EXHIBIT 1.01
DXP Enterprises, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2016
Introduction
This Conflict Minerals Report has been prepared by management of DXP for the period from January 1, 2016 to December 31, 2016 (the "Reporting Period"). Unless the context otherwise indicates, "DXP," "we," "us," the "Company" and "our" mean DXP Enterprises, Inc. and its consolidated and combined subsidiaries.
This Report is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule"). This Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines "conflict minerals" as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold ("3TGs") that are necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.
As described in this report, DXP has reason to believe that some of the 3TGs present in its supply chain may have originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (the "Covered Countries"). Therefore, we performed a reasonable country of origin inquiry ("RCOI") to determine whether any of the 3TGs in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we determined that we may have some suppliers that sourced 3TG from the DRC Region and proceeded to conduct due diligence on our supplier base. The results of this are covered below.
Company Overview
Our business
DXP is engaged in the business of distributing maintenance, repair, and operating products, equipment and services to energy and industrial customers. DXP is organized into three business segments: Service Centers, Innovative Pumping Solutions and Supply Chain Services. The Service Centers segment is engaged in providing maintenance, MRO products and equipment, including logistics capabilities, to industrial customers. The Service Centers segment provides a wide range of MRO products in the rotating equipment, bearing, power transmission, hose, fluid power, metal working, fastener, industrial supply, safety products and safety services categories. The Innovative Pumping Solutions segment fabricates and assembles custom-made pump packages, remanufactures pumps and manufactures branded private label pumps. The Supply Chain Services segment manages all or part of a customer's MRO products supply chain, including warehouse and inventory management.
We have become customer driven experts in five key product categories. As such, our three business segments are supported by the following five key product categories: rotating equipment, bearings & power transmission, industrial supplies, metal working and safety products & services. Each business segment tailors its inventory and leverages product experts to meet the needs of its local customers.
Key product categories that we offer include:
| · | Rotating Equipment. Our rotating equipment products include a full line of centrifugal pumps for transfer and process service applications, such as petrochemicals, refining and crude oil production; rotary gear pumps for low- to- medium pressure service applications, such as pumping lubricating oils and other viscous liquids; plunger and piston pumps for high-pressure service applications such as disposal of produced water and crude oil pipeline service; and air-operated diaphragm pumps. We also provide a large variety of pump accessories. |
| · | Bearings & Power Transmission. Our bearing products include several types of mounted and un-mounted bearings for a variety of applications. The power transmission products we distribute include speed reducers, flexible-coupling drives, chain drives, sprockets, gears, conveyors, clutches, brakes and hoses. |
| · | Industrial Supplies. We offer a broad range of industrial supplies, such as abrasives, tapes and adhesive products, coatings and lubricants, fasteners, hand tools, janitorial products, pneumatic tools, welding supplies and welding equipment. |
| · | Metal Working. Our metal working products include a broad range of cutting tools, abrasives, coolants, gauges, industrial tools and machine shop supplies. |
| · | Safety Products & Services. We sell a broad range of safety products including eye and face protection, first aid, hand protection, hazardous material handling, instrumentation and respiratory protection products. Additionally, we provide safety services including hydrogen sulfide (H2S) gas protection and safety, specialized and standby fire protection, safety supervision, training, monitoring, equipment rental and consulting. Our safety services include safety supervision, medic services, safety audits, instrument repair and calibration, training, monitoring, equipment rental and consulting. |
Our Covered Products
We conducted an analysis of our products to determine which of our products were likely to contain 3TG.We have identified tungsten in certain of our rotating equipment products within our segments that are necessary to the functionality or production of products that we manufactured or contracted to manufacture during the Reporting Period ("Covered Products"). DXP was unsure of further presence of 3TGs in their products however, through the RCOI, via supplier responses using the CMRT, the presence of all 3TGs were claimed by suppliers. Of the suppliers surveyed, many completed their CMRTs at the company, business unit or entity level. Due to this we are unable to definitively conclude which 3TGs are present in the parts or products that they supplied to us however we did continue with the RCOI and due diligence as applicable based on the information supplied.
Description of RCOI
DXP began our scoping process by extracting a list of our suppliers that provide us with Covered Products that may contain one or more of the 3TGs. Once the filtering was completed, we populated the list with contact information and provided the list to our third-party service provider. This supplier list was then uploaded to our third-party provider's software platform that allows us to store and manage supplier responses and documentation.
From there, we defined our scoping process even further by removing service providers, indirect materials suppliers, and suppliers who are inactive. This ensures that all suppliers surveyed provided items to DXP that were used in final products in the year 2016.
Our service provider then conducted the supplier survey portion of the RCOI. Utilizing the CFSI Conflict Minerals Reporting Template (the "CMRT"), version 4.10 or higher, the suppliers identified through the procedures above were surveyed on their sourcing of the 3TG that we identified in our products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company's supply chain. It includes questions regarding a direct supplier's conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TG used by those facilities.
During the supplier survey, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in the software platform. Non-responsive suppliers were contacted a minimum of three times and then were also managed by our service provider's Supply Chain Team in one-on-one communications. This included at least two follow ups in order to encourage their response via CMRTs. To ensure that our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party consultant have provided training to suppliers though webinars, videos, documentation, and one-on-one discussions.
The RCOI also included 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. All submitted forms are accepted and classified as valid or invalid so that data is still retained. All suppliers who submitted CMRTs that were flagged as "invalid" were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our service provider's system for future reporting and transparency. As of May 2, 2017, there were 37 invalid submissions that were not corrected by suppliers.
Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we proceeded to conduct due diligence on our supplier base.
Due Diligence
Design of due diligence
We have designed our due diligence procedures to conform, in all material respects, with the due diligence framework presented by the Organisation for Economic Co-operation and Development ("OECD") in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing and the related Supplements for gold and for tin, tantalum and tungsten.
DXP's conflict minerals due diligence process includes the five steps as defined by the Guidance: 1) establishing strong company management systems, 2) identifying and assessing risks in our supply chain, 3) designing and implementing a strategy to respond to identified risks, 4) utilizing independent third-party audits, and 5) publicly reporting on our supply chain due diligence. A summary of the due diligence measures undertaken by the Company is outlined below.
Due diligence performed
Establish Strong Company Management Systems
Internal team
We have organized a Conflict Minerals Committee comprised of individuals in management positions across multiple departments such as legal, finance, and procurement. The Conflict Minerals Committee leads our conflict minerals compliance effort and is responsible for implementing our conflict minerals compliance strategy and overseeing the program.
We have also taken on other management systems that include the use of a third-party vendor. Through our vendor's tool we are able to collect and store supplier data and CMRTs, communicate with suppliers, and monitor risks in our supply chain. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
Control systems
Controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all DXP employees and third parties doing business with DXP, and our Policy regarding Conflict Minerals. We established a conflict minerals policy related to our sourcing of 3TGs as described in full in the "Conflict Minerals Policy" posted on our website at www.dxpe.com within the "Investor Relations" section under "Corporate Governance."
Supplier engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 4.10 or higher and a third-party vendor's software reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information to support chain of custody of the 3TG identified in our products.
Grievance Mechanism
For concerns regarding potential violations, the "Conflict Minerals Policy" includes contact information for DXP's third party conduct helpline and means to make a report using dxpe.ethicspoint.com.
Maintain records
We have maintained company-wide document retention policies. These policies extend to the documentation accumulated in performing our due diligence procedures and requires that documentation will be retained for a period of not less than three years.
Identify and Assess Risks in the Supply Chain
It is important to note that DXP has relied on supplier responses to provide us with the information about the source of 3TGs contained in the parts and components they supply to us. Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to the recognized industry best practices.
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
| 1. | Geographic proximity to the DRC and covered countries; |
| 2. | Conflict-Free Smelter Program (CFSP) audit status; |
| 3. | Known or plausible evidence of unethical or conflict sourcing. |
Based on this criteria the following facilities have been identified as being of highest concern to the supply chain:
| · | Tony Goetz NV - CID002587 |
| · | Kaloti Precious Metals - CID002563 |
| · | Phoenix Metals - CID002507 |
| · | Universal Precious Metals Refining Zambia - CID002854 |
| · | Fidelity Printers and Refiners - CID002515 |
| · | Sudan Gold Refinery - CID002567 |
When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to DXP, and escalating up to removal of these high risk smelters from their supply chain.
As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier's specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.
In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
We also calculate supplier risk based on the chances that the supplier provides 3TG that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have "unknown" as some of the answers. It has been decided that penalizing or failing them for working through the process is likely not the best approach for the initial years of compliance, it does not meet the goals or spirit of the Rule, however evaluating and tracking the strength of the program does meet the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are:
A. Do you have a policy in place that includes DRC conflict-free sourcing?
E. Have you implemented due diligence measures for conflict-free sourcing? .
H. Do you verify due diligence information received from your suppliers?
I. Does your verification process include corrective action management?
When suppliers meet or exceed the above criteria, by answering yes to all four questions, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. We store all of this information and will continue to assess our suppliers' program strength and monitor any improvements or changes.
Design and Implement a Strategy to Respond to Identified Risks
DXP has established a Conflict Minerals Policy that outlines our expectations for suppliers. If these expectations are not met, the business relationship between that supplier will be evaluated. For example, if we find that we source 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries, DXP will assess the supplier relationship and encourage that supplier to establish an alternative source of the minerals that does not support such conflict. If an alternative source cannot be found or the supplier chooses not to respond to this risk, we will assess whether or not that supplier can be replaced.
Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with smelters and refiners of Conflict Minerals and therefore do not perform or direct audits of these entities. In connection with our due diligence, we utilized information made available by the CFSI concerning independent third-party audits of smelters and refiners.
Report on Supply Chain Due Diligence
This Report, which constitutes our annual report on our due diligence efforts, is available on our website at www.dxpe.com within the "Investor Relations" section under "Investors Home > SEC Filings > Documents" and is filed with the SEC.
Results of Due Diligence
Survey results
As of May 2, 2017, we received responses from 36%, we received valid CMRTs from 34% and invalid CMRTs from 3% of our surveyed suppliers for the 2016 year.
As described above, DXP surveys our supply chain and reviews all responses against set criteria that has been developed to determine whether further communication is needed. These criteria include: nonresponsiveness, incomplete responses and overall inconsistencies. Those that provided us with a CMRT were also asked to submit SOR information. The results of this are discussed the Smelters and Refiners section below.
Smelters and refiners
Of the suppliers surveyed, many completed their CMRTs at the company, business unit or entity level. Due to this we are unable to conclude that which 3TGs from which of the processing facilities they listed have actually been included in parts or products that they supplied to us. Many of the responses provided by a supplier via the CMRT included the names of facilities listed by the suppliers as smelters or refiners (SORs). The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our third-party provider follows up on these, urging suppliers to resubmit the form and include smelter information. That being said, there are still suppliers that are unable to provide SORs used for the materials supplied to us.
For all responses that indicated a smelter, our third party consultant compared the facilities listed to the list of smelters maintained by the Conflict-Free Sourcing Initiative ("CFSI"). If a supplier indicated that the facility was certified as "Conflict-Free," our vendor confirmed that the name was listed by CFSI as a certified smelter. No violations were identified. As of May 2, 2017, we have validated 317 smelters or refiners and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and CFSI.
As our suppliers are largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to provide additional smelter and refiner names and country of origin of the necessary 3TG in this report at this time. We will continue to work with our suppliers to obtain smelter information at the product level.
Future Steps to be Taken
We are committed to complying with the provisions of the Rule and Form SD and expect to continue our efforts to improve our conflict minerals program and related due diligence. As we further develop our program and procedures, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to the following:
| · | Engage with suppliers and direct them to training resources to attempt to increase our response rate and improve the content of responses to assist in our RCOI process and our efforts to determine the processing facilities for and country of origin of our 3TG with the greatest specificity possible; |
| · | Engage suppliers and encourage them to provide responses at the product level |
| · | Continue to invest in Conflict Minerals due diligence tools |
| · | Continue to respond to industry trends and legal requirements to further improve the traceability of 3TGs in our supply chain. |
Appendix A:
The table below lists, as of May 2, 2017, the smelters or refiners identified by our responsive Direct Suppliers that may have been used to process the conflict minerals necessary to the functionality or production of our Covered Products during 2016. As described above, this list may contain more facilities than are actually linked to the Company's Covered Products. Alternatively, this list may not include all applicable facilities as not all of our suppliers were able to provide SOR information at this time. Those that have been validated as compliant under the CFSP (Conflict Free Smelter Protocol) by the CFSI, have been noted as such in the final column on the right.
| Metal | Standard Smelter Name | Smelter Facility Location | CFSI Audit Status |
| Gold | Abington Reldan Metals, LLC | UNITED STATES | Active |
| Gold | Advanced Chemical Company | UNITED STATES | Compliant |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Compliant |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Compliant |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Compliant |
| Gold | Asahi Pretec Corp. | JAPAN | Compliant |
| Gold | Asahi Refining Canada Ltd. | CANADA | Compliant |
| Gold | Asahi Refining USA Inc. | UNITED STATES | Compliant |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Not Enrolled |
| Gold | AU Traders and Refiners | SOUTH AFRICA | Compliant |
| Gold | AURA-II | UNITED STATES | Not Enrolled |
| Gold | Aurubis AG | GERMANY | Compliant |
| Gold | Bangalore Refinery | INDIA | Active |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant |
| Gold | Boliden AB | SWEDEN | Compliant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant |
| Gold | Caridad | MEXICO | Not Enrolled |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Compliant |
| Gold | Cendres + Métaux S.A. | SWITZERLAND | Active |
| Gold | Chimet S.p.A. | ITALY | Compliant |
| Gold | Chugai Mining | JAPAN | Not Enrolled |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not Enrolled |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not Enrolled |
| Gold | DODUCO GmbH | GERMANY | Compliant |
| Gold | Dowa | JAPAN | Compliant |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Compliant |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant |
| Gold | Elemetal Refining, LLC | UNITED STATES | Compliant |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Compliant |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Not Enrolled |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Not Enrolled |
| Gold | Geib Refining Corporation | UNITED STATES | Active |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not Enrolled |
| Gold | Guangdong Jinding Gold Limited | CHINA | Not Enrolled |
| Gold | Gujarat Gold Centre | INDIA | Not Enrolled |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not Enrolled |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not Enrolled |
| Gold | Heimerle + Meule GmbH | GERMANY | Compliant |
| Gold | Heraeus Ltd. Hong Kong | CHINA | Compliant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not Enrolled |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Not Enrolled |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Compliant |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant |
| Gold | Istanbul Gold Refinery | TURKEY | Compliant |
| Gold | Japan Mint | JAPAN | Compliant |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Compliant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Compliant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Not Enrolled |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not Enrolled |
| Gold | Kazzinc | KAZAKHSTAN | Compliant |
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Compliant |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | Active |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Compliant |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Compliant |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Not Enrolled |
| Gold | Lingbao Gold Co., Ltd. | CHINA | Not Enrolled |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not Enrolled |
| Gold | L'Orfebre S.A. | ANDORRA | Not Enrolled |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not Enrolled |
| Gold | Materion | UNITED STATES | Compliant |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Compliant |
| Gold | Metalor Technologies S.A. | SWITZERLAND | Compliant |
| Gold | Metalor USA Refining Corporation | UNITED STATES | Compliant |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Compliant |
| Gold | Mitsubishi Materials Corporation | JAPAN | Compliant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant |
| Gold | Modeltech Sdn Bhd | MALAYSIA | Not Enrolled |
| Gold | Morris and Watson | NEW ZEALAND | Not Enrolled |
| Gold | Morris and Watson Gold Coast | AUSTRALIA | Not Enrolled |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Compliant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Active |
| Gold | Nihon Material Co., Ltd. | JAPAN | Compliant |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant |
| Gold | PAMP S.A. | SWITZERLAND | Compliant |
| Gold | Pease & Curren | UNITED STATES | Not Enrolled |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not Enrolled |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Compliant |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant |
| Gold | PX Précinox S.A. | SWITZERLAND | Compliant |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant |
| Gold | Remondis Argentia B.V. | NETHERLANDS | Not Enrolled |
| Gold | Republic Metals Corporation | UNITED STATES | Compliant |
| Gold | Royal Canadian Mint | CANADA | Compliant |
| Gold | SAAMP | FRANCE | Not Enrolled |
| Gold | Sabin Metal Corp. | UNITED STATES | Not Enrolled |
| Gold | SAFINA A.S. | CZECH REPUBLIC | Not Enrolled |
| Gold | Sai Refinery | INDIA | Not Enrolled |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Compliant |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Not Enrolled |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Compliant |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Compliant |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | Compliant |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not Enrolled |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant |
| Gold | Singway Technology Co., Ltd. | TAIWAN | Compliant |
| Gold | So Accurate Group, Inc. | UNITED STATES | Not Enrolled |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Compliant |
| Gold | Sudan Gold Refinery | SUDAN | Not Enrolled |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant |
| Gold | SungEel HiTech | KOREA, REPUBLIC OF | Active |
| Gold | T.C.A S.p.A | ITALY | Compliant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Compliant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not Enrolled |
| Gold | Tony Goetz NV | BELGIUM | Active |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Not Enrolled |
| Gold | Torecom | KOREA, REPUBLIC OF | Compliant |
| Gold | Umicore Brasil Ltda. | BRAZIL | Compliant |
| Gold | Umicore Precious Metals Thailand | THAILAND | Compliant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Compliant |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Compliant |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | Not Enrolled |
| Gold | Valcambi S.A. | SWITZERLAND | Compliant |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Compliant |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Compliant |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Compliant |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Compliant |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not Enrolled |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Compliant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Compliant |
| Tantalum | D Block Metals, LLC | UNITED STATES | Compliant |
| Tantalum | Duoluoshan | CHINA | Compliant |
| Tantalum | Exotech Inc. | UNITED STATES | Compliant |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Compliant |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Compliant |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Compliant |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Not Enrolled |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Compliant |
| Tantalum | H.C. Starck Inc. | UNITED STATES | Compliant |
| Tantalum | H.C. Starck Ltd. | JAPAN | Compliant |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Compliant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Compliant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Compliant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Compliant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
| Tantalum | KEMET Blue Metals | MEXICO | Compliant |
| Tantalum | KEMET Blue Powder | UNITED STATES | Compliant |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Compliant |
| Tantalum | LSM Brasil S.A. | BRAZIL | Compliant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Compliant |
| Tantalum | Mineração Taboca S.A. | BRAZIL | Compliant |
| Tantalum | Mitsui Mining & Smelting | JAPAN | Compliant |
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Compliant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant |
| Tantalum | Plansee SE Liezen | AUSTRIA | Not Enrolled |
| Tantalum | Plansee SE Reutte | AUSTRIA | Compliant |
| Tantalum | Power Resources Ltd. | MACEDONIA | Compliant |
| Tantalum | QuantumClean | UNITED STATES | Compliant |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Compliant |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant |
| Tantalum | Taki Chemicals | JAPAN | Compliant |
| Tantalum | Telex Metals | UNITED STATES | Compliant |
| Tantalum | Tranzact, Inc. | UNITED STATES | Compliant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Compliant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | Compliant |
| Tin | Alpha | UNITED STATES | Compliant |
| Tin | An Thai Minerals Co., Ltd. | VIET NAM | Not Enrolled |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Not Enrolled |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Compliant |
| Tin | China Tin Group Co., Ltd. | CHINA | Compliant |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not Enrolled |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Compliant |
| Tin | CV Ayi Jaya | INDONESIA | Compliant |
| Tin | CV Dua Sekawan | INDONESIA | Compliant |
| Tin | CV Gita Pesona | INDONESIA | Compliant |
| Tin | CV Serumpun Sebalai | INDONESIA | Compliant |
| Tin | CV Tiga Sekawan | INDONESIA | Compliant |
| Tin | CV United Smelting | INDONESIA | Compliant |
| Tin | CV Venus Inti Perkasa | INDONESIA | Compliant |
| Tin | Dowa | JAPAN | Compliant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Active |
| Tin | Elmet S.L.U. | SPAIN | Compliant |
| Tin | EM Vinto | BOLIVIA | Compliant |
| Tin | Estanho de Rondônia S.A. | BRAZIL | Not Enrolled |
| Tin | Fenix Metals | POLAND | Compliant |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Compliant |
| Tin | Gejiu Jinye Mineral Company | CHINA | Compliant |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Active |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Active |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Not Enrolled |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Compliant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Compliant |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Not Enrolled |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Compliant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Compliant |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Compliant |
| Tin | Metallic Resources, Inc. | UNITED STATES | Compliant |
| Tin | Metallo-Chimique N.V. | BELGIUM | Compliant |
| Tin | Mineração Taboca S.A. | BRAZIL | Compliant |
| Tin | Minsur | PERU | Compliant |
| Tin | Mitsubishi Materials Corporation | JAPAN | Compliant |
| Tin | Modeltech Sdn Bhd | MALAYSIA | Not Enrolled |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Active |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Not Enrolled |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Compliant |
| Tin | Phoenix Metal Ltd. | RWANDA | Not Enrolled |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Compliant |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Compliant |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant |
| Tin | PT Babel Inti Perkasa | INDONESIA | Compliant |
| Tin | PT Bangka Prima Tin | INDONESIA | Compliant |
| Tin | PT Bangka Tin Industry | INDONESIA | Compliant |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Compliant |
| Tin | PT Bukit Timah | INDONESIA | Compliant |
| Tin | PT Cipta Persada Mulia | INDONESIA | Compliant |
| Tin | PT DS Jaya Abadi | INDONESIA | Compliant |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Compliant |
| Tin | PT Inti Stania Prima | INDONESIA | Compliant |
| Tin | PT Justindo | INDONESIA | Not Enrolled |
| Tin | PT Karimun Mining | INDONESIA | Compliant |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Compliant |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Compliant |
| Tin | PT Mitra Stania Prima | INDONESIA | Compliant |
| Tin | PT O.M. Indonesia | INDONESIA | Compliant |
| Tin | PT Panca Mega Persada | INDONESIA | Compliant |
| Tin | PT Prima Timah Utama | INDONESIA | Compliant |
| Tin | PT Refined Bangka Tin | INDONESIA | Compliant |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Compliant |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Compliant |
| Tin | PT Sukses Inti Makmur | INDONESIA | Compliant |
| Tin | PT Sumber Jaya Indah | INDONESIA | Compliant |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Compliant |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Compliant |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Compliant |
| Tin | PT Tommy Utama | INDONESIA | Compliant |
| Tin | PT Wahana Perkit Jaya | INDONESIA | Compliant |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant |
| Tin | Rui Da Hung | TAIWAN | Compliant |
| Tin | Soft Metais Ltda. | BRAZIL | Compliant |
| Tin | Thaisarco | THAILAND | Compliant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Not Enrolled |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Compliant |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Compliant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Active |
| Tin | Yunnan Tin Company Limited | CHINA | Compliant |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Compliant |
| Tungsten | ACL Metais Eireli | BRAZIL | Not Enrolled |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Compliant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Not Enrolled |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Not Enrolled |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Compliant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | H.C. Starck GmbH | GERMANY | Compliant |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Compliant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Not Enrolled |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not Enrolled |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Kennametal Fallon | UNITED STATES | Compliant |
| Tungsten | Kennametal Huntsville | UNITED STATES | Compliant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Compliant |
| Tungsten | Niagara Refining LLC | UNITED STATES | Compliant |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Compliant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Compliant |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Compliant |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Compliant |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Compliant |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Compliant |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Compliant |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Compliant |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant |
Country of Origin List:
This list below sets out possible countries of origin of 3TGs used in the manufacture of products containing conflict minerals that are necessary to the functionality or production of our products. The list is based on publicly available information, our reasonable country of origin investigation, and other due diligence. For the reasons described in the Report, however, these possible countries of origin cannot necessarily be linked to our products.
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Columbia, Cote D'Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
