Exhibit 1.01
TechnipFMC plc
Conflict Minerals Report
for the Year Ended December 31, 2019
1.Introduction
This Conflict Minerals Report describes TechnipFMC plc’s (the “Company,” “TechnipFMC,” “we,” “us,” and “our”) due diligence process in accordance with the requirements of Rule 13p-1 of the Securities Exchange Act of 1934, as amended.
2.Company Overview and Applicability of Rule 13p-1
TechnipFMC plc is a public limited company incorporated and organized under the laws of England and Wales, with registered number 09909709, and with registered office at One St. Paul’s Churchyard, London EC4M 8AP, United Kingdom.
TechnipFMC is a global energy service company with a portfolio of solutions for the production and transformation of hydrocarbons and renewable energy sources. These solutions range from discreet products and services to fully integrated solutions based on proprietary technologies, with a clear focus to deliver greater efficiency across project lifecycles from concept to delivery and beyond.
We have operational headquarters in Paris, France and Houston, Texas, United States. We operate across three business segments: Subsea, Technip Energies (previously our Onshore/Offshore segment), and Surface Technologies. Through these segments, we are levered to the three energy growth areas of unconventionals, liquefied natural gas, and deepwater developments.
We have a unique and comprehensive set of capabilities to serve the oil and gas industry. With our proprietary technologies and production systems, integration expertise, and comprehensive solutions, we are transforming our clients’ project economics. We have evaluated our product lines and determined that certain products that we manufacture or contract to manufacture contain tin, tungsten, tantalum, and/or gold (“3TG”) and that such 3TG are necessary to the functionality or production of such product(s). These products include, but are not limited to, subsea production and processing systems, surface wellhead production systems, high pressure fluid control equipment, measurement solutions, marine loading systems, remotely operating vehicle systems, manipulator systems, subsea control systems, fracturing flowback services, and umbilical systems for the energy industry.
TechnipFMC is a global company with a supply chain that is reflective of our business. As such, our supply chain is complex and multi-tiered. Because of this, we rely on input from our Tier 1 suppliers (i.e., those that deliver directly to TechnipFMC) to provide input regarding the source of conflict minerals in both the raw materials and parts that we purchase to use in the manufacture of our products.
3.Reasonable Country of Origin Inquiry
To implement the reasonable country of origin inquiry (“RCOI”), we conducted an internal analysis of our products and components. From this analysis, we established a list of Tier 1 suppliers who were
determined to be in-scope for regulatory reporting purposes based on TechnipFMC’s influence over the manufacturing process and potential use of 3TG. We then collected information from the suppliers regarding the presence and sourcing of 3TG used in the products and components they supplied to TechnipFMC. Information was collected and stored using an online platform provided by a third-party vendor, Source Intelligence. These suppliers were engaged following the RCOI process described below:
Supplier Outreach and Engagement:
•TechnipFMC provided Source Intelligence with at least one method of contact for each supplier designated as in-scope (e.g., email address, telephone number, facsimile number, or mailing address). Email was the preferred method of communication.
•The RCOI began with a combined introduction email from Source Intelligence and TechnipFMC to suppliers describing our Conflict Minerals Compliance Program (“CMCP”) standards and identifying Source Intelligence as our compliance vendor in the process. We informed our suppliers of our Conflict Minerals policy and our expectation of compliance with that policy, as well as their cooperation in developing conflict minerals data. This email also contained a registration link for the Source Intelligence on-line platform, as well as our conflict minerals questionnaire.
•In an effort to facilitate awareness of our CMCP, conflict minerals regulation, and frequently asked questions concerning conflict minerals, we provided suppliers a link to Source Intelligence’s website (https://www.sourceintelligence.com) in the initial email. The Source Intelligence website includes materials, white papers, videos, and FAQs to support a deeper understanding of our CMCP and conflict minerals and provides background as to why information was being requested.
•Following the initial introductions to the program and information request, up to five reminder emails were sent by Source Intelligence to each non-responsive supplier requesting a response to our conflict minerals questionnaire.
•For suppliers who remained non-responsive to the email reminders, Source Intelligence then contacted them by telephone, up to three times per supplier, to offer assistance. This assistance included, but was not limited to, further information about the CMCP, an explanation of why the information was being collected, a review of how the information would be used, and clarification regarding how the information needed could be provided.
•If, after these efforts, a supplier still did not register with the system or provide the information requested, an escalation process was initiated. The escalation process consisted of direct outreach by TechnipFMC to request participation in the program. After this direct outreach, Source Intelligence would follow up with an email in a timely manner.
Supplier Questionnaire – Information Requested:
•Suppliers were asked to provide information regarding the sourcing of their materials with the ultimate goal of identifying the 3TG smelters or refiners (“SORs”) and associated mine countries of origin.
•We requested that our suppliers respond to our conflict minerals questionnaire, which was based on the Responsible Minerals Initiative’s (formerly known as the Conflict-Free Sourcing Initiative) Conflict Minerals Reporting Template 5.0 (“CMRT”), an initiative of the Responsible Business Alliance and Global e-Sustainability Initiative.
◦Suppliers were offered two options to submit the relevant information: uploading the CMRT in Microsoft Excel format into the Source Intelligence platform or completing an online version of the conflict minerals questionnaire directly within the Source Intelligence platform. In certain cases, if a supplier was unable to complete the relevant information on the platform, we or Source Intelligence uploaded the CMRT on their behalf.
◦Suppliers were able to provide responses at the part-specific, product-specific or company level. The majority of our suppliers provided their responses at a company level.
◦Where a supplier did not provide a CMRT, Source Intelligence requested information on its suppliers of products or components that might require 3TG for their production and/or functionality. These Tier 2 suppliers, and subsequent tiers of suppliers, as needed, were then engaged following the contact procedures explained above. When contact information was provided, Tier 2 and beyond suppliers were contacted via email or telephone in order to build a chain-of-custody back to the 3TG SOR. When needed, Source Intelligence executed non-disclosure agreements with our Suppliers to address and meet supplier concerns regarding the confidentiality of their data.
Quality Assurance of Supplier Data:
•Supplier responses were evaluated for plausibility, consistency, and gaps. If any of the following “quality control” flags were raised, suppliers were automatically contacted by Source Intelligence on a bi-weekly basis with a request for additional clarification:
•One or more SORs were listed for an unused mineral;
•SOR information was not provided for a used mineral, or the SOR information provided did not relate to a verified metal processor in Source Intelligence’s SOR database;
•Supplier answered “yes” to sourcing from the Democratic Republic of the Congo or adjoining countries (“DRC”), but none of the SORs listed by such supplier are known to source from the DRC;
•Supplier indicated that they had not received conflict minerals data for each metal from all its relevant suppliers;
•Supplier indicated that they had not identified all of the SORs used for the products included in their declaration scope;
•Supplier indicated that they had not provided all applicable SOR information received; and/or
•Supplier indicated that 100% of the 3TG for products covered by their questionnaire originated from scrap/recycled sources, but one or more SORs listed are not known to be exclusive recyclers.
RCOI Results:
Responding suppliers indicated one or more of the regulated metals (3TG) as necessary to the functionality or production of the products they supply to TechnipFMC. Based on our RCOI inquiry, we believe that certain of our products may contain 3TG that originated in the DRC and were not from recycled or scrap sources. As such, we then proceeded to exercise due diligence on the source and chain of custody of such 3TG.
4.Due Diligence
For those supply chains with SORs that are known or thought to be sourcing from the DRC, additional investigation and diligence was needed to determine the source and chain-of-custody of the regulated metals. Our due diligence process was based on the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying supplements (the “OECD Framework”), which is an internationally recognized due diligence framework. All steps taken by us in preparing this Conflict Minerals Report were in accordance with the OECD Framework. The OECD Framework is written for the entire mineral supply chain and our due diligence measures were tailored to include steps appropriate for “downstream” companies.
Source Intelligence relies on the following internationally accepted audit standards to determine which SORs are considered “DRC Conflict Free”: the Responsible Minerals Assurance Process, the London Bullion Market Association Good Delivery Program, and the Responsible Jewellery Council Chain-of-Custody Certification. Source Intelligence has become an official vendor member of the Responsible Minerals Initiative to further facilitate the exchange of supply chain data and technical information in the quest for global ethical sourcing of materials.
If an identified SOR was not certified by these internationally-recognized schemes, attempts were made to contact the SOR to gain more information about their sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes that the SOR followed to track the chain of custody of the source of its minerals. The relevant information we reviewed included whether the SOR had a documented, effective, and communicated conflict-free policy; an accounting system to support a mass balance of materials processed; and/or traceability documentation. Internet research was also performed to determine whether there were any outside sources of information regarding the SOR’s sourcing practices. Up to three contact attempts were made to each SOR to gather information on mine country of origin and sourcing practices.
TechnipFMC’s due diligence measures can only provide a reasonable, and not absolute, assurance regarding the source and custody of conflict minerals. Our due diligence process is based on the necessity to obtain information from our Tier 1 suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. Such sources of information may yield inaccurate or incomplete information, may not respond, and some may be subject to fraud. However, we have taken measures to verify responses and minimize these limitations but cannot guarantee the accuracy of the responses provided.
5.SORs and Countries of Origin
The table below lists, as of April 23, 2020, the SORs known to supply necessary conflict minerals contained in our covered products and who source their conflict minerals from the DRC.
| | | | | | | | | | | |
| Metal | Official Smelter Name | Country of Origin | Certified Smelter1 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Zambia | YES |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | DRC- Congo (Kinshasa) | YES |
| Gold | Asaka Riken Co., Ltd. | Burundi | YES |
| Gold | Asaka Riken Co., Ltd. | Rwanda | YES |
| Gold | CCR Refinery - Glencore Canada Corporation | DRC- Congo (Kinshasa) | YES |
| Gold | CCR Refinery - Glencore Canada Corporation | Zambia | YES |
| Gold | CCR Refinery - Glencore Canada Corporation | DRC- Congo (Kinshasa) | YES |
| Gold | Jiangxi Copper Co., Ltd. | Rwanda | YES |
| Gold | Mitsubishi Materials Corporation | Congo (Brazzaville) | YES |
| Gold | Nihon Material Co., Ltd. | Rwanda | YES |
| Gold | Nihon Material Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Gold | Prioksky Plant of Non-Ferrous Metals | Rwanda | YES |
| Gold | Rand Refinery (Pty) Ltd. | DRC- Congo (Kinshasa) | YES |
| Gold | Rand Refinery (Pty) Ltd. | Tanzania | YES |
| Gold | Samduck Precious Metals | Rwanda | YES |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tantalum | F&X Electro-Materials Ltd. | Angola | YES |
| Tantalum | F&X Electro-Materials Ltd. | Burundi | YES |
| Tantalum | F&X Electro-Materials Ltd. | South Sudan | YES |
| Tantalum | F&X Electro-Materials Ltd. | Rwanda | YES |
| Tantalum | F&X Electro-Materials Ltd. | Tanzania | YES |
| Tantalum | F&X Electro-Materials Ltd. | DRC- Congo (Kinshasa) | YES |
| Tantalum | F&X Electro-Materials Ltd. | Zambia | YES |
| Tantalum | F&X Electro-Materials Ltd. | Congo (Brazzaville) | YES |
| Tantalum | F&X Electro-Materials Ltd. | Uganda | YES |
| Tantalum | F&X Electro-Materials Ltd. | Central African Republic | YES |
| Tantalum | Global Advanced Metals Aizu | DRC- Congo (Kinshasa) | YES |
| Tantalum | Global Advanced Metals Aizu | Uganda | YES |
| Tantalum | Global Advanced Metals Aizu | South Sudan | YES |
| Tantalum | Global Advanced Metals Aizu | Central African Republic | YES |
| Tantalum | Global Advanced Metals Aizu | Burundi | YES |
| Tantalum | Global Advanced Metals Aizu | Rwanda | YES |
| Tantalum | Global Advanced Metals Aizu | Angola | YES |
| Tantalum | Global Advanced Metals Aizu | Congo (Brazzaville) | YES |
| Tantalum | Global Advanced Metals Aizu | Tanzania | YES |
| Tantalum | Global Advanced Metals Aizu | Zambia | YES |
| | | | | | | | | | | |
| Tantalum | Global Advanced Metals Boyertown | Angola | YES |
| Tantalum | Global Advanced Metals Boyertown | Rwanda | YES |
| Tantalum | Global Advanced Metals Boyertown | Zambia | YES |
| Tantalum | Global Advanced Metals Boyertown | Tanzania | YES |
| Tantalum | Global Advanced Metals Boyertown | Central African Republic | YES |
| Tantalum | Global Advanced Metals Boyertown | Congo (Brazzaville) | YES |
| Tantalum | Global Advanced Metals Boyertown | Uganda | YES |
| Tantalum | Global Advanced Metals Boyertown | Burundi | YES |
| Tantalum | Global Advanced Metals Boyertown | DRC- Congo (Kinshasa) | YES |
| Tantalum | Global Advanced Metals Boyertown | South Sudan | YES |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | Rwanda | YES |
| Tantalum | H.C. Starck Co., Ltd. | Burundi | YES |
| Tantalum | H.C. Starck Co., Ltd. | Uganda | YES |
| Tantalum | H.C. Starck Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tantalum | H.C. Starck Co., Ltd. | Tanzania | YES |
| Tantalum | H.C. Starck Co., Ltd. | Congo (Brazzaville) | YES |
| Tantalum | H.C. Starck Co., Ltd. | Rwanda | YES |
| Tantalum | H.C. Starck Co., Ltd. | South Sudan | YES |
| Tantalum | H.C. Starck Co., Ltd. | Zambia | YES |
| Tantalum | H.C. Starck Co., Ltd. | Central African Republic | YES |
| Tantalum | H.C. Starck Co., Ltd. | Angola | YES |
| Tantalum | H.C. Starck Hermsdorf GmbH | Rwanda | YES |
| Tantalum | H.C. Starck Hermsdorf GmbH | Burundi | YES |
| Tantalum | H.C. Starck Hermsdorf GmbH | DRC- Congo (Kinshasa) | YES |
| Tantalum | H.C. Starck Inc. | Rwanda | YES |
| Tantalum | H.C. Starck Inc. | Congo (Brazzaville) | YES |
| Tantalum | H.C. Starck Inc. | Burundi | YES |
| Tantalum | H.C. Starck Ltd. | Rwanda | YES |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Rwanda | YES |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | DRC- Congo (Kinshasa) | YES |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Burundi | YES |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Congo (Brazzaville) | YES |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Rwanda | YES |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Angola | YES |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | South Sudan | YES |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Zambia | YES |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Central African Republic | YES |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Tanzania | YES |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | DRC- Congo (Kinshasa) | YES |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Uganda | YES |
| | | | | | | | | | | |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Congo (Brazzaville) | YES |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Burundi | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Angola | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Zambia | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Burundi | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Tanzania | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Congo (Brazzaville) | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Central African Republic | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | South Sudan | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Rwanda | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Uganda | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | Congo (Brazzaville) | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | Tanzania | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | Uganda | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | Rwanda | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | Burundi | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | South Sudan | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | Central African Republic | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | Angola | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | Zambia | YES |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tantalum | KEMET Blue Metals | Tanzania | YES |
| Tantalum | KEMET Blue Metals | Rwanda | YES |
| Tantalum | KEMET Blue Metals | South Sudan | YES |
| Tantalum | KEMET Blue Metals | Zambia | YES |
| Tantalum | KEMET Blue Metals | Central African Republic | YES |
| Tantalum | KEMET Blue Metals | DRC- Congo (Kinshasa) | YES |
| Tantalum | KEMET Blue Metals | Congo (Brazzaville) | YES |
| Tantalum | KEMET Blue Metals | Angola | YES |
| Tantalum | KEMET Blue Metals | Uganda | YES |
| Tantalum | KEMET Blue Metals | Burundi | YES |
| Tantalum | LSM Brasil S.A. | DRC- Congo (Kinshasa) | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Central African Republic | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Uganda | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Congo (Brazzaville) | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Zambia | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Burundi | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | South Sudan | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Tanzania | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Rwanda | YES |
| | | | | | | | | | | |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Angola | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Rwanda | YES |
| Tantalum | Taki Chemical Co., Ltd. | Uganda | YES |
| Tantalum | Taki Chemical Co., Ltd. | Angola | YES |
| Tantalum | Taki Chemical Co., Ltd. | South Sudan | YES |
| Tantalum | Taki Chemical Co., Ltd. | Congo (Brazzaville) | YES |
| Tantalum | Taki Chemical Co., Ltd. | Zambia | YES |
| Tantalum | Taki Chemical Co., Ltd. | Burundi | YES |
| Tantalum | Taki Chemical Co., Ltd. | Tanzania | YES |
| Tantalum | Taki Chemical Co., Ltd. | Rwanda | YES |
| Tantalum | Taki Chemical Co., Ltd. | Central African Republic | YES |
| Tantalum | Ulba Metallurgical Plant JSC | Central African Republic | YES |
| Tantalum | Ulba Metallurgical Plant JSC | Zambia | YES |
| Tantalum | Ulba Metallurgical Plant JSC | Burundi | YES |
| Tantalum | Ulba Metallurgical Plant JSC | Angola | YES |
| Tantalum | Ulba Metallurgical Plant JSC | Uganda | YES |
| Tantalum | Ulba Metallurgical Plant JSC | Tanzania | YES |
| Tantalum | Ulba Metallurgical Plant JSC | Congo (Brazzaville) | YES |
| Tantalum | Ulba Metallurgical Plant JSC | DRC- Congo (Kinshasa) | YES |
| Tantalum | Ulba Metallurgical Plant JSC | South Sudan | YES |
| Tantalum | Ulba Metallurgical Plant JSC | DRC- Congo (Kinshasa) | YES |
| Tantalum | Ulba Metallurgical Plant JSC | Rwanda | YES |
| Tin | EM Vinto | Congo (Brazzaville) | YES |
| Tin | EM Vinto | DRC- Congo (Kinshasa) | YES |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | DRC- Congo (Kinshasa) | YES |
| Tin | Malaysia Smelting Corporation (MSC) | DRC- Congo (Kinshasa) | YES |
| Tin | Malaysia Smelting Corporation (MSC) | Angola | YES |
| Tin | Malaysia Smelting Corporation (MSC) | South Sudan | YES |
| Tin | Malaysia Smelting Corporation (MSC) | Congo (Brazzaville) | YES |
| Tin | Malaysia Smelting Corporation (MSC) | Burundi | YES |
| Tin | Malaysia Smelting Corporation (MSC) | Zambia | YES |
| Tin | Malaysia Smelting Corporation (MSC) | Tanzania | YES |
| Tin | Malaysia Smelting Corporation (MSC) | Uganda | YES |
| Tin | Malaysia Smelting Corporation (MSC) | Central African Republic | YES |
| Tin | Metallo Belgium N.V. | DRC- Congo (Kinshasa) | YES |
| Tin | Operaciones Metalurgicas S.A. | DRC- Congo (Kinshasa) | YES |
| Tin | Thaisarco | Uganda | YES |
| Tin | Thaisarco | Burundi | YES |
| Tin | Thaisarco | Congo (Brazzaville) | YES |
| Tin | Thaisarco | Tanzania | YES |
| Tin | Thaisarco | Angola | YES |
| Tin | Thaisarco | Central African Republic | YES |
| | | | | | | | | | | |
| Tin | Thaisarco | South Sudan | YES |
| Tin | Thaisarco | Zambia | YES |
| Tin | Thaisarco | DRC- Congo (Kinshasa) | YES |
| Tin | Thaisarco | Rwanda | YES |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | DRC- Congo (Kinshasa) | YES |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Burundi | YES |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Rwanda | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Congo (Brazzaville) | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | South Sudan | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Angola | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Tanzania | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Central African Republic | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Zambia | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Rwanda | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Uganda | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Burundi | YES |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | Rwanda | YES |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tungsten | H.C. Starck Tungsten GmbH | Rwanda | YES |
| Tungsten | Hydrometallurg, JSC | DRC- Congo (Kinshasa) | YES |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | Rwanda | YES |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | Burundi | YES |
| Tungsten | Xiamen Tungsten Co., Ltd. | DRC- Congo (Kinshasa) | YES |
| Tungsten | Xiamen Tungsten Co., Ltd. | Rwanda | YES |
_____________________________
1 “Certified Smelter” means a smelter who has been validated and/or certified under the Responsible Minerals Assurance Process (RMAP), Responsible Jewellery Council (RJC), or the London Bullion Market Association (LBMA).
6.Risk Mitigation for Future Due Diligence
In moving to improve our due diligence and further mitigate the risk of benefiting armed groups, we have taken as of December 31, 2019, or will take, the following steps:
•Continue communicating clear standards with suppliers regarding performance, transparency, and responsible sourcing, including developing a dedicated supplier website;
•Undertake reasonable efforts to increase the response rate of our suppliers in our RCOI process by continuing our corrective action plans for non-responsive suppliers to ensure compliance with our supplier standards;
•Provide assistance and education to suppliers regarding Dodd-Frank Act Section 1502 to cascade compliance protocols to more tiers of our supply chain;
•Continue to compare the RCOI results to information collected via independent conflict-free smelter validation programs and share information with our suppliers and our supply chain organization;
•Engage suppliers who presently source from other suppliers who are using uncertified SORs;
•Engage uncertified SORs directly to communicate industry-based need for certification; and
•Continue to participate in both local and national industry groups to develop best practices regarding responsible sourcing.
