Exhibit 1.01
STEELCASE INC.
Conflict Minerals Report
For the reporting period from January 1, 2017 to December 31, 2017
Introduction
This Conflict Minerals Report (“Report”) of Steelcase Inc. has been prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period January 1, 2017 to December 31, 2017. As used in this Report and unless otherwise expressly stated or the context otherwise requires, all references to “Steelcase,” “we,” “our,” “Company” and similar references are references to Steelcase Inc. and its consolidated subsidiaries.
Rule 13p-1 was adopted by the Securities and Exchange Commission (“SEC”) to implement certain disclosure requirements related to minerals specified in the rule. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“Conflict Minerals”). Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which Conflict Minerals are necessary to the production or functionality of those products (such minerals are referred to herein as “Necessary Conflict Minerals”).
Company Overview
We offer a comprehensive portfolio of architecture, furniture, furnishings and technology products and services which are designed to unlock human promise and support social, economic and environmental sustainability globally.
Conflict Minerals Policy and Supplier Code of Conduct
Our Conflict Minerals Policy states our intent to refrain from purchasing products, components or materials containing any Necessary Conflict Minerals from the Covered Countries that directly or indirectly finance or benefit armed groups and are not otherwise from recycled or scrap sources. The policy also expresses our expectation that our suppliers follow this same practice, establish appropriate due diligence programs and provide us with information, upon our request, regarding the source and chain of custody of any Necessary Conflict Minerals in the products, components or materials they sell to us. In addition, our Supplier Code of Conduct includes a Fair Operating Practices section regarding “Responsible Sourcing of Minerals” which is consistent with our Conflict Minerals Policy. Our policy and our Supplier Code of Conduct are publicly available on our website at www.steelcase.com/discover/steelcase/sustainability/#resources.
Reasonable Country of Origin Inquiry
Pursuant to Rule 13p-1, we conducted a Reasonable Country of Origin Inquiry (“RCOI”). Our RCOI began with an evaluation of our global suppliers who provided materials, components or products that became part of products we manufactured or contracted to be manufactured in 2017 which contained or were likely to contain Necessary Conflict Minerals. This evaluation consisted of examining internal records such as bills of materials or other product specifications and performing a qualitative review of purchasing records and/or information provided by the supplier. Based on our evaluation, we surveyed the suppliers of those materials, components or products which we concluded contained or were likely to contain Necessary Conflict Minerals. The suppliers were asked to report on the presence of any Necessary Conflict Minerals in the goods sold to us. In cases where we knew or confirmed that Necessary Conflict
Minerals were present, we asked the applicable supplier to submit information to us about the country of origin of the Necessary Conflict Minerals.
Due Diligence
Design of Due Diligence
We designed our due diligence measures to conform to the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on tin, tantalum, tungsten, and gold (collectively, the “OECD Guidance”).
Due Diligence Measures Performed
Pursuant to Rule 13p-1, we undertook due diligence measures on the source and chain of custody of the Necessary Conflict Minerals in our products which we had reason to believe may have originated from the Democratic Republic of the Congo or an adjoining country (collectively, the "Covered Countries") and which may not have come from recycled or scrap sources. Following is a summary of the due diligence actions we performed with regard to the reporting period:
1. Establish strong company management systems
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| • | As referenced previously, we have a Conflict Minerals Policy which is shared with our supply chain and publicly available on our website. |
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| • | We have an established project team from our Global Compliance & Sustainability department which leads the RCOI, due diligence and reporting processes. Our Conflict Minerals Governance Committee provides oversight for the project team and is comprised of senior management from our legal, compliance and internal audit functions. |
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| • | We are a “downstream company” in our supply chain, meaning we are generally several tiers removed from the smelters and refiners which process the Necessary Conflict Minerals present in some of our products. Accordingly, we rely on communication with and through our immediate suppliers to provide us with information relating to the presence and sourcing of the Necessary Conflict Minerals present in our products. |
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| • | We intend to maintain our records relating to Conflict Minerals reporting for a minimum of five years after each applicable reporting period, in accordance with the OECD Guidance and our own Records Retention Policy. |
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| • | Our Supplier Code of Conduct includes language that reinforces our Conflict Minerals Policy, and we have included Conflict Minerals reporting requirements in our purchasing contract templates. |
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| • | We have implemented Conflict Minerals checkpoints into both our supplier qualification and product development processes to begin engaging new suppliers and suppliers of new materials early in the process. |
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| • | We have continued to educate our suppliers and employees about Conflict Minerals and the related reporting requirements in each of the regions in which we operate: the Americas, Europe, Middle East and Africa, and Asia Pacific. |
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| • | We have continued to provide an international integrity helpline to both employees and non-employees for reporting ethics and compliance issues, including those related to Conflict Minerals. Information about contacting the helpline can be found at http://integrity.steelcase.com. |
2. Identify and assess risks in the supply chain
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| • | We surveyed suppliers we either knew or had reason to believe may have provided materials, components or products which may contain Necessary Conflict Minerals, using the due diligence tool created by the Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“GESI”)’s Responsible Minerals Initiative (“RMI”)’s Conflict Minerals Reporting Template (“CMRT”), which is a survey designed to identify the smelters and refiners that process, and the country of origin of, Conflict Minerals contained in the products supplied by the applicable supplier. |
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| • | We selected a subset of suppliers among all surveyed suppliers to be targeted for prioritized follow up. We referred to this subset as “prioritized suppliers.” Prioritized suppliers were selected for additional follow up to capture the greatest risk in our supply chain. The criteria used to select prioritized suppliers included: material composition, previously submitted smelter and refiner information, geographic region, spend, type of supplier and quantity of parts purchased. |
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| • | We followed up with prioritized suppliers that did not respond to our survey request or that we identified as providing incomplete or potentially inaccurate information to seek additional clarification or remediation and to bring them into conformity with our Conflict Minerals Policy and contractual agreements. |
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| • | We cross-referenced smelters and refiners identified in the CMRTs submitted by our suppliers against the list of facilities that have received a “conformant” designation from the Responsible Minerals Assurance Process ("RMAP") and its cross-recognized programs (e.g. the Responsible Jewellery Council and the London Bullion Market Association, otherwise known as “RJC” and “LBMA” respectfully), whose designations provide country of origin and additional due diligence information on the Conflict Minerals sourced by such facilities. |
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| • | We continued to encourage the participation of smelters and refiners in the RMAP, through our continued membership and active participation in the RMI and related working groups, and by conducting outreach to those smelters and refiners identified by our supply chain. |
3. Design and implement a strategy to respond to identified risks
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| • | The status and findings of our RCOI and due diligence efforts were reported to our Conflict Minerals Governance Committee during monthly updates between the months of September 2017 and May 2018. |
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| • | We intend to follow a risk mitigation plan that is consistent with our Conflict Minerals Policy. If a smelter or refiner in our supply chain were known to be sourcing from a mine within a Covered Country which directly or indirectly finances or benefits armed groups, we would consider all available options, including, but not limited to, making changes to our sourcing of those items. |
4. Independent third-party audit of smelter or refiner’s due diligence practices
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| • | As a downstream company and an active member of the RMI, we support the independent third-party audits of smelters and refiners performed by the RMAP and other cross-recognized programs (e.g. RJC and LBMA) to audit the conformant status of smelters and refiners. |
5. Report annually on supply chain due diligence
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| • | We plan to report annually to the SEC by filing a Form SD and Conflict Minerals Report as required by applicable law. |
Results of Due Diligence Measures Performed
Inherent Limitations of Due Diligence Measures
As a downstream company in a complex supply chain, our due diligence measures can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Necessary Conflict Minerals contained in our products. Our due diligence processes rely on obtaining data from our tier one suppliers and those suppliers seeking similar information from their supply chains to identify the original sources of the Necessary Conflict Minerals. We also rely on information collected and provided by independent third party audit programs. Such sources of information may yield inaccurate or incomplete information.
Product Description
For the reporting period, we identified the following types of products which we either manufactured or contracted with others to manufacture that contained Necessary Conflict Minerals which may have originated in the Covered Countries but for which we could not confirm the countries of origin of all the Necessary Conflict Minerals contained in such products:
Some of our desking products, wall systems, doors, tiles, panels, lighting, and other office furniture products which contain one or more of the following: electrical components, lighting components and glass panels.
Determination
Based on the information provided by our suppliers, the facilities that may have been used to process the Necessary Conflict Minerals used in our products may include the smelters and refiners listed in Annex I.
Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of all the Necessary Conflict Minerals in the products described above in the “Product Description” section of this report or whether the Necessary Conflict Minerals were from recycled or scrap sources. However, based on the information provided by our suppliers and available from the RMI, the countries of origin of the Necessary Conflict Minerals contained in the products described above may include, but may not be limited to, the countries listed in Annex II, in addition to recycled or scrap sources.
Smelter and Refiner Summary
In response to our survey, our suppliers identified 309 smelter and refiner facilities which may have processed the Necessary Conflict Minerals contained in the materials provided to us. Of those facilities, as of May 8, 2018:
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| • | 250 have received a “conformant” designation from the RMAP; |
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| • | 8 have not yet received a “conformant” designation but are considered “active” in the RMAP; and, |
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| • | the remaining facilities are not currently participating in the RMAP |
Under the RMAP’s standards, “conformant” means a facility has been audited and found to be conformant with the relevant RMAP protocol, and “active” means a facility that is engaged in the program but has not yet been found to be "conformant."
Each of the facilities which we believe may source Conflict Minerals from the Covered Countries has received a “conformant” designation from the RMAP.
To our knowledge, none of the Necessary Conflict Minerals contained in the products we manufactured or contracted to be manufactured during the reporting period directly or indirectly financed or benefitted armed groups in the Covered Countries.
Risk Mitigation
We remain committed to familiarizing our supply chain with our compliance process and enhancing our internal systems of controls, and we expect to continue improving upon the steps outlined below. These are the steps we took for our 2017 reporting cycle to mitigate the risk that the Necessary Conflict Minerals contained in the products we manufacture or contract to be manufactured may have benefitted armed groups:
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| • | further educated our supply chain and employees about Conflict Minerals reporting requirements; |
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| • | continued pursuing Conflict Minerals identification during our supplier qualification and product development processes; |
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| • | continued including our Conflict Minerals clause into purchasing contracts, either upon establishment or during the renewal process; |
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| • | performed additional material research and further identified where Necessary Conflict Minerals are present in our existing products and likely to be present in future products; |
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| • | surveyed suppliers and collected responses for the respective reporting period; |
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| • | prioritized supplier follow up by using criteria which captured the greatest risk and leverage in our supply chain; |
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| • | continued to encourage our suppliers to obtain current, accurate and complete smelter and refiner information that is specific to the products they sell to us; |
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| • | compared and validated supplier-identified smelters and refiners to information collected via independent smelter and refiner audit programs such as the RMAP; and, |
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| • | maintained our membership and active participation in the RMI and related working groups. |
Conclusion Statement
We have provided the information in this Report as of the date of filing with the SEC.
Annex I
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| Metal | Facility Name | Facility Location |
| Gold | Abington Reldan Metals, LLC | United States of America |
| Gold | Advanced Chemical Company | United States of America |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Gold | Asahi Pretec Corp. | Japan |
| Gold | Asahi Refining Canada Ltd. | Canada |
| Gold | Asahi Refining USA Inc. | United States of America |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | AU Traders and Refiners | South Africa |
| Gold | Aurubis AG | Germany |
| Gold | Bangalore Refinery | India |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | Boliden AB | Sweden |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | Caridad | Mexico |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | Chimet S.p.A. | Italy |
| Gold | Chugai Mining | Japan |
| Gold | Daejin Indus Co., Ltd. | Korea, Republic of |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | DODUCO Contacts and Refining GmbH | Germany |
| Gold | Dowa | Japan |
| Gold | DSC (Do Sung Corporation) | Korea, Republic of |
| Gold | Eco-System Recycling Co., Ltd. | Japan |
| Gold | Elemetal Refining, LLC | United States of America |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Geib Refining Corporation | United States of America |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | HeeSung Metal Ltd. | Korea, Republic of |
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| Metal | Facility Name | Facility Location |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic of |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Italpreziosi | Italy |
| Gold | Japan Mint | Japan |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Kaloti Precious Metals | United Arab Emirates |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Kazzinc | Kazakhstan |
| Gold | Kennecott Utah Copper LLC | United States of America |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic of |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | L'Orfebre S.A. | Andorra |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Marsam Metals | Brazil |
| Gold | Materion | United States of America |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold | Metalor Technologies (Suzhou) Ltd. | China |
| Gold | Metalor Technologies S.A. | Switzerland |
| Gold | Metalor USA Refining Corporation | United States of America |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | MMTC-PAMP India Pvt., Ltd. | India |
| Gold | Modeltech Sdn Bhd | Malaysia |
| Gold | Morris and Watson | New Zealand |
| Gold | Morris and Watson Gold Coast | Australia |
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| Metal | Facility Name | Facility Location |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
| Gold | OJSC Novosibirsk Refinery | Russian Federation |
| Gold | PAMP S.A. | Switzerland |
| Gold | Pease & Curren | United States of America |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | Planta Recuperadora de Metales SpA | Chile |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | PX Precinox S.A. | Switzerland |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | Refinery of Seemine Gold Co., Ltd. | China |
| Gold | Remondis Argentia B.V. | Netherlands |
| Gold | Republic Metals Corporation | United States of America |
| Gold | Royal Canadian Mint | Canada |
| Gold | SAAMP | France |
| Gold | Sabin Metal Corp. | United States of America |
| Gold | Safimet S.p.A | Italy |
| Gold | SAFINA A.S. | Czech Republic |
| Gold | Sai Refinery | India |
| Gold | Samduck Precious Metals | Korea, Republic of |
| Gold | Samwon Metals Corp. | Korea, Republic of |
| Gold | SAXONIA Edelmetalle GmbH | Germany |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province of China |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province of China |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | Sudan Gold Refinery | Sudan |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of |
| Gold | T.C.A S.p.A | Italy |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
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| Metal | Facility Name | Facility Location |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | Tony Goetz NV | Belgium |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan |
| Gold | Torecom | Korea, Republic of |
| Gold | Umicore Brasil Ltda. | Brazil |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
| Gold | United Precious Metal Refining, Inc. | United States of America |
| Gold | Universal Precious Metals Refining Zambia | Zambia |
| Gold | Valcambi S.A. | Switzerland |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | Yamakin Co., Ltd. | Japan |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Tantalum | Asaka Riken Co., Ltd. | Japan |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
| Tantalum | D Block Metals, LLC | United States of America |
| Tantalum | Exotech Inc. | United States of America |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | Global Advanced Metals Boyertown | United States of America |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
| Tantalum | H.C. Starck Co., Ltd. | Thailand |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
| Tantalum | H.C. Starck Inc. | United States of America |
| Tantalum | H.C. Starck Ltd. | Japan |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | KEMET Blue Metals | Mexico |
| Tantalum | KEMET Blue Powder | United States of America |
| Tantalum | LSM Brasil S.A. | Brazil |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | Mineracao Taboca S.A. | Brazil |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
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| Metal | Facility Name | Facility Location |
| Tantalum | NPM Silmet AS | Estonia |
| Tantalum | Power Resources Ltd. | Macedonia, The Former Yugoslav Republic Of |
| Tantalum | QuantumClean | United States of America |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | Telex Metals | United States of America |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tin | Alpha | United States of America |
| Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
| Tin | China Tin Group Co., Ltd. | China |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tin | CV Ayi Jaya | Indonesia |
| Tin | CV Dua Sekawan | Indonesia |
| Tin | CV Gita Pesona | Indonesia |
| Tin | CV United Smelting | Indonesia |
| Tin | CV Venus Inti Perkasa | Indonesia |
| Tin | Dowa | Japan |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam |
| Tin | EM Vinto | Bolivia (Plurinational State of) |
| Tin | Estanho de Rondonia S.A. | Brazil |
| Tin | Fenix Metals | Poland |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | China |
| Tin | Gejiu Jinye Mineral Company | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
| Tin | Huichang Jinshunda Tin Co., Ltd. | China |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China |
| Tin | Jiangxi New Nanshan Technology Ltd. | China |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | Metallic Resources, Inc. | United States of America |
| Tin | Metallo Belgium N.V. | Belgium |
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| Metal | Facility Name | Facility Location |
| Tin | Metallo Spain S.L.U. | Spain |
| Tin | Mineracao Taboca S.A. | Brazil |
| Tin | Minsur | Peru |
| Tin | Mitsubishi Materials Corporation | Japan |
| Tin | Modeltech Sdn Bhd | Malaysia |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | Operaciones Metalurgical S.A. | Bolivia (Plurinational State of) |
| Tin | PT Aries Kencana Sejahtera | Indonesia |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin | PT Babel Inti Perkasa | Indonesia |
| Tin | PT Bangka Prima Tin | Indonesia |
| Tin | PT Bangka Serumpun | Indonesia |
| Tin | PT Bangka Tin Industry | Indonesia |
| Tin | PT Belitung Industri Sejahtera | Indonesia |
| Tin | PT Bukit Timah | Indonesia |
| Tin | PT DS Jaya Abadi | Indonesia |
| Tin | PT Eunindo Usaha Mandiri | Indonesia |
| Tin | PT Inti Stania Prima | Indonesia |
| Tin | PT Karimun Mining | Indonesia |
| Tin | PT Kijang Jaya Mandiri | Indonesia |
| Tin | PT Lautan Harmonis Sejahtera | Indonesia |
| Tin | PT Menara Cipta Mulia | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Premium Tin Indonesia | Indonesia |
| Tin | PT Prima Timah Utama | Indonesia |
| Tin | PT Rajehan Ariq | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
| Tin | PT Sariwiguna Binasentosa | Indonesia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
| Tin | PT Sukses Inti Makmur | Indonesia |
| Tin | PT Sumber Jaya Indah | Indonesia |
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia |
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia |
| Tin | PT Tinindo Inter Nusa | Indonesia |
| Tin | PT Tommy Utama | Indonesia |
| Tin | Resind Industria e Comercio Ltda. | Brazil |
| Tin | Rui Da Hung | Taiwan, Province of China |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | Super Ligas | Brazil |
| Tin | Thaisarco | Thailand |
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| Metal | Facility Name | Facility Location |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Tin | Yunnan Tin Company Limited | China |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders Corp. | United States of America |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tungsten | H.C. Starck Tungsten GmbH | Germany |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | China |
| Tungsten | Hydrometallurg, JSC | Russian Federation |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | Kennametal Fallon | United States of America |
| Tungsten | Kennametal Huntsville | United States of America |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Moliren Ltd. | Russian Federation |
| Tungsten | Niagara Refining LLC | United States of America |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam |
|
| | |
| Metal | Facility Name | Facility Location |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria |
| Tungsten | Woltech Korea Co., Ltd. | Korea, Republic of |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
Annex II
|
| |
| Argentina | Laos |
| Australia | Madagascar |
| Austria | Malaysia |
| Benin | Mali |
| Bolivia (Plurinational State of) | Mexico |
| Brazil | Mongolia |
| Burkina Faso | Mozambique |
| Burundi | Myanmar |
| Cambodia | Namibia |
| Canada | Nicaragua |
| Chile | Nigeria |
| China | Panama |
| Colombia | Peru |
| Congo, Democratic Republic of the | Portugal |
| Ecuador | Russian Federation |
| Eritrea | Rwanda |
| Ethiopia | Senegal |
| France | Sierra Leone |
| Germany | South Africa |
| Ghana | Spain |
| Guatemala | Thailand |
| Guinea | Togo |
| Guyana | Uganda |
| Honduras | United Kingdom of Great Britain and Northern Ireland |
| India | United States of America |
| Indonesia | Uzbekistan |
| Japan | Vietnam |
| Kazakhstan | Zimbabwe |
