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EXHIBIT 1.01

BABCOCK & WILCOX ENTERPRISES, INC.
CONFLICT MINERALS REPORT
YEAR ENDED DECEMBER 31, 2024

Introduction

This Conflict Minerals Report (this "Report") has been prepared by management of Babcock & Wilcox Enterprises, Inc. In this Report, unless the context otherwise indicates, "B&W," "we," "us," the "Company" and "our" mean Babcock & Wilcox Enterprises, Inc. and its consolidated subsidiaries. This Report for the year ended December 31, 2024 (the “Reporting Period”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines “conflict minerals” as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold (“3TG”) as necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.

As described in this Report, B&W has reason to believe that some of the 3TG present in its supply chain may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”). Therefore, we performed a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TG in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we cannot rule out the possibility that we may have some suppliers that sourced 3TG from the Covered Countries and proceeded to conduct due diligence on our in scope suppliers.

Forward looking statements

Statements we make in this Report, which express a belief, expectation or intention, as well as those that are not historical fact, are forward- looking statements, including statements relating to our compliance efforts and expected actions identified under the “Steps to be taken” section of this Report. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other things, our ability to implement improvements in our conflict minerals program and identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see our other filings with the Securities and Exchange Commission (“SEC”), including our Annual Report on Form 10-K for the year ended December 31, 2024. B&W cautions not to place undue reliance on these forward-looking statements, which speak only as of the date of this Report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.

Overview

We are a globally-focused renewable, environmental and thermal technologies provider with over 155 years of experience providing diversified energy and emissions control solutions to a broad range of



industrial, electrical utility, municipal and other customers. Our innovative products and services are organized into three market-facing segments. Our reportable segments are as follows:

Babcock & Wilcox Renewable: The B&W Renewable segment offers technologies for efficient and environmentally sustainable power and heat generation, including waste-to-energy, oxygen-fired biomass-to-energy and black liquor systems for the pulp and paper industry. Our leading waste-to-energy technologies support a circular economy, diverting waste from landfills to use for power generation and replacing fossil fuels, while recovering recyclable metals and reducing emissions.
Babcock & Wilcox Environmental: The B&W Environmental segment offers a full suite of emissions control and environmental technology solutions for utility, waste-to-energy, biomass-to-energy, carbon black, and industrial steam generation applications around the world. Our broad experience includes systems for ash handling, particulate control, nitrogen oxides and sulfur dioxides removal, chemical looping for carbon control, and mercury control.
Babcock & Wilcox Thermal: The B&W Thermal segment offers steam generation equipment, aftermarket parts, construction, maintenance and field services for plants in the power generation, oil and gas, and industrial sectors. We have an extensive global base of installed equipment for utilities and general industrial applications including refining, petrochemical, food processing, metals and others.

Our business depends significantly on the capital, operations and maintenance expenditures of global electric power generating companies, including renewable and thermal powered heat generation industries and industrial facilities with environmental compliance policy requirements. Several factors may influence these expenditures, including:
climate change initiatives promoting environmental policies, including renewable energy options utilizing waste-to-energy or biomass, to meet legislative requirements and clean energy portfolio standards in the United States, Europe, Middle East and Asia;
regulations requiring environmental improvements in various industries and global markets;
expectations regarding future governmental requirements to further limit or reduce greenhouse gas and other emissions in the United States, Europe and other international climate change sensitive countries;
prices for electricity, along with the cost of production and distribution, including the cost of fuels, within the United States, Europe, Middle East and Asia;
demand for electricity and other end products of steam-generating facilities;
level of capacity utilization at operating power plants and other industrial users of steam production;
maintenance and upkeep requirements at operating power plants, including to address the accumulated effects of usage;
overall strength of the industrial industry;
ability of electric power generating companies and other steam users to raise capital; and
the impact of geopolitical conflicts, including the ongoing conflicts in Ukraine and the Middle East.

Customer demand is heavily affected by the variations in our customers’ business cycles, power demand in their operating territories and by the overall economies and energy, environmental and noise abatement needs of the countries in which they operate.



Our products

We conducted an analysis of our products to determine which of our products were likely to contain 3TG. We have identified 3TG in products within each of our business segments that are necessary to the functionality or production of products that we manufactured or contracted to manufacture during the Reporting Period.

Conflict minerals policy

We have adopted a conflict minerals policy, as follows, which is also publicly available on our website at “https://investors.babcock.com/assets/Governance-Documents/Conflict-Minerals-Policy.pdf”. The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.

We support sourcing components and materials from companies that share our values regarding respect for human rights, ethics and environmental responsibility. We are committed to complying with the SEC disclosure requirements and are working with our suppliers to perform reasonable country of origin inquiries and due diligence in determining the potential for conflict minerals in our supply chain and products.

We expect our suppliers to partner with us in our commitment to compliance and have designed our efforts to align with conflict minerals reporting rules.

Description of RCOI

Our operations use materials, such as carbon and alloy steels in various forms and components and accessories for assembly, which are available from numerous sources. We generally purchase materials and components as needed for individual contracts.

As noted above, we manufacture a variety of products for which materials included in those products may differ from year to year. These products are highly complex, typically containing thousands of parts from many suppliers throughout the world. We may purchase the same materials from multiple different suppliers and distributors. These suppliers and distributors often obtain their materials from lower tier suppliers. Accordingly, our supply chain is deep and identifying the ultimate source of materials supplied to us is difficult. We rely on our direct suppliers to work with their suppliers to provide information on the smelters and origin of the 3TG contained in components and materials supplied to us.

During the Reporting Period, our compliance efforts included both our domestic and our international locations. For each of the products (or subassemblies) that we identified as containing 3TG necessary to their functionality or production, we identified the suppliers that provided the materials comprising each of these products. We specifically identified each supplier that provided the materials containing the 3TG that we identified, as the 3TG in these products and related supplier base was limited.

To determine whether necessary 3TGs in our products originated in Covered Countries, we retained Assent Compliance (“Assent”), our third party service provider, to assist us in reviewing our supply chain and identifying risks. We provided a list composed of suppliers associated with the covered products to Assent for upload to the Assent Compliance Manager tool (“ACM”).




B&W utilized the RBA-GeSI Conflict Minerals Reporting Template (“CMRT”) version 6.31 or higher to conduct a survey of all in scope suppliers. During the supplier survey, we contacted suppliers via the ACM, a software-as-a-service (SaaS) platform provided by Assent that enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, question 1 of the CMRT asks suppliers whether any of the 3TGs are intentionally added or used in the products or in the production process. Question 2 also asks if any 3TGs remain in their products. We also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process. We conducted this analysis based on the following criteria:

The company supplies packaging only (excluding labels)
The company supplies us with items that do not end up in our products (including equipment used to make our products)
The company is a test lab
The company is a service provider only
The company is in active litigation with B&W

Assent requested that all suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. B&W directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested such suppliers to complete the CMRT form and submit such form to Assent.

Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT.

All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regards to invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. As of May 9, 2025, there were 11 invalid supplier submissions that could not be corrected.

Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the Responsible Mineral Initiative (“RMI”) and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TGs. Our suppliers identified a total of 365 smelters and refiners that appear on the lists maintained by RMI. Of these 365 smelters and refiners, 240 are validated as conflict free by RMI or a cross-recognized initiative.

Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TGs contained in our products.




Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the conflict minerals in question.

As of May 9, 2025, there were 1,164 suppliers in scope of the conflict minerals program and 631 provided a completed CMRT. B&W’s total response rate for this reporting year was 55%. These metrics are summarized in the table below in order to assess progress over time:


YearSuppliers in Scope% Responded% Invalid
RY 20221,752 44 %1.1 %
RY 20231,179 53 %0.6 %
RY 20241,164 55 %0.9 %

Due diligence

Design of due diligence

We designed our due diligence measures to conform, in all material respects, with the framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“the Guidance”) and the related Supplements for gold, tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:

1Establishing strong company management systems regarding conflict minerals;
2Identifying and assessing risks in our supply chain;
3Designing and implementing a strategy to respond to identified risks in our supply chain;
4Utilizing independent third-party audits of supply chain diligence; and
5Reporting annually on our supply chain due diligence

Due diligence requires B&W’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as we cannot fully own this process. However, through continued outreach and process validation, this aligns with industry standards and market expectations for downstream companies’ due diligence.

We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, B&W does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.




The Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.

Due diligence performed

1. Establish strong company management systems

Conflict minerals policy

We established a Conflict Minerals Policy related to our sourcing of 3TG as described in full in the “Conflict Minerals Policy” section above and posted this policy on our website at “https://investors.babcock.com/assets/Governance-Documents/Conflict-Minerals-Policy.pdfwithin the “Investors” section under “Corporate Governance.” The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.

Internal team

We commissioned a Conflict Minerals Steering Committee comprised of individuals in management positions across the procurement, legal and finance functions. The Conflict Minerals Steering Committee is led by members of our senior management. The Conflict Minerals Steering Committee governs our conflict minerals compliance effort and is responsible for providing guidance and direction for the implementation of our conflict minerals program.

We also use a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that we will undertake with suppliers in regards to conflict minerals. The use of Assent and its tools has allowed us to assist our suppliers in understanding our expectations and requirements with respect to conflict minerals compliance.

We leverage Assent’s Managed Services in order to work with dedicated program specialists who support B&W’s conflict minerals program. We communicate regularly with the Assent team in order to receive updates on program status.

Control systems and grievance mechanism

We do not typically have a direct relationship with smelters and refiners. However, we have controls in place designed to uphold our core values and ethical standards in all interactions with customers, vendors, suppliers, shareholders, fellow employees and others. These controls include a Code of Business Conduct and a Supplier Code of Conduct that outline expected behaviors for all employees, vendors and independent contractors. These Codes are publicly available on our website. To this



end, anyone can utilize our Integrity Line as detailed in the Codes to proactively report a violation of our Code or policies, including our conflict minerals policy and related program efforts.

Maintain records

We have maintained company-wide document retention policies. These policies extend to the documentation accumulated in performing our due diligence procedures and requires that documentation will be retained for a period of 10 years.

In addition, we implemented a document retention policy through Assent to retain conflict minerals related documents for five years, including supplier responses to CMRTs. We store all the information and findings from this process in a database that can be audited by internal or external parties.

Supplier engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 6.31 or higher and Assent’s web-based reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.

We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information to support chain of custody of the 3TG identified in our products. We have provided suppliers access to our Conflict Minerals Policy through the website above or upon request.

We continue to emphasize supplier education and training. To accomplish this, we utilized Assent’s learning management system and provided all in-scope suppliers access to many conflict minerals training and support resources. This training was tracked and evaluated based on completion. B&W has a strong relationship with Tier 1 direct suppliers. As an extremely important part of the supply chain, B&W through Assent has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support and other multilingual resources. B&W suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly file a CMRT. Suppliers are provided guidance in their native language, if needed.

We believe that the combination of the Supplier Code of Conduct, our Conflict Minerals Policy, and direct engagement with suppliers for conflict minerals training and requests constitute a strong program when it comes to supplier engagement.

2. Identify and assess risks in the supply chain

Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in the Assent Compliance Manager system based on criteria established for supplier responses in the System. These risks are addressed by Assent Compliance Supply Chain staff and



members of our supply chain team internally who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.

Many of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TGs in the components supplied to B&W. Additionally, some suppliers indicated that they received incomplete information regarding their supply chains from their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.


In accordance with the Guidance, it is important to identify and assess risks associated with conflict minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the 2024 calendar year.

To assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed the RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.

Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

Geographic proximity to the DRC and Covered Countries;
Known mineral source country of origin;
RMAP audit status;
Credible evidence of unethical or conflict sourcing;
Peer Assessments conducted by credible third-party sources.

As part of our risk management plan under the Guidance, when facilities of interest were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent Compliance, submissions that include any facilities of interest immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to B&W, and escalating up to removal of these smelters of interest from their supply chain.

As per the Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to the Assent’s learning management system to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.




Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the Guidance and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:

A. Have you established a conflict minerals sourcing policy?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Do you review due diligence information received from your suppliers against your company’s expectations?
H. Does your review process include corrective action management?

When suppliers meet or exceed those criteria (Yes to at least A, E, G, H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. As of May 9, 2025, a total of 57 of our responsive suppliers have been identified as having a weak program.

3. Design and implement a strategy to respond to risks

We report our findings annually to the Conflict Minerals Steering Committee prior to the issuance of Form SD and this Report. We also report any significant due diligence findings to the Conflict Minerals Steering Committee as they arise. For example, if we find that we source 3TG that directly or indirectly finances or benefits armed groups, in the Covered Countries, B&W will assess the supplier relationship and encourage the supplier in question to establish an alternative source of 3TG that does not support such conflict. We have found no instance where it was necessary to implement risk mitigation efforts as a result of a supplier’s response to our information request.

As per the Guidance, risk mitigation will depend on the supplier’s specific context. Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. We engage suppliers believed to be supplying 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the Guidance. Assent also communicates directly with smelters that have not yet been determined to be conformant with the RMAP in order to request sourcing information and encourage their involvement with the RMI program.

4. Carry-out independent third-party audit of supply chain due diligence at identified points in the supply chain

We do not typically have a direct relationship with smelters and refiners and therefore do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.

Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners.

5. Public reporting on supply chain due diligence




This Report, which constitutes our annual report on our due diligence efforts, is available on our website at “https://investors.babcock.com/home/financial-reports/ ” and is filed with the SEC. The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.

Results of due diligence

Survey results

As described above, B&W actively surveys our supply chain and reviews the responses against criteria developed to determine whether further engagement is required. These criteria include: untimely responses, incomplete responses and inconsistencies within the data reported in the CMRT.

As of May 9, 2025 we received responses from over 55% of our 1,164 surveyed suppliers for the Reporting Period. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. A total of 11 suppliers were unable to correct their CMRTs and as such, are still listed as invalid submissions.

Supply chain outreach metrics are as follows:

Number of In-Scope Suppliers for 2024Change in Number of In-Scope Suppliers From 2023Response RateValid Response Rate
1,164 (15)55 %54 %

Efforts to determine mine or location of origin

Given that we do not have established relationships with the ultimate smelters and refiners from which the 3TG in our products is sourced, we have determined that requesting our suppliers to complete the CMRT represents our good faith effort to determine the mines or locations of origin of 3TG in our supply chain.

Smelters and refiners

Of the suppliers surveyed, many completed the CMRT at the company, business unit or entity level and are unable to represent that 3TG from the processing facilities they listed had actually been included in components that they supplied to us. The quality of the responses that we received from our surveyed suppliers continues to be varied. Many of the responses provided by suppliers via the CMRT included the names of facilities listed by the suppliers as smelters or refiners ("SORs"). The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and Assent follows up on these, urging suppliers to resubmit the form and include smelter information. Any CMRTs submitted by suppliers unable to provide SORs used for the materials supplied to us are deemed invalid.

For all responses that indicated a smelter, Assent compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as "Conflict-Free," Assent confirmed that the name was listed by the RMI as a certified smelter. As of May 9, 2025, we have identified 365 smelters or refiners that were reported by our suppliers via the CMRT. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. All



smelters and refiners listed by suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are attached in Appendix A. Appendix B includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI.

Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 233 smelters that are deemed RMAP Conformant - this indicates these smelters or refiners are compliant with the Conflict Free Smelter Program assessment protocols. There are 4 more smelters or refiners that are deemed RMAP Active - Smelters and refiners on the Active list have committed to undergo a RMAP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. The remaining 130 smelters listed have not yet been confirmed as Conflict-Free. We have assessed these facilities and determined that most of these are of low risk due to their geographic location. As mentioned above, there are 21 smelters or refiners that we consider “High Risk Smelters.

Risk mitigation activities were initiated on the suppliers submitting these entries in their CMRT. Through Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions including removal of these red-flag smelters from their supply chain. The submission of these smelters by B&W suppliers does not guarantee that these smelters or refiners are present in the B&W supply chain as these B&W suppliers were only able to provide company-level CMRTs and not able to provide product-level CMRTs directly linking those smelters or refiners to the products they provide to B&W.

As our suppliers are largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to make any determinations regarding the 3TG included in our products during the Reporting Period or to provide additional smelter and refiner names and country of origin of the necessary 3TGs at this time.

StatusNumber of Identified Smelters and Refiners
RMAP Conformant233
RMAP Active4
Not Enrolled96
Non-Conformant32

Countries of Origin

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. As mentioned in the above section, it is understood that many responses may provide more data than can be directly linked to products sold by our company, therefore, Appendix B may contain more countries than those that the Company’s products are being sourced from.

Steps to be taken

We are committed to complying with the provisions of the Rule and Form SD and expect to continue our conflict minerals program and related due diligence. Our next steps may include, but are not limited to the following:




Engage with suppliers and direct them to training resources, including increasing the number who utilize Assent’s learning management system. This will encourage supplier participation and improve the overall efficiency of our Conflict Minerals Due Diligence Program.
Increase the emphasis on clean and validated smelter and refiner information from our supply chain through Assent as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the RMAP program.
Encourage our suppliers through Assent to develop and strengthen their internal policies to include due diligence procedures for their supply chains to improve the quality of the responses from such suppliers.
Update and maintain the supplier list and contact information for subsequent supplier engagement.
Further document procedures and timelines for administering the conflict mineral program.

Smelter & Refiner Risk Evaluation

Understanding the risks associated with the smelters and refiners potentially providing material into our supply chain is an important part of the due diligence process. Through Assent, comprehensive and ongoing analysis is conducted by Assent’s smelter library manager to assess sourcing risk. This information is used to:
Provide supplier feedback.
Determine the health of the Company’s overall program.
Conduct outreach to smelters, refiners and their respective associations.
Provide detailed analysis in this report.

The following risk categories are used for smelter evaluation and risk determination:
Geo-Risk: Did the mineral originate from or has been transported through a conflict-affected area as defined by Section 1502 of the Dodd-Frank Act (the DRC and its nine adjoining countries; Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia)?

Audit Status: Has the refiner’s due diligence practices been audited against a standard in conformance with the OECD Guidance? Assent relies on the RMI audit standard, including cross-recognition of the London Bullion Market Association (“LBMA”) Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance.

Sourcing risk: Has evidence of any other risk characteristic is supported by credible sources been identified?

Appendix A:

The following smelters and refiners were reported by our suppliers as being in their supply chains. Facilities that have been certified as conflict-free by an internationally-recognized validation scheme for 3TG smelters and refiners are designated below in the fifth column.




MetalSmelter NameSmelter Facility LocationSmelter IdAudit StatusRisk StatusSource from DRC
Tantalum5D Production OUEstoniaCID003926Outreach RequiredLowUnknown
Gold8853 S.p.A.ItalyCID002763NonConformantLowNo
TungstenA.L.M.T. Corp.JapanCID000004ConformantMediumYes
GoldABC Refinery Pty Ltd.AustraliaCID002920Outreach RequiredLowUnknown
GoldAbington Reldan Metals, LLCUnited States Of AmericaCID002708ConformantLowNo
TungstenACL Metais EireliBrazilCID002833NonConformantMediumNo
GoldAdvanced Chemical CompanyUnited States Of AmericaCID000015ConformantLowNo
GoldAfrican Gold RefineryUgandaCID003185Review Cant ProceedHighYes
GoldAgosi AGGermanyCID000035ConformantLowNo
GoldAida Chemical Industries Co., Ltd.JapanCID000019ConformantLowNo
GoldAl Etihad Gold Refinery DMCCUnited Arab EmiratesCID002560NonConformantLowNo
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BrazilCID003427NonConformantMediumYes
GoldAlbino Mountinho Lda.PortugalCID002760Outreach RequiredLowUnknown
GoldAlexy MetalsUnited States Of AmericaCID003500NonConformantLowNo
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UzbekistanCID000041ConformantMediumYes
TinAlphaUnited States Of AmericaCID000292ConformantMediumNo
TantalumAMG BrasilBrazilCID001076ConformantMediumYes
TinAn Vinh Joint Stock Mineral Processing CompanyViet NamCID002703Outreach RequiredLowNo



GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazilCID000058ConformantMediumYes
GoldArgor-Heraeus S.A.SwitzerlandCID000077ConformantMediumNo
TungstenArtek LLCRussian FederationCID003553Review Cant ProceedMediumNo
GoldAsahi Pretec Corp.JapanCID000082ConformantLowNo
GoldAsahi Refining Canada Ltd.CanadaCID000924ConformantLowNo
GoldAsahi Refining USA Inc.United States Of AmericaCID000920ConformantMediumYes
GoldAsaka Riken Co., Ltd.JapanCID000090ConformantLowNo
TungstenAsia Tungsten Products Vietnam Ltd.Viet NamCID002502ConformantMediumYes
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TurkeyCID000103Outreach RequiredLowNo
GoldAttero Recycling Pvt LtdIndiaCID004697Outreach RequiredLowUnknown
GoldAU Traders and RefinersSouth AfricaCID002850NonConformantMediumYes
GoldAugmont Enterprises Private LimitedIndiaCID003461NonConformantLowNo
GoldAurubis AGGermanyCID000113ConformantMediumNo
TinAurubis BeerseBelgiumCID002773ConformantMediumYes
TinAurubis BerangoSpainCID002774ConformantMediumNo
GoldBangalore RefineryIndiaCID002863ActiveLowNo
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PhilippinesCID000128ConformantLowNo
GoldBoliden RonnskarSwedenCID000157ConformantLowNo
GoldC. Hafner GmbH + Co. KGGermanyCID000176ConformantLowNo
GoldCaridadMexicoCID000180Outreach RequiredLowNo



GoldCCR Refinery - Glencore Canada CorporationCanadaCID000185ConformantMediumYes
GoldCendres + Metaux S.A.SwitzerlandCID000189NonConformantLowNo
GoldCGR Metalloys Pvt Ltd.IndiaCID003382Outreach RequiredLowNo
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaCID000228ConformantMediumNo
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaCID003190ConformantLowNo
GoldChimet S.p.A.ItalyCID000233ConformantHighNo
TungstenChina Molybdenum Tungsten Co., Ltd.ChinaCID002641ConformantLowNo
TinChina Tin Group Co., Ltd.ChinaCID001070ConformantMediumNo
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaCID000258ConformantMediumYes
GoldChugai MiningJapanCID000264ConformantLowNo
TungstenCNMC (Guangxi) PGMA Co., Ltd.ChinaCID000281Outreach RequiredLowNo
GoldCoimpa Industrial LTDABrazilCID004010ConformantLowUnknown
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBrazilCID003486ConformantLowNo
TinCRM SynergiesSpainCID003524ConformantLowNo
TungstenCronimet Brasil LtdaBrazilCID003468ConformantLowNo
TinCV Ayi JayaIndonesiaCID002570ConformantMediumNo
TinCV Venus Inti PerkasaIndonesiaCID002455ConformantLowNo
TantalumD Block Metals, LLCUnited States Of AmericaCID002504ConformantMediumYes
GoldDaye Non-Ferrous Metals Mining Ltd.ChinaCID000343Outreach RequiredLowNo



GoldDegussa Sonne / Mond Goldhandel GmbHGermanyCID002867Outreach RequiredLowNo
GoldDijllah Gold Refinery FZCUnited Arab EmiratesCID003348Outreach RequiredLowNo
TinDongguan CiEXPO Environmental Engineering Co., Ltd.ChinaCID003356NonConformantLowNo
TungstenDONGKUK INDUSTRIES CO., LTD.Korea, Republic OfCID004060Outreach RequiredLowUnknown
GoldDongwu Gold GroupChinaCID003663Outreach RequiredLowUnknown
TinDowaJapanCID000402ConformantLowNo
GoldDowaJapanCID000401ConformantMediumNo
TinDS MyanmarMyanmarCID003831ConformantLowNo
GoldDSC (Do Sung Corporation)Korea, Republic OfCID000359ConformantLowNo
GoldEco-System Recycling Co., Ltd. East PlantJapanCID000425ConformantLowNo
GoldEco-System Recycling Co., Ltd. North PlantJapanCID003424ConformantLowNo
GoldEco-System Recycling Co., Ltd. West PlantJapanCID003425ConformantLowNo
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyViet NamCID002572NonConformantLowNo
GoldElite Industech Co., Ltd.Taiwan, Province Of ChinaCID004755ConformantLowUnknown
TinEM VintoBolivia (Plurinational State Of)CID000438ConformantMediumNo
GoldEmerald Jewel Industry India Limited (Unit 1)IndiaCID003487Outreach RequiredLowUnknown
GoldEmerald Jewel Industry India Limited (Unit 2)IndiaCID003488Outreach RequiredLowUnknown



GoldEmerald Jewel Industry India Limited (Unit 3)IndiaCID003489Outreach RequiredLowUnknown
GoldEmerald Jewel Industry India Limited (Unit 4)IndiaCID003490Outreach RequiredLowUnknown
GoldEmirates Gold DMCCUnited Arab EmiratesCID002561NonConformantMediumYes
TinEstanho de Rondonia S.A.BrazilCID000448ConformantLowNo
TantalumF&X Electro-Materials Ltd.ChinaCID000460ConformantMediumYes
TinFabrica Auricchio Industria e Comercio Ltda.BrazilCID003582NonConformantLowNo
TinFenix MetalsPolandCID000468ConformantMediumNo
GoldFidelity Printers and Refiners Ltd.ZimbabweCID002515Review Cant ProceedHighYes
TantalumFIR Metals & Resource Ltd.ChinaCID002505ConformantLowNo
GoldFujairah Gold FZCUnited Arab EmiratesCID002584Outreach RequiredLowNo
TungstenFujian Xinlu Tungsten Co., Ltd.ChinaCID003609ConformantLowUnknown
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.ChinaCID002315ConformantMediumYes
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaCID002494ConformantMediumNo
TinGejiu City Fuxiang Industry and Trade Co., Ltd.ChinaCID003410Outreach RequiredLowNo
TinGejiu Kai Meng Industry and Trade LLCChinaCID000942NonConformantMediumNo
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaCID000538ConformantMediumNo
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.ChinaCID001908NonConformantLowNo



TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaCID000555NonConformantMediumNo
GoldGG Refinery Ltd.Tanzania, United Republic OfCID004506ConformantLowUnknown
GoldGGC Gujrat Gold Centre Pvt. Ltd.IndiaCID002852NonConformantMediumNo
TantalumGlobal Advanced Metals AizuJapanCID002558ConformantMediumYes
TantalumGlobal Advanced Metals BoyertownUnited States Of AmericaCID002557ConformantMediumYes
TinGlobal Advanced Metals Greenbushes Pty Ltd.AustraliaCID004754ConformantLowUnknown
TungstenGlobal Tungsten & Powders LLCUnited States Of AmericaCID000568ConformantMediumYes
GoldGold by Gold ColombiaColombiaCID003641ConformantLowUnknown
GoldGold Coast RefineryGhanaCID003186Outreach RequiredLowNo
GoldGold Refinery of Zijin Mining Group Co., Ltd.ChinaCID002243ConformantHighNo
GoldGreat Wall Precious Metals Co., Ltd. of CBPMChinaCID001909Outreach RequiredLowNo
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaCID003116ConformantMediumNo
GoldGuangdong Jinding Gold LimitedChinaCID002312Outreach RequiredLowNo
TantalumGuangdong Rising Rare Metals-EO Materials Ltd.ChinaCID000291ConformantMediumYes
TungstenGuangdong Xianglu Tungsten Co., Ltd.ChinaCID000218ConformantLowNo



GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.ChinaCID000651Outreach RequiredLowNo
TungstenH.C. Starck Tungsten GmbHGermanyCID002541ConformantMediumYes
GoldHangzhou Fuchunjiang Smelting Co., Ltd.ChinaCID000671Outreach RequiredLowNo
TungstenHANNAE FOR T Co., Ltd.Korea, Republic OfCID003978Outreach RequiredLowUnknown
GoldHeimerle + Meule GmbHGermanyCID000694ConformantMediumYes
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaCID002492ConformantLowNo
GoldHeraeus Germany GmbH Co. KGGermanyCID000711ConformantLowNo
GoldHeraeus Metals Hong Kong Ltd.ChinaCID000707ConformantLowNo
TungstenHubei Green Tungsten Co., Ltd.ChinaCID003417ConformantLowNo
TinHuiChang Hill Tin Industry Co., Ltd.ChinaCID002844ConformantLowNo
GoldHunan Chenzhou Mining Co., Ltd.ChinaCID000767Outreach RequiredLowNo
TungstenHunan Chenzhou Mining Co., Ltd.ChinaCID000766ConformantLowNo
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.ChinaCID000773Outreach RequiredLowYes
TungstenHunan Jintai New Material Co., Ltd.ChinaCID000769NonConformantMediumNo
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchChinaCID002513ConformantMediumNo



GoldHwaSeong CJ CO., LTD.Korea, Republic OfCID000778Communication SuspendedLowNo
TungstenHydrometallurg, JSCRussian FederationCID002649Review Cant ProceedMediumYes
GoldImpala Platinum - Platinum Metals Refinery (PMR)South AfricaCID004714ConformantLowUnknown
GoldIndustrial Refining CompanyBelgiumCID002587NonConformantHighNo
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.ChinaCID000801ConformantLowNo
GoldInternational Precious Metal RefinersUnited Arab EmiratesCID002562Outreach RequiredLowNo
GoldIshifuku Metal Industry Co., Ltd.JapanCID000807ConformantLowNo
GoldIstanbul Gold RefineryTurkeyCID000814ConformantMediumYes
GoldItalpreziosiItalyCID002765ConformantLowNo
GoldJALAN & CompanyIndiaCID002893Outreach RequiredLowNo
GoldJapan MintJapanCID000823ConformantLowNo
TungstenJapan New Metals Co., Ltd.JapanCID000825ConformantMediumNo
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.ChinaCID002551ConformantMediumYes
GoldJiangxi Copper Co., Ltd.ChinaCID000855ConformantLowNo
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.ChinaCID002512ConformantLowNo
TungstenJiangxi Gan Bei Tungsten Co., Ltd.ChinaCID002321ConformantMediumNo
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.ChinaCID002313Communication SuspendedLowNo
TinJiangxi New Nanshan Technology Ltd.ChinaCID001231ConformantMediumNo



TantalumJiangxi Sanshi Nonferrous Metals Co., LtdChinaCID004813in CommunicationLowUnknown
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.ChinaCID002318ConformantMediumNo
TantalumJiangxi Tuohong New Raw MaterialChinaCID002842ConformantLowNo
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.ChinaCID002317ConformantMediumYes
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaCID002316ConformantLowNo
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaCID000914ConformantMediumYes
TantalumJiujiang Tanbre Co., Ltd.ChinaCID000917ConformantMediumYes
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaCID002506ConformantMediumYes
TungstenJSC "Kirovgrad Hard Alloys Plant"Russian FederationCID003408Review Cant ProceedHighNo
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRussian FederationCID000927Review Cant ProceedHighNo
GoldJSC Novosibirsk RefineryRussian FederationCID000493Review Cant ProceedHighNo
GoldJSC UralelectromedRussian FederationCID000929Review Cant ProceedHighNo
GoldJX Nippon Mining & Metals Co., Ltd.JapanCID000937ConformantLowNo
GoldK.A. RasmussenNorwayCID003497Outreach RequiredMediumYes
GoldKaloti Precious MetalsUnited Arab EmiratesCID002563Review Cant ProceedHighNo
GoldKazakhmys Smelting LLCKazakhstanCID000956Outreach RequiredLowNo



GoldKazzincKazakhstanCID000957ConformantLowNo
TantalumKEMET de MexicoMexicoCID002539ConformantMediumYes
TungstenKenee Mining Corporation VietnamViet NamCID004619ConformantLowUnknown
TungstenKennametal FallonUnited States Of AmericaCID000966ConformantMediumYes
TungstenKennametal HuntsvilleUnited States Of AmericaCID000105ConformantMediumNo
GoldKennecott Utah Copper LLCUnited States Of AmericaCID000969ConformantLowNo
GoldKGHM Polska Miedz Spolka AkcyjnaPolandCID002511ConformantLowNo
GoldKojima Chemicals Co., Ltd.JapanCID000981ConformantLowNo
GoldKorea Zinc Co., Ltd.Korea, Republic OfCID002605ConformantLowNo
GoldKundan Care Products Ltd.IndiaCID003463Outreach RequiredMediumYes
GoldKyrgyzaltyn JSCKyrgyzstanCID001029NonConformantLowNo
GoldKyshtym Copper-Electrolytic Plant ZAORussian FederationCID002865Review Cant ProceedHighNo
GoldL'azurde Company For JewelrySaudi ArabiaCID001032Review Cant ProceedLowNo
TungstenLianyou Metals Co., Ltd.Taiwan, Province Of ChinaCID003407ConformantLowNo
TungstenLianyou Resources Co., Ltd.Taiwan, Province Of ChinaCID004397ConformantLowUnknown
GoldLingbao Gold Co., Ltd.ChinaCID001056Outreach RequiredMediumNo
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.ChinaCID001058Outreach RequiredLowNo
TungstenLLC VostokRussian FederationCID003643Review Cant ProceedMediumUnknown



TinLongnan Chuangyue Environmental Protection Technology Development Co., LtdChinaCID004796Outreach RequiredLowUnknown
GoldL'Orfebre S.A.AndorraCID002762NonConformantMediumYes
GoldLS MnM Inc.Korea, Republic OfCID001078ConformantLowNo
GoldLT Metal Ltd.Korea, Republic OfCID000689ConformantLowNo
TinLuna Smelter, Ltd.RwandaCID003387ConformantMediumYes
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.ChinaCID001093Outreach RequiredLowNo
TinMa'anshan Weitai Tin Co., Ltd.ChinaCID003379NonConformantLowNo
TinMagnu's Minerais Metais e Ligas Ltda.BrazilCID002468ConformantMediumNo
TungstenMALAMET SMELTING SDN. BHD.MalaysiaCID004056Outreach RequiredLowUnknown
TinMalaysia Smelting Corporation (MSC)MalaysiaCID001105ConformantMediumYes
TinMalaysia Smelting Corporation Berhad (Port Klang)MalaysiaCID004434ConformantLowUnknown
TungstenMalipo Haiyu Tungsten Co., Ltd.ChinaCID002319ConformantMediumNo
GoldMarsam MetalsBrazilCID002606NonConformantLowNo
TungstenMasan High-Tech MaterialsViet NamCID002543ConformantMediumNo
GoldMaterionUnited States Of AmericaCID001113ConformantLowNo
TantalumMaterion Newton Inc.United States Of AmericaCID002548ConformantMediumYes
GoldMatsuda Sangyo Co., Ltd.JapanCID001119ConformantLowNo



GoldMD OverseasIndiaCID003548Outreach RequiredLowNo
TinMelt Metais e Ligas S.A.BrazilCID002500ActiveMediumNo
GoldMetal Concentrators SA (Pty) Ltd.South AfricaCID003575ConformantLowNo
TinMetallic Resources, Inc.United States Of AmericaCID001142ConformantMediumNo
GoldMetallix Refining Inc.United States Of AmericaCID003557Outreach RequiredLowUnknown
TantalumMetallurgical Products India Pvt., Ltd.IndiaCID001163ConformantLowNo
GoldMetalor Technologies (Hong Kong) Ltd.ChinaCID001149ConformantMediumYes
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeCID001152ConformantLowNo
GoldMetalor Technologies (Suzhou) Ltd.ChinaCID001147ConformantLowNo
GoldMetalor Technologies S.A.SwitzerlandCID001153ConformantMediumYes
GoldMetalor USA Refining CorporationUnited States Of AmericaCID001157ConformantLowNo
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MexicoCID001161ConformantLowNo
TantalumMineracao Taboca S.A.BrazilCID001175ConformantLowNo
TinMineracao Taboca S.A.BrazilCID001173ConformantLowNo
TinMining Minerals Resources SARLCongo, Democratic Republic Of TheCID004065ConformantMediumYes
TinMinsurPeruCID001182ConformantMediumNo
TinMitsubishi Materials CorporationJapanCID001191ConformantLowNo
GoldMitsubishi Materials CorporationJapanCID001188ConformantMediumYes



TantalumMitsui Mining and Smelting Co., Ltd.JapanCID001192ConformantMediumYes
GoldMitsui Mining and Smelting Co., Ltd.JapanCID001193ConformantLowNo
GoldMKS PAMP SASwitzerlandCID001352ConformantMediumYes
GoldMMTC-PAMP India Pvt., Ltd.IndiaCID002509ConformantMediumYes
TinModeltech Sdn BhdMalaysiaCID002858NonConformantLowNo
GoldModeltech Sdn BhdMalaysiaCID002857NonConformantLowNo
TungstenMoliren Ltd.Russian FederationCID002845Review Cant ProceedHighNo
GoldMorris and WatsonNew ZealandCID002282Outreach RequiredLowNo
GoldMoscow Special Alloys Processing PlantRussian FederationCID001204Review Cant ProceedHighNo
GoldNadir Metal Rafineri San. Ve Tic. A.S.TurkeyCID001220ConformantLowNo
TungstenNam Viet Cromit Joint Stock CompanyViet NamCID004034Outreach RequiredLowUnknown
GoldNavoi Mining and Metallurgical CombinatUzbekistanCID001236ConformantLowNo
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyViet NamCID002573Outreach RequiredMediumYes
GoldNH Recytech CompanyKorea, Republic OfCID003189ConformantLowNo
TungstenNiagara Refining LLCUnited States Of AmericaCID002589ConformantMediumNo
GoldNihon Material Co., Ltd.JapanCID001259ConformantMediumYes
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaCID001277ConformantMediumYes
GoldNOBLE METAL SERVICESUnited States Of AmericaCID003690Outreach RequiredLowUnknown
TinNovosibirsk Tin CombineRussian FederationCID001305Review Cant ProceedMediumNo
TantalumNPM Silmet ASEstoniaCID001200ConformantMediumYes



TungstenNPP Tyazhmetprom LLCRussian FederationCID003416Review Cant ProceedHighNo
TinO.M. Manufacturing (Thailand) Co., Ltd.ThailandCID001314ConformantLowNo
TinO.M. Manufacturing Philippines, Inc.PhilippinesCID002517ConformantMediumNo
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustriaCID002779ActiveMediumNo
GoldOhura Precious Metal Industry Co., Ltd.JapanCID001325ConformantLowNo
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)Russian FederationCID001326Review Cant ProceedHighNo
TungstenOOO “Technolom” 1Russian FederationCID003614Review Cant ProceedMediumUnknown
TungstenOOO “Technolom” 2Russian FederationCID003612Review Cant ProceedMediumUnknown
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)CID001337ConformantMediumNo
GoldPease & CurrenUnited States Of AmericaCID002872Communication SuspendedMediumNo
GoldPenglai Penggang Gold Industry Co., Ltd.ChinaCID001362Outreach RequiredLowNo
TungstenPhilippine Bonway Manufacturing Industrial CorporationPhilippinesCID004797ConformantLowUnknown
TungstenPhilippine Carreytech Metal Corp.PhilippinesCID004438ActiveLowUnknown
TungstenPhilippine Chuangxin Industrial Co., Inc.PhilippinesCID002827ConformantLowNo



GoldPlanta Recuperadora de Metales SpAChileCID002919ConformantLowNo
TinPongpipat Company LimitedMyanmarCID003208Outreach RequiredMediumNo
TantalumPowerX Ltd.RwandaCID004054ConformantLowUnknown
TinPrecious Minerals and Smelting LimitedIndiaCID003409NonConformantLowNo
GoldPrioksky Plant of Non-Ferrous MetalsRussian FederationCID001386Review Cant ProceedHighNo
GoldPT Aneka Tambang (Persero) TbkIndonesiaCID001397ConformantLowNo
TinPT Aries Kencana SejahteraIndonesiaCID000309ConformantMediumNo
TinPT Artha Cipta LanggengIndonesiaCID001399ConformantMediumNo
TinPT ATD Makmur Mandiri JayaIndonesiaCID002503ConformantMediumNo
TinPT Babel Inti PerkasaIndonesiaCID001402ConformantMediumNo
TinPT Babel Surya Alam LestariIndonesiaCID001406ConformantLowNo
TinPT Bangka Prima TinIndonesiaCID002776ConformantMediumNo
TinPT Bangka SerumpunIndonesiaCID003205ConformantMediumNo
TinPT Bangka Tin IndustryIndonesiaCID001419ConformantMediumYes
TinPT Belitung Industri SejahteraIndonesiaCID001421ConformantMediumNo
TinPT Bukit TimahIndonesiaCID001428ConformantMediumNo
TinPT Cipta Persada MuliaIndonesiaCID002696ConformantLowNo
TinPT Menara Cipta MuliaIndonesiaCID002835ConformantMediumNo
TinPT Mitra Graha RayaIndonesiaCID004685Outreach RequiredLowUnknown
TinPT Mitra Stania PrimaIndonesiaCID001453ConformantMediumNo
TinPT Mitra Sukses GlobalindoIndonesiaCID003449ConformantLowNo
TinPT Panca Mega PersadaIndonesiaCID001457Outreach RequiredMediumNo



TinPT Premium Tin IndonesiaIndonesiaCID000313ConformantMediumNo
TinPT Prima Timah UtamaIndonesiaCID001458ConformantMediumNo
TinPT Putera Sarana Shakti (PT PSS)IndonesiaCID003868ConformantLowUnknown
TinPT Rajawali Rimba PerkasaIndonesiaCID003381ConformantLowNo
TinPT Rajehan AriqIndonesiaCID002593ConformantMediumNo
TinPT Refined Bangka TinIndonesiaCID001460ConformantMediumNo
TinPT Sariwiguna BinasentosaIndonesiaCID001463ConformantMediumNo
TinPT Stanindo Inti PerkasaIndonesiaCID001468ConformantMediumNo
TinPT Sukses Inti MakmurIndonesiaCID002816ConformantMediumNo
TinPT Timah NusantaraIndonesiaCID001486ConformantMediumNo
TinPT Timah Tbk KundurIndonesiaCID001477ConformantMediumNo
TinPT Timah Tbk MentokIndonesiaCID001482ConformantMediumNo
TinPT Tinindo Inter NusaIndonesiaCID001490ConformantMediumNo
TinPT Tirus Putra MandiriIndonesiaCID002478Outreach RequiredLowNo
TinPT Tommy UtamaIndonesiaCID001493ConformantLowNo
GoldPX Precinox S.A.SwitzerlandCID001498ConformantLowNo
GoldQG Refining, LLCUnited States Of AmericaCID003324Outreach RequiredMediumYes
TantalumQuantumCleanUnited States Of AmericaCID001508ConformantLowNo
GoldRand Refinery (Pty) Ltd.South AfricaCID001512ConformantMediumYes
GoldRefinery of Seemine Gold Co., Ltd.ChinaCID000522Outreach RequiredLowNo
GoldREMONDIS PMR B.V.NetherlandsCID002582ConformantLowNo
TantalumResind Industria e Comercio Ltda.BrazilCID002707ConformantLowNo



TinResind Industria e Comercio Ltda.BrazilCID002706ConformantMediumYes
TantalumRFH Yancheng Jinye New Material Technology Co., Ltd.ChinaCID003583ConformantLowUnknown
TinRIKAYAA GREENTECH PRIVATE LIMITEDIndiaCID004692Outreach RequiredLowUnknown
GoldRoyal Canadian MintCanadaCID001534ConformantLowNo
TinRui Da HungTaiwan, Province Of ChinaCID001539ConformantMediumNo
GoldSAAMPFranceCID002761NonConformantMediumNo
GoldSabin Metal Corp.United States Of AmericaCID001546Communication SuspendedMediumNo
GoldSafimet S.p.AItalyCID002973NonConformantMediumYes
GoldSAFINA A.S.CzechiaCID002290ConformantLowNo
GoldSai RefineryIndiaCID002853Outreach RequiredLowNo
GoldSam Precious MetalsUnited Arab EmiratesCID003666in CommunicationLowUnknown
GoldSamduck Precious MetalsKorea, Republic OfCID001555NonConformantMediumYes
GoldSamwon Metals Corp.Korea, Republic OfCID001562Communication SuspendedLowNo
GoldSEMPSA Joyeria Plateria S.A.SpainCID001585ConformantLowNo
GoldShandong Gold Smelting Co., Ltd.ChinaCID001916ConformantHighYes
GoldShandong Humon Smelting Co., Ltd.ChinaCID002525Outreach RequiredLowNo
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.ChinaCID001619Outreach RequiredLowNo



GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaCID001622ConformantHighNo
GoldShenzhen CuiLu Gold Co., Ltd.ChinaCID002750Outreach RequiredLowUnknown
GoldSHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD.ChinaCID004435Outreach RequiredLowUnknown
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.ChinaCID002527Outreach RequiredLowNo
TungstenShinwon Tungsten (Fujian Shanghang) Co., Ltd.ChinaCID004430ConformantLowUnknown
GoldShirpur Gold Refinery Ltd.IndiaCID002588Outreach RequiredLowNo
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaCID001736ConformantLowNo
GoldSingway Technology Co., Ltd.Taiwan, Province Of ChinaCID002516NonConformantLowNo
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian FederationCID001756Review Cant ProceedHighNo
GoldSolar Applied Materials Technology Corp.Taiwan, Province Of ChinaCID001761ConformantLowNo
TantalumSolikamsk Magnesium Works OAORussian FederationCID001769Review Cant ProceedHighNo
GoldSovereign MetalsIndiaCID003383Outreach RequiredMediumYes
GoldState Research Institute Center for Physical Sciences and TechnologyLithuaniaCID003153Outreach RequiredMediumYes
GoldSudan Gold RefinerySudanCID002567Outreach RequiredHighYes
GoldSumitomo Metal Mining Co., Ltd.JapanCID001798ConformantLowNo



GoldSungEel HiMetal Co., Ltd.Korea, Republic OfCID002918ConformantLowNo
GoldSuper Dragon Technology Co., Ltd.Taiwan, Province Of ChinaCID001810Outreach RequiredLowNo
TinSuper LigasBrazilCID002756ConformantMediumYes
GoldT.C.A S.p.AItalyCID002580ConformantLowNo
TinTakehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.JapanCID004403ConformantLowNo
TantalumTaki Chemical Co., Ltd.JapanCID001869ConformantLowNo
GoldTanaka Kikinzoku Kogyo K.K.JapanCID001875ConformantLowNo
TantalumTANIOBIS Co., Ltd.ThailandCID002544ConformantMediumYes
TantalumTANIOBIS GmbHGermanyCID002545ConformantMediumYes
TantalumTANIOBIS Japan Co., Ltd.JapanCID002549ConformantMediumYes
TantalumTANIOBIS Smelting GmbH & Co. KGGermanyCID002550ConformantMediumYes
TungstenTANIOBIS Smelting GmbH & Co. KGGermanyCID002542ConformantMediumYes
TantalumTelex MetalsUnited States Of AmericaCID001891ConformantMediumYes
TinThaisarcoThailandCID001898ConformantMediumYes
TinTin Smelting Branch of Yunnan Tin Co., Ltd.ChinaCID002180ConformantLowNo
TinTin Technology & RefiningUnited States Of AmericaCID003325ConformantLowNo
GoldTokuriki Honten Co., Ltd.JapanCID001938ConformantLowNo
GoldTongling Nonferrous Metals Group Co., Ltd.ChinaCID001947Outreach RequiredLowNo
GoldTOO Tau-Ken-AltynKazakhstanCID002615ConformantLowNo



GoldTorecomKorea, Republic OfCID001955NonConformantLowNo
TungstenTungsten Vietnam Joint Stock CompanyViet NamCID003993ConformantLowUnknown
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyViet NamCID002574Outreach RequiredLowNo
TantalumUlba Metallurgical Plant JSCKazakhstanCID001969ConformantMediumYes
CobaltUmicore Finland OyFinlandCID003226ConformantLowNo
GoldUmicore Precious Metals ThailandThailandCID002314NonConformantLowNo
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgiumCID001980ConformantLowNo
TungstenUnecha Refractory metals plantRussian FederationCID002724NonConformantMediumNo
GoldUnited Precious Metal Refining, Inc.United States Of AmericaCID001993ConformantLowNo
GoldValcambi S.A.SwitzerlandCID002003ConformantMediumYes
TinVQB Mineral and Trading Group JSCViet NamCID002015Outreach RequiredMediumYes
GoldWEEEREFININGFranceCID003615ConformantLowUnknown
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaCID002030ConformantLowNo
TinWhite Solder Metalurgia e Mineracao Ltda.BrazilCID002036ConformantMediumYes
GoldWIELAND Edelmetalle GmbHGermanyCID002778ConformantLowNo
TungstenWolfram Bergbau und Hutten AGAustriaCID002044ConformantMediumYes
TinWoodcross Smelting Company LimitedUgandaCID004724ConformantLowUnknown



TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaCID002320ConformantMediumYes
TungstenXiamen Tungsten Co., Ltd.ChinaCID002082ConformantMediumYes
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDChinaCID000616ConformantMediumYes
TantalumXinXing HaoRong Electronic Material Co., Ltd.ChinaCID002508ConformantLowNo
GoldYamakin Co., Ltd.JapanCID002100ConformantLowNo
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaCID001522ConformantLowNo
GoldYokohama Metal Co., Ltd.JapanCID002129ConformantMediumYes
TungstenYUDU ANSHENG TUNGSTEN CO., LTD.ChinaCID003662Outreach RequiredLowUnknown
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaCID002158ConformantMediumNo
GoldYunnan Copper Industry Co., Ltd.ChinaCID000197Outreach RequiredMediumYes
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.ChinaCID003397ConformantMediumNo
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaCID002224ConformantLowNo

Appendix B:

Countries of origin:

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.




Andorra, Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Burundi Canada, Chile, China, Columbia, Democratic Republic of The Congo, Czechia, El Salvador, Estonia, Ethiopia, Finland, France, Germany, Ghana, Hungary, India, Indonesia, Israel, Italy, Japan, Kazakhstan, Republic of Korea, Kyrgyzstan, Lithuania, Luxembourg, Madagascar, Malaysia, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Norway, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa, Spain, Sudan, Sweden, Switzerland, United Republic of Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United States of America, Uzbekistan, Vietnam, Zimbabwe.