Exhibit 1.01
| 1. | Introduction |
Cubic Corporation (“Cubic”) is a leading international provider of cost-effective systems and solutions addressing the mass transit and global defense markets’ most pressing challenges. We have significant transportation and defense industry expertise which, combined with our innovative technology capabilities, contributes to our leading positions with our customers.
Cubic’s manufacturing processes use a wide array of products which may contain tin, tantalum, tungsten or gold (collectively known as “3TG”). As these materials are necessary to the functionality of many Cubic products, our company is dedicated to tracing the origin of these metals. Cubic is working to ensure our sourcing practices do not support conflict or human rights abuses in the Democratic Republic of the Congo (“DRC”) and surrounding areas (collectively with the DRC, the “Covered Countries”). Cubic’s statement on supply chain responsibility can be found athttps://www.cubic.com/corporate-responsibility.
Over the past fiscal year, Cubic made great strides in organizational commitment to programs supporting supply chain and vendor risk with the acquisition of the OneTrust Vendor Risk Management module. This tool is the keystone of Cubic’s Supply Chain Compliance department supporting the supplier risk evaluation and documentation process. Cubic’s strategy of increased resource building for top tier suppliers advanced further this year with an increased supplier response rate and more complete data reported on the Conflict Minerals Reporting Templates (“CMRT”) that we received from our suppliers. Cubic takes its responsibility as an ethical company seriously, and we continue to perform diligence on our supply chain and report our findings accordingly.
| 2. | Conflict Minerals Disclosure |
During calendar year 2019, Cubic and its subsidiary companies have manufactured or contracted to manufacture products for which 3TG is necessary to the functionality or production. Cubic’s reasonable country of origin inquiry (“RCOI”) and subsequent due diligence identified 34 smelters who our supply chain has reported as potentially sourcing from at least one of the covered countries. All 34 smelters that were identified to us by our suppliers as sourcing from at least one of the covered countries were conformant with the Responsible Mineral Assurance Process (“RMAP”), which means that the smelters complied with the RMAP due diligence assessment protocols or an equivalent cross-recognized assessment. Notwithstanding this assurance, since we rely on information from our suppliers as reported to us in the CMRTs and since not all of our suppliers were able to identify country of origin from which the smelters they use source minerals as further described below, we have concluded in good faith that Cubic cannot definitively state whether its sourcing practices directly or indirectly funded armed groups in the Covered Countries.
9333 Balboa Avenue, San Diego, CA 92123 • P.O. Box 85587, San Diego, CA 92186-5587
858-277-6780 • Fax 858-277-1876
www.cubic.com • NYSE: CUB
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Cubic employed a combination of measures to determine whether the necessary 3TG in Cubic’s products originated from the Covered Countries. Cubic’s RCOI methods are discussed in Section 3 of this disclosure. As a result of these findings, Cubic has exercised and continues to exercise due diligence on the source and chain of custody of 3TG minerals in a manner that conforms to an internationally recognized due diligence framework (the Organization for Economic Cooperation and Development, or “OECD”)1. Cubic hereby submits its Conflict Minerals Report as the attached Exhibit 1.01, as required by Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”).
The table below shows improved metrics on supplier scoping and response and highlights the work Cubic’s Supply Chain Compliance team has done to improve strategic development of its supply-base, targeted inquiries, vendor communications, and vendor capacity building.
| Vendors In- Scope for our RCOI | CMRTs Received | CMRT Stated “No 3TG” | Overall Supplier Response Rate | |||||||||||||
| Fiscal 2019 | 452 | 157 | 15 | 43 | % | |||||||||||
| Change over previous year | -9 | % | +5 | % | -4 | % | +4 | % | ||||||||
The table below shows the number of responsive suppliers who stated that their products contained the 3TG minerals and indicates the number of those suppliers who stated that all smelters/refiners for that mineral had been identified. Increased ability to identify all smelters within a mineral supply chain indicates maturity in a mineral sourcing program.
| Mineral | A. Suppliers who stated that their products contain the designated mineral | B. Suppliers in Column A who also stated that “All smelters [and refiners] identified” for the designated mineral* | C. Improvement over previous year’s findings | |||||||||
| Tantalum | 74 | 24 | +1.9 | % | ||||||||
| Tin | 137 | 70 | +5.6 | % | ||||||||
| Gold | 127 | 62 | +3.5 | % | ||||||||
| Tungsten | 70 | 22 | -0.7 | % | ||||||||
Proper smelter identification continues to be a difficult issue to resolve in conducting diligence. Smelters are often known by different names and smaller smelting operations may not be identified. The table below shows how many smelters or refiners (“SORs”) Cubic identified in its supply chain and their RMAP conformance status. Although Cubic does not have any direct relationships with SORs, Cubic’s membership with the Responsible Mineral Initiative (“RMI”) supports the audit and process development of the remaining 63 identified smelters not yet conformant with the RMAP audit protocol and still in operation.
1 Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
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| SORs Identified | SORs Conformant to RMAP | Percent of SORs Conformant to RMAP | SORs not yet Conformant to | |||||||||||
| 330 | 267 | 81 | % | 63 | ||||||||||
| 3. | Cubic’s Reasonable Country of Origin Inquiry |
To begin the RCOI for this reporting year, Cubic’s Supply Chain Compliance Analyst collected consolidated purchasing data from Cubic’s ERP system in October of 2019.
Cubic’s transition to a company-wide ERP system aided the process of supplier scoping for 3TG by providing a baseline of vendor identification data and commodity/cost data. As is Cubic’s standard process, the commodity list is reviewed by our Engineering team to determine which commodities would contain 3TG. Using this list as a basis, suppliers are sorted by whether they are in-scope of our RCOI (where it is likely that 3TG is intentionally added or used in the purchased product or production process) and arranged by total cost of purchased products. Suppliers providing parts containing 3TG to Cubic account for a small minority of Cubic’s total suppliers (roughly 14% of Cubic’s total suppliers).
Cubic assigned suppliers into three risk level groups based on the amount of spend (higher spend equates to a higher risk level). These risk levels are shown in the table below.
| Supplier count by Risk level and in-scope spend accounted for | Risk 1 | Risk 2 | Risk 3 | |||||||||
| Supplier Count | 42 | 77 | 333 | |||||||||
| Percentage of total in-scope spend | 80 | % | 15 | % | 5 | % | ||||||
The table below reflects a shift in the way Cubic approaches supplier management. In accordance with OECD best practice guidelines, we are developing long-term strategic partnerships with fewer suppliers as opposed to short-term arrangements with many suppliers.
| Total Suppliers accounting for 95% in-scope spend by year | Fiscal Year 2018 | Fiscal Year 2019 | Change | |||||||||
| Supplier Count | 132 | 119 | -10 | % | ||||||||
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Once the grouping was complete, Cubic’s Compliance Analyst requested in-scope suppliers to report their 3TG sourcing information on the most recent revision (5.12) of the industry standard CMRT provided by the RMI (Responsible Mineral Initiative).
As in past years, Cubic encountered some resistance from distributors, who frequently state that they do not track this information. As compliance with these requests is mandated by our standard terms and conditions, Cubic continued to engage with these suppliers and stress the importance of our requirements.
The table below illustrates the breakdown of mineral origin from supplier responses containing a CMRT:
| Contains 3TG from DRC | Does not contain 3TG from DRC | 3TG Source Unknown | No Conflict Minerals Present | |||||||||
| Tantalum | ||||||||||||
| 30 | 11 | 33 | 83 | |||||||||
| Tin | ||||||||||||
| 42 | 48 | 47 | 20 | |||||||||
| Gold | ||||||||||||
| 27 | 52 | 48 | 30 | |||||||||
| Tungsten | ||||||||||||
| 28 | 11 | 31 | 86 | |||||||||
Conflict Minerals Report
| I. | Cubic’s Exercise of Due Diligence under the OECD Guidance. |
Cubic’s due diligence process is modeled after the 3rd Edition of the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains, Supplements on Tin, Tantalum, Tungsten, and Gold (“OECD Guidance”). The OECD Guidance highlights the importance of risk assessment and mitigation, supplier and smelter engagement, and the identification of red flags in the supply chain.
Due to the high non-response or incomplete response rate of several Cubic suppliers coupled with Cubic’s downstream position in the supply chain, Cubic has relied heavily on industry initiatives, such as the RMI CMRT and its membership in the Responsible Mineral Initiative in order to ascertain the origin of the minerals in the components Cubic purchases. Cubic continues to explore ways to increase its participation in these industry efforts in order to facilitate a greater transparency and more open communication from mine to manufacturer.
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| A. | Strong Company Management Systems. |
Cubic has adopted a supply chain policy entitled Corporate Social Responsibility in Supply Chain Management which is based on the OECD Model Supply Chain Policy. This policy sets forth Cubic’s commitment to avoiding doing business with any company sourcing from the DRC or otherwise contributing to armed conflict or human rights abuses anywhere in the world. It also sets forth a summary of Cubic’s diligence process as detailed in Appendix A to this Conflict Minerals Report below.
As Cubic continues to improve its supply chain processes, Cubic has amended and improved its policy to reflect current best practices in fuller detail in accordance with OECD guidance and its policy is publicly available on its website (via the link to this filing). Cubic has also either amended or is in the process of amending U.S. and International terms and condition to require our suppliers to source only from conflict-free smelters and mines, and to provide us confirming information upon request.
In accordance with the OECD Guidance, Cubic has assigned senior level representatives from procurement and legal to oversee and jointly run its Conflict Minerals Team. Part of the Team’s legal function is to periodically report to the Board to outline current status of RCOI, diligence, and overall compliance efforts. Cubic continues to improve its communication processes and ensure availability of resources to support the Conflict Minerals Team and its overall supply chain compliance efforts.
We have established a dedicated email address for employee and supplier questions or concerns on conflict minerals and included that email address in the training seminars. Senior management’s goal is to create and maintain awareness around conflict minerals and supply chain transparency generally and to continue to live our core value of “Doing The Right Thing” in all procurement activities. This is reflected in annual training to procurement staff on Cubic’s ethical sourcing program and how their actions affect the risk of contributing to human rights abuses within Cubic’s supply chain. They are advised to review and consider a supplier’s conformance to Cubic’s ethical sourcing program requirements as part of the procurement decision during supplier selection.
| B. | Identifying and Assessing Risks in the Supply Chain. |
Cubic has historically encountered considerable difficulty in identifying upstream suppliers in its supply chain. This is because Cubic purchases many components necessary to its products from large distribution companies which are not subject to Rule 13p-1. Those distribution companies often purchase their stock of components from other distributors, and chain of custody and origin information is not being passed through the distribution network.
| C. | Responding to Identified Risks. |
Cubic continues to work with its direct suppliers and distributors to reach further upstream and engage those upstream companies in a more effective way — namely, to avoid the use of non-Conflict Free Smelters and move towards sourcing from Conflict Free Smelters only. Cubic sometimes requires obsolete parts which limit our choice of suppliers; however, these parts were generally manufactured prior to the conflict mineral rule’s cut-off date and any 3TG in them would therefore be considered outside of the scope of Section 1502 of the Dodd-Frank Act.
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All the relevant supplier compliance documentation is housed on a dedicated file share website where quality, procurement and legal employees can easily check or reference the documentation. We continue to work on a system where supplier ratings will be more informative and complete and will allow us to act accordingly when presented with red flags during the diligence process.
| D. | Third Party Audits. |
Due to Cubic’s position as a downstream manufacturer, Cubic does not have any direct relationships with smelters or refiners. To help support the third party audit work done by RMI, Cubic became a member of RMI in 2014 and remained a member throughout this reporting period and presently. Cubic considers third party audits by the RMI to be vital to the continued development of the mining industry in the Democratic Republic of the Congo and will continue to support RMI audit initiatives.
| E. | Annual Reporting on Supply Chain Diligence. |
Cubic is committed to compliance with Rule 13p-1 not only as a legal requirement, but as a responsible business practice. We strive for transparency in our supply chain and will present our diligence and risk findings annually, as well as provide details about our ongoing efforts on our website athttps://www.cubic.com/corporate-responsibility. Cubic is also trying to improve the quality and nature of existing information about smelters, so we have included our own research notes on each smelter within the CMRT we provide our own customers.
| II. | Manufacturing and Product Information. |
Cubic has not been able to ascertain with certainty the origin of all the 3TG minerals necessary to the production of its products. These minerals are present in all of the electronics Cubic manufactures (specific products and components which contain 3TG are mentioned below in conjunction with the manufacturing facility mentioned). Tin is used as a base for solder on all circuit boards, wires and cables, and in alloys; tantalum is the primary mineral component in capacitors; gold is a non-corrosive lead on circuit boards and connectors; and tungsten is used in wire or as counterweights. This is just a sample of the many uses for these minerals in Cubic’s products and is not exhaustive. As nearly all of Cubic’s products lines depend on 3TG minerals, all of these product lines are similarly affected. Cubic maintains manufacturing facilities in San Diego, California; Tijuana, Mexico; Tullahoma, Tennessee; Orlando, FL; Auckland, New Zealand; and Salfords, Redhill in the United Kingdom (“UK”).
Cubic’s facilities in San Diego, Tijuana, Orlando, and Auckland are dedicated to manufacturing processes for Cubic’s defense-related businesses. The Tijuana facility supports manufacturing for both the defense and the transportation business. These four facilities manufacture systems and components for its air, ground, and virtual training systems, data links, and personnel locator systems. Tijuana also manufactures hardware and cabling to support Cubic’s transportation business’s point-of-sale and farebox devices.
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GATR Technologies in Huntsville, Alabama manufactures inflatable, portable satellite communication antennas. GATR’s location in Ashburn, Virginia manufactures a range of rugged deployable and tactical communications products including specialized gateways to vehicular telematics systems.
Cubic’s facility in Tullahoma is the primary manufacturing location for Cubic Transportation Systems. The Tullahoma facility manufactures Cubic’s point-of-sale and farebox devices, driver control units, gates, ticket validators, vending devices, back office encoders, and depot computers.
Cubic’s facility in the UK performs light manufacturing work, such as installing upgrades or repairing equipment.
| III. | Cubic’s Supply Chain/Countries of Origin Identified. |
Cubic’s diligence process revealed that many of its responding suppliers provide Cubic with products which are sourced from recycled and scrap, as well as from RMAP-conformant smelters. Without the software solution used in previous years, supplier data gathering, compiling and cleansing was done manually by our Compliance Analyst. The processing of 22,875 lines of smelter data was made more manageable with an excel file created by our Compliance Analyst that validates incorrect data using previous year’s smelter analysis. This in-depth analysis produced a list of 330 legitimate smelters. However, as mentioned above, we were encouraged by the high representation of RMAP-conformant smelters in our supplier CMRTs.
Cubic’s current process identified the RMAP-conformant or LBMA-certified smelters (LBMA has added a materials traceability element to their certification process which meets the requirements of the RMI Conformance Program) set forth in Appendix B.
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Appendix A
Corporate Social Responsibility in Supply Chain Management Policy
| I. | PURPOSE |
Cubic Corporation recognizes the significant adverse impacts of procuring goods that fund human rights abuses. As a responsible corporate citizen, we take a stand to respect human rights and not contribute to global conflict in the way we do business. Cubic has developed this policy on Corporate Responsibility in Supply Chain Management to set forth its commitment to refrain from any action which contributes to the financing of conflict or which supports or encourages unlawful labor practices, and to comply with relevant United Nations sanctions resolutions and, where applicable, domestic laws implementing such resolutions.
| II. | SCOPE |
This Policy is applicable to all Cubic companies.
| III. | POLICY |
| A. | Serious Abuses in the Trade of Minerals and Risk Management |
Cubic will neither tolerate, nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of:
| 1. | any forms of torture, cruel, inhuman, and degrading treatment; |
| 2. | the recruitment, harboring, transportation, provision, or obtaining of a person for: |
| a. | labor or services or slavery through the use of force, fraud, or coercion for the purposes of subjection to involuntary servitude, peonage, debt bondage; or |
| b. | the services of a commercial sex act through the use of force, fraud, or coercion, or in which the person induced to perform such an act has not attained 18 years of age |
| 3. | the worst forms of child labor, and any child labor that is exploitative and/or interferes with a child’s ability to participate in required schooling; |
| 4. | other gross human rights violations and abuses such as widespread sexual violence; |
| 5. | war crimes or other serious violations of international humanitarian law, crimes against humanity, or genocide. |
We will immediately suspend or discontinue engagement with any supplier where we identify a reasonable risk that it is sourcing from, or linked to, any party committing serious abuses as defined in this paragraph.
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| B. | Direct or Indirect Support to Non-State Armed Groups and Risk Management |
Cubic will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling, or export of minerals. "Direct or indirect support" includes, but is not limited to, procuring minerals from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:
| 1. | Illegally control mine sites or otherwise control transportation routes, points where minerals are traded, and upstream actors in the supply chain; or |
| 2. | Illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; or |
| 3. | Illegally tax or extort intermediaries, export companies, or international traders. |
We will immediately suspend or discontinue engagement of any supplier where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined in this paragraph.
| C. | Supply Chain Diligence |
To aid in the fight against human rights abuses, Cubic has developed diligence frameworks based on the OECD Due Diligence Guidance on Responsible Supply Chains to target the use of conflict minerals in funding non-state armed groups as well as human trafficking in our supply chain worldwide. These frameworks are unique; however, both programs involve supplier audits and certifications; risk analysis, verification, and mitigation; diligence; training (both internal and external); and public reporting. Supplier certification is required in order to do business with Cubic.
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| D. | Conflict Minerals |
Cubic’s manufacturing operations often require the use of components containing tantalum, tin, tungsten, and gold (“3TG”). Regardless of their country of origin, these minerals are known as “conflict minerals.” Cubic strives to procure components that are not manufactured using conflict minerals that directly or indirectly fund non-state armed groups. To achieve this goal, Cubic has implemented procedures to conduct diligence on and analyze its supply chain. This diligence includes periodic supplier visits, conducting an onsite Supplier Business Survey with questions on supply chain compliance, and annual country of origin inquiries. These inquiries consist of contacting Cubic’s suppliers of components containing 3TG and inquiring as to the country of origin of their component parts. Cubic maintains this information in a database so it can easily ascertain whether a certain supplier provides conflict-free components to Cubic.
Cubic also requires suppliers to supply conflict-free materials to Cubic, and to provide records evidencing the conflict-free status of the materials upon our request.
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APPENDIX B
List of RMI-Conformant or LBMA-Certified Smelters
GOLD
| 8853 S.p.A. | ITALY | CID002763 |
| Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
| Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
| Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 |
| Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 |
| Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
| AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
| Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
| Asahi Pretec Corp. | JAPAN | CID000082 |
| Asahi Refining Canada Ltd. | CANADA | CID000924 |
| Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
| Asaka Riken Co., Ltd. | JAPAN | CID000090 |
| AU Traders and Refiners | SOUTH AFRICA | CID002850 |
| Aurubis AG | GERMANY | CID000113 |
| Bangalore Refinery | INDIA | CID002863 |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
| Boliden AB | SWEDEN | CID000157 |
| C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
| CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
| Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
| Chimet S.p.A. | ITALY | CID000233 |
| Chugai Mining | JAPAN | CID000264 |
| DODUCO Contacts and Refining GmbH | GERMANY | CID000362 |
| Dowa | JAPAN | CID000401 |
| DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | CID003195 |
| DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
| Eco-System Recycling Co., Ltd. | JAPAN | CID000425 |
| Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
| Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 |
| Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
| HeeSung Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
| Heimerle + Meule GmbH | GERMANY | CID000694 |
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| Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
| Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
| Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
| Istanbul Gold Refinery | TURKEY | CID000814 |
| Italpreziosi | ITALY | CID002765 |
| Japan Mint | JAPAN | CID000823 |
| Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
| JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 |
| JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
| Kazzinc | KAZAKHSTAN | CID000957 |
| Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
| KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 |
| Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
| Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
| Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
| L'Orfebre S.A. | ANDORRA | CID002762 |
| LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
| Marsam Metals | BRAZIL | CID002606 |
| Materion | UNITED STATES OF AMERICA | CID001113 |
| Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
| Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
| Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
| Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
| Metalor Technologies S.A. | SWITZERLAND | CID001153 |
| Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
| Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
| Mitsubishi Materials Corporation | JAPAN | CID001188 |
| Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
| MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
| Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
| Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
| Nihon Material Co., Ltd. | JAPAN | CID001259 |
| Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
| Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
| OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
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| OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
| PAMP S.A. | SWITZERLAND | CID001352 |
| Planta Recuperadora de Metales SpA | CHILE | CID002919 |
| Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
| PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
| PX Precinox S.A. | SWITZERLAND | CID001498 |
| Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
| REMONDIS PMR B.V. | NETHERLANDS | CID002582 |
| Royal Canadian Mint | CANADA | CID001534 |
| SAAMP | FRANCE | CID002761 |
| Safimet S.p.A | ITALY | CID002973 |
| SAFINA A.S. | CZECHIA | CID002290 |
| Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 |
| SAXONIA Edelmetalle GmbH | GERMANY | CID002777 |
| SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
| Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
| Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 |
| SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
| Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
| Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
| SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
| T.C.A S.p.A | ITALY | CID002580 |
| Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
| The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 |
| Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
| TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
| Torecom | KOREA, REPUBLIC OF | CID001955 |
| Umicore Brasil Ltda. | BRAZIL | CID001977 |
| Umicore Precious Metals Thailand | THAILAND | CID002314 |
| Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
| United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
| Valcambi S.A. | SWITZERLAND | CID002003 |
| Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
| WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
| Yamakin Co., Ltd. | JAPAN | CID002100 |
| Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
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Mine locations: Afghanistan, Albania, Angola, Argentina, Australia, Austria, Azerbaijan, Belgium, Bolivia, Brazil, Bulgaria, Burkina Faso, Burundi, Canada, Central African Republic, Chile, China, Colombia, Dominican Republic, Ecuador, England, France, Germany, Ghana, Guinea, Guyana, Hong Kong, India, Indonesia, Italy, Japan, Kazakhstan, Kenya, Korea, Kyrgyzstan, Liberia, Malaysia, Mauritania, Mexico, Mongolia, Peru, Philippines, Poland, Portugal, Republic of the Congo, Russia, Rwanda, Singapore, South Africa, South Sudan, Spain, Suriname, Sweden, Switzerland, Taiwan, Tanzania, Thailand, The Netherlands, Turkey, Uganda, USA, Uzbekistan, Zambia, Zimbabwe, countries identified as L1, L2, and L3, and “Europe.”
TIN:
| Alpha | UNITED STATES OF AMERICA | CID000292 |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
| Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 |
| China Tin Group Co., Ltd. | CHINA | CID001070 |
| CV Ayi Jaya | INDONESIA | CID002570 |
| CV Dua Sekawan | INDONESIA | CID002592 |
| CV Gita Pesona | INDONESIA | CID000306 |
| CV United Smelting | INDONESIA | CID000315 |
| CV Venus Inti Perkasa | INDONESIA | CID002455 |
| Dowa | JAPAN | CID000402 |
| EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
| Fenix Metals | POLAND | CID000468 |
| Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 |
| Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
| Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
| Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
| Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 |
| HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
| Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 |
| Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
| Ma'anshan Weitai Tin Co., Ltd. | CHINA | CID003379 |
| Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
| Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
Page 14
| Melt Metais e Ligas S.A. | BRAZIL | CID002500 |
| Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
| Metallo Belgium N.V. | BELGIUM | CID002773 |
| Metallo Spain S.L.U. | SPAIN | CID002774 |
| Mineracao Taboca S.A. | BRAZIL | CID001173 |
| Minsur | PERU | CID001182 |
| Mitsubishi Materials Corporation | JAPAN | CID001191 |
| O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
| Precious Minerals and Smelting Limited | INDIA | CID003409 |
| PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
| PT Artha Cipta Langgeng | INDONESIA | CID001399 |
| PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
| PT Babel Inti Perkasa | INDONESIA | CID001402 |
| PT Babel Surya Alam Lestari | INDONESIA | CID001406 |
| PT Bangka Prima Tin | INDONESIA | CID002776 |
| PT Bangka Serumpun | INDONESIA | CID003205 |
| PT Bangka Tin Industry | INDONESIA | CID001419 |
| PT Belitung Industri Sejahtera | INDONESIA | CID001421 |
| PT Bukit Timah | INDONESIA | CID001428 |
| PT DS Jaya Abadi | INDONESIA | CID001434 |
| PT Inti Stania Prima | INDONESIA | CID002530 |
| PT Karimun Mining | INDONESIA | CID001448 |
| PT Kijang Jaya Mandiri | INDONESIA | CID002829 |
| PT Menara Cipta Mulia | INDONESIA | CID002835 |
| PT Mitra Stania Prima | INDONESIA | CID001453 |
| PT Panca Mega Persada | INDONESIA | CID001457 |
| PT Premium Tin Indonesia | INDONESIA | CID000313 |
| PT Prima Timah Utama | INDONESIA | CID001458 |
| PT Rajawali Rimba Perkasa | INDONESIA | CID003381 |
| PT Rajehan Ariq | INDONESIA | CID002593 |
| PT Refined Bangka Tin | INDONESIA | CID001460 |
| PT Sariwiguna Binasentosa | INDONESIA | CID001463 |
| PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
| PT Sukses Inti Makmur | INDONESIA | CID002816 |
| PT Sumber Jaya Indah | INDONESIA | CID001471 |
| PT Timah Tbk Kundur | INDONESIA | CID001477 |
Page 15
| PT Timah Tbk Mentok | INDONESIA | CID001482 |
| PT Tinindo Inter Nusa | INDONESIA | CID001490 |
| PT Tirus Putra Mandiri | INDONESIA | CID002478 |
| PT Tommy Utama | INDONESIA | CID001493 |
| Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
| Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
| Soft Metais Ltda. | BRAZIL | CID001758 |
| Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | CID002834 |
| Thaisarco | THAILAND | CID001898 |
| Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 |
| White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
| Yunnan Tin Company Limited | CHINA | CID002180 |
| Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 |
Mine Locations: Australia, Belgium, Bolivia, Brazil, Burundi, Central Africa, China, DRC, Indonesia, Laos, Malaysia, Morocco, Myanmar, Peru, Philippines, Portugal, Republic of Congo, Rwanda, Spain, Thailand, Uganda, Viet Nam, and countries identified as L1, L2, and L3.
TUNGSTEN
| A.L.M.T. Corp. | JAPAN | CID000004 |
| ACL Metais Eireli | BRAZIL | CID002833 |
| Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
| Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
| Fujian Ganmin RareMetal Co., Ltd. | CHINA | CID003401 |
| Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 |
| Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 |
| Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
| Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 |
| Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 |
| H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
| Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 |
Page 16
| Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 |
| Hunan Litian Tungsten Industry Co., Ltd. | CHINA | CID003182 |
| Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
| Japan New Metals Co., Ltd. | JAPAN | CID000825 |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 |
| Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
| Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
| JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | CID003408 |
| Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
| Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
| KGETS Co., Ltd. | KOREA, REPUBLIC OF | CID003388 |
| Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 |
| Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
| Masan Tungsten Chemical LLC (MTC) | VIET NAM | CID002543 |
| Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
| Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
| Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
| Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 |
| Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 |
| Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
| Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 |
| Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
| Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 |
Mine locations: Australia, Austria, Bolivia, Brazil, Canada, China, Colombia, Georgia, Germany, Korea, Mexico, Nigeria, Portugal, Russia, Rwanda, Spain, Thailand, USA, Viet Nam, and countries identified as L1 and L3.
Page 17
TANTALUM
| Asaka Riken Co., Ltd. | JAPAN | CID000092 |
| Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
| CP Metals Inc. | UNITED STATES OF AMERICA | CID003402 |
| D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
| Exotech Inc. | UNITED STATES OF AMERICA | CID000456 |
| F&X Electro-Materials Ltd. | CHINA | CID000460 |
| FIR Metals & Resource Ltd. | CHINA | CID002505 |
| Global Advanced Metals Aizu | JAPAN | CID002558 |
| Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
| Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 |
| Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 |
| H.C. Starck Co., Ltd. | THAILAND | CID002544 |
| H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 |
| H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 |
| H.C. Starck Ltd. | JAPAN | CID002549 |
| H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 |
| H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 |
| Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
| Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
| Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
| KEMET Blue Metals | MEXICO | CID002539 |
| KEMET Blue Powder | UNITED STATES OF AMERICA | CID002568 |
| LSM Brasil S.A. | BRAZIL | CID001076 |
| Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
| Mineracao Taboca S.A. | BRAZIL | CID001175 |
| Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 |
| Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
| NPM Silmet AS | ESTONIA | CID001200 |
| Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | CID002847 |
| QuantumClean | UNITED STATES OF AMERICA | CID001508 |
| Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
Page 18
| RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
| Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
| Taki Chemical Co., Ltd. | JAPAN | CID001869 |
| Telex Metals | UNITED STATES OF AMERICA | CID001891 |
| Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
| XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
Mine locations: Australia, Austria, Bolivia, Brazil, Burundi, China, DRC, Ethiopia, Germany, India, Japan, Kazakhstan, Mexico, Mozambique, Namibia, Nigeria, Russia, Rwanda, Sierra Leone, Thailand, USA, Zimbabwe, and countries identified as L1, L2, and L3.