Exhibit 1.01
EATON CORPORATION plc
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2020
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 (RCOI) 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 2020 net sales of $17.9 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 key business segments: Electrical Americas and Electrical Global, Hydraulics, Aerospace, Vehicle, and eMobility. In 2020, 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 2020 Form 10-K.
2. REASONABLE COUNTRY OF ORIGIN INQUIRY
For the reporting period from January 1 through December 31, 2020, 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 Vice President for Global Supplier Performance. 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 2020 we solicited approximately 1,000 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 https://www.eaton.com/us/en-us/company/selling-to-eaton.html.
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, 2020 through December 31, 2020, Eaton solicited approximately 1,000 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, 2020, 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. 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
* =
• | | | | | | | | | | | |
| Mineral | Status | Smelter or Refiner Name | Country Location of Smelter or Refiner |
| Tin | * | Minsur | PERU |
| Tin | * | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | * | Thaisarco | THAILAND |
| Tin | * | PT Timah Tbk Mentok | INDONESIA |
| Tin | * | Mineracao Taboca S.A. | BRAZIL |
| Tin | * | Yunnan Tin Company Limited | CHINA |
| Tin | * | PT Timah Tbk Kundur | INDONESIA |
| Tin | * | Metallo Belgium N.V. | BELGIUM |
| Tin | * | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | * | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | * | PT Mitra Stania Prima | INDONESIA |
| Tin | * | PT Refined Bangka Tin | INDONESIA |
| Tin | * | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | * | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | * | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | * | Fenix Metals | POLAND |
| Tin | * | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | * | China Tin Group Co., Ltd. | CHINA |
| Tin | * | Mitsubishi Materials Corporation | JAPAN |
| Tin | * | Alpha | UNITED STATES OF AMERICA |
| Gold | * | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Tin | * | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | * | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | * | PT Artha Cipta Langgeng | INDONESIA |
| Gold | * | Royal Canadian Mint | CANADA |
| Tin | * | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Gold | * | Metalor Technologies S.A. | SWITZERLAND |
| Tin | * | Soft Metais Ltda. | BRAZIL |
| Tin | * | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Gold | * | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Tin | * | Melt Metais e Ligas S.A. | BRAZIL |
| Gold | * | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | * | Heraeus Germany GmbH Co. KG | GERMANY |
| Gold | * | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | * | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | * | Argor-Heraeus S.A. | SWITZERLAND |
| Tin | * | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Gold | * | Heimerle + Meule GmbH | GERMANY |
| Gold | * | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Tin | * | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Gold | * | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Tin | * | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | * | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Gold | * | Chimet S.p.A. | ITALY |
| Tin | * | Dowa | JAPAN |
| Gold | * | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | * | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | * | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| | | | | | | | | | | |
| Tungsten | * | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Gold | * | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | * | Asahi Refining Canada Ltd. | CANADA |
| Gold | * | CCR Refinery - Glencore Canada Corporation | CANADA |
| Tantalum | * | F&X Electro-Materials Ltd. | CHINA |
| Gold | * | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Tungsten | * | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tantalum | * | Exotech Inc. | UNITED STATES OF AMERICA |
| Gold | * | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | * | Materion | UNITED STATES OF AMERICA |
| Gold | * | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Tin | * | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Gold | * | Valcambi S.A. | SWITZERLAND |
| Gold | * | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | * | Istanbul Gold Refinery | TURKEY |
| Gold | * | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | * | PAMP S.A. | SWITZERLAND |
| Gold | * | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | * | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
| Gold | * | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | * | Aurubis AG | GERMANY |
| Gold | * | Boliden AB | SWEDEN |
| Gold | * | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | * | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | * | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | * | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | * | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tin | * | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Gold | * | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | * | Japan Mint | JAPAN |
| Gold | * | Kazzinc | KAZAKHSTAN |
| Gold | * | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | * | Mitsubishi Materials Corporation | JAPAN |
| Gold | * | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | * | Shandong Gold Smelting Co., Ltd. | CHINA |
| Gold | * | Tokuriki Honten Co., Ltd. | JAPAN |
| Tantalum | * | TANIOBIS GmbH | GERMANY |
| Tin | * | Resind Industria e Comercio Ltda. | BRAZIL |
| Gold | * | Dowa | JAPAN |
| Tin | * | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tungsten | * | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| Gold | * | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | * | Nihon Material Co., Ltd. | JAPAN |
| Gold | * | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | * | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | * | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | * | PX Precinox S.A. | SWITZERLAND |
| Gold | * | Yokohama Metal Co., Ltd. | JAPAN |
| Tungsten | * | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tantalum | * | Global Advanced Metals Aizu | JAPAN |
| Tin | * | Metallo Spain S.L.U. | SPAIN |
| | | | | | | | | | | |
| Tantalum | * | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Gold | * | JSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | * | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Tantalum | * | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Gold | * | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | * | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Tantalum | * | H.C. Starck Inc. | UNITED STATES OF AMERICA |
| Tantalum | * | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Gold | * | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | * | Asahi Pretec Corp. | JAPAN |
| Gold | * | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | * | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | * | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Gold | * | Torecom | KOREA, REPUBLIC OF |
| Gold | * | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
| Gold | * | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Tungsten | * | H.C. Starck Tungsten GmbH | GERMANY |
| Gold | * | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | * | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | * | Asaka Riken Co., Ltd. | JAPAN |
| Tungsten | * | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tantalum | * | Jiujiang Tanbre Co., Ltd. | CHINA |
| Gold | * | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | * | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | * | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Tantalum | * | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Gold | * | Yamakin Co., Ltd. | JAPAN |
| Tantalum | * | FIR Metals & Resource Ltd. | CHINA |
| Gold | * | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Tin | * | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Gold | * | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Tungsten | * | Japan New Metals Co., Ltd. | JAPAN |
| Tantalum | * | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | * | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | * | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Gold | * | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tantalum | * | TANIOBIS Japan Co., Ltd. | JAPAN |
| Gold | * | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | * | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Tungsten | * | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tantalum | * | LSM Brasil S.A. | BRAZIL |
| Gold | * | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Tantalum | * | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tungsten | * | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tantalum | * | TANIOBIS Co., Ltd. | THAILAND |
| Tantalum | * | H.C. Starck Hermsdorf GmbH | GERMANY |
| Gold | * | T.C.A S.p.A | ITALY |
| Tungsten | * | A.L.M.T. Corp. | JAPAN |
| Gold | * | DODUCO Contacts and Refining GmbH | GERMANY |
| | | | | | | | | | | |
| Tungsten | * | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | * | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | * | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | * | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | * | Telex Metals | UNITED STATES OF AMERICA |
| Gold | * | Umicore Precious Metals Thailand | THAILAND |
| Tantalum | * | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | * | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tungsten | * | Masan High-Tech Materials | VIET NAM |
| Gold | * | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | * | AU Traders and Refiners | SOUTH AFRICA |
| Gold | * | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | * | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Tantalum | * | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | * | QuantumClean | UNITED STATES OF AMERICA |
| Tungsten | * | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tantalum | * | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tungsten | * | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tantalum | * | KEMET de Mexico | MEXICO |
| Gold | * | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | * | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Tantalum | * | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
| Tantalum | * | Mineracao Taboca S.A. | BRAZIL |
| Tungsten | * | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tantalum | * | Resind Industria e Comercio Ltda. | BRAZIL |
| Gold | * | SAAMP | FRANCE |
| Tungsten | * | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Gold | * | Chugai Mining | JAPAN |
| Tantalum | * | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tungsten | * | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tantalum | * | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Gold | * | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Tungsten | * | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tantalum | * | Jiangxi Tuohong New Raw Material | CHINA |
| Tungsten | * | Moliren Ltd. | RUSSIAN FEDERATION |
| Tantalum | * | NPM Silmet AS | ESTONIA |
| Tantalum | * | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Gold | * | REMONDIS PMR B.V. | NETHERLANDS |
| Tungsten | * | ACL Metais Eireli | BRAZIL |
| Tungsten | * | Kennametal Fallon | UNITED STATES OF AMERICA |
| Gold | * | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Tungsten | * | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | * | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Gold | * | Bangalore Refinery | INDIA |
| Tin | * | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tungsten | * | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | * | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Gold | * | Marsam Metals | BRAZIL |
| Gold | * | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| | | | | | | | | | | |
| Gold | * | LT Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | * | Italpreziosi | ITALY |
| Tungsten | * | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | * | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tin | * | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM |
| Tantalum | * | Meta Materials | NORTH MACEDONIA, REPUBLIC OF |
| Gold | * | Planta Recuperadora de Metales SpA | CHILE |
| Gold | * | Safimet S.p.A | ITALY |
| Gold | * | TSK Pretech | KOREA, REPUBLIC OF |
| Gold | * | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | * | 8853 S.p.A. | ITALY |
| Tantalum | * | Asaka Riken Co., Ltd. | JAPAN |
| Tungsten | * | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
| Tin | * | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Gold | * | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Tin | * | Estanho de Rondonia S.A. | BRAZIL |
| Gold | * | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Tungsten | * | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
| Tin | * | PT Bangka Serumpun | INDONESIA |
| Gold | | Caridad | MEXICO |
| Gold | | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | | Guangdong Jinding Gold Limited | CHINA |
| Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Tin | | Modeltech Sdn Bhd | MALAYSIA |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| Tin | * | PT Bukit Timah | INDONESIA |
| Tin | * | PT Prima Timah Utama | INDONESIA |
| Tin | * | PT Tinindo Inter Nusa | INDONESIA |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | | Refinery of Seemine Gold Co., Ltd. | CHINA |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | | Lingbao Gold Co., Ltd. | CHINA |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | | Morris and Watson | NEW ZEALAND |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | * | Super Ligas | BRAZIL |
| Gold | | Sai Refinery | INDIA |
| Gold | | Pease & Curren | UNITED STATES OF AMERICA |
| Gold | | QG Refining, LLC | UNITED STATES OF AMERICA |
| Tungsten | * | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | | Shandong Humon Smelting Co., Ltd. | CHINA |
| | | | | | | | | | | |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Gold | | Modeltech Sdn Bhd | MALAYSIA |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| Tungsten | * | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| Tin | * | PT Stanindo Inti Perkasa | INDONESIA |
| Gold | | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| Gold | * | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| Gold | | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| Tin | * | PT Babel Inti Perkasa | INDONESIA |
| Gold | | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| Gold | | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Tin | | Pongpipat Company Limited | MYANMAR |
| Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tungsten | * | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Gold | | CGR Metalloys Pvt Ltd. | INDIA |
| Tin | | Precious Minerals and Smelting Limited | INDIA |
| Tin | * | PT Aries Kencana Sejahtera | INDONESIA |
| Gold | | Value Trading | BELGIUM |
| Tin | * | PT Menara Cipta Mulia | INDONESIA |
| Gold | | African Gold Refinery | UGANDA |
| Gold | | Sovereign Metals | INDIA |
| Tin | * | CV Venus Inti Perkasa | INDONESIA |
| Tungsten | * | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tin | * | PT Rajehan Ariq | INDONESIA |
| Gold | * | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Tin | * | PT Sukses Inti Makmur | INDONESIA |
| Gold | * | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | * | CV Ayi Jaya | INDONESIA |
| Tin | | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| Tin | * | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| Tin | * | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | * | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | * | Luna Smelter, Ltd. | RWANDA |
| Gold | | JALAN & Company | INDIA |
| Gold | | Gold Coast Refinery | GHANA |
| Gold | * | C.I Metales Procesados Industriales SAS | COLOMBIA |
| Tungsten | * | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tin | * | PT Lautan Harmonis Sejahtera | INDONESIA |
| Tungsten | * | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| Tungsten | * | GEM Co., Ltd. | CHINA |
| Gold | | Kundan Care Products Ltd. | INDIA |
| Gold | | Shirpur Gold Refinery Ltd. | INDIA |
| | | | | | | | | | | |
| Tungsten | * | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tin | | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | * | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| Tin | | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | | PT Cipta Persada Mulia | INDONESIA |
| Gold | * | Augmont Enterprises Private Limited | INDIA |
| Tin | * | PT Timah Nusantara | INDONESIA |
| Gold | | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| Gold | | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | * | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Gold | * | L'Orfebre S.A. | ANDORRA |
| Tin | * | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | | PT Masbro Alam Stania | INDONESIA |
| Gold | | K.A. Rasmussen | NORWAY |
* = Conformant or actively participating in the RMI Responsible Minerals Assurance Process (as reported by RMI as of April 28, 2021).
ANNEX II
POSSIBLE COUNTRIES OF ORIGIN OF MINERALS PROCESSED BY SUPPLIER-REPORTED
SMELTERS AND REFINERS*
| | | | | | | | |
| Argentina | Ghana | Peru |
| Australia | Guatemala | Philippines |
| Austria | Guinea | Portugal |
| Azerbaijan | Guyana | Puerto Rico |
| Benin | Honduras | Russian Federation |
| Bolivia (Plurinational State of) | India | Rwanda |
| Botswana | Indonesia | Saudi Arabia |
| Brazil | Iran | Senegal |
| Burkina Faso | Ivory Coast | Serbia |
| Burundi | Japan | Sierra Leone |
| Canada | Kazakhstan | Slovakia |
| Chile | Kenya | Solomon Islands |
| China | Laos | South Africa |
| Colombia | Liberia | Spain |
| Congo, Democratic Republic of the | Madagascar | Suriname |
| Costa Rica | Malaysia | Swaziland |
| Cote d'Ivoire | Mali | Sweden |
| Cuba | Mauritania | Taiwan |
| Cyprus | Mexico | Tajikistan |
| Dominican Republic | Mongolia | Tanzania |
| Ecuador | Morocco | Thailand |
| Egypt | Mozambique | Turkey |
| Eritrea | Myanmar | Uganda |
| Ethiopia | Namibia | United Kingdom of Great Britain and Northern Ireland |
| Fiji | Netherlands | United States of America |
| Finland | New Zealand | Uruguay |
| France | Nicaragua | Venezuela |
| French Guiana | Niger | Vietnam |
| Georgia | Nigeria | Zimbabwe |
| Germany | Papua New Guinea | |
*The list of possible countries of origin of Minerals processed by supplier-reported smelters and refiners is based upon RCOI 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.
