UNITED
STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
IntriCon Corporation
(Exact name of registrant as specified in its charter)
| Pennsylvania | 1-5005 | 23-1069060 |
| (State or other jurisdiction of incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) |
| 1260 Red Fox Road, Arden Hills, Minnesota | 55112 |
| (Address of principal executive offices) | (Zip Code) |
| Scott Longval | (651) 636-9770 |
| (Name and telephone number, including area code, of the person to contact in connection with this report) | |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period of January 1 to December 31, 2020. |
Page 1 of 17
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of IntriCon Corporation (the "Company") is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for calendar year 2020.
A copy of the Company's Conflict Minerals Report for calendar year 2020 is filed as Exhibit 1.01 to this Form SD. It is publicly available at https://investorrelations.intricon.com/sec-filings; however, the contents of that site are not incorporated by reference into, and are not otherwise a part of, this Form SD.
Item 1.02 Exhibits
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit 1.01 – Conflict Minerals Report of IntriCon Corporation for calendar year 2020
Page 2 of 17
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| IntriCon Corporation | |||
| By: | /s/ Scott Longval | Date: | May 28, 2021 |
| Name: | Scott Longval | ||
| Title: | President and Chief Executive Officer | ||
Page 3 of 17
Exhibit 1.01
Conflict
Minerals Report of IntriCon Corporation
in Accordance with Rule 13p-1 under the Securities Exchange Act of 1934
Explanatory Note
This is the Conflict Minerals Report (the "Report") of IntriCon Corporation (the "Company") for calendar year 2020 in accordance with Rule 13p-1 ("Rule 13p-1") under the Securities Exchange Act of 1934 (the "1934 Act"). Please refer to Rule 13p-1, Form SD, and the 1934 Act Release No. 34-67716 for definitions of the terms used in this Report, unless otherwise defined herein.
Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products and any of the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The minerals specified in Rule 13p-1 are collectively referred to as Conflict Minerals. For purposes of Rule 13p-1 and the related disclosures, the term "Conflict Minerals" is defined to include: (A) columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to metallic forms of 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 "Covered Countries" for the purposes of Rule 13p-1 and this Report are the Democratic Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola. As described in this Report, Conflict Minerals are necessary to the functionality or production of certain of the Company's products that the Company manufactures or contracts to manufacture.
Description of the Company and the Products Covered by this Report
The Company is an international company and joint development manufacturer ("JDM") of micromedical components, sub-assemblies and final devices. The Company serves as a JDM partner to leading medical device original equipment manufacturers ("OEMs") by designing, developing, engineering, manufacturing, packaging and distributing micromedical products for high growth markets, such as diabetes, peripheral vascular, interventional pulmonology, electrophysiology, and hearing healthcare. Conflict Minerals are necessary to the functionality or production of certain of the Company's products that the Company manufactured or contracted to manufacture and for which the manufacture was completed during calendar year 2020 (the "Covered Products"). The Covered Products include:
Page 4 of 17
The Company does not purchase ore or unrefined Conflict Minerals from mines and is many steps removed in the supply chain from the mining of Conflict Minerals. The Company purchases materials used in its products from a large network of suppliers. The Company must therefore rely on its supply chain to provide information regarding the origin of the Conflict Minerals that are included in the Covered Products. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and the Company has therefore requested suppliers take steps to identify the applicable smelters and refiners of Conflict Minerals in the Company's Covered Products supply chain.
Reasonable Country of Origin Inquiry
The Company conducted a good faith reasonable country of origin inquiry ("RCOI") with respect to the Conflict Minerals included in the Covered Products. Such RCOI was reasonably designed to determine whether any of the Conflict Minerals included in the Covered Products originated in the Covered Countries or were from recycled or scrap sources.
The Company began the RCOI by (i) creating a list of part numbers of component parts that the Company utilizes in the Covered Products, and (ii) identifying the names of the suppliers from whom the Company obtained such parts. The list of suppliers was then provided to the Company's third-party service provider for upload to their cloud-based compliance management system ("Compliance Management tool") that allows the Company to store and manage supplier requests and documentation.
The service provider then conducted the supplier survey portion of the RCOI. Utilizing the Conflict Minerals Reporting Template (the "CMRT") developed by the Responsible Minerals Alliance, formerly the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative, the suppliers were surveyed on the sourcing of the Conflict Minerals identified in the Company's products.
As part of the survey, suppliers were asked to complete the survey and were provided educational materials on how to complete the form. In completing the CMRT, each supplier was asked, among other questions; whether the products or components they supplied to the Company contained Conflict Minerals; the origin of such Conflict Minerals; to identify the sources of Conflict Minerals from their lower tier level suppliers; to determine the smelter or mine origin or whether the Conflict Minerals were sourced from recycled or scrap sources. The service provider also followed up with suppliers that did not respond to the request to complete the CMRT. All communications were tracked and monitored by the service provider's Compliance Management tool. Suppliers were asked to return a copy of the CMRT once completed via email, or to upload the CMRT directly to the service provider's Compliance Management tool. All submitted CMRTs were automatically analyzed by the Compliance Management tool for completeness and internal consistency and against lists of known smelters and refiners. If information on the CMRT returned from a supplier appeared to be incomplete, incorrect, or not trustworthy, the supplier was contacted with a request to complete or correct the questionable information.
None of the Company's suppliers indicated that the Conflict Minerals in their supply chains were sourced from recycled or scrap sources. Based on the results of the RCOI, the Company could not definitively determine whether or not suppliers sourced Conflict Minerals from the Covered Countries. Therefore, the Company determined that there was reason to believe that some of the Conflict Minerals necessary for the functionality of the Covered Products may have originated in a Covered Country. Accordingly, it was necessary for the Company to exercise due diligence on the source and chain of custody of such Conflict Minerals.
Page 5 of 17
Design of Due Diligence Framework
The Company's due diligence measures have been designed to conform, in all material respects, to the framework in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas: Third Edition.
Due Diligence Measures Performed by the Company
The due diligence measures the Company performed related to the Covered Products included, but were not limited to, the following:
| · | The Company maintained an internal Conflict Minerals project team comprised of representatives from the Company's corporate finance, quality and regulatory, and supply chain management departments to implement the Company's Conflict Minerals due diligence. |
| · | The team reported to senior management on suppliers' responses to the Company's Conflict Minerals information requests. |
| · | The Company communicated its Conflict Minerals Policy to suppliers. A copy of the Company's Conflict Minerals Policy is available in the list of Corporate Documents at https://intricon.com/corporate-documents/; however, the contents of that site are not incorporated by reference into, and are not otherwise a part of, this Form SD. |
| · | Contractual provisions related to the sourcing of Conflict Minerals were included in applicable purchase orders. |
| · | The Company reviewed supplier risk ratings based on the responses provided within their completed CMRTs. In the situation where the Company becomes aware of a potential risk in the supply chain, where an item being purchased is believed to have been sourced from a smelter or refiner which is supporting armed conflict in the Covered Countries, the Company will explore sourcing alternatives for the item in question and take appropriate action. |
| · | Compared the smelters and refiners identified in the RCOI against the list of Compliant Smelters on the Responsible Minerals Initiative (RMI) website. The Company does not typically have a direct relationship with smelters and refiners, and therefore does not perform direct audits of such entities. Instead, reliance is on third party assurances and certifications such as from RMI's Responsible Minerals Assurance Process. |
| · | This Report, which constitutes the Company's annual report of due diligence efforts, has been filed with the SEC and is available on the Company's website, at: https://investorrelations.intricon.com/sec-filings. The contents of that website are not incorporated by reference into, and are not otherwise a part of, this Form SD. |
Appendix A contains a list of known smelters and refiners reported by the Company's suppliers which may have been used to process the Conflict Minerals utilized in the Covered Products. It is difficult to confirm the accuracy of information that was collected and transmitted through many levels of the supply chain for the Covered Products. Based on the information obtained pursuant to the due diligence process, the Company does not have sufficient information with respect to those Covered Products purchased from its suppliers to determine the country of origin of the Conflict Minerals in all Covered Products. At the same time, the Company received no information from its suppliers indicating that the Conflict Minerals in the Company's Covered Products directly or indirectly financed or benefitted armed groups in the Covered Countries. In some cases, information was provided to us for the entire supply chain of a supplier and was not necessarily limited to facilities that have been confirmed to contribute necessary Conflict Minerals to a Covered Product. Accordingly, we have been unable to definitely link the identified smelters and refiners to only those products/materials in our supply chain; therefore our list of smelters and refiners likely contains more processing facilities than are actually in our supply chain for Covered Products. As the Company's engagement with its supply chain evolves, the list of facilities may change to reflect improvements in the quality of information provided. Based on the information that was obtained, the Company has reasonably determined that countries of origin of the Conflict Minerals in the Covered Products may include the countries listed within Appendix B.
Page 6 of 17
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of Conflict Minerals, the Company's efforts undertaken to identify the source and chain of custody of Conflict Minerals in its products can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals. The Company's process relies on data obtained directly from suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary Conflict Minerals. Such sources of information may yield inaccurate or incomplete information.
Steps to Further Mitigate Risk and Improve Due Diligence in 2021
The Company expects to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Company's products finance or benefit armed groups in the Covered Countries:
| ● | The Company will continue to work closely with its third party conflict minerals service provider to obtain CMRTs on a product-specific basis to enable it to determine which smelters and refiners actually process Conflict Minerals contained in the Company's products. |
| ● | The Company will continue to provide its suppliers with information and training resources regarding responsible sourcing of Conflict Minerals. |
| ● | The Company will continue to encourage its suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers. |
| ● | The Company will include contractual provisions in applicable supplier contracts, as well as in each purchase order issued, regarding products and materials sold to the Company specifying products must not include Conflict Minerals from the Covered Countries that benefit armed groups in the Covered Countries. |
Page 7 of 17
APPENDIX A
SMELTERS AND REFINERS
Set forth below are known smelters and refiners reported by the Company's suppliers which may have been used to process Conflict Minerals in the Covered Products.
| Metal | Standard Smelter Name |
| Gold | 8853 S.p.A. |
| Gold | Abington Reldan Metals, LLC |
| Gold | Advanced Chemical Company |
| Gold | African Gold Refinery |
| Gold | Aida Chemical Industries Co., Ltd. |
| Gold | Al Etihad Gold Refinery DMCC |
| Gold | Alexy Metals |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao |
| Gold | Argor-Heraeus S.A. |
| Gold | Asahi Pretec Corp. |
| Gold | Asahi Refining Canada Ltd. |
| Gold | Asahi Refining USA Inc. |
| Gold | Asaka Riken Co., Ltd. |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Gold | AU Traders and Refiners |
| Gold | Augmont Enterprises Private Limited |
| Gold | Aurubis AG |
| Gold | Bangalore Refinery |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold | Boliden AB |
| Gold | C. Hafner GmbH + Co. KG |
| Gold | C.I Metales Procesados Industriales SAS |
| Gold | Caridad |
| Gold | CCR Refinery - Glencore Canada Corporation |
| Gold | Cendres + Metaux S.A. |
| Gold | CGR Metalloys Pvt Ltd. |
| Gold | Chimet S.p.A. |
| Gold | Chugai Mining |
| Gold | Daye Non-Ferrous Metals Mining Ltd. |
| Gold | Degussa Sonne / Mond Goldhandel GmbH |
| Gold | Dijllah Gold Refinery FZC |
| Gold | DODUCO Contacts and Refining GmbH |
| Gold | Dowa |
Page 8 of 17
| Metal | Standard Smelter Name |
| Gold | DS PRETECH Co., Ltd. |
| Gold | DSC (Do Sung Corporation) |
| Gold | Eco-System Recycling Co., Ltd. East Plant |
| Gold | Eco-System Recycling Co., Ltd. North Plant |
| Gold | Eco-System Recycling Co., Ltd. West Plant |
| Gold | Emerald Jewel Industry India Limited (Unit 1) |
| Gold | Emerald Jewel Industry India Limited (Unit 2) |
| Gold | Emerald Jewel Industry India Limited (Unit 3) |
| Gold | Emerald Jewel Industry India Limited (Unit 4) |
| Gold | Emirates Gold DMCC |
| Gold | Fidelity Printers and Refiners Ltd. |
| Gold | Fujairah Gold FZC |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. |
| Gold | Geib Refining Corporation |
| Gold | Gold Coast Refinery |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM |
| Gold | Guangdong Jinding Gold Limited |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold | Heimerle + Meule GmbH |
| Gold | Heraeus Metals Hong Kong Ltd. |
| Gold | Heraeus Precious Metals GmbH & Co. KG |
| Gold | Hunan Chenzhou Mining Co., Ltd. |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| Gold | HwaSeong CJ CO., LTD. |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| Gold | International Precious Metal Refiners |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Gold | Istanbul Gold Refinery |
| Gold | Italpreziosi |
| Gold | JALAN & Company |
| Gold | Japan Mint |
| Gold | Jiangxi Copper Co., Ltd. |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| Gold | JSC Uralelectromed |
| Gold | JX Nippon Mining & Metals Co., Ltd. |
| Gold | K.A. Rasmussen |
| Gold | Kaloti Precious Metals |
| Gold | Kazakhmys Smelting LLC |
Page 9 of 17
| Metal | Standard Smelter Name |
| Gold | Kazzinc |
| Gold | Kennecott Utah Copper LLC |
| Gold | KGHM Polska Miedz Spolka Akcyjna |
| Gold | Kojima Chemicals Co., Ltd. |
| Gold | Korea Zinc Co., Ltd. |
| Gold | Kundan Care Products Ltd. |
| Gold | Kyrgyzaltyn JSC |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO |
| Gold | L'azurde Company For Jewelry |
| Gold | Lingbao Gold Co., Ltd. |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| Gold | L'Orfebre S.A. |
| Gold | LS-NIKKO Copper Inc. |
| Gold | LT Metal Ltd. |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| Gold | Marsam Metals |
| Gold | Materion |
| Gold | Matsuda Sangyo Co., Ltd. |
| Gold | MD Overseas |
| Gold | Metal Concentrators SA (Pty) Ltd. |
| Gold | Metallix Refining Inc. |
| Gold | Metalor Technologies (Hong Kong) Ltd. |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. |
| Gold | Metalor Technologies (Suzhou) Ltd. |
| Gold | Metalor Technologies S.A. |
| Gold | Metalor USA Refining Corporation |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. |
| Gold | Mitsubishi Materials Corporation |
| Gold | Mitsui Mining and Smelting Co., Ltd. |
| Gold | MMTC-PAMP India Pvt., Ltd. |
| Gold | Modeltech Sdn Bhd |
| Gold | Morris and Watson |
| Gold | Moscow Special Alloys Processing Plant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. |
| Gold | Navoi Mining and Metallurgical Combinat |
| Gold | NH Recytech Company |
| Gold | Nihon Material Co., Ltd. |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
| Gold | Ohura Precious Metal Industry Co., Ltd. |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
Page 10 of 17
| Metal | Standard Smelter Name |
| Gold | OJSC Novosibirsk Refinery |
| Gold | PAMP S.A. |
| Gold | Pease & Curren |
| Gold | Penglai Penggang Gold Industry Co., Ltd. |
| Gold | Planta Recuperadora de Metales SpA |
| Gold | Prioksky Plant of Non-Ferrous Metals |
| Gold | PT Aneka Tambang (Persero) Tbk |
| Gold | PX Precinox S.A. |
| Gold | QG Refining, LLC |
| Gold | Rand Refinery (Pty) Ltd. |
| Gold | Refinery of Seemine Gold Co., Ltd. |
| Gold | REMONDIS PMR B.V. |
| Gold | Royal Canadian Mint |
| Gold | SAAMP |
| Gold | Sabin Metal Corp. |
| Gold | Safimet S.p.A |
| Gold | SAFINA A.S. |
| Gold | Sai Refinery |
| Gold | Samduck Precious Metals |
| Gold | Samwon Metals Corp. |
| Gold | Sancus ZFS (L’Orfebre, SA) |
| Gold | SAXONIA Edelmetalle GmbH |
| Gold | Sellem Industries Ltd. |
| Gold | SEMPSA Joyeria Plateria S.A. |
| Gold | Shandong Humon Smelting Co., Ltd. |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. |
| Gold | Shirpur Gold Refinery Ltd. |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. |
| Gold | Singway Technology Co., Ltd. |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals |
| Gold | Solar Applied Materials Technology Corp. |
| Gold | Sovereign Metals |
| Gold | State Research Institute Center for Physical Sciences and Technology |
| Gold | Sudan Gold Refinery |
| Gold | Sumitomo Metal Mining Co., Ltd. |
| Gold | SungEel HiMetal Co., Ltd. |
| Gold | T.C.A S.p.A |
| Gold | Tanaka Kikinzoku Kogyo K.K. |
Page 11 of 17
| Metal | Standard Smelter Name |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. |
| Gold | Tokuriki Honten Co., Ltd. |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. |
| Gold | Tony Goetz NV |
| Gold | TOO Tau-Ken-Altyn |
| Gold | Torecom |
| Gold | Umicore Precious Metals Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining |
| Gold | United Precious Metal Refining, Inc. |
| Gold | Valcambi S.A. |
| Gold | Western Australian Mint (T/a The Perth Mint) |
| Gold | WIELAND Edelmetalle GmbH |
| Gold | Yamakin Co., Ltd. |
| Gold | Yokohama Metal Co., Ltd. |
| Gold | Yunnan Copper Industry Co., Ltd. |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Tantalum | Asaka Riken Co., Ltd. |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. |
| Tantalum | D Block Metals, LLC |
| Tantalum | Exotech Inc. |
| Tantalum | F&X Electro-Materials Ltd. |
| Tantalum | FIR Metals & Resource Ltd. |
| Tantalum | Global Advanced Metals Aizu |
| Tantalum | Global Advanced Metals Boyertown |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. |
| Tantalum | H.C. Starck Co., Ltd. |
| Tantalum | H.C. Starck Hermsdorf GmbH |
| Tantalum | H.C. Starck Inc. |
| Tantalum | H.C. Starck Ltd. |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| Tantalum | Jiangxi Tuohong New Raw Material |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| Tantalum | Jiujiang Tanbre Co., Ltd. |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| Tantalum | KEMET Blue Metals |
| Tantalum | LSM Brasil S.A. |
| Tantalum | Metallurgical Products India Pvt., Ltd. |
Page 12 of 17
| Metal | Standard Smelter Name |
| Tantalum | Mineracao Taboca S.A. |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum | NPM Silmet AS |
| Tantalum | Power Resources Ltd. |
| Tantalum | QuantumClean |
| Tantalum | Resind Industria e Comercio Ltda. |
| Tantalum | Solikamsk Magnesium Works OAO |
| Tantalum | Taki Chemical Co., Ltd. |
| Tantalum | Telex Metals |
| Tantalum | Ulba Metallurgical Plant JSC |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| Tin | Alpha |
| Tin | An Vinh Joint Stock Mineral Processing Company |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. |
| Tin | China Tin Group Co., Ltd. |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
| Tin | CRM Synergies |
| Tin | CV Ayi Jaya |
| Tin | CV Venus Inti Perkasa |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| Tin | Dowa |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| Tin | EM Vinto |
| Tin | Estanho de Rondonia S.A. |
| Tin | Fenix Metals |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. |
| Tin | Gejiu Fengming Metallurgy Chemical Plant |
| Tin | Gejiu Kai Meng Industry and Trade LLC |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
| Tin | HuiChang Hill Tin Industry Co., Ltd. |
| Tin | Jiangxi New Nanshan Technology Ltd. |
| Tin | Luna Smelter, Ltd. |
| Tin | Ma'anshan Weitai Tin Co., Ltd. |
| Tin | Magnu's Minerais Metais e Ligas Ltda. |
Page 13 of 17
| Metal | Standard Smelter Name |
| Tin | Malaysia Smelting Corporation (MSC) |
| Tin | Melt Metais e Ligas S.A. |
| Tin | Metallic Resources, Inc. |
| Tin | Metallo Belgium N.V. |
| Tin | Metallo Spain S.L.U. |
| Tin | Mineracao Taboca S.A. |
| Tin | Minsur |
| Tin | Mitsubishi Materials Corporation |
| Tin | Modeltech Sdn Bhd |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Tin | Novosibirsk Processing Plant Ltd. |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin | O.M. Manufacturing Philippines, Inc. |
| Tin | Operaciones Metalurgicas S.A. |
| Tin | Pongpipat Company Limited |
| Tin | Precious Minerals and Smelting Limited |
| Tin | PT Aries Kencana Sejahtera |
| Tin | PT Artha Cipta Langgeng |
| Tin | PT ATD Makmur Mandiri Jaya |
| Tin | PT Babel Surya Alam Lestari |
| Tin | PT Bangka Serumpun |
| Tin | PT Lautan Harmonis Sejahtera |
| Tin | PT Menara Cipta Mulia |
| Tin | PT Mitra Stania Prima |
| Tin | PT Mitra Sukses Globalindo |
| Tin | PT Prima Timah Utama |
| Tin | PT Rajawali Rimba Perkasa |
| Tin | PT Rajehan Ariq |
| Tin | PT Refined Bangka Tin |
| Tin | PT Stanindo Inti Perkasa |
| Tin | PT Timah Tbk Kundur |
| Tin | PT Timah Tbk Mentok |
| Tin | PT Tinindo Inter Nusa |
| Tin | Resind Industria e Comercio Ltda. |
| Tin | Rui Da Hung |
| Tin | Soft Metais Ltda. |
| Tin | Super Ligas |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. |
| Tin | Thaisarco |
| Tin | Tin Technology & Refining |
Page 14 of 17
| Metal | Standard Smelter Name |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| Tin | White Solder Metalurgia e Mineracao Ltda. |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tin | Yunnan Tin Company Limited |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
| Tungsten | A.L.M.T. Corp. |
| Tungsten | ACL Metais Eireli |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
| Tungsten | Artek LLC |
| Tungsten | Asia Tungsten Products Vietnam Ltd. |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. |
| Tungsten | China Molybdenum Co., Ltd. |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. |
| Tungsten | Cronimet Brasil Ltda |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten | GEM Co., Ltd. |
| Tungsten | Global Tungsten & Powders Corp. |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG |
| Tungsten | H.C. Starck Tungsten GmbH |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. |
| Tungsten | Hydrometallurg, JSC |
| Tungsten | Japan New Metals Co., Ltd. |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" |
| Tungsten | Kennametal Fallon |
| Tungsten | Kennametal Huntsville |
| Tungsten | KGETS Co., Ltd. |
| Tungsten | Lianyou Metals Co., Ltd. |
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| Metal | Standard Smelter Name |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten | Masan Tungsten Chemical LLC (MTC) |
| Tungsten | Moliren Ltd. |
| Tungsten | Niagara Refining LLC |
| Tungsten | NPP Tyazhmetprom LLC |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. |
| Tungsten | Unecha Refractory metals plant |
| Tungsten | Wolfram Bergbau und Hutten AG |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
| Tungsten | Xiamen Tungsten Co., Ltd. |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
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APPENDIX B
Countries of Origin
Based on the information that was obtained from our RCOI and due diligence, the Company has reasonably determined that countries of origin of the Conflict Minerals in the Covered Products may include the countries listed below:
Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo, Democratic Republic of the, Czech Republic, Djibouti, Dominican Republic, 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 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, Vietnam, Zambia, Zimbabwe.
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