Exhibit 1.01
Radware Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2016
This Conflict Minerals Report for the year ended December 31, 2016 (this "Report") has been prepared by Radware Ltd. (“Radware,” the “Company” or “we”) pursuant to Rule 13p-1(the "Rule" or "Rule 13p-1") promulgated under the Securities Exchange Act of 1934, as amended, and Form SD thereunder.
The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, tungsten and gold (“conflict minerals” or “3TG”).
In general, if an SEC registrant, like Radware, has reason to believe that any of the conflict minerals in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”), or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody, and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
This Report relates to the process undertaken for Radware products that were manufactured or contracted to be manufactured, during calendar year 2016 and that may contain 3TG minerals.
A copy of this Report as well as the Form SD that we filed with the SEC is available on our website at https://www.radware.com/corporategovernance/conflictminerals/.
Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in the Rule and Form SD as well as SEC Release No. 34-67716 issued by the SEC on August 22, 2012.
Except as set forth otherwise in this Report, Radware has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with Radware’s Conflict Minerals Policy, may affect Radware’s future determinations under Rule 13p-1.
1. | Overview |
Company Overview
We are a leading provider of cyber security and application delivery solutions designed to secure the user digital experience from applications in virtual, cloud and software defined data centers. We offer a set of products and services that address data center application service level and are designed to solve key challenges with applications’ availability, applications’ response time and data center availability. Our solutions provide application layer service on top of the enterprise or carrier network “front end” applications and, in general, address three primary target markets and challenges: the Distributed Denial of Service (DDoS) protection market; the Application Delivery Controllers (ADCs) market; and the Web application firewall (WAF) market. We sell our products primarily to independent distributors, including value added resellers (VARs), original equipment manufacturers (OEMs) and system integrators, with most of our direct sales being to strategic customers.
For more information about Radware, please visit www.radware.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein.
Supply Chain
We conducted an analysis of our products and found that small quantities of 3TG could potentially be found in our products.
The products that we manufacture are highly complex, typically containing thousands of parts from many direct suppliers. In general, we primarily rely on third-party assembly and manufacturing vendors to provide our finished products and, in this respect, these vendors typically receive components and subassemblies included in our products from other suppliers and subcontractors.
We have relationships with a vast network of suppliers throughout the world and there are generally multiple tiers between the 3TG mines and our direct suppliers. Therefore, we must rely on our direct suppliers to cooperate with us and work with their own upstream suppliers or sub-contractors in order that they may provide us with accurate information about the origin of 3TG in the components we purchase from them. In particular, many of our supplier contracts have fixed durations and we cannot unilaterally impose new contract terms or flow-down requirements that would otherwise compel these suppliers to support our due diligence efforts with respect to 3TG content.
Reasonable Country of Origin Inquiry (RCOI)
We have determined that requesting our suppliers to complete the CMRT (as defined below) as well as following the steps described under Section 2 below (Due Diligence Process), represent our reasonable efforts to determine the mines or locations of origin of 3TG in our supply chain.
We developed a risk-based approach (pareto analysis) that focuses on the suppliers that represented as of December 31, 2016, in aggregate, at least 90% of our spending on the manufacturing costs of our finished products that were shipped in 2016. We identified in total 184 relevant suppliers (the “Relevant Suppliers”) and engaged a third party data collection and software vendor (the "Third Party Vendor") to monitor the due diligence process and the gathering of information from all such Relevant Suppliers.
We sent letters to our Relevant Suppliers to explain the Rule and to refer them to online training materials and instructions. We also solicited information from our Relevant Suppliers, using the most up to date Conflict Minerals Reporting Template (“CMRT”), an industry-standard template for conflict mineral reporting developed by the Conflict-Free Sourcing Initiative (the "CFSI").
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We reviewed the responses that we received and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information. Out of the 184 Relevant Suppliers, 145 Relevant Suppliers (79%) completed and returned the CMRT’s to us.
Based on these efforts, we already know that some of our products may contain conflict minerals that originated in Covered Countries and are not from recycled or scrap sources. Therefore, according to the Rule, we have engaged in the Due Diligence Process described in detail in Section 2 below.
| 2. | Due Diligence Process |
| 2.1 | Design of Due Diligence |
Our due diligence measures have been designed to conform, in all material respects, with the internationally recognized due diligence framework prescribed by the Organisation for Economic Co-operation and Development ("OECD") known as "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas" and related Supplements for Tin, Tantalum and Tungsten and for Gold (the “OECD Guidance”). We designed our due diligence measures according to the recommendations of the OECD Guidance for downstream companies that have no direct relationships to smelters or refiners.
| 2.2 | Due Diligence Performed |
| 2.2.1 | Establish Strong Management Systems |
Corporate Policy
We have adopted a conflict minerals policy (our "Policy" or our "Conflict Minerals Policy") that is aimed at achieving responsible sourcing. The Policy is publicly available on our website at https://www.radware.com/corporategovernance/conflictminerals/.
Internal Team
We have established a management system to support supply chain due diligence related to 3TG. Our management system includes a steering committee headed by the Company’s VP Finance (the “CM Steering Committee”), and a team of subject matter experts from functions such as supplier management, engineering, finance and legal.
Control systems
We requested that all Relevant Suppliers provide information to us regarding 3TG and smelters using the CMRT.
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We adopted, and communicated to our suppliers and to the public through our website and direct letters, our Policy for the supply chain of minerals originating from conflict affected and high-risk areas.
During 2016, we reviewed our internal and external communication plan from 2015 and updated it as we deemed required.
Controls include a company-wide code of conduct that outlines expected behaviors from all our employees as well as engaging the Third Party Vendor to assist us in collecting and analyzing relevant data and in maintaining a smelter/refiner database.
Grievance Mechanism
Our Conflict Minerals Policy is available to the public on our website and provides the contact details for reporting concerns or questions regarding the Policy or violations thereof, and suppliers and other external parties are encouraged to contact their regular sourcing channel if they wish to seek guidance on the application of this approach, or if they wish to report a suspected abuse.
Maintain records
We maintain data records relating to our due diligence efforts in the Third Party Vendor’s Conflict Minerals Reporting Dashboard Software (“CMR Dashboard”) for the five (5) year duration recommended by the OECD Guidance. The CMR Dashboard stores current and former CMRTs from suppliers to maintain traceability.
Supplier Engagement
We maintain an electronic portal which directs suppliers to resources related to Conflict Minerals, including FAQs from the SEC.
We established a Conflict Minerals webpage to host our Conflict Minerals Policy and our conflict minerals reports along with their related Form SDs.
We have also engaged the Third Party Vendor to provide training and outreach to suppliers, as well as to conduct, collect, validate and archive supplier responses.
As we enter into new supply contracts or renew existing supply contracts, we are adding (where feasible) a conflict minerals contract clause that requires suppliers to provide us with information about the source of 3TG and smelters.
| 2.2.2 | Identify and assess risk in the supply chain |
We approached our 184 Relevant Suppliers and received responses from 145 Relevant Suppliers representing 79% of the Relevant Suppliers as described in the RCOI. We reviewed and analyzed the respective CMRTs of our Relevant Suppliers and compared the information provided therein with the Compliant Smelter List of the Conflict Free Smelter Program, a list issued by the CFSI which aims to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. We rely on these Relevant Suppliers, whose components contain 3TG, to provide us with information about the source of conflict minerals contained in the components supplied to us. Our Relevant Suppliers are similarly reliant upon information provided by their suppliers.
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| 2.2.3 | Design and Implement a Strategy to Respond to Risks |
We implemented the following strategy to address the results of our risk assessment described in Section 2.2.2 above:
| · | The CM Steering Committee held regular meetings to review progress and assess the risks identified. |
| · | We reviewed the responses that we received and followed up on what we perceived to be inconsistent, incomplete, or inaccurate responses, as well as sent reminders to Relevant Suppliers who did not respond to our requests for information. |
| · | We sent follow up letters to non-responding Relevant Suppliers asking them to complete their due diligence process in order to validate that all smelters in Covered Countries are compliant with the CFSI or other independent conflict free smelter validation program. |
| · | Relevant senior management, including our Vice President and General Counsel is briefed about our due diligence efforts, risk analysis results and mitigation efforts on a regular basis. |
| · | We approached Relevant Suppliers that we identified as possibly sourcing from smelters located in Covered Countries that were not recognized as conflict free by the CFSI and asked for a corrective action plan. |
| 2.2.4 | Carry out Independent Third Party Audit of Smelters/Refiners Due Diligence Practices |
We rely on industry-wide initiatives, such as the CFSI, to conduct risk assessment at the upstream level.
Since we do not have direct sourcing relationships with conflict mineral smelters or refiners, we did not perform direct audits of these entities within our supply chain.
| 2.2.5 | Report on supply chain due diligence |
Our supply chain conflict mineral due diligence efforts are described in this report. This Conflict Minerals Report is available on our website https://www.radware.com/corporategovernance/conflictminerals/ and is filed with the SEC.
| 3. | Results of Assessment |
Based on information provided by our Relevant Suppliers as well as by CFSI, the results of our due diligence investigation as of the date of this Report are as follows:
| · | We were successful in approaching almost all Relevant Suppliers. |
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| · | Out of the 184 Relevant Suppliers, 145 Relevant Suppliers (79%) completed and returned the CMRTs to us. Based on the CMRTs we received from these Relevant Suppliers (the "Responsive Relevant Suppliers"): |
| · | Approximately 84% of the responses received provided data at a company or divisional level. All of the remaining Responsive Relevant Suppliers declared that information was provided at a product level, as shown in the following table: |
Category | Percentage of Responsive Relevant Suppliers |
Company level | 72% (104 from 145 Relevant Suppliers) |
| User defined | 12% (18 from 145 Relevant Suppliers) |
| Product list | 16% (23 from 145 Relevant Suppliers ) |
| · | We identified 317 smelters or refiners that may be involved in our supply chain, out of which 81% are either recognized as conflict free by the CFSI (each a “Compliant Smelter”) or are committed to undergo a CFSP audit. Analysis of information about these 317 smelters is provided in the following diagrams: |
 |  |
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Based on the information provided by the Responsive Relevant Suppliers as well as by CFSI, as of the date of this Report, Radware believes that the facilities that may have been used to process the conflict minerals in Radware’s products may include the smelters and refiners listed in Annex I below.
Based on the information provided by the Responsive Relevant Suppliers as well as by CFSI, as of the date of this Report, Radware believes that the mine countries of origin of the conflict minerals contained in its products may include the countries listed in Annex II below.
The information gathered from our Responsive Relevant Suppliers is not on a continuous, real-time basis.
In addition, Radware can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals, since the information comes primarily from direct and secondary suppliers as well as from independent third party audit programs.
Lastly, given that most of our Responsive Relevant Suppliers were unable to provide information at product level, Radware cannot clearly identify the source of origin of the 3TG included in its products.
| 4. | Steps to be taken to mitigate risk |
We currently intend to continue working with our global supply chain to achieve responsible sourcing and compliance with applicable regulations to the extent required by same:
| · | Continue implementing follow up processes with regard to non-responsive or non-compliant suppliers. |
| · | As described in our Conflict Minerals Policy, to the extent we will have reason to believe that any of our suppliers who are supplying us with 3TG, receive such minerals from sources that may support conflict in the DRC or any adjoining country, we would encourage such suppliers to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD Guidance. |
| · | Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts. |
| · | Continue to direct our suppliers through our website and direct communications to information and training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
| · | Request suppliers to procure materials through validated smelters and request our suppliers to take mitigating actions in case they do not. |
| · | Continue to validate supplier responses using information collected via independent conflict free smelter validation programs, such as the CFSI. |
| · | Continue to engage in regular ongoing risk assessment through our suppliers’ annual data submissions. |
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Annex I – List of Smelters
| Metal | Smelter Name | Smelter Country |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | 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 | Aurubis AG | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Dowa | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Ltd. Hong Kong | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | LS-NIKKO Copper Inc. | KOREA (REPUBLIC OF) |
| Gold | Materion | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | PAMP S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN |
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| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Cendres + Métaux S.A. | SWITZERLAND |
| Gold | Daejin Indus Co., Ltd. | KOREA (REPUBLIC OF) |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | DODUCO GmbH | GERMANY |
| Gold | DSC (Do Sung Corporation) | KOREA (REPUBLIC OF) |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | Istanbul Gold Refinery | TURKEY |
| 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 | Kazzinc | KAZAKHSTAN |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
| Gold | Korea Zinc Co., Ltd. | KOREA (REPUBLIC OF) |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
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| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Précinox S.A. | SWITZERLAND |
| Gold | Samduck Precious Metals | KOREA (REPUBLIC OF) |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS |
| 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 | T.C.A S.p.A | ITALY |
| Gold | Torecom | KOREA (REPUBLIC OF) |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | AURA-II | UNITED STATES OF AMERICA |
| Gold | Bangalore Refinery | INDIA |
| Gold | Caridad | MEXICO |
| Gold | Chugai Mining | JAPAN |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Gujarat Gold Centre | INDIA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
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| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | HwaSeong CJ Co., Ltd. | KOREA (REPUBLIC OF) |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Gold Co., Ltd. | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | Modeltech Sdn Bhd | MALAYSIA |
| Gold | Morris and Watson | NEW ZEALAND |
| Gold | Morris and Watson Gold Coast | AUSTRALIA |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | Remondis Argentia B.V. | NETHERLANDS |
| Gold | SAAMP | FRANCE |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | SAFINA A.S. | CZECH REPUBLIC |
| Gold | Sai Refinery | INDIA |
| Gold | Samwon Metals Corp. | KOREA (REPUBLIC OF) |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | So Accurate Group, Inc. | UNITED STATES OF AMERICA |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | Sudan Gold Refinery | SUDAN |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Tony Goetz NV | BELGIUM |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
| 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 | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
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| Tantalum | Molycorp Silmet A.S. | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | Plansee SE Liezen | AUSTRIA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | E.S.R. Electronics | UNITED STATES OF AMERICA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES OF AMERICA |
| 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 Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineração Taboca S.A. | BRAZIL |
| Tantalum | Plansee SE Reutte | AUSTRIA |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | Tranzact, Inc. | UNITED STATES OF AMERICA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA |
| Tantalum | Power Resources Ltd. | MACEDONIA (THE FORMER YUGOSLAV REPUBLIC OF) |
| Tin | Alpha | UNITED STATES OF AMERICA |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
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| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | Elmet S.L.U. | SPAIN |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Metallo-Chimique N.V. | BELGIUM |
| Tin | Mineração Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| 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 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 Justindo | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Wahana Perkit Jaya | INDONESIA |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Thaisarco | THAILAND |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
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| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Yunnan Tin Company Limited | CHINA |
| Tin | An Thai Minerals Co., Ltd. | VIET NAM |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Dua Sekawan | INDONESIA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | CV Tiga Sekawan | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | Phoenix Metal Ltd. | RWANDA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Kijang Jaya Mandiri | INDONESIA |
| Tin | PT Sukses Inti Makmur | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | Estanho de Rondônia S.A. | BRAZIL |
| Tin | Gejiu Jinye Mineral Company | CHINA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | Modeltech Sdn Bhd | MALAYSIA |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | PT O.M. Indonesia | INDONESIA |
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| Tin | PT Tirus Putra Mandiri | INDONESIA |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck GmbH | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| 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 Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | 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 | VIET NAM |
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| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| Tungsten | Woltech Korea Co., Ltd. | KOREA (REPUBLIC OF) |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
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Annex II – List of Mine Countries of Origin
| Gold | Tantalum | Tin | Tungsten |
| Argentina | Australia | Argentina | Bolivia |
| Australia | Bolivia | Australia | Canada |
| Brazil | Brazil | Bolivia | China |
| Canada | Ethiopia | Brazil | Democratic republic of the Congo |
| China | India | Canada | Peru |
| Germany | Mozambique | Chile | Portugal |
| Guyana | Namibia | China | Spain |
| Hong Kong | Russia | Democratic republic of the Congo | |
| Indonesia | Sierra Leone | Indonesia | |
| Japan | Zimbabwe | Laos | |
| Peru | Morocco | ||
| Philippines | Myanmar | ||
| Singapore | Papua New Guinea | ||
| Switzerland | Peru | ||
| United States | Portugal | ||
| Rwanda | |||
| Vietnam |
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