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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)

Ana Sempertegui
Assistant General Counsel
847-724-7500
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, 2019.








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 the Company’s website at www.itw.com/about-itw/suppliers. Information contained on the Company’s website is not part of, or incorporated by reference into, this Form SD or the Conflict Minerals Report.

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, 2019.









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.


By: /s/ Christopher A. O'Herlihy                    Dated: May 28, 2020
Christopher A. O’Herlihy
Vice Chairman



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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 84 divisions in 53 countries, and has prepared this Conflict Minerals Report for calendar year 2019 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,” “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 2019.

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 (with the DRC, 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. We have included 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 in-scope products may have 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

ITW is a “downstream company” as defined by 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 (Third Edition) (the “OECD Guidance”). Most of our businesses are many levels removed from 3TG mining, smelting and processing facilities, and we have no relationships with mines. We source materials and components from suppliers who in turn source their materials and components from sub-tier suppliers, and therefore, we 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. Due to our position in the supply chain, we utilize 3TG source information provided by the Responsible Minerals Initiative (the “RMI”), whose stated mission is to provide companies with tools and resources to make sourcing decisions that improve regulatory compliance and support responsible sourcing from conflict-affected and high-risk areas. RMI also manages the Responsible Minerals Assurance Process (the “RMAP”), which implements a risk-based audit program for SORs. We are a member of the RMI (member identifier = ITWI) 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 humane

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treatment and 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. For 2019, we have not found that any of the 3TG contained in our in-scope products directly or indirectly financed or benefited armed groups in a Covered Country. However, we have not concluded that any of our products are “DRC conflict free.” Information about SORs relating to our in-scope products containing 3TG is described in Section V. Identified Smelters and Refiners and on Annex A.
The terms “adjoining country,” “armed group,” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.
F.
2019 Program Enhancements

For 2019, we took the following actions to enhance our RCOI and 3TG due diligence and mitigate sourcing risk. These actions build on our insights after several years of engaging in this process and on the 2018 enhancements described in our Conflict Minerals Report for that year.

Enhanced Smelter Outreach

We continued our active participation in the RMI’s due diligence practices, multi-stakeholder and plenary teams and smelter engagement team, contributing perspective and recommendations we believe to be of benefit to all members;

We continued our active participation in the Automotive Industry Action Group’s (“AIAG”) Responsible Materials Working Group and joined their smelter engagement team, contributing Tier 1 perspective and insight;

We sent tailored communications to smelters believed to be in our supply chain who are scheduled to undergo RMI re-audit, encouraging them to go through the re-audit process;

We contributed to RMI’s Initial Audit Fund;

General Process Enhancements

We benchmarked our 3TG compliance and disclosure against peer companies and other selected “best practice” customers and companies;

We continued to strengthen, revise and simplify our written communications, reminders and instructions to our businesses regarding supplier selection and supplier red flag follow-up to enhance the effectiveness of our 3TG compliance program; in particular, we believe that our enhancements in 2019 relating to reminders resulted in part in an improvement in our supplier response rate, which increased by 10% from our rate in 2018;

We continued providing compliance information and assistance at our global strategic sourcing conference, including a responsible sourcing training presentation covering 3TG, other materials of concern and modern slavery;

We integrated, and will continue to integrate updates of, the results of our conflict minerals supplier surveys into our supplier risk assessment platform to assist our businesses in their supplier assessment processes; and

We intend to continue our internal audit review of the operation of our 3TG compliance program and processes every three years.

In addition, we have taken the following actions to continuously improve our sourcing processes beyond our 3TG RCOI and due diligence.


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Further Continuous Improvement
We continued to revisit and enhance our internal responsible sourcing webpage, which is used to inform our businesses as to recent responsible sourcing developments, including relating to cobalt, upcoming European Union conflict minerals requirements and RMI resources available to our businesses as part of our RMI membership;

We transferred our responsible sourcing newsletters, intended to inform our businesses as to bigger picture responsible sourcing developments, into a separate internal webpage, which we update regularly; and

We are considering responsible sourcing risks relating to the principal minerals in our products (in addition to 3TG), including by reviewing third-party risk assessments.

II.
Reasonable Country of Origin Inquiry

Our RCOI utilized management systems recommended by the first step of 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 the 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 Chairman and 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 potential suppliers participating in our online bid portal process whose products contain or may contain 3TG.

Our Conflict Minerals Policy, which was most recently updated in February 2019, states that:

We do not knowingly procure 3TG that originates from Covered Countries unless processed by SORs that are verified or in the process of becoming verified as “conflict free.”

Our due diligence processes and efforts conform to the relevant portions of the OECD Guidance.

Our due diligence requests to our suppliers are supported by our Supplier Code of Conduct, which is described below.

If we discover that products procured by us contain 3TG from the Covered Countries that are processed by facilities that are not third party-verified or in the process of becoming verified, we will take steps to transition the product to other SORs that conform to the policy.

We do not seek to embargo responsibly sourced 3TG from the Covered Countries as doing so could be detrimental to the legitimate economies and populations of those countries, and our suppliers are encouraged to continue support of SORs in the Covered Countries that are third party verified or in the process of becoming verified and to take similar measures with their supply chains.

The information provided by our suppliers is used to conduct our due diligence and to inform our risk assessments and risk mitigation activities and in the development of our Conflict Minerals Report and Form SD.

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 and conditions associated with 3TG mining and processing, including use of child or forced labor, unsafe working conditions, corruption and bribery. The Supplier Code of Conduct also requires that, upon request, our suppliers determine whether any products provided by them contain 3TG

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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.

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 strategic sourcing, sourcing risk, environmental, legal, internal audit, IT, trade compliance, corporate communications and selected personnel from various operations. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets quarterly to discuss the 3TG compliance process, modern slavery, and related developments. Senior management is briefed on the results of our RCOI and due diligence efforts on a regular basis.

3.    Internal Training

We maintain an internal responsible sourcing webpage, 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. We continually encourage our businesses to watch the training videos prior to sending RCOI requests to suppliers. We also provide training to attendees of ITW’s global sourcing conference, which was most recently held in March 2020.

4.    Supplier Engagement and Training

In addition to our Conflict Minerals Policy and Supplier Code of Conduct, ITW’s standard “Terms and Conditions” obligates our 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.

ITW has an established protocol for its supplier inquiry process and uses a third-party software vendor whose role is 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”).

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 encourage our businesses’ use of RMI’s eLearning Academy for supplier training in our responsible sourcing newsletter, 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.

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. Web-based reporting is offered in 16 languages and telephone-based reporting is offered in more than 200 languages, both available 24 hours a day, seven days a week. A link to the Helpline is included in our Conflict Minerals Policy and our Supplier Code of Conduct 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 2019 reporting cycle.

For 2019, our 3TG working team, together with various members of our sourcing department, compiled a list of the Company’s “80” suppliers by segment (i.e., the most significant suppliers), with or likely to have 3TG in their products, and distributed the list to our businesses with products containing or likely to contain 3TG. Those businesses were asked to further refine the list by identifying their own “80” suppliers and were instructed to survey those suppliers (we refer to the surveyed suppliers for 2019 as the “Suppliers”). We asked our businesses to concentrate their outreach on their “80” suppliers because these suppliers are the most likely to be recurring suppliers and responsible for a significant portion of the 3TG in our products.

The purpose of the Supplier 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 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.

ITW has an established protocol for its supplier inquiry process and uses the CM System, a third-party software vendor whose role is 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.

We sent 2,654 requests in eight languages to the Suppliers to provide us with a completed CMRT, as compared to 3,138 requests sent for 2018. The number of queried Suppliers decreased year-over-year due to the enhanced internal scoping. 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 1,639 completed CMRTs from the Suppliers surveyed, compared to 1,615 received for 2018. Since our earliest report in 2014, our supplier response rate has improved steadily year-over-year, increasing from 52% in 2018 to 62% in 2019.

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 265 SORs verified by the RMI as Conformant. We determined that 44 of these Conformant SORs sourced in whole or in part from within the Covered Countries. 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 also identified an additional eight SORs that were listed as “Active” (as later defined in Section III.B.) by the RMI and 72 that were listed on the Smelter Look-up tab of the CMRT but were not Conformant or Active.

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.


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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 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 2019 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 are conformant with the RMAP assessment protocols, including those listed as “re-audit in progress.” “Active” SORs are those that have committed to undergo an RMAP assessment.

CMRTs received from our Suppliers that indicated 3TG from a source within a Covered Country 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. For our 2019 compliance, we continued to revise and simplify our written communications and instructions to our businesses regarding supplier red flag follow-up to enhance program effectiveness.

In addition, we reached out directly to the SORs that were not listed as Conformant or Active by the RMI and asked them to become Conformant. Entities that the RMI has determined are either not SORs or not in operation were not addressed in our outreach efforts. 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. As a result of our due diligence activities in 2019, we have instructed certain of the Suppliers to remove a total of nine SORs from our supply chain that were not Conformant or otherwise fail to meet our supplier requirements.

Our 3TG working 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 due diligence at identified points in the supply chain

The Company continued its membership in the RMI for 2019. 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 this annual Conflict Minerals Report. We post this report 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 at www.itw.com/about-itw/suppliers. We also refer to our efforts relating to 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 2019, 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:

Adhesive tapes
Industrial equipment
Air delivery equipment
Industrial ovens
Arc welding and cutting equipment and consumables
Industrial warewashers
Automotive components
Inspection equipment
Commercial cooking equipment
LED lamps
Commercial food equipment
Measuring equipment
Commercial refrigerators
Mixers
Disposers/Waste Treatment Equipment
Motors
Drills
Power sources
Electrical devices
Printers and dispensers
Electrical enclosures
Production equipment
Electronic components
Sealants
Electronic equipment
Sealing equipment
Fasteners
Solder products
Fastening tools
Switches, capacitors and electronics
Flow control meters
Testing equipment
Ground support equipment
Welding hardware
Industrial cleaning equipment
Wire assembly

V.    Identified Smelters and Refiners

As stated above, our Supplier responses identified 265 SORs that were on the RMI Conformant lists, eight that were listed as Active with the RMI and 72 that were on the Smelter Look-up tab list of the CMRT but not listed as Conformant or Active by the RMI. Those facilities are listed on Annex A. The information on Annex A includes only information regarding the SORs identified by our Suppliers that were on the Smelter Look-up tab list contained in the CM System as of February 10, 2020. 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 cannot 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 on 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, because we did not obtain a response from all Suppliers surveyed, some Suppliers were unable to identify all of the SORs in their supply chain, and 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 utilized the information made available to RMI members regarding the potential countries of origin of the 3TG processed by these SORs and did not find for 2019 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country.

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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 2020 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 enhance supplier communications 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 designation;

Continue our membership in the RMI and active participation in its Plenary, Multi-Stakeholder, Due Diligence and Smelter Engagement Teams and support the RMAP;

Continue our membership and active participation in the AIAG Responsible Materials Working Group; and

Continue to submit to the RMI facilities identified by our suppliers that have not yet been identified by the RMI as SORs, 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 and the enactment of laws and rules in other jurisdictions, 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
8853 S.p.A.
ITALY
Conformant
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Conformant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Conformant
Gold
Al Etihad Gold Refinery DMCC
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
Bangalore Refinery
INDIA
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
Chugai Mining
JAPAN
Conformant
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Conformant
Gold
Dowa
JAPAN
Conformant
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Conformant
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
Conformant
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Conformant
Gold
Eco-System Recycling Co., Ltd. West Plant
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
Heimerle + Meule GmbH
GERMANY
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Conformant


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Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
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
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
KGHM Polska Miedz Spolka Akcyjna
POLAND
Conformant
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Conformant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Conformant
Gold
L'Orfebre S.A.
ANDORRA
Conformant
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Conformant
Gold
LT Metal Ltd.
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

10




Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
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
REMONDIS PMR B.V.
NETHERLANDS
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
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



11




Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
Gold
SAFINA A.S.
CZECHIA
Active
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
On Smelter Look-up List
Gold
African Gold Refinery
UGANDA
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
CGR Metalloys Pvt Ltd.
INDIA
On Smelter Look-up List
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
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
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
On Smelter Look-up List
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
On Smelter Look-up List
Gold
Fujairah Gold FZC
UNITED ARAB EMIRATES
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
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
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
On Smelter Look-up List
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
On Smelter Look-up List
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
On Smelter Look-up List
Gold
JSC Ekaterinburg Non-Ferrous Metal Refiners
RUSSIAN FEDERATION
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
Modeltech Sdn Bhd
MALAYSIA
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
NH Recytech Company
KOREA, REPUBLIC OF
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
QG Refining, LLC
UNITED STATES OF AMERICA
On Smelter Look-up List
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
On Smelter Look-up List

12




Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
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 Humon Smelting Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
On Smelter Look-up List
Gold
Sovereign Metals
INDIA
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
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

13




Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
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
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
PRG Dooel
NORTH MACEDONIA, REPUBLIC OF
Conformant
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Conformant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
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
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
CP Metals Inc.
UNITED STATES OF AMERICA
Active
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
On Smelter Look-up List
Tin
Alpha
UNITED STATES OF AMERICA
Conformant
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Conformant
Tin
Chifeng Dajingzi Tin Industry 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 United Smelting
INDONESIA
Conformant
Tin
CV Venus Inti Perkasa
INDONESIA
Conformant
Tin
Dowa
JAPAN
Conformant


14




Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
Tin
Fenix Metals
POLAND
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
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
Gejiu Zili Mining And Metallurgy 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 Hill Tin Industry Co., Ltd.
CHINA
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Conformant
Tin
Ma'anshan Weitai Tin Co., 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 Metalurgicas 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 Babel Surya Alam Lestari
INDONESIA
Conformant
Tin
PT Bangka Prima Tin
INDONESIA
Conformant
Tin
PT Bangka Serumpun
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 Inti Stania Prima
INDONESIA
Conformant
Tin
PT Karimun Mining
INDONESIA
Conformant

15




Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
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 Panca Mega Persada
INDONESIA
Conformant
Tin
PT Premium Tin Indonesia
INDONESIA
Conformant
Tin
PT Prima Timah Utama
INDONESIA
Conformant
Tin
PT Rajawali Rimba Perkasa
INDONESIA
Conformant
Tin
PT Rajehan Ariq
INDONESIA
Conformant
Tin
PT Refined Bangka Tin
INDONESIA
Conformant
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 Tbk Kundur
INDONESIA
Conformant
Tin
PT Timah Tbk Mentok
INDONESIA
Conformant
Tin
PT Tinindo Inter Nusa
INDONESIA
Conformant
Tin
PT Tirus Putra Mandiri
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
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
Conformant
Tin
Thaisarco
THAILAND
Conformant
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
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
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
Conformant
Tin
Luna Smelter, Ltd.
RWANDA
Active
Tin
Precious Minerals and Smelting Limited
INDIA
Active
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
On Smelter Look-up List
Tin
Gejiu City Fuxiang Industry and Trade 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
Pongpipat Company Limited
MYANMAR
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
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
On Smelter Look-up List

16




Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
Tin
Dongguan CiEXPO Environmental Engineering 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 Jinye Mineral Company
CHINA
On Smelter Look-up List
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
On Smelter Look-up List
Tin
Modeltech Sdn Bhd
MALAYSIA
On Smelter Look-up List
Tin
PT Eunindo Usaha Mandiri
INDONESIA
On Smelter Look-up List
Tin
PT Timah Nusantara
INDONESIA
On Smelter Look-up List
Tungsten
A.L.M.T. 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 Ganmin RareMetal Co., Ltd.
CHINA
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Haichuang 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
Hunan Litian Tungsten Industry 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
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Conformant


17




Mineral
Smelter or Refiner Name
Smelter or Refiner Country
Smelter or Refiner
Status
Tungsten
Jiangxi Xinsheng Tungsten Industry 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
KGETS Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
Conformant
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Conformant
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Conformant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
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
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
Active
Tungsten
CP Metals Inc.
UNITED STATES OF AMERICA
Active
Tungsten
Jiangxi Xianglu Tungsten Co., Ltd.
CHINA
Active
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Active
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
On Smelter Look-up List
Tungsten
Ganzhou Yatai 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
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
On Smelter Look-up List
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
On Smelter Look-up List


18




Country of Origin Information
The countries of origin of the newly-mined 3TG processed by the Conformant SORs listed above may have included the countries listed below, as well as possibly other countries. We did not determine the possible countries of origin of the 3TG processed by any other SORs listed on this Annex A. The listed countries of origin are derived from information made available by the RMI to its members, which includes London Bullion Market Association Good Delivery List information. 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 newly-mined 3TG processed by the listed Conformant SORs with greater specificity. 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 countries indicated below.
Argentina
Hungary
Paraguay
Armenia
Iceland
Peru
Australia
India
Philippines
Austria
Indonesia
Poland
Azerbaijan
Ireland
Portugal
Belgium
Israel
Romania
Benin
Italy
Russian Federation
Bolivia (Plurinational State of)
Ivory Coast
Rwanda*
Botswana
Japan
San Marino
Brazil
Jordan
Saudi Arabia
Brunei
Republic of Korea
Senegal
Bulgaria
Kazakhstan
Serbia
Burkina Faso
Kenya
Sierra Leone
Burundi*
Kuwait
Singapore
Cambodia
Kyrgyzstan
Slovakia
Cameroon
Laos
Slovenia
Canada
Latvia
Solomon Islands
Chile
Lebanon
Somaliland
China
Liberia
South Africa
Colombia
Liechtenstein
Spain
Croatia
Lithuania
Sudan
Cuba
Luxembourg
Suriname
Cyprus
Macau
Swaziland
Czech Republic
Madagascar
Sweden
Democratic Republic of the Congo*
Malaysia
Switzerland
Denmark
Mali
Taiwan
Dominican Republic
Malta
Tanzania*
Ecuador
Mauritania
Tajikistan
Egypt
Mauritius
Thailand
El Salvador
Mexico
Togo
Eritrea
Mongolia
Trinidad and Tobago
Estonia
Morocco
Tunisia
Ethiopia
Mozambique
Turkey
Fiji
Myanmar
Ukraine
Finland
Namibia
United Arab Emirates

19




France
Netherlands
United Kingdom of Great Britain and Northern Ireland
Gambia
New Caledonia
Uganda*
Georgia
New Zealand
United States of America
Germany
Nicaragua
Uruguay
Ghana
Niger
Uzbekistan
Greece
Nigeria
Vietnam
Guatemala
Norway
Zambia*
Guinea
Pakistan
Zimbabwe
Guyana
Panama
 
Honduras
Papua Guinea
 
*Covered Country.


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