Exhibit 1.01
CONFLICT MINERALS REPORT
Introduction
This Conflict Minerals Report of Worthington Enterprises, Inc. (the “Company”) for the calendar year ended December 31, 2024 (“Reporting Period”) is filed pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934. The Company is a designer and manufacturer of innovative products and services, including manufactured metal products. The Company’s operations are currently comprised of two primary operating segments: Building Products and Consumer Products.
In accordance with the Rule, the Company identified products that it believes may contain tin, tantalum, tungsten or gold (“Conflict Minerals”) that were manufactured by or on behalf of the Company during the Reporting Period (the “Covered Products”), and undertook a reasonable country of origin inquiry (“RCOI”) to ascertain whether any Conflict Minerals in its Covered Products originated in the Democratic Republic of the Congo or an adjoining country (each, a “Covered Country”). Based on the information received by the Company as a result of the RCOI, the Company determined that it is required by the Rule to undertake due diligence with respect to the Conflict Minerals contained in its Covered Products and file this Conflict Minerals Report. The due diligence undertaken by the Company (including the RCOI) and the results of that due diligence are set forth below.
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Part I. |
Reasonable Country of Origin Inquiry |
To determine whether Conflict Minerals in the Company’s Covered Products originated in Covered Countries, the Company retained Assent Inc. (“Assent”), a third-party service provider, to assist in reviewing the supply chain. The Company provided a list composed of Covered Suppliers and parts associated with the Covered Products to Assent for upload to the Assent Compliance Manager, a software-as-a-service (SaaS) platform provided by Assent.
To trace Conflict Minerals in the Company’s supply chain, the Company utilized the Conflict Minerals Reporting Template (“CMRT”) in the form maintained by the Responsible Minerals Initiative (“RMI”) to conduct a survey of all suppliers who supply the Company with Covered Products or components or materials that may contain Conflict Minerals that are contained in Covered Products (“Covered Suppliers”). During the supplier survey, the Company contacted Covered Suppliers via the Assent Compliance Manager, which enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. According to Assent, the Assent Compliance Manager provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations, are managed through this platform.
Through the Assent Compliance Manager and the Assent team, the Company requested that all Covered Suppliers complete a CMRT. Training and education to guide Covered Suppliers on completing the CMRTs was included. Assent monitored and tracked all communications in the Assent Compliance Manager. Assent contacted suppliers that were unresponsive during the diligence process and requested these suppliers complete the CMRT and submit it to Assent.
The Assent Compliance Manager includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which helps identify areas that require further classification or risk assessment.
All submitted CMRTs are accepted so that data is retained, but they are classified as valid or invalid based on a set criteria of validation errors. Suppliers are contacted regarding invalid CMRTs and are encouraged to correct
validated errors to resubmit a valid CMRT. Suppliers are provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses, and direct engagement help through Assent.
Through aggregate country of origin data provided by Assent, the Company was able to determine all the possible countries Conflict Minerals used in its product may have originated from. As such, the Company can perform further due diligence on the source and chain of custody of the Conflict Minerals identified as required by the Rule.
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Part II. |
Description of Due Diligence Undertaken by the Company. |
The Company has performed due diligence on the source of the Conflict Minerals contained in the Covered Products within the framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “Framework”) as required by the Rule. The Company’s Conflict Minerals due diligence procedures are summarized below within each category specified by the Framework.
1. Establish Strong Company Management Systems.
1.1. The Company has a written Conflict Minerals policy (the “Policy”) under which it does not knowingly purchase Conflict Minerals that finance or benefit armed groups in the Covered Countries. As stated in the Policy, the Company expects its suppliers to conduct due diligence to ascertain the source of Conflict Minerals supplied to the Company.
1.2 The Company also has written Conflict Minerals procedures (“Procedures”) under which certain Company managers are designated to serve on a conflict minerals working group (“Conflict Minerals Team”). The Conflict Minerals Team has the responsibility for overseeing, reviewing and implementing the Conflict Minerals supply chain due diligence required by the Rule and reporting periodically to the Chief Compliance Officer.
1.3 The Company uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding Conflict Minerals, identifying potential risks, and in the development and implementation of additional due diligence steps that the Company will undertake with Covered Suppliers. The Company communicates regularly with Assent to receive updates on program status.
1.4 The Company has identified its Covered Products and its Covered Suppliers. The Procedures require periodic reviews and updates of the Covered Products and Covered Suppliers. The Company undertook such a review and update for the current Reporting Period.
1.5 The Procedures require that each of the Company’s Covered Suppliers is contacted annually to complete a CMRT. This is now done through the Assent Compliance Manager platform to facilitate consistent communication, data analysis and recordkeeping.
1.6 The Company collects and centrally maintains the completed CMRTs received by each of the Company’s operating segments from the Covered Suppliers.
1.7 The Procedures include sample clauses that each of the Company’s operating segments can integrate into their respective supplier agreements. These clauses inform suppliers of the Company’s Conflict Minerals sourcing policy and the expectations the Company has with respect to its suppliers.
2. Identify and Assess Risk in the Supply Chain.
The Assent Compliance Manager assesses each CMRT received from the Company’s Covered Suppliers to ascertain (a) whether the CMRT is complete, (b) whether the CMRT is consistent with the Company’s understanding of the materials, products or components supplied by the Covered Supplier, (c) whether the Covered Supplier indicates that the Conflict Minerals are sourced from a Covered Country or are from scrap or recycled sources, and (d) whether the Covered Supplier has identified the smelters, processors or refiners of its Conflict Minerals. The Company has Procedures to follow up with Covered Suppliers who are unresponsive.
Risks associated with Covered Suppliers’ due diligence processes were assessed by their declaration responses on a CMRT, which the Assent Compliance Manager identifies automatically based on established criteria. These risks are addressed by Assent staff and members of the Company’s internal Conflict Minerals Team performing an overall assessment of the supplier’s conformity status. Risks at the Covered Supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT is submitted, the Company is unable to determine if all of the specified smelters/refiners were used for Conflict Minerals in the Covered Products supplied to the Company. The risk assessment also includes a review, through the Assent Compliance Manager, of the smelter validation process, which establishes risk at the smelter level.
Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters/refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent’s smelter validation program compared listed facilities into the list of smelters/refiners identified by the RMI to ensure that the facilities met the recognized definition of a processing facility that was operational during the Reporting Period.
Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). The Company does not have a direct relationship with smelters/refiners and does not perform direct audits of these entities. Smelters that are conformant to RMAP audit standards are considered to have their sourcing validated. In cases where the smelter/refiner’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, further due diligence steps are followed to notify suppliers reporting these facilities.
3. Strategy to Respond to Identified Risks.
The Procedures provide that Covered Suppliers who continue to refuse or fail to cooperate may be identified to the Conflict Minerals Team for further action. Feedback on Covered Supplier submissions is given directly to Covered Suppliers and educational resources are provided to assist suppliers. The results of the program and risk assessment are shared with the Conflict Minerals Team.
4. Independent Third Party Audit.
The Procedures require the Company to obtain an independent audit of its Conflict Minerals due diligence process if and when required under the Rule. No audit is required under the Rule for the current Reporting Period. The Company does not audit processing facilities in light of its downstream position in the supply chain. Instead, the Company relies on the results of third-party audits of smelters/refiners that are provided to it by Assent.
5. Report on Supply Chain Due Diligence.
The Procedures require the Company to report annually to the Securities and Exchange Commission and to make a copy of its annual Conflict Minerals Report available on its website in each case as required by the Rule. A copy of this Conflict Minerals Report will be available on the Company’s website.
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Part III. |
Results of Due Diligence |
1. Covered Products.
The Company determined that the following product lines contained Covered Products during the Reporting Period:
•pressure cylinders for industrial gas applications;
•indirect fired water heaters, water systems, well water and expansion tanks;
•products for camping, grilling, hand torch solutions, specialized hand tools and instruments; and
2. Supplier Data; Identification of Processing Facilities
Due to its position in the supply chain, the Company does not have direct relationships with the smelters and refiners that process the Conflict Minerals contained in its Covered Products. Accordingly, the Company relies on its Covered Suppliers to provide information on the smelters and refiners of the Conflict Minerals contained in the Company’s Covered Products. The Company’s Covered Suppliers often rely on information provided to them by their suppliers and, consequently, the Company’s ability to determine the ultimate origin and source of the Conflict Minerals actually contained in its Covered Products is limited.
After its most recent Covered Product and Covered Supplier scoping review, the Company identified 103 Covered Suppliers. With respect to the current Reporting Period, the Company received responses from approximately 52 of its Covered Suppliers. Since a number of the Company’s Covered Suppliers reported data at a company level, it is not possible for the Company to determine with certainty whether all of the Conflict Minerals identified by such Covered Suppliers were supplied to the Company and included within Covered Products, or which of the smelters or refiners identified by such Covered Suppliers processed Conflict Minerals actually contained in the Company’s Covered Products. Accordingly, the Company has listed in Attachment A all of the processing facilities currently identified by RMI as smelters or refiners that were reported by the Company’s Covered Suppliers as being in their respective supply chains during the Reporting Period. Attachment A also identifies the countries in which RMI indicates such processing facilities are located.
In light of the Company’s position in the supply chain and the lack of certainty as to which smelters or refiners identified by the Covered Suppliers processed Conflict Minerals actually contained in the Company’s Covered Products, it is not possible for the Company to identify with certainty the country of origin of those Conflict Minerals actually contained in the Company’s Covered Products. The Company’s efforts to determine the location of the mines from which the ore or minerals used by the processing facilities identified by the Covered Suppliers was sourced included (i) its request to all Covered Suppliers to complete the CMRT, (ii) its review of the processing facility information provided by Covered Suppliers, and (iii) its review of the aggregate country of origin data provided to the Company by Assent. Attachment B includes an aggregated list of countries of origin from which the reported facilities collectively source Conflict Minerals based on aggregate country of origin data obtained via Assent’s supply chain database.
3. Current and Future Due Diligence Measures
The steps undertaken by the Company during the current Reporting Period to mitigate the risk that the Conflict Minerals used in its Covered Products will benefit armed groups in the Covered Countries are described in Parts I and II of this Conflict Minerals Report. The Company intends to continue work with its Covered Suppliers to obtain information about the Conflict Minerals in its Covered Products and to report the results of its efforts as required by the Rule.
Forward looking statements
Selected statements contained in this Conflict Minerals Report are “forward-looking statements.” Forward-looking statements reflect the Company’s current expectations, estimates or projections concerning future results or events. These statements are often identified by the use of forward-looking words or phrases such as “believe,” “expect,” “anticipate,” “may,” “could,” “intend,” “estimate,” “plan,” “foresee,” “likely,” “will,” “should” or other similar words or phrases. Because they are based on beliefs, estimates and assumptions, forward-looking statements are inherently subject to risks and uncertainties that could cause actual results to differ materially from those projected. Any forward-looking statements in this Conflict Minerals Report are based on current information as of the date of this Conflict Minerals Report, and the Company assumes no obligation to correct or update any such statements in the future, except as required by applicable law.
Attachment A
The processing facilities that have been identified by RMI as smelters or refiners in the CMRTs that have been reported to the Company by its Covered Suppliers as processing Conflict Minerals used by those Covered Suppliers and the country in which they are located is set forth below. As noted in Part III of the Company’s Conflict Minerals Report, a number of the Company’s Covered Suppliers identified smelters and refiners at a company level. Accordingly, it is not possible for the Company to determine whether or which of the smelters or refiners identified below processed Conflict Minerals actually contained in the Company’s Covered Products.
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METAL |
STANDARD SMELTER NAME |
SMELTER COUNTRY |
Gold |
8853 S.p.A. |
ITALY |
Gold |
8853 S.p.A. |
Italy |
Gold |
ABC Refinery Pty Ltd. |
Australia |
Gold |
Abington Reldan Metals, LLC |
United States Of America |
Gold |
Advanced Chemical Company |
United States Of America |
Gold |
African Gold Refinery |
Uganda |
Gold |
Agosi AG |
Germany |
Gold |
Aida Chemical Industries Co., Ltd. |
Japan |
Gold |
Al Etihad Gold Refinery DMCC |
United Arab Emirates |
Gold |
Albino Mountinho Lda. |
Portugal |
Gold |
Alexy Metals |
United States Of America |
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
Uzbekistan |
Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
Brazil |
Gold |
Argor-Heraeus S.A. |
Switzerland |
Gold |
Asahi Pretec Corp. |
Japan |
Gold |
Asahi Refining Canada Ltd. |
Canada |
Gold |
Asahi Refining USA Inc. |
United States Of America |
Gold |
Asaka Riken Co., Ltd. |
Japan |
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
Turkey |
Gold |
Attero Recycling Pvt Ltd |
India |
Gold |
AU Traders and Refiners |
South Africa |
Gold |
Augmont Enterprises Private Limited |
India |
Gold |
Aurubis AG |
Germany |
Gold |
Bangalore Refinery |
India |
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Philippines |
Gold |
Boliden Ronnskar |
Sweden |
Gold |
C. Hafner GmbH + Co. KG |
Germany |
Gold |
Caridad |
Mexico |
Gold |
CCR Refinery - Glencore Canada Corporation |
Canada |
Gold |
Cendres + Metaux S.A. |
Switzerland |
Gold |
CGR Metalloys Pvt Ltd. |
India |
Gold |
Chimet S.p.A. |
Italy |
Gold |
Chugai Mining |
Japan |
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Gold |
Coimpa Industrial LTDA |
Brazil |
Gold |
Daye Non-Ferrous Metals Mining Ltd. |
China |
Gold |
Degussa Sonne / Mond Goldhandel GmbH |
Germany |
Gold |
Dijllah Gold Refinery FZC |
United Arab Emirates |
Gold |
Dongwu Gold Group |
China |
Gold |
Dowa |
Japan |
Gold |
DSC (Do Sung Corporation) |
Korea, Republic Of |
Gold |
Eco-System Recycling Co., Ltd. East Plant |
Japan |
Gold |
Eco-System Recycling Co., Ltd. North Plant |
Japan |
Gold |
Eco-System Recycling Co., Ltd. West Plant |
Japan |
Gold |
Elite Industech Co., Ltd. |
Taiwan, Province Of China |
Gold |
Emerald Jewel Industry India Limited (Unit 1) |
India |
Gold |
Emerald Jewel Industry India Limited (Unit 2) |
India |
Gold |
Emerald Jewel Industry India Limited (Unit 3) |
India |
Gold |
Emerald Jewel Industry India Limited (Unit 4) |
India |
Gold |
Emirates Gold DMCC |
United Arab Emirates |
Gold |
Fidelity Printers and Refiners Ltd. |
Zimbabwe |
Gold |
Fujairah Gold FZC |
United Arab Emirates |
Gold |
GG Refinery Ltd. |
Tanzania, United Republic Of |
Gold |
GGC Gujrat Gold Centre Pvt. Ltd. |
India |
Gold |
Gold by Gold Colombia |
Colombia |
Gold |
Gold Coast Refinery |
Ghana |
Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
China |
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
China |
Gold |
Guangdong Jinding Gold Limited |
China |
Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
China |
Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
China |
Gold |
Heimerle + Meule GmbH |
Germany |
Gold |
Heraeus Germany GmbH Co. KG |
Germany |
Gold |
Heraeus Metals Hong Kong Ltd. |
China |
Gold |
Hunan Chenzhou Mining Co., Ltd. |
China |
Gold |
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
China |
Gold |
HwaSeong CJ CO., LTD. |
Korea, Republic Of |
Gold |
Impala Platinum - Platinum Metals Refinery (PMR) |
South Africa |
Gold |
Industrial Refining Company |
Belgium |
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
China |
Gold |
International Precious Metal Refiners |
United Arab Emirates |
Gold |
Ishifuku Metal Industry Co., Ltd. |
Japan |
Gold |
Istanbul Gold Refinery |
Turkey |
Gold |
Italpreziosi |
Italy |
|
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Gold |
JALAN & Company |
India |
Gold |
Japan Mint |
Japan |
Gold |
Jiangxi Copper Co., Ltd. |
China |
Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
Russian Federation |
Gold |
JSC Novosibirsk Refinery |
Russian Federation |
Gold |
JSC Uralelectromed |
Russian Federation |
Gold |
JX Nippon Mining & Metals Co., Ltd. |
Japan |
Gold |
K.A. Rasmussen |
Norway |
Gold |
Kaloti Precious Metals |
United Arab Emirates |
Gold |
Kazakhmys Smelting LLC |
Kazakhstan |
Gold |
Kazzinc |
Kazakhstan |
Gold |
Kennecott Utah Copper LLC |
United States Of America |
Gold |
KGHM Polska Miedz Spolka Akcyjna |
Poland |
Gold |
Kojima Chemicals Co., Ltd. |
Japan |
Gold |
Korea Zinc Co., Ltd. |
Korea, Republic Of |
Gold |
Kundan Care Products Ltd. |
India |
Gold |
Kyrgyzaltyn JSC |
Kyrgyzstan |
Gold |
Kyshtym Copper-Electrolytic Plant ZAO |
Russian Federation |
Gold |
L'azurde Company For Jewelry |
Saudi Arabia |
Gold |
Lingbao Gold Co., Ltd. |
China |
Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
China |
Gold |
L'Orfebre S.A. |
Andorra |
Gold |
LS MnM Inc. |
Korea, Republic Of |
Gold |
LT Metal Ltd. |
Korea, Republic Of |
Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
China |
Gold |
Marsam Metals |
Brazil |
Gold |
Materion |
United States Of America |
Gold |
Matsuda Sangyo Co., Ltd. |
Japan |
Gold |
MD Overseas |
India |
Gold |
Metal Concentrators SA (Pty) Ltd. |
South Africa |
Gold |
Metallix Refining Inc. |
United States Of America |
Gold |
Metalor Technologies (Hong Kong) Ltd. |
China |
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
Singapore |
Gold |
Metalor Technologies (Suzhou) Ltd. |
China |
Gold |
Metalor Technologies S.A. |
Switzerland |
Gold |
Metalor USA Refining Corporation |
United States Of America |
Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. |
Mexico |
Gold |
Mitsubishi Materials Corporation |
Japan |
Gold |
Mitsui Mining and Smelting Co., Ltd. |
Japan |
Gold |
MKS PAMP SA |
Switzerland |
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|
Gold |
MMTC-PAMP India Pvt., Ltd. |
India |
Gold |
Modeltech Sdn Bhd |
Malaysia |
Gold |
Morris and Watson |
New Zealand |
Gold |
Moscow Special Alloys Processing Plant |
Russian Federation |
Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. |
Turkey |
Gold |
Navoi Mining and Metallurgical Combinat |
Uzbekistan |
Gold |
NH Recytech Company |
Korea, Republic Of |
Gold |
Nihon Material Co., Ltd. |
Japan |
Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
Austria |
Gold |
Ohura Precious Metal Industry Co., Ltd. |
Japan |
Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
Russian Federation |
Gold |
Pease & Curren |
United States Of America |
Gold |
Penglai Penggang Gold Industry Co., Ltd. |
China |
Gold |
Planta Recuperadora de Metales SpA |
Chile |
Gold |
Prioksky Plant of Non-Ferrous Metals |
Russian Federation |
Gold |
PT Aneka Tambang (Persero) Tbk |
Indonesia |
Gold |
PX Precinox S.A. |
Switzerland |
Gold |
QG Refining, LLC |
United States Of America |
Gold |
Rand Refinery (Pty) Ltd. |
South Africa |
Gold |
Refinery of Seemine Gold Co., Ltd. |
China |
Gold |
REMONDIS PMR B.V. |
Netherlands |
Gold |
Royal Canadian Mint |
Canada |
Gold |
SAAMP |
France |
Gold |
Sabin Metal Corp. |
United States Of America |
Gold |
Safimet S.p.A |
Italy |
Gold |
SAFINA A.S. |
Czechia |
Gold |
Sai Refinery |
India |
Gold |
Sam Precious Metals |
United Arab Emirates |
Gold |
Samduck Precious Metals |
Korea, Republic Of |
Gold |
Samwon Metals Corp. |
Korea, Republic Of |
Gold |
SEMPSA Joyeria Plateria S.A. |
Spain |
Gold |
Shandong Gold Smelting Co., Ltd. |
China |
Gold |
Shandong Humon Smelting Co., Ltd. |
China |
Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
China |
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
China |
Gold |
Shenzhen CuiLu Gold Co., Ltd. |
China |
Gold |
SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. |
China |
Gold |
Shenzhen Zhonghenglong Real Industry Co., Ltd. |
China |
|
|
|
Gold |
Shirpur Gold Refinery Ltd. |
India |
Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
China |
Gold |
Singway Technology Co., Ltd. |
Taiwan, Province Of China |
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
Russian Federation |
Gold |
Solar Applied Materials Technology Corp. |
Taiwan, Province Of China |
Gold |
Sovereign Metals |
India |
Gold |
State Research Institute Center for Physical Sciences and Technology |
Lithuania |
Gold |
Sudan Gold Refinery |
Sudan |
Gold |
Sumitomo Metal Mining Co., Ltd. |
Japan |
Gold |
SungEel HiMetal Co., Ltd. |
Korea, Republic Of |
Gold |
Super Dragon Technology Co., Ltd. |
Taiwan, Province Of China |
Gold |
T.C.A S.p.A |
Italy |
Gold |
Tanaka Kikinzoku Kogyo K.K. |
Japan |
Gold |
Tokuriki Honten Co., Ltd. |
Japan |
Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
China |
Gold |
TOO Tau-Ken-Altyn |
Kazakhstan |
Gold |
Torecom |
Korea, Republic Of |
Gold |
Umicore Precious Metals Thailand |
Thailand |
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
Belgium |
Gold |
United Precious Metal Refining, Inc. |
United States Of America |
Gold |
Valcambi S.A. |
Switzerland |
Gold |
WEEEREFINING |
France |
Gold |
Western Australian Mint (T/a The Perth Mint) |
Australia |
Gold |
WIELAND Edelmetalle GmbH |
Germany |
Gold |
Yamakin Co., Ltd. |
Japan |
Gold |
Yokohama Metal Co., Ltd. |
Japan |
Gold |
Yunnan Copper Industry Co., Ltd. |
China |
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
China |
Tantalum |
5D Production OU |
Estonia |
Tantalum |
AMG Brasil |
Brazil |
Tantalum |
D Block Metals, LLC |
United States Of America |
Tantalum |
F&X Electro-Materials Ltd. |
China |
Tantalum |
FIR Metals & Resource Ltd. |
China |
Tantalum |
Global Advanced Metals Aizu |
Japan |
Tantalum |
Global Advanced Metals Boyertown |
United States Of America |
Tantalum |
Guangdong Rising Rare Metals-EO Materials Ltd. |
China |
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
China |
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
China |
Tantalum |
Jiangxi Sanshi Nonferrous Metals Co., Ltd |
China |
Tantalum |
Jiangxi Tuohong New Raw Material |
China |
|
|
|
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
China |
Tantalum |
Jiujiang Tanbre Co., Ltd. |
China |
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
China |
Tantalum |
KEMET de Mexico |
Mexico |
Tantalum |
Materion Newton Inc. |
United States Of America |
Tantalum |
Metallurgical Products India Pvt., Ltd. |
India |
Tantalum |
Mineracao Taboca S.A. |
Brazil |
Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
Japan |
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
China |
Tantalum |
NPM Silmet AS |
Estonia |
Tantalum |
PowerX Ltd. |
Rwanda |
Tantalum |
QuantumClean |
United States Of America |
Tantalum |
Resind Industria e Comercio Ltda. |
Brazil |
Tantalum |
RFH Yancheng Jinye New Material Technology Co., Ltd. |
China |
Tantalum |
Solikamsk Magnesium Works OAO |
Russian Federation |
Tantalum |
Taki Chemical Co., Ltd. |
Japan |
Tantalum |
TANIOBIS Co., Ltd. |
Thailand |
Tantalum |
TANIOBIS GmbH |
Germany |
Tantalum |
TANIOBIS Japan Co., Ltd. |
Japan |
Tantalum |
TANIOBIS Smelting GmbH & Co. KG |
Germany |
Tantalum |
Telex Metals |
United States Of America |
Tantalum |
Ulba Metallurgical Plant JSC |
Kazakhstan |
Tantalum |
XIMEI RESOURCES (GUANGDONG) LIMITED |
China |
Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. |
China |
Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
China |
Tin |
Alpha |
United States Of America |
Tin |
An Vinh Joint Stock Mineral Processing Company |
Viet Nam |
Tin |
Aurubis Beerse |
Belgium |
Tin |
Aurubis Berango |
Spain |
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
China |
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
China |
Tin |
China Tin Group Co., Ltd. |
China |
Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
Brazil |
Tin |
CRM Synergies |
Spain |
Tin |
CV Ayi Jaya |
Indonesia |
Tin |
CV Venus Inti Perkasa |
Indonesia |
Tin |
Dongguan CiEXPO Environmental Engineering Co., Ltd. |
China |
Tin |
Dowa |
Japan |
Tin |
DS Myanmar |
Myanmar |
|
|
|
Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
Viet Nam |
Tin |
EM Vinto |
Bolivia (Plurinational State Of) |
Tin |
Estanho de Rondonia S.A. |
Brazil |
Tin |
Fabrica Auricchio Industria e Comercio Ltda. |
Brazil |
Tin |
Fenix Metals |
Poland |
Tin |
Gejiu City Fuxiang Industry and Trade Co., Ltd. |
China |
Tin |
Gejiu Kai Meng Industry and Trade LLC |
China |
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
China |
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
China |
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
China |
Tin |
Global Advanced Metals Greenbushes Pty Ltd. |
Australia |
Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
China |
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
China |
Tin |
Jiangxi New Nanshan Technology Ltd. |
China |
Tin |
Luna Smelter, Ltd. |
Rwanda |
Tin |
Ma'anshan Weitai Tin Co., Ltd. |
China |
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
Brazil |
Tin |
Malaysia Smelting Corporation (MSC) |
Malaysia |
Tin |
Malaysia Smelting Corporation Berhad (Port Klang) |
Malaysia |
Tin |
Melt Metais e Ligas S.A. |
Brazil |
Tin |
Metallic Resources, Inc. |
United States Of America |
Tin |
Mineracao Taboca S.A. |
Brazil |
Tin |
Mining Minerals Resources SARL |
Congo, Democratic Republic Of The |
Tin |
Minsur |
Peru |
Tin |
Mitsubishi Materials Corporation |
Japan |
Tin |
Modeltech Sdn Bhd |
Malaysia |
Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
Viet Nam |
Tin |
Novosibirsk Tin Combine |
Russian Federation |
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
Thailand |
Tin |
O.M. Manufacturing Philippines, Inc. |
Philippines |
Tin |
Operaciones Metalurgicas S.A. |
Bolivia (Plurinational State Of) |
Tin |
Pongpipat Company Limited |
Myanmar |
Tin |
Precious Minerals and Smelting Limited |
India |
Tin |
PT Aries Kencana Sejahtera |
Indonesia |
Tin |
PT Artha Cipta Langgeng |
Indonesia |
Tin |
PT ATD Makmur Mandiri Jaya |
Indonesia |
Tin |
PT Babel Inti Perkasa |
Indonesia |
Tin |
PT Babel Surya Alam Lestari |
Indonesia |
Tin |
PT Bangka Prima Tin |
Indonesia |
|
|
|
Tin |
PT Bangka Serumpun |
Indonesia |
Tin |
PT Bangka Tin Industry |
Indonesia |
Tin |
PT Bukit Timah |
Indonesia |
Tin |
PT Cipta Persada Mulia |
Indonesia |
Tin |
PT Menara Cipta Mulia |
Indonesia |
Tin |
PT Mitra Stania Prima |
Indonesia |
Tin |
PT Mitra Sukses Globalindo |
Indonesia |
Tin |
PT Premium Tin Indonesia |
Indonesia |
Tin |
PT Prima Timah Utama |
Indonesia |
Tin |
PT Putera Sarana Shakti (PT PSS) |
Indonesia |
Tin |
PT Rajawali Rimba Perkasa |
Indonesia |
Tin |
PT Rajehan Ariq |
Indonesia |
Tin |
PT Refined Bangka Tin |
Indonesia |
Tin |
PT Sariwiguna Binasentosa |
Indonesia |
Tin |
PT Stanindo Inti Perkasa |
Indonesia |
Tin |
PT Sukses Inti Makmur |
Indonesia |
Tin |
PT Timah Nusantara |
Indonesia |
Tin |
PT Timah Tbk Kundur |
Indonesia |
Tin |
PT Timah Tbk Mentok |
Indonesia |
Tin |
PT Tinindo Inter Nusa |
Indonesia |
Tin |
PT Tommy Utama |
Indonesia |
Tin |
Resind Industria e Comercio Ltda. |
Brazil |
Tin |
RIKAYAA GREENTECH PRIVATE LIMITED |
India |
Tin |
Rui Da Hung |
Taiwan, Province Of China |
Tin |
Super Ligas |
Brazil |
Tin |
Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. |
Japan |
Tin |
Thaisarco |
Thailand |
Tin |
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
China |
Tin |
Tin Technology & Refining |
United States Of America |
Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
Viet Nam |
Tin |
VQB Mineral and Trading Group JSC |
Viet Nam |
Tin |
White Solder Metalurgia e Mineracao Ltda. |
Brazil |
Tin |
Woodcross Smelting Company Limited |
Uganda |
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
China |
Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
China |
Tungsten |
A.L.M.T. Corp. |
Japan |
Tungsten |
ACL Metais Eireli |
Brazil |
Tungsten |
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
Brazil |
Tungsten |
Artek LLC |
Russian Federation |
|
|
|
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
Viet Nam |
Tungsten |
China Molybdenum Tungsten Co., Ltd. |
China |
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
China |
Tungsten |
CNMC (Guangxi) PGMA Co., Ltd. |
China |
Tungsten |
Cronimet Brasil Ltda |
Brazil |
Tungsten |
DONGKUK INDUSTRIES CO., LTD. |
Korea, Republic Of |
Tungsten |
Fujian Xinlu Tungsten Co., Ltd. |
China |
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
China |
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
China |
Tungsten |
Global Tungsten & Powders LLC |
United States Of America |
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
China |
Tungsten |
H.C. Starck Tungsten GmbH |
Germany |
Tungsten |
HANNAE FOR T Co., Ltd. |
Korea, Republic Of |
Tungsten |
Hubei Green Tungsten Co., Ltd. |
China |
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
China |
Tungsten |
Hunan Jintai New Material Co., Ltd. |
China |
Tungsten |
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
China |
Tungsten |
Hydrometallurg, JSC |
Russian Federation |
Tungsten |
Japan New Metals Co., Ltd. |
Japan |
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
China |
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
China |
Tungsten |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
China |
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
China |
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
China |
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
China |
Tungsten |
JSC "Kirovgrad Hard Alloys Plant" |
Russian Federation |
Tungsten |
Kenee Mining Corporation Vietnam |
Viet Nam |
Tungsten |
Kennametal Fallon |
United States Of America |
Tungsten |
Kennametal Huntsville |
United States Of America |
Tungsten |
Lianyou Metals Co., Ltd. |
Taiwan, Province Of China |
Tungsten |
Lianyou Resources Co., Ltd. |
Taiwan, Province Of China |
Tungsten |
LLC Vostok |
Russian Federation |
Tungsten |
MALAMET SMELTING SDN. BHD. |
Malaysia |
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
China |
Tungsten |
Masan High-Tech Materials |
Viet Nam |
Tungsten |
Moliren Ltd. |
Russian Federation |
Tungsten |
Nam Viet Cromit Joint Stock Company |
Viet Nam |
Tungsten |
Niagara Refining LLC |
United States Of America |
|
|
|
Tungsten |
NPP Tyazhmetprom LLC |
Russian Federation |
Tungsten |
OOO “Technolom” 1 |
Russian Federation |
Tungsten |
OOO “Technolom” 2 |
Russian Federation |
Tungsten |
Philippine Bonway Manufacturing Industrial Corporation |
Philippines |
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
Philippines |
Tungsten |
Shinwon Tungsten (Fujian Shanghang) Co., Ltd. |
China |
Tungsten |
TANIOBIS Smelting GmbH & Co. KG |
Germany |
Tungsten |
Tungsten Vietnam Joint Stock Company |
Viet Nam |
Tungsten |
Unecha Refractory metals plant |
Russian Federation |
Tungsten |
Wolfram Bergbau und Hutten AG |
Austria |
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
China |
Tungsten |
Xiamen Tungsten Co., Ltd. |
China |
Tungsten |
YUDU ANSHENG TUNGSTEN CO., LTD. |
China |
Attachment B
Based on aggregated country of origin data obtained by the Company through Assent, the processing facilities identified in Attachment A source raw materials from one or more of the following countries: Albania, Andorra, Angola, Argentina, Armenia, Australia, Austria, Azerbaijan, Belarus, Belgium, Benin, Bermuda, Bolivia, Botswana, Brazil, Bulgaria, Burkina Faso, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo, Cote d’Ivoire, Cyprus, Democratic Republic of the Congo, Djibouti, Dominica, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Eswatini, Estonia, Ethiopia, Fiji, Finland, France, Georgia, Germany, Ghana, Guam, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jersey, Kazakhstan, Kenya, Kyrgyzstan, Luxembourg, Liberia, Liechtenstein, Lithuania, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Norway, Oman, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russia, Rwanda, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Soloman Islands, South Africa, South Korea, South Sudan, Spain, Sudan, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Togo, Turkey, Uganda, United Arab Emirates, United Kingdom, United States of America, Uruguay, Uzbekistan, Vietnam and Zambia.