Exhibit 1.01
Sangoma Technologies Corporation
Conflict Minerals Report
For the Calendar Year Ended December 31, 2025
This conflict minerals report (this “Conflict Minerals Report”) for Sangoma Technologies Corporation (collectively, the “Company”, “Sangoma”, “we”, “our” or “us”) is being filed with the United States Securities and Exchange Commission (the “SEC”) pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and Form SD for the reporting period from January 1, 2025 to December 31, 2025. The Rule was adopted by the SEC to implement reporting and disclosure requirements related to Conflict Minerals (as defined below) as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. “Conflict Minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives (collectively, “Conflict Minerals”), which are limited to tin, tantalum, tungsten, and gold (“3TG”) for purposes of this Conflict Minerals Report. For products which contain Conflict Minerals, registrants must conduct in good faith a reasonable country of origin inquiry (an “RCOI”) designed to determine whether any of the Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country (which encompasses Angola, Burundi, The Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia) (collectively, the “Covered Countries”). Numerous terms in this Conflict Minerals Report are defined in the Rule and SEC Release No. 34-67716 issued by the SEC on August 22, 2012, and the reader of this Conflict Minerals Report is referred to these materials for such definitions. This Conflict Minerals Report is not audited as provided by the April 2014 public statement made by the SEC’s Division of Corporation Finance.
Conflict Minerals Disclosure
1. Company Overview
The Company is a trusted leader in delivering value-based Communications as a Service (CaaS) solutions for businesses of all sizes. The Company simplifies communications by providing businesses with the industry’s most comprehensive suite of cloud-native communications solutions, which work together seamlessly to streamline business processes. The Company provides businesses with a complete solution, including cloud software, endpoints, and connectivity – all delivered and supported by the Company’s expert team.
2. Overview of Products
In addition to the CaaS solutions, the Company also offers network interconnection products, such as session border controller (SBCs), gateways and PSTN interface and media processing boards. The Company contracts to manufacture certain of its network interconnection products that contain Conflict Minerals that are necessary to the functionality or production of such products (together, the “Covered Products”). For a further discussion of the Company’s products, including the Covered Products, please refer to the Annual Information Form of the Company for the year ended June 30, 2025 (filed as Exhibit 99.1 to the Company's Annual Report on Form 40-F for the year ended June 30, 2025, which was filed with the SEC on September 17, 2025 (the “Annual Report”)).
3. Supply Chain Overview and Due Diligence
The Company does not engage in the actual mining of Conflict Minerals nor does it make purchases of raw ore or unrefined Conflict Minerals, and makes no purchases in the Covered Countries. Rather, the Company’s manufacturing process is significantly removed from the mining, smelting and/or refining of 3TG minerals, and there are numerous third parties in the supply chain between the original sources of 3TG minerals and the ultimate manufacture of our products. Therefore, tracing these minerals to their sources is a challenge that requires the Company to rely on its direct and indirect suppliers in its efforts to achieve supply chain transparency, including obtaining information regarding the origin of the 3TG minerals. More specifically, the Company continues to rely upon its direct and indirect suppliers to provide information on the origin of Conflict Minerals contained in the Covered Products, including the sources of Conflict Minerals that are supplied to those manufacturers.
The Company has taken certain measures to identify the source of Conflict Minerals used in its products, including:
| · | Assessing whether the Conflict Minerals were necessary to the functionality or production of the products; |
| · | Conducting an RCOI by requiring our direct and indirect suppliers to complete the Responsible Minerals Initiative’s Conflict Minerals Reporting Template (the “CMRT”), which is regarded as the most common reporting tool for Conflict Minerals content and sourcing information worldwide; |
| · | Including Conflict Minerals-related requirements in our purchasing documents to direct suppliers; |
| · | Reviewing responses received from suppliers and following up on incomplete responses; |
| · | Sending reminders to suppliers who did not respond to the Company’s requests; and |
| · | Filing an annual report with the SEC on Form SD that includes a conflict minerals report. |
4. Reasonable Country of Origin Inquiry Results and Conclusion
As required by the Rule, the Company undertook an analysis and determined that the Covered Products contain one or more Conflict Minerals, which are necessary to the Covered Products’ functionality or production. Accordingly, as required by the Rule, the Company conducted in good faith an RCOI regarding those Conflict Minerals, which was designed to determine whether any of those Conflict Minerals originated from a Covered Country or are from recycled or scrap sources, as each defined in the Rule. To this end, the Company sent communications to each third-party manufacturer of the Covered Products explaining the requirements of the Rule and its applicability to the Company and seeking the certification from each third-party manufacturer that the Conflict Minerals in the applicable Covered Product did not originate in a Covered Country and/or to provide answers to the CMRT reflecting the Company’s position on the supply chain.
The Company received back responses from a majority of the third-party suppliers surveyed. A list of smelters and refiners that sourced 3TG for our products contracted to be manufactured during the reporting period covered by this Conflict Minerals Report is attached hereto as Exhibit A. Each CMRT received from third-party suppliers identified lists of smelters or refiners, and their countries of origin, which may supply Conflict Minerals utilized in the Covered Products. The Company exercised due diligence to determine the source and chain of custody of the 3TG necessary to the functionality or production of the Covered Products as required by the Rule. Certain responses to the Company’s RCOI regarding the origin or source of the 3TG contained in the components sold to the Company by its third-party suppliers did not provide the Company with sufficient information to conclusively determine whether the 3TG originated from a Covered Country, or whether such 3TG came from recycled or scrap sources. However, based on the information that has been obtained from the Company’s third-party suppliers as of the date hereof, the Company has reason to believe that a portion of the Conflict Minerals used in the Covered Products may have originated in the Covered Countries set forth on Exhibit B and may not be exclusively from scrap or recycled sources. Furthermore, the necessary 3TG in our products, which may have originated from outside the Covered Countries, came from one or more of the countries listed in the attached Exhibit C.
We believe our RCOI process was reasonably designed and performed in good faith, but there are inherent limitations in the information provided to us by third parties, including the possibility of information being inaccurate, incomplete or falsified despite our efforts to validate and confirm the information. Because of the relatively small amount of the Company’s components that contain Conflict Minerals and the fact that the Company’s third-party suppliers are several steps removed from the applicable smelters and refiners, the Company has assessed, and will continue to assess, if any additional actions can or should be implemented that would improve the information gathered from its due diligence to ensure compliance with its reporting requirements under the Rule.
5. Non-Conformant or Sanctioned Smelters
Our version 6.5 CMRT (the “v6.5 CMRT”) consists of a compilation of 3TG Smelters or Refiners (“SORs”) received from our suppliers for the 2025 reporting period. The CMRT is regularly updated, and we required use of version 6.5 for reporting. We are aware that as of the current date, some of these SORs are no longer considered RMAP eligible and may no longer have an audit status of conformant. Some of these SORs on the v6.5 CMRT were either active or conformant for at least part of the 2025 reporting period and were reported by our suppliers as used in their supply chains; therefore, we must continue to report them on our CMRT. Sangoma has no direct affiliation or business with the SORs and instead relies on information from a multi-level upstream supply base. Based on these factors and the size of our supply chain, we are unable to provide a specific removal date at this time as we have no direct influence over (i) the supply base purchasing sources and (ii) related budgetary constraints.
We are committed to responsible sourcing and conformance with global standards. As part of our due diligence procedures, we conduct a review of the supply chain and seek to promote supplier direct/indirect contact with the smelters to encourage RMAP conformance and/or participation. In the case of smelters which are unable (or unwilling) to conform to RMAP audit standards, we will thereafter work collaboratively with our supply chain to disengage from these smelters and/or find alternative sourcing locations should they remain non-conformant. We reviewed the smelters of concern and have provided comments below regarding the RMAP “non-conformant” and/or “high risk” smelters. Each of the sanctioned SORs identified in our due diligence process are listed on Exhibit D attached hereto.
| · | Russia Sanctioned Smelters: Government sanctions against Russia took effect beginning as of March 2022 in connection with the Russian-Ukrainian conflict. The Responsible Minerals Initiative (“RMI”) has noted the Russia-related sanctions are not retroactive and became effective as of March 2022 to present date. Due to the continued Russian activities in Ukraine, and ceased RMAP assessments in Russia, the amount of ineligible, sanctioned and/or non-conformant smelters significantly increased over the past few reporting cycles. We must report applicable smelters in our CMRT after they are identified in the supply chain by one (or more) of our suppliers. As part of our due diligence procedures for the 2025 reporting period, we continue to reach out to the applicable suppliers regarding next steps, remediation and/or disengagement procedures from these sanctioned smelters, and will continue to collaborate with our supply chain in an attempt to disengage from these smelters and/or find alternative sourcing locations should they remain ineligible due to government sanctions. |
| · | RMAP Non-Conformant Smelters: The SORs in these categories are not necessarily a “high risk” due to sourcing locations; instead, “high risk” constitutes a non-conformant category due to the RMAP audit status. In particular, these SORs are non-conformant due to ineligibility to participate in RMAP or failed RMAP inspections. The applicable SOR is deemed non-conformant if (i) its systems, processes, and practices significantly deviate from the standard requirements or assessment criteria, (ii) sanctions are imposed on the smelter, (iii) the smelter refuses to participate in the assessment process, or (iv) the smelter does not provide adequate access to facilities, personnel and/or evidence to complete the assessment. The CMRT contains smelters that are non-conformant, and we are therefore engaging with our suppliers to encourage RMAP conformance. Proof of participation in audit programs, conflict free evidence and/or corrective action plans are requested from our suppliers. As part of our due diligence procedures, we will collaborate with our suppliers to remove the applicable non-conformant SORs from their supply chains should they remain non-conformant with RMAP audit standards. |
| · | Democratic Republic of the Congo (the “DRC”) and Conflict Affected and High-Risk Areas (“CAHRAs”) Regions: SORs that are RMI compliant can source from the DRC and CAHRAs, but must continue to demonstrate the undertaking of due diligence actions to reasonably ensure that minerals are sourced responsibly and align with the European policies on conflict prevention and the development of local communities. When non-conformant status is noted for SORs sourcing from the DRC and/or CAHRAs, due diligence efforts are performed to advise the supplier of the non-conformant status. This notification includes the referenced CMRT along with the high-risk and/or non-conformant smelter report. Suppliers are encouraged to reach out to SORs directly (and indirectly) to encourage RMAP conformance and/or participation, and to provide proposed next steps, due diligence procedures and/or corrective actions that are being taken for these SORs. Additionally, alternative supply chain sourcing is encouraged for SORs, which remain non-conformant or are unwilling (or unable) to participate in the RMAP. |
| · | Uyghur Forced Labor Prevention Act (the “UFLPA”): Some SORs have been identified as having possible links to sourcing and/or refining operations in China’s Xinjiang Uyghur Autonomous Region, which makes them subject to the UFLPA. Suppliers have been recontacted for due diligence programs or compliance procedures regarding responsible sourcing from these areas. |
| · | Office of Foreign Assets Control Sanctions: |
| · | At this time, African Gold Refinery, cannot participate in the RMAP due to extensive sanctions on the global gold Goetz operations. While Sangoma has no direct business with this SOR, such SOR was reported as being utilized by certain of our suppliers in their supply chains. As part of our escalation process, we contacted the applicable suppliers regarding next steps, remediation and/or disengagement procedures from the sanctioned SOR, and will seek to collaborate with our supply chain to disengage from such SOR. Several of our suppliers have removed the applicable SOR from their supply chain, and the escalation process remains ongoing with respect to certain other suppliers. |
6. Continued Steps to Mitigate Risk
We intend to continue improving our RCOI process and to further mitigate risk that any Conflict Minerals in our products could benefit armed groups in a Covered Country contributing to human rights violations through the following measures:
| · | Continuing to conduct and report annually on supply chain RCOI for the applicable Conflict Minerals; |
| · | Examining the possibility of including Conflict Mineral-related clauses in new or renewed supplier agreements such as requiring representations of compliance; and |
| · | Engaging with suppliers and using commercially reasonable efforts to direct them, where appropriate, to training resources to attempt to improve the content of the supplier survey results. |
Moreover, we continually look to improve on our due diligence processes. As the SEC and Organization for Economic Co-operation and Development provide more guidance on this process, we will implement necessary measures to report on our Conflict Minerals status. We will work with our direct suppliers to get more relevant and complete data on the source and chain of custody of the Conflict Minerals used in our products and will continue to refine the list of relevant suppliers.
7. Cautionary Note Regarding Forward-Looking Statements
Certain statements contained in this Conflict Minerals Report constitute forward-looking statements within the meaning of Canadian securities legislation, Section 21E of the Exchange Act and Section 27A of the Securities Act of 1933, as amended. Please see “Forward Looking Information” in the Annual Information Form of the Company for the year ended June 30, 2025 filed as Exhibit 99.1 to the Annual Report for a discussion of the risks, uncertainties, assumptions and other factors that could cause the actual results and performance of the Company to vary and deviate from those forward-looking statements. Readers are cautioned that such risks, uncertainties and assumptions are not exhaustive, and the Company does not undertake any obligation to update, modify or revise any forward-looking statements, whether as a result of future events, newly obtained information or otherwise, except as may be required by applicable laws. Moreover, given that forward-looking statements involve significant and inherent risks, uncertainties and assumptions, readers of this Conflict Minerals Report are strongly advised not to place any undue reliance on any such information.
Exhibit A
Smelters and Refiners Reported in the Company’s Supply Chain as of April 8, 2026
| Metal | Smelter Name | Smelter Country |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | ABC Refinery Pty Ltd. | AUSTRALIA |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Agosi AG | GERMANY |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Alexy Metals | UNITED STATES OF AMERICA |
| Gold | Albino Mountinho Lda. | PORTUGAL |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | ASAHI METALFINE, Inc. | JAPAN |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| 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 Mineral AB (Ronnskar) | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Caridad | MEXICO |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | CGR Metalloys Pvt Ltd. | INDIA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Coimpa Industrial LTDA | BRAZIL |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Metal | Smelter Name | Smelter Country |
| 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 | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| Gold | Gasabo Gold Refinery Ltd | RWANDA |
| Gold | GG Refinery Ltd. | TANZANIA, UNITED REPUBLIC OF |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | Glencore Canada Corporation - CCR Refinery | CANADA |
| Gold | Gold by Gold Colombia | COLOMBIA |
| Gold | Gold Coast Refinery | GHANA |
| Gold | Gold Corporation - The Perth Mint | AUSTRALIA |
| 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 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 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| Metal | Smelter Name | Smelter Country |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Italpreziosi | ITALY |
| 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 Advanced Metals Corporation | JAPAN |
| Gold | K.A. Rasmussen | NORWAY |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | Kazzinc Ltd | 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'Orfebre S.A. | ANDORRA |
| Gold | Lingbao Gold Co., Ltd. | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| 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 |
| Metal | Smelter Name | Smelter Country |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | Minera Titan del Peru SRL (MTP) - Belen Plant | PERU |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | MKS PAMP SA | SWITZERLAND |
| 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 | NOBLE METAL SERVICES | UNITED STATES OF AMERICA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| 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 | REMONDIS PMR B.V. | NETHERLANDS |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | SAAMP | FRANCE |
| Gold | Safimet S.p.A | ITALY |
| Gold | SAFINA A.S. | CZECHIA |
| Gold | SAM Precious Metals FZ-LLC | UNITED ARAB EMIRATES |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Metal | Smelter Name | Smelter Country |
| 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 | 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 | TITAN COMPANY LIMITED, JEWELLERY DIVISION | INDIA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Tongling Nonferrous Jinguan (Ausmelt) Copper Industry | 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 |
| Metal | Smelter Name | Smelter Country |
| Gold | WEEEREFINING | FRANCE |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | 8853 S.p.A. | ITALY |
| Gold | African Gold Refinery | UGANDA |
| Gold | Yamakin Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Yunnan Copper Southwest Copper Branch | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Zijin Mining Group Gold Smelting Co. Ltd. | CHINA |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| 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 Suns Nonferrous Materials 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 | Resind Industria e Comercio Ltda. | BRAZIL |
| Metal | Smelter Name | Smelter Country |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND |
| Tantalum | TANIOBIS GmbH | GERMANY |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tin | Alpha Assembly Solutions Inc | UNITED STATES OF AMERICA |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | Aurubis Beerse | BELGIUM |
| Tin | Aurubis Berango | SPAIN |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | Chenzhou Yunxiang Mining and Metallurgy 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 EMEA, S.L.U. | SPAIN |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | Dongguan Best Alloys Co., Ltd. | CHINA |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tin | Dowa | JAPAN |
| 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 |
| Metal | Smelter Name | Smelter Country |
| 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 | Longnan Chuangyue Environmental Protection Technology Development Co., 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 | P Kay Metal, Inc | UNITED STATES OF AMERICA |
| Tin | Precious Minerals and Smelting Limited | INDIA |
| Tin | PT Arsed Indonesia | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | PT Premium Tin Indonesia | INDONESIA |
| Metal | Smelter Name | Smelter Country |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
| Tin | PT Rajehan Ariq | INDONESIA |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| Tin | PT Timah Tbk Mentok | 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 | 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 | 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 | 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 |
| Metal | Smelter Name | Smelter Country |
| 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 VIETNAM COMPANY LIMITED | VIET NAM |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | LAOS SOUTHERN MINING SMELTING SOLE CO.,LTD | LAO PEOPLE'S DEMOCRATIC REPUBLIC |
| 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 Carreytech Metal Corp. | PHILIPPINES |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Metal | Smelter Name | Smelter Country |
| 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 |
EXHIBIT B
Covered Countries from Which the Company’s Necessary 3TG
May Have Originated as of April 8, 2026
| 1. | Democratic Republic of Congo |
| 2. | Rwanda |
| 3. | Tanzania |
| 4. | Uganda |
EXHIBIT C
Countries, Outside of the Covered Countries, from Which the Company’s Necessary 3TG May Have Originated as of April 8, 2026
Andorra
Australia
Austria
Belgium
Bolivia (Plurinational State of)
Brazil
Canada
Chile
China
Colombia
Czechia
Estonia
France
Germany
Ghana
India
Indonesia
Italy
Japan
Kazakhstan
Republic of Korea
Kyrgyzstan
Lao People's Democratic Republic
Lithuania
Malaysia
Mexico
Netherlands
New Zealand
Norway
Peru
Philippines
Poland
Portugal
Russian Federation
Singapore
South Africa
Spain
Sweden
Switzerland
Taiwan, Province of China
Thailand
Turkey
United Arab Emirates
United States of America
Uzbekistan
Viet Nam
Zimbabwe
EXHIBIT D
Non-Conformant or Sanctioned SORs as of April 8, 2026
| Mineral | Smelter Name | Location |
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Unecha Refractory Metals Plant | RUSSIAN FEDERATION |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| Gold | African Gold Refinery | UGANDA |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| Tungsten | Artek LLC | RUSSIAN FEDERATION |
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION |
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION |
| Tungsten | LLC Vostok | RUSSIAN FEDERATION |
| Gold | Gasabo Gold Refinery Ltd. | RWANDA |