Exhibit 1.01
John Bean Technologies Corporation
Conflict Minerals Report
For the Calendar Year Ended December 31, 2023
This report for the calendar year ended December 31, 2023 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). Unless otherwise specified or indicated by the context, JBT Corporation, JBT, we, us, our and the Company refer to John Bean Technologies Corporation and its subsidiaries. In accordance with the Rule, the information presented in this report does not include products manufactured by businesses acquired after May 1, 2022.
JBT has reason to believe that some of the 3TGs (as defined below) present in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”). We are unable to determine the origin of the 3TGs in our products and therefore cannot exclude the possibility that some may have originated in the Covered Countries. For that reason, we are required under the Rule to submit to the Securities and Exchange Commission a Conflict Minerals Report (“CMR”) as an Exhibit to Form SD. In accordance with the instructions to Form SD, this CMR has not been audited by an independent private sector auditor.
The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the DRC or an adjoining country. Gold, columbite-tantalite (coltan), cassiterite and wolframite, and their derivatives, tin, tungsten and tantalum are hereinafter referred to collectively as “3TGs.”
Forward-Looking Statement
This report and other materials filed by JBT, as well as information in oral statements or other written statements made or to be made by us, contain statements that are, or may be considered to be, forward-looking statements. All statements that are not historical facts, including statements about our beliefs or expectations, are forward-looking statements. You can identify these forward-looking statements by the use of “seeks”, “approximately”, “predicts”, “intends”, “outlook”, “believes”, “expects”, “potential”, “continues”, “may”, “will”, “should”, “plans”, “estimates”, “anticipates”, “foresees” or the negative version of those words or other comparable words or phrases. Any forward-looking statements contained in this report are based upon our historical performance and on current plans, estimates and expectations. These forward-looking statements include, among other things, statements about our compliance efforts and our ability to engage suppliers to obtain information. The inclusion of this forward-looking information should not be regarded as a representation by us or any other person that the future plans, estimates or expectations contemplated by us will be achieved.
We believe that the factors that could cause our actual results to differ materially from expectations include but are not limited to the factors we described in our Form 10-K under “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations.” If one or more of those or other risks or uncertainties materialize, or if our underlying assumptions prove to be incorrect, actual results may vary materially from what we projected. Consequently, actual events and results may vary significantly from those included in or contemplated or implied by our forward-looking statements. The forward-looking statements included in this report are made only as of the date hereof, and we undertake no obligation to publicly update or revise any forward-looking statement made by us or on our behalf, whether as a result of new information, future developments, subsequent events or changes in circumstances or otherwise.
1. Company Overview
We are a leading global technology solutions and service provider to high-value segments of the food and beverage industry. We design, produce, and service sophisticated products and systems for multi-national and regional customers. Our mission is to make better use of the world’s precious resources by providing solutions that substantially enhance our customers’ success, and in doing so design, produce and service sophisticated and critical products and systems for food and beverage companies that improve yields and boost efficiency.
The product offering of our businesses includes:
•Food and Beverage Solutions. Our equipment offerings include primary, secondary and further value-added processing, including chilling, mixing/grinding, injecting, blending, marinating, tumbling, flattening, forming, portioning, coating, cooking, frying, freezing, extracting, pasteurizing, sterilizing, concentrating, high pressure processing, weighing, inspecting, filling, closing, sealing, end of line material handling, and packaging solutions, which support a large and growing portfolio of food, beverage, and health end markets.
•Automated Guided Vehicle Systems. Our Automated Guided Vehicle Systems offerings include stand-alone, fully-integrated, and dual-mode robotic systems for material movement requirements with a wide variety of applications including automotive manufacturing, warehousing, and medical facilities.
On August 1, 2023, we completed the sale of the AeroTech business segment ("AeroTech"). AeroTech marketed its solutions and
services to domestic and international airport authorities, passenger airlines, airfreight and ground handling companies, defense
forces and defense contractors.
Our historically strong position in the markets we serve has provided us with a large installed base of systems and equipment that is a source of recurring revenue from our aftermarket parts and service offerings and re-build services for customer-owned equipment. As part of our aftermarket program, we also provide a digital solution called OmniBlu™, a subscription-based offering including integrated best-in-class service, parts availability, and machine optimization capabilities - all supported by a powerful digital infrastructure leveraging AI, machine learning, and predictive analytics. We also provide continuous, proactive service to our customers including the fulfillment of preventative maintenance agreements, such as PRoCARE® and consulting services. We offer full service operating leases on certain high-capacity industrial extractors, which include routine parts and maintenance support.
Our products may contain conflict minerals within the following components:
•Tantalum, used in capacitors
•Tin, used in soldered components
•Tungsten, used in coatings, alloys, heating elements and electrodes
•Gold, used in circuit boards, electrodes and electronic components
Our policy regarding Conflicts Minerals is posted on our website under “About Us” “Environmental, Social & Governance” and may be accessed via the following link: https://www.jbtc.com/conflict-minerals-policy/
2. Description of Reasonable County of Origin Inquiry and Conclusion
We engaged Assent Inc. (“Assent”) to assist in developing our approach to conduct in good faith a reasonable country of origin inquiry (“RCOI”). Assent is a recognized software and consulting provider supporting companies’ regulatory compliance.
JBT’s RCOI employed a combination of measures to determine whether the necessary 3TGs in JBT products originated from the Covered Countries. JBT’s primary means of determining country of origin of necessary 3TGs was by conducting a supply chain survey through Assent with direct JBT suppliers using the Responsible Minerals Initiative (“RMI”)’s Conflict Minerals Reporting Template (“CMRT”).
JBT began its scoping process by compiling a list of direct suppliers of materials for JBT’s businesses that were likely to source materials that might contain 3TGs. This list was then filtered to remove suppliers of direct materials for all business units sourced prior to January 1, 2023.
The first two questions in the CMRT allowed for further scoping as they ask suppliers whether any of the 3TGs are intentionally added and if they are necessary to the functionality or production of their products.
JBT surveyed its suppliers via the Assent Compliance Manager, a software platform licensed by JBT to log and track supplier communications. This platform also allows suppliers to upload completed CMRTs directly to the platform for assessment and management. In their responses, suppliers specified whether information was being provided at the company level or the product level. Non-responsive suppliers were contacted a minimum of three times by the Assent Compliance Manager and also via one-on-one communications. For the 2023 reporting period, JBT received responses from 46% of its in-scope suppliers. Of the 910 suppliers that provided a response, 14.5% reported that their products contained 3TGs necessary to the functionality or production of their products.
We provided training and education on the completion of the CMRT to assist suppliers in accurately completing the survey questions in the CMRT.
All of these communications were monitored and tracked in the Assent Compliance Manager for future reporting and transparency.
JBT’s survey process with Assent 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. This data validation is based on the construction and relationship of the questions submitted to the suppliers in the CMRT. Suppliers must provide the minimum responses to the CMRT in order to determine the scope of applicability of the remaining CMRT questions - this aligns with the design of the CMRT itself. The remainder of the questions are then automatically assessed for consistency. All submitted forms are accepted and classified as valid or invalid, preserving all of the data submitted for record keeping purposes. Suppliers are contacted in regard to invalid forms and are strongly encouraged to resubmit a valid form. As of May 2, 2024, there were 19 (1.0%) invalid supplier submissions.
As a result of its assessment, JBT has concluded in good faith that during calendar year 2023:
a.JBT has manufactured or contracted to manufacture products as to which 3TGs are necessary to the functionality or production of such products.
b.Based on its RCOI, JBT is unable to determine whether a portion of its necessary 3TGs originated or may have originated in the Covered Countries and is unable to determine whether those necessary 3TGs may not be from recycle or scrap sources.
3. Due Diligence Process and Results
Our due diligence measures have been designed 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, Third Edition (“OECD Guidance”) and the related Supplements for gold and for tin, tantalum and tungsten. The 5 steps of due diligence are:
1.Establishing strong company management systems regarding conflict minerals;
2.Identifying and assessing risks in our supply chain;
3.Designing and implementing a strategy to respond to identified risks in our supply chain;
4.Utilizing independent third-party audits of supply chain diligence; and
5.Publicly reporting on our supply chain 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, JBT 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 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 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.
3.1. Management Systems
Internal Team
JBT has established a management system for conflict minerals. Our management system includes a Conflict Minerals team sponsored by JBT’s executive management, as well as engineering and sourcing resources within JBT’s business segments. The Conflict Minerals Team includes subject matter experts from relevant corporate functions such as:
•Controller
•General Counsel
•Executive Vice President Supply Chain
The team is responsible for implementing our conflict minerals compliance strategy and is led by the Company’s Executive Vice President and Chief Financial Officer.
Control Systems
As described above, we have adopted a Conflict Minerals policy which is posted on our website at https://www.jbtc.com/conflict-minerals-policy/
JBT’s standard purchase order form terms and conditions include a requirement that suppliers comply with all local laws including those pertaining to business integrity.
As we do not typically have a direct relationship with 3TGs smelters and refiners, and due to our position in the supply chain and limited insight into deeper levels of the supply chain, we seek to be engaged and actively cooperate with other major manufacturers in the industry regarding 3TGs sourcing matters.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have provided education with respect to conflict minerals regulations as well as our expectations for a continued business relationship, and leveraged the existing communications with our supplier base as is available. We put a strong emphasis on supplier education. To accomplish this, we utilized Assent’s informational resources and Supplier Help Center, and provided all in-scope suppliers access to their Conflict Minerals educational resources.
Grievance Mechanism
We have a hotline whereby employees can report violations of JBT’s policies. Employees are encouraged to report concerns about compliance with policies to their managers, their human resources representative or company counsel unless they prefer to remain anonymous and utilize the hotline.
Maintain Records
We have adopted a policy to retain relevant documentation. Documentation will be retained for a minimum period of five years based on OECD guidance.
3.2 Identify and Assess Risk in the Supply Chain
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified conflict-free pose a risk to the supply chain. 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 OECD Guidance. There are 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 (RMAP) audit status;
•Credible evidence of unethical or conflict sourcing; and
•Peer Assessments conducted by credible third-party sources.
If any smelter or refiner is not recognized by the RMI, Assent conducts outreach and research to gain more information about whether they are a smelter or a refiner, sourcing practices, location, and country of origin. Additionally, if any smelter is not certified conflict-free, Assent conducts outreach providing education on the RMAP and encouraging them to join this program.
We also calculate supplier risk based on the risk ratings of the smelters declared by that supplier on their CMRT.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). At this stage, evaluating and tracking the strength of the program meets the OECD Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program include the following CMRT questions:
•Have you established a conflict minerals sourcing policy?
•Have you implemented due diligence measures for conflict-free sourcing?
•Do you review due diligence information received from your suppliers against your company’s expectations?
•Does your review process include corrective action management?
When suppliers meet or exceed those criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
3.3 Design and Implement a Strategy to Respond to Identified Risks
In response to this risk assessment, we have a risk management plan, through which the conflict minerals program is implemented, managed and monitored.
As part of our risk management plan, to ensure suppliers understand our expectations we have provided both video, recorded training and documented instructions through Assent’s compliance supply chain staff. As the program progresses, contacts via email and phone by our business segments may be utilized to communicate the importance of a response via CMRTs to Assent and the required cooperation for compliance without conflict minerals policies will be emphasized.
3.4 Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with 3TGs smelters and refiners and do not presently perform or direct audits of these entities within our supply chain. JBT depends on audits performed and submitted to the RMI for conflict-free certifications.
3.5 Report Annually on Supply Chain Due Diligence
We report annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission. Our Form SD and Conflict Minerals Report can be found on the Investor Relations page of our website https://ir.jbtc.com/financials/sec-filings/
4. Due Diligence Results
Survey Results
For the 2023 reporting year, JBT received a CMRT from 46% of the suppliers surveyed, versus 48% in the previous year. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. 19 suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. We surveyed a total of 1,981 in scope suppliers and received 890 CMRT submissions by May 2, 2024.
Certain of the responses provided by the Company’s suppliers to the CMRT included the names of smelters or refiners. See Appendix A - Identified Smelter List, which includes all smelters or refiners identified by our suppliers in their CMRTs and which have been verified by Assent. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI. Assent, using the sources above, has validated 341 smelters and refiners (“SORs”) disclosed by the Company’s suppliers on submitted CMRTs. Going forward, Assent is continuing to validate additional SORs from the submitted CMRTs. 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 collectively source conflict minerals, based on information provided by our suppliers and RMI.
The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the smelters or refiners identified by our suppliers contained in Appendix A below may include smelters or refiners that processed conflict minerals that our suppliers 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 the tables below were used to process the conflict minerals necessary to the functionality or production of our products during calendar year 2023. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed above were the country of origin of conflict minerals in our products during calendar year 2022, and we are therefore also unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the third-party audits conducted on smelters as part of the RMAP and the information that we receive from our suppliers may yield inaccurate or incomplete information. For example, the information received from our suppliers may be incomplete because they may not have received accurate and complete conflict 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.
Many of our surveyed suppliers are still unable to provide the smelters or refiners used for materials they supplied to us. Furthermore, many of the responses provided at the company or division level indicated an “unknown” status in terms of determining the origin of 3TGs.
As noted above, the current efforts focus on gathering smelter information via the CMRT and requesting full completion of all necessary smelter identification information which will enable the validation and disclosure of the smelters as well as the tracing of the 3TGs to their location of origin.
We believe that the inquiries and assessment processes described above represent a reasonable effort to determine the origin of the 3TGs in our products, including (1) seeking information about 3TGs smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
5. Program Enhancement
We continue to review our program to identify and remediate risks that sources of the necessary 3TGs used in our products that we purchase through our supply chains could benefit armed groups in the Covered Countries. Although the processes we employ to identify these risks cannot determine with precision which of the products we buy in our supply chain present this risk, we can provide information to our direct suppliers about our policies and requirements and encourage and incentivize our suppliers to push that information through the successive layers of their supply chains to the point where the acquisition of raw materials occurs that create these risks.
We believe that we can further these objectives by:
a. Continuing to engage with our direct suppliers and provide training resources to attempt to increase the response rate to CMRs and improve the accuracy of the supplier responses.
b. Facilitating the evaluation and identification of upstream sources of necessary 3TGs by:
•Maintaining a database that includes the smelters and refiners identified by our suppliers and information about those smelters and refiners that are obtained to evaluate risk.
•Periodically screening the list of smelters and refiners against government sanction and denied parties lists.
•Seeking assurances from our suppliers who identify smelters and refiners that are identified as high risk through our due diligence process that the products we purchase from them do not include 3TGs from such smelters and refiners.
c. Continuing to include a conflict minerals flow-down clause in our direct supplier contracts and in the terms and conditions of each purchase order issued to direct suppliers of materials for JBT businesses likely to source materials that might contain 3TGs.
Appendix A - Identified Smelter List*
| | | | | | | | | | | |
Metal | Standard Smelter Name | Country | Smelter ID |
Tantalum | 5D Production OU | Estonia | CID003926 |
Gold | 8853 S.p.A. | Italy | CID002763 |
Tungsten | A.L.M.T. Corp. | Japan | CID000004 |
Gold | ABC Refinery Pty Ltd. | Australia | CID002920 |
Gold | Abington Reldan Metals, LLC | United States Of America | CID002708 |
Tungsten | ACL Metais Eireli | Brazil | CID002833 |
Gold | Advanced Chemical Company | United States Of America | CID000015 |
Gold | African Gold Refinery | Uganda | CID003185 |
Gold | Agosi AG | Germany | CID000035 |
Gold | Aida Chemical Industries Co., Ltd. | Japan | CID000019 |
Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | CID002560 |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | CID003427 |
Gold | Albino Mountinho Lda. | Portugal | CID002760 |
Gold | Alexy Metals | United States Of America | CID003500 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | CID000041 |
Tin | Alpha | United States Of America | CID000292 |
Tantalum | AMG Brasil | Brazil | CID001076 |
Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | CID002703 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | CID000058 |
Gold | Argor-Heraeus S.A. | Switzerland | CID000077 |
Tungsten | Artek LLC | Russian Federation | CID003553 |
Gold | Asahi Pretec Corp. | Japan | CID000082 |
Gold | Asahi Refining Canada Ltd. | Canada | CID000924 |
Gold | Asahi Refining USA Inc. | United States Of America | CID000920 |
Gold | Asaka Riken Co., Ltd. | Japan | CID000090 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | CID002502 |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | CID000103 |
Gold | AU Traders and Refiners | South Africa | CID002850 |
Gold | Augmont Enterprises Private Limited | India | CID003461 |
Gold | Aurubis AG | Germany | CID000113 |
Tin | Aurubis Beerse | Belgium | CID002773 |
Tin | Aurubis Berango | Spain | CID002774 |
Gold | Bangalore Refinery | India | CID002863 |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | CID000128 |
Gold | Boliden AB | Sweden | CID000157 |
Gold | C. Hafner GmbH + Co. KG | Germany | CID000176 |
Gold | Caridad | Mexico | CID000180 |
Gold | CCR Refinery - Glencore Canada Corporation | Canada | CID000185 |
Gold | Cendres + Metaux S.A. | Switzerland | CID000189 |
Gold | CGR Metalloys Pvt Ltd. | India | CID003382 |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | CID000228 |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | CID003190 |
Gold | Chimet S.p.A. | Italy | CID000233 |
Tungsten | China Molybdenum Tungsten Co., Ltd. | China | CID002641 |
Tin | China Tin Group Co., Ltd. | China | CID001070 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | CID000258 |
Gold | Chugai Mining | Japan | CID000264 |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | CID000281 |
Gold | Coimpa Industrial LTDA | Brazil | CID004010 |
| | | | | | | | | | | |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | CID003486 |
Tin | CRM Synergies | Spain | CID003524 |
Tungsten | Cronimet Brasil Ltda | Brazil | CID003468 |
Tin | CV Ayi Jaya | Indonesia | CID002570 |
Tin | CV Venus Inti Perkasa | Indonesia | CID002455 |
Tantalum | D Block Metals, LLC | United States Of America | CID002504 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | China | CID000343 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | CID002867 |
Gold | Dijllah Gold Refinery FZC | United Arab Emirates | CID003348 |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | CID003356 |
Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of | CID004060 |
Gold | Dongwu Gold Group | China | CID003663 |
Tin | Dowa | Japan | CID000402 |
Gold | Dowa | Japan | CID000401 |
Tin | DS Myanmar | Myanmar | CID003831 |
Gold | DSC (Do Sung Corporation) | Korea, Republic Of | CID000359 |
Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | CID000425 |
Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | CID003424 |
Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | CID003425 |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | CID002572 |
Tin | EM Vinto | Bolivia (Plurinational State Of) | CID000438 |
Gold | Emerald Jewel Industry India Limited (Unit 1) | India | CID003487 |
Gold | Emerald Jewel Industry India Limited (Unit 2) | India | CID003488 |
Gold | Emerald Jewel Industry India Limited (Unit 3) | India | CID003489 |
Gold | Emerald Jewel Industry India Limited (Unit 4) | India | CID003490 |
Gold | Emirates Gold DMCC | United Arab Emirates | CID002561 |
Tin | Estanho de Rondonia S.A. | Brazil | CID000448 |
Tantalum | F&X Electro-Materials Ltd. | China | CID000460 |
Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | CID003582 |
Tin | Fenix Metals | Poland | CID000468 |
Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | CID002515 |
Tantalum | FIR Metals & Resource Ltd. | China | CID002505 |
Gold | Fujairah Gold FZC | United Arab Emirates | CID002584 |
Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | CID003609 |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | CID002315 |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | CID002494 |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | CID003410 |
Tin | Gejiu Kai Meng Industry and Trade LLC | China | CID000942 |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | CID000538 |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | CID001908 |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | CID000555 |
Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India | CID002852 |
Tantalum | Global Advanced Metals Aizu | Japan | CID002558 |
Tantalum | Global Advanced Metals Boyertown | United States Of America | CID002557 |
Tungsten | Global Tungsten & Powders LLC | United States Of America | CID000568 |
Gold | Gold by Gold Colombia | Colombia | CID003641 |
Gold | Gold Coast Refinery | Ghana | CID003186 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | CID002243 |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | CID001909 |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | CID003116 |
Gold | Guangdong Jinding Gold Limited | China | CID002312 |
| | | | | | | | | | | |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | CID000218 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | CID000651 |
Tungsten | H.C. Starck Tungsten GmbH | Germany | CID002541 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | CID000671 |
Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic Of | CID003978 |
Gold | Heimerle + Meule GmbH | Germany | CID000694 |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | CID002492 |
Gold | Heraeus Germany GmbH Co. KG | Germany | CID000711 |
Gold | Heraeus Metals Hong Kong Ltd. | China | CID000707 |
Tungsten | Hubei Green Tungsten Co., Ltd. | China | CID003417 |
Gold | Hunan Chenzhou Mining Co., Ltd. | China | CID000767 |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | CID000766 |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | CID000773 |
Tungsten | Hunan Jintai New Material Co., Ltd. | China | CID000769 |
Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | CID002513 |
Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | CID000778 |
Tungsten | Hydrometallurg, JSC | Russian Federation | CID002649 |
Gold | Industrial Refining Company | Belgium | CID002587 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | CID000801 |
Gold | International Precious Metal Refiners | United Arab Emirates | CID002562 |
Gold | Ishifuku Metal Industry Co., Ltd. | Japan | CID000807 |
Gold | Istanbul Gold Refinery | Turkey | CID000814 |
Gold | Italpreziosi | Italy | CID002765 |
Gold | JALAN & Company | India | CID002893 |
Gold | Japan Mint | Japan | CID000823 |
Tungsten | Japan New Metals Co., Ltd. | Japan | CID000825 |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | CID002551 |
Gold | Jiangxi Copper Co., Ltd. | China | CID000855 |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | CID002512 |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | CID002321 |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | CID002313 |
Tin | Jiangxi New Nanshan Technology Ltd. | China | CID001231 |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | CID002318 |
Tantalum | Jiangxi Tuohong New Raw Material | China | CID002842 |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | CID002317 |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | CID002316 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | CID000914 |
Tantalum | Jiujiang Tanbre Co., Ltd. | China | CID000917 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | CID002506 |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | CID003408 |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | CID000927 |
Gold | JSC Novosibirsk Refinery | Russian Federation | CID000493 |
Gold | JSC Uralelectromed | Russian Federation | CID000929 |
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | CID000937 |
Gold | K.A. Rasmussen | Norway | CID003497 |
Gold | Kaloti Precious Metals | United Arab Emirates | CID002563 |
Gold | Kazakhmys Smelting LLC | Kazakhstan | CID000956 |
Gold | Kazzinc | Kazakhstan | CID000957 |
Tantalum | KEMET de Mexico | Mexico | CID002539 |
Tungsten | Kennametal Fallon | United States Of America | CID000966 |
Tungsten | Kennametal Huntsville | United States Of America | CID000105 |
| | | | | | | | | | | |
Gold | Kennecott Utah Copper LLC | United States Of America | CID000969 |
Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | CID002511 |
Gold | Kojima Chemicals Co., Ltd. | Japan | CID000981 |
Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | CID002605 |
Gold | Kundan Care Products Ltd. | India | CID003463 |
Gold | Kyrgyzaltyn JSC | Kyrgyzstan | CID001029 |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | CID002865 |
Gold | L'azurde Company For Jewelry | Saudi Arabia | CID001032 |
Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | CID003407 |
Gold | Lingbao Gold Co., Ltd. | China | CID001056 |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | CID001058 |
Tungsten | LLC Vostok | Russian Federation | CID003643 |
Gold | L'Orfebre S.A. | Andorra | CID002762 |
Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | CID001078 |
Gold | LT Metal Ltd. | Korea, Republic Of | CID000689 |
Tin | Luna Smelter, Ltd. | Rwanda | CID003387 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | CID001093 |
Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | CID002468 |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia | CID001105 |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | CID002319 |
Gold | Marsam Metals | Brazil | CID002606 |
Tungsten | Masan High-Tech Materials | Viet Nam | CID002543 |
Gold | Materion | United States Of America | CID001113 |
Tantalum | Materion Newton Inc. | United States Of America | CID002548 |
Gold | Matsuda Sangyo Co., Ltd. | Japan | CID001119 |
Gold | MD Overseas | India | CID003548 |
Tin | Melt Metais e Ligas S.A. | Brazil | CID002500 |
Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | CID003575 |
Tin | Metallic Resources, Inc. | United States Of America | CID001142 |
Gold | Metallix Refining Inc. | United States Of America | CID003557 |
Tantalum | Metallurgical Products India Pvt., Ltd. | India | CID001163 |
Gold | Metalor Technologies (Hong Kong) Ltd. | China | CID001149 |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | CID001152 |
Gold | Metalor Technologies (Suzhou) Ltd. | China | CID001147 |
Gold | Metalor Technologies S.A. | Switzerland | CID001153 |
Gold | Metalor USA Refining Corporation | United States Of America | CID001157 |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | CID001161 |
Tantalum | Mineracao Taboca S.A. | Brazil | CID001175 |
Tin | Mineracao Taboca S.A. | Brazil | CID001173 |
Tin | Mining Minerals Resources SARL | Congo, Democratic Republic Of The | CID004065 |
Tin | Minsur | Peru | CID001182 |
Gold | Mitsubishi Materials Corporation | Japan | CID001188 |
Tin | Mitsubishi Materials Corporation | Japan | CID001191 |
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001193 |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001192 |
Gold | MKS PAMP SA | Switzerland | CID001352 |
Gold | MMTC-PAMP India Pvt., Ltd. | India | CID002509 |
Tin | Modeltech Sdn Bhd | Malaysia | CID002858 |
Gold | Modeltech Sdn Bhd | Malaysia | CID002857 |
Tungsten | Moliren Ltd. | Russian Federation | CID002845 |
Gold | Morris and Watson | New Zealand | CID002282 |
Gold | Moscow Special Alloys Processing Plant | Russian Federation | CID001204 |
| | | | | | | | | | | |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | CID001220 |
Tungsten | Nam Viet Cromit Joint Stock Company | Viet Nam | CID004034 |
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | CID001236 |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002573 |
Gold | NH Recytech Company | Korea, Republic Of | CID003189 |
Tungsten | Niagara Refining LLC | United States Of America | CID002589 |
Gold | Nihon Material Co., Ltd. | Japan | CID001259 |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | CID001277 |
Tin | Novosibirsk Tin Combine | Russian Federation | CID001305 |
Tantalum | NPM Silmet AS | Estonia | CID001200 |
Tungsten | NPP Tyazhmetprom LLC | Russian Federation | CID003416 |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | CID001314 |
Tin | O.M. Manufacturing Philippines, Inc. | Philippines | CID002517 |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | CID002779 |
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | CID001325 |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | CID001326 |
Tungsten | OOO “Technolom” 1 | Russian Federation | CID003614 |
Tungsten | OOO “Technolom” 2 | Russian Federation | CID003612 |
Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | CID001337 |
Gold | Pease & Curren | United States Of America | CID002872 |
Gold | Penglai Penggang Gold Industry Co., Ltd. | China | CID001362 |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | CID002827 |
Gold | Planta Recuperadora de Metales SpA | Chile | CID002919 |
Tin | Pongpipat Company Limited | Myanmar | CID003208 |
Tantalum | PowerX Ltd. | Rwanda | CID004054 |
Tin | Precious Minerals and Smelting Limited | India | CID003409 |
Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | CID001386 |
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | CID001397 |
Tin | PT Aries Kencana Sejahtera | Indonesia | CID000309 |
Tin | PT Artha Cipta Langgeng | Indonesia | CID001399 |
Tin | PT ATD Makmur Mandiri Jaya | Indonesia | CID002503 |
Tin | PT Babel Inti Perkasa | Indonesia | CID001402 |
Tin | PT Babel Surya Alam Lestari | Indonesia | CID001406 |
Tin | PT Bangka Prima Tin | Indonesia | CID002776 |
Tin | PT Bangka Serumpun | Indonesia | CID003205 |
Tin | PT Bangka Tin Industry | Indonesia | CID001419 |
Tin | PT Belitung Industri Sejahtera | Indonesia | CID001421 |
Tin | PT Bukit Timah | Indonesia | CID001428 |
Tin | PT Cipta Persada Mulia | Indonesia | CID002696 |
Tin | PT Menara Cipta Mulia | Indonesia | CID002835 |
Tin | PT Mitra Stania Prima | Indonesia | CID001453 |
Tin | PT Mitra Sukses Globalindo | Indonesia | CID003449 |
Tin | PT Panca Mega Persada | Indonesia | CID001457 |
Tin | PT Premium Tin Indonesia | Indonesia | CID000313 |
Tin | PT Prima Timah Utama | Indonesia | CID001458 |
Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | CID003868 |
Tin | PT Rajawali Rimba Perkasa | Indonesia | CID003381 |
Tin | PT Refined Bangka Tin | Indonesia | CID001460 |
Tin | PT Sariwiguna Binasentosa | Indonesia | CID001463 |
Tin | PT Stanindo Inti Perkasa | Indonesia | CID001468 |
Tin | PT Sukses Inti Makmur | Indonesia | CID002816 |
| | | | | | | | | | | |
Tin | PT Timah Nusantara | Indonesia | CID001486 |
Tin | PT Timah Tbk Kundur | Indonesia | CID001477 |
Tin | PT Timah Tbk Mentok | Indonesia | CID001482 |
Tin | PT Tinindo Inter Nusa | Indonesia | CID001490 |
Tin | PT Tirus Putra Mandiri | Indonesia | CID002478 |
Tin | PT Tommy Utama | Indonesia | CID001493 |
Gold | PX Precinox S.A. | Switzerland | CID001498 |
Gold | QG Refining, LLC | United States Of America | CID003324 |
Tantalum | QuantumClean | United States Of America | CID001508 |
Gold | Rand Refinery (Pty) Ltd. | South Africa | CID001512 |
Gold | Refinery of Seemine Gold Co., Ltd. | China | CID000522 |
Gold | REMONDIS PMR B.V. | Netherlands | CID002582 |
Tantalum | Resind Industria e Comercio Ltda. | Brazil | CID002707 |
Tin | Resind Industria e Comercio Ltda. | Brazil | CID002706 |
Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | CID003583 |
Gold | Royal Canadian Mint | Canada | CID001534 |
Tin | Rui Da Hung | Taiwan, Province Of China | CID001539 |
Gold | SAAMP | France | CID002761 |
Gold | Sabin Metal Corp. | United States Of America | CID001546 |
Gold | Safimet S.p.A | Italy | CID002973 |
Gold | SAFINA A.S. | Czechia | CID002290 |
Gold | Sai Refinery | India | CID002853 |
Gold | Sam Precious Metals | United Arab Emirates | CID003666 |
Gold | Samduck Precious Metals | Korea, Republic Of | CID001555 |
Gold | Samwon Metals Corp. | Korea, Republic Of | CID001562 |
Gold | SEMPSA Joyeria Plateria S.A. | Spain | CID001585 |
Gold | Shandong Gold Smelting Co., Ltd. | China | CID001916 |
Gold | Shandong Humon Smelting Co., Ltd. | China | CID002525 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | CID001619 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | CID001622 |
Gold | Shenzhen CuiLu Gold Co., Ltd. | China | CID002750 |
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | CID002527 |
Gold | Shirpur Gold Refinery Ltd. | India | CID002588 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | CID001736 |
Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | CID002516 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | CID001756 |
Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | CID001761 |
Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | CID001769 |
Gold | Sovereign Metals | India | CID003383 |
Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | CID003153 |
Gold | Sudan Gold Refinery | Sudan | CID002567 |
Gold | Sumitomo Metal Mining Co., Ltd. | Japan | CID001798 |
Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | CID002918 |
Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province Of China | CID001810 |
Tin | Super Ligas | Brazil | CID002756 |
Gold | T.C.A S.p.A | Italy | CID002580 |
Tantalum | Taki Chemical Co., Ltd. | Japan | CID001869 |
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | CID001875 |
Tantalum | TANIOBIS Co., Ltd. | Thailand | CID002544 |
Tantalum | TANIOBIS GmbH | Germany | CID002545 |
Tantalum | TANIOBIS Japan Co., Ltd. | Japan | CID002549 |
Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002550 |
| | | | | | | | | | | |
Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002542 |
Tantalum | Telex Metals | United States Of America | CID001891 |
Tin | Thaisarco | Thailand | CID001898 |
Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | CID002180 |
Tin | Tin Technology & Refining | United States Of America | CID003325 |
Gold | Tokuriki Honten Co., Ltd. | Japan | CID001938 |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | CID001947 |
Gold | TOO Tau-Ken-Altyn | Kazakhstan | CID002615 |
Gold | Torecom | Korea, Republic Of | CID001955 |
Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam | CID003993 |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002574 |
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | CID001969 |
Gold | Umicore Precious Metals Thailand | Thailand | CID002314 |
Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | CID001980 |
Tungsten | Unecha Refractory metals plant | Russian Federation | CID002724 |
Gold | United Precious Metal Refining, Inc. | United States Of America | CID001993 |
Gold | Valcambi S.A. | Switzerland | CID002003 |
Tin | VQB Mineral and Trading Group JSC | Viet Nam | CID002015 |
Gold | WEEEREFINING | France | CID003615 |
Gold | Western Australian Mint (T/a The Perth Mint) | Australia | CID002030 |
Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | CID002036 |
Gold | WIELAND Edelmetalle GmbH | Germany | CID002778 |
Tungsten | Wolfram Bergbau und Hutten AG | Austria | CID002044 |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | CID002320 |
Tungsten | Xiamen Tungsten Co., Ltd. | China | CID002082 |
Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | CID000616 |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | CID002508 |
Gold | Yamakin Co., Ltd. | Japan | CID002100 |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | CID001522 |
Gold | Yokohama Metal Co., Ltd. | Japan | CID002129 |
Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China | CID003662 |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | CID002158 |
Gold | Yunnan Copper Industry Co., Ltd. | China | CID000197 |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | CID003397 |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | CID002224 |
* Information from supplier declarations identified smelters located in the Russian Federation and Uganda as a potential source of metals used by the Company’s third-party suppliers. We have communicated with our suppliers about our concerns regarding the inclusion of these smelters in our supply chain and have asked these suppliers to take corrective action to remove them. Despite our communications, if our suppliers delay implementation of corrective action plans, then these potential sources may remain in our supply chain. The Company does not knowingly source directly or indirectly from sanctioned countries or parties. The inclusion of a country on the list of smelters is not a final indicator that the Company utilized materials sourced from this country.
List of Potential Countries of Origin:
Andorra, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Colombia, Congo, Czechia, Estonia, France, Germany, Ghana, India, Indonesia, Italy, Japan, Kazakhstan, Korea, Kyrgyzstan, Lithuania, Malaysia, Mexico, Myanmar, Netherlands, New Zealand, Norway, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, Uganda, United Arab Emirates, United States of America, Uzbekistan, Vietnam, Zimbabwe