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Exhibit 1.01
CONFLICT MINERALS REPORT
Pursuant to Rule 13P-1 under the Securities Exchange Act (17 CFR 240.13P-1)
FOR THE REPORTING PERIOD FROM
JANUARY 1, 2024, TO DECEMBER 31, 2024
I. INTRODUCTION
This Conflict Minerals Report (“report”) of Intuitive Surgical, Inc. (“Intuitive,” “we,” or “us”) for the year ended December 31, 2024, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (17 CFR Parts 240 and 249b) (the “Rule”).
Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (commonly referred to as “3TG”). If we know or have reason to believe that any of the Conflict Minerals necessary to the functionality or production of our products (i) may have originated in the Democratic Republic of the Congo (the “DRC”) and the adjoining countries (the “Covered Countries”), as defined in Item 1.01(d)(1) of Form SD, and (ii) may not be from recycled or scrap sources, we must perform due diligence on the source and chain of custody of our Conflict Minerals.
We are committed to our efforts to source materials from suppliers that share our values with regard to ethics, integrity, respect for human rights, and environmental responsibility. In support of the Rule, we expect our suppliers to establish due diligence programs to ensure proper monitoring and reporting of the use of Conflict Minerals in their supply chains. It is our policy that all of our suppliers in the supply chain comply with all applicable governmental laws, statutes, ordinances, rules, regulations, orders, and other requirements. It is also our policy to assess our relationship with any supplier whose supply chain includes minerals from a conflict source, which directly or indirectly benefits or finances armed groups in the Covered Countries.
Product Description
Product and brand names and logos, including Intuitive, da Vinci, and Ion, are trademarks or registered trademarks of Intuitive Surgical, Inc. or one of its subsidiaries, or of their respective owners. Additional information about our trademarks can be found on our website at www.intuitive.com/trademarks. Although we reference our trademarks located on our website, this list of trademarks and any other materials on our corporate website are not incorporated by reference into this report or any of our other filings under the Securities Act of 1933, as amended, or the Exchange Act.
Our manufactured products can be classified in two major categories: (1) da Vinci surgical systems and instruments and accessories and (2) Ion endoluminal systems and instruments and accessories (collectively, the “Covered Products”). The Covered Products contain Conflict Minerals that are necessary to the functionality or production of these products.
Da Vinci surgical systems, instruments and accessories, and digital solutions
Through December 31, 2024, there are several models of the da Vinci surgical system currently used by our customers: our recently released fifth-generation da Vinci 5 surgical system, our fourth-generation da Vinci X, da Vinci Xi, and da Vinci SP surgical systems, and our third-generation da Vinci Si surgical system. Our da Vinci surgical systems products generally include the following: surgeon’s console, patient-side cart, 3DHD vision system, Integrated Table Motion, and Firefly fluorescence imaging.
We sell various instruments and accessories which are used in conjunction with the da Vinci surgical systems as surgical procedures are performed. These products include da Vinci Instruments, da Vinci Stapling, da Vinci Energy, and accessory products.
We also offer customers digital solutions and connected offerings for streamlining performance with program-enhancing insights. These digital solution products include Intuitive Hosted & Managed Services, 3D Modeling Services, My Intuitive, and Intuitive Hub. Additionally, we provide learning technologies to help customers access training, including Intuitive Learning and SimNow, as well as enabling technologies that help bring innovative offerings to customers, including Telepresence and the Advanced Insights Suite.
Ion endoluminal system
The Ion endoluminal system is a flexible, robotic-assisted, catheter-based platform that utilizes Ion instruments and accessory products for which the first cleared indication is minimally invasive biopsies in the lung.
For a full description of the above product offerings, refer to our Annual Report on Form 10-K for the year ended December 31, 2024, and our Quarterly Report on Form 10-Q for the period ended March 31, 2025.
II. CONFLICT MINERALS COMPLIANCE PROGRAM
Our Conflict Minerals Compliance Program (the “Compliance Program”) has been designed to conform, in all material respects, to the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition” publication, which includes Supplements on Tin, Tantalum, Tungsten, and Gold, issued by the Organization for Economic Co-operation and Development (the “OECD Framework”). Our Compliance Program is designed to address the following five key objectives:
•Establish a Corporate Program for Conflict Minerals
•Identify and Assess Risk in the Supply Chain
•Design a Strategy to Respond to Identified Risk in the Supply Chain
•Fulfill Conflict Minerals Independent Audit and Reporting Obligations
•Maintain a Due Diligence Program: Internal Review and Monitoring
We maintain a cross-functional Conflict Minerals Steering Committee to monitor our Compliance Program with senior management support, including representatives from Global Supply Chain Operations, Corporate Finance, Legal, and Global Public Affairs.
The Conflict Minerals Steering Committee oversees a task force with representation from the relevant functions to design, implement, and execute the Compliance Program. The task force formally documents the Compliance Program, as approved by senior management, to ensure compliance with the Rule, including performance of the following measures:
•Maintenance of our Conflict Minerals policy on our website at https://www.intuitive.com/en-us/about-us/company/legal/governance.
•Provision of a Supplier Manual document to all candidates and existing first-tier suppliers that support our manufacturing operations. Included in this manual is a provision that describes our expectations with respect to suppliers’ involvement and participation to support our Compliance Program.
•Incorporation of specific language in our standard quality agreements for first-tier suppliers that requires participation in our Compliance Program.
•Maintenance of a Conflict Minerals Supplier Risk Assessment program (the “Risk Assessment”) using quantitative and qualitative factors to identify our first-tier suppliers that have not met (or are less likely to meet) our expectations to support our Compliance Program and Conflict Minerals policy by, for example, providing insufficient or no response to requests for information, failing to establish their own due diligence program, or not complying with the Rule.
We are a member of the Responsible Minerals Initiative (“RMI”) supporting the development and implementation of due diligence practices to further enable us to make informed decisions about Conflict Minerals in our supply chain. We support the Responsible Minerals Assurance Process (the “RMAP”), part of the RMI, which offers companies and suppliers independent, third-party audits that can help to assess the conflict status of smelters and refiners.
III. REASONABLE COUNTRY OF ORIGIN INQUIRY
For 2024, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the Conflict Minerals in our Covered Products originated in a Covered Country or came from recycled or scrap materials. To collect country of origin information from our suppliers, we conducted a supply chain survey with our suppliers using the Conflict Minerals Reporting Template (“CMRT”) maintained by the RMI. We utilized the RMI’s CMRT to request that our suppliers identify the facilities used to process the Conflict Minerals included in the supply chain of our Covered Products and their countries of origin. During the reporting period ended December 31, 2024, we received responses from approximately 93% of our first-tier suppliers. Refer
to our “Results of Due Diligence” section for a summary of the smelter and refiner statuses as reported by the RMI, the “Facilities Used to Process the Necessary Conflict Minerals” section for a listing of the smelters and refiners identified by our suppliers for each of the Conflict Minerals, and the “Countries of Origin of 3TG” section for a summary of the country of origin information collected.
We worked in good faith to obtain complete and accurate Conflict Minerals information from our suppliers. We evaluated the information collected, including subjecting the results to a quality review. If discrepancies, errors, or omissions were identified, the response for that supplier was deemed incomplete and was returned for correction by the supplier. If suppliers failed to return a complete CMRT, we conducted a number of follow-up inquiries. Follow-up actions may include email, phone, and in-person communications with the suppliers. First-tier suppliers not satisfying our RCOI requirement are escalated to management, as needed, based on our due diligence process.
Based on our RCOI efforts, we determined that Conflict Minerals used in our Covered Products may have originated in a Covered Country and may not have come from recycled or scrap sources. In response, we engaged in a due diligence effort to determine the source and chain of custody of these Conflict Minerals. Suppliers define the scope of their representations in the CMRT at their own discretion and, as a result, the information provided to us may be provided at a company level, division level, product category level, or at a product level. Therefore, as a downstream procurer of components that contain Conflict Minerals, our RCOI efforts and due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody on Conflict Minerals.
IV. DUE DILIGENCE FRAMEWORK AND IMPLEMENTATION
Design of Due Diligence Framework
Our due diligence framework has been designed to conform, in all material respects, to the OECD Framework.
Due Diligence Measures Undertaken
We are a downstream company and, although we have relationships with our first-tier (direct) suppliers, we do not have direct relationships with parties such as sub-tier (indirect) suppliers or the associated smelters and refiners who have knowledge of the sources of raw minerals. As the components included in our Covered Products are manufactured by sub-tier suppliers, we engaged a third party supply chain management firm to assist us in the identification of Conflict Minerals used in components manufactured by sub-tier suppliers that we could not identify on our own. In addition, we utilized a supply chain management firm to assist us with the collection of data needed for our RCOI and the due diligence review process for our first-tier and sub-tier suppliers.
We also designed and performed additional due diligence procedures for suppliers deemed to be “high risk” (based on our Risk Assessment) and those with responses identified to have “red flags,” including but not limited to:
◦The supplier’s response was not submitted utilizing the CMRT.
◦The supplier has indicated that Conflict Minerals are present in their products but does not provide smelter (or refiner) or country of origin data.
◦The supplier reported that the smelters or refiners are unknown or does not list them but confirms that none of the minerals originate from the Covered Countries.
◦The supplier has identified the country of origin information but does not identify a smelter or refiner.
◦The supplier identified a smelter or refiner that does not actually process the identified conflict mineral.
High-risk suppliers with risks that have not been sufficiently mitigated have specific, documented risk mitigation action plans assigned and reviewed with management. The nature of the actions is decided at management discretion.
In evaluating the smelters and refiners, we compared our survey responses with published data from the RMAP listing of validated smelters and refiners that are conformant with the RMAP assessment protocols. The RMAP relies on independent private sector auditors to audit the source, including mines of origin and chain of custody of the Conflict Minerals used by smelters and refiners that agree to participate in the RMAP.
Future Due Diligence Measures for Risk Mitigation
As Conflict Minerals data is obtained through a self-reporting effort, awareness and training of suppliers in our supply chain is necessary to ensure that reliable and detailed information is provided. We are a member of the RMI, supporting the development and implementation of due diligence practices to enable us to make informed decisions about Conflict Minerals in our supply chain. We intend to continue to work with our suppliers to improve the effectiveness of our due diligence procedures described above and to continue to emphasize the importance of compliance with our conflict minerals reporting expectations.
V. CONCLUSIONS
Inherent Limitations on Due Diligence Measures
As a downstream procurer of products which contain Conflict Minerals, our due diligence procedures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals. Our due diligence process is based on the necessity of seeking data from our direct and indirect suppliers. We also rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information may yield inaccurate or incomplete information and may be subject to misrepresentations or fraud.
Results of Due Diligence
Through our participation in the RMI, implementation of the OECD framework and requesting our suppliers to complete the CMRT survey, we have determined that seeking information about 3TG smelters or refiners in our supply chain from our suppliers represents the most reasonable effort that we can make to determine the mines or locations of origin of the 3TG in our supply chain.
Based on the data collected from our suppliers, we have concluded that most of the Conflict Minerals included in the supply chain of our Covered Products have been sourced from outside the Covered Countries. However, for some of the Conflict Minerals contained in the supply chain of our Covered Products, we have insufficient information from suppliers and other sources regarding the smelters and refiners that processed the Conflict Minerals and the related name and location of the mines used to conclude whether they originated in the Covered Countries and, if they did, whether those Conflict Minerals were from recycled or scrap sources, or other conflict free sources.
The results of our due diligence on the 3TG used in our Covered Products, using smelter and refiner statuses as reported by the RMI as of April 22, 2025, are noted in the table below.
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Table 1: Smelter or Refiner Status by Mineral |
2024 Smelters or Refiners | Tin | Tungsten | Tantalum | Gold | Total |
Number of smelters listed as “Conformant” 1 | 67 | 36 | 34 | 91 | 228 |
Number of smelters listed as “active” by RMI 2 | 3 | 1 | 0 | 4 | 8 |
Number of smelters listed as “Non-Conformant” by RMI 3 | 9 | 4 | 0 | 19 | 32 |
Number of smelters not yet active, and outreach is needed by RMAP member companies 4 | 12 | 15 | 3 | 68 | 98 |
| Total number of smelters | 91 | 56 | 37 | 182 | 366 |
(1)A “Conformant” audit status means the smelter or refiner has been assessed and found to conform with the relevant RMAP standard.
(2)An “Active” audit status means the smelter or refiner has engaged in the RMAP program but is not yet conformant.
(3)A “Non-Conformant” audit status means the smelter or refiner was assessed and found not to conform with the relevant RMAP standard.
(4)The smelter or refiner is not yet active, and outreach is needed by RMAP member companies to encourage them to participate in RMAP.
Facilities Used to Process the Necessary Conflict Minerals
The table below lists the known smelters and refiners and their locations as reported by our suppliers in the RMI’s CMRT.
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Table 2: List of Smelters or Refiners |
Mineral | Smelter or Refiner Name | Smelter or Refiner Location (Country) | | | |
| Tantalum | 5D Production OU | Estonia | | | |
| Gold | 8853 S.p.A. | Italy | | | |
| Tungsten | A.L.M.T. Corp. | Japan | | | |
| Gold | ABC Refinery Pty Ltd. | Australia | | | |
| Gold | Abington Reldan Metals, LLC | United States | | | |
| Tungsten | ACL Metais Eireli | Brazil | | | |
| Gold | Advanced Chemical Company | United States | | | |
| 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 | | | |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | | | |
| Gold | Albino Mountinho Lda. | Portugal | | | |
| Gold | Alexy Metals | United States | | | |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | | | |
| Tin | Alpha | United States | | | |
| Tantalum | AMG Brasil | Brazil | | | |
| Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam | | | |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | | | |
| Gold | Argor-Heraeus S.A. | Switzerland | | | |
| Tungsten | Artek LLC | Russian Federation | | | |
| Gold | Asahi Pretec Corp. | Japan | | | |
| Gold | Asahi Refining Canada Ltd. | Canada | | | |
| Gold | Asahi Refining USA Inc. | United States | | | |
| Gold | Asaka Riken Co., Ltd. | Japan | | | |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam | | | |
| 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 | | | |
| Tin | Aurubis Beerse | Belgium | | | |
| Tin | Aurubis Berango | Spain | | | |
| 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 | Caridad | Mexico | | | |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | | | |
| | | | | | | | | | | |
| Gold | Cendres + Metaux S.A. | Switzerland | | | |
| Gold | CGR Metalloys Pvt Ltd. | India | | | |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | | | |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | | | |
| Gold | Chimet S.p.A. | Italy | | | |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China | | | |
| Tin | China Tin Group Co., Ltd. | China | | | |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | | | |
| Gold | Chugai Mining | Japan | | | |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | | | |
| Gold | Coimpa Industrial LTDA | Brazil | | | |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | | | |
| Tin | CRM Synergies | Spain | | | |
| Tungsten | Cronimet Brasil Ltda | Brazil | | | |
| Tin | CV Ayi Jaya | Indonesia | | | |
| Tantalum | D Block Metals, LLC | United States | | | |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | | | |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | | | |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | | | |
| Tin | Dongguan Best Alloys Co., Ltd. | China | | | |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | | | |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | South Korea | | | |
| Gold | Dongwu Gold Group | China | | | |
| Gold | Dowa | Japan | | | |
| Tin | Dowa | Japan | | | |
| Tin | DS Myanmar | Myanmar | | | |
| Gold | DSC (Do Sung Corporation) | South 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 | | | |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam | | | |
| Gold | Elite Industech Co., Ltd. | Taiwan | | | |
| Tin | EM Vinto | Bolivia | | | |
| 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 | | | |
| Tin | Estanho de Rondonia S.A. | Brazil | | | |
| Tantalum | F&X Electro-Materials Ltd. | China | | | |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | | | |
| | | | | | | | | | | |
| Tin | Fenix Metals | Poland | | | |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | | | |
| Tantalum | FIR Metals & Resource Ltd. | China | | | |
| Gold | Fujairah Gold FZC | United Arab Emirates | | | |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | | | |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | | | |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | | | |
| Gold | Gasabo Gold Refinery Ltd | Rwanda | | | |
| 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 | | | |
| Gold | GG Refinery Ltd. | United Republic of Tanzania | | | |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India | | | |
| Tantalum | Global Advanced Metals Aizu | Japan | | | |
| Tantalum | Global Advanced Metals Boyertown | United States | | | |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | Australia | | | |
| Tungsten | Global Tungsten & Powders LLC | United States | | | |
| 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 | | | |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | | | |
| Gold | Guangdong Jinding Gold Limited | China | | | |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | | | |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | | | |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | | | |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | | | |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | | | |
| Tungsten | HANNAE FOR T Co., Ltd. | South Korea | | | |
| Gold | Heimerle + Meule GmbH | Germany | | | |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | | | |
| Gold | Heraeus Germany GmbH Co. KG | Germany | | | |
| Gold | Heraeus Metals Hong Kong Ltd. | China | | | |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | | | |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | | | |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | | | |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | | | |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | | | |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | | | |
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| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | | | |
| Gold | HwaSeong CJ CO., LTD. | South Korea | | | |
| Tungsten | Hydrometallurg, JSC | Russian Federation | | | |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR) | South Africa | | | |
| 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 | | | |
| Tungsten | Japan New Metals Co., Ltd. | Japan | | | |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | | | |
| Gold | Jiangxi Copper Co., Ltd. | China | | | |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | | | |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | | | |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | | | |
| Tin | Jiangxi New Nanshan Technology Ltd. | China | | | |
| Tantalum | Jiangxi Sanshi Nonferrous Metals Co., Ltd | China | | | |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | | | |
| Tantalum | Jiangxi Tuohong New Raw Material | China | | | |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | | | |
| Tungsten | Jiangxi Yaosheng Tungsten 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 | | | |
| Tungsten | JSC “Kirovgrad Hard Alloys Plant” | Russian Federation | | | |
| 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. | Japan | | | |
| Gold | K.A. Rasmussen | Norway | | | |
| Gold | Kaloti Precious Metals | United Arab Emirates | | | |
| Gold | Kazakhmys Smelting LLC | Kazakhstan | | | |
| Gold | Kazzinc | Kazakhstan | | | |
| Tantalum | KEMET de Mexico | Mexico | | | |
| Tungsten | Kenee Mining Corporation Vietnam | Vietnam | | | |
| Tungsten | Kennametal Fallon | United States | | | |
| Tungsten | Kennametal Huntsville | United States | | | |
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| Gold | Kennecott Utah Copper LLC | United States | | | |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | | | |
| Gold | Kojima Chemicals Co., Ltd. | Japan | | | |
| Gold | Korea Zinc Co., Ltd. | South 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 | L’Orfebre S.A. | Andorra | | | |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan | | | |
| Tungsten | Lianyou Resources Co., Ltd. | Taiwan | | | |
| Gold | Lingbao Gold Co., Ltd. | China | | | |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | | | |
| Tungsten | LLC Vostok | Russian Federation | | | |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | China | | | |
| Gold | LS MnM Inc. | South Korea | | | |
| Gold | LT Metal Ltd. | South Korea | | | |
| Tin | Luna Smelter, Ltd. | Rwanda | | | |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | | | |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China | | | |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | | | |
| Tungsten | MALAMET SMELTING SDN. BHD. | Malaysia | | | |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | | | |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia | | | |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | | | |
| Gold | Marsam Metals | Brazil | | | |
| Tungsten | Masan High-Tech Materials | Vietnam | | | |
| Gold | Materion | United States | | | |
| Tantalum | Materion Newton Inc. | United States | | | |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | | | |
| Gold | MD Overseas | India | | | |
| Tin | Melt Metais e Ligas S.A. | Brazil | | | |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | | | |
| Tin | Metallic Resources, Inc. | United States | | | |
| Gold | Metallix Refining Inc. | United States | | | |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | | | |
| 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 | | | |
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| Gold | Minera Titán del Perú SRL (MTP) - Belen Plant | Peru | | | |
| Tin | Mineracao Taboca S.A. | Brazil | | | |
| Tantalum | Mineracao Taboca S.A. | Brazil | | | |
| Tin | Mining Minerals Resources SARL | Democratic Republic of the Congo | | | |
| Tin | Minsur | Peru | | | |
| Gold | Mitsubishi Materials Corporation | Japan | | | |
| Tin | Mitsubishi Materials Corporation | Japan | | | |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | | | |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | | | |
| Gold | MKS PAMP SA | Switzerland | | | |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | | | |
| Gold | Modeltech Sdn Bhd | Malaysia | | | |
| Tin | Modeltech Sdn Bhd | Malaysia | | | |
| Tungsten | Moliren Ltd. | Russian Federation | | | |
| Gold | Morris and Watson | New Zealand | | | |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | | | |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | | | |
| Tungsten | Nam Viet Cromit Joint Stock Company | Vietnam | | | |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | | | |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam | | | |
| Gold | NH Recytech Company | South Korea | | | |
| Tungsten | Niagara Refining LLC | United States | | | |
| Gold | Nihon Material Co., Ltd. | Japan | | | |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | | | |
| Gold | NOBLE METAL SERVICES | United States | | | |
| Tin | Novosibirsk Tin Combine | Russian Federation | | | |
| Tantalum | NPM Silmet AS | Estonia | | | |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | | | |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | | | |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | | | |
| 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 | | | |
| Tungsten | OOO “Technolom” 1 | Russian Federation | | | |
| Tungsten | OOO “Technolom” 2 | Russian Federation | | | |
| Tin | Operaciones Metalurgicas S.A. | Bolivia | | | |
| Tin | P Kay Metal, Inc | United States | | | |
| Gold | Pease & Curren | United States | | | |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | | | |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation | Philippines | | | |
| Tungsten | Philippine Carreytech Metal Corp. | Philippines | | | |
| | | | | | | | | | | |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | | | |
| Gold | Planta Recuperadora de Metales SpA | Chile | | | |
| Tin | Pongpipat Company Limited | Myanmar | | | |
| Tantalum | PowerX Ltd. | Rwanda | | | |
| Tin | Precious Minerals and Smelting Limited | India | | | |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | | | |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | | | |
| Tin | PT Aries Kencana Sejahtera | Indonesia | | | |
| Tin | PT Arsed Indonesia | 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 Graha Raya | 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 Sukses Inti Makmur | Indonesia | | | |
| Tin | PT Timah Nusantara | Indonesia | | | |
| Tin | PT Timah Tbk Kundur | Indonesia | | | |
| Tin | PT Timah Tbk Mentok | Indonesia | | | |
| Tin | PT Tirus Putra Mandiri | Indonesia | | | |
| Tin | PT Tommy Utama | Indonesia | | | |
| Gold | PX Precinox S.A. | Switzerland | | | |
| Gold | QG Refining, LLC | United States | | | |
| Tantalum | QuantumClean | United States | | | |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | | | |
| Gold | Refinery of Seemine Gold Co., Ltd. | China | | | |
| Gold | REMONDIS PMR B.V. | Netherlands | | | |
| Tin | Resind Industria e Comercio Ltda. | Brazil | | | |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | | | |
| | | | | | | | | | | |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | | | |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | India | | | |
| Gold | Royal Canadian Mint | Canada | | | |
| Tin | Rui Da Hung | Taiwan | | | |
| Gold | SAAMP | France | | | |
| Gold | Sabin Metal Corp. | United States | | | |
| 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 | South Korea | | | |
| Gold | Samwon Metals Corp. | South Korea | | | |
| 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 | | | |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) 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 | | | |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | | | |
| 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. | South Korea | | | |
| Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province Of China | | | |
| Tin | Super Ligas | Brazil | | | |
| Gold | T.C.A S.p.A | Italy | | | |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | Japan | | | |
| Tantalum | Taki Chemical Co., Ltd. | Japan | | | |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | | | |
| Tantalum | TANIOBIS Co., Ltd. | Thailand | | | |
| Tantalum | TANIOBIS GmbH | Germany | | | |
| | | | | | | | | | | |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | | | |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | | | |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | | | |
| Tantalum | Telex Metals | United States | | | |
| Tin | Thaisarco | Thailand | | | |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | | | |
| Tin | Tin Technology & Refining | United States | | | |
| Gold | TITAN COMPANY LIMITED, JEWELLERY DIVISION | India | | | |
| Gold | Tokuriki Honten Co., Ltd. | Japan | | | |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | | | |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | | | |
| Gold | Torecom | South Korea | | | |
| Tungsten | Tungsten Vietnam Joint Stock Company | Vietnam | | | |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam | | | |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | | | |
| Gold | Umicore Precious Metals Thailand | Thailand | | | |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | | | |
| Tungsten | Unecha Refractory metals plant | Russian Federation | | | |
| Gold | United Precious Metal Refining, Inc. | United States | | | |
| Gold | Valcambi S.A. | Switzerland | | | |
| Tin | VQB Mineral and Trading Group JSC | Vietnam | | | |
| Gold | WEEEREFINING | France | | | |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | | | |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | | | |
| Gold | WIELAND Edelmetalle GmbH | Germany | | | |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | | | |
| Tin | Woodcross Smelting Company Limited | Uganda | | | |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | | | |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | | | |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | | | |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | | | |
| Gold | Yamakin Co., Ltd. | Japan | | | |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | | | |
| Gold | Yokohama Metal Co., Ltd. | Japan | | | |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China | | | |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | | | |
| Gold | Yunnan Copper Industry Co., Ltd. | China | | | |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | | | |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | | | |
Note: Smelter or refiner names and locations as reported by the RMI as of April 22, 2025.
Countries of Origin of 3TG
The below list aggregates the believed countries of origin for the smelters and refiners identified reported by our suppliers in the RMI’s CMRT which processed 3TG minerals during 2024:
Andorra, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Colombia, Czechia, Democratic Republic of the Congo, Estonia, France, Germany, Ghana, India, Indonesia, Italy, Japan, Kazakhstan, Kyrgyzstan, Lithuania, Malaysia, Mexico, Myanmar, Netherlands, New Zealand, Norway, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Singapore, South Africa, South Korea, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, Uganda, United Arab Emirates, United Republic of Tanzania, United States, Uzbekistan, Vietnam, Zimbabwe
The RMI does not provide a specific country of origin of the conflict minerals processed by conformant smelters or refiners. Due to business confidentiality reasons, the country of origin data is provided in an aggregated way based on country risk level. Thus, we were not able to determine with certainty the specific countries of origin of the conflict minerals processed by the listed conformant smelters or refiners.
Efforts to Determine the Mine or Location of Origin with the Greatest Possible Specificity
As part of our due diligence process, for those suppliers whose products were not found to be DRC conflict free, we took additional steps in an effort to determine the mine or location of origin, which included the follow-up procedures and the Risk Assessment program described above.
Based on the information collected and evaluated from our suppliers in the CMRT, we determined that the data was generally insufficient to identify the mine name or specific location of origin for those Conflict Minerals that may have been sourced from the Covered Countries. The CMRT states that the smelter or refiner fields are mandatory; however, specific mine data is not. As such, suppliers have provided less information in these fields and, in some instances, have not provided the data or identified the information as “confidential,” “trade secret,” or similar. Therefore, we have not always received adequate information to identify the applicable sources of such Conflict Minerals that may have directly or indirectly financed or benefited armed groups.
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Intuitive. These statements are based on the infrastructure and information available at the time that the RCOI process and due diligence process were performed. As noted above, a number of factors could introduce errors or otherwise affect our analysis and the disclosure provided herein.
These factors include, but are not limited to, gaps in product or product content information, gaps in supplier data, gaps in smelter data, errors or omissions by or of suppliers, errors or omissions of smelters, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the protocol, oversights or errors in conflict free smelter audits, materials sourced from the Covered Countries being declared secondary materials, certification programs that are not equally advanced for all industry segments and metals, and smuggling of Conflict Minerals to countries outside of the Covered Countries.
Forward-Looking Statements
This report contains “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. Forward-looking statements relate to expectations concerning matters that are not historical facts. Statements using words such as “estimates,” “projects,” “believes,” “anticipates,” “plans,” “expects,” “intends,” “may,” “will,” “could,” “should,” “would,” “targeted,” and similar words and expressions are intended to identify forward-looking statements. These forward-looking statements are necessarily estimates reflecting the judgment of Intuitive’s management and involve a number of risks and uncertainties that could cause actual results to differ materially from those suggested by the forward-looking statements. These forward-looking statements include, but are not limited to, statements based on current expectations, estimates, forecasts, and projections about the economies and markets in which Intuitive operates and Intuitive’s beliefs and assumptions regarding these economies and markets, as well as Intuitive’s actions with respect to compliance with the Rule. These forward-looking statements should be considered in light of
various important factors that could cause actual results to differ materially from those in the forward-looking statements, including the following: changes to regulations and requirements for assessing and reporting Conflict Minerals; litigation related to regulations and requirements for Conflict Minerals; and adverse publicity regarding Intuitive. Readers are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of this report and which are based on current expectations and are subject to risks, uncertainties, and assumptions that are difficult to predict, including those risk factors identified under the heading “Risk Factors” in Intuitive’s Annual Report on Form 10-K for the year ended December 31, 2024, as updated by Intuitive’s other filings with the Securities and Exchange Commission. Intuitive’s actual results may differ materially and adversely from those expressed in any forward-looking statement, and Intuitive undertakes no obligation to publicly update or release any revisions to these forward-looking statements, except as required by law.
