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EXHIBIT 1.01
Conflict Minerals Report
This is the Conflict Minerals Report of Spectrum Brands Holdings, Inc. and its consolidated subsidiaries, including SB/RH Holdings, LLC and its consolidated subsidiaries (the “Company,” “Spectrum Brands,” “we,” “us,” or “our”), for January 1, 2024 through December 31, 2024 (“Calendar Year 2024”) in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended (the “1934 Act”). As used herein, “Conflict Minerals” or “3TG” is defined as, consistent with the Conflict Minerals Rule, cassiterite, columbite-tantalite (coltan), gold, wolframite and the derivatives tin, tantalum and tungsten. Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 for definitions of the other terms used in this Report, unless otherwise defined herein.
Applying the Dodd-Frank Act to Spectrum Brands Holdings, Inc.
The Securities and Exchange Commission’s (the “SEC”) conflict minerals rule requires a three-step compliance approach. The first step is determining applicability of the conflict minerals rule to Spectrum Brands; the second step is a reasonable country of origin inquiry (“RCOI”) to determine whether we have reason to believe that conflict minerals from the Democratic Republic of the Congo (the “DRC”) or adjoining countries (the “Covered Countries”) that are necessary to the functionality or production of products manufactured by us, or contracted to be manufactured by us, are present in our products; and the third step (referred to as “due diligence” in the SEC rule) is to determine the source and origin of any such conflict minerals and the facilities in which they were processed.
As a downstream company, Spectrum Brands is several tiers removed from mining operations and smelters or refiners (“SORs”) in dealing with its direct suppliers. Spectrum Brands hired a third-party provider to assist it in performing conflict mineral supply chain due diligence (the “Provider”). Using our Provider as well as our supply chain due diligence processes and focusing on accountability within the supply chain by using the industry standard Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”) and reaching out to our suppliers, we seek to gain greater transparency in our supply chain. Certain of the activities described below were performed by the Provider on our behalf.
Due Diligence Framework and Resources
As an initial matter, Spectrum Brands considered whether conflict minerals were necessary to the production or functionality of its products. In conducting its due diligence, Spectrum Brands implemented the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”), an internationally recognized due diligence framework, and related supplements for each of the conflict minerals. Accordingly, the steps taken by Spectrum Brands in preparing this Conflict Minerals Report were in accordance with the OECD Framework. As such, we used the RMI’s CMRT, which includes standard supply chain survey and information tracking methods, as part of: (i) determining if our manufactured products contained conflict minerals necessary to their functionality or production, (ii) performing a RCOI to determine whether such minerals originated in the DRC or a Covered Country, or are from recycled or scrap sources, and (iii) assessing our supply chain’s adherence to due diligence measures stated by the OECD Framework.
Reasonable Country of Origin Inquiry
Our Steering Committee reviewed the products manufactured or contracted to be manufactured by the Company in order to determine which products might contain conflict minerals that are necessary to their functionality or production; the list of products is contained on Attachment A to this Conflict Minerals Report. The Company conducted this review at a product level. A list of the suppliers determined to be in-scope for purposes of the conflict minerals rules was compiled and the RCOI was conducted as follows:
a. Spectrum Brands sent initial inquiries to 78 suppliers and instructed them to complete the CMRT and return it to Spectrum Brands.
b. For 2024, Spectrum Brands hired the Provider to engage its suppliers to collect information about the presence and sourcing of conflict minerals used in the products and components supplied to Spectrum Brands in the Calendar Year 2024 and by doing so add more transparency to Spectrum Brands’ supply chain with the ultimate goal of identifying the related smelters or refiners and associated mine countries of origin.
c. Spectrum Brands or the Provider conducted follow-up inquiries of the initially unresponsive suppliers.
d. Spectrum Brands or the Provider also conducted follow-ups with suppliers for further information if initial responses were incomplete or unclear.
e. Spectrum Brands or the Provider performed follow-ups with suppliers who returned an incomplete CMRT; all issues were addressed.
f. The Provider also evaluated the completed CMRTs for plausibility, consistency and gaps. Additional supplier contacts were conducted to attempt to resolve “quality control” flags, such as: (a) SORs were not provided for a used metal, (b) the supplier listed one or more SORs for an unused metal, (c) the supplier indicated that it had not identified all SORs for the in-scope products, (d) the supplier indicated it had not received conflict minerals data for each metal from all of its relevant suppliers, or (e) the supplier indicated that all of its conflict minerals were from recycled or scrap sources, but one or more of the SORs listed are not known to be exclusive recyclers.
g. After follow-up, Spectrum Brands had a 65% supplier response rate for those suppliers indicating that one or more of the conflict minerals are necessary to the functionality or production of the products they supply to Spectrum Brands.
Due Diligence Steps Performed
1. Steps Taken to Establish Strong Company Management Systems
a. Spectrum Brands continued disseminating conflict minerals information and updates internally through its Steering Committee, which implements and manages Spectrum Brands’ conflict minerals compliance program.
b. Spectrum Brands is committed to sourcing components and materials from companies that share its values about human rights, ethics and environmental responsibility. Spectrum Brands’ employees and the Steering Committee continue to enforce its Conflict Minerals Policy, which is available on the Company’s website at https://spectrumbrands.com/about-us/our-company/corporate-compliance/conflict-minerals.html. As required by our Conflict Minerals Policy, all of our suppliers are required to sign Spectrum Brands’ Supplier Code of Conduct, which includes requirements relating to conflict minerals and responsible sourcing. A copy of Spectrum Brands’ Supplier Code of Conduct can be found at https://www.spectrumbrands.com/about-us/suppliers/supplier-code-of-conduct.html. Spectrum Brands’ Supplier Code of Conduct (the “Code”) incorporates requirements related to conflict minerals so that current and future suppliers are obligated to comply with Spectrum Brands’ policies on conflict minerals, including participation in related due diligence activities.
c. Spectrum Brands educates its relevant employees and, in addition the Steering Committee, disseminates conflict minerals information through sourcing leads, supply chains, and sales forces.
d. Spectrum Brands maintains a grievance mechanism to enable the reporting of grievances related to conflict minerals and other supply chain matters.
e. Spectrum Brands retains conflict minerals program documentation in accordance with the Company’s record retention policies.
2. Steps Taken to Identify Risks in the Supply Chain and Strategies to Respond to Identified Risks.
a. Spectrum Brands identified the products it manufactured or contracted to manufacture in Calendar Year 2024.
b. Spectrum Brands identified 78 suppliers from whom it purchases components used in the production of those products, and which could contain conflict minerals necessary to the functionality or production of such products and solicited information from such suppliers as part of its RCOI. The Provider compared the list of the SORs collected to the Provider’s SOR database, which incorporates information from the lists publicly published by the RMI. Attached hereto as Exhibit A is a list of SORs identified by our suppliers with valid smelter certification identification numbers.
Spectrum Brands performed, and continues to perform, risk mitigation efforts to bring suppliers into conformity with its Conflict Minerals Policy and contractual requirements. These efforts included working with direct suppliers to consider alternative sources of components or supplying components which contain conflict minerals from sources listed as “conformant” or the equivalent by independent third party audit programs as sponsored by the RMI, London Bullion Market Association (the “LBMA”) and Responsible Jewellery Council (the “RJC”). Spectrum Brands publicly communicated its Conflict Minerals’ Policy on its website at https://spectrumbrands.com/about-us/our-company/corporate-compliance/conflict-minerals.html.
3. Carry out independent third-party audit of smelter/refiner due diligence practices.
The Company uses information publicly provided by the RMI, LBMA and RJC to confirm the existence and verify the OECD conformance status of SORs identified during due diligence. We are many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals, and we do not conduct any purchasing activities directly in the Covered Countries.
4. Mitigation Steps Spectrum Brands Has Taken or Will Take Since the End of Calendar Year 2024.
We undertook the following steps since the end of Calendar Year 2024 to mitigate the risk that our products may contain conflict minerals that benefit armed groups within the Covered Countries, including steps to improve our due diligence:
a. Continued to enforce our Conflict Minerals Policy, which is embedded in our Code, and disseminate the Code to those suppliers who provide raw materials and components in Spectrum Brands’ manufacturing operations and Spectrum Brands’ contract manufacturers.
b. Continued to enforce the process within Spectrum Brands’ manufacturing operations/procurement function to notify new vendors of our conflict minerals policy within the Code.
c. Published a copy of our current Form SD and this Conflict Minerals Report on our website at https://spectrumbrands.com/about-us/our-company/global-sustainability-statement.html.
d. Continued our supply chain due diligence with the assistance of our Provider, on the source and chain of custody of raw materials and components purchased for Spectrum Brands’ manufacturing operations. Spectrum Brands plans to continue to enhance supplier communication on conflict
minerals. Spectrum Brands values its supplier relationships, but if any supplier is at risk to or violates Spectrum Brands’ Conflict Minerals Policy or its Code, Spectrum Brands plans to require a corrective action plan from the supplier and move towards conflict free sourcing. Spectrum Brands will not ban sourcing from the Covered Countries, but it seeks to procure materials from responsible sources in the region to assist legitimate, conflict-free businesses there.
e. Because of Spectrum Brands’ size, the complexity of its products, and the depth, breadth and constant evolution of its supply chain, it is difficult to identify sub-tier suppliers downstream from its direct suppliers. Spectrum Brands does not purchase products directly from any suppliers, SORs or mines in the Covered Countries and has no direct contractual relationships with SORs, as previously noted. Instead, it relies on its direct suppliers to gather and provide specific information about the source of conflict minerals contained in the components supplied to it. Spectrum Brands’ direct suppliers are similarly reliant upon information provided by their suppliers. Therefore, the Provider’s assistance with unresponsive first tier suppliers is used to add transparency to the Spectrum Brands supply chain. Our suppliers identified 148 SORs potentially in the Spectrum Brands supply chain that our Provider’s database indicated as having valid smelter certification identification numbers. Additional investigation was undertaken to determine the source of and chain of custody of the conflict minerals. The following internationally accepted audit standards were reviewed: the RMI Responsible Minerals Assurance Process (“RMAP”), the LBMA Responsible Gold Guidance and the RJC Chain-of-Custody Standard.
f. Attached to this Conflict Minerals Report as Attachment A is a list of the 148 smelters with valid smelter certification numbers identified by our suppliers that provided product specific information; a list of the products covered by this Conflict Minerals Report; and a list of the smelter location for the metals that are necessary to the production of our products. We identified 48 suppliers that may source from Covered Countries. For the remainder of Spectrum Brands’ Fiscal Year 2025, Spectrum Brands plans to continue to emphasize to its suppliers the importance of sourcing responsibly and from conflict-free sources if the suppliers desire to retain Spectrum Brands’ business.
Pursuant to SEC rules and guidance, this Conflict Minerals Report was not subjected to an independent private sector audit.
Spectrum Brands’ review of its Conflict Minerals Report for January 1, 2023 through December 31, 2023 (“Calendar Year 2023”) found that Spectrum Brands had listed the location of the SORs in Attachment A as the country of origin of the corresponding minerals. For Calendar Year 2023, Spectrum Brands did not correctly determine the origin of any of the conflict minerals in its in-scope products.
Attachment A
List of Products
The following products are more fully described in Spectrum Brands Holdings, Inc. Form 10-K, which may be found publicly on our website at: https://investor.spectrumbrands.com/sec-spectrum-brands-holdings-inc.
•Electric shavers and accessories
•Grooming products and hair care appliances
•Small household appliances
•Personal care products
•Herbicides
•Insecticides and repellants
•Specialty pet supplies
•Household cleaning products
List of Identified Smelters
| | | | | | | | | | | |
| Metal | Standard Smelter Name | Smelter Country | Smelter ID |
| Gold | Agosi AG | GERMANY | CID000035 |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
| 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 Ronnskar | 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 | Dowa | JAPAN | CID000401 |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 |
| Gold | Heimerle + Meule GmbH* | GERMANY | CID000694 |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | CID000711 |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
| Gold | Istanbul Gold Refinery* | TURKEY | CID000814 |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF | CID001078 |
| Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
| 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 | MKS PAMP SA* | SWITZERLAND | CID001352 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
| 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 | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
| Gold | PX Precinox S.A. | SWITZERLAND | CID001498 |
| Gold | Rand Refinery (Pty) Ltd.* | SOUTH AFRICA | CID001512 |
| | | | | | | | | | | |
| Metal | Standard Smelter Name | Smelter Country | Smelter ID |
| Gold | Royal Canadian Mint | CANADA | CID001534 |
| 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, PROVINCE OF CHINA | CID001761 |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
| 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 | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
| 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 | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | CHINA | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd.* | CHINA | CID000917 |
| Tantalum | Materion Newton Inc.* | UNITED STATES OF AMERICA | CID002548 |
| 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 | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
| Tantalum | TANIOBIS Co., Ltd.* | THAILAND | CID002544 |
| Tantalum | TANIOBIS GmbH* | GERMANY | CID002545 |
| Tantalum | TANIOBIS Japan Co., Ltd.* | JAPAN | CID002549 |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG* | GERMANY | CID002550 |
| Tantalum | Telex Metals* | UNITED STATES OF AMERICA | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC* | KAZAKHSTAN | CID001969 |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED* | CHINA | CID000616 |
| Tin | Alpha | UNITED STATES OF AMERICA | CID000292 |
| | | | | | | | | | | |
| Metal | Standard Smelter Name | Smelter Country | Smelter ID |
| Tin | Aurubis Beerse* | BELGIUM | CID002773 |
| Tin | Aurubis Berango | SPAIN | CID002774 |
| 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 | Dowa | JAPAN | CID000402 |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
| Tin | Fenix Metals | POLAND | CID000468 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
| 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 | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
| Tin | Malaysia Smelting Corporation (MSC)* | MALAYSIA | CID001105 |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
| Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 |
| Tin | Minsur | PERU | CID001182 |
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
| Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
| Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 |
| Tin | PT Bangka Serumpun | INDONESIA | CID003205 |
| Tin | PT Bukit Timah | INDONESIA | CID001428 |
| Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 |
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | CID003381 |
| Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
| Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
| Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
| Tin | Resind Industria e Comercio Ltda.* | BRAZIL | CID002706 |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
| 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 Mineracao Ltda.* | BRAZIL | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
| Tungsten | A.L.M.T. Corp.* | JAPAN | CID000004 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | CHINA | CID000258 |
| | | | | | | | | | | |
| Metal | Standard Smelter Name | Smelter Country | Smelter ID |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | CHINA | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| Tungsten | H.C. Starck Tungsten GmbH* | GERMANY | CID002541 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA | CID000769 |
| 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 | Kennametal Fallon* | UNITED STATES OF AMERICA | CID000966 |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
| Tungsten | Masan High-Tech Materials | VIET NAM | CID002543 |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG* | GERMANY | CID002542 |
| Tungsten | Wolfram Bergbau und Hutten AG* | AUSTRIA | CID002044 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | CHINA | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd.* | CHINA | CID002082 |
* Denotes potential sourcing from a Covered Country based on information provided by the Provider.