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Exhibit 1.01
Welbilt, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2021
This Conflict Minerals Report (this "Report") for the year ended December 31, 2021 is presented to comply with Rule 13p-1 ("Rule 13p-1") under the Securities Exchange Act of 1934, as amended. Unless otherwise expressly stated or the context otherwise requires, references to "we," "our," "us," the "Company" or "Welbilt," refer to Welbilt, Inc. and its consolidated subsidiaries.
This Report has been prepared by our management for calendar year 2021 in accordance with Rule 13p-1. This Report discusses our efforts related to determining whether any of the products we manufacture or that we have contracted to be manufactured contain tin, tantalum, tungsten and gold (collectively, the "3TG Minerals") that are necessary to the functionality or production of such products that may have originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (collectively, the "Covered Countries") or are from recycled or scrap sources.
Forward-Looking Statements
Certain statements contained in, or incorporated into, this Report constitute "forward-looking statements" within the meaning of the U.S. Private Securities Litigation Reform Act of 1995. Statements that are not historical fact are forward-looking statements and include, for example, descriptions of our supply chain improvement efforts and risk mitigation strategies. Certain of these forward-looking statements can be identified by the use of words such as "anticipates," "believes," "intends," "estimates," "targets," "expects," "could," "will," "may," "plans," "projects," "assumes," "should" or other similar expressions. Such forward-looking statements involve known and unknown risks and uncertainties, and our actual results could differ materially from future results expressed or implied in these forward-looking statements. The forward-looking statements included in this report are based on our current beliefs and expectations and speak only as of the date of this report. These statements are not guarantees or indicators of future performance. Important assumptions and other important factors that could cause actual results to differ materially from these forward-looking statements include, but are not limited to, those risks, uncertainties and factors described in more detail under the caption "Risk Factors" in our Annual Report on Form 10-K for the year ended December 31, 2021, our Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2022 and in our other filings with the U.S. Securities and Exchange Commission (the "SEC"). We do not intend, and, except as required by law, we undertake no obligation, to update any of our forward-looking statements after the date of this report to reflect any future events or circumstances. Given these risks and uncertainties, readers are cautioned not to place undue reliance on such forward-looking statements.
1. Company Overview
We are one of the world's leading commercial foodservice equipment companies leveraging a full suite of equipment capable of storing, cooking, holding, displaying, dispensing and serving in both hot and cold foodservice categories. Headquartered in the Tampa Bay Region of Florida, Welbilt was incorporated in Delaware in 2015 and became publicly traded in March 2016 after a spin-off from its former parent. We operate 19 manufacturing facilities globally at which we design, manufacture and supply best-in-class equipment for the global commercial foodservice market, consisting of commercial and institutional foodservice operators represented by full-service restaurants, quick-service restaurant ("QSR") chains, hotels, resorts, cruise ships, caterers, supermarkets, convenience stores, hospitals, schools and other institutions. We sell our products through a global network of over 5,000 distributors, dealers, buying groups and manufacturers' representatives. Our portfolio of award-winning product brands includes Cleveland™, Convotherm®, Crem®, Delfield®, Frymaster®, Garland®, Kolpak®, Lincoln™, Manitowoc® Ice, Merco®, Merrychef® and Multiplex®. These product brands are supported by three service brands: FitKitchen®, our fully-integrated kitchen systems business, KitchenConnect®, our digital cloud-based application offering and KitchenCare®, our aftermarket parts and service business. We have approximately 4,700 employees and generated sales of $1.5 billion in 2021.
As a downstream supplier, many steps removed from the mining of 3TG Minerals, we do not purchase any 3TG Minerals directly from smelters or refiners and do not knowingly purchase any 3TG Minerals in their raw material form. We are committed to the responsible sourcing of our products and we expect the same from our suppliers, including ensuring that the products or components supplied to us do not directly or indirectly finance or benefit armed groups in the Covered Countries. Our suppliers are required to support our efforts to comply with Rule 13p-1. We have a Conflict Minerals Policy, which is available on our Investor Relations website (ir.welbilt.com) under Corporate Governance - Governance Documents. In addition, our standard supplier terms and conditions address our expectations related to any 3TG Minerals supplied to us.
2. Reasonable Country of Origin Inquiry
We undertook a reasonable country of origin inquiry ("RCOI") in good faith to determine whether the 3TG Minerals in the products we manufacture, or contract to manufacture, that are necessary to the functionality or production of our products may have originated in the Covered Countries or may have come from recycled or scrap sources.
To assist in determining whether 3TG Minerals in our products originated in Covered Countries, we retained Assent Compliance, Inc. ("Assent"), a third-party service provider. We provided a list of direct suppliers that provide us with products and components used in our manufacturing process that contain, or had a high probability of containing, one or more 3TG Minerals (the "in-scope suppliers") to Assent. We also periodically reviewed the supplier list to ensure that irrelevant or "out-of-scope" suppliers were removed from the survey process.
We utilized the RBA-GeSI Conflict Minerals Reporting Template ("CMRT") to conduct a survey of all in-scope suppliers. During the supplier survey, we contacted 513 suppliers via the Assent Compliance Manager (the "ACM"), a software platform maintained by Assent that enables its users to complete and track supplier communications as well as allows suppliers to upload completed CMRTs directly to the platform for assessment and management.
Assent requested that all suppliers complete a CMRT and provided training resources 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. We directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested such suppliers complete the CMRT form and submit such form to Assent. Assent's program also includes 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. Suppliers with invalid CMRTs were contacted and asked to resubmit after correcting the errors. As of May 17, 2022, there were 14 invalid supplier submissions that could not be corrected.
Based on the RCOI, we have reason to believe that some of the 3TG Minerals in our products may have originated from the Covered Countries or may have come from recycled or scrap sources, therefore, in accordance with Rule 13p-1, we performed further due diligence on the source and chain of custody of the 3TG Minerals in question.
3. Due Diligence Process
We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework set forth in The Organisation for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance"), and the related supplements for each of the 3TG Minerals.
The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD 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 OECD Guidance further 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.
We integrated the five steps recommended by the OECD Guidance as follows:
Step 1: Establish Strong Company Management Systems
Internal Team. We maintained an internal team, led by our procurement group, to manage our conflict minerals compliance program and related engagement with our suppliers. This includes integrating new suppliers, working with our employees to provide training and guidance, implementing reporting systems and facilitating cross-departmental communications to ensure compliance with the SEC’s reporting requirements regarding conflict minerals.
Controls and Policies. As stated above, we have a Conflict Minerals Policy, which is available on our Investor Relations website (ir.welbilt.com) under Corporate Governance - Governance Documents. In addition, our standard supplier terms and conditions address our expectations related to any 3TG Minerals supplied to us. Our controls also include our Code of Conduct and our Supplier Code of Conduct, which outline expected behaviors for our employees and suppliers.
Grievance Mechanisms. We maintain a hotline that provides employees with a mechanism to report violations or concerns related to our policies, including our Conflict Minerals Policy, Code of Conduct and our Supplier Code of Conduct. Such reporting may be made on an anonymous basis if employees wish.
Supplier Engagement. With respect to the OECD requirement to strengthen engagement with suppliers, we engaged Assent to assist with supplier engagement, evaluating supply chain information regarding 3TG Minerals and to assist with the development and implementation of additional due diligence steps. We also use Assent’s online learning management system and have provided all in-scope suppliers access to Assent's Conflict Minerals training course.
Step 2: Identify and Assess Risks in Our Supply Chain
In accordance with OECD Guidance, it is important to identify and assess risks associated with 3TG Minerals in the supply chain. Certain risks are identified automatically in the ACM system based on pre-established criteria. These risks are addressed by Assent's compliance staff and members of our internal conflict minerals compliance team who contacted the supplier to gather pertinent data and perform an assessment.
Many of the responses provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG Minerals in the components supplied to us. Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
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 Responsible Minerals Initiative ("RMI") to ensure that the facilities met the RMI definition of a 3TG Minerals processing facility that was operational during the 2021 calendar year.
In order to assess the risk that any of these smelters posed to our supply chain, Assent considered whether the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process ("RMAP"). Smelters that have completed an 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. We do not typically have a direct relationship with 3TG Minerals smelters and refiners and do not perform or direct audits of these entities within our supply chain.
Each facility that meets the RMI definition of a smelter or refiner of a 3TG Mineral is assessed according to red flag indicators defined in the OECD 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 Covered Countries;
•Known mineral source country of origin;
•Responsible Minerals Assurance Process audit status;
•Credible evidence of unethical or conflict sourcing;
•Peer assessments conducted by credible third-party sources.
Consistent with of our risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent, submissions that include any red flag facilities 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 us, and escalating up to removal of these red flag smelters from their supply chain.
As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable time frames with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to Assent's online learning platform 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 OECD 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:
1.Do you have a conflict minerals sourcing policy in place?
2.Have you implemented due diligence measures for conflict-free sourcing?
3.Do you review due diligence information received from your suppliers against your company’s expectations?
4.Does your review process include corrective action management?
Suppliers who respond affirmatively to each of the above questions are deemed to have a strong program in place. If they do not meet this criteria, they are identified as having a weak program, and follow-up emails are sent in order to provide them guidance on how to improve their program going forward.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
We completed a management reporting dashboard on a periodic basis summarizing the results of the risk assessment process. Other elements of our due diligence process designed to respond to identified risks included the following:
•Suppliers that did not respond to our initial survey request were sent escalation communications requesting that they provide the information requested.
•Suppliers who provided incomplete or inconsistent responses were sent follow-up communications asking for clarification. Based on the type of red flag identified during a review of supplier responses, suppliers were sent a corrective action communication.
Step 4: Utilize Third-Party Audits of Supply Chain Due Diligence
We do not have a direct relationship with 3TG Minerals smelters or refiners, and we do not perform or direct audits of these entities within our supply chain. We rely on third-party audits of smelters and refiners conducted as part of the RMAP, 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.
Step 5: Report Annually on Supply Chain Due Diligence
We report annually on our conflict minerals due diligence program by filing a Form SD and a Conflict Minerals Report with the SEC. Our
4. Due Diligence Results
For the 2021 reporting year, we received completed CMRTs from approximately 59% of the 503 in-scope suppliers surveyed.
Appendix A to this Report lists the legitimate smelters and refiners that our in-scope suppliers reported as being in used their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix A also includes an aggregated list of the potential countries of origin from which the reported facilities may collectively source 3TG Minerals, based on information provided by our suppliers and RMI.
The majority of the responses we received from our suppliers were made on a company or division level, rather than on a product-level basis. Accordingly, the smelters or refiners identified by our suppliers in Appendix A may include smelters or refiners that processed 3TG Minerals supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the smelters or refiners included in Appendix A were used to process the 3TG Minerals necessary to the functionality or production of Welbilt products during 2021. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed in Appendix A was a country of origin of 3TG Minerals used in our products during 2021 and therefore unable to conclusively determine the source and chain of custody of those 3TG Minerals.
In addition, the third-party audits conducted by the RMI, and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete 3TG Minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMAP and, as a result, are not responsible for the quality of these audits or the audit findings.
5. Risk Mitigation and Continuous Improvement Efforts
In addition to the commitments set forth in our Conflict Minerals Policy, we intend to take the following steps to improve our conflict minerals program and further mitigate the risk that our products contain 3TG Minerals from sources that support conflict in the Covered Countries:
•Engage with suppliers to provide better resources for responsible sourcing of 3TG Minerals and implementing improved due diligence procedures for their supply chains;
•Collaborate with Assent to improve supplier survey response rates and implement stronger supplier education practices;
•Improve training programs to educate Welbilt employees who may be in direct contact with suppliers or other third parties regarding the Company’s conflict minerals compliance efforts; and
•Attempt to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TG Minerals contained in our products.
Appendix A
| | | | | | | | |
| Metal | Facility Name | Smelter ID |
| Gold | Advanced Chemical Company | CID000015 |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | CID000058 |
| Gold | Argor-Heraeus S.A. | CID000077 |
| Gold | Asahi Pretec Corp. | CID000082 |
| Gold | Asaka Riken Co., Ltd. | CID000090 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 |
| Gold | Aurubis AG | CID000113 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 |
| Gold | Boliden AB | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | CID000176 |
| Gold | Caridad | CID000180 |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 |
| Gold | Cendres + Metaux S.A. | CID000189 |
| | | | | | | | |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 |
| Gold | Chimet S.p.A. | CID000233 |
| Gold | Chugai Mining | CID000264 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 |
| Gold | DSC (Do Sung Corporation) | CID000359 |
| Gold | Dowa | CID000401 |
| Gold | Eco-System Recycling Co., Ltd. East Plant | CID000425 |
| Gold | OJSC Novosibirsk Refinery | CID000493 |
| Gold | Refinery of Seemine Gold Co., Ltd. | CID000522 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 |
| Gold | LT Metal Ltd. | CID000689 |
| Gold | Heimerle + Meule GmbH | CID000694 |
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 |
| Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CID000773 |
| Gold | HwaSeong CJ CO., LTD. | CID000778 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 |
| Gold | Istanbul Gold Refinery | CID000814 |
| Gold | Japan Mint | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 |
| Gold | Asahi Refining USA Inc. | CID000920 |
| Gold | Asahi Refining Canada Ltd. | CID000924 |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 |
| Gold | JSC Uralelectromed | CID000929 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 |
| Gold | Kazakhmys Smelting LLC | CID000956 |
| Gold | Kazzinc | CID000957 |
| Gold | Kennecott Utah Copper LLC | CID000969 |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 |
| Gold | Kyrgyzaltyn JSC | CID001029 |
| Gold | L'azurde Company For Jewelry | CID001032 |
| Gold | Lingbao Gold Co., Ltd. | CID001056 |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 |
| Gold | LS-NIKKO Copper Inc. | CID001078 |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 |
| Gold | Materion | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 |
| Gold | Metalor Technologies S.A. | CID001153 |
| Gold | Metalor USA Refining Corporation | CID001157 |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | CID001161 |
| Gold | Mitsubishi Materials Corporation | CID001188 |
| | | | | | | | |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 |
| Gold | Moscow Special Alloys Processing Plant | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 |
| Gold | Nihon Material Co., Ltd. | CID001259 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 |
| Gold | PAMP S.A. | CID001352 |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 |
| Gold | PX Precinox S.A. | CID001498 |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 |
| Gold | Royal Canadian Mint | CID001534 |
| Gold | Sabin Metal Corp. | CID001546 |
| Gold | Samduck Precious Metals | CID001555 |
| Gold | Samwon Metals Corp. | CID001562 |
| Gold | SEMPSA Joyeria Plateria S.A. | CID001585 |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | CID001761 |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 |
| Gold | Super Dragon Technology Co., Ltd. | CID001810 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 |
| Gold | Torecom | CID001955 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 |
| Gold | United Precious Metal Refining, Inc. | CID001993 |
| Gold | Valcambi S.A. | CID002003 |
| Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 |
| Gold | Yamakin Co., Ltd. | CID002100 |
| Gold | Yokohama Metal Co., Ltd. | CID002129 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 |
| Gold | Morris and Watson | CID002282 |
| Gold | SAFINA A.S. | CID002290 |
| Gold | Guangdong Jinding Gold Limited | CID002312 |
| Gold | Umicore Precious Metals Thailand | CID002314 |
| Gold | Geib Refining Corporation | CID002459 |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 |
| Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 |
| | | | | | | | |
| Gold | Singway Technology Co., Ltd. | CID002516 |
| Gold | Shandong Humon Smelting Co., Ltd. | CID002525 |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CID002527 |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 |
| Gold | Emirates Gold DMCC | CID002561 |
| Gold | International Precious Metal Refiners | CID002562 |
| Gold | Kaloti Precious Metals | CID002563 |
| Gold | Sudan Gold Refinery | CID002567 |
| Gold | T.C.A S.p.A | CID002580 |
| Gold | REMONDIS PMR B.V. | CID002582 |
| Gold | Fujairah Gold FZC | CID002584 |
| Gold | Industrial Refining Company | CID002587 |
| Gold | Shirpur Gold Refinery Ltd. | CID002588 |
| Gold | Korea Zinc Co., Ltd. | CID002605 |
| Gold | Marsam Metals | CID002606 |
| Gold | TOO Tau-Ken-Altyn | CID002615 |
| Gold | Abington Reldan Metals, LLC | CID002708 |
| Gold | SAAMP | CID002761 |
| Gold | L'Orfebre S.A. | CID002762 |
| Gold | 8853 S.p.A. | CID002763 |
| Gold | Italpreziosi | CID002765 |
| Gold | WIELAND Edelmetalle GmbH | CID002778 |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 |
| Gold | AU Traders and Refiners | CID002850 |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | CID002852 |
| Gold | Sai Refinery | CID002853 |
| Gold | Modeltech Sdn Bhd | CID002857 |
| Gold | Bangalore Refinery | CID002863 |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 |
| Gold | Pease & Curren | CID002872 |
| Gold | JALAN & Company | CID002893 |
| Gold | SungEel HiMetal Co., Ltd. | CID002918 |
| Gold | Planta Recuperadora de Metales SpA | CID002919 |
| Gold | Safimet S.p.A | CID002973 |
| Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 |
| Gold | African Gold Refinery | CID003185 |
| Gold | Gold Coast Refinery | CID003186 |
| Gold | NH Recytech Company | CID003189 |
| Gold | QG Refining, LLC | CID003324 |
| Gold | Dijllah Gold Refinery FZC | CID003348 |
| Gold | CGR Metalloys Pvt Ltd. | CID003382 |
| Gold | Sovereign Metals | CID003383 |
| Gold | C.I Metales Procesados Industriales SAS | CID003421 |
| Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 |
| Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 |
| Gold | Augmont Enterprises Private Limited | CID003461 |
| | | | | | | | |
| Gold | Kundan Care Products Ltd. | CID003463 |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | CID003487 |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | CID003488 |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | CID003489 |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | CID003490 |
| Gold | K.A. Rasmussen | CID003497 |
| Gold | Alexy Metals | CID003500 |
| Gold | Sancus ZFS (L’Orfebre, SA) | CID003529 |
| Gold | Sellem Industries Ltd. | CID003540 |
| Gold | MD Overseas | CID003548 |
| Gold | Metallix Refining Inc. | CID003557 |
| Gold | Metal Concentrators SA (Pty) Ltd. | CID003575 |
| Gold | WEEEREFINING | CID003615 |
| Gold | Value Trading | CID003617 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 |
| Tantalum | LSM Brasil S.A. | CID001076 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 |
| Tantalum | Mineracao Taboca S.A. | CID001175 |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 |
| Tantalum | NPM Silmet AS | CID001200 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 |
| Tantalum | QuantumClean | CID001508 |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 |
| Tantalum | Taki Chemical Co., Ltd. | CID001869 |
| Tantalum | Telex Metals | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 |
| Tantalum | D Block Metals, LLC | CID002504 |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 |
| Tantalum | KEMET Blue Metals | CID002539 |
| Tantalum | H.C. Starck Co., Ltd. | CID002544 |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | CID002545 |
| Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 |
| Tantalum | H.C. Starck Inc. | CID002548 |
| Tantalum | H.C. Starck Ltd. | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | CID002550 |
| Tantalum | Global Advanced Metals Boyertown | CID002557 |
| Tantalum | Global Advanced Metals Aizu | CID002558 |
| Tantalum | Resind Industria e Comercio Ltda. | CID002707 |
| | | | | | | | |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 |
| Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | CID003583 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 |
| Tin | Alpha | CID000292 |
| Tin | PT Aries Kencana Sejahtera | CID000309 |
| Tin | Dowa | CID000402 |
| Tin | EM Vinto | CID000438 |
| Tin | Estanho de Rondonia S.A. | CID000448 |
| Tin | Fenix Metals | CID000468 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 |
| Tin | China Tin Group Co., Ltd. | CID001070 |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 |
| Tin | Metallic Resources, Inc. | CID001142 |
| Tin | Mineracao Taboca S.A. | CID001173 |
| Tin | Minsur | CID001182 |
| Tin | Mitsubishi Materials Corporation | CID001191 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 |
| Tin | Novosibirsk Processing Plant Ltd. | CID001305 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 |
| Tin | Operaciones Metalurgicas S.A. | CID001337 |
| Tin | PT Artha Cipta Langgeng | CID001399 |
| Tin | PT Babel Inti Perkasa | CID001402 |
| Tin | PT Babel Surya Alam Lestari | CID001406 |
| Tin | PT Belitung Industri Sejahtera | CID001421 |
| Tin | PT Bukit Timah | CID001428 |
| Tin | PT Mitra Stania Prima | CID001453 |
| Tin | PT Panca Mega Persada | CID001457 |
| Tin | PT Prima Timah Utama | CID001458 |
| Tin | PT Refined Bangka Tin | CID001460 |
| Tin | PT Sariwiguna Binasentosa | CID001463 |
| Tin | PT Stanindo Inti Perkasa | CID001468 |
| Tin | PT Timah Tbk Kundur | CID001477 |
| Tin | PT Timah Tbk Mentok | CID001482 |
| Tin | PT Timah Nusantara | CID001486 |
| Tin | PT Tinindo Inter Nusa | CID001490 |
| Tin | PT Tommy Utama | CID001493 |
| Tin | Rui Da Hung | CID001539 |
| Tin | Soft Metais Ltda. | CID001758 |
| Tin | Thaisarco | CID001898 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 |
| Tin | VQB Mineral and Trading Group JSC | CID002015 |
| Tin | White Solder Metalurgia e Mineracao Ltda. | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 |
| Tin | Yunnan Tin Company Limited | CID002180 |
| Tin | CV Venus Inti Perkasa | CID002455 |
| | | | | | | | |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 |
| Tin | PT Tirus Putra Mandiri | CID002478 |
| Tin | Melt Metais e Ligas S.A. | CID002500 |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 |
| Tin | PT Cipta Persada Mulia | CID002696 |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 |
| Tin | Resind Industria e Comercio Ltda. | CID002706 |
| Tin | Super Ligas | CID002756 |
| Tin | Metallo Belgium N.V. | CID002773 |
| Tin | Metallo Spain S.L.U. | CID002774 |
| Tin | PT Sukses Inti Makmur | CID002816 |
| Tin | PT Menara Cipta Mulia | CID002835 |
| Tin | Modeltech Sdn Bhd | CID002858 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 |
| Tin | PT Bangka Serumpun | CID003205 |
| Tin | Pongpipat Company Limited | CID003208 |
| Tin | Tin Technology & Refining | CID003325 |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CID003379 |
| Tin | PT Rajawali Rimba Perkasa | CID003381 |
| Tin | Luna Smelter, Ltd. | CID003387 |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 |
| Tin | Precious Minerals and Smelting Limited | CID003409 |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CID003410 |
| Tin | PT Mitra Sukses Globalindo | CID003449 |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | CID003486 |
| Tin | CRM Synergies | CID003524 |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | CID003582 |
| Tungsten | A.L.M.T. Corp. | CID000004 |
| Tungsten | Kennametal Huntsville | CID000105 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CID000281 |
| Tungsten | Global Tungsten & Powders Corp. | CID000568 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 |
| Tungsten | Kennametal Fallon | CID000966 |
| Tungsten | Wolfram Bergbau und Hutten AG | CID002044 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 |
| | | | | | | | |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 |
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | CID002542 |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | CID002543 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 |
| Tungsten | Niagara Refining LLC | CID002589 |
| Tungsten | China Molybdenum Co., Ltd. | CID002641 |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CID002645 |
| Tungsten | Hydrometallurg, JSC | CID002649 |
| Tungsten | Unecha Refractory metals plant | CID002724 |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 |
| Tungsten | ACL Metais Eireli | CID002833 |
| Tungsten | Moliren Ltd. | CID002845 |
| Tungsten | KGETS Co., Ltd. | CID003388 |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CID003401 |
| Tungsten | Lianyou Metals Co., Ltd. | CID003407 |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | CID003408 |
| Tungsten | NPP Tyazhmetprom LLC | CID003416 |
| Tungsten | GEM Co., Ltd. | CID003417 |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | CID003427 |
| Tungsten | Cronimet Brasil Ltda | CID003468 |
| Tungsten | Artek LLC | CID003553 |
| Tungsten | Fujian Xinlu Tungsten | CID003609 |
| Tungsten | OOO “Technolom” 2 | CID003612 |
| Tungsten | OOO “Technolom” 1 | CID003614 |
| Tungsten | LLC Volstok | CID003643 |
Potential Countries of Origin: Afghanistan, Aland Islands, Albania, American Samoa, Andorra, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo, Democratic Republic of Congo, Djibouti, Dominica, Dominican Republic, Ecuador, Egypt, Eritrea, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Kazakhstan, Kenya, Korea, Kyrgyzstan, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, South Sudan, Spain, Sudan, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia, and Zimbabwe. 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 listing is based on public information and company level responses as further described in the Report, and therefore, it is not certain which of these countries of origin can be linked to our products.