Exhibit 1.01
Conflict Minerals Report of Donaldson Company, Inc.
In accord with Rule 13p-1 under the Securities Exchange Act of 1934
| 1. | Introduction and Summary |
This report for the year ended December 31st 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements pursuant to Section 13(p) of the Securities and Exchange Act of 1934 (“Section 13(p)”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. The term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (“Conflict Minerals”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. These requirements apply to registrants regardless of the geographic origin of the Conflict Minerals or whether they fund armed conflict.
Donaldson Company, Inc. (“Donaldson” or “the Company”) determined that Conflict Minerals were necessary to the functionality or production of products that we manufactured or contracted to be manufactured during the 2015 calendar year. Therefore, Donaldson conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the Conflict Minerals in its products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”). Based on its RCOI, Donaldson has concluded that its products contain Conflict Minerals that originated in the Covered Countries and, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the Conflict Minerals in question to determine whether its products are “DRC Conflict Free”. Donaldson designed its due diligence measures to conform, in all material respects, with the nationally recognized due diligence framework in The Organization for Economic Co-Operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold and for tin, tantalum and tungsten (the “OECD Guidance”). As a result of our due diligence efforts, the Company has concluded some of the Conflict Minerals for the Company’s products originated in, or may have originated in, the Covered Countries and were not from recycled or scrap sources. The Company did not receive responses from all companies in its supply chain and most of the responses were at the company or division level. The smelters or refiners (“SORs”) identified to date by the supply chain are Conflict-Free Sourcing Initiative (“CFSI”) certified.
| 2. | Company Overview |
Donaldson was founded in 1915 and organized in its present corporate form under the laws of the State of Delaware in 1936. The Company is a worldwide manufacturer of filtration systems and replacement parts. The Company’s product mix includes air and liquid filtration systems and exhaust and emission control products. Products are manufactured at 42 plants around the world and through three joint ventures.
| 3. | Product Description |
The Company has two reporting segments: Engine Products and Industrial Products. Products in the Engine Products segment consist of air filtration systems, exhaust and emissions systems, liquid filtration systems including hydraulics, fuel, and lube, and replacement filters. The Engine Products segment sells to original equipment manufacturers (“OEMs”) in the construction, mining, agriculture, aerospace, defense, and truck markets, and to independent distributors, OEM dealer networks, private label accounts, and large equipment fleets. Products in the Industrial Products segment consist of dust, fume, and mist collectors, compressed air purification systems, air filtration systems for gas turbines, PTFE membrane-based products, and specialized air filtration systems for applications including computer hard disk drives and semi-conductor manufacturing. The Industrial Products segment sells to various industrial dealers, distributors, OEMs of gas-fired turbines, and OEMs and end-users requiring clean air filtration solutions and replacement filters.
The Company manufactures and contracts to manufacture products containing Conflict Minerals. Conflict Minerals were identified in products from both of the Company’s reporting segments, Engine Products and Industrial Products.
The Company has adopted a Conflict Minerals Policy articulating our conflict minerals supply chain due diligence process and our commitment to our reporting obligations regarding conflict minerals:
Conflict Minerals Policy
The ongoing conflict in the Democratic Republic of the Congo (DRC) is fueled in part from trade of “conflict minerals,” which are defined as tantalum, tin, tungsten, and gold or any of their derivatives. Donaldson will work with our supply chain partners to take reasonable steps to assure Conflict Minerals are not sourced by Donaldson or our supply chain partners in a way that would directly or indirectly benefit armed groups responsible for serious human rights abuses in the DRC or adjoining countries. Donaldson expects that our suppliers will comply with our requests to provide statements and perform due diligence about the source of any Conflict Minerals in their products which are provided to us.
The Conflict Minerals policy is posted on the Company’s website:
https://secure.ethicspoint.com/domain/media/en/gui/19744/minerals.pdf
| 4. | Reasonable Country of Origin Inquiry |
The Company developed a supply chain transparency program utilizing internal resources and a third-party vendor to allow for the identification of SORs in the suppliers’ mineral supply chains.
Suppliers received an email via the third-party vendor system describing the compliance requirements and requesting Conflict Minerals, SORs information and also included instructions for providing requested supply chain information. Suppliers were requested to provide such SORs information through the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”) Conflict Minerals Reporting Template (“CMRT”), version 4.01.
An escalation process was initiated for suppliers who continued to be non-responsive after the above contacts were made. This process included direct emails to the non-responsive suppliers.
Following the suppliers submission of their CMRT, a data validation process was employed to increase the accuracy of submissions and identify contradictory answers in the CMRT. Suppliers were then contacted to address items such as the following:
| · | Incomplete data including missing SORs |
| · | Responses that indicated a sourcing location without complete supporting information |
Certain of the responses provided by suppliers on the CMRT included the names of facilities listed by the suppliers as smelters or refiners. The Company does not typically have a direct relationship with Conflict Minerals smelters and refiners and does not perform or direct audits of these entities within our supply chain. The Company’s third-party vendor compared the facilities listed in the responses to the list of smelters maintained by the CFSI. If a supplier indicated that the facility was certified as “Conflict-Free,” the third-party vendor confirmed that the name was listed by CFSI. Organizations that were identified by suppliers as SORs, but were invalid or undetermined, were contacted directly to clarify their status as an SOR.
Smelters and Refiners
Attached as Appendix A is a list of all of the validated SORs as identified by the Company’s supply chain in their submitted CMRTs that appear on the CFSI list. Because most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which SORs listed on Appendix A actually processed the Conflict Minerals contained in our products. Therefore, our list of processing SORs disclosed in Appendix A may contain more facilities than those that actually processed the Conflict Minerals contained in our products.
Country of Origin
Attached as Appendix B is a list of the countries of origin as identified by the CFSI for the SORs included in Appendix A.
| 5. | Due Diligence |
The Company’s due diligence process is based on the Organization for Economic Cooperation and Development’s (“OECD’s”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements. It is important to note that the OECD Guidance was written for both upstream and downstream companies in the supply chain. Upstream companies refer to those between the mines and SORs. As such, the companies typically include mine operators, local traders, or exporters from the country of mineral origin, international concentrate traders, and SORs. Downstream companies refer to those entities between the SOR and retailer. As such, the companies typically include metal traders and exchanges, component manufacturers, product manufacturers, OEMs, and retailers. As the Companyis a downstream company in the supply chain, its due diligence practices were tailored accordingly.
A summary of the due diligence measures undertaken bythe Company is below:
Establish strong company management systems:
Internal Team
The Company’s management systems for Conflict Minerals covering the 2015 calendar year were sponsored by a Steering Committee whose members included the Vice President and Chief Financial Officer, Vice President and General Counsel, Vice President Global Operations , and Senior Vice President Engine Products. Steering Committee members provide reports directly to the Audit Committee of the Board of Directors. The Steering Committee was supported by a Process Development Team consisting of subject matter experts from relevant functions such as Legal, Materials Compliance, Purchasing, Sales, Engineering, and Internal Audit.
Conflict Minerals Policy
The Company’s Conflict Minerals policy is publicly available at:
https://secure.ethicspoint.com/domain/media/en/gui/19744/minerals.pdf
Control Systems
Since we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our business sector and other sectors, through our own efforts and those organized by trade associations. We also participate in or actively monitor the following industry-wide initiatives to disclose upstream parties in the supply chain: Member of the Electronics Industry Citizenship Coalition-Global e-Sustainability Initiative’s (EICC-GeSI) Conflict Free Sourcing Initiative (CFSI), as well as other manufacturing industry consortiums including the National Association of Manufacturers (NAM), and the Manufacturers Alliance for Productivity and Innovation (MAPI).
Controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all Donaldson employees and third parties doing business with Donaldson, and our Policy regarding Conflict Minerals.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 4 and a third-party vendor’s web-based reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests. We continue to observe that a great deal of follow-up has been required with suppliers to educate them on the Rule, Donaldson’s Conflict Minerals policy, and our expectations for their supply chain due diligence and reporting.
Grievance Mechanism
The Company continues to maintain a secured third-party hosted Company-level grievance mechanism accessible via the Company’s website:https://secure.ethicspoint.com/domain/media/en/gui/19744/index.html
Maintain Records
Maintained a policy related to relevant documentation of our Conflict Mineral compliance process requires that documentation will be retained for a period of at least five years
Identify and assess risks in the supply chain:
The SORs and countries of origin listed by suppliers were matched against a database of verified SORs and associated mines. Verified SORs were matched against available lists of processors that have been certified by internationally-recognized industry validation schemes, such as the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program.
If the SOR was not certified by an internationally-recognized organization, research was conducted to gain more information about the SOR’s sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes the SOR had taken to track the chain-of-custody on the source of its mineral ores.
Based on the smelter lists provided by suppliers via the CMRTs and the CFSI-provided SOR sourcing information, the Company is aware that, in their supply chain, there are twenty-three smelters sourcing from the Covered Countries that are certified conflict-free and a number of other smelters sourcing from other countries that are not disclosed at this time but are also certified conflict free smelters. Many of the responses provided by suppliers are at the company or division level indicating they are still unable to provide SORs specific to the materials supplied to Donaldson.
In accordance with OECD Guidelines, it is important to understand risk levels associated with Conflict Minerals in the supply chain. Smelter risk is classified as High, Medium and Low; this Risk rating is generated based on three scoring criteria: Regulated Body, Proximity, and Certification.
Additionally, suppliers are evaluated on program strength, which further assists in identifying risk in the supply chain. At this stage in Conflict Minerals compliance it is well-known that many companies are in the middle of the process and do not have many answers beyond “unknown”. It has been decided that penalizing or failing them for working through the process is likely not the best approach for the initial years of compliance, it does not meet the goals or spirit of the Rule, however evaluating and tracking the strength of the program does meet the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses.
Design and implement a strategy to respond to identified risks:
The Company, in conjunction with a third-party vendor, identified, assessed, and responded to risks in the supply chain. The status of this process is reported on a regular basis to the Company’s senior management.
The Company worked with its third-party vendor to help improve the quality of the information provided to the Company by its supply chain and to help strengthen its Conflict Minerals programs through education and direct support. Where SOR risks were identified the actions taken were consistent with the Company’s Conflict Minerals policy.
Carry out independent third-party audit of smelter/refiners’ due diligence practices:
The Company does not have any direct relationship with SORs and does not perform or direct audits on SORs identified by our supply chain. Instead Donaldson relies on third-party audits performed by an internationally-recognized validation organization. Donaldson is a member of CFSI and therefore has access to CFSI’s audit program.
Report annually on supply chain due diligence:
The Form Specialized Disclosure (“Form SD”) and CMR are contained herein and are publicly available at https://ir.donaldson.com/financial-information/sec-filings/default.aspx
The Company believes that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the Conflict Minerals in our Covered Products.
| 6. | Steps to Improve Due Diligence |
The Company will endeavor to improve upon its supply chain due diligence efforts through the following efforts:
| · | Continue to assess the presence of Conflict Minerals in its supply chain |
| · | Communicate expectations with regard to supplier performance, transparency, and sourcing |
| · | Continue to compare RCOI results to the most currently available information collected via independent conflict free smelter validation programs such as the EICC-GeSI Conflict Free Smelter program |
Appendix A – Smelter List
| Metal | Standard Smelter Name | Smelter ID |
| Gold | Advanced Chemical Company | CID000015 |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 |
| Gold | Aktyubinsk Copper Company TOO | CID000028 |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | CID000058 |
| Gold | Argor-Heraeus SA | CID000077 |
| Gold | Asahi Pretec Corporation | CID000082 |
| Gold | Asahi Refining Canada Limited | CID000924 |
| Gold | Asahi Refining USA Inc. | CID000920 |
| Gold | Asaka Riken Co., Ltd. | CID000090 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 |
| Gold | Aurubis AG | CID000113 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 |
| Gold | Bauer Walser AG | CID000141 |
| Gold | Boliden AB | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | CID000176 |
| Gold | Caridad | CID000180 |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 |
| Gold | Cendres + Métaux SA | CID000189 |
| Gold | Chimet S.p.A. | CID000233 |
| Gold | Chugai Mining | CID000264 |
| Gold | Daejin Indus Co., Ltd. | CID000328 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 |
| Gold | Do Sung Corporation | CID000359 |
| Gold | DODUCO GmbH | CID000362 |
| Gold | Dowa | CID000401 |
| Gold | Eco-System Recycling Co., Ltd. | CID000425 |
| Gold | Elemetal Refining, LLC | CID001322 |
| Gold | Emirates Gold DMCC | CID002561 |
| Gold | Faggi Enrico S.p.A. | CID002355 |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CID000522 |
| Gold | Geib Refining Corporation | CID002459 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 |
| Gold | Guangdong Jinding Gold Limited | CID002312 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 |
| Gold | Heimerle + Meule GmbH | CID000694 |
| Gold | Heraeus Ltd. Hong Kong | CID000707 |
| Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 |
| Gold | Hwasung CJ Co., Ltd. | CID000778 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 |
| Gold | Istanbul Gold Refinery | CID000814 |
| Gold | Japan Mint | CID000823 |
| Gold | Jiangxi Copper Company Limited | CID000855 |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 |
| Gold | JSC Uralelectromed | CID000929 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 |
| Gold | Kaloti Precious Metals | CID002563 |
| Gold | Kazakhmys Smelting LLC | CID000956 |
| Gold | Kazzinc | CID000957 |
| Gold | Kennecott Utah Copper LLC | CID000969 |
| Gold | KGHM Polska Miedź Spółka Akcyjna | CID002511 |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 |
| Gold | Korea Metal Co., Ltd. | CID000988 |
| Gold | Korea Zinc Co. Ltd. | CID002605 |
| Gold | Kyrgyzaltyn JSC | CID001029 |
| Gold | L’ azurde Company For Jewelry | CID001032 |
| Gold | Lingbao Gold Company Limited | CID001056 |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 |
| Gold | LS-NIKKO Copper Inc. | CID001078 |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 |
| Gold | Materion | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 |
| Gold | Metahub Industries Sdn. Bhd. | CID002821 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 |
| Gold | Metalor Technologies SA | CID001153 |
| Gold | Metalor USA Refining Corporation | CID001157 |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | CID001161 |
| Gold | Mitsubishi Materials Corporation | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 |
| Gold | Morris and Watson | CID002282 |
| Gold | Moscow Special Alloys Processing Plant | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 |
| Gold | Nihon Material Co., Ltd. | CID001259 |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | CID001326 |
| Gold | OJSC Kolyma Refinery | CID001328 |
| Gold | OJSC Novosibirsk Refinery | CID000493 |
| Gold | PAMP SA | CID001352 |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 |
| Gold | PX Précinox SA | CID001498 |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 |
| Gold | Republic Metals Corporation | CID002510 |
| Gold | Royal Canadian Mint | CID001534 |
| Gold | Sabin Metal Corp. | CID001546 |
| Gold | Samduck Precious Metals | CID001555 |
| Gold | SAMWON Metals Corp. | CID001562 |
| Gold | SAXONIA Edelmetalle GmbH | CID002777 |
| Gold | Schone Edelmetaal B.V. | CID001573 |
| Gold | SEMPSA Joyería Platería SA | CID001585 |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 |
| Gold | Singway Technology Co., Ltd. | CID002516 |
| Gold | So Accurate Group, Inc. | CID001754 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | CID001761 |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 |
| Gold | T.C.A S.p.A | CID002580 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 |
| Gold | Torecom | CID001955 |
| Gold | Umicore Brasil Ltda. | CID001977 |
| Gold | Umicore Precious Metals Thailand | CID002314 |
| Gold | Umicore SA Business Unit Precious Metals Refining | CID001980 |
| Gold | United Precious Metal Refining, Inc. | CID001993 |
| Gold | Valcambi SA | CID002003 |
| Gold | Western Australian Mint trading as The Perth Mint | CID002030 |
| Gold | WIELAND Edelmetalle GmbH | CID002778 |
| Gold | Yamamoto Precious Metal Co., Ltd. | CID002100 |
| Gold | Yokohama Metal Co., Ltd. | CID002129 |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CID002243 |
| Tantalum | Avon Specialty Metals Ltd | CID002705 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CID000291 |
| Tantalum | D Block Metals, LLC | CID002504 |
| Tantalum | Duoluoshan | CID000410 |
| Tantalum | Exotech Inc. | CID000456 |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 |
| Tantalum | Global Advanced Metals Aizu | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | CID002557 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CID002501 |
| Tantalum | H.C. Starck Co., Ltd. | CID002544 |
| Tantalum | H.C. Starck GmbH Goslar | CID002545 |
| Tantalum | H.C. Starck GmbH Laufenburg | CID002546 |
| Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 |
| Tantalum | H.C. Starck Inc. | CID002548 |
| Tantalum | H.C. Starck Ltd. | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | CID002550 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 |
| Tantalum | Hi-Temp Specialty Metals, Inc. | CID000731 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 |
| Tantalum | KEMET Blue Metals | CID002539 |
| Tantalum | KEMET Blue Powder | CID002568 |
| Tantalum | King-Tan Tantalum Industry Ltd. | CID000973 |
| Tantalum | LSM Brasil S.A. | CID001076 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 |
| Tantalum | Mineração Taboca S.A. | CID001175 |
| Tantalum | Mitsui Mining & Smelting | CID001192 |
| Tantalum | Molycorp Silmet A.S. | CID001200 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 |
| Tantalum | Plansee SE Liezen | CID002540 |
| Tantalum | Plansee SE Reutte | CID002556 |
| Tantalum | QuantumClean | CID001508 |
| Tantalum | Resind Indústria e Comércio Ltda. | CID002707 |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CID001522 |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 |
| Tantalum | Taki Chemicals | CID001869 |
| Tantalum | Telex Metals | CID001891 |
| Tantalum | Tranzact, Inc. | CID002571 |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CID002307 |
| Tantalum | Zhuzhou Cemented Carbide | CID002232 |
| Tin | Alpha | CID000292 |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 |
| Tin | Chenzhou Yun Xiang mining limited liability company | CID000228 |
| Tin | China Tin Group Co., Ltd. | CID001070 |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CID000278 |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | CID000295 |
| Tin | CV Ayi Jaya | CID002570 |
| Tin | CV Dua Sekawan | CID002592 |
| Tin | CV Gita Pesona | CID000306 |
| Tin | CV Serumpun Sebalai | CID000313 |
| Tin | CV United Smelting | CID000315 |
| Tin | CV Venus Inti Perkasa | CID002455 |
| Tin | Dowa | CID000402 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 |
| Tin | Elmet S.L.U. (Metallo Group) | CID002774 |
| Tin | EM Vinto | CID000438 |
| Tin | Estanho de Rondônia S.A. | CID000448 |
| Tin | Feinhütte Halsbrücke GmbH | CID000466 |
| Tin | Fenix Metals | CID000468 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CID000244 |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CID001063 |
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | CID002468 |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 |
| Tin | Melt Metais e Ligas S/A | CID002500 |
| Tin | Metahub Industries Sdn. Bhd. | CID001136 |
| Tin | Metallic Resources, Inc. | CID001142 |
| Tin | Metallo-Chimique N.V. | CID002773 |
| Tin | Mineração Taboca S.A. | CID001173 |
| Tin | Minsur | CID001182 |
| Tin | Mitsubishi Materials Corporation | CID001191 |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CID001231 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 |
| Tin | Operaciones Metalurgical S.A. | CID001337 |
| Tin | Phoenix Metal Ltd. | CID002507 |
| Tin | PT Alam Lestari Kencana | CID001393 |
| Tin | PT Aries Kencana Sejahtera | CID000309 |
| Tin | PT Artha Cipta Langgeng | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 |
| Tin | PT Babel Inti Perkasa | CID001402 |
| Tin | PT Bangka Kudai Tin | CID001409 |
| Tin | PT Bangka Prima Tin | CID002776 |
| Tin | PT Bangka Timah Utama Sejahtera | CID001416 |
| Tin | PT Bangka Tin Industry | CID001419 |
| Tin | PT Belitung Industri Sejahtera | CID001421 |
| Tin | PT BilliTin Makmur Lestari | CID001424 |
| Tin | PT Bukit Timah | CID001428 |
| Tin | PT Cipta Persada Mulia | CID002696 |
| Tin | PT DS Jaya Abadi | CID001434 |
| Tin | PT Eunindo Usaha Mandiri | CID001438 |
| Tin | PT Fang Di MulTindo | CID001442 |
| Tin | PT Inti Stania Prima | CID002530 |
| Tin | PT Justindo | CID000307 |
| Tin | PT Karimun Mining | CID001448 |
| Tin | PT Mitra Stania Prima | CID001453 |
| Tin | PT Panca Mega Persada | CID001457 |
| Tin | PT Pelat Timah Nusantara Tbk | CID001486 |
| Tin | PT Prima Timah Utama | CID001458 |
| Tin | PT Refined Bangka Tin | CID001460 |
| Tin | PT Sariwiguna Binasentosa | CID001463 |
| Tin | PT Seirama Tin Investment | CID001466 |
| Tin | PT Stanindo Inti Perkasa | CID001468 |
| Tin | PT Sukses Inti Makmur | CID002816 |
| Tin | PT Sumber Jaya Indah | CID001471 |
| Tin | PT Timah (Persero) Tbk Kundur | CID001477 |
| Tin | PT Timah (Persero) Tbk Mentok | CID001482 |
| Tin | PT Tinindo Inter Nusa | CID001490 |
| Tin | PT Tirus Putra Mandiri | CID002478 |
| Tin | PT Tommy Utama | CID001493 |
| Tin | PT Wahana Perkit Jaya | CID002479 |
| Tin | Resind Indústria e Comércio Ltda. | CID002706 |
| Tin | Rui Da Hung | CID001539 |
| Tin | Soft Metais Ltda. | CID001758 |
| Tin | Thaisarco | CID001898 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 |
| Tin | VQB Mineral and Trading Group JSC | CID002015 |
| Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 |
| Tin | Yunnan Tin Group (Holding) Company Limited | CID002180 |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | CID000004 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CID002518 |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CID000345 |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CID000499 |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CID002531 |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CID000868 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CID002536 |
| Tungsten | Global Tungsten & Powders Corp. | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 |
| Tungsten | H.C. Starck GmbH | CID002541 |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | CID002542 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CID002578 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 |
| Tungsten | Hydrometallurg, JSC | CID002649 |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CID002647 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 |
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CID002313 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CID002535 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 |
| Tungsten | Kennametal Fallon | CID000966 |
| Tungsten | Kennametal Huntsville | CID000105 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 |
| Tungsten | Niagara Refining LLC | CID002589 |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CID002543 |
| Tungsten | Pobedit, JSC | CID002532 |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | CID002538 |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | CID002011 |
| Tungsten | Wolfram Bergbau und Hütten AG | CID002044 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 |
Appendix B – Countries of Origin
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chili, China, Colombia, Cote D’lvoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States of America, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
