UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM SD

Specialized Disclosure Report

Graco Inc.

(Exact name of registrant as specified in its charter)

 

Minnesota

001-09249

41-0285640

(State or other Jurisdiction of Incorporation or organization)

(Commission File Number)

(IRS Employer Identification No.)

 

88 – 11th Avenue Northeast Minneapolis, Minnesota

55413

(Address of principal executive offices)

(Zip Code)

 

Joseph James Humke, (612) 623-6000
(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

¨ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the fiscal year ended____________.

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Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

This Form SD of Graco Inc. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period of January 1 to December 31, 2021.

A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD and is publicly available at www.graco.com.

Item 1.02 Exhibit

As specified in Section 3, Item 3.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.

Section 2 - Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

Section 3 - Exhibits

Item 3.01 Exhibits

The following exhibit is filed as part of this report.

Exhibit No.						Description
1.01						Conflict Minerals Report of Graco Inc. as required by Items 1.01 and 1.02 of this Form SD

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Signature

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

GRACO INC.

Date:

May 27, 2022

By:

/s/ Joseph James Humke

Joseph James Humke

Executive Vice President, General Counsel and Corporate Secretary

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EXHIBIT INDEX

Exhibit

Description

Method of Filing

1.01

Conflict Minerals Report of Graco Inc. as required by Items 1.01 and 1.02 of this Form SD

Filed Electronically

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Exhibit 1.01

GRACO INC.

Conflict Minerals Report

For the reporting period from January 1, 2021 to December 31, 2021

This is the Conflict Minerals Report (“Report”) of Graco Inc. (“Graco,” “we,” “our” or “us”) for the 2021 calendar year, pursuant to Rule 13p-1 of the Securities Exchange Act of 1934 (the “Rule”). Certain capitalized terms used but not defined herein have the meanings assigned to them in the Rule. This Report includes the activities of all subsidiaries of Graco that were required to be consolidated during the reporting period, other than any acquired companies that are not yet required by the Rule to be included in this Report.

The Rule requires certain SEC reporting companies that manufacture or contract to be manufactured products for which tantalum, tin, tungsten or gold (“3TG”) are necessary to the functionality or production of such products to disclose annually whether any of the 3TG in such products originated in the Democratic Republic of the Congo or one of its adjoining countries (collectively, the “Covered Countries”). If the company knows that the 3TG necessary to its products originated in the Covered Countries, or has reason to believe that the 3TG may have originated in the Covered Countries and did not or may not have come from scrap or recycled sources, the company must exercise due diligence on the source and chain of custody of the 3TG and prepare and file a Report describing its due diligence measures.

Graco Overview

Graco is a multi-national manufacturer of systems and equipment that move, measure, control, dispense and spray fluid and powder materials. Our systems and equipment are used in the manufacturing, processing, construction and maintenance industries. Our primary products include air, electric, gas and hydraulic pumps and sprayers; electronic and mechanical controls and sensors; and automatic and manual dispense valves, meters and spray guns. Our products that contain control boards, certain other electronic components, motors, engines, batteries, spray tips, and certain pumps and valves contain 3TG.

Company Management Systems

We have established management systems to support the execution of our Conflict Minerals program and to ensure it operates effectively and is sustainable into the future. Our management systems include the following:

Conflict Minerals Policy

We have adopted a policy affirming our commitment to conducting business fairly and ethically with respect for human rights and in compliance with all applicable laws and regulations, including the

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Rule. Our policy also affirms our support for the responsible sourcing of 3TG through our global supply chain, and states that we are actively and diligently working with our global supply chain partners to determine the origin of any 3TG they may supply to us, and that we will continue to work with them towards the goal of providing greater supply chain transparency and responsible sourcing. Our policy is available on our website at http://www.graco.com/us/en/about-graco/conflict-minerals.html.

Internal Team

We have a cross-functional team with executive-level sponsorship and support that implemented and oversees our Conflict Minerals compliance program. The cross-functional team includes employees from functional groups such as procurement, finance, operations, legal and information systems. We report our Conflict Minerals findings to our team and designated members of senior management.

Control Systems

We have contributed to industry efforts to support the responsible sourcing of 3TG through our membership in the Responsible Minerals Initiative (RMI), which has helped develop standards, best practices and tools that benefit all companies working to end the link between 3TG and conflict in the Covered Countries. In prior years, we have also participated in the National Association of Manufacturers Conflict Minerals Working Group, the Manufacturers Alliance for Productivity and Innovation Conflict Minerals Forum and the Twin Cities Conflict Minerals Task Force. In addition, we retain a third party service provider to assist with collecting, evaluating and retaining supply chain information, identifying potential supply chain risks, and developing and implementing additional engagement steps with suppliers.

Supplier Engagement

We have a process in place to engage relevant first-tier suppliers to educate them about the Rule and request information from them regarding 3TG. We also have a process in place to try to improve the number and quality of supplier responses year over year. To help ensure suppliers understand the Rule and how to properly respond to requests for information from us regarding 3TG, we provide our suppliers access to on-line Conflict Minerals support materials, help desk support and other multilingual resources. We also respond to supplier inquiries during the information gathering process and take steps to address supplier issues that arise during that process.

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Grievance Mechanism

We have an established grievance mechanism through which employees, suppliers, customers and other interested parties may communicate their concerns to us.

Records Management

We have a process in place to collect, analyze and retain Conflict Minerals information received from our suppliers. We will maintain records relating to Conflict Minerals supply chain due diligence in accordance with our records retention policy, which provides for retention of such records for five years.

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 any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. As a member of the RMI, we support the RMI’s efforts to carry out independent third-party audits of smelter and refiner due diligence activities and contribute to the improvement of smelter and refiner and upstream due diligence practices.

Report on Supply Chain Due Diligence

Graco has filed a Form SD and this Report with the Securities Exchange Commission. The filing is available on our website at https://www.graco.com/us/en/about-graco/conflict-minerals.html.

Reasonable Country of Origin Inquiry

Supply Chain

We do not directly source 3TG. Instead, we purchase components and raw materials from third party suppliers that are multiple layers removed from the smelters and refiners of the 3TG that are in the components and raw materials ultimately supplied to us. We evaluated our products and determined that certain products manufactured during calendar year 2021 were manufactured with components and raw materials that contain or likely contain 3TG that are necessary to the functionality or production of those products. We then identified the first-tier suppliers of those components and raw materials.

Request for Information

We use a third-party software solution to automate our reasonable country of origin inquiry (“RCOI”) process and improve the quality and efficiency of our Conflict Minerals compliance program. With this software solution, we surveyed all of our in-scope first-tier suppliers using the Conflict Minerals Reporting Template (CMRT) (version 6.1) developed by the RMI. We also provided these suppliers with

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access to on-line Conflict Minerals support materials to help educate them on the Rule and to aid them in responding to the survey.

Survey Responses

All submitted CMRTs were reviewed and classified as valid or invalid. We tracked supplier responses and identified instances where suppliers submitted an invalid response (due to missing information or inconsistencies across responses) or did not provide us with a timely response, and followed up with those suppliers and requested that they submit a valid CMRT. Suppliers were provided with guidance on how to correct any validation errors in the form of feedback to their CMRT submissions, training courses and direct engagement help from a multilingual service team. As of May 2, 2022, there was a small percentage of invalid supplier CMRTs that were not corrected.

We compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters and refiners maintained by the RMI to determine the validity and the RMAP assessment status of each of the smelters and refiners identified by our suppliers. Our suppliers identified a total of 335 smelters and refiners that appear on the lists maintained by the RMI. Of these 335 smelters and refiners, 230 have been deemed conformant with the RMAP assessment protocols by an independent third party auditor according to the RMI list of conformant smelters and refiners. Based on information provided by the RMI, a further 19 have agreed to undergo or are currently undergoing a third-party audit. Most of the CMRTs we received were completed on a company or supplier-defined level, which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TG contained in our products.

Identification and Assessment of Risk

Risks are identified based on criteria established for supplier responses in the CMRT. Risks are addressed by contacting the supplier, gathering pertinent information, and performing an assessment of the supplier’s Conflict Minerals status. The primary risk identified relates to the nature of responses received. Many suppliers provided information at a company or supplier-defined level, which prevents us from determining whether the smelters or refiners listed by those suppliers actually processed the 3TG contained in the components and raw materials supplied to us. Additionally, many suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they were unable to provide a complete list of all smelters and refiners in their supply chains.

Smelters and refiners that are not conformant with the RMAP assessment protocols or have not committed to undergo an RMAP assessment also pose a risk. When a CMRT is received, the smelters and refiners that are reported are examined. Each facility that meets the RMI definition of a smelter or refiner of 3TG is assigned a risk level based on: (i) geographic proximity to the Covered Countries; (ii) known mineral source country of origin; (iii) RMI Responsible Minerals Assurance Process (RMAP) audit status; (iv) credible evidence of unethical or conflict sourcing; and (v) peer assessments conducted by credible

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third-party sources. When certain high-risk facilities are reported, risk mitigation activities are initiated, including sending an automated reply instructing the supplier to take risk mitigation actions, including submission of a product-specific CMRT to better identify the connection to components and raw materials supplied to us.

In addition, suppliers are evaluated on the strength of their Conflict Minerals programs based on whether: (i) they have a conflict minerals sourcing policy; (ii) they have implemented due diligence measures for responsible sourcing; (iii) they review information received from their suppliers against their own expectations; and (iv) their review process includes corrective action management. We evaluate and track the strength of their programs so we can make risk mitigation decisions as their programs progress.

Through our membership with the RMI, we encourage smelters and refiners to participate in the RMAP. Any smelters and refiners that were reported by our suppliers that were not part of the RMAP were also contacted directly to encourage them to participate in the RMAP.

Design of Due Diligence Measures

Our due diligence measures have been designed to be in conformity, in all material respects, with the applicable provisions of the internationally recognized framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, and the related supplements on 3TG.

Due Diligence Measures Performed

The due diligence measures we performed include defining roles and responsibilities for our cross-functional Conflict Minerals team and designated members of senior management; reporting our Conflict Minerals findings to our cross-functional Conflict Minerals team and designated members of senior management; and comparing the smelter and refiner information received from our suppliers against the RMI list of smelters and refiners that are conformant with the RMAP assessment protocols, the RMI list of smelters and refiners that have committed to undergo an RMAP audit, and the RMI reference list of known smelters and refiners. With respect to smelters and refiners that were on the RMI list of known smelters and refiners and certain other smelters and refiners that were not on the RMI list of known smelters and refiners, we reviewed certain other publicly available sources of information.

Due Diligence Results

A majority of suppliers surveyed responded to the survey. The majority of those who responded provided data at a company or supplier-defined level rather than at a product level, and reported that their products do not contain 3TG or, if they do, the 3TG in their products does not come from the Covered Countries. A number of suppliers reported that they do not know whether the 3TG in their products comes from the Covered Countries or from scrap or recycled sources. A small number of suppliers reported that

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the 3TG in their products comes from or may come from the Covered Countries, and some of these suppliers further reported that some of the 3TG in their products comes from scrap or recycled sources.

Our suppliers identified over 500 entities in their supply chains as part of their smelter and refiner lists. However, not all of the entities identified by these suppliers appear to be actual smelters or refiners as the total number of entities identified exceeds the number of entities on the RMI list of known smelters and refiners. In addition, not all of the actual smelters and refiners identified by our suppliers may have processed the 3TG in the components and raw materials supplied to us. In some cases, our suppliers may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in information received from their suppliers or for other reasons.

Schedule 1 to this Report contains a list of legitimate smelters and refiners identified by our suppliers, and whose materials and components may or may not be in our products, including the RMAP assessment status of each smelter and refiner as of May 2, 2022. (Schedule 1 excludes any smelters and refiners identified by our suppliers that do not appear on the RMI list of known smelters and refiners.) 230 of the smelters and refiners identified by our suppliers have been deemed conformant with the RMAP assessment protocols by an independent third party auditor according to the RMI list of conformant smelters and refiners. 19 of the smelters and refiners identified by our suppliers have not yet been deemed conformant but have committed to undergo an RMAP audit according to the RMI list of smelters and refiners who have committed to undergo an RMAP audit. 69 of the smelters and refiners identified by our suppliers have not been deemed conformant and have not begun participating in an independent third party audit program. 17 of the smelters and refiners identified by our suppliers have failed an RMAP audit, refused to participate in the RMAP assessment process, or have failed to provide adequate access to their facilities to complete the RMAP assessment process. Schedule 2 to this Report includes an aggregate list of the countries of origin from which the smelters and refiners identified on Schedule 1 collectively source 3TG, based on information provided by the RMI.

Given that the majority of suppliers who responded to the survey provided their responses at a company or supplier-defined level rather than at a level specific to the materials and components they supplied to us, we were unable to determine which, if any, of the smelters and refiners listed in their responses were the actual source of the 3TG they supplied.

Determination

Given that a number of suppliers did not respond to our survey, the majority of responses we received were provided at a company or supplier-defined level not specific to the components and raw materials supplied to us, and that a number of suppliers do not know the origin of the 3TG in their products, we do not have sufficient information to determine the origin of the 3TG in our products subject to this Report, whether the 3TG came from scrap or recycled sources, the specific facilities used to process the 3TG, or the country of origin or the mine or location of origin of the 3TG.

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Steps to be Taken to Mitigate Risk in 2022

We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TG in our products finance or benefit armed groups in the Covered Countries:

•Continue to engage with our direct suppliers to increase the response rate to our survey and improve the content and quality of their responses; and

•Continue to engage with our direct suppliers to receive more information farther upstream regarding the source and chain of custody of the 3TG in the components and raw materials they supply to us.

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Schedule 1

Metal

Standard Smelter or Refiner Name

Facility Location (Country)

Smelter or Refiner Status*

Gold

8853 S.p.A.

Italy

Conformant

Gold

Abington Reldan Metals, LLC

United States

Non Conformant

Gold

Advanced Chemical Company

United States

Conformant

Gold

African Gold Refinery

Uganda

Not Enrolled

Gold

Aida Chemical Industries Co., Ltd.

Japan

Conformant

Gold

Al Etihad Gold Refinery DMCC

United Arab Emirates

Conformant

Gold

Alexy Metals

United States

Active

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

Germany

Conformant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

Uzbekistan

Conformant

Gold

AngloGold Ashanti Córrego do Sítio Mineração

Brazil

Conformant

Gold

Argor-Heraeus S.A.

Switzerland

Conformant

Gold

Asahi Pretec Corp.

Japan

Conformant

Gold

Asahi Refining Canada Ltd.

Canada

Conformant

Gold

Asahi Refining USA Inc.

United States

Conformant

Gold

Asaka Riken Co., Ltd.

Japan

Conformant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

Turkey

Not Enrolled

Gold

AU Traders and Refiners

South Africa

Non Conformant

Gold

Augmont Enterprises Private Limited

India

Active

Gold

Aurubis AG

Germany

Conformant

Gold

Bangalore Refinery

India

Conformant

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Philippines

Conformant

Gold

Boliden AB

Sweden

Conformant

Gold

C. Hafner GmbH + Co. KG

Germany

Conformant

Gold

C. I. Metales Procesados Industriales SAS

Colombia

Active

Gold

Caridad

Mexico

Not Enrolled

Gold

CCR Refinery - Glencore Canada Corporation

Canada

Conformant

Gold

Cendres + Métaux S.A.

Switzerland

Conformant

Gold

CGR Metalloys Pvt Ltd.

India

Not Enrolled

Gold

Chimet S.p.A.

Italy

Conformant

Gold

Chugai Mining

Japan

Conformant

Gold

Daye Non-Ferrous Metals Mining Ltd.

China

Not Enrolled

Gold

Degussa Sonne / Mond Goldhandel GmbH

Germany

Not Enrolled

Gold

Dijllah Gold Refinery FZC

United Arab Emirates

Not Enrolled

Gold

Dowa

Japan

Conformant

Gold

DSC (Do Sung Corporation)

Republic of Korea

Conformant

Gold

Eco-System Recycling Co., Ltd. - East Plant

Japan

Conformant

Gold

Eco-System Recycling Co., Ltd. - North Plant

Japan

Conformant

Gold

Eco-System Recycling Co., Ltd. - West Plant

Japan

Conformant

Gold

Emerald Jewel Industry India Limited (Unit 1)

India

Not Enrolled

Gold

Emerald Jewel Industry India Limited (Unit 2)

India

Not Enrolled

Gold

Emerald Jewel Industry India Limited (Unit 3)

India

Not Enrolled

Gold

Emerald Jewel Industry India Limited (Unit 4)

India

Not Enrolled

Gold

Emirates Gold DMCC

United Arab Emirates

Conformant

Gold

Fidelity Printers and Refiners Ltd.

Zimbabwe

Not Enrolled

Gold

Fujairah Gold FZC

United Arab Emirates

Not Enrolled

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

India

Active

Gold

Geib Refining Corporation

United States

Conformant

Gold

Gold Coast Refinery

Ghana

Not Enrolled

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

China

Conformant

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

China

Not Enrolled

Gold

Guangdong Jinding Gold Limited

China

Not Enrolled

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Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

China

Not Enrolled

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

China

Not Enrolled

Gold

Heimerle + Meule GmbH

Germany

Conformant

Gold

Heraeus Metals Hong Kong Ltd.

China

Conformant

Gold

Heraeus Precious Metals GmbH & Co. KG

Germany

Conformant

Gold

Hunan Chenzhou Mining Co., Ltd.

China

Not Enrolled

Gold

Hunan Guiyang Yinxing Nonferrous Smelting Co., Ltd.

China

Not Enrolled

Gold

HwaSeong CJ Co., Ltd.

Republic of Korea

Not Enrolled

Gold

Industrial Refining Company

Belgium

Non Conformant

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

China

Conformant

Gold

International Precious Metal Refiners

United Arab Emirates

Not Enrolled

Gold

Ishifuku Metal Industry Co., Ltd.

Japan

Conformant

Gold

Istanbul Gold Refinery

Turkey

Conformant

Gold

Italpreziosi

Italy

Conformant

Gold

JALAN & Company

India

Not Enrolled

Gold

Japan Mint

Japan

Conformant

Gold

Jiangxi Copper Co., Ltd.

China

Conformant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Russian Federation

Not Enrolled

Gold

JSC Uralelectromed

Russian Federation

Non Conformant

Gold

JX Nippon Mining & Metals Co., Ltd.

Japan

Non Conformant

Gold

K.A. Rasmussen

Norway

Not Enrolled

Gold

Kaloti Precious Metals

United Arab Emirates

Not Enrolled

Gold

Kazakhmys Smelting LLC

Kazakhstan

Not Enrolled

Gold

Kazzinc

Kazakhstan

Conformant

Gold

Kennecott Utah Copper LLC

United States

Conformant

Gold

KGHM Polska Miedz Spolka Akcyjna

Poland

Conformant

Gold

Kojima Chemicals Co., Ltd.

Japan

Conformant

Gold

Korea Zinc Co., Ltd.

Republic of Korea

Conformant

Gold

Kundan Care Products Ltd.

India

Not Enrolled

Gold

Kyrgyzaltyn JSC

Kyrgyzstan

Non Conformant

Gold

Kyshtym Copper-Electrolytic Plant ZAO

Russian Federation

Not Enrolled

Gold

L’azurde Company For Jewelry

Saudi Arabia

Not Enrolled

Gold

Lingbao Gold Co., Ltd.

China

Not Enrolled

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

China

Not Enrolled

Gold

L’Orfebre S.A.

Andorra

Conformant

Gold

LS-NIKKO Copper Inc.

Republic of Korea

Conformant

Gold

LT Metal Ltd.

Republic of Korea

Conformant

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

China

Not Enrolled

Gold

Marsam Metals

Brazil

Conformant

Gold

Materion

United States

Conformant

Gold

Matsuda Sangyo Co., Ltd.

Japan

Conformant

Gold

MD Overseas

India

Not Enrolled

Gold

Metal Concentrators SA (Pty) Ltd.

South Africa

Conformant

Gold

Metallix Refining Inc.

United States

Not Enrolled

Gold

Metalor Technologies (Hong Kong) Ltd.

China

Conformant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

Singapore

Conformant

Gold

Metalor Technologies (Suzhou) Ltd.

China

Conformant

Gold

Metalor Technologies S.A.

Switzerland

Conformant

Gold

Metalor USA Refining Corporation

United States

Conformant

Gold

Metalúrgica Met-Mex Peñoles S.A. De C.V.

Mexico

Conformant

Gold

Mitsubishi Materials Corporation

Japan

Conformant

Gold

Mitsui Mining and Smelting Co., Ltd.

Japan

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

India

Conformant

Gold

Modeltech Sdn Bhd

Malaysia

Non Conformant

Gold

Morris and Watson

New Zealand

Not Enrolled

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Gold

Moscow Special Alloys Processing Plant

Russian Federation

Non Conformant

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

Turkey

Conformant

Gold

Navoi Mining and Metallurgical Combinat

Uzbekistan

Conformant

Gold

NH Recytech Company

Republic of Korea

Non Conformant

Gold

Nihon Material Co., Ltd.

Japan

Conformant

Gold

Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH

Austria

Conformant

Gold

Ohura Precious Metal Industry Co., Ltd.

Japan

Conformant

Gold

OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)

Russian Federation

Non Conformant

Gold

OJSC Novosibirsk Refinery

Russian Federation

Non Conformant

Gold

PAMP S.A.

Switzerland

Conformant

Gold

Pease & Curren

United States

Not Enrolled

Gold

Penglai Penggang Gold Industry Co., Ltd.

China

Not Enrolled

Gold

Planta Recuperadora de Metales SpA

Chile

Conformant

Gold

Prioksky Plant of Non-Ferrous Metals

Russian Federation

Non Conformant

Gold

PT Aneka Tambang (Persero) Tbk

Indonesia

Conformant

Gold

PX Précinox S.A.

Switzerland

Conformant

Gold

QG Refining, LLC

United States

Not Enrolled

Gold

Rand Refinery (Pty) Ltd.

South Africa

Conformant

Gold

Refinery of Seemine Gold Co., Ltd.

China

Not Enrolled

Gold

REMONDIS PMR B.V.

Netherlands

Conformant

Gold

Royal Canadian Mint

Canada

Conformant

Gold

SAAMP

France

Conformant

Gold

Sabin Metal Corp.

United States

Not Enrolled

Gold

Safimet S.p.A

Italy

Conformant

Gold

SAFINA A.S.

Czech Republic

Conformant

Gold

Sai Refinery

India

Not Enrolled

Gold

Samduck Precious Metals

Republic of Korea

Conformant

Gold

Samwon Metals Corp.

Republic of Korea

Not Enrolled

Gold

Sancus ZFS (L’Orfebre, SA)

Colombia

Active

Gold

Sellem Industries Ltd.

Mauritania

Not Enrolled

Gold

SEMPSA Joyería Platería S.A.

Spain

Conformant

Gold

Shangdong Humon Smelting Co., Ltd.

China

Not Enrolled

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

China

Not Enrolled

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

China

Conformant

Gold

Shenzhen Zhonghenglong Real Industry Co., Ltd.

China

Not Enrolled

Gold

Shirpur Gold Refinery Ltd.

India

Not Enrolled

Gold

Sichuan Tianze Precious Metals Co., Ltd.

China

Conformant

Gold

Singway Technology Co., Ltd.

Taiwan

Conformant

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

Russian Federation

Non Conformant

Gold

Solar Applied Materials Technology Corp.

Taiwan

Conformant

Gold

Sovereign Metals

India

Not Enrolled

Gold

State Research Institute Center for Physical Sciences and Technology

Lithuania

Not Enrolled

Gold

Sudan Gold Refinery

Sudan

Not Enrolled

Gold

Sumitomo Metal Mining Co., Ltd.

Japan

Conformant

Gold

SungEel HiMetal Co., Ltd.

Republic of Korea

Conformant

Gold

Super Dragon Technology Co., Ltd.

Taiwan

Not Enrolled

Gold

T.C.A S.p.A

Italy

Conformant

Gold

Tanaka Kikinzoku Kogyo K.K.

Japan

Conformant

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

China

Conformant

Gold

Tokuriki Honten Co., Ltd.

Japan

Conformant

Gold

Tongling Nonferrous Metals Group Co., Ltd.

China

Not Enrolled

Gold

TOO Tau-Ken-Altyn

Kazakhstan

Conformant

Gold

Torecom

Republic of Korea

Conformant

Gold

Umicore Precious Metals Thailand

Thailand

Conformant

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Gold

Umicore S.A. Business Unit Precious Metals Refining

Belgium

Conformant

Gold

United Precious Metal Refining, Inc.

United States

Conformant

Gold

Valcambi S.A.

Switzerland

Conformant

Gold

Value Trading

Belgium

Not Enrolled

Gold

Western Australian Mint trading as The Perth Mint

Australia

Conformant

Gold

WIELAND Edelmetalle GmbH

Germany

Conformant

Gold

Yamakin Co., Ltd.

Japan

Conformant

Gold

Yokohama Metal Co., Ltd.

Japan

Conformant

Gold

Yunnan Copper Industry Co., Ltd.

China

Not Enrolled

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

China

Conformant

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

China

Conformant

Tantalum

D Block Metals, LLC

United States

Conformant

Tantalum

F&X Electro-Materials Ltd.

China

Conformant

Tantalum

FIR Metals & Resource Ltd.

China

Conformant

Tantalum

Global Advanced Metals Aizu

Japan

Conformant

Tantalum

Global Advanced Metals Boyertown

United States

Conformant

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

China

Conformant

Tantalum

H.C. Starck Co., Ltd.

Thailand

Conformant

Tantalum

H.C. Starck Hermsdorf GmbH

Germany

Conformant

Tantalum

H.C. Starck Inc.

United States

Conformant

Tantalum

H.C. Starck Ltd.

Japan

Conformant

Tantalum

H.C. Starck Smelting GmbH & Co. KG

Germany

Conformant

Tantalum

H.C. Starck Tantalum and Niobium GmbH

Germany

Conformant

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

China

Conformant

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

China

Conformant

Tantalum

Jiangxi Tuohong New Raw Material

China

Conformant

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

China

Conformant

Tantalum

Jiujiang Tanbre Co., Ltd.

China

Conformant

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

China

Conformant

Tantalum

KEMET Blue Metals

Mexico

Conformant

Tantalum

LSM Brasil S.A.

Brazil

Conformant

Tantalum

Metallurgical Products India Pvt., Ltd.

India

Conformant

Tantalum

Mineracao Taboca S.A.

Brazil

Conformant

Tantalum

Mitsui Mining and Smelting Co., Ltd.

Japan

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

China

Conformant

Tantalum

NPM Silmet AS

Estonia

Conformant

Tantalum

QuantumClean

United States

Conformant

Tantalum

Resind Industria e Comercio Ltda.

Brazil

Conformant

Tantalum

Solikamsk Magnesium Works OAO

Russian Federation

Conformant

Tantalum

Taki Chemical Co., Ltd.

Japan

Conformant

Tantalum

Telex Metals

United States

Conformant

Tantalum

Ulba Metallurgical Plant JSC

Kazakhstan

Conformant

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

China

Conformant

Tantalum

Yancheng Jinye New Material Technology Co., Ltd.

China

Conformant

Tantalum

Yangling Jincheng Tantalum and Niobium Co., Ltd.

China

Conformant

Tin

Alpha

United States

Conformant

Tin

An Vinh Joint Stock Mineral Processing Company

Vietnam

Not Enrolled

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

China

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

China

Conformant

Tin

China Tin Group Co., Ltd.

China

Conformant

Tin

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

Brazil

Active

Tin

CRM Synergies

Spain

Conformant

Tin

CV Venus Inti Perkasa

Indonesia

Active

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

China

Non Conformant

11

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Tin

Dowa

Japan

Conformant

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

Vietnam

Non Conformant

Tin

EM Vinto

Bolivia

Conformant

Tin

Estanho de Rondônia S.A.

Brazil

Conformant

Tin

Fabrica Auricchio Industria e Comercio Ltda.

Brazil

Conformant

Tin

Fenix Metals

Poland

Conformant

Tin

Gejiu City Fuxiang Industry & Trade Co., Ltd.

China

Not Enrolled

Tin

Gejiu Kai Meng Industry and Trade LLC

China

Non Conformant

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

China

Conformant

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

China

Conformant

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

China

Conformant

Tin

Guangdong Hanhe Non-ferrous Metal Limited Company

China

Conformant

Tin

Jiangxi New Nanshan Technology Ltd.

China

Conformant

Tin

Luna Smelter, Ltd.

Rwanda

Conformant

Tin

Ma’ Anshan Weitai Tin Co., Ltd.

China

Conformant

Tin

Magnu’s Minerais Metais e Ligas Ltda.

Brazil

Conformant

Tin

Malaysia Smelting Corporation (MSC)

Malaysia

Conformant

Tin

Melt Metais e Ligas S.A.

Brazil

Not Enrolled

Tin

Metallic Resources, Inc.

United States

Conformant

Tin

Metallo Belgium N.V.

Belgium

Conformant

Tin

Metallo Spain S.L.U.

Spain

Conformant

Tin

Mineracao Taboca S.A.

Brazil

Conformant

Tin

Minsur

Peru

Conformant

Tin

Mitsubishi Materials Corporation

Japan

Conformant

Tin

Modeltech Sdn Bhd

Malaysia

Non Conformant

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

Vietnam

Not Enrolled

Tin

Novosibirsk Processing Plant Ltd.

Russian Federation

Conformant

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

Thailand

Conformant

Tin

O.M. Manufacturing Philippines, Inc.

Philippines

Conformant

Tin

Operaciones Metalurgica S.A.

Bolivia

Conformant

Tin

Pongpipat Company Limited

Myanmar

Not Enrolled

Tin

Precious Minerals and Smelting Limited

India

Non Conformant

Tin

PT Aries Kencana Sejahtera

Indonesia

Active

Tin

PT Artha Cipta Langgeng

Indonesia

Conformant

Tin

PT ATD Makmur Mandiri Jaya

Indonesia

Conformant

Tin

PT Babel Inti Perkasa

Indonesia

Conformant

Tin

PT Babel Surya Alam Lestari

Indonesia

Conformant

Tin

PT Bangka Serumpun

Indonesia

Conformant

Tin

PT Bukit Timah

Indonesia

Active

Tin

PT Cipta Persada Mulia

Indonesia

Conformant

Tin

PT Masbro Alam Stania

Indonesia

Active

Tin

PT Menara Cipta Mulia

Indonesia

Conformant

Tin

PT Mitra Stania Prima

Indonesia

Conformant

Tin

PT Mitra Sukses Globalindo

Indonesia

Active

Tin

PT Panca Mega Persada

Indonesia

Not Enrolled

Tin

PT Prima Timah Utama

Indonesia

Conformant

Tin

PT Rajawali Rimba Perkasa

Indonesia

Conformant

Tin

PT Refined Bangka Tin

Indonesia

Conformant

Tin

PT Sariwiguna Binasentosa

Indonesia

Conformant

Tin

PT Stanindo Inti Perkasa

Indonesia

Conformant

Tin

PT Sukses Inti Makmur

Indonesia

Active

Tin

PT Timah Nusantra

Indonesia

Active

Tin

PT Timah Tbk Kundur

Indonesia

Conformant

Tin

PT Timah Tbk Mentok

Indonesia

Conformant

12

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Tin

PT Tinindo Inter Nusa

Indonesia

Conformant

Tin

PT Tirus Putra Mandiri

Indonesia

Not Enrolled

Tin

PT Tommy Utama

Indonesia

Not Enrolled

Tin

Resind Industria e Comercio Ltda.

Brazil

Conformant

Tin

Rui Da Hung

Taiwan

Conformant

Tin

Soft Metais Ltda.

Brazil

Conformant

Tin

Super Ligas

Brazil

Active

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

Vietnam

Conformant

Tin

Thaisarco

Thailand

Conformant

Tin

Tin Technology & Refining

United States

Conformant

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

Vietnam

Not Enrolled

Tin

VQB Mineral and Trading Group JSC

Vietnam

Not Enrolled

Tin

White Solder Metalurgia e Mineração Ltda.

Brazil

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

China

Conformant

Tin

Yunnan Tin Company Limited

China

Conformant

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

China

Non Conformant

Tungsten

A.L.M.T. Corp.

Japan

Conformant

Tungsten

ACL Metais Eireli

Brazil

Conformant

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

Brazil

Active

Tungsten

Artek LLC

Russian Federation

Not Enrolled

Tungsten

Asia Tungsten Products Vietnam Ltd.

Vietnam

Conformant

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

China

Conformant

Tungsten

China Molybdenum Co., Ltd.

China

Conformant

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

China

Conformant

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

China

Not Enrolled

Tungsten

Cronimet Brasil Ltda.

Brazil

Conformant

Tungsten

Fujian Ganmin RareMetal Co., Ltd.

China

Conformant

Tungsten

Fujian Xinlu Tungsten

China

Conformant

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

China

Conformant

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

China

Conformant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

China

Conformant

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

China

Conformant

Tungsten

GEM Co. Ltd.

China

Conformant

Tungsten

Global Tungsten & Powders Corp.

United States

Conformant

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

China

Conformant

Tungsten

H.C. Starck Smelting GmbH & Co.KG

Germany

Conformant

Tungsten

H.C. Starck Tungsten GmbH

Germany

Conformant

Tungsten

Hunan Chenzhou Mining Co., Ltd.

China

Conformant

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

China

Conformant

Tungsten

Hydrometallurg, JSC

Russian Federation

Conformant

Tungsten

Japan New Metals Co., Ltd.

Japan

Conformant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

China

Conformant

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

China

Conformant

Tungsten

Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.

China

Not Enrolled

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

China

Conformant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

China

Conformant

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

China

Conformant

Tungsten

JSC “Kirovgrad Hard Alloys Plant”

Russian Federation

Conformant

Tungsten

Kennametal Fallon

United States

Conformant

Tungsten

Kennametal Huntsville

United States

Conformant

Tungsten

KGETS Co., Ltd.

Republic of Korea

Conformant

Tungsten

Lianyou Metals Co., Ltd.

Taiwan

Conformant

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

China

Conformant

Tungsten

Masan Tungsten Chemical LLC

Vietnam

Conformant

Tungsten

Moliren Ltd.

Russian Federation

Conformant

13

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Tungsten

Niagara Refining LLC

United States

Conformant

Tungsten

NPP Tyazhmetprom LLC

Russian Federation

Active

Tungsten

OOO “Technolom” 1

Russian Federation

Active

Tungsten

OOO “Technolom” 2

Russian Federation

Active

Tungsten

Philippine Chuangxin Industrial Co., Inc.

Philippines

Conformant

Tungsten

Unecha Refractory metals plant

Russian Federation

Conformant

Tungsten

Wolfram Bergbau und Hütten AG

Austria

Conformant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

China

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

China

Conformant

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

China

Conformant

* “Conformant” means the smelter or refiner is included on the RMI list of smelters and refiners that have successfully completed an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment; “Active” means the smelter or refiner is included on the RMI list of smelters and refiners that have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment (these smelters or refiners may be in the pre-assessment, assessment, or corrective-action phases of the assessment); “Not Enrolled” means the smelter or refiner is listed on the RMI reference list of smelters and refiners but is not Conformant and is not currently participating in an RMAP assessment; and “Non Conformant” means the smelter or refiner is listed on the RMI list of smelters and refiners and has failed an RMAP assessment, refuses to participate in the RMAP assessment process, or does not provide adequate access to facilities to complete the RMAP assessment. The compliance status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by us.

14

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Schedule 2

The following 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.

Argentina, Armenia, Australia, Austria, Azerbaijan, Benin, Bolivia, Botswana, Brazil, Bulgaria, Burkina Faso, Burundi, Canada, Chile, China, Colombia, Costa Rica, Cote d’Ivoire, Cuba, Cyprus, Democratic Republic of the Congo, Dominican Republic, Ecuador, Eritrea, Ethiopia, Fiji, Finland, France, French Guiana, Georgia, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Ivory Coast, Japan, Kazakhstan, Kenya, Krygyzstan, Laos, Liberia, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Montenegro, Morocco, Mozambique, Myanmar, Namibia, New Zealand, Nicaragua, Niger, Nigeria, Oman, Papua New Guinea, Peru, Philippines, Portugal, Russian Federation, Rwanda, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Solomon Islands, South Africa, South Korea, Spain, Sudan, Suriname, Swaziland, Sweden, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Zambia, Zimbabwe

15