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Exhibit 1.01

Glaukos Corporation

Conflict Minerals Report

for the Year Ended December 31, 2025

Glaukos Corporation (“Glaukos,” “the Company,” “we,” “our,” and “us”) has filed this Conflict Minerals Report (“CMR”) for the year ended December 31, 2025 to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) issuers whose manufactured products contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). The Rule focuses on 3TG emanating from the Democratic Republic of Congo (“DRC”) region and nine adjoining countries (together, the “Covered Countries”). If any Conflict Minerals contained in an issuer’s manufactured products that are necessary to the functionality or production of such products may have originated in the Covered Countries, or if the issuer is unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody and submit a CMR to the SEC that includes a description of those due diligence measures.

 

Forward-Looking Statements and Other Disclaimers

This Specialized Disclosure Report on Form SD contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, the Company’s risk mitigation and improvement plans may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to conflict minerals; (b) the ability of our suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward- looking statements are made as of the date hereof and we assume no obligation to update such statements, except as required by law.

The statements included in this CMR are based on the Reasonable Country of Origin Inquiry process and due diligence performed in good faith by Glaukos and are based on the information available at the time of such inquiry. A number of factors could introduce errors or otherwise affect the accuracy of these statements. These factors include, but are not limited to: (i) gaps in supplier or smelter data, (ii) errors or omissions by suppliers or smelters, (iii) uncertainty or varied interpretations of the disclosure requirements described in the SEC rules, (iv) inaccuracies by our suppliers in reporting the conflict minerals necessary to the functionality or manufacturing of our products, (v) the unfamiliarity of some suppliers and smelters with the diligence process and information required to be provided, which could lead to inaccurate or incomplete responses, (vi) timeliness of data received from our suppliers, (vii) information that is in the public domain may not be discovered despite having conducted a reasonable search, (viii) errors in publicly available information, (ix) language barriers or errors in translation could lead to inaccurate information, (x) oversights or errors in conflict-free smelter audits, (xi) materials sourced from the Covered Countries could be inaccurately declared as sourced from outside the Covered Countries, (xii) illegally tagged Conflict Minerals could be introduced into the supply chain without our knowledge or the knowledge of our suppliers, (xiii) difficulties obtaining information from companies that are no longer in business, and (xiv) smuggling of Conflict Minerals outside the Covered Countries, which could make identification of their place of origin more difficult.


Introduction

 

Glaukos is an ophthalmic pharmaceutical and medical technology company focused on developing and commercializing novel therapies for the treatment of glaucoma, corneal disorders, and retinal disease. We first developed Micro-Invasive Glaucoma Surgery ("MIGS") as an alternative to the traditional glaucoma treatment paradigm, launching our first MIGS device commercially in 2012, and continue to develop and advance a portfolio of novel, dropless platform technologies designed to meaningfully advance the standard of care and improve outcomes for patients suffering from chronic, sight-threatening diseases across the areas of glaucoma, corneal disorders such as keratoconus and dry eye, and retinal diseases. We have designed commercial and development-stage solutions to provide ophthalmologists with new treatment alternatives.

 

This CMR relates to the process undertaken for Glaukos products that were manufactured, or contracted to be manufactured, for commercial use during calendar year 2025 and that contain Conflict Minerals.

 

Executive Summary

We performed a Reasonable Country of Origin Inquiry (“RCOI”) on our suppliers, including those we believe provided materials or components containing 3TGs necessary to the manufacturing of our commercial products during calendar year 2025. Our due diligence process included contacting each supplier requesting conflict minerals data using the Conflict Minerals Reporting Template (“CMRT”); 90% of these suppliers responded to our inquiries. Our suppliers identified 337 valid smelters and refineries (“Smelters”). Of these 337 Smelters, we identified 48 as sourcing (or there was a reason to believe they may be sourcing) from the Covered Countries. Our due diligence review indicated that 32 of these Smelters have been audited and recognized as conformant to the Responsible Minerals Assurance Process (“RMAP”). This process was in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”). Glaukos conducted risk mitigation on the remaining 16 Smelters.

 

Company Management Systems

Glaukos established strong management systems based on Step 1 of the OECD Guidance.

· Step 1A - Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. We have adopted a conflict minerals policy as part of our Supplier Code of Conduct and Conflict Minerals Policy that is publicly available on our Investor website under the heading “Corporate Responsibility” at http://investors.glaukos.com. The Supplier Code of Conduct and Conflict Minerals Policy is communicated to our suppliers as part of the RCOI process.

· Step 1B - Structure internal management to support supply chain due diligence. We maintain a cross- functional internal team to support our supply chain due diligence efforts. This team reports its findings to a senior member of the supply chain management organization.

· Step 1C - Establish a system of transparency, information collection and control over the supply chain. We implemented a detailed process to collect required supplier and smelter RCOI and due diligence data. Full details on the supply chain data gathering are included in the RCOI and due diligence sections of this Report.

· Step 1D - Strengthen company engagement with suppliers. We engage directly with suppliers during the RCOI process. Additionally, we endeavor to include updated the terms and conditions in the agreements that will apply to our suppliers on a prospective basis to require them to work with us to source materials from smelters that, if sourcing from conflict-affected or high-risk areas, are either


conformant with the RMI’s RMAP assessment protocols (“RMAP Conformant”) or are working towards RMAP Conformance.

· Step 1E - Establish a company level grievance mechanism. Our employees and suppliers can anonymously report a violation of our policies according to our Code of Business Conduct and Ethics, ask questions or voice concerns by calling 1-844-462-5721, or online at www.glaukos.ethicspoint.com.

 

Reasonable Country of Origin Inquiry (RCOI)

We designed our RCOI process in accordance with Step 2A and 2B of the OECD Guidance. Our RCOI process involved two stages:

 

· Stage 1 - Supplier RCOI (Step 2A of the OECD Guidance)

· Stage 2 - Smelter RCOI (Step 2B of the OECD Guidance)

 

For the 2025 reporting period, Glaukos’ RCOI process was executed by Claigan Environmental Inc. (“Claigan”).

 

Supplier RCOI

 

We designed our supplier RCOI process to identify the smelters in our supply chain. Our supplier RCOI process for the 2025 reporting period included:

 

· developing a list of suppliers providing components for our commercial products

· contacting each supplier and requesting Conflict Minerals data using the industry-standard CMRT

· reviewing supplier responses for accuracy and completeness

· aggregating supplier-provided smelters into a single unique list of smelters meeting the definition of a smelter under one of three industry-recognized audit protocols

· reviewing the final smelter list (and comparing it to industry peers) to determine if we reasonably identified all the smelters in our supply chain.

 

Through the supplier RCOI process, we identified 337 Smelters in our supply chain.

 

Smelter RCOI

 

Due to the overlap between smelter RCOI and smelter due diligence, the smelter RCOI process is summarized in the due diligence section of this report.

 

Due Diligence

Glaukos’s due diligence process was designed in accordance with the applicable sections of Steps 2, 3, and 4 of the OECD Guidance.

 

For the 2025 reporting period, Glaukos’s smelter RCOI and due diligence process were executed by Claigan.


 

Smelter RCOI and Due Diligence

 

Glaukos’ smelter RCOI and due diligence processes were designed to meet the criteria of Step 2 of the OECD Guidance.

 

We engaged with each Smelter identified in our supply chain to determine whether or not they sourced from the Covered Countries. For Smelters that confirmed, either directly or through industry associations, that they did not source from the Covered Countries but who were not recognized as RMAP Conformant, we reviewed publicly available information to determine whether there was any evidence that contradicted the Smelter’s declaration. In doing so, we reviewed sources such as NGO publications, the most recent United Nations Group of Experts reports on the DRC, and performed public internet searches.

 

If Smelters did not respond to our inquiry, we reviewed the same publicly available sources to determine whether there was reason to believe the Smelter may have sourced from the Covered Countries during the reporting period.

 

We categorize Smelters that are sourcing (or that we have reason to believe may be sourcing) from the Covered Countries and not currently RMAP Conformant as high-risk. We plan to consider options to transition to smelters that reflect Glaukos’ company values, which may include engaging with our suppliers who source from these high-risk smelters or considering alternative suppliers for the relevant components.

 

Our suppliers identified 337 unique Smelters, of which 48 Smelters source, or there is a reason to believe they may source, from the Covered Countries. We determined that 32 of these Smelters have been audited and recognized as RMAP Conformant. Glaukos conducted risk mitigation on the remaining 16 Smelters.

 

Risk Mitigation

 

Glaukos conducted risk mitigation on 16 Smelters that were not recognized as RMAP Conformant and were sourcing (or there is a reason to believe they may be sourcing) from the DRC or surrounding countries. Glaukos’ risk mitigation was designed in accordance with Step 3B of the OECD Guidance and will be reported to the Company’s Management Compliance Committee in accordance with Step 3A of the OECD Guidance.

 

As part of our risk mitigation process, we performed additional due diligence to determine if there was any reason to believe the smelters directly or indirectly financed or benefited armed groups in the DRC or adjoining countries. We also attempted to verify with internal stakeholders and relevant suppliers whether 3TGs from the Smelter in question were actually in Glaukos’ supply chain during the 2025 reporting period, and considered whether we could find alternative products or suppliers. Finally, we have engaged directly with our suppliers to encourage them to source from Smelters that are audited and recognized as RMAP Conformant. These Smelters are scheduled to be re-visited in the 2026 reporting period.

 

During the due diligence process, Glaukos found that one of the 16 identified high risk Smelters was RMAP Conformant for the entirety of the reporting period in question and was removed from the RMAP Conformant list at the beginning of 2026. Around the same time, it was announced that the Smelter had ceased operations. Another of the 16 identified high risk Smelters was RMAP Conformant for the majority of the reporting period in question and was removed from the RMAP Conformant list in August 2025. Therefore, this facility was considered low risk for most of the reporting period in question. If this Smelter does not re-engage with the RMAP, Glaukos will follow-up with suppliers regarding this Smelter during the 2026 reporting period.


Risk Mitigation Improvement Plan

Glaukos is committed to continuous improvement in our due diligence process to further mitigate the risk that the 3TG materials in our products could directly or indirectly benefit or finance armed groups in the Covered Countries. As part of our efforts to mitigate this risk, new or renewed supplier contracts will require suppliers to substantially comply with our Supplier Code of Conduct and Conflict Minerals Policy, and provide information that will allow us to evaluate their Conflict Mineral sourcing status. Additionally, we are continuing to engage with and educate our suppliers to increase supplier response rates and improve the timeliness, accuracy and comprehensiveness of the supplier survey responses we receive. We are also continuing to work with our suppliers to encourage them to source from RMAP Conformant smelters when sourcing material from the Covered Countries.

 

 

Smelters and Refineries

 

 

 

3TG Metal

Standard Smelter Name

Gold

8853 S.p.A.

Gold

ABC Refinery Pty Ltd.

Gold

Abington Reldan Metals, LLC

Gold

Advanced Chemical Company

Gold

African Gold Refinery*

Gold

Agosi AG

Gold

Aida Chemical Industries Co., Ltd.

Gold

Al Etihad Gold Refinery DMCC

Gold

Albino Mountinho Lda.

Gold

Alexy Metals

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

Gold

AngloGold Ashanti Córrego do Sítio Mineração

Gold

Argor-Heraeus S.A.

Gold

ASAHI METALFINE, Inc.

Gold

Asahi Refining Canada Ltd.

Gold

Asahi Refining USA Inc.

Gold

Asaka Riken Co., Ltd.

Gold

Atlantic Copper, S.L.U.

Gold

Attero Recycling Pvt Ltd

Gold

AU Traders and Refiners

Gold

Augmont Enterprises Private Limited

Gold

Aurubis AG, Hamburg

Gold

Bangalore Refinery

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Gold

Boliden Mineral AB (Ronnskar)

Gold

C. Hafner GmbH + Co. KG

Gold

Caridad

Gold

Cendres + Métaux S.A.

Gold

CGR Metalloys Pvt Ltd.

Gold

Chimet S.p.A.

Gold

Chugai Mining

Gold

Coimpa Industrial LTDA


Gold

Daye Non-Ferrous Metals Mining Ltd.

Gold

Degussa Sonne / Mond Goldhandel GmbH

Gold

Dijllah Gold Refinery FZC

Gold

Dongwu Gold Group

Gold

Dowa

Gold

DSC (Do Sung Corporation)

Gold

Eco-System Recycling Co., Ltd. East Plant

Gold

Eco-System Recycling Co., Ltd. North Plant

Gold

Eco-System Recycling Co., Ltd. West Plant

Gold

Elite Industech Co., Ltd.

Gold

Emerald Jewel Industry India Limited (Unit 1)

Gold

Emerald Jewel Industry India Limited (Unit 2)

Gold

Emerald Jewel Industry India Limited (Unit 3)

Gold

Emerald Jewel Industry India Limited (Unit 4)

Gold

Emirates Gold DMCC

Gold

Fidelity Printers and Refiners Ltd.

Gold

Fujairah Gold FZC

Gold

Gasabo Gold Refinery Ltd

Gold

GG Refinery Ltd.

Gold

GGC Gujrat Gold Centre Pvt. Ltd.

Gold

Glencore Canada Corporation - CCR Refinery

Gold

Gold by Gold Colombia

Gold

Gold Coast Refinery

Gold

Gold Corporation - The Perth Mint

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

Gold

Heimerle + Meule GmbH

Gold

Heraeus Limited Hong Kong (HLH)

Gold

Heraeus Precious Metals Germany (HPMG)

Gold

Hunan Chenzhou Mining Co., Ltd.

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

Gold

HwaSeong CJ Co., Ltd.

Gold

Impala Platinum - Platinum Metals Refinery (PMR)

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

Gold

International Precious Metal Refiners

Gold

Ishifuku Metal Industry Co., Ltd.

Gold

Istanbul Gold Refinery

Gold

Italpreziosi

Gold

JALAN & Company

Gold

Japan Mint

Gold

Jiangxi Copper Co., Ltd.

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Gold

JSC Novosibirsk Refinery

Gold

JSC Uralelectromed*

Gold

JX Advanced Metals Corporation

Gold

K.A. Rasmussen

Gold

Kazakhmys Smelting LLC


Gold

Kazzinc

Gold

Kennecott Utah Copper LLC

Gold

KGHM Polska Miedź Spółka Akcyjna

Gold

Kojima Chemicals Co., Ltd.

Gold

Korea Zinc Co., Ltd.

Gold

Kundan Care Products Ltd.

Gold

Kyrgyzaltyn JSC

Gold

Kyshtym Copper-Electrolytic Plant ZAO

Gold

L'Orfebre S.A.

Gold

Lingbao Gold Co., Ltd.

Gold

LS MnM Inc.

Gold

LT Metal Ltd.

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

Gold

Marsam Metals

Gold

Materion

Gold

Matsuda Sangyo Co., Ltd.

Gold

MD Overseas

Gold

Metal Concentrators SA (Pty) Ltd.

Gold

Metallix Refining Inc.

Gold

Metalor Technologies (Hong Kong) Ltd.

Gold

Metalor Technologies (Singapore) Pte., Ltd.

Gold

Metalor Technologies (Suzhou) Ltd.

Gold

Metalor Technologies S.A.

Gold

Metalor USA Refining Corporation

Gold

Metalúrgica Met-Mex Peñoles S.A. De C.V.

Gold

Minera Titan del Peru SRL (MTP) - Belen Plant

Gold

Mitsubishi Materials Corporation

Gold

Mitsui Mining and Smelting Co., Ltd.

Gold

MKS PAMP SA

Gold

MMTC-PAMP India Pvt., Ltd.

Gold

Modeltech Sdn Bhd

Gold

Morris and Watson

Gold

Moscow Special Alloys Processing Plant

Gold

Nadir Metal Rafineri San. Ve Tic. A.Ş.

Gold

Navoi Mining and Metallurgical Combinat

Gold

NH Recytech Company

Gold

Nihon Material Co., Ltd.

Gold

NOBLE METAL SERVICES

Gold

Oegussa Oesterreichische Gold- und Silber-Scheideanstalt Gesm.b.H.

Gold

Ohura Precious Metal Industry Co., Ltd.

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

Gold

Pease & Curren

Gold

Penglai Penggang Gold Industry Co., Ltd.

Gold

Planta Recuperadora de Metales SpA

Gold

Prioksky Plant of Non-Ferrous Metals

Gold

PT Aneka Tambang (Persero) Tbk

Gold

PX Précinox S.A.


Gold

QG Refining, LLC

Gold

Rand Refinery (Pty) Ltd.

Gold

REMONDIS PMR B.V.

Gold

Royal Canadian Mint

Gold

SAAMP

Gold

Sabin Metal Corp.

Gold

Safimet S.p.A

Gold

SAFINA A.S.

Gold

SAM Precious Metals FZ-LLC

Gold

Samduck Precious Metals

Gold

Samwon Metals Corp.

Gold

SEMPSA Joyería Platería S.A.

Gold

Shandong Gold Smelting Co., Ltd.

Gold

Shandong Humon Smelting Co., Ltd.

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

Gold

Shenzhen CuiLu Gold Co., Ltd.

Gold

SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD.

Gold

Shenzhen Zhonghenglong Real Industry Co., Ltd.

Gold

Shirpur Gold Refinery Ltd.

Gold

Sichuan Tianze Precious Metals Co., Ltd.

Gold

Singway Technology Co., Ltd.

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

Gold

Solar Applied Materials Technology Corp.

Gold

SOLEIL METALS (Chala One Plant)

Gold

SOLEIL METALS (YAKARI Plant)

Gold

Sovereign Metals

Gold

State Research Institute Center for Physical Sciences and Technology

Gold

Sumitomo Metal Mining Co., Ltd.

Gold

SungEel HiMetal Co., Ltd.

Gold

Super Dragon Technology Co., Ltd.

Gold

T.C.A S.p.A

Gold

Tanaka Kikinzoku Kogyo K.K.

Gold

TITAN COMPANY LIMITED, JEWELLERY DIVISION

Gold

Tokuriki Honten Co., Ltd.

Gold

Tongling (Jinguan) Nonferrous Jinguan Copper Industry

Gold

TOO Tau-Ken-Altyn

Gold

Torecom

Gold

Umicore Precious Metals Thailand

Gold

Umicore S.A. Business Unit Precious Metals Refining

Gold

United Precious Metal Refining, Inc.

Gold

Valcambi S.A.

Gold

WEEEREFINING

Gold

WIELAND Edelmetalle GmbH

Gold

Yamakin Co., Ltd.

Gold

Yokohama Metal Co., Ltd.

Gold

Yunnan Copper Southwest Copper Branch


Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

Gold

Zijin Mining Group Gold Smelting Co. Ltd.

Tantalum

5D Production OU

Tantalum

AMG Brasil

Tantalum

D Block Metals, LLC

Tantalum

F&X Electro-Materials Ltd.

Tantalum

FIR Metals & Resource Ltd.

Tantalum

Global Advanced Metals Aizu

Tantalum

Global Advanced Metals Boyertown

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

Tantalum

Jiangxi Suns Nonferrous Materials Co. Ltd.

Tantalum

Jiangxi Tuohong New Raw Material

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

Tantalum

Jiujiang Tanbre Co., Ltd.

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

Tantalum

KEMET de Mexico

Tantalum

Materion Newton Inc.

Tantalum

Metallurgical Products India Pvt., Ltd.

Tantalum

Mineração Taboca S.A.

Tantalum

Mitsui Kinzoku Company, Limited

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

Tantalum

NPM Silmet AS

Tantalum

PowerX Ltd.

Tantalum

Resind Indústria e Comércio Ltda.

Tantalum

Solikamsk Magnesium Works OAO

Tantalum

Taki Chemical Co., Ltd.

Tantalum

TANIOBIS Co., Ltd.

Tantalum

TANIOBIS GmbH

Tantalum

TANIOBIS Japan Co., Ltd.

Tantalum

TANIOBIS Smelting GmbH & Co. KG

Tantalum

Telex Metals

Tantalum

Ulba Metallurgical Plant JSC

Tantalum

XIMEI RESOURCES (GUANGDONG) LIMITED

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

Tin

Alpha Assembly Solutions Inc

Tin

An Vinh Joint Stock Mineral Processing Company

Tin

Aurubis Beerse

Tin

Aurubis Berango

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

Tin

China Tin Group Co., Ltd.

Tin

Conecsus LLC

Tin

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

Tin

CRM Synergies


Tin

CV Ayi Jaya

Tin

Dongguan Best Alloys Co., Ltd.

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

Tin

Dowa

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

Tin

EM Vinto

Tin

Estanho de Rondônia S.A.

Tin

Fabrica Auricchio Industria e Comercio Ltda.

Tin

Fenix Metals

Tin

Gejiu City Fuxiang Industry and Trade Co., Ltd.

Tin

Gejiu Kai Meng Industry and Trade LLC

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

Tin

Global Advanced Metals Greenbushes Pty Ltd.

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

Tin

HuiChang Hill Tin Industry Co., Ltd.

Tin

Jiangxi New Nanshan Technology Ltd.

Tin

Longnan Chuangyue Environmental Protection Technology Development Co., Ltd

Tin

Luna Smelter, Ltd.

Tin

Ma'anshan Weitai Tin Co., Ltd.

Tin

Magnu's Minerais Metais e Ligas Ltda.

Tin

Malaysia Smelting Corporation (MSC)

Tin

Malaysia Smelting Corporation Berhad (Port Klang)

Tin

Melt Metais e Ligas S.A.

Tin

Metallic Resources, Inc.

Tin

Mineração Taboca S.A.

Tin

Mining Minerals Resources SARL

Tin

Minsur

Tin

Mitsubishi Materials Corporation

Tin

Modeltech Sdn Bhd

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

Tin

Novosibirsk Tin Combine

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

Tin

O.M. Manufacturing Philippines, Inc.

Tin

Operaciones Metalúrgicas S.A.

Tin

P Kay Metal, Inc

Tin

Precious Minerals and Smelting Limited

Tin

PT Aries Kencana Sejahtera

Tin

PT Arsed Indonesia

Tin

PT ATD Makmur Mandiri Jaya

Tin

PT Bangka Prima Tin

Tin

PT Cipta Persada Mulia

Tin

PT Masbro Alam Stania

Tin

PT Mitra Stania Prima

Tin

PT Mitra Sukses Globalindo

Tin

PT Premium Tin Indonesia


Tin

PT Prima Timah Utama

Tin

PT Putera Sarana Shakti (PT PSS)

Tin

PT Rajehan Ariq

Tin

PT Timah Tbk Kundur

Tin

PT Timah Tbk Mentok

Tin

Resind Indústria e Comércio Ltda.

Tin

RIKAYAA GREENTECH PRIVATE LIMITED

Tin

Rui Da Hung

Tin

Super Ligas

Tin

Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.

Tin

Thaisarco

Tin

Tin Smelting Branch of Yunnan Tin Co., Ltd.

Tin

Tin Technology & Refining

Tin

VQB Mineral and Trading Group JSC

Tin

White Solder Metalurgia e Mineração Ltda.

Tin

Woodcross Smelting Company Limited

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

Tungsten

A.L.M.T. Corp.

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

Tungsten

Asia Tungsten Products Vietnam Ltd.

Tungsten

China Molybdenum Tungsten Co., Ltd.

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

Tungsten

Cronimet Brasil Ltda

Tungsten

Fujian Xinlu Tungsten Co., Ltd.

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

Tungsten

Geo Enterprise

Tungsten

Global Tungsten & Powders LLC.

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

Tungsten

H.C. Starck Tungsten GmbH

Tungsten

Hubei Green Tungsten Co., Ltd.

Tungsten

Hunan Jintai New Material Co., Ltd.

Tungsten

Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch

Tungsten

Hydrometallurg, JSC

Tungsten

Japan New Metals Co., Ltd.

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

Tungsten

Jing Yuan Tungsten Technology Co., Ltd.

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

Tungsten

KENEE MINING VIETNAM COMPANY LIMITED

Tungsten

Kennametal Fallon

Tungsten

Kennametal Huntsville


Tungsten

LAOS SOUTHERN MINING SMELTING SOLE CO., LTD

Tungsten

Lianyou Metals Co., Ltd.

Tungsten

Lianyou Resources Co., Ltd.

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

Tungsten

Masan High-Tech Materials

Tungsten

Moliren Ltd.

Tungsten

Nam Viet Cromit Joint Stock Company

Tungsten

Niagara Refining LLC

Tungsten

NPP Tyazhmetprom LLC

Tungsten

OOO “Technolom” 1

Tungsten

OOO “Technolom” 2

Tungsten

Philippine Bonway Manufacturing Industrial Corporation

Tungsten

Philippine Carreytech Metal Corp.

Tungsten

S.P.T. spol.s r.o.

Tungsten

Shinwon Tungsten (Fujian Shanghang) Co., Ltd.

Tungsten

TANIOBIS Smelting GmbH & Co. KG

Tungsten

Tungamoy Metals Inc.

Tungsten

Tungsten Vietnam Joint Stock Company

Tungsten

Unecha Refractory Metals Plant

Tungsten

Uzbekistan Technological Metallurgical Complex JSC

Tungsten

Wolfram Bergbau and Hütten AG

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

Tungsten

Xiamen Tungsten Co., Ltd.

Tungsten

YUDU ANSHENG TUNGSTEN CO., LTD.

* Certain of our suppliers reported the presence of entities that were sanctioned by the United States Department of Treasury, Office of Foreign Assets Control, consisting of JSC Uralelectromed and African Gold Refinery. Because of the over-inclusive nature of the industry CMRT information collection process, and the nature of the supply chains and goods, we are unable to confirm this, or any, Smelter is or was active in our supply chain.

Forty-eight of the 337 unique Smelters identified during our RCOI either declared that they were sourcing, or there was reason to believe may be sourcing, from the Covered Countries. Based on the Smelters’ disclosures and the publicly available information, we have reason to believe these Smelters may be sourcing from the following Covered Countries: The Democratic Republic of the Congo, Rwanda, Burundi, Uganda, Tanzania, Angola, and Zambia. Our due diligence review indicated that 32 of these Smelters have been audited and recognized as RMAP Conformant.