Exhibit 1.01
Regal Rexnord Corporation
Conflict Minerals Report
For the Year Ended December 31, 2021
This Conflict Minerals Report (this “Report”) of Regal Rexnord Corporation (the “Company,” “we,” “Regal Rexnord,” “us,” “our”) has been prepared pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Rule”), for the reporting period January 1 to December 31, 2021.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the conflict minerals specified in the Rule are intentionally added and necessary to the functionality or production of those products. Conflict Minerals are defined in section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The specified minerals, which we collectively refer to in this Report as the “3TGs,” are gold, tantalum, tin and tungsten, respectively. The “Covered Countries” for the purposes of this Report are the DRC and the adjoining countries. As described in this Report, during the reporting period between January 1, 2021 and December 31, 2021, certain of the Company’s operations manufactured, or contracted to manufacture, products for which the 3TGs are intentionally added and necessary to the functionality or production.
Cautionary Statement
Certain statements made in this Report are forward-looking statements, including statements relating to our compliance efforts and expected actions identified under the “Process Improvement Considerations” section of this Report, intended to qualify for the safe harbor from liability established by the Private Securities Litigation Reform Act of 1995. This report contains forward-looking statements, within the meaning of Section 21E of the Securities Exchange Act of 1934, as amended, which reflect the Company’s current estimates, expectations and projections about the Company’s future results, performance, prospects and opportunities. Such forward-looking statements may include, among other things, statements about the Company’s future operations, anticipated business levels, future earnings, planned activities, anticipated growth, market opportunities, strategies, competition and other expectations and estimates for future periods. Forward-looking statements include statements that are not historical facts and can be identified by forward-looking words such as “anticipate,” “believe,” “could,” “estimate,” “expect,” “intend,” “plan,” “may,” “should,” “will,” “would,” “project,” “forecast,” and similar expressions. These forward-looking statements are based upon information currently available to the Company and are subject to a number of risks, uncertainties, and other factors that could cause the performance, prospects, or opportunities to differ materially from those expressed in, or implied by, these forward-looking statements. Shareholders, potential investors, and other readers are cautioned not to place undue reliance on such forward-looking statements. The forward-looking statements included in this Report are made only as of the date of this Report, and the Company undertakes no obligation to update any forward-looking information contained in this Report or with respect to the announcements described herein to reflect subsequent events or circumstances. Additional information regarding the risks, uncertainties, and other factors that could cause the performance, prospects, or opportunities to differ materially from those expressed in, or implied by, the forward-looking statements contained in this Report is included in "Part I - Item 1A - Risk Factors" in our Annual Report on Form 10-K filed with the SEC on March 2, 2022 and from time to time in other filed reports.
Summary
Through our Reasonable Country of Origin Inquiry (“RCOI”) and due diligence efforts, we identified 64 smelters and/or refiners (“SORs”) as either sourcing Conflict Minerals from the Covered Countries or giving us reason to believe they are sourcing Conflict Minerals from the Covered Countries. Out of those 64 smelters, 59 smelters are recognized as conformant with the Responsible Minerals Assurance Process (“RMAP”). The following sections describe in detail our RCOI, our due diligence framework, and the results of our due diligence efforts.
Company Overview
Regal Rexnord is a global leader in the engineering and manufacturing of industrial powertrain solutions, power transmission components, electric motors and electronic controls, air moving products and specialty electrical components and systems, serving markets throughout the world. Through longstanding technology leadership and an intentional focus on producing more energy-efficient products and systems, Regal Rexnord helps create a better tomorrow – for its customers and for the planet. Regal Rexnord is comprised of four operating segments: Motion Control Solutions, Climate Solutions, Commercial Systems and Industrial Systems.
As previously disclosed, on October 4, 2021, we completed a Reverse Morris Trust transaction in which (i) substantially all of the assets and liabilities of the former Process and Motion Control business (the “PMC business”) of Rexnord Corporation (now known as Zurn Water Solutions Corporation) (“Zurn”) were transferred into a newly created subsidiary of Zurn, Land Newco, Inc. (“Land”), (ii) the shares of Land were distributed to Zurn’s stockholders pro rata, and (iii) Land was merged with a subsidiary of Regal Rexnord, in which the stock of Land was converted into a certain number of shares of Regal Rexnord in accordance with the exchange ratio. For purposes of this Report and the
applicable reporting period, the disclosures made herein do not include those of the PMC business. Instead, Zurn’s conflict mineral report for the applicable reporting period includes any disclosures required with respect to the PMC business.
In addition, Regal Rexnord acquired Arrowhead Systems, LLC (the “Arrowhead business”) on November 23, 2021. Prior to this transaction, the Arrowhead business was not required to file a conflict minerals report pursuant to the Rule. As permitted by the Rule, the Arrowhead business has been excluded from this Report.
Description of the Company’s Products Covered by this Report
This Report relates to products: (i) for which the 3TGs are intentionally added and necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2021.
These products, which are referred to in this Report collectively as the “Covered Products,” are the following:
| | | | | | | | |
| 1. | Electric motors and controls (may contain tin and tin and gold respectively) |
| 2. | Electric generators and controls (may contain tin and tin and gold respectively) |
| 3. | Gear reducers (may contain tin) |
| 4. | Electronic switchgears (may contain tin and gold) |
| 5. | Actuators (may contain tin, gold, tantalum and tungsten) |
| 6. | Servo systems (may contain tin, gold, tantalum and tungsten) |
| 7. | Conveyor systems (may contain tin, gold, tantalum and tungsten) |
| 8. | Power transmission products including gearboxes, transfer cases, transmissions, worm gears and other gears (may contain tin) |
| 9. | Loadbanks (may contain tin, gold, tantalum and tungsten) |
| 10. | Other electrical/electronic components (may contain tin, gold, tantalum and tungsten) |
As previously noted, Covered Products exclude products of the PMC and Arrowhead businesses.
Reasonable Country of Origin Inquiry
Our supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between us as the manufacturer of the Covered Products and the original sources of 3TGs. In this regard, we do not typically purchase Conflict Minerals directly from mines, smelters or refiners. We must therefore rely on our suppliers to provide information regarding the origin of 3TGs that are included in the Covered Products. Moreover, we believe that the smelters and refiners of the 3TGs are best situated to identify the sources of 3TGs, and therefore have taken steps to identify the applicable smelters and refiners of 3TGs in our supply chain.
To determine whether 3TGs necessary to our products originated in the Covered Countries, we retained a third-party service provider to assist us in reviewing and surveying our supply chain. We believe that we conducted a good faith RCOI to provide a reasonable basis for us to determine whether we source 3TGs from the Covered Countries. This good faith RCOI was designed to determine whether any of the 3TGs originated in the Covered Countries and whether any of the 3TGs may be from recycled or scrap sources. We are utilizing the supplier engagement approach outlined by the Responsible Minerals Initiative (“RMI”), including the utilization of their Conflict Minerals Reporting Template version 6.1 and higher (“CMRT”).
As the first step in our RCOI, we determined which of our products would most likely contain the 3TGs. After review, it was decided that substantially all of the products that we manufacture are Covered Products. Using our supply chain data systems, we refined our list of suppliers by filtering out service providers, indirect materials suppliers, and inactive suppliers. We further refined this list to filter out suppliers who, based on our knowledge of our parts, supply us with parts that do not contain any 3TGs. Based on these steps, we identified 1134 direct suppliers as in-scope for our 2021 RCOI. When key contact information for in-scope suppliers was not available in our systems, we initiated a process to gather that information.
Once supplier contact information was obtained, that information as well as the applicable part information was uploaded into our third-party service provider’s web-based compliance tool. We then conducted the supplier survey portion of the RCOI. Our in-scope suppliers were contacted via our third-party provider’s Software as a Service (“SaaS”) platform that enables its users to complete and track supplier communications, and request that suppliers complete and upload a CMRT directly to the platform for assessment and management for the products they provide to us. Included in the supplier requests was a link to our Conflict Minerals Policy (our “Policy”) to reinforce our commitment to sourcing responsibly and to make clear the responsibility of each of our suppliers to support us to fulfill this commitment.
As indicated in our Policy, we require suppliers to provide their Conflict Minerals information using the CMRT. To provide suppliers flexibility, we allowed them to provide their responses to the CMRT by submitting their completed CMRT via e-mail or by uploading the CMRT directly to our service provider’s software portal.
During our review and analysis of the submitted CMRTs, it was clear that many suppliers continued to erroneously assume that the country of operation of the smelter as listed in the CMRT was the country of origin of the Conflict Minerals. This led to incorrect and inconsistent responses to many of the questions in the submitted CMRTs.
Supplier communications were tracked and all non-responsive suppliers were contacted a minimum of four times. Our third-party service provider also included automated data validation on all submitted CMRTs. The goal of this step is to increase the accuracy and validity of submission and identify contradictory answers. Any invalid responses were flagged and those suppliers were contacted and encouraged to resubmit a valid form. As of May 6, 2022, 62.96% of our in scope suppliers submitted a valid CMRT. All final CMRT submissions were then reviewed to identify smelters or refiners in our supply chain, which list of smelters and refiners was then cross-referenced with the RMI data in order to conduct the RCOI. The overall supplier response rate to our RCOI was approximately 66.31%.
Conflict Minerals Policy
We developed our Policy and initially published it on our website in April 2013. Our Policy is reviewed annually and updated as needed to reflect our commitment to sourcing responsibly and to make clear the responsibility of each of our suppliers to support us to fulfill this commitment. Our Policy can be viewed at https://investors.regalrexnord.com/investors/corporate-governance/integrity-and-compliance/default.aspx. Further, Regal Rexnord supports conflict-free minerals trade in the DRC and Covered Countries and will not avoid sourcing from conflict-free organizations in the region.
Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”). We utilize all five steps of the OECD Guidance for downstream companies.
Establish Strong Company Management Systems
Control Systems
Regal Rexnord is committed to sourcing conflict-free minerals from the DRC and Covered Countries, and as such, we have communicated our Policy to our suppliers and customers. Our Policy was provided to suppliers during our RCOI process. Our Policy is provided to customers requesting Conflict Minerals information. This Policy is publicly available on our website as discussed above.
In addition to our efforts directly related to Conflict Minerals, Regal Rexnord maintains a strong company commitment to conducting business in an ethical manner as detailed in our Code of Business Conduct & Ethics as well as our Global Anti-Corruption Policy, both of which are also available on our website (https://investors.regalrexnord.com/investors/corporate-governance/integrity-and-compliance/default.aspx).
Internal Team
Consistent with the OECD Guidance, we formed an internal team tasked with supporting supply chain due diligence. This team consists of vice presidents from the following functional groups: Legal, Supply Chain, Technology, and Environmental, Health, Safety and Sustainability (EHSS). Additional members of the committee included the General Manager of Supplier Quality and Development and our materials compliance manager.
Supplier Engagement
We utilized the RMI’s RMAP as a compliance standard for upstream due diligence. We have implemented an RCOI process. As a part of our Standard Terms and Conditions of Purchase, companies selling products to Regal Rexnord are required to implement a policy regarding conflict minerals, to exercise due diligence in investigating the source of these minerals, and to respond in a timely manner to Regal Rexnord’s requests for evidence of their compliance with these requirements. Conflict minerals compliance is also included as a requirement in our Supplier Quality Manual. Conflict minerals compliance process and documentation review are requirements of our Supplier Audit Assessment and Production Part Approval Process.
Grievance Mechanisms
We have an Integrity Alert line through which suppliers, customers, company employees or any interested stakeholder can communicate their thoughts, concerns and grievances regarding Conflict Minerals or, more generally, any of our business practices. A link to our Integrity Alert Line is available here. (https://investors.regalrexnord.com/investors/corporate-governance/integrity-and-compliance/default.aspx)
Maintain Records
All responses from suppliers and source smelters are recorded and stored for a minimum of five years.
Identify and Assess Risk in the Supply Chain
For upstream due diligence, we have adopted the processes and protocols of the RMAP. Risks are identified automatically in our third-party provider’s system based on criteria established for supplier responses in the system. The primary risk that we identified with respect to reporting year 2021 was with respect to the nature of the responses we received. A large number of the responses we received provided data at a company or divisional level rather than at a specific product level.
We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Our third-party provider compared the facilities listed in the responses to the list of smelters and refiners maintained by the RMI and, if a supplier indicated that the facility was certified as “Conflict-Free,” confirmed that the name was listed by the RMI. As of May 6, 2022, we have identified 336 legitimate smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primarily company-level CMRTs, we cannot definitively determine their connection to our products.
We believe that all 3TGs “necessary to the functionality of the products” have been identified, the suppliers of those 3TGs have been identified, and smelter data has been collected from those that responded to our RCOI. Responses provided by suppliers have undergone a review for accuracy.
Design and Implement a Strategy to Respond to Identified Risks
We have implemented a plan to report Conflict Minerals findings to Robert J. Rehard, Vice President, Chief Financial Officer of the Company (the “CFO”), who is the member of senior management appointed for this role. A process has been adopted to aggregate and update the list of smelters. Furthermore, a process has been adopted to review supplier responses, follow up with delinquent suppliers, and update supplier information. A risk management process has been adopted that manages smelters that cannot provide country of origin information, identifies red-flag smelters, tracks and records compliance information for individual smelters, and communicates these results back to the CFO. We require new suppliers to complete a CMRT as part of becoming an approved supplier to Regal Rexnord.
Carry out an Independent Third Party Audit of Refiner’s Due Diligence Practices
We have utilized the risk management and due diligence processes of the RMAP and the RMAP’s independent third party audit process performed on smelters that source from the Covered Countries. This includes other programs accepted by the RMAP, including the certification processes of the London Bullion Market Association (LBMA), The Responsible Jewellery Council (RJC), and the Tungsten Industry – Conflict Minerals Council (TI-CMC). To be identified as conflict free, we require smelters to be compliant with the requirements of the RMAP if they are sourcing from the Covered Countries.
Report on Supply Chain Due Diligence
In accordance with the OECD Guidance and the Rule, this Report is also available on our website (https://investors.regalrexnord.com/investors/financial-information/sec-filings/default.aspx). Through our participation with the RMI, we encouraged smelters or refiners to participate in the RMI Responsible Minerals Assurance Process. Any smelters or refiners that were reported by our suppliers who were not part of the RMAP were also contacted directly to encourage them to participate in the RMAP.
Due Diligence Results
For all responses that indicated a smelter, our third-party provider compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as "Conflict-Free," our vendor confirmed that the name was listed by the RMI as a validated conflict-free smelter. As of May 6, 2022, we have identified 336 smelters or refiners that were reported by our suppliers via the CMRT. Annex I lists, to the best of our knowledge, the majority of the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Annex I any smelters or refiners that we have not been able to validate. Annex II includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI.
Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 230 smelters that are deemed RMAP Conformant – this indicates these smelters or refiners are conformant with the RMAP assessment protocols. There are 19 more smelters or refiners that are deemed RMAP Active - smelters and refiners on the Active list have committed to undergo a RMAP audit or are
participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewellery Program Chain-of-Custody Certification. There are an additional eight smelters or refiners that are deemed non-conformant. The remaining 87 smelters listed have not yet been confirmed as Conflict-Free. We have assessed these facilities and determined that most of these are of low risk due to their geographic location.
59 out of 64 smelters either identified as sourcing conflict minerals from Covered Countries or those which Regal Rexnord has reason to believe source conflict minerals from the Covered Countries were compliant with the RMAP assessment.
Risk Mitigation Process
The following is an outline of the process we have developed and are currently working relative to the suppliers who have indicated that red flag smelters are in their supply chains - and, thus, Regal Rexnord’s.
| | | | | | | | |
| • | Since the suppliers provided company or divisional level information during our RCOI rather than part specific information, we will conduct a review of engineering drawings and material specifications and conduct chemical analysis as appropriate to identify which if any of the parts supplied by the suppliers contain gold. If described information is inconclusive, engage with the supplier to confirm the presence of gold in accordance with the requirements of the SEC rules, in the parts being supplied to Regal Rexnord. |
| | | | | | | | |
| • | For parts where gold is confirmed intentionally added and necessary to functionality, request smelter information specific to the gold or tin used in those parts. |
| | | | | | | | |
| • | If the smelters so identified are linked to the gold used in the parts, ensure that suppliers are actively trying to remove these smelters from their supply chains and will communicate with Regal Rexnord the results of their activities. |
| | | | | | | | |
| • | For suppliers failing to actively remove or failing to communicate their progress to remove these smelters from their supply chains, Regal Rexnord will initiate further escalation steps with the supplier up to removing these suppliers from our supply chain. |
Facility and Mine Information
Based on the information provided by our suppliers and our own due diligence efforts, we believe that, to the best of our knowledge, the majority of the smelters that may have been used to process the Conflict Minerals in our products include the smelters listed in Annex 1 below. Information regarding the mines from which minerals processed at these smelters were sourced is not always publicly available and was not disclosed by these smelters. Accordingly, we are not able to identify with certainty all of the countries of origin of the conflict minerals processed at the indicated smelters.
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Regal Rexnord. A number of factors could introduce errors or otherwise affect our conclusion. These factors include, but are not limited to the following:
| | | | | | | | |
| 1. | Gaps in supplier data |
| 2. | Gaps in knowledge of the chemistry of the component parts and materials provided by suppliers |
| 3. | Gaps in smelter data and the source of their conflict minerals |
| 4. | Errors or omissions in survey responses provided by suppliers |
| 5. | Errors or omissions by smelters |
| 6. | Gaps in supplier education and knowledge |
| 7. | Supplier uncertainty regarding country of operation of the smelter and/or refiner versus country of origin of the conflict minerals |
| 8. | Not all instances of conflict minerals necessary to the functionality or production of our Covered Products were identified |
| 9. | Timeliness of data |
| 10. | Public information not discovered during a reasonable search |
| 11. | Errors in public data |
| 12. | Language barriers and translation |
| 13. | Supplier and smelter unfamiliarity with the protocol relating to the Rule |
| 14. | Oversights or errors in conflict free smelter audits |
| 15. | DRC-sourced materials being declared secondary materials |
| 16. | Companies going out of business in 2021 |
| 17. | Certification programs not being equally advanced for all industry segments and metals |
| 18. | Smuggling of DRC conflict minerals to countries beyond the Covered Countries |
Process Improvement Considerations
We intend to take the following steps to improve our processes surrounding conflict minerals to further mitigate any risk that the necessary conflict minerals in our Covered Products could benefit armed groups in the Covered Countries:
| | | | | | | | |
| 1. | Engage with suppliers and direct them to training resources to attempt to increase the response rate and to improve the quality of the content of suppliers’ conflict minerals information, especially smelter information. |
| 2. | Identify those suppliers who do not have a conflict minerals program and work with the suppliers to set up a program. |
| 3. | Engage with suppliers to encourage them to implement responsible sourcing and to have them encourage smelters and refiners to obtain a “conflict-free” designation from an independent third-party auditor. |
| 4. | For suppliers found to be using smelters sourcing from, or for which we have reason to believe are sourcing from, the Covered Countries and who are not conformant with the requirements of the RMAP, we encourage them to use RMAP compliant smelters. |
| 5.
| Expand our knowledge of the chemistry of the component parts and materials contained in our Covered Products by conducting chemical analysis and/or requesting specific chemical information from our suppliers on each component part or material used in the Covered Products to further identify those suppliers providing conflict minerals and their derivatives. To date we have conducted an analysis of over 82,754 component parts. |
Annex I
List of Smelters and Refiners Identified in Regal Rexnord Corporation’s Supply Chain
| | | | | | | | | | | | | | |
| Subject Mineral | | Standard Smelter Name | | Country |
| Gold | | 8853 S.p.A. | | ITALY |
| Gold | | Abington Reldan Metals, LLC | | UNITED STATES |
| Gold | | Advanced Chemical Company | | UNITED STATES |
| Gold | | African Gold Refinery | | UGANDA |
| Gold | | Aida Chemical Industries Co., Ltd. | | JAPAN |
| Gold | | Al Etihad Gold Refinery DMCC | | UNITED ARAB EMIRATES |
| Gold | | Alexy Metals | | UNITED STATES |
| Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | GERMANY |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | UZBEKISTAN |
| Gold | | AngloGold Ashanti Corrego do Sitio Mineracao | | BRAZIL |
| Gold | | Argor-Heraeus S.A. | | SWITZERLAND |
| Gold | | Asahi Pretec Corp. | | JAPAN |
| Gold | | Asahi Refining Canada Ltd. | | CANADA |
| Gold | | Asahi Refining USA Inc. | | UNITED STATES |
| 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 |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | PHILIPPINES |
| Gold | | Boliden AB | | SWEDEN |
| Gold | | C. Hafner GmbH + Co. KG | | GERMANY |
| Gold | | C.I Metales Procesados Industriales SAS | | COLOMBIA |
| 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 | | Daye Non-Ferrous Metals Mining Ltd. | | CHINA |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | | GERMANY |
| Gold | | Dijllah Gold Refinery FZC | | UNITED ARAB EMIRATES |
| 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 | | GCC Gujrat Gold Centre Pvt. Ltd. | | INDIA |
| Gold | | Geib Refining Corporation | | UNITED STATES |
| 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 |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | CHINA |
| Gold | | Heimerle + Meule GmbH | | GERMANY |
| Gold | | Heraeus Metals Hong Kong Ltd. | | CHINA |
| Gold | | Heraeus Precious Metals GmbH & Co. KG | | GERMANY |
| 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 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 |
| 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 |
| 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 |
| Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN |
| Gold | | MD Overseas | | INDIA |
| Gold | | Metal Concentrators SA (Pty) Ltd. | | SOUTH AFRICA |
| Gold | | Metallix Refining Inc. | | UNITED STATES |
| 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 |
| 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 | | 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 | | OJSC Novosibirsk Refinery | | RUSSIAN FEDERATION |
| Gold | | PAMP S.A. | | SWITZERLAND |
| Gold | | Pease & Curren | | UNITED STATES |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | CHINA |
| Gold | | Planta Recuperadora de Metales SpA | | CHILE |
| Gold | | Prioksky Plant of Non-Ferrous Metals | | RUSSIAN FEDERATION |
| Gold | | PT Aneka Tambang (Persero) Tbk | | INDONESIA |
| Gold | | PX Precinox S.A. | | SWITZERLAND |
| Gold | | QG Refining, LLC | | UNITED STATES |
| 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 |
| Gold | | Safimet S.p.A | | ITALY |
| Gold | | SAFINA A.S. | | CZECHIA |
| Gold | | Sai Refinery | | INDIA |
| Gold | | Samduck Precious Metals | | KOREA, REPUBLIC OF |
| Gold | | Samwon Metals Corp. | | KOREA, REPUBLIC OF |
| | | | | | | | | | | | | | |
| Gold | | Sancus ZFS (L’Orfebre, SA) | | COLOMBIA |
| Gold | | Sellem Industries Ltd. | | MAURITANIA |
| Gold | | SEMPSA Joyeria Plateria S.A. | | SPAIN |
| 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 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 |
| Gold | | Super Dragon Technology Co., Ltd. | | CHINA |
| Gold | | T.C.A S.p.A | | ITALY |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | JAPAN |
| Gold | | The Refinery of Shandong Gold Mining Co., Ltd. | | CHINA |
| 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 |
| Gold | | Valcambi S.A. | | SWITZERLAND |
| Gold | | Value Trading | | BELGIUM |
| 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 |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA |
| Tantalum | | D Block Metals, LLC | | UNITED STATES |
| 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 |
| Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA |
| Tantalum | | H.C. Starck Co., Ltd. | | THAILAND |
| Tantalum | | H.C. Starck Hermsdorf GmbH | | GERMANY |
| Tantalum | | H.C. Starck Inc. | | UNITED STATES |
| | | | | | | | | | | | | | |
| Tantalum | | H.C. Starck Ltd. | | JAPAN |
| Tantalum | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY |
| Tantalum | | H.C. Starck Tantalum and Niobium GmbH | | GERMANY |
| 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 Blue Metals | | MEXICO |
| Tantalum | | LSM Brasil S.A. | | BRAZIL |
| 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 | | QuantumClean | | UNITED STATES |
| Tantalum | | Resind Industria e Comercio Ltda. | | BRAZIL |
| Tantalum | | Solikamsk Magnesium Works OAO | | RUSSIAN FEDERATION |
| Tantalum | | Taki Chemical Co., Ltd. | | JAPAN |
| Tantalum | | Telex Metals | | UNITED STATES |
| Tantalum | | Ulba Metallurgical Plant JSC | | KAZAKHSTAN |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA |
| Tantalum | | Yancheng Jinye New Material Technology Co., Ltd. | | CHINA |
| Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | CHINA |
| Tin | | Alpha | | UNITED STATES |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | VIET NAM |
| 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 Venus Inti Perkasa | | INDONESIA |
| Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | | CHINA |
| Tin | | Dowa | | JAPAN |
| 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 | | 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 | | Melt Metais e Ligas S.A. | | BRAZIL |
| Tin | | Metallic Resources, Inc. | | UNITED STATES |
| Tin | | Metallo Belgium N.V. | | BELGIUM |
| Tin | | Metallo Spain S.L.U. | | SPAIN |
| Tin | | Mineracao Taboca S.A. | | BRAZIL |
| 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 Processing Plant Ltd. | | 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 Serumpun | | INDONESIA |
| Tin | | PT Belitung Industri Sejahtera | | INDONESIA |
| Tin | | PT Bukit Timah | | INDONESIA |
| Tin | | PT Cipta Persada Mulia | | INDONESIA |
| Tin | | PT Masbro Alam Stania | | 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 Prima Timah Utama | | INDONESIA |
| Tin | | PT Rajawali Rimba Perkasa | | INDONESIA |
| 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 | | Soft Metais Ltda. | | BRAZIL |
| Tin | | Super Ligas | | BRAZIL |
| Tin | | Thai Nguyen Mining and Metallurgy Co., Ltd. | | VIET NAM |
| Tin | | Thaisarco | | THAILAND |
| Tin | | Tin Technology & Refining | | UNITED STATES |
| 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 Tin Company Limited | | 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 | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | China Molybdenum Co., Ltd. | | CHINA |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | CHINA |
| Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | | CHINA |
| Tungsten | | Cronimet Brasil Ltda | | BRAZIL |
| Tungsten | | Fujian Ganmin RareMetal Co., Ltd. | | CHINA |
| Tungsten | | Fujian Xinlu Tungsten | | CHINA |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA |
| Tungsten | | GEM Co., Ltd. | | CHINA |
| Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | CHINA |
| Tungsten | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY |
| Tungsten | | H.C. Starck Tungsten GmbH | | GERMANY |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | CHINA |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | 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 | | Kennametal Fallon | | UNITED STATES |
| | | | | | | | | | | | | | |
| Tungsten | | Kennametal Huntsville | | UNITED STATES |
| Tungsten | | KGETS Co., Ltd. | | KOREA, REPUBLIC OF |
| Tungsten | | Lianyou Metals Co., Ltd. | | TAIWAN, PROVINCE OF CHINA |
| Tungsten | | LLC Volstok | | RUSSIAN FEDERATION |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Masan Tungsten Chemical LLC (MTC) | | VIET NAM |
| Tungsten | | Moliren Ltd. | | RUSSIAN FEDERATION |
| Tungsten | | Niagara Refining LLC | | UNITED STATES |
| 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 |
| 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 | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA |
Annex II
List of Countries of Origin for Subject Minerals
Afghanistan, Åland Islands, Albania, American Samoa, Andorra, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia (Plurinational State of), 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, VietNam, Zambia, 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 is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.
* Suppliers’ CMRTs identified smelters that were not subject to U.S. economic sanctions during reporting year 2021, but now appear to be owned by parties sanctioned by the U.S. Department of the Treasury’s Office of Foreign Assets Control following the Russian Government’s invasion of Ukraine. Suppliers reporting these and other potentially problematic smelters in reporting year 2022 will be subject to an escalation process.
