Exhibit 1.01
Welbilt, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2019
This Conflict Minerals Report (this "Report") for the year ended December 31, 2019 is presented to comply with Rule 13p-1 ("Rule 13p-1") under the Securities Exchange Act of 1934, as amended. Unless otherwise expressly stated or the context otherwise requires, references to "we," "our," "us," the "Company" or "Welbilt," refer to Welbilt, Inc. and its consolidated subsidiaries.
This Report has been prepared by our management for calendar year 2019 in accordance with Rule 13p-1. This Report discusses our efforts related to determining whether any of the products we manufacture or that we have contracted to be manufactured contain tin, tantalum, tungsten and gold (collectively, the "3TG Minerals") that are necessary to the functionality or production of such products that may have originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (collectively, the "Covered Countries") or are from recycled or scrap sources.
Forward-Looking Statements
Certain statements contained in, or incorporated into, this Report constitute "forward-looking statements" within the meaning of the U.S. Private Securities Litigation Reform Act of 1995. Statements that are not historical fact are forward-looking statements and include, for example, descriptions of our supply chain improvement efforts and risk mitigation strategies. Certain of these forward-looking statements can be identified by the use of words such as "anticipates," "believes," "intends," "estimates," "targets," "expects," "could," "will," "may," "plans," "projects," "assumes," "should" or other similar expressions. Such forward-looking statements involve known and unknown risks and uncertainties, and our actual results could differ materially from future results expressed or implied in these forward-looking statements. The forward-looking statements included in this report are based on our current beliefs and expectations and speak only as of the date of this report. These statements are not guarantees or indicators of future performance. Important assumptions and other important factors that could cause actual results to differ materially from these forward-looking statements include, but are not limited to, those risks, uncertainties and factors described in more detail under the caption "Risk Factors" in our Annual Report on Form 10-K for the year ended December 31, 2019, our Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2020 and in our other filings with the U.S. Securities and Exchange Commission (the "SEC"). We do not intend, and, except as required by law, we undertake no obligation, to update any of our forward-looking statements after the date of this report to reflect any future events or circumstances. Given these risks and uncertainties, readers are cautioned not to place undue reliance on such forward-looking statements.
1. Company Overview
We are one of the world's leading commercial foodservice equipment companies leveraging a full suite of equipment capable of storing, cooking, holding, displaying, dispensing and serving in both hot and cold foodservice categories. Headquartered in New Port Richey, Florida, Welbilt was incorporated in Delaware in 2015 and became publicly traded in March 2016 after a spin-off from its former parent. We operate 20 manufacturing facilities globally at which we design, manufacture and supply best-in-class equipment for the global commercial foodservice market, consisting of commercial and institutional foodservice operators including full-service restaurants, quick-service restaurant ("QSR") chains, hotels, resorts, cruise ships, caterers, supermarkets, convenience stores, hospitals, schools and other institutions. We sell our products through a global network of over 5,000 distributors, dealers, buying groups and manufacturers' representatives. Our portfolio of award-winning brands includes Cleveland™, Convotherm®, Crem®, Delfield®, Frymaster®, Garland®, Kolpak®, Lincoln™, Manitowoc® Ice, Merco®, Merrychef® and Multiplex®. These product brands are supported by three service brands: KitchenCare®, our aftermarket parts and service brand, FitKitchen®, our fully-integrated kitchen systems brand and KitchenConnect®, our cloud-based application brand.
We serve our customers through the following foodservice equipment product and service groups:
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| • | Storing. We design, manufacture and sell commercial upright and undercounter refrigerators and freezers, blast freezers, blast chillers and cook-chill systems under the Delfield brand name. We manufacture modular and fully assembled walk-in refrigerators, coolers and freezers, and prefabricated cooler and freezer panels for use in the construction of refrigerated storage rooms and environmental systems under the Kolpak brand name. |
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| • | Cooking. We sell traditional ovens, combination ovens, convection ovens, conveyor ovens, rapid-cooking ovens, range and grill products under the Convotherm, Garland, Lincoln, Merrychef and other brand names. We market fryers and frying systems principally under the Frymaster brand name, and our steam equipment under the Cleveland brand. |
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| • | Holding and Displaying. We design, manufacture and sell a range of cafeteria and buffet equipment stations, bins, boxes, warming cabinets, warmers, display and deli cases, and insulated and refrigerated salad and food bars. We market our equipment stations, cases, food bars and food serving lines under the Delfield, Merco and other brand names. |
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| • | Dispensing and Serving. We produce beverage dispensers, blended ice machines, ice/beverage dispensers, beer coolers, post-mix dispensing valves, backroom equipment and support system components and related equipment for use by QSR chains, convenience stores, bottling operations, movie theaters, the soft-drink industry and others. We design, manufacture and sell ice machines under the Manitowoc and other brand names. We sell our coffee equipment under the Crem brand name and other beverage-related products under Multiplex and Manitowoc brand names. |
Our working platforms and foodservice equipment product groups are augmented through the following cross portfolio service brands:
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| • | KitchenCare. We provide a broad range of services and after-market parts and manage a comprehensive factory-authorized service network, assuring proper installation and start-up, preventative maintenance, after-market parts supply and maximum customer uptime on all Welbilt products. |
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| • | FitKitchen. We produce individually designed kitchens that optimize the use of our customers' kitchen space which helps to reduce the customers' labor costs. The goal of FitKitchen is to provide customized solutions that reduces the kitchen footprint and right-sizes equipment in order to reduce capital costs while producing improvements in speed of service and quality of food |
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| • | KitchenConnect. Our KitchenConnect enabled products include the option for data output monitoring intended to facilitate menu management by the equipment operators through the interaction of menus and equipment. We believe that these products produce an operator experience that allows for a collaborative and agile service supported by just-in-time maintenance. We believe this reduces downtime, optimizes energy use and improves service response time. |
As a downstream supplier, many steps removed from the mining of 3TG Minerals, we do not purchase any 3TG Minerals directly from smelters or refiners and do not knowingly purchase any 3TG Minerals in their raw material form. We are committed to the responsible sourcing of our products and we expect the same from our suppliers, including ensuring that the products or components supplied to us do not directly or indirectly finance or benefit armed groups in the Covered Countries. Our suppliers are required to support our efforts to comply with Rule 13p-1. We have a Conflict Minerals Policy, which is available on our website (www.welbilt.com) under Investor Relations - Corporate Governance - Governance Documents. In addition, our standard supplier terms and conditions address our expectations related to any 3TG Minerals supplied to us.
2. Reasonable Country of Origin Inquiry
We undertook a reasonable country of origin inquiry ("RCOI") in good faith to determine whether the 3TG Minerals in the products we manufacture, or contract to manufacture, that are necessary to the functionality or production of our products may have originated in the Covered Countries or may have come from recycled or scrap sources.
To assist in determining whether 3TG Minerals in our products originated in Covered Countries, we retained Assent Compliance, Inc. ("Assent"), a third-party service provider. We provided a list of direct suppliers that provide us with products and components used in our manufacturing process that contain, or had a high probability of containing, one or more 3TG Minerals (the "in-scope suppliers") to Assent. We also periodically reviewed the supplier list to ensure that irrelevant or "out-of-scope" suppliers were removed from the survey process.
We utilized the RBA-GeSI Conflict Minerals Reporting Template ("CMRT") to conduct a survey of all in-scope suppliers. During the supplier survey, we contacted 446 suppliers via the Assent Compliance Manager (the "ACM"), a software platform maintained by Assent that enables its users to complete and track supplier communications as well as allows suppliers to upload completed CMRTs directly to the platform for assessment and management.
Assent requested that all suppliers complete a CMRT and provided training resources to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. We directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested such suppliers complete the CMRT form and submit such form to Assent. Assent's program also includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. Suppliers with invalid CMRTs were contacted and asked to resubmit after correcting the errors. As of May 21, 2020, there were 8 invalid supplier submissions that could not be corrected.
Based on the RCOI, we have reason to believe that some of the 3TG Minerals in our products may have originated from the Covered Countries or may have come from recycled or scrap sources, therefore, in accordance with Rule 13p-1, we performed further due diligence on the source and chain of custody of the 3TG Minerals in question.
3. Due Diligence Process
We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized 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 ("OECD Guidance"), and the related supplements for each of the 3TG Minerals.
The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance further advises that downstream companies exercise due
diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our "tier 1" (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.
We integrated the five steps recommended by the OECD Guidance as follows:
Step 1: Establish Strong Company Management Systems
Internal Team. We maintained an internal team, led by our procurement group, to manage our conflict minerals compliance program and related engagement with our suppliers. This includes integrating new suppliers, working with our employees to provide training and guidance, implementing reporting systems and facilitating cross-departmental communications to ensure compliance with the SEC’s reporting requirements regarding conflict minerals.
Controls and Policies. As stated above, we have a Conflict Minerals Policy, which is available on our website (www.welbilt.com) under Investor Relations - Corporate Governance - Governance Documents. In addition, our standard supplier terms and conditions address our expectations related to any 3TG Minerals supplied to us. Our controls also include our Code of Conduct and our Supplier Code of Conduct, which outline expected behaviors for our employees and suppliers.
Grievance Mechanisms. We maintain a hotline that provides employees with a mechanism to report violations or concerns related to our policies, including our Conflict Minerals Policy, Code of Conduct and our Supplier Code of Conduct. Such reporting may be made on an anonymous basis if employees wish.
Supplier Engagement. With respect to the OECD requirement to strengthen engagement with suppliers, we engaged Assent to assist with supplier engagement, evaluating supply chain information regarding 3TG Minerals and to assist with the development and implementation of additional due diligence steps. We also use Assent’s online learning management system and have provided all in-scope suppliers access to Assent's Conflict Minerals training course.
Step 2: Identify and Assess Risks in Our Supply Chain
In accordance with OECD Guidance, it is important to identify and assess risks associated with 3TG Minerals in the supply chain. Certain risks are identified automatically in the ACM system based on pre-established criteria. These risks are addressed by Assent's compliance staff and members of our internal conflict minerals compliance team who contacted the supplier to gather pertinent data and perform an assessment.
Many of the responses provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG Minerals in the components supplied to us. Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the Responsible Minerals Initiative ("RMI") to ensure that the facilities met the RMI definition of a 3TG Minerals processing facility that was operational during the 2019 calendar year.
In order to assess the risk that any of these smelters posed to our supply chain, Assent considered whether the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process ("RMAP"). Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists. We do not typically have a direct relationship with 3TG Minerals smelters and refiners and do not perform or direct audits of these entities within our supply chain.
Each facility that meets the RMI definition of a smelter or refiner of a 3TG Mineral is assessed according to red flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
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| • | Geographic proximity to the Covered Countries; |
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| • | Known mineral source country of origin; |
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| • | Responsible Minerals Assurance Process audit status; |
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| • | Credible evidence of unethical or conflict sourcing; |
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| • | Peer assessments conducted by credible third-party sources. |
Consistent with of our risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent, submissions that include any red flag facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product-specific CMRT to better identify the connection to products that they supply to us, and escalating up to removal of these red flag smelters from their supply chain.
As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable time frames with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to Assent's online learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Guidance and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:
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| 1. | Do you have a conflict minerals sourcing policy in place? |
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| 2. | Have you implemented due diligence measures for conflict-free sourcing? |
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| 3. | Do you review due diligence information received from your suppliers against your company’s expectations? |
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| 4. | Does your review process include corrective action management? |
Suppliers who respond affirmatively to each of the above questions are deemed to have a strong program in place. If they do not meet this criteria, they are identified as having a weak program, and follow-up emails are sent in order to provide them guidance on how to improve their program going forward.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
We completed a management reporting dashboard on a periodic basis summarizing the results of the risk assessment process. Other elements of our due diligence process designed to respond to identified risks included the following:
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| • | Suppliers that did not respond to our initial survey request were sent escalation communications requesting that they provide the information requested. |
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| • | Suppliers who provided incomplete or inconsistent responses were sent follow-up communications asking for clarification. Based on the type of red flag identified during a review of supplier responses, suppliers were sent a corrective action communication. |
Step 4: Utilize Third-Party Audits of Supply Chain Due Diligence
We do not have a direct relationship with 3TG Minerals smelters or refiners, and we do not perform or direct audits of these entities within our supply chain. We rely on third-party audits of smelters and refiners conducted as part of the RMAP, independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.
Step 5: Report Annually on Supply Chain Due Diligence
4. Due Diligence Results
For the 2019 reporting year, we received completed CMRTs from approximately 64% of the 444 in-scope suppliers surveyed, which includes 2% of our in-scope suppliers that were unable to correct their CMRT and are deemed invalid submissions.
Appendix A to this Report lists the legitimate smelters and refiners that our in-scope suppliers reported as being in used their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix A also includes an aggregated list of the potential countries of origin from which the reported facilities may collectively source 3TG Minerals, based on information provided by our suppliers and RMI.
The majority of the responses we received from our suppliers were made on a company or division level, rather than on a product-level basis. Accordingly, the smelters or refiners identified by our suppliers in Appendix A may include smelters or refiners that processed 3TG Minerals supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the smelters or refiners included in Appendix A were used to process the 3TG Minerals necessary to the functionality or production of Welbilt products during 2019. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed in Appendix A was a country of origin of 3TG Minerals used in our products during 2019 and therefore unable to conclusively determine the source and chain of custody of those 3TG Minerals.
In addition, the third-party audits conducted by the RMI, and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete 3TG Minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMAP and, as a result, are not responsible for the quality of these audits or the audit findings.
5. Risk Mitigation and Continuous Improvement Efforts
In addition to the commitments set forth in our Conflict Minerals Policy, we intend to take the following steps to improve our conflict minerals program and further mitigate the risk that our products contain 3TG Minerals from sources that support conflict in the Covered Countries:
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| • | Engage with suppliers to provide better resources for responsible sourcing of 3TG Minerals and implementing improved due diligence procedures for their supply chains; |
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| • | Collaborate with Assent to improve supplier survey response rates and implement stronger supplier education practices; |
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| • | Improve training programs to educate Welbilt employees who may be in direct contact with suppliers or other third parties regarding the Company’s conflict minerals compliance efforts; and |
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| • | Attempt to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TG Minerals contained in our products. |
Appendix A
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| Metal | Facility Name | Smelter ID |
| Gold | 8853 S.p.A. | CID002763 |
| Gold | Abington Reldan Metals, LLC | CID002708 |
| Gold | Advanced Chemical Company | CID000015 |
| Gold | African Gold Refinery | CID003185 |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | CID000058 |
| Gold | Argor-Heraeus S.A. | CID000077 |
| Gold | Asahi Pretec Corp. | CID000082 |
| Gold | Asahi Refining Canada Ltd. | CID000924 |
| Gold | Asahi Refining USA Inc. | CID000920 |
| Gold | Asaka Riken Co., Ltd. | CID000090 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 |
| Gold | AU Traders and Refiners | CID002850 |
| Gold | Aurubis AG | CID000113 |
| Gold | Bangalore Refinery | CID002863 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 |
| Gold | Boliden AB | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | CID000176 |
| Gold | C.I Metales Procesados Industriales SAS | CID003421 |
| Gold | Caridad | CID000180 |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 |
| Gold | Cendres + Metaux S.A. | CID000189 |
| Gold | CGR Metalloys Pvt Ltd. | CID003382 |
| Gold | Chimet S.p.A. | CID000233 |
| Gold | Chugai Mining | CID000264 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 |
| Gold | Dijllah Gold Refinery FZC | CID003348 |
| Gold | DODUCO Contacts and Refining GmbH | CID000362 |
| Gold | Dowa | CID000401 |
| Gold | DS PRETECH Co., Ltd. | CID003195 |
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| Gold | DSC (Do Sung Corporation) | CID000359 |
| Gold | Eco-System Recycling Co., Ltd. | CID000425 |
| Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 |
| Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 |
| Gold | Emirates Gold DMCC | CID002561 |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 |
| Gold | Fujairah Gold FZC | CID002584 |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | CID002852 |
| Gold | Geib Refining Corporation | CID002459 |
| Gold | Gold Coast Refinery | CID003186 |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 |
| Gold | Guangdong Jinding Gold Limited | CID002312 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 |
| Gold | Heimerle + Meule GmbH | CID000694 |
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 |
| Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CID000773 |
| Gold | HwaSeong CJ CO., LTD. | CID000778 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 |
| Gold | International Precious Metal Refiners | CID002562 |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 |
| Gold | Istanbul Gold Refinery | CID000814 |
| Gold | Italpreziosi | CID002765 |
| Gold | JALAN & Company | CID002893 |
| Gold | Japan Mint | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 |
| Gold | JSC Uralelectromed | CID000929 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 |
| Gold | Kaloti Precious Metals | CID002563 |
| Gold | Kazakhmys Smelting LLC | CID000956 |
| Gold | Kazzinc | CID000957 |
| Gold | Kennecott Utah Copper LLC | CID000969 |
| Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 |
| Gold | Korea Zinc Co., Ltd. | CID002605 |
| Gold | Kundan Care Products Ltd. | CID003463 |
| Gold | Kyrgyzaltyn JSC | CID001029 |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 |
| Gold | L'azurde Company For Jewelry | CID001032 |
| Gold | Lingbao Gold Co., Ltd. | CID001056 |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 |
| Gold | L'Orfebre S.A. | CID002762 |
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| Gold | LS-NIKKO Copper Inc. | CID001078 |
| Gold | HeeSung Metal Ltd. | CID000689 |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 |
| Gold | Marsam Metals | CID002606 |
| Gold | Materion | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 |
| Gold | Metalor Technologies S.A. | CID001153 |
| Gold | Metalor USA Refining Corporation | CID001157 |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | CID001161 |
| Gold | Mitsubishi Materials Corporation | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 |
| Gold | Modeltech Sdn Bhd | CID002857 |
| Gold | Morris and Watson | CID002282 |
| Gold | Moscow Special Alloys Processing Plant | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 |
| Gold | NH Recytech Company | CID003189 |
| Gold | Nihon Material Co., Ltd. | CID001259 |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 |
| Gold | OJSC Novosibirsk Refinery | CID000493 |
| Gold | PAMP S.A. | CID001352 |
| Gold | Pease & Curren | CID002872 |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 |
| Gold | Planta Recuperadora de Metales SpA | CID002919 |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 |
| Gold | PX Precinox S.A. | CID001498 |
| Gold | QG Refining, LLC | CID003324 |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 |
| Gold | Refinery of Seemine Gold Co., Ltd. | CID000522 |
| Gold | REMONDIS PMR B.V. | CID002582 |
| Gold | Royal Canadian Mint | CID001534 |
| Gold | SAAMP | CID002761 |
| Gold | Sabin Metal Corp. | CID001546 |
| Gold | Safimet S.p.A | CID002973 |
| Gold | SAFINA A.S. | CID002290 |
| Gold | Sai Refinery | CID002853 |
| Gold | Samduck Precious Metals | CID001555 |
| Gold | Samwon Metals Corp. | CID001562 |
| Gold | SAXONIA Edelmetalle GmbH | CID002777 |
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| Gold | SEMPSA Joyeria Plateria S.A. | CID001585 |
| Gold | Shandong Humon Smelting Co., Ltd. | CID002525 |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 |
| Gold | Shirpur Gold Refinery Ltd. | CID002588 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 |
| Gold | Singway Technology Co., Ltd. | CID002516 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | CID001761 |
| Gold | Sovereign Metals | CID003383 |
| Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 |
| Gold | Sudan Gold Refinery | CID002567 |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 |
| Gold | SungEel HiMetal Co., Ltd. | CID002918 |
| Gold | T.C.A S.p.A | CID002580 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 |
| Gold | Tony Goetz NV | CID002587 |
| Gold | TOO Tau-Ken-Altyn | CID002615 |
| Gold | Torecom | CID001955 |
| Gold | Umicore Brasil Ltda. | CID001977 |
| Gold | Umicore Precious Metals Thailand | CID002314 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 |
| Gold | United Precious Metal Refining, Inc. | CID001993 |
| Gold | Valcambi S.A. | CID002003 |
| Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 |
| Gold | WIELAND Edelmetalle GmbH | CID002778 |
| Gold | Yamakin Co., Ltd. | CID002100 |
| Gold | Yokohama Metal Co., Ltd. | CID002129 |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 |
| Tantalum | Asaka Riken Co., Ltd. | CID000092 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 |
| Tantalum | CP Metals Inc. | CID003402 |
| Tantalum | D Block Metals, LLC | CID002504 |
| Tantalum | Exotech Inc. | CID000456 |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 |
| Tantalum | Global Advanced Metals Aizu | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | CID002557 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 |
| Tantalum | H.C. Starck Co., Ltd. | CID002544 |
| Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 |
| Tantalum | H.C. Starck Inc. | CID002548 |
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| | |
| Tantalum | H.C. Starck Ltd. | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | CID002550 |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | CID002545 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 |
| Tantalum | KEMET Blue Metals | CID002539 |
| Tantalum | LSM Brasil S.A. | CID001076 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 |
| Tantalum | Mineracao Taboca S.A. | CID001175 |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 |
| Tantalum | NPM Silmet AS | CID001200 |
| Tantalum | Power Resources Ltd. | CID002847 |
| Tantalum | QuantumClean | CID001508 |
| Tantalum | Resind Industria e Comercio Ltda. | CID002707 |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 |
| Tantalum | Taki Chemical Co., Ltd. | CID001869 |
| Tantalum | Telex Metals | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 |
| Tin | Alpha | CID000292 |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 |
| Tin | China Tin Group Co., Ltd. | CID001070 |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 |
| Tin | Dowa | CID000402 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 |
| Tin | EM Vinto | CID000438 |
| Tin | Estanho de Rondonia S.A. | CID000448 |
| Tin | Fenix Metals | CID000468 |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd.” | CID003410 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CID002849 |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 |
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| | |
| Tin | Luna Smelter, Ltd. | CID003387 |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CID003379 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 |
| Tin | Melt Metais e Ligas S.A. | CID002500 |
| Tin | Metallic Resources, Inc. | CID001142 |
| Tin | Metallo Belgium N.V. | CID002773 |
| Tin | Metallo Spain S.L.U. | CID002774 |
| Tin | Mineracao Taboca S.A. | CID001173 |
| Tin | Minsur | CID001182 |
| Tin | Mitsubishi Materials Corporation | CID001191 |
| Tin | Modeltech Sdn Bhd | CID002858 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 |
| Tin | Operaciones Metalurgicas S.A. | CID001337 |
| Tin | Pongpipat Company Limited | CID003208 |
| Tin | Precious Minerals and Smelting Limited | CID003409 |
| Tin | PT Artha Cipta Langgeng | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 |
| Tin | PT Menara Cipta Mulia | CID002835 |
| Tin | PT Mitra Stania Prima | CID001453 |
| Tin | PT Refined Bangka Tin | CID001460 |
| Tin | PT Timah Tbk Kundur | CID001477 |
| Tin | PT Timah Tbk Mentok | CID001482 |
| Tin | Resind Industria e Comercio Ltda. | CID002706 |
| Tin | Rui Da Hung | CID001539 |
| Tin | Soft Metais Ltda. | CID001758 |
| Tin | Super Ligas | CID002756 |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | CID002834 |
| Tin | Thaisarco | CID001898 |
| Tin | Tin Technology & Refining | CID003325 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 |
| Tin | White Solder Metalurgia e Mineracao Ltda. | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 |
| Tin | Yunnan Tin Company Limited | CID002180 |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 |
| Tungsten | A.L.M.T. Corp. | CID000004 |
| Tungsten | ACL Metais Eireli | CID002833 |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | CID003427 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CID002641 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CID000281 |
| Tungsten | CP Metals Inc. | CID003448 |
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| | |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CID003401 |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CID000499 |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CID002645 |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 |
| Tungsten | GEM Co., Ltd. | CID003417 |
| Tungsten | Global Tungsten & Powders Corp. | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | CID002542 |
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CID003182 |
| Tungsten | Hydrometallurg, JSC | CID002649 |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CID002647 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | CID003408 |
| Tungsten | Kennametal Fallon | CID000966 |
| Tungsten | Kennametal Huntsville | CID000105 |
| Tungsten | KGETS Co., Ltd. | CID003388 |
| Tungsten | Lianyou Metals Co., Ltd. | CID003407 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | CID002543 |
| Tungsten | Moliren Ltd. | CID002845 |
| Tungsten | Niagara Refining LLC | CID002589 |
| Tungsten | NPP Tyazhmetprom LLC | CID003416 |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 |
| Tungsten | Unecha Refractory metals plant | CID002724 |
| Tungsten | Wolfram Bergbau und Hutten AG | CID002044 |
| Tungsten | Woltech Korea Co., Ltd. | CID002843 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 |
Potential Countries of Origin: Andorra, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Czech Republic, Estonia, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Republic of Korea, Kyrgyzstan, Lithuania, Macedonia, Malaysia, Mexico, Myanmar, Netherlands, New Zealand, Peru, Philippines, Poland, Russian Federation, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, Uganda, United Arab Emirates, United States, Uzbekistan, Vietnam, Zambia and Zimbabwe. This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this listing is based on public information and company level responses as further described in the Report, and therefore, it is not certain which of these countries of origin can be linked to our products.
