Bloom Energy Corporation
Conflict Minerals Report
For Year Ended December 31, 2023
This Conflict Minerals Report (“Report”) for the year ended December 31, 2023 has been prepared by the management of Bloom Energy Corporation (herein referred to as “Bloom Energy”). The information includes the activities of all majority-owned subsidiaries and variable interest entities that are consolidated.
As used in this Report, “3TGs” means tin, tungsten, tantalum and/or gold or its derivatives and “Covered Countries” means the Democratic Republic of the Congo (“DRC”) and its nine adjoining countries; Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
INTRODUCTION
Product Covered by This Report
Pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), the 2023 calendar year is the fifth year that Bloom Energy is filing a Conflict Minerals Report.
Bloom Energy has determined that only two products manufactured or contracted to be manufactured contained 3TGs that were necessary to their functionality or production: the Bloom Energy Server, a stationary power generation platform, and the Bloom Energy Electrolyzer, a stationary producer of hydrogen (the “Covered Products”).
Bloom Energy conducted in good faith a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TGs in the Covered Products originated in the Covered Countries by engaging with certain suppliers who provided materials that may contain 3TG that was used in the Covered Products (“In-Scope Suppliers”). Based on Bloom Energy’s RCOI, Bloom Energy had reason to believe that its Covered Products could contain 3TGs that originated in the Covered Countries and may not be from recycled or scrap sources. Therefore, in accordance with Section 1502 of the Dodd-Frank Act, Bloom Energy performed due diligence on the source and chain of custody of the 3TGs.
Reasonable Country of Origin Inquiry
To assist Bloom Energy with its determination whether 3TGs necessary for its Covered Products originated in Covered Countries, Bloom Energy engaged a third-party service provider, Source Intelligence (“SI”). SI provided Bloom Energy with access to its platform that tracks supplier communications and provides additional tools that support the internationally recognized due diligence framework set forth in the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements on Tin, Tantalum and Tungsten, and on Gold (the “OECD Guidance”). For example, the SI platform has functionality that evaluates the quality of each supplier’s response and assigns a health score based on the supplier’s declaration. The metrics provided in this Report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through the SI platform.
Bloom Energy provided a list of In-Scope Suppliers to SI for upload to the SI platform. SI assisted with the evaluation of Bloom Energy’s supply chain information regarding 3TGs, identification of potential risks, and development and implementation of additional due diligence steps. Bloom Energy communicated regularly with SI services team concerning program status. SI’s team members are trained in conflict minerals compliance and understand the intricacies of the CMRT (as defined below), conflict minerals reporting, and generally, Section 1502 of the Dodd-Frank Act.
Bloom Energy’s RCOI process included conducting an inquiry of its In-Scope Suppliers using the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”). Bloom Energy does not have direct supply contracts with the providers of raw materials used in the Covered Products and Bloom Energy does not directly source 3TGs. Bloom Energy sources components and materials from suppliers, which in turn, source materials, components and products from their suppliers.
Bloom Energy used SI’s platform to request that the In-Scope Suppliers complete the CMRT to collect data on the sources of origin of the materials necessary for the Covered Products. Suppliers then uploaded their completed CMRTs directly to the platform for validation, assessment and management. SI monitored and tracked all communications in its platform for future reporting and transparency. Bloom Energy directly contacted suppliers that were unresponsive to SI’s communications and requested that they complete and submit the CMRT.
Bloom Energy’s program 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. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as to understand the due diligence efforts of the In-Scope Suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the In-Scope Suppliers to support their understanding of areas that need their clarification or improvement.
All submitted CMRT forms were accepted and classified as valid or invalid. The “invalid” classification can be the result of a number of factors, including incomplete tabs and can also occur when the supplier uses an obsolete template instead of the current version. A supplier who submits an invalid form is contacted and encouraged to submit a valid form. Suppliers receive feedback on their submissions and guidance on correcting validation errors and may seek assistance from SI’s multilingual Supplier Experience team or online training. Data concerning suppliers who remain unresponsive to feedback is tracked as a program gap for future improvement.
As of April 1, 2024, Bloom Energy had 158 In-Scope Suppliers. 153 (or ~96.8%) of the In-Scope Suppliers completed a valid CMRT. This helped Bloom Energy determine the countries of origin for nearly all of the 3TGs in the Covered Products.
DUE DILIGENCE
Bloom Energy designed its due diligence measures to conform with the OECD Guidance in all material respects and endeavored to align its program with the five steps for due diligence described in the OECD Guidance. Bloom Energy continues to evaluate market expectations for data collection and reporting to make improvements to its program.
Bloom Energy is a downstream consumer of 3TGs and does not purchase raw minerals directly from any mines, smelters or refiners or any of the Covered Countries. Bloom Energy’s supply chain is extensive and complex with many layers of suppliers positioned between Bloom Energy and 3TG smelters and refiners. Therefore, to execute due diligence, Bloom Energy must rely on data from its direct suppliers and third-party audit programs. As Bloom Energy does not solely control these processes, there is a risk of incomplete or inaccurate data. However, multiple supplier-outreach efforts and process validation steps help mitigate this risk. Bloom Energy believes this due diligence process aligns with industry standards and market expectations for downstream companies.
Step One: Establish Strong Company Management Systems
Internal Compliance Team
Bloom Energy established a cross-functional Conflict Minerals Team led by the Executive Vice President, Chief Operations Officer. The Conflict Minerals Team is responsible for implementing Bloom Energy’s responsible sourcing strategy and for briefing senior management on the results of due diligence.
Conflict Minerals Policy
In May 2020, Bloom Energy adopted a Policy on Responsible Sourcing of Minerals articulating the due diligence process and Bloom Energy’s commitment to reporting obligations regarding 3TGs originating in the Covered Countries. The Policy is publicly available at bloomenergy.com/supplychain.
Control Systems
Bloom Energy relies on its direct suppliers to provide information on the origin of the 3TGs contained in components and materials that they supply to Bloom Energy, such as sources of 3TGs that the suppliers purchase from their lower-tier suppliers. However, Bloom Energy expects all suppliers to have policies and procedures in place that work toward ensuring that all 3TGs used in the production of the products sold to Bloom Energy are sourced from smelters or refiners that conform with an independent responsible mineral sourcing validation program.
Supplier Engagement
Bloom Energy has a strong relationship with its In-Scope Suppliers. Bloom Energy engages directly with its In-Scope Suppliers to request a valid CMRT for the products that they supply to Bloom Energy. To strengthen supplier education and training, Bloom Energy provides In-Scope Suppliers with access to the SI platform, at no-charge, to upload their CMRTs as well as to seek help-desk support in their native language from SI’s team of supplier support specialists. Suppliers can also participate in SI’s online library of conflict minerals training.
Grievance Mechanisms
Bloom Energy has established multiple grievance mechanisms whereby employees, suppliers and other third parties can report violations of its policies. In Bloom Energy’s Policy on Responsible Sourcing. Suppliers, Bloom Energy has published a dedicated email address for suppliers to contact the Bloom Energy Supplier Team to ask questions regarding the collection of CMRTs and to report any violations of this policy within the supply chain. In addition, employees and third parties have access to the Bloom Energy Helpline to ask questions, communicate concerns or report potential violations of applicable law or company policies, which is publicly available at https://bloomhelpline.com/.
In the event that employees and suppliers wish to contact Bloom Energy’s Board of Directors, Bloom Energy also publishes the Board’s address in its Global Code of Business Conduct and Ethics, available on Bloom Energy’s website under the Investors section.
Records Management
SI’s platform also includes a document retention policy to retain any conflict minerals-related documents, including supplier responses to CMRTs and the sources for each reporting period. Bloom Energy stores all of the information and findings from this process in a database that can be audited by internal or external parties.
Step Two: Identify and Assess Risks in the Supply Chain
Risks associated with supplier CMRT content are identified by SI based on criteria established for supplier responses. Supplier responses were evaluated for plausibility, consistency and gaps. If any of the foregoing quality control flags were raised, the supplier was automatically contacted by the SI platform to correct any inconsistencies.
Risks at the supplier level may include non-responsive suppliers down the supply chain, incomplete CMRTs, or CMRTs that are submitted that are not specific to the Covered Products. Additionally, some suppliers could not provide a comprehensive list of all smelters or refiners in their supply chains.
Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers who listed smelters and refiners on their CMRT declarations. To determine if the facilities met the recognized definition of a 3TG processing facility that was operational during the 2023 calendar year, SI compared these facilities to the RMI list of smelters and refiners. SI relied on the RMI audit standard, including cross-recognition of the London Bullion Market Association (“LBMA”) Good Delivery Program and the Responsible Jewelry Council (“RJC”) Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance.
SI determined if the smelter or refiner had been audited against a standard that conforms to the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). As discussed earlier, Bloom Energy does not have a direct relationship with smelters and refiners, and does not perform direct audits of these entities within the supply chain. In cases where a smelter’s due diligence practices have not been audited against RMAP or a similar independent standard, or RMAP considers a smelter to be non-conforming, Bloom Energy followed-up with suppliers reporting those facilities. Smelters are then assessed for potential sourcing risk.
Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed using the red-flag indicators in the OECD Guidance. SI uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
• Geographic proximity to the Covered Countries;
• Known mineral source country of origin;
• RMAP or a similar independent audit status that is cross-recognized by RMI;
• Credible evidence of unethical or conflict sourcing; and
• Peer assessments conducted by credible third-party sources.
Risk mitigation activities are initiated when a supplier’s CMRT reports smelters of concern. Suppliers with submissions that include smelters or refiners of concern are provided with feedback instructing that supplier to take their own independent risk mitigation actions. Additional escalation may be necessary to address any continued sourcing from these smelters of concern. In addition, In-Scope Suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.
In-Scope Suppliers are also evaluated on program strength, which will assist Bloom Energy with making key risk mitigation decisions as its program progresses. The criteria used to evaluate the strength of the program is based on questions in the CMRT related to the suppliers’ conflict minerals practices and policies.
Step Three: Design and Implement a Strategy to Respond to Identified Risks
Bloom Energy has developed a process to assess and respond to the risks identified in the supply chain as well as to manage and monitor risk. Communications were sent to non-responsive suppliers to communicate the importance of their completion of the CMRT and their support of Bloom Energy’s compliance with the Rule and Bloom Energy’s expectations.
Suppliers received feedback on their submissions as well as educational resources regarding corrective action methods and potential improvements for their internal programs. Bloom Energy encouraged suppliers that may be supplying 3TGs from sources that may support conflict in the Covered Countries to endeavor to seek an alternative source of 3TGs that does not support such conflict, as provided in the OECD Guidance. SI also communicates directly with smelters that have not yet been determined to be conformant with the RMAP to seek data on sourcing and to encourage their involvement with the RMI program.
In cases where suppliers have continuously been non-responsive or do not appear to be committed to corrective action plans, Bloom Energy assesses internally if replacing that supplier is feasible. The results of the program and risk assessment are shared with both the Conflict Minerals Team and senior management to support transparency within Bloom Energy.
Step Four: Support the Development and Implementation of Independent Third-Party Audits
As discussed above, Bloom Energy does not have a direct relationship with any 3TG smelters or refiners and does not perform or direct audits of these entities within the supply chain. Instead, Bloom Energy relies on third-party audits of smelters and refiners conducted as part of the RMAP. The RMAP uses independent private-sector auditors, and audits 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.
SI also attempts to directly contact smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners.
Step Five: Report Annually on Supply Chain Due Diligence
Bloom Energy has filed this Report and a Form SD for the year ended December 31, 2023 with the United States Securities and Exchange Commission (“SEC”). As indicated in the Form SD, this Report is publicly available at investor.bloomenergy.com/. Bloom Energy’s Policy on Responsible Sourcing of Minerals is also publicly available at bloomenergy.com/supplychain.
RCOI AND DUE DILIGENCE RESULTS
Supply Chain Outreach Results
Supply chain outreach is required to identify the upstream sources of origin of 3TG. In accordance with industry standards, CMRTs are sent to and requested from In-Scope Suppliers, who are expected to follow this process until the smelter and refiner sources are identified. For the 2023 reporting year, Table 1 sets out the result of Bloom Energy’s supply chain outreach.
Table 1
SUPPLY CHAIN OUTREACH METRICS
| | | | | | | | |
| Number of In-Scope Suppliers | | Response Rate |
| | ~96.8% |
| 158 | | (153 out of 158) |
Upstream Data Transparency
As mentioned above, Bloom Energy is a downstream consumer of 3TGs and does not purchase raw minerals directly from any mines, smelters or refiners or any of the Covered Countries. Bloom Energy’s supply chain is extensive and complex with many layers of suppliers positioned between Bloom Energy and 3TG smelters and refiners. Therefore, to execute due diligence, Bloom Energy must rely on data from its direct suppliers and third-party audit programs. As Bloom Energy does not solely control these processes, there is a risk of incomplete or inaccurate data. However, multiple supplier-outreach efforts and process validation steps help mitigate this risk. Bloom Energy believes this due diligence process aligns with industry standards and market expectations for downstream companies.
All known smelters and refiners listed by suppliers in completed CMRTs (which appear on the RMI-maintained smelters list as of May 1, 2024) are set out in Appendix A. As is a common practice when requests are sent upstream in the supply chain, those companies who purchase materials from smelters may not be able to discern exactly which of their products contain the materials. As a result, those companies who provide a list of smelters and refiners tend to list all smelters and refiners from which they may purchase within the reporting period. Therefore, the smelters or refiners listed in Appendix A as sources are likely to be more comprehensive than the list of smelters or refiners that actually processed the 3TGs in the Covered Products.
In accordance with OECD Guidance, suppliers that identified specific smelters or refiners of concern in their CMRT were contacted to communicate the potential for risk and to evaluate whether or not these smelters or refiners could be
connected to the Covered Products. Bloom Energy obtained RCOI data through the SI platform and with the help of SI this data was used to determine the 3TG country of origin for the 352 smelters and refiners identified in Bloom Energy’s supply chain. The RMAP classifies smelters and refiners audit status in the following manner:
• RMAP/LBMA/RJC Conformant: Smelters or refiners have been audited and found to conform with a relevant, third-party audit protocol, including RMAP, LBMA, or RJC;
• RMAP-Active: The active lists represent smelters and refiners that have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment;
• RMAP-Progressing: Smelters or refiners have committed to take an audit and complete a conflict-free certification within two (2) years;
• Non-Conformant or Not Enrolled: The smelter or refiner is listed on the Smelter Look-up tab of the CMRT but is not Conformant or RMAP-Active.
| | | | | | | | |
| Status | | Number of Identified Smelters or Refiners |
| RMAP/LBMA/RJC Conformant | | 225 |
| RMAP-Active | | 11 |
| RMAP-Progressing | | 1 |
| Non-Conformant or Not Enrolled | | 115 |
| Total Number | | 352 |
As Bloom Energy does not directly purchase from any mines, smelters or refiners, nor does the majority of its In-Scope Suppliers, Bloom Energy has very little influence over their sourcing. Bloom Energy relies, to a large extent, on the information provided by independent third-party audit programs. Such sources of information may contain incomplete or inaccurate data, and may be subject to fraud.
Bloom Energy has determined that a portion of the 3TGs contained in the Covered Products originated from the Covered Countries, but Bloom Energy was unable to determine the origin of all the 3TG in the Covered Products. As of the date of this Report and for the reporting period covered by this Report, Bloom Energy has not identified a supplier, smelter or refiner that Bloom Energy has reason to believe is sourcing 3TG contained in the Covered Products that is directly or indirectly financing or benefiting an armed group. However, given that Bloom Energy has received insufficient information with respect to certain smelters and refiners that may have provided 3TG for the Covered Products, Bloom Energy has not determined that the Covered Products are “DRC conflict-free.”
Due Diligence Improvement Efforts
Bloom Energy will continue to communicate its expectations and information requirements to its In-Scope Suppliers and continue to work towards a conflict-free supply chain. In addition, Bloom Energy will continue to make inquiries of its In-Scope Suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If Bloom Energy becomes aware of a supplier whose due diligence process or reporting needs improvement, Bloom Energy currently intends to continue the trade relationship while that supplier improves its compliance program. Bloom Energy expects its In-Scope Suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
In addition to the plans described above, Bloom Energy will undertake the following steps during the next reporting period:
• Continue to collect responses from suppliers using the CMRT, including the collection of more product-level responses specific to the Covered Products.
• Work with In-Scope Suppliers to reduce the number of non-conformant smelters and refiners within Bloom Energy’s supply chain.
• Continue to work directly with its suppliers to provide more complete responses as a number of suppliers have been unable to determine the origin of the 3TG in products or components supplied to Bloom Energy or to determine whether they come from recycled or scrap sources.
• Continue to allow verified conflict-free material from the Covered Countries to enter Bloom Energy’s supply chain.
Additional Information
The statements above are based on the RCOI process and due diligence performed in good faith by Bloom Energy. These statements are based on information available at the time. A number of factors could introduce errors or otherwise affect Bloom Energy’s status with respect to this Report. These factors include, but are not limited to, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources, all instances of conflict minerals necessary to the functionality or manufacturing of the Covered Products possibly not yet having been identified, gaps in supplier education and knowledge, timeliness of data, public information not discovered during a reasonable search, language barriers and translation, oversights or errors in conflict free smelter audits, Covered Countries sourced materials being declared secondary materials, companies in Bloom Energy’s supply chain going out of business, certification programs being not equally advanced for all industry segments and metals, updated guidance regarding the SEC final rules, and smuggling of conflict minerals from the Covered Countries to countries beyond the Covered Countries.
The information contained on any website referred to in this Report does not form any part of this Report or Form SD and is not incorporated by reference herein unless expressly noted.
Countries of Origin
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs. This list is based on information provided through the CMRT data collection process from direct smelter outreach and the RMAP. As mentioned above, it is understood that many responses may provide more data than can be directly linked to the sale of the Covered Products by Bloom Energy, therefore, Appendix B may contain more countries than those from which the Covered Products are sourced.
APPENDIX A: SMELTER LIST
Metal Official Smelter Name
Gold 8853 S.p.A.
Gold ABC Refinery Pty Ltd.
Gold Abington Reldan Metals, LLC
Gold Advanced Chemical Company
Gold African Gold Refinery1
Gold Agosi AG
Gold Aida Chemical Industries Co., Ltd.
Gold Al Etihad Gold Refinery DMCC
Gold Albino Mountinho Lda.
Gold Alexy Metals
Gold Almalyk Mining and Metallurgical Complex (AMMC)
Gold AngloGold Ashanti Corrego do Sitio Mineracao
Gold Argor-Heraeus S.A.
Gold Asahi Pretec Corp.
Gold Asahi Refining Canada Ltd.
Gold Asahi Refining USA Inc.
Gold Asaka Riken Co., Ltd.
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold AU Traders and Refiners
Gold Augmont Enterprises Private Limited
Gold Aurubis AG
Gold Bangalore Refinery
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold Boliden AB
Gold C. Hafner GmbH + Co. KG
Gold Caridad
Gold CCR Refinery - Glencore Canada Corporation
Gold Cendres + Metaux S.A.
Gold CGR Metalloys Pvt Ltd.
Gold Chimet S.p.A.
Gold Chugai Mining
Gold Coimpa Industrial LTDA
Gold Daye Non-Ferrous Metals Mining Ltd.
Gold Degussa Sonne / Mond Goldhandel GmbH
Gold Dijllah Gold Refinery FZC
Gold Dongwu Gold Group
Gold Dowa
Gold DSC (Do Sung Corporation)
Gold Eco-System Recycling Co., Ltd. East Plant
Gold Eco-System Recycling Co., Ltd. North Plant
Gold Eco-System Recycling Co., Ltd. West Plant
Gold Emerald Jewel Industry India Limited (Unit 1)
Gold Emerald Jewel Industry India Limited (Unit 2)
Gold Emerald Jewel Industry India Limited (Unit 3)
Gold Emerald Jewel Industry India Limited (Unit 4)
Gold Emirates Gold DMCC
1 Certain of the In-Scope Suppliers reported the presence of this entity that was sanctioned by the United States Department of Treasury, Office of Foreign Assets Control on March 17, 2022. Because of the over-reporting nature of the industry CMRT information collection process, and the nature of the our and our subsidiaries’ supply chains, we are unable to confirm whether or not this, or any, smelter or refiner is or was active in our supply chain.
Gold Fidelity Printers and Refiners Ltd.
Gold Fujairah Gold FZC
Gold Geib Refining Corporation
Gold GG Refinery Ltd.
Gold GGC Gujrat Gold Centre Pvt. Ltd.
Gold Gold by Gold Colombia
Gold Gold Coast Refinery
Gold Gold Refinery of Zijin Mining Group Co., Ltd.
Gold Great Wall Precious Metals Co., Ltd. of CBPM
Gold Guangdong Jinding Gold Limited
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold Heimerle + Meule GmbH
Gold Heraeus Germany GmbH Co. KG
Gold Heraeus Metals Hong Kong Ltd.
Gold Hunan Chenzhou Mining Co., Ltd.
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
Gold HwaSeong CJ CO., LTD.
Gold Industrial Refining Company
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold International Precious Metal Refiners
Gold Ishifuku Metal Industry Co., Ltd.
Gold Istanbul Gold Refinery
Gold Italpreziosi
Gold JALAN & Company
Gold Japan Mint
Gold Jiangxi Copper Co., Ltd.
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold JSC Novosibirsk Refinery
Gold JSC Uralelectromed2
Gold JX Nippon Mining & Metals Co., Ltd.
Gold K.A. Rasmussen
Gold Kaloti Precious Metals
Gold Kazakhmys Smelting LLC
Gold Kazzinc
Gold Kennecott Utah Copper LLC
Gold KGHM Polska Miedz Spolka Akcyjna
Gold Kojima Chemicals Co., Ltd.
Gold Korea Zinc Co., Ltd.
Gold Kundan Care Products Ltd.
Gold Kyrgyzaltyn JSC
Gold Kyshtym Copper-Electrolytic Plant ZAO
Gold L'azurde Company For Jewelry
Gold Lingbao Gold Co., Ltd.
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold L'Orfebre S.A.
Gold LS-NIKKO Copper Inc.
Gold LT Metal Ltd.
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
2 Certain of the In-Scope Suppliers reported the presence of this entity that was sanctioned by the United States Department of Treasury, Office of Foreign Assets Control on July 20, 2023. Because of the over-reporting nature of the industry CMRT information collection process, and the nature of the our and our subsidiaries’ supply chains, we are unable to confirm whether or not this, or any, smelter or refiner is or was active in our supply chain.
Gold Marsam Metals
Gold Materion
Gold Matsuda Sangyo Co., Ltd.
Gold MD Overseas
Gold Metal Concentrators SA (Pty) Ltd.
Gold Metallix Refining Inc.
Gold Metalor Technologies (Hong Kong) Ltd.
Gold Metalor Technologies (Singapore) Pte., Ltd.
Gold Metalor Technologies (Suzhou) Ltd.
Gold Metalor Technologies S.A.
Gold Metalor USA Refining Corporation
Gold Metalurgica Met-Mex Penoles S.A. De C.V.
Gold Mitsubishi Materials Corporation
Gold Mitsui Mining and Smelting Co., Ltd.
Gold MKS PAMP SA
Gold MMTC-PAMP India Pvt., Ltd.
Gold Modeltech Sdn Bhd
Gold Morris and Watson
Gold Moscow Special Alloys Processing Plant
Gold Nadir Metal Rafineri San. Ve Tic. A.S.
Gold Navoi Mining and Metallurgical Combinat
Gold NH Recytech Company
Gold Nihon Material Co., Ltd.
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Gold Ohura Precious Metal Industry Co., Ltd.
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Gold Pease & Curren
Gold Penglai Penggang Gold Industry Co., Ltd.
Gold Planta Recuperadora de Metales SpA
Gold Prioksky Plant of Non-Ferrous Metals
Gold PT Aneka Tambang (Persero) Tbk
Gold PX Precinox S.A.
Gold QG Refining, LLC
Gold Rand Refinery (Pty) Ltd.
Gold Refinery of Seemine Gold Co., Ltd.
Gold REMONDIS PMR B.V.
Gold Royal Canadian Mint
Gold SAAMP
Gold Sabin Metal Corp.
Gold Safimet S.p.A
Gold SAFINA A.S.
Gold Sai Refinery
Gold Sam Precious Metals
Gold Samduck Precious Metals
Gold SAMWON METALS Corp.
Gold SEMPSA Joyeria Plateria S.A.
Gold Shandong Gold Smelting Co., Ltd.
Gold Shandong Humon Smelting Co., Ltd.
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold Shenzhen CuiLu Gold Co., Ltd.
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd.
Gold Shirpur Gold Refinery Ltd.
Gold Sichuan Tianze Precious Metals Co., Ltd.
Gold Singway Technology Co., Ltd.
Gold SOE Shyolkovsky Factory of Secondary Precious Metals
Gold Solar Applied Materials Technology Corp.
Gold Sovereign Metals
Gold State Research Institute Center for Physical Sciences and Technology
Gold Sudan Gold Refinery
Gold Sumitomo Metal Mining Co., Ltd.
Gold SungEel HiMetal Co., Ltd.
Gold Super Dragon Technology Co., Ltd.
Gold T.C.A S.p.A
Gold Tanaka Kikinzoku Kogyo K.K.
Gold Tokuriki Honten Co., Ltd.
Gold Tongling Nonferrous Metals Group Co., Ltd.
Gold TOO Tau-Ken-Altyn
Gold Torecom
Gold Umicore Precious Metals Thailand
Gold Umicore S.A. Business Unit Precious Metals Refining
Gold United Precious Metal Refining, Inc.
Gold Valcambi S.A.
Gold WEEEREFINING
Gold Western Australian Mint (T/a The Perth Mint)
Gold WIELAND Edelmetalle GmbH
Gold Yamakin Co., Ltd.
Gold Yokohama Metal Co., Ltd.
Gold Yunnan Copper Industry Co., Ltd.
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Tantalum 5D Production OU
Tantalum AMG Brasil
Tantalum Changsha South Tantalum Niobium Co., Ltd.
Tantalum D Block Metals, LLC
Tantalum F&X Electro-Materials Ltd.
Tantalum FIR Metals & Resource Ltd.
Tantalum Global Advanced Metals Aizu
Tantalum Global Advanced Metals Boyertown
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd.
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum Jiangxi Tuohong New Raw Material
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum Jiujiang Tanbre Co., Ltd.
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Tantalum KEMET de Mexico
Tantalum Materion Newton Inc.
Tantalum Metallurgical Products India Pvt., Ltd.
Tantalum Mineracao Taboca S.A.
Tantalum Mitsui Mining and Smelting Co., Ltd.
Tantalum Molycorp Silmet A.S.
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum PowerX Ltd.
Tantalum QuantumClean
Tantalum Resind Industria e Comercio Ltda.
Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd.
Tantalum Solikamsk Magnesium Works OAO
Tantalum Taki Chemical Co., Ltd.
Tantalum TANIOBIS Co., Ltd.
Tantalum TANIOBIS GmbH
Tantalum TANIOBIS Japan Co., Ltd.
Tantalum TANIOBIS Smelting GmbH & Co. KG
Tantalum Telex Metals
Tantalum Ulba Metallurgical Plant JSC
Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED
Tantalum XinXing Haorong Electronic Material Co., Ltd.
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd.
Tin Alpha
Tin An Vinh Joint Stock Mineral Processing Company
Tin Aurubis Beerse
Tin Aurubis Berango
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin Chifeng Dajingzi Tin Industry Co., Ltd.
Tin China Tin Group Co., Ltd.
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
Tin CRM Synergies
Tin CV Ayi Jaya
Tin CV Venus Inti Perkasa
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd.
Tin Dowa
Tin DS Myanmar
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin EM Vinto
Tin Estanho de Rondonia S.A.
Tin Fabrica Auricchio Industria e Comercio Ltda.
Tin Fenix Metals
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd.
Tin Gejiu Kai Meng Industry and Trade LLC
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin Gejiu Zili Mining And Metallurgy Co., Ltd.
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
Tin HuiChang Hill Tin Industry Co., Ltd.
Tin Jiangxi New Nanshan Technology Ltd.
Tin Luna Smelter, Ltd.
Tin Ma'anshan Weitai Tin Co., Ltd.
Tin Magnu's Minerais Metais e Ligas Ltda.
Tin Malaysia Smelting Corporation (MSC)
Tin Malaysia Smelting Corporation Berhad (Port Klang)
Tin Melt Metais e Ligas S.A.
Tin Metallic Resources, Inc.
Tin Mineracao Taboca S.A.
Tin Mining Minerals Resources SARL
Tin Minsur
Tin Mitsubishi Materials Corporation
Tin Modeltech Sdn Bhd
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin Novosibirsk Tin Combine
Tin O.M. Manufacturing (Thailand) Co., Ltd.
Tin O.M. Manufacturing Philippines, Inc.
Tin Operaciones Metalurgicas S.A.
Tin Pongpipat Company Limited
Tin Precious Minerals and Smelting Limited
Tin PT Aries Kencana Sejahtera
Tin PT Artha Cipta Langgeng
Tin PT ATD Makmur Mandiri Jaya
Tin PT Babel Inti Perkasa
Tin PT Babel Surya Alam Lestari
Tin PT Bangka Prima Tin
Tin PT Bangka Serumpun
Tin PT Bangka Tin Industry
Tin PT Belitung Industri Sejahtera
Tin PT Bukit Timah
Tin PT Cipta Persada Mulia
Tin PT Menara Cipta Mulia
Tin PT Mitra Stania Prima
Tin PT Mitra Sukses Globalindo
Tin PT Panca Mega Persada
Tin PT Premium Tin Indonesia
Tin PT Prima Timah Utama
Tin PT Putera Sarana Shakti (PT PSS)
Tin PT Rajawali Rimba Perkasa
Tin PT Rajehan Ariq
Tin PT Refined Bangka Tin
Tin PT Sariwiguna Binasentosa
Tin PT Stanindo Inti Perkasa
Tin PT Sukses Inti Makmur
Tin PT Timah Tbk Kundur
Tin PT Timah Tbk Mentok
Tin PT Tinindo Inter Nusa
Tin PT Tirus Putra Mandiri
Tin PT Tommy Utama
Tin Resind Industria e Comercio Ltda.
Tin Rui Da Hung
Tin Super Ligas
Tin Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.
Tin Thaisarco
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd.
Tin Tin Technology & Refining
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tin VQB Mineral and Trading Group JSC
Tin White Solder Metalurgia e Mineracao Ltda.
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd.
Tungsten A.L.M.T. TUNGSTEN Corp.
Tungsten ACL Metais Eireli
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
Tungsten Artek LLC
Tungsten Asia Tungsten Products Vietnam Ltd.
Tungsten China Molybdenum Co., Ltd.
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten CNMC (Guangxi) PGMA Co., Ltd.
Tungsten Cronimet Brasil Ltda
Tungsten DONGKUK INDUSTRIES CO., LTD.
Tungsten Fujian Xinlu Tungsten Co., Ltd.
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten Global Tungsten & Powders LLC
Tungsten Guangdong Xianglu Tungsten Co., Ltd.
Tungsten H.C. Starck Tungsten GmbH
Tungsten HANNAE FOR T Co., Ltd.
Tungsten Hubei Green Tungsten Co., Ltd.
Tungsten Hunan Chenzhou Mining Co., Ltd.
Tungsten Hunan Jintai New Material Co., Ltd.
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
Tungsten Hydrometallurg, JSC
Tungsten Japan New Metals Co., Ltd.
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten JSC "Kirovgrad Hard Alloys Plant"
Tungsten Kenee Mining Corporation Vietnam
Tungsten Kennametal Fallon
Tungsten Kennametal Huntsville
Tungsten Lianyou Metals Co., Ltd.
Tungsten Lianyou Resources Co., Ltd.
Tungsten LLC Vostok
Tungsten Malipo Haiyu Tungsten Co., Ltd.
Tungsten Masan High-Tech Materials
Tungsten Moliren Ltd.
Tungsten Nam Viet Cromit Joint Stock Company
Tungsten Niagara Refining LLC
Tungsten NPP Tyazhmetprom LLC
Tungsten OOO “Technolom” 1
Tungsten OOO “Technolom” 2
Tungsten Philippine Chuangxin Industrial Co., Inc.
Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd.
Tungsten TANIOBIS Smelting GmbH & Co. KG
Tungsten Tungsten Vietnam Joint Stock Company
Tungsten Unecha Refractory Metals Plant
Tungsten Wolfram Bergbau und Hutten AG
Tungsten Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten Xiamen Tungsten Co., Ltd.
Tungsten YUDU ANSHENG TUNGSTEN CO., LTD.
APPENDIX B: COUNTRIES OF ORIGIN
This Appendix B includes the countries from which the declared are known to source material.
Country of Origin
Angola Guyana Papua New Guinea
Argentina Hong Kong Peru
Armenia Hungary Philippines
Australia India Poland
Austria Indonesia Portugal
Belarus Ireland Russian Federation
Belgium Israel Rwanda
Bermuda Italy Saudi Arabia
Bolivia Ivory Coast Sierra Leone
Brazil Japan Singapore
Burundi Jersey Slovakia
Cambodia Kazakhstan South Africa
Canada Kenya South Sudan
Central African Republic Korea, Republic of Spain
Chile Kyrgyzstan Suriname
China Laos Sweden
Colombia Luxembourg Switzerland
Congo (Brazzaville) Madagascar Taiwan
Czech Republic Malaysia Tajikistan
Djibouti Mali Tanzania
DRC- Congo (Kinshasa) Mexico Thailand
Ecuador Mongolia Turkey
Egypt Morocco Uganda
Estonia Mozambique United Arab Emirates
Ethiopia Myanmar United Kingdom
Finland Namibia United States
France Netherlands Uzbekistan
Germany New Zealand Vietnam
Ghana Niger Zambia
Guinea Nigeria Zimbabwe
