Exhibit 1.01
KVH Industries, Inc.
CONFLICT MINERALS REPORT
This Conflict Minerals Report of KVH Industries, Inc. (“KVH”, “we”, or “our”) has been prepared pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2024 to December 31, 2024.
Rule 13p-1 and Form SD require companies to disclose certain information regarding products that they manufacture, or contract to manufacture, when: (a) those products contain one or more of the minerals gold, columbite-tantalite (coltan), cassiterite, or wolframite, or their derivatives tantalum, tin, and tungsten (the “Conflict Minerals”); (b) those Conflict Minerals are necessary to the functionality or production of those products; and (c) those Conflict Minerals originated, or may have originated, in the Democratic Republic of the Congo or in a country that shares an internationally recognized border with the Democratic Republic of the Congo (the “Covered Countries”).
Section 1. Product Review and Reasonable Country of Origin Inquiry
Section 1.1 Product Review
KVH conducted an analysis of its product lines and determined that Conflict Minerals are used in its system-level products and components.
Section 1.2 Reasonable Country of Origin Inquiry and Conclusion
KVH’s international supply chain is complex. KVH is several layers removed from the smelters in its supply chain, making it difficult to trace the origin of any Conflict Minerals necessary to the functionality or production of its products.
For our 2024 reasonable country of origin inquiry (“RCOI”), we reviewed our suppliers of direct materials, components and system-level products (collectively referred to as “Supplier Materials”). We generated internal reports analyzing all Supplier Material purchases for 2024 (“Total Supplier Spend”). We then ranked each supplier based on the aggregate Total Supplier Spend. We determined that suppliers with $50,000 or more in Total Supplier Spend accounted for approximately 95% of Total Supplier Spend made by KVH during 2024 and determined that it would be reasonable to concentrate our RCOI efforts on this group of 44 suppliers. We refer to this group of suppliers as our “Primary Suppliers.”
In our RCOI for 2024, we surveyed our Primary Suppliers using a template developed by the Responsible Business Alliance (RBA) and the Global e-Sustainability Initiative (GeSI) (the “Conflict Minerals Reporting Template”). KVH sent the Conflict Minerals Reporting Template to all 44 Primary Suppliers and received 41 responses, which represented approximately 93% of our targeted supplier group and approximately 93% of Total Supplier Spend. We made additional requests for responses from the three Primary Suppliers that did not respond initially, but our efforts were not successful. Of the 41 responses received by KVH, 12 indicated that the Conflict Minerals used in Supplier Materials supplied to KVH came from “conflict-free” sources and furnished a list of their verified smelters; 26 confirmed that no Conflict Minerals were used in the Supplier Materials supplied to KVH; and three indicated that their Supplier Materials contained Conflict Minerals and furnished a list of their smelters, some of which were not verified to be “conflict-free”.
The response rate of our Primary Suppliers increased from 91% in 2023 to 93% in 2024, and the number of respondents who reported themselves as DRC “conflict-free” also increased. The percentage of the responding Primary Suppliers who reported themselves as DRC “undeterminable” (including the three Primary Suppliers who sourced some of their materials from unverified smelters) decreased from 32% in 2023 to 7% in 2024. Thus, we concluded that, for 2024, as in prior reporting years, we do not have sufficient information from our suppliers or other sources to determine with specificity the countries of origin of the Conflict Minerals used in our products or whether they are from recycled or scrap sources. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the Covered Countries and/or are not from recycled or scrap sources.
Section 2. Due Diligence
KVH’s due diligence efforts related to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by KVH; (iii) for which the manufacture was completed during 2024; and (iv) for which KVH was unable to form the basis for a reasonable belief that none of the Conflict Minerals necessary to the functionality or production of those products originated in a Covered Country. The products, which are hereinafter referred to collectively as the “Covered Products,” include KVH’s mobile satellite communications products and components.
Section 2.1 Design of KVH’s Due Diligence Measures
KVH designed its due diligence measures to conform to the framework set forth in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”).
Section 2.2 Due Diligence Measures Performed by KVH
The due diligence processes followed by KVH are described below under sub-headings corresponding to the five-step framework of the OECD Guidance.
| 1. | Management Systems |
We previously established and have maintained throughout 2024 internal processes for Conflict Minerals supply chain due diligence and reporting. We have implemented a Conflict Minerals Policy Statement and related procedures to help support our supply chain due diligence efforts and communication processes designed to provide information, including our Conflict Minerals Policy Statement, to our suppliers and to the public. In this regard, our supplier purchase contracts include terms and conditions and other contractual flow-downs requiring supplier cooperation and compliance with KVH’s due diligence efforts. We also maintain a “Supplier Information” web page to facilitate supplier access to important documents, including but not limited to KVH’s Conflicts Minerals Policy Statement, General Terms and Conditions of Purchase and General Supplier Quality Clauses, each of which can be found at http://www.kvh.com/suppliers. Additionally, prior to any engagement with KVH, we generally require all prospective suppliers to (a) provide information about their due diligence program and the steps they have taken to determine whether there are any Conflict Minerals in their supply chain; and (b) submit a completed copy of their latest Conflict Minerals Reporting Template. This information gives our Global Supply Chain team early visibility into the compliance program maturity level and smelter base of prospective vendors before we start to do business with that company.
For 2024, our efforts to identify smelters/refiners in our supply chain was facilitated through the use of due diligence tools created by the Responsible Minerals Initiative (“RMI”) founded by the RBA and GeSI for independent third-party audit information, including the Conflict Minerals Reporting Template. The information furnished by our Primary Suppliers was reviewed and analyzed by our internal team led by KVH’s Materials Manager and retained within the company’s document retention system. The data obtained from our Primary Suppliers was vetted by our Global Supply Chain team and then used to generate a comprehensive list of all smelters/refiners that had been identified by our Primary Suppliers, which list was then cross-referenced against information from RMI’s Responsible Minerals Assurance Process (“RMAP”) to help us identify the compliant smelters/refiners and origin of minerals processed.
| 2. | Assessment of Risk in the Supply Chain |
In order to determine the origin of Conflict Minerals in the Covered Products:
| · | An initial meeting of our Global Supply Chain team was held on January 20, 2025, to review our 2024 annual spending and to determine the parameters of our RCOI for 2024. |
| · | On or around January 27, 2025, we sent letters to our Primary Suppliers, explaining our conflict minerals disclosure obligations and referring the suppliers to online training materials and instructions, and solicited survey responses using the Conflict Minerals Reporting Template. |
| · | Having received responses from only 29 of the 44 Primary Suppliers by March 30, 2025, a second meeting of our Global Supply Chain team was held on March 31, 2025, during which team members were tasked with following-up with all non-responsive Primary Suppliers. |
| · | Over the next 3 weeks, members of KVH’s Global Supply Chain team continued its efforts to contact the remaining Primary Suppliers, and by April 21, 2025, KVH had received responses from 41 of the 44 Primary Suppliers. Of the 41 respondents, 33 returned the Conflict Minerals Reporting Template and 8 provided a separate company statement regarding conflict minerals. |
| · | Having received responses from approximately 93% of our Primary Suppliers, which represented approximately 93% of Total Supplier Spend for 2024, KVH then reviewed the responses and followed up on any incomplete or ambiguous responses. |
| · | Our Global Supply Chain team then compared the smelters/refiners identified by its Primary Suppliers against the list of facilities that have received a “conformant” designation from the RMI’s RMAP, which designations provide country of origin and due diligence information on the Conflict Minerals sourced by such facilities. |
| 3. | Strategies to Respond to Identified Risks |
KVH’s due diligence efforts are an evolving process that we strive to improve by: (i) maintaining a supplier onboarding process that solicits information about sourcing of conflict minerals, (ii) focusing on the reliability and quality of the information received from our Primary Suppliers; (iii) reviewing responses and following up on incomplete, inaccurate or ambiguous data; (iv) contacting Primary Suppliers who have consistently reported products to be “DRC conflict undeterminable” or the equivalent to determine what steps they have taken to improve their due diligence processes; and (v) maintaining internal processes designed to emphasize the importance of supplier cooperation and compliance with our Conflict Minerals Policy Statement through readily accessible policies and contractual flow-down clauses governing the business relationship, which not only provide us with leverage to promote compliance but also the flexibility needed to reassess and/or terminate certain relationships, as appropriate.
| 4. | Independent Third-Party Audits |
As a result of KVH’s position in the supply chain, there are generally several tiers of suppliers between KVH and the smelters/refiners in our supply chain, and therefore we do not conduct or commission independent third-party audits of the smelters and refiners from which our Primary Suppliers source Conflict Minerals. KVH has relied upon industry initiatives, including the RMI’s RMAP, for independent third-party audit information.
| 5. | Reporting |
With the preparation and submission of this Conflict Minerals Report, KVH has provided a public report of its due diligence measures with regard to the sourcing of Conflict Minerals. A copy of this report is available at https://ir.kvh.com/financial-information/sec-filings.
Section 3. Results of Due Diligence
The response rate among our Primary Suppliers in 2024 was 93%. Among the responses, some of our Primary Suppliers were unable to identify any of the smelters or refiners used in the Supplier Materials supplied to us and certain responses also included names of smelters or refiners that we believe may have been incomplete or misidentified. Such names have not been included among the list of smelters and refiners identified by our Primary Suppliers in Annex 1 below.
In total, we identified approximately 385 smelters as potential sources of Conflict Minerals that were reported to be in the supply chain at some point during the 2024 calendar year. The table below presents the total number of identified smelters or refiners for each mineral and the corresponding percentage of each group that we have been able to verify as conflict-free according to information provided on the RMI website.
| Metal | Total Number of Identified Smelters for Each Metal | Identified Smelters or Refiners Verified or certified as RMAP Conformant | ||||||
| Gold | 188 | 51 | % | |||||
| Tantalum | 41 | 85 | % | |||||
| Tin | 96 | 73 | % | |||||
| Tungsten | 60 | 60 | % | |||||
For the Conflict Minerals contained in the Covered Products, KVH’s due diligence efforts failed to clarify whether the Conflict Minerals contained in those products may have originated in a Covered Country or came from recycled or scrap sources. Seven Primary Suppliers identified six smelters in their supply chains that KVH believes to be higher risk based on publicly available information regarding their location, namely:
| Mineral | Smelter | Location | ||
| Gold | African Gold Refinery | Uganda | ||
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | ||
| Tin | Mining Minerals Resources SARL | Republic of Congo | ||
| Tin | Luna Smelter, Ltd. | Rwanda | ||
| Tin | Woodcross Smelting Company Ltd. | Uganda | ||
| Tantalum | PowerX Ltd. | Rwanda |
RMI identified Mining Minerals Resources SARL of the Republic of Congo and Luna Smelter, Ltd. and PowerX Ltd. of Rwanda as “conformant”smelters.
Our Global Supply Chain team previously contacted the Primary Suppliers who identified the smelters listed above to confirm what efforts each has taken either to certify its smelters or to identify alternate sources. Each of the Primary Suppliers informed KVH that they do not directly purchase materials from any of the smelters listed above and that they were either (i) downstream distributors of components and/or (ii) engaged as build-to-print contract manufacturers who do not choose the components. Consequently, as in prior reporting years, we were unable to validate that any of the smelters or refiners identified by our Primary Suppliers, including the smelters identified above, are actually in our supply chain. We will continue to follow our risk-mitigation processes first implemented in 2019 to help identify possible higher-risk suppliers prior to engagement, and we intend to contact any new suppliers who identify higher-risk smelters such as these to confirm what efforts they have taken either to certify their smelters or to identify alternate sources, if necessary.
Based on our due diligence efforts, KVH has concluded that we do not have sufficient information to determine with specificity the country of origin of all of the Conflict Minerals in our Covered Products or to determine whether the Conflict Minerals were from recycled or scrap sources. Based on the information received from our Primary Suppliers, KVH believes that the facilities that may have been used to process Conflict Minerals in our Covered Products include the smelters and refiners listed in Annex 1 below.
As noted above, certain of our suppliers identified African Gold Refinery as a smelter in their supply chains. We understand that African Gold Refinery was sanctioned by the U.S. Department of the Treasury’s Office of Foreign Assets Control on March 17, 2022. KVH has no direct business with African Gold Refinery; we are a downstream consumer in the global supply chain leading from smelters and refiners of conflict minerals. However, given the responses by its suppliers, as part of the escalation process, KVH contacted the suppliers that identified African Gold Refinery as a smelter in their supply chains to request additional information regarding whether African Gold Refinery is actually in their supply chains as relevant to KVH. In response, certain suppliers notified us that they are not able to determine whether African Gold Refinery is in the KVH supply chain as a smelter given the complexity of the supply chain for the nature of the products. Accordingly, KVH has no basis to conclude affirmatively that African Gold Refinery is in its supply chain. KVH is continuing this review and will take appropriate steps regarding its supply chain as needed in connection with that review. KVH is committed to acting in full compliance with the U.S. sanctions, including in connection with its supply chain.
Section 4. Future Steps to Improve Due Diligence
In February 2024, KVH announced a staged wind-down of its manufacturing operations at its Middletown, Rhode Island facility. KVH expects that it will cease substantially all manufacturing activity by the end of 2025. As a result, KVH plans to reassess whether, as of December 31, 2025, it manufactures or contracts to manufacture any products. If not, KVH would expect to file a Form SD with respect to the year ending December 31, 2025 but not for periods thereafter.
In order to improve our due diligence process and compliance efforts during the portion of 2025 that it continues to manufacture or contract to manufacture products, KVH intends to continue to:
| · | gather additional information which will assist us in determining whether the Conflict Minerals we utilize benefit armed groups contributing to human rights violations; |
| · | collect and evaluate supplier responses and follow-up with those suppliers that we have deemed to be a higher risk due to incomplete or ambiguous responses; and |
| · | review, and, if necessary, reassess supplier relationships based on information and resources provided by third-party conflict minerals audit programs such as the RMI’s RMAP and other industry initiatives promoting responsible mineral sourcing practices. |
During the period that KVH continues to manufacture or contract to manufacture products, KVH will continue to expect our suppliers to reasonably assure us that the minerals in the products they supply are conflict-free.
Section 5. Forward Looking Statements
This report includes forward-looking statements that involve risks and uncertainties, including for example statements regarding our due diligence processes with respect to Conflict Minerals. Forward-looking statements are not guarantees of future performance. KVH assumes no obligation to revise or update any forward-looking statements for any reason, except as required by law.
Annex 1
* Denotes smelters/ refiners that received a “conflict-free” designation from an independent third-party audit program, as of May 27, 2025.
| Metal | Smelter or Refiner Name | Country |
| Gold | 8853 S.p.A. | Italy |
| Gold | ABC Refinery Pty Ltd. | Australia |
| Gold | Abington Reldan Metals, LLC* | United States of America |
| Gold | Advanced Chemical Company* | United States of America |
| Gold | African Gold Refinery | Uganda |
| Gold | Agosi AG* | Germany |
| Gold | Aida Chemical Industries Co., Ltd.* | Japan |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
| Gold | Albino Mountinho Lda. | Portugal |
| Gold | Alexy Metals | United States of America |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC)* | Uzbekistan |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao* | Brazil |
| Gold | Argor-Heraeus S.A.* | Switzerland |
| Gold | Asahi Pretec Corp.*1 | Japan |
| Gold | Asahi Refining Canada Ltd.* | Canada |
| Gold | Asahi Refining USA Inc.* | United States of America |
| Gold | Asaka Riken Co., Ltd.* | Japan |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | Attero Recycling Pvt Ltd | India |
| Gold | AU Traders and Refiners | South Africa |
| Gold | Augmont Enterprises Private Limited | India |
| Gold | Aurubis AG* | Germany |
| Gold | Bangalore Refinery | India |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | Philippines |
| Gold | Boliden Ronnskar* | Sweden |
| Gold | C. Hafner GmbH + Co. KG* | Germany |
| Gold | C.I Metales Procesados Industriales SAS | Colombia |
| Gold | Caridad | Mexico |
| Gold | CCR Refinery - Glencore Canada Corporation* | Canada |
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | CGR Metalloys Pvt Ltd. | India |
| Gold | Chimet S.p.A.* | Italy |
| Gold | Chugai Mining* | Japan |
| Gold | Coimpa Industrial LTDA* | Brazil |
1 This smelter has the same identification number as the entity identified by RMI as “ASAHI METALINE, Inc.,” a conformant smelter.
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
| Gold | Dongwu Gold Group | China |
| Gold | Dowa* | Japan |
| Gold | DSC (Do Sung Corporation)* | Republic of Korea |
| Gold | Eco-System Recycling Co., Ltd. East Plant* | Japan |
| Gold | Eco-System Recycling Co., Ltd. North Plant* | Japan |
| Gold | Eco-System Recycling Co., Ltd. West Plant* | Japan |
| Gold | Elite Industech Co., Ltd.* | Taiwan |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Gold | Fujairah Gold FZC | United Arab Emirates |
| Gold | Geib Refining Corporation | United States of America |
| Gold | GG Refinery Ltd.* | United Republic of Tanzania |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Gold by Gold Colombia* | Colombia |
| Gold | Gold Coast Refinery | Ghana |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd.* | China |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | Heimerle + Meule GmbH* | Germany |
| Gold | Heraeus Germany GmbH Co. KG* | Germany |
| Gold | Heraeus Metals Hong Kong Ltd.* | China |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
| Gold | HwaSeong CJ CO., LTD. | Republic of Korea |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR)* | South Africa |
| Gold | Impala Refineries – Base Metals Refinery (BMR)* | South Africa |
| Gold | Impala Rustenburg* | South Africa |
| Gold | Inca One (Chala One Plant) | Peru |
| Gold | Inca One (Koricancha Plant) | Peru |
| Gold | Industrial Refining Company | Belgium |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | China |
| Gold | International Precious Metal Refiners | United Arab Emirates |
| Gold | Ishifuku Metal Industry Co., Ltd.* | Japan |
| Gold | Istanbul Gold Refinery* | Turkey |
| Gold | Italpreziosi* | Italy |
| Gold | JALAN & Company | India |
| Gold | Japan Mint* | Japan |
| Gold | Jiangxi Copper Co., Ltd.* | China |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
| Gold | JSC Novosibirsk Refinery | Russian Federation |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | JX Nippon Mining & Metals Co., Ltd.*2 | Japan |
| Gold | K.A. Rasmussen | Norway |
| Gold | Kaloti Precious Metals | United Arab Emirates |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Kazzinc* | Kazakhstan |
| Gold | Kennecott Utah Copper LLC* | United States of America |
| Gold | KGHM Polska Miedz Spolka Akcyjna* | Poland |
| Gold | Kojima Chemicals Co., Ltd.* | Japan |
| Gold | Korea Zinc Co., Ltd.* | Republic of Korea |
| Gold | Kundan Care Products Ltd. | India |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | L'Orfebre S.A. | Andorra |
| Gold | LS MnM Inc.* | Republic of Korea |
| Gold | LT Metal Ltd.* | Republic of Korea |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Marsam Metals | Brazil |
| Gold | Materion* | United States of America |
| Gold | Matsuda Sangyo Co., Ltd.* | Japan |
| Gold | MD Overseas | India |
| Gold | Metal Concentrators SA (Pty) Ltd.* | South Africa |
| Gold | Metallix Refining Inc. | United States of America |
| Gold | Metalor Technologies (Hong Kong) Ltd.* | China |
| Gold | Metalor Technologies (Singapore) Pte., Ltd.* | Singapore |
| Gold | Metalor Technologies (Suzhou) Ltd.* | China |
| Gold | Metalor Technologies S.A.* | Switzerland |
| Gold | Metalor USA Refining Corporation* | United States of America |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V.* | Mexico |
| Gold | Mitsubishi Materials Corporation* | Japan |
2 This smelter has the same identification number as the entity identified by RMI as “JX Advanced Metals Corporation,” a conformant smelter.
| Gold | Mitsui Mining and Smelting Co., Ltd.* | Japan |
| Gold | MKS PAMP SA* | Switzerland |
| Gold | MMTC-PAMP India Pvt., Ltd.* | India |
| Gold | Modeltech Sdn Bhd | Malaysia |
| Gold | Morris and Watson | New Zealand |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S.* | Turkey |
| Gold | Navoi Mining and Metallurgical Combinat* | Uzbekistan |
| Gold | NH Recytech Company* | Republic of Korea |
| Gold | Nihon Material Co., Ltd.* | Japan |
| Gold | NOBLE METAL SERVICES | United States of America |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | Austria |
| Gold | Ohura Precious Metal Industry Co., Ltd.* | Japan |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
| Gold | Pease & Curren | United States of America |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | Planta Recuperadora de Metales SpA* | Chile |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | PT Aneka Tambang (Persero) Tbk* | Indonesia |
| Gold | PX Precinox S.A.* | Switzerland |
| Gold | QG Refining, LLC | United States of America |
| Gold | Rand Refinery (Pty) Ltd.* | South Africa |
| Gold | Refinery of Seemine Gold Co., Ltd. | China |
| Gold | REMONDIS PMR B.V.* | Netherlands |
| Gold | Royal Canadian Mint* | Canada |
| Gold | SAAMP | France |
| Gold | Sabin Metal Corp. | United States of America |
| Gold | Safimet S.p.A | Italy |
| Gold | SAFINA A.S.* | Czechia |
| Gold | Sai Refinery | India |
| Gold | Sam Precious Metals | United Arab Emirates |
| Gold | Samduck Precious Metals | Republic of Korea |
| Gold | Samwon Metals Corp. | Republic of Korea |
| Gold | Sancus ZFS (L’Orfebre, SA) | Colombia |
| Gold | Sellem Industries Ltd. | Mauritania |
| Gold | SEMPSA Joyeria Plateria S.A.* | Spain |
| Gold | Shandong Gold Smelting Co., Ltd.* | China |
| Gold | Shandong Humon Smelting Co., Ltd. | China |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | China |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | China |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China |
| Gold | Shirpur Gold Refinery Ltd. | India |
| Gold | Sichuan Tianze Precious Metals Co., Ltd.* | China |
| Gold | Singway Technology Co., Ltd. | Taiwan |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Solar Applied Materials Technology Corp.* | Taiwan |
| Gold | Sovereign Metals | India |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | Sudan Gold Refinery | Sudan |
| Gold | Sumitomo Metal Mining Co., Ltd.* | Japan |
| Gold | SungEel HiMetal Co., Ltd.* | Republic of Korea |
| Gold | Super Dragon Technology Co., Ltd. | Taiwan |
| Gold | T.C.A S.p.A* | Italy |
| Gold | Tanaka Kikinzoku Kogyo K.K.* | Japan |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd.* | China |
| Gold | Tokuriki Honten Co., Ltd.* | Japan |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | TOO Tau-Ken-Altyn* | Kazakhstan |
| Gold | Torecom | Republic of Korea |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining* | Belgium |
| Gold | United Precious Metal Refining, Inc.* | United States of America |
| Gold | Valcambi S.A.* | Switzerland |
| Gold | WEEEREFINING* | France |
| Gold | Western Australian Mint (T/a The Perth Mint)* | Australia |
| Gold | WIELAND Edelmetalle GmbH* | Germany |
| Gold | Yamakin Co., Ltd.* | Japan |
| Gold | Yokohama Metal Co., Ltd.* | Japan |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | China |
| Tantalum | 5D Production OU | Estonia |
| Tantalum | AMG Brasil* | Brazil |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | China |
| Tantalum | D Block Metals, LLC* | United States of America |
| Tantalum | Exotech Inc. | United States of America |
| Tantalum | F&X Electro-Materials Ltd.* | China |
| Tantalum | FIR Metals & Resource Ltd.* | China |
| Tantalum | Global Advanced Metals Aizu* | Japan |
| Tantalum | Global Advanced Metals Boyertown* | United States of America |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd.* | China |
| Tantalum | H.C. Starck Hermsdorf GmbH*3 | Germany |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | China |
| Tantalum | Jiangxi Sanshi Nonferrous Metals Co., Ltd | China |
| Tantalum | Jiangxi Tuohong New Raw Material* | China |
| Tantalum | Jiujiang Janny New Material Co., Ltd.* | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | China |
| Tantalum | Jiujiang Tanbre Co., Ltd.* | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* | China |
| Tantalum | KEMET de Mexico* | Mexico |
| Tantalum | Materion Newton Inc.* | United States of America |
| Tantalum | Metallurgical Products India Pvt., Ltd.* | India |
| Tantalum | Mitsui Mining and Smelting Co., Ltd.* | Japan |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | China |
| Tantalum | NPM Silmet AS* | Estonia |
| Tantalum | Plansee SE Reutte | Austria |
| Tantalum | PowerX Ltd.* | Rwanda |
| Tantalum | QuantumClean* | United States of America |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd.* | China |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | Taki Chemical Co., Ltd.* | Japan |
| Tantalum | TANIOBIS Co., Ltd.* | Thailand |
| Tantalum | TANIOBIS GmbH* | Germany |
| Tantalum | TANIOBIS Japan Co., Ltd.* | Japan |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG* | Germany |
| Tantalum | Telex Metals* | United States of America |
| Tantalum | Ulba Metallurgical Plant JSC* | Kazakhstan |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED* | China |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | China |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd.* | China |
| Tantalum | Zhuzhou Cemented Carbide Group Co. Ltd | China |
| Tin | Alpha Assembly Solutions Inc* | United States of America |
| Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam |
| Tin | Aurubis Beerse* | Belgium |
| Tin | Aurubis Berango* | Spain |
| Tin | Chengfeng Metals Co Pte Ltd* | China |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | China |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd.* | China |
| Tin | China Tin Group Co., Ltd.* | China |
3 This smelter has the same identification number as the entity identified by RMI as “QSIL Metals Hermsdorf GmbH,” a conformant smelter.
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda* | Brazil |
| Tin | CRM Synergies* | Spain |
| Tin | CV Ayi Jaya* | Indonesia |
| Tin | CV Venus Inti Perkasa* | Indonesia |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
| Tin | Dowa* | Japan |
| Tin | DS Myanmar* | Myanmar |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam |
| Tin | EM Vinto* | Bolivia |
| Tin | Estanho de Rondonia S.A.* | Brazil |
| Tin | Fábrica Auricchio | Brazil |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil |
| Tin | Feinhütte Halsbrücke GmbH | Germany |
| Tin | Fenix Metals* | Poland |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | China |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| Tin | Global Advanced Metals Greenbushes Pty Ltd.* | Australia |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* | China |
| Tin | HuiChang Hill Tin Industry Co., Ltd.* | China |
| Tin | Jiangxi New Nanshan Technology Ltd.* | China |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | China |
| Tin | Luna Smelter, Ltd.* | Rwanda |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China |
| Tin | Magnu's Minerais Metais e Ligas Ltda.* | Brazil |
| Tin | Malaysia Smelting Corporation (MSC)* | Malaysia |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang)* | Malaysia |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | Metallic Resources, Inc.* | United States of America |
| Tin | Mineracao Taboca S.A.* | Brazil |
| Tin | Mining Minerals Resources SARL* | Democratic Republic of the Congo |
| Tin | Minsur* | Peru |
| Tin | Modeltech Sdn Bhd | Malaysia |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | Novosibirsk Tin Combine | Russian Federation |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | Thailand |
| Tin | O.M. Manufacturing Philippines, Inc.* | Philippines |
| Tin | Operaciones Metalurgicas S.A.* | Plurinational State of Bolivia |
| Tin | Pongpipat Company Limited | Myanmar |
| Tin | Precious Minerals and Smelting Limited | India |
| Tin | PT Aries Kencana Sejahtera* | Indonesia |
| Tin | PT Artha Cipta Langgeng* | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya* | Indonesia |
| Tin | PT Babel Inti Perkasa* | Indonesia |
| Tin | PT Babel Surya Alam Lestari* | Indonesia |
| Tin | PT Bangka Prima Tin* | Indonesia |
| Tin | PT Bangka Serumpun* | Indonesia |
| Tin | PT Bangka Tin Industry* | Indonesia |
| Tin | PT Belitung Industri Sejahtera* | Indonesia |
| Tin | PT Bukit Timah* | Indonesia |
| Tin | PT Cipta Persada Mulia* | Indonesia |
| Tin | PT Menara Cipta Mulia* | Indonesia |
| Tin | PT Mitra Stania Prima* | Indonesia |
| Tin | PT Mitra Sukses Globalindo* | Indonesia |
| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Premium Tin Indonesia* | Indonesia |
| Tin | PT Prima Timah Utama* | Indonesia |
| Tin | PT Putera Sarana Shakti (PT PSS)* | Indonesia |
| Tin | PT Rajawali Rimba Perkasa* | Indonesia |
| Tin | PT Rajehan Ariq* | Indonesia |
| Tin | PT Refined Bangka Tin* | Indonesia |
| Tin | PT Sariwiguna Binasentosa* | Indonesia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
| Tin | PT Sukses Inti Makmur (SIM)* | Indonesia |
| Tin | PT Timah Nusantara* | Indonesia |
| Tin | PT Timah Tbk Kundur* | Indonesia |
| Tin | PT Timah Tbk Mentok* | Indonesia |
| Tin | PT Tinindo Inter Nusa* | Indonesia |
| Tin | PT Tirus Putra Mandiri | Indonesia |
| Tin | PT Tommy Utama* | Indonesia |
| Tin | Resind Industria e Comercio Ltda.* | Brazil |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | India |
| Tin | Rui Da Hung* | Taiwan |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | Super Ligas* | Brazil |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.* | Japan |
| Tin | Thaisarco* | Thailand |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd.* | China |
| Tin | Tin Technology & Refining* | United States of America |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | VQB Mineral and Trading Group JSC | Vietnam |
| Tin | White Solder Metalurgia e Mineracao Ltda.* | Brazil |
| Tin | Woodcross Smelting Company Limited* | Uganda |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | China |
| Tin | Yunnan Tin Company, Ltd. | China |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd.* | China |
| Tungsten | A.L.M.T. Corp.* | Japan |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil |
| Tungsten | Artek LLC | Russian Federation |
| Tungsten | Asia Tungsten Products Vietnam Ltd.* | Vietnam |
| Tungsten | China Molybdenum Tungsten Co., Ltd.* | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | China |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tungsten | Cronimet Brasil Ltda* | Brazil |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Republic of Korea |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd.* | China |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | China |
| Tungsten | Global Tungsten & Powders LLC* | United States of America |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | China |
| Tungsten | H.C. Starck Tungsten GmbH* | Germany |
| Tungsten | HANNAE FOR T Co., Ltd. | Republic of Korea |
| Tungsten | Hubei Green Tungsten Co., Ltd.* | China |
| Tungsten | Hunan Chenzhou Mining Co., Ltd.* | China |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch* | China |
| Tungsten | Hydrometallurg, JSC | Russian Federation |
| Tungsten | Japan New Metals Co., Ltd.* | Japan |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | China |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation |
| Tungsten | Kenee Mining Corporation Vietnam* | Vietnam |
| Tungsten | Kennametal Fallon* | United States of America |
| Tungsten | Kennametal Huntsville* | United States of America |
| Tungsten | Lianyou Metals Co., Ltd.* | Taiwan |
| Tungsten | Lianyou Resources Co., Ltd.* | Taiwan |
| Tungsten | LLC Vostok | Russian Federation |
| Tungsten | MALAMET SMELTING SDN. BHD. | Malaysia |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | China |
| Tungsten | Masan High-Tech Materials* | Vietnam |
| Tungsten | Moliren Ltd. | Russian Federation |
| Tungsten | Nam Viet Cromit Joint Stock Company | Vietnam |
| Tungsten | Niagara Refining LLC* | United States of America |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation |
| Tungsten | OOO “Technolom” 1 | Russian Federation |
| Tungsten | OOO “Technolom” 2 | Russian Federation |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation* | Philippines |
| Tungsten | Philippine Carreytech Metal Corp. | Philippines |
| Tungsten | Philippine Chuangxin Industrial Co., Inc.* | Philippines |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | Vietnam |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd.* | China |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG* | Germany |
| Tungsten | Tungsten Vietnam Joint Stock Company* | Vietnam |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | Wolfram Bergbau und Hutten AG* | Austria |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | China |
| Tungsten | Xiamen Tungsten Co., Ltd.* | China |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China |