CONFLICT MINERALS REPORT OF
Peloton Interactive, Inc.
FOR THE REPORTING PERIOD FROM JANUARY 1, 2025 TO
DECEMBER 31, 2025
I.Introduction
Peloton Interactive, Inc. (“we,” “our,” “us,” “Peloton,” or the “Company”) provides this Conflict Minerals1 Report for calendar year 2025 (the “Reporting Period”) in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended. In this report, the words “we,” “us,” “our,” “the Company,” and “Peloton”, refer to Peloton Interactive, Inc. and its wholly owned subsidiaries, unless the context requires otherwise.
At Peloton, we are committed to respecting and protecting the human rights for all our stakeholders, including our team members, Members (as defined below), partners, and individuals at all levels of our supply chain. We designed our processes to enable sufficient knowledge of input materials and components to reasonably assure that they were obtained from sources in compliance with applicable laws and regulatory requirements, including those relating to conflict minerals. As part of our commitment to responsible sourcing practices, we undertook due diligence with respect to potential sourcing of tin, tungsten, tantalum, and gold (“3TG” or “conflict minerals”) materials within our products. Our due diligence efforts were consistent with the internationally recognized framework set forth 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 Areas2 (“OECD Due Diligence Guidance”) and related supplements.
The statements below are based on the activities performed to date in good faith by the Company and are based on the infrastructure and information available at the time of this filing. Factors that could cause actual results to differ materially from these statements include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving identification of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding U.S. Securities and Exchange Commission (“SEC”) final rules, and other issues.
Forward-Looking Statements
This report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. We intend such forward-looking statements to be covered by the safe harbor provisions for forward-looking statements contained in Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. All statements contained in this report other than statements of historical fact, including, without limitation, statements regarding our future conflict minerals due diligence efforts, are forward-looking statements. The words “believe,” “may,” “will,” “estimate,” “potential,” “continue,” “anticipate,” “intend,” “expect,” “could,” “would,” “project,” “plan,” “target,” and similar expressions are intended to identify forward-looking statements, though not all forward-looking statements use these words or expressions. You should not rely upon forward-looking statements as predictions of future events. The events and circumstances reflected in the forward-looking statements may not be achieved or occur. Although we believe that the expectations reflected in the forward-looking statements are reasonable, we cannot guarantee future results, performance, or achievements. Our forward-looking statements speak only as of the date of this report, and we undertake no obligation to update any of these forward-looking statements for any reason after the date of this report or to conform these statements to actual results or revised expectations, except as required by law.
II.Overview
Company Profile
1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country.
2 OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264252479-en.
Peloton is a leading global fitness and wellness company that empowers people to live fit, strong, long, and happy, by providing fitness and wellness experiences to Members (as defined below) anytime, anywhere. We have a highly engaged community of Members across the United States, United Kingdom, Canada, Germany, Australia, and Austria. As a category innovator at the nexus of fitness and wellness, technology, and media, we deliver experiences through our world-renowned instructors, premium hardware and innovative software, personalization, extensive modalities, and an expansive content library.
We define a “Member” as any individual who has a Peloton account through a Paid Connected Fitness Subscription or a Paid App Subscription, inclusive of the Peloton App+, App One, Strength+, and Breathwrk Memberships (our “Peloton Apps”), and engages in one or more workouts in the trailing 12-month period. We define workout engagement as either (i) completing the lesser of 50% or 10 minutes of Instructor-led classes, Scenic (guided, time, and distance-based rides filed in locations around the world), and Lanebreak workouts (our game-inspired workout experience); (ii) at least 10 minutes of any activity tracking workout (such as “Just Ride,” “Just Run,” or “Just Row”), or Peloton Entertainment workout (video streaming); (iii) at least 5 minutes of any Strength+ workout with 80% of sets marked complete; or (iv) at least 10 minutes of any Breathwrk class.
We define a “Paid Connected Fitness Subscription” as a person, household, or commercial property, such as a hotel or residential building, that has paid for a subscription to a Connected Fitness Product (a Connected Fitness Subscription with a successful credit card billing or with prepaid subscription credits or waivers). “Paid App Subscriptions” include all subscriptions to our Peloton Apps for which we currently receive payment.
We have determined that, during the Reporting Period, conflict minerals were likely necessary to the functionality or production of certain products that Peloton, and its wholly-owned subsidiary, Precor Inc. (“Precor”), manufactured or contracted to manufacture, based on the inclusion of metal and electronic components that contain 3TG materials. Although Peloton does not directly purchase, procure, or source conflict minerals, and is many steps removed from the mining of conflict minerals, we are committed to meeting internationally accepted due diligence standards for primary minerals in our supply chain. Our responsible minerals sourcing program includes requirements that apply to all levels of Peloton’s and Precor’s supply chain.
Peloton maintains a conflict minerals policy that reflects our commitments to conflict-free sourcing. The link to this Policy is maintained on Peloton’s website at:
https://investor.onepeloton.com/corporate-governance.
Reasonable Country of Origin Inquiry Information
We have conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the necessary conflict minerals originated in the DRC or an adjoining country, or came from recycled or scrap sources.
Similar to other companies our size, our supply chain is complex, consisting of a number of suppliers across many countries that provide products and components. Peloton does not purchase raw ore or unrefined minerals from, or conduct business directly with, any SORs. Peloton is downstream from SORs, with many layers of suppliers between Peloton and 3TG SORs. We source our products and components from suppliers, which, in turn, source materials described in this report from sub-tier suppliers. Given the nature of our supply chain, we relied on the information concerning the source of 3TG in our products provided by our in-scope direct suppliers, who in turn gathered the information from their upstream suppliers.
The Company’s RCOI process included reviewing the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope under Rule 13p-1 and conducting an inquiry of our direct suppliers of the in-scope products using the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Based on the results of our RCOI, which indicated sourcing from the DRC or an adjoining country, we exercised due diligence on the source and chain of custody of the conflict minerals in accordance with the OECD Due Diligence Guidance. Our due diligence efforts are discussed further in this Conflict Minerals Report.
Due Diligence Program Design
The Company designed its conflict minerals program to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as they relate to our position in the minerals supply chain as a “downstream” company:
Step 1: Establish strong company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Carry out independent third-party audit of smelter/refiner due diligence practices
Step 5: Report annually on supply chain due diligence
III.Due Diligence Measures Performed by The Company
Consistent with the five steps of the OECD Due Diligence Guidance, Peloton has undertaken the following steps to reasonably determine the country of origin of, and to exercise due diligence in, the 3TG mineral supply chain.
Step 1: Establish strong company management systems
We have established and maintain certain policies, procedures, and systems, in connection with the mineral supply chain and our commitments related thereto:
a.Supplier Code of Conduct – Peloton’s Supplier Code of Conduct (the “Supplier Code”), which incorporates Peloton’s Conflict Minerals Policy, applies to all levels of Peloton’s supply chain, including our trusted partners and sub-tier suppliers. The Supplier Code and Conflict Minerals Policy are based on industry and internationally accepted principles, including the International Labour Organization’s Labour Standards and the OECD Due Diligence Guidance.
b.Conflict Minerals Policy – The Conflict Minerals Policy highlights the Company’s commitment to complying with the reporting and due diligence obligations required by Rule 13p-1 and the Company’s expectations that our suppliers comply with the same obligations. The policy is available on our corporate website at https://investor.onepeloton.com/corporate-governance.
c.Policy Commitments – The Supplier Code sets forth Peloton’s commitments for our suppliers in the areas of labor and human rights, health and safety, the environment, integrity in business dealings, and other risk areas. The Company’s policy commitments are sustained through the structures and processes set forth below. The Supplier Code establishes five Guiding Principles that shape our commitments to help maintain a responsible and ethical supply chain. A key Guiding Principle is acting as a responsible global citizen, which encompasses our conflict minerals due diligence commitments as reflected in the Company’s Conflict Minerals Policy.
d.Other Relevant Policies – We maintain other policies relevant to the Company’s Conflict Minerals commitments, which include the following:
The Company’s Code of Conduct: Sets forth the standards that govern all of our business dealings and establishes expectations for everyone at Peloton. Peloton’s commitments in the Code of Conduct are reflected in the Supplier Code, and we expect our partners and sub-tier suppliers to be aware of and adhere to Peloton’s standards and Guiding Principles for maintaining a responsible and ethical supply chain.
Global Integrity Reporting Policy: Applies to Peloton’s team members, directors, and officers, and contractors, and sets forth our approach to protecting and supporting individuals who report potential misconduct.
e.Peloton Management Systems – The Peloton Safety, Compliance, Policy and Regulatory Affairs, and Procurement Teams, in coordination with other stakeholders, manage the Company’s Conflict Minerals diligence efforts. These efforts include senior leadership involvement to ensure that critical information, including the Company’s conflict minerals standard and the Supplier Code, reach relevant team members and all suppliers. These teams coordinate efforts related to Peloton’s Supplier Code and across Peloton’s business teams and functions, including Supply Chain, Product, legal, and finance. The Safety, Compliance, Policy and Regulatory Affairs, and Procurement teams regularly report to, and consult with, Peloton’s senior management to review progress and set ongoing commitments for our responsible sourcing of materials and environmental due diligence efforts.
f.Board Oversight – Peloton’s Board of Directors oversees Peloton’s Chief Executive Officer and other senior management in the competent and ethical operation of Peloton on a day-to-day basis related to conflict minerals. The Audit Committee assists Peloton’s Board of Directors in monitoring significant business risks, including operational and reputational risks.
g.Internal Engagement – The Company administers a role based program to ensure that team members involved with the conflict minerals process are aware of the goals of its program, and its reporting obligations as a public company.
h.Supplier Engagement – The Company communicates its Conflict Minerals Policy and provides educational materials to its in-scope suppliers, enforced by the Supplier Code. In-scope suppliers are informed of the Company’s conflict minerals disclosure requirements on an annual basis when the Company requests information in connection with the Conflict Minerals Policy, along with recommendations for developing, implementing, and documenting a conflict minerals compliance program.
i.Company Level Reporting Mechanism – Stakeholders, internal and external, can communicate directly and confidentially with the Company’s Safety, Ethics and Compliance team by reporting through available channels. For example, Peloton maintains a dedicated, external Integrity Helpline so that team members, contractors, and supplier partners can raise concerns or report misconduct on a confidential basis. Concerns can be reported anonymously. All concerns are reviewed by dedicated investigators through our confidential investigation processes.
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk management process:
a.Identified products in scope – Peloton conducted a detailed review of the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release.
b.Conducted RCOI – The Company utilized the most recent version of the industry-developed CMRT to query our suppliers for conflict minerals information. We requested this information from the Tier 1 suppliers who provide materials and components for the products deemed in-scope by our Conflict Minerals team. We evaluated the responses from the templates submitted by our suppliers to determine our reporting obligation based on this RCOI. See Appendix I for a list of countries of origin identified through the RCOI process.
c.Completed additional follow-up – The Company contacted direct suppliers multiple times to request detailed conflict minerals information. We worked to clarify and validate the accuracy of information provided by our suppliers through standardized feedback questions to address any issues or uncertainty with the template provided when necessary and/or obtaining additional information upon request (product identification, order numbers, or shipping addresses) to help ensure we received conflict minerals information specific to our supply-chain.
d.Identified smelters or refiners (“SORs”) – The Company compiled a list of SORs in our supply chain using our suppliers’ responses in their CMRTs. The Company reconciled this list to the list of smelter facilities designated by the RMI’s Responsible Minerals Assurance Process (“RMAP”). The RMAP conducts independent, third-party audits of SORs to determine which have validated systems that help ensure the minerals were responsibly sourced according to the OECD Due Diligence Guidance. The Company also utilized information provided by the London Bullion Market Association (“LBMA”), and Responsible Jewelry Council (“RJC”) cross-recognition audit programs. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs. We have provided that list in this report within section IV – Product Description; Processing Facilities.
Step 3: Design and implement a strategy to respond to identified risks
We performed the following steps as part of our risk management plan:
a.Reporting results to senior management – The Conflict Minerals team reports the results of our RCOI to senior management. These communications included the Conflict Minerals team’s plan to respond, as needed, to risks identified in the due diligence processes.
b.Designed and implemented a plan – The Company used established risk rating criteria to evaluate suppliers based on the responses provided within their CMRTs, as well as any additional documentation furnished to support those responses and the suppliers’ due diligence processes. The resulting risk ratings were used to develop specific supplier outreach and training to address the identified risks and to take corrective actions with suppliers found not in compliance with the Company’s Conflict Minerals Policy. This includes additional outreach to suppliers who failed to respond to our multiple requests for information, suppliers who provided inconsistent or erroneous information, and suppliers who indicated they had received responses from less than 50% of their in-scope suppliers. Our Conflict Minerals team further reviews the responses to verify the validity of SORs reported by our suppliers, the audit status of such SORs and the country of origin of the minerals processed at such facilities.
c.Provided informational materials – The Company provided each supplier with informational materials that explain Section 1502 of the Dodd Frank Act, the OECD framework, the RCOI process, and general information on the contents of the most
recent revision of the CMRT (including definitions of common phrases and frequently asked questions). These materials are provided to suppliers at the time of the initial request for a completed CMRT. The informational materials serve as a point of reference for suppliers that are unfamiliar with the rule and helps to limit the risk of obtaining inaccurate information from them. We offer assistance to our suppliers throughout the process to improve the quality of the information provided to us.
d.Identified SORs – As part of the risk mitigation process, the Company reconciled the list of SORs collected from suppliers to the list of smelter facilities validated by the RMI.
Step 4: Carry out independent third-party audit of smelter/refiner due diligence practices
The Company uses information provided by independent third-party audit programs, including the RMI RMAP, LBMA, and RJC, to confirm the existence, and verify the OECD-conformance status, of SORs identified during our due diligence.
The Company encouraged participation in the RMAP and requested the SORs to provide the mines and/or locations from which the SOR sources to assist in identifying all countries of origin.
The Company is also a member of the RMI (under member ID PLTN). As a member, the Company financially supports the development of the RMAP through its member dues and utilizes the RMI data to determine the country of origin of conflict minerals in the Company’s products in addition to the Company’s efforts of reaching out to smelters.
Step 5: Report annually on supply chain due diligence
Accordingly, this Conflict Minerals Report has been filed with the SEC and is available on our investor relations website at https://investor.onepeloton.com.
IV.Product Description; Processing Facilities
Our Connected Fitness Products
We provide Members with expert instruction and world-class content to create impactful and entertaining workout and wellness experiences for anyone, anywhere, and at any stage in their fitness journey. At home, outdoors, traveling, or at the gym, we offer an immersive and personalized experience. With a vast library of classes across many fitness disciplines, Members can access Peloton content via our hardware or our Peloton Apps, which can be accessed via phone, tablet, computer, or TV, allowing Members to work out when, where, and how they want. Our business is managed and our financial results are reported on a segment basis, consisting of Connected Fitness Products and Subscriptions. Our Connected Fitness Products are subject to Rule 13p-1 and include the Peloton Pro series, a refresh of our portfolio of commercial-certified Peloton-branded products, which includes the Bike+ Pro, Tread+ Pro, and Row+ Pro, as well as our Cross Training Series, a refreshed portfolio of Connected Fitness Products, which include:
●Peloton Bike: The original Peloton Bike combines fitness, technology, and media, to connect riders to live and on-demand workouts led by Peloton Instructors. It features a carbon steel frame, a nearly silent belt drive, durable magnetic resistance, and a rotating 22” high-definition (“HD”) touchscreen with built-in stereo speakers to stream live and on-demand classes, all in a compact 4’ by 2’ footprint. The Peloton Bike also offers alternative workout experiences like Peloton Entertainment, Scenic, and Lanebreak. The original Peloton Bike is available in the United States, Canada, the United Kingdom, Germany, Australia and Austria.
●Peloton Bike+: The Peloton Bike+ includes all original Peloton Bike features, but introduces an upgraded 24”, 360-degree rotating HD touchscreen display, allowing Members to easily pivot and tilt the screen for floor-based routines. Resistance on the Peloton Bike+ is controlled digitally with an electronic braking system that enables an Instructor-led “Auto Follow” feature. Additional hardware components include a three-speed fan for optimal airflow, Sonos-tuned speakers, a powerful built-in soundbar and subwoofer system, and a front-facing, movement-tracking camera powered by Peloton IQ for real-time form correction, repetition tracking, and weight suggestions. The Peloton Bike+ is currently available for purchase in the United States, Canada, the United Kingdom, Germany, Australia and Austria.
●Peloton Tread: The Peloton Tread combines a treadmill hardware design with Peloton’s Instructor-led running, walking, hiking, and bootcamp content, as well as Peloton Entertainment, Scenic, and Lanebreak. It maintains an ample running surface area and runner comfort in an affordable and compact form. The Peloton Tread features a sleek belt drive, a rotating 24” HD touchscreen with integrated soundbar and subwoofer, heart rate monitor integration, and hardware control elements unique to Peloton, including dial control knobs, jump buttons, and an auto-incline feature. The Peloton Tread is currently available for purchase in the United States, Canada, the United Kingdom, Australia, and Germany.
●Peloton Tread+: The Peloton Tread+ includes all base Peloton Tread features and incorporates a shock-absorbing rubber-slat belt and ball bearing system designed for low-impact training. It features an upgraded 32” swivel HD touchscreen with a 20-watt sound bar, ergonomic pace and incline control knobs, and a rear safety guard that enhances the product’s safety features. The Peloton Tread+ further incorporates an integrated three-speed fan for optimal airflow, Sonos-tuned speakers, hands-free control, and a front-facing, movement-tracking camera powered by Peloton IQ for real-time form correction, repetition tracking, and weight suggestions.
●Peloton Row+: The Peloton Row+ combines innovative software, premium hardware design, and exclusive Peloton content to deliver a unique low-impact, full-body cardio and strength rowing workout. The Peloton Row+ features a rotating HD touchscreen, proprietary rowing form assistance and form guidance technology, an integrated three-speed fan for optimal airflow, Sonos-tuned speakers, and hands-free control. It also incorporates a front-facing, movement-tracking camera powered by Peloton IQ for repetition tracking and weight suggestions. The Peloton Row+ is currently available for purchase in the United States and Canada.
Precor Products and Services
Precor products and services span across all major categories, including cardio, connected fitness consoles, strength, and functional fitness. Precor cardio products include treadmills, Elliptical Fitness Crosstrainers, adaptive motion trainers, bikes, and a StairClimber. Cardio products may be equipped with touchscreen internet-connected fitness consoles, or non-internet-connected LED consoles. Precor strength products include a variety of selectorized and plate-loaded machines, as well as functional multi-station units, benches, racks, and stretching equipment.
Processing Facilities
Based on our due diligence process and the information received from our suppliers, the facilities listed in the table below were identified by the Company’s suppliers as the smelters and refiners of the 3TG present in and necessary to the functionality of products manufactured for the Company in the Reporting Period. As such, this smelter list is presented in good faith as the best information we have to date. During the Reporting Period, we identified 216 SORs in our supply chain. This list may contain smelters that are not in our supply chain and/or there may be other smelters in our supply chain which have not yet been identified by our due diligence process.
| | | | | | | | | | | |
| Metal | Smelter Name | Country | Smelter ID |
| Gold | ABC Refinery Pty Ltd. | AUSTRALIA | CID002920 |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
| Gold | Agosi AG | GERMANY | CID000035 |
| Gold | Gold Corporation - The Perth Mint | AUSTRALIA | CID002030 |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
| Gold | Dowa | JAPAN | CID000401 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
| Gold | ASAHI METALFINE, Inc. | JAPAN | CID000082 |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
| Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
| Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 |
| Gold | Gold by Gold Colombia | COLOMBIA | CID003641 |
| Gold | Aurubis AG, Hamburg | GERMANY | CID000113 |
| Gold | Bangalore Refinery | INDIA | CID002863 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
| Gold | Boliden Mineral AB (Ronnskar) | SWEDEN | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
| | | | | | | | | | | |
| Metal | Smelter Name | Country | Smelter ID |
| Gold | Glencore Canada Corporation - CCR Refinery | CANADA | CID000185 |
| Gold | Chimet S.p.A. | ITALY | CID000233 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
| Gold | Chugai Mining | JAPAN | CID000264 |
| Gold | Coimpa Industrial LTDA | BRAZIL | CID004010 |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
| Gold | Dongwu Gold Group | CHINA | CID003663 |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 |
| Gold | Elite Industech Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID004755 |
| Gold | Zijin Mining Group Gold Smelting Co. Ltd. | CHINA | CID002243 |
| Gold | GG Refinery Ltd. | TANZANIA, UNITED REPUBLIC OF | CID004506 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | CID000711 |
| Gold | Heraeus Metals Hong Kong Ltd. | HONG KONG | CID000707 |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR) | SOUTH AFRICA | CID004714 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
| Gold | Italpreziosi | ITALY | CID002765 |
| Gold | Japan Mint | JAPAN | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
| Gold | JX Advanced Metals Corporation | JAPAN | CID000937 |
| Gold | Kazzinc Ltd | KAZAKHSTAN | CID000957 |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 |
| Gold | Yamakin Co., Ltd. | JAPAN | CID002100 |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF | CID001078 |
| Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | CID003575 |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
| Gold | MKS PAMP SA | SWITZERLAND | CID001352 |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 |
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 |
| Gold | Oegussa Oesterreichische Gold- und Silber-Scheideanstalt Gesm.b.H. | AUSTRIA | CID002779 |
| | | | | | | | | | | |
| Metal | Smelter Name | Country | Smelter ID |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
| Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
| Gold | PX Precinox S.A. | SWITZERLAND | CID001498 |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 |
| Gold | Royal Canadian Mint | CANADA | CID001534 |
| Gold | SAFINA A.S. | CZECHIA | CID002290 |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA | CID002750 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
| Gold | T.C.A S.p.A | ITALY | CID002580 |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
| Tantalum | AMG Brasil | BRAZIL | CID001076 |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 |
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | CID000616 |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | CID002544 |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | CID002548 |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | CID002549 |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002550 |
| Tantalum | TANIOBIS GmbH | GERMANY | CID002545 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
| Tantalum | KEMET de Mexico | MEXICO | CID002539 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 |
| Tantalum | Mitsui Kinzoku Company, Limited | JAPAN | CID001192 |
| Tantalum | NPM Silmet OU | ESTONIA | CID001200 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
| Tantalum | PowerX Ltd. | RWANDA | CID004054 |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
| | | |
| | | | | | | | | | | |
| Metal | Smelter Name | Country | Smelter ID |
| Tin | Alpha Assembly Solutions Inc | UNITED STATES OF AMERICA | CID000292 |
| Tin | Aurubis Beerse | BELGIUM | CID002773 |
| Tin | Aurubis Berango | SPAIN | CID002774 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | CID002180 |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | CID003486 |
| Tin | CRM Synergies EMEA, S.L.U. | SPAIN | CID003524 |
| Tin | CV Ayi Jaya | INDONESIA | CID002570 |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
| Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 |
| Tin | PT Rajehan Ariq | INDONESIA | CID002593 |
| Tin | Dongguan Best Alloys Co., Ltd. | CHINA | CID000377 |
| Tin | Dowa | JAPAN | CID000402 |
| Tin | Empresa Metallurgica Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
| Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | CID003582 |
| Tin | Fenix Metals | POLAND | CID000468 |
| Tin | Minsur | PERU | CID001182 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | AUSTRALIA | CID004754 |
| Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | CHINA | CID003116 |
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
| Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
| Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
| Tin | Luna Smelter, Ltd. | RWANDA | CID003387 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA | CID004434 |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
| Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE | CID004065 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
| Tin | P Kay Metal, Inc | UNITED STATES OF AMERICA | CID005189 |
| Tin | Precious Minerals and Smelting Limited | INDIA | CID003409 |
| Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
| Tin | PT Bangka Prima Tin | INDONESIA | CID002776 |
| Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 |
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | CID003449 |
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | CID003868 |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
| Tin | Super Ligas | BRAZIL | CID002756 |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | JAPAN | CID004403 |
| Tin | Thaisarco | THAILAND | CID001898 |
| | | | | | | | | | | |
| Metal | Smelter Name | Country | Smelter ID |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
| Tin | Woodcross Smelting Company Limited | UGANDA | CID004724 |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 |
| Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | CID002513 |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | CID002641 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | CID003468 |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA | CID003609 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | CID003417 |
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA | CID000568 |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002542 |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
| Tungsten | KENEE MINING VIETNAM COMPANY LIMITED | VIET NAM | CID004619 |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 |
| Tungsten | Lianyou Resources Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID004397 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
| Tungsten | Masan High-Tech Materials | VIET NAM | CID002543 |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CHINA | CID004430 |
| Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM | CID003993 |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
V.Future Due Diligence
We intend to continue communicating our expectations and data requirements to our direct suppliers. Over time, we anticipate that the global availability of traceability and sourcing information for these minerals will expand, enhancing our supply chain visibility. We will continue to inquire with our direct suppliers regarding the ultimate sources of these raw materials, and will undertake additional risk assessments as new facts or circumstances arise. If a supplier fails to meet our responsible sourcing expectations, we will work collaboratively with them, leveraging industry-wide programs where appropriate, to build their capacity. We expect our direct suppliers to implement similar due diligence measures with their own upstream suppliers to ensure alignment throughout our entire supply chain.
In addition to the actions noted elsewhere in this report, we expect to undertake the following steps during the next compliance period:
●Review and update our Conflict Minerals Policy, as necessary.
●Review and refine supplier and internal team member training materials, as necessary.
●Continue collecting supplier disclosures utilizing the most recent revision of the CMRT.
●Engage with suppliers that did not provide a response in prior year(s) or provided incomplete responses to enhance our data collection for 2026.
●Monitor and track performance of our risk mitigation efforts, including the performance of suppliers deemed high-risk.
●Request product-level or user-defined level disclosures from suppliers, where feasible, to obtain more granular sourcing data.
●Compare and validate RCOI results against data from independent third-party audit programs, such as the RMI, and through our own coordinated outreach to smelters.
●Encourage responsible sourcing from the DRC and its adjoining countries, while monitoring global developments and emerging standards across all regions applicable to our supply chain.
●Track emerging supply chain challenges that impact the RMI audit status of smelters and refiners.
●Continue supporting the initiatives of industry groups, like the RMI, to strengthen broader institutional due diligence efforts.
APPENDIX I – Countries of Origin
The information provided in this Appendix is based on the information collected from the Company’s suppliers.
| | | | | |
| Australia | Myanmar |
| Benin | Namibia |
| Bolivia | Nicaragua |
| Brazil | Niger |
| Burundi | Nigeria |
| Canada | Papua New Guinea |
| Chile | Peru |
| China | Philippines |
| Colombia | Portugal |
| Congo, Democratic Republic of the | Rwanda |
| Ethiopia | Sierra Leone |
| France | South Africa |
| Germany | Spain |
| Guyana | Sweden |
| India | Tanzania |
| Indonesia | Thailand |
| Japan | Uganda |
| Laos | United Kingdom |
| Liberia | United States of America |
| Madagascar | Uzbekistan |
| Malaysia | Vietnam |
| Mongolia | Zambia |
| Mozambique | Zimbabwe |