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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549


_________________

FORM SD
Specialized Disclosure Report


_________________
Powell Industries, Inc.
(Exact name of registrant as specified in its charter)

_________________


Delaware
001-12488
88-0106100
(State or other jurisdiction of
incorporation or organization)
(Commission File No.)
(I.R.S. Employer
Identification No.)
8550 Mosley Road
Houston, Texas
77075-1180
(Address of principal executive offices)
(Zip Code)
Michael W. Metcalf, 713-944-6900
(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:

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



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SECTION 1 - Conflict Minerals Disclosure

Item 1.01 - Conflict Minerals Report

    Powell Industries Inc. has included the Conflict Minerals Report as an exhibit to its Form SD for the period from January 1, 2021 to December 31, 2021. Unless the context otherwise indicates, “Powell,” “the Company,” “we,” “us” and “our” refer to Powell Industries Inc. and its consolidated subsidiaries.

    For the year 2021, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs, as defined below, are necessary to their functionality or production (“Covered 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 (together with gold collectively referred to as 3TGs), or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo ("DRC") or any adjoining country that shares an internationally recognized border with the DRC (the “Covered Countries”). Accordingly, we have conducted a reasonable country of origin inquiry (“RCOI”) that was designed to determine whether any of the 3TGs in our Covered Products originated in the Democratic Republic of the Congo or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia), or were from recycled or scrap sources.

    A summary of our RCOI and steps of due diligence on the source and chain of custody of any 3TGs in our Covered Products, is included in our Conflict Minerals Report, which is filed as Exhibit 1.01 to this Form SD. In addition to this, our Conflict Minerals Policy is publicly available on our company website at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."


Forward-Looking Statements
    The Report contains forward-looking statements which express a belief, expectation or intention, as well as those that are historical fact, are forward-looking statements, including statements relating to our compliance efforts and expected actions. The words “expects,” “intends,” “plans,” “believes,” and “anticipates” and similar expressions are used to identify these forward-looking statements. These statements are not guarantees of future actions or performance and are subject to various risks, uncertainties and assumptions. Undue reliance should not be placed on these statements, which are only effective as of the date of this report, and the Company undertakes no obligation to publicly update or revise any forward-looking statement.

Item 1.02    Exhibit.

We have filed our Conflict Minerals Report as Exhibit 1.01 to this Form SD.

Item 2.01     Exhibits.

Exhibit No.Description
Exhibit 1.01







SIGNATURES

    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.

Date: May 27, 2022By:/s/ Michael W. Metcalf
Michael W. Metcalf
Executive Vice President
Chief Financial Officer
(Principal Financial Officer)





















Document

Exhibit 1.01
Conflict Minerals Report
For the Year Ended December 31, 2021

This is the Conflict Minerals Report (this “Report”) of Powell Industries, Inc. (referred to herein as, “Powell”, the “Company”, “we”, “us” or “our”) for calendar year 2021 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Please refer to Section 13(p) of the Exchange Act and the general instructions to the Specialized Disclosure Report on Form SD for definitions of certain terms used in this Report, unless otherwise defined herein.

This Report for the year ended December 31, 2021 is presented to comply with Rule 13p-1 under the Exchange Act (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold. For the purposes of this Report, tin, tantalum, tungsten and gold shall be collectively referred to as the 3TGs. These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.

Company Overview

Powell Industries, Inc. was incorporated in the state of Delaware in 2004 as a successor to a Nevada company incorporated in 1968. The Nevada company was the successor to a company founded by William E. Powell in 1947, which merged into the Company in 1977. We are headquartered in Houston, Texas, and our major subsidiaries, all of which are wholly owned, include: Powell Electrical Systems, Inc.; Powell (UK) Limited; Powell Canada Inc. and Powell Industries International, B.V.

Our website is www.powellind.com. We make available, free of charge on or through our website, copies of our Annual Reports on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934 as soon as is reasonably practicable after we electronically file such material with, or furnish it to, the Securities and Exchange Commission (SEC). Additionally, all of our reports filed with the SEC are available via their website at http://www.sec.gov. We have also posted on our company website Powell’s Conflict Minerals policy statement at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."

We develop design, manufacture and service custom-engineered equipment and systems which (1) distribute, control and monitor the flow of electrical energy and (2) provide protection to motors, transformers and other electrically powered equipment. Our principal products include integrated power control room substations (PCRs®), custom-engineered modules, electrical houses (E-Houses), traditional and arc-resistant distribution switchgear and control gear, medium-voltage circuit breakers, monitoring and control communications systems, motor control centers and bus duct systems. These products are designed for application voltages ranging from 480 volts to 38,000 volts and are used in oil and gas refining, onshore and offshore oil and gas production, petrochemical, liquid natural gas terminals, pipeline, terminal, mining and metals, light rail traction power, electric utility, pulp and paper and other heavy industrial markets. Our product scope includes designs tested to meet both U.S. standards and international standards, under both the American National Standards Institute (ANSI) and International Electrotechnical Commission (IEC). We assist customers by providing value-added services such as spare parts, field service inspection, installation, commissioning, modification and repair, retrofit and retrofill components for existing systems and replacement circuit breakers for switchgear that is obsolete or that is no longer produced by the original manufacturer. We seek to establish long-term relationships with the end users of our systems as well as the design and construction engineering firms contracted by those end users. We believe that our culture of safety and focus on customer satisfaction, along with our financial strength, allow us to continue to capitalize on opportunities in the industries we serve.



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Product Description

Our broad and complex product range 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.

Description of Reasonable Country of Origin Inquiry (RCOI)

In conducting the RCOI, Powell engaged a third-party service provider. Assent Compliance (“Assent”) to assist with the effectiveness of our conflict minerals program. We identified the scope of our inquiry by first completing a supplier list extraction from our preferred vendor list. This list was then filtered to remove service providers, indirect materials suppliers and inactive suppliers (minimum of one year since last purchase). This was intended to ensure that all suppliers surveyed provided items to Powell that were used in final products in the year 2021. Once the filtering was completed, we populated the list with contact information. This list, composed of 585 suppliers, was then provided to Assent for upload to their Assent Sustainability Manager software system (the “Assent Sustainability Manager”).

Assent conducted the supplier survey portion of the RCOI. The supplier survey utilized a template developed by the Responsible Business Alliance® and The Global e-Sustainability Initiative (RBA/GeSI) called the Conflict Mineral Report Template (CMRT). The CMRT was developed to facilitate general disclosures and information regarding smelters that provide materials to the supplier. It includes questions regarding the supplier’s conflict-free minerals policy, the engagement process with its direct suppliers and identification of the smelters used by the supplier.

Non-responsive suppliers were contacted a minimum of nine times. We conducted a total of 9 campaigns (5 standard + 4 escalation), 1 invalid CMRT follow up, and 2 rounds of phone calls to incomplete CMRT suppliers. After three months of non-responsiveness, top suppliers were then contacted by Powell management, as an escalation to encourage their response to Assent.

Assent communications included training and education on the completion of the CMRT form as well as access to Assent’s learning management system, Assent University. All in-scope suppliers were provided access to the Conflict Minerals Training course and this training was monitored and tracked in Assent's system for future reporting and transparency.


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The below metrics provide a summary of the data collected, number of suppliers in scope and responses.
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Due Diligence Process
Powell’s 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 and the related supplements for 3TG (collectively, the “OECD Guidance”). In 2021, the due diligence process was aimed to help Powell assess and respond to risk in its supply chain by investigating the source of its products down the chain to the smelters and refiners and
the strength of its suppliers’ conflict minerals programs. The following is a brief summary of certain aspects of our due diligence process.
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A.Establish Strong Powell Management Systems

In accordance with our due diligence framework and compliance efforts:

We have communicated to all of our in-scope suppliers our efforts to comply with Section 1502 of the Dodd-Frank Act pursuant to a compliance statement and other communications (together, the “Compliance Statement”). We requested that our in-scope suppliers provide a comprehensive conflict minerals declaration for all conflict minerals in the form of the CMRT version 6.1 or higher. We provide our Compliance Statement to all new suppliers and plan to provide annual related compliance statement communications to our entire supply base.
We implemented internal compliance efforts, including internal reporting requirements, to support our supply chain due diligence process.
We implemented a risk mitigation response plan to address business relationships with suppliers that are DRC conflict undeterminable (as defined in Item 1.01(d)(5) of Form SD). Our program includes continuous monitoring to adjust our strategies as sourcing data improves and new information is received.

Powell has adopted a company policy with respect to conflict minerals which is posted on our website at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."

Internal Team

Powell has established a management system for conflict minerals. Our management system is sponsored by the Chief Financial Officer as well as executive-level representatives and a team of subject matter experts from relevant functions, such as our Supply Chain Director, Corporate Controller, Vice President of Research and Product Development, Trade Compliance and Category Managers.

The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and senior management is briefed about the results of our due diligence efforts.

Control Systems

Controls include, but are not limited to, our code of conduct which outlines expected behaviors for all Powell employees and a conflict minerals policy which can be found on our website.

We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers. Contracts with our suppliers are frequently in force for three to five years or more and we cannot unilaterally impose new contract terms and flow-down requirements. As we enter into new contracts, or our contracts renew, we are adding a clause to require suppliers to provide information about the source of 3TG and smelters. It will take a number of years to ensure that all our supplier contracts contain appropriate flow-down clauses. In the meantime, as described below, we are working with selected suppliers to ensure they provide the 3TG sourcing information until the contracts can be amended.

Supplier Engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have, through Assent, provided education on the conflict minerals regulation. We have leveraged the existing communications within the Company, specifically the procurement department, to encourage supplier interactions with Assent as well as to help suppliers understand the requirement for completion of their CMRTs. Feedback from this engagement has allowed us to enhance the training and focus and adapt it to each user’s needs. It has also allowed for our supplier communications to be more focused and to clarify expectations.
Grievance Mechanisms

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We have multiple longstanding grievance mechanisms whereby employees, contractors, suppliers and agents can report violations of Powell’s policies. There are established escalation protocols for reporting grievances internally, as well as the EthicsPoint hotline, which is independently managed. Our ethics and reporting Hotline can be found at https://powellind.ethicspoint.com.

Maintain Records

We have also adopted a policy to retain relevant documentation. Such documentation will be retained for minimum of five years in company secured shared drive files.

B.Identify and Assess Risks in Our Supply Chain

We identified direct material suppliers to capture possible 3TG risk suppliers. As we progress, we expect that transparency in our supply chain will increase to allow for better risk assessment at more detailed levels of our supply chain. We intend to continue communicating with our suppliers regarding conflict minerals.

Based on assessed risks, our RCOI covered applicable suppliers.

Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance: Assent uses 3 factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags.

1.Geographic proximity to the DRC and covered countries;
2.Responsible Minerals Assurance Process (RMAP) audit status;
3.Credible evidence of unethical or conflict sourcing.



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Based on this criteria the following facilities have been identified as being of highest concern to the supply chain:

Smelter NameSmelter Facility LocationSmelter ID
African Gold RefineryUgandaCID003185
Artek LLCRussian FederationCID003553
Fidelity Printers and Refiners Ltd.ZimbabweCID002515
Industrial Refining CompanyBelgiumCID002587
JSC "Kirovgrad Hard Alloys Plant"Russian FederationCID003408
JSC Ekaterinburg Non-Ferrous Metal ProcessingRussian FederationCID000927
JSC UralectromedRussian FederationCID000929
Kaloti Precious MetalsUnited Arab EmiratesCID002563
Kyrgyzaltyn JSCKyrgyzstanCID001029
Kysthtym Copper-Electrolytic Plant ZAORussian FederationCID002865
LLC VolstokRussian FederationCID003643
Moscow Special Alloys Processing PlantRussian FederationCID001204
NPP Tyazhmetprom LLCRussian FederationCID003416
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant"Russian FederationCID001326
OJSC Novosibirsk RefineryRussian FederationCID000493
OOO "Technolom" 1Russian FederationCID003614
OOO "Technolom" 2Russian FederationCID003612
Prioksky Plant of Non-Ferrous MetalsRussian FederationCID001386
SOE Shyolkovsky Factory of Secondary Precious MetalsRussian FederationCID001756
Sudan Gold RefinerySudanCID002567

As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by some of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above facilities produce a receipt instructing the suppliers to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Powell. As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context.

In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
C.
Design and Implement a Strategy to Respond to Identified Risks

We believe that our RCOI was reasonably designed and executed in good faith to determine the existence and source of the 3TGs in our supply chain, including from recycled or scrap sources (as defined in Item 1.01(d)(6) of Form SD). We utilized the CMRT template version 6.1 or higher for our RCOI. We conducted our effort to send surveys in good faith, utilizing up to three rounds of communications with our suppliers. We evaluated survey responses to identify: (i) the use and source of the 3TGs; and (ii) any warning signs indicating that conflict minerals may have come from one of the Covered Countries. We intend to make additional inquiries on a case-by-case basis during 2021 to clarify or obtain more information as necessary. We tracked results of our supply chain diligence process and periodically reported the results to our executive leadership team.
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Because of Powell’s size, the complexity of its products, and the depth, breadth, and constant evolution of its supply chain, it is difficult to identify parties upstream from its direct suppliers. Powell continues to work with suppliers to identify the upstream sources of the 3TGs through the CMRTs, follow up on invalid responses on the CMRTs, use of a risk-based assessment of identified smelters and assessment of the conflict minerals programs of its suppliers, as described below in this Report. Information and findings from this process are stored in the Assent Sustainability Manager, a database that can be tracked and audited.

Certain of the responses to the surveys included the names of facilities listed by the suppliers as smelters or refiners. 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. We and our consultant compared these facilities listed in the responses to the list of smelters maintained by the Responsible Minerals Initiative (RMI) and, if a supplier indicated that the facility was certified as “Conflict-Free,” we confirmed that the name was listed by the RMI.

In accordance with OECD Guidance, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free pose a significant risk to the supply chain. In the Assent Sustainability Manager, risk is classified based on 3 scoring criteria that we outlined in the previous section.

Powell does not have a direct relationship with conflict minerals smelters and refiners and, as a result, does not perform or direct audits of these entities within its supply chain. Powell captured smelter and refiner information as part of the CMRT, as some suppliers provided the names of facilities it used as smelters or refiners. Assent compared the facilities identified by the suppliers to the list of smelters maintained by the RMI.

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). At this stage in conflict minerals compliance it is well-known that many companies are in the middle of the process and do not have many answers beyond “unknown”. The criteria from the questionnaire used to evaluate the strength of the program are:

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 (Yes to at least A, E, G, H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our applicable products, including (1) seeking information about 3TG smelters and refiners in our supply chain by 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. As mentioned above, our existing policy related to relevant documentation of our conflict mineral compliance process requires that documentation will be retained for a period of at least five years.
D.
Implement Targeted Independent Third-Party Due Diligence

We engaged Assent to assist in the RCOI, data collection and survey process. Assent supports industry associations that administer independent third-party smelter and refinery audit programs and encourages targeted suppliers and/or facilities to participate in comparable due diligence validation activities.

E.
Report on Supply Chain Due Diligence

We have responded to various customer requests for information regarding our conflict minerals determination.

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Powell reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC. We also disclose our company policy with respect to conflict minerals on our website at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."

Due Diligence Results

For the 2021 reporting year, Powell received CMRT forms from 80% of the suppliers surveyed. All submitted forms are accepted and classified as valid or invalid in order to retain all data. Suppliers were contacted if they submitted invalid forms and were encouraged to resubmit a valid form. As of May 13, 2022, there were 14 invalid or incomplete supplier submissions.

While due diligence is ongoing and the information received continues to improve in quantity and quality, the majority of the responses received provided data at a company or divisional level or did not specify the smelters or refiners used for materials specifically supplied to us. We have decided to disclose validated smelters provided to us by our supply chain. However, we cannot definitively determine whether any of the 3TGs reported by the suppliers were contained in materials supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. As a result, we are unable to identify all smelters and refiners as well as all the countries of origin of the 3TGs that are contained in the applicable products

As of May 13, 2022, Powell validated 334 smelters or refiners identified within its supply chain. If a supplier indicated that the facility was certified as “conflict-free,” such status was confirmed by Assent if the facility was listed by the RMI as certified.

Many suppliers within Powell’s supply chain are still unable to provide the smelters or refiners used for products supplied. Furthermore, many of the suppliers provided responses at the company or division level and indicated an “unknown” status in terms of determining the origin of the 3TGs. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our Assent follows up on these, urging suppliers to resubmit with increased smelter information. There are still suppliers unable to provide the smelters or refiners used for materials supplied to us.

In cases where any red-flagged smelters were reported on a CMRT by a supplier, risk mitigation activities were initiated. Through Assent, the suppliers were asked to submit a product-level CMRT to better identify the connection between the smelters or refiners they listed and the products they provide to us. Suppliers were also guided to Assent University where they were provided with educational materials on mitigating the risk of smelters or refiners in the supply chain.

Appendix I lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix I any smelters or refiners that we have not been able to validate. Appendix II also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and RMI. Powell supports the refinement and expansion of the list of participating smelters through our membership in the RMI program.

The large majority of the responses received either provided data at a company or subsidiary level and chose not to provide information at the component level, or did not specify the smelters or refiners used for components supplied to Powell. Accordingly, we are unable to determine, in those cases, whether any of the 3TGs reported by the suppliers were contained in components or parts supplied to us, or to validate that any of the smelters or refiners identified are actually in our supply chain.

Steps to Improve Future Due Diligence and Supply Chain Risk Mitigation

Powell takes the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in its products could benefit armed groups in the Covered Countries:

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Reinforce conflict minerals policy statement on website and specified requirements in standard terms and conditions for any new or renewed supplier contracts.

New and existing suppliers must certify compliance with Powell’s Supplier Code of Conduct and Ethics, which includes due diligence for Responsible Sourcing (in progress, implemented in June, 2021).

Continue engagement with suppliers and direct them to training resources to increase the response rate and improve the content of the supplier survey responses.

Engage any suppliers found to be supplying Powell with conflict minerals to establish an alternative source of conflict minerals that does not support the conflict in the Covered Countries.

Define and improve best practices and build leverage over its supply chain in accordance with the OECD Guidance.

Smelter Risk Evaluation through Assent, comprehensive and ongoing analysis is conducted by their smelter library manager to assess sourcing risk. The information is then used to provide supplier feedback and conduct outreach with higher risk suppliers.

Based on its due diligence process as of the date of this Report, Powell has found no instances where it was necessary to terminate a supplier contract or to find a replacement supply of any conflict minerals.


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Appendix I

MetalSmelter NameSmelter Facility LocationSmelter ID
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaCID000228
TinAlphaUnited States Of AmericaCID000292
TinDowaJapanCID000402
TinFenix MetalsPolandCID000468
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaCID000538
TinChina Tin Group Co., Ltd.ChinaCID001070
TinMalaysia Smelting Corporation (MSC)MalaysiaCID001105
TinMetallic Resources, Inc.United States Of AmericaCID001142
TinMineracao Taboca S.A.BrazilCID001173
TinMinsurPeruCID001182
TinMitsubishi Materials CorporationJapanCID001191
TinJiangxi New Nanshan Technology Ltd.ChinaCID001231
TinO.M. Manufacturing (Thailand) Co., Ltd.ThailandCID001314
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)CID001337
TinPT Artha Cipta LanggengIndonesiaCID001399
TinPT Babel Surya Alam LestariIndonesiaCID001406
TinPT Mitra Stania PrimaIndonesiaCID001453
TinPT Prima Timah UtamaIndonesiaCID001458
TinPT Refined Bangka TinIndonesiaCID001460
TinPT Stanindo Inti PerkasaIndonesiaCID001468
TinPT Timah Tbk KundurIndonesiaCID001477
TinPT Timah Tbk MentokIndonesiaCID001482
TinPT Tinindo Inter NusaIndonesiaCID001490
TinRui Da HungTaiwan, Province Of ChinaCID001539
TinThaisarcoThailandCID001898
TinWhite Solder Metalurgia e Mineracao Ltda.BrazilCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaCID002158
TinPT ATD Makmur Mandiri JayaIndonesiaCID002503
TinO.M. Manufacturing Philippines, Inc.PhilippinesCID002517
TinMetallo Belgium N.V.BelgiumCID002773
TinMetallo Spain S.L.U.SpainCID002774
TinPT Menara Cipta MuliaIndonesiaCID002835
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaCID003116
TinPT Bangka SerumpunIndonesiaCID003205
TinTin Technology & RefiningUnited States Of AmericaCID003325
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TinMa'anshan Weitai Tin Co., Ltd.ChinaCID003379
TinPT Rajawali Rimba PerkasaIndonesiaCID003381
TinLuna Smelter, Ltd.RwandaCID003387
TungstenA.L.M.T. Corp.JapanCID000004
GoldAdvanced Chemical CompanyUnited States Of AmericaCID000015
GoldAida Chemical Industries Co., Ltd.JapanCID000019
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GermanyCID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UzbekistanCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazilCID000058
GoldArgor-Heraeus S.A.SwitzerlandCID000077
GoldAsahi Pretec Corp.JapanCID000082
GoldAsaka Riken Co., Ltd.JapanCID000090
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TurkeyCID000103
TungstenKennametal HuntsvilleUnited States Of AmericaCID000105
GoldAurubis AGGermanyCID000113
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PhilippinesCID000128
GoldBoliden ABSwedenCID000157
GoldC. Hafner GmbH + Co. KGGermanyCID000176
GoldCaridadMexicoCID000180
GoldCCR Refinery - Glencore Canada CorporationCanadaCID000185
GoldCendres + Metaux S.A.SwitzerlandCID000189
GoldYunnan Copper Industry Co., Ltd.ChinaCID000197
TantalumChangsha South Tantalum Niobium Co., Ltd.ChinaCID000211
TungstenGuangdong Xianglu Tungsten Co., Ltd.ChinaCID000218
GoldChimet S.p.A.ItalyCID000233
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaCID000258
GoldChugai MiningJapanCID000264
TungstenCNMC (Guangxi) PGMA Co., Ltd.ChinaCID000281
TinPT Aries Kencana SejahteraIndonesiaCID000309
GoldDaye Non-Ferrous Metals Mining Ltd.ChinaCID000343
GoldDSC (Do Sung Corporation)Korea, Republic OfCID000359
GoldDowaJapanCID000401
GoldEco-System Recycling Co., Ltd. East PlantJapanCID000425
TinEM VintoBolivia (Plurinational State Of)CID000438
TinEstanho de Rondonia S.A.BrazilCID000448
TantalumF&X Electro-Materials Ltd.ChinaCID000460
GoldAfrican Gold RefineryUgandaCID003185
GoldRefinery of Seemine Gold Co., Ltd.ChinaCID000522
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TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaCID000555
TungstenGlobal Tungsten & Powders Corp.United States Of AmericaCID000568
TantalumGuangdong Zhiyuan New Material Co., Ltd.ChinaCID000616
GoldHangzhou Fuchunjiang Smelting Co., Ltd.ChinaCID000671
GoldLT Metal Ltd.Korea, Republic OfCID000689
GoldHeimerle + Meule GmbHGermanyCID000694
GoldHeraeus Metals Hong Kong Ltd.ChinaCID000707
GoldHeraeus Precious Metals GmbH & Co. KGGermanyCID000711
TungstenHunan Chenzhou Mining Co., Ltd.ChinaCID000766
GoldHunan Chenzhou Mining Co., Ltd.ChinaCID000767
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.ChinaCID000769
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.ChinaCID000773
GoldHwaSeong CJ CO., LTD.Korea, Republic OfCID000778
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.ChinaCID000801
GoldIshifuku Metal Industry Co., Ltd.JapanCID000807
GoldIstanbul Gold RefineryTurkeyCID000814
GoldJapan MintJapanCID000823
TungstenJapan New Metals Co., Ltd.JapanCID000825
GoldJiangxi Copper Co., Ltd.ChinaCID000855
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.ChinaCID000875
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaCID000914
TantalumJiujiang Tanbre Co., Ltd.ChinaCID000917
GoldAsahi Refining USA Inc.United States Of AmericaCID000920
GoldAsahi Refining Canada Ltd.CanadaCID000924
TungstenArtek LLCRussian FederationCID003553
GoldJX Nippon Mining & Metals Co., Ltd.JapanCID000937
TinGejiu Kai Meng Industry and Trade LLCChinaCID000942
GoldKazakhmys Smelting LLCKazakhstanCID000956
GoldKazzincKazakhstanCID000957
TungstenKennametal FallonUnited States Of AmericaCID000966
GoldKennecott Utah Copper LLCUnited States Of AmericaCID000969
GoldKojima Chemicals Co., Ltd.JapanCID000981
GoldFidelity Printers and Refiners Ltd.ZimbabweCID002515
GoldL'azurde Company For JewelrySaudi ArabiaCID001032
GoldLingbao Gold Co., Ltd.ChinaCID001056
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.ChinaCID001058
TantalumLSM Brasil S.A.BrazilCID001076
GoldLS-NIKKO Copper Inc.Korea, Republic OfCID001078
Page 12 of 20



GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.ChinaCID001093
GoldMaterionUnited States Of AmericaCID001113
GoldMatsuda Sangyo Co., Ltd.JapanCID001119
GoldMetalor Technologies (Suzhou) Ltd.ChinaCID001147
GoldMetalor Technologies (Hong Kong) Ltd.ChinaCID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeCID001152
GoldMetalor Technologies S.A.SwitzerlandCID001153
GoldMetalor USA Refining CorporationUnited States Of AmericaCID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MexicoCID001161
TantalumMetallurgical Products India Pvt., Ltd.IndiaCID001163
TantalumMineracao Taboca S.A.BrazilCID001175
GoldMitsubishi Materials CorporationJapanCID001188
TantalumMitsui Mining and Smelting Co., Ltd.JapanCID001192
GoldMitsui Mining and Smelting Co., Ltd.JapanCID001193
TantalumNPM Silmet ASEstoniaCID001200
GoldIndustrial Refining CompanyBelgiumCID002587
GoldNadir Metal Rafineri San. Ve Tic. A.S.TurkeyCID001220
GoldNavoi Mining and Metallurgical CombinatUzbekistanCID001236
GoldNihon Material Co., Ltd.JapanCID001259
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaCID001277
TinNovosibirsk Processing Plant Ltd.Russian FederationCID001305
GoldOhura Precious Metal Industry Co., Ltd.JapanCID001325
TungstenJSC "Kirovgrad Hard Alloys Plant"Russian FederationCID003408
GoldPAMP S.A.SwitzerlandCID001352
GoldPenglai Penggang Gold Industry Co., Ltd.ChinaCID001362
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRussian FederationCID000927
GoldPT Aneka Tambang (Persero) TbkIndonesiaCID001397
TinPT Babel Inti PerkasaIndonesiaCID001402
TinPT Bukit TimahIndonesiaCID001428
TinPT Timah NusantaraIndonesiaCID001486
GoldPX Precinox S.A.SwitzerlandCID001498
TantalumQuantumCleanUnited States Of AmericaCID001508
GoldRand Refinery (Pty) Ltd.South AfricaCID001512
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaCID001522
GoldRoyal Canadian MintCanadaCID001534
GoldSabin Metal Corp.United States Of AmericaCID001546
GoldSamduck Precious MetalsKorea, Republic OfCID001555
GoldSamwon Metals Corp.Korea, Republic OfCID001562
GoldSEMPSA Joyeria Plateria S.A.SpainCID001585
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.ChinaCID001619
Page 13 of 20



GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaCID001622
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaCID001736
GoldJSC UralelectromedRussian FederationCID000929
TinSoft Metais Ltda.BrazilCID001758
GoldSolar Applied Materials Technology Corp.Taiwan, Province Of ChinaCID001761
TantalumSolikamsk Magnesium Works OAORussian FederationCID001769
GoldSumitomo Metal Mining Co., Ltd.JapanCID001798
GoldSuper Dragon Technology Co., Ltd.Taiwan, Province Of ChinaCID001810
TantalumTaki Chemical Co., Ltd.JapanCID001869
GoldTanaka Kikinzoku Kogyo K.K.JapanCID001875
TantalumTelex MetalsUnited States Of AmericaCID001891
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.ChinaCID001908
GoldGreat Wall Precious Metals Co., Ltd. of CBPMChinaCID001909
GoldThe Refinery of Shandong Gold Mining Co., Ltd.ChinaCID001916
GoldTokuriki Honten Co., Ltd.JapanCID001938
GoldTongling Nonferrous Metals Group Co., Ltd.ChinaCID001947
GoldTorecomKorea, Republic OfCID001955
TantalumUlba Metallurgical Plant JSCKazakhstanCID001969
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgiumCID001980
GoldUnited Precious Metal Refining, Inc.United States Of AmericaCID001993
GoldValcambi S.A.SwitzerlandCID002003
TinVQB Mineral and Trading Group JSCViet NamCID002015
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaCID002030
TungstenWolfram Bergbau und Hutten AGAustriaCID002044
TungstenXiamen Tungsten Co., Ltd.ChinaCID002082
GoldYamakin Co., Ltd.JapanCID002100
GoldYokohama Metal Co., Ltd.JapanCID002129
TinYunnan Tin Company LimitedChinaCID002180
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaCID002224
GoldGold Refinery of Zijin Mining Group Co., Ltd.ChinaCID002243
GoldMorris and WatsonNew ZealandCID002282
GoldGuangdong Jinding Gold LimitedChinaCID002312
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.ChinaCID002313
GoldUmicore Precious Metals ThailandThailandCID002314
Page 14 of 20



TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.ChinaCID002315
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaCID002316
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.ChinaCID002317
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.ChinaCID002318
TungstenMalipo Haiyu Tungsten Co., Ltd.ChinaCID002319
TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaCID002320
TungstenJiangxi Gan Bei Tungsten Co., Ltd.ChinaCID002321
TinCV Venus Inti PerkasaIndonesiaCID002455
GoldGeib Refining CorporationUnited States Of AmericaCID002459
TinMagnu's Minerais Metais e Ligas Ltda.BrazilCID002468
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaCID002492
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaCID002494
TinMelt Metais e Ligas S.A.BrazilCID002500
TungstenAsia Tungsten Products Vietnam Ltd.Viet NamCID002502
TantalumD Block Metals, LLCUnited States Of AmericaCID002504
TantalumFIR Metals & Resource Ltd.ChinaCID002505
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaCID002506
TantalumXinXing HaoRong Electronic Material Co., Ltd.ChinaCID002508
GoldMMTC-PAMP India Pvt., Ltd.IndiaCID002509
GoldKGHM Polska Miedz Spolka AkcyjnaPolandCID002511
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.ChinaCID002512
TungstenChenzhou Diamond Tungsten Products Co., Ltd.ChinaCID002513
GoldSingway Technology Co., Ltd.Taiwan, Province Of ChinaCID002516
GoldShandong Humon Smelting Co., Ltd.ChinaCID002525
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.ChinaCID002527
TantalumKEMET Blue MetalsMexicoCID002539
TungstenH.C. Starck Tungsten GmbHGermanyCID002541
TungstenH.C. Starck Smelting GmbH & Co. KGGermanyCID002542
TungstenMasan Tungsten Chemical LLC (MTC)Viet NamCID002543
TantalumH.C. Starck Co., Ltd.ThailandCID002544
TantalumH.C. Starck Tantalum and Niobium GmbHGermanyCID002545
TantalumH.C. Starck Hermsdorf GmbHGermanyCID002547
TantalumH.C. Starck Inc.United States Of AmericaCID002548
TantalumH.C. Starck Ltd.JapanCID002549
TantalumH.C. Starck Smelting GmbH & Co. KGGermanyCID002550
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.ChinaCID002551
Page 15 of 20



TantalumGlobal Advanced Metals BoyertownUnited States Of AmericaCID002557
TantalumGlobal Advanced Metals AizuJapanCID002558
GoldAl Etihad Gold Refinery DMCCUnited Arab EmiratesCID002560
GoldEmirates Gold DMCCUnited Arab EmiratesCID002561
GoldInternational Precious Metal RefinersUnited Arab EmiratesCID002562
GoldKaloti Precious MetalsUnited Arab EmiratesCID002563
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyViet NamCID002572
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyViet NamCID002573
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyViet NamCID002574
GoldT.C.A S.p.AItalyCID002580
GoldREMONDIS PMR B.V.NetherlandsCID002582
GoldFujairah Gold FZCUnited Arab EmiratesCID002584
GoldKyrgyzaltyn JSCKyrgyzstanCID001029
GoldShirpur Gold Refinery Ltd.IndiaCID002588
TungstenNiagara Refining LLCUnited States Of AmericaCID002589
GoldKorea Zinc Co., Ltd.Korea, Republic OfCID002605
GoldMarsam MetalsBrazilCID002606
GoldTOO Tau-Ken-AltynKazakhstanCID002615
TungstenChina Molybdenum Co., Ltd.ChinaCID002641
TungstenGanzhou Haichuang Tungsten Co., Ltd.ChinaCID002645
TungstenHydrometallurg, JSCRussian FederationCID002649
TinPT Cipta Persada MuliaIndonesiaCID002696
TinAn Vinh Joint Stock Mineral Processing CompanyViet NamCID002703
TinResind Industria e Comercio Ltda.BrazilCID002706
TantalumResind Industria e Comercio Ltda.BrazilCID002707
GoldAbington Reldan Metals, LLCUnited States Of AmericaCID002708
TungstenUnecha Refractory metals plantRussian FederationCID002724
TinSuper LigasBrazilCID002756
GoldSAAMPFranceCID002761
GoldL'Orfebre S.A.AndorraCID002762
Gold8853 S.p.A.ItalyCID002763
GoldItalpreziosiItalyCID002765
GoldWIELAND Edelmetalle GmbHGermanyCID002778
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustriaCID002779
TinPT Sukses Inti MakmurIndonesiaCID002816
TungstenPhilippine Chuangxin Industrial Co., Inc.PhilippinesCID002827
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.ChinaCID002830
TungstenACL Metais EireliBrazilCID002833
Page 16 of 20



TantalumJiangxi Tuohong New Raw MaterialChinaCID002842
TungstenMoliren Ltd.Russian FederationCID002845
GoldAU Traders and RefinersSouth AfricaCID002850
GoldGCC Gujrat Gold Centre Pvt. Ltd.IndiaCID002852
GoldSai RefineryIndiaCID002853
GoldModeltech Sdn BhdMalaysiaCID002857
TinModeltech Sdn BhdMalaysiaCID002858
GoldBangalore RefineryIndiaCID002863
GoldKyshtym Copper-Electrolytic Plant ZAORussian FederationCID002865
GoldDegussa Sonne / Mond Goldhandel GmbHGermanyCID002867
GoldPease & CurrenUnited States Of AmericaCID002872
GoldJALAN & CompanyIndiaCID002893
GoldSungEel HiMetal Co., Ltd.Korea, Republic OfCID002918
GoldPlanta Recuperadora de Metales SpAChileCID002919
GoldSafimet S.p.AItalyCID002973
GoldState Research Institute Center for Physical Sciences and TechnologyLithuaniaCID003153
TungstenLLC VolstokRussian FederationCID003643
GoldGold Coast RefineryGhanaCID003186
GoldNH Recytech CompanyKorea, Republic OfCID003189
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaCID003190
TinPongpipat Company LimitedMyanmarCID003208
GoldQG Refining, LLCUnited States Of AmericaCID003324
GoldDijllah Gold Refinery FZCUnited Arab EmiratesCID003348
TinDongguan CiEXPO Environmental Engineering Co., Ltd.ChinaCID003356
GoldCGR Metalloys Pvt Ltd.IndiaCID003382
GoldSovereign MetalsIndiaCID003383
TungstenKGETS Co., Ltd.Korea, Republic OfCID003388
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.ChinaCID003397
TungstenFujian Ganmin RareMetal Co., Ltd.ChinaCID003401
TungstenLianyou Metals Co., Ltd.Taiwan, Province Of ChinaCID003407
GoldMoscow Special Alloys Processing PlantRussian FederationCID001204
TinPrecious Minerals and Smelting LimitedIndiaCID003409
TinGejiu City Fuxiang Industry and Trade Co., Ltd.ChinaCID003410
TungstenNPP Tyazhmetprom LLCRussian FederationCID003416
TungstenGEM Co., Ltd.ChinaCID003417
GoldC.I Metales Procesados Industriales SASColombiaCID003421
GoldEco-System Recycling Co., Ltd. North PlantJapanCID003424
GoldEco-System Recycling Co., Ltd. West PlantJapanCID003425
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BrazilCID003427
Page 17 of 20



TinPT Mitra Sukses GlobalindoIndonesiaCID003449
GoldAugmont Enterprises Private LimitedIndiaCID003461
GoldKundan Care Products Ltd.IndiaCID003463
GoldK.A. RasmussenNorwayCID003497
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.ChinaCID000651
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)Russian FederationCID001326
TinPT Belitung Industri SejahteraIndonesiaCID001421
TinPT Panca Mega PersadaIndonesiaCID001457
TinPT Sariwiguna BinasentosaIndonesiaCID001463
TinPT Tommy UtamaIndonesiaCID001493
GoldSAFINA A.S.CzechiaCID002290
TinPT Tirus Putra MandiriIndonesiaCID002478
GoldOJSC Novosibirsk RefineryRussian FederationCID000493
TungstenOOO “Technolom” 1Russian FederationCID003614
TungstenCronimet Brasil LtdaBrazilCID003468
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBrazilCID003486
GoldEmerald Jewel Industry India Limited (Unit 1)IndiaCID003487
GoldEmerald Jewel Industry India Limited (Unit 2)IndiaCID003488
GoldEmerald Jewel Industry India Limited (Unit 3)IndiaCID003489
GoldEmerald Jewel Industry India Limited (Unit 4)IndiaCID003490
GoldAlexy MetalsUnited States Of AmericaCID003500
TinCRM SynergiesSpainCID003524
GoldSancus ZFS (L’Orfebre, SA)ColombiaCID003529
GoldSellem Industries Ltd.MauritaniaCID003540
GoldMD OverseasIndiaCID003548
TungstenOOO “Technolom” 2Russian FederationCID003612
GoldMetallix Refining Inc.United States Of AmericaCID003557
GoldMetal Concentrators SA (Pty) Ltd.South AfricaCID003575
TinFabrica Auricchio Industria e Comercio Ltda.BrazilCID003582
TantalumYancheng Jinye New Material Technology Co., Ltd.ChinaCID003583
TungstenFujian Xinlu TungstenChinaCID003609
GoldPrioksky Plant of Non-Ferrous MetalsRussian FederationCID001386
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian FederationCID001756
GoldWEEEREFININGFranceCID003615
Page 18 of 20



GoldValue TradingBelgiumCID003617
GoldSudan Gold RefinerySudanCID002567




Page 19 of 20



Appendix II

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.

Aggregated Country of Origin List
Afghanistan
Finland
Nigeria
Åland Islands
France
Panama
Albania
Germany
Papua New Guinea
American Samoa
Ghana
Peru
Andorra
Guinea
Philippines
Angola
Guyana
Poland
Argentina
Hong Kong
Portugal
Armenia
Hungary
Russian Federation
Australia
India
Rwanda
Austria
Indonesia
Saudi Arabia
Belarus
Ireland
Sierra Leone
Belgium
Israel
Singapore
Bermuda
Italy
Slovakia
Bolivia
Japan
Slovenia
Brazil
Kazakhstan
South Africa
Bulgaria
Kenya
South Sudan
Burundi
Korea
Spain
Cambodia
Kyrgyzstan
Sudan
Canada
Liberia
Suriname
Central African Republic
Lithuania
Sweden
Chile
Luxembourg
Switzerland
China
Madagascar
Taiwan
Colombia
Malaysia
Tajikistan
Congo
Mali
Tanzania
Democratic Republic of Congo
Mauritania
Thailand
Djibouti
Mexico
Turkey
Dominica
Mongolia
Uganda
Dominican Republic
Morocco
United Arab Emirates
Ecuador
Mozambique
United Kingdom
Egypt
Myanmar
United States
Eritrea
Namibia
Uzbekistan
Estonia
Netherlands
Viet Nam
Ethiopia
New Zealand
Zambia
Niger
Zimbabwe
Page 20 of 20