Exhibit 1.01
Conflict Minerals Report
For the Year Ended December 31, 2018
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 | |
| OECD Step 4: Carry out Independent Third-Party Audit of Due Diligence Practices in the Supply Chain | |
| OECD Step 5: Report on Supply Chain Due Diligence | |
| Results of Due Diligence | |
| Improvement Measures | |
| Annex 1: Smelter List | |
| Annex 2: Countries of Origin | |
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. References to our website in this document are intended to provide inactive, textual references only; and the information contained on our website is not incorporated by reference into this Conflict Minerals Report or our Form SD filed with the U.S. Securities and Exchange Commission and should not be considered part of our Conflict Minerals Report or Form SD.
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”) conducted a reasonable country of origin inquiry (“RCOI”) on its supply chain and undertook due diligence measures to determine whether the “conflict minerals” contained in and necessary to the functionality or production of its 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/company/corporate-social-responsibility/.
Business Overview
Sierra Wireless, founded in 1993, is headquartered in Richmond, British Columbia, Canada and services a global market for its products. We are an Internet of Things ("IoT") pioneer that empowers businesses and industries to transform and thrive in the connected economy.
We provide an integrated device-to-cloud IoT solution comprised of our IoT platform and connectivity services connected with our embedded cellular modules and cellular gateways. Original Equipment Manufacturers ("OEMs") and enterprises worldwide rely on our expertise in delivering fully integrated IoT solutions to reduce complexity, turn edge network data into intelligent decisions and get their connected products and services to market faster. We operate our business under two reportable segments: IoT Solutions and Embedded Broadband.
IoT Solutions
Our IoT Solutions segment is focused on integrated end-to-end IoT solutions that include connectivity services, cloud platform, software and devices (cellular modules or cellular gateways) targeted primarily at Enterprises and OEMs in the IoT space. These include IoT opportunities where there is a high potential for recurring connectivity services and solutions to be provided to the customer along with our cloud platform, devices and management tools. Our IoT Solutions segment provides Device-to-Cloud IoT solutions that include: (i) our cloud platform services, which provide a secure and scalable cloud platform for deploying and managing IoT subscriptions, over-the-air updates, devices and applications; (ii) our global cellular connectivity services, which are subscription-based and include our flexible Smart SIM and core network platforms; and (iii) our managed broadband cellular services, which include a combination of hardware, managed high speed connectivity and cloud services.
Our devices in this segment are comprised of IoT embedded cellular wireless modules which includes Low Power Wide Area technologies ("LPWA"), second generation ("2G"), third generation ("3G"), and some fourth generation ("4G") Long-Term Evolution ("LTE") products. We also provide cellular gateways and routers that are complemented by cloud-based services and on-premise software for secure device and network management.
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Our gateway solutions address a broad range of vertical market applications within the mobility, industrial and enterprise market segments.
Embedded Broadband
Our Embedded Broadband segment is comprised of our high-speed cellular embedded modules that are typically used in non-industrial applications, namely Automobile, Mobile Computing and Enterprise Networking markets. The products in this segment are typically high-speed 4G LTE and LTE-Advanced cellular modules that are ordered in larger volumes. In this segment, we do not have the opportunity to provide connectivity services or a fully integrated IoT solutions to the OEM customer. We have a strong customer base in the Embedded Broadband business that is expected to transition over time from 4G LTE to 5G technology.
As a leading embedded module vendor, we make it simple for our customers to embed high-speed cellular technologies and manage these devices through our IoT cloud platform. Our portfolio also includes cloud-based remote device and data management capability, as well as support for our embedded application framework called Legato, which is an open source, Linux-based platform.
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, testing 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 logistics services. We also use manufacturing partners to support regional manufacturing requirements and certain 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.
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 products contain 3TG, as a "downstream" company, we are many steps removed from the mining and processing of the 3TG in the supply chain. The materials used in our products come from a large network of suppliers and thus we rely on our suppliers to assist us with our RCOI and due diligence efforts. Our suppliers are also downstream in the supply chain and may have challenges similar to those that we face in undertaking supply chain due diligence.
In 2018, we engaged Claigan Environmental Inc. ("Claigan"), to assist us with data collection and aggregation. Together we worked with our suppliers and other manufacturing partners to collect information about 3TG in our supply chain. Using the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (CMRT), a globally recognized industry-wide 3TG reporting standard for purposes of complying with the Rule, we received
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responses from approximately 84% of our suppliers who were identified as being "in scope" for the purposes of our RCOI. 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 because certain products that we manufacture or contract to manufacture contain 3TG. As a result, we have adopted a Conflict Minerals Policy (available on our website at www.sierrawireless.com/company/corporate-social-responsibility/) and implemented a due diligence program to conform, in all material respects, with the internationally recognized Organisation 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 due diligence framework:
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 due diligence practices in the supply chain
Step 5: Report on supply chain due diligence
This report provides information on the due diligence measures undertaken for 2018 and has not been subject to an independent private sector audit.
Determination of Scope
Sierra Wireless does not own manufacturing facilities for its products and as a result, contracts external manufacturers to produce its products. To determine which products fall within scope for our RCOI and due diligence, the Company conducted a review of its products manufactured during 2018.
Our contract manufacturers were asked to provide an updated list of the suppliers of components used in our products which contain 3TG. Upon receipt of this list, our Conflict Minerals Working Group (the "Working Group") engaged in the following activities to determine the appropriate scope of suppliers subject to our due diligence efforts:
| 1. | Exclude products from recently-acquired companies not yet covered by the Rule. |
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| 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) and provided the resulting list of suppliers to Claigan for data collection purposes. |
OECD Step 1: Establish Strong Company Management Systems
Sierra Wireless has adopted and clearly communicated a company policy for the conflict minerals compliance program, which notes that it uses the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas as its foundation. A public copy is available on our website at https://www.sierrawireless.com/company/corporate-social-responsibility/. This policy is communicated to suppliers when annual conflict minerals data is requested from them. It is also provided to customers whenever Sierra Wireless smelter data is communicated to customers.
Sierra Wireless has structured internal management systems to support supply chain due diligence. 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, a member of senior staff with the necessary competence, knowledge, and experience to oversee supply chain due diligence, who coordinates conflict minerals program activities and reports to senior management and the program’s Steering Committee. All of these resources ensure the successful operation and monitoring of the processes that comprise the Sierra Wireless conflict minerals compliance program.
Our conflict minerals compliance program is integrated into the Company’s existing policy framework and operational processes and procedures to ensure effective management, oversight and implementation. Relevant aspects of conflict minerals compliance are also documented in the following:
| • | Sierra Wireless Conflict Minerals Policy |
| • | Master Quality Agreement |
| • | 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 |
| • | The Global Supply Agreement is a standard form contract that governs the relationship between the Company and its suppliers. |
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| • | Sierra Wireless Conflict Minerals Due Diligence Implementation Handbook |
| • | Sierra Wireless Corporate Website, www.sierrawireless.com |
| • | Grievance Mechanism |
We have a dedicated electronic mailbox used for communications regarding our Conflict Minerals program and a business conduct hotline that provides a mechanism for anyone who has concerns related to business conduct, including concerns related to conflict minerals, to report those concerns in a confidential and, if desired, anonymous manner.
Sierra Wireless has established a system of control and transparency over the mineral supply chain. This system was designed to identify the smelters and refiners in our minerals supply chain. The specific details are found below when discussing OECD Step 2. All records are maintained for a minimum of five years. The system was also designed to strengthen company engagement with suppliers. Sierra Wireless has implemented a reasonable country of origin (“RCOI”) process to collect conflict minerals data on an annual basis. Additionally, conflict minerals compliance is included in all supplier agreements as well as our quality management framework. There is also a program in place to improve the number and quality of supplier responses year over year.
As recommended in the OECD Guidance, Sierra Wireless supports RMI, an industry initiative that audits due diligence activities of smelters and refiners. The RMI is a joint initiative of the Responsible Business Alliance ("RBA") and the Global e-Sustainability Initiative ("GeSI") and has become one of the most utilized and respected resources for companies from a range of industries addressing conflict minerals issues in their supply chains and therefore, as part of our due diligence, we rely on data obtained through our membership in the RMI.
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OECD Step 2: Identify and Assess Risk in the Supply Chain
We designed our RCOI process in accordance with the OECD Guidance. Our RCOI process involved two stages:
| • | Stage 1 - Supplier RCOI (responds to Step 2A of the OECD Guidance) |
| • | Stage 2 - Smelter RCOI (responds to Steps 2B, C, and D of the OECD Guidance) |
For the 2018 reporting period, our RCOI process was executed by Claigan with assistance from the Company’s Working Group.
We have designed our Supplier RCOI around collecting the data provided in the CMRT in order to identify, to the best of our efforts, all of the smelters and refiners in the supply chain. All suppliers subject to our due diligence efforts are requested to submit the most recently available version of the CMRT. Given our downstream position in the 3TG supply chain, we rely on our suppliers to identify smelters and refineries through the CMRT. To gather the smelter and refiner information, we engage suppliers either directly or indirectly through our contract manufacturers. For 2018 we surveyed 253 of our suppliers and received 213 responses.
We review supplier responses for accuracy and completeness. The smelter data provided by suppliers is then aggregated into a single, unique list of smelters. Finally, we review the final smelter list and compare it against industry peers to determine if we have reasonably identified all of the smelters and refiners in our supply chain. Through this process we determined that our suppliers identified 306 3TG smelters and refiners in their supply chains.
The Smelter RCOI was designed to identify the scope of the risk assessment of the 3TG supply chain. We engaged by attempting to contact each smelter that our suppliers identified in our supply chain to determine whether or not they sourced from the Covered Countries. For smelters that confirmed or responded, either directly or through industry associations, that they did not source from the Covered Countries but who were not recognized as conformant to the Responsible Minerals Assurance Process (“RMAP”), we reviewed publicly available information to determine whether there was any contrary evidence that contradicted the smelter’s declaration. In doing so we reviewed sources such as NGO publications, including the Enough Project, Global Witness, Southern Africa Resource Watch and Radio Okapi. We also consulted the most recent United Nations Group of Experts reports on the DRC and performed public internet searches.
If smelters did not respond to our inquiry, we reviewed the same publicly available sources to determine whether there was reason to believe the smelter may have sourced from the Covered Countries during the reporting period.
The smelter RCOI process determined that 40 of the 306 smelters and refiners sourced (or there is some reason to believe they may have sourced) 3TG from the Covered Countries in 2018. Of these 40 smelters and refiners, 35 have been audited and recognized as conformant to the RMAP. The remaining five smelters are considered high-risk (i.e. they confirmed sourcing, or there is some reason to believe they may have sourced from the Covered
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Countries and are not RMAP conformant). All five of the high-risk smelters processed gold, which means that we did not identify any high-risk smelters that process tin, tantalum, or tungsten. We conducted risk mitigation on those five smelters (see OECD Step 3 below) as part of our increased due diligence.
OECD Step 3: Design and Implement a Strategy to Respond to Identified Risks
The findings of our RCOI process were reported to our Vice President, Manufacturing Engineering and Quality, the designated member of senior management, to outline the potential risks identified in the supply chain.
We then devised and adopted a risk management plan. Since the majority of our suppliers reported their smelter data at the company level, we first determined if gold was in the products we bought from the suppliers that listed high risk smelters. If gold was contained in the products we bought from those suppliers, we then leveraged our position in the supply chain to encourage these suppliers to provide smelter data more specific to the products we bought from them.
There were seventeen suppliers that listed high-risk gold smelters in their supply chain. We were able to determine conclusively that thirteen of these seventeen suppliers do not supply us with gold from any of the high-risk smelters. The remaining four suppliers collectively identified the five smelters as referenced above under OECD Step 2. These additional findings are continually monitored to track the performance of risk mitigation.
OECD Step 4: Carry out Independent Third-Party Audit of Due Diligence Practices in the Supply Chain
The OECD Guidance recommends an independent third party audit of smelters and refiners in 3TG supply chains, and we support a recognized and industry-wide program of third-party audits through our RMAP membership. Other industry-wide efforts include those of the London Bullion Market Association (“LBMA”) and the Responsible Jewelry Council (“RJC”).
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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 306 smelters that may have been used to process the 3TG in our products. Those smelters are listed in Annex 1 hereto. We conducted due diligence and risk mitigation activities as outlined above in OECD Steps 2 and 3 with the result that there were five potentially high-risk smelters remaining in our smelter list. As noted below, we will continue to engage with our suppliers regarding any high-risk smelters identified during our risk analysis process.
A publicly available version of our 2018 and prior year reports can be found on our website at https://www.sierrawireless.com/company/corporate-social-responsibility/.
Improvement Measures
For reporting year 2019, we intend to continue improving our due diligence program and risk mitigation efforts through the following:
| • | Continued support of the RMAP third party supplier audit process and, as necessary, mandated supplier audits to validate CMRT data and supplier conflict minerals processes; |
| • | Informing the RMAP of high-risk smelters identified as a result of our due diligence activities; |
| • | Continued engagement with the Company’s strategic suppliers including informing suppliers of high-risk smelters identified during our 2018 risk analysis; |
| • | Improved data collection and due diligence processes through the continued use of a third-party service provider, improved accuracy of our material and supplier lists and incorporation of lessons learned from the 2018 RCOI process; and |
| • | Continued improvement of our communication and understanding of conflict free sourcing criteria. |
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Annex 1: Smelter List
| Metal | Smelter Name | Smelter Country | Smelter Identification |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | CID000058 |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
| Gold | Asahi Pretec Corp. | JAPAN | CID000082 |
| Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
| Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
| Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 |
| Gold | Aurubis AG | GERMANY | CID000113 |
| Gold | Bangalore Refinery | INDIA | CID002863 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
| 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 S.A. | SWITZERLAND | CID000189 |
| Gold | Chimet S.p.A. | ITALY | CID000233 |
| Gold | Chugai Mining | JAPAN | CID000264 |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 |
| Gold | Dowa | JAPAN | CID000401 |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | CID003195 |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | CID000425 |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 |
| Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 |
| Gold | Gujarat Gold Centre | INDIA | CID002852 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
| Gold | Henan Yuguang Gold & Lead Co., Ltd. | CHINA | CID002519 |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
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| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
| Gold | HwaSeong CJ Co., Ltd. | KOREA, REPUBLIC OF | CID000778 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
| Gold | Italpreziosi | ITALY | CID002765 |
| Gold | Japan Mint | JAPAN | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
| 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 | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 |
| Gold | Kazzinc | KAZAKHSTAN | CID000957 |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
| Gold | KGHM Polska MiedŸ Spó³ka Akcyjna | POLAND | CID002511 |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 |
| Gold | L'Orfebre S.A. | ANDORRA | CID002762 |
| Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 |
| Gold | Marsam Metals | BRAZIL | CID002606 |
| Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | CID001161 |
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
| Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 |
| Gold | Morris and Watson | NEW ZEALAND | CID002282 |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | TURKEY | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
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| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
| Gold | PAMP S.A. | SWITZERLAND | CID001352 |
| Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 |
| Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
| Gold | PX Précinox S.A. | SWITZERLAND | CID001498 |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 |
| Gold | Remondis Argentia B.V. | NETHERLANDS | CID002582 |
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | CID002510 |
| Gold | Royal Canadian Mint | CANADA | CID001534 |
| Gold | SAAMP | FRANCE | CID002761 |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 |
| Gold | Safimet S.p.A | ITALY | CID002973 |
| Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 |
| Gold | Sai Refinery | INDIA | CID002853 |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | CID001562 |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | CID001585 |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 |
| Gold | Sudan Gold Refinery | SUDAN | CID002567 |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
| Gold | T.C.A S.p.A | ITALY | CID002580 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
| 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 | Tony Goetz NV | BELGIUM | CID002587 |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 |
| Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 |
| Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | CID002854 |
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
| Gold | Yamakin Co., Ltd. | JAPAN | CID002100 |
| Page | 3 |
| 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 |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | CID000092 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | CID000456 |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 |
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 |
| Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA | CID003191 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
| Tantalum | KEMET Blue Metals | MEXICO | CID002539 |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | CID002568 |
| 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 | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
| Tantalum | NPM Silmet AS | ESTONIA | CID001200 |
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | CID002847 |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | CID002707 |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
| Tantalum | Taki Chemicals | JAPAN | CID001869 |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
| Tin | Alpha | UNITED STATES OF AMERICA | CID000292 |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 |
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 |
| Tin | CV Ayi Jaya | INDONESIA | CID002570 |
| Page | 4 |
| Tin | CV Dua Sekawan | INDONESIA | CID002592 |
| Tin | CV Gita Pesona | INDONESIA | CID000306 |
| Tin | CV United Smelting | INDONESIA | CID000315 |
| Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 |
| Tin | Dowa | JAPAN | CID000402 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
| Tin | Estanho de Rondônia S.A. | BRAZIL | CID000448 |
| Tin | Fenix Metals | POLAND | CID000468 |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
| 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 | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
| Tin | Metallo Belgium N.V. | BELGIUM | CID002773 |
| Tin | Metallo Spain S.L.U. | SPAIN | CID002774 |
| Tin | Mineração Taboca S.A. | BRAZIL | CID001173 |
| Tin | Minsur | PERU | CID001182 |
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
| Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
| Tin | Pongpipat Company Limited | MYANMAR | CID003208 |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
| Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
| Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 |
| Tin | PT Bangka Prima Tin | INDONESIA | CID002776 |
| Tin | PT Bangka Serumpun | INDONESIA | CID003205 |
| Tin | PT Bangka Tin Industry | INDONESIA | CID001419 |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | CID001421 |
| Tin | PT Bukit Timah | INDONESIA | CID001428 |
| Tin | PT DS Jaya Abadi | INDONESIA | CID001434 |
| Tin | PT Inti Stania Prima | INDONESIA | CID002530 |
| Tin | PT Karimun Mining | INDONESIA | CID001448 |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | CID002829 |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | CID002870 |
| Page | 5 |
| Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 |
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
| Tin | PT Panca Mega Persada | INDONESIA | CID001457 |
| Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 |
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 |
| Tin | PT Rajehan Ariq | INDONESIA | CID002593 |
| Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
| Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 |
| Tin | PT Sumber Jaya Indah | INDONESIA | CID001471 |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | CID001477 |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 |
| Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 |
| Tin | PT Tommy Utama | INDONESIA | CID001493 |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | CID002706 |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
| Tin | Soft Metais Ltda. | BRAZIL | CID001758 |
| Tin | Super Ligas | BRAZIL | CID002756 |
| Tin | Thaisarco | THAILAND | CID001898 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
| Tin | Yunnan Tin Company Limited | CHINA | CID002180 |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 |
| Tungsten | ACL Metais Eireli | BRAZIL | CID002833 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | CID003182 |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
| Page | 6 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | CID002543 |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CID002815 |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 |
| Tungsten | Unecha Refractory Metals Plant | RUSSIAN FEDERATION | CID002724 |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | CID002044 |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 |
| Page | 7 |
Annex 2: Countries of Origin
Below is an aggregated list of countries of origin, to the extent known, from which the Smelters identified in Annex 1 are believed to have sourced conflict minerals, based on data available as of April 2, 2019.
| Argentina | Honduras | Russia |
| Australia | India | Rwanda |
| Bolivia | Indonesia | South Africa |
| Botswana | Ivory Coast | South Korea |
| Brazil | Japan | Sudan |
| Bulgaria | Kazakhstan | Sweden |
| Burkina Faso | Kyrgyzstan | Tajikistan |
| Burundi | Laos | Tanzania |
| Canada | Malaysia | Thailand |
| Chile | Mali | Turkey |
| China | Mexico | Uganda |
| Colombia | Mongolia | United Kingdom |
| Democratic Republic of the Congo | Mozambique | United States of America |
| Ethiopia | Namibia | Uzbekistan |
| Fiji | New Zealand | Vietnam |
| Finland | Papua New Guinea | Zambia |
| French Guyana | Peru | Zimbabwe |
| Georgia | Philippines | |
| Ghana | Poland | |
| Guyana | Portugal | |
| Page | 1 |