Exhibit 1.01
EATON CORPORATION plc
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2023
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: https://www.eaton.com/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.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 (Eaton or the Company) is an intelligent power management company dedicated to protecting the environment and improving the quality of life for people everywhere. We make products for the data center, utility, industrial, commercial, machine building, residential, aerospace and mobility markets. We are well positioned to capitalize on the megatrends of electrification, energy transition and digitalization. The reindustrialization of North America and Europe, growth in North American megaprojects, and increased global infrastructure spending focused on clean energy programs are expanding our end markets and positioning Eaton for growth for years to come. We are strengthening our participation across the entire electrical power value chain and benefiting from momentum in the data center and utility end markets as well as a growth cycle in the commercial aerospace and defense markets. We are guided by our commitment to operate sustainably and with the highest ethical standards. Our work is accelerating the planet’s transition to renewable energy sources, helping to solve the world’s most urgent power management challenges, and building a more sustainable society for people today and for future generations.
Eaton was founded in 1911 and has been listed on the New York Stock Exchange for more than a century. We reported revenues of $23.2 billion in 2023 and serve customers in more than 160 countries.
Eaton has five key business segments: Electrical Americas and Electrical Global, Aerospace, Vehicle, and eMobility. In 2023 Eaton considers all products to be in-scope and include, but are not limited to:
Electrical Americas and Electrical Global
These segments consist 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. Electrical Systems and Services is also a part of this segment and 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.
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.
For additional information about our business segments, including the wide variety of products manufactured in each segment, refer to Eaton's 2023 Form 10-K.
2.REASONABLE COUNTRY OF ORIGIN INQUIRY
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 business segments. Our supply chain is multi-tiered, and Eaton is typically many levels removed from the mines, smelters and 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 the reporting period from January 1 through December 31, 2023, 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 Conflict Affected and High Risk Areas (CAHRAs) including 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. 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 CAHRAs including the DRC and adjoining countries and requires suppliers and smelters or refiners to source responsibly from these regions. 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) which can be used by employees, suppliers or other stakeholders to report any concerns relating to Eaton’s sourcing 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 2023 we solicited approximately 1,000 suppliers.
We verified the information provided by our suppliers (to the extent possible) by comparing it to the information shared on the RMI website and monthly plenary calls, and against CMRT acceptance criteria for completeness and consistency of responses. Through this process, for suppliers who provided names of smelters and refiners, we determined the conformance 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 smelters and refiners conformant to RMI’s Responsible Minerals Assurance Process (RMAP), 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 determine the conformance 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, LBMA, and RCS Global Group’s Better Mining Project, with which RMI collaborates to jointly address Minerals issues in CAHRAs including 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 flags receive follow-up communication to remind them of Eaton’s expectations relating to the use and sourcing of Minerals as well as support and resources including training available to them through our membership in RMI. Corrective action plans are assigned as needed to ensure suppliers improve on their due diligence practices and comply with Eaton’s Purchase Order Terms and Conditions and the Code.
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. In addition, Eaton has contributed financially to RCS Global Group’s Better Mining program which has been recognized as a valid upstream assurance mechanism for its work to address risks associated with artisanal small mines.
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.
4.RESULTS OF REVIEW
For the reporting period of January 1, 2023 through December 31, 2023, 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, 2023, 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 CAHRAs including 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 comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as per Eaton’s policy.
ANNEX I
• | | | | | | | | | | | |
| Metal | Status | Smelter or Refiner Name | Country Location of Smelter or Refiner |
| Gold | * | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | * | Asahi Pretec Corp. | JAPAN |
| Gold | * | Asaka Riken Co., Ltd. | JAPAN |
| Gold | * | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Gold | * | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | * | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | * | Asahi Refining Canada Ltd. | CANADA |
| Gold | * | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | * | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | * | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | * | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | * | Materion | UNITED STATES OF AMERICA |
| Gold | * | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | * | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | * | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | * | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | * | Metalor 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 | * | Nihon Material Co., Ltd. | JAPAN |
| Gold | * | Royal Canadian Mint | CANADA |
| Gold | * | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | * | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | * | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | * | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | * | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
| Gold | * | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | * | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | * | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | | Augmont Enterprises Private Limited | INDIA |
| Gold | | Alexy Metals | UNITED STATES OF AMERICA |
| Gold | * | WEEEREFINING | FRANCE |
| Gold | | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | * | LT Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | * | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | * | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | * | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Gold | | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | * | T.C.A S.p.A | ITALY |
| Gold | * | REMONDIS PMR B.V. | NETHERLANDS |
| Gold | * | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| | | | | | | | | | | |
| Gold | * | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | | SAAMP | FRANCE |
| Gold | * | L.Orfebre S.A. | ANDORRA |
| Gold | | 8853 S.p.A. | ITALY |
| Gold | * | Italpreziosi | ITALY |
| Gold | * | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | * | SAFINA A.S. | CZECHIA |
| Gold | | Bangalore Refinery | INDIA |
| Gold | * | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | * | Planta Recuperadora de Metales SpA | CHILE |
| Gold | | Safimet S.p.A | ITALY |
| Gold | * | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | * | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | * | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Gold | * | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| Gold | * | Chimet S.p.A. | ITALY |
| Gold | * | Chugai Mining | JAPAN |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | * | Heimerle + Meule GmbH | GERMANY |
| Gold | * | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | * | Kazzinc | KAZAKHSTAN |
| Gold | * | Kosak Seiren | JAPAN |
| Gold | | Lingbao Gold Co., Ltd. | CHINA |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | * | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| Gold | * | Istanbul Gold Refinery | TURKEY |
| Gold | * | Japan Mint | JAPAN |
| Gold | * | JCC | CHINA |
| Gold | * | Metalor Switzerland | SWITZERLAND |
| Gold | * | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | * | SEMPSA Joyería Platería S.A. | SPAIN |
| Gold | * | Shan Dong Huangjin | CHINA |
| Gold | * | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| Gold | | Shandong Tarzan Bio-Gold Industry Co., Ltd. | CHINA |
| Gold | * | Zhaojin Mining Industry Co., Ltd. | CHINA |
| Gold | | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | | Anhui Tongling Nonferrous Metal Mining Co., Ltd. | CHINA |
| Gold | * | Umicore Precious Metals Refining Hoboken | BELGIUM |
| Gold | * | Shonan Plant Tanaka Kikinzoku | JAPAN |
| Gold | | Great Wall Precious Metals Co,. LTD. | CHINA |
| Gold | * | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | * | Zijin Mining Industry Corporation | CHINA |
| Gold | | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| Gold | | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| Gold | | Shirpur Gold Refinery Ltd. | INDIA |
| | | | | | | | | | | |
| Gold | | Marsam Metals | BRAZIL |
| Gold | | Gold Coast Refinery | GHANA |
| Gold | | Shandong Humon Smelting Co., Ltd. | CHINA |
| Gold | | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| Gold | | Sai Refinery | INDIA |
| Gold | | DEGUSSA | GERMANY |
| Gold | | JALAN & Company | INDIA |
| Gold | | Sovereign Metals | INDIA |
| Gold | | MD Overseas | INDIA |
| Gold | | Kundan Care Products Ltd. | INDIA |
| Gold | | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
| Gold | | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
| Gold | | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
| Gold | | K.A. Rasmussen | NORWAY |
| Gold | * | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | * | Valcambi S.A. | SWITZERLAND |
| Gold | | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| Gold | | Refinery of Seemine Gold Co., Ltd. | CHINA |
| Gold | | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | | Morris and Watson | NEW ZEALAND |
| Gold | | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | | AU Traders and Refiners | SOUTH AFRICA |
| Gold | * | PX Precinox S.A. | SWITZERLAND |
| Gold | * | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | * | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | * | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | * | Yamakin Co., Ltd. | JAPAN |
| Gold | * | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | * | Torecom | KOREA, REPUBLIC OF |
| Gold | * | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | | Umicore Precious Metals Thailand | THAILAND |
| Gold | | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
| Gold | | Industrial Refining Company | BELGIUM |
| Gold | * | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | | L.azurde Company For Jewelry | SAUDI ARABIA |
| Gold | | Sudan Gold Refinery | SUDAN |
| Gold | | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | | Caridad | MEXICO |
| Gold | * | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | * | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | | Pease & Curren | UNITED STATES OF AMERICA |
| Gold | | QG Refining, LLC | UNITED STATES OF AMERICA |
| | | | | | | | | | | |
| Gold | | Modeltech Sdn Bhd | MALAYSIA |
| Gold | | Guangdong Jinding Gold Limited | CHINA |
| Gold | | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| Gold | * | Aurubis AG | GERMANY |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | * | PAMP S.A. | SWITZERLAND |
| Gold | * | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | * | Boliden AB | SWEDEN |
| Gold | | Metallix Refining Inc. | UNITED STATES OF AMERICA |
| Gold | * | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | | CGR Metalloys Pvt Ltd. | INDIA |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | * | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Tantalum | * | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | | Exotech Inc. | UNITED STATES OF AMERICA |
| Tantalum | * | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | * | LSM Brasil S.A. | BRAZIL |
| Tantalum | * | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | * | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | * | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | * | RFH | CHINA |
| Tantalum | * | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | * | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | * | TANIOBIS GmbH | GERMANY |
| Tantalum | * | H.C. Starck Inc. | UNITED STATES OF AMERICA |
| Tantalum | * | H.C. Starck Ltd. | JAPAN |
| Tantalum | * | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tantalum | * | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | * | Global Advanced Metals Aizu | JAPAN |
| Tantalum | * | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | * | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | * | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | * | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | * | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | * | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | * | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | * | NPM Silmet AS | ESTONIA |
| Tantalum | * | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | * | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | * | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | * | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | * | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | * | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | * | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | * | KEMET Blue Metals | MEXICO |
| Tantalum | * | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | * | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| | | | | | | | | | | |
| Tantalum | * | Jiujiang Janny New Material Co., Ltd. | CHINA |
| Tantalum | | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
| Tantalum | * | Plansee SE Reutte | AUSTRIA |
| Tantalum | * | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA |
| Tin | * | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | * | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | * | PT Timah Tbk Kundur | INDONESIA |
| Tin | * | PT Timah Tbk Mentok | INDONESIA |
| Tin | * | PT Tinindo Inter Nusa | INDONESIA |
| Tin | * | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | * | Soft Metais Ltda. | BRAZIL |
| Tin | * | Thaisarco | THAILAND |
| Tin | * | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | * | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | * | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| Tin | * | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | * | PT Cipta Persada Mulia | INDONESIA |
| Tin | * | Metallo Belgium N.V. | BELGIUM |
| Tin | * | PT Menara Cipta Mulia | INDONESIA |
| Tin | * | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | * | PT Bangka Serumpun | INDONESIA |
| Tin | * | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | | Ma.anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | * | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | * | Luna Smelter, Ltd. | RWANDA |
| Tin | * | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | * | Fenix Metals | POLAND |
| Tin | * | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | * | China Tin Group Co., Ltd. | CHINA |
| Tin | * | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | * | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | * | Mineracao Taboca S.A. | BRAZIL |
| Tin | * | Minsur | PERU |
| Tin | * | Mitsubishi Materials Corporation | JAPAN |
| Tin | * | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | * | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | * | PT Artha Cipta Langgeng | INDONESIA |
| Tin | * | PT Babel Inti Perkasa | INDONESIA |
| Tin | * | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | * | PT Bukit Timah | INDONESIA |
| Tin | * | PT Mitra Stania Prima | INDONESIA |
| Tin | * | PT Prima Timah Utama | INDONESIA |
| Tin | * | PT Refined Bangka Tin | INDONESIA |
| Tin | * | CV Venus Inti Perkasa | INDONESIA |
| Tin | * | Alpha | UNITED STATES OF AMERICA |
| Tin | * | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | * | Dowa | JAPAN |
| Tin | | Melt Metais e Ligas S.A. | BRAZIL |
| | | | | | | | | | | |
| Tin | * | Metallo Spain S.L.U. | SPAIN |
| Tin | * | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | * | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | * | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | * | PT Rajehan Ariq | INDONESIA |
| Tin | * | CV Ayi Jaya | INDONESIA |
| Tin | * | PT Premium Tin Indonesia | INDONESIA |
| Tin | * | Feinhutte Halsbrucke GmbH | GERMANY |
| Tin | * | PT Bangka Prima Tin | INDONESIA |
| Tin | | PT Bangka Tin Industry | INDONESIA |
| Tin | * | Super Ligas | BRAZIL |
| Tin | * | PT Sukses Inti Makmur | INDONESIA |
| Tin | * | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | * | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | * | PT Timah Nusantara | INDONESIA |
| Tin | * | Magnu.s Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | * | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | * | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | * | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | * | CRM Synergies | SPAIN |
| Tin | * | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL |
| Tin | * | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
| Tin | * | Estanho de Rondonia S.A. | BRAZIL |
| Tin | | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | * | PT Tommy Utama | INDONESIA |
| Tin | | PT Panca Mega Persada | INDONESIA |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
| Tin | | Pongpipat Company Limited | MYANMAR |
| Tin | | PT Tirus Putra Mandiri | INDONESIA |
| Tin | | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| Tin | | Precious Minerals and Smelting Limited | INDIA |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
| Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tin | | Modeltech Sdn Bhd | MALAYSIA |
| Tin | * | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | | VQB Mineral and Trading Group JSC | VIETNAM |
| Tin | * | DS Myanmar | MYANMAR |
| Tungsten | * | A.L.M.T. Corp. | JAPAN |
| Tungsten | * | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | * | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| | | | | | | | | | | |
| Tungsten | * | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | * | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | * | Masan Tungsten Chemical LLC (MTC) | VIETNAM |
| Tungsten | | ACL Metais Eireli | BRAZIL |
| Tungsten | * | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | * | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | * | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | * | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | * | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | * | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | * | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | * | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
| Tungsten | * | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | * | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | * | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | * | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | * | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Fujian Xinlu Tungsten Co., Ltd. | CHINA |
| Tungsten | * | Hubei Green Tungsten Co., Ltd. | CHINA |
| Tungsten | | Sanher Tungsten Vietnam Co., Ltd. | VIETNAM |
| Tungsten | * | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | * | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | * | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tungsten | | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tungsten | | Jiangxi Minmetals Gao.an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF |
* = Conformant or actively participating in the RMI Responsible Minerals Assurance Process (as reported by RMI as of February 08, 2024).
ANNEX II
POSSIBLE COUNTRIES OF ORIGIN OF MINERALS PROCESSED BY SUPPLIER-REPORTED
SMELTERS AND REFINERS*
| | | | | | | | |
| Benin | Namibia | Malta |
| Canada | New Zealand | Mauritius |
| Chile | Oman | Monaco |
| Guyana | Panama | Netherlands |
| Papua New Guinea | Peru | Nigeria |
| Philippines | Russia | Norway |
| South Africa | Saudi Arabia | Pakistan |
| Korea, Republic of | Senegal | Poland |
| Sweden | Serbia | Portugal |
| Uzbekistan | Spain | Puerto Rico |
| Bolivia (Plurinational State of) | Sudan | Romania |
| Colombia | Suriname | Singapore |
| Nicaragua | Turkey | Slovakia |
| Niger | United States of America | Slovenia |
| Tanzania | Algeria | Switzerland |
| Zimbabwe | Andorra | Tajikistan |
| Argentina | Austria | Thailand |
| Australia | Bangladesh | Trinidad and Tobago |
| Azerbaijan | Belarus | Tunisia |
| Botswana | Belgium | Ukraine |
| Brazil | Bosnia and Herzegovina | United Arab Emirates |
| Burkina Faso | Bulgaria | United Kingdom of Great Britain and Northern Ireland |
| Cambodia | Chinese Taipei | Uruguay |
| China | Croatia | Viet Nam |
| Côte d'Ivoire | Cyprus | Bolivia |
| Dominican Republic | Czech Republic | French Guiana |
| Ecuador | Denmark | Morrocco |
| Egypt | Estonia | Mozambique |
| Fiji | France | Burundi |
| Finland | Germany | Rwanda |
| Georgia | Greece | Congo, Democratic Republic of the |
| Ghana | Hong Kong | Laos |
| Guatemala | Hungary | Myanmar |
| Guinea | Iceland | United Kingdom |
| Honduras | India | Vietnam |
| Indonesia | Ireland | Ethiopia |
| Japan | Israel | Madagascar |
| Kazakhstan | Italy | Sierra Leone |
| Kenya | Jamaica | |
| Kyrgyzstan | Jordan | |
| Lao People's Democratic Republic | Latvia | |
| Liberia | Lebanon | |
| Mali | Liechtenstein | |
| Mauritania | Lithuania | |
| | | | | | | | |
| Mexico | Luxembourg | |
| Mongolia | Macao | |
| Morocco | Malaysia | |
*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.
