Exhibit 1.01
Conflict Minerals Report
For the Year Ended December 31, 2014
Table of Contents
| Introduction | |
| Statement of Purpose | |
| Determination of Scope | |
| OECD Step 1: Establish Strong Company Management Systems | |
| OECD Step 2: Identify and Assess Risk in the Supply Chain | |
| OECD Step 3: Design and Implement a Strategy to Respond to Identified Risks | |
| Supplier focused risk mitigation actions | |
| OECD Step 4: Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain | |
| OECD Step 5: Report on Supply Chain Due Diligence | |
| Results of Due Diligence | |
| Improvement Measures | |
| Annex 1: Sierra Wireless Smelter List (CMRT) | |
We have made statements in this conflict minerals report that may constitute forward-looking statements about our plans to take additional actions or to implement additional policies or procedures with respect to our due diligence efforts to determine the origin of conflict minerals contained in our products. We undertake no obligation to publicly update or revise any forward-looking statement, whether as a result of new information, future events or otherwise. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report.
Introduction
Pursuant to Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “Rule”), Sierra Wireless, Inc. (“Sierra Wireless,” the “Company,” “we,” “us” and “our”) was required to conduct a reasonable country of origin inquiry (“RCOI”) on its supply chain to determine whether the “conflict minerals” contained in and necessary to the functionality or production of our products originated from the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”). As used in this report, the term “conflict minerals” includes gold, cassiterite, columbite-tantalite, wolframite and their derivatives tin, tantalum and tungsten (along with gold, “3TG”).
A copy of this Conflict Minerals Report is publicly available on our website at www.sierrawireless.com/ AboutUs/investorinformation/boardofdirectorsgovernance.
Business Overview
Sierra Wireless Inc., founded in 1993, is headquartered in Richmond, British Columbia, Canada and services a global market for its products. The Company is building the Internet of Things (“IoT”) with intelligent wireless solutions that empower organizations to innovate in the connected world. We offer the industry’s most comprehensive portfolio of second generation (“2G”), third generation (“3G”) and fourth generation (“4G”) embedded wireless modules and gateways, seamlessly integrated with our secure cloud and connectivity services. Original equipment manufacturers (“OEM”) and enterprises worldwide trust our innovative solutions to get their connected products and services to market faster. Our devices operate on more than 80 networks globally, and the Company has shipped more than 100 million machine-to-machine “M2M” devices worldwide.
We operate the Company under two reportable segments: OEM Solutions and Enterprise Solutions.
Our OEM Solutions segment includes cellular embedded modules, software and tools for OEM customers to integrate wireless cellular connectivity into products and solutions across a broad range of industries, including automotive, transportation, enterprise networking, energy, sales and payment, mobile computing, security, industrial monitoring, field services, and healthcare. Within our OEM Solutions segment, the AirPrime® Embedded Wireless Modules product portfolio spans 2G, 3G, and 4G cellular technologies and includes remote device management capability, as well as support for on-board embedded applications using the OpenAT® application framework and our new open source, Linux-based application framework, Legato.
Our Enterprise Solutions segment includes intelligent gateways, connectivity services and cloud services for enterprise customers. This integrated solution enables enterprise customers to accelerate the deployment of their IoT applications. Within our Enterprise Solutions segment, the AirLink® product portfolio includes 2G, 3G and 4G LTE gateways. AirLink devices are intelligent wireless gateways that provide plug-and-play mission-critical connectivity. The gateways are designed for use where reliability and security are essential, and are used in transportation, public safety, field services, energy, industrial, and enterprise networking applications worldwide. AirLink gateways can be easily configured for specific customer applications and also support on-board embedded applications using our ALEOS application framework.
Supply Chain Overview and RCOI
While we perform certain supply chain related functions in-house, we outsource our manufacturing, including procurement of certain parts, kitting, logistics, assembly and repair. We use several contract manufacturers and logistics partners to provide an end-to-end supply chain solution that covers procurement, manufacturing, repair and logistic services. We also use manufacturing partners to support regional manufacturing requirements and select products, including more complex, lower volume devices. By using the fully integrated supply chain services provided by these manufacturing partners, we expect to optimize product costs, improve alignment with our international customer base and achieve increased operating efficiencies and scalability. Many of our supplier relationships are entered into through our manufacturing partners and therefore, as part of our RCOI procedures, we were able to leverage our manufacturing partners to contact our suppliers in order to obtain conflict minerals data.
After conducting an internal assessment of our hardware products and the components within our products, we determined that the majority of our embedded wireless modules, intelligent gateways and modems contain 3TG. We therefore considered those products as part of our conflict minerals assessment. Although many of our hardware
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products contain 3TG, we are many steps removed in the supply chain from the mining and processing of the 3TG. We purchase the materials used in our products from a large network of suppliers and thus rely on our suppliers to assist us with our RCOI and due diligence efforts.
Based on the results of our RCOI, we had reason to believe that certain of the 3TG contained in our products may have originated in the Covered Countries and may not have come from recycled or scrap sources. We therefore exercised due diligence to determine the source and chain of custody of those conflict minerals.
Statement of Purpose
Sierra Wireless has determined that we are subject to the Rule adopted pursuant to Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act and relating to so-called “conflict minerals.” We are subject to the Rule due to the fact that certain products we manufacture contain 3TG. As a result of this determination, we have adopted a Conflict Minerals Policy (available on our website at www.sierrawireless.com/aboutus/investorinformation/boardofdirectorsgovernance/) and implemented a due diligence program in conformance with the internationally recognized Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains from Conflict-Affected and High-Risk Areas (the “OECD Guidance”).
The OECD Guidance outlines a five step process for implementing effective due diligence:
| Step 1: | Establish strong company management systems |
| Step 2: | Identify and assess risk in the supply chain |
| Step 3: | Design and implement a strategy to respond to identified risks |
| Step 4: | Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain |
| Step 5: | Report on supply chain due diligence |
This report provides information on the due diligence measures undertaken to conform to the OECD Guidance for our products and suppliers for 2014.
Determination of Scope
Sierra Wireless does not own manufacturing facilities for its products and as a result contracts external manufacturers to produce products. In order to determine which products fall within scope for our RCOI and due diligence, the Company conducted a review of its products manufactured during 2014.
In July 2014, our Global Supply Chain Group requested that our contract manufacturers provide an updated list of the suppliers of products or components that contain 3TG that end up in our products. Upon receipt of this list, our Conflict Minerals Working Group (the "Working Group") engaged in the following activities to determine the appropriate scope of our due diligence efforts:
| 1. | Excluded products from recently-acquired companies not yet covered by the Rule. |
| 2. | Analyzed our Bill of Materials (“BOM”) data to extract the list of known suppliers that are engaged in the manufacturing of products containing 3TG. |
| 3. | Where contract manufacturers were requested to provide a list of suppliers, we compared the list of suppliers submitted by our contract manufacturers against our BOM data to ensure consistent and comprehensive information. |
| 4. | Reviewed the remaining list of suppliers to eliminate products not covered by the Rule (e.g., no 3TG contained in product). |
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OECD Step 1: Establish Strong Company Management Systems
The Sierra Wireless conflict minerals compliance program is managed by the Working Group, a cross-functional team whose members represent the Company's Operations, Purchasing, Quality Management and Finance functions. The Working Group is assisted in its efforts by third party consultants. The working group is led by a Project Manager who coordinates conflict minerals program activities and provides regular reporting to senior management and the program’s Steering Committee.
The Sierra Wireless conflict minerals compliance program does not operate as a standalone program but rather is embedded as much as possible in the Company’s existing policies, processes and procedures to ensure effective management, oversight and implementation. Relevant aspects of conflict minerals compliance are integrated into the Company’s processes and procedures, which are based on and/or reflected in the following:
| • | Sierra Wireless Conflict Minerals Policy |
| • | Master Quality Agreement (2015) |
The Master Quality Agreement stipulates the quality standards we expect of our suppliers in the provision of goods to be incorporated into Company products.
| • | Global Supply Agreement (2015) |
The Global Supply Agreement is a standard form contract that governs the relationship between the Company and its suppliers.
| • | Sierra Wireless Conflict Minerals Due Diligence Implementation Handbook |
| • | Sierra Wireless Corporate Website, www.sierrawireless.com |
As outlined in the OECD Guidance, the internationally recognized standard on which our system is based, Sierra Wireless supports the Conflict Free Sourcing Initiative (“CFSI”), an industry initiative that audits smelters’ and refiners’ due diligence activities. As part of our due diligence, we rely on data obtained through our membership in the CFSI.
OECD Step 2: Identify and Assess Risk in the Supply Chain
We have designed our conflict minerals compliance program around the data provided in the CFSI Conflict Minerals Reporting Template (CMRT), a globally recognized, industry wide, 3TG reporting standard for purposes of complying with the Rule. All of our suppliers are requested to submit the most recently available version of the CMRT by October of each year. Given our position in the 3TG supply chain, we rely on our suppliers to identify smelters and refineries through the CMRT. In order to gather the smelter information, we engage either directly or indirectly through our contract manufacturers with suppliers. In addition, further in-depth validation of the information provided was conducted using a third party consultant (RCS Global) and a software tool (Green Status Pro).
Our risk analysis is based on two main factors: supplier responsiveness and the existence of identified risks (or so-called “red flags”). Suppliers identified with red flags have at least one of the following deficiencies: no conflict minerals policy; do not require that their suppliers be conflict free; have received less than 75% of conflict minerals data or information for each metal from their 3TG suppliers; and have not reported all smelter information in the CMRT.
In 2014 we surveyed 211 of our suppliers and received 206 responses. Of those responses, 34 triggered one or more red flags. At our request, our contract manufacturers followed up with 12 suppliers to obtain revised/updated CMRTs, thereby resolving the issues. For the remaining suppliers, we determined that the red flags most likely resulted from a misunderstanding of the CMRT. These suppliers will receive a communication from the Company in 2015 in advance of the request to submit a new CMRT, highlighting the expected areas of improvement for their CMRT.
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OECD Step 3: Design and Implement a Strategy to Respond to Identified Risks
Due to our position in the supply chain, our due diligence relies upon information provided by suppliers, as well as data from industry wide initiatives. As such, the Company’s risk management strategy includes the following:
| • | Ongoing membership, support and promotion of the CFSI as an industry-wide initiative to ensure 3TG smelters worldwide only source conflict free material. |
| ◦ | Sierra Wireless joined CFSI in May 2014. |
| • | Promotion of the use of CFSI compliant smelters with our supplier group through our policy and purchasing requirements. |
| • | Development of the Working Group, policies and procedures governing conflict minerals compliance. |
| ◦ | Sierra Wireless conducted two workshops to educate the Working Group about identifying and responding to red flags. |
| • | As described above, responding to red flags identified during the annual review of supplier CMRTs and conducting further due diligence through supplier inquiries or audits as required. |
Supplier focused risk mitigation actions
In January 2015, our Working Group reviewed suppliers with respect to which one or more red flag criteria were identified. For each supplier, the Working Group proposed risk mitigation measures intended to assist suppliers in their compliance with the company’s conflict free sourcing requirements. Initial outreach was conducted via email to select suppliers to clarify responses on the CMRT and/or to obtain updated CMRTs with higher response rates.
OECD Step 4: Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We intend to perform audits of selected suppliers to confirm that those suppliers conducted the due diligence, supply chain mapping and reporting of smelters and refineries as described in their CMRTs. The Working Group intends to use the findings from such audits to address any discrepancies between reported and actual activities and further reduce identified risks.
We do not have a direct relationship with 3TG smelters, nor do we perform direct audits of these entities that provide 3TG to our suppliers. However, we do rely upon industry efforts, including those of the CFSI, the London Bullion Market Association (“LBMA”) and the Responsible Jewelry Council (“RJC”) to influence smelters to become audited and certified through CFSI’s Conflict Free Smelter Program. We also continue to support these efforts through our membership in CFSI.
Pursuant to the Rule, this report is not subject to an independent private sector audit for 2014.
OECD Step 5: Report on Supply Chain Due Diligence
Results of Due Diligence
Based on the Working Group’s analysis of the information provided by our suppliers, we identified 250 smelters that may have been used to process the 3TG in our products. Those smelters are listed in Annex 1 hereto.
Based on information provided by the CFSI, we identified the country of origin of the 3TG for 119 smelters. We have been unable to identify the country of origin of the 3TG for 131 of the smelters. Of the identified smelters, 20 were determined to source from the Covered Countries and all of them were certified by the CFSI as compliant with its Conflict Free Smelter Program. A total of 155 smelters were certified by the CFSI as compliant, including 52 gold smelters audited by the LBMA or RJC.
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The information received from our due diligence efforts from suppliers or other sources is not sufficient to determine the origin of all 3TG in our products and, as a result, we have been unable to determine whether the 3TG in our supply chain directly or indirectly finance or benefit armed groups in the Covered Countries.
Improvement Measures
For reporting year 2015, Sierra Wireless intends to continue improving our due diligence program and risk mitigation efforts through the following:
| • | Enhance the level of engagement with the Company’s strategic suppliers |
| • | Implement third party audits of suppliers, with a focus on suppliers identified with red flags |
| • | Undergo an IPSA of our due diligence program in line with the SEC requirements |
| • | Improve and update process documentation to include specific references to conflict minerals considerations |
| • | Refine supplier selection criteria related to conflict minerals considerations |
| • | Improve communication and understanding of conflict free sourcing criteria within the Company |
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Annex 1: Sierra Wireless Smelter List (CMRT)
| Metal | Smelter Name | Smelter Country | CFSI Smelter ID |
| Gold | Advanced Chemical Company | UNITED STATES | CID000015 |
| Gold | Aida Chemical Industries Co. Ltd. | JAPAN | CID000019 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | BRAZIL | CID000058 |
| Gold | Argor-Heraeus SA | SWITZERLAND | CID000077 |
| Gold | Asahi Pretec Corporation | JAPAN | CID000082 |
| Gold | Asaka Riken Co Ltd | JAPAN | CID000090 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
| Gold | Aurubis AG | GERMANY | CID000113 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
| Gold | Bauer Walser AG | GERMANY | CID000141 |
| Gold | Boliden AB | SWEDEN | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
| Gold | Caridad | MEXICO | CID000180 |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
| Gold | Cendres + Métaux SA | SWITZERLAND | CID000189 |
| Gold | Chimet S.p.A. | ITALY | CID000233 |
| Gold | China National Gold Group Corporation | CHINA | CID000242 |
| Gold | Chugai Mining | JAPAN | CID000264 |
| Gold | Colt Refining | UNITED STATES | CID000288 |
| Gold | Daejin Indus Co. Ltd | KOREA, REPUBLIC OF | CID000328 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF | CID000359 |
| Gold | Doduco | GERMANY | CID000362 |
| Gold | Dowa | JAPAN | CID000401 |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | CID000425 |
| Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
| Gold | Gansu Seemine Material Hi-Tech Co Ltd | CHINA | CID000522 |
| Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
| Gold | Heraeus Ltd. Hong Kong | HONG KONG | CID000707 |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 |
| Gold | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | CID000767 |
| Gold | Hwasung CJ Co. Ltd | KOREA, REPUBLIC OF | CID000778 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
| Gold | Japan Mint | JAPAN | CID000823 |
| Gold | Jiangxi Copper Company Limited | CHINA | CID000855 |
| Gold | Johnson Matthey Inc | UNITED STATES | CID000920 |
| Gold | Johnson Matthey Ltd | CANADA | CID000924 |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
| Gold | Kazzinc Ltd | KAZAKHSTAN | CID000957 |
| Gold | Kennecott Utah Copper LLC | UNITED STATES | CID000969 |
| Gold | Kojima Chemicals Co., Ltd | JAPAN | CID000981 |
| Gold | Korea Metal Co. Ltd | KOREA, REPUBLIC OF | CID000988 |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA | CID001032 |
| Gold | Lingbao Gold Company Limited | CHINA | CID001056 |
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | CHINA | CID001058 |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
| Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | CHINA | CID001093 |
| Gold | Materion | UNITED STATES | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
| Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte. Ltd. | SINGAPORE | CID001152 |
| Gold | Metalor Technologies SA | SWITZERLAND | CID001153 |
| Gold | Metalor USA Refining Corporation | UNITED STATES | CID001157 |
| Gold | Met-Mex Peñoles, S.A. | MEXICO | CID001161 |
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
| Gold | Nihon Material Co. LTD | JAPAN | CID001259 |
| Gold | Ohio Precious Metals, LLC | UNITED STATES | CID001322 |
| Gold | Ohura Precious Metal Industry Co., Ltd | JAPAN | CID001325 |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIAN FEDERATION | CID001326 |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | CID001328 |
| Gold | PAMP SA | SWITZERLAND | CID001352 |
| Gold | Penglai Penggang Gold Industry Co Ltd | CHINA | CID001362 |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
| Gold | PX Précinox SA | SWITZERLAND | CID001498 |
| Gold | Rand Refinery (Pty) Ltd | SOUTH AFRICA | CID001512 |
| Gold | Royal Canadian Mint | CANADA | CID001534 |
| Gold | Sabin Metal Corp. | UNITED STATES | CID001546 |
| Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF | CID001562 |
| Gold | Schone Edelmetaal | NETHERLANDS | CID001573 |
| Gold | SEMPSA Joyería Platería SA | SPAIN | CID001585 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | CHINA | CID001622 |
| Gold | So Accurate Group, Inc. | UNITED STATES | CID001754 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | CID001761 |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
| Gold | The Great Wall Gold and Silver Refinery of China | CHINA | CID001909 |
| Gold | The Refinery of Shandong Gold Mining Co. Ltd | CHINA | CID001916 |
| Gold | Tokuriki Honten Co., Ltd | JAPAN | CID001938 |
| Gold | Tongling nonferrous Metals Group Co.,Ltd | CHINA | CID001947 |
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 |
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| Gold | Umicore Brasil Ltda | BRAZIL | CID001977 |
| Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | CID001980 |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | CID001993 |
| Gold | Valcambi SA | SWITZERLAND | CID002003 |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | CID002030 |
| Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | JAPAN | CID002100 |
| Gold | Yokohama Metal Co Ltd | JAPAN | CID002129 |
| Gold | Yunnan Copper Industry Co Ltd | CHINA | CID000197 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
| Gold | Zijin Mining Group Co. Ltd | CHINA | CID002243 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | CID000291 |
| Tantalum | Duoluoshan | CHINA | CID000410 |
| Tantalum | Exotech Inc. | UNITED STATES | CID000456 |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 |
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | CID002557 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | CID002501 |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | CID002545 |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | CID002546 |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 |
| Tantalum | H.C. Starck Inc. | UNITED STATES | CID002548 |
| Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | CID002550 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
| Tantalum | Hi-Temp | UNITED STATES | CID000731 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
| Tantalum | KEMET Blue Metals | MEXICO | CID002539 |
| Tantalum | KEMET Blue Powder | UNITED STATES | CID002568 |
| Tantalum | King-Tan Tantalum Industry Ltd | CHINA | CID000973 |
| Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 |
| Tantalum | Metallurgical Products India (Pvt.) Ltd. | INDIA | CID001163 |
| Tantalum | Mineração Taboca S.A. | BRAZIL | CID001175 |
| Tantalum | Mitsui Mining & Smelting | JAPAN | CID001192 |
| Tantalum | Molycorp Silmet A.S. | ESTONIA | CID001200 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
| Tantalum | Plansee SE Liezen | AUSTRIA | CID002540 |
| Tantalum | Plansee SE Reutte | AUSTRIA | CID002556 |
| Tantalum | QuantumClean | UNITED STATES | CID001508 |
| Tantalum | RFH Tantalum Smeltry Co., Ltd | CHINA | CID001522 |
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | CHINA | CID001634 |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
| Tantalum | Taki Chemicals | JAPAN | CID001869 |
| Tantalum | Telex | UNITED STATES | CID001891 |
| Tantalum | Ulba | KAZAKHSTAN | CID001969 |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd | CHINA | CID002307 |
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| Tantalum | Zhuzhou Cement Carbide | CHINA | CID002232 |
| Tin | Alpha | UNITED STATES | CID000292 |
| Tin | China Rare Metal Materials Company | CHINA | CID000244 |
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 |
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | CHINA | CID000278 |
| Tin | Cooper Santa | BRAZIL | CID000295 |
| Tin | CV Gita Pesona | INDONESIA | CID000306 |
| Tin | CV JusTindo | INDONESIA | CID000307 |
| Tin | CV Makmur Jaya | INDONESIA | CID000308 |
| Tin | CV Nurjanah | INDONESIA | CID000309 |
| Tin | CV Serumpun Sebalai | INDONESIA | CID000313 |
| Tin | CV United Smelting | INDONESIA | CID000315 |
| Tin | Dowa | JAPAN | CID000402 |
| Tin | EM Vinto | BOLIVIA | CID000438 |
| Tin | Estanho de Rondônia S.A. | BRAZIL | CID000448 |
| Tin | Fenix Metals | POLAND | CID000468 |
| Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | CHINA | CID000538 |
| Tin | Gejiu Zi-Li | CHINA | CID000555 |
| Tin | Huichang Jinshunda Tin Co. Ltd | CHINA | CID000760 |
| Tin | Jiangxi Nanshan | CHINA | CID000864 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
| Tin | Linwu Xianggui Smelter Co | CHINA | CID001063 |
| Tin | Magnu's Minerais Metais e Ligas LTDA | BRAZIL | CID002468 |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
| Tin | Melt Metais e Ligas S/A | BRAZIL | CID002500 |
| Tin | Metallo Chimique | BELGIUM | CID001143 |
| Tin | Mineração Taboca S.A. | BRAZIL | CID001173 |
| Tin | Minsur | PERU | CID001182 |
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
| Tin | Novosibirsk Integrated Tin Works | RUSSIAN FEDERATION | CID001305 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Tin | OMSA | BOLIVIA | CID001337 |
| Tin | PT Alam Lestari Kencana | INDONESIA | CID001393 |
| Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
| Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 |
| Tin | PT Babel Surya Alam Lestari | INDONESIA | CID001406 |
| Tin | PT Bangka Putra Karya | INDONESIA | CID001412 |
| Tin | PT Bangka Tin Industry | INDONESIA | CID001419 |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | CID001421 |
| Tin | PT BilliTin Makmur Lestari | INDONESIA | CID001424 |
| Tin | PT Bukit Timah | INDONESIA | CID001428 |
| Tin | PT DS Jaya Abadi | INDONESIA | CID001434 |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | CID001438 |
| Tin | PT Fang Di MulTindo | INDONESIA | CID001442 |
| Tin | PT HANJAYA PERKASA METALS | INDONESIA | CID002287 |
| Tin | PT HP Metals Indonesia | INDONESIA | CID001445 |
| Tin | PT Inti Stania Prima | INDONESIA | CID002530 |
| Tin | PT Karimun Mining | INDONESIA | CID001448 |
| Page | 4 |
| Tin | PT Koba Tin | INDONESIA | CID001449 |
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
| Tin | PT Panca Mega Persada | INDONESIA | CID001457 |
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 |
| Tin | PT REFINED BANGKA TIN | INDONESIA | CID001460 |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 |
| Tin | PT Seirama Tin investment | INDONESIA | CID001466 |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
| Tin | PT Sumber Jaya Indah | INDONESIA | CID001471 |
| Tin | PT Supra Sukses Trinusa | INDONESIA | CID001476 |
| Tin | PT Tambang Timah | INDONESIA | CID001477 |
| Tin | PT Timah (Persero), Tbk | INDONESIA | CID001482 |
| Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 |
| Tin | PT Tommy Utama | INDONESIA | CID001493 |
| Tin | PT Yinchendo Mining Industry | INDONESIA | CID001494 |
| Tin | Rui Da Hung | TAIWAN | CID001539 |
| Tin | Soft Metais, Ltda. | BRAZIL | CID001758 |
| Tin | Thaisarco | THAILAND | CID001898 |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | CHINA | CID002158 |
| Tin | Yunnan Tin Company, Ltd. | CHINA | CID002180 |
| Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | CID000345 |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | CID000868 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| Tungsten | H.C. Starck GmbH | GERMANY | CID002541 |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | CID002542 |
| Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | CID000766 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | CHINA | CID002493 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
| Tungsten | Kennametal Fallon | UNITED STATES | CID000966 |
| Tungsten | Kennametal Huntsville | UNITED STATES | CID000105 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM | CID002543 |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | CID001889 |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | VIETNAM | CID002011 |
| Page | 5 |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | CID002044 |
| Tungsten | Wolfram Company CJSC | RUSSIAN FEDERATION | CID002047 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 |
| Page | 6 |