | Minsur | | Peru |
| Tin | | Operaciones Metalurgicas S.A. | | Bolivia (Plurinational State Of) |
| Tin | | PT Bangka Tin Industry | | Indonesia |
| Tin | | PT Mitra Stania Prima | | Indonesia |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | Thailand |
| | | | | | | | | | | | | | |
| Tin | | PT Artha Cipta Langgeng | | Indonesia |
| Tin | | PT Babel Inti Perkasa | | Indonesia |
| Tin | | PT Belitung Industri Sejahtera | | Indonesia |
| Tin | | PT Bukit Timah | | Indonesia |
| Tin | | PT Babel Surya Alam Lestari | | Indonesia |
| Tin | | PT Stanindo Inti Perkasa | | Indonesia |
| Tin | | PT Timah Tbk Kundur | | Indonesia |
| Tin | | PT Tinindo Inter Nusa | | Indonesia |
| Tin | | PT Timah Nusantara | | Indonesia |
| Tin | | PT Tommy Utama | | Indonesia |
| Tin | | VQB Mineral and Trading Group JSC | | Viet Nam |
| Tin | | Rui Da Hung | | Taiwan, Province Of China |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | China |
| Tin | | Magnu's Minerais Metais e Ligas Ltda. | | Brazil |
| Tin | | PT Tirus Putra Mandiri | | Indonesia |
| Tin | | Melt Metais e Ligas S.A. | | Brazil |
| Tin | | PT ATD Makmur Mandiri Jaya | | Indonesia |
| Tin | | CV Ayi Jaya | | Indonesia |
| Tin | | White Solder Metalurgia e Mineracao Ltda. | | Brazil |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | Viet Nam |
| Tin | | CV Venus Inti Perkasa | | Indonesia |
| Tin | | PT Cipta Persada Mulia | | Indonesia |
| Tin | | Super Ligas | | Brazil |
| Tin | | Aurubis Berango | | Spain |
| Tin | | O.M. Manufacturing Philippines, Inc. | | Philippines |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | China |
| Tin | | Pongpipat Company Limited | | Myanmar |
| Tin | | PT Rajehan Ariq | | Indonesia |
| Tin | | Resind Industria e Comercio Ltda. | | Brazil |
| Tin | | CRM Synergies | | Spain |
| Tin | | Aurubis Beerse | | Belgium |
| Tin | | PT Sukses Inti Makmur | | Indonesia |
| Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | China |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | Viet Nam |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | Viet Nam |
| Tin | | PT Bangka Serumpun | | Indonesia |
| Tin | | PT Rajawali Rimba Perkasa | | Indonesia |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | Viet Nam |
| Tin | | PT Menara Cipta Mulia | | Indonesia |
| Tin | | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | | Brazil |
| Tin | | Modeltech Sdn Bhd | | Malaysia |
| Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | | China |
| Tin | | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | | China |
| Tin | | Estanho de Rondonia S.A. | | Brazil |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | China |
| Tin | | Malaysia Smelting Corporation (MSC) | | Malaysia |
| | | | | | | | | | | | | | |
| Tin | | Mitsubishi Materials Corporation | | Japan |
| Tin | | PT Panca Mega Persada | | Indonesia |
| Tin | | PT Prima Timah Utama | | Indonesia |
| Tin | | PT Refined Bangka Tin | | Indonesia |
| Tin | | PT Sariwiguna Binasentosa | | Indonesia |
| Tin | | PT Timah Tbk Mentok | | Indonesia |
| Tin | | Thaisarco | | Thailand |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | China |
| Tin | | Tin Smelting Branch of Yunnan Tin Co., Ltd. | | China |
| Tin | | PT Bangka Prima Tin | | Indonesia |
| Tin | | Tin Technology & Refining | | United States Of America |
| Tin | | Luna Smelter, Ltd. | | Rwanda |
| Tin | | Precious Minerals and Smelting Limited | | India |
| Tin | | Gejiu City Fuxiang Industry and Trade Co., Ltd. | | China |
| Tin | | PT Mitra Sukses Globalindo | | Indonesia |
| Tin | | Fabrica Auricchio Industria e Comercio Ltda. | | Brazil |
| Tin | | DS Myanmar | | Myanmar |
| Tin | | PT Putera Sarana Shakti (PT PSS) | | Indonesia |
| Tungsten | | A.L.M.T. Corp. | | Japan |
| Tungsten | | Kennametal Huntsville | | United States Of America |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | China |
| Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | | China |
| Tungsten | | Japan New Metals Co., Ltd. | | Japan |
| Tungsten | | Global Tungsten & Powders LLC | | United States Of America |
| Tungsten | | Hunan Jintai New Material Co., Ltd. | | China |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | China |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | China |
| Tungsten | | Kennametal Fallon | | United States Of America |
| Tungsten | | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | | China |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | China |
| Tungsten | | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | | China |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | China |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | China |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | China |
| Tungsten | | Wolfram Bergbau und Hutten AG | | Austria |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | China |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | China |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | China |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | Philippines |
| Tungsten | | ACL Metais Eireli | | Brazil |
| Tungsten | | Moliren Ltd. | | Russian Federation |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | China |
| Tungsten | | Masan High-Tech Materials | | Viet Nam |
| Tungsten | | Niagara Refining LLC | | United States Of America |
| Tungsten | | China Molybdenum Tungsten Co., Ltd. | | China |
| Tungsten | | JSC "Kirovgrad Hard Alloys Plant" | | Russian Federation |
| | | | | | | | | | | | | | |
| Tungsten | | NPP Tyazhmetprom LLC | | Russian Federation |
| Tungsten | | HANNAE FOR T Co., Ltd. | | Korea, Republic Of |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | China |
| Tungsten | | Hydrometallurg, JSC | | Russian Federation |
| Tungsten | | Lianyou Metals Co., Ltd. | | Taiwan, Province Of China |
| Tungsten | | Hubei Green Tungsten Co., Ltd. | | China |
| Tungsten | | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | | Brazil |
| Tungsten | | OOO “Technolom” 1 | | Russian Federation |
| Tungsten | | LLC Vostok | | Russian Federation |
| Tungsten | | Tungsten Vietnam Joint Stock Company | | Viet Nam |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | China |
| Tungsten | | Cronimet Brasil Ltda | | Brazil |
| Tungsten | | Artek LLC | | Russian Federation |
| Tungsten | | Fujian Xinlu Tungsten Co., Ltd. | | China |
| Tungsten | | OOO “Technolom” 2 | | Russian Federation |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | China |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | China |
| Tungsten | | Asia Tungsten Products Vietnam Ltd. | | Viet Nam |
| Tungsten | | H.C. Starck Tungsten GmbH | | Germany |
| Tungsten | | TANIOBIS Smelting GmbH & Co. KG | | Germany |
| Tungsten | | Unecha Refractory metals plant | | Russian Federation |
| Tungsten | | YUDU ANSHENG TUNGSTEN CO., LTD. | | China |
Annex II
List of Countries of Origin for Subject Minerals
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, 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, 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, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Vietnam, Zambia, Zimbabwe
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.
* Information from supplier declarations identified smelters located in the Russian Federation and Uganda as a potential source of metals used by the Company’s third-party suppliers. These smelters lost their certifications during the reporting year. As they may have been part of the Company’s supply chain prior to change in status, they are still listed. The Company does not knowingly source directly or indirectly from sanctioned countries or parties. The inclusion of a country on the list of smelters is not a final indicator that the Company utilized materials sourced from this country.