EX-1.01 (Exhibit 1.01)
Conflict Minerals Report of Ormat Technologies, Inc.
For the Year Ended December 31, 2022
Introduction:
We are a Delaware corporation, whose shares of common stock are listed on the New York Stock Exchange and on the Tel Aviv Stock Exchange and are registered with the Securities and Exchange Commission (the "SEC").
We are a leading vertically integrated company that is primarily engaged in the geothermal energy power business. Ormat is leveraging its core capabilities and global presence to expand its activity in recovered energy generation and into different energy storage services and solar photovoltaic (PV) (including hybrid geothermal and solar PV as well as energy storage plus Solar PV). Ormat aims to become a leading global provider of renewable energy and has adopted a strategic plan to focus on several key initiatives to expand its business.
This is the Conflict Minerals Report (this "Report") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the reporting period from January 1, 2022 to December 31, 2022, which has been prepared in accordance with Rule 13p-1 (“Rule 13p-1”), promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Rule 13p-1 requires every registrant that files reports with the SEC under Sections 13(a) or 15(d) of the Exchange Act to disclose certain information when the registrant manufactures or contracts to manufacture products and when the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The specified minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, the “Conflict Minerals” or “3TG”), that originate, or are likely originate, in the Democratic Republic of the Congo (the “DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).
As part of Ormat's sustainability approach, our Supplier Code of Conduct and Code of Business Conduct and Ethics outlines the Company‘s overall principles and commitments to legal compliance, ethical conduct, human rights, anti-corruption, labor rights and environmental protection. These high expectations extend to Ormat's partners, subcontractors and suppliers. We have adopted a policy (the “Conflict Minerals Policy”) with respect to our sourcing of Conflict Minerals, which was developed in accordance with the Organization for Economic Co-operation and Development (“OECD”) guidance, and we implement a comprehensive Conflict Minerals program aimed to ensure responsible sourcing. Our Conflict Minerals Policy is available at https://www.ormat.com/en/company/engagement/view/?ContentID=9199.
Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in Rule 13p-1 and Form SD.
1. | Overview |
Company Overview
Ormat and its subsidiaries currently conduct business activities in the following three business segments:
● | Electricity Segment: In this segment, we develop, build, own and operate geothermal, solar PV and recovered energy-based power plants in the United States and geothermal power plants in other countries around the world and sell the electricity they generate. | |
● | Product Segment: In this segment, we design, manufacture and sell equipment for geothermal and recovered energy-based electricity generation and provide services relating to the engineering, procurement and construction of geothermal, and recovered energy-based power plants. | |
● | Energy Storage Segment: In this segment, we own and operate grid connected In Front of the Meter (IFM) BESS facilities, which provide capacity, energy and ancillary services directly to the electric grid. |
Our customers for the Product segment are contractors, geothermal power plant owners and geothermal power plant developers and operators.
For more information about Ormat, please visit www.ormat.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein.
Supply Chain
In accordance with applicable SEC rules, we conducted due diligence on the source and chain of custody of the Conflict Minerals used in our Product Segment. We concluded that no such examination is necessary with respect to the Electricity Segment or the Energy Storage Segment because neither of these segments involves the offer of products by the Company to third parties for consideration.
In connection with our manufacturing activities in the Product Segment, we identified certain Conflict Minerals that are used by us and that are necessary to the functionality and production of our products with regards to the following raw materials or components: steel (low and high grade), electronic cards and electronic cables (including tin plating). These materials are purchased from our network of suppliers. As a downstream company that does not work directly with the smelters or refiners of the necessary Conflict Minerals, we work with our large network of international suppliers to obtain information on the likely source and chain of custody of those necessary Conflict Minerals and often there are multiple tiers between the 3TG mines and our direct suppliers. Therefore, we rely on our direct Tier 1 suppliers to cooperate with us and work with their own upstream suppliers or subcontractors to provide us with information on the origin of the 3TG in the components we purchase from them that are necessary to the functionality or production of our products. In order to overcome certain challenges in receiving accurate information from a complex supply chain, Ormat has communicated its Conflict Minerals Policy to our suppliers, and has adopted the Responsible Minerals Initiative's ("RMI") reporting template for surveying suppliers, i.e. the Conflict Minerals Reporting Template ("CMRT") of at least version 6.01 or above.
2. | Reasonable Country of Origin Inquiry (RCOI) |
Ormat has conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the necessary Conflict Minerals originated, or likely originated, in the DRC or Covered Countries or originated entirely from "recycled or scrap sources" (as such terms are defined in Rule 13p-1). In parallel, we conduct due diligence on our mineral supply chain in order to investigate, to a reasonable degree of accuracy, the likely source and chain of custody of the necessary Conflict Minerals used in our products or product components that is sourced from our global network of suppliers.
As part of our RCOI, we employed several methods to assess whether the necessary Conflict Minerals in our products originated, or likely originated, in the DRC or the Covered Countries, including the following:
● | Conducted an internal assessment and analysis of our products manufactured or contracted to manufacture in 2022 to determine which products contain or may contain Conflict Minerals that are necessary to the functionality or production of those products. | |
● | Compiled a list of applicable suppliers based on relevant product categories that Ormat purchased from during the calendar year 2022, which list was issued using the Ormat Management System (“OMS”) by information technology developers and according to the criteria defined by the OMS manager and the purchasing manager. For calendar year 2022, the list included a total of 1,001 suppliers. Each supplier has a "Purchase Types" field, which contains one of the following values: Services, BOM, Office supplier, Goods and Capital Expenditure. Only the suppliers with "BOM" values in the "Purchase Types" field were applicable for the RCOI under Rule 13p-1. | |
● | In order to identify and assess risks in the supply chain, we undertook a risk-based approach and engaged the suppliers representing approximately 90% of our 2022 expenditures on procurement for the Product Segment. On that basis, Ormat's final direct Tier 1 suppliers list ("relevant suppliers") included a total of 103 suppliers for the calendar year 2022 supply chain inquiry. | |
● | Contracted a third-party service provider to assist us with the survey of suppliers. Through this third-party service provider, we sent letters to our relevant suppliers to explain Rule 13p-1 and to refer the suppliers to online training materials and instructions. | |
● | Solicited information from our relevant suppliers of raw materials and components of products using the standard template of the independent third-party audit body, the Responsible Minerals Initiative (“RMI”), known as the Conflict Minerals Reporting Template (“CMRT”). We requested that our suppliers provide at least version 6.01 of the CMRT. |
● | Reviewed the responses that we received and followed up on inconsistent, incomplete, and inaccurate responses. We sent reminders to suppliers who did not respond to our requests for information or to suppliers whose responses required further clarification, as per the expectations noted above. We compared information received from our direct suppliers on their relevant smelters or refiners against the list of facilities that have been validated by RMAP, receiving a "conformant" or "active" status, as well as the documented country of origin information as provided in the declarations from the suppliers. The complete list of smelters or refiners identified in the scope of our supply chain inquiry is included as Annex 1 hereto and the complete list of counties of origin, or likely countries of origin, to the best of our knowledge, is included in Annex 2 hereto. |
Currently, we do not have sufficient information from our suppliers to determine the complete list of countries 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 Covered Countries or are not entirely from recycled or scrap sources.
Based on these results, Ormat conducted due diligence activities and described these activities in this Report.
3. | Due Diligence Framework |
We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the 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”). We design our due diligence measures according to the recommendations of the OECD Due Diligence Guidance for downstream companies that have no direct relationships to smelters or refiners.
4. | Due Diligence Measures |
Our due diligence efforts for the reporting period from January 1, 2022 to December 31, 2022 included the following steps as prescribed by the OECD Due Diligence Guidance:
4.1 | Establish strong Company management systems for Conflict Minerals supply chain due diligence and reporting compliance |
The Company implemented the following measures:
● | Continued operating a cross-functional Conflict Minerals steering committee comprised of representatives from procurement, legal and finance departments to direct the overall efforts of the Conflict Minerals compliance program, with the Senior Vice President of Finance as the process owner. |
● | Continued to implement our Conflict Minerals Policy with respect to sourcing of minerals from the DRC and the Covered Countries. Our Conflict Minerals Policy provides further clarification to the principles of the Code of Conduct and Ormat's Human Rights Approach, as outlined in our Human Rights & Labor Policy, regarding illegal trade of natural resources and promotes the procurement of minerals from credible and conflict-free sources. Pursuant to our Conflict Minerals Policy, we strive to ensure that purchased metals originate only from smelters or refiners that have been validated as being “conformant” or “active” by the RMI's RMAP; however the Company does not seek to eliminate sourcing from the DRC, or Covered Countries. In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and encourage them to define, implement and communicate to their sub-suppliers their own policies outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. The Company's Conflict Minerals Policy is available at: https://www.ormat.com/en/company/engagement/view/?ContentID=9199. | |
● | Maintain a grievance mechanism through which concerns and violations of the Conflict Minerals Policy can be reported to Ormat: |
● | online via our website www.ormat.com; or | |
● | by electronic mail to the following address: ormat@ormat.com. |
● | Strengthened our engagement with suppliers by referring suppliers to training materials that included an overview of the applicable SEC rules and instructions on how to respond to the survey. | |
● | Required our suppliers to provide us the information required to perform our analysis of Conflict Minerals. | |
● | Implemented a requirement to maintain records relating to Conflict Minerals due diligence and responsible mineral sourcing for a minimum of five years. |
4.2 | Identify and assess risks in the supply chain |
To identify risks in our supply chain, we undertook the following measures:
● | We identified two risks in the supply chain: (i) the risk of not receiving timely and accurate information from the supplier; and (ii) the risk of not being able to replace a supplier, when aiming to move towards the goal of responsible sourcing of Conflict Minerals to ensure that the purchase and sourcing of such minerals does not benefit or fund the armed conflict and human rights abuses on-going in the DRC, Covered Countries, or in other conflict-affected areas. We have segmented our suppliers into three risk levels (high, medium and low) by referring to Conflict Minerals-related risks based on suppliers’ characteristics, including the extent to which the Company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers. This segmentation allowed us to focus our risk mitigation efforts according to the supplier level of risk. |
● | As part of the risk assessment phase, Ormat decided to focus on the top approximately 90% of the purchasing spend in 2022. We have determined that, out of the responses received, 64.7% of Ormat's relevant suppliers have a policy in place that addresses the sourcing of Conflict Minerals. |
● | Responses received were subject to a "red flag" review. Responses that we identified as incomplete or inconsistent based on the red flag review process were marked for follow up. We identified the smelters or refiners that are likely a part of our mineral supply chain by conducting a supply chain survey using the CMRT (at least version 6.01 or higher), requesting suppliers to identify relevant smelters or refiners and country of origin, or likely country of origin, of the Conflict Minerals in products supplied to Ormat in 2022. In addition, we compared smelters and refiners identified by the supply chain survey against the list of facilities that received RMAP’s “conformant” and “active” designations. The RMAP is a program in which the RMI works with independent third-party auditors or cross-certification programs to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters and refiners that agree to undergo an audit or to take part in a cross-certification program. |
● | A smelter or refiner is considered RMAP “conformant” if the audited smelter or refiner has successfully completed an RMAP audit and maintains good standing in the program, through a continual validation process. These smelters or refiners have the systems and processes in place to support responsible sourcing of raw materials and can provide evidence to support their sourcing activities. |
● | Smelters and refiners labeled as RMAP “active” by the RMI represent smelters and refiners that have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment. These may be in the pre-assessment, assessment or corrective-action phases of the assessment. The RMI notes on the active smelters list the names of any smelters or refiners that have left the “active” or “conformant” list and intend to re-enter the program. |
● | Downstream smelters or refiners may not take part in the RMAP. However, they may participate in the RMI’s Downstream Audit Program, an independent validation of companies’ sourcing practices outside of the RMAP audit process. |
4.3 | Design and implement a strategy to respond to identified risks |
To address the risks in our supply chain, Ormat maintains a risk mitigation plan, which includes the following:
● | Ormat expects its suppliers to define, implement and communicate to sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, and legal compliance and measures for implementation. We also ask suppliers to work with sub-tier suppliers to ensure traceability of these materials at least to the smelter or refiner level (e.g., by using a recent version of the CMRT). |
● | Ormat's senior management, including the CEO, CFO, President Head of Products and Operations, EVP Electricity Segment, EVP Energy Storage and Business Development, and the Legal Counsel and Chief Compliance Officer, were updated with the risk analysis and risk management actions and outcomes. |
● | Suppliers who provided incomplete or inconsistent responses were sent a corrective action letter for follow up, requesting clarification. |
● | Suppliers that did not respond to our initial survey request were sent follow-up letters requesting that they provide the necessary information. |
● | Should the Company find uncertified smelters or refiners in its suppliers’ responses, it will follow up with the supplier and ask for further clarifications or corrective action plans |
Supply chain due diligence is a dynamic process that requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process and update the risk mitigation strategy accordingly.
4.4 | Carry out independent third-party audit of smelter/refiner’s due diligence practices |
We do not typically have direct relationships with 3TG smelters or refiners of Conflict Minerals and therefore do not perform direct audits of these entities. As a result, our due diligence efforts relied on independent third-party audit body and cross-industry initiatives, such as those led by the RMI, to conduct smelter or refiner due diligence.
4.5 | Report annually on supply chain due diligence |
Our Conflict Minerals Policy was adopted with a view to assuring compliance with Section 1502 of the Dodd Frank Act, which requires the filing of a Form SD and this Report with the SEC and disclosure of them on its publicly available Internet website. The Company's Conflict Minerals Reports can be viewed at: https://investor.ormat.com/sec-filings/documents/default.aspx
5 | The Company’s Due Diligence Findings and Conclusions |
We conducted a supply-chain survey of the 103 relevant suppliers that we identified as potentially contributing the necessary Conflict Minerals contained in our products in 2022. The overall response rate to this survey was approximately 53%. The responses included the names and locations of smelters or refiners (see Annex 1) and possible countries of origin, according to the information provided in our suppliers' declarations (see Annex 2).
As a downstream purchaser of products which contain Conflict Minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the Conflict Minerals. Our supply chain is complex and there are multiple tiers between the Company and the mines or facilities that process the necessary Conflict Minerals. Accordingly, we rely on our suppliers to provide information on the origin of the Conflict Minerals contained in components that are supplied to us to be included in our products.
We also rely, to a large extent, on information collected and provided by responsible mineral sourcing validation programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.
Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers and the entire supply chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners. We ask that the data cover the entire calendar year covered by the Report, and we seek to use contract provisions requiring the suppliers to promptly update us in the event that the sourcing data changes.
Despite receiving responses from suppliers listing smelter or refiner names in their supply chain, the suppliers were unable to conclusively determine all of the specific smelters or refiners that were part of the supply chain of the components sold to Ormat in 2022. In light of inconclusive information, we are unable to determine and to describe the full list of facilities used to process 3TG in the Covered Products or their countries of origin. The below shows the RMAP status of smelters or refiners our suppliers identified in response to our due diligence, with the location of such smelters or refiners included in Annex 1. The Company cannot be certain that these smelters and refiners were in fact in the Company’s supply chain during the period covered by this Report.
Smelters or refiners verified as RMAP “Conformant” or “Active”:
Tantalum | 33 of 37 (89.2%) |
Tin | 62 of 83 (74.7%) |
Tungsten | 36 of 52 (69.2%) |
Gold | 100 of 178 (56.2%) |
Total | 231 of 350 (66.0%) |
Status of identified smelters or refiners:
RMAP Status | Number |
RMAP “Conformant” | 223 |
RMAP “Active” | 8 |
Not RMAP “Conformant” or “Active” | 119 |
Total | 350 |
6. | Steps to be taken to mitigate risk |
The Company has taken, and intends to continue to take, steps to improve its due diligence processes. Due diligence is an ongoing, proactive and reactive process, and the Company is continually working to improve its methods and processes for identifying the source or likely source of the Conflict Minerals contained in its Covered Products. The Company plans to continue to inform suppliers of their role in the Company’s Conflict Minerals compliance program and to engage its suppliers to obtain current, accurate and complete information regarding their mineral supply chains. The Company intends to monitor the performance and efficiency of its due diligence efforts to ensure responsible sourcing in compliance with its Conflict Minerals Policy and increase transparency in its supply chain.
Specific steps the Company has taken and continues to take to manage risks include:
● | Continue to work with our global supply chain to obtain current, accurate and complete information about the supply chain, ensure responsible sourcing, while also assuring compliance with certain international regulations. | |
● | Continue to strengthen communications with suppliers in order to improve the number of suppliers that respond to the company's supply chain surveys and requests for information and continue to communicate the expectation that they steer their supply chain towards conformant smelters as defined by the RMI's RMAP or other equivalent programs. | |
● | Continue to improve due diligence efforts to ensure responsible sourcing in compliance with the Conflict Minerals Policy. | |
● | Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts. |
Cautionary Note Concerning Forward-Looking Statements
Information provided in this Report may contain statements relating to current expectations and plans that are "forward-looking statements" as defined in the Private Securities Litigation Reform Act of 1995. These forward-looking statements generally relate to Ormat's plans, objectives and expectations for future plans and events and are based upon its management's current estimates. These statements are subject to risks and uncertainties and may not prove to be accurate. These risks and uncertainties include those associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on our ability to verify the accuracy or completeness of any supply chain information provided by suppliers and other factors discussed under the heading "Risk Factors" as described in Ormat Technologies, Inc.'s Annual Report on Form 10-K filed with the Securities and Exchange Commission on February 24, 2023 and other documents subsequently filed with or furnished to the U.S. Securities and Exchange Commission. These forward-looking statements are made only as of the date hereof, and, except as required by applicable law, we undertake no obligation to update or revise the forward-looking statements, whether as a result of new information, future events or otherwise.
Annex 1-Smelter or Refiner Names in Supply Chain
Metal | Smelter Name | Smelter Country |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Agosi AG | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
Gold | Argor-Heraeus S.A. | SWITZERLAND |
Gold | Asahi Pretec Corp. | JAPAN |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | Aurubis AG | GERMANY |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
Gold | Boliden AB | SWEDEN |
Gold | C. Hafner GmbH + Co. KG | GERMANY |
Gold | Caridad | MEXICO |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
Gold | Cendres + Metaux S.A. | SWITZERLAND |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Chimet S.p.A. | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | DODUCO Contacts and Refining GmbH | GERMANY |
Gold | Dowa | JAPAN |
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
Gold | Heraeus Germany GmbH Co. KG | GERMANY |
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 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
Gold | Asahi Refining Canada Ltd. | CANADA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Kazzinc | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Gold Co., Ltd. | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Materion | UNITED STATES OF AMERICA |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Metalor 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 | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
Gold | PAMP S.A. | SWITZERLAND |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Precinox S.A. | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Royal Canadian Mint | CANADA |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | Shandong Gold Smelting Co., Ltd. | CHINA |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
Gold | Valcambi S.A. | SWITZERLAND |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
Gold | Yamakin Co., Ltd. | JAPAN |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
Gold | Morris and Watson | NEW ZEALAND |
Gold | SAFINA A.S. | CZECHIA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
Gold | Sudan Gold Refinery | SUDAN |
Gold | T.C.A S.p.A | ITALY |
Gold | REMONDIS PMR B.V. | NETHERLANDS |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
Gold | Industrial Refining Company | BELGIUM |
Gold | Shirpur Gold Refinery Ltd. | INDIA |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Marsam Metals | BRAZIL |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA |
Gold | Albino Mountinho Lda. | PORTUGAL |
Gold | SAAMP | FRANCE |
Gold | L'Orfebre S.A. | ANDORRA |
Gold | 8853 S.p.A. | ITALY |
Gold | Italpreziosi | ITALY |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | AU Traders and Refiners | SOUTH AFRICA |
Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA |
Gold | Sai Refinery | INDIA |
Gold | Modeltech Sdn Bhd | MALAYSIA |
Gold | Bangalore Refinery | INDIA |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
Gold | Pease & Curren | UNITED STATES OF AMERICA |
Gold | JALAN & Company | INDIA |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Planta Recuperadora de Metales SpA | CHILE |
Gold | ABC Refinery Pty Ltd. | AUSTRALIA |
Gold | Safimet S.p.A | ITALY |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
Gold | African Gold Refinery+ | UGANDA |
Gold | Gold Coast Refinery | GHANA |
Gold | NH Recytech Company | KOREA, REPUBLIC OF |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
Gold | CGR Metalloys Pvt Ltd. | INDIA |
Gold | Sovereign Metals | INDIA |
Gold | C.I Metales Procesados Industriales SAS | COLOMBIA |
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
Gold | Augmont Enterprises Private Limited | INDIA |
Gold | Kundan Care Products Ltd. | INDIA |
Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
Gold | K.A. Rasmussen | NORWAY |
Gold | Alexy Metals | UNITED STATES OF AMERICA |
Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA |
Gold | Sellem Industries Ltd. | MAURITANIA |
Gold | MD Overseas | INDIA |
Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA |
Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
+ On March 17, 2022, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) sanctioned this gold refinery in Uganda. Ormat has no direct business with the refinery. Through our due diligence examination, we identified our direct suppliers who reported utilizing the Ugandan refinery in their supply chain. We are in communication with the direct suppliers who listed this refinery to confirm if the refinery actually exists in our supply chain and will continue as necessary to follow-up to have this refinery removed from our supply chain.
Gold | WEEEREFINING | FRANCE |
Gold | Value Trading | BELGIUM |
Gold | Gold by Gold Colombia | COLOMBIA |
Gold | Dongwu Gold Group | CHINA |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
Tantalum | AMG Brasil | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
Tantalum | Mineracao Taboca S.A. | BRAZIL |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Tantalum | NPM Silmet AS | ESTONIA |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | QuantumClean | UNITED STATES OF AMERICA |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemical Co., Ltd. | JAPAN |
Tantalum | Telex Metals | UNITED STATES OF AMERICA |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | KEMET de Mexico | MEXICO |
Tantalum | TANIOBIS Co., Ltd. | THAILAND |
Tantalum | TANIOBIS GmbH | GERMANY |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN |
Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
Tantalum | Global Advanced Metals Aizu | JAPAN |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
Tantalum | 5D Production OU | ESTONIA |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
Tin | Alpha | UNITED STATES OF AMERICA |
Tin | PT Aries Kencana Sejahtera | INDONESIA |
Tin | Dowa | JAPAN |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | Estanho de Rondonia S.A. | BRAZIL |
Tin | Fenix Metals | POLAND |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
Tin | Mineracao Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT Babel Inti Perkasa | INDONESIA |
Tin | PT Babel Surya Alam Lestari | INDONESIA |
Tin | PT Belitung Industri Sejahtera | INDONESIA |
Tin | PT Bukit Timah | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT Panca Mega Persada | INDONESIA |
Tin | PT Prima Timah Utama | INDONESIA |
Tin | PT Refined Bangka Tin | INDONESIA |
Tin | PT Sariwiguna Binasentosa | INDONESIA |
Tin | PT Stanindo Inti Perkasa | INDONESIA |
Tin | PT Timah Tbk Kundur | INDONESIA |
Tin | PT Timah Tbk Mentok | INDONESIA |
Tin | PT Timah Nusantara | INDONESIA |
Tin | PT Tinindo Inter Nusa | INDONESIA |
Tin | PT Tommy Utama | INDONESIA |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Thaisarco | THAILAND |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | VQB Mineral and Trading Group JSC | VIETNAM |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
Tin | CV Venus Inti Perkasa | INDONESIA |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
Tin | PT Tirus Putra Mandiri | INDONESIA |
Tin | Melt Metais e Ligas S.A. | BRAZIL |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
Tin | PT Cipta Persada Mulia | INDONESIA |
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
Tin | Resind Industria e Comercio Ltda. | BRAZIL |
Tin | Super Ligas | BRAZIL |
Tin | Metallo Belgium N.V. | BELGIUM |
Tin | Metallo Spain S.L.U. | SPAIN |
Tin | PT Sukses Inti Makmur | INDONESIA |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIETNAM |
Tin | PT Menara Cipta Mulia | INDONESIA |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
Tin | Modeltech Sdn Bhd | MALAYSIA |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
Tin | PT Bangka Serumpun | INDONESIA |
Tin | Pongpipat Company Limited | MYANMAR |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
Tin | PT Masbro Alam Stania | INDONESIA |
Tin | PT Rajawali Rimba Perkasa | INDONESIA |
Tin | Luna Smelter, Ltd. | RWANDA |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Precious Minerals and Smelting Limited | INDIA |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
Tin | PT Mitra Sukses Globalindo | INDONESIA |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
Tin | CRM Synergies | SPAIN |
Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL |
Tin | DS Myanmar | MYANMAR |
Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
Tungsten | A.L.M.T. Corp. | JAPAN |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Japan New Metals Co., Ltd. | JAPAN |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
Tungsten | Masan High-Tech Materials | VIETNAM |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
Tungsten | ACL Metais Eireli | BRAZIL |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
Tungsten | Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd. | CHINA |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
Tungsten | Cronimet Brasil Ltda | BRAZIL |
Tungsten | Artek LLC | RUSSIAN FEDERATION |
Tungsten | Fujian Xinlu Tungsten | CHINA |
Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION |
Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION |
Tungsten | LLC Vostok | RUSSIAN FEDERATION |
Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CHINA |
Tungsten | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF |
Annex 2-Reasonable Country of Origin (RCOI) Inquiry Results*
GOLD | TANTALUM | TIN | TUNGSTEN |
ANDORRA | BRAZIL | BELGIUM | AUSTRIA |
AUSTRALIA | CHINA | BOLIVIA (PLURINATIONAL STATE OF) | BRAZIL |
AUSTRIA | ESTONIA | BRAZIL | CHINA |
BELGIUM | GERMANY | CHINA | GERMANY |
BRAZIL | INDIA | INDIA | JAPAN |
CANADA | JAPAN | INDONESIA | KOREA, REPUBLIC OF |
CHILE | KAZAKHSTAN | JAPAN | PHILIPPINES |
CHINA | MEXICO | MALAYSIA | RUSSIAN FEDERATION |
COLOMBIA | RUSSIAN FEDERATION | MYANMAR | TAIWAN, PROVINCE OF CHINA |
CZECHIA | THAILAND | PERU | UNITED STATES OF AMERICA |
FRANCE | UNITED STATES OF AMERICA | PHILIPPINES | VIETNAM |
GERMANY | POLAND | ||
GHANA | RUSSIAN FEDERATION | ||
INDIA | RWANDA | ||
INDONESIA | SPAIN | ||
ITALY | TAIWAN, PROVINCE OF CHINA | ||
JAPAN | THAILAND | ||
KAZAKHSTAN | UNITED STATES OF AMERICA | ||
KOREA, REPUBLIC OF | VIETNAM | ||
KYRGYZSTAN | |||
LITHUANIA | |||
MALAYSIA | |||
MAURITANIA | |||
MEXICO | |||
NETHERLANDS | |||
NEW ZEALAND | |||
NORWAY | |||
PHILIPPINES | |||
POLAND | |||
PORTUGAL | |||
RUSSIAN FEDERATION | |||
SAUDI ARABIA | |||
SINGAPORE | |||
SOUTH AFRICA |
SPAIN | |||
SUDAN | |||
SWEDEN | |||
SWITZERLAND | |||
TAIWAN, PROVINCE OF CHINA | |||
THAILAND | |||
TURKEY | |||
UGANDA | |||
UNITED ARAB EMIRATES | |||
UNITED STATES OF AMERICA | |||
UZBEKISTAN | |||
ZIMBABWE |
* As some smelters or refiners did not provide complete information on the location of mine in their CMRTs, and the Company was not able to establish with complete certainty, based on the suppliers’ 3TG sourcing information, the exact location for the processing of the minerals. Therefore, we have listed in the RCOI the closest indication provided as to the source of Conflict Minerals (i.e. the smelter or refiner country as reported in our relevant suppliers' CMRT declarations, if provided).
