Exhibit 1.01
Radware Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2021
This Conflict Minerals Report for the year ended December 31, 2021 (this "Report") has been prepared by Radware Ltd. (“Radware,” the “Company”, “our” 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 a 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”) and that such conflict minerals may not originate entirely from recycled or scrap sources, 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 as well as measures to address and analyze risks in its supply chain.
This Report relates to the process undertaken for Radware's products that were manufactured or contracted to be manufactured during the calendar year 2021 and that may contain 3TG minerals that are necessary to the functionality or production of such products manufactured or to the products contracted to be manufactured.
A copy of this Report, as well as the Form SD that we filed with the SEC, are 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 to comply with Radware’s Conflict Minerals Policy or Radware’s other relevant policies for suppliers and contractors, such as our Supplier Code of Conduct, may affect Radware’s future determinations under Rule 13p-1.
As part of Radware's Labor Practice and Human Rights Policy, Radware respects the protection of human rights, including the basic human rights of employees and workers, and supports and recognizes relevant international frameworks and agreements, such as the United Nations’ Declaration of Human Rights and the International Labor Organization’s Declaration of Fundamental Principles. The Company aims to uphold the human rights of those affected by its business activities, and in particular, of the workers engaged in its supply chain. Accordingly, the Company aspires to source components and materials from suppliers that share our values regarding respect for human rights, integrity and environmental responsibility, and that comply with applicable legal standards and requirements. To that end, the Company upholds a Code of Conduct for Suppliers that addresses issues associated with mineral sourcing and/or conflict minerals. By upholding standards for its suppliers, Radware expresses its commitment to using minerals in its products that do not directly or indirectly finance armed conflict in the DRC or one of the other Covered Countries, or that benefit, directly or indirectly, armed groups in those countries.
Company Overview
We are a provider of cyber security and application delivery solutions for physical, cloud, physical and software defined data centers (SDDC). Our solutions secure the digital experience by providing infrastructure, application, and corporate IT protection and availability services to enterprises globally. Our solutions are deployed by, among others, enterprises, carriers and cloud service providers. Our solutions are offered in two main categories: products and customer services. Our product offering includes a range of physical, software-based products, product subscriptions and cloud-based subscriptions (or a combination of these) for enterprise and carrier data centers, as part of their IT and application infrastructure. Our customer services offering includes technical support, professional services, managed services and training and certification to our customers. We sell through sales channels such as resellers and distributors whereas most of our direct sales are 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.
Responsible Sourcing Efforts in Our Supply Chain
We conducted an analysis of our products and found that small quantities of 3TG could potentially be found in our products that were manufactured or contracted to be manufactured in 2021, and that the 3TG is or could be necessary to the functionality or production of our products.
The products that we manufacture are highly complex, typically containing thousands of parts that are sourced from direct suppliers. In general, as a downstream company (as further explained under Section 2.1 below), 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 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 so that they may provide us with accurate information regarding the origin, or likely origin, of 3TG in the components we purchase from them and that is necessary to the production or functionality of our products. 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. However, as we enter into supplier contracts or renew existing supplier contracts, we seek to add, where feasible, a conflict minerals contract clause that requires relevant suppliers to provide us with information on the likely source and chain of custody of 3TG and relevant smelters or refiners. In attempting to determine the source of the 3TG content in our products, i.e., through our supply chain due diligence, we do not seek to eliminate sourcing from the DRC or other Covered Countries, but rather to ensure that our suppliers responsibly source the necessary minerals in a fashion that does not directly or indirectly fund or support the armed conflict ongoing in that region.
Reasonable Country of Origin Inquiry (RCOI)
We have determined that requesting our direct suppliers to complete the standard Conflict Minerals Reporting Template (“CMRT”) 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, 2021, in aggregate, at least 90% of our spend on the manufacturing costs of our finished products that were shipped in 2021. We identified in total four (4) relevant suppliers (the “In-Scope Suppliers”). We collected all relevant data from our In-Scope Suppliers who were requested to submit CMRT of at least version 6.01 or higher published by the Responsible Minerals Initiatives' ("RMI") in order to monitor the due diligence process and to gather and assess information from all such In-Scope Suppliers in a standardized format that is approved by an independent third party audit body, such as the RMI or the London Bullion Market Association (“LBMA”).
We sent letters to our In-Scope Suppliers to explain the Rule and to refer them to online training materials and instructions.
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 four In-Scope Suppliers, all of the suppliers (100%) completed and returned to us a CMRT.
Based on these efforts, we have reason to believe that some of our products may contain necessary conflict minerals that potentially originated in the DRC or one of the Covered Countries and are not entirely 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.
| 2.1 | 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 Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016)" and related Supplements (the “OECD Guidance”). The OECD Guidance distinguishes between the roles of, and the corresponding due diligence recommendations addressed to upstream companies and downstream companies in the supply chain, whereby “upstream” generally means the mineral supply chain from the mine to smelters or refineries, and “downstream” generally means the minerals supply chain from smelters/refiners to retailers. 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 as we believe that we are a “downstream” company.
| 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 of the necessary conflict minerals. The Policy is publicly available on our website at https://www.radware.com/corporategovernance/conflictminerals.
Internal Team
We have established a management system to implement our responsible sourcing practices, to assist in the completion of the RCOI inquiry, and to further enable our supply chain due diligence related to the necessary 3TG. Our management system includes a steering committee headed by the Company's Legal Department (the “CM Steering Committee”), and a team of subject matter functions such as supplier management, operations and legal.
Supply Chain Control Systems and Transparency
We requested that all In-Scope Suppliers provide information to us regarding 3TG and relevant smelters or refiners using the CMRT of at least version 6.01 or higher. We collect and analyze all relevant data submitted to us through the CMRT to maintain a smelter or refiner database for Radware. This database of records is compared against the list of smelters or refiners that have received 'conformant' or 'active' designation according to the RMI's independent smelter or refiner audit program, namely the Responsible Minerals Assurance Process ("RMAP") or the LBMA.
We adopted, and communicated to our suppliers and to the public through our website and direct letters, our Policy for the sourcing of minerals originating from conflict-affected and high-risk areas that are under scrutiny for human right abuses, namely from the DRC or other Covered Countries, as per the stipulations of the Rule.
Grievance Mechanism
Our Conflict Minerals Policy is available to the public on our website at https://www.radware.com/corporategovernance/conflictminerals and provides the contact details for reporting concerns or questions regarding the Policy or violations thereof. 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 grievance in relation to our Conflict Minerals Policy.
Maintaining Records
We maintain data records relating to our due diligence efforts for the five-year duration recommended by the OECD Guidance. Radware stores current and former CMRTs received from suppliers to maintain traceability and transparency.
Supplier Engagement
We maintain an electronic portal that 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. Our webpage is hosted at https://www.radware.com/corporategovernance/conflictminerals.
We also provide guidance on the topic for relevant suppliers and engage in on-going outreach to our suppliers in order to collect, validate and archive supplier responses that relate to our conflict minerals due diligence process and supply chain inquiry.
As we enter into supplier contracts or renew existing supplier contracts, we seek to add, where feasible, a conflict minerals contract clause that requires suppliers to provide us with information on the likely source of the necessary 3TG they provide us, and relevant smelters or refiners.
Our internal controls also include a company-wide Code of Conduct that outlines expected behaviors from all of our employees, contractors and consultants in engaging with suppliers. We have also adopted a Supplier Code of Conduct in which we convey to our suppliers, contractors and relevant third parties our expectations regarding, among other topics, responsible sourcing practices. The full text of our Code of Conduct and Supplier Code of Conduct is available on our website at https://www.radware.com/corporategovernance.
| 2.2.2 | Identify and Assess Risks in the Supply Chain |
We approached four In-Scope Suppliers and received responses from all (100%) of the In-Scope Suppliers as described in the RCOI. We reviewed and analyzed the respective CMRTs of our In-Scope Suppliers and compared the information provided therein against the Standard Smelter List of Compliant and Active Smelters from the RMAP - a list issued by RMI that aims to identify smelters or refiners that have systems in place to assure the responsible sourcing of conflict minerals, including those conflict minerals originating from the DRC or other Covered Countries We rely on these In-Scope Suppliers, whose components may contain 3TG, to provide us with information on the likely source and chain of custody of conflict minerals contained in the components supplied to us that are necessary to the production and/or to the functionality of our products. Our In-Scope Suppliers are similarly reliant upon information provided by their suppliers.
| 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 goal of the design and implementation of our risk management strategy is not to eliminate sourcing from the DRC or other Covered Countries, but rather to encourage participation with the RMI and other relevant third party audit bodies, where possible. The following steps were taken to implement a strategy to help us assess potential risks:
| • | The CM Steering Committee held periodic meetings to review progress and assess the risks identified. |
| • | We reviewed the responses that we received from In-Scope Suppliers and followed up on what we perceived to be inconsistent, incomplete, or inaccurate responses, as well as sent reminders to In-Scope Suppliers that did not respond to our requests for information. |
| • | We sent, where applicable, follow up letters to unresponsive In-Scope Suppliers and to In-Scope Suppliers who declared they sourced conflict minerals from the DRC or other Covered Countries, asking them to complete their supply chain due diligence process in order to validate that all smelters or refiners from the DRC or other Covered Countries are compliant with the RMI or other independent conflict-free smelter validation programs, such as the London Bullion Market (LBMA) or the Responsible Jewelry Council (RJC). |
| • | Engaged relevant senior management, including our Vice President and General Counsel, who were briefed on our due diligence efforts, risk analysis results and mitigation efforts. |
| • | We approached In-Scope Suppliers that we identified as possibly sourcing from smelters or refiners located in the DRC or other Covered Countries that did not receive a conformant or active designation from the RMI or LBMA, 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 RMI, to conduct risk assessments 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.
Based on information provided by our In-Scope Suppliers as well as by RMI, the results of our due diligence investigation on the dates covered by this Report, are as follows:
| • | We were successful in approaching all In-Scope Suppliers. |
| • | Out of the four (4) In-Scope Suppliers, all (100%) completed and returned the CMRTs to us. Based on the CMRTs we received from these In-Scope Suppliers: |
| o | 100% of the responses received provided data at the following levels. |
Category of RMI CMRT Filed | Percentage of Responsive In-Scope Suppliers |
Company level | 50% (2 out of 4 suppliers) |
| User defined | 25% (1 out of 4 suppliers) |
| Product list | 25% (1 out of 4 suppliers) |
| o | We identified that 91% of the 298 reported smelters or refiners (“SoRs”), as of the publication of this Report, are conformant or active in the RMI’s RMAP audit program, as detailed below: |
SoR RMI Status (Conformant, Active and Undocumented):
| Conformant | 271 Smelters or Refiners, 91% of Smelters or Refiners |
| Active | 20 Smelters or Refiners, 7% of Smelter or Refiners |
| Undocumented | 7 Smelters or Refiners, 2% of Smelters or Refiners |
| Total | 298 Smelters or Refiners, 100% of Smelters or Refiners |
Based on the information provided by the In-Scope Suppliers as well as by RMI, 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 or refiners listed in Annex I below.
Based on the information provided by the In-Scope Suppliers as well as by RMI, as of the date of this Report, Radware believes that the 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 In-Scope Suppliers is not collected on a continuous, real-time basis.
In addition, Radware can only provide reasonable and good faith, yet not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals, since the information is provided from direct suppliers as well as from independent third party audit programs such as the RMI and the LBMA.
| 4. | Future Risk Mitigation Efforts |
We currently intend to continue working with our global supply chain to achieve the responsible sourcing of minerals from conflict areas and to comply with applicable regulations to the extent that they are required:
| • | Continue implementing risk management measures and follow up processes with regard to non-responsive suppliers or suppliers working with undocumented suppliers according to current information from the RMI’s RMAP program. |
| • | As described in our Conflict Minerals Policy, to the extent that we have reason to believe that any of our 3TG suppliers source, or potentially source, such minerals from facilities that may, directly or indirectly, support the on-going conflict in the DRC or the other Covered Countries, we encourage such suppliers to establish an alternative source of 3TG sourcing that does not support such conflict, as outlined in the OECD Guidance. This engagement is important to us as we are committed to discouraging the propagation of human rights abuses in our supply chain. |
| • | 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 with the goal of maintaining a 100% response rate and improving the content of the supplier’s survey responses. |
| • | Request suppliers to procure materials through validated smelters or refiners pursuant to the RMI or other approved resources and request suppliers to take mitigating actions in case they do not. |
| • | Continue to validate supplier responses using information collected via independent conflict-free smelter or refiner validation programs, such RMI's RMAP program. |
| • | Continue to engage in regular and ongoing risk assessment through our suppliers’ annual data submissions. |
Annex I – List of Smelters and/or Refiners
| Metal (*) | Smelter Name Look-up | Smelter Country (*) |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Brazil | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Amagasaki Factory, Hyogo Prefecture, Japan | JAPAN |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CCR | CANADA |
| Gold | Cendres + M?taux SA | SWITZERLAND |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF |
| Gold | Doduco | GERMANY |
| Gold | AKITA Seiren | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Ltd. Hong Kong | CHINA |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY |
| 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 | Japan Mint | JAPAN |
| Gold | JCC | CHINA |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kazzinc | KAZAKHSTAN |
| 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 (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Switzerland | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Metal?rgica Met-Mex Pe?oles, S.A. de C.V | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Kinzoku Co., Ltd. | JAPAN |
| Gold | Federal State Unitary Enterprise Moscow Special Processing Plant (FSUE MZSS) | 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 | C.I Metales Procesados Industriales SAS | COLOMBIA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | PAMP S.A. | SWITZERLAND |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | Augmont Enterprises Private Limited | INDIA |
| Gold | Alexy Metals | UNITED STATES OF AMERICA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Samdok Metal | KOREA, REPUBLIC OF |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Shyolkovsky | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | MEM(Sumitomo Group) | JAPAN |
| Gold | Shonan Plant Tanaka Kikinzoku | JAPAN |
| Gold | Great Wall Precious Metals Co,. LTD. | CHINA |
| Gold | China's Shandong Gold Mining Co., Ltd | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Metallurgie Hoboken Overpelt | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | AGR (Perth Mint Australia) | AUSTRALIA |
| Gold | Yamakin Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA |
| Gold | China Henan Zhongyuan Gold Smelter | CHINA |
| Gold | Fujian Zijin mining stock company gold smelter | CHINA |
| Gold | SAFINA A.S. | CZECHIA |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | KGHM Polska Miedz S.A. | POLAND |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Remondis Argentia B.V. | NETHERLANDS |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Marsam Metals | BRAZIL |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | SAAMP | FRANCE |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | 8853 S.p.A. | ITALY |
| Gold | Italpreziosi | ITALY |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | BALORE REFINERSGA | INDIA |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | Safimet S.p.A | ITALY |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
| Tantalum | F & X | CHINA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | CHINA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | Metallurgical Products India Pvt. Ltd. (MPIL) | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining & Smelting | JAPAN |
| Tantalum | Molycorp Silmet A.S. | ESTONIA |
| Tantalum | Ningxia Non-Ferrous Metal Smeltery | CHINA |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | RFH | CHINA |
| Tantalum | Solikamsk | RUSSIAN FEDERATION |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | ULBA | KAZAKHSTAN |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | 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 | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Resind Ind e Com Ltda. | BRAZIL |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN |
| Tantalum | PRG Dooel | NORTH MACEDONIA |
| Tin | Chenzhou Yun Xiang mining limited liability company | CHINA |
| Tin | Alent plc | UNITED STATES OF AMERICA |
| Tin | Dowa | JAPAN |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Gejiu Zi-Li | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | China Tin (Hechi) | CHINA |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Funsur Smelter | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Jiangxi Nanshan | CHINA |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | OMSA | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | Smelter not listed | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | Brand RBT | INDONESIA |
| Tin | Smelter not listed | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | Kundur Smelter | INDONESIA |
| Tin | INDONESIAN STATE TIN CORPORATION MENTOK SMELTER | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Thai Solder Industry Corp., Ltd. | THAILAND |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | Chengfeng Metals Co Pte Ltd | CHINA |
| Tin | Estanho de Rondonia S.A. | BRAZIL |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Smelter not listed | INDONESIA |
| Tin | Resind Ind e Com Ltda. | BRAZIL |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| Tin | Metallo Belgium N.V. | BELGIUM |
| Tin | Metallo Spain S.L.U. | SPAIN |
| Tin | Smelter not listed | INDONESIA |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | PT Timah Nusantara | INDONESIA |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | PT Bangka Serumpun | INDONESIA |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | China Yunnan Tin Co Ltd. | CHINA |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | Luna Smelter, Ltd. | RWANDA |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Super Ligas | BRAZIL |
| Tin | Smelter not listed | INDONESIA |
| Tin | Smelter not listed | INDONESIA |
| Tin | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | CRM Synergies | SPAIN |
| Tin | Smelter Not Listed | INDONESIA |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | ATI Metalworking Products | UNITED STATES OF AMERICA |
| Tungsten | Chaozhou Xianglu Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Human Chun-Chang non-ferrous Smelting & Concentrating Co., Ltd. | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | China National Non Ferrous | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | WBH | AUSTRIA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Xiamen H.C. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tungsten | Masan High-Tech Materials | VIET NAM |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | China Molybdenum Co., Ltd. | CHINA |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tungsten | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| Tungsten | GEM Co., Ltd. | CHINA |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
Annex II – Country of Origin Inquiry (COO)
| Gold | Tantalum | Tin | Tungsten |
| UNITED STATES OF AMERICA | CHINA | CHINA | JAPAN |
| JAPAN | UNITED STATES OF AMERICA | UNITED STATES OF AMERICA | UNITED STATES OF AMERICA |
| GERMANY | BRAZIL | JAPAN | CHINA |
| UZBEKISTAN | INDIA | BOLIVIA (PLURINATIONAL STATE OF) | AUSTRIA |
| BRAZIL | JAPAN | BRAZIL | VIET NAM |
| SWITZERLAND | ESTONIA | POLAND | GERMANY |
| PHILIPPINES | RUSSIAN FEDERATION | MALAYSIA | RUSSIAN FEDERATION |
| SWEDEN | KAZAKHSTAN | PERU | PHILIPPINES |
| CANADA | MEXICO | RUSSIAN FEDERATION | BRAZIL |
| ITALY | THAILAND | THAILAND | KOREA, REPUBLIC OF |
| CHINA | GERMANY | INDONESIA | TAIWAN, PROVINCE OF CHINA |
| KOREA, REPUBLIC OF | NORTH MACEDONIA | TAIWAN, PROVINCE OF CHINA | |
| RUSSIAN FEDERATION | | PHILIPPINES | |
| TURKEY | | BELGIUM | |
| KAZAKHSTAN | | SPAIN | |
| SINGAPORE | | VIET NAM | |
| MEXICO | | RWANDA | |
| INDONESIA | | | |
| SOUTH AFRICA | | | |
| SPAIN | | | |
| TAIWAN, PROVINCE OF CHINA | | | |
| BELGIUM | | | |
| AUSTRALIA | | | |
| CZECHIA | | | |
| THAILAND | | | |
| INDIA | | | |
| POLAND | | | |
| UNITED ARAB EMIRATES | | | |
| NETHERLANDS | | | |
| FRANCE | | | |
| ANDORRA | | | |
| AUSTRIA | | | |
| CHILE | | | |
| COLOMBIA | | | |
| KYRGYZSTAN | | | |
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