Exhibit 1.01

Bloom Energy Corporation

Conflict Minerals Report

For Year Ended December 31, 2025

This Conflict Minerals Report (“Report”) for the year ended December 31, 2025 has been prepared by the management of Bloom Energy Corporation (herein referred to as “Bloom Energy”). The information includes the activities of all majority-owned subsidiaries and variable interest entities that are consolidated.

As used in this Report, “3TGs” means tin, tungsten, tantalum and/or gold or its derivatives and “Covered Countries” means the Democratic Republic of the Congo (“DRC”) and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

INTRODUCTION

Products Covered by This Report

Pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to as “Section 1502 of the Dodd-Frank Act” or “the Rule”), the 2025 calendar year is the seventh year that Bloom Energy is filing a Conflict Minerals Report.

Bloom Energy has determined that only two products manufactured or contracted to be manufactured contained 3TGs that were necessary to their functionality or production: the Bloom Energy Server, a stationary power generation platform and the Bloom Energy Electrolyzer, a stationary producer of hydrogen (the “Covered Products”).

Bloom Energy conducted in good faith a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TGs in the Covered Products originated in the Covered Countries by engaging with certain suppliers who provided materials that may contain 3TGs that was used in the Covered Products (“In-Scope Suppliers”). Based on Bloom Energy’s RCOI, Bloom Energy had reason to believe that its Covered Products could contain 3TGs that originated in the Covered Countries. Therefore, in accordance with Section 1502 of the Dodd-Frank Act, Bloom Energy performed due diligence on the source and chain of custody of the 3TGs.

Reasonable Country of Origin Inquiry

To assist Bloom Energy with its determination on whether 3TGs necessary for its Covered Products originated in Covered Countries, Bloom Energy engaged a third-party service provider, Source Intelligence (“SI”). SI provided Bloom Energy with access to its platform that tracks supplier communications and provides additional tools that support the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements on Tin, Tantalum and Tungsten, and on Gold (the “OECD Guidance”). For example, the SI platform has functionality that evaluates the quality of each supplier’s response and assigns a health score based on the supplier’s declaration. The metrics provided in this Report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through the SI platform.

 

1

Bloom Energy provided a list of In-Scope Suppliers to SI for upload to the SI platform. SI assisted with the evaluation of Bloom Energy’s supply chain information regarding 3TGs, identification of potential risks, and development and implementation of additional due diligence steps. Bloom Energy communicated regularly with the SI services team concerning program status. SI’s team members are trained in conflict minerals compliance and understand the intricacies of the CMRT (as defined below), conflict minerals reporting, and generally, Section 1502 of the Dodd-Frank Act.

Bloom Energy’s RCOI process included conducting an inquiry of its In-Scope Suppliers using the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”). Bloom Energy does not have direct supply contracts with the providers of raw materials used in the Covered Products and Bloom Energy does not directly source 3TGs. Bloom Energy sources components and materials from suppliers, which in turn, source materials, components and products from their suppliers.

Bloom Energy used SI’s platform to request that the In-Scope Suppliers complete the CMRT to collect data on the sources of origin of the materials necessary for the Covered Products. Suppliers then uploaded their completed CMRTs directly to the platform for validation, assessment and management. SI monitored and tracked all communications in its platform for future reporting and transparency. Bloom Energy directly contacted suppliers that were unresponsive to SI’s communications and requested that they complete and submit the CMRT.

Bloom Energy’s program includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as to understand the due diligence efforts of the In-Scope Suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the In-Scope Suppliers to support their understanding of areas that need their clarification or improvement.

All submitted CMRT forms were accepted and classified as valid or invalid. The “invalid” classification can be the result of a number of factors, including incomplete tabs and can also occur when the supplier uses an obsolete template instead of the current version. A supplier who submits an invalid form is contacted and encouraged to submit a valid form. Suppliers receive feedback on their submissions and guidance on correcting validation errors and may seek assistance from SI’s multilingual Supplier Experience team or online training. Data concerning suppliers who remain unresponsive to feedback is tracked as a program gap for future improvement.

As of April 23, 2026, Bloom Energy had 136 In-Scope Suppliers. 136 (100%) of the In-Scope Suppliers completed a valid CMRT. This helped Bloom Energy determine the countries of origin for all of the 3TGs in the Covered Products.

DUE DILIGENCE

Bloom Energy designed its due diligence measures to conform with the OECD Guidance in all material respects and endeavored to align its program with the five steps for due diligence described in the OECD Guidance. Bloom Energy continues to evaluate market expectations for data collection and reporting to make improvements to its program.

 

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Bloom Energy is a downstream consumer of 3TGs and does not purchase raw minerals directly from any mines, smelters or refiners or any of the Covered Countries. Bloom Energy’s supply chain is extensive and complex with many layers of suppliers positioned between Bloom Energy and 3TG smelters and refiners. Therefore, to execute due diligence, Bloom Energy must rely on data from its direct suppliers and third-party audit programs. As Bloom Energy does not solely control these processes, there is a risk of incomplete or inaccurate data. However, multiple supplier outreach efforts and process validation steps help mitigate this risk. Bloom Energy believes this due diligence process aligns with industry standards and market expectations for downstream companies.

Step One: Establish Strong Company Management Systems

Internal Compliance Team

Bloom Energy established a cross-functional Conflict Minerals Team led by the Chief Operations Officer. The Conflict Minerals Team is responsible for implementing Bloom Energy’s responsible sourcing strategy and for briefing senior management on the results of due diligence.

Conflict Minerals Policy

In May 2020, Bloom Energy adopted a Policy on Responsible Sourcing of Minerals articulating the due diligence process and Bloom Energy’s commitment to reporting obligations regarding 3TGs originating in the Covered Countries. The Policy is publicly available at www.bloomenergy.com/supplychain.

Control Systems

Bloom Energy relies on its direct suppliers to provide information on the origin of the 3TGs contained in components and materials that they supply to Bloom Energy, such as sources of 3TGs that the suppliers purchase from their lower-tier suppliers. However, Bloom Energy expects all suppliers to have policies and procedures in place that work toward ensuring that all 3TGs used in the production of the products sold to Bloom Energy are sourced from smelters or refiners that conform with an independent responsible mineral sourcing validation program.

Supplier Engagement

Bloom Energy has a strong relationship with its In-Scope Suppliers. Bloom Energy engages directly with its In-Scope Suppliers to request a valid CMRT for the products that they supply to Bloom Energy. To strengthen supplier education and training, Bloom Energy provides In-Scope Suppliers with access to the SI platform, at no-charge, to upload their CMRTs as well as to seek help-desk support in their native language from SI’s team of supplier support specialists. Suppliers can also participate in SI’s online library of conflict minerals training.

Grievance Mechanisms

Bloom Energy has established multiple grievance mechanisms whereby employees, suppliers and other third parties can report violations of its policies. In Bloom Energy’s Policy on Responsible Sourcing of Minerals, Bloom Energy has published a dedicated email address for suppliers to contact the Bloom Energy Supplier Team to ask questions regarding the collection of CMRTs and to report any violations of this policy within the supply chain. In addition, employees and third parties have access to the Bloom Energy Helpline to ask questions, communicate concerns or report potential violations of applicable law or company policies, which is publicly available at www.bloomhelpline.com/.

In the event that employees and suppliers wish to contact Bloom Energy’s Board of Directors, Bloom Energy also publishes the Board’s address in its Global Code of Business Conduct and Ethics, available on Bloom Energy’s website under the Investors section. Finally, violations or grievances at the industry level can be reported directly to RMI at: https:/www.responsiblemineralsinitiative.org/minerals-due-diligence-container/risk-management/rmi-grievance-mechanism/.

Records Management

SI’s platform also includes a document retention policy to retain any conflict minerals-related documents, including supplier responses to CMRTs and the sources for each reporting period. Bloom Energy stores all of the information and findings from this process in a database that can be audited by internal or external parties.

Step Two: Identify and Assess Risks in the Supply Chain

Risks associated with supplier CMRT content are identified by SI based on criteria established for supplier responses. Supplier responses were evaluated for plausibility, consistency and gaps. If any of the foregoing quality control flags were raised, suppliers were automatically contacted by the SI platform to correct any inconsistencies.

Risks at the supplier level may include non-responsive suppliers down the supply chain, incomplete CMRTs, or CMRTs that are submitted that are not specific to the Covered Products. Additionally, some suppliers could not provide a comprehensive list of all smelters or refiners in their supply chains.

Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers who listed smelters and refiners on their CMRT declarations. To determine if the facilities met the recognized definition of a 3TG processing facility that was operational during the 2025 calendar year, SI compared these facilities to the RMI list of smelters and refiners. SI relied on the RMI audit standard, including cross-recognition of the London Bullion Market Association (“LBMA”) Good Delivery Program and the Responsible Jewellery Council (“RJC”) Chain of Custody Standard, which are developed according to global standards, including the OECD Guidance.

 

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SI determined if the smelter or refiner had been audited against a standard that conforms to the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). As discussed earlier, Bloom Energy does not have a direct relationship with smelters and refiners, and does not perform direct audits of these entities within the supply chain. In cases where a smelter’s due diligence practices have not been audited against RMAP or a similar independent standard, or RMAP considers a smelter to be non-conforming, Bloom Energy followed up with suppliers reporting those facilities. Smelters are then assessed for potential sourcing risk.

Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed using the red-flag indicators in the OECD Guidance. SI uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

 

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Geographic proximity to the Covered Countries;

 

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Known mineral source country of origin;

 

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RMAP or a similar independent audit status that is cross-recognized by RMI;

 

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Credible evidence of unethical or conflict sourcing; and

 

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Peer assessments conducted by credible third-party sources.

Risk mitigation activities are initiated when a supplier’s CMRT reports smelters of concern. Suppliers with submissions that include smelters or refiners of concern are provided with feedback instructing that supplier to take their own independent risk mitigation actions. Additional escalation may be necessary to address any continued sourcing from these smelters of concern. In addition, In-Scope Suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.

In-Scope Suppliers are also evaluated on program strength, which will assist Bloom Energy with making key risk mitigation decisions as its program progresses. The criteria used to evaluate the strength of the program is based on questions in the CMRT related to the suppliers’ conflict minerals practices and policies.

Step Three: Design and Implement a Strategy to Respond to Identified Risks

Bloom Energy has developed a process to assess and respond to the risks identified in the supply chain as well as to manage and monitor risk. Communications were sent to non-responsive suppliers to communicate the importance of their completion of the CMRT and their support of Bloom Energy’s compliance with the Rule and Bloom Energy’s expectations.

Suppliers received feedback on their submissions as well as educational resources regarding corrective action methods and potential improvements for their internal programs. Bloom Energy encouraged suppliers that may be supplying 3TGs from sources that may support conflict in the Covered Countries to endeavor to seek an alternative source of 3TGs that does not support such conflict, as provided in the OECD Guidance. SI also communicates directly with smelters that have not yet been determined to be conformant with the RMAP to seek data on sourcing and to encourage their involvement with the RMI program.

In cases where suppliers have continuously been non-responsive or do not appear to be committed to corrective action plans, Bloom Energy assesses internally if replacing that supplier is feasible. The results of the program and risk assessment are shared with both the Conflict Minerals Team and senior management to support transparency within Bloom Energy.

Step Four: Support the Development and Implementation of Independent Third-Party Audits

As discussed above, Bloom Energy does not have a direct relationship with any 3TG smelters or refiners and does not perform or direct audits of these entities within the supply chain. Instead, Bloom Energy relies on third-party audits of smelters and refiners conducted as part of the RMAP. The RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.

SI also attempts to directly contact smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facility’s sourcing practices on behalf of its compliance partners.

 

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Step Five: Report Annually on Supply Chain Due Diligence

Bloom Energy has filed this Report and a Form SD for the year ended December 31, 2025 with the United States Securities and Exchange Commission (“SEC”). As indicated in the Form SD, this Report is publicly available at www.investor.bloomenergy.com/. Bloom Energy’s Policy on Responsible Sourcing of Minerals is also publicly available at www.bloomenergy.com/supplychain.

RCOI AND DUE DILIGENCE RESULTS

Supply Chain Outreach Results

Supply chain outreach is required to identify the upstream sources of origin of 3TGs. In accordance with industry standards, CMRTs are sent to and requested from In-Scope Suppliers, who are expected to follow this process until the smelter and refiner sources are identified. For the 2025 reporting year, Table 1 sets out the results of Bloom Energy’s supply chain outreach.

 

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Table 1

SUPPLY CHAIN OUTREACH METRICS

 

Number of In-Scope Suppliers		Response Rate
136		100% (136 out of 136)

Upstream Data Transparency

As mentioned above, Bloom Energy is a downstream consumer of 3TGs and does not purchase raw minerals directly from any mines, smelters or refiners or any of the Covered Countries. Bloom Energy’s supply chain is extensive and complex with many layers of suppliers positioned between Bloom Energy and 3TG smelters and refiners. Therefore, to execute due diligence, Bloom Energy must rely on data from its direct suppliers and third-party audit programs. As Bloom Energy does not solely control these processes, there is a risk of incomplete or inaccurate data. However, multiple supplier outreach efforts and process validation steps help mitigate this risk. Bloom Energy believes this due diligence process aligns with industry standards and market expectations for downstream companies.

All known smelters and refiners listed by suppliers in completed CMRTs (which appear on the RMI-maintained smelters list as of May 1, 2025) are set out in Appendix A. As is a common practice when requests are sent upstream in the supply chain, those companies who purchase materials from smelters may not be able to discern exactly which of their products contain the materials. As a result, those companies who provide a list of smelters and refiners tend to list all smelters and refiners from which they may purchase within the reporting period. Although the potential for over-reporting is understood, Bloom Energy has taken measures to validate these sources of origin against validated audit programs intended to verify the material types and mine sources of origin for these smelters and refiners. Therefore, the smelters or refiners listed in Appendix A as sources are likely to be more comprehensive than the list of smelters or refiners that actually processed the 3TGs in the Covered Products.

Certain of the In-Scope Suppliers reported the presence of smelters sanctioned by the United States Department of the Treasury, Office of Foreign Assets Control; the UK Sanctions List; and/or the Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions. Because of the over-reporting nature of the industry, CMRT information collection process, and the nature of our and our subsidiaries’ supply chains, we are unable to confirm whether any such smelter or refiner is or was active in our supply chain.

In accordance with the OECD Guidance, suppliers that identified specific smelters or refiners of concern in their CMRT were contacted to communicate the potential for risk and to evaluate whether or not these smelters or refiners could be connected to the Covered Products. Bloom Energy obtained RCOI data through the SI platform and with the help of SI this data was used to determine the 3TG country of origin for the 360 smelters and refiners identified in Bloom Energy’s supply chain. The RMAP classifies smelters’ and refiners’ audit status in the following manner:

 

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Conformant: Smelters or refiners have been audited and found to conform with a relevant, third-party audit protocol, including RMAP, LBMA, or RJC;

 

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RMAP-Active: The active lists represent smelters and refiners that have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment;

 

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RMAP-Progressing: Smelters or refiners have committed to take an audit and complete a conflict-free certification within two (2) years;

 

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Non-Conformant or Not Enrolled: The smelter or refiner is listed on the Smelter Look-up tab of the CMRT but is not Conformant or RMAP-Active.

 

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Status		Number of Identified Smelters or Refiners
RMAP/LBMA/RJC Conformant		227
RMAP-Active		15
RMAP-Progressing		0
Non-Conformant or Not Enrolled		118
Total Number		360

As Bloom Energy does not directly purchase from any mines, smelters or refiners, nor does the majority of its In-Scope Suppliers, Bloom Energy has very little influence over their sourcing. Bloom Energy relies, to a large extent, on the information provided by independent third-party audit programs. Such sources of information may contain incomplete or inaccurate data, and may be subject to fraud.

Bloom Energy has determined that a portion of the 3TGs contained in the Covered Products originated from the Covered Countries, but Bloom Energy was unable to determine the origin of all the 3TGs in the Covered Products. As of the date of this Report and for the reporting period covered by this Report, Bloom Energy has not identified a supplier, smelter or refiner that Bloom Energy has reason to believe is sourcing 3TGs contained in the Covered Products that is directly or indirectly financing or benefiting an armed group. However, given that Bloom Energy has received insufficient information with respect to certain smelters and refiners that may have provided 3TGs for the Covered Products, Bloom Energy has not determined that the Covered Products are “DRC conflict-free.”

Due Diligence Improvement Efforts

Bloom Energy will continue to communicate its expectations and information requirements to its In-Scope Suppliers and continue to work towards a conflict-free supply chain. In addition, Bloom Energy will continue to make inquiries of its In-Scope Suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If Bloom Energy becomes aware of a supplier whose due diligence process or reporting needs improvement, Bloom Energy currently intends to continue the trade relationship while that supplier improves its compliance program. Bloom Energy expects its In-Scope Suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.

In addition to the plans described above, Bloom Energy will undertake the following steps during the next reporting period:

 

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Continue to collect responses from suppliers using the CMRT, including the collection of more product-level responses specific to the Covered Products.

 

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Work with In-Scope Suppliers to reduce the number of non-conformant smelters and refiners within Bloom Energy’s supply chain.

 

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Continue to work directly with its suppliers to provide more complete responses as a number of suppliers have been unable to determine the origin of the 3TGs in products or components supplied to Bloom Energy or to determine whether they come from recycled or scrap sources.

 

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Continue to allow verified conflict-free material from the Covered Countries to enter Bloom Energy’s supply chain.

 

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Additional Information

The statements above are based on the RCOI process and due diligence performed in good faith by Bloom Energy. These statements are based on information available at the time. A number of factors could introduce errors or otherwise affect Bloom Energy’s status with respect to this Report. These factors include, but are not limited to, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources, all instances of conflict minerals necessary to the functionality or manufacturing of the Covered Products possibly not yet having been identified, gaps in supplier education and knowledge, timeliness of data, public information not discovered during a reasonable search, language barriers and translation, oversights or errors in conflict-free smelter audits, Covered Countries’ sourced materials being declared secondary materials, companies in Bloom Energy’s supply chain going out of business, certification programs being not equally advanced for all industry segments and metals, updated guidance regarding the SEC final rules, and smuggling of conflict minerals from the Covered Countries to countries beyond the Covered Countries.

The information contained on any website referred to in this Report does not form any part of this Report or Form SD and is not incorporated by reference herein unless expressly noted.

Countries of Origin

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs. This list is based on information provided through the CMRT data collection process from direct smelter outreach and the RMAP. As mentioned above, it is understood that many responses may provide more data than can be directly linked to the sale of the Covered Products by Bloom Energy. Therefore, Appendix B may contain more countries than those from which the Covered Products are sourced.

 

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APPENDIX A: SMELTER LIST

 

Metal		Official Smelter Name
Gold		8853 S.p.A.
Gold		ABC Refinery Pty Ltd.
Gold		Abington Reldan Metals, LLC
Gold		Advanced Chemical Company
Gold		African Gold Refinery1
Gold		Agosi AG
Gold		Aida Chemical Industries Co., Ltd.
Gold		Al Etihad Gold Refinery DMCC
Gold		Albino Mountinho Lda.
Gold		Alexy Metals
Gold		Almalyk Mining and Metallurgical Complex (AMMC)
Gold		AngloGold Ashanti Corrego do Sitio Mineracao
Gold		Argor-Heraeus S.A.
Gold		ASAHI METALFINE, Inc.
Gold		Asahi Refining Canada Ltd.
Gold		Asahi Refining USA Inc.
Gold		Asaka Riken Co., Ltd.
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold		Attero Recycling Pvt Ltd
Gold		AU Traders and Refiners
Gold		Augmont Enterprises Private Limited
Gold		Aurubis AG
Gold		Bangalore Refinery
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold		Boliden Ronnskar
Gold		C. Hafner GmbH + Co. KG
Gold		Caridad
Gold		Cendres + Metaux S.A.
Gold		CGR Metalloys Pvt Ltd.
Gold		Chimet S.p.A.
Gold		Chugai Mining
Gold		Coimpa Industrial LTDA
Gold		Daye Non-Ferrous Metals Mining Ltd.
Gold		Degussa Sonne / Mond Goldhandel GmbH
Gold		Dijllah Gold Refinery FZC
Gold		Dongwu Gold Group
Gold		Dowa
Gold		DSC (Do Sung Corporation)
Gold		Eco-System Recycling Co., Ltd. East Plant
Gold		Eco-System Recycling Co., Ltd. North Plant
Gold		Eco-System Recycling Co., Ltd. West Plant

1

Certain of the In-Scope Suppliers reported the presence of this entity that was sanctioned by the United States Department of Treasury, Office of Foreign Assets Control on March 17, 2022. Because of the over-reporting nature of the industry, CMRT information collection process, and the nature of our and our subsidiaries’ supply chains, we are unable to confirm whether or not this, or any, smelter or refiner is or was active in our supply chain.

 

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Gold		Elite Industech Co., Ltd.
Gold		Emerald Jewel Industry India Limited (Unit 1)
Gold		Emerald Jewel Industry India Limited (Unit 2)
Gold		Emerald Jewel Industry India Limited (Unit 3)
Gold		Emerald Jewel Industry India Limited (Unit 4)
Gold		Emirates Gold DMCC
Gold		Fidelity Printers and Refiners Ltd.
Gold		Fujairah Gold FZC
Gold		Geib Refining Corporation
Gold		GG Refinery Ltd.
Gold		GGC Gujrat Gold Centre Pvt. Ltd.
Gold		Global Tungsten & Powders LLC
Gold		Gold by Gold Colombia
Gold		Gold Coast Refinery
Gold		Gold Corporation—The Perth Mint
Gold		Great Wall Precious Metals Co., Ltd. of CBPM
Gold		Guangdong Jinding Gold Limited
Gold		Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold		Heimerle + Meule GmbH
Gold		Heraeus Germany GmbH Co. KG
Gold		Heraeus Metals Hong Kong Ltd.
Gold		Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
Gold		HwaSeong CJ CO., LTD.
Gold		Impala Refineries – Base Metals Refinery (BMR)
Gold		Impala Refineries – Platinum Metals Refinery (PMR)
Gold		Impala Rustenburg
Gold		Industrial Refining Company
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold		International Precious Metal Refiners
Gold		Ishifuku Metal Industry Co., Ltd.
Gold		Istanbul Gold Refinery
Gold		Italpreziosi
Gold		JALAN & Company
Gold		Japan Mint
Gold		Jiangxi Copper Co., Ltd.
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold		JSC Novosibirsk Refinery
Gold		JSC Uralelectromed2
Gold		JX Advanced Metals Corporation
Gold		K.A. Rasmussen
Gold		Kaloti Precious Metals
Gold		Kazakhmys Smelting LLC
Gold		Kazzinc

 

2

Certain of the In-Scope Suppliers reported the presence of this entity that was sanctioned by the United States Department of Treasury, Office of Foreign Assets Control on July 20, 2023. Because of the over-reporting nature of the industry, CMRT information collection process, and the nature of our and our subsidiaries’ supply chains, we are unable to confirm whether or not this, or any, smelter or refiner is or was active in our supply chain.

 

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Gold		Kennecott Utah Copper LLC
Gold		KGHM Polska Miedz Spolka Akcyjna
Gold		Kojima Chemicals Co., Ltd.
Gold		Korea Zinc Co., Ltd.
Gold		Kundan Care Products Ltd.
Gold		Kyrgyzaltyn JSC
Gold		Kyshtym Copper-Electrolytic Plant ZAO
Gold		L’azurde Company For Jewelry
Gold		Lingbao Gold Co., Ltd.
Gold		Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold		L’Orfebre S.A.
Gold		LS MnM Inc.
Gold		LT Metal Ltd.
Gold		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Gold		Marsam Metals
Gold		Materion
Gold		Matsuda Sangyo Co., Ltd.
Gold		MD Overseas
Gold		Metal Concentrators SA (Pty) Ltd.
Gold		Metallix Refining Inc.
Gold		Metalor Technologies (Hong Kong) Ltd.
Gold		Metalor Technologies (Singapore) Pte., Ltd.
Gold		Metalor Technologies (Suzhou) Ltd.
Gold		Metalor Technologies S.A.
Gold		Metalor USA Refining Corporation
Gold		Metalurgica Met-Mex Penoles S.A. De C.V.
Gold		Minera Titan del Peru SRL (MTP) - Belen Plant
Gold		Mitsubishi Materials Corporation
Gold		Mitsui Mining and Smelting Co., Ltd.
Gold		MKS PAMP SA
Gold		MMTC-PAMP India Pvt., Ltd.
Gold		Modeltech Sdn Bhd
Gold		Morris and Watson
Gold		Moscow Special Alloys Processing Plant
Gold		Nadir Metal Rafineri San. Ve Tic. A.S.
Gold		Navoi Mining and Metallurgical Combinat
Gold		NH Recytech Company
Gold		Nihon Material Co., Ltd.
Gold		NOBLE METAL SERVICES
Gold		Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Gold		Ohura Precious Metal Industry Co., Ltd.
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)
Gold		Pease & Curren
Gold		Penglai Penggang Gold Industry Co., Ltd.
Gold		Planta Recuperadora de Metales SpA
Gold		Prioksky Plant of Non-Ferrous Metals
Gold		PT Aneka Tambang (Persero) Tbk
Gold		PX Precinox S.A.

 

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Gold		QG Refining, LLC
Gold		Rand Refinery (Pty) Ltd.
Gold		Refinery of Seemine Gold Co., Ltd.
Gold		REMONDIS PMR B.V.
Gold		Royal Canadian Mint
Gold		SAAMP
Gold		Sabin Metal Corp.
Gold		Safimet S.p.A
Gold		SAFINA A.S.
Gold		Sai Refinery
Gold		SAM Precious Metals FZ-LLC
Gold		Samduck Precious Metals
Gold		SAMWON METALS Corp.
Gold		SEMPSA Joyeria Plateria S.A.
Gold		Shandong Gold Smelting Co., Ltd.
Gold		Shandong Humon Smelting Co., Ltd.
Gold		Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold		Shenzhen CuiLu Gold Co., Ltd.
Gold		SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD.
Gold		Shenzhen Zhonghenglong Real Industry Co., Ltd.
Gold		Shirpur Gold Refinery Ltd.
Gold		Sichuan Tianze Precious Metals Co., Ltd.
Gold		Singway Technology Co., Ltd.
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals
Gold		Solar Applied Materials Technology Corp.
Gold		SOLEIL METALS (Chala One Plant)
Gold		SOLEIL METALS (YAKARI Plant)
Gold		Sovereign Metals
Gold		State Research Institute Center for Physical Sciences and Technology
Gold		Sudan Gold Refinery
Gold		Sumitomo Metal Mining Co., Ltd.
Gold		SungEel HiMetal Co., Ltd.
Gold		Super Dragon Technology Co., Ltd.
Gold		T.C.A S.p.A
Gold		Tanaka Kikinzoku Kogyo K.K.
Gold		TITAN COMPANY LIMITED, JEWELLERY DIVISION
Gold		Tokuriki Honten Co., Ltd.
Gold		Tongling Nonferrous Metals Group Co., Ltd.
Gold		TOO Tau-Ken-Altyn
Gold		Torecom
Gold		Umicore Precious Metals Thailand
Gold		Umicore S.A. Business Unit Precious Metals Refining
Gold		United Precious Metal Refining, Inc.
Gold		Valcambi S.A.
Gold		WEEEREFINING
Gold		WIELAND Edelmetalle GmbH
Gold		Yamakin Co., Ltd.

 

12

Gold		Yokohama Metal Co., Ltd.
Gold		Yunnan Copper Industry Co., Ltd.
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Gold		Zijin Mining Group Gold Smelting Co. Ltd.
Tantalum		5D Production OU
Tantalum		AMG Brasil
Tantalum		D Block Metals, LLC
Tantalum		F&X Electro-Materials Ltd.
Tantalum		FIR Metals & Resource Ltd.
Tantalum		Global Advanced Metals Aizu
Tantalum		Global Advanced Metals Boyertown
Tantalum		Guangdong Rising Rare Metals-EO Materials Ltd.
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum		Jiangxi Suns Nonferrous Materials Co. Ltd.
Tantalum		Jiangxi Tuohong New Raw Material
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum		Jiujiang Tanbre Co., Ltd.
Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Tantalum		KEMET de Mexico
Tantalum		Materion Newton Inc.
Tantalum		Metallurgical Products India Pvt., Ltd.
Tantalum		Mineracao Taboca S.A.
Tantalum		Mitsui Mining and Smelting Co., Ltd.
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum		NPM Silmet AS
Tantalum		PowerX Ltd.
Tantalum		QuantumClean
Tantalum		Resind Industria e Comercio Ltda.
Tantalum		RFH Yancheng Jinye New Material Technology Co., Ltd.
Tantalum		Solikamsk Magnesium Works OAO
Tantalum		Taki Chemical Co., Ltd.
Tantalum		TANIOBIS Co., Ltd.
Tantalum		TANIOBIS GmbH
Tantalum		TANIOBIS Japan Co., Ltd.
Tantalum		TANIOBIS Smelting GmbH & Co. KG
Tantalum		Telex Metals
Tantalum		Ulba Metallurgical Plant JSC
Tantalum		XIMEI RESOURCES (GUANGDONG) LIMITED
Tantalum		XinXing Haorong Electronic Material Co., Ltd.
Tantalum		Yanling Jincheng Tantalum & Niobium Co., Ltd.
Tin		Alpha Assembly Solutions Inc
Tin		An Vinh Joint Stock Mineral Processing Company
Tin		Aurubis Beerse
Tin		Aurubis Berango
Tin		Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin		Chifeng Dajingzi Tin Industry Co., Ltd.
Tin		China Tin Group Co., Ltd.

 

13

Tin		Conecsus LLC
Tin		CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
Tin		CRM Synergies
Tin		CV Ayi Jaya
Tin		Dongguan Best Alloys Co., Ltd.
Tin		Dongguan CiEXPO Environmental Engineering Co., Ltd.
Tin		Dowa
Tin		Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin		EM Vinto
Tin		Estanho de Rondonia S.A.
Tin		Fabrica Auricchio Industria e Comercio Ltda.
Tin		Fenix Metals
Tin		Gejiu City Fuxiang Industry and Trade Co., Ltd.
Tin		Gejiu Kai Meng Industry and Trade LLC
Tin		Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin		Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin		Gejiu Zili Mining And Metallurgy Co., Ltd.
Tin		Global Advanced Metals Greenbushes Pty Ltd.
Tin		Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
Tin		HuiChang Hill Tin Industry Co., Ltd.
Tin		Jiangxi New Nanshan Technology Ltd.
Tin		Longnan Chuangyue Environmental Protection Technology Development Co., Ltd
Tin		Luna Smelter, Ltd.
Tin		Ma’anshan Weitai Tin Co., Ltd.
Tin		Magnu’s Minerais Metais e Ligas Ltda.
Tin		Malaysia Smelting Corporation (MSC)
Tin		Malaysia Smelting Corporation Berhad (Port Klang)
Tin		Melt Metais e Ligas S.A.
Tin		Metallic Resources, Inc.
Tin		Mineracao Taboca S.A.
Tin		Mining Minerals Resources SARL
Tin		Minsur
Tin		Mitsubishi Materials Corporation
Tin		Modeltech Sdn Bhd
Tin		Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin		Novosibirsk Tin Combine
Tin		O.M. Manufacturing (Thailand) Co., Ltd.
Tin		O.M. Manufacturing Philippines, Inc.
Tin		Operaciones Metalurgicas S.A.
Tin		P Kay Metal, Inc
Tin		Pongpipat Company Limited
Tin		Precious Minerals and Smelting Limited
Tin		PT Aries Kencana Sejahtera
Tin		PT Artha Cipta Langgeng
Tin		PT ATD Makmur Mandiri Jaya
Tin		PT Bangka Prima Tin
Tin		PT Cipta Persada Mulia
Tin		PT Masbro Alam Stania

 

14

Tin		PT Mitra Stania Prima
Tin		PT Mitra Sukses Globalindo
Tin		PT Panca Mega Persada
Tin		PT Premium Tin Indonesia
Tin		PT Prima Timah Utama
Tin		PT Putera Sarana Shakti (PT PSS)
Tin		PT Rajehan Ariq
Tin		PT Timah Tbk Kundur
Tin		PT Timah Tbk Mentok
Tin		Resind Industria e Comercio Ltda.
Tin		RIKAYAA GREENTECH PRIVATE LIMITED
Tin		Rui Da Hung
Tin		Super Ligas
Tin		Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.
Tin		Thaisarco
Tin		Tin Smelting Branch of Yunnan Tin Co., Ltd.
Tin		Tin Technology & Refining
Tin		Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tin		VQB Mineral and Trading Group JSC
Tin		White Solder Metalurgia e Mineracao Ltda.
Tin		Woodcross Smelting Company Limited
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin		Yunnan Yunfan Non-ferrous Metals Co., Ltd.
Tungsten		A.L.M.T. TUNGSTEN Corp.
Tungsten		ACL Metais Eireli
Tungsten		Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
Tungsten		Artek LLC3
Tungsten		Asia Tungsten Products Vietnam Ltd.
Tungsten		China Molybdenum Tungsten Co., Ltd.
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten		CNMC (Guangxi) PGMA Co., Ltd.
Tungsten		Cronimet Brasil Ltda
Tungsten		DONGKUK INDUSTRIES CO., LTD.
Tungsten		Fujian Xinlu Tungsten Co., Ltd.
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten		Global Tungsten & Powders LLC
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.
Tungsten		H.C. Starck Tungsten GmbH
Tungsten		HANNAE FOR T Co., Ltd.
Tungsten		Hubei Green Tungsten Co., Ltd.
Tungsten		Hunan Chenzhou Mining Co., Ltd.
Tungsten		Hunan Jintai New Material Co., Ltd.
Tungsten		Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch

 

3

Certain of the In-Scope Suppliers reported the presence of this entity, which may have been sanctioned by the United States Department of Treasury, Office of Foreign Assets Control on February 23, 2024. Because of the over-reporting nature of the industry, CMRT information collection process, and the nature of our and our subsidiaries’ supply chains, we are unable to confirm whether or not this, or any, smelter or refiner is or was active in our supply chain.

 

15

Tungsten		Hydrometallurg, JSC
Tungsten		Japan New Metals Co., Ltd.
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten		JSC “Kirovgrad Hard Alloys Plant”
Tungsten		Kenee Mining Corporation Vietnam
Tungsten		Kennametal Fallon
Tungsten		Kennametal Huntsville
Tungsten		LAOS SOUTHERN MINING SMELTING SOLE CO.,LTD
Tungsten		Lianyou Metals Co., Ltd.
Tungsten		Lianyou Resources Co., Ltd.
Tungsten		LLC Vostok
Tungsten		MALAMET SMELTING SDN. BHD.
Tungsten		Malipo Haiyu Tungsten Co., Ltd.
Tungsten		Masan High-Tech Materials
Tungsten		Moliren Ltd.
Tungsten		Nam Viet Cromit Joint Stock Company
Tungsten		Niagara Refining LLC
Tungsten		NPP Tyazhmetprom LLC
Tungsten		OOO “Technolom” 1
Tungsten		OOO “Technolom” 2
Tungsten		Philippine Bonway Manufacturing Industrial Corporation
Tungsten		Philippine Carreytech Metal Corp.
Tungsten		Philippine Chuangxin Industrial Co., Inc.
Tungsten		S.P.T. spol.s r.o.
Tungsten		Shinwon Tungsten (Fujian Shanghang) Co., Ltd.
Tungsten		TANIOBIS Smelting GmbH & Co. KG
Tungsten		Tungamoy Metals Inc.
Tungsten		Tungsten Vietnam Joint Stock Company
Tungsten		Unecha Refractory Metals Plant
Tungsten		Uzbekistan Technological Metallurgical Complex JSC
Tungsten		Wolfram Bergbau und Hutten AG
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten		Xiamen Tungsten Co., Ltd.
Tungsten		YUDU ANSHENG TUNGSTEN CO., LTD.

 

16

APPENDIX B: COUNTRIES OF ORIGIN

This Appendix B includes the countries from which the declared are known to source material.

 

Country of Origin
Angola		Guinea		Papua New Guinea
Argentina		Guyana		Peru
Armenia		Hong Kong		Philippines
Australia		Hungary		Poland
Austria		India		Portugal
Belarus		Indonesia		Russian Federation
Belgium		Ireland		Rwanda
Bermuda		Israel		Saudi Arabia
Bolivia		Italy		Sierra Leone
Brazil		Japan		Singapore
Burundi		Jersey		Slovakia
Cambodia		Kazakhstan		South Africa
Canada		Kenya		South Sudan
Central African Republic		Republic of Korea		Spain
Chile		Kyrgyzstan		Suriname
China		Lao People Democratic Republic		Sweden
Colombia		Luxembourg		Switzerland
Congo (Brazzaville)		Madagascar		Taiwan
Cote D’ivoire		Malaysia		Tajikistan
Czech Republic		Mali		Tanzania
Djibouti		Mexico		Thailand
Democratic Republic of the Congo		Mongolia		Turkey
Ecuador		Morocco		Uganda
Egypt		Mozambique		United Arab Emirates
Estonia		Myanmar		United Kingdom
Ethiopia		Namibia		United States
Finland		Netherlands		Uzbekistan
France		New Zealand		Viet Nam
Germany		Niger		Zambia
Ghana		Nigeria		Zimbabwe

 

17