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Exhibit 1.01
 
Conflict Minerals Report of
Lifeward Ltd.
For the year ended December 31, 2024

Introduction
 
This is the Conflict Minerals Report (the “CMR”) of Lifeward Ltd. (the “Company,” “we” or “us” or “our”) for calendar year 2024 in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “1934 Act”). The Rule requires disclosure of certain information when a registrant manufactures or contracts to manufacture products that contain, or likely contain, the “Conflict Minerals” specified in the Rule, which are necessary to the functionality or production of products (the “Covered Products”).

“Conflict Minerals” are defined as gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. Tantalum, tin, tungsten and gold are collectively referred to as “3TG” for the purposes of this assessment. According to the Rule, if a registrant, based on a good faith reasonable country of origin inquiry regarding the Conflict Minerals, has reason to believe that (i) the Conflict Minerals contained in its Covered Products may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively with the DRC, the “Covered Countries”) or (ii) such Conflict Minerals may not be from recycled or scrap sources, then the registrant must exercise due diligence on the source and chain of custody of the Conflict Minerals, and submit a conflict minerals report describing those due diligence measures.

Reasonable Country of Origin Inquiry

During the year ended December 31, 2024, we conducted a Reasonable Country of Origin Inquiry (“RCOI”) to determine, using good faith and reasonable best efforts, whether any of the necessary 3TG that was necessary to the production or functionality of our Covered Products in 2024 originated, or likely originated, from any of the Covered Countries or whether the 3TG originated, or likely originated, from entirely recycled or scrap sources. We held meetings with management from various departments to discuss the applicable definitions of “manufacturer” and/or “contract to manufacture.” By way of this process, we identified specific types of product parts within our products that contain within them 3TG that is necessary to their production or functionality and mapped them to their respective suppliers.
 
We developed a risk-based approach that focuses on our key suppliers involved in manufacturing the majority of our finished products. We identified 17 relevant suppliers. We requested that all identified suppliers provide information regarding the origin of the Conflict Minerals contained in products supplied using version 6.4, or higher, of the Conflict Minerals Reporting Template (“CMRT”) of the Responsible Business Alliance and created by the Responsible Minerals Initiative (“RMI”).
 
We reviewed the responses received, checked for inconsistencies, incomplete forms, and inaccurate responses, and sent reminders to suppliers who did not respond to our requests for information. We compared the Conflict Minerals smelters or refiners reported in the surveys with the 17 suppliers against the lists of facilities that received a conformant or active designation by the RMI’s Responsible Minerals Assurance Process (“RMAP”). In accordance with the Rule, we concluded in good faith that during the year ended December 31, 2024:
 

 •
Certain of our operations manufactured, or contracted to manufacture, products for which Conflict Minerals are necessary to the functionality or production of those products; and

•
Based on our good faith RCOI regarding the Conflict Minerals, we had reason to believe that: (i) the Conflict Minerals contained in our Covered Products may have originated in the DRC or one or more of the Covered Countries and (ii) such Conflict Minerals may not be from entirely recycled or scrap sources.

As a result, we exercised due diligence on the Conflict Minerals’ source and chain of custody and are filing this CMR with our Form SD to comply with the requirements of the Rule. In accordance with applicable guidance from the U.S. Securities and Exchange Commission (the “SEC”), we are not required to obtain an independent private sector audit of our CMR for the year ended December 31, 2024. The due diligence measures we performed are discussed below.

Part I. Company Overview and Description of the Company’s Products Covered by This Report


             We are a medical device company that designs, develops, and commercializes life-changing solutions that span the continuum of care in physical rehabilitation and recovery, delivering proven functional and health benefits in clinical settings as well as in the home and community.  Our initial product offerings were the ReWalk Personal and ReWalk Rehabilitation devices for individuals with Spinal Cord Injury (“SCI Products”). These devices are robotic exoskeletons that are designed for individuals with paraplegia that use the Company’s patented tilt-sensor technology and an on-board computer and motion sensors to drive motorized legs that power movement. These SCI Products allow individuals with spinal cord injury the ability to stand and walk again during everyday activities at home or in the community.

The Company has sought to expand its product offerings beyond the SCI Products through internal development and distribution agreements. The Company has developed its ReStore Exo-Suit device (the “ReStore”), which it began commercializing in June 2019. The ReStore is a powered, lightweight soft exo-suit intended for use during the rehabilitation of individuals with lower limb disabilities due to stroke. During the second quarter of 2020, the Company signed an agreement to be the exclusive distributor of the MYOLYN MyoCycle FES Pro cycles to U.S. rehabilitation clinics and for the MyoCycle Home cycles available to US veterans through VA hospitals.

Our principal markets are the United States and Europe.

Following the acquisition of AlterG, Inc. by Lifeward in August 2023, the Anti-Gravity Treadmill has been added to Lifeward's products line. As permitted by Item 1.01, our disclosure report for fiscal year 2025 will include Conflict Minerals disclosure with respect to the Anti-Gravity Treadmill.

Part II. The Company’s Due Diligence Process
 
Design of Due Diligence
 
We have adopted due diligence processes in accordance with Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016), including the related Supplements on Tin, Tantalum and Tungsten and on Gold published by the Organization for Economic Co-Operation and Development (collectively, the “OECD Guidance”).

The design of our Conflict Minerals program is in conformity with the OECD Guidance, specifically as it relates to our position in the minerals supply chain as a company that is several levels removed from the actual mining of Conflict Minerals (i.e., a “downstream company”). We do not make direct purchases of raw ore or unrefined Conflict Minerals and instead rely on our direct suppliers to provide us with the information regarding the likely source and chain of custody of the 3TG minerals supplied to us. Summarized below are the design components of our Conflict Minerals program as they relate to the five-step framework set forth in the OECD Guidance:

Due Diligence Performed
 
Step 1. Establish Strong Company Management Systems
 
Adopt, communicate and commit to a supply chain policy for minerals from conflict-affected and high-risk areas.

We have continued to communicate our Conflict Minerals Policy (the “Policy”) related to our sourcing of 3TG to our supplies and other stakeholders. Our Policy outlines our commitment to responsible sourcing and the requirements imposed on participants in our supply chain and is available on the "Charters & Policies" under the “Corporate Governance” page in the “Investor Relations” section of our website at https://ir.golifeward.com/corporate-governance/charters-and-policies. Information contained on, or that can be accessed through, our website does not constitute a part of this CMR and is not incorporated by reference herein.

Structure internal management systems to support supply chain due diligence.

A cross-functional Conflict Minerals steering committee operates our Conflict Minerals program. The committee consists of representatives from the Company’s finance and purchasing functions and is led by our Principal Financial Officer. Regular meetings of our Conflict Minerals steering committee were held, and the committee updated representatives of our senior management on the status of the Conflict Minerals program.

Establish a System of Controls and Transparency over the Conflict Minerals Supply Chain.

We have implemented a supply chain system of controls and transparency through the use of due diligence tools created by the RMI. These tools include, as discussed in “Step 2” below, accepting at a minimum version 6.4, or higher, of the CMRT, which is designed to identify and verify information regarding the smelters or refiners that process the necessary Conflict Minerals contained in our products. We have also adopted a process to maintain business records relating to 3TG due diligence, including retention of records of our due diligence processes, findings and resulting decisions for a period of five years.

Strengthen the Company’s Engagement with Suppliers

We inform our-scope manufacturers and suppliers of our disclosure requirements, including our compliance with the OECD Guidance and the Rule.

Establish a Company-level Grievance Mechanism.
 
Our Policy includes a grievance procedure by which employees, suppliers and other stakeholders may contact us should they wish to seek guidance or report concerns regarding Conflict Minerals. Concerns or grievances reported through this procedure are reviewed by the relevant staff members and follow-up activities are conducted, as appropriate.
 
Step 2. Identify and Assess Risks in the Supply Chain
 
Identify Risks in the Supply Chain by Identifying Company Suppliers.
 
Identify Company Suppliers.
 
As explained above, we do not buy raw ore or unrefined Conflict Minerals directly from refiners, smelters or mines. Our supply chain with respect to the Covered Products is complex, with multiple intermediaries and third parties in the supply chain between the manufacturing of the Covered Products and the original sources of the necessary Conflict Minerals. Because we believe that the smelters or refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us.

As discussed above under “Reasonable Country of Origin Inquiry” and “Part I. Company Overview and Description of the Company’s Products Covered by This Report,” we identified our Covered Products falling within the scope of the Rule (i.e., products which were manufactured or contracted to be manufactured by us) during the 2024 calendar year. Based on these Covered Products, we were able to identify the suppliers from which we purchase components or materials for the Covered Products that may include Conflict Minerals. We identified 17 relevant suppliers whose products may contain 3TG.
 
Request Conflict Minerals Reporting Templates (CMRTs) from suppliers.

We surveyed 17 suppliers to identify the 3TG contained in the products they supply us with, the smelters or refiners that process the 3TG and the country of origin, or likely country of origin, of such 3TG. The survey was conducted by utilizing version 6.4, or higher, of the CMRT. We utilize this RMI reporting template to collect data and information from our suppliers in order to identify the origins of 3TG in our supply chain. We received responses from 14 out of 17 suppliers (82%).

Assess Risks in the Supply Chain.

Analyze surveys for RMAP “conformant” and “active” smelters or refiners.
 
We compared smelters or refiners identified in the supply chain survey against the RMI’s “conformant” or “active” smelter or refiner list, which lists all facilities that have received a RMAP “conformant” or “active” designation from the RMI. We reviewed all of the responses to determine whether smelters or refiners identified in our supply chain obtained a designation of “conformant” or “active” from the RMI.
 
Of the CMRT responses we received from suppliers, some included incomplete responses as well as inconsistencies and inaccuracies within the reported data. In such cases, we contacted the suppliers directly in an effort to secure revised responses. Through this process, we have identified, to the best of our efforts, the smelters or refiners in our supply chain and country of origin, or likely country of origin, based on information for the smelters or refiners identified in the supply chain survey.
 
Understand and define RMAP “conformant” and “active” statuses.

To compile its list, the RMI employs independent third-party auditors to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters or refiners which agree to undergo an audit. “Conformant” means that a smelter or refiner was listed as “conformant” with the RMAP’s assessment protocols, including those indicated as “re-audit in progress”.

Smelters or refiners labeled as “active” have committed to undergo an audit, which may be in progress, or are participating in one of the cross-recognized certification programs, namely, the London Bullion Market Association ("LBMA") Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification.
 
Step 3. Design and Implement a Strategy to Respond to Identified Risks
 
We are working to improve our due diligence processes with respect to 3TG. Our risk mitigation efforts during 2024 included those discussed in this section.
 
Participate in Existing Industry Conflict Minerals Initiatives.
 
In light of the complexity of our and our suppliers’ supply chains, we are currently unable to assess adequately all of the risks in our supply chain. However, we continue to engage with suppliers to obtain current, accurate and complete information about our supply chain through the use of version 6.4, or higher, of the CMRT and to improve due diligence efforts to ensure responsible sourcing in compliance with our Policy.

Report Findings to Designated Senior Management.
 
Our senior management, including our Chief Executive Officer, is briefed about our supply chain due diligence efforts, risk analysis results and mitigation efforts.

Devise, Adopt and Implement a Risk Management Plan and Monitor Risk Mitigation Efforts.

Our Policy seeks to encourage suppliers to responsibly source Conflict Minerals, but does not necessarily seek to eliminate sourcing from any of the Covered Countries. We also periodically review our progress, assess identified risks and determine follow-up action, as follows:
 

 •
We follow up on inconsistent, incomplete, or inaccurate responses, and send reminders to suppliers who have not responded to our requests for information.
 

 •
Suppliers that source from smelters or refiners from any of the Covered Countries, where such smelters or refiners are not certified by the RMAP, are contacted and are asked to submit more information about their sourcing practices, including a corrective action plan.
 
Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
 
Due to our downstream position in the supply chain, we do not have a direct relationship with 3TG smelters or refiners. Therefore, we do not perform direct audits of these entities within our supply chain, but instead rely on the efforts of organizations such as the RMI to influence smelters or refiners to undergo audits and become certified through the RMAP.
 
Step 5. Report Annually on Supply Chain Due Diligence
 
Our supply chain due diligence efforts are described in this CMR. We have filed this CMR in accordance with the Rule by filing a Form SD with the SEC, with this CMR as an exhibit. This CMR is also available on our website https://ir.golifeward.com/corporate-governance/charters-and-policies. Information contained on, or that can be accessed through, our website does not constitute a part of this CMR and is not incorporated by reference herein.

Part III. The Company’s Due Diligence Findings and Conclusions

Our Conflict Minerals process, as described above, allowed us to identify in-scope products and the corresponding suppliers. These 17 identified suppliers were surveyed using version 6.4, or higher, of the CMRT. We received survey responses from 82% of our suppliers. The results of the survey do not allow us to make definitive conclusions as to the source or likely source of any potential Conflict Minerals that were necessary to the production or functionality of our products that were manufactured, or contracted to manufacture, in 2024.

Facilities Used to Process the Conflict Minerals in the Covered Products

Based on the information obtained during the minerals supply chain due diligence process, we were unable to conclusively determine the origin or likely origin of all the Conflict Minerals contained in the Covered Products. Based on the information provided by our suppliers as well as by the RMI, as of the date of this CMR, we believe that the facilities that may have been used to process the Conflict Minerals in our products during the reporting period in the 2024 calendar year may include the smelters or refiners listed in Annex I hereto.

Countries of Origin of the Conflict Minerals in the Covered Products

Based on the information provided by our suppliers as well as by RMI, as of the date of this CMR, we believe that the facilities for processing of the Conflict Minerals countries of origin, or likely countries of origin of the Conflict Minerals contained in our products may include one or more of the countries listed in Annex II hereto.

We can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals in our Covered Products, since the information comes from direct and secondary suppliers and the RMI. Information gathered from our suppliers is not on a continuous, real-time basis. Despite our efforts to follow up with certain suppliers, we did not receive responses from all suppliers, and the suppliers who responded showed varying degrees of cooperation with our inquiries.

Part IV. Implementation of Strategies to Respond to Identified Risks and Future Steps

We have taken, and intend to continue taking, steps to improve our due diligence processes and to minimize the risk that our necessary Conflict Minerals benefit, or likely benefit, armed groups in the DRC or Covered Countries, as well as Conflict-Affected or High-Risk Areas. Going forward, we will continue working with our global supply chain to ensure responsible sourcing and assure compliance with applicable regulations through the following steps:


 1.
Contacting from time to time, as is reasonably required, direct suppliers that do not respond to the supply chain survey by a specified date, requesting their responses.

2.
Comparing, as is reasonably required, applicable smelters or refiners identified in the supply chain survey against the list of facilities that have received a RMAP “conformant” or “active” designation from the RMI’s RMAP.

3.
Making a good faith effort to enact terms and conditions related to Conflict Minerals in supplier contracts.

4.
Continuing to implement the Company’s Conflict Minerals Policy.

5.
Engaging with suppliers to encourage them to provide requested information for future reporting years.

6.
Continuing to communicate to our suppliers the expectation that they steer their supply chain towards “conformant” smelters as defined by the RMI's RMAP or other equivalent programs.

7.
Using revised and updated versions of the CMRT for our survey tools.

Forward-Looking Statements

In addition to historical facts, this CMR contains forward-looking statements within the meaning of Section 27A of the U.S. Securities Act of 1933, as amended, Section 21E of the 1934 Act, and the safe harbor provisions of the U.S. Private Securities Litigation Reform Act of 1995. We have based these forward-looking statements on our current expectations and projections about future events. Forward-looking statements include information regarding further supplier engagement, due diligence and risk mitigation efforts and strategy, and involve certain risks and uncertainties. Actual results could differ materially from the forward-looking statements. Words such as “expects,” “anticipates,” “intends,” “seeks,” “believes,” “may,” “will,” variations of these words, and similar expressions are intended to identify such forward looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on our ability to verify the accuracy or completeness of any supply chain information provided by suppliers and other factors discussed under the heading “Risk Factors” in our annual report on Form 10-K for the year ended December 31, 2024, as filed with the SEC on March 7, 2025, and other documents subsequently filed with or furnished to the SEC. Any forward-looking statement made in this CMR speaks only as of the date hereof. Except as otherwise required by law, the Company undertakes no obligation to update publicly the information contained in this CMR, or any forward looking statements, to reflect new information, events or circumstances after the date they were made, or to reflect the occurrence of unanticipated events.
 
Annex I
 
List of Identified Smelters or Refiners
 
Metal (*)
Smelter Reference List (*)
Smelter Country (*)
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Agosi AG
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
Gold
Aurubis AG
GERMANY
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
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
Chimet S.p.A.
ITALY
Gold
Chugai Mining
JAPAN
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Dowa
JAPAN
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
Gold
JSC Novosibirsk Refinery
RUSSIAN FEDERATION

Gold
Refinery of Seemine Gold Co., Ltd.
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 Germany GmbH Co. KG
GERMANY
Gold
Hunan Chenzhou Mining 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
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN

Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Gold
Lingbao Gold Co., Ltd.
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
LS MnM Inc.
KOREA, REPUBLIC OF
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
Materion
UNITED STATES OF AMERICA
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
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
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
MKS PAMP SA
SWITZERLAND
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION

Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Precinox S.A.
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Royal Canadian Mint
CANADA
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
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Gold
Shandong Gold Smelting Co., Ltd.
CHINA
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Valcambi S.A.
SWITZERLAND

Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Gold
Morris and Watson
NEW ZEALAND
Gold
SAFINA A.S.
CZECHIA
Gold
Guangdong Jinding Gold Limited
CHINA
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Sudan Gold Refinery
SUDAN
Gold
T.C.A S.p.A
ITALY
Gold
REMONDIS PMR B.V.
NETHERLANDS
Gold
Industrial Refining Company
BELGIUM
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
Marsam Metals
BRAZIL
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Gold
SAAMP
FRANCE
Gold
L'Orfebre S.A.
ANDORRA
Gold
Italpreziosi
ITALY
Gold
WIELAND Edelmetalle GmbH
GERMANY

Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
AU Traders and Refiners
SOUTH AFRICA
Gold
GGC Gujrat Gold Centre Pvt. Ltd.
INDIA
Gold
Sai Refinery
INDIA
Gold
Modeltech Sdn Bhd
MALAYSIA
Gold
Bangalore Refinery
INDIA
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Gold
Pease & Curren
UNITED STATES OF AMERICA
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
Planta Recuperadora de Metales SpA
CHILE
Gold
Safimet S.p.A
ITALY
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Gold
African Gold Refinery
UGANDA
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
Gold
8853 S.p.A.
ITALY
Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
Gold
Fujairah Gold FZC
UNITED ARAB EMIRATES
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
Gold
Shirpur Gold Refinery Ltd.
INDIA

Gold
JALAN & Company
INDIA
Gold
Gold Coast Refinery
GHANA
Gold
CGR Metalloys Pvt Ltd.
INDIA
Gold
Sovereign Metals
INDIA
Gold
Augmont Enterprises Private Limited
INDIA
Gold
Kundan Care Products Ltd.
INDIA
Gold
Alexy Metals
UNITED STATES OF AMERICA
Gold
Metal Concentrators SA (Pty) Ltd.
SOUTH AFRICA
Gold
WEEEREFINING
FRANCE
Gold
Super Dragon Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
Shenzhen Zhonghenglong Real Industry Co., Ltd.
CHINA
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
Gold
Gold by Gold Colombia
COLOMBIA
Gold
Coimpa Industrial LTDA
BRAZIL
Gold
ABC Refinery Pty Ltd.
AUSTRALIA
Gold
Albino Mountinho Lda.
PORTUGAL
Gold
Dongwu Gold Group
CHINA
Gold
Shenzhen CuiLu Gold Co., Ltd.
CHINA
Gold
GG Refinery Ltd.
TANZANIA, UNITED REPUBLIC OF
Gold
Elite Industech Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
Attero Recycling Pvt Ltd
INDIA
Gold
Impala Refineries – Base Metals Refinery (BMR)
SOUTH AFRICA
Gold
Impala Refineries – Platinum Metals Refinery (PMR)
SOUTH AFRICA

Gold
Impala Rustenburg
SOUTH AFRICA
Gold
KP Sanghvi International Pvt Ltd
INDIA
Gold
NOBLE METAL SERVICES
UNITED STATES OF AMERICA
Gold
Sam Precious Metals
UNITED ARAB EMIRATES
Gold
SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD.
CHINA
Tantalum
Smelter not listed
CHINA
Tantalum
F&X Electro-Materials Ltd.
CHINA
Tantalum
XIMEI RESOURCES (GUANGDONG) LIMITED
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
AMG Brasil
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineracao Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
NPM Silmet AS
ESTONIA
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
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
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET de Mexico
MEXICO
Tantalum
TANIOBIS Co., Ltd.
THAILAND
Tantalum
TANIOBIS GmbH
GERMANY
Tantalum
Smelter not listed
GERMANY
Tantalum
Materion Newton Inc.
UNITED STATES OF AMERICA
Tantalum
TANIOBIS Japan Co., Ltd.
JAPAN
Tantalum
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Tantalum
RFH Yancheng Jinye New Material Technology Co., Ltd.
CHINA
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Tantalum
PowerX Ltd.
RWANDA
Tantalum
5D Production OU
ESTONIA
Tantalum
Avon Specialty Metals Ltd.
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND
Tantalum
CMT Rare Metal Advanced Materials (Hunan) Co., Ltd.
CHINA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
Jiangxi Suns Nonferrous Materials Co. Ltd.
CHINA

Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
Tantalum
RFH Recycling Metals Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
V&D New Materials (Jiangsu) Co., Ltd.
CHINA
Tantalum
XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD.
CHINA
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
Alpha
UNITED STATES OF AMERICA
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
PT Premium Tin Indonesia
INDONESIA
Tin
Dowa
JAPAN
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Estanho de Rondonia S.A.
BRAZIL
Tin
Fenix Metals
POLAND
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
Mineracao Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND

Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT Babel Inti Perkasa
INDONESIA
Tin
PT Bangka Tin Industry
INDONESIA
Tin
PT Belitung Industri Sejahtera
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Refined Bangka Tin
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Timah Tbk Kundur
INDONESIA
Tin
PT Timah Tbk Mentok
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Thaisarco
THAILAND
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.
CHINA
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
Melt Metais e Ligas S.A.
BRAZIL
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
CV Ayi Jaya
INDONESIA
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM

Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
PT Rajehan Ariq
INDONESIA
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Tin
Super Ligas
BRAZIL
Tin
Aurubis Beerse
BELGIUM
Tin
Aurubis Berango
SPAIN
Tin
PT Bangka Prima Tin
INDONESIA
Tin
PT Sukses Inti Makmur (SIM)
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
Modeltech Sdn Bhd
MALAYSIA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
PT Bangka Serumpun
INDONESIA
Tin
Pongpipat Company Limited
MYANMAR
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
PT Babel Surya Alam Lestari
INDONESIA
Tin
PT Tirus Putra Mandiri
INDONESIA
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
Tin
PT Rajawali Rimba Perkasa
INDONESIA
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
Tin
Luna Smelter, Ltd.
RWANDA

Tin
Precious Minerals and Smelting Limited
INDIA
Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.
CHINA
Tin
PT Mitra Sukses Globalindo
INDONESIA
Tin
Novosibirsk Tin Combine
RUSSIAN FEDERATION
Tin
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
BRAZIL
Tin
CRM Synergies
SPAIN
Tin
Fabrica Auricchio Industria e Comercio Ltda.
BRAZIL
Tin
PT Cipta Persada Mulia
INDONESIA
Tin
PT Timah Nusantara
INDONESIA
Tin
PT Putera Sarana Shakti (PT PSS)
INDONESIA
Tin
VQB Mineral and Trading Group JSC
VIET NAM
Tin
DS Myanmar
MYANMAR
Tin
Mining Minerals Resources SARL
CONGO, DEMOCRATIC REPUBLIC OF THE
Tin
Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.
JAPAN
Tin
Malaysia Smelting Corporation Berhad (Port Klang)
MALAYSIA
Tin
Woodcross Smelting Company Limited
UGANDA
Tin
Feinhutte Halsbrucke GmbH
GERMANY
Tin
Global Advanced Metals Greenbushes Pty Ltd.
AUSTRALIA
Tin
Jean Goldschmidt International (JGI Hydrometal)
BELGIUM

Tin
Longnan Chuangyue Environmental Protection Technology Development Co., Ltd
CHINA
Tin
PT Masbro Alam Stania
INDONESIA
Tin
RIKAYAA GREENTECH PRIVATE LIMITED
INDIA
Tin
Soft Metais Ltda.
BRAZIL
Tin
TRATHO Metal Quimica
BRAZIL
Tungsten
A.L.M.T. Corp.
JAPAN
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders LLC
UNITED STATES OF AMERICA
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Jintai New Material Co., Ltd.
CHINA
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
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
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
CHINA
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Tungsten
Masan High-Tech Materials
VIET NAM
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tungsten
China Molybdenum Tungsten Co., Ltd.
CHINA
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Tungsten
NPP Tyazhmetprom LLC
RUSSIAN FEDERATION
Tungsten
Hubei Green Tungsten Co., Ltd.
CHINA
Tungsten
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL

Tungsten
Cronimet Brasil Ltda
 BRAZIL
Tungsten
Fujian Xinlu Tungsten Co., Ltd.
CHINA
Tungsten
OOO “Technolom” 1
RUSSIAN FEDERATION
Tungsten
OOO “Technolom” 2
RUSSIAN FEDERATION
Tungsten
Artek LLC
RUSSIAN FEDERATION
Tungsten
Tungsten Vietnam Joint Stock Company
VIET NAM
Tungsten
HANNAE FOR T Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
LLC Vostok
RUSSIAN FEDERATION
Tungsten
YUDU ANSHENG TUNGSTEN CO., LTD.
CHINA
Tungsten
DONGKUK INDUSTRIES CO., LTD.
KOREA, REPUBLIC OF
Tungsten
Shinwon Tungsten (Fujian Shanghang) Co., Ltd.
CHINA
Tungsten
Lianyou Resources Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Tungsten
Kenee Mining Corporation Vietnam
VIET NAM
Tungsten
Avon Specialty Metals Ltd.
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND
Tungsten
Ganzhou Sunny Non-Ferrous Metals Co., Ltd.
CHINA
Tungsten
MALAMET SMELTING SDN. BHD.
MALAYSIA
Tungsten
Nam Viet Cromit Joint Stock Company
VIET NAM
Tungsten
Philippine Bonway Manufacturing Industrial Corporation
PHILIPPINES
Tungsten
Philippine Carreytech Metal Corp.
PHILIPPINES
Tungsten
Plansee Composite Materials GmbH
GERMANY

Annex II
 
List of Countries of Origin of Conflict Minerals*

Based on our due diligence, the above smelters or refiners reported by our relevant suppliers may process Conflict Minerals from one or more of the following reported countries of origin:*

Conflict Mineral
Country of Origin May Include the Following
Gold
ANDORRA
AUSTRALIA
AUSTRIA
BELGIUM
BRAZIL
CANADA
CHILE
CHINA
COLOMBIA
CZECHIA
FRANCE
GERMANY
GHANA
INDIA
INDONESIA
ITALY
JAPAN
KAZAKHSTAN
KOREA, REPUBLIC OF
KYRGYZSTAN
LITHUANIA
MALAYSIA
MEXICO
NETHERLANDS
NEW ZEALAND
NORWAY
PHILIPPINES
POLAND
PORTUGAL
RUSSIAN FEDERATION
SAUDI ARABIA
SINGAPORE
SOUTH AFRICA
SPAIN
SUDAN
SWEDEN
SWITZERLAND
TAIWAN, PROVINCE OF CHINA
TANZANIA, UNITED REPUBLIC OF
THAILAND
TURKEY
UGANDA
UNITED ARAB EMIRATES
UNITED STATES OF AMERICA
UZBEKISTAN
ZIMBABWE

Tantalum
BRAZIL
CHINA
ESTONIA
GERMANY
INDIA
JAPAN
KAZAKHSTAN
MEXICO
RUSSIAN FEDERATION
RWANDA
THAILAND
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND
UNITED STATES OF AMERICA
Tin
AUSTRALIA
BELGIUM
BOLIVIA (PLURINATIONAL STATE OF)
BRAZIL
CHINA
CONGO, DEMOCRATIC REPUBLIC OF THE
GERMANY
INDIA
INDONESIA
JAPAN
MALAYSIA
MYANMAR
PERU
PHILIPPINES
POLAND
RUSSIAN FEDERATION
RWANDA
SPAIN
TAIWAN, PROVINCE OF CHINA
THAILAND
UGANDA
UNITED STATES OF AMERICA
VIET NAM

Tungsten
AUSTRIA
BRAZIL
CHINA
GERMANY
JAPAN
KOREA, REPUBLIC OF
MALAYSIA
PHILIPPINES
RUSSIAN FEDERATION
TAIWAN, PROVINCE OF CHINA
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND
UNITED STATES OF AMERICA
VIET NAM
 
* The description of the Company’s due diligence exercise set forth above under the heading “Part II. The Company’s Due Diligence Process” explains the Company’s efforts to determine the mine or location of origin with the greatest possible specificity. As our suppliers’ Smelters or Refiners did not provide complete information on the location of the mine in their CMRTs, the Company was not able to establish the exact country of origin from the sourcing information reported regarding their Conflict Minerals. Therefore, the Company has indicated the countries of origin information as reported in our suppliers’ CMRTs, in the relevant “Smelter or Refiner Country” field of the CMRT declaration.