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Exhibit 1.01
EATON CORPORATION plc
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2024
This Conflict Minerals Report (Report) is for calendar year 2024 and is filed as an exhibit to Eaton Corporation plc’s Form SD as required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the Rule).
Eaton Corporation plc (Eaton, the Company, we, us or our) is required to perform a reasonable country of origin inquiry into the sources of necessary conflict minerals in our products and disclose the results of such diligence. Conflict minerals have been defined as tin, tantalum, tungsten, and gold (the Conflict Minerals). The design of our due diligence program and related results are described below.
A copy of Eaton Corporation plc's Conflict Minerals Report is publicly available at www.eaton.com under "Responsible Sourcing of Conflict Minerals" at: https://www.eaton.com/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html. The contents of our website referred to in this Report are not incorporated by reference into this Report.
1.COMPANY OVERVIEW
Eaton Corporation plc is an intelligent power management company dedicated to protecting the environment and improving the quality of life for people everywhere. We make products for the data center, utility, industrial, commercial, machine building, residential, aerospace and mobility markets. We are capitalizing on the megatrends of the energy transition, electrification, and digitalization. The reindustrialization of and growth of megaprojects in North America and increased global infrastructure spending focused on clean energy programs are expanding our end markets and positioning Eaton for growth for years to come. We are strengthening our participation across the entire electrical power value chain and benefiting from momentum in the data center and utility end markets as well as a growth cycle in the commercial aerospace and defense markets. We are guided by our commitment to operate sustainably and with the highest ethical standards. Our work is accelerating the planet’s transition to renewable energy sources, helping to solve the world’s most urgent power management challenges, and building a more sustainable society for people today and for future generations.
Founded in 1911, Eaton has continuously evolved to meet the changing and expanding needs of our stakeholders. With revenues of $24.9 billion in 2024, the Company serves customers in more than 160 countries.
Eaton has five key business segments: Electrical Americas and Electrical Global, Aerospace, Vehicle, and eMobility. In 2024 Eaton considers all products to be in-scope and include, but are not limited to:
Electrical Americas and Electrical Global
The Electrical Americas segment consists of electrical components, industrial components, power distribution and assemblies, residential products, single phase power quality and connectivity, three phase power quality, wiring devices, circuit protection, utility power distribution, power reliability equipment, and services that are primarily produced and sold in North and South America. The Electrical Global segment consists of electrical components, industrial components, power distribution and assemblies, single phase and three phase power quality, and services that are primarily produced and sold outside of North and South America; as well as hazardous duty electrical equipment, emergency lighting, fire detection, intrinsically safe explosion-proof instrumentation, and structural support systems that are produced and sold globally.
Aerospace
The Aerospace segment is a leading global supplier of aerospace fuel, hydraulics, and pneumatic systems for commercial and military use as well as filtration systems for industrial applications. Products include hydraulic power generation systems for aerospace applications including pumps, motors, hydraulic power units, hose and fittings, electro-hydraulic pumps; controls and sensing products including valves, cylinders, electronic controls, electromechanical actuators, sensors, aircraft flap and slat systems and nose wheel steering systems; fluid conveyance products, including hose, thermoplastic tubing, fittings, adapters, couplings, sealing and ducting; and fuel systems including air-to-air refueling systems, fuel pumps, fuel inerting products, sensors, valves, adapters and regulators, mission systems including oxygen generation system, payload carriages, and thermal management products; high performance interconnect products including wiring connectors and cables. The Aerospace segment also includes filtration systems including hydraulic filters, bag filters, strainers and cartridges, and golf grips.
Vehicle
The Vehicle segment is a leader in the design, manufacture, marketing, and supply of: drivetrain, powertrain systems and critical components that reduce emissions and improve fuel economy, stability, performance, and safety of cars, light trucks and commercial vehicles. Products include transmissions, clutches, hybrid power systems, superchargers, engine valves and valve actuation systems, cylinder heads, locking and limited slip differentials, transmission controls, and fuel vapor components for the global vehicle industry.
eMobility
The eMobility segment designs, manufactures, markets, and supplies electrical and electronic components and systems that improve the power management and performance of both on-road and off-road vehicles. Products include high voltage inverters, converters, fuses, circuit protection units, vehicle controls, power distribution, fuel tank isolation valves, and commercial vehicle hybrid systems.
For additional information about our business segments, including the wide variety of products manufactured in each segment, refer to Eaton's 2024 Form 10-K.
2.REASONABLE COUNTRY OF ORIGIN INQUIRY
Purchased raw materials and parts are varied and are sourced from many suppliers. Eaton has a substantial number of suppliers globally that span across our business segments. Our supply chain is multi-tiered, and Eaton is typically many levels removed from the mines, smelters, and refiners. Therefore, Eaton must rely on its suppliers to provide information about the origin of the Conflict Minerals in its products for our reasonable country of origin inquiry (RCOI). Some of Eaton’s products may contain Conflict Minerals either from recycled sources or in their processed form.
For the reporting period from January 1 through December 31, 2024, Eaton conducted a good faith RCOI of the Conflict Minerals that are necessary to the functionality or production of the products that Eaton manufactured or contracted with others to manufacture during the reporting period. Based on this RCOI, Eaton was unable to conclude that these Conflict Minerals did not originate from the Democratic Republic of the Congo (the DRC) or adjoining countries. Accordingly, Eaton undertook further due diligence measures on the source and chain of custody of the identified necessary Conflict Minerals.
3.CONFLICT MINERALS DUE DILIGENCE
3.1 Design of Due Diligence Program and Overview
Our due diligence program measures were designed to conform, in all material respects, with the internationally recognized due diligence framework set forth in The Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, and the related supplements on tin, tantalum, tungsten and gold. Pursuant to this framework, we undertook to: (a) establish strong company management systems, (b) identify and assess risks in our supply chain, (c) design and implement a strategy to respond to the identified risks, (d) carry out independent third-party audits of smelter/refiner's due diligence practices, and (e) report annually on supply chain due diligence.
3.2 Due Diligence Measures Performed
a. Establish Strong Company Management Systems
Eaton has taken steps to develop strong company management systems pertaining to the use of Conflict Minerals in our products and supply chain. These include the adoption of a responsible sourcing of conflict minerals policy, which is available at http://www.eaton.com/content/eaton/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html.
In addition, we have implemented an internal management reporting structure to manage and oversee Eaton’s Conflict Minerals activities consisting of a dedicated Conflict Minerals team and executive-level Conflict Minerals Steering Committee chaired by Eaton’s Vice President for Global Supplier Performance and comprising members from Eaton's Sustainability, Supply Chain and Legal teams. The Steering Committee oversees and supports the Company’s conflict minerals compliance efforts to meet the reporting requirements of the Rule. The Steering Committee meets periodically and regularly monitors and reviews compliance activities including the results of compliance activities against prior year’s results.
We have also established formal requirements for suppliers related to the use and reporting of Conflict Minerals, including the implementation of a supplier Conflict Minerals solicitation process utilizing tools created by the Responsible Minerals Initiative (RMI) which includes the Conflict Minerals Reporting Template (CMRT). In this reporting period Eaton requested that its suppliers use the CMRT version 6.4 (which was released in April 2024). Through our policy and participation in RMI, Eaton is committed to responsible sourcing of Conflict Minerals from the DRC and adjoining countries and requires suppliers and smelters or refiners to source responsibly from these regions. Through our RMI participation and in our due diligence program we include Conflict Affected and High-Risk Areas (CAHRA).
We retain relevant Conflict Minerals documentation and records in accordance with our record retention policy and procedures.
Finally, we maintain a global ethics e-mail address and telephone helpline (http://www.eaton.com/content/eaton/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html) which can be used by employees, suppliers or other stakeholders to report any concerns relating to Eaton’s sourcing activities. It is our policy that if any concerns about conflict minerals sourcing are reported, we will investigate appropriately.
b. Identify and Assess Risks in our Supply Chain
As a downstream user of Conflict Minerals, Eaton is many layers removed from the mine or location from which the Minerals originated and the smelters and refiners which processed the Minerals. Eaton does not purchase raw ore or unrefined conflict minerals, and, to the best of our knowledge, conducts no purchasing activities directly in the DRC or adjoining countries.
We solicited relevant suppliers using due diligence tools including the RMI’s CMRT. Our solicitation letter included an explanation of the Conflict Minerals and the related legal regulations, and a request for suppliers to comply with the regulations, our policy and Supplier Code of Conduct and to respond to us at our contact information to direct any questions. Additional solicitation requests, including in additional languages beyond English, were sent to suppliers that did not respond or provide sufficient information. Through this process, during 2024 we solicited approximately 1,000 suppliers.
We verified the information provided by our suppliers (to the extent possible) by comparing it to the information shared on the RMI website and monthly plenary calls, and against CMRT acceptance criteria for completeness and consistency of responses. Through this process, for suppliers who provided names of smelters and refiners, we determined the conformance status of those supplier-reported smelters and refiners. For those suppliers who provided country of origin information for the Conflict Minerals, we confirmed the listed countries of origin for each smelter and refiner if that information was available from RMI. If there are discrepancies between the supplier information and RMI’s, we made follow up inquiries with our suppliers following RMI's acceptance criteria guidance and rejected the relevant suppliers CMRTs until any discrepancies were resolved.
c. Design and Implement a Strategy to Respond to Identified Risks
Eaton’s strategy to respond to identified risks concerning Conflict Minerals includes the development of a responsible sourcing of conflict minerals policy, as referenced above. In line with our conflict minerals policy, our Supplier Code of Conduct (the Code) requires our suppliers to commit to the responsible sourcing of the Conflict Minerals. The Code and the Conflict Minerals requirements are incorporated by reference into Eaton’s Purchase Order Terms and Conditions. Both the Code and Purchase Order Terms and Conditions are used to communicate requirements to our suppliers, including expectations relating to the use and sourcing of Conflict Minerals. In particular, Eaton’s Code and Purchase Order Terms and Conditions requires our suppliers to perform due diligence into their respective supply chains to determine whether products sold to us contain Conflict Minerals, and whether, and to what extent, the Conflict Minerals are sourced from smelters and refiners conformant to RMI’s Responsible Minerals Assurance Process (RMAP), and to report to Eaton the results of this due diligence. The Code and Purchase Order Terms and Conditions are available on our website at https://www.eaton.com/us/en-us/company/selling-to-eaton.html.
Eaton monitors the information received from suppliers in response to our solicitations, and periodically shares summaries of this information with our Conflict Minerals Steering Committee. Eaton is a member of RMI (member Code EATN) and uses data from the RMI to determine the conformance status of supplier-reported smelters and refiners, as well as reported country of origin information related to the Conflict Minerals sourced from such smelters or refiners, if available. Through our membership in RMI, Eaton further supports several complementary programs such as iTSCi, LBMA, and RCS Global Group’s Better Mining Project, with which RMI collaborates to jointly address Conflict Minerals issues in CAHRAs including the DRC and adjoining countries.
Suppliers that are either non-responsive or provide incomplete or inconsistent responses to Eaton’s solicitations are escalated within Eaton’s Supply Chain Management organization for follow-up engagement. Responding suppliers reporting smelters and refiners that are non-conformant or have other identified red flags (risks from open-source information that merit further review) receive follow-up communication to remind them of Eaton’s expectations relating to the use and sourcing of Conflict Minerals as well as support and resources including training available to them through our membership in RMI. Corrective action plans are assigned as needed to ensure suppliers improve on their due diligence practices and comply with Eaton’s Code and Purchase Order Terms and Conditions.
d. Carry Out Independent Third-Party Audits of Smelter/Refiner's Due Diligence Practices
As a downstream user of Conflict Minerals, Eaton and its direct supply chain are many layers removed from the mine or location from which the Conflict Minerals originated and smelters and refiners that process the Conflict Minerals. Through our membership and participation in the RMI, we collaborate at a cross-industry level, and we continue to support the development and implementation of due diligence practices, the RMI Responsible Minerals Assurance Process (RMAP) and tools such as the CMRT. In addition, Eaton has previously contributed financially to RCS Global Group’s Better Mining program, which has been recognized as a valid upstream assurance mechanism for its work to address risks associated with artisanal small mines.
e. Report Annually on Supply Chain Due Diligence
Eaton publicly communicates our responsible sourcing of conflict minerals policy, due diligence activities and related supplier expectations on our website and in our Form SD and Conflict Minerals Report available at: http://www.eaton.com/content/eaton/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html.
4.RESULTS OF REVIEW
For the reporting period of January 1 through December 31, 2024, Eaton solicited approximately 1,000 suppliers identified as potentially having Conflict Minerals in their products to gather detailed information regarding the existence of Conflict Minerals in products sold to us, as well as the origin and chain of custody of the Conflict Minerals, using the CMRT.
Based on the information provided by Eaton’s suppliers and our own due diligence efforts in the reporting period, we do not have sufficient information to conclusively determine the countries of origin or chain of custody of all Conflict Minerals in our products. A majority of our suppliers responded that their materials did not contain the Conflict Minerals, they used recycled materials, they were unable to determine whether the products they sold to us contained Conflict Minerals, or they were still in the process of evaluating the source of the Conflict Minerals in their products.
Based on the information provided by our suppliers, the smelters and refiners that may have been used to produce Conflict Minerals in Eaton’s products include those listed in Annex I. Based on information provided by our suppliers and information available from the RMI, the countries of origin of Conflict Minerals processed by these smelters and refiners may include the countries listed in Annex II. None of the responses acknowledged that Conflict Minerals were sourced from smelters/mines that financed or benefited armed groups in the DRC or adjoining countries. Eaton has no knowledge that any Conflict Minerals known to be in its supply chain directly or indirectly financed or benefited armed groups in the DRC or adjoining countries.
5.STEPS TAKEN AND TO BE TAKEN TO MITIGATE RISK
Eaton intends to continue to evaluate its due diligence program in accordance with the provisions of the Rule. We will continue to annually review the criteria used to select suppliers for solicitation and engage with our suppliers to identify the Conflict Minerals used within our supply chain, as well as the origin and chain of custody of those Conflict Minerals. We intend to continue to engage with third party programs such as the RMI. Finally, to the extent that any Eaton supplier is found to be using non-conformant smelters or refiners within its supply chain, Eaton intends to engage that supplier and re-communicate our requirement for suppliers to commit to comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from the DRC or adjoining countries, as per Eaton’s policy and Code.
ANNEX I
Annex I includes all smelters/refiners that Eaton’s responding suppliers listed in their completed CMRTs that meet the recognized definition of a smelter or refiner and were operational during the 2024 calendar year. Because of the nature of its suppliers’ responses, Eaton believes that the smelters/refiners listed in Annex I are likely to include smelters and refiners that do not actually process the Conflict Minerals contained in its products. If a supplier has included in their CMRT a smelter or refiner of concern Eaton takes additional due diligence steps, as described above, to verify if this smelter or refiner is processing Conflict Minerals for Eaton products. This includes smelters or refiners that are identified as high-risk or that may be on the OFAC sanctions list or the Uygur Forced Labor Prevention Act entity listing. If Eaton receives confirmation that this is used for Eaton products, then this smelter or refiner will be included in the Annex I list.
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Metal | Status | Smelter or Refiner Name | Country Location of Smelter or Refiner |
| Tungsten | * | A.L.M.T. Corp. | JAPAN |
| Gold | * | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | * | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | * | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| 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. | JAPAN |
| Gold | * | Asaka Riken Co., Ltd. | JAPAN |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Tungsten | * | ATI Tungsten Materials | UNITED STATES OF AMERICA |
| Gold | * | Aurubis AG | GERMANY |
| Gold | * | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | * | Boliden AB | 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 | | Yunnan Copper Industry Co., Ltd. | CHINA |
| Tantalum | * | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tungsten | * | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tin | * | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Gold | * | Chimet S.p.A. | ITALY |
| Tungsten | * | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Gold | * | Chugai Mining | JAPAN |
| Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tantalum | * | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
| Tin | * | Alpha Metals | UNITED STATES OF AMERICA |
| Tin | * | PT Premium Tin Indonesia | INDONESIA |
| Gold | * | Do Sung Corporation | KOREA, REPUBLIC OF |
| Gold | * | Dowa | JAPAN |
| Tin | * | Dowa | JAPAN |
| Gold | * | Eco-System Recycling Co., Ltd. | JAPAN |
| Tin | * | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | * | Estanho de Rondonia S.A. | BRAZIL |
| Tantalum | | Exotech Inc. | UNITED STATES OF AMERICA |
| Tantalum | * | F & X | CHINA |
| Tin | * | Feinhutte Halsbrucke GmbH | GERMANY |
| | | | | | | | | | | |
| Tin | * | Fenix Metals | POLAND |
| Gold | | Refinery of Seemine Gold Co., Ltd. | CHINA |
| Tin | * | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tungsten | * | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA |
| Tantalum | * | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
| Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | * | LT Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | * | Heimerle + Meule GmbH | GERMANY |
| Gold | * | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | * | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | | Hunan Jintai New Material Co., Ltd. | CHINA |
| Gold | | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| Gold | | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| Gold | * | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | * | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | * | Istanbul Gold Refinery | TURKEY |
| Gold | * | Japan Mint | JAPAN |
| Tungsten | * | Japan New Metals Co., Ltd. | JAPAN |
| Tin | | Jean Goldschmidt International (JGI Hydro metal) | BELGIUM |
| Gold | * | Jiangxi Copper Co., Ltd. | CHINA |
| Tantalum | * | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | * | Jiujiang Tanbre Co., Ltd. | CHINA |
| Gold | * | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | * | Johnson Matthey Limited | CANADA |
| Gold | * | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Gold | | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | * | Kazzinc | KAZAKHSTAN |
| Tungsten | * | Kennametal Fallon | UNITED STATES OF AMERICA |
| Gold | * | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | * | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Tin | * | GuangXi China Tin | CHINA |
| Tantalum | * | LSM Brasil S.A. | BRAZIL |
| Gold | * | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | * | Materion | UNITED STATES OF AMERICA |
| Gold | * | Matsuda Sangyo Co., Ltd. | JAPAN |
| Tin | * | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Gold | * | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | * | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | * | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| 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 |
| | | | | | | | | | | |
| Tantalum | * | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tin | * | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | * | Mineracao Taboca S.A. | BRAZIL |
| Tin | * | Minsur | PERU |
| Gold | * | Mitsubishi Materials Corporation | JAPAN |
| Tin | * | Mitsubishi Materials Corporation | JAPAN |
| Tantalum | * | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | * | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | * | Molycorp Silmet A.S. | ESTONIA |
| Gold | * | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Tin | * | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Gold | * | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | * | Nihon Material Co., Ltd. | JAPAN |
| Tantalum | * | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tin | * | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Gold | * | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Tin | * | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Gold | * | PAMP S.A. | SWITZERLAND |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | * | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Tin | * | PT Mitra Stania Prima | INDONESIA |
| Tin | * | PT Timah Tbk Kundur | INDONESIA |
| Tin | * | PT Timah Tbk Mentok | INDONESIA |
| Gold | * | PX Precinox S.A. | SWITZERLAND |
| Tantalum | * | QuantumClean | UNITED STATES OF AMERICA |
| Gold | * | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Tantalum | * | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Gold | * | Royal Canadian Mint | CANADA |
| Tin | * | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Gold | | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | * | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | * | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Tin | * | Soft Metais Ltda. | BRAZIL |
| Gold | * | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | * | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tantalum | * | Taki Chemical Co., Ltd. | JAPAN |
| Gold | * | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Tantalum | * | Telex Metals | UNITED STATES OF AMERICA |
| Tin | * | Thaisarco | THAILAND |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | * | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | * | Torecom | KOREA, REPUBLIC OF |
| Tantalum | * | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| | | | | | | | | | | |
| 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 |
| Tin | | VQB Mineral and Trading Group JSC | VIET NAM |
| Gold | * | The Perth Mint | AUSTRALIA |
| Tin | * | White Solder Metalurgica | BRAZIL |
| Tungsten | * | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | * | Xiamen Tungsten Co., Ltd. | CHINA |
| Gold | * | Yamakin Co., Ltd. | JAPAN |
| Gold | * | Yokohama Metal Co., Ltd. | JAPAN |
| Tin | * | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Gold | * | China Henan Zhongyuan Gold Smelter | CHINA |
| Gold | | Morris and Watson | NEW ZEALAND |
| Gold | * | SAFINA A.S. | CZECHIA |
| Gold | | Guangdong Jinding Gold Limited | CHINA |
| Tungsten | | Jiangxi Minmetals Gao.an Non-ferrous Metals Co., Ltd. | CHINA |
| Gold | | Umicore Precious Metals Thailand | THAILAND |
| Tungsten | * | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | * | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | * | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | * | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | * | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tin | * | Magnus Minerais Metais e Ligas Ltda. | BRAZIL |
| Tantalum | * | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tungsten | * | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tin | | Melt Metais e Ligas S.A. | BRAZIL |
| Tungsten | * | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tin | * | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tantalum | * | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | * | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | * | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | * | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Gold | * | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | | Pease & Curren | UNITED STATES OF AMERICA |
| Gold | | SAM Precious Metals FZ-LLC | UNITED ARAB EMIRATES |
| Gold | | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM |
| Gold | | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Gold | | Marsam Metals | BRAZIL |
| Gold | | SAAMP | FRANCE |
| Gold | | 8853 S.p.A. | ITALY |
| Tungsten | | ACL Metais Eireli | BRAZIL |
| Gold | | AU Traders and Refiners | SOUTH AFRICA |
| Gold | | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| | | | | | | | | | | |
| Gold | | Modeltech Sdn Bhd | MALAYSIA |
| Tin | | Modeltech Sdn Bhd | MALAYSIA |
| Tantalum | | ULVAC Inc. | JAPAN |
| Gold | | Safimet S.p.A | ITALY |
| Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tin | | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tungsten | | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Gold | | Augmont Enterprises Private Limited | INDIA |
| Gold | | Alexy Metals | UNITED STATES OF AMERICA |
| Gold | | Shandong Humon Smelting Co., Ltd. | CHINA |
| Gold | | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| Gold | | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Gold | | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| Gold | | Shirpur Gold Refinery Ltd. | INDIA |
| Tin | | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Gold | | Shenzhen CuiLu Gold Co., Ltd. | CHINA |
| Gold | | Albino Mountinho Lda. | PORTUGAL |
| Gold | | Sai Refinery | INDIA |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| Gold | | JALAN & Company | INDIA |
| Gold | | ABC Refinery Pty Ltd. | AUSTRALIA |
| Gold | | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | | Gold Coast Refinery | GHANA |
| Tin | | Pongpipat Company Limited | MYANMAR |
| Gold | | QG Refining, LLC | UNITED STATES OF AMERICA |
| Gold | | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| Gold | | CGR Metalloys Pvt Ltd. | INDIA |
| Gold | | Sovereign Metals | INDIA |
| Tin | | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| Gold | | Kundan Care Products Ltd. | INDIA |
| 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 | | K.A. Rasmussen | NORWAY |
| Gold | | MD Overseas | INDIA |
| Gold | | Metallix Refining Inc. | UNITED STATES OF AMERICA |
| Tungsten | | YUDU ANSHENG TUNGSTEN CO., LTD. | CHINA |
| Gold | | Dongwu Gold Group | CHINA |
| Tantalum | | 5D Production OU | ESTONIA |
| Tungsten | | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | | Nam Viet Cromit Joint Stock Company | VIET NAM |
| Tungsten | | DONGKUK INDUSTRIES CO., LTD. | KOREA, REPUBLIC OF |
| Gold | | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | CHINA |
| Tin | * | PT Rajehan Ariq | INDONESIA |
| | | | | | | | | | | |
| Tin | * | PT Bangka Prima Tin | INDONESIA |
| Tin | * | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE |
| Tin | * | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| Tin | * | Aurubis Beerse | BELGIUM |
| Tin | * | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Gold | * | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Tantalum | * | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tungsten | * | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA |
| Tin | * | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tantalum | * | KEMET de Mexico | MEXICO |
| Tungsten | * | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | * | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | * | Masan High-Tech Materials | VIET NAM |
| Tantalum | * | TANIOBIS Co., Ltd. | THAILAND |
| Tantalum | * | TANIOBIS GmbH | GERMANY |
| Tantalum | * | Materion Newton Inc. | UNITED STATES OF AMERICA |
| Tantalum | * | TANIOBIS Japan Co., Ltd. | JAPAN |
| Tantalum | * | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | * | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tantalum | * | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | * | Global Advanced Metals Aizu | JAPAN |
| Gold | * | T.C.A S.p.A | ITALY |
| Gold | * | REMONDIS PMR B.V. | NETHERLANDS |
| Tungsten | * | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Gold | * | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | * | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Tungsten | * | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tin | * | PT Cipta Persada Mulia | INDONESIA |
| Tin | * | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | * | Resind Industria e Comercio Ltda. | BRAZIL |
| Gold | * | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Tin | * | Super Ligas | BRAZIL |
| Gold | * | L'Orfebre S.A. | ANDORRA |
| Gold | * | Italpreziosi | ITALY |
| Tin | * | Aurubis Berango | SPAIN |
| Gold | * | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | * | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Tungsten | * | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tantalum | * | Jiangxi Tuohong New Raw Material | CHINA |
| Tin | * | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Gold | * | Bangalore Refinery | INDIA |
| Gold | * | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | * | Planta Recuperadora de Metales SpA | CHILE |
| Tin | * | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Gold | * | NH Recytech Company | KOREA, REPUBLIC OF |
| Tin | * | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | * | Tin Technology & Refining | UNITED STATES OF AMERICA |
| | | | | | | | | | | |
| Tin | * | Luna Smelter, Ltd. | RWANDA |
| Tin | * | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | * | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tin | * | Precious Minerals and Smelting Limited | INDIA |
| Tungsten | * | Hubei Green Tungsten Co., Ltd. | CHINA |
| Gold | * | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | * | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Tin | * | PT Mitra Sukses Globalindo | INDONESIA |
| Tungsten | * | Cronimet Brasil Ltda | BRAZIL |
| Tin | * | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | * | CRM Synergies | SPAIN |
| Gold | * | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| Tin | * | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL |
| Tantalum | * | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| Tungsten | * | Fujian Xinlu Tungsten Co., Ltd. | CHINA |
| Gold | * | WEEEREFINING | FRANCE |
| Gold | * | Gold by Gold Colombia | COLOMBIA |
| Tin | * | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
| Tungsten | * | Tungsten Vietnam Joint Stock Company | VIET NAM |
| Gold | * | Coimpa Industrial LTDA | BRAZIL |
| Tantalum | * | Industrial Refining Company | RWANDA |
| Gold | | PowerX Ltd. | BELGIUM |
* = Conformant or actively participating in the RMI Responsible Minerals Assurance Process (as reported by RMI as of January 23, 2025).
ANNEX II
Annex II includes possible countries of origin of Conflict Minerals that were processed by supplier-reported smelters and refiners. Eaton believes that Annex II is likely to include more countries than those that are actually sources of the Conflict Minerals in Eaton’s products and supply chain.
| | | | | | | | |
| Annex II** |
| Albania | Greece | Pakistan |
| Algeria | Grenada | Panama |
| Andorra | Guatemala | Papua New Guinea |
| Antigua and Barbuda | Guinea | Peru |
| Argentina | Guyana | Philippines |
| Australia | Honduras | Poland |
| Austria | Hong Kong | Portugal |
| Azerbaijan | Hungary | Puerto Rico |
| Bahamas | Iceland | Romania |
| Barbados | India | Russia |
| Belarus | Indonesia | Rwanda |
| Belgium | Ireland | Saint Kitts and Nevis |
| Benin | Israel | Saint Vincent and Grenadines |
| Bolivia | Italy | San Marino |
| Bolivia (Plurinational State of) | Jamaica | Saudi Arabia |
| Bosnia and Herzegovina | Japan | Senegal |
| Botswana | Jordan | Serbia |
| Brazil | Kazakhstan | Sierra Leone |
| Bulgaria | Kenya | Singapore |
| Burkina Faso | Korea, Republic of | Sint Maarten |
| Burundi | Kuwait | Slovakia |
| Cameroon | Kyrgyzstan | Slovenia |
| Canada | Lao People's Democratic Republic | South Africa |
| Cayman Islands | Laos | South Korea |
| Chile | Latvia | Spain |
| China | Lebanon | Sri Lanka |
| Chinese Taipei | Liberia | Sudan |
| Colombia | Liechtenstein | Suriname |
| Congo, Democratic Republic of the | Lithuania | Sweden |
| Costa Rica | Luxembourg | Switzerland |
| Côte d'Ivoire | Macao | Tajikistan |
| Croatia | Madagascar | Tanzania |
| Curacao | Malaysia | Thailand |
| Cyprus | Mali | Togo |
| Czech Republic | Malta | Trinidad and Tobago |
| Denmark | Mauritania | Tunisia |
| Djibouti | Mexico | Turkey |
| Dominica | Mongolia | Uganda |
| Dominican Republic | Morrocco | Ukraine |
| Ecuador | Mozambique | United Arab Emirates |
| Egypt | Myanmar | United Kingdom |
| El Salvador | Namibia | United Kingdom of Great Britain and Northern Ireland |
| Estonia | Netherlands | United States of America |
| | | | | | | | |
| Eswatini | New Caledonia | Uruguay |
| Ethiopia | New Zealand | Uzbekistan |
| Finland | Nicaragua | Venezuela |
| France | Niger | Viet Nam |
| French Guiana | Nigeria | Vietnam |
| Georgia | North Macedonia | Zambia |
| Germany | Norway | Zimbabwe |
| Ghana | Oman | |
**The list of possible countries of origin of Conflict Minerals processed by supplier-reported smelters and refiners is based upon country-of-origin information available from The Responsible Minerals Initiative. As a downstream manufacturer many tiers removed from the smelters/refiners and mines of origin, Eaton does not have sufficient information to conclusively determine the countries of origin or chain of custody of Conflict Minerals in our products.