Exhibit 1.01
EATON CORPORATION plc
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2019
This Conflict Minerals Report (Report) is filed as an exhibit to Eaton’s Form SD as required by Rule 13p-1 (the Rule) under the Securities Exchange Act of 1934, as amended.
Eaton Corporation plc (Eaton, the Company, we, us or our) is required to perform a reasonable country of origin inquiry into the sources of necessary conflict minerals in our products and disclose the results of such diligence. Conflict minerals have been defined as tin, tantalum, tungsten and gold (the Minerals). The design of our due diligence and related results are described below.
A copy of Eaton Corporation plc's Conflict Minerals Report is publicly available at www.eaton.com under "Responsible Sourcing of Conflict Minerals" at: http://www.eaton.com/content/eaton/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html.html. The contents of our website referred to in this Report are not incorporated by reference into this Report.
1. COMPANY OVERVIEW
Eaton Corporation plc is a power management company with 2019 net sales of $21.4 billion. The Company provides sustainable solutions that help our customers effectively manage electrical, hydraulic and mechanical power - more safely, more efficiently, and more reliably. Eaton is dedicated to improving the quality of life and the environment through the use of power management technologies and services.
Eaton has six principal business segments: Electrical Products and Electrical Systems and Services, Hydraulics, Aerospace, Vehicle and eMobility. In 2019, Eaton considers all products to be in-scope and include, but are not limited to:
Electrical Products and Electrical Systems and Services
The Electrical Products segment consists of electrical components, industrial components, residential products, single phase power quality, emergency lighting, fire detection, wiring devices, structural support systems, circuit protection, and lighting products. The Electrical Systems and Services segment consists of power distribution and assemblies, three phase power quality, hazardous duty electrical equipment, intrinsically safe explosion-proof instrumentation, utility power distribution,
power reliability equipment, and services.
Hydraulics
The Hydraulics segment is a global leader in hydraulics components, systems and services for industrial and mobile equipment. Eaton offers a wide range of power products including pumps, motors and hydraulic power units; a broad range of controls and sensing products including valves, cylinders and electronic controls; a full range of fluid conveyance products including industrial and hydraulic hose, fittings, and assemblies, thermoplastic hose and tubing, couplings, connectors, and assembly equipment; filtration systems solutions; industrial drum and disc brakes; and golf grips.
Aerospace
The Aerospace segment is a leading global supplier of aerospace fuel, hydraulics, and pneumatic systems for commercial and military use. Products include hydraulic power generation systems for aerospace applications including pumps, motors, hydraulic power units, hose and fittings, electro-hydraulic pumps; controls and sensing products including valves, cylinders, electronic controls, electromechanical actuators, sensors, aircraft flap and slat systems and nose wheel steering systems; fluid conveyance products, including hose, thermoplastic tubing, fittings, adapters, couplings, sealing and ducting; and fuel systems
including fuel pumps, sensors, valves, adapters and regulators.
Vehicle
The Vehicle segment is a leader in the design, manufacture, marketing, and supply of: drivetrain, powertrain systems and critical components that reduce emissions and improve fuel economy, stability, performance, and
safety of cars, light trucks and commercial vehicles. Products include transmissions, clutches, hybrid power systems, superchargers, engine valves and valve actuation systems, cylinder heads, locking and limited slip differentials, transmission controls, and fuel vapor components for the global vehicle industry.
eMobility
The eMobility segment designs, manufactures, markets, and supplies electrical and electronic components and systems that improve the power management and performance of both on-road and off-road vehicles. Products include high voltage inverters, converters, fuses, onboard chargers, circuit protection units, vehicle controls, power distribution, fuel tank isolation valves, and commercial vehicle hybrid systems.
Purchased raw materials and parts are varied and are sourced from many suppliers. Eaton has a substantial number of suppliers globally that span across our six business segments. Our supply chain is multi-tiered and Eaton is typically many levels removed from the mines, smelters and refiners. Eaton does not purchase any Minerals directly from mines, smelters or refiners. Therefore, Eaton must rely on its suppliers to provide information about the origin of the Minerals in its products. Some of Eaton’s products may contain the Minerals either from recycled sources or in their processed form.
For additional information about our business segments, including the wide variety of products manufactured in each segment, refer to Eaton's 2019 Form 10-K.
2. REASONABLE COUNTRY OF ORIGIN INQUIRY
For the reporting period from January 1 through December 31, 2019, Eaton conducted a good faith reasonable country of origin inquiry of the Minerals that are necessary to the functionality or production of the products that Eaton manufactured or contracted with others to manufacture during the reporting period. Based on this reasonable country of origin inquiry, Eaton was unable to conclude that these Minerals did not originate from the Democratic Republic of the Congo (the DRC) or adjoining countries. Accordingly, Eaton undertook due diligence measures on the source and chain of custody of the identified necessary Minerals.
3. DUE DILIGENCE
3.1 Design of Due Diligence
Our due diligence measures were designed to conform, in all material respects, with the due diligence framework set forth in The Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for tin, tantalum, and tungsten and for gold. Pursuant to this framework, we undertook to: (a) establish company management systems, (b) identify and assess risks in our supply chain, (c) design and implement a strategy to respond to the risks identified, (d) support the development and implementation of independent third party audits of smelter and refiner sourcing, and (e) report on the results of our supply chain due diligence.
3.2 Due Diligence Measures Performed
a. Establishment of Company Management Systems
Eaton has taken steps to develop strong company management systems pertaining to the use of Minerals in our products and supply chain. These include the development of a conflict minerals policy, which is available at http://www.eaton.com/content/eaton/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html.html. In addition, we have implemented an internal management reporting structure to manage and oversee Eaton’s conflict minerals activities consisting of a dedicated Conflict Minerals team and executive-level Conflict Minerals Steering Committee chaired by Eaton’s Executive Vice President for Supply Chain Management. We have also established formal requirements for suppliers related to the use and reporting of Minerals, including the implementation of a supplier conflict minerals solicitation process utilizing tools created by the Responsible Minerals Initiative (RMI) which includes the Conflict Minerals Reporting Template (CMRT). Through our policy and participation in RMI, Eaton is committed to responsible sourcing of Minerals from the DRC and adjoining countries and encourages suppliers and smelters or refiners to source responsibly from the DRC region. Finally, we maintain a global ethics e-mail address and telephone helpline (http://www.eaton.com/content/eaton/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-
minerals0.html.html) which can be used by employees, suppliers or other stakeholders to report any concerns relating to Eaton’s Minerals activities.
b. Identify and Assess Risks in our Supply Chain
As a downstream user of Minerals, Eaton is many layers removed from the mine or location from which the Minerals originated and the smelters and refiners which processed the Minerals. We solicited relevant suppliers using due diligence tools including the RMI’s CMRT. Our solicitation letter included an explanation of the Minerals and the related legal regulations, a request for suppliers to comply with the regulations and respond to us, and our contact information to direct any questions. Additional solicitation requests, including in additional languages beyond English, were sent to suppliers that did not respond or provide sufficient information. Through this process, during 2019 we solicited approximately 1,100 suppliers.
We verified the information provided by our suppliers (to the extent possible) by comparing it to the information contained on the RMI website and against CMRT acceptance criteria for completeness and consistency of responses. Through this process, for suppliers who provided names of smelters and refiners, we confirmed the validation status of those supplier-reported smelters and refiners. For those suppliers who provided country of origin information for the Minerals, we confirmed the listed countries of origin for each smelter and refiner if that information was available from RMI.
c. Design and Implement a Strategy to Respond to Identified Risks
Eaton’s strategy to respond to identified risks includes the development of a conflict minerals policy, referenced above. This policy is also included in Eaton’s Purchase Order Terms and Conditions and associated Supplier Code of Conduct (the Code). Both the Purchase Order Terms and Conditions and the Code are used to communicate requirements to our suppliers, including expectations relating to the use and sourcing of the Minerals. In particular, Eaton’s Purchase Order Terms and Conditions and associated Code require our suppliers to perform due diligence into their respective supply chains to determine whether products sold to us contain Minerals, and whether, and to what extent, the Minerals are sourced from conflict-free smelters and refiners, and to report to Eaton the results of this due diligence. The Terms and Conditions and the Code are available on our website at www.eaton.com.
Eaton monitors the information received from suppliers in response to our solicitations, and periodically shares summaries of this information with our Conflict Minerals Steering Committee. Eaton is a member of RMI (member Code EATN) and uses data from the RMI to confirm the validation status of supplier-reported smelters and refiners, as well as reported country of origin information related to the Minerals sourced from such smelters or refiners, if available. Through our membership in RMI, Eaton further supports several complementary programs such as iTSCi, Better Sourcing Program, and Solutions for Hope, with which RMI collaborates to jointly address Minerals issues in the DRC and adjoining countries.
Suppliers that are either non-responsive or provide incomplete or inconsistent responses to Eaton’s solicitations are escalated within Eaton’s Supply Chain Management organization for follow-up engagement. Responding suppliers reporting smelters and refiners that are non-conformant or have other identified red flag triggers receive follow-up communication to remind them of Eaton’s expectations relating to the use and sourcing of Minerals as well as to notify them of further resources and training available to them through RMI.
d. Support the Development and Implementation of Independent Third-Party Audits of Smelter and Refiner Sourcing
As a downstream user of Minerals, Eaton and its direct supply chain are many layers removed from the mine or location from which the Minerals originated and smelters and refiners that process the Minerals. Through our membership and participation in the RMI, we collaborate at a cross-industry level, and we continue to support the development and implementation of due diligence practices, the RMI Responsible Minerals Assurance Process (RMAP) and tools such as the CMRT.
e. Report on Supply Chain Due Diligence
Eaton publicly communicates our conflict minerals policy, due diligence activities and related supplier expectations on our website and in our Form SD and Conflict Minerals Report available at: http://www.eaton.com/content/eaton/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html.html.
4. RESULTS OF REVIEW
For the reporting period of January 1, 2019 through December 31, 2019, Eaton solicited approximately 1,100 suppliers to gather detailed information regarding the existence of the Minerals in products sold to us, as well as the origin and chain of custody of the Minerals, using the CMRT. Based on the information provided by Eaton’s suppliers and our own due diligence efforts through December 31, 2019, we do not have sufficient information to conclusively determine the countries of origin or chain of custody of Minerals in our products. A majority of our suppliers responded that their materials did not contain the Minerals, they used recycled materials, they were unable to determine whether the products they sold to us contained Minerals, or they were still in the process of evaluating the source of the Minerals in their products.
Based on the information provided by our suppliers, Eaton believes the smelters and refiners that may have been used to produce Minerals in Eaton’s products include those listed in Annex I. Based on information provided by our suppliers and information available from the RMI, Eaton believes that the countries of origin of Minerals processed by these smelters and refiners may include the countries listed in Annex II. Of the supplier-reported smelters or refiners, 43 were identified by RMI as potentially sourcing Minerals directly or indirectly from the DRC or adjoining countries; however, all 43 of these smelters or refiners are indicated by RMI to be conformant with the RMI Responsible Minerals Assurance Process (formerly the Conflict-Free Smelter Program). Eaton found no reasonable basis for concluding that any Minerals known to be in its supply chain directly or indirectly financed or benefitted armed groups in the DRC or surrounding countries.
5. STEPS TAKEN TO MITIGATE RISK
Eaton intends to continue to evaluate its due diligence program in accordance with the provisions of the Rule. In particular, we intend to annually review the criteria used to select suppliers for solicitation and to continue to engage with our suppliers to identify the Minerals used within our supply chain, as well as the origin and chain of custody of those Minerals. We intend to continue to engage with third party programs such as the RMI. Finally, to the extent any Eaton supplier is found to be using non-conformant smelters or refiners within its supply chain, Eaton intends to engage that supplier and re-communicate our requirement for suppliers to commit to be conflict-free, as per Eaton’s policy.
ANNEX I
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| Mineral | Status | Smelter or Refiner Name | Country Location of Smelter or Refiner |
| Tin | * | PT Menara Cipta Mulia | INDONESIA |
| Tungsten | * | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Gold | * | Chugai Mining | JAPAN |
| Tin | * | Alpha | UNITED STATES OF AMERICA |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | * | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | * | Dowa | JAPAN |
| Tin | * | Dowa | JAPAN |
| Gold | * | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Tin | * | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | | Estanho de Rondonia S.A. | BRAZIL |
| Tantalum | * | Exotech Inc. | UNITED STATES OF AMERICA |
| Tantalum | * | F&X Electro-Materials Ltd. | CHINA |
| Tin | * | Fenix Metals | POLAND |
| Gold | * | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Tungsten | * | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tin | * | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | * | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tungsten | * | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| Tantalum | * | Guangdong Zhiyuan New Material 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 Precious Metals GmbH & Co. KG | GERMANY |
| Tin | * | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tungsten | * | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | * | Hunan Chunchang Nonferrous Metals 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 |
| Tungsten | * | Japan New Metals Co., Ltd. | JAPAN |
| Gold | * | Jiangxi Copper Co., Ltd. | CHINA |
| Tungsten | * | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tantalum | * | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | * | Jiujiang Tanbre Co., Ltd. | CHINA |
| Gold | * | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | * | Asahi Refining Canada Ltd. | CANADA |
| Tantalum | * | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tungsten | * | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tantalum | * | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | * | Global Advanced Metals Aizu | JAPAN |
| Gold | * | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | * | Emirates Gold DMCC | UNITED ARAB EMIRATES |
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| | | |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tungsten | * | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Gold | * | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Tin | * | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Gold | | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | * | Kazzinc | KAZAKHSTAN |
| Tungsten | * | Kennametal Fallon | UNITED STATES OF AMERICA |
| 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 |
| Tin | * | China Tin Group Co., Ltd. | CHINA |
| Gold | * | T.C.A S.p.A | ITALY |
| Gold | * | REMONDIS PMR B.V. | NETHERLANDS |
| Tungsten | * | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Gold | * | Marsam Metals | BRAZIL |
| Gold | * | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Tungsten | * | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tin | | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | * | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | * | Resind Industria e Comercio Ltda. | BRAZIL |
| Tungsten | * | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tin | | Super Ligas | BRAZIL |
| Gold | * | SAAMP | FRANCE |
| Gold | * | Italpreziosi | ITALY |
| Gold | * | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | * | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | * | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Tungsten | * | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tin | * | Mineracao Taboca S.A. | BRAZIL |
| Tin | * | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | * | Thaisarco | THAILAND |
| Tin | * | PT Timah Tbk Kundur | INDONESIA |
| Tin | * | PT Timah Tbk Mentok | INDONESIA |
| Tin | * | Metallo Belgium N.V. | BELGIUM |
| Tin | * | PT Mitra Stania Prima | INDONESIA |
| Tin | * | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | * | Minsur | PERU |
| Tungsten | * | A.L.M.T. Corp. | JAPAN |
| Gold | * | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | * | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | * | Allgemeine Gold-und Silberscheideanstalt A.G. | 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 |
| Tantalum | * | Asaka Riken Co., Ltd. | JAPAN |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Tungsten | * | Kennametal Huntsville | UNITED STATES OF AMERICA |
| 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 |
| Tantalum | * | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tungsten | * | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tin | * | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Gold | * | Chimet S.p.A. | ITALY |
| Gold | * | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | * | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Gold | * | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| 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 (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 | | Morris and Watson | NEW ZEALAND |
| 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 | | NH Recytech Company | KOREA, REPUBLIC OF |
| 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 | | Pease & Curren | UNITED STATES OF AMERICA |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | * | Planta Recuperadora de Metales SpA | CHILE |
| 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 | * | Royal Canadian Mint | CANADA |
| Gold | | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | * | Safimet S.p.A | ITALY |
| Gold | | Sai Refinery | INDIA |
| 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 | * | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | * | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | * | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | * | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | * | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | * | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| 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 | * | Torecom | KOREA, REPUBLIC OF |
| Gold | * | Umicore Brasil Ltda. | BRAZIL |
| 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 | * | 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 |
| Tantalum | * | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | * | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | * | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | * | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | * | H.C. Starck Inc. | UNITED STATES OF AMERICA |
| Tantalum | * | H.C. Starck Ltd. | JAPAN |
| Tantalum | * | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
| Tantalum | * | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | * | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | * | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | * | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | * | KEMET Blue Metals | MEXICO |
| 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 | * | NPM Silmet AS | ESTONIA |
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| | | |
| Tantalum | * | PRG Dooel | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
| 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 | * | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tin | * | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | * | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | * | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | * | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
| Tin | * | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | * | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | * | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | * | Metallo Spain S.L.U. | SPAIN |
| Tin | * | Mitsubishi Materials Corporation | JAPAN |
| Tin | | Modeltech Sdn Bhd | MALAYSIA |
| Tin | * | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | * | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | * | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | * | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | | Pongpipat Company Limited | MYANMAR |
| Tin | * | Yunnan Tin Company Limited | CHINA |
| Tin | * | PT Refined Bangka Tin | INDONESIA |
| Tin | * | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tungsten | * | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Tin | * | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Gold | * | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
| Gold | | Guangdong Jinding Gold Limited | 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 |
| Tin | * | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tungsten | * | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | * | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tungsten | * | ACL Metais Eireli | BRAZIL |
| Tungsten | * | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| Tin | * | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tungsten | * | Moliren Ltd. | RUSSIAN FEDERATION |
| Gold | * | AU Traders and Refiners | SOUTH AFRICA |
| Tin | * | PT Artha Cipta Langgeng | INDONESIA |
| Gold | * | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Tin | * | Soft Metais Ltda. | BRAZIL |
| Tungsten | * | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | * | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Xinhai Rendan Shaoguan 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 |
| Gold | * | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Tungsten | * | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | * | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | * | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tungsten | * | Masan Tungsten Chemical LLC (MTC) | VIET NAM |
| Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | * | Bangalore Refinery | INDIA |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| Gold | * | 8853 S.p.A. | ITALY |
| Gold | | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| Gold | * | DODUCO Contacts and Refining GmbH | GERMANY |
| Gold | * | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
| Tin | * | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tungsten | * | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
| Gold | | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| Gold | | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| Tungsten | * | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
| Tin | * | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM |
| Gold | | Modeltech Sdn Bhd | MALAYSIA |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Gold | | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | | African Gold Refinery | UGANDA |
| Gold | | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | | Tony Goetz NV | BELGIUM |
| Tungsten | * | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Gold | | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| Gold | | Shandong Humon Smelting Co., Ltd. | CHINA |
| Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tin | * | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | * | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
| Tantalum | * | CP Metals Inc. | UNITED STATES OF AMERICA |
| Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Gold | | Sovereign Metals | INDIA |
| Gold | | CGR Metalloys Pvt Ltd. | INDIA |
| Tin | * | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tungsten | * | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tin | * | Precious Minerals and Smelting Limited | INDIA |
| Tin | | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| Gold | * | L'Orfebre S.A. | ANDORRA |
| Tungsten | * | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tungsten | * | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
* = Conformant or actively participating in the RMI Responsible Minerals Assurance Process (as reported by RMI as of March 18, 2020).
ANNEX II
POSSIBLE COUNTRIES OF ORIGIN OF MINERALS PROCESSED BY SUPPLIER-REPORTED
SMELTERS AND REFINERS
|
| | |
| Argentina | Honduras | Saudi Arabia |
| Australia | India | Senegal |
| Austria | Indonesia | Serbia |
| Azerbaijan | Iran* | Sierra Leone |
| Benin | Ivory Coast | Slovakia |
| Bolivia (Plurinational State of) | Japan | Solomon Islands |
| Botswana | Kazakhstan | Somaliland |
| Brazil | Kenya | South Africa |
| Burkina Faso | Laos | Spain |
| Burundi | Liberia | Suriname |
| Canada | Madagascar | Swaziland |
| Chile | Malaysia | Sweden |
| China | Mali | Taiwan |
| Colombia | Mauritania | Tajikistan |
| Cuba* | Mexico | Tanzania |
| Cyprus | Mongolia | Thailand |
| Dominican Republic | Morocco | The Democratic Republic of Congo |
| Ecuador | Mozambique | Togo |
| Egypt | Myanmar | Turkey |
| Eritrea | Namibia | Uganda |
| Ethiopia | Netherlands | United Kingdom of Great Britain and |
| Fiji | New Zealand | Northern Ireland |
| Finland | Nicaragua | United States of America |
| France | Nigeria | Uruguay |
| Georgia | Papua New Guinea | Uzbekistan |
| Germany | Peru | Venezuela |
| Ghana | Philippines | Vietnam |
| Guatemala | Portugal | Zambia |
| Guinea | Russian Federation | Zimbabwe |
| Guyana | Rwanda | |
* = Eaton does not have any indication or reason to believe that any Minerals from this country are ultimately being incorporated into Eaton products. The inclusion of this country in the list of possible countries of origin of Minerals processed by supplier-reported smelters and refiners is based upon information available from The Responsible Minerals Initiative. As a downstream manufacturer many tiers removed from the smelters/refiners and mines of origin, Eaton does not have sufficient information to conclusively determine the countries of origin or chain of custody of Minerals in our products.
