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Lifetime Brands, Inc. (the “Company” and, unless the context otherwise requires, references to the “Company” shall include its consolidated subsidiaries) designs, sources and sells branded kitchenware, tableware and other products used in the home and markets its products under a number of widely-recognized brand names and trademarks, which are either owned or licensed by the Company, or through retailers’ private labels and their licensed brands. The Company’s products, which are targeted primarily towards consumers purchasing moderately priced kitchenware, tableware and housewares, are sold through virtually every major level of trade. The Company generally markets several lines within each of its product categories under more than one brand. The Company sells its products directly to retailers (who may resell the Company’s products through their websites) and, to a lesser extent, to distributors. The Company also sells a limited selection of its products directly to consumers through its own websites.

For the year ended December 31, 2021, the Company’s product categories include two categories of products used to prepare, serve and consume foods, Kitchenware (kitchen tools and gadgets, cutlery, kitchen scales, thermometers, cutting boards, shears, cookware, pantryware, spice racks and bakeware) and Tableware (dinnerware, stemware, flatware and giftware); and one category, Home Solutions, which comprises other products used in the home (thermal beverageware, bath scales, weather and outdoor household products, food storage, neoprene travel products and home décor).

The Company in 2014 adopted a conflict minerals due diligence program which included establishing a management team to oversee the Company’s compliance with conflict minerals reporting. The management team overseeing the program is led by the Company’s Senior Vice President of Quality Assurance, and also includes the Company’s Chief Financial Officer, Senior Vice President of Operations, President of Global Sourcing, General Counsel and a team of subject matter experts from relevant functions such as purchasing and merchandising. The Company’s conflict minerals due diligence program also included the development of a Conflict Minerals Policy Statement and due diligence compliance process to assess the potential for products to contain conflict minerals, the engagement of suppliers, record keeping and escalation procedures. The Company’s due diligence procedures have been designed to be consistent with the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”).

The Company’s Conflict Minerals Policy Statement was provided to each of the Company’s direct suppliers. It emphasizes the Company’s commitment to work with manufacturers and suppliers to undertake due diligence with their supply chain to assure that conflict minerals originate only from smelters or refiners who source minerals outside the conflict region as defined in the Rule or regulations thereunder, or mines and smelters or refiners which have been certified by an independent third party as conflict free if sourced from the conflict region. The Company’s Conflict Minerals Policy Statement can be found on the Company’s website, www.lifetimebrands.com, in the Corporate Governance subsection under Investor Relations.

With the exception of the Company’s sterling silver and pewter products, the Company sources almost all of its products from suppliers located outside the United States, primarily in the People’s Republic of China. The Company manufactures its sterling silver and pewter products at a leased facility in San Germán, Puerto Rico and fills containers with spices and assembles spice racks at its owned Winchendon, Massachusetts distribution facility.

Based upon the Company’s assessment, kitchen tools and gadgets, cutlery, kitchen scales, thermometers shears, stemware, flatware, giftware, tableware, pantryware, food storage, bath scales, weather and outdoor household products, and certain home décor products the Company contracts to manufacture have the potential to contain conflict minerals through the use of gold, tin and tin solder and tungsten. The Company’s silver manufacturing facility was also assessed and it was determined that tin and tin solder are used in certain products. Tin solder is used to join together metal pieces and could be considered necessary for the functionality of these products. For the purposes of the required Reasonable Country of Origin Inquiry (“RCOI”), the Company focused its inquiry on its direct tin and tin solder suppliers and suppliers contracted to manufacture products the Company believes to have the potential to contain conflict minerals.

The Company identified over 280 suppliers contracted to manufacture products with the potential to contain conflict minerals. A survey was sent to each of these suppliers. The survey was developed to facilitate the disclosure and communication of information regarding the supply chain. It included questions regarding the supplier’s conflict minerals policy, the engagement and requirements of its direct suppliers, and details of smelters or refiners and sources of conflict minerals. The survey was designed to be consistent with industry-adopted surveys used in conflict mineral due diligence processes.

The Company’s suppliers contracted to manufacture products identified 11 smelters used in turn by such suppliers. The 8 smelters listed below have been identified as being conformant with the relevant Responsible Minerals Assurance Process (RMAP) assessment protocols of the Responsible Minerals Initiative (“RMI”) (formerly the Conflict-Free Sourcing Initiative):


Metal:	Smelter Facility Name:	Country of Facility:
Gold	Heraus Germany	Germany
Gold	Heraeus	China
Gold	Umicore Gahanotechnik Gmbh.	Germany
Gold	Ishifuku Metal Industry	Japan
Tin	Yunnan Tin Company Ltd	China
Tin	Nankang Nanshan Tin Manufactory Co., Ltd	China
Tin	Yunnan Chengfeng Non-ferrous Metals Co., Ltd.	China
Tin	Chifeng Dajinzi Tin Industry Co., Ltd.	China

Based on comparison to information made publicly available by the RMI, the Company was unable to identify the below three (3) smelters as being conformant with the relevant RMAP assessment protocols of the RMI. However, the Company’s respective suppliers that used the below three (3) smelters as their direct supplier of gold, tin or a tin alloy represented to the Company that no minerals from the conflict region were used in the manufacturing of products supplied to the Company:

The Company has relied on the supplier responses received through the surveys to provide it with information about the source of conflict minerals contained in its products. Each supplier response was certified by a representative of the supplier. All responses received were summarized and provided to the Company’s management team overseeing the due diligence program. Further, the management team assessed the reliability of the supplier responses and performed reasonable diligence by requesting and receiving from certain suppliers additional supporting documentation or clarification, as needed, and by comparing identified smelters or refiners to publicly available information about such smelters or refiners.

Products contracted to be manufactured by the Company containing gold, tin or a tin alloy are manufactured at facilities located in China, Czech Republic, Indonesia, Japan, Taiwan, Thailand and Vietnam. The amount of tin, or gold used in products contracted to be manufactured by the Company at these facilities was less than 1% of all materials used.

The Company’s direct suppliers of pewter and tin solder are located in the United States. The Company surveyed these suppliers and received responses which included the supplier’s conflict minerals policy, the terms of engagement and requirements of its direct suppliers, and details of smelters and sources of conflict minerals. The Company’s direct suppliers of pewter and tin solder identified a total of 30 smelters used in turn by such suppliers, including 24 smelters of tin and 6 smelters of gold. The smelters listed below have all been identified as being conformant with the relevant RMAP assessment protocols:


Metal:	Smelter Facility Name:	Country of Facility:
Gold	Asahi Refining Canada Ltd.	Canada
Gold	Heraeus Metals Hong Kong Ltd.	China
Gold	Kennecott Utah Copper Llc	United States of America
Gold	Metalor Usa Refining Corporation	United States of America
Gold	Metalurgica Met-Mex Penoles S.A. De C.V.	Mexico
Gold	Royal Canadian Mint	Canada
Tin	Minsur	Peru
Tin	Em Vinto	Bolivia (Plurinational State of)
Tin	Operaciones Metalúrgicas S.A.	Bolivia (Plurinational State of)
Tin	Fenix Metals	Poland
Tin	Thaisarco	Thailand
Tin	China Tin Group Co., Ltd.	China
Tin	Pt Timah Tbk Mentok	Indonesia
Tin	Malaysia Smelting Corporation (Msc)	Malaysia
Tin	Pt Prima Timah Utama	Indonesia
Tin	White Solder Metalurgia E Mineracao Ltda.	Brazil
Tin	Pt Mitra Stania Prima	Indonesia
Tin	Pt Atd Makmur Mandiri Jaya	Indonesia
Tin	Pt Timah Tbk Kundur	Indonesia
Tin	Guangdong Hanhe Non-Ferrous Metal Co., Ltd.	China
Tin	Gejiu Non-Ferrous Metal Processing Co., Ltd.	China
Tin	Metallo Spain S.L.U.	Spain
Tin	Rui Da Hung	Taiwan, Province of China
Tin	Pt Refined Bangka Tin	Indonesia
Tin	Pt Menara Cipta Mulia	Indonesia
Tin	Operaciones Metalurgicas S.A.	Bolivia (Plurinational State of)
Tin	Mineracao Taboca S.A.	Brazil
Tin	Metallo Belgium N.V.	Belgium
Tin	Tin Technology & Refining	United States of America

Due to the nature of the Company’s supply chain, it is difficult to identify contributing sources upstream from the Company’s direct suppliers. Despite the good-faith RCOI performed during this reporting period, the Company was not able to identify all mines of origin or all of the refining facilities sourcing the conflict minerals used by each of the suppliers identified through the survey.

Tracing materials back to their mine of origin is complex and an aspect of responsible sourcing. Due diligence efforts will continue to focus on the education of suppliers regarding the Company’s commitment to ensuring the safety, health and protection of people and the environment worldwide. The Company will continue to work with its suppliers to improve the content of survey responses and will continue to include a conflict minerals clause in new or renewed supplier contracts. The clause will require the disclosure of use of conflict minerals and will also require suppliers to complete an annual conflict minerals survey. As the Company develops new products and manufactures or contracts to manufacture these new products, or acquires new subsidiaries, the Company will also perform an upfront assessment of the supply chain to ensure it is compliant with the Company’s Conflict Minerals Policy Statement.

In this Conflict Minerals Report the use of words such as “intends,” “will,” or similar expressions is intended to identify forward-looking statements. Examples of such forward-looking statements include, but are not limited to, statements concerning the Company’s future supply management practices, policies and plans for procurement of materials, risk management practices, and efforts to improve supply chain transparency. Such statements represent the Company’s current good faith judgment and expectations of possible future events. The Company believes these judgments and expectations are reasonable, but these statements are not guarantees of future performance and are subject to risks and uncertainties. These risks and uncertainties may include, but are not limited to, the implementation of satisfactory traceability, reporting and other compliance measures by the Company’s direct and indirect suppliers on a timely basis, or at all, and political and regulatory developments, whether in the conflict region, the United States, or elsewhere. These forward-looking statements speak only as of the date of this Conflict Minerals Report. The Company undertakes no obligation to update these forward-looking statements other than as required by law.