Exhibit 1.01
Mazor Robotics Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2016
This report for the year ended December 31, 2016 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to Conflict Minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain Conflict Minerals which are necessary to the functionality or production of their products. "Conflict Minerals" are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG") for the purposes of this assessment.
If a registrant can establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the "Covered Countries"), or from recycled and scrap sources, it must disclose its determination, provide a brief description of the inquiry it undertook and the results of the inquiry on Form SD.
If a registrant has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals' source and chain of custody. The registrant must annually submit a report, Conflict Minerals Report (the "CMR"), as an exhibit to its Form SD to the SEC that includes a description of those due diligence measures.
1. Overview
This report has been prepared by management of Mazor Robotics Ltd. (herein referred to as "Mazor", "Mazor Robotics", "Company", "we", "us", or "our"). The information includes the activities of Mazor's wholly owned subsidiaries.
We engage in the development, production and marketing of innovative medical devices for supporting surgical procedures in the fields of orthopedics and neurosurgery. We operate in the fields of image guided surgery and computer-assisted surgery enabling the use of surgical instruments with high precision and minimal invasiveness and aiming to simplify complex and minimally-invasive surgical procedures. We believe that our portfolio of products, including the recently launched Mazor X Surgical Guidance System (the "Mazor X"), and the Renaissance® Surgical Guidance System (the "Renaissance" and together with the Mazor X, the "Products"), are transforming spine surgery from freehand procedures to highly accurate, state-of-the-art, guided procedures that raise the standard of care with better clinical results.
Our customers are mainly comprised of hospitals, medical centers, academic centers and medical device distributors. We sell our Products and services in the United States through our direct sales force, and in most other territories, we mainly sell our Products using third-party distributors.
Mazor is committed to the highest ethical standards and to conducting its business with the highest level of integrity, as defined in our Code of Business Conduct and Ethics. We strive to source materials from companies that share our values around human rights, ethics and environmental responsibility. We conducted an analysis of our Products and found the presence of 3TG materials. Therefore, the Products that we manufacture are subject to the reporting obligations of the Rule.
2. Supply Chain Overview
Mazor does not purchase Conflict Minerals directly from mines, smelters or refiners, and tracing these minerals to their sources is a challenge that requires us to rely on suppliers and manufacturers ("Suppliers") in the efforts to achieve supply chain transparency, including obtaining information regarding the origin of the Conflict Minerals. Our Suppliers are expected to provide the 3TG sourcing information to us per our Conflict Minerals Policy.
3. Reasonable Country of Origin Inquiry (RCOI)
We performed an internal assessment and prioritized the list of Suppliers to approach. In the first step we conducted a comprehensive analysis of our Products components and identified potential 3TG Suppliers ("Potential 3TG Suppliers"). We contacted the identified Potential 3TG Suppliers to further investigate the possibility of 3TG minerals presence within our Products. We identified 92 Potential 3TG Suppliers whose products can potentially include 3TG.
We believe that implementing the OECD guidelines and using the Conflict-Free Sourcing Initiative ("CFSI") template to gather information from smelters and refiners are currently the best known efforts to obtain mine and country of origin information.
Due to the size of the company, the breadth, the complexity of our Products and the dynamic nature of our supply chain, it is challenging to identify the source and origin of the 3TG incorporated in our Products. The manufacturing process for Mazor's Products is significantly removed from the mining, smelting and refining of Conflict Minerals, therefore, we must rely on our direct Suppliers to assist us in obtaining information regarding the origin of the Conflict Minerals. We reached out to those Suppliers through letters and questionnaires designed to explain the relevant SEC requirements and Mazor's due diligence expectations as well as refer them to online training materials and instructions. Suppliers were asked to provide us with information regarding 3TG and smelters using the Conflict Minerals Reporting Template ("CMRT") developed by the CFSI.
We engaged with a global third-party service provider to compile the survey results, we reviewed the responses that we received and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to Suppliers who did not respond to our requests for information. We received response from 47 Suppliers who represent 51% of our Potential 3TG Suppliers.
Based on information obtained, and taking into account the complexities of our supply chain, we do not have sufficient information from our Suppliers to determine the country of origin of the conflict minerals used in our Products or the facilities used to process those conflict minerals. Therefore, we cannot exclude the possibility that some of these conflict minerals may have originated in the Covered Countries and are not from recycled or scrap sources.
Based on this result, Mazor undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of its Products during 2016. There is significant overlap between our RCOI efforts and our due diligence measures performed.
4. Due Diligence Program
4.1. Design of Our Due Diligence and Description of the Due Diligence Process
Our due diligence processes and efforts have been designed and developed in conjunction with The Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance") and the related supplements for gold and for tin, tantalum and tungsten. That includes the following measures:
Step 1: Establish Strong Company Management Systems;
Step 2: Identify and Assess Risk in the Supply Chain;
Step 3: Design and Implement Strategy to Respond to Risks;
Step 4: Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Point in the Supply Chain; and
Step 5: Report Annually on Supply Chain Due Diligence.
4.2. Due Diligence Process
4.2.1. Establish Strong Company Management Systems
Our Conflict Minerals due diligence process includes: the development of a Conflict Minerals Policy, establishment of governance structures with cross functional team members and senior executives, communication to, and engagement of, Suppliers, due diligence compliance process and measurement and record keeping and escalation procedures. We report from time to time to the Audit Committee of the Board of Directors with respect to our due diligence process and compliance obligations.
4.2.1.1. Conflict Minerals Policy
Mazor believes that ethical business conduct is critical to its operations and therefore has established a Code of Business Conduct and Ethics. Mazor is concerned that the trade of conflict minerals mined in the Covered Countries may be fueling human rights atrocities in the region. Therefore, Mazor has adopted a Conflict Minerals Policy. As described in the policy, Mazor is striving to source materials from companies that share our values around human rights, ethics and environmental responsibility. We expect our Suppliers to comply with our Conflict Mineral Policy. The Policy is available on the Company's website at www.MazorRobotics.com under "Investor Relations\ Corporate Governance".
4.2.1.2. Management Systems and internal team
Mazor has created a Conflict Minerals taskforce and engaged with an external consultant to ensure compliance with the Rule. Our taskforce led by our Chief Operations Officer ("COO"), Chief Financial Officer ("CFO"), and a team of subject matter experts from relevant functions such as purchasing and manufacturing. The taskforce is in-charge of ongoing communication with the Potential 3TG Suppliers, to obtain Conflict Minerals evaluation results, to perform the required procedures to ensure that the responses received from our Suppliers are adequate in light of the Rule and to deal with all issues that are to be addressed according to ROCI and the due diligence program.
4.2.1.3 Control systems
We utilize the CFSI reporting template to collect data and information from our Suppliers in order to identify the 3TG origin in our supply chain. We also engage with a global third party service provider to assist us with the identification of the smelters and refiners which process the 3TG in our Products. Mazor has established our due diligence compliance process and set forth documentation and record maintenance mechanism to ensure the retaining of relevant documentation in a structured electronic database, for 5 years.
4.2.1.4 Supplier Engagement
We sent letters informing the Suppliers that Mazor is subject to the Rule, advised them of Mazor's commitment to responsible sourcing of minerals, and indicated that their cooperation in the due diligence efforts is expected, including by completion of the CMRT. We have also engaged with a global third party service provider to facilitate training and outreach to Suppliers, as well as to conduct, collect, validate and archive Supplier responses. We are in a process of implementing conflict minerals clause that requires Suppliers to provide us with information about the source of 3TG in the products they provide us.
4.2.1.5 Grievance Mechanism
Our Conflict Minerals Policy is available to the public on our website and provides the contact details for reporting concerns or seeking guidance regarding our Conflict Minerals program.
4.2.2. Identify and assess risk in the supply chain
As described above, we identified through a comprehensive analysis of our Products 92 Potential 3TG Suppliers. We reached out to those Suppliers through letters and questionnaires designed to explain the relevant SEC requirements and Mazor's due diligence expectations as well as refer them to online training materials and instructions. Suppliers were asked to provide us with information regarding 3TG and smelters using the CMRT. We received responses from 47 Suppliers. We compared the information provided therein with the CFSI Conflict Free smelter list.
4.2.3. Design and Implement Strategy to Respond to Risks
Each CMRT received from our Suppliers was entered into a database maintained by a global third party service provider and reviewed. For non-responsive Suppliers or Suppliers which provided unclear or incomplete responses, an escalation process was used in order to obtain complete and accurate required information, sometimes requiring multiple telephone and/or email contacts to further the data collection process. Potential 3TG Suppliers that were identified as possibly sourcing 3TG not from smelters designated as conflict free according to CFSI, were contacted and required to provide a corrective action plan. We are communicating to all of our Suppliers the importance of compliance and have a Conflict Minerals management program in place to collect, analyze, store and monitor the results of our inquires. Our COO and CFO are briefed about the results of our due diligence efforts on a timely basis.
4.2.4. Carry Out Independent Third Party Audit of Supply Chain Due Diligence
Mazor does not have direct sourcing relationships with Conflict Mineral smelters or refiners. Where possible, we have relied on third-party assurances and certifications, such as the CFSI's Conflict Free Smelter Program ("CFSP").
4.2.5. Report Annually on Supply Chain Due Diligence
Our Conflict Mineral annual report is available on the Company's website at www.MazorRobotics.com under "Investor Relations\ Corporate Governance" and is filed with the SEC.
5. Results of Assessment:
5.1. Survey Responses
As indicated above, the Products that we manufacture, or contract to manufacture, are highly complex, and typically contain thousands of components from many Suppliers. Since there are generally multiple tiers between the mines that extract Conflict Minerals and our Suppliers, we relied on our Suppliers to provide information on the origin of the Conflict Minerals contained in components supplied to us.
Most of our Suppliers were unable to provide information at product level, and therefore Mazor cannot clearly identify the source of origin of the 3TG included in its products.
Based on information provided by our Potential 3TG Suppliers as well as by CFSI, the results of our due diligence investigations as of the date of this Report are as follows:
Based on the information we received from these Suppliers, we identified 316 smelters, of which 261 smelters or refiners, or 83%, have been certified as Conflict Free by the CFSI, or have been engaged in an audit process ("Active"). We have identified 2 smelters that were not designated as conflict free by the CFSI, from the Covered Countries. As of the date of this report, one of those smelters no longer operates. We are in communication with our supplier regarding the other smelter and are still under valuation.
Based on the information provided by the relevant Suppliers as well as by CFSI, as of the date of this Report, the facilities that may have been used to process the Conflict Minerals in our Products may include the smelters and refiners listed in Annex I below.
Based on the information provided by the relevant Suppliers as well as by CFSI, as of the date of this Report, the mine countries of origin of the Conflict Minerals contained in our Products may include one or more of the countries listed in Annex II below.
Please note that information gathered from Mazor's Suppliers is not on a continuous, real-time basis, and that, since the information comes from direct and secondary Suppliers and independent third party audit programs, Mazor can only provide reasonable (not absolute) assurance regarding the source and chain of custody of the necessary Conflict Minerals.
6. Continuous Improvement Efforts to Mitigate Risk
As we move forward with our due diligence program, we intend to enhance Supplier communication, training process to improve due diligence data accuracy and completion. We will consider taking the following steps to improve the due diligence that we conduct to further mitigate any risk that the Conflict Minerals in our Products could benefit armed groups in the Covered Countries:
| | a. | Periodically engage with Suppliers to attempt to increase the response rate to our inquiries and to improve the accuracy of the Supplier responses, including responses that were identified as incomplete, inconsistent or inaccurate. |
| | b. | Subject to the Rule, continue to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals. |
| | c. | Validate Supplier responses regarding smelters and refiners using information collected from reliable industry certification programs. |
| | d. | Continue to compare smelters and refiners identified by our supply chain survey against lists of facilities that have received a third-party "conflict free" designation in order to track those that have not received such a designation. |
| | e. | Continue to report to management on the findings of our supply chain risk assessment. |
Caution Concerning Forward-Looking Statements
Any statements contained in this report regarding future expectations, beliefs, goals, plans or prospects constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Further, any statements that are not statements of historical fact (including statements containing the words "believes," "anticipates," "plans," "expects," "may," "will," "would," "intends," "estimates" and similar expressions) should also be considered to be forward-looking statements. The forward-looking statements included herein are based on current expectations and beliefs that involve a number of known and unknown risks and uncertainties. Examples of forward-looking statements in this document include statements relating to our future plans. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. There are a number of factors that could cause events to differ materially from those indicated by the forward-looking statements in this document, including the risks associated with our Suppliers not cooperating fully or at all with our efforts. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.
Annex I - List of identified smelters or refiners
| Number | Metal | Smelter Name | Smelter Country |
| 1 | Gold | Bangalore Refinery | INDIA |
| 2 | Gold | Modeltech Sdn Bhd | MALAYSIA |
| 3 | Gold | Universal Precious Metals Refining Zambia | ZAMBIA |
| 4 | Gold | Sai Refinery | INDIA |
| 5 | Gold | Gujarat Gold Centre | INDIA |
| 6 | Gold | AURA-II | UNITED STATES OF AMERICA |
| 7 | Gold | AU Traders and Refiners | SOUTH AFRICA |
| 8 | Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| 9 | Gold | WIELAND Edelmetalle GmbH | GERMANY |
| 10 | Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| 11 | Gold | SAAMP | FRANCE |
| 12 | Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| 13 | Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| 14 | Gold | Korea Zinc Co., Ltd. | KOREA (REPUBLIC OF) |
| 15 | Gold | Tony Goetz NV | BELGIUM |
| 16 | Gold | Remondis Argentia B.V. | NETHERLANDS |
| 17 | Gold | T.C.A S.p.A | ITALY |
| 18 | Gold | Sudan Gold Refinery | SUDAN |
| 19 | Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| 20 | Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| 21 | Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| 22 | Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| 23 | Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| 24 | Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
| 25 | Gold | Republic Metals Corporation | UNITED STATES OF AMERICA |
| 26 | Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| 27 | Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| 28 | Gold | Umicore Precious Metals Thailand | THAILAND |
| 29 | Gold | Guangdong Jinding Gold Limited | CHINA |
| 30 | Gold | Safina a.s. | CZECH REPUBLIC |
| 31 | Gold | Morris and Watson | NEW ZEALAND |
| 32 | Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
| 33 | Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| 34 | Gold | Yokohama Metal Co., Ltd. | JAPAN |
| 35 | Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | JAPAN |
| 36 | Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
| 37 | Gold | Valcambi S.A. | SWITZERLAND |
| 38 | Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| 39 | Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| 40 | Gold | Umicore Brasil Ltda. | BRAZIL |
| 41 | Gold | Torecom | KOREA (REPUBLIC OF) |
| 42 | Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| 43 | Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| 44 | Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| 45 | Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| 46 | Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| 47 | Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| 48 | Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| 49 | Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| 50 | Gold | So Accurate Group, Inc. | UNITED STATES OF AMERICA |
| 51 | Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| 52 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| 53 | Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| 54 | Gold | SEMPSA Joyería Platería S.A. | SPAIN |
| 55 | Gold | Schone Edelmetaal B.V. | NETHERLANDS |
| 56 | Gold | SAMWON METALS Corp. | KOREA (REPUBLIC OF) |
| 57 | Gold | Samduck Precious Metals | KOREA (REPUBLIC OF) |
| 58 | Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| 59 | Gold | Royal Canadian Mint | CANADA |
| 60 | Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| 61 | Gold | PX Précinox S.A. | SWITZERLAND |
| 62 | Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| 63 | Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| 64 | Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| 65 | Gold | PAMP S.A. | SWITZERLAND |
| 66 | Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| 67 | Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| 68 | Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA |
| 69 | Gold | Nihon Material Co., Ltd. | JAPAN |
| 70 | Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| 71 | Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| 72 | Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| 73 | Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| 74 | Gold | Mitsubishi Materials Corporation | JAPAN |
| 75 | Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO |
| 76 | Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| 77 | Gold | Metalor Technologies S.A. | SWITZERLAND |
| 78 | Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| 79 | Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| 80 | Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| 81 | Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| 82 | Gold | Materion | UNITED STATES OF AMERICA |
| 83 | Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| 84 | Gold | LS-NIKKO Copper Inc. | KOREA (REPUBLIC OF) |
| 85 | Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| 86 | Gold | Lingbao Gold Co., Ltd. | CHINA |
| 87 | Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| 88 | Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| 89 | Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| 90 | Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| 91 | Gold | Kazzinc | KAZAKHSTAN |
| 92 | Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| 93 | Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| 94 | Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| 95 | Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| 96 | Gold | Asahi Refining Canada Ltd. | CANADA |
| 97 | Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| 98 | Gold | Jiangxi Copper Co., Ltd. | CHINA |
| 99 | Gold | Japan Mint | JAPAN |
| 100 | Gold | Istanbul Gold Refinery | TURKEY |
| 101 | Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| 102 | Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| 103 | Gold | HwaSeong CJ Co., Ltd. | KOREA (REPUBLIC OF) |
| 104 | Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| 105 | Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| 106 | Gold | Heraeus Ltd. Hong Kong | CHINA |
| 107 | Gold | Heimerle + Meule GmbH | GERMANY |
| 108 | Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| 109 | Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| 110 | Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
| 111 | Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| 112 | Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| 113 | Gold | Dowa | JAPAN |
| 114 | Gold | DODUCO GmbH | GERMANY |
| 115 | Gold | DSC (Do Sung Corporation) | KOREA (REPUBLIC OF) |
| 116 | Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| 117 | Gold | Daejin Indus Co., Ltd. | KOREA (REPUBLIC OF) |
| 118 | Gold | Chugai Mining | JAPAN |
| 119 | Gold | Chimet S.p.A. | ITALY |
| 120 | Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| 121 | Gold | Cendres + Métaux S.A. | SWITZERLAND |
| 122 | Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| 123 | Gold | Caridad | MEXICO |
| 124 | Gold | C. Hafner GmbH + Co. KG | GERMANY |
| 125 | Gold | Boliden AB | SWEDEN |
| 126 | Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| 127 | Gold | Aurubis AG | GERMANY |
| 128 | Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| 129 | Gold | Asaka Riken Co., Ltd. | JAPAN |
| 130 | Gold | Asahi Pretec Corp. | JAPAN |
| 131 | Gold | Argor-Heraeus S.A. | SWITZERLAND |
| 132 | Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
| 133 | Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| 134 | Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| 135 | Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| 136 | Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| 137 | Tantalum | Power Resources Ltd. | MACEDONIA (THE FORMER YUGOSLAV REPUBLIC OF) |
| 138 | Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| 139 | Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
| 140 | Tantalum | E.S.R. Electronics | UNITED STATES OF AMERICA |
| 141 | Tantalum | Tranzact, Inc. | UNITED STATES OF AMERICA |
| 142 | Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA |
| 143 | Tantalum | Global Advanced Metals Aizu | JAPAN |
| 144 | Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| 145 | Tantalum | Plansee SE Reutte | AUSTRIA |
| 146 | Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| 147 | Tantalum | H.C. Starck Ltd. | JAPAN |
| 148 | Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
| 149 | Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| 150 | Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
| 151 | Tantalum | H.C. Starck GmbH Goslar | GERMANY |
| 152 | Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| 153 | Tantalum | Plansee SE Liezen | AUSTRIA |
| 154 | Tantalum | KEMET Blue Metals | MEXICO |
| 155 | Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| 156 | Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| 157 | Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| 158 | Tantalum | FIR Metals & Resource Ltd. | CHINA |
| 159 | Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| 160 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| 161 | Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| 162 | Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA |
| 163 | Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| 164 | Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| 165 | Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| 166 | Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| 167 | Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
| 168 | Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| 169 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| 170 | Tantalum | Molycorp Silmet A.S. | ESTONIA |
| 171 | Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| 172 | Tantalum | Mineração Taboca S.A. | BRAZIL |
| 173 | Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| 174 | Tantalum | LSM Brasil S.A. | BRAZIL |
| 175 | Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
| 176 | Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| 177 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| 178 | Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES OF AMERICA |
| 179 | Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| 180 | Tantalum | F&X Electro-Materials Ltd. | CHINA |
| 181 | Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
| 182 | Tantalum | Duoluoshan | CHINA |
| 183 | Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| 184 | Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| 185 | Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
| 186 | Tin | Gejiu Jinye Mineral Company | CHINA |
| 187 | Tin | Modeltech Sdn Bhd | MALAYSIA |
| 188 | Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
| 189 | Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| 190 | Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| 191 | Tin | PT Menara Cipta Mulia | INDONESIA |
| 192 | Tin | PT Kijang Jaya Mandiri | INDONESIA |
| 193 | Tin | An Thai Minerals Co., Ltd. | VIET NAM |
| 194 | Tin | PT Sukses Inti Makmur | INDONESIA |
| 195 | Tin | PT Bangka Prima Tin | INDONESIA |
| 196 | Tin | Elmet S.L.U. | SPAIN |
| 197 | Tin | Metallo-Chimique N.V. | BELGIUM |
| 198 | Tin | PT O.M. Indonesia | INDONESIA |
| 199 | Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
| 200 | Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| 201 | Tin | PT Cipta Persada Mulia | INDONESIA |
| 202 | Tin | CV Tiga Sekawan | INDONESIA |
| 203 | Tin | CV Dua Sekawan | INDONESIA |
| 204 | Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| 205 | Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| 206 | Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| 207 | Tin | CV Ayi Jaya | INDONESIA |
| 208 | Tin | PT Inti Stania Prima | INDONESIA |
| 209 | Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| 210 | Tin | Phoenix Metal Ltd. | RWANDA |
| 211 | Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| 212 | Tin | Melt Metais e Ligas S.A. | BRAZIL |
| 213 | Tin | PT Wahana Perkit Jaya | INDONESIA |
| 214 | Tin | PT Tirus Putra Mandiri | INDONESIA |
| 215 | Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| 216 | Tin | CV Venus Inti Perkasa | INDONESIA |
| 217 | Tin | Yunnan Tin Company Limited | CHINA |
| 218 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| 219 | Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| 220 | Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| 221 | Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| 222 | Tin | Thaisarco | THAILAND |
| 223 | Tin | Soft Metais Ltda. | BRAZIL |
| 224 | Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| 225 | Tin | PT Tommy Utama | INDONESIA |
| 226 | Tin | PT Tinindo Inter Nusa | INDONESIA |
| 227 | Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
| 228 | Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
| 229 | Tin | PT Sumber Jaya Indah | INDONESIA |
| 230 | Tin | PT Stanindo Inti Perkasa | INDONESIA |
| 231 | Tin | PT Sariwiguna Binasentosa | INDONESIA |
| 232 | Tin | PT REFINED BANGKA TIN | INDONESIA |
| 233 | Tin | PT Prima Timah Utama | INDONESIA |
| 234 | Tin | PT Panca Mega Persada | INDONESIA |
| 235 | Tin | PT Mitra Stania Prima | INDONESIA |
| 236 | Tin | PT Karimun Mining | INDONESIA |
| 237 | Tin | PT Eunindo Usaha Mandiri | INDONESIA |
| 238 | Tin | PT DS Jaya Abadi | INDONESIA |
| 239 | Tin | PT Bukit Timah | INDONESIA |
| 240 | Tin | PT Belitung Industri Sejahtera | INDONESIA |
| 241 | Tin | PT Bangka Tin Industry | INDONESIA |
| 242 | Tin | PT Babel Inti Perkasa | INDONESIA |
| 243 | Tin | PT Artha Cipta Langgeng | INDONESIA |
| 244 | Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| 245 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| 246 | Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
| 247 | Tin | Mitsubishi Materials Corporation | JAPAN |
| 248 | Tin | Minsur | PERU |
| 249 | Tin | Mineração Taboca S.A. | BRAZIL |
| 250 | Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| 251 | Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| 252 | Tin | China Tin Group Co., Ltd. | CHINA |
| 253 | Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| 254 | Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| 255 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| 256 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| 257 | Tin | Fenix Metals | POLAND |
| 258 | Tin | Estanho de Rondônia S.A. | BRAZIL |
| 259 | Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| 260 | Tin | Dowa | JAPAN |
| 261 | Tin | CV United Smelting | INDONESIA |
| 262 | Tin | CV Serumpun Sebalai | INDONESIA |
| 263 | Tin | PT Aries Kencana Sejahtera | INDONESIA |
| 264 | Tin | PT Justindo | INDONESIA |
| 265 | Tin | CV Gita Pesona | INDONESIA |
| 266 | Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
| 267 | Tin | Alpha | UNITED STATES OF AMERICA |
| 268 | Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| 269 | Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
| 270 | Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| 271 | Tungsten | Moliren Ltd | RUSSIAN FEDERATION |
| 272 | Tungsten | Woltech Korea Co., Ltd. | KOREA (REPUBLIC OF) |
| 273 | Tungsten | ACL Metais Eireli | BRAZIL |
| 274 | Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| 275 | Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| 276 | Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
| 277 | Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| 278 | Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| 279 | Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
| 280 | Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| 281 | Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| 282 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| 283 | Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
| 284 | Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| 285 | Tungsten | H.C. Starck GmbH | GERMANY |
| 286 | Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| 287 | Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
| 288 | Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
| 289 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| 290 | Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| 291 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| 292 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| 293 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| 294 | Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| 295 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| 296 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| 297 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| 298 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| 299 | Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| 300 | Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| 301 | Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| 302 | Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| 303 | Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| 304 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| 305 | Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| 306 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| 307 | Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| 308 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| 309 | Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| 310 | Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| 311 | Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| 312 | Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| 313 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| 314 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| 315 | Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| 316 | Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Annex II - List of possible countries of origin of Conflict Minerals
| AUSTRALIA |
| AUSTRIA |
| BOLIVIA |
| BRAZIL |
| BURUNDI |
| CANADA |
| CHILE |
| CHINA |
| DEMOCRATIC REPUBLIC OF THE CONGO |
| ETHIOPIA |
| GERMANY |
| GUYANA |
| HK |
| INDIA |
| INDONESIA |
| ITALY |
| JAPAN |
| MOZAMBIQUE |
| NAMIBIA |
| NIGERIA |
| PERU |
| PORTUGAL |
| RUSSIA |
| RWANDA |
| SIERRA LEONE |
| SPAIN |
| SURINAME |
| TAIWAN |
| THAILAND |
| UNITED STATES |
| VIETNAM |
| ZIMBABWE |
