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Exhibit 1.01
Conflict Minerals Report of Woodward, Inc.
For the reporting period from January 1, 2024 to December 31, 2024
This Conflict Minerals Report (the “Report”) of Woodward, Inc. (the “Company,” “Woodward,” “we,” “us” or “our”) has been prepared pursuant to Rule 13p-1 (“Rule 13p-1”) and Form SD (“Form SD”) promulgated under the Securities Exchange Act of 1934 (the “Exchange Act”) for the reporting period January 1, 2024 to December 31, 2024 (the “Reporting Period”).
Rule 13p-1, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain conflict minerals (as defined below) are necessary to the functionality or production of such products. As defined in Form SD, and as used herein, “conflict minerals” means: (i)(a) columbite-tantalite (or coltan), (b) cassiterite, (c) gold and (d) wolframite, or their derivatives, which are currently limited to tantalum, tin and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an “adjoining country” as defined in Form SD (collectively, the “Covered Countries”).
Woodward’s Manufactured and Contracted-to-Manufacture Products
Woodward, including our consolidated subsidiaries, manufactures and subcontracts for the manufacture of products for which conflict minerals are necessary to the functionality or production of those products. We provide energy control and optimization solutions for the aerospace and industrial market segments through the precise and efficient control of energy, including motion, fluid, combustion, and electrical energy. Please see (i) our Form SD for a detailed description of our products, including those products that we believe are likely to contain one or more conflict minerals, and (ii) Item 1 in our Annual Report on Form 10-K for the fiscal year ended September 30, 2024 for a more detailed description of our business, markets, services and product applications.
The Company’s Due Diligence Process
The Company’s due diligence measures have been designed to conform to the framework in the Organisation for Economic Co-operation and Development’s (“OECD”), “OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas,” Third Edition (2016), including applicable supplements thereto (the “OECD Guidelines”).
Woodward has implemented or is addressing each of the steps in the OECD 5-step due diligence framework as discussed or referenced below:
1.Establish strong company management systems
a.Company conflict minerals policy
Woodward has adopted a written conflict minerals policy (the “Conflict Minerals Policy”). The Conflict Minerals Policy affirms the Company’s commitment to responsible sourcing of minerals from conflict affected and high-risk areas. The policy is publicly available and can be accessed at https://www.woodward.com/about/ethics-and-compliance. The policy is reviewed annually to determine if any revisions are appropriate.
b.Internal management structure
Our Executive Vice President and Chief Operating Officer (the “COO”) oversees our Sourcing function and is responsible for ensuring our compliance with conflict minerals due diligence requirements, including the establishment of related compliance measures. Senior Sourcing leadership oversees the day-to-day conflict minerals program activities, and they provide regular updates on the conflict minerals program to the COO. Woodward’s Director of Governance and Securities serves as an advisor on conflict minerals compliance. The Sourcing team is responsible for reaching out to the Company’s in-scope suppliers on an ongoing basis (both independently and through Assent) to collect information, including, once per year, a Conflict Minerals Reporting Template (“CMRT”), regarding the presence and sourcing of conflict minerals in the products supplied to the Company. Other functions within Woodward provide focused support as required. When appropriate, conflict minerals and our conflict minerals program are a topic of discussion and review by our Board of Directors, or an appropriate committee thereof. These actions have aligned existing strategic and organizational structures to address the due diligence and reporting requirements of Rule 13p-1.
c.System of controls and transparency over the mineral supply chain
Our enterprise resource planning (“ERP”) systems provide controls over our supply chain. The ERP systems currently provide:
•Identification of the end item products we provide to each of our customers;
•shipping transaction history to assist in bounding our sales/shipments by calendar year;
•a bill of material identifying all of the components and materials in each of our end item products;
•a purchasing history of each of our purchased components and raw materials, and the identification of the suppliers used for these purchases; and
•a receiving inspection function that accepts or rejects purchased components and raw materials based upon whether the purchased items meet or do not meet the specification requirements (including specified material requirements) of the associated drawing or other specification documents. This is accomplished by a combination of direct measurements / inspections of the actual parts, or by reviewing the existence and completeness of formal supplier certifications to selected specifications, such as certifying proper use of specified aluminum or steel specifications.
We have contracted with Assent Compliance, Inc., a provider of compliance solutions, (“Assent”) to license the Assent Sustainability Manager (“ASM”), and we utilize Assent’s support services to automate supplier inquiry, data collection and data validation tasks, and automated CMRT generation. In addition, Woodward maintains full membership with the Responsible Materials Initiative (“RMI”).
d.Strengthen Company engagement with suppliers
Woodward is committed to conducting business in a socially responsible manner and is determined to partner with suppliers who are similarly committed. We continue to engage with our suppliers regarding conflict minerals requirements. Our standard purchase order terms and conditions and our standard long-term supplier agreement require our suppliers to support our conflict minerals reporting, and we review these provisions on a regular basis. We desire to achieve improved supply chain transparency and responsible sourcing to increase the traceability of materials from each supplier.
The following language is included in our standard purchase order terms and conditions:
“…warrants and certifies that it complies with Section 1502 of the Dodd Frank Act and the Final Rule issued by the U.S. Securities and Exchange Commission, and any subsequent rules and regulations related thereto issued by the United States Government and, where identified by Woodward, other governments and/or authorities in regions that Woodward provides its products (“Conflict Minerals Regulations”), and has implemented compliant processes to ensure its suppliers are in compliance with the Conflict Minerals Regulations.
Where Supplier does not have direct and formal reporting requirements under the Conflict Minerals Regulations, and upon request by Woodward, Supplier agrees to provide due diligence and Responsible Country of Origin Inquiry (“RCOI”) information under this Agreement to Woodward in support of Woodward’s reporting requirements (the “RCOI Requirements”).
Further, Supplier shall promptly comply with all requests by Woodward to provide documentation, and other substantiating data and assurances with respect to its compliance with Conflict Minerals Regulations and the RCOI Requirements as Woodward may deem necessary from time to time. In the event: (a) Woodward deems Supplier is not in compliance with the Conflict Minerals Regulations or the RCOI Requirements, (b) Woodward is not satisfied with the outcome of any review of Supplier documentation and/or data or otherwise, or (c) Supplier does not provide the documentation, other data and/or other further assurances to Woodward as requested by Woodward, Woodward shall have the right to terminate this Order or any portion thereof without penalty or further liability to Woodward.”
To the extent a supplier needs assistance, Woodward conducts one-on-one contact sessions with suppliers to address their inquiries and provide guidance where needed. Through our contract with Assent, our suppliers have access to an extensive suite of training videos, slide decks, how-to manuals and regulation guidance documents. Our suppliers also have access to online chat with an Assent specialist if they have difficulties or questions while preparing their responses.
e.Establish a company-level, or industry-wide, grievance mechanism as an early warning risk-awareness system
Woodward has a comprehensive Code of Business Conduct and Ethics (the “Code”) and employees receive regular training on a variety of ethics and compliance topics. Woodward also has robust reporting mechanisms for employees’ ethics concerns and grievances, including concerns regarding our supply chain and ethical sourcing. All Woodward employees have the right and responsibility to promptly report concerns, including but not limited to suspected or known violations of applicable law or regulation. We have established an Ethics Help Line that employees (or third parties) can contact to report concerns, including on an anonymous basis. The reporting mechanisms are set forth in the Code which is available on our website, and the concepts are reinforced during employee trainings. Investigations of alleged violations are handled pursuant to the process established by our Business Conduct Oversight Committee, and are ultimately overseen by the Audit Committee of the Board of Directors.
Woodward suppliers are encouraged to contact their Woodward point of contact or the Ethics Help Line if they believe elements of Woodward direction may cause them to be noncompliant with Woodward’s stated social responsibility goals and compliance requirements. The Woodward Product Material Compliance team and other Woodward employees are available to provide guidance regarding conflict minerals issues, including compliance matters and contract flow down requirements. Further,
Woodward has adopted a Supplier Code of Conduct, which can be found at https://www.woodward.com/about/ethics-and-compliance.
2.Identify and assess risks in the supply chain
Woodward is a downstream manufacturer. As such, Woodward does not control the origin, source or composition of many of the materials provided by our suppliers. Consequently, we ask our suppliers to inquire, identify, and conduct data collection and due diligence activities, which in turn are fundamental elements of our due diligence activities. Woodward analyses the data collected from our in-scope suppliers for accuracy and completeness in order to identify and assess risks in the Woodward supply chain. This analysis includes:
•the initial smelter checklist analysis contained in the CMRT;
•Assent validation of smelter or refiner (“SOR”) lists in the supplier CMRTs, using an extensive database consisting of the RMI, Responsible Jewelry Council (“RJC”), and London Bullion Market Association (“LBMA”) validated SOR lists, and the results of Assent’s extensive internal and independent SOR validation efforts; and
•the indirect analysis input that Woodward has acquired as a result of submitting interim roll-up CMRTs to our customers and receiving analysis results from the various software applications they use.
ASM generates for us the Woodward CMRT based on the valid supplier CMRTs we receive. We then compare the SOR list in the Woodward CMRT against the RMI SOR list and the RMI compliance and country of origin databases to ensure the accuracy of our data as of the conclusion of our conflict minerals campaign.
We use supplier CMRTs to identify the parent companies of our suppliers (if any), parent company contact data (if applicable), and whether the supplier reported conflict minerals data at the parent company level or at the affiliate level. This approach enables us to improve the targeting of future campaigns.
Data from our suppliers can be inaccurate or incomplete. For example, from time to time our suppliers report smelters in their supply chain (i) that do not match publicly available smelter data and therefore cannot be confirmed as a smelter, or (ii) for which the conflict-free sourcing status has not been validated. In such cases, ASM automatically provides a corrective action request to suppliers. Assent and Woodward jointly work with suppliers needing additional assistance to correct or eliminate these undetermined inputs as appropriate.
There is significant overlap between our RCOI efforts and our due diligence measures performed. Our RCOI process is described in our Form SD.
3.Design and implement a strategy to respond to identified risks
a.Report and implement a strategy to respond to identified risks
We continue to work closely with Assent to perform assessments of supplier-provided SOR data as described in the “Woodward Calendar Year 2024 Due Diligence Results” section of this Report. Both of our business segments conduct periodic reviews of critical supply chain matters for the segment, including conflict minerals and product materials compliance. Additionally, each year, senior Global
Sourcing leadership engages in a strategic planning review with senior management of the Company to provide strategic oversight of our supply chain strategies and performance.
b.Devise and adopt a risk management plan
Woodward has several established procedures and tools that form the foundation of the conflict minerals aspects of our risk management plan. These procedures and tools include but are not limited to our supplier approval process, purchasing procedures, purchase order and supplier agreement terms and conditions (described above), supplier registration portal, and parts transition process, as well as the evaluation of other existing and possible future software solutions. In addition, Assent and ASM enable us to perform a risk assessment of, and assign a risk rating to, each supplier CMRT we receive.
c.Implement a risk mitigation plan
Together with many other companies, we co-sign an annual letter coordinated by Assent that is sent to every SOR that has not completed or that was not actively participating in an independent conflict-free sourcing practices audit. The purpose of the letter is to encourage participation in an independent third-party audit program and the use of conflict-free sourcing practices, and to leverage the collective influence we may have on the SORs. We also send letters directly from Woodward to our suppliers who do not adequately respond to our initial data requests.
We continue to engage in additional fact finding and risk assessments to identify risks requiring mitigation or after a change in circumstances.
4.Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain
Woodward is significantly downstream in the supply chain from smelters and refiners. In order to obtain SOR information, Woodward seeks information from our upstream suppliers and from third party data aggregating services. Woodward is an RMI member and leverages the RMI Responsible Minerals Assurance Process and the resulting audit data from that program.
5.Report annually on supply chain due diligence
The Form SD, this Report, and our Conflict Minerals Policy can be found at https://www.woodward.com/about/ethics-and-compliance.
Woodward Calendar Year 2024 Due Diligence Results
Woodward Conflict Minerals Data Requests and Supplier Responses (the Due Diligence in Acquiring Supplier Data)
We initiated our 2024 campaign for in-scope Woodward suppliers in November 2024 by sending CMRT requests. All CMRT requests were sent at the part level. If suppliers were unable to provide part-level CMRTs, then we accepted company-level CMRTs. To eliminate ambiguity in our requests to suppliers, we provide each in-scope supplier a complete list of the specific parts that Woodward purchased from them that were incorporated into our calendar year shipments.
As part of the 2024 campaign, two follow-up inquiries were sent to non-respondents and, where suppliers had still not responded, we followed up with three further “escalation” inquiries. As part of the escalation, Assent separated those suppliers who reported a “no 3TG” status last year into a separate simplified campaign, asking them if they could confirm their “no 3TG” status for this year. Additionally,
Woodward twice followed up with suppliers that returned incomplete or invalid CMRTs with corrective action requests.
Summary results for our 2024 campaign, as of April 18, 2025 are as follows:
•We campaigned 1,394 suppliers (compared to 2,300 suppliers last year)
•We received CMRTs from 867 suppliers for a response rate of 62% (last year, we received CMRTs from 1,216 suppliers for a 53% response rate)
•836 suppliers, or 60% of the suppliers we campaigned, returned valid CMRTs (compared to 1005, or 44%, last year)
•125, or 14%, of our supplier CMRT responses were made at the Woodward-requested part level (compared to 175, or 14%, of CMRT responses last year)
We continue to make improvements in identifying suppliers who do not supply parts to us that contain 3TG, which has enabled us to engage in more direct campaigns with targeted suppliers. We experienced an increase in our supplier response rate this year. We believe this increase was primarily driven by our improved identification of in-scope suppliers, which enabled us to perform a more targeted campaign.
Supplier Response Assessment (Smelter Determination Due Diligence)
ASM generated an integrated roll-up CMRT from all valid supplier CMRTs received as of April 18, 2025. This resulted in 372 SORs with RMI identification numbers who provide, through our supply chain, conflict minerals used in Woodward’s products. See Exhibit A to this Report for a list of these SORs. Woodward conducts no direct transactions and has no contractual relationship with these SORs or their sources of ore.
We used RMI’s SOR compliance status data and the results of our 2024 campaign, in each case as of April 18, 2025, to evaluate the 372 SORs with respect to RMI compliance. The summarized results are as follows:
•233 SORs were determined by RMI to be “conformant”, meaning the SOR has been verified as having completed a responsible mineral sourcing validation program
•9 SORs are designated by RMI as “active”, meaning the SOR has begun participating in a responsible mineral sourcing validation program
•98 SORs had other RMI designations
•32 SORs are designated by RMI as “non-conformant” (compared to 29 in the prior year)
Certain suppliers reported potential sourcing from a gold smelter in the Uganda that has not been assessed by RMI (CID003185 – African Gold Refinery)(“AGR”). On March 17, 2022, the U.S. Department of the Treasury added African Gold Refinery in Uganda to the OFAC’s Specially Designated Nationals (SDN) List. Because of the over-reporting nature of the industry CMRT information collection process, and the nature of the supply chains and goods, we are unable to confirm if minerals from AGR are in our products. Woodward is in contact with suppliers who reported potential sourcing from AGR and will continue to engage with those suppliers to improve due diligence efforts and transparency.
We have identified 40 SORs in our supply chain that are categorized as “high risk” based on the sourcing practices and relationships of the applicable SOR, including AGR. Woodward conducts outreach via Assent multiple times each year to all in-scope suppliers who utilize one or more high risk SORS and to encourage these suppliers to (i) request the supplier perform additional smelter validation and due
diligence work, (ii) request that the applicable SORs participate in a responsible mineral sourcing validation program, and/or (iii) find alternative sourcing relationships with conformant SORs. Additionally, Woodward requests these suppliers to conduct additional due diligence to confirm the chain of custody of parts supplied to Woodward.
Smelter or Refiner Mine Country of Origin Results
Mine country of origin data was available for all 233 of the conformant SORs. Of these 233 SORs, the mine country of origin data for 59 were provided on an aggregate basis to RMI by the LBMA. See Exhibit B to this Report for our country of origin findings as of April 18, 2025.
Concluding Statement
We continue to refine our supplier conflict minerals risk analysis, relevant supplier identification, SOR identification, and mine country of origin through improvements in our due diligence activity, our use of the ASM and other Assent services, and our association memberships. However, because (i) Woodward has not yet achieved a 100% supplier response rate; (ii) a significant majority of our supplier responses are still at a company level and not yet focused on Woodward specific parts; and (iii) complete SOR conflict status and mine country of origin data is not yet available from centralized sources specializing in the collection and assessment of such data, Woodward does not have sufficiently complete or discriminating data at this time to confirm the conflict-free or may-not-be-conflict-free status of any of its product families or individual products. We have also found that many supplier respondents have supply chains using SORs that were not conformant to a responsible mineral sourcing validation program, and we will continue to actively address this issue to mitigate such usage through targeted supplier outreach enabled by our use of ASM and other Assent services. Woodward is continuing our efforts and progress on the improvement actions described above.
Exhibit A: Smelter and Refiner List
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|
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|
Metal |
Standard Smelter Name |
Smelter Facility Location |
Smelter ID (from RMI) |
Gold |
Abington Reldan Metals, LLC |
United States of America |
CID002708 |
Gold |
Advanced Chemical Company |
United States of America |
CID000015 |
Gold |
Aida Chemical Industries Co., Ltd. |
Japan |
CID000019 |
Gold |
Agosi AG |
Germany |
CID000035 |
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
Uzbekistan |
CID000041 |
Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
Brazil |
CID000058 |
Gold |
Argor-Heraeus S.A. |
Switzerland |
CID000077 |
Gold |
Asahi Pretec Corp. |
Japan |
CID000082 |
Gold |
Asahi Refining Canada Ltd. |
Canada |
CID000924 |
Gold |
Asahi Refining USA Inc. |
United States of America |
CID000920 |
Gold |
Asaka Riken Co., Ltd. |
Japan |
CID000090 |
Gold |
Aurubis AG |
Germany |
CID000113 |
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Philippines |
CID000128 |
Gold |
Boliden AB |
Sweden |
CID000157 |
Gold |
C. Hafner GmbH + Co. KG |
Germany |
CID000176 |
Gold |
CCR Refinery - Glencore Canada Corporation |
Canada |
CID000185 |
Gold |
Chimet S.p.A. |
Italy |
CID000233 |
Gold |
Chugai Mining |
Japan |
CID000264 |
Gold |
Coimpa Industrial Ltda |
Brazil |
CID004010 |
Gold |
Dowa |
Japan |
CID000401 |
Gold |
DSC (Do Sung Corporation) |
Korea, Republic of |
CID000359 |
Gold |
Elite Industech Co., Ltd. |
Taiwan |
CID004755 |
Gold |
Eco-System Recycling Co., Ltd. East Plant |
Japan |
CID000425 |
Gold |
Eco-System Recycling Co., Ltd. North Plant |
Japan |
CID003424 |
Gold |
Eco-System Recycling Co., Ltd. West Plant |
Japan |
CID003425 |
Gold |
GG Refinery Ltd. |
Tanzania |
CID004506 |
Gold |
Gold by Gold Colombia |
Colombia |
CID003641 |
Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
China |
CID002243 |
Gold |
Heimerle + Meule GmbH |
Germany, Austria |
CID000694 |
Gold |
Heraeus Germany GmbH Co. KG |
Germany |
CID000711 |
|
|
|
|
Gold |
Heraeus Metals Hong Kong Ltd. |
China |
CID000707 |
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
China |
CID000801 |
Gold |
Ishifuku Metal Industry Co., Ltd. |
Japan |
CID000807 |
Gold |
Istanbul Gold Refinery |
Turkey |
CID000814 |
Gold |
Italpreziosi |
Italy |
CID002765 |
Gold |
Japan Mint |
Japan |
CID000823 |
Gold |
Jiangxi Copper Co., Ltd. |
Japan |
CID000855 |
Gold |
JX Advanced Metals Corporation |
Japan |
CID000937 |
Gold |
Kazzinc |
Kazakhstan |
CID000957 |
Gold |
KGHM Polska Miedz Spolka Akcyjna |
Poland |
CID002511 |
Gold |
Kojima Chemicals Co., Ltd. |
Japan |
CID000981 |
Gold |
Korea Zinc Co., Ltd. |
Korea, Republic of |
CID002605 |
Gold |
LS-NIKKO Copper Inc. |
Korea, Republic of |
CID001078 |
Gold |
LT Metal Ltd. |
Korea, Republic of |
CID000689 |
Gold |
Materion |
United States of America |
CID001113 |
Gold |
Matsuda Sangyo Co., Ltd. |
Japan |
CID001119 |
Gold |
Metal Concentrators SA (Pty) Ltd. |
South Africa |
CID003575 |
Gold |
Metalor Technologies (Hong Kong) Ltd. |
China |
CID001149 |
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
Singapore |
CID001152 |
Gold |
Metalor Technologies (Suzhou) Ltd. |
China |
CID001147 |
Gold |
Metalor Technologies S.A. |
Switzerland |
CID001153 |
Gold |
Metalor USA Refining Corporation |
United States of America |
CID001157 |
Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. |
Mexico |
CID001161 |
Gold |
Mitsubishi Materials Corporation |
Japan |
CID001188 |
Gold |
Mitsui Mining and Smelting Co., Ltd. |
Japan |
CID001193 |
Gold |
MMTC-PAMP India Pvt., Ltd. |
India |
CID002509 |
Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. |
Turkey |
CID001220 |
Gold |
Navoi Mining and Metallurgical Combinat |
Uzbekistan |
CID001236 |
Gold |
NH Recytech Company |
Korea, Republic of |
CID003189 |
Gold |
Nihon Material Co., Ltd. |
Japan |
CID001259 |
Gold |
Ohura Precious Metal Industry Co., Ltd. |
Japan |
CID001325 |
Gold |
MKS PAMP SA |
Switzerland |
CID001352 |
Gold |
Planta Recuperadora de Metales SpA |
Chile |
CID002919 |
Gold |
PT Aneka Tambang (Persero) Tbk |
Indonesia |
CID001397 |
|
|
|
|
Gold |
PX Precinox S.A. |
Switzerland |
CID001498 |
Gold |
Rand Refinery (Pty) Ltd. |
South Africa |
CID001512 |
Gold |
REMONDIS PMR B.V. |
Netherlands |
CID002582 |
Gold |
Royal Canadian Mint |
Canada |
CID001534 |
Gold |
Safina A.S. |
Czech Republic |
CID002290 |
Gold |
SEMPSA Joyeria Plateria S.A. |
Spain |
CID001585 |
Gold |
Shandong Gold Smelting Co., Ltd. |
China |
CID001916 |
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
China |
CID001622 |
Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
China |
CID001736 |
Gold |
Solar Applied Materials Technology Corp. |
Taiwan |
CID001761 |
Gold |
Sumitomo Metal Mining Co., Ltd. |
Japan |
CID001798 |
Gold |
SungEel HiMetal Co., Ltd. |
Korea, Republic of |
CID002918 |
Gold |
T.C.A S.p.A |
Italy |
CID002580 |
Gold |
Tanaka Kikinzoku Kogyo K.K. |
Japan |
CID001875 |
Gold |
Tokuriki Honten Co., Ltd. |
Japan |
CID001938 |
Gold |
TOO Tau-Ken-Altyn |
Kazakhstan |
CID002615 |
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
Belgium |
CID001980 |
Gold |
United Precious Metal Refining, Inc. |
United States of America |
CID001993 |
Gold |
Valcambi S.A. |
Switzerland |
CID002003 |
Gold |
WEEEREFINING |
France |
CID003615 |
Gold |
Western Australian Mint (T/a The Perth Mint) |
Australia |
CID002030 |
Gold |
WIELAND Edelmetalle GmbH |
Germany |
CID002778 |
Gold |
Yamakin Co., Ltd. |
Japan |
CID002100 |
Gold |
Yokohama Metal Co., Ltd. |
Japan |
CID002129 |
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
China |
CID002224 |
Tantalum |
AMG Brasil |
Brazil |
CID001076 |
Tantalum |
D Block Metals, LLC |
United States of America |
CID002504 |
Tantalum |
F&X Electro-Materials Ltd. |
China |
CID000460 |
Tantalum |
FIR Metals & Resource Ltd. |
China |
CID002505 |
Tantalum |
Global Advanced Metals Aizu |
Japan |
CID002558 |
Tantalum |
Global Advanced Metals Boyertown |
United States of America |
CID002557 |
Tantalum |
Guangdong Rising Rare Metals-EO Materials Ltd. |
China |
CID000291 |
Tantalum |
Materion Newton Inc. |
United States of America |
CID002548 |
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|
|
|
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
China |
CID002492 |
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
China |
CID002512 |
Tantalum |
Jiangxi Tuohong New Raw Material |
China |
CID002842 |
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
China |
CID000914 |
Tantalum |
Jiujiang Tanbre Co., Ltd. |
China |
CID000917 |
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
China |
CID002506 |
Tantalum |
KEMET de Mexico |
Mexico |
CID002539 |
Tantalum |
Metallurgical Products India Pvt., Ltd. |
India |
CID001163 |
Tantalum |
Mineracao Taboca S.A. |
Brazil |
CID001175 |
Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
Japan |
CID001192 |
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
China |
CID001277 |
Tantalum |
NPM Silmet AS |
Estonia |
CID001200 |
Tantalum |
PowerX Ltd. |
Rwanda |
CID004054 |
Tantalum |
QuantumClean |
United States of America |
CID001508 |
Tantalum |
Resind Industria e Comercio Ltda. |
Brazil |
CID002707 |
Tantalum |
RFH Yancheng Jinye New Material Technology Co., Ltd. |
China |
CID003583 |
Tantalum |
Taki Chemical Co., Ltd. |
Japan |
CID001869 |
Tantalum |
TANIOBIS Co., Ltd. |
Thailand |
CID002544 |
Tantalum |
TANIOBIS Smelting GmbH & Co. KG |
Germany |
CID002550 |
Tantalum |
TANIOBIS GmbH |
Germany |
CID002545 |
Tantalum |
TANIOBIS Japan Co., Ltd. |
Japan |
CID002549 |
Tantalum |
Telex Metals |
United States of America |
CID001891 |
Tantalum |
Ulba Metallurgical Plant JSC |
Kazakhstan |
CID001969 |
Tantalum |
Ximei Resources (Guangdong) Limited |
China |
CID000616 |
Tantalum |
XinXing Haorong Electronic Material Co., Ltd. |
China |
CID002508 |
Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
China |
CID001522 |
Tin |
Alpha |
United States of America |
CID000292 |
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
China |
CID000228 |
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
China |
CID003190 |
Tin |
China Tin Group Co., Ltd. |
China |
CID001070 |
|
|
|
|
Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
Brazil |
CID003486 |
Tin |
CRM Synergies |
Spain |
CID003524 |
Tin |
CV Ayi Jaya |
Indonesia |
CID002570 |
Tin |
CV Venus Inti Perkasa |
Indonesia |
CID002455 |
Tin |
Dowa |
Japan |
CID000402 |
Tin |
DS Myanmar |
Myanmar |
CID003831 |
Tin |
EM Vinto |
Bolivia |
CID000438 |
Tin |
Estanho de Rondonia S.A. |
Brazil |
CID000448 |
Tin |
Fenix Metals |
Poland |
CID000468 |
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
China |
CID000538 |
Tin |
Global Advanced Metals Greenbushes Pty Ltd. |
Australia |
CID004754 |
Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
China |
CID003116 |
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
China |
CID002844 |
Tin |
Jiangxi New Nanshan Technology Ltd. |
China |
CID001231 |
Tin |
Luna Smelter, Ltd. |
Rwanda |
CID003387 |
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
Brazil |
CID002468 |
Tin |
Malaysia Smelting Corporation (MSC) |
Malaysia |
CID001105 |
Tin |
Malaysia Smelting Corporation Berhad (Port Klang) |
Malaysia |
CID004434 |
Tin |
Metallic Resources, Inc. |
United States of America |
CID001142 |
Tin |
Aurubis Beerse |
Belgium |
CID002773 |
Tin |
Aurubis Berango |
Spain |
CID002774 |
Tin |
Mineracao Taboca S.A. |
Brazil |
CID001173 |
Tin |
Minsur |
Perú |
CID001182 |
Tin |
Mitsubishi Materials Corporation |
Japan |
CID001191 |
Tin |
Mining Minerals Resources SARL |
Congo, Democratic Republic of the |
CID004065 |
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
Thailand |
CID001314 |
Tin |
O.M. Manufacturing Philippines, Inc. |
Philippines |
CID002517 |
Tin |
Operaciones Metalurgicas S.A. |
Bolivia |
CID001337 |
Tin |
PT Aries Kencana Sejahtera |
Indonesia |
CID000309 |
Tin |
PT Arsed Indonesia |
Indonesia |
CID005067 |
Tin |
PT Artha Cipta Langgeng |
Indonesia |
CID001399 |
Tin |
PT ATD Makmur Mandiri Jaya |
Indonesia |
CID002503 |
Tin |
PT Babel Inti Perkasa |
Indonesia |
CID001402 |
|
|
|
|
Tin |
PT Babel Surya Alam Lestari |
Indonesia |
CID001406 |
Tin |
PT Bangka Prima Tin |
Indonesia |
CID002776 |
Tin |
PT Bangka Tin Industry |
Indonesia |
CID001419 |
Tin |
PT Bangka Serumpun |
Indonesia |
CID003205 |
Tin |
PT Belitung Industri Sejahtera |
Indonesia |
CID001421 |
Tin |
PT Bukit Timah |
Indonesia |
CID001428 |
Tin |
PT Cipta Persada Mulia |
Indonesia |
CID002696 |
Tin |
PT Menara Cipta Mulia |
Indonesia |
CID002835 |
Tin |
PT Mitra Stania Prima |
Indonesia |
CID001453 |
Tin |
PT Mitra Sukses Globalindo |
Indonesia |
CID003449 |
Tin |
PT Premium Tin Indonesia |
Indonesia |
CID000313 |
Tin |
PT Prima Timah Utama |
Indonesia |
CID001458 |
Tin |
PT Putera Sarana Shakti (PT PSS) |
Indonesia |
CID003868 |
Tin |
PT Rajawali Rimba Perkasa |
Indonesia |
CID003381 |
Tin |
PT Rajehan Ariq |
Indonesia |
CID002593 |
Tin |
PT Refined Bangka Tin |
Indonesia |
CID001460 |
Tin |
PT Sariwiguna Binasentosa |
Indonesia |
CID001463 |
Tin |
PT Stanindo Inti Perkasa |
Indonesia |
CID001468 |
Tin |
PT Sukses Inti Makmur (SIM) |
Indonesia |
CID002816 |
Tin |
PT Timah Tbk Kundur |
Indonesia |
CID001477 |
Tin |
PT Timah Tbk Mentok |
Indonesia |
CID001482 |
Tin |
PT Timah Nusantara |
Indonesia |
CID001486 |
Tin |
PT Tommy Utama |
Indonesia |
CID001493 |
Tin |
PT Tinindo Inter Nusa |
Indonesia |
CID001490 |
Tin |
Resind Industria e Comercio Ltda. |
Brazil |
CID002706 |
Tin |
Rui Da Hung |
Taiwan |
CID001539 |
Tin |
Super Ligas |
Brazil |
CID002756 |
Tin |
Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. |
Japan |
CID004403 |
Tin |
Thaisarco |
Thailand |
CID001898 |
Tin |
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
China |
CID002180 |
Tin |
Tin Technology & Refining |
United States of America |
CID003325 |
Tin |
White Solder Metalurgia e Mineração Ltda. |
Brazil |
CID002036 |
Tin |
WOODCROSS SMELTING COMPANY LIMITED |
Uganda |
CID004724 |
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
China |
CID002158 |
|
|
|
|
Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
China |
CID003397 |
Tungsten |
A.L.M.T. Corp. |
Japan |
CID000004 |
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
Vietnam |
CID002502 |
Tungsten |
China Molybdenum Tungsten Co., Ltd. |
China |
CID002641 |
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
China |
CID000258 |
Tungsten |
Cronimet Brasil Ltda |
Brazil |
CID003468 |
Tungsten |
Fujian Xinlu Tungsten Co., Ltd. |
China |
CID003609 |
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
China |
CID002315 |
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
China |
CID002494 |
Tungsten |
Global Tungsten & Powders Corp. |
United States of America |
CID000568 |
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
China |
CID000218 |
Tungsten |
H.C. Starck Tungsten GmbH |
Germany |
CID002541 |
Tungsten |
Hubei Green Tungsten Co., Ltd. |
China |
CID003417 |
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
China |
CID000766 |
Tungsten |
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
China |
CID002513 |
Tungsten |
Japan New Metals Co., Ltd. |
Japan |
CID000825 |
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
China |
CID002551 |
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
China |
CID002321 |
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
China |
CID002318 |
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
China |
CID002317 |
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
China |
CID002316 |
Tungsten |
KENEE MINING CORPORATION VIETNAM |
Vietnam |
CID004619 |
Tungsten |
Kennametal Fallon |
United States of America |
CID000966 |
Tungsten |
Kennametal Huntsville |
United States of America |
CID000105 |
Tungsten |
Lianyou Metals Co., Ltd. |
Taiwan |
CID003407 |
Tungsten |
Lianyou Resources Co., Ltd. |
Taiwan |
CID004397 |
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
China |
CID002319 |
Tungsten |
Masan High-Tech Materials |
Vietnam |
CID002543 |
Tungsten |
Niagara Refining LLC |
United States of America |
CID002589 |
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
Philippines |
CID002827 |
|
|
|
|
Tungsten |
Philippine Bonway Manufacturing Industrial Corporation |
Philippines |
CID004797 |
Tungsten |
Shinwon Tungsten (Fujian Shanghang) Co., Ltd. |
China |
CID004430 |
Tungsten |
TANIOBIS Smelting GmbH & Co. KG |
Germany |
CID002542 |
Tungsten |
Tungsten Vietnam Joint Stock Company |
Vietnam |
CID003993 |
Tungsten |
Wolfram Bergbau und Hutten AG |
Austria |
CID002044 |
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
China |
CID002320 |
Tungsten |
Xiamen Tungsten Co., Ltd. |
China |
CID002082 |
Cobalt |
Anhui Hanrui New Material Co., Ltd. |
China |
CID003927 |
Cobalt |
Chemaf Etoile |
Congo, Democratic Republic of the |
CID003264 |
Cobalt |
CMOC Kisanfu Mining SARL Number 1 |
Congo, Democratic Republic of the |
CID004811 |
Cobalt |
Compagnie de Tifnout Tiranimine |
Morocco |
CID003280 |
Cobalt |
Dynatec Madagascar Company |
Madagascar |
CID003232 |
Cobalt |
Eti Bakir A.S |
Turkey |
CID004057 |
Cobalt |
Fujian Evergreen New Energy Technology Co. |
China |
CID003974 |
Cobalt |
Ganzhou Highpower Technology Co., Ltd. |
China |
CID003384 |
Cobalt |
Ganzhou Tengyuan Cobalt New Material Co., Ltd. |
China |
CID003212 |
Cobalt |
Gem (Jiangsu) Cobalt Industry Co., Ltd. |
China |
CID003209 |
Cobalt |
Guangdong Jiana Energy Technology Co., Ltd. |
China |
CID003291 |
Cobalt |
Guangxi CNGR New Energy Science & Technology Co., Ltd. |
China |
CID004681 |
Cobalt |
Guangxi Yinyi Advanced Material Co., Ltd. |
China |
CID003213 |
Cobalt |
Guizhou CNGR Resource Recycling Industry Development Co., Ltd. |
China |
CID003610 |
Cobalt |
Guizhou Red Star Electronic Material Co., Ltd. |
China |
CID004391 |
Cobalt |
Harima Refinery, Sumitomo Metal Mining |
Japan |
CID003577 |
Cobalt |
Hunan CNGR New Energy Science & Technology Co., Ltd. |
China |
CID003411 |
Cobalt |
Hunan Yacheng New Materials Co., Ltd. |
China |
CID003404 |
|
|
|
|
Cobalt |
Impala Platinum - Base Metal Refinery (BMR) |
South Africa |
CID004608 |
Cobalt |
Impala Platinum - Rustenburg Smelter |
South Africa |
CID004614 |
Cobalt |
Jiangsu Xiongfeng Technology Co., Ltd. |
China |
CID003293 |
Cobalt |
Jiangxi Jiangwu Cobalt Industrial Co., Ltd. |
China |
CID003377 |
Cobalt |
Jiangxi Miracle Golden Tiger Cobalt Co. Ltd. |
China |
CID004003 |
Cobalt |
Jingmen GEM Co., Ltd. |
China |
CID003378 |
Cobalt |
Kamoto Copper Company |
Congo, Democratic Republic of the |
CID003261 |
Cobalt |
Kisanfu Mining (Kimin) |
Congo, Democratic Republic of the |
CID003587 |
Cobalt |
La Compagnie de Traitement des Rejets de Kingamyambo S.A. (Metalkol S.A.) |
Congo, Democratic Republic of the |
CID003275 |
Cobalt |
Lanzhou Jinchuan Advanced Materials Technology Co., Ltd. |
China |
CID003210 |
Cobalt |
Lianyou Resources Co., Ltd. |
Taiwan |
CID004393 |
Cobalt |
Mechema Taiwan Plant 2 |
Taiwan |
CID003534 |
Cobalt |
Murrin Murrin Nickel Cobalt Plant |
Australia |
CID003406 |
Cobalt |
Mutanda Mining SPRL |
Congo, Democratic Republic of the |
CID003301 |
Cobalt |
Niihama Nickel Refinery, Sumitomo Metal Mining |
Japan |
CID003278 |
Cobalt |
Ningbo Hubang New Material Co., Ltd. |
China |
CID003465 |
Cobalt |
NORILSK NICKEL HARJAVALTA OY |
Finland |
CID003390 |
Cobalt |
Port Colborne Refinery |
Canada |
CID003239 |
Cobalt |
PT Halmahera Persada Lygend |
Indonesia |
CID004802 |
Cobalt |
PT HUAYUE NICKEL COBALT |
Indonesia |
CID004524 |
Cobalt |
PT QMB NEW ENERGY MATERIALS |
Indonesia |
CID004731 |
Cobalt |
Quzhou Huayou Cobalt New Material Co., Ltd. |
China |
CID003255 |
Cobalt |
Societe pour le Traitment du Terril de Lubumbashi (STL) |
Congo, Democratic Republic of the |
CID003266 |
Cobalt |
Somika Miniere du Katanga -SOMIKA (Lupoto plant) |
Congo, Democratic Republic of the |
CID004745 |
Cobalt |
SungEel HiTech Co., Ltd. |
Korea, Republic of |
CID003338 |
Cobalt |
Tenke Fungurume Mining SA |
Congo, Democratic Republic of the |
CID003429 |
|
|
|
|
Cobalt |
Tianjin Maolian Science & Technology Co., Ltd. |
China |
CID003215 |
Cobalt |
Umicore Finland Oy |
Finland |
CID003226 |
Cobalt |
Umicore Olen |
Belgium |
CID003228 |
Cobalt |
Uranus Chemicals |
Taiwan |
CID003473 |
Cobalt |
Vale – Long Harbour Processing Plant (LHPP) |
Newfoundland, Canada |
CID003584 |
Cobalt |
Zhejiang Greatpower Cobalt Materials Co., Ltd. |
China |
CID003526 |
Cobalt |
Zhejiang Huayou Cobalt Company Limited |
China |
CID003225 |
Cobalt |
Zhejiang New Era Zhongneng Technology Co., Ltd. |
China |
CID003398 |
Cobalt |
Zhuhai Kelixin Metal Materials Co., Ltd. |
China |
CID003211 |
Exhibit B: Mine Country of Origin Data
Potential Countries of Origin for Conflict Minerals associated with the SORs listed in Exhibit A
|
|
|
Albania |
Algeria |
Andorra |
Angola |
Antigua and Barbuda |
Argentina |
Australia |
Austria |
Azerbaijan |
Bahamas |
Bangladesh |
Barbados |
Belarus |
Belgium |
Benin |
Bolivia |
Bosnia and Herzegovina |
Botswana |
Brazil |
Bulgaria |
Burkina Faso |
Burundi |
Cambodia |
Cameroon |
Canada |
Cayman Islands |
Chile |
China |
Colombia |
Congo, Democratic Republic of the |
Costa Rica |
Côte d'Ivoire |
Croatia |
Curacao |
Czech Republic |
Denmark |
Dominica |
Dominican Republic |
Ecuador |
Egypt |
El Salvador |
Estonia |
Eswatini |
Ethiopia |
Fiji |
Finland |
France |
French Guiana |
Georgia |
Germany |
Ghana |
Greece |
Grenada |
Guatemala |
Guinea |
Guyana |
Honduras |
Hong Kong |
Hungary |
Iceland |
India |
Indonesia |
Ireland |
Israel |
Italy |
Jamaica |
Japan |
Jordan |
Kazakhstan |
Kenya |
Korea, Republic of |
Kuwait |
Kyrgyzstan |
Lao People's Democratic Republic |
Laos |
Latvia |
Lebanon |
Liberia |
Liechtenstein |
Lithuania |
Luxembourg |
Macao |
Madagascar |
Malaysia |
Mali |
Malta |
Mauritania |
Mexico |
Moldova, Republic of |
Mongolia |
Morrocco |
Mozambique |
Myanmar |
Namibia |
Netherlands |
New Caledonia |
New Zealand |
Nicaragua |
Niger |
Nigeria |
Norway |
Oman |
Panama |
Papua New Guinea |
Peru |
Philippines |
Poland |
Portugal |
Puerto Rico |
Romania |
Russia |
Rwanda |
Saint Kitts and Nevis |
Saint Vincent and Grenadines |
Saudi Arabia |
Senegal |
Serbia |
Sierra Leone |
Singapore |
Sint Maarten |
Slomon Islands |
Slovakia |
South Africa |
South Korea |
Spain |
Sri Lanka |
|
|
|
Sudan |
Suriname |
Sweden |
Switzerland |
Tajikistan |
Tanzania |
Thailand |
Taiwan |
Timore-Leste |
Togo |
Trinidad and Tobago |
Tunisia |
Turkey |
Uganda |
Ukraine |
United Arab Emirates |
United Kingdom |
United States of America |
Uruguay |
Uzbekistan |
Venezuela |
Vietnam |
Zambia |
Zimbabwe |