Exhibit 1.01
GRACO INC.
Conflict Minerals Report
For the reporting period from January 1, 2018 to December 31, 2018
This is the Conflict Minerals Report (“Report”) of Graco Inc. (“Graco,” “we,” “our” or “us”) for the 2018 calendar year, pursuant to Rule 13p-1 of the Securities Exchange Act of 1934 (the “Rule”). Certain capitalized terms used but not defined herein have the meanings assigned to them in the Rule. This Report includes the activities of all subsidiaries of Graco that were required to be consolidated during the reporting period, other than any acquired companies that are not yet required by the Rule to be included in this Report.
The Rule requires certain SEC reporting companies that manufacture or contract to be manufactured products for which tantalum, tin, tungsten or gold (“3TG”) are necessary to the functionality or production of such products to disclose annually whether any of the 3TG in such products originated in the Democratic Republic of the Congo or one of its adjoining countries (collectively, the “Covered Countries”). If the company knows that the 3TG necessary to its products originated in the Covered Countries, or has reason to believe that the 3TG may have originated in the Covered Countries and did not or may not have come from scrap or recycled sources, the company must exercise due diligence on the source and chain of custody of the 3TG and prepare and file a Report describing its due diligence measures.
Graco Overview
Graco is a multi-national manufacturer of systems and equipment that move, measure, control, dispense and spray fluid and powder materials. Our systems and equipment are used in the manufacturing, processing, construction and maintenance industries. Our primary products include air, electric, gas and hydraulic pumps and sprayers; electronic and mechanical controls and sensors; and automatic and manual dispense valves, meters and spray guns. Our products that contain control boards, certain other electronic components, motors, engines, batteries, spray tips, and certain pumps and valves contain 3TG.
Company Management Systems
We have established management systems to support the execution of our Conflict Minerals program and to ensure it operates effectively and is sustainable into the future. Our management systems include the following:
Conflict Minerals Policy
We have adopted a policy affirming our commitment to conducting business fairly and ethically with respect for human rights and in compliance with all applicable laws and regulations, including the Rule. Our policy also affirms our support for the responsible sourcing of 3TG through our global supply chain, and states that we are actively and diligently working with our global supply chain partners to determine the
origin of any 3TG they may supply to us, and that we will continue to work with them towards the goal of providing greater supply chain transparency and responsible sourcing. Our policy is available on our website at http://www.graco.com/us/en/about-graco/conflict-minerals.html.
Internal Team
We have assembled a cross-functional team with executive-level sponsorship and support to implement and oversee our Conflict Minerals compliance program. The cross-functional team includes employees from functional groups such as procurement, finance, operations, legal and information systems. We report our Conflict Minerals findings to our team and designated members of senior management.
Control Systems
Graco is a member of the Responsible Minerals Initiative (RMI) and has participated in the National Association of Manufacturers Conflict Minerals Working Group, the Manufacturers Alliance for Productivity and Innovation Conflict Minerals Forum and the Twin Cities Conflict Minerals Task Force. We also retain a third party service provider to assist with collecting, evaluating and retaining supply chain information, identifying potential supply chain risks, and developing and implementing additional engagement steps with suppliers.
Supplier Engagement
We have a process in place to engage relevant first-tier suppliers to educate them about the Rule and request information from them regarding 3TG. We also have a process in place to improve the number and quality of supplier responses year over year. To help ensure suppliers understand the Rule and how to properly respond to requests for information from us regarding 3TG, we provide our suppliers access to on-line Conflict Minerals training courses. We track and monitor completion of these courses and continue to prioritize education in our Conflict Minerals program. We also respond to supplier inquiries during the information gathering process and take steps to address supplier issues that arise during that process.
Grievance Mechanism
We have an established grievance mechanism through which employees, suppliers, customers and other interested parties may communicate their concerns to us.
Records Management
We have a process in place to collect, analyze and retain Conflict Minerals information received from our suppliers. We will maintain records relating to Conflict Minerals supply chain due diligence in accordance with our records retention policy, which provides for retention of such records for five years.
Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. As a member of the RMI, we support the RMI’s efforts to carry out independent third-party audits of smelter and refiner due diligence activities and contribute to the improvement of smelter and refiner and upstream due diligence practices.
Report on Supply Chain Due Diligence
Graco has filed a Form SD and this Report with the Securities Exchange Commission. The filing is available on our website at http://www.graco.com/us/en/about-graco/conflict-minerals.html.
Reasonable Country of Origin Inquiry
Supply Chain
We do not directly source 3TG. Instead, we purchase components and raw materials from third party suppliers that are multiple layers removed from the smelters and refiners of the 3TG that are in the components and raw materials ultimately supplied to us. We evaluated our products and determined that certain products manufactured during calendar year 2018 were manufactured with components and raw materials that contain or likely contain 3TG that are necessary to the functionality or production of those products. We then identified the first-tier suppliers of those components and raw materials.
Request for Information
We use a third-party software solution to automate our reasonable country of origin inquiry (“RCOI”) process and improve the quality and efficiency of our Conflict Minerals compliance program. With this software solution, we surveyed all of our in-scope first-tier suppliers using the RBA-GeSI Conflict Minerals Reporting Template (CMRT) (version 5.11 or higher) developed by the Responsible Business Alliance (RBA) and the Global e-Sustainability Initiative (GeSI). We also provided these suppliers with a list of components and raw materials they supply to us, background information on the Rule, and access to on-line Conflict Minerals training courses to help educate them on the Rule and to aid them in responding to the survey.
Survey Responses
All submitted CMRTs were reviewed and classified as valid or invalid. We tracked supplier responses and identified instances where suppliers submitted an invalid response (due to missing information or inconsistencies across responses) or did not provide us with a timely response, and followed up with those suppliers and requested that they submit a valid CMRT. As of May 22, 2019, there was a small percentage of invalid supplier CMRTs that were not corrected.
We compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters and refiners maintained by the RMI and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict-free smelters and refiners of the 3TG in question. Our suppliers identified a total of 324 smelters and refiners that appear on the lists maintained by RMI. Of these 324 smelters and refiners, 257 are validated as conflict-free by RMI, and, based on information provided by RMI, a further 6 have agreed to undergo or are currently undergoing a third-party audit. Most of the CMRTs we received were completed on a company or division level, which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TG contained in our products.
Identification and Assessment of Risk
Risks are identified based on criteria established for supplier responses in the CMRT. Risks are addressed by contacting the supplier, gathering pertinent information, and performing an assessment of the supplier’s Conflict Minerals status. The primary risk identified related to the nature of responses received. Many suppliers provided information at a company or division level, or were unable to specify the smelters or refiners used for the 3TG in the components and raw materials supplied to us. Additionally, many suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they were unable to provide a complete list of all smelters and refiners in their supply chains.
Smelters and refiners that are not certified as conflict-free also pose a risk. When a CMRT is received, the smelters and refiners that are reported are examined. Each facility that meets the RMI definition of a smelter or refiner of 3TG is assigned a risk level based on: (i) geographic proximity to the Covered Countries; (ii) known mineral source country of origin; (iii) RMI Responsible Minerals Assurance Process (RMAP) audit status; (iv) credible evidence of unethical or conflict sourcing; and (v) peer assessments conducted by credible third-party sources. When certain high-risk facilities are reported, risk mitigation activities are initiated, including sending an automated reply instructing the supplier to take risk mitigation actions, including submission of a product-specific CMRT to better identify the connection to components and raw materials supplied to us.
In addition, suppliers are evaluated on the strength of their Conflict Minerals programs based on whether: (i) they have a conflict minerals sourcing policy; (ii) they have implemented due diligence measures for conflict-free sourcing; (iii) they review information received from their suppliers against their own expectations; and (iv) their review process includes corrective action management. We evaluate and track the strength of their programs so we can make risk mitigation decisions as their programs progress.
Through our membership with the RMI, we encourage smelters and refiners to participate in the RMAP. Any smelters and refiners that were reported by our suppliers that were not part of the RMAP were also contacted directly to encourage them to participate in the RMAP.
Design of Due Diligence Measures
Our due diligence measures have been designed to be in conformity, in all material respects, with the applicable provisions of the internationally recognized framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, and the related supplements on 3TG.
Due Diligence Measures Performed
The due diligence measures we performed include defining roles and responsibilities for our cross-functional Conflict Minerals team and designated members of senior management; reporting our Conflict Minerals findings to our cross-functional Conflict Minerals team and designated members of senior management; and comparing the smelter and refiner information received from our suppliers against the RMI list of smelters and refiners that are conformant with the RMAP assessment protocols, the RMI list of smelters and refiners that have committed to undergo a RMAP audit, and the RMI reference list of known smelters and refiners. With respect to smelters and refiners that were on the RMI list of known smelters and refiners and certain other smelters and refiners that were not on the RMI list of known smelters and refiners, we reviewed certain other publicly available sources of information.
Due Diligence Results
A majority of suppliers surveyed responded to the survey. The majority of those who responded provided data at a company or division level rather than at a product or supplier-defined level, and reported that their products do not contain 3TG or, if they do, the 3TG in their products does not come from the Covered Countries. A number of suppliers reported that they do not know whether the 3TG in their products comes from the Covered Countries or from scrap or recycled sources. A small number of suppliers reported that the 3TG in their products comes from or may come from the Covered Countries, and some of these suppliers further reported that some of the 3TG in their products comes from scrap or recycled sources.
Our suppliers identified over 1,500 entities in their supply chains as part of their smelter and refiner lists. However, not all of the entities identified by these suppliers appear to be actual smelters or refiners as the total number of entities identified exceeds the number of entities on the RMI list of known smelters and refiners. In addition, not all of the actual smelters and refiners identified by our suppliers may have processed the 3TG in the components and raw materials supplied to us. In some cases, our suppliers may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in information received from their suppliers or for other reasons.
Schedule 1 to this Report contains a list of legitimate smelters and refiners identified by our suppliers, and whose materials and components may or may not be in our products, including the status of each smelter and refiner as of May 22, 2019. (Schedule 1 excludes any smelters and refiners identified by our suppliers that do not appear on the RMI list of known smelters and refiners.) 257 of the smelters and refiners identified by our suppliers have been deemed conformant with the RMAP assessment protocols by an independent
third party auditor according to the RMI list of conformant smelters and refiners. 6 of the smelters and refiners identified by our suppliers have not yet been deemed conformant but have committed to undergo a RMAP audit according to the RMI list of smelters and refiners who have committed to undergo a RMAP audit. 55 of the smelters and refiners identified by our suppliers have not been deemed conformant and have not begun participating in an independent third party audit program. 6 of the smelters and refiners identified by our suppliers have failed a RMAP audit, refused to participate in the RMAP assessment process, or have failed to provide adequate access to their facilities to complete the RMAP assessment process. Schedule 2 to this Report includes an aggregate list of the countries of origin from which the smelters and refiners identified by our suppliers collectively source 3TG, based on information provided by the RMI.
Given that the majority of suppliers who responded to the survey provided their responses at a company or division level rather than at a level specific to the materials and components they supplied to us, we were unable to determine which, if any, of the smelters and refiners listed in their responses were the actual source of the 3TG they supplied.
Determination
Given that a number of suppliers did not respond to our survey, the majority of responses we received were provided at a company or division level or other level not specific to the components and raw materials supplied to us, and that a number of suppliers do not know the origin of the 3TG in their products, we do not have sufficient information to determine the origin of the 3TG in our products subject to this Report, whether the 3TG came from scrap or recycled sources, the specific facilities used to process the 3TG, or the country of origin or the mine or location of origin of the 3TG.
Steps to be Taken to Mitigate Risk in 2019
We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TG in our products finance or benefit armed groups in the Covered Countries:
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| • | Continue to engage with our direct suppliers to increase the response rate to our survey and improve the content and quality of their responses; and |
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| • | Continue to engage with our direct suppliers to receive more information farther upstream regarding the source and chain of custody of the 3TG in the components and raw materials they supply to us. |
Schedule 1
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| Metal | | Standard Smelter or Refiner Name | | Facility Location (Country) | | Smelter or Refiner Status* |
| Gold | | 8853 S.p.A. | | Italy | | Conformant |
| Gold | | Abington Reldan Metals, LLC | | United States | | Non Conformant |
| Gold | | Advanced Chemical Company | | United States | | Conformant |
| Gold | | African Gold Refinery | | Uganda | | Not Enrolled |
| Gold | | Aida Chemical Industries Co., Ltd. | | Japan | | Conformant |
| Gold | | Al Etihad Gold LLC | | United Arab Emirates | | Conformant |
| Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | Germany | | Conformant |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | Uzbekistan | | Conformant |
| Gold | | AngloGold Ashanti Córrego do Sítio Mineração | | Brazil | | Conformant |
| Gold | | Argor-Heraeus S.A. | | Switzerland | | Conformant |
| Gold | | Asahi Pretec Corp. | | Japan | | Conformant |
| Gold | | Asahi Refining Canada Ltd. | | Canada | | Conformant |
| Gold | | Asahi Refining USA Inc. | | United States | | Conformant |
| Gold | | Asaka Riken Co., Ltd. | | Japan | | Conformant |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | Turkey | | Not Enrolled |
| Gold | | AU Traders and Refiners | | South Africa | | Conformant |
| Gold | | Aurubis AG | | Germany | | Conformant |
| Gold | | Bangalore Refinery | | India | | Conformant |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | Philippines | | Conformant |
| Gold | | Boliden AB | | Sweden | | Conformant |
| Gold | | C. Hafner GmbH + Co. KG | | Germany | | Conformant |
| Gold | | Caridad | | Mexico | | Not Enrolled |
| Gold | | CCR Refinery - Glencore Canada Corporation | | Canada | | Conformant |
| Gold | | Cendres + Métaux S.A. | | Switzerland | | Conformant |
| Gold | | CGR Metalloys Pvt Ltd. | | India | | Not Enrolled |
| Gold | | Chimet S.p.A. | | Italy | | Conformant |
| Gold | | Chugai Mining | | Japan | | Active |
| Gold | | Daejin Indus Co., Ltd | | Republic of Korea | | Conformant |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | | China | | Not Enrolled |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | | Germany | | Not Enrolled |
| Gold | | Dijllah Gold Refinery FZC | | United Arab Emirates | | Not Enrolled |
| Gold | | DODUCO Contacts and Refining GmbH | | Germany | | Conformant |
| Gold | | Dowa | | Japan | | Conformant |
| Gold | | DS PRETECH Co., Ltd. | | Republic of Korea | | Conformant |
| Gold | | DSC (Do Sung Corporation) | | Republic of Korea | | Conformant |
| Gold | | Eco-System Recycling Co., Ltd. | | Japan | | Conformant |
| Gold | | Emirates Gold DMCC | | United Arab Emirates | | Conformant |
| Gold | | Fidelity Printers and Refiners Ltd. | | Zimbabwe | | Not Enrolled |
| Gold | | Fujairah Gold FZE | | United Arab Emirates | | Not Enrolled |
| Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | | India | | Not Enrolled |
| Gold | | Geib Refining Corporation | | United States | | Conformant |
| Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | China | | Conformant |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | | China | | Not Enrolled |
| Gold | | Guangdong Jinding Gold Limited | | China | | Not Enrolled |
| Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | China | | Not Enrolled |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | China | | Not Enrolled |
| Gold | | HeeSung | | Republic of Korea | | Conformant |
| Gold | | Heimerle + Meule GmbH | | Germany | | Conformant |
| Gold | | Heraeus Metals Hong Kong Ltd. | | China | | Conformant |
| Gold | | Heraeus Precious Metals GmbH & Co. KG | | Germany | | Conformant |
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| Gold | | Hunan Chenzhou Mining Co., Ltd. | | China | | Not Enrolled |
| Gold | | Hunan Guiyang Yinxing Nonferrous Smelting Co., Ltd. | | China | | Not Enrolled |
| Gold | | Hwasung CJ Co., Ltd. | | Republic of Korea | | Not Enrolled |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | China | | Conformant |
| Gold | | International Precious Metal Refiners | | United Arab Emirates | | Not Enrolled |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | Japan | | Conformant |
| Gold | | Istanbul Gold Refinery | | Turkey | | Conformant |
| Gold | | Italpreziosi | | Italy | | Conformant |
| Gold | | Japan Mint | | Japan | | Conformant |
| Gold | | Jiangxi Copper Co., Ltd. | | China | | Conformant |
| Gold | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | Russian Federation | | Conformant |
| Gold | | JSC Uralelectromed | | Russian Federation | | Conformant |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | Japan | | Conformant |
| Gold | | Kaloti Precious Metals | | United Arab Emirates | | Not Enrolled |
| Gold | | Kazakhmys Smelting LLC | | Kazakhstan | | Not Enrolled |
| Gold | | Kazzinc | | Kazakhstan | | Conformant |
| Gold | | Kennecott Utah Copper LLC | | United States | | Conformant |
| Gold | | KGHM Polska Miedz Spolka Akcyjna | | Poland | | Active |
| Gold | | Kojima Chemicals Co., Ltd. | | Japan | | Conformant |
| Gold | | Korea Zinc Co., Ltd. | | Republic of Korea | | Conformant |
| Gold | | Kyrgyzaltyn JSC | | Kyrgyzstan | | Conformant |
| Gold | | Kyshtym Copper-Electrolytic Plant ZAO | | Russian Federation | | Not Enrolled |
| Gold | | L’azurde Company For Jewelry | | Saudi Arabia | | Not Enrolled |
| Gold | | Lingbao Gold Co., Ltd. | | China | | Not Enrolled |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | China | | Not Enrolled |
| Gold | | L’Orfebre S.A. | | Andorra | | Conformant |
| Gold | | LS-NIKKO Copper Inc. | | Republic of Korea | | Conformant |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | China | | Not Enrolled |
| Gold | | Marsam Metals | | Brazil | | Conformant |
| Gold | | Materion | | United States | | Conformant |
| Gold | | Matsuda Sangyo Co., Ltd. | | Japan | | Conformant |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | China | | Conformant |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | Singapore | | Conformant |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | China | | Conformant |
| Gold | | Metalor Technologies S.A. | | Switzerland | | Conformant |
| Gold | | Metalor USA Refining Corporation | | United States | | Conformant |
| Gold | | Metalúrgica Met-Mex Peñoles S.A. De C.V. | | Mexico | | Conformant |
| Gold | | Mitsubishi Materials Corporation | | Japan | | Conformant |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | Japan | | Conformant |
| Gold | | MMTC-PAMP India Pvt., Ltd. | | India | | Conformant |
| Gold | | Modeltech Sdn Bhd | | Malaysia | | Non Conformant |
| Gold | | Morris and Watson | | New Zealand | | Not Enrolled |
| Gold | | Morris and Watson Gold Coast | | Australia | | Not Enrolled |
| Gold | | Moscow Special Alloys Processing Plant | | Russian Federation | | Conformant |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.ª. | | Turkey | | Conformant |
| Gold | | Navoi Mining and Metallurgical Combinat | | Uzbekistan | | Not Enrolled |
| Gold | | NH Recytech Company | | Republic of Korea | | Active |
| Gold | | Nihon Material Co., Ltd. | | Japan | | Conformant |
| Gold | | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | | Austria | | Conformant |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | Japan | | Conformant |
| Gold | | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | | Russian Federation | | Conformant |
| Gold | | OJSC Novosibirsk Refinery | | Russian Federation | | Conformant |
| Gold | | PAMP S.A. | | Switzerland | | Conformant |
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| Gold | | Pease & Curren | | United States | | Not Enrolled |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | China | | Not Enrolled |
| Gold | | Planta Recuperadora de Metales SpA | | Chile | | Conformant |
| Gold | | Prioksky Plant of Non-Ferrous Metals | | Russian Federation | | Conformant |
| Gold | | PT Aneka Tambang (Persero) Tbk | | Indonesia | | Conformant |
| Gold | | PX Précinox S.A. | | Switzerland | | Conformant |
| Gold | | QG Refining, LLC | | United States | | Not Enrolled |
| Gold | | Rand Refinery (Pty) Ltd. | | South Africa | | Conformant |
| Gold | | Refinery of Seemine Gold Co., Ltd. | | China | | Not Enrolled |
| Gold | | Remondis Argentia B.V. | | Netherlands | | Conformant |
| Gold | | Republic Metals Corporation | | United States | | Conformant |
| Gold | | Royal Canadian Mint | | Canada | | Conformant |
| Gold | | SAAMP | | France | | Conformant |
| Gold | | Sabin Metal Corp. | | United States | | Not Enrolled |
| Gold | | Safimet S.p.A | | Italy | | Conformant |
| Gold | | SAFINA A.S. | | Czech Republic | | Not Enrolled |
| Gold | | Sai Refinery | | India | | Not Enrolled |
| Gold | | Samduck Precious Metals | | Republic of Korea | | Non Conformant |
| Gold | | SAMWON Metals Corp. | | Republic of Korea | | Not Enrolled |
| Gold | | SAXONIA Edelmetalle GmbH | | Germany | | Conformant |
| Gold | | SEMPSA Joyería Platería S.A. | | Spain | | Conformant |
| Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | China | | Not Enrolled |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | China | | Conformant |
| Gold | | Shangdong Humon Smelting Co., Ltd. | | China | | Not Enrolled |
| Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | China | | Conformant |
| Gold | | Singway Technology Co., Ltd. | | Taiwan | | Conformant |
| Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | Russian Federation | | Conformant |
| Gold | | Solar Applied Materials Technology Corp. | | Taiwan | | Conformant |
| Gold | | Sovereign Metals | | India | | Not Enrolled |
| Gold | | State Research Institute Center for Physical Sciences and Technology | | Lithuania | | Not Enrolled |
| Gold | | Sudan Gold Refinery | | Sudan | | Not Enrolled |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | Japan | | Conformant |
| Gold | | SungEel HiTech | | Republic of Korea | | Conformant |
| Gold | | T.C.A S.p.A | | Italy | | Conformant |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | Japan | | Conformant |
| Gold | | The Refinery of Shandong Gold Mining Co., Ltd. | | China | | Conformant |
| Gold | | Tokuriki Honten Co., Ltd. | | Japan | | Conformant |
| Gold | | Tongling Nonferrous Metals Group Co., Ltd. | | China | | Not Enrolled |
| Gold | | Tony Goetz NV | | Belgium | | Non Conformant |
| Gold | | TOO Tau-Ken-Altyn | | Kazakhstan | | Not Enrolled |
| Gold | | Torecom | | Republic of Korea | | Conformant |
| Gold | | Umicore Brasil Ltda. | | Brazil | | Conformant |
| Gold | | Umicore Precious Metals Thailand | | Thailand | | Conformant |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | Belgium | | Conformant |
| Gold | | United Precious Metal Refining, Inc. | | United States | | Conformant |
| Gold | | Universal Precious Metals Refining Zambia | | Zambia | | Not Enrolled |
| Gold | | Valcambi S.A. | | Switzerland | | Conformant |
| Gold | | Western Australian Mint trading as The Perth Mint | | Australia | | Conformant |
| Gold | | WIELAND Edelmetalle GmbH | | Germany | | Conformant |
| Gold | | Yamamoto Precious Metal Co., Ltd. | | Japan | | Conformant |
| Gold | | Yokohama Metal Co., Ltd. | | Japan | | Conformant |
| Gold | | Yunnan Copper Industry Co., Ltd. | | China | | Not Enrolled |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | China | | Conformant |
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| Tantalum | | Asaka Riken Co., Ltd. | | Japan | | Conformant |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | China | | Conformant |
| Tantalum | | CP Metals Inc. | | United States | | Active |
| Tantalum | | D Block Metals, LLC | | United States | | Conformant |
| Tantalum | | Exotech Inc. | | United States | | Conformant |
| Tantalum | | F&X Electro-Materials Ltd. | | China | | Conformant |
| Tantalum | | FIR Metals & Resource Ltd. | | China | | Conformant |
| Tantalum | | Global Advanced Metals Aizu | | Japan | | Conformant |
| Tantalum | | Global Advanced Metals Boyertown | | United States | | Conformant |
| Tantalum | | Guangdong Rising Rare Metals-EO Materials Ltd. | | China | | Conformant |
| Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | China | | Conformant |
| Tantalum | | H.C. Starck Co., Ltd. | | Thailand | | Conformant |
| Tantalum | | H.C. Starck Hermsdorf GmbH | | Germany | | Conformant |
| Tantalum | | H.C. Starck Inc. | | United States | | Conformant |
| Tantalum | | H.C. Starck Ltd. | | Japan | | Conformant |
| Tantalum | | H.C. Starck Smelting GmbH & Co. KG | | Germany | | Conformant |
| Tantalum | | H.C. Starck Tantalum and Niobium GmbH | | Germany | | Conformant |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | China | | Conformant |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | China | | Conformant |
| Tantalum | | Jiangxi Tuohong New Raw Material | | China | | Conformant |
| Tantalum | | Jiujiang Janny New Material Co., Ltd. | | China | | Conformant |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | China | | Conformant |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | China | | Conformant |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | China | | Conformant |
| Tantalum | | KEMET Blue Metals | | Mexico | | Conformant |
| Tantalum | | KEMET Blue Powder | | United States | | Conformant |
| Tantalum | | LSM Brasil S.A. | | Brazil | | Conformant |
| Tantalum | | Metallurgical Products India Pvt., Ltd. | | India | | Conformant |
| Tantalum | | Mineracao Taboca S.A. | | Brazil | | Conformant |
| Tantalum | | Mitsui Mining and Smelting Co., Ltd. | | Japan | | Conformant |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | China | | Conformant |
| Tantalum | | NPM Silmet AS | | Estonia | | Conformant |
| Tantalum | | Power Resources Ltd. | | Macedonia | | Conformant |
| Tantalum | | QuantumClean | | United States | | Conformant |
| Tantalum | | Resind Industria e Comercio Ltda. | | Brazil | | Conformant |
| Tantalum | | RFH Tantalum Smeltry Co., Ltd. | | China | | Conformant |
| Tantalum | | Solikamsk Magnesium Works OAO | | Russian Federation | | Conformant |
| Tantalum | | Taki Chemicals | | Japan | | Conformant |
| Tantalum | | Telex Metals | | United States | | Conformant |
| Tantalum | | Ulba Metallurgical Plant JSC | | Kazakhstan | | Conformant |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | China | | Conformant |
| Tin | | Alpha | | United States | | Conformant |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | Vietnam | | Not Enrolled |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | China | | Conformant |
| Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | China | | Conformant |
| Tin | | China Tin Group Co., Ltd. | | China | | Conformant |
| Tin | | CV Ayi Jaya | | Indonesia | | Conformant |
| Tin | | CV Dua Sekawan | | Indonesia | | Conformant |
| Tin | | CV Gita Pesona | | Indonesia | | Conformant |
| Tin | | CV Tiga Sekawan | | Indonesia | | Conformant |
| Tin | | CV United Smelting | | Indonesia | | Conformant |
| Tin | | CV Venus Inti Perkasa | | Indonesia | | Conformant |
| Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | | China | | Active |
| Tin | | Dowa | | Japan | | Conformant |
|
| | | | | | |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | Vietnam | | Non Conformant |
| Tin | | EM Vinto | | Bolivia | | Conformant |
| Tin | | Estanho de Rondônia S.A. | | Brazil | | Not Enrolled |
| Tin | | Fenix Metals | | Poland | | Conformant |
| Tin | | Gejiu Fengming Metallurgy Chemical Plant | | China | | Conformant |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | China | | Conformant |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | China | | Conformant |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | China | | Conformant |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | China | | Conformant |
| Tin | | Guangdong Hanhe Non-ferrous Metal Limited Company | | China | | Conformant |
| Tin | | Guanyang Guida Nonferrous Metal Smelting Plant | | China | | Conformant |
| Tin | | HuiChang Hill Tin Industry Co., Ltd. | | China | | Conformant |
| Tin | | Huichang Jinshunda Tin Co., Ltd. | | China | | Conformant |
| Tin | | Jiangxi New Nanshan Technology Ltd. | | China | | Conformant |
| Tin | | Magnu’s Minerais Metais e Ligas Ltda. | | Brazil | | Conformant |
| Tin | | Malaysia Smelting Corporation (MSC) | | Malaysia | | Conformant |
| Tin | | Melt Metais e Ligas S.A. | | Brazil | | Conformant |
| Tin | | Metallic Resources, Inc. | | United States | | Conformant |
| Tin | | Metallo Belgium N.V. | | Belgium | | Conformant |
| Tin | | Metallo Spain S.L.U. | | Spain | | Conformant |
| Tin | | Mineracao Taboca S.A. | | Brazil | | Conformant |
| Tin | | Minsur | | Peru | | Conformant |
| Tin | | Mitsubishi Materials Corporation | | Japan | | Conformant |
| Tin | | Modeltech Sdn Bhd | | Malaysia | | Conformant |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | Vietnam | | Not Enrolled |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | Thailand | | Conformant |
| Tin | | O.M. Manufacturing Philippines, Inc. | | Philippines | | Conformant |
| Tin | | Operaciones Metalurgical S.A. | | Bolivia | | Conformant |
| Tin | | Pongpipat Company Limited | | Myanmar | | Not Enrolled |
| Tin | | PT Aries Kencana Sejahtera | | Indonesia | | Conformant |
| Tin | | PT Artha Cipta Langgeng | | Indonesia | | Conformant |
| Tin | | PT ATD Makmur Mandiri Jaya | | Indonesia | | Conformant |
| Tin | | PT Babel Inti Perkasa | | Indonesia | | Conformant |
| Tin | | PT Babel Surya Alam Lestari | | Indonesia | | Conformant |
| Tin | | PT Bangka Prima Tin | | Indonesia | | Conformant |
| Tin | | PT Bangka Serumpun | | Indonesia | | Conformant |
| Tin | | PT Bangka Tin Industry | | Indonesia | | Conformant |
| Tin | | PT Belitung Industri Sejahtera | | Indonesia | | Conformant |
| Tin | | PT Bukit Timah | | Indonesia | | Conformant |
| Tin | | PT DS Jaya Abadi | | Indonesia | | Conformant |
| Tin | | PT Inti Stania Prima | | Indonesia | | Conformant |
| Tin | | PT Kijang Jaya Mandiri | | Indonesia | | Conformant |
| Tin | | PT Menara Cipta Mulia | | Indonesia | | Conformant |
| Tin | | PT Mitra Stania Prima | | Indonesia | | Conformant |
| Tin | | PT Panca Mega Persada | | Indonesia | | Conformant |
| Tin | | PT Premium Tin Indonesia | | Indonesia | | Conformant |
| Tin | | PT Prima Timah Utama | | Indonesia | | Conformant |
| Tin | | PT Rajawali Rimba Perkasa | | Indonesia | | Conformant |
| Tin | | PT Refined Bangka Tin | | Indonesia | | Conformant |
| Tin | | PT Sariwiguna Binasentosa | | Indonesia | | Conformant |
| Tin | | PT Stanindo Inti Perkasa | | Indonesia | | Conformant |
| Tin | | PT Sukses Inti Makmur | | Indonesia | | Conformant |
| Tin | | PT Sumber Jaya Indah | | Indonesia | | Conformant |
|
| | | | | | |
| Tin | | PT Timah (Persero) Tbk Kundur | | Indonesia | | Conformant |
| Tin | | PT Timah (Persero) Tbk Mentok | | Indonesia | | Conformant |
| Tin | | PT Tinindo Inter Nusa | | Indonesia | | Conformant |
| Tin | | PT Tirus Putra Mandiri | | Indonesia | | Conformant |
| Tin | | PT Tommy Utama | | Indonesia | | Conformant |
| Tin | | Resind Industria e Comercio Ltda. | | Brazil | | Conformant |
| Tin | | Rui Da Hung | | Taiwan | | Conformant |
| Tin | | Soft Metais Ltda. | | Brazil | | Conformant |
| Tin | | Super Ligas | | Brazil | | Not Enrolled |
| Tin | | Thai Nguyen Mining and Metallurgy Co., Ltd. | | Vietnam | | Conformant |
| Tin | | Thaisarco | | Thailand | | Conformant |
| Tin | | Tin Technology & Refining | | United States | | Conformant |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | Vietnam | | Not Enrolled |
| Tin | | White Solder Metalurgia e Mineração Ltda. | | Brazil | | Conformant |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | China | | Conformant |
| Tin | | Yunnan Tin Company Limited | | China | | Conformant |
| Tungsten | | A.L.M.T. TUNGSTEN Corp. | | Japan | | Conformant |
| Tungsten | | ACL Metais Eireli | | Brazil | | Conformant |
| Tungsten | | Asia Tungsten Products Vietnam Ltd. | | Vietnam | | Conformant |
| Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | China | | Conformant |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | China | | Conformant |
| Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | | China | | Not Enrolled |
| Tungsten | | Fujian Jinxin Tungsten Co., Ltd. | | China | | Conformant |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | China | | Conformant |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | China | | Conformant |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | China | | Conformant |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | China | | Conformant |
| Tungsten | | Ganzhou Yatai Tungsten Co., Ltd. | | China | | Non Conformant |
| Tungsten | | Global Tungsten & Powders Corp. | | United States | | Conformant |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | China | | Conformant |
| Tungsten | | H.C. Starck Smelting GmbH & Co.KG | | Germany | | Conformant |
| Tungsten | | H.C. Starck Tungsten GmbH | | Germany | | Conformant |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | China | | Conformant |
| Tungsten | | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | | China | | Conformant |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | China | | Conformant |
| Tungsten | | Hunan Litian Tungsten Industry Co., Ltd. | | China | | Active |
| Tungsten | | Hydrometallurg, JSC | | Russian Federation | | Conformant |
| Tungsten | | Japan New Metals Co., Ltd. | | Japan | | Conformant |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | China | | Conformant |
| Tungsten | | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | | China | | Not Enrolled |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | China | | Conformant |
| Tungsten | | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | | China | | Not Enrolled |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | China | | Conformant |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | China | | Conformant |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | China | | Conformant |
| Tungsten | | Kennametal Fallon | | United States | | Conformant |
| Tungsten | | Kennametal Huntsville | | United States | | Conformant |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | China | | Conformant |
| Tungsten | | Moliren Ltd | | Russian Federation | | Conformant |
| Tungsten | | Niagara Refining LLC | | United States | | Conformant |
| Tungsten | | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | | Vietnam | | Conformant |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | Philippines | | Conformant |
| Tungsten | | South-East Nonferrous Metal Company Limited of Hengyang City | | China | | Conformant |
| Tungsten | | Tejing (Vietnam) Tungsten Co., Ltd. | | Vietnam | | Conformant |
|
| | | | | | |
| Tungsten | | Unecha Refractory metals plant | | Russian Federation | | Conformant |
| Tungsten | | Wolfram Bergbau und Hütten AG | | Austria | | Conformant |
| Tungsten | | Woltech Korea Co., Ltd. | | Republic of Korea | | Conformant |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | China | | Conformant |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | China | | Conformant |
| Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | China | | Conformant |
| Tungsten | | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | | China | | Conformant |
* “Conformant” means the smelter or refiner is included on the RMI list of smelters and refiners that are conformant with the RMAP assessment protocols and can be considered DRC conflict-free; “Active” means the smelter or refiner is included on the RMI list of smelters and refiners that have committed to undergo a RMAP assessment; “Not Enrolled” means the smelter or refiner is listed on the RMI reference list of smelters and refiners but is not Conformant and is not currently participating in a RMAP assessment; and “Non Conformant” means the smelter or refiner is listed on the RMI list of smelters and refiners and has failed a RMAP assessment, refuses to participate in the RMAP assessment process, or does not provide adequate access to facilities to complete the RMAP assessment.
Schedule 2
The following list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore it is not certain which of these countries of origin can be linked to our products.
Argentina, Armenia, Australia, Austria, Azerbaijan, Benin, Bolivia, Botswana, Brazil, Burkina Faso, Canada, Chile, China, Colombia, Cyprus, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Finland, Georgia, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Iran, Ivory Coast, Kazakhstan, Kyrgyzstan, Laos, Lebanon, Madagascar, Malaysia, Mali, Mauritania, Mauritius, Mexico, Mongolia, Morocco, Myanmar, Namibia, Nicaragua, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Portugal, Puerto Rico, Russian Federation, Saudi Arabia, Senegal, Sierra Leone, Slovakia, Solomon Islands, Spain, Suriname, Swaziland, Sweden, Taiwan, Thailand, Togo, Turkey, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Zimbabwe
