Exhibit 1.01
Conflict Minerals Report
Bloom Energy Corporation
This Conflict Minerals Report (“Report”) for the year ended December 31, 2019 has been prepared by the management of Bloom Energy Corporation (herein referred to as “Bloom Energy”, “Company”, “we”, “us”, or “our”). 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.
I.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 2019 calendar year is the first year that Bloom Energy is filing a Conflict Minerals Report (“First Reporting Period”).
For the First Reporting Period, Bloom Energy determined that only one product manufactured or contracted to be manufactured contained tin, tungsten, tantalum and/or gold or its derivatives (“3TGs”) that were necessary to its functionality or production: the Bloom Energy Server, a stationary power generation platform (the “Covered Product”).
Bloom Energy conducted in good faith a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TGs in the Covered Product originated in the Covered Countries by engaging with certain suppliers who provided materials that may contain 3TG that was used in the Covered Product (“In-Scope Suppliers”). Based on our RCOI, Bloom Energy had reason to believe that our Covered Product could contain 3TGs that originated in the Covered Countries. Therefore, in accordance with Section 1502 of the Dodd-Frank Act, we performed due diligence on the source and chain of custody of the 3TGs.
Reasonable Country of Origin Inquiry
To assist us with our with our determination whether 3TGs, necessary for our products originated in Covered Countries, Bloom Energy engaged a third-party service provider, Assent Compliance (“Assent”). Assent provided Bloom Energy with access to the Assent Compliance Manager (“ACM”), a software-as-a-service 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
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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 ACM 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 Conflict Minerals Report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through the ACM.
Bloom Energy provided a list of In-Scope Suppliers and parts associated with the Covered Product to Assent for upload to the ACM. Assent assisted with our evaluation of supply chain information regarding 3TGs, identification of potential risks, and development and implementation of additional due diligence steps. Bloom Energy also leveraged Assent’s Managed Services Team to collaborate with dedicated program specialists. Bloom Energy communicated regularly with Assent’s Managed Services Team concerning program status. Assent’s team members are trained in conflict minerals compliance and understand the intricacies of the CMRT, conflict minerals reporting, and generally, Section 1502 of the Dodd-Frank Act.
We used the ACM to request that our In-Scope Suppliers complete the Responsible Mineral Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”), version 5.12 or higher, to collect data on the sources of origin of the materials we purchase that are necessary for our products. Suppliers then uploaded their completed CMRTs directly to the platform for validation, assessment and management. Suppliers were also offered training and education, available in the ACM. Assent monitored and tracked all communications in the ACM for future reporting and transparency. Bloom Energy directly contacted suppliers that were unresponsive to Assent’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 Assent’s multilingual Supplier Experience team or on-line training. Data concerning suppliers who remain unresponsive to feedback is tracked as a program gap for future improvement.
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As of March 1, 2020, we had 146 In-Scope Suppliers. 119 (or 81.51%) of the In-Scope Suppliers completed a valid CMRT. We classified 2 supplier CMRT forms as “invalid” because their submissions could not be corrected. Therefore, our RCOI process produced data to help determine the countries of origin for nearly all of the 3TGs in our Covered Product.
II.DUE DILIGENCE
Bloom Energy designed its due diligence measures to conform with the OECD Guidance in all material respects and as appropriate for our First Reporting Period. We endeavored to align the program with the 5 steps for due diligence described in the OECD Guidance as set forth in Section II of this report. We continue to evaluate market expectations for data collection and reporting to make improvements to our 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. Therefore, to execute due diligence, we must rely on data from our 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, our multiple supplier-outreach efforts and process validation steps help mitigate this risk. 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 our responsible sourcing strategy and for briefing senior management on the results of due diligence.
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
We rely on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials that they supply to us, such as sources of 3TGs that the suppliers purchase from their lower-tier suppliers. However, we expect 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.
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Supplier Engagement
Bloom Energy has a strong relationship with our In-Scope Suppliers. We engage directly with our 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 ACM, at no-charge, to upload their CMRTs as well as to seek help-desk support in their native language from Assent’s team of supplier support specialists. Suppliers can also participate in Assent’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 our policies. In our Policy on Responsible Sourcing. Suppliers, we have published a dedicated email address for suppliers to contact the Bloom Energy Supplier Team to ask questions. 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 BloomEnergy.ethicspoint.com.
In the event that employees and suppliers wish to contact our Board of Directors, we also publish the Board’s address in our Global Code of Business Conduct and Ethics, available at: s22.q4cdn.com/122868703/files/doc_downloads/govDocs/bloomenergy_code_final.pdf. Finally, violations or grievances at the industry level can be reported directly to RMI at: www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.
Maintain Records
The ACM Platform also includes a document retention policy to retain our 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 automatically in the ACM based on criteria established for supplier responses. These risks are addressed by Assent staff and members of Bloom Energy’s Conflict Minerals Team, who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.
Risks at the supplier level may include non-responsive suppliers, incomplete CMRTs, or CMRTs that are submitted at the Bloom Energy level. In those cases where a Bloom Energy-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, Bloom Energy is unable to determine if all of the specified smelters and refiners were used for 3TGs in the materials supplied to Bloom Energy. Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their own suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
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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 2019 calendar year, Assent compared these facilities to the RMI list of smelters and refiners. Assent relied on the RMI audit standard, including cross-recognition of the London Bullion Market Association Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance.
Assent determined if the smelter 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, we 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. 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:
•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 of concern are provided with feedback instructing that supplier to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to Bloom Energy. Additional escalation may be necessary to address any continued sourcing from these smelters of concern. Suppliers were given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters of concern from the supply chain. In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process
Suppliers are also evaluated on program strength, which will assist us with making key risk mitigation decisions as our program progresses. The criteria used to evaluate the strength of our program is based on questions in the CMRT related to the suppliers’ conflict minerals practices and policies.
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Step Three: Design and Implement a Strategy to Respond to Identified Risks
Together with Assent, in this First Reporting Period, Bloom Energy developed inaugural processes 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 our 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. Assent also communicated 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 if replacing that supplier is feasible. The results of the program and risk assessment are shared with both the Conflict Minerals Team and our leadership 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.
Assent also directly contacts 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, 2019 with the United States Securities and Exchange Commission. 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.
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III 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 Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. For the 2019 reporting year, Table 1 sets out the result of our supply chain outreach.
Table 1
SUPPLY CHAIN OUTREACH METRICS
| Number of In-Scope Suppliers | Change in Number of In-Scope Suppliers From 2018 | Response Rate | Valid Response Rate | ||||||||
| 146 | N/A (2019 is our first year of reporting) | 82.88% (121 out of 146) | 81.51% (119 out of 146) | ||||||||
Upstream Data Transparency
All legitimate smelters and refiners listed by suppliers in completed CMRTs (which appear on the RMI-maintained smelters list) 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.
Although the potential for over-reporting is understood, Bloom Energy has taken measures to validate these sources of origin against validated audit programs intended to verify the material types and mine sources of origin for these smelters and refiners. From the gathered responses, 5 smelters that potentially posed a risk due to the presence of some red flag indicators were identified. Based on the diligence performed, and understanding that risks were identified, Bloom Energy is able to conclude that it has no reason to believe that its suppliers were sourcing minerals through a supply chain that benefited armed groups in the DRC region.
In accordance with OECD Guidance, suppliers that identified these specific smelters of concern in their CMRT were contacted to communicate the potential for risk and to evaluate whether or not these smelters could be connected to Bloom Energy’s products. The suppliers were then asked to complete a user-defined or product-level CMRT specific to the materials, products or piece parts purchased by Bloom Energy, rather than a company-level CMRT, to help us identify the connection to products that they supply to Bloom Energy.
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| Status | Number of Identified Smelters and Refiners | ||||
| RMAP Conformant | 232 | ||||
| RMAP Active | 5 | ||||
| Not Enrolled | 52 | ||||
| Non-Conformant | 7 | ||||
| Total Number of Identified Smelters and Refiners | 296 | ||||
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 in the preceding section, it is understood that many responses may provide more data than can be directly linked to products sold by Bloom Energy, therefore, Appendix B may contain more countries than those from which Bloom Energy’s products are sourced.
The information contained on any website referred to in this Conflict Minerals Report does not form any part of this Report or Form SD and is not incorporated by reference herein unless expressly noted.
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APPENDIX A
SMELTER LIST
| Minerals | Standard Smelter Name | Smelter Facility Location | ||||||
| Gold | 8853 S.p.A. | ITALY | ||||||
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||||||
| Gold | African Gold Refinery | UGANDA | ||||||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||||||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||||||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | ||||||
| Gold | Asahi Pretec Corp. | JAPAN | ||||||
| Gold | Asahi Refining Canada Ltd. | CANADA | ||||||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||||||
| Gold | AU Traders and Refiners | SOUTH AFRICA | ||||||
| Gold | Aurubis AG | GERMANY | ||||||
| Gold | Bangalore Refinery | INDIA | ||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||||||
| Gold | Boliden AB | SWEDEN | ||||||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | ||||||
| Gold | Caridad | MEXICO | ||||||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||||||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | ||||||
| Gold | CGR Metalloys Pvt Ltd. | INDIA | ||||||
| Gold | Chimet S.p.A. | ITALY | ||||||
| Gold | Chugai Mining | JAPAN | ||||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||||||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||||||
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||||||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||||||
| Gold | Dowa | JAPAN | ||||||
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||||||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||||||
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | ||||||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||||||
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| Minerals | Standard Smelter Name | Smelter Facility Location | ||||||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||||||
| Gold | Guangdong Jinding Gold Limited | CHINA | ||||||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||||||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||||||
| Gold | Heimerle + Meule GmbH | GERMANY | ||||||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||||||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||||||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | ||||||
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||||||
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | ||||||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold | Istanbul Gold Refinery | TURKEY | ||||||
| Gold | Italpreziosi | ITALY | ||||||
| Gold | Japan Mint | JAPAN | ||||||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | ||||||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | ||||||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||||||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||||||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||||||
| Gold | Kazzinc | KAZAKHSTAN | ||||||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||||||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||||||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||||||
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | ||||||
| Gold | Lingbao Gold Co., Ltd. | CHINA | ||||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||||||
| Gold | L'Orfebre S.A. | ANDORRA | ||||||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||||||
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||||||
| Gold | Marsam Metals | BRAZIL | ||||||
| Gold | Materion | UNITED STATES OF AMERICA | ||||||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||||||
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| Minerals | Standard Smelter Name | Smelter Facility Location | ||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||||||
| Gold | Metalor Technologies S.A. | SWITZERLAND | ||||||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||||||
| Gold | Mitsubishi Materials Corporation | JAPAN | ||||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||||||
| Gold | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Gold | Morris and Watson | NEW ZEALAND | ||||||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||||||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||||
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | ||||||
| Gold | Nihon Material Co., Ltd. | JAPAN | ||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||||||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||||||
| Gold | PAMP S.A. | SWITZERLAND | ||||||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | ||||||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||||||
| Gold | Planta Recuperadora de Metales SpA | CHILE | ||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||||||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||||||
| Gold | PX Precinox S.A. | SWITZERLAND | ||||||
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | ||||||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||||||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | ||||||
| Gold | REMONDIS PMR B.V. | NETHERLANDS | ||||||
| Gold | Royal Canadian Mint | CANADA | ||||||
| Gold | SAAMP | FRANCE | ||||||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||||||
| Gold | Safimet S.p.A | ITALY | ||||||
| Gold | SAFINA A.S. | CZECH REPUBLIC | ||||||
| Gold | Sai Refinery | INDIA | ||||||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||||
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||||||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||||||
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||||||
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | ||||||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||||||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
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| Minerals | Standard Smelter Name | Smelter Facility Location | ||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||||||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold | Sovereign Metals | INDIA | ||||||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||||||
| Gold | Sudan Gold Refinery | SUDAN | ||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||||||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | T.C.A S.p.A | ITALY | ||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||||||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||||||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||||||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||||||
| Gold | Tony Goetz NV | BELGIUM | ||||||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||||||
| Gold | Torecom | KOREA, REPUBLIC OF | ||||||
| Gold | Umicore Brasil Ltda. | BRAZIL | ||||||
| Gold | Umicore Precious Metals Thailand | THAILAND | ||||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||||||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Valcambi S.A. | SWITZERLAND | ||||||
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||||||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | ||||||
| Gold | Yamakin Co., Ltd. | JAPAN | ||||||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | ||||||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||||||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | ||||||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | ||||||
| Tantalum | Global Advanced Metals Aizu | JAPAN | ||||||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||||||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||||||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | ||||||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||||||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | H.C. Starck Ltd. | JAPAN | ||||||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||||||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | ||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||||||
13
| Minerals | Standard Smelter Name | Smelter Facility Location | ||||||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | ||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | KEMET Blue Metals | MEXICO | ||||||
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | ||||||
| Tantalum | LSM Brasil S.A. | BRAZIL | ||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||||||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||||||
| Tantalum | NPM Silmet AS | ESTONIA | ||||||
| Tantalum | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | ||||||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||||||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||||||
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||||||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | ||||||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tin | Alpha | UNITED STATES OF AMERICA | ||||||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||||||
| Tin | China Tin Group Co., Ltd. | CHINA | ||||||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||||||
| Tin | Dowa | JAPAN | ||||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||||||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin | Estanho de Rondonia S.A. | BRAZIL | ||||||
| Tin | Fenix Metals | POLAND | ||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||||||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||||||
14
| Minerals | Standard Smelter Name | Smelter Facility Location | ||||||
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | ||||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | ||||||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||||||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | ||||||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||||||
| Tin | Metallo Belgium N.V. | BELGIUM | ||||||
| Tin | Metallo Spain S.L.U. | SPAIN | ||||||
| Tin | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tin | Minsur | PERU | ||||||
| Tin | Mitsubishi Materials Corporation | JAPAN | ||||||
| Tin | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||||||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||||||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA,PLURINATIONAL STATE OF | ||||||
| Tin | Pongpipat Company Limited | MYANMAR | ||||||
| Tin | Precious Minerals and Smelting Limited | INDIA | ||||||
| Tin | PT Artha Cipta Langgeng | INDONESIA | ||||||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||||||
| Tin | PT Mitra Stania Prima | INDONESIA | ||||||
| Tin | PT Refined Bangka Tin | INDONESIA | ||||||
| Tin | PT Timah Tbk Kundur | INDONESIA | ||||||
| Tin | PT Timah Tbk Mentok | INDONESIA | ||||||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||||||
| Tin | Soft Metais Ltda. | BRAZIL | ||||||
| Tin | Super Ligas | BRAZIL | ||||||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||||||
| Tin | Thaisarco | THAILAND | ||||||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||||||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tin | Yunnan Tin Company Limited | CHINA | ||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | A.L.M.T. Corp. | JAPAN | ||||||
| Tungsten | ACL Metais Eireli | BRAZIL | ||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | China Molybdenum Co., Ltd. | CHINA | ||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||||||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||||||
15
| Minerals | Standard Smelter Name | Smelter Facility Location | ||||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||||||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||||||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||||||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||||||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | ||||||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||||||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||||||
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | ||||||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||||||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||||||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | ||||||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||||||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||||||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||||||
16
APPENDIX B:
COUNTRIES OF ORIGIN
| ANDORRA | JAPAN | SINGAPORE | ||||||
| AUSTRALIA | KAZAKHSTAN | SOUTH AFRICA | ||||||
| AUSTRIA | KOREA, REPUBLIC OF | SPAIN | ||||||
| BELGIUM | KYRGYZSTAN | SUDAN | ||||||
| BOLIVIA , PLURINATIONAL STATE OF | LITHUANIA | SWEDEN | ||||||
| BRAZIL | MALAYSIA | SWITZERLAND | ||||||
| CANADA | MEXICO | TAIWAN, PROVINCE OF CHINA | ||||||
| CHILE | MYANMAR | THAILAND | ||||||
| CHINA | NETHERLANDS | TURKEY | ||||||
| CZECH REPUBLIC | NEW ZEALAND | UGANDA | ||||||
| ESTONIA | NORTH MACEDONIA, REPUBLIC OF | UNITED ARAB EMIRATES | ||||||
| FRANCE | PERU | UNITED STATES OF AMERICA | ||||||
| GERMANY | PHILIPPINES | UZBEKISTAN | ||||||
| INDIA | POLAND | VIETNAM | ||||||
| INDONESIA | RUSSIAN FEDERATION | ZIMBABWE | ||||||
| ITALY | SAUDI ARABIA | |||||||