EXHIBIT 1.01
CONFLICT MINERALS REPORT OF IRIDIUM COMMUNICATIONS INC.
For the year ended December 31, 2025
This Conflict Minerals Report (this “Report”) of Iridium Communications Inc. (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2025 to December 31, 2025 (the “Reporting Period”). 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 (the “Dodd-Frank Act”). For purposes of this Report, “conflict minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, the Company contracts to manufacture products for which conflict minerals are necessary to their functionality or production.
Description of the Company’s Products Covered by this Report
The Company is a provider of mobile voice and data communications services via satellite. The Company also sells related voice and data equipment that it contracts to manufacture, including satellite handsets, Wi-Fi accessories, voice and data modems, broadband data devices and machine-to-machine data devices. The Company has determined that conflict minerals are necessary to the functionality or production of this equipment. These products are collectively referred to in this Report as the “Covered Products.” This Report relates to Covered Products the manufacture of which was completed during the Reporting Period.
Reasonable Country of Origin Inquiry
The Company has conducted a good faith reasonable country-of-origin inquiry (“RCOI”) regarding the conflict minerals necessary to the Covered Products that was reasonably designed to determine whether any of the conflict minerals originated in the Covered Countries and whether any of the conflict minerals may be from recycled or scrap sources. The RCOI consisted principally of identifying the suppliers of components that contain conflict minerals and circulating to them a supply-chain survey using the conflict minerals Reporting Template of the Responsible Minerals Initiative (the “RMI template”). Among the purposes of this supplier survey was to identify, if possible, the suppliers, including smelters and refiners that contribute smelted or refined conflict minerals to the Company’s products, and to request information from those identified suppliers, smelters and refiners regarding whether any of the conflict minerals in the components they provided originated from Covered Countries and whether those conflict minerals came from recycled or scrap sources.
Because, based on its RCOI, the Company could not determine the country of origin of all conflict minerals used in Covered Products, the Company also performed due diligence on the source and chain of custody of such conflict minerals.
The Company’s Due Diligence Process
The Company’s due diligence measures were based on multi-industry initiatives with the smelters and refiners of conflict minerals that provide those conflict minerals to the Company’s
suppliers. The Company’s supply chain with respect to the Covered Products is complex, and as a purchaser, the Company is many steps removed from the mining and smelting or refining of the conflict minerals. The Company does not purchase raw ore or unrefined conflict minerals and does no purchasing in the Covered Countries. The origin of conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other Conflict Mineral-containing derivatives. Because the smelters and refiners are consolidating points for raw ore, the Company believes the smelters and refiners are in the best position in the supply chain to know the origin of the ores. Tracing these minerals to their sources is therefore a challenge that requires the Company to enlist its suppliers in the Company’s efforts to achieve supply chain transparency, including its efforts to obtain information regarding the origin of conflict minerals. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. Because of the Company’s location within the supply chain in relation to the actual extraction, transport, smelting, and refinement of conflict minerals, its ability to verify the accuracy of information reported by suppliers is limited.
The Company has regular contact with a limited number of suppliers – its first-tier suppliers – within its supply chain. The Company’s second-tier suppliers report to the Company’s direct suppliers and contract manufacturers, some of which, like the Company, are subject to the Rule and file specialized disclosure reports on Form SD annually as required. The Company has chosen to directly survey all its second-tier suppliers in lieu of relying only on the surveying efforts of contract manufacturers or other direct suppliers. These efforts include, but are not limited to, requesting and receiving supplier RMI templates.
A.Design of the Company’s due diligence framework
The design of the Company’s due diligence measures conforms, in all material respects, with the internationally recognized due diligence framework in The Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (OECD 2016), including related Supplements for each of the conflict minerals, consistent with the Company’s position as a downstream company.
Establish Strong Company Management Systems
•Conflict Minerals Team. The Company maintains a Conflict Minerals Team comprised of senior members of its legal, manufacturing, engineering and purchasing organizations under the oversight of the Chief Legal Officer.
•Policy. The Company has communicated to its suppliers and the public the Company’s Conflict Minerals Policy (the “Policy”). The Policy can be found here: https://www.iridium.com/conflict-minerals-policy. Any reference to the Company’s website in the Form SD or this Report is provided for convenience only, and its contents are not incorporated by reference into the Form SD or this Report nor deemed filed with the SEC.
•System of controls and transparency. The Company maintains internal standard operating procedures to guide the Company’s due diligence efforts. These procedures establish a process to be followed in order to generate and maintain the information needed to comply with Section 1502 of the Dodd-Frank Act.
•Strengthen engagement with suppliers. The Company maintains a standard provision in its supply chain contracts under which the supplier agrees that it shall not knowingly include conflict minerals in any products that it delivers to the Company that originate from the Covered Countries. The provision further states that the supplier agrees to cooperate in any audit and produce any information that may reasonably be required by the Company to ensure that it fully complies with its legal and regulatory obligations that
govern the use of conflict minerals. This provision also requests that this clause be included in agreements that each supplier may have with its suppliers, vendors, or subcontractors. Where a supplier includes conflict minerals in products that it delivers to the Company that originate from the Covered Countries from a smelter or refiner that has been validated as conflict-free by organizations such as RMI, the Company has elected to take no enforcement action.
•Establish a company grievance mechanism. The Company maintains a grievance mechanism for concerned parties who wish to report information regarding the Company’s use of conflict minerals. Communications may be sent to supplychain@iridium.com.
Identify and Assess Risks in the Supply Chain
Identify smelters and refiners in the supply chain. The Company assessed its Covered Products and its suppliers in order to identify conflict minerals scope and risk. The Company’s Covered Products and suppliers were reviewed throughout the year. The Company looked for supplier changes in its supply chain and evaluated new suppliers for use of conflict minerals through a review of internal documents, including bills of material, materials declarations, and purchasing contracts. New suppliers were assessed as part of the Company’s vendor due diligence and compliance assessment program, which was designed to assess transparency from its vendors and compliance with the Policy. Suppliers identified as providing parts to the Company that included conflict minerals were tracked through an information system that captures and categorizes supplier and product information.
The Company surveyed the suppliers on the Company’s master supplier list. The Company also conducted a survey of its direct and second-tier suppliers used by its contract manufacturers, Benchmark Electronics, Inc. and Beam Communications Pty Ltd., unless it was explicitly known from the material description or internal review that the material purchased did not contain conflict minerals. Due to the Company’s location within the supply chain relative to the extraction, transport, smelting, and refinement of ore, its ability to verify the accuracy of information reported by suppliers is limited. The Company requested that suppliers provide sourcing information for materials used in all products manufactured during the Reporting Period.
Assessment of risk. All Company suppliers’ responses were assessed by evaluating the reasonableness and consistency of responses within the RMI template and follow-up email correspondence, as well as information known about supplies and suppliers. To the extent that, based on data provided by its suppliers, the Company was able to identify smelters and refiners that might be in the Company’s supply chain, the Company took steps to assess the smelter’s or refiner’s due diligence to the extent practicable. To that end, the Company examined whether each smelter or refiner had been validated as conflict-free through industry group programs, such as the RMI’s Responsible Minerals Assurance Process (the “RMAP”). The RMAP provides a list of smelters and refiners that an independent third-party audit has confirmed have systems in place that comply with the RMAP’s assessment protocols to ensure sourcing of only conflict-free minerals.
Design and Implement Strategy to Respond to Identified Risks
Strategy to respond to identified risks. The Company has developed a strategy to manage suppliers that cannot or will not provide sufficient component and supply chain information or are using minerals from smelters or refiners that have not received a “conflict free” designation. The specific supplier corrective actions taken will depend on factors such as vendor size, risk
level and vendor capabilities, and may include actions ranging from encouraging the supplier to source responsibly to removing the supplier from the Company’s supply chain.
Steps taken to implement strategy to mitigate risk. The Company completes steps to improve its due diligence process, improve its supply chain transparency, and further mitigate the risk that conflict minerals necessary to the Covered Products finance or benefit armed groups in the Covered Countries:
•Encouraging supplier participation in an industry initiative such as iPoint to increase compliance and response rate to suppliers’ smelter surveys.
•Providing training materials for suppliers, if requested, on responsible sourcing to increase the response rate and improve the content of the supplier survey responses.
•Developing and communicating a policy whereby suppliers that do not improve their responses in a timely fashion will be evaluated for potential removal as a preferred supplier from the Company’s supply chain.
•Conducting independent research to attempt to identify and respond to risks in the Company’s supply chain.
Carry Out Independent Third-Party Audit of Supply Chain
The Company does not have any direct relationships with smelters or refiners that process conflict minerals, and it does not perform or direct audits of these entities within its supply chain. As an alternative, the Company considers information collected and provided by independent third-party audit programs, such as the RMAP.
Report Annually on Supply Chain Due Diligence
The Company expects to report annually, as required by the Rule, and has posted this Report on its website here: https://www.iridium.com/company/corporate-social-responsibility#governance-policies.
B.Description of the Company’s due diligence measures performed with respect to Covered Products the manufacture of which was completed during the Reporting Period
The Company’s due diligence measures performed with respect to Covered Products the manufacture of which was completed during the Reporting Period followed the due diligence framework described above and included:
•Providing a monthly briefing to members of supply chain management about results of the Company’s due diligence efforts. A member of senior management was briefed about the results of the Company’s due diligence efforts on a quarterly basis.
•Keeping an up-to-date Policy. Inquiries with regard to conflict minerals are communicated to the Company’s supply chain information team.
•Maintaining a contract template with a standard provision regarding conflict minerals. Any changes to the Company’s contracts or contracts in progress are subject to negotiation and the Company’s review and approval process.
•Requesting a full list of supplier information from the Company’s contract manufacturers that have direct contact with suppliers in the supply chain.
•Analyzing the bill of materials for each product to confirm all identified suppliers are included within the Company’s due diligence efforts.
•Conducting its due diligence using the RMI template, requesting country-of-origin information regarding the conflict minerals and identification of smelters and refiners that process such minerals.
•Completing follow-up inquiries to obtain as much needed information as reasonably possible from as many surveyed suppliers as reasonably possible.
•Comparing survey results to information collected via independent third-party conflict-free smelter validation programs, such as RMAP, to determine if the identified smelters or refiners have been validated as conflict-free.
•Discussing actions to be taken with regard to suppliers that do not comply with the Policy.
•Filing the specialized disclosure report on Form SD and related conflict minerals report annually as required by the SEC.
C. Results of the Company’s Due Diligence
Identified Smelters and Refiners. As a result of the Company’s due diligence efforts and based on information provided by most of the Company’s suppliers, the Company has identified and obtained completed RMI templates from most of its suppliers that provide components containing conflict minerals. However, in most cases, the information provided by suppliers was not specific enough to identify the smelters and refiners that processed the conflict minerals in the specific components provided by the supplier to the Company, and instead included information regarding the smelters and refiners that processed conflict minerals used by the responding supplier only on a company-wide or general product basis. In those cases, the Company has not been able to reasonably or reliably determine whether the identified smelters and refiners processed conflict minerals used in the components furnished to the Company for use in the Covered Products and thus did not include the smelters or refiners on Appendix A below. However, when the supplier provided information that reasonably appeared to be specific product-level information, the smelters or refiners identified by the supplier are listed on Appendix A. Based on the information that was provided by the Company’s suppliers through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that may have been used to process the conflict minerals contained in the Covered Products included the smelters and refiners identified on Appendix A.
Identified Countries of Origin. Based on the information provided by suppliers pursuant to the due diligence process, the Company does not have sufficient information to reliably determine the countries of origin of all the conflict minerals in the Covered Products. However, as noted above, when the supplier provided information that reasonably appeared to be specific enough to identify the smelters and refiners that processed the conflict minerals in the specific components provided by the supplier to the Company, the Company has listed on Appendix B the countries of origin of the conflict minerals identified by the supplier. When the supplier provided only company-level or general product information, the Company determined that it did not have sufficient information to identify with any reasonable level of confidence the particular countries of origin of the conflict minerals contained in the component in the Covered Products.
Determination. The Company received responses from 74% of its suppliers that provide components containing conflict minerals contained in Covered Products. On the basis of the due diligence measures performed, the Company believes, to the extent reasonably determinable, that of the responses received, including specific product level, supplier defined, and broader company level responses, 85.7% either (i) provided materials that did not contain conflict minerals, (ii) believe they provided materials containing conflict minerals not originating in the Covered Countries, or (iii) believe they provided materials containing conflict minerals that do
originate from the Covered Countries but were processed using certified conflict-free smelters or refiners or from smelters or refiners that were “Active” or “Conformant” and 14.3% of the suppliers from which the Company obtained sourcing information provided materials that contained conflict minerals that are of uncertain origin (in each case as defined on Appendix A).
D. Measures to Improve Due Diligence
The Company currently expects to continue to perform its supply chain due diligence measures with the goal of achieving greater accuracy and transparency into the Company’s supply chain by reviewing supplier contracts and their conflict minerals policies on an as-needed basis to verify that relevant Conflict Mineral provisions are in place, developing the Company’s Conflict Mineral guidelines and procedures as needed, creating further awareness within the organization to promote positive change, and continually identifying areas of improvement.
Forward-Looking Statements
Statements in this Report that are not strictly historical statements may constitute forward-looking statements as defined in the Private Securities litigation Reform Act of 1995. Forward-looking statements, include, without limitation, the Company’s intentions and expectations regarding future supplier engagement, due diligence and risk mitigation efforts, strategy, and future reporting. Actual results could differ materially from the forward-looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers, third-party audit programs or others, as well as the possibility of future statutory and regulatory changes.
Appendix A
Conformant - The “Conformant” status reflects successful completion of an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment as reported by RMAP.
Active - The “Active” status reflects commitment to undergo an RMAP assessment, completion of the relevant documents, and scheduling the on-site assessment as reported by RMAP. These smelters and refiners may be in the pre-assessment, assessment, or corrective-action phases of the assessment.
| | | | | | | | | | | | | | |
| Metal | Smelter Identification | Smelter Reference List | Smelter Country | RMI Smelter List |
| Tantalum | CID000616 | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | Conformant |
| Tantalum | CID000460 | F&X Electro-Materials Ltd. | CHINA | Conformant |
| Tantalum | CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tantalum | CID000917 | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant |
| Tantalum | CID001163 | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
| Tantalum | CID001192 | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Tantalum | CID001200 | NPM Silmet AS | ESTONIA | Conformant |
| Tantalum | CID001277 | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
| Tantalum | CID001522 | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | CID001891 | Telex Metals | UNITED STATES OF AMERICA | Conformant |
| Tantalum | CID001969 | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
| Tantalum | CID002492 | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
| Tantalum | CID002504 | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant |
| Tantalum | CID002505 | FIR Metals & Resource Ltd. | CHINA | Conformant |
| Tantalum | CID002506 | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | CID002539 | KEMET de Mexico | MEXICO | Conformant |
| Tantalum | CID002544 | TANIOBIS Co., Ltd. | THAILAND | Conformant |
| Tantalum | CID002545 | TANIOBIS GmbH | GERMANY | Conformant |
| Tantalum | CID002548 | Materion Newton Inc. | UNITED STATES OF AMERICA | Conformant |
| Tantalum | CID002549 | TANIOBIS Japan Co., Ltd. | JAPAN | Conformant |
| Tantalum | CID002550 | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tantalum | CID002557 | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant |
| Tantalum | CID002558 | Global Advanced Metals Aizu | JAPAN | Conformant |
| Tantalum | CID002842 | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
| Tantalum | CID001076 | AMG Brasil | BRAZIL | Conformant |
| Tantalum | CID001175 | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tantalum | CID002707 | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tantalum | CID002512 | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | CID003583 | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | Conformant |
| | | | | | | | | | | | | | |
| Tantalum | CID001869 | Taki Chemical Co., Ltd. | JAPAN | Conformant |
| Tantalum | CID001508 | QuantumClean | UNITED STATES OF AMERICA | Conformant |
| Tantalum | CID002508 | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
| Tantalum | CID000291 | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant |
| Tantalum | CID000211 | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | CID003191 | Jiujiang Janny New Material Co., Ltd. | CHINA | Conformant |
| Tantalum | CID004054 | PowerX Ltd. | RWANDA | Conformant |
| Tin | CID004434 | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA | Conformant |
| Tin | CID000292 | Alpha | UNITED STATES OF AMERICA | Conformant |
| Tin | CID003325 | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
| Tin | CID001142 | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
| Tin | CID001314 | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
| Tin | CID001898 | Thaisarco | THAILAND | Conformant |
| Tin | CID001539 | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tin | CID002774 | Aurubis Berango | SPAIN | Conformant |
| Tin | CID003387 | Luna Smelter, Ltd. | RWANDA | Conformant |
| Tin | CID002517 | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
| Tin | CID000468 | Fenix Metals | POLAND | Conformant |
| Tin | CID001182 | Minsur | PERU | Conformant |
| Tin | CID001105 | Malaysia Smelting Corporation (MSC) | MALAYSIA | |
| Tin | CID000402 | Dowa | JAPAN | Conformant |
| Tin | CID001191 | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Tin | CID001477 | PT Timah Tbk Kundur | INDONESIA | Conformant |
| Tin | CID001482 | PT Timah Tbk Mentok | INDONESIA | Conformant |
| Tin | CID001453 | PT Mitra Stania Prima | INDONESIA | Conformant |
| Tin | CID002503 | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
| Tin | CID002696 | PT Cipta Persada Mulia | INDONESIA | Conformant |
| Tin | CID002593 | PT Rajehan Ariq | INDONESIA | Conformant |
| Tin | CID001458 | PT Prima Timah Utama | INDONESIA | Conformant |
| Tin | CID001070 | China Tin Group Co., Ltd. | CHINA | Conformant |
| Tin | CID000538 | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
| Tin | CID000228 | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
| Tin | CID003397 | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tin | CID002158 | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | |
| Tin | CID002180 | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | Conformant |
| Tin | CID003116 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
| | | | | | | | | | | | | | |
| Tin | CID001231 | Jiangxi New Nanshan Technology Ltd. | CHINA | Active |
| Tin | CID003190 | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | CID002036 | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
| Tin | CID001173 | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tin | CID002756 | Super Ligas | BRAZIL | Conformant |
| Tin | CID001337 | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | CID002468 | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
| Tin | CID002706 | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tin | CID000438 | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | CID002773 | Aurubis Beerse | BELGIUM | Conformant |
| Tin | CID003449 | PT Mitra Sukses Globalindo | INDONESIA | Conformant |
| Tin | CID003524 | CRM Synergies | SPAIN | Conformant |
| Tin | CID003868 | PT Putera Sarana Shakti (PT PSS) | INDONESIA | Conformant |
| Tin | CID002570 | CV Ayi Jaya | INDONESIA | Conformant |
| Tin | CID000448 | Estanho de Rondonia S.A. | BRAZIL | Conformant |
| Tin | CID003486 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | Active |
| Tin | CID003582 | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tin | CID000309 | PT Aries Kencana Sejahtera | INDONESIA | |
| Tin | CID001399 | PT Artha Cipta Langgeng | INDONESIA | Active |
| Tin | CID001402 | PT Babel Inti Perkasa | INDONESIA | |
| Tin | CID001406 | PT Babel Surya Alam Lestari | INDONESIA | |
| Tin | CID001428 | PT Bukit Timah | INDONESIA | |
| Tin | CID001460 | PT Refined Bangka Tin | INDONESIA | |
| Tin | CID001463 | PT Sariwiguna Binasentosa | INDONESIA | |
| Tin | CID001468 | PT Stanindo Inti Perkasa | INDONESIA | |
| Tin | CID001490 | PT Tinindo Inter Nusa | INDONESIA | |
| Tin | CID001493 | PT Tommy Utama | INDONESIA | |
| Tin | CID002816 | PT Sukses Inti Makmur | INDONESIA | |
| Tin | CID002835 | PT Menara Cipta Mulia | INDONESIA | |
| Tin | CID003381 | PT Rajawali Rimba Perkasa | INDONESIA | |
| Tin | CID003831 | DS Myanmar | MYANMAR | |
| Tin | CID000313 | PT Premium Tin Indonesia | INDONESIA | Conformant |
| Tin | CID002776 | PT Bangka Prima Tin | INDONESIA | Conformant |
| Tin | CID003379 | Ma'anshan Weitai Tin Co., Ltd. | CHINA | |
| Tin | CID004065 | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE | Conformant |
| Tin | CID005067 | PT Arsed Indonesia | INDONESIA | Conformant |
| Tin | CID002185 | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | |
| Tin | CID002844 | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | CID001758 | Soft Metais Ltda. | BRAZIL | Conformant |
| | | | | | | | | | | | | | |
| Tin | CID004403 | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | JAPAN | Conformant |
| Tin | CID004724 | Woodcross Smelting Company Limited | UGANDA | Conformant |
| Tin | CID003409 | Precious Minerals and Smelting Limited | INDIA | |
| Gold | CID002030 | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant |
| Gold | CID001980 | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
| Gold | CID000058 | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant |
| Gold | CID000185 | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
| Gold | CID001534 | Royal Canadian Mint | CANADA | Conformant |
| Gold | CID000924 | Asahi Refining Canada Ltd. | CANADA | Conformant |
| Gold | CID001736 | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
| Gold | CID001147 | Metalor Technologies (Suzhou) Ltd. | China | Conformant |
| Gold | CID001149 | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
| Gold | CID001916 | Shandong Gold Smelting Co., Ltd. | CHINA | Conformant |
| Gold | CID000707 | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
| Gold | CID002224 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
| Gold | CID002243 | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
| Gold | CID001622 | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| Gold | CID000855 | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
| Gold | CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
| Gold | CID002290 | SAFINA A.S. | CZECHIA | Conformant |
| Gold | CID000711 | Heraeus Germany GmbH Co. KG | GERMANY | Conformant |
| Gold | CID000113 | Aurubis AG | GERMANY | Conformant |
| Gold | CID000035 | Agosi AG | GERMANY | Conformant |
| Gold | CID000176 | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
| Gold | CID002778 | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
| Gold | CID000694 | Heimerle + Meule GmbH | GERMANY | Conformant |
| Gold | CID001397 | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
| Gold | CID002765 | Italpreziosi | ITALY | Conformant |
| Gold | CID002580 | T.C.A S.p.A | ITALY | Conformant |
| Gold | CID000233 | Chimet S.p.A. | ITALY | Conformant |
| Gold | CID001188 | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Gold | CID000425 | Eco-System Recycling Co., Ltd. East Plant | JAPAN | Conformant |
| Gold | CID001193 | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Gold | CID000401 | Dowa | JAPAN | Conformant |
| Gold | CID001875 | Tanaka Kikinzoku Kogyo K.K. | Japan | Conformant |
| Gold | CID000264 | Chugai Mining | JAPAN | Conformant |
| Gold | CID000807 | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | CID001119 | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
| Gold | CID002129 | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
| | | | | | | | | | | | | | |
| Gold | CID000981 | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
| Gold | CID000082 | ASAHI METALFINE, Inc. | JAPAN | Conformant |
| Gold | CID002100 | Yamakin Co., Ltd. | JAPAN | Conformant |
| Gold | CID001798 | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
| Gold | CID001259 | Nihon Material Co., Ltd. | JAPAN | Conformant |
| Gold | CID001325 | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | CID000937 | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
| Gold | CID000823 | Japan Mint | JAPAN | Conformant |
| Gold | CID000090 | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Gold | CID000019 | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
| Gold | CID001938 | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
| Gold | CID000957 | Kazzinc | KAZAKHSTAN | Conformant |
| Gold | CID000359 | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
| Gold | CID002605 | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | CID002918 | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | CID000689 | LT Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | CID002582 | REMONDIS PMR B.V. | NETHERLANDS | Conformant |
| Gold | CID001161 | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant |
| Gold | CID001152 | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
| Gold | CID001585 | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant |
| Gold | CID001512 | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | CID000157 | Boliden Ronnskar | SWEDEN | Conformant |
| Gold | CID001498 | PX Precinox S.A. | SWITZERLAND | Conformant |
| Gold | CID001153 | Metalor Technologies S.A. | SWITZERLAND | Conformant |
| Gold | CID000077 | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
| Gold | CID002003 | Valcambi S.A. | SWITZERLAND | Conformant |
| Gold | CID001352 | MKS PAMP SA | SWITZERLAND | Conformant |
| Gold | CID001761 | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Gold | CID001220 | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant |
| Gold | CID000814 | Istanbul Gold Refinery | TURKEY | Conformant |
| Gold | CID001157 | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| Gold | CID000920 | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | CID001993 | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | CID000015 | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant |
| Gold | CID001113 | Materion | UNITED STATES OF AMERICA | Conformant |
| Gold | CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
| Gold | CID002762 | L'Orfebre S.A. | ANDORRA | |
| Gold | CID002779 | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Active |
| | | | | | | | | | | | | | |
| Gold | CID002919 | Planta Recuperadora de Metales SpA | CHILE | Conformant |
| Gold | CID002509 | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
| Gold | CID003424 | Eco-System Recycling Co., Ltd. North Plant | JAPAN | Conformant |
| Gold | CID003425 | Eco-System Recycling Co., Ltd. West Plant | JAPAN | Conformant |
| Gold | CID002615 | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant |
| Gold | CID001078 | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
| Gold | CID001955 | Torecom | KOREA, REPUBLIC OF | |
| Gold | CID003189 | NH Recytech Company | KOREA, REPUBLIC OF | Conformant |
| Gold | CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
| Gold | CID002511 | KGHM Polska Miedz Spolka Akcyjna | POLAND | Conformant |
| Gold | CID003575 | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | CID002708 | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Conformant |
| Gold | CID001236 | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant |
| Gold | CID003641 | Gold by Gold Colombia | COLOMBIA | Conformant |
| Gold | CID000969 | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
| Gold | CID002863 | Bangalore Refinery | INDIA | Conformant |
| Gold | CID004010 | Coimpa Industrial LTDA | BRAZIL | Conformant |
| Gold | CID004506 | GG Refinery Ltd. | TANZANIA, UNITED REPUBLIC OF | Conformant |
| Gold | CID003615 | WEEEREFINING | FRANCE | |
| Gold | CID004755 | Elite Industech Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Gold | CID004714 | Impala Refineries – Platinum Metals Refinery (PMR) | SOUTH AFRICA | Conformant |
| Tungsten | CID000004 | A.L.M.T. Corp. | JAPAN | Conformant |
| Tungsten | CID000218 | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CID000258 | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CID000568 | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA | Conformant |
| Tungsten | CID000825 | Japan New Metals Co., Ltd. | JAPAN | Conformant |
| Tungsten | CID002082 | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CID002320 | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
| Tungsten | CID002494 | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
| Tungsten | CID002541 | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
| Tungsten | CID002542 | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tungsten | CID002543 | Masan High-Tech Materials | VIET NAM | Conformant |
| Tungsten | CID002551 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | CID002589 | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
| Tungsten | CID002044 | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant |
| Tungsten | CID003468 | Cronimet Brasil Ltda | BRAZIL | Conformant |
| Tungsten | CID000766 | Hunan Chenzhou Mining Co., Ltd. | CHINA | |
| | | | | | | | | | | | | | |
| Tungsten | CID002315 | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | |
| Tungsten | CID002316 | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CID002317 | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | CID002318 | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
| Tungsten | CID002319 | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CID002321 | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CID002513 | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | |
| Tungsten | CID002641 | China Molybdenum Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CID003417 | Hubei Green Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CID003609 | Fujian Xinlu Tungsten Co., Ltd. | CHINA | |
| Tungsten | CID002827 | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
| Tungsten | CID003407 | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tungsten | CID000105 | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant |
| Tungsten | CID000966 | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
| Tungsten | CID002502 | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
| Tungsten | CID003993 | Tungsten Vietnam Joint Stock Company | VIET NAM | Conformant |
| Tungsten | CID004397 | Lianyou Resources Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tungsten | CID004430 | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CHINA | Conformant |
| Tungsten | CID004619 | KENEE MINING VIETNAM COMPANY LIMITED | VIET NAM | Conformant |
Appendix B
| | |
| Country of Origin |
| Brazil |
| Canada |
| Chile |
| China |
| Indonesia |
| Japan |
| Malaysia |
| Mexico |
| Peru |
| Poland |
| Thailand |
| United States of America |
Note: Based on RMAP information, the conflict minerals known to be sourced from the above countries of origin were from smelters or refiners that were either Active or Conformant during the Reporting Period.