Sotera Health Company
Conflict Minerals Report for the Reporting Period from January 1, 2025 to December 31, 2025
Introduction
This Conflict Minerals Report (“Report”) is filed by Sotera Health Company (“Sotera Health”) for the reporting period from January 1, 2025 to December 31, 2025 (the “Reporting Period”), as Exhibit 1.01 to Sotera Health’s Form SD. The filing is made pursuant to the requirements of Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “Rule”), which was promulgated pursuant to the requirements of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
The Rule requires the annual filing with the Securities and Exchange Commission (the “SEC”) of a Form SD, together with this Report (if relevant) as an Exhibit to Form SD, regarding the sourcing of those Conflict Minerals (as defined below) contained in the products that Sotera Health and its subsidiaries (collectively, the “Company”, “us” or “we”) manufacture or contract to manufacture if the Conflict Minerals are necessary to the production or functionality of such products. Conflict minerals are defined as gold, columbite-tantalite (coltan), cassiterite, and wolframite, or their derivatives, which are currently limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of the Congo and its adjoining countries (Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia).
This Report has not been audited, and an independent private sector audit is not required under the Rule, the SEC partial stay of the Rule, or current SEC guidance. The content on or connected to any website referred to in this Report is not incorporated by reference.
Overview
Sotera Health is a leading global provider of mission-critical end-to-end sterilization solutions, lab testing, and advisory services for the healthcare industry. The Company goes to market through its three businesses -- Sterigenics, Nordion, and Nelson Labs. We determined that certain Nordion products are the only products of the Company that may contain 3TGs given that Sterigenics and Nelson Labs are service-only businesses.
Nordion is the leading global provider of Cobalt-60 (“Co-60”) used in the sterilization and irradiation processes for the medical device, pharmaceutical, food safety, and high-performance materials industries, as well as in the treatment of cancer. In addition, Nordion is a leading global provider of gamma irradiation systems. Co-60 is a radioactive isotope that emits gamma radiation that sterilizes items by reducing or eliminating contaminating micro-organisms. In addition to selling Co-60 sources for sterilization purposes, Nordion also sells high specific activity Co-60 for health applications including uses in stereotactic radiosurgery as a radiation source for oncology applications.
Nordion provides our customers with high quality, reliable, safe and secure Co-60 source supply and services at each stage of the source’s life cycle. It also provides regulatory and technical service expertise to enhance the efficacy and safety of gamma processing operations.
Nordion also designs, manufactures, installs and maintains gamma irradiation systems, which include radiation shielding, and a series of conveyors and control systems that are designed to expose products to the correct gamma radiation dosage in a safe and efficient manner.
We analyzed the products we manufacture or contract to manufacture and have determined that Nordion’s gamma irradiation systems and their respective components and/or spare or replacement parts may contain one or more 3TGs.
Supply Chain
The Company expects that our suppliers will act in accordance with Sotera Health’s Conflict Minerals Policy and Supplier Code of Business Ethics and Conduct, each of which may be found at https://www.soterahealth.com/responsibility and https://investors.soterahealth.com/governance/governance-overview, respectively. Nordion manufactures its products using parts, components, and raw materials procured from third-party suppliers, the majority of whom are located in North America. Nordion’s supply chain is extensive and complex, consisting of numerous direct suppliers, many of whom source materials from a wide network of sub-suppliers. Nordion does not have direct relationships with, nor does it purchase any Conflict Minerals from, mines, smelters, or refiners. Instead, Nordion relies on direct suppliers to provide information about the origin of any Conflict Minerals contained in the parts, components and materials supplied to us, including the origin of any Conflict Minerals supplied to them from their suppliers and sub-suppliers.
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (“RCOI”) in good faith. Our RCOI was reasonably designed to determine whether any of the necessary Conflict Minerals in our products originated in a Covered Country or came from recycled or scrap materials. Our RCOI process began by analyzing Nordion’s purchasing data to identify products that we manufactured or contracted to manufacture during the Reporting Period. Based on this analysis, we compiled a list of suppliers that may have provided products or materials containing 3TG (our “in-scope suppliers”).
We engaged Assent Compliance, an experienced third-party advisor (our “Advisor”), to assist with our RCOI, supplier engagement, and due diligence. We sent each of our in-scope suppliers an introductory communication describing our Conflict Minerals compliance program requirements and introducing them to our Advisor. Our Advisor then engaged with those in-scope suppliers and asked them to provide and/or update their RCOI information. We used the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”) (Revision 6.4 and 6.5 were used) to conduct a survey of all our in-scope suppliers.
Our Advisor requested our suppliers complete the CMRT and offered suppliers online educational materials intended to guide them on best practices related to use of the CMRT. All submitted forms were accepted and classified as valid or invalid. We continued to engage with our suppliers throughout the RCOI process, including by providing suppliers feedback on any named smelters and refiners, reminders to any non-responsive suppliers, and detailed reasoning and recommendations for those whose data did not meet our Advisor’s validity-check expectations. As necessary, our Advisor and/or representatives of Nordion followed-up with suppliers about Nordion’s CMRT request. To determine the country of origin of 3TGs with the greatest possible specificity, our Advisor compared data obtained from our suppliers’ responses to data collected and verified by third parties, including information in our Advisor’s database. In all, 56 percent of our in-scope suppliers responded to our request for information, and the responding in-scope suppliers represented 80 percent of our in-scope products.
In the CMRTs provided to us, our suppliers identified 329 verified smelters and refiners. Based on the information available to us through our Advisor, 82 of those smelters and refiners were reported to have some sourcing from Covered Countries. During the course of our RCOI process, we were not able to confirm the country of origin for 100 percent of 3TGs that may be contained in the materials or products we purchased from our suppliers or to determine whether those 3TGs were from recycled or scrap sources. Therefore, we have concluded that some of our products manufactured during the Reporting Period may contain necessary 3TGs that may have originated in the Covered Countries or may not be from recycled or scrap sources. Accordingly, we performed due diligence in an effort to determine the source and chain of custody of these necessary 3TGs.
Due Diligence
Design of Due Diligence Measures
The Company’s due diligence measures were designed to conform in all material respects with the due diligence framework in the Organisation 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 tin, tantalum, tungsten and for gold, Third Edition, 2016 (“OECD Guidance”).
Due Diligence Measures Performed
Due diligence measures performed for the Reporting Period consisted of the following:
1. OECD Step #1: Establish and Maintain Strong Company Management Systems. The Company has established a cross-functional conflict minerals compliance team led by the purchasing group (the “Compliance Team”) to lead and oversee our Conflict Minerals compliance program. The Compliance Team reviews and analyzes information about our products and supply chains to determine which product components and materials might be reasonably likely to contain necessary 3TGs.
The Company will retain supplier responses and other communications and information relating to Conflict Minerals in electronic form for at least 5 years.
The Company’s existing global ethics helpline, the Sotera Health Ethics Line, has been designated as a grievance mechanism whereby interested parties can report concerns or ask questions about our supply chain or Conflict Minerals Policy. Reports may be made online at https://www.soterahealth.ethicspoint.com or via telephone at 1-888-288-1841 in the United States. Information on how to make a report via telephone from outside of the United States is available at https://www.soterahealth.ethicspoint.com.
2. OECD Step #2: Identify and Assess Supply Chain Risk. Our Advisor reviewed all responses received from our in-scope suppliers and followed-up with them regarding incomplete responses and responses that appeared to contain inaccuracies. Our Advisor reviewed the lists of smelters and refiners provided by our suppliers and validated and cross-referenced such smelter and refiner information against information available through the RMI website. Our Advisor further analyzed the aggregate results of this review and provided us with their analysis. We provided information to our direct suppliers about their identified smelters and refiners, including whether or not they had been audited and had a status of “conformant” with the Responsible Minerals Assurance Process (“RMAP”) or by RMAP-recognized programs (including the London Bullion Market Association Responsible Gold Guidance and the Responsible Jewelry Council).
3. OECD Step #3: Design and Implement a Strategy to Respond to Identified Risks. Our Compliance Team periodically briefed Nordion senior management and Sotera Health General Counsel about the Company’s Conflict Minerals due diligence and compliance activities and the results of our due diligence measures. Also as noted above, we followed-up with non-responding suppliers and suppliers who provided incomplete responses or responses we believed to be inaccurate. We provided information to certain suppliers about the Rule and explained the goals and objectives of RMI.
Suppliers who disclosed a smelter or refiner that we determined was “high-risk” for Conflict Minerals issues were flagged following completion of the CMRT campaign. When our supplier responses included any of these high-risk facilities, our Advisor instructed that supplier to take certain risk mitigation actions, from providing additional, product specific information relevant to the Company via additional due diligence, escalating up to removal of these high-risk smelters from its supply chain. Based on instructions from Sotera Health, our Advisor has provided these suppliers with FAQ’s about Conflict Minerals compliance and clear performance objectives to be accomplished within reasonable timeframes with the ultimate goal of progressive elimination of these high risk smelters and refiners from their supply chain. Our Advisor also requested that these high-risk smelters engage with the Responsible Minerals Audit Process and become conformant with the conflict-free assessment protocol.
Any grievances reported to the Sotera Health Ethics Line with respect to Conflict Minerals will be investigated and reported to the Audit Committee of the Sotera Health Board of Directors.
To enhance the quality of our relationships within our supply chains, we aim to establish long-term relationships with our suppliers. Our standard terms and conditions contain provisions that require contract counterparties to provide responses to our inquiries about the sourcing of products containing Conflict Minerals.
4. OECD Step #4: Carry Out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices. Because we do not have direct relationships with smelters or refiners of Conflict Minerals, we do not carry out audits of smelters or refiners identified by our suppliers as being in their supply chains. However, we are supportive of the audits conducted by third parties as a part of the RMI process.
5. OECD Step #5: Report Annually on Supply Chain Due Diligence. We are making our Form SD and this Conflict Minerals Report publicly available on our website at https://investors.soterahealth.com/sec-filings, and we intend to report on our Conflict Minerals due diligence annually.
Results of Due Diligence
Suppliers provided us with names of smelters and refiners that may have processed the necessary 3TGs in their supply chains. Based on our Advisor’s review of the lists of smelters and refiners provided by our direct suppliers as of May 14, 2026, our Advisor identified a total of 329 smelters and refiners. Of those, 207 (or 63 percent) of the smelters and refiners identified by our in-scope suppliers for calendar year 2025 were designated by RMI as conformant; 7 (or 2 percent) were designated by RMI as active; and 38 (or 12 percent) were designated by RMI as non-conformant. The remaining 78 (or 24 percent) of the smelters and refiners identified by our in-scope suppliers were designated by our Advisor as “not enrolled” in the RMI process. Based on responses provided by our suppliers as reviewed against our Advisor’s database as of May 14, 2026, we have concluded that some of the 3TG contained in our products may have originated in certain of the countries listed in Appendix B.
1. Facilities Used to Process Necessary Conflict Minerals. As a result of our due diligence, we obtained information from approximately 56 percent of our in-scope suppliers about the smelters and refiners that processed the necessary Conflict Minerals in their supply chains. We reviewed our suppliers’ responses and compared the names of the smelters and refiners they disclosed to the information included on the RMI website and in our Advisor’s database. Because most of our suppliers provided Company-level CMRTs, we were unable to determine whether any particular smelters or refiners named in their responses actually processed the necessary 3TGs in our products. However, based on our review of our suppliers’ CMRT responses, the facilities that may have been used to process the 3TGs contained in our products include, but may not be limited to, the smelters and refiners listed in Appendix A. Because most of our suppliers provided Company-level CMRTs, we have not determined which of these smelters and refiners processed the 3TG in our products.
Our supplier responses included conformant, active, and non-conformant smelters and refiners and others that were unknown or that were not participating in the RMAP process. Only the conformant, active, and non-conformant smelters and refiners have been listed in Appendix A.
2. Countries of Origin of Our Necessary Conflict Minerals. Our Advisor reviewed the lists of smelters and refiners provided by our direct suppliers and validated and cross-referenced that information against our Advisor’s database. Based on this information, as of May 14, 2026 the possible countries of origin of the necessary Conflict Minerals in our products include, but may not be limited to, those countries listed in Appendix B.
3. Efforts to Determine Mine or Location of Origin. In order to identify the specific mines or locations of origin of our necessary Conflict Minerals, it was determined that the most reasonable course of action was to seek information from our direct suppliers, and request they seek information from their respective suppliers, about the smelters and refiners and countries of origin of the necessary Conflict Minerals in our supply chain. We also reviewed information made available by RMI, to the extent available, to try to determine the mine or location of
origin. Our suppliers’ responses and the RMI’s information did not provide sufficiently detailed information for us to determine the mine or location of origin of the necessary 3TG in our products for calendar year 2025.
Steps Taken and Being Taken to Mitigate Risk and Improve Due Diligence
During the reporting year 2026, Sotera Health has taken or expects to take the following steps to continuously improve our due diligence and supplier engagement:
• Continue engagement with relevant suppliers, including by providing additional background and educational information with respect to the RMI process.
• Continue to encourage suppliers to establish and conduct their own due diligence regarding countries of origin and smelter and refiners of 3TG in their supply chains.
Cautionary Note Regarding Forward-Looking Statements
This Report, including the section “Steps Taken and Being Taken to Mitigate Risk and Improve Due Diligence”, contains “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements are often characterized by the use of words such as “believes,” “estimates,” “expects,” “projects,” “may,” “intends,” “plans” or “anticipates,” or by discussions of strategy, plans or intentions. Such forward-looking statements involve known and unknown risks, uncertainties and other important factors that could cause our actual results, performance or achievements, or industry results, to differ materially from historical results or any future results, performance or achievements expressed, suggested or implied by such forward-looking statements. For additional discussion of these risks and uncertainties, please refer to the Company’s filings with the SEC, such as its Annual Report on Form 10-K and quarterly reports. Sotera Health does not undertake any obligation to publicly update or revise these forward-looking statements, except as otherwise required by law.
APPENDIX A
Based on our review of our suppliers’ CMRT responses, the facilities that may have been used to process the 3TGs contained in our products include, but may not be limited to, the smelters and refiners listed below. We have listed all confirmed smelters and refiners provided by our suppliers, but given the nature of our suppliers’ CMRT responses, we have not determined which of these smelters and refiners processed the 3TG in our products.
| | | | | | | | |
| Metal | Smelter Name | Smelter ID |
| Gold | Advanced Chemical Company | CID000015 |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 |
| Gold | Agosi AG | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | CID000058 |
| Gold | Argor-Heraeus S.A. | CID000077 |
| Gold | Asahi Pretec Corp. | CID000082 |
| Gold | Asaka Riken Co., Ltd. | CID000090 |
| Gold | Aurubis AG | CID000113 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 |
| Gold | Boliden Ronnskar | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | CID000176 |
| Gold | Caridad | CID000180 |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 |
| Gold | Cendres + Metaux S.A. | CID000189 |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 |
| Gold | Chimet S.p.A. | CID000233 |
| Gold | Chugai Mining | CID000264 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 |
| Gold | DSC (Do Sung Corporation) | CID000359 |
| Gold | Dowa | CID000401 |
| Gold | Eco-System Recycling Co., Ltd. East Plant | CID000425 |
| Gold | JSC Novosibirsk Refinery | CID000493 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 |
| Gold | LT Metal Ltd. | CID000689 |
| Gold | Heimerle + Meule GmbH | CID000694 |
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 |
| Gold | Heraeus Germany GmbH Co. KG | CID000711 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CID000773 |
| Gold | HwaSeong CJ CO., LTD. | CID000778 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 |
| Gold | Istanbul Gold Refinery | CID000814 |
| Gold | Japan Mint | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 |
| Gold | Asahi Refining USA Inc. | CID000920 |
| Gold | Asahi Refining Canada Ltd. | CID000924 |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 |
| Gold | JSC Uralelectromed | CID000929 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 |
| Gold | Kazakhmys Smelting LLC | CID000956 |
| Gold | Kazzinc | CID000957 |
| Gold | Kennecott Utah Copper LLC | CID000969 |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 |
| Gold | Kyrgyzaltyn JSC | CID001029 |
| Gold | Lingbao Gold Co., Ltd. | CID001056 |
| Gold | LS MnM Inc. | CID001078 |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 |
| Gold | Materion | CID001113 |
| | | | | | | | |
| Metal | Smelter Name | Smelter ID |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 |
| Gold | Metalor Technologies S.A. | CID001153 |
| Gold | Metalor USA Refining Corporation | CID001157 |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | CID001161 |
| Gold | Mitsubishi Materials Corporation | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 |
| Gold | Moscow Special Alloys Processing Plant | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 |
| Gold | Nihon Material Co., Ltd. | CID001259 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 |
| Gold | MKS PAMP SA | CID001352 |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 |
| Gold | PX Precinox S.A. | CID001498 |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 |
| Gold | Royal Canadian Mint | CID001534 |
| Gold | Sabin Metal Corp. | CID001546 |
| Gold | Samduck Precious Metals | CID001555 |
| Gold | Samwon Metals Corp. | CID001562 |
| Gold | SEMPSA Joyeria Plateria S.A. | CID001585 |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | CID001761 |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 |
| Gold | Super Dragon Technology Co., Ltd. | CID001810 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 |
| Gold | Shandong Gold Smelting Co., Ltd. | CID001916 |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 |
| Gold | Torecom | CID001955 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 |
| Gold | United Precious Metal Refining, Inc. | CID001993 |
| Gold | Valcambi S.A. | CID002003 |
| Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 |
| Gold | Yamakin Co., Ltd. | CID002100 |
| Gold | Yokohama Metal Co., Ltd. | CID002129 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 |
| Gold | Morris and Watson | CID002282 |
| Gold | SAFINA A.S. | CID002290 |
| Gold | Umicore Precious Metals Thailand | CID002314 |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 |
| Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 |
| Gold | Singway Technology Co., Ltd. | CID002516 |
| Gold | Shandong Humon Smelting Co., Ltd. | CID002525 |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CID002527 |
| | | | | | | | |
| Metal | Smelter Name | Smelter ID |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 |
| Gold | Emirates Gold DMCC | CID002561 |
| Gold | International Precious Metal Refiners | CID002562 |
| Gold | T.C.A S.p.A | CID002580 |
| Gold | REMONDIS PMR B.V. | CID002582 |
| Gold | Fujairah Gold FZC | CID002584 |
| Gold | Shirpur Gold Refinery Ltd. | CID002588 |
| Gold | Korea Zinc Co., Ltd. | CID002605 |
| Gold | Marsam Metals | CID002606 |
| Gold | TOO Tau-Ken-Altyn | CID002615 |
| Gold | Abington Reldan Metals, LLC | CID002708 |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CID002750 |
| Gold | Albino Mountinho Lda. | CID002760 |
| Gold | SAAMP | CID002761 |
| Gold | L'Orfebre S.A. | CID002762 |
| Gold | 8853 S.p.A. | CID002763 |
| Gold | Italpreziosi | CID002765 |
| Gold | WIELAND Edelmetalle GmbH | CID002778 |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 |
| Gold | AU Traders and Refiners | CID002850 |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | CID002852 |
| Gold | Modeltech Sdn Bhd | CID002857 |
| Gold | Bangalore Refinery | CID002863 |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 |
| Gold | Pease & Curren | CID002872 |
| Gold | JALAN & Company | CID002893 |
| Gold | SungEel HiMetal Co., Ltd. | CID002918 |
| Gold | Planta Recuperadora de Metales SpA | CID002919 |
| Gold | ABC Refinery Pty Ltd. | CID002920 |
| Gold | Safimet S.p.A | CID002973 |
| Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 |
| Gold | African Gold Refinery | CID003185 |
| Gold | Gold Coast Refinery | CID003186 |
| Gold | NH Recytech Company | CID003189 |
| Gold | QG Refining, LLC | CID003324 |
| Gold | Dijllah Gold Refinery FZC | CID003348 |
| Gold | CGR Metalloys Pvt Ltd. | CID003382 |
| Gold | Sovereign Metals | CID003383 |
| Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 |
| Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 |
| Gold | Augmont Enterprises Private Limited | CID003461 |
| Gold | Kundan Care Products Ltd. | CID003463 |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | CID003487 |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | CID003488 |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | CID003489 |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | CID003490 |
| Gold | K.A. Rasmussen | CID003497 |
| Gold | Alexy Metals | CID003500 |
| Gold | MD Overseas | CID003548 |
| Gold | Metallix Refining Inc. | CID003557 |
| Gold | Metal Concentrators SA (Pty) Ltd. | CID003575 |
| Gold | WEEEREFINING | CID003615 |
| Gold | Gold by Gold Colombia | CID003641 |
| Gold | Dongwu Gold Group | CID003663 |
| Gold | Sam Precious Metals | CID003666 |
| | | | | | | | |
| Metal | Smelter Name | Smelter ID |
| Gold | Coimpa Industrial LTDA | CID004010 |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | CID004435 |
| Gold | TITAN COMPANY LIMITED, JEWELLERY DIVISION | CID004491 |
| Gold | GG Refinery Ltd. | CID004506 |
| Gold | Attero Recycling Pvt Ltd | CID004697 |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR) | CID004714 |
| Gold | Elite Industech Co., Ltd. | CID004755 |
| Gold | Minera Titán del Perú SRL (MTP) - Belen Plant | CID005014 |
| Gold | NOBLE METAL SERVICES | CID003690 |
| Gold | Gasabo Gold Refinery Ltd | CID005006 |
| Gold | SOLEIL METALS (Chala One Plant) | CID004704 |
| Gold | SOLEIL METALS (YAKARI Plant) | CID004705 |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CID000291 |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CID000616 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 |
| Tantalum | AMG Brasil | CID001076 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 |
| Tantalum | Mineracao Taboca S.A. | CID001175 |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 |
| Tantalum | NPM Silmet AS | CID001200 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 |
| Tantalum | Taki Chemical Co., Ltd. | CID001869 |
| Tantalum | Telex Metals | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 |
| Tantalum | D Block Metals, LLC | CID002504 |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 |
| Tantalum | KEMET de Mexico | CID002539 |
| Tantalum | TANIOBIS Co., Ltd. | CID002544 |
| Tantalum | TANIOBIS GmbH | CID002545 |
| Tantalum | Materion Newton Inc. | CID002548 |
| Tantalum | TANIOBIS Japan Co., Ltd. | CID002549 |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | CID002550 |
| Tantalum | Global Advanced Metals Boyertown | CID002557 |
| Tantalum | Global Advanced Metals Aizu | CID002558 |
| Tantalum | Resind Industria e Comercio Ltda. | CID002707 |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 |
| Tantalum | 5D Production OU | CID003926 |
| Tantalum | PowerX Ltd. | CID004054 |
| Tantalum | Jiangxi Sanshi Nonferrous Metals Co., Ltd | CID004813 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 |
| Tin | Alpha Assembly Solutions Inc | CID000292 |
| Tin | PT Premium Tin Indonesia | CID000313 |
| Tin | Dowa | CID000402 |
| Tin | EM Vinto | CID000438 |
| Tin | Estanho de Rondonia S.A. | CID000448 |
| Tin | Fenix Metals | CID000468 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 |
| | | | | | | | |
| Metal | Smelter Name | Smelter ID |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 |
| Tin | China Tin Group Co., Ltd. | CID001070 |
| Tin | Metallic Resources, Inc. | CID001142 |
| Tin | Mineracao Taboca S.A. | CID001173 |
| Tin | Minsur | CID001182 |
| Tin | Mitsubishi Materials Corporation | CID001191 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 |
| Tin | Novosibirsk Tin Combine | CID001305 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 |
| Tin | Operaciones Metalurgicas S.A. | CID001337 |
| Tin | PT Mitra Stania Prima | CID001453 |
| Tin | PT Prima Timah Utama | CID001458 |
| Tin | PT Timah Tbk Kundur | CID001477 |
| Tin | PT Timah Tbk Mentok | CID001482 |
| Tin | Rui Da Hung | CID001539 |
| Tin | Thaisarco | CID001898 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 |
| Tin | VQB Mineral and Trading Group JSC | CID002015 |
| Tin | White Solder Metalurgia e Mineracao Ltda. | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CID002180 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 |
| Tin | Melt Metais e Ligas S.A. | CID002500 |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 |
| Tin | PT Rajehan Ariq | CID002593 |
| Tin | PT Cipta Persada Mulia | CID002696 |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 |
| Tin | Resind Industria e Comercio Ltda. | CID002706 |
| Tin | Super Ligas | CID002756 |
| Tin | Aurubis Beerse | CID002773 |
| Tin | Aurubis Berango | CID002774 |
| Tin | PT Bangka Prima Tin | CID002776 |
| Tin | Modeltech Sdn Bhd | CID002858 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 |
| Tin | Tin Technology & Refining | CID003325 |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CID003379 |
| Tin | Luna Smelter, Ltd. | CID003387 |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 |
| Tin | Precious Minerals and Smelting Limited | CID003409 |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CID003410 |
| Tin | PT Mitra Sukses Globalindo | CID003449 |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | CID003486 |
| Tin | CRM Synergies | CID003524 |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | CID003582 |
| Tin | PT Putera Sarana Shakti (PT PSS) | CID003868 |
| Tin | Mining Minerals Resources SARL | CID004065 |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | CID004403 |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | CID004434 |
| Tin | Woodcross Smelting Company Limited | CID004724 |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | CID004754 |
| Tin | Dongguan Best Alloys Co., Ltd. | CID000377 |
| | | | | | | | |
| Metal | Smelter Name | Smelter ID |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | CID004692 |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | CID004796 |
| Tin | P Kay Metal, Inc | CID005189 |
| Tin | PT Aries Kencana Sejahtera | CID000309 |
| Tin | PT Artha Cipta Langgeng | CID001399 |
| Tin | CV Ayi Jaya | CID002570 |
| Tin | PT Masbro Alam Stania | CID003380 |
| Tungsten | A.L.M.T. Corp. | CID000004 |
| Tungsten | Kennametal Huntsville | CID000105 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 |
| Tungsten | Global Tungsten & Powders LLC | CID000568 |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CID000769 |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 |
| Tungsten | Kennametal Fallon | CID000966 |
| Tungsten | Wolfram Bergbau und Hutten AG | CID002044 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CID002513 |
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | CID002542 |
| Tungsten | Masan High-Tech Materials | CID002543 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 |
| Tungsten | Niagara Refining LLC | CID002589 |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CID002641 |
| Tungsten | Hydrometallurg, JSC | CID002649 |
| Tungsten | Unecha Refractory metals plant | CID002724 |
| Tungsten | Moliren Ltd. | CID002845 |
| Tungsten | Lianyou Metals Co., Ltd. | CID003407 |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | CID003408 |
| Tungsten | NPP Tyazhmetprom LLC | CID003416 |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CID003417 |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | CID003427 |
| Tungsten | Cronimet Brasil Ltda | CID003468 |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CID003609 |
| Tungsten | OOO “Technolom” 2 | CID003612 |
| Tungsten | OOO “Technolom” 1 | CID003614 |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CID003662 |
| Tungsten | Tungsten Vietnam Joint Stock Company | CID003993 |
| Tungsten | Nam Viet Cromit Joint Stock Company | CID004034 |
| Tungsten | Lianyou Resources Co., Ltd. | CID004397 |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CID004430 |
| Tungsten | Philippine Carreytech Metal Corp. | CID004438 |
| Tungsten | KENEE MINING VIETNAM COMPANY LIMITED | CID004619 |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation | CID004797 |
| Tungsten | Jing Yuan Tungsten Technology Co., Ltd. | CID005012 |
| Tungsten | S.P.T. spol.s r.o. | CID005068 |
| Tungsten | Tungamoy Metals Inc. | CID005248 |
APPENDIX B
Based on our Advisor’s review of the lists of smelters and refiners provided by our direct suppliers, as of May 14, 2026, the possible countries of origin of the necessary Conflict Minerals in our products include, but may not be limited to, those countries listed below.
Possible Countries of Origin – Tin
| | | | | | | | |
| Belgium | Japan | United States of America |
| Bolivia | Malaysia | Vietnam |
| Congo | Rwanda | |
| China | Thailand | |
Possible Countries of Origin – Tantalum
| | | | | | | | |
| Brazil | Japan | Thailand |
| China | Kazakhstan | United States of America |
| Estonia | Mexico | |
| Germany | Russian Federation | |
Possible Countries of Origin – Tungsten
| | | | | | | | |
| Austria | Germany | United States of America |
| Brazil | Japan | Vietnam |
| China | Russian Federation | |
Possible Countries of Origin – Gold
| | | | | | | | |
| Andorra | Japan | Sudan |
| Australia | Kazakhstan | Switzerland |
| Brazil | Korea, Republic Of | Turkey |
| Canada | Lithuania | Uganda |
| China | Norway | United Arab Emirates |
| Germany | Philippines | United States of America |
| India | Russian Federation | Uzbekistan |
| Italy | South Africa | Zimbabwe |