Exhibit 1.01
Best Buy Co., Inc.
Conflict Minerals Report
For The Year Ended December 31, 2024
This Conflict Minerals Report for Best Buy Co., Inc. (“Best Buy”, “we”, “us” or “our”) covers the reporting period from January 1,2024 to December 31, 2024, and is presented in accordance with the Securities Exchange Act of 1934, Rule 13p‐1 (the “conflict minerals law”).
This Report describes the design of our 2024 conflict minerals program and provides an account of how due diligence was applied to determine, to the best of our ability, the source, chain of custody, and facilities used to process certain minerals used in Best Buy’s private label products in order to verify that no non‐state armed groups in the Democratic Republic of the Congo (“DRC”) or an adjoining country (“covered country”) directly or indirectly benefitted. It is filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD and both documents are posted on our website at www.investors.bestbuy.com.
Overview of our Responsible Sourcing Program
Best Buy is committed to respecting human rights and the responsible sourcing of our private label products. We seek to ensure this commitment is fulfilled by engaging our direct suppliers and the smelters and refiners reported to be in our supply chain and, wherever possible, we further embed our commitment through contractual and policy requirements, including a supplier code of conduct that sets specific standards related to labor, health and safety, environmental practices, management systems and ethics, and includes provisions directly relating to the responsible sourcing of raw materials.
We recognize the immense complexity of globalized supply chains requires a collaborative approach to address shared challenges. To that end, Best Buy has a long history of engaging industry peers to develop, share and implement best practices that seek to mitigate supply chain risks.
In 2024, we engaged 61 of our private label suppliers to conduct due diligence on the responsible sourcing of raw materials. The 61 suppliers collectively reported 234 eligible tin, tungsten, tantalum, and gold facilities that may have processed the metals that were necessary to the functionality and/or production of our private label products. Of the 234 reported facilities, more than 89.74% have successfully completed a third‐party audit that assessed their responsible sourcing policies and practices, or they are in the process of completing a third‐party audit. For those facilities that had not committed to an audit, we conducted outreach to encourage their participation in an audit program or we requested their removal from our supply chain. While there are limitations to our program, such as having no contractual relationship with any smelters or refiners and having to rely on the information provided by several tiers of the supply chain which is challenging to verify, we are unable to confirm that any of the smelters and refiners reported to be in our supply chain sourced from mines that directly or indirectly financed or benefitted non‐state armed groups in the DRC or an adjoining country.
1
Products
Best Buy is driven by its purpose to enrich lives through technology and our vision to personalize and humanize technology solutions for every stage of life. We accomplish this by leveraging our combination of technology and a human touch to meet our customers’ everyday needs, whether they come to us online, visit our stores or invite us into their homes. In 2024, we had retail operations in the U.S. and Canada.
We sell private label product categories, under brand names Insignia, Dynex, Rocketfish, Platinum, Best Buy Essentials, and Modal collectively known as Exclusive Brands (“ExB”), in which we believe contain tin, tungsten, tantalum, and/or gold and are therefore within scope of our Reasonable Country of Origin Inquiry (“RCOI”) and due diligence efforts include the following:
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Product Category |
Product Examples |
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TV |
TVs. |
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Accessories |
Cables, chargers, keyboards, speakers, sound bars, etc. |
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Appliances |
Refrigerators, freezers, washing machines, microwaves, etc. |
Reasonable Country of Origin Inquiry
The DRC and its adjoining countries have massive reserves of tin, tantalum, tungsten, and gold (collectively known as “3TG”), all of which are commonly used in the manufacturing of many consumer products. Occasionally, these minerals are illegally mined, transported, taxed, and/or traded in the eastern DRC and surrounding areas by armed groups who use funds derived from these activities to fuel violence and commit human rights violations. As such, these minerals, regardless of where they are mined, are known as “conflict minerals.”
Pursuant to the conflict minerals law, we conducted a RCOI on the source of 3TG necessary to the functionality and/or production of our products (“necessary 3TG”) to determine whether any of the necessary 3TG originated in the DRC and its adjoining countries or were from recycled or scrap sources. As part of our RCOI process, we conducted the following activities:
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Reviewed past Conflict Minerals Reporting Templates ("CMRTs"), utilized a 3TG risk assessment tool and consulted with our engineering team to identify 61 active, in-scope, first‐tier suppliers we knew or had reason to believe used necessary 3TG in the production of ExB products (“relevant suppliers”); |
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Used the CMRT created by the RMI to survey relevant suppliers, requesting the names of the facilities that processed the necessary 3TG they utilized and the country of origin from which the ores (i.e., unrefined minerals) were sourced; |
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Reviewed information provided by the 61 relevant suppliers to determine the completeness and reasonableness of their responses and verified the processing facilities they identified by comparing against the list of known smelters and refiners as provided by RMI; |
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Reviewed country of origin information available to Best Buy through our membership in RMI (member ID V1720151223); and |
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Conducted additional research on the 3TG processing facilities identified by relevant suppliers, including direct contact and reviewing reports from media, government and civil society organizations, to augment the country of origin information gathered through CMRTs and our membership in RMI. |
2
Based on the results of our RCOI, we had reason to believe that some of the necessary 3TG used in ExB products may have been processed by facilities that sourced from the DRC or an adjoining country and may not have been from recycled or scrap sources. In compliance with the conflict minerals law, we then exercised due diligence on the source and chain of custody of the necessary 3TG processed by these facilities that conformed to an internationally recognized due diligence framework.
To determine, to the best of our ability, the source and chain of custody of the necessary 3TG used in ExB products, we conducted due diligence on our supply chain. Our due diligence measures were developed to ascertain if the minerals originated from the DRC or an adjoining country and, if so, whether armed groups directly or indirectly benefited as a result. Additional measures were designed to mitigate risks identified through the implementation of our due diligence process.
Design of our Due Diligence Measures
Our due diligence process is designed to conform, in all material aspects given our downstream position in the supply chain, to the Organisation for Economic Co‐operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict‐Affected and High‐Risk Areas, Third Edition, and the related supplements on tin, tantalum, tungsten and gold (collectively, the “OECD Guidance”), an internationally recognized due diligence framework. In accordance with the OECD Guidance, the design of our due diligence includes, but is not limited to, the following:
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1. |
Maintaining a strong company management system through the adoption of a Conflict Minerals Policy, the implementation of a conflict minerals governance structure, applying supply chain controls, and strengthened engagement with our suppliers. |
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2. |
Identifying and assessing risks by identifying relevant suppliers to engage in our RCOI and due diligence efforts, determining a reasonable engagement approach to identify smelters and refiners in our supply chain and assess their sourcing practices and reviewing and validating smelter information provided by suppliers to determine risks. |
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3. |
Responding to identified risks by reporting to senior management the findings derived from our RCOI and due diligence efforts, designing training for relevant suppliers to improve their systems of transparency and control, and devising and implementing a risk mitigation strategy that seeks to ensure necessary 3TG in the supply chain are conflict‐free. |
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4. |
Supporting independent, third‐party audits of smelters and refiners’ due diligence via our membership in and support of an industry association that developed a third‐party audit program. |
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5. |
Reporting on due diligence through our Specialized Disclosure and Conflict Minerals Report filed with the SEC and the inclusion of conflict minerals content in our annual Corporate Responsibility & Sustainability (CRS) report. |
3
Due Diligence Measures Performed
We worked with RMI and industry peers to ensure the implementation of our company’s due diligence process was aligned with the OECD Guidance and complemented and amplified the industry’s approach. The primary objective of this alignment was to maximize the efficiency and effectiveness of our efforts to identify smelters and refiners and encourage their participation in RMI’s Responsible Minerals Assurance Process (“RMAP”) or an equivalent program, including the London Bullion Market Association’s (“LBMA”) Good Delivery program and the Responsible Jewellery Council’s (“RJC”) Chain of Custody program. For this reporting period, we performed the due diligence measures described below, many of which go beyond compliance, on the source and chain of custody of necessary 3TG in the ExB supply chain that we knew or had reason to believe originated from the DRC or Covered Countries and may not have been from recycled or scrap sources:
OECD Guidance Step 1: Maintaining a strong company management system
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We maintained a Conflict Minerals Policy (“Policy”) that specifically requires our suppliers to utilize smelters and refiners (“SORs”) who have successfully completed a third‐party audit of their due diligence practices; |
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The Policy, communicated to all ExB suppliers, also requires in-scope suppliers to have a conflict minerals policy, provide an annual CMRT that identifies the SORs in their supply chain, and apply relevant aspects of the OECD Guidance to their sourcing practices. These requirements were assessed and reinforced when we conducted social compliance audits at supplier factories; |
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Our Policy expectations were further reinforced through our supplier code of conduct and contract language that obliges our suppliers to meet Policy requirements; |
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We maintained a conflict minerals governance structure comprised of an operations team and an executive committee that included the department heads from Legal, External Reporting & Accounting, Corporate Responsibility, Exclusive Brands, Government Affairs, Supply Chain, Merchandising, Best Buy Health, Inclusion & Belonging, and Communications & Public Affairs. The program is ultimately managed by our Chief Communications & Public Affairs Officer; |
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We further strengthened our engagement with relevant ExB suppliers by providing training regarding the conflict minerals law, our Policy requirements, and their role in supporting our RCOI and due diligence efforts; |
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We partnered with a third-party software platform to streamline data collection and reporting. The software is linked to the RMI facility database and maintains up-to-date information on Smelter and Refiner operational and conformance status, as well as RCOI information. The tool performs initial data validation checks on our suppliers’ CMRT data and has improved the quality of our suppliers’ CMRT data giving us more visibility to potential risk areas. We have streamlined communication through the platform by providing clear and consistent, automated email guides to drive corrective actions for suppliers, including submission reminders, data errors, and additional actions required; and |
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We tracked our program performance across a set of Key Performance Indicators (KPIs) as detailed in the table below: |
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Conflict Mineral Program KPIs |
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Percent of relevant ExB suppliers who received training material |
98.36% |
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Percent of products containing necessary 3TG that have had their supply chains surveyed |
100% |
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Percent of relevant ExB suppliers who returned a CMRT |
100% |
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Percent of relevant ExB suppliers who have a conflict minerals policy |
98.36% |
4
OECD Guidance Step 2: Identifying and assessing risks
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We surveyed relevant suppliers, via RMI’s Conflict Minerals Reporting Template, twice in 2024 to identify the SORs in the ExB supply chain. We required CMRTs be completed at a product level from more than 51% of relevant suppliers in 2024, resulting in more accurate data; |
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All our suppliers’ CMRTs underwent a two-step validation process. They were initially assessed through the software platform for completeness and accuracy and returned to vendors as needed to get additional information. We identified 16 suppliers with incomplete or inaccurate CMRTs and all 16suppliers returned an updated CMRT. This was followed by a more in-depth review by our team. 5 high risk CMRTs were identified as needing additional corrective action and we will continuously monitor these suppliers for their improvement in the coming year. |
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We reviewed data collected via our RCOI and due diligence efforts to determine if smelters in our supply chain may have been sourcing from a covered country and potentially directly or indirectly financed or benefited armed groups in the DRC or an adjoining country; |
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We conducted outreach to smelters and refiners who had not been audited to determine their level of conformance to the RMI standard or another independent third‐party standard and to encourage their participation in such a program; |
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We further assessed the level of risk posed by SORs reported to be in our supply chain via shared industry insights, media, and other stakeholder reports, publicly available information, and the results of third‐ party audits, including audit programs from RMI, LBMA and RJC; and |
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We also identified relevant suppliers that posed a risk of not complying with our contractual and policy requirements related to conflict minerals. |
OECD Guidance Step 3: Responding to identified risks
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We reported the findings of our RCOI and due diligence measures, the subsequent risks identified, and the risk mitigation strategies to the Executive Human Rights Committee; |
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We designed, implemented, and monitored risk mitigation strategies for suppliers who did not comply with our Policy and SORs that had not successfully completed a third‐party audit, including communications that reinforced our policy, providing additional training and support, and conducting audits which included corrective action plans; |
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We helped smelters and refiners prepare for a RMAP audit and complete corrective action plans post‐ audit, as needed; |
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We monitored progress on SORs who implemented post‐audit corrective action plans through our membership in RMI to ensure improvements were made and the audit successfully passed; and |
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We conducted 2 CMRT validation audits. These audits assess the due diligence capabilities of key ExB suppliers, determine their level of compliance with our contract and policy requirements, support better understanding of their alignment with the OECD Guidance, and build their due diligence capacity to improve sourcing practices and the quality of data received from suppliers. |
OECD Guidance Step 4: Supporting independent, third‐party audits of smelter and refiners’ due diligence
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We contributed to the development and implementation of an effective smelter audit program through our membership in the RMI, which administers the Responsible Minerals Assurance Process audits; |
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We attended the annual RMI conference to gather best practices and collaborate with industry peers. |
5
OECD Guidance Step 5: Reporting on due diligence
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We disclosed information regarding our due diligence efforts on the sourcing of 3TG via our Specialized Disclosure and the Conflict Minerals Report filed with the SEC and we will include information on our conflict minerals due diligence efforts in our fiscal 2025 CRS Report, which we intend to release in the summer of 2025 |
Results of Due Diligence Performed
We conducted the due diligence process described above to identify SORs and ascertain source and chain of custody information for the necessary 3TG in our ExB supply chain. We exclude products where the supplier merely has affixed brands, trademarks, logos, or labels to generic products manufactured by a third party, as permitted by Securities and Exchange Commission guidance.
In 2024, more than 89.74% of the processing facilities reported by relevant suppliers have been found conformant to the RMI, LBMA, or RJC standard via an independent, third‐party audit or they have committed to go through an audit. Nevertheless, based on our due diligence process and the subsequent information we gathered, we are unable to determine the origin of all the 3TG used in our products and whether armed groups directly or indirectly benefited. This is primarily due to incomplete information from suppliers who were unable to identify all the SORs used in their supply chain, often because of unwilling or inept upstream actors in their supply chain, company level CMRTs in which we are unable to discern which of the reported SORs processed the necessary 3TG in our products, and the lack of transparency among smelters who have not yet been audited, in particular, gold refiners. Further complicating our ability to determine the origin of all the necessary 3TG is our downstream position in which we have no contractual relationship with upstream actors.
Of the 234 smelters and refiners provided by relevant ExB suppliers, we identified 38 for which we had reason to believe that at least a portion of the 3TG they processed may have originated in the DRC or an adjoining country and may not have been from recycled or scrap sources. All 38 of these processing facilities have been found conformant through RMAP or another independent, third‐party audit program. Furthermore, we have not identified a supplier, smelter, or refiner who we have reason to believe may be sourcing from the DRC or an adjoining country and directly or indirectly benefiting armed groups.
We are also aware that allegations, including violence perpetrated by security forces at source mines and ties to corrupt business entities in the sourcing of gold, have been leveled against a few of the smelters reported to be in our supply chain. We take these allegations seriously and we are monitoring third‐party investigations and corrective actions taken by these smelters. Based on the results of these efforts, we may take additional action, up to and including the removal of these smelters from our supply chain.
6
Please see the table below for the status of facilities reported to us by relevant ExB suppliers and see Attachment A for the list of smelters and refiners, their location, and the countries from where they source, which is provided in aggregate by metal.
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Metal |
# of SORs |
Conformant (1) |
Active or TI‐CMC Member (1) |
Unknown (1) |
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Gold |
109 |
83.49% |
1.83% |
14.68% |
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Tantalum |
31 |
100% |
0% |
0% |
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Tin |
57 |
89.47% |
1.75% |
8.77% |
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Tungsten |
37 |
91.89% |
0% |
8.11% |
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Totals |
234 |
88.46% |
1.28% |
10.26% |
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(1) |
Facility status is defined as the following: |
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Facility Status |
Status Definition |
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Conformant |
Facilities as of May 9, 2025, that conform with a third‐party due diligence standard |
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Active or TI‐CMC Member |
Facilities that have committed to a RMAP audit or are participating in another independent third‐party audit program |
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Unknown |
Facilities for which we do not know to what degree they conform to the RMAP or another audit program’s standard |
Future Steps to Optimize Our Due Diligence Efforts
Best Buy is committed to be a socially and environmentally responsible corporation and this commitment extends throughout the length of our value chain, from the sourcing of raw material to the responsible recycling of products. We recognize that this commitment is a journey and one that we cannot take on our own. This challenge is exacerbated given the complexity of our supply chain, which is, in essence, in a constant state of flux. As a result, we will continue to focus our efforts on collaborating across industries to improve the systems of transparency and control in our supply chain. We will also continue our engagement with relevant suppliers to build their knowledge, so they are able to provide more complete and accurate information on the source of conflict minerals in our ExB supply chain and, furthermore, to impress upon them our expectation that they also apply the OECD Guidance in good faith.
Steps we intend to take in 2025 include:
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Continue to enhance the system used to store our CMRT results to improve data analysis and reporting; |
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Continue to conduct CMRT Validation audits at key supplier and leverage the learnings from these audits to update our training material that is delivered to all relevant suppliers; and |
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Continue to participate in RMI meetings to gather best practices and collaborate with industry peers. |
7
Attachment A
Many of the CMRT responses we received from relevant suppliers provided data at a company level, meaning they provided the names of smelters and refiners they believe supplied 3TG for all the products they produced, not just the products they produced for Best Buy. Therefore, the processing facilities listed in the table below represent the smelters and refiners provided by our suppliers, but we do not have sufficient information to confirm whether these are the actual smelters that processed necessary 3TG used in our products. Additionally, we are unable to conclusively determine the country of origin information for our necessary 3TG but based on the data gathered from suppliers, processing facilities, public information and RMI, we believe that the sources may include the countries listed in the table below.
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Metal |
Processing Facility Name (2) |
Location of Facility(2) |
Facility Status (3) |
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Gold |
Advanced Chemical Company |
UNITED STATES OF AMERICA |
Conformant |
|
Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN |
Conformant |
|
Gold |
Agosi AG |
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 METALFINE, Inc. |
JAPAN |
Conformant |
|
Gold |
Asaka Riken Co., Ltd. |
JAPAN |
Conformant |
|
Gold |
Aurubis AG |
GERMANY |
Conformant |
|
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES |
Conformant |
|
Gold |
Boliden Ronnskar |
SWEDEN |
Conformant |
|
Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
Conformant |
|
Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA |
Conformant |
|
Gold |
Chimet S.p.A. |
ITALY |
Conformant |
|
Gold |
Chugai Mining |
JAPAN |
Conformant |
|
Gold |
DSC (Do Sung Corporation) |
KOREA, REPUBLIC OF |
Conformant |
|
Gold |
Dowa |
JAPAN |
Conformant |
|
Gold |
Eco-System Recycling Co., Ltd. East Plant |
JAPAN |
Conformant |
|
Gold |
LT Metal Ltd. |
KOREA, REPUBLIC OF |
Conformant |
|
Gold |
Heimerle + Meule GmbH |
GERMANY |
Conformant |
|
Gold |
Heraeus Metals Hong Kong Ltd. |
CHINA |
Conformant |
|
Gold |
Heraeus Germany 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 |
Japan Mint |
JAPAN |
Conformant |
|
Gold |
Jiangxi Copper Co., Ltd. |
CHINA |
Conformant |
|
Gold |
Asahi Refining USA Inc. |
UNITED STATES OF AMERICA |
Conformant |
|
Gold |
Asahi Refining Canada Ltd. |
CANADA |
Conformant |
|
Gold |
JX Advanced Metals Corporation |
JAPAN |
Conformant |
|
Gold |
Kazzinc |
KAZAKHSTAN |
Conformant |
|
Gold |
Kennecott Utah Copper LLC |
UNITED STATES OF AMERICA |
Conformant |
|
Gold |
Kojima Chemicals Co., Ltd. |
JAPAN |
Conformant |
|
Gold |
LS MnM Inc. |
KOREA, REPUBLIC OF |
Conformant |
|
Gold |
Materion |
UNITED STATES OF AMERICA |
Conformant |
|
Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN |
Conformant |
|
Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA |
Conformant |
|
Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA |
Conformant |
|
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE |
Conformant |
|
Gold |
Metalor Technologies S.A. |
SWITZERLAND |
Conformant |
|
Gold |
Metalor USA Refining Corporation |
UNITED STATES OF AMERICA |
Conformant |
8
|
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 |
Nadir Metal Rafineri San. Ve Tic. A.S. |
TURKEY |
Conformant |
|
Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN |
Conformant |
|
Gold |
Nihon Material Co., Ltd. |
JAPAN |
Conformant |
|
Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN |
Conformant |
|
Gold |
MKS PAMP SA |
SWITZERLAND |
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 |
Royal Canadian Mint |
CANADA |
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 |
Solar Applied Materials Technology Corp. |
TAIWAN, PROVINCE OF CHINA |
Conformant |
|
Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
Conformant |
|
Gold |
Tanaka Kikinzoku Kogyo K.K. |
JAPAN |
Conformant |
|
Gold |
Shandong Gold Smelting Co., Ltd. |
CHINA |
Conformant |
|
Gold |
Tokuriki Honten Co., Ltd. |
JAPAN |
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 |
Yamakin Co., Ltd. |
JAPAN |
Conformant |
|
Gold |
Yokohama Metal Co., Ltd. |
JAPAN |
Conformant |
|
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA |
Conformant |
|
Gold |
Zijin Mining Group Gold Smelting Co. Ltd. |
CHINA |
Conformant |
|
Gold |
SAFINA A.S. |
CZECHIA |
Conformant |
|
Gold |
MMTC-PAMP India Pvt., Ltd. |
INDIA |
Conformant |
|
Gold |
KGHM Polska Miedz Spolka Akcyjna |
POLAND |
Conformant |
|
Gold |
T.C.A S.p.A |
ITALY |
Conformant |
|
Gold |
REMONDIS PMR B.V. |
NETHERLANDS |
Conformant |
|
Gold |
Korea Zinc Co., Ltd. |
KOREA, REPUBLIC OF |
Conformant |
|
Gold |
TOO Tau-Ken-Altyn |
KAZAKHSTAN |
Conformant |
|
Gold |
Abington Reldan Metals, LLC |
UNITED STATES OF AMERICA |
Conformant |
|
Gold |
Italpreziosi |
ITALY |
Conformant |
|
Gold |
WIELAND Edelmetalle GmbH |
GERMANY |
Conformant |
|
Gold |
SungEel HiMetal Co., Ltd. |
KOREA, REPUBLIC OF |
Conformant |
|
Gold |
Planta Recuperadora de Metales SpA |
CHILE |
Conformant |
|
Gold |
NH Recytech Company |
KOREA, REPUBLIC OF |
Conformant |
|
Gold |
Eco-System Recycling Co., Ltd. North Plant |
JAPAN |
Conformant |
|
Gold |
Eco-System Recycling Co., Ltd. West Plant |
JAPAN |
Conformant |
|
Gold |
Metal Concentrators SA (Pty) Ltd. |
SOUTH AFRICA |
Conformant |
|
Gold |
WEEEREFINING |
FRANCE |
Conformant |
|
Gold |
Gold by Gold Colombia |
COLOMBIA |
Conformant |
|
Gold |
Coimpa Industrial LTDA |
BRAZIL |
Conformant |
|
Gold |
GG Refinery Ltd. |
TANZANIA, UNITED REPUBLIC OF |
Conformant |
|
Gold |
Impala Platinum - Platinum Metals Refinery (PMR) |
SOUTH AFRICA |
Conformant |
|
Gold |
Elite Industech Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
Conformant |
|
Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
AUSTRIA |
Active |
|
Gold |
Bangalore Refinery |
INDIA |
Active |
|
Gold |
Cendres + Metaux S.A. |
SWITZERLAND |
Unknown |
|
Gold |
Kyrgyzaltyn JSC |
KYRGYZSTAN |
Unknown |
|
Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
RUSSIAN FEDERATION |
Unknown |
9
|
Gold |
Samduck Precious Metals |
KOREA, REPUBLIC OF |
Unknown |
|
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
CHINA |
Unknown |
|
Gold |
Torecom |
KOREA, REPUBLIC OF |
Unknown |
|
Gold |
Umicore Precious Metals Thailand |
THAILAND |
Unknown |
|
Gold |
Singway Technology Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
Unknown |
|
Gold |
Al Etihad Gold Refinery DMCC |
UNITED ARAB EMIRATES |
Unknown |
|
Gold |
Emirates Gold DMCC |
UNITED ARAB EMIRATES |
Unknown |
|
Gold |
Marsam Metals |
BRAZIL |
Unknown |
|
Gold |
SAAMP |
FRANCE |
Unknown |
|
Gold |
L'Orfebre S.A. |
ANDORRA |
Unknown |
|
Gold |
8853 S.p.A. |
ITALY |
Unknown |
|
Gold |
AU Traders and Refiners |
SOUTH AFRICA |
Unknown |
|
Gold |
Safimet S.p.A |
ITALY |
Unknown |
|
Tantalum |
Guangdong Rising Rare Metals-EO Materials Ltd. |
CHINA |
Conformant |
|
Tantalum |
F&X Electro-Materials Ltd. |
CHINA |
Conformant |
|
Tantalum |
XIMEI RESOURCES (GUANGDONG) LIMITED |
CHINA |
Conformant |
|
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA |
Conformant |
|
Tantalum |
Jiujiang Tanbre Co., Ltd. |
CHINA |
Conformant |
|
Tantalum |
AMG Brasil |
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 |
NPM Silmet AS |
ESTONIA |
Conformant |
|
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA |
Conformant |
|
Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
CHINA |
Conformant |
|
Tantalum |
Taki Chemical Co., Ltd. |
JAPAN |
Conformant |
|
Tantalum |
Telex Metals |
UNITED STATES OF AMERICA |
Conformant |
|
Tantalum |
Ulba Metallurgical Plant JSC |
KAZAKHSTAN |
Conformant |
|
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA |
Conformant |
|
Tantalum |
D Block Metals, LLC |
UNITED STATES OF AMERICA |
Conformant |
|
Tantalum |
FIR Metals & Resource Ltd. |
CHINA |
Conformant |
|
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CHINA |
Conformant |
|
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CHINA |
Conformant |
|
Tantalum |
KEMET de Mexico |
MEXICO |
Conformant |
|
Tantalum |
TANIOBIS Co., Ltd. |
THAILAND |
Conformant |
|
Tantalum |
TANIOBIS GmbH |
GERMANY |
Conformant |
|
Tantalum |
Materion Newton Inc. |
UNITED STATES OF AMERICA |
Conformant |
|
Tantalum |
TANIOBIS Japan Co., Ltd. |
JAPAN |
Conformant |
|
Tantalum |
TANIOBIS Smelting GmbH & Co. KG |
GERMANY |
Conformant |
|
Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES OF AMERICA |
Conformant |
|
Tantalum |
Global Advanced Metals Aizu |
JAPAN |
Conformant |
|
Tantalum |
Resind Industria e Comercio Ltda. |
BRAZIL |
Conformant |
|
Tantalum |
Jiangxi Tuohong New Raw Material |
CHINA |
Conformant |
|
Tantalum |
RFH Yancheng Jinye New Material Technology Co., Ltd. |
CHINA |
Conformant |
|
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA |
Conformant |
|
Tin |
Alpha Assembly Solutions Inc |
UNITED STATES OF AMERICA |
Conformant |
|
Tin |
PT Premium Tin Indonesia |
INDONESIA |
Conformant |
|
Tin |
Dowa |
JAPAN |
Conformant |
|
Tin |
EM Vinto |
BOLIVIA (PLURINATIONAL STATE OF) |
Conformant |
|
Tin |
Estanho de Rondonia S.A. |
BRAZIL |
Conformant |
|
Tin |
Fenix Metals |
POLAND |
Conformant |
|
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA |
Conformant |
|
Tin |
China Tin Group Co., Ltd. |
CHINA |
Conformant |
|
Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
Conformant |
|
Tin |
Metallic Resources, Inc. |
UNITED STATES OF AMERICA |
Conformant |
|
Tin |
Mineracao Taboca S.A. |
BRAZIL |
Conformant |
|
Tin |
Minsur |
PERU |
Conformant |
10
|
Tin |
Mitsubishi Materials Corporation |
JAPAN |
Conformant |
|
Tin |
Jiangxi New Nanshan Technology Ltd. |
CHINA |
Conformant |
|
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
Conformant |
|
Tin |
Operaciones Metalurgicas S.A. |
BOLIVIA (PLURINATIONAL STATE OF) |
Conformant |
|
Tin |
PT Mitra Stania Prima |
INDONESIA |
Conformant |
|
Tin |
PT Prima Timah Utama |
INDONESIA |
Conformant |
|
Tin |
PT Timah Tbk Kundur |
INDONESIA |
Conformant |
|
Tin |
PT Timah Tbk Mentok |
INDONESIA |
Conformant |
|
Tin |
Rui Da Hung |
TAIWAN, PROVINCE OF CHINA |
Conformant |
|
Tin |
Thaisarco |
THAILAND |
Conformant |
|
Tin |
White Solder Metalurgia e Mineracao Ltda. |
BRAZIL |
Conformant |
|
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CHINA |
Conformant |
|
Tin |
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
CHINA |
Conformant |
|
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
BRAZIL |
Conformant |
|
Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
Conformant |
|
Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
Conformant |
|
Tin |
CV Ayi Jaya |
INDONESIA |
Conformant |
|
Tin |
PT Rajehan Ariq |
INDONESIA |
Conformant |
|
Tin |
PT Cipta Persada Mulia |
INDONESIA |
Conformant |
|
Tin |
Resind Industria e Comercio Ltda. |
BRAZIL |
Conformant |
|
Tin |
Super Ligas |
BRAZIL |
Conformant |
|
Tin |
Aurubis Beerse |
BELGIUM |
Conformant |
|
Tin |
Aurubis Berango |
SPAIN |
Conformant |
|
Tin |
PT Bangka Prima Tin |
INDONESIA |
Conformant |
|
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
CHINA |
Conformant |
|
Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
CHINA |
Conformant |
|
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
CHINA |
Conformant |
|
Tin |
Tin Technology & Refining |
UNITED STATES OF AMERICA |
Conformant |
|
Tin |
Luna Smelter, Ltd. |
RWANDA |
Conformant |
|
Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
CHINA |
Conformant |
|
Tin |
PT Mitra Sukses Globalindo |
INDONESIA |
Conformant |
|
Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
BRAZIL |
Conformant |
|
Tin |
CRM Synergies |
SPAIN |
Conformant |
|
Tin |
PT Putera Sarana Shakti (PT PSS) |
INDONESIA |
Conformant |
|
Tin |
Mining Minerals Resources SARL |
CONGO, DEMOCRATIC REPUBLIC OF THE |
Conformant |
|
Tin |
Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING SMELTING |
JAPAN |
Conformant |
|
Tin |
Malaysia Smelting Corporation Berhad (Port Klang) |
MALAYSIA |
Conformant |
|
Tin |
Woodcross Smelting Company Limited |
UGANDA |
Conformant |
|
Tin |
Melt Metais e Ligas S.A. |
BRAZIL |
Active |
|
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CHINA |
Unknown |
|
Tin |
Gejiu Kai Meng Industry and Trade LLC |
CHINA |
Unknown |
|
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CHINA |
Unknown |
|
Tin |
Precious Minerals and Smelting Limited |
INDIA |
Unknown |
|
Tin |
Fabrica Auricchio Industria e Comercio Ltda. |
BRAZIL |
Unknown |
|
Tungsten |
A.L.M.T. Corp. |
JAPAN |
Conformant |
|
Tungsten |
Kennametal Huntsville |
UNITED STATES OF AMERICA |
Conformant |
|
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Global Tungsten & Powders LLC |
UNITED STATES OF AMERICA |
Conformant |
|
Tungsten |
Japan New Metals Co., Ltd. |
JAPAN |
Conformant |
|
Tungsten |
Kennametal Fallon |
UNITED STATES OF AMERICA |
Conformant |
|
Tungsten |
Wolfram Bergbau und Hutten AG |
AUSTRIA |
Conformant |
|
Tungsten |
Xiamen Tungsten Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA |
Conformant |
11
|
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
VIET NAM |
Conformant |
|
Tungsten |
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
CHINA |
Conformant |
|
Tungsten |
H.C. Starck Tungsten GmbH |
GERMANY |
Conformant |
|
Tungsten |
TANIOBIS Smelting GmbH & Co. KG |
GERMANY |
Conformant |
|
Tungsten |
Masan High-Tech Materials |
VIET NAM |
Conformant |
|
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Niagara Refining LLC |
UNITED STATES OF AMERICA |
Conformant |
|
Tungsten |
China Molybdenum Tungsten Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
PHILIPPINES |
Conformant |
|
Tungsten |
Lianyou Metals Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
Conformant |
|
Tungsten |
Hubei Green Tungsten Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Cronimet Brasil Ltda |
BRAZIL |
Conformant |
|
Tungsten |
Fujian Xinlu Tungsten Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
Tungsten Vietnam Joint Stock Company |
VIET NAM |
Conformant |
|
Tungsten |
Lianyou Resources Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
Conformant |
|
Tungsten |
Shinwon Tungsten (Fujian Shanghang) Co., Ltd. |
CHINA |
Conformant |
|
Tungsten |
KENEE MINING VIETNAM COMPANY LIMITED |
VIET NAM |
Conformant |
|
Tungsten |
Hunan Jintai New Material Co., Ltd. |
CHINA |
Unknown |
|
Tungsten |
Unecha Refractory metals plant |
RUSSIAN FEDERATION |
Unknown |
|
Tungsten |
ACL Metais Eireli |
BRAZIL |
Unknown |
|
Country of origin for the mined and recycled Gold processed by the facilities listed above may include: Albania, Algeria, Andorra, Angola, Antigua and Barbuda, Argentina, Australia , Austria, Azerbaijan, Bahamas, Bangladesh, Barbados, Belgium ,Benin, Bolivia, Bolivia (Plurinational State of), Bosnia and Herzegovina, Botswana, Brazil, Bulgaria, Burkina Faso, Cambodia, Cameroon, Canada, Cayman Islands, Chile, China, Chinese Taipei, 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, Latvia, Lebanon, Liberia, Liechtenstein, Lithuania, Luxembourg, Macao, Madagascar, Malaysia, Mali, Malta, Mauritania, Mexico, Moldova, Republic of, Mongolia ,Morocco, Mozambique, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Norway, Oman, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Puerto Rico, Romania, Saint Kitts and Nevis, Saint Vincent and Grenadines, Saudi Arabia, Senegal, Serbia, Singapore, Sint Maarten, Slomon Islands, Slovakia, Slovenia, South Africa, South Korea, Spain, Sri Lanka, Sudan, Suriname, Sweden, Switzerland, Tajikistan, Tanzania, Thailand, Timore-Leste, Togo, Trinidad and Tobago, Tunisia, Turkey, Uganda, United Arab Emirates, United Kingdom, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Zambia, Zimbabwe |
|||
|
Country of origin for the mined and recycled Tantalum processed by the facilities listed above may include: Australia, Belarus, Brazil, Burundi, Canada, China ,Chinese Taipei, Congo, Democratic Republic of the,Czech Republic, El Salvador, Estonia, Ethiopia, France, Germany, Hong Kong, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Korea, Republic of, Madagascar, Mexico, Mozambique, Nigeria, Russia, Rwanda, Sierra Leone, Singapore, Spain, Thailand, United Kingdom of Great Britain and Northern Ireland, United States of America, Zimbabwe |
|||
|
Country of origin for the mined and recycled Tin processed by the facilities listed above may include: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Bulgaria, Burundi, Canada, Chile, China, Chinese Taipei, Congo, Democratic Republic of the, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Korea, Republic of, Laos, Latvia, Lithuania, Luxembourg, Malaysia, Malta, Mexico, Mongolia, Morocco, Myanmar, Namibia, Netherlands, New Zealand, Nigeria, Peru, Philippines, Poland, Portugal, Puerto Rico, Romania, Russia, Rwanda, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sweden, Switzerland, Tanzania, Thailand, Tunisia, Turkey, Uganda, Ukraine, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Vietnam, Zambia |
|||
|
Country of origin for the mined and recycled Tungsten processed by the facilities listed above may include: Australia, Austria, Bolivia, Brazil, Burundi, Canada, China, Chinese Taipei, Congo, Democratic Republic of the, France, Germany, India, Ireland, Israel, Japan, Kazakhstan, Korea, Republic of, Malaysia, Mexico, Mongolia, Myanmar, Netherlands, Nigeria, Portugal, Russia, Rwanda, Singapore, South Africa, Spain, Switzerland, Tanzania, Thailand, Turkey, Uganda, Ukraine, United Arab Emirates, United Kingdom, United Kingdom of Great Britain and Northern Ireland, United States of America, Vietnam |
|||
12
|
(2) |
Facility name and location as reported by the Responsible Minerals Initiative. |
|
(3) |
Facility status is defined as the following: |
|
|
|
|
Facility Status |
Status Definition |
|
Conformant |
Facilities as of May 9, 2025, that conform with a 3rd party due diligence audit standard |
|
Active |
Facilities that have committed to a RMAP audit or are participating in another independent third‐party audit program |
|
Unknown |
Facilities for which we do not know to what degree they conform to the RMAP or another audit program’s standard |
13