Exhibit 1.01
Conflict Minerals Report
Enovis Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for the period from January 1, 2023 to December 31, 2023 as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). Unless the context indicates otherwise, the terms “Enovis,” “we,” “its,” “us,” and “our” refer to Enovis Corporation and its consolidated subsidiaries. As used herein, “Conflict Minerals” or “3TG” is defined as, consistent with the Conflict Minerals Rule, cassiterite, columbite-tantalite (coltan), gold, wolframite and the derivatives tin, tantalum and tungsten.
Forward-Looking Statements
This document contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG benefit armed groups.
Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG, and (3) political, regulatory and economic developments, whether in the Democratic Republic of the Congo (“DRC”) region (the “Covered Countries”), the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this document or to reflect the occurrence of unanticipated events.
Company and Product Information
Enovis Corporation is an innovation-driven medical technology growth company dedicated to developing clinically differentiated solutions that generate measurably better patient outcomes and transform workflows. Powered by a culture of continuous improvement, global talent and innovation, our extensive range of products, services and integrated technologies fuels active lifestyles in orthopedics and beyond.
Our continuing in-scope product categories for 2023 were orthopedic devices. For a further discussion of our products, see our Annual Report on Form 10-K for the year ended December 31, 2023. The information contained in our Form 10-K and other external materials referenced herein, including our website, is not incorporated by reference into this Conflict Minerals Report or our Form SD and should not be considered part of this Conflict Minerals Report or the Form SD.
Applicability of the Conflict Minerals Rule to Our Company
We are subject to the Conflict Minerals Rule because some of the products that we manufacture contain 3TG that are necessary to their functionality or production. Our in-scope products contain tin, tantalum, tungsten and gold, although no in-scope product contains all four 3TG.
We generally do not source 3TG from smelters or refiners and have no direct relationships with mines, and we believe that we are in most cases many levels removed from all of these market participants. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy, which is described below, and encourage conflict free sourcing in our supply chain.
1
Product, smelter and refiner information in respect of 2023 is described under “Product Information” below and on Annex A. For 2023, we were unable to determine the origin of 3TG contained in each of our in-scope products. None of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. However, we did not conclude that any of our products were “DRC conflict free.” The terms “adjoining country,” “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.
Our Conflict Minerals Policy
We are committed to being a responsible corporate citizen and are opposed to human rights abuses such as are occurring in the DRC. To this end, we have adopted and communicated to our suppliers and the public a company policy (the “Conflict Minerals Policy”) for the supply chain of 3TG.
The Conflict Minerals Policy includes, but is not limited to, our expectations that:
| 1. | The components, parts and products supplied to us are DRC conflict free within the meaning of the Conflict Minerals Rule; |
| 2. | Our suppliers define, implement and communicate to sub-suppliers their own 3TG policy consistent with our Conflict Minerals Policy and the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”); and |
| 3. | Our suppliers require that their direct and indirect sub-suppliers implement policies, procedures and frameworks that are consistent with the OECD Guidance, and that our suppliers otherwise work with sub-suppliers to ensure traceability of 3TG. |
We do not embargo responsibly sourced 3TG from the Covered Countries or other conflict-affected and high-risk areas and encourage our suppliers to continue to source responsibly from the Covered Countries or other conflict-affected and high-risk areas, from sources that do not support conflict.
Our policy is available on our website at https://ir.enovis.com/static-files/5f7e2a02-e1de-4317-aa11-f1a284e476c0.
Reasonable Country of Origin Inquiry Information
As required by the Conflict Minerals Rule, for 2023, we conducted a “reasonable country of origin inquiry” (“RCOI”). For our RCOI, to the extent applicable, we utilized the same processes and procedures as for our due diligence, in particular Steps 1 and 2 of the OECD Guidance, which are discussed below.
Our inquiry included approximately 209 suppliers (the “Suppliers”) that we identified as having provided us with components, parts or products that contain 3TG or that we believe may have provided us with components, parts or products that contain 3TG. For 2023, the Suppliers identified to us 350 smelters and refiners that processed or may have processed the necessary 3TG contained in our in-scope products, as shown and described under Annex A below. These smelters and refiners include 225 smelters and refiners identified as “Conformant” and 6 identified as “Active,” each as defined in Annex A. This information is based primarily on company-level declarations from Suppliers. Accordingly, many of these smelters and refiners may not be part of our supply chain, as we generally were not able to collect data at the product-level.
Based on the results of our RCOI, we exercised due diligence for 2023. These due diligence efforts are discussed below.
Due Diligence Program
Design Framework
We designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the OECD Guidance, Third Edition, including the related Supplements for tin, tantalum and tungsten and for gold (hereinafter referred to as the “OECD Guidance”).
2
Selected Elements of our Due Diligence Program
The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our due diligence program are discussed below. However, these are not all of the elements of the program that we have put in place to help ensure that the 3TG contained in our in-scope products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the five steps.
| 1. | OECD Guidance Step One: “Establish strong company management systems” |
| a. | We have a Conflict Minerals Policy. We communicate the policy internally to our sourcing teams and to selected suppliers. The Conflict Minerals Policy also is posted on our website at https://ir.enovis.com/static-files/5f7e2a02-e1de-4317-aa11-f1a284e476c0. |
| b. | We have a team of senior staff under the Senior Vice President, Supply Chain and Senior Vice President and Chief Legal Officer charged with managing our 3TG compliance strategy. We supplement our compliance efforts with specialist outside counsel. |
| c. | Selected internal personnel are educated on the Conflict Minerals Rule, the OECD Guidance, our compliance plan and the procedures for reviewing and validating supplier responses to our inquiries. |
| d. | We utilize the Conflict Minerals Reporting Template (the “CMRT”) developed by the Responsible Minerals Initiative (the “RMI”) to identify smelters and refiners in our supply chain. The CMRT requests suppliers to provide information concerning the usage and source of 3TG in their products, as well as information concerning their related compliance efforts. We utilize a third-party service provider (the “Service Provider”) to conduct our supplier outreach and follow-up, as well as for the review and validation of supplier responses. |
| e. | We maintain business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, for at least five years. |
| f. | The Service Provider provides training and educational materials to suppliers to enhance the quality of responses. |
| g. | We have contractual terms relating to 3TG, which are incorporated into selected supplier contracts. |
| h. | We have a mechanism for employees, suppliers and other interested parties to report violations of our Conflict Minerals Policy. The contact information for our grievance mechanism is www.enovis.ethicspoint.com. |
| 2. | OECD Guidance Step Two: “Identify and assess risk in the supply chain” |
| a. | We requested in writing, through the Service Provider, that the Suppliers provide us with a completed CMRT. The Service Provider followed up by email or phone on our behalf with Suppliers that did not respond to the request within the specified time frame. The Service Provider followed up with non-responsive Suppliers. |
| b. | The Service Provider, on our behalf, reviewed Supplier responses against its written review criteria to identify incomplete responses, potential errors and inaccuracies in the CMRTs. The Service Provider followed up by email with Suppliers that submitted a response that triggered specific quality issues relating to completeness and accuracy. |
3
| c. | Smelter and refiner information provided by Suppliers was reviewed by the Service Provider against the RMI’s list of known smelters and refiners. To the extent that a smelter or refiner identified by a Supplier is not on that list, the Service Provider may take additional steps to attempt to determine whether the listed entity is a smelter or refiner. Smelter and refiner information also was reviewed against the lists of Conformant and Active smelters and refiners published by the RMI. 225 of the identified smelters and refiners were listed as Conformant by the RMI and 6 were listed as Active, as of April 30, 2023. Please see Annex A below for further information regarding the smelters and refiners identified to us through our RCOI and due diligence. |
The Service Provider bases its country of origin determinations on publicly available information, its outreach to smelters and refiners and information provided by suppliers in their completed CMRTs. Consistent with the foregoing, to the extent that a smelter or refiner identified by a Supplier was not listed as Conformant by the RMI, the Service Provider undertook an additional review to attempt to determine whether that smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the Covered Countries.
The Service Provider attempted to reach out to the smelter or refiner directly and conducted research to gain more information about the smelter’s or refiner’s sourcing practices, including the countries of origin of the minerals that it processes, the transit and transfer of the minerals that it processes and whether it has in place internal due diligence procedures or other processes to track the chain-of-custody of its 3TG.
| d. | The Service Provider evaluated Suppliers’ due diligence processes and policies based on the Suppliers’ responses to certain of the questions in the CMRT. These questions ask suppliers about their internal processes regarding 3TG. |
| e. | We take steps to gather additional information from suppliers whose responses lead us to believe additional information is warranted to help ensure that our supply chain is responsibly sourcing 3TG. This may include requesting product-specific CMRTs or other information. |
| 3. | OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks” |
| a. | Our 3TG compliance team reviewed the reports and evaluations prepared by the Service Provider and liaised with appropriate members of senior management in our legal and supply chain teams, including our Senior Vice President, Supply Chain and Senior Vice President and Chief Legal Officer, regarding the results of our Supplier outreach. |
| b. | We undertake additional internal reviews with our legal and supply chain teams on a periodic basis using the information provided by the Service Provider, our suppliers and our independent inquiries, and respond via supplier follow-up, commercial escalation or other commensurate means to the risks identified via these reviews. |
| 4. | OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain” |
In connection with our due diligence, we utilize and rely on information made available by the RMI concerning independent third-party audits of smelters and refiners to assess smelter and refiner due diligence.
| 5. | OECD Guidance Step Five: “Report on supply chain due diligence” |
We file a Form SD and Conflict Minerals Report with the Securities and Exchange Commission and make these filings available on our website at http://ir.enovis.com/sec-filings.
4
Identified Smelters and Refiners
In connection with our RCOI or due diligence, as applicable, the Suppliers identified to us the smelters and refiners listed on Annex A below either as part of our supply chain or as potentially having processed the necessary 3TG contained in our in-scope products in 2023. Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our suppliers for accurate smelter and refiner information and our due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products.
We endeavored to determine the mine or location of origin of the 3TG contained in our in-scope products by requesting that the Suppliers provide us or our Service Provider with a completed CMRT, and through the other activities described herein that were taken by us or the Service Provider.
Future Risk Mitigation Efforts
We intend to take the following additional steps to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups in the Covered Countries. These steps are in addition to the steps that we took in respect of 2023 described in this Conflict Minerals Report, which we intend to continue to take in respect of 2024 to the extent applicable.
| 1. | Engage with applicable Suppliers that provided non-Conformant smelters and refiners, incomplete responses or that did not provide responses for 2023 to help ensure that they provide requested information for 2024. |
| • | Engage in additional outreach to Suppliers with non-Conformant responses; |
| • | Conduct further training for Suppliers; and |
| • | Work to identify improved contacts for non-respondents. |
| 2. | Encourage the continuing development and progress of traceability measures at Suppliers that indicated for 2023 that the source of 3TG was unknown or undeterminable. |
| 3. | Continue communicating to suppliers our sourcing expectations, including through the dissemination of the Conflict Minerals Policy to them and required adherence to contractual sourcing requirements. |
5
Annex A
Capitalized terms used and not otherwise defined in this Annex have the meanings set forth in the Conflict Minerals Report of which this Annex is a part.
Smelters and Refiners
In connection with our RCOI or due diligence, as applicable, the Suppliers identified to us the smelters and refiners listed below as either being part of our supply chain or as potentially having processed the necessary 3TG contained in our in-scope products in 2023. Please see the accompanying notes for additional information concerning the tables.
Smelter and Refiner Names and Status
Metal | Standard Smelter Name | Smelter Facility Location | ||
| Gold | 8853 S.p.A. | Italy | ||
| Gold | ABC Refinery Pty Ltd. | Australia | ||
| Gold | Abington Reldan Metals, LLC | United States Of America | ||
| Gold | Advanced Chemical Company | United States Of America | ||
| Gold | African Gold Refinery | Uganda | ||
| Gold | Agosi AG | Germany | ||
| Gold | Aida Chemical Industries Co., Ltd. | Japan | ||
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | ||
| Gold | Albino Mountinho Lda. | Portugal | ||
| Gold | Alexy Metals | United States Of America | ||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | ||
| Gold | Argor-Heraeus S.A. | Switzerland | ||
| Gold | Asahi Pretec Corp. | Japan | ||
| Gold | Asahi Refining Canada Ltd. | Canada | ||
| Gold | Asahi Refining USA Inc. | United States Of America | ||
| Gold | Asaka Riken Co., Ltd. | Japan | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | ||
| Gold | AU Traders and Refiners | South Africa | ||
| Gold | Augmont Enterprises Private Limited | India | ||
| Gold | Aurubis AG | Germany | ||
| Gold | Bangalore Refinery | India |
A-1
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||
| Gold | Boliden AB | Sweden | ||
| Gold | C. Hafner GmbH + Co. KG | Germany | ||
| Gold | Caridad | Mexico | ||
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | ||
| Gold | Cendres + Metaux S.A. | Switzerland | ||
| Gold | CGR Metalloys Pvt Ltd. | India | ||
| Gold | Chimet S.p.A. | Italy | ||
| Gold | Chugai Mining | Japan | ||
| Gold | Coimpa Industrial LTDA | Brazil | ||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | ||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | ||
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | ||
| Gold | Dongwu Gold Group | China | ||
| Gold | Dowa | Japan | ||
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of | ||
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | ||
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | ||
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | ||
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India | ||
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India | ||
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India | ||
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India | ||
| Gold | Emirates Gold DMCC | United Arab Emirates | ||
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | ||
| Gold | Fujairah Gold FZC | United Arab Emirates | ||
| Gold | GG Refinery Ltd. | Tanzania, United Republic Of | ||
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India | ||
| Gold | Gold by Gold Colombia | Colombia | ||
| Gold | Gold Coast Refinery | Ghana | ||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | ||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | ||
| Gold | Guangdong Jinding Gold Limited | China | ||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
A-2
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | ||
| Gold | Heimerle + Meule GmbH | Germany | ||
| Gold | Heraeus Germany GmbH Co. KG | Germany | ||
| Gold | Heraeus Metals Hong Kong Ltd. | China | ||
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | ||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | ||
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | ||
| Gold | Industrial Refining Company | Belgium | ||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | ||
| Gold | International Precious Metal Refiners | United Arab Emirates | ||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | ||
| Gold | Istanbul Gold Refinery | Turkey | ||
| Gold | Italpreziosi | Italy | ||
| Gold | JALAN & Company | India | ||
| Gold | Japan Mint | Japan | ||
| Gold | Jiangxi Copper Co., Ltd. | China | ||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | ||
| Gold | JSC Novosibirsk Refinery | Russian Federation | ||
| Gold | JSC Uralelectromed | Russian Federation | ||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | ||
| Gold | K.A. Rasmussen | Norway | ||
| Gold | Kaloti Precious Metals | United Arab Emirates | ||
| Gold | Kazakhmys Smelting LLC | Kazakhstan | ||
| Gold | Kazzinc | Kazakhstan | ||
| Gold | Kennecott Utah Copper LLC | United States Of America | ||
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | ||
| Gold | Kojima Chemicals Co., Ltd. | Japan | ||
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | ||
| Gold | Kundan Care Products Ltd. | India | ||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | ||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | ||
| Gold | L’azurde Company For Jewelry | Saudi Arabia | ||
| Gold | Lingbao Gold Co., Ltd. | China | ||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
A-3
| Gold | L’Orfebre S.A. | Andorra | ||
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | ||
| Gold | LT Metal Ltd. | Korea, Republic Of | ||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | ||
| Gold | Marsam Metals | Brazil | ||
| Gold | Materion | United States Of America | ||
| Gold | Matsuda Sangyo Co., Ltd. | Japan | ||
| Gold | MD Overseas | India | ||
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | ||
| Gold | Metallix Refining Inc. | United States Of America | ||
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | ||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | ||
| Gold | Metalor Technologies (Suzhou) Ltd. | China | ||
| Gold | Metalor Technologies S.A. | Switzerland | ||
| Gold | Metalor USA Refining Corporation | United States Of America | ||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | ||
| Gold | Mitsubishi Materials Corporation | Japan | ||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Gold | MKS PAMP SA | Switzerland | ||
| Gold | MMTC-PAMP India Pvt., Ltd. | India | ||
| Gold | Modeltech Sdn Bhd | Malaysia | ||
| Gold | Morris and Watson | New Zealand | ||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | ||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | ||
| Gold | NH Recytech Company | Korea, Republic Of | ||
| Gold | Nihon Material Co., Ltd. | Japan | ||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | ||
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | ||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | Russian Federation | ||
| Gold | Pease & Curren | United States Of America | ||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | ||
| Gold | Planta Recuperadora de Metales SpA | Chile | ||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
A-4
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | ||
| Gold | PX Precinox S.A. | Switzerland | ||
| Gold | QG Refining, LLC | United States Of America | ||
| Gold | Rand Refinery (Pty) Ltd. | South Africa | ||
| Gold | Refinery of Seemine Gold Co., Ltd. | China | ||
| Gold | REMONDIS PMR B.V. | Netherlands | ||
| Gold | Royal Canadian Mint | Canada | ||
| Gold | SAAMP | France | ||
| Gold | Sabin Metal Corp. | United States Of America | ||
| Gold | Safimet S.p.A | Italy | ||
| Gold | SAFINA A.S. | Czechia | ||
| Gold | Sai Refinery | India | ||
| Gold | Sam Precious Metals | United Arab Emirates | ||
| Gold | Samduck Precious Metals | Korea, Republic Of | ||
| Gold | Samwon Metals Corp. | Korea, Republic Of | ||
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | ||
| Gold | Shandong Gold Smelting Co., Ltd. | China | ||
| Gold | Shandong Humon Smelting Co., Ltd. | China | ||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | ||
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China | ||
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | ||
| Gold | Shirpur Gold Refinery Ltd. | India | ||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | ||
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | ||
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | ||
| Gold | Sovereign Metals | India | ||
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | ||
| Gold | Sudan Gold Refinery | Sudan | ||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | ||
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of |
A-5
| Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province Of China | ||
| Gold | T.C.A S.p.A | Italy | ||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | ||
| Gold | Tokuriki Honten Co., Ltd. | Japan | ||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | ||
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | ||
| Gold | Torecom | Korea, Republic Of | ||
| Gold | Umicore Precious Metals Thailand | Thailand | ||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | ||
| Gold | United Precious Metal Refining, Inc. | United States Of America | ||
| Gold | Valcambi S.A. | Switzerland | ||
| Gold | WEEEREFINING | France | ||
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | ||
| Gold | WIELAND Edelmetalle GmbH | Germany | ||
| Gold | Yamakin Co., Ltd. | Japan | ||
| Gold | Yokohama Metal Co., Ltd. | Japan | ||
| Gold | Yunnan Copper Industry Co., Ltd. | China | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
A-6
| Tantalum | 5D Production OU | Estonia | ||
| Tantalum | AMG Brasil | Brazil | ||
| Tantalum | D Block Metals, LLC | United States Of America | ||
| Tantalum | F&X Electro-Materials Ltd. | China | ||
| Tantalum | FIR Metals & Resource Ltd. | China | ||
| Tantalum | Global Advanced Metals Aizu | Japan | ||
| Tantalum | Global Advanced Metals Boyertown | United States Of America | ||
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | ||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | ||
| Tantalum | Jiangxi Tuohong New Raw Material | China | ||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | ||
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | ||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | ||
| Tantalum | KEMET de Mexico | Mexico | ||
| Tantalum | Materion Newton Inc. | United States Of America | ||
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | ||
| Tantalum | Mineracao Taboca S.A. | Brazil | ||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | ||
| Tantalum | NPM Silmet AS | Estonia | ||
| Tantalum | PowerX Ltd. | Rwanda | ||
| Tantalum | QuantumClean | United States Of America | ||
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | ||
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | ||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | ||
| Tantalum | Taki Chemical Co., Ltd. | Japan | ||
| Tantalum | TANIOBIS Co., Ltd. | Thailand | ||
| Tantalum | TANIOBIS GmbH | Germany | ||
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | ||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | ||
| Tantalum | Telex Metals | United States Of America | ||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | ||
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | ||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
A-7
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | ||
| Tin | Alpha | United States Of America | ||
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | ||
| Tin | Aurubis Beerse | Belgium | ||
| Tin | Aurubis Berango | Spain | ||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | ||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | ||
| Tin | China Tin Group Co., Ltd. | China | ||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | ||
| Tin | CRM Synergies | Spain | ||
| Tin | CV Ayi Jaya | Indonesia | ||
| Tin | CV Venus Inti Perkasa | Indonesia | ||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | ||
| Tin | Dowa | Japan | ||
| Tin | DS Myanmar | Myanmar | ||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | ||
| Tin | EM Vinto | Bolivia (Plurinational State Of) | ||
| Tin | Estanho de Rondonia S.A. | Brazil | ||
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | ||
| Tin | Fenix Metals | Poland | ||
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | ||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | ||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | ||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | ||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | ||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | ||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | ||
| Tin | Jiangxi New Nanshan Technology Ltd. | China | ||
| Tin | Luna Smelter, Ltd. | Rwanda | ||
| Tin | Ma’anshan Weitai Tin Co., Ltd. | China | ||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | Brazil | ||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | ||
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia |
A-8
| Tin | Melt Metais e Ligas S.A. | Brazil | ||
| Tin | Metallic Resources, Inc. | United States Of America | ||
| Tin | Mineracao Taboca S.A. | Brazil | ||
| Tin | Mining Minerals Resources SARL | Congo, Democratic Republic Of The | ||
| Tin | Minsur | Peru | ||
| Tin | Mitsubishi Materials Corporation | Japan | ||
| Tin | Modeltech Sdn Bhd | Malaysia | ||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | ||
| Tin | Novosibirsk Tin Combine | Russian Federation | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | ||
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | ||
| Tin | Pongpipat Company Limited | Myanmar | ||
| Tin | Precious Minerals and Smelting Limited | India | ||
| Tin | PT Aries Kencana Sejahtera | Indonesia | ||
| Tin | PT Artha Cipta Langgeng | Indonesia | ||
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | ||
| Tin | PT Babel Inti Perkasa | Indonesia | ||
| Tin | PT Babel Surya Alam Lestari | Indonesia | ||
| Tin | PT Bangka Prima Tin | Indonesia | ||
| Tin | PT Bangka Serumpun | Indonesia | ||
| Tin | PT Bangka Tin Industry | Indonesia | ||
| Tin | PT Belitung Industri Sejahtera | Indonesia | ||
| Tin | PT Bukit Timah | Indonesia | ||
| Tin | PT Cipta Persada Mulia | Indonesia | ||
| Tin | PT Menara Cipta Mulia | Indonesia | ||
| Tin | PT Mitra Stania Prima | Indonesia | ||
| Tin | PT Mitra Sukses Globalindo | Indonesia | ||
| Tin | PT Panca Mega Persada | Indonesia | ||
| Tin | PT Premium Tin Indonesia | Indonesia | ||
| Tin | PT Prima Timah Utama | Indonesia | ||
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | ||
| Tin | PT Rajawali Rimba Perkasa | Indonesia | ||
| Tin | PT Rajehan Ariq | Indonesia |
A-9
| Tin | PT Refined Bangka Tin | Indonesia | ||
| Tin | PT Sariwiguna Binasentosa | Indonesia | ||
| Tin | PT Stanindo Inti Perkasa | Indonesia | ||
| Tin | PT Sukses Inti Makmur | Indonesia | ||
| Tin | PT Timah Nusantara | Indonesia | ||
| Tin | PT Timah Tbk Kundur | Indonesia | ||
| Tin | PT Timah Tbk Mentok | Indonesia | ||
| Tin | PT Tinindo Inter Nusa | Indonesia | ||
| Tin | PT Tirus Putra Mandiri | Indonesia | ||
| Tin | PT Tommy Utama | Indonesia | ||
| Tin | Resind Industria e Comercio Ltda. | Brazil | ||
| Tin | Rui Da Hung | Taiwan, Province Of China | ||
| Tin | Super Ligas | Brazil | ||
| Tin | Thaisarco | Thailand | ||
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | ||
| Tin | Tin Technology & Refining | United States Of America | ||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | ||
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | ||
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | ||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | ||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | ||
| Tungsten | A.L.M.T. Corp. | Japan | ||
| Tungsten | ACL Metais Eireli | Brazil | ||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | ||
| Tungsten | Artek LLC | Russian Federation | ||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | ||
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China | ||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | ||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | ||
| Tungsten | Cronimet Brasil Ltda | Brazil | ||
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of | ||
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | ||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
A-10
| Tungsten | Global Tungsten & Powders LLC | United States Of America | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | ||
| Tungsten | H.C. Starck Tungsten GmbH | Germany | ||
| Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic Of | ||
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | ||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | ||
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | ||
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | ||
| Tungsten | Hydrometallurg, JSC | Russian Federation | ||
| Tungsten | Japan New Metals Co., Ltd. | Japan | ||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | China | ||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | ||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | ||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | ||
| Tungsten | JSC “Kirovgrad Hard Alloys Plant” | Russian Federation | ||
| Tungsten | Kenee Mining Corporation Vietnam | Viet Nam | ||
| Tungsten | Kennametal Fallon | United States Of America | ||
| Tungsten | Kennametal Huntsville | United States Of America | ||
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | ||
| Tungsten | Lianyou Resources Co., Ltd. | Taiwan, Province Of China | ||
| Tungsten | LLC Vostok | Russian Federation | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | ||
| Tungsten | Masan High-Tech Materials | Viet Nam | ||
| Tungsten | Moliren Ltd. | Russian Federation | ||
| Tungsten | Nam Viet Cromit Joint Stock Company | Viet Nam | ||
| Tungsten | Niagara Refining LLC | United States Of America | ||
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | ||
| Tungsten | OOO “Technolom” 1 | Russian Federation | ||
| Tungsten | OOO “Technolom” 2 | Russian Federation | ||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
A-11
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | China | ||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | ||
| Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam | ||
| Tungsten | Unecha Refractory metals plant | Russian Federation | ||
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | ||
| Tungsten | Xiamen Tungsten Co., Ltd. | China | ||
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China |
We note the following in connection with the information contained in the foregoing tables:
| (a) | The smelters and refiners reflected in the table were identified by the Suppliers to us as potentially being part of our 2023 supply chain. However, not all of the included smelters and refiners are believed by us to have processed the necessary 3TG contained in our in-scope products, since most Suppliers reported to us at a “company level” the 3TG contained in all of their products, not just those in the products that they sold to us. Some Suppliers also may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. The smelters and refiners reflected above may not be all of the smelters and refiners in our supply chain, since many Suppliers were unable to identify all of the smelters and refiners used to process the necessary 3TG content contained in our in-scope products and not all of the Suppliers responded to our inquiries. |
| (b) | All compliance status information in the tables is as of April 30, 2024. Compliance status is based on information published by the RMI, without independent verification by us. |
| (c) | The table includes only entities that are listed as verified smelters on the Smelter Look-up list tab of the CMRT. |
| (d) | Smelter and refiner country location and status is based on information published by the RMI, without independent verification by us. |
Country of Origin Information
The identified countries of origin of the 3TG processed by the smelters and refiners listed in the table above may have included the countries below, based on publicly available information, our RCOI and due diligence and other information gathered by the Service Provider. These may not be all of the countries of origin from which the smelters and refiners listed above may have sourced 3TG.
| Albania | Dominican Republic | Kenya | Russian Federation | |||
| Andorra | Ecuador | Korea | Rwanda* | |||
| Angola* | Egypt | Kyrgyzstan | Saudi Arabia | |||
| Argentina | El Salvador | Liberia | Senegal | |||
| Armenia | Eritrea | Liechtenstein | Serbia | |||
| Australia | Estonia | Lithuania | Sierra Leone | |||
| Austria | Ethiopia | Luxembourg | Singapore |
A-12
| Azerbaijan | Fiji | Madagascar | Slovakia | |||
| Belarus | Finland | Malaysia | Solomon Islands | |||
| Belgium | France | Mali | South Africa | |||
| Benin | Georgia | Mauritania | South Sudan* | |||
| Bermuda | Germany | Mexico | Spain | |||
| Bolivia (Plurinational State of) | Ghana | Mongolia | Sudan | |||
| Botswana | Guam | Morocco | Suriname | |||
| Brazil | Guatemala | Mozambique | Sweden | |||
| Bulgaria | Guinea | Myanmar | Switzerland | |||
| Burkina Faso | Guyana | Namibia | Taiwan | |||
| Burundi* | Honduras | Netherlands | Tajikistan | |||
| Cambodia | Hong Kong | New Zealand | Tanzania* | |||
| Canada | Hungary | Nicaragua | Thailand | |||
| Central African Republic* | India | Niger | Togo | |||
| Chile | Indonesia | Nigeria | Turkey | |||
| China | Ireland | Norway | Uganda* | |||
| Colombia | Israel | Oman | United Arab Emirates | |||
| Republic of the Congo* | Italy | Panama | United Kingdom | |||
| Cyprus | Ivory Coast | Papua New Guinea | United States | |||
| Democratic Republic of the Congo* | Japan | Peru | Uruguay | |||
| Djibouti | Jersey | Philippines | Uzbekistan | |||
| Dominica | Kazakhstan | Poland | Viet Nam | |||
| Portugal | Zambia* |
| * | Covered Country. |
Alternatively, or in addition, some of the smelters and refiners may have sourced from recycled or scrap sources.
A-13
