Exhibit 1.01
SodaStream International Ltd.
Conflict Minerals Report
For the reporting period from January 1, 2014 to December 31, 2014
This is the Conflict Minerals Report (the “Report”) of SodaStream International Ltd. (“SodaStream,” the“Company,” “we” or “us”) for the reporting period from January 1, 2014 to December 31, 2014 (the “2014 calendar year”), which has been prepared pursuant to Rule 13p-1 (the“Rule”) promulgated under the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives as limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”), that originated in the Democratic Republic of the Congo (the “DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).
SodaStream has concluded, in good faith, that during the 2014 calendar year:
| · | SodaStream manufactured, or contracted to manufacture, products as to which the Conflict Minerals are necessary to the functionality or production of those products; and |
| · | based on its good faith reasonable country of origin inquiry, SodaStream has reason to believe that a portion of its necessary Conflict Minerals may have originated from the Covered Countries, and has reason to believe that its necessary Conflict Minerals may not be solely from recycled or scrap sources. |
As a result, SodaStream is filing this Report with its Form SD to comply with the requirements of the Rule. This Report has not been subject to an independent private sector audit.
PART I. DESCRIPTION OF THE COMPANY’S PRODUCTS COVERED BY THIS REPORT
SodaStream manufactures home beverage carbonation systems that enable consumers to transform ordinary tap water easily and instantly into sparkling water and flavored sparkling water. SodaStream develops, manufactures and sells sparkling water makers and exchangeable carbon-dioxide cylinders, along with consumables including carbon-dioxide refills, reusable carbonation bottles and flavors which consumers may add to the carbonated water. As of December 31, 2014, SodaStream’s products were sold through more than 70,000 individual retail stores in 45 countries.
As described in this Report, during the 2014 calendar year, certain of the Company’s operations manufactured, or contracted to manufacture, products for which the Conflict Minerals are necessary to the functionality or production of those products (collectively, the “Covered Products”). Three models of SodaStream’s sparkling water makers contain electronic circuit boards and other electrical components which may comprise tin, tungsten and gold. Additionally, Conflict Minerals can be found in the brass components within certain of SodaStream’s sparkling water makers and in the brass valves on its carbon-dioxide cylinders. While brass mainly consists of copper and zinc, brass may contain trace quantities of tin as an impurity to the other metals.
PART II. THE COMPANY’S DUE DILIGENCE PROCESS
SodaStream has established a multi-stage diligence inquiry intended to verify the possible sources of the Conflict Minerals contained in the Company’s Covered Products. The Company has designed its due diligence measures to conform to the Rule and to the five-step framework laid out by the Organization for Economic Co-operation and Development in itsOECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition (2013),including the related supplements on gold, tin, tantalum and tungsten(collectively, the “OECD Guidance”). Because the Company does not purchase raw or unrefined Conflict Minerals directly from mines, smelters or refiners, and makes no direct purchases of any minerals in the Covered Countries, it has tailored its due diligence to the OECD Guideline standards applicable to downstream companies.
| 1 |
OECD Guidance Step 1: Establish strong management systems for conflict minerals supply chain due diligence and reporting compliance.
The Company has adopted a policy relating to the Conflict Minerals (the “Policy”), which incorporates the standards set forth in the OECD Guidance. As stated in the Policy, the Company expects its suppliers to implement sourcing and due diligence practices that prevent Conflict Minerals from the Covered Countries from entering the Company’s supply chain, and to require that their own suppliers do the same. Each supplier should also cooperate with the Company when the Company inquires as to the components of the supplier’s products and the details of the supplier’s supply chain, and should promptly inform the Company whenever the supplier has determined that such components originated in the Covered Countries. The Policy is available on the Company’s website athttp://sodastream.investorroom.com/CorporateGovernance.
The Company has also structured internal management systems to support supply chain due diligence by establishing an internal working group consisting of cross-functional team members and senior executives. The working group, which includes employees from the Company’s procurement, legal and finance departments, is charged with executing the Company’s Conflict Minerals strategy and compliance processes and with training employees outside of the team on their roles and responsibilities in connection with the compliance program. Additionally, this team corresponds regularly to assess the progress of the Company’s compliance program and periodically updates the audit committee of the board of directors (the “Audit Committee”) with respect to the Company’s due diligence efforts and ongoing compliance obligations.
OECD Guidance Step 2: Identify and assess risks in the Company’s supply chain.
Identify risk in the supply chain.
As explained above, the Company does not buy raw ore or unrefined Conflict Minerals directly from refiners, smelters or mines. The Company’s supply chain with respect to the Covered Products is complex, with multiple intermediaries and third parties in the supply chain between the manufacture of the Covered Products and the original sources of the necessary Conflict Minerals. The Company relies on its direct suppliers (i.e. “first-tier suppliers”) to provide information on the origin of the Conflict Minerals contained in components and materials supplied to the Company, including information about the sources of the Conflict Minerals that the first-tier suppliers obtain from their own suppliers (i.e. “second-tier suppliers”). For its diligence during the 2014 calendar year, the Company reached out to its first-tier suppliers to discuss applicable smelters and refiners of Conflict Minerals in the Company’s supply chain.
The first step in the Company’s due diligence process was to determine which products manufactured or contracted to be manufactured by the Company during the 2014 calendar year fell within the scope of the Rule. A description of the Covered Products appears in Part I of this Report. In tandem with its analysis of its Covered Products, the Company identified those suppliers from which it purchases components or materials for the Covered Products that may include Conflict Minerals.
Next, the Company provided all suppliers identified in connection with the Covered Products with a supply chain survey in the form of the latest version of the Electronic Industry Citizenship Coalition Conflict Minerals Reporting Template (the “Template”). The Company used 3.01 of the Template for most of the 2014 calendar year, and then adopted version 3.02 of the Template following its release on November 7, 2014, to the extent it was contacting suppliers at that point. The Template requires suppliers to make representations regarding (i) the country of origin for the Conflict Minerals contained in the components or products it provides to the Company, (ii) all of the smelters in the supplier’s supply chain for such Conflict Minerals, (iii) whether such smelters have been validated as being in compliance with the Conflict-Free Smelter Initiative’s (“CFSI”) Conflict Free Smelter Program (“CFSP”), (iv) whether the supplier has its own Conflict Minerals policy that requires its own direct suppliers to be DRC conflict-free and (v) whether the supplier uses the Template with its own suppliers to gather similar information.
| 2 |
Assess risk in the supply chain.
SodaStream received responses from all of the suppliers to its request for information. SodaStream analyzed the survey responses to evaluate the level of compliance exercised by each surveyed supplier, and, to the extent possible, by upstream suppliers, with the Company’s Policy. The information received from suppliers was also reviewed against the CFSI’s Conflict-Free Smelter list. To compile its list, the CFSI employs independent third-party auditors to audit the source, including mines of origin and chain of custody, of the Conflict Minerals processed by smelters and refiners which agree to undergo an audit. SodaStream determined whether smelters and refiners identified in its supply chain qualified as “conflict-free” on the CFSI Conflict-Free Smelter list. SodaStream also designated smelter or refiners as “active,” where applicable, according to the CFSI Conflict-Free Smelter list.
A smelter or refiner is considered “conflict-free” on the CFSI Conflict-Free Smelter list if (i) the audited smelter or refiner adheres to the CFSP’s assessment protocols by disclosing to auditors the identities and locations of the mines from which it sources Conflict Minerals and (ii) the independent auditor verifies separately that the smelter’s or refiner’s Conflict Minerals originated from conflict-free sources. The CFSI Conflict-Free Smelter list provides the names, locations and links to conflict minerals policies of all smelters and refiners deemed compliant with the CFSP’s assessment protocols. Smelters and refiners labeled as “active” have committed to undergo an audit which remains in progress. “Active” smelters and refiners may be at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase, but may not retain their “active” status if they are unresponsive to requests for re-audit or corrective action past a certain time.
OECD Guidance Step 3: Design and implement a strategy to respond to identified risks.
In light of the complexity of the Company’s and its suppliers’ supply chains, the Company is currently unable to assess adequately all of the risks in its supply chain. However, since the end of the 2014 calendar year, the Company has worked to mitigate the risk that the necessary Conflict Minerals contained in the Company’s products finance or benefit armed groups in the Covered Countries. Specific steps the Company has taken and continues to take to manage risks include:
| · | continuing to engage with manufacturers and suppliers to obtain current, accurate and complete information about the supply chain; |
| · | continuing to improve due diligence efforts to ensure responsible sourcing in compliance with SodaStream’s Policy; and |
| · | in coordination with the legal and other relevant teams, reviewing contractual engagement procedures with suppliers who, following the above process, failed to comply with SodaStream’s Policy for consideration of possible corrective actions, including cancellation of contracts and future engagements. |
OECD Guidance Step 4: Carry out independent third-party audit of smelter/refiner due diligence practices.
Due to the Company’s position in the supply chain, the Company does not have a direct relationship with smelters and refiners, nor does it perform direct audits of the smelters and refiners that provide its supply chain with the Conflict Minerals contained in the Company’s Covered Products. The Company relies upon industry efforts to influence smelters and refiners to undergo audits and become certified through the CFSP.
OECD Guidance Step 5:Report annually on supply chain due diligence.
The Company has filed with the Securities and Exchange Commission its specialized disclosure report on Form SD, which includes this Report as Exhibit 1.01, for the reporting period in the 2014 calendar year. In accordance with OECD Guidance and the Rule, the Company has also made these disclosures available on its website at http://sodastream.investorroom.com/.
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PART III. THE COMPANY’S DUE DILIGENCE FINDINGS AND CONCLUSIONS
Following the process outlined above, as of December 31, 2014, 38% of SodaStream’s suppliers to whom a Template was sent have not been able to verify the origin of all of the Conflict Minerals incorporated into the components and materials they supply to SodaStream. Therefore, after exercising its due diligence, the Company was unable to determine conclusively the origin of all of the Conflict Minerals contained in the Covered Products.
However, based on the information that was provided by the Company’s suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the smelters and refiners listed inAppendix A attached to this Report.
PART IV. IMPLEMENTATION OF STRATEGIES TO RESPOND TO IDENTIFIED RISKS AND FUTURE STEPS
The Company plans to continue to educate suppliers about their role in the Company’s conflict minerals compliance program and to engage its suppliers to obtain current, accurate and complete information about the supply chain. Since the Company’s supply chain due diligence processes could assist in mitigating the possible risk that the necessary Conflict Minerals in the Company’s products could benefit armed groups in the Covered Countries, the Company intends to monitor the performance and efficiency of its due diligence efforts and to establish procedures designed to incorporate any new risks into the risk management plan, ensure responsible sourcing in compliance with its Policy and increase transparency in its supply chain.
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Appendix A
Currently Known Smelter and Refinery List
| Metal | Standard Smelter Names | Country of Smelter Facility | Conflict-Free Smelter Initiative Smelter Status | |||
| Tungsten | A.L.M.T. Corp. | Japan | Conflict-Free | |||
| Gold | Aida Chemical Industries Co. Ltd. | Japan | Conflict-Free | |||
| Gold | Allgemeine Gold- und Silberscheideanstalt A.G. | Germany | Conflict-Free | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Unknown | |||
| Tin | Alpha | USA | Conflict-Free | |||
| Tin | Amalgamated Metals Corporation | Peru | Conflict-Free | |||
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | Brazil | Conflict-Free | |||
| Gold | Argor-Heraeus SA | Switzerland | Conflict-Free | |||
| Gold | Asahi Pretec Corporation | Japan | Conflict-Free | |||
| Gold | Asaka Riken Co Ltd | Japan | Active | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | Conflict-Free | |||
| Gold | Aurubis AG | Germany | Conflict-Free | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Unknown | |||
| Gold | Boliden AB | Sweden | Conflict-Free | |||
| Gold | Caridad | Mexico | Unknown | |||
| Gold | CCR Refinery – Glencore Canada Corporation | Canada | Conflict-Free | |||
| Gold | Cendres & Métaux SA | Switzerland | Active | |||
| Gold | Chimet S.p.A. | Italy | Conflict-Free | |||
| Tin | China Tin Group Co., Ltd. | China | Active | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co Ltd | China | Conflict-Free | |||
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | China | Conflict-Free | |||
| Tantulum | Conghua Tantalum and Niobium Smeltry | China | Conflict-Free | |||
| Tin | Cooper Santa | Brazil | Conflict-Free | |||
| Tin | CV Serumpun Sebalai | Indonesia | Unknown | |||
| A-1 |
| Tin | CV United Smelting | Indonesia | Conflict-Free | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | Unknown | |||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China | Conflict-Free | |||
| Gold | Dowa | Japan | Conflict-Free | |||
| Tantalum | Duoluoshan | China | Conflict-Free | |||
| Tin | EM Vinto | Bolivia | Conflict-Free | |||
| Tin | Estanho de Rondônia S.A. | Brazil | Unknown | |||
| Tantalum | Exotech Inc. | USA | Conflict-Free | |||
| Tantalum | F&X Electro-Materials Ltd. | China | Conflict-Free | |||
| Tin | Fenix Metals | Poland | Active | |||
| Gold | FSE Novosibirsk Refinery | Russia | Unknown | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | Conflict-Free | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | Conflict-Free | |||
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | China | Conflict-Free | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Conflict-Free | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | China | Conflict-Free | |||
| Tin | Gejiu Zi-Li | China | Unknown | |||
| Tantalum | Global Advanced Metals Boyertown | USA | Conflict-Free | |||
| Tungsten | Global Tungsten & Powders Corp. | USA | Conflict-Free | |||
| Gold | Guangdong Jinding Gold Limited | China | Unknown | |||
| Tungsten | Guangdong Xianglu Tungsten Industry Co., Ltd. | China | Conflict-Free | |||
| Tungsten | HC Starck GmbH | Germany | Conflict-Free | |||
| Gold | Heimerle + Meule GmbH | Austria | Conflict-Free | |||
| Gold | Heraeus Ltd. Hong Kong | China | Conflict-Free | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Conflict-Free | |||
| Tantalum | Hi-Temp Speciality Metals Inc | USA | Conflict-Free | |||
| Tin | Huichang Jinshunda Tin Co. Ltd | China | Unknown | |||
| Tungsten | Hunan Chenzhou Mining Group Co, Ltd | China | Conflict-Free | |||
| Gold | Hunan Chenzhou Mining Industry Co. Ltd | China | Unknown | |||
| Tungsten | Hunan Chunchang Nonferrous Smelting & Concentrating Co., Ltd. | China | Unknown | |||
| A-2 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | China | Unknown | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Conflict-Free | |||
| Gold | Istanbul Gold Refinery | Turkey | Conflict-Free | |||
| Gold | Japan Mint | Japan | Conflict-Free | |||
| Tungsten | Japan New Metals Co Ltd | Japan | Conflict-Free | |||
| Gold | Jiangxi Copper Company Limited | China | Unknown | |||
| Tin | Jiangxi Nanshan | China | Unknown | |||
| Tantulum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conflict-Free | |||
| Tantulum | Jiujiang Tanbre Co., Ltd. | China | Conflict-Free | |||
| Gold | Johnson Matthey Inc | USA | Conflict-Free | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russia | Conflict-Free | |||
| Gold | JSC Uralectromed | Russia | Conflict-Free | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | Conflict-Free | |||
| Tin | Kai Unita Trade Limited Liability Company | China | Unknown | |||
| Gold | Kazzinc | Kazakhstan | Conflict-Free | |||
| Tantulum | Kemet Blue Powder | USA | Conflict-Free | |||
| Tungsten | Kennametal Fallon | USA | Conflict-Free | |||
| Tungsten | Kennametal Huntsville | USA | Conflict Free | |||
| Gold | Kennecott Utah Copper LLC | USA | Conflict-Free | |||
| Tantulum | King-Tan Tantalum Industry Ltd | China | Conflict-Free | |||
| Gold | Kojima Chemicals Co., Ltd | Japan | Conflict-Free | |||
| Gold | Korea Metal Co. Ltd | Korea | Unknown | |||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | Unknown | |||
| Gold | L'azurde Company For Jewelry | Saudi Arabia | Conflict-Free | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | China | Unknown | |||
| Tin | Linwu Xianggui Smelter Co | China | Unknown | |||
| Tin | Liuzhou China Tin Group Co | China | Active | |||
| Tantalum | LSM Brasil S.A. | Brazil | Conflict-Free | |||
| Gold | LS-NIKKO Copper Inc. | Korea | Conflict-Free | |||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Conflict-Free | |||
| A-3 |
| Gold | Materion | USA | Conflict-Free | |||
| Gold | Matsuda Sangyo Co., Ltd. | Japan | Conflict-Free | |||
| Tin | Metallo-Chimique N.V. | Belgium | Conflict-Free | |||
| Tantalum | Metallurgical Products India (Pvt.) Ltd. | India | Conflict-Free | |||
| Gold | Metalor Technologies (Hong Kong) Ltd | China | Conflict-Free | |||
| Gold | Metalor Technologies (Singapore) Pte. Ltd. | Singapore | Conflict-Free | |||
| Gold | Metalor Technologies (Suzhou) Ltd | China | Unknown | |||
| Gold | Metalor Technologies SA | Switzerland | Conflict-Free | |||
| Gold | Metalor USA Refining Corporation | USA | Conflict-Free | |||
| Gold | Met-Mex Peñoles, S.A. | Mexico | Conflict-Free | |||
| Tantalum | Mineração Taboca S.A. | Brazil | Conflict-Free | |||
| Tin | Minsur | Peru | Conflict-Free | |||
| Tin | Mitsubishi Materials Corporation | Japan | Conflict-Free | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Conflict-Free | |||
| Tantalum | Molycorp Silmet A.S. | Estonia | Conflict-Free | |||
| Gold | Moscow Special Alloys Processing Plant | Russia | Unknown | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey | Conflict-Free | |||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekestan | Unknown | |||
| Gold | Nihon Material Co. Ltd | Japan | Conflict-Free | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conflict-Free | |||
| Tin | Novosibirsk Integrated Tin Works | Russia | Unknown | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Active | |||
| Gold | Ohio Precious Metals, LLC | USA | Conflict-Free | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | Russia | Conflict-Free | |||
| Gold | OJSC Kolyma Refinery | Russia | Unknown | |||
| Tin | Operaciones Metalurgical S.A. | Bolivia | Conflict-Free | |||
| Gold | PAMP SA | Switzerland | Conflict-Free | |||
| Tantalum | Plansee SE Liezen | Austria | Conflict-Free | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russia | Unknown | |||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Conflict-Free | |||
| A-4 |
| Tin | PT Artha Cipta Langgeng | Indonesia | Conflict-Free | |||
| Tin | PT Babel Inti Perkasa | Indonesia | Conflict-Free | |||
| Tin | PT Bangka Putra Karya | Indonesia | Conflict-Free | |||
| Tin | PT Bangka Tin Industry | Indonesia | Conflict-Free | |||
| Tin | PT Bukit Timah | Indonesia | Conflict-Free | |||
| Tin | PT DS Jaya Abadi | Indonesia | Conflict-Free | |||
| Tin | PT Eunindo Usaha Mandiri | Indonesia | Conflict-Free | |||
| Tin | PT Koba Tin | Indonesia | Unknown | |||
| Tin | PT Mitra Stania Prima | Indonesia | Unknown | |||
| Tin | PT Prima Timah Utama | Indonesia | Conflict-Free | |||
| Tin | PT Refined Bangka Tin | Indonesia | Conflict-Free | |||
| Tin | PT Sariwiguna Binasentosa | Indonesia | Conflict-Free | |||
| Tin | PT Stanindo Inti Perkasa | Indonesia | Conflict-Free | |||
| Tin | PT Tambang Timah | Indonesia | Conflict-Free | |||
| Tin | PT Timah (Persero), Tbk | Indonesia | Conflict-Free | |||
| Tin | PT Tinindo Inter Nusa | Indonesia | Conflict-Free | |||
| Gold | PX Précinox SA | Switzerland | Conflict-Free | |||
| Gold | Rand Refinery (Pty) Ltd | South Africa | Conflict-Free | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd | China | Conflict-Free | |||
| Gold | Royal Canadian Mint | Canada | Conflict-Free | |||
| Tin | Rui Da Hung | Taiwan | Active | |||
| Gold | Sabin Metal Corp. | USA | Unknown | |||
| Gold | Samwon Metals Corp. | Korea | Unknown | |||
| Gold | Schone Edelmetaal B.V. | The Netherlands | Conflict-Free | |||
| Gold | SEMPSA Joyería Platería SA | Spain | Conflict-Free | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | China | Conflict-Free | |||
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | China | Unknown | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russia | Active | |||
| Gold | Solar Applied Materials Technology Corp. | Taiwan | Conflict-Free | |||
| Tantalum | Solikamsk Magnesium Works OAO | Russia | Conflict-Free | |||
| A-5 |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | Conflict-Free | |||
| Tantalum | Taki Chemicals | Japan | Conflict-Free | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | Conflict-Free | |||
| Tantalite | Tantalite Resources (Pty) Ltd | South Africa | Unknown | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam | Conflict-Free | |||
| Tantalum | Telex Metals | USA | Conflict-Free | |||
| Tin | Thailand Smelting & Refining Co.,Ltd. | Thailand | Conflict-Free | |||
| Gold | The Great Wall Gold and Silver Refinery of China | China | Unknown | |||
| Gold | The Refinery of Shandong Gold Mining Co. Ltd | China | Conflict-Free | |||
| Gold | Tokuriki Honten Co., Ltd | Japan | Conflict-Free | |||
| Gold | Tongling Nonferrous Metals Group Co.,Ltd | China | Unknown | |||
| Gold | Torecom | Korea | Unknown | |||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Conflict-Free | |||
| Gold | Umicore Brasil Ltda | Brazil | Conflict-Free | |||
| Gold | Umicore SA Business Unit Precious Metals Refining | Belgium | Conflict-Free | |||
| Gold | United Precious Metal Refining, Inc. | USA | Conflict-Free | |||
| Gold | Valcambi SA | Switzerland | Conflict-Free | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | Vietnam | Conflict-Free | |||
| Gold | Western Australian Mint trading as The Perth Mint | Australia | Conflict-Free | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | Brazil | Conflict-Free | |||
| Tungsten | Wolfram Bergbau und Hütten AG | Austria | Conflict-Free | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | Conflict-Free | |||
| Tungsten | Xiamen Tungsten Co., Ltd | China | Conflict-Free | |||
| Gold | Yokohama Metal Co Ltd | Japan | Active | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co, Ltd | China | Active | |||
| Tin | Yunnan Tin Group (Holding) Company Limited | China | Conflict-Free | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Conflict-Free | |||
| Tantalum | Zhuzhou Cemented Carbide | China | Conflict-Free | |||
| Gold | Zijin Mining Group Co. Ltd | China | Conflict-Free |
| A-6 |
