Exhibit 1.01
CERAGON NETWORKS LTD.
Conflict Minerals Report
For The Year Ended December 31, 2021
A. OVERVIEW
This report has been prepared by Ceragon Networks Ltd. (NASDAQ: CRNT) (herein referred to as “Ceragon,” the “Company,” “we,” “us,” or “our”) pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended. According to the Rule, if a SEC registrant has reason to believe that any of the conflict minerals, including tin, tantalum, tungsten and gold (“Conflict Minerals” or “3TG”), in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”), or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody, and submit a Conflict Minerals Report that includes a description of those due diligence measures.
As part of Ceragon’s commitment to corporate responsibility and respecting human rights in our own operations and global supply chain, Ceragon is committed to complying with the legislation and supports responsible conflict mineral sourcing. Furthermore, due to the potential negative economic and social impacts on the economies of the DRC and the Covered Countries, Ceragon does not seek to completely eliminate sourcing from the DRC or Covered Countries, but rather is dedicated to the responsible sourcing of such minerals, inter alia, as supported by information and/or data from independent third party audits or reports. In addition, it is important to note that, like many other companies, Ceragon does not directly purchase minerals from smelters or other mineral processors, and is several layers removed from these processors within the supply chain. Ceragon also fully recognizes that the minerals supply chain is global and complex, and many product and/or product component suppliers and manufacturers may lack the resources or commercial strength to trace the necessary minerals all the way back to the mine or original source of the ores. Notwithstanding these issues and realities, Ceragon is committed to the responsible sourcing of the necessary Conflict Minerals used in its products, and therefore asks its suppliers to follow the company’s Conflict Minerals Policy, and strives, to a reasonable degree, to conduct a reasonable country of origin inquiry (“RCOI”) on the likely source and chain of custody of the necessary Conflict Minerals used in its products through the resources provided by third party audit bodies, such as (but not necessarily through) the Responsible Minerals Initiative (“RMI”). As such, the company commits resources to ensure compliance with the applicable Conflict Minerals regulations and practices in responsible sourcing of those minerals.
Our Solutions
We are the leading wireless hauling specialist company in terms of unit shipments and global distribution of our business, providing innovative high capacity wireless connectivity solutions to global markets across various industries, mainly wireless (mobile) networks service providers.
Wireless hauling is a means for connecting mobile network sites (e.g. cellular base stations in various architectures) to the rest of the network. It carries information to and from the cellular base stations. It is used when high-speed wireline connectivity to telecom sites (typically fiber optics) is not available or rapid development is required. According to market research, about 45% of global telecom sites are connected to the rest of the network via wireless hauling.
Ceragon’s innovative technology related to the transition from Wireless SDH to Wireless IP, and the further transition to compact multi-core all-outdoor wireless backhaul solutions, assisted in positioning Ceragon as a leader in the global wireless hauling market, and we expect that it would have potentially positioned us to benefit from new wireless generation transitions such as the current 5G evolution.
In preparation for the transition from 4G to 5G technologies, we have begun planning the roll-out of new 5G-supporting products. In 2019, we introduced the market-first “disaggregated wireless hauling” architecture, which allows operators to significantly simplify 5G network deployment and maintenance, as well as reduce of capital and operating expenses. Currently, we are investing in a new chipset which incorporates 8-cores (Octa-core) in a chipset to be incorporated in products expected to be introduced in 2024.
The term ‘wireless hauling’ refers to various types of network connectivity signaling and network protocols which vary in speeds and include (i) backhaul - used in 4G, 5G and earlier generations of mobile networks to send data packets between the network and the base-stations and between the base-stations to other network elements, and (ii) fronthaul - used in 4G and 5G networks to send radio signal values between building blocks of the base station, which can be separated from another across geographic site locations to achieve network efficiencies in some network scenarios.
Wireless hauling offers network operators a cost-efficient alternative to wire-line connectivity between network nodes at different sites, mainly fiber optics. Support for high broadband speeds and very large numbers of devices, means that all value-added services can be supported, while the high reliability of wireless systems provide for lower maintenance costs. Because they require no trenching, wireless hauling links can also be set up much faster and at a fraction of the cost of fiber solutions. On the operator’s side, this translates into an increase in operational efficiency and faster time-to-market, as well as a shorter timetable to achieving new revenue streams.
We provide wireless hauling solutions and services that enable cellular operators and other service providers to build new networks and evolve networks towards 4G and 5G services. The services provided over these networks are: voice, mobile and fixed broadband, Industrial/Machine-to-Machine (M2M), Internet of Things (IoT) connectivity, public safety and other mission critical services. We also provide our solutions for wireless backhaul to other vertical markets such as Internet service providers, public safety, utilities, oil and gas offshore drilling platforms, as well as maritime communications. Our wireless hauling solutions use microwave and millimeter-wave radio technologies to transfer large amounts of telecommunication traffic between wireless 5G, 4G, 3G and other cellular base station technologies (distributed, or centralized with dispersed remote radio heads) and the core of the service provider’s network. We are also a member of industry consortiums of companies, which attempt to better define future technologies in ICT (Information and Communication Technologies) markets, such as Open Networking Foundation (ONF), Metro Ethernet Forum (MEF), European Telecommunications Standards Institute (ETSI), Telecom Infra Project (TIP) and others.
In addition to providing our solutions, we also offer our customers a comprehensive set of turn-key services, including advanced network and radio planning, site survey, solutions development, network rollout, maintenance, wireless hauling network audit and optimization, and training. To enable delivery of turn-key solutions to our customers, in addition to providing roll-out services, we have partnered with other third party providers of technologies complementary to our own. Our offering includes technologies such as: Unlicensed Point-to-Point, Private LTE, Licensed/unlicensed Point-to-Multipoint, IP/MPLS and others. This allows us to better cover our customers’ end-to-end needs and increases the level of stickiness with these customers. Our services include powerful project management tools that streamline deployments of complex wireless networks, thereby reducing time and costs associated with network set-up and allowing a fast time-to-revenue. Our experienced teams can deploy hundreds of wireless hauling links every week, and our rollout project track record includes hundreds of thousands of links already installed and operational with a variety of industry-leading operators.
Designed for any network scenario, including risk-free flexible migration from current and legacy network technologies and architectures to evolving standards and network hauling scenarios, our solutions provide ultra-high speed connectivity at any distance, be it a few kilometers or tens of kilometers, and even longer, over any available spectrum (or combinations of available spectrum bands) and in any site and network architecture. Our solutions support all wireless access technologies, including 5G-NR NSA, 5G-NR SALTE, HSPA, EV-DO, CDMA, W-CDMA, WIFI and GSM as well as Tetra, P.25 and LMR for critical communications. These solutions allow wireless service providers to cost-effectively and seamlessly evolve their networks from a monolithic base-station architecture to an open RAN architecture, utilizing vertical and horizontal disaggregation, allowing them extra flexibility, scalability and efficiency, thereby meeting the increasing demand of a growing number of connections of any type for consumers and enterprises with growing needs for mobile and other multimedia services, and a growing number of machines or IoT devices such as street surveillance devices or meters.
We also provide our solutions to other non-carrier vertical markets such as oil and gas companies, public safety organizations, businesses and public institutions, broadcasters, energy utilities and others that operate their own private communications networks. Our solutions are deployed by more than 460 service providers of all sizes, as well as in more than 1,500 private networks, in more than approximately 155 countries.
Supply Chain
The products that we manufacture are highly complex, typically containing thousands of parts from many suppliers. We have relationships with a vast network of suppliers throughout the world and there are generally multiple tiers in the chain of custody between the 3TG mines or processing facilities, where tungsten, tantalum, tin and gold are extracted and/or processed, and Ceragon. Hence, and as per 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 Due Diligence Guidance”), Ceragon is constituted as a “downstream” company. As such, we must rely on our direct and secondary suppliers to work with their relevant upstream suppliers so that they may provide us with accurate information on the origin of 3TG in the components we purchase, where applicable, by using a template issued by a third party audit body, namely the RMI’s Conflict Minerals Reporting Template (“CMRT”), of at least version 6.01 or higher, to report on the origin, or likely origin, of the 3TG in the components we purchase that are necessary to the functionality or production of our products.
Reasonable Country of Origin Inquiry (RCOI)
Based on the aforementioned risk-based approach, we surveyed one hundred and fifteen (115) suppliers, out of which we received one hundred and six (106) responses. Out of these 106 responses we received from our supply chain inquiry, we identified ninety-seven (97) suppliers whose products may contain 3TG (91.5%) and 9 were found not to use 3TG at their supplies (8.5%). We requested that all identified suppliers provide information to us regarding 3TG existence and relevant smelters or refiners (“SoRs”) with whom they engage, while using the Conflict Minerals Reporting Template (“CMRT”) of at least version 6.01 or higher, developed by independent third party audit body such as the Responsible Minerals Initiative (“RMI”), formerly the Conflict-Free Sourcing Initiative (“CFSI”).
In order to facilitate the implementation of our risk-based approach, Ceragon utilized the services of a third party service provider that assisted in sending relevant communications to our suppliers to explain our expectations regarding compliance and responsible mineral sourcing, while referring suppliers to online training materials, as well as our Conflict Minerals Policy and instructions. We solicited information from suppliers using a template adopted by an independent third-party audit body, the RMI, namely, the CMRT version 6.01 or higher. We received a response rate of 92.7% We reviewed the responses that we received and followed up on inconsistent, incomplete, and inaccurate responses, sending reminders to suppliers that did not respond to our requests for information. We compared the smelters or refiners identified in the surveys provided by our relevant suppliers against the lists of facilities that have received a conflict-free or audit-in-process designation by the RMI’s Responsible Minerals Assurance Process (“RMAP”), formerly the Conflict Free Smelter Program (“CFSP”). Ceragon is a downstream company as indicated above. As such, we source products and components from suppliers, which, in turn, source materials from their sub-tier suppliers. Our supply chain is extensive and complex with many layers of suppliers positioned between ourselves and 3TG smelters or refiners. Due to our extended supply chain, we expect our suppliers to provide us with accurate information concerning the likely sources and chains of custody of 3TG necessary to the functionality or production of our products.
Efforts to Determine Mine or Location of Origin
We have determined that requesting our suppliers to complete a current version of the CMRT (i.e., 6.01 and above) represents our reasonable best efforts to determine the mines or locations of origin of 3TG in our supply chain.
The Company’s efforts to determine the origin of the Conflict Minerals with the greatest possible accuracy consisted of the due diligence measures described in this Conflict Minerals Report.
Smelters or Refiners (“SoR”) and Countries of Origin of 3TG
The vast majority of suppliers from which we requested information responded and provided information through version 6.01 or higher of the RMI’s CMRT.
The Company has attempted, with reasonable best effort, to determine the smelters or refiners that are part of its mineral supply chain, through information provided by its suppliers that sold products or product components to the company in 2021.
Currently, the Company does not have the sufficient information to determine the exact country of origin of the Conflict Minerals used in our products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the DRC or one of the Covered Countries, and do not originate entirely from recycled or scrap sources.
Based on this result, and in order to mitigate the lack of information, the Company conducted supply chain Conflict Minerals due diligence activities and details those activities in this Conflict Minerals Report.
B. DUE DILIGENCE
Design of Due Diligence
Our supply chain due diligence measures were designed to conform, in all material respects, with the due diligence framework presented by The Organization for Economic Co-operation and Development (OECD) in the publication OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and its related supplements for gold, tin, tantalum and tungsten. We designed our due diligence measures according to the recommendations of the OECD Guidance for downstream companies that have no direct relationships with smelters or refiners of necessary Conflict Minerals.
Due Diligence Performed
OECD Step 1: Strong Company Management Systems
Conflict Minerals Policy
We have adopted a Conflict Minerals Policy that expresses our commitment to responsible sourcing and our expectations of suppliers regarding the sourcing of the necessary 3TG in our products, which is publicly available on our website at: https://www.ceragon.com/investors/corporate-governance.
To the extent required by the SEC, we support increased transparency with regards to our sourcing practices, in particular the sourcing of minerals from areas of on-going conflict, such as the Conflict Minerals from the DRC and Covered Countries. We expect our suppliers to adopt similar policies and meet our expectations regarding responsible sourcing and human rights. As a downstream company, our supply chain is highly complex and our manufacturing process is significantly removed from the mining, smelting or refining of conflict minerals. As a result, we expect our suppliers to cooperate with us to provide: (i) the required supply chain due diligence process, in order to facilitate our compliance with the Rule; and (ii) demonstrate processes in place to reasonably assure the origin, or the likely origin, of the necessary Conflict Minerals contained in the products that they provide Ceragon, and that these minerals did not directly or indirectly benefit, to the best of their knowledge, the armed groups in the DRC or one of the Covered Countries.
In addition, our ethical commitment is reflected not only in our Conflict Minerals Policy, but also in our Code of Conduct, which outlines expected behaviors for all of the Company’s stakeholders, as well as our Standards of Business Conduct (see https://www.ceragon.com/investors/corporate-governance) for suppliers that includes our specific approach to human rights, bribery, conflict of interests, insider trading etc. expectations.
Internal Team
We have established an internal team led by the Global Director of Procurement and EVP General Counsel of the Company, responsible for implementing our Conflict Minerals compliance strategy, as well as other team members from our Procurement, Operations and Legal departments. The team assesses progress and discusses further steps regarding implementation of our Conflict Minerals strategy and risk management processes.
Control Systems
As a downstream company, we do not typically have a direct relationship with 3TG smelters or refiners. We do, however, use the RMI Standard Smelter Lists to verify the status of SoRs that have undergone, or are in the process of undergoing, an independent third-party audit on their labor and human rights practices.
We utilize the RMI’s CMRT reporting template, accepting versions 6.01 or higher for the 2021 reporting year, to collect data and information from our suppliers and in order to identify the origins, or likely origins, of the 3TG in our supply chain that is necessary to the functionality or production of products that we manufactured or contracted to manufacture in 2021. As mentioned previously in this report, we also engage a third-party service provider to assist us in in engaging in communication with our suppliers to collect information on the smelters or refiners that process the minerals that may ultimately be assimilated into our products.
We communicate the Company’s due diligence efforts to our customers upon request and to senior management on a periodic basis, in addition to the filing of this report with the SEC.
Maintenance of Records
As per the recommendation in the OECD Guidance and Related Supplements, we retain records and relevant materials for a period of five years.
Supplier Engagement
As part of our supply chain due diligence and in engaging our supply chain on responsible sourcing, we sent notifications to relevant suppliers in 2021 requesting them to complete version 6.01 or higher of the RMI’s CMRT. We also provide training and instructions for completing the CMRT to its relevant suppliers. As stated in our Conflict Minerals Policy, suppliers are expected to implement and communicate policies that promote responsible sourcing and that are consistent with our Conflict Minerals Policy and we expect their direct and indirect suppliers do the same. In addition, our suppliers are expected to establish procedures to facilitate the traceability of the necessary Conflict Minerals in our supply chain.
Many of our supplier purchase contracts have terms of three to five years or more, or consider the volume we purchase as not material (and hence, show less willingness to change their procurement terms), and we may not be able to unilaterally impose new contract terms or flow-down requirements that would otherwise compel these suppliers to support our supply chain due diligence efforts with respect to 3TG content. For suppliers that do not meet our expectations, we reserve the right to contact them and request information regarding the source, or likely source, and chain of custody of the Conflict Minerals in their supply chain, and as we enter into new contracts or renew existing contracts, we negotiate the adding of relevant Conflict Minerals language that requires suppliers to cooperate in identifying the source or the likely source, if any, of 3TG in their supply chain.
Grievance Mechanism
We have internal processes in place that allow all relevant stakeholders to express their concerns about possible improper or unethical business practices or violations of company policies, laws, or regulations. Our Conflict Minerals Policy is available to the public on our website (at https://www.ceragon.com/investors/corporate-governance) and includes a grievance procedure for suppliers and other external parties to contact us should they wish to seek guidance or report concerns regarding Conflict Minerals or responsible sourcing topics.
OECD Step 2: Identifying and Assessing Potential Risks in the Supply Chain
We surveyed approximately 115 suppliers and had a response rate of 92.17%. We surveyed those suppliers in order to identify the 3TG contained in the products they supply us, and to request information in the CMRT regarding the smelters or refiners that process the 3TG and the reasonable countries of origin of the 3TG in their supply chains. The survey was conducted by utilizing version 6.01 or higher of the CMRT and the services of a third-party service provider in order to collect the responses.
We reviewed the responses against the risk criteria development by our internal team as well as the correspondence with our responsible sourcing policy in order to determine the responses that required further engagement and follow-up. The responses included certain incomplete responses as well as inconsistencies within the data reported by those suppliers and we worked with them in an effort to secure revised responses. Smelters or refiners identified by the Company’s suppliers were compared against the list of smelters or refiners that have received a conflict-free or active designation from the RMAP.
OECD Step 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 Step 2 above. The goal of the design and implementation strategy is not to eliminate sourcing from the DRC and Covered Countries, but to encourage participation with the RMI and other third-party audit bodies, where possible.
| • | Our senior management and relevant procurement directors are briefed about our due diligence efforts on a periodic basis. |
| • | We adopted a risk management approach aimed at encouraging responsible sourcing practices, primarily focused on suppliers that may source or process 3TG originating or likely originating in the DRC or Covered Countries. |
| • | The goal of the risk management approach is not to eliminate sourcing from the DRC, but to encourage suppliers to engage in responsible mineral sourcing, as per the Company’s policy. |
| • | We found no instance where it was necessary to escalate risk management efforts, temporarily suspend business or disengage with a supplier due to Conflict Minerals sourcing-related issues. However, certain suppliers were contacted regarding the existence of smelters or refiners that were not identified as compliant with the RMAP or their sourcing facilities are not audited by and independent Third-Party Audit body, such as the RMI. These suppliers were contacted and required to submit a corrective action plan regarding these SoRs to the Company. |
| • | We engage in regular ongoing risk assessment through our suppliers’ annual data submissions, as well as by documenting our reported SoRs and likely Countries of Origin (“COO”). |
| • | Our internal team, led by the Company’s EVP General Counsel and Global Director of Procurement, assesses identified risks and determines follow-up actions, if any. |
OECD Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not typically have a direct relationship with 3TG smelters or refiners reported within our supply chain and therefore do not perform direct audits of these entities. We rely on the efforts of independent Third-Party Audit initiatives, such as the RMI, that conduct validation audits of sourcing and human rights practices among smelters or refiners of the Conflict Minerals.
OECD Step 5: Report On Supply Chain Due Diligence
This Conflict Minerals Report constitutes our annual report on our 3TG due diligence, and is made available on our website at: https://www.ceragon.com/investors/corporate-governance, as well as being filed with the SEC.
C. RESULTS OF ASSESSMENT
The Company sent out 115 survey requests and received 106 responses, amounting to a 92.17% response rate.
Currently, we do not have sufficient information from our suppliers to determine the complete list of the countries of origin of the Conflict Minerals used in our products that were manufactured or that were contracted to manufacture in 2021 or the facilities used to process those Conflict Minerals.
Based on the information provided by the Company’s suppliers and its own due diligence efforts with known smelters or refiners until December 31, 2021, the Company believes that the facilities that may have been used to process the 3TG in the Company products in 2021 include the smelters or refiners listed in Annex I below.
Based on these due diligence efforts, the Company does not have sufficient information to conclusively determine the countries of origin of the 3TG in its products or whether the 3TG in its products originated entirely from recycled or scrap sources. However, based on the information provided by the Company’s relevant direct suppliers, as well as their reported smelters or refiners, which was validated against independent sources, such as the status’ of those SoRs in the RMI’s RMAP program and other sources, the Company believes that the countries of origin of the 3TG contained in its products may include the countries listed in Annex II below.
The charts below summarize the 611 operational smelters and/or refiners and their participation status in the RMAP, as indicated in the compiled data from our due diligence efforts:
In regard to the chart below, please note that:
| - | “Compliant” refers to SoRs that have received a “conflict-free” designation from an independent third party audit program; |
| - | “Active” refers to SoRs that have begun or are currently participating in an independent third-party audit program; |
| - | “Not Active” refers to SoRs that have not begun participating in an independent third-party audit program. |
Manufacturer's response rate:
| 2020 | 2021 | |
| Number of Items/P/N | ||
| Response rate | 90.76% | 92.17% |
| Number of MFR ue | 119 | 115 |
Smelter Compliance status:
| 2020 | 2021 | |
| Verified Conflict Free | 233 (75.0%) | 227 (67.4%) |
| Participating in an audit | 11 (3.5%) | 17 (5.0%) |
| Not Participating | 67 (21.5%) | 93 (27.6%) |
| Total | 311 (100%) | 337 (100%) |
Please note that information gathered from Ceragon’s suppliers is not collected on a continuous, real-time basis, and that, since the information comes from direct and secondary suppliers and independent Third Party Audit programs, Ceragon can only provide reasonable (not absolute) assurance regarding the source and chain of custody of the necessary Conflict Minerals. Nonetheless, the Company continuously strives to improve its processes on an annual basis.
D. ONGOING MITIGATION EFFORTS
Subject to the Rule, we intend to take the following steps to improve the supply chain due diligence and responsible sourcing practices to further mitigate the risk that the 3TG in that could potentially finance or benefit armed groups in the DRC or Covered Countries:
| • | Ensure that new or renewed supplier contracts adhere to the Conflict Minerals requirement in such contracts. |
| • | Continue to send follow-up letters to non-responsive suppliers and to suppliers that source the necessary conflict minerals from the DRC or Covered Countries, i.e. conflict minerals originating from smelters or refiners that are not compliant with RMAP or other independent Third-Party Audit programs. |
| • | Send surveys to suppliers as an annual routine in order to assimilate such routines by our suppliers and allow our suppliers to establish as process that will assure providing a complete response. |
| • | Continue to validate supplier responses using information collected via independent conflict free smelter validation programs such as the Responsible Minerals Initiative’s (RMI) RMAP. |
| • | Strengthen communications with suppliers in order to improve the number of suppliers that respond to the Company’s supply chain surveys and continue to emphasize the importance of this initiative to Ceragon and to encourage their participation. |
Caution Concerning Forward- Looking Statements
This report on Form SD contains “forward-looking statements” within the meaning of the Securities Act of 1933, as amended, or the Securities Act, and the Securities Exchange Act of 1934, as amended, or the Exchange Act, and the safe-harbor provisions of the Private Securities Litigation Reform Act of 1995. Also, documents that we incorporate by reference into this report or annexed to it, including documents that we subsequently file with the Commission, will contain forward-looking statements. Forward-looking statements are those that predict or describe future events, trends and expected results and that do not relate solely to historical matters. We have based these forward-looking statements on our current expectations and projections about future events.
Forward-looking statements can be identified by the use of terminology such as “may,” “will,” “assume,” “expect,” “anticipate,” “estimate,” “continue,” “believe,” “potential,” “possible,” “intend,” and similar expressions or negatives of those expressions that are intended to identify forward-looking statements, although not all forward-looking statements contain these identifying words. All statements contained or incorporated by reference in this report on Form SD or other filings with the SEC regarding our future strategy, future expectations, plans and events, future operations, projected financial position, proposed products, estimated future revenues, projected costs, future prospects, the future of our industry and results that might be obtained by pursuing management’s current plans and objectives, projections of results of operations or of financial condition, are “forward-looking statements”.
You should not place undue reliance on our forward-looking statements because the matters they describe are subject to certain risks, uncertainties and assumptions that are difficult to predict, and they involve known and unknown risks and uncertainties that may cause our actual results, performance or achievements to be materially different from any future results, performance or achievements expressed or implied by such forward-looking statements. Our forward-looking statements are based on the information currently available to us and speak only as of the date on the cover of this report on Form SD, or, in the case of forward-looking statements incorporated by reference, the date of the filing that includes the statement. Over time, our actual results, performance or achievements may differ from those expressed or implied by our forward-looking statements, and such difference might be significant and materially adverse to our security holders. We undertake no obligation to update publicly any forward-looking statements, whether as a result of new information, future events or otherwise.
We have identified some of the important factors that could cause future events to differ from our current expectations and they are described in our Annual Report on Form 20-F for the fiscal year ended December 31, 2021, including without limitation under the captions “Item 3. Key Information - Risk Factors,” the information about us set forth under Item 4. “INFORMATION ON THE COMPANY” and information related to our financial condition under Item 5. “OPERATING AND FINANCIAL REVIEW AND PROSPECTS”, in our 2021 Form 20-F generally, and in other documents that we filed or may file with the Commission, all of which you should review carefully. Please consider our forward-looking statements in light of those risks as you read this report.
Annex I – List of Identified Operating SoRs
| Metal | SOR Name | SOR Country |
| Gold | 8853 s.p.a. | ITALY |
| Gold | ?gussa ?sterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | abington reldan metals, llc | UNITED STATES OF AMERICA |
| Gold | advanced chemical company | UNITED STATES OF AMERICA |
| Gold | african gold refinery | UGANDA |
| Gold | aida chemical industries co., ltd. | JAPAN |
| Gold | al etihad gold llc | UNITED ARAB EMIRATES |
| Gold | al etihad gold refinery dmcc | UNITED ARAB EMIRATES |
| Gold | allgemeine gold-und silberscheideanstalt a.g. | GERMANY |
| Gold | almalyk mining and metallurgical complex (ammc) | UZBEKISTAN |
| Gold | AngloGold Ashanti C?rrego do S?tio Miner??o | BRAZIL |
| Gold | anglogold ashanti corrego do sitio mineracao | BRAZIL |
| Gold | argor-heraeus s.a. | SWITZERLAND |
| Gold | asahi pretec corp. | JAPAN |
| Gold | asahi refining canada ltd. | CANADA |
| Gold | asahi refining usa inc. | UNITED STATES OF AMERICA |
| Gold | asaka riken co., ltd. | JAPAN |
| Gold | atasay kuyumculuk sanayi ve ticaret a.s. | TURKEY |
| Gold | au traders and refiners | SOUTH AFRICA |
| Gold | augmont enterprises private limited | INDIA |
| Gold | AURA-II | UNITED STATES OF AMERICA |
| Gold | aurubis ag | GERMANY |
| Gold | Baiyin Nonferrous Metals Corporation (BNMC) | CHINA |
| Gold | balore refinersga | INDIA |
| Gold | bangalore refinery | INDIA |
| Gold | bangko sentral ng pilipinas (central bank of the philippines) | PHILIPPINES |
| Gold | Bauer Walser AG | GERMANY |
| Gold | boliden ab | SWEDEN |
| Gold | c. hafner gmbh + co. kg | GERMANY |
| Gold | c.i metales procesados industriales sas | COLOMBIA |
| Gold | caridad | MEXICO |
| Gold | ccr refinery - glencore canada corporation | CANADA |
| Gold | CCR Refinery – Glencore Canada Corporation | CANADA |
| Gold | cendres + metaux s.a. | SWITZERLAND |
| Gold | cgr metalloys pvt ltd. | INDIA |
| Gold | Changzhou Chemical Research Institute Co. Ltd. | CHINA |
| Gold | chimet s.p.a. | ITALY |
| Gold | chugai mining | JAPAN |
| Gold | daejin indus co., ltd. | KOREA, REPUBLIC OF |
| Gold | daye non-ferrous metals mining ltd. | CHINA |
| Gold | degussa sonne / mond goldhandel gmbh | GERMANY |
| Gold | dijllah gold refinery fzc | UNITED ARAB EMIRATES |
| Gold | doduco | GERMANY |
| Gold | doduco contacts and refining gmbh | GERMANY |
| Gold | dowa | JAPAN |
| Gold | ds pretech co., ltd. | KOREA, REPUBLIC OF |
| Gold | dsc (do sung corporation) | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | eco-system recycling co., ltd. east plant | JAPAN |
| Gold | eco-system recycling co., ltd. north plant | JAPAN |
| Gold | eco-system recycling co., ltd. north plant | JAPAN |
| Gold | eco-system recycling co., ltd. west plant | JAPAN |
| Gold | elemetal refining, llc | UNITED STATES OF AMERICA |
| Gold | elemetal refining, llc | UNITED STATES OF AMERICA |
| Gold | emirates gold dmcc | UNITED ARAB EMIRATES |
| Gold | Faggi Enrico S.p.A. | ITALY |
| Gold | fidelity printers and refiners ltd. | ZIMBABWE |
| Gold | fujairah gold fzc | UNITED ARAB EMIRATES |
| Gold | Fujairah Gold FZE | UNITED ARAB EMIRATES |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
| Gold | gcc gujrat gold centre pvt. ltd. | INDIA |
| Gold | geib refining corporation | UNITED STATES OF AMERICA |
| Gold | gold coast refinery | GHANA |
| Gold | gold refinery of zijin mining group co., ltd. | CHINA |
| Gold | great wall precious metals co., ltd. of cbpm | CHINA |
| Gold | GUANGDONG HUA JIAN TRADE DO.,LTD | CHINA |
| Gold | guangdong jinding gold limited | CHINA |
| Gold | GUANGDONG JINXIAN GAOXIN CAI LIAO GONG SI | CHINA |
| Gold | Guangdong macro jin precious metal smelting | CHINA |
| Gold | Guangdong MingFa Precious Metal Co.,Ltd | CHINA |
| Gold | Gujarat Gold Centre | INDIA |
| Gold | guoda safina high-tech environmental refinery co., ltd. | CHINA |
| Gold | Hang Seng Technology | CHINA |
| Gold | hangzhou fuchunjiang smelting co., ltd. | CHINA |
| Gold | Harmony Gold Refinery | SOUTH AFRICA |
| Gold | heesung metal ltd. | KOREA, REPUBLIC OF |
| Gold | heimerle + meule gmbh | GERMANY |
| Gold | Henan Yuguang Gold and Lead Co., Ltd | CHINA |
| Gold | heraeus metals hong kong ltd. | CHINA |
| Gold | heraeus precious metals gmbh & co. kg | GERMANY |
| Gold | HeTai Gold Mineral GuangDong Ltd. Co. | CHINA |
| Gold | hunan chenzhou mining co., ltd. | CHINA |
| Gold | hunan guiyang yinxing nonferrous smelting co., ltd. | CHINA |
| Gold | hwaseong cj co., ltd. | KOREA, REPUBLIC OF |
| Gold | Hwasung CJ Co. Ltd | KOREA, REPUBLIC OF |
| Gold | inner mongolia qiankun gold and silver refinery share co., ltd. | CHINA |
| Gold | inovan gmbh | GERMANY |
| Gold | international precious metal refiners | UNITED ARAB EMIRATES |
| Gold | ishifuku metal industry co., ltd. | JAPAN |
| Gold | istanbul gold refinery | TURKEY |
| Gold | italpreziosi | ITALY |
| Gold | jalan & company | INDIA |
| Gold | japan mint | JAPAN |
| Gold | jiangxi copper co., ltd. | CHINA |
| Gold | Jin Jinyin refining company limited | CHINA |
| Gold | Jinlong Copper Co., Ltd. | CHINA |
| Gold | johnson matthey inc. | UNITED STATES OF AMERICA |
| Gold | jsc ekaterinburg non-ferrous metal processing plant | RUSSIAN FEDERATION |
| Gold | jsc uralelectromed | RUSSIAN FEDERATION |
| Gold | jx nippon mining & metals co., ltd. | JAPAN |
| Gold | kaloti precious metals | UNITED ARAB EMIRATES |
| Gold | kazakhmys smelting llc | KAZAKHSTAN |
| Gold | kazzinc | KAZAKHSTAN |
| Gold | kennecott utah copper llc | UNITED STATES OF AMERICA |
| Gold | kghm polska miedz s.a. | POLAND |
| Gold | kghm polska miedz spolka akcyjna | POLAND |
| Gold | kojima chemicals co., ltd. | JAPAN |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | korea zinc co., ltd. | KOREA, REPUBLIC OF |
| Gold | Kosak Seiren | JAPAN |
| Gold | kundan care products ltd. | INDIA |
| Gold | kyrgyzaltyn jsc | KYRGYZSTAN |
| Gold | kyshtym copper-electrolytic plant zao | RUSSIAN FEDERATION |
| Gold | L''azurde Company For Jewelry | SAUDI ARABIA |
| Gold | l'azurde company for jewelry | SAUDI ARABIA |
| Gold | l'orfebre s.a. | ANDORRA |
| Gold | LiBaoJia | CHINA |
| Gold | lingbao gold co., ltd. | CHINA |
| Gold | Lingbao Gold Company Limited | CHINA |
| Gold | lingbao jinyuan tonghui refinery co., ltd. | CHINA |
| Gold | ls-nikko copper inc. | KOREA, REPUBLIC OF |
| Gold | lt metal ltd. | KOREA, REPUBLIC OF |
| Gold | luoyang zijin yinhui gold refinery co., ltd. | CHINA |
| Gold | marsam metals | BRAZIL |
| Gold | materion | UNITED STATES OF AMERICA |
| Gold | matsuda sangyo co., ltd. | JAPAN |
| Gold | metalor technologies (hong kong) ltd. | CHINA |
| Gold | metalor technologies (singapore) pte., ltd. | SINGAPORE |
| Gold | metalor technologies (suzhou) ltd. | CHINA |
| Gold | metalor technologies s.a. | SWITZERLAND |
| Gold | metalor usa refining corporation | UNITED STATES OF AMERICA |
| Gold | metalurgica met-mex penoles s.a. de c.v. | MEXICO |
| Gold | mitsubishi materials corporation | JAPAN |
| Gold | mitsui mining and smelting co., ltd. | JAPAN |
| Gold | mmtc-pamp india pvt., ltd. | INDIA |
| Gold | modeltech sdn bhd | MALAYSIA |
| Gold | morris and watson | NEW ZEALAND |
| Gold | morris and watson | NEW ZEALAND |
| Gold | moscow special alloys processing plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.?. | TURKEY |
| Gold | nadir metal rafineri san. ve tic. a.s. | TURKEY |
| Gold | navoi mining and metallurgical combinat | UZBEKISTAN |
| Gold | nh recytech company | KOREA, REPUBLIC OF |
| Gold | nihon material co., ltd. | JAPAN |
| Gold | Nihon Superior Co., Ltd. | JAPAN |
| Gold | Nyrstar Metals | UNITED STATES |
| Gold | ogussa osterreichische gold- und silber-scheideanstalt gmbh | AUSTRIA |
| Gold | ohura precious metal industry co., ltd. | JAPAN |
| Gold | ojsc "the gulidov krasnoyarsk non-ferrous metals plant" (ojsc krastsvetmet) | RUSSIAN FEDERATION |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
| Gold | ojsc novosibirsk refinery | RUSSIAN FEDERATION |
| Gold | opm | UNITED STATES OF AMERICA |
| Gold | pamp s.a. | SWITZERLAND |
| Gold | pease & curren | UNITED STATES OF AMERICA |
| Gold | penglai penggang gold industry co., ltd. | CHINA |
| Gold | planta recuperadora de metales spa | CHILE |
| Gold | Precious Metals Sales Corp. | UNITED STATES |
| Gold | prioksky plant of non-ferrous metals | RUSSIAN FEDERATION |
| Gold | pt aneka tambang (persero) tbk | INDONESIA |
| Gold | px precinox s.a. | SWITZERLAND |
| Gold | qg refining, llc | UNITED STATES OF AMERICA |
| Gold | rand refinery (pty) ltd. | SOUTH AFRICA |
| Gold | refinery of seemine gold co., ltd. | CHINA |
| Gold | remondis argentia b.v. | NETHERLANDS |
| Gold | remondis pmr b.v. | NETHERLANDS |
| Gold | republic metals corporation | UNITED STATES OF AMERICA |
| Gold | royal canadian mint | CANADA |
| Gold | saamp | FRANCE |
| Gold | sabin metal corp. | UNITED STATES OF AMERICA |
| Gold | safimet s.p.a | ITALY |
| Gold | safina a.s. | CZECHIA |
| Gold | sai refinery | INDIA |
| Gold | samduck precious metals | KOREA, REPUBLIC OF |
| Gold | samwon metals corp. | KOREA, REPUBLIC OF |
| Gold | saxonia edelmetalle gmbh | GERMANY |
| Gold | schone edelmetaal b.v. | NETHERLANDS |
| Gold | sempsa joyeria plateria s.a. | SPAIN |
| Gold | Shan Dong Huangjin | CHINA |
| Gold | Shandon Jin Jinyin Refining Limited | CHINA |
| Gold | Shandong Hengbang Smelter Co.,ltd | CHINA |
| Gold | shandong humon smelting co., ltd. | CHINA |
| Gold | shandong tiancheng biological gold industrial co., ltd. | CHINA |
| Gold | Shandong Yanggu Xiangguang Co. Ltd. | CHINA |
| Gold | shandong zhaojin gold & silver refinery co., ltd. | CHINA |
| Gold | Shangdong Humon Smelting Co., Ltd. | CHINA |
| Gold | Shenzhen Heng Zhong Industry Co.,Ltd. | CHINA |
| Gold | Shenzhen Kuril company | CHINA |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| Gold | shirpur gold refinery ltd. | INDIA |
| Gold | sichuan tianze precious metals co., ltd. | CHINA |
| Gold | singway technology co., ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sino-Platinum Metals Co.,Ltd | CHINA |
| Gold | So Accurate Group, Inc. | UNITED STATES OF AMERICA |
| Gold | soe shyolkovsky factory of secondary precious metals | RUSSIAN FEDERATION |
| Gold | solar applied materials technology corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | sovereign metals | INDIA |
| Gold | state research institute center for physical sciences and technology | LITHUANIA |
| Gold | sudan gold refinery | SUDAN |
| Gold | sumitomo kinzoku kozan k.k. | JAPAN |
| Gold | sumitomo metal mining co., ltd. | JAPAN |
| Gold | sungeel himetal co., ltd. | KOREA, REPUBLIC OF |
| Gold | Super Dragon Technology Co., Ltd | CHINA |
| Gold | t.c.a s.p.a | ITALY |
| Gold | tanaka denshi kogyo k.k | JAPAN |
| Gold | tanaka kikinzoku kogyo k.k. | JAPAN |
| Gold | The Great Wall Gold and Silver Refinery of China | CHINA |
| Gold | the refinery of shandong gold mining co., ltd. | CHINA |
| Gold | tokuriki honten co., ltd. | JAPAN |
| Gold | tongling nonferrous metals group co., ltd. | CHINA |
| Gold | TongLing Nonferrous Metals Group Holdings Co., Ltd. | CHINA |
| Gold | tony goetz nv | BELGIUM |
| Gold | too tau-ken-altyn | KAZAKHSTAN |
| Gold | torecom | KOREA, REPUBLIC OF |
| Gold | umicore brasil ltda. | BRAZIL |
| Gold | umicore precious metals refining hoboken | BELGIUM |
| Gold | umicore precious metals thailand | THAILAND |
| Gold | umicore s.a. business unit precious metals refining | BELGIUM |
| Gold | united precious metal refining, inc. | UNITED STATES OF AMERICA |
| Gold | universal precious metals refining zambia | ZAMBIA |
| Gold | valcambi s.a. | SWITZERLAND |
| Gold | Viagra Di precious metals (Zhaoyuan) Co., Ltd. | CHINA |
| Gold | W.C. Heraeus GmbH | GERMANY |
| Gold | WAM Technologies Taiwan Co.,Ltd. | TAIWAN |
| Gold | western australian mint (t/a the perth mint) | AUSTRALIA |
| Gold | wieland edelmetalle gmbh | GERMANY |
| Gold | Wuzhong Group | CHINA |
| Gold | xstrata | CANADA |
| Gold | yamakin co., ltd. | JAPAN |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
| Gold | yokohama metal co., ltd. | JAPAN |
| Gold | yunnan copper industry co., ltd. | CHINA |
| Gold | Zhaoyuan Li Fu Industrial | CHINA |
| Gold | ZHAOYUAN LIFUSHIYE Co., Ltd | CHINA |
| Gold | Zhe Jiang Guang Yuan Noble Metal Smelting Factory | CHINA |
| Gold | Zhongkuang Gold Industry Co.,LTD | CHINA |
| Gold | Zhongshan Hyper-Toxic Substance Monopolized Co., Ltd. | CHINA |
| Gold | ZHONGSHAN POISON MATERIAL PROPRIETARY CO., LTD | CHINA |
| Gold | zhongyuan gold smelter of zhongjin gold corporation | CHINA |
| Gold | Zhuhai toxic materials Monopoly Ltd. | CHINA |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
| Tantalum | asaka riken co., ltd. | JAPAN |
| Tantalum | changsha south tantalum niobium co., ltd. | CHINA |
| Tantalum | cp metals inc. | UNITED STATES OF AMERICA |
| Tantalum | d block metals, llc | UNITED STATES OF AMERICA |
| Tantalum | duoluoshan | CHINA |
| Tantalum | E.S.R. Electronics | UNITED STATES OF AMERICA |
| Tantalum | exotech inc. | UNITED STATES OF AMERICA |
| Tantalum | f&x electro-materials ltd. | CHINA |
| Tantalum | fir metals & resource ltd. | CHINA |
| Tantalum | ganzhou grand sea w & mo group co ltd | CHINA |
| Tantalum | global advanced metals aizu | JAPAN |
| Tantalum | global advanced metals boyertown | UNITED STATES OF AMERICA |
| Tantalum | guangdong rising rare metals-eo materials ltd. | CHINA |
| Tantalum | guangdong zhiyuan new material co., ltd. | CHINA |
| Tantalum | h.c. starck ltd. | JAPAN |
| Tantalum | h.c. starck ltd. | JAPAN |
| Tantalum | h.c. starck ltd. | JAPAN |
| Tantalum | h.c. starck ltd. | JAPAN |
| Tantalum | h.c. starck ltd. | JAPAN |
| Tantalum | h.c. starck smelting gmbh & co. kg | GERMANY |
| Tantalum | h.c. starck tantalum and niobium gmbh | GERMANY |
| Tantalum | hengyang king xing lifeng new materials co., ltd. | CHINA |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES OF AMERICA |
| Tantalum | jiangxi dinghai tantalum & niobium co., ltd. | CHINA |
| Tantalum | jiangxi tuohong new raw material | CHINA |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA |
| Tantalum | jiujiang jinxin nonferrous metals co., ltd. | CHINA |
| Tantalum | jiujiang nonferrous metals smelting company limited | CHINA |
| Tantalum | jiujiang tanbre co., ltd. | CHINA |
| Tantalum | jiujiang zhongao tantalum & niobium co., ltd. | CHINA |
| Tantalum | kemet blue metals | MEXICO |
| Tantalum | kemet blue powder | UNITED STATES OF AMERICA |
| Tantalum | kemet blue powder | UNITED STATES OF AMERICA |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
| Tantalum | lsm brasil s.a. | BRAZIL |
| Tantalum | metallurgical products india pvt., ltd. | INDIA |
| Tantalum | mineracao taboca s.a. | BRAZIL |
| Tantalum | mitsui mining and smelting co., ltd. | JAPAN |
| Tantalum | ningxia orient tantalum industry co., ltd. | CHINA |
| Tantalum | Now known as Meta Materials | NORTH MACEDONIA |
| Tantalum | npm silmet as | ESTONIA |
| Tantalum | Plansee SE Liezen | AUSTRIA |
| Tantalum | Plansee SE Reutte | AUSTRIA |
| Tantalum | power resources ltd. | NORTH MACEDONIA |
| Tantalum | prg dooel | NORTH MACEDONIA |
| Tantalum | quantumclean | UNITED STATES OF AMERICA |
| Tantalum | resind industria e comercio ltda. | BRAZIL |
| Tantalum | rfh tantalum smeltery co., ltd./yanling jincheng tantalum & niobium co., ltd. | CHINA |
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | CHINA |
| Tantalum | solikamsk magnesium works oao | RUSSIAN FEDERATION |
| Tantalum | taki chemical co., ltd. | JAPAN |
| Tantalum | taki chemicals | JAPAN |
| Tantalum | taniobis co., ltd. | |
| Tantalum | taniobis japan co., ltd. | |
| Tantalum | telex metals | UNITED STATES OF AMERICA |
| Tantalum | Tranzact, Inc. | UNITED STATES OF AMERICA |
| Tantalum | ulba metallurgical plant jsc | KAZAKHSTAN |
| Tantalum | xinxing haorong electronic material co., ltd. | CHINA |
| Tantalum | yanling jincheng tantalum & niobium co., ltd. | CHINA |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | yichun jin yang rare metal co., ltd. | CHINA |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA |
| Tin | 5NPLUS UK Ltd | UNITED KINGDOM |
| Tin | alpha | UNITED STATES OF AMERICA |
| Tin | alpha metals korea ltd. | UNITED STATES OF AMERICA |
| Tin | An Thai Minerals Co., Ltd. | VIET NAM |
| Tin | an vinh joint stock mineral processing company | VIET NAM |
| Tin | Angelcast Enterprise Co., Ltd. | CHINA |
| Tin | asahi pretec | JAPAN |
| Tin | Asahiseiren Co.,Ltd | JAPAN |
| Tin | Aurubis Netherlands | NETHERLANDS |
| Tin | Brinkmann Chemie AG | GERMANY |
| Tin | chenzhou yunxiang mining and metallurgy co., ltd. | CHINA |
| Tin | chifeng dajingzi tin industry co., ltd. | CHINA |
| Tin | China Al | CHINA |
| Tin | china tin group co., ltd. | CHINA |
| Tin | Chongqing Qingfeng | CHINA |
| Tin | cnmc (guangxi) pgma co., ltd. | CHINA |
| Tin | Cooper Santa | BRAZIL |
| Tin | Cooperativa Metalurgica de Rond?nia Ltda. | BRAZIL |
| Tin | Cooperativa Metalurgica de Rondonia Ltda. | BRAZIL |
| Tin | cv ayi jaya | INDONESIA |
| Tin | cv dua sekawan | INDONESIA |
| Tin | CV Duta Putra Bangka | INDONESIA |
| Tin | cv gita pesona | INDONESIA |
| Tin | CV Makmur Jaya | INDONESIA |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | cv tiga sekawan | INDONESIA |
| Tin | cv united smelting | INDONESIA |
| Tin | cv venus inti perkasa | INDONESIA |
| Tin | dongguan ciexpo environmental engineering co., ltd. | CHINA |
| Tin | dowa | JAPAN |
| Tin | electro-mechanical facility of the cao bang minerals & metallurgy joint stock company | VIET NAM |
| Tin | em vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | empresa metal?rgica vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | empressa nacional de fundiciones (enaf) | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | enaf | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Estanho de Rond?nia S.A. | BRAZIL |
| Tin | estanho de rondonia s.a. | BRAZIL |
| Tin | Feinh?tte Halsbr?cke GmbH | GERMANY |
| Tin | fenix metals | POLAND |
| Tin | Fuji Metal Mining Corp. | JAPAN |
| Tin | FUJII MANUFACTURING CO. ,LTD | JAPAN |
| Tin | Galva-Metall GmbH | GERMANY |
| Tin | Ge Jiu Trading Company | CHINA |
| Tin | gejiu city fuxiang industry and trade co., ltd. | CHINA |
| Tin | gejiu fengming metallurgy chemical plant | CHINA |
| Tin | gejiu jinye mineral company | CHINA |
| Tin | gejiu kai meng industry and trade llc | CHINA |
| Tin | gejiu non-ferrous metal processing co., ltd. | CHINA |
| Tin | GEJIU YE LIAN CHANG | CHINA |
| Tin | Gejiu Yunxi Group Corp. | CHINA |
| Tin | gejiu yunxin nonferrous electrolysis co., ltd. | CHINA |
| Tin | gejiu zili mining and metallurgy co., ltd. | CHINA |
| Tin | guangdong hanhe non-ferrous metal co., ltd. | CHINA |
| Tin | Guangxi Nonferrous Metals Group | CHINA |
| Tin | Guangxi Pinggui PGMA Co. Ltd. | CHINA |
| Tin | Guangxi Zhongshan Jin Yi Smelting Co., Ltd. | CHINA |
| Tin | guanyang guida nonferrous metal smelting plant | CHINA |
| Tin | Hongqiao Metals (Kunshan) Co., Ltd. | CHINA |
| Tin | huichang hill tin industry co., ltd. | CHINA |
| Tin | huichang jinshunda tin co., ltd. | CHINA |
| Tin | Hunan Xianghualing tin | CHINA |
| Tin | indonesian state tin corporation mentok smelter | INDONESIA |
| Tin | Jau Janq Enterprise Co. Ltd. | TAIWAN |
| Tin | jiangxi ketai advanced material co., ltd. | CHINA |
| Tin | jiangxi nanshan | CHINA |
| Tin | jiangxi nanshan | CHINA |
| Tin | jiangxi new nanshan technology ltd. | CHINA |
| Tin | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tin | JU TAI INDUSTRIAL CO.,LTD. | CHINA |
| Tin | Kiyomine Metal Industry Co.,LTD | JAPAN |
| Tin | kundur smelter | INDONESIA |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA |
| Tin | luna smelter, ltd. | RWANDA |
| Tin | ma'anshan weitai tin co., ltd. | CHINA |
| Tin | magnu's minerais metais e ligas ltda. | BRAZIL |
| Tin | malaysia smelting corporation (msc) | MALAYSIA |
| Tin | manas metallurgical | INDIA |
| Tin | Materials Eco-Refining CO.LTD | JAPAN |
| Tin | melt metais e ligas s.a. | BRAZIL |
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA |
| Tin | metallic resources, inc. | UNITED STATES OF AMERICA |
| Tin | metallo belgium n.v. | BELGIUM |
| Tin | Metallo Chimique | BELGIUM |
| Tin | metallo spain s.l.u. | SPAIN |
| Tin | Metallo-Chimique N.V. | BELGIUM |
| Tin | Minchai Metal Indust | TAIWAN |
| Tin | Minchali Metal Industry Co., Ltd. | TAIWAN |
| Tin | minera??o taboca s.a. | BRAZIL |
| Tin | mineracao taboca s.a. | BRAZIL |
| Tin | Ming Li Jia smelt Metal Factory | CHINA |
| Tin | Mingtai | CHINA |
| Tin | minsur | PERU |
| Tin | mitsubishi materials corporation | JAPAN |
| Tin | modeltech sdn bhd | MALAYSIA |
| Tin | Morigin Company | JAPAN |
| Tin | nghe tinh non-ferrous metals joint stock company | VIET NAM |
| Tin | Norte?a de Metales, SA | SPAIN |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| Tin | o.m. manufacturing (thailand) co., ltd. | THAILAND |
| Tin | o.m. manufacturing philippines, inc. | PHILIPPINES |
| Tin | omsa | BOLIVIA |
| Tin | operaciones metalurgicas s.a. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Phoenix Metal Ltd. | RWANDA |
| Tin | pongpipat company limited | MYANMAR |
| Tin | precious minerals and smelting limited | INDIA |
| Tin | PT Alam Lestari Kencana | INDONESIA |
| Tin | pt aries kencana sejahtera | INDONESIA |
| Tin | pt artha cipta langgeng | INDONESIA |
| Tin | pt atd makmur mandiri jaya | INDONESIA |
| Tin | pt babel inti perkasa | INDONESIA |
| Tin | pt babel surya alam lestari | INDONESIA |
| Tin | PT Bangka Kudai Tin | INDONESIA |
| Tin | pt bangka prima tin | INDONESIA |
| Tin | PT Bangka Putra Karya | INDONESIA |
| Tin | pt bangka serumpun | INDONESIA |
| Tin | pt bangka serumpun | INDONESIA |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
| Tin | pt bangka tin industry | INDONESIA |
| Tin | pt belitung industri sejahtera | INDONESIA |
| Tin | PT BilliTin Makmur Lestari | INDONESIA |
| Tin | pt bukit timah | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | pt ds jaya abadi | INDONESIA |
| Tin | pt eunindo usaha mandiri | INDONESIA |
| Tin | PT Fang Di MulTindo | INDONESIA |
| Tin | PT HP Metals Indonesia | INDONESIA |
| Tin | pt inti stania prima | INDONESIA |
| Tin | PT Justindo | INDONESIA |
| Tin | pt karimun mining | INDONESIA |
| Tin | pt kijang jaya mandiri | INDONESIA |
| Tin | PT KOBA TIN | INDONESIA |
| Tin | pt lautan harmonis sejahtera | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | pt mitra stania prima | INDONESIA |
| Tin | pt mitra sukses globalindo | INDONESIA |
| Tin | PT O.M. Indonesia | INDONESIA |
| Tin | pt panca mega persada | INDONESIA |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA |
| Tin | pt premium tin indonesia | INDONESIA |
| Tin | pt prima timah utama | INDONESIA |
| Tin | pt rajawali rimba perkasa | INDONESIA |
| Tin | pt rajehan ariq | INDONESIA |
| Tin | pt refined bangka tin | INDONESIA |
| Tin | pt sariwiguna binasentosa | INDONESIA |
| Tin | PT Seirama Tin investment | INDONESIA |
| Tin | pt stanindo inti perkasa | INDONESIA |
| Tin | pt sukses inti makmur | INDONESIA |
| Tin | pt sumber jaya indah | INDONESIA |
| Tin | pt tambang timah | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
| Tin | pt timah tbk kundur | INDONESIA |
| Tin | pt timah tbk mentok | INDONESIA |
| Tin | pt tinindo inter nusa | INDONESIA |
| Tin | PT Tirus Putra Mandiri | INDONESIA |
| Tin | pt tommy utama | INDONESIA |
| Tin | PT Wahana Perkit Jaya | INDONESIA |
| Tin | PT Yinchendo Mining Industry | INDONESIA |
| Tin | resind ind e com ltda. | BRAZIL |
| Tin | Resind Ind?stria e Com?rcio Ltda. | BRAZIL |
| Tin | resind industria e comercio ltda. | BRAZIL |
| Tin | Rohm und Haas | GERMANY |
| Tin | rui da hung | TAIWAN, PROVINCE OF CHINA |
| Tin | S. Izaguirre | SPAIN |
| Tin | Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co. Ltd. | CHINA |
| Tin | Shapiro | UNITED STATES |
| Tin | shen zhen qi xiang da hua gong gong si | CHINA |
| Tin | Shenzhen Hong Chang Metal Manufacturing Factory | CHINA |
| Tin | Sichuan Guanghan Jiangnan casting smelters | CHINA |
| Tin | SIGMA TIN ALLOY CO., LTD | CHINA |
| Tin | smelter not yet identified | N/A |
| Tin | soft metais ltda. | BRAZIL |
| Tin | Solar Applied materials | TAIWAN |
| Tin | Spectro Alloys Corp | UNITED STATES |
| Tin | super ligas | BRAZIL |
| Tin | SUZHOU NUONENGDA CHEMICAL CO.,LTD | CHINA |
| Tin | Taicang City Nancang Metal Material Co.,Ltd | CHINA |
| Tin | Taiwan high-tech Co., Ltd. | TAIWAN |
| Tin | Taiwan qinggao qiye you xian gong si | TAIWAN |
| Tin | Taiwan's lofty Enterprises Ltd. | TAIWAN |
| Tin | thai nguyen mining and metallurgy co., ltd. | VIET NAM |
| Tin | thailand smelting & refining co ltd | THAILAND |
| Tin | thaisarco | THAILAND |
| Tin | Tianshui ling bo technology co., Ltd | CHINA |
| Tin | TIN PLATING GEJIU | CHINA |
| Tin | tin technology & refining | UNITED STATES OF AMERICA |
| Tin | TOP-TEAM TECHNOLOGY (SHENZHEN) LIMITED | CHINA |
| Tin | tuyen quang non-ferrous metals joint stock company | VIET NAM |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | Wang Yu Manufacturing Co. Ltd. | CHINA |
| Tin | white solder metalurgia e minera??o ltda. | BRAZIL |
| Tin | white solder metalurgia e mineracao ltda. | BRAZIL |
| Tin | WONIL METAL Co., Ltd. | KOREA, REPUBLIC OF |
| Tin | Wu Xi Shi Yi Zheng Ji Xie She Bei Company | CHINA |
| Tin | WUJIANG CITY LUXE TIN FACTORY | CHINA |
| Tin | Wuxi Lantronic Electronic Co Ltd | CHINA |
| Tin | Xianghualing Tin Minerals | CHINA |
| Tin | Xin Furukawa Metal ( Wuxi ) Co., Ltd. | CHINA |
| Tin | XURI | CHINA |
| Tin | Yao Zhang | CHINA |
| Tin | YH(Yunnan) | CHINA |
| Tin | Yifeng Tin | CHINA |
| Tin | Yuecheng Tin com.,LTD | CHINA |
| Tin | yunan gejiu yunxin electrolyze limited | CHINA |
| Tin | yunnan chengfeng non-ferrous metals co., ltd. | CHINA |
| Tin | Yunnan Chengo Electric Smelting Plant | CHINA |
| Tin | Yunnan Copper Zinc Industry Co., Ltd. | CHINA |
| Tin | Yunnan Industrial Co., Ltd. | CHINA |
| Tin | yunnan tin company limited | CHINA |
| Tin | Yunnan Xi YE | CHINA |
| Tin | yunnan yunfan non-ferrous metals co., ltd. | CHINA |
| Tin | Zhuhai Quanjia | CHINA |
| Tungsten | a.l.m.t. corp. | JAPAN |
| Tungsten | a.l.m.t. tungsten corp. | JAPAN |
| Tungsten | acl metais eireli | BRAZIL |
| Tungsten | albasteel industria e comercio de ligas para fundicao ltd. | BRAZIL |
| Tungsten | asia tungsten products vietnam ltd. | VIET NAM |
| Tungsten | chenzhou diamond tungsten products co., ltd. | CHINA |
| Tungsten | china molybdenum co., ltd. | CHINA |
| Tungsten | chongyi zhangyuan tungsten co., ltd. | CHINA |
| Tungsten | cnmc (guangxi) pgma co., ltd. | CHINA |
| Tungsten | cp metals inc. | UNITED STATES OF AMERICA |
| Tungsten | cronimet brasil ltda | BRAZIL |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Tungsten | fujian ganmin raremetal co., ltd. | CHINA |
| Tungsten | fujian jinxin tungsten co., ltd. | CHINA |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA |
| Tungsten | ganzhou haichuang tungsten co., ltd. | CHINA |
| Tungsten | ganzhou huaxing tungsten products co., ltd. | CHINA |
| Tungsten | ganzhou jiangwu ferrotungsten co., ltd. | CHINA |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
| Tungsten | ganzhou seadragon w & mo co., ltd. | CHINA |
| Tungsten | ganzhou yatai tungsten co., ltd. | CHINA |
| Tungsten | gem co., ltd. | CHINA |
| Tungsten | global tungsten & powders corp. | UNITED STATES OF AMERICA |
| Tungsten | guangdong xianglu tungsten co., ltd. | CHINA |
| Tungsten | h.c. starck smelting gmbh & co. kg | GERMANY |
| Tungsten | h.c. starck tungsten gmbh | GERMANY |
| Tungsten | hunan chenzhou mining co., ltd. | CHINA |
| Tungsten | hunan chuangda vanadium tungsten co., ltd. wuji | CHINA |
| Tungsten | hunan chunchang nonferrous metals co., ltd. | CHINA |
| Tungsten | hunan litian tungsten industry co., ltd. | CHINA |
| Tungsten | hydrometallurg, jsc | RUSSIAN FEDERATION |
| Tungsten | japan new metals co., ltd. | JAPAN |
| Tungsten | jiangwu h.c. starck tungsten products co., ltd. | CHINA |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
| Tungsten | jiangxi gan bei tungsten co., ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao''an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | jiangxi minmetals gao'an non-ferrous metals co., ltd. | CHINA |
| Tungsten | jiangxi tonggu non-ferrous metallurgical & chemical co., ltd. | CHINA |
| Tungsten | jiangxi xianglu tungsten co., ltd. | CHINA |
| Tungsten | jiangxi xinsheng tungsten industry co., ltd. | CHINA |
| Tungsten | jiangxi xiushui xianggan nonferrous metals co., ltd. | CHINA |
| Tungsten | jiangxi yaosheng tungsten co., ltd. | CHINA |
| Tungsten | jsc "kirovgrad hard alloys plant" | RUSSIAN FEDERATION |
| Tungsten | kennametal fallon | UNITED STATES OF AMERICA |
| Tungsten | kennametal huntsville | UNITED STATES OF AMERICA |
| Tungsten | kgets co., ltd. | KOREA, REPUBLIC OF |
| Tungsten | lianyou metals co., ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | malipo haiyu tungsten co., ltd. | CHINA |
| Tungsten | masan tungsten chemical llc (mtc) | VIET NAM |
| Tungsten | moliren ltd. | RUSSIAN FEDERATION |
| Tungsten | niagara refining llc | UNITED STATES OF AMERICA |
| Tungsten | npp tyazhmetprom llc | RUSSIAN FEDERATION |
| Tungsten | nui phao h.c. starck tungsten chemicals manufacturing llc | VIET NAM |
| Tungsten | philippine chuangxin industrial co., inc. | PHILIPPINES |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM |
| Tungsten | south-east nonferrous metal company limited of hengyang city | CHINA |
| Tungsten | taniobis gmbh | |
| Tungsten | taniobis smelting gmbh & co. kg | |
| Tungsten | tejing (vietnam) tungsten co., ltd. | VIET NAM |
| Tungsten | unecha refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | vietnam youngsun tungsten industry co., ltd. | VIET NAM |
| Tungsten | wolfram bergbau und hutten ag | AUSTRIA |
| Tungsten | Wolfram Company CJSC | RUSSIAN FEDERATION |
| Tungsten | woltech korea co., ltd. | KOREA, REPUBLIC OF |
| Tungsten | xiamen tungsten co., ltd. | CHINA |
| Tungsten | xiamen tungsten co., ltd. | CHINA |
| Tungsten | xinfeng huarui tungsten & molybdenum new material co., ltd. | CHINA |
| Tungsten | xinhai rendan shaoguan tungsten co., ltd. | CHINA |
| Tungsten | Zhuzhou Cemented Carbide Group Co Ltd | CHINA |
Annex II –Reported Country of Origin
Based on our due diligence, the above smelters or refiners may process Conflict Minerals from one or more of the following countries of origin:
| Reported Smelter or Refiner Country |
| ANDORRA |
| AUSTRALIA |
| AUSTRIA |
| BELGIUM |
| BOLIVIA |
| BOLIVIA (PLURINATIONAL STATE OF) |
| BRAZIL |
| CANADA |
| CHILE |
| CHINA |
| COLOMBIA |
| CZECHIA |
| ESTONIA |
| FRANCE |
| GERMANY |
| GHANA |
| INDIA |
| INDONESIA |
| ITALY |
| JAPAN |
| KAZAKHSTAN |
| KOREA, REPUBLIC OF |
| KYRGYZSTAN |
| LITHUANIA |
| MALAYSIA |
| MAURITANIA |
| MEXICO |
| MYANMAR |
| N/A |
| NETHERLANDS |
| NEW ZEALAND |
| NORTH MACEDONIA |
| NORTH MACEDONIA, REPUBLIC OF |
| NORWAY |
| PERU |
| PHILIPPINES |
| POLAND |
| RUSSIAN FEDERATION |
| RWANDA |
| SAUDI ARABIA |
| SINGAPORE |
| SOUTH AFRICA |
| SPAIN |
| SUDAN |
| SWEDEN |
| SWITZERLAND |
| TAIWAN |
| TAIWAN, PROVINCE OF CHINA |
| THAILAND |
| TURKEY |
| UGANDA |
| UNITED ARAB EMIRATES |
| UNITED STATES |
| UNITED STATES OF AMERICA |
| UZBEKISTAN |
| VIET NAM |
| ZAMBIA |
| ZIMBABWE |