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Section 1: SD (SD)

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549




FORM SD

SPECIALIZED DISCLOSURE REPORT


__________________________________________

ILLINOIS TOOL WORKS INC.
(Exact name of registrant as specified in its charter)
__________________________________________



Delaware
1-4797
36-1258310
(State or other jurisdiction of incorporation or organization)
(Commission File Number)
(I.R.S. Employer Identification No.)
 
 
 
155 Harlem Avenue, Glenview, IL
 
60025
(Address of principal executive offices)
 
(Zip Code)

Janet O. Love (224-661-7778)
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:

[ X ]
Rule 13p-1 under the Securities Exchange Act (17CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017.








Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

As provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report is provided as an Exhibit to this Form SD and is available on our website at www.itw.com.

Item 1.02 Exhibits

The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 2 - Exhibits

Item 2.01 Exhibits

1.01    Conflict Minerals Report for the calendar year ended December 31, 2017.
















































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.



 
ILLINOIS TOOL WORKS INC.
 
 
 
 
Dated: May 31, 2018
By: /s/ CHRISTOPHER A. O'HERLIHY
 
Christopher A. O’Herlihy
 
Vice Chairman













































EXHIBIT INDEX
    
Exhibit
 
Description
 



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Section 2: EX-1.01 (EXHIBIT 1.01)

Exhibit


Exhibit 1.01

Conflict Minerals Report
I.
Introduction

A.
Our Business

Illinois Tool Works Inc. is a global manufacturer of a diversified range of industrial products and equipment with 85 divisions in 56 countries, and has prepared this Conflict Minerals Report for calendar year 2017 as provided for in Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended, and Form SD (together referred to as the "Conflict Minerals Rule"). Unless the context indicates otherwise, the terms “Company,” “ITW,” “we,” “its,” “us” and “our” refer to Illinois Tool Works Inc. and its consolidated subsidiaries. “Conflict minerals” or “3TG” as used in this report, refers to cassiterite, columbite-tantalite, gold, wolframite and their derivatives, tin, tantalum, tungsten and/or gold, without regard to their location of origin.
The Company’s operations are reported as the following segments: Automotive OEM; Food Equipment; Test & Measurement and Electronics; Welding; Polymers & Fluids; Construction Products; and Specialty Products. Each of our segments manufactures certain products that contain 3TG that are necessary to the functionality or production of the products (which we sometimes refer to herein as "in-scope" products). ITW’s in-scope products collectively contain all four 3TGs.

B.
Reasonable Country of Origin Inquiry and Due Diligence Overview

As provided for in the Conflict Minerals Rule, we conducted a "reasonable country of origin inquiry" ("RCOI"), designed in good faith to determine the origin of the 3TG that are contained in our in-scope products. See Section II. Reasonable Country of Origin Inquiry for a description of our RCOI process for 2017.

If the Company has reason to believe that any of the 3TG in our supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”), or we are unable to determine the country of origin of the 3TG, we exercise due diligence on the source and chain of custody of the 3TG and include a description of our due diligence measures in this Conflict Minerals Report. On the basis of our RCOI, we have determined that some of the 3TG contained in our products originated from a Covered Country, and we are therefore submitting this Conflict Minerals Report, which describes the due diligence we have performed pursuant to the Conflict Minerals Rule and our related processes and procedures. This report is filed as an exhibit to our Form SD and is available on our website at http://www.itw.com/about-itw/suppliers/. Information contained on our website or otherwise actively linked to this Conflict Minerals Report is not part of or incorporated by reference into this Conflict Minerals Report or our Form SD.

C.
ITW’s Position in the Supply Chain

Most of our businesses are many levels removed from 3TG mining, smelting and processing facilities, and we have no relationships with mines. We therefore require the cooperation of our supply chain to provide information on smelters and refiners (“SORs”) as well as the origin of 3TG contained in our products, and we rely on the Responsible Minerals Initiative (the “RMI,” formerly known as the Conflict-Free Sourcing Initiative), whose mission is to help companies make sourcing decisions to improve regulatory compliance while supporting responsible sourcing from conflict-affected and high risk areas, and to manage the Responsible Minerals Assurance Process (the “RMAP”), which conducts and recognizes independent, third-party audits of SORs. We are a member of the RMI and actively participate in its initiatives, as discussed later in this Conflict Minerals Report.

D.
Responsible Sourcing Commitment

Through the efforts described in this Conflict Minerals Report, we seek to ensure that our suppliers responsibly source 3TG. Our responsible sourcing goes beyond compliance with the Conflict Minerals Rule, however, and our Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) mandates compliance with all laws, and in particular prohibits use of child labor, forced labor, and discrimination, and mandates compliance with safety rules, wage and hour laws, and anti-bribery laws.

E.
Smelter and Refiner and Country of Origin Information

The Company’s in-scope products that contain 3TG that originated or might have originated from a Covered Country are described in Section IV. Product Information. Information about SORs relating to these in-scope products is described in Section V. Identified Smelters and Refiners and on Annex A. We have not found for 2017 that any of the necessary 3TG contained in our in-scope products directly or indirectly financed or benefited armed groups in a Covered Country. However, we have not declared

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that any of our products are “DRC conflict free.” The terms "adjoining country," "armed group," and "DRC conflict free" have the meanings contained in the Conflict Minerals Rule.

F.
2017 Program Enhancements

For 2017, we took the following actions to enhance our RCOI and conflict minerals due diligence and mitigate sourcing risk. These actions build on further insights after several years of engaging in this process, and the 2016 enhancements described in our Conflict Minerals Report for that year.
    
Enhanced Identification of In-Scope Products and Suppliers

We enhanced training and materials for our internal 3TG compliance participants;

Enhanced Smelter Outreach

We continued our participation in the RMI’s due diligence practices, multi-stakeholder and plenary teams and increased our participation in its smelter engagement team and in the Automotive Industry Action Group’s (“AIAG”) Conflict Minerals Working Group;

General Process Enhancements

Additional data was made available to our internal sourcing team showing the progress of each of our locations in the RCOI process;
We increased the level of assistance and support for our 3TG compliance team across the enterprise;
We continued to revise and simplify our written communications and instructions to our businesses regarding supplier red flag follow-up to enhance program effectiveness; and
We continued providing information and assistance at our enterprise-wide strategic sourcing conference, including a responsible sourcing training presentation covering 3TG, other materials of concern and modern slavery.

II.
Reasonable Country of Origin Inquiry

Our RCOI utilized management systems recommended by the first step of the Organisation for Economic Co-operation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (the “OECD Guidance”), and was conducted in accordance with the second step of the OECD Guidance. Selected elements of our program design and RCOI process are discussed below. However, these are not all of the discrete elements of the program that we have put in place in accordance with these steps of the OECD Guidance to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the first and second steps.

A.
Establish Strong Management Systems

1.    ITW Policies

ITW has adopted a company-wide Conflict Minerals Policy Statement (the "Conflict Minerals Policy"), which has been approved by ITW’s Chief Executive Officer and is available in seven languages on our website at http://www.itw.com/about-itw/suppliers/page/en/conflict-minerals-policy-statement/. We also provide a copy of ITW’s Conflict Minerals Policy to every potential supplier participating in our online bid portal process whose product contains or may contain 3TG.

Our Conflict Minerals Policy states that we do not knowingly procure 3TG that originates from the Covered Countries unless they originate from mines or SORs that are certified as having followed established protocols to allow them to be considered “conflict free.” We ask our suppliers to undertake reasonable due diligence with their supply chains to determine whether products containing 3TG used in the manufacture of our products originate from a Covered Country and, if they do originate from a Covered Country, that the SORs be certified as Conformant. The Conflict Minerals Policy encourages our suppliers to continue to support Conformant SORs in the Covered Countries and to make similar requests of their sub-suppliers. If we discover that any 3TG procured by us are produced in a Covered Country from facilities that are not Conformant, we will request that our supplier ask the facility to become Conformant or use our best efforts to transition the product to be from Conformant sources.


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ITW’s Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) sets forth expectations for all ITW suppliers to adhere to the highest ethical standards in the conduct of their business. It also requires suppliers to adhere to specific standards and specifically prohibits certain behaviors associated with 3TG mining and processing, including use of child or forced labor, unsafe working conditions and bribery. The Code of Conduct also requires that, upon request, our suppliers determine whether any products provided by them contain 3TG and to take such actions as necessary to provide the information requested by ITW to conduct its RCOI, as described below under B. Identify and Assess Risk in the Supply Chain.

We do not support a general embargo of sourcing from the Covered Countries, and our Conflict Minerals Policy encourages our suppliers to continue to source from responsible sources in those countries.

2.    Cross Functional Committee

ITW has a cross-functional responsible sourcing committee (the “Committee”). The Committee is headed by ITW’s Vice President of Global Strategic Sourcing & Environmental Health and Safety, who reports to ITW’s Vice Chairman, and includes dedicated employees and representatives from strategic sourcing, environmental, legal, internal audit, IT, corporate communications and selected personnel from various operations. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets as needed to discuss the 3TG compliance process, modern slavery and related developments. Senior management is briefed on the results of our due diligence efforts on a regular basis.

3.    Internal Training

We maintain an intranet conflict minerals website which contains resources, instructions and guidance on the RCOI and due diligence processes to be followed by our businesses that have or may have in-scope products. The site also contains step-by-step instructions for making supplier inquiries, including training videos regarding our RCOI and due diligence process, and can be accessed by all ITW businesses for reference. Our businesses are instructed to view at least one of the training sessions. Training was also presented to attendees of ITW’s global sourcing conference.

4.    Supplier Engagement and Training

In addition to our Conflict Minerals Policy and Supplier Code of Conduct, ITW’s standard “Terms and Conditions” with its suppliers obligates suppliers to take such actions as requested by ITW to enable us to comply with our conflict minerals disclosure requirements. We also include conflict minerals screening questions into incoming supplier bids.

Our supplier invitation letters are translated into eight languages. ITW educates key suppliers through presentations regarding our conflict minerals compliance program during supplier meetings and other interactions. The training is intended to help ensure the quality and completeness of the Conflict Minerals Reporting Templates (“CMRTs”) received from suppliers. We also post information and guidance for suppliers on our Company website and encourage our businesses to share relevant information with suppliers on the process for responding to our RCOI requests for information. See http://www.itw.com/about-itw/suppliers/.

5.    Records Retention

ITW retains its conflict minerals related records for at least five years. These records generally are maintained in an electronic format.

6.    Grievance Mechanism

ITW maintains a web- and telephone-based reporting system (“Helpline”), providing employees with a confidential reporting mechanism by which they can communicate issues and concerns associated with violations of ITW’s Principles of Conduct, which requires all employees to comply with all applicable laws and Company policies, including the Conflict Minerals Policy.
A link to the Helpline is included in our Conflict Minerals Policy on our website to provide convenient access to external stakeholders, suppliers and other third parties to communicate issues and concerns regarding ITW’s supply chain. The contact information for our Helpline is http://www.itwhelpline.ethicspoint.com.

As an RMI member, we also support the use of the RMI’s grievance mechanism for reporting grievances relating to SORs and the RMAP.


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B.    Identify and Assess Risk in the Supply Chain

Our RCOI process was used to survey our potential in-scope suppliers to identify and assess 3TG sourcing risk in our supply chain for the 2017 reporting cycle.

All ITW businesses were requested to identify suppliers furnishing components, parts or products containing or likely to contain 3TG or to confirm that their products do not contain 3TG. Those with products containing or likely to contain 3TG were asked to survey the “80” suppliers (i.e., suppliers representing a significant amount of spend) from that supplier population (we refer to the surveyed suppliers for 2017 as the “Suppliers”). The purpose of the survey was to determine whether 3TG in the components, parts or products from the Suppliers originated or may have originated from a Covered Country and were not from recycled or scrap sources. Businesses were instructed to survey the Suppliers using the then latest version of the RMI’s CMRT. The CMRT requests information regarding 3TG included in suppliers’ products, SOR identity and location, suppliers’ RCOI processes and other information about the suppliers’ 3TG policies and practices. We instructed our businesses to concentrate their outreach on larger suppliers, since these suppliers are the most likely to be recurring suppliers and responsible for a significant portion of the 3TG in our products.

ITW has an established protocol for its supplier inquiry process and uses a third party software vendor to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and in-scope suppliers through use of a cloud-based 3TG tracking tool (the “CM System”).

For 2017, as mentioned above, our businesses were asked to focus their efforts on their larger suppliers that likely had products containing 3TG. As a result, we sent 2,366 requests in eight languages to the Suppliers to provide us with a completed CMRT, as compared to 4,113 requests sent for 2016. A number of our businesses source different products from the same Supplier, which means the total number of unique suppliers is less than the number of Suppliers queried. We received 1,244 CMRTs from the Suppliers surveyed, as compared to 1,768 received for 2016. Our response rate increased from approximately 43% to 52% year-over-year.

The CM System issued automatic weekly follow-up reminders to non-responding Suppliers, and our businesses were given instructions regarding follow-up actions beyond the automatic reminders and in response to receipt of incomplete or incorrect CMRTs.

Our protocol also includes a follow-up process to investigate any CMRTs received that raised “red flags”. See Section III. Due Diligence for a description of the follow-up process.

Our Supplier responses identified 253 SORs verified by the RMI as Conformant. We determined that 214 of these Conformant SORs sourced exclusively from outside the Covered Countries, including in whole or in part from recycled or scrap sources. Our determination was based on country of origin information the RMI has obtained through the RMAP that is made available to RMI members.

Our Supplier responses identified an additional 9 SORs that were listed as “Active” (as later defined in Section III.B.) by the RMI and 52 that were on the Smelter Look-up tab of the CMRT but were not Conformant or Active.

A member of our conflict minerals team participated on the RMI’s Smelter Engagement Team, and, for the 52 SORs that were not listed as Conformant or Active with the RMI, we either asked them to become Conformant or instructed our businesses to request that their suppliers remove them from their supply chains.

Based on the results of our RCOI, we were required to conduct due diligence, as described below.

III.
Due Diligence

A.
Design Framework

ITW´s conflict minerals due diligence process is designed in conformance with the related third, fourth and fifth steps of the OECD Guidance.

B.
Due Diligence Activities

Selected elements of our program design and implementation in furtherance of the third, fourth and fifth steps of the OECD Guidance are discussed below. However, these are not all of the discrete elements of the program that we have put in place pursuant

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to these steps to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the third, fourth and fifth steps. The actions taken by the Company to address the first and second steps of the OECD Guidance are described in Section II. Reasonable Country of Origin Inquiry. See also our 2017 program enhancements discussed in Section I. Introduction.

Design and implement a strategy to respond to identified risks

The SOR information provided by Suppliers in response to the Company’s supplier survey described in Section II.B. was reviewed against the Smelter Look-up tab list in the CMRT. SOR information also was reviewed against the lists of Conformant, Active and other SORs not listed as Conformant or Active and country-of-origin information provided by the RMI and contained in the CM System. “Conformant” SORs have been audited and found conformant with the RMAP assessment protocols, including through mutual recognition and those that are listed as “re-audit in process.” “Active” SORs are those that are taking action to become Conformant.

CMRTs received from our Suppliers that indicated 3TG from a source within a Covered Country or that contained inconsistent SOR information triggered a “red flag” in the CM System, and communications with the flagged Suppliers were escalated. Businesses and their respective flagged Suppliers indicating 3TG from a source within a Covered Country were asked to provide additional information, and our businesses were given written guidance and instructions for these Supplier communications. The escalated Supplier responses were evaluated on a case-by-case basis. Suppliers with CMRTs containing inconsistent SOR information were asked to resubmit a corrected CMRT.

In addition, we either reached out directly to the SORs that were not listed as Conformant or Active by the RMI and asked them to become Conformant, or instructed our businesses to request that their Suppliers remove them from their supply chains. SORs that were categorized by the RMI as “not applicable” were not addressed in our outreach efforts, as the RMI has determined that these are either not SORs or not in operation. To the extent that identified SORs are not Conformant, we also seek to exercise leverage over these SORs to become Conformant through our participation in and support of the RMI and its Smelter Engagement Team. We also utilize information provided by the RMI to its members to monitor SOR improvement.

In 2017, we continued to revise and simplify our written communications and instructions to our businesses regarding Supplier red flag follow-up to enhance program effectiveness.

Our 3TG compliance team reported the findings from its RCOI and due diligence process to our Vice President of Global Strategic Sourcing, and these results were in turn discussed with senior management.

Carry out independent third party audit of supply chain diligence at identified points in the supply chain

The Company continued its membership in the RMI for 2017. Due to our location in the mineral supply chain, which is discussed earlier in this Conflict Minerals Report, we support and utilize the RMI’s RMAP to perform third-party audits of SORs.

Report annually on supply chain due diligence

We describe our supply chain due diligence efforts in our Conflict Minerals Report. We prepare this report annually, post it on our website and file it with the SEC as an exhibit to our annual Form SD. Once filed, the Form SD and Conflict Minerals Report become available on our website. We also mention our efforts in the area of conflict minerals in our annual Corporate Social Responsibility Report, which is available on our website at https://itw-csr.com/.















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IV.
Product Information

For 2017, our in-scope products that contain 3TG that originated or might have originated from a Covered Country included products in each of the categories below:

Arc welding and cutting equipment and consumables
Inspection equipment
Automotive components
LEDs
Catalysts
Marking and coding equipment
Commercial cooking equipment
Measuring equipment
Commercial food equipment
Mixers
Commercial refrigerators
Motors
Cutting equipment
Printers and dispensers
Electrical devices
Production equipment
Electronic components
Sealants
Electronic equipment
Sealing equipment
Fastening tools
Soldering equipment
Flow control meters
Switches, capacitors and electronics
Household appliances
Testing equipment
Industrial equipment
Welding hardware
Industrial ovens
Wire
Industrial warewashers
 

V.
Identified Smelters and Refiners

Our Supplier responses identified 253 SORs that were on the RMI Conformant list, 9 that were listed as Active with the RMI and 52 that were on the Smelter Look-up tab list of the CMRT but not Conformant or Active with the RMI. These facilities are listed on Annex A. The information in Annex A includes only the information and entities identified by our Suppliers as SORs that were on the Smelter Look-up tab list contained in the CM System as of March 26, 2018, which are those entities identified to us that we were able to determine were SORs. Entities identified by our Suppliers that are not on Annex A have been submitted to the RMI to support their ongoing effort to identify and audit all 3TG SORs.

Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our Suppliers for accurate SOR information, and our RCOI and due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products. The information that we received from most of our Suppliers was made at a company or user defined level, rather than at a product level, meaning that such Suppliers provided information on all of their products that contained 3TG, not just the products that were sold to us. Therefore, our list of SORs disclosed in Annex A may contain facilities that did not process the 3TG contained in our products. In addition, the identified SORs may not include all SORs present in our in-scope product supply chain, since we do not have a response from all Suppliers surveyed, some Suppliers were unable to identify all of the SORs in their supply chain and because we surveyed only the larger suppliers of products containing or potentially containing 3TG.

Annex A includes information concerning the locations of the SORs listed. We applied the information made available to RMI members regarding the countries of origin of these SORs and have not found for 2017 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country. However, we have not declared that any of our products are “DRC conflict free.”

VI.
Additional Risk Mitigation

In addition to the actions described elsewhere in this Conflict Minerals Report, we intend to take or continue the following steps in respect of our 2018 compliance to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:

Continue to analyze and review our current processes to improve their effectiveness and efficiency.

Continue to analyze spend data against supplier response data to identify inconsistencies and areas of potential enhanced focus for supplier outreach efforts.

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Engage with Suppliers that provided incomplete responses or that did not provide responses for 2017 to help ensure that they will provide requested information for 2018.

Continue to enhance supplier communication and training to improve RCOI and due diligence data accuracy and completion.
        
Continue to seek to influence non-Conformant SORs in our supply chain to obtain a Conformant certification.

Continue our membership in the RMI and participation in its Plenary, Multi-Stakeholder, Due Diligence and Smelter Engagement Teams and support the RMI’s RMAP program.

Continue our membership and participation in the Automotive Industry Action Group’s (AIAG) Conflict Minerals Working Group.

Continue to submit to the RMI facilities identified by our Suppliers that are not on the Smelter Look-up tab list, to support the RMI's ongoing effort to identify and audit all 3TG SORs.

VII.
Forward Looking Statements

This report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements include expectations concerning the Company’s future actions to identify improvements to our due diligence processes, to engage with our suppliers, and to take other actions regarding our product sourcing. These statements are subject to certain risks, uncertainties and other factors, including but not limited to, incomplete information from industry or other third party sources, continuing guidance regarding the Conflict Minerals Rule, decisions to make changes to our continual improvement efforts and delays or difficulties in engaging suppliers and/or transitioning sources of product containing 3TG.

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Annex A to Exhibit 1.01
RMI Smelters and Refiners

Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Conformant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Conformant
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Conformant
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Conformant
Gold
Argor-Heraeus S.A.
SWITZERLAND
Conformant
Gold
Asahi Pretec Corp.
JAPAN
Conformant
Gold
Asahi Refining Canada Ltd.
CANADA
Conformant
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Conformant
Gold
Asaka Riken Co., Ltd.
JAPAN
Conformant
Gold
AU Traders and Refiners
SOUTH AFRICA
Conformant
Gold
Aurubis AG
GERMANY
Conformant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Conformant
Gold
Boliden AB
SWEDEN
Conformant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Conformant
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Conformant
Gold
Cendres + Metaux S.A.
SWITZERLAND
Conformant
Gold
Chimet S.p.A.
ITALY
Conformant
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Conformant
Gold
Dowa
JAPAN
Conformant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Conformant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Conformant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Conformant
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Conformant
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Heimerle + Meule GmbH
GERMANY
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Conformant
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Conformant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
Istanbul Gold Refinery
TURKEY
Conformant
Gold
Italpreziosi
ITALY
Conformant
Gold
Japan Mint
JAPAN
Conformant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Conformant

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Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Conformant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Conformant
Gold
Kazzinc
KAZAKHSTAN
Conformant
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Conformant
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Conformant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Conformant
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Conformant
Gold
Marsam Metals
BRAZIL
Conformant
Gold
Materion
UNITED STATES OF AMERICA
Conformant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Conformant
Gold
Metalor Technologies S.A.
SWITZERLAND
Conformant
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Conformant
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Conformant
Gold
Mitsubishi Materials Corporation
JAPAN
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Conformant
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Conformant
Gold
Nihon Material Co., Ltd.
JAPAN
Conformant
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Conformant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Conformant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Conformant
Gold
PAMP S.A.
SWITZERLAND
Conformant
Gold
Planta Recuperadora de Metales SpA
CHILE
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Conformant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Conformant
Gold
PX Precinox S.A.
SWITZERLAND
Conformant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Conformant
Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
Conformant
Gold
Royal Canadian Mint
CANADA
Conformant
Gold
SAAMP
FRANCE
Conformant
Gold
Safimet S.p.A
ITALY
Conformant
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Conformant
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Conformant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Conformant

9



Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Conformant
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Conformant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Conformant
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Conformant
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Conformant
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Conformant
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
T.C.A S.p.A
ITALY
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Conformant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Conformant
Gold
Torecom
KOREA, REPUBLIC OF
Conformant
Gold
Umicore Brasil Ltda.
BRAZIL
Conformant
Gold
Umicore Precious Metals Thailand
THAILAND
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Conformant
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Conformant
Gold
Valcambi S.A.
SWITZERLAND
Conformant
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Conformant
Gold
WIELAND Edelmetalle GmbH
GERMANY
Conformant
Gold
Yamakin Co., Ltd.
JAPAN
Conformant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Conformant
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Conformant
Gold
Bangalore Refinery
INDIA
Active
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Active
Gold
L'Orfebre S.A.
ANDORRA
Active
Gold
Modeltech Sdn Bhd
MALAYSIA
Active
Gold
Remondis Argentia B.V.
NETHERLANDS
Active
Gold
SAFINA A.S.
CZECH REPUBLIC
Active
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
On Smelter Look-up List
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
On Smelter Look-up List
Gold
Caridad
MEXICO
On Smelter Look-up List
Gold
Chugai Mining
JAPAN
On Smelter Look-up List
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
On Smelter Look-up List
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
On Smelter Look-up List
Gold
Elemetal Refining, LLC
UNITED STATES OF AMERICA
On Smelter Look-up List
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
On Smelter Look-up List
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
On Smelter Look-up List
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
On Smelter Look-up List
Gold
Guangdong Jinding Gold Limited
CHINA
On Smelter Look-up List

10



Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
On Smelter Look-up List
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
On Smelter Look-up List
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
On Smelter Look-up List
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
On Smelter Look-up List
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
On Smelter Look-up List
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
On Smelter Look-up List
Gold
Lingbao Gold Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Morris and Watson
NEW ZEALAND
On Smelter Look-up List
Gold
Morris and Watson Gold Coast
AUSTRALIA
On Smelter Look-up List
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
On Smelter Look-up List
Gold
Pease & Curren
UNITED STATES OF AMERICA
On Smelter Look-up List
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
On Smelter Look-up List
Gold
Sai Refinery
INDIA
On Smelter Look-up List
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
On Smelter Look-up List
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
On Smelter Look-up List
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
On Smelter Look-up List
Gold
Sudan Gold Refinery
SUDAN
On Smelter Look-up List
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Tony Goetz NV
BELGIUM
On Smelter Look-up List
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
On Smelter Look-up List
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
On Smelter Look-up List
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
On Smelter Look-up List
Tantalum
Asaka Riken Co., Ltd.
JAPAN
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Conformant
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Conformant
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Conformant
Tantalum
F&X Electro-Materials Ltd.
CHINA
Conformant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Conformant
Tantalum
Global Advanced Metals Aizu
JAPAN
Conformant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Conformant
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Conformant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Conformant
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Conformant

11



Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Conformant
Tantalum
H.C. Starck Ltd.
JAPAN
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Conformant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Conformant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
KEMET Blue Metals
MEXICO
Conformant
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Conformant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Conformant
Tantalum
LSM Brasil S.A.
BRAZIL
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Conformant
Tantalum
Mineracao Taboca S.A.
BRAZIL
Conformant
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Conformant
Tantalum
NPM Silmet AS
ESTONIA
Conformant
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Conformant
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Conformant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Conformant
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Conformant
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Conformant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Conformant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Conformant
Tantalum
Duoluoshan
CHINA
On Smelter Look-up List
Tin
Alpha
UNITED STATES OF AMERICA
Conformant
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Conformant
Tin
China Tin Group Co., Ltd.
CHINA
Conformant
Tin
CV Ayi Jaya
INDONESIA
Conformant
Tin
CV Dua Sekawan
INDONESIA
Conformant
Tin
CV Gita Pesona
INDONESIA
Conformant
Tin
CV Tiga Sekawan
INDONESIA
Conformant
Tin
CV United Smelting
INDONESIA
Conformant
Tin
CV Venus Inti Perkasa
INDONESIA
Conformant
Tin
Dowa
JAPAN
Conformant
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Conformant

12



Tin
Fenix Metals
POLAND
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Conformant
Tin
Gejiu Jinye Mineral Company
CHINA
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Conformant
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Conformant
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Conformant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Conformant
Tin
Melt Metais e Ligas S.A.
BRAZIL
Conformant
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Conformant
Tin
Metallo Belgium N.V.
BELGIUM
Conformant
Tin
Metallo Spain S.L.U.
SPAIN
Conformant
Tin
Mineracao Taboca S.A.
BRAZIL
Conformant
Tin
Minsur
PERU
Conformant
Tin
Mitsubishi Materials Corporation
JAPAN
Conformant
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Conformant
Tin
Operaciones Metalurgical S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
Tin
PT Aries Kencana Sejahtera
INDONESIA
Conformant
Tin
PT Artha Cipta Langgeng
INDONESIA
Conformant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Conformant
Tin
PT Babel Inti Perkasa
INDONESIA
Conformant
Tin
PT Bangka Prima Tin
INDONESIA
Conformant
Tin
PT Bangka Tin Industry
INDONESIA
Conformant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Conformant
Tin
PT Bukit Timah
INDONESIA
Conformant
Tin
PT DS Jaya Abadi
INDONESIA
Conformant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Conformant
Tin
PT Inti Stania Prima
INDONESIA
Conformant
Tin
PT Karimun Mining
INDONESIA
Conformant
Tin
PT Kijang Jaya Mandiri
INDONESIA
Conformant
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Conformant
Tin
PT Menara Cipta Mulia
INDONESIA
Conformant
Tin
PT Mitra Stania Prima
INDONESIA
Conformant
Tin
PT O.M. Indonesia
INDONESIA
Conformant
Tin
PT Panca Mega Persada
INDONESIA
Conformant
Tin
PT Premium Tin Indonesia
INDONESIA
Conformant
Tin
PT Prima Timah Utama
INDONESIA
Conformant
Tin
PT Refined Bangka Tin
INDONESIA
Conformant

13



Tin
PT Sariwiguna Binasentosa
INDONESIA
Conformant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Conformant
Tin
PT Sukses Inti Makmur
INDONESIA
Conformant
Tin
PT Sumber Jaya Indah
INDONESIA
Conformant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Conformant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Conformant
Tin
PT Tinindo Inter Nusa
INDONESIA
Conformant
Tin
PT Tommy Utama
INDONESIA
Conformant
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Conformant
Tin
Soft Metais Ltda.
BRAZIL
Conformant
Tin
Thaisarco
THAILAND
Conformant
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Conformant
Tin
Yunnan Tin Company Limited
CHINA
Conformant
Tin
Modeltech Sdn Bhd
MALAYSIA
Active
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
On Smelter Look-up List
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
On Smelter Look-up List
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
On Smelter Look-up List
Tin
Estanho de Rondonia S.A.
BRAZIL
On Smelter Look-up List
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
On Smelter Look-up List
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
On Smelter Look-up List
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
On Smelter Look-up List
Tin
Super Ligas
BRAZIL
On Smelter Look-up List
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
On Smelter Look-up List
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Conformant
Tungsten
ACL Metais Eireli
BRAZIL
Conformant
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Conformant
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Conformant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Conformant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Conformant

14



Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Conformant
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Conformant
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Conformant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Conformant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Conformant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Conformant
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Conformant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Active
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
Active
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
On Smelter Look-up List
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
On Smelter Look-up List
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
On Smelter Look-up List

Country of Origin Information

The countries of origin of the 3TG processed by the Conformant SORs listed above may have included minerals from the respective countries listed below. The listed countries of origin are derived from information made available by the RMI to its members. Except for the DRC, the RMI does not indicate individual countries of origin of the 3TG processed by Conformant SORs. Instead, the RMI indicates country of origin by category. Conformant SORs listed above sourced minerals directly and/or indirectly (second tier smelter) from one or more of the following categories: L1, countries not identified as conflict regions or plausible areas of smuggling or export of 3TG from the DRC and its nine adjoining countries; L2, countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG; L3, which includes the DRC and its nine adjoining countries; and/or the DRC.

L1: Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, the Russian Federation, Senegal, Sierra Leone, Spain, Thailand, Togo, the

15



United Kingdom of Great Britain and Northern Ireland, the United States of America, Uzbekistan, Vietnam, Zimbabwe
L2: Mozambique, South Africa
L3: Burundi, Rwanda, Uganda
DRC: Democratic Republic of the Congo

In addition, according to information made available by the RMI to its members, some of the listed SORs processed 3TG originating solely from recycled or scrap sources and others processed both recycled and scrap content and newly mined content from one or more of the regions indicated above.

Because the RMI generally does not indicate individual countries of origin of the 3TG processed by Conformant SORs, we were not able to determine the countries of origin of the 3TG processed by the listed Conformant SORs with greater specificity. In addition, for some of the listed Conformant SORs, origin information is not disclosed. We did not determine the countries of origin of the 3TG processed by any other SORs listed on this Annex A.



16
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