Exhibit 1.01
Kimberly-Clark Corporation
Conflict Minerals Report
for the Year Ended December 31, 2022
This Conflict Minerals Report of Kimberly-Clark Corporation has been prepared for the period from January 1, 2022 to December 31, 2022. Unless the context indicates otherwise, “Kimberly-Clark,” “we,” “us” and “our” refer to Kimberly-Clark Corporation and its consolidated subsidiaries.
During 2022, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs (as defined below) are necessary to their functionality or production (“Covered Products”). The term “3TGs” refers to columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten. The vast majority of our products do not contain 3TGs and our revenue from sales of Covered Products in 2022 was immaterial relative to our total net sales. In 2022, we manufactured or contracted for manufacture Covered Products primarily through our K-C Professional business. We have no reason to believe that any of the Covered Products are in our consumer businesses, which include our Personal Care and Consumer Tissue operating segments.
Electronic components account for a significant majority of any 3TGs present in our Covered Products. Electronic components commonly contain 3TGs for a variety of reasons (for example tin is usually present in solder). The Covered Products include dispensers (e.g., for hand sanitizers, soaps and paper products) which contain electronic sensors and actuators.
We have developed a conflict minerals compliance program reasonably designed to identify whether the 3TGs in our Covered Products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia) (collectively, the “Covered Countries”), or whether any of the 3TGs in our Covered Products are from recycled or scrap sources. Our conflict minerals compliance program is overseen by an internal team of subject matter experts from key functions (“Core Team”).
Description of Our Reasonable Country of Origin Inquiry
We have conducted a reasonable country of origin inquiry (“RCOI”) that was designed to determine whether any of the 3TGs in our Covered Products originated from one of the Covered Countries or was from recycled or scrap sources.
In conducting our RCOI, we used a risk-based approach. First, we identified our product materials which contain or potentially contain 3TGs necessary to their functionality or production. Second, we identified the direct suppliers of the materials, components and finished goods supplied to us for those products. Third, we risk-stratified each supplier’s “materials risk” based on the likelihood that the product materials they supply to us contain 3TGs. Fourth, we conducted a supply chain survey of our direct suppliers to provide information on the origin of any 3TGs contained in materials supplied to us in our Covered Products, including sources of 3TGs supplied to these direct suppliers from second-tier suppliers, as well as suppliers further upstream.
Our survey included those suppliers rated with a materials risk of high risk and medium risk. We have determined that it is not necessary to survey our low risk and very low risk rated suppliers, based on a sampling program we conducted in past
years in which we surveyed certain of these suppliers. This sampling program allowed us to confirm that the materials associated with our low risk and very low risk suppliers do not contain 3TGs.
Our supply chain survey employed the Conflict Minerals Reporting Template (the “CMRT”) version 6.3 developed by the Responsible Minerals Initiative of the Responsible Business Alliance (“RMI”). The CMRT was developed to facilitate general disclosures and information regarding smelters and refiners that provide materials to the supplier. It includes questions regarding the supplier’s conflict-free minerals policy, the engagement process with its direct suppliers and identification of the smelters and refiners used by the supplier.
As of May 20, 2023, approximately 90% of our direct suppliers included in the supply chain survey have responded with a completed CMRT or acceptable declaration, including all of our high risk suppliers. We compared the list of smelters and refiners provided in our suppliers’ responses to the lists maintained by the RMI and, if a supplier indicated that a facility was certified as conformant, confirmed that the facility was listed on the RMI’s list of smelters or refiners that are conformant with the Responsible Minerals Assurance Process (“RMAP”) assessment protocols. For suppliers that are not listed as RMAP conformant we check their status under other internationally recognized programs such as the London Bullion Market Association Good Delivery program (“LBMA”) and the Responsible Jewelery Council Chain-of-Custody Certification program (“RJC”). Two suppliers indicated that their supply chains may include the same single smelter that potentially could be sourcing from the Covered Countries; however, we have validated in the due diligence process described below that this smelter has been certified as RMAP conformant. Many of the supplier responses were unable to specify all smelters or refiners used for materials supplied to us. Furthermore, many of the responses were provided at the company or division level, rather than the product level, and therefore, their list of smelters and refiners cannot be definitively linked to the products they provided to us.
Due Diligence Process
Following our RCOI, we conducted a due diligence review of the source and chain of custody of the 3TGs contained in our Covered Products. Our due diligence measures were designed to conform in all material respects with the 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.
Management Systems and Controls
Internal Team
We have a centralized, cross-functional conflict minerals Core Team to oversee the implementation and daily administration of the program, which includes geographically diverse representation from the following departments: Procurement; Legal; and Environmental, Health, Safety & Sustainability. The Core Team periodically reports to senior management on program developments and progress. Our Senior Vice President and Chief Supply Chain Officer serves as the executive sponsor of the Conflict Minerals Compliance program.
Control Systems
We address 3TGs sourced from the Covered Countries in our Supplier Social Compliance Standards and our Supplier Stewardship Standards, which are embedded in our Purchase Order Terms and Conditions and certain of our supplier agreements, as well as posted in the Company/SupplierLINK/Standards and Requirements section of our corporate website at: http://www.kimberly-clark.com.
Our suppliers are required to source responsibly and adhere to our Supplier Social Compliance Standards, which require suppliers to source 3TGs from smelters and refiners who source outside of the Covered Countries or that are designated as “conformant” by the RMI. We engage independent third-party audit firms to conduct Supplier Social Compliance audits (on-site inspections) of suppliers of certain commodity categories, particularly contract manufacturers. If an assessment reveals that the supplier is in violation of our Supplier Social Compliance Standards, we require that the supplier submit documentation showing that violations have been addressed and remediated. We conduct additional follow-up audits at our discretion to confirm compliance with our Supplier Social Compliance Standards. Any concerns regarding suppliers or our compliance program can be reported to our Corporate Social Compliance team as specified on our Corporate Social Compliance website. During 2022, we conducted 284 supplier audits covering 238 suppliers.
Supplier Engagement
We rely on our direct (tier one) suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us - including sources of 3TGs that are supplied to them from upstream suppliers.
In addition, we conduct periodic in-house training of our Procurement function to educate employees to identify 3TGs in products and to work more closely with our suppliers to encourage responsible sourcing.
Grievance Mechanism
We maintain a comprehensive and multi-faceted system for the reporting of Code of Conduct violations, concerns and grievances. To ensure that every employee (and every stakeholder) has the ability to report concerns on an anonymous basis, we have established a Code of Conduct telephone helpline which is staffed by a professional independent company. This line is available 24 hours a day, 365 days a year, and one can give a report in any language. Our Code of Conduct, as well as the reporting process and helpline contact information, is available on our external website.
Calls are investigated by various internal subject matter experts in our Compliance, Internal Audit, Global Security, Human Resources and Legal departments. We report summary results and statistics to our executive leadership and our Board of Directors as deemed appropriate.
Maintenance of Records
We have adopted a policy to retain relevant documentation for a minimum of five years.
Identify and Assess Risk in the Supply Chain
As part of our due diligence process, we reviewed our suppliers’ responses to the supply chain survey against criteria developed to determine which responses required further engagement. These criteria included untimely or incomplete responses, as well as inconsistencies within the reported data.
Certain of the responses to the surveys included the names of facilities listed by the suppliers as smelters or refiners. We compared each facility listed in the responses to the lists of smelters and refiners maintained by the RMI to verify the existence of the facility and to determine whether the facility is certified as conformant with the RMAP assessment protocols
We classify each listed smelter or refiner as high, medium or low risk based on three scoring criteria: geographic proximity to the Covered Countries, Conflict-Free Sourcing Program audit status and known or plausible evidence of unethical or conflict sourcing. Based on these criteria, we have identified no facilities as being high risk. When a supplier reports a high risk facility on a CMRT, we initiate risk mitigation activities. When CMRT
responses include any high or medium risk facilities, we request the supplier to provide a product-specific CMRT to better identify any connection between the subject facilities and the products supplied to us.
If any smelter or refiner is not recognized by the RMI, we conduct outreach and research to gain more information about whether they are a smelter or a refiner, sourcing practices, location, and country of origin. Additionally, if any smelter is not certified conformant, we conduct outreach providing education on the Conflict-Free Smelter Program and encourage them to join this program.
Design and Implement a Strategy to Respond to Identified Risks
We have developed a risk management plan that includes the following elements:
•Communication directly with our suppliers of our conflict minerals requirements under our Supplier Social Compliance Standards, as described above.
•Communication with suppliers who do not satisfy our due diligence requests to obtain more complete and accurate responses.
•Additional follow up, due diligence, and/or risk mitigation activities, as appropriate, upon learning of changes in supplier circumstances or information.
Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not typically have a direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain.
Report Annually on Supply Chain Due Diligence
We report annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC.
Due Diligence Results
Attachment A lists the 224 legitimate smelters and refiners that the suppliers we surveyed reported as being in their supply chains and indicates which of these smelters and refiners have been certified as RMAP Conformant. The majority of the responses received either provided data at a company or divisional level or did not specify the smelters or refiners used for materials supplied to us. We are therefore unable to determine whether the smelters or refiners reported by certain suppliers processed the 3TGs in the materials supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. Attachment B contains an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and publicly by the RMI.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products with the greatest possible specificity, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners using the RMI list, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
This Report has not been audited, nor is an independent private sector audit required for this Report.
Risk Mitigation and Due Diligence Improvement
We have taken or intend to take the following steps to further mitigate the risk that the 3TGs in our Covered Products could benefit armed groups in the Covered Countries:
•Continue to review the refinement and expansion of the RMI list of smelters and refiners to validate the smelters and refiners provided by suppliers.
•Provide continuing education of the Core Team and stakeholders on their on-going responsibilities with respect to conflict minerals compliance and any legislative or organizational developments.
•Encourage suppliers that provided company or division level information for 2022 to provide product level information for 2023 through ongoing communications with these suppliers.
•Maintain a global supplier screening program that requires our suppliers to provide information regarding 3TGs and requires each new in-scope direct supplier we add to our supply chain to provide a completed CMRT.
Attachment A
2022 Facility List
The following lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains and indicates which of these smelters and refiners have been certified as conformant by RMI or are recognized by LBMA and/or RJC.
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | RMI Conformance Level or LMBA/ RJC COP or CoC “RECOGNIZED” |
| Gold | | Advanced Chemical Company | | UNITED STATES | | UNKNOWN |
| Gold | | Aida Chemical Industries Co., Ltd. | | JAPAN | | CONFORMANT |
| Gold | | Agosi AG | | GERMANY | | RECOGNIZED |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | UZBEKISTAN | | RECOGNIZED |
| Gold | | AngloGold Ashanti Corrego do Sitio Mineracao | | BRAZIL | | RECOGNIZED |
| Gold | | Argor-Heraeus S.A. | | SWITZERLAND | | RECOGNIZED |
| Gold | | Asahi Pretec Corp. | | JAPAN | | RECOGNIZED |
| Gold | | Asaka Riken Co., Ltd. | | JAPAN | | CONFORMANT |
| Gold | | Aurubis AG | | GERMANY | | RECOGNIZED |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | PHILIPPINES | | RECOGNIZED |
| Gold | | Boliden AB | | SWEDEN | | RECOGNIZED |
| Gold | | C. Hafner GmbH + Co. KG | | GERMANY | | RECOGNIZED |
| Gold | | CCR Refinery - Glencore Canada Corporation | | CANADA | | RECOGNIZED |
| Gold | | Chimet S.p.A. | | ITALY | | RECOGNIZED |
| Gold | | DSC (Do Sung Corporation) | | SOUTH KOREA | | CONFORMANT |
| Gold | | Dowa | | JAPAN | | CONFORMANT |
| Gold | | Eco-System Recycling Co., Ltd. East Plant | | JAPAN | | CONFORMANT |
| Gold | | LT Metal Ltd. | | SOUTH KOREA | | CONFORMANT |
| Gold | | Heimerle + Meule GmbH | | GERMANY | | RECOGNIZED |
| Gold | | Heraeus Metals Hong Kong Ltd. | | CHINA | | RECOGNIZED |
| Gold | | Heraeus Germany GmbH Co. KG | | GERMANY | | CONFORMANT |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | CHINA | | RECOGNIZED |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | JAPAN | | RECOGNIZED |
| Gold | | Istanbul Gold Refinery | | TURKEY | | RECOGNIZED |
| Gold | | Japan Mint | | JAPAN | | RECOGNIZED |
| Gold | | Jiangxi Copper Co., Ltd. | | CHINA | | RECOGNIZED |
| Gold | | Asahi Refining USA Inc. | | UNITED STATES | | RECOGNIZED |
| Gold | | Asahi Refining Canada Ltd. | | CANADA | | RECOGNIZED |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | JAPAN | | RECOGNIZED |
| Gold | | Kazzinc | | KAZAKHSTAN | | RECOGNIZED |
| Gold | | Kennecott Utah Copper LLC | | UNITED STATES | | RECOGNIZED |
| Gold | | Kojima Chemicals Co., Ltd. | | JAPAN | | CONFORMANT |
| Gold | | LS-NIKKO Copper Inc. | | SOUTH KOREA | | RECOGNIZED |
| Gold | | Materion | | UNITED STATES | | CONFORMANT |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | RMI Conformance Level or LMBA/ RJC COP or CoC “RECOGNIZED” |
| Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN | | RECOGNIZED |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | CHINA | | RECOGNIZED |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | CHINA | | RECOGNIZED |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | SINGAPORE | | RECOGNIZED |
| Gold | | Metalor Technologies S.A. | | SWITZERLAND | | RECOGNIZED |
| Gold | | Metalor USA Refining Corporation | | UNITED STATES | | RECOGNIZED |
| Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | MEXICO | | RECOGNIZED |
| Gold | | Mitsubishi Materials Corporation | | JAPAN | | RECOGNIZED |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN | | RECOGNIZED |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.S. | | TURKEY | | RECOGNIZED |
| Gold | | Nihon Material Co., Ltd. | | JAPAN | | RECOGNIZED |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | JAPAN | | CONFORMANT |
| Gold | | PAMP S.A. | | SWITZERLAND | | RECOGNIZED |
| Gold | | PT Aneka Tambang (Persero) Tbk | | INDONESIA | | RECOGNIZED |
| Gold | | PX Precinox S.A. | | SWITZERLAND | | RECOGNIZED |
| Gold | | Rand Refinery (Pty) Ltd. | | SOUTH AFRICA | | RECOGNIZED |
| Gold | | Royal Canadian Mint | | CANADA | | RECOGNIZED |
| Gold | | SEMPSA Joyeria Plateria S.A. | | SPAIN | | RECOGNIZED |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | CHINA | | RECOGNIZED |
| Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | CHINA | | RECOGNIZED |
| Gold | | Solar Applied Materials Technology Corp. | | TAIWAN | | RECOGNIZED |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | JAPAN | | RECOGNIZED |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | JAPAN | | RECOGNIZED |
| Gold | | The Refinery of Shandong Gold Mining Co., Ltd. | | CHINA | | RECOGNIZED |
| Gold | | Tokuriki Honten Co., Ltd. | | JAPAN | | RECOGNIZED |
| Gold | | Torecom | | SOUTH KOREA | | CONFORMANT |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | BELGIUM | | RECOGNIZED |
| Gold | | United Precious Metal Refining, Inc. | | UNITED STATES | | CONFORMANT |
| Gold | | Valcambi S.A. | | SWITZERLAND | | RECOGNIZED |
| Gold | | Western Australian Mint (T/a The Perth Mint) | | AUSTRALIA | | RECOGNIZED |
| Gold | | Yamakin Co., Ltd. | | JAPAN | | CONFORMANT |
| Gold | | Yokohama Metal Co., Ltd. | | JAPAN | | CONFORMANT |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | CHINA | | RECOGNIZED |
| Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | CHINA | | RECOGNIZED |
| Gold | | Guangdong Jinding Gold Limited | | CHINA | | UNKNOWN |
| Gold | | Geib Refining Corporation | | UNITED STATES | | CONFORMANT |
| Gold | | MMTC-PAMP India Pvt., Ltd. | | INDIA | | RECOGNIZED |
| Gold | | KGHM Polska Miedz Spolka Akcyjna | | POLAND | | RECOGNIZED |
| Gold | | Al Etihad Gold Refinery DMCC | | UNITED ARAB EMIRATES | | RECOGNIZED |
| Gold | | Emirates Gold DMCC | | UNITED ARAB EMIRATES | | CONFORMANT |
| Gold | | T.C.A S.p.A | | ITALY | | RECOGNIZED |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | RMI Conformance Level or LMBA/ RJC COP or CoC “RECOGNIZED” |
| Gold | | REMONDIS PMR B.V. | | NETHERLANDS | | CONFORMANT |
| Gold | | Korea Zinc Co., Ltd. | | SOUTH KOREA | | CONFORMANT |
| Gold | | TOO Tau-Ken-Altyn | | KAZAKHSTAN | | RECOGNIZED |
| Gold | | Abington Reldan Metals, LLC | | UNITED STATES | | CONFORMANT |
| Gold | | SAAMP | | FRANCE | | RECOGNIZED |
| Gold | | L'Orfebre S.A. | | ANDORRA | | CONFORMANT |
| Gold | | Italpreziosi | | ITALY | | RECOGNIZED |
| Gold | | WIELAND Edelmetalle GmbH | | GERMANY | | RECOGNIZED |
| Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | AUSTRIA | | RECOGNIZED |
| Gold | | Bangalore Refinery | | INDIA | | CONFORMANT |
| Gold | | SungEel HiMetal Co., Ltd. | | SOUTH KOREA | | CONFORMANT |
| Gold | | Planta Recuperadora de Metales SpA | | CHILE | | CONFORMANT |
| Gold | | NH Recytech Company | | SOUTH KOREA | | CONFORMANT |
| Gold | | Eco-System Recycling Co., Ltd. North Plant | | JAPAN | | CONFORMANT |
| Gold | | Eco-System Recycling Co., Ltd. West Plant | | JAPAN | | CONFORMANT |
| Gold | | Metal Concentrators SA (Pty) Ltd. | | SOUTH AFRICA | | RECOGNIZED |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA | | UNKNOWN |
| Tantalum | | Exotech Inc. | | UNITED STATES | | UNKNOWN |
| Tantalum | | F&X Electro-Materials Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | XIMEI RESOURCES (GUANGDONG) LIMITED | | CHINA | | UNKNOWN |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | AMG Brasil | | BRAZIL | | UNKNOWN |
| 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 | | NPM Silmet AS | | ESTONIA | | CONFORMANT |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | QuantumClean | | UNITED STATES | | CONFORMANT |
| Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | Taki Chemical Co., Ltd. | | JAPAN | | CONFORMANT |
| Tantalum | | Telex Metals | | UNITED STATES | | CONFORMANT |
| Tantalum | | Ulba Metallurgical Plant JSC | | KAZAKHSTAN | | CONFORMANT |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | D Block Metals, LLC | | UNITED STATES | | CONFORMANT |
| Tantalum | | FIR Metals & Resource Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | CHINA | | CONFORMANT |
| Tantalum | | KEMET de Mexico | | MEXICO | | CONFORMANT |
| Tantalum | | TANIOBIS Co., Ltd. | | THAILAND | | CONFORMANT |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | RMI Conformance Level or LMBA/ RJC COP or CoC “RECOGNIZED” |
| Tantalum | | TANIOBIS GmbH | | GERMANY | | CONFORMANT |
| Tantalum | | H.C. Starck Hermsdorf GmbH | | GERMANY | | CONFORMANT |
| Tantalum | | H.C. Starck Inc. | | UNITED STATES | | CONFORMANT |
| Tantalum | | TANIOBIS Japan Co., Ltd. | | JAPAN | | CONFORMANT |
| Tantalum | | TANIOBIS Smelting GmbH & Co. KG | | GERMANY | | CONFORMANT |
| Tantalum | | Global Advanced Metals Boyertown | | UNITED STATES | | CONFORMANT |
| Tantalum | | Global Advanced Metals Aizu | | JAPAN | | CONFORMANT |
| Tantalum | | Resind Industria e Comercio Ltda. | | BRAZIL | | CONFORMANT |
| Tantalum | | Jiangxi Tuohong New Raw Material | | CHINA | | CONFORMANT |
| Tantalum | | RFH Yancheng Jinye New Material Technology Co., Ltd. | | CHINA | | CONFORMANT |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CHINA | | CONFORMANT |
| Tin | | Alpha | | UNITED STATES | | CONFORMANT |
| Tin | | PT Aries Kencana Sejahtera | | INDONESIA | | CONFORMANT |
| Tin | | Dowa | | JAPAN | | CONFORMANT |
| Tin | | EM Vinto | | BOLIVIA | | CONFORMANT |
| Tin | | Estanho de Rondonia S.A. | | BRAZIL | | CONFORMANT |
| Tin | | Fenix Metals | | POLAND | | CONFORMANT |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | CHINA | | CONFORMANT |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | CHINA | | UNKNOWN |
| Tin | | China Tin Group Co., Ltd. | | CHINA | | CONFORMANT |
| Tin | | Malaysia Smelting Corporation (MSC) | | MALAYSIA | | CONFORMANT |
| Tin | | Metallic Resources, Inc. | | UNITED STATES | | CONFORMANT |
| Tin | | Mineracao Taboca S.A. | | BRAZIL | | CONFORMANT |
| Tin | | Minsur | | PERU | | CONFORMANT |
| Tin | | Mitsubishi Materials Corporation | | JAPAN | | CONFORMANT |
| Tin | | Jiangxi New Nanshan Technology Ltd. | | CHINA | | CONFORMANT |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND | | CONFORMANT |
| Tin | | Operaciones Metalurgicas S.A. | | BOLIVIA | | CONFORMANT |
| Tin | | PT Artha Cipta Langgeng | | INDONESIA | | CONFORMANT |
| Tin | | PT Babel Inti Perkasa | | INDONESIA | | CONFORMANT |
| Tin | | PT Babel Surya Alam Lestari | | INDONESIA | | CONFORMANT |
| Tin | | PT Bukit Timah | | INDONESIA | | CONFORMANT |
| Tin | | PT Mitra Stania Prima | | INDONESIA | | CONFORMANT |
| Tin | | PT Prima Timah Utama | | INDONESIA | | CONFORMANT |
| Tin | | PT Refined Bangka Tin | | INDONESIA | | CONFORMANT |
| Tin | | PT Sariwiguna Binasentosa | | INDONESIA | | CONFORMANT |
| Tin | | PT Stanindo Inti Perkasa | | INDONESIA | | CONFORMANT |
| Tin | | PT Timah Tbk Kundur | | INDONESIA | | CONFORMANT |
| Tin | | PT Timah Tbk Mentok | | INDONESIA | | CONFORMANT |
| Tin | | PT Tinindo Inter Nusa | | INDONESIA | | UNKNOWN |
| Tin | | PT Tommy Utama | | INDONESIA | | CONFORMANT |
| Tin | | Rui Da Hung | | TAIWAN | | CONFORMANT |
| Tin | | Thaisarco | | THAILAND | | CONFORMANT |
| | | | | | | | | | | | | | | | | | | | |
| Metal | | Standard Smelter Name | | Smelter Facility Location | | RMI Conformance Level or LMBA/ RJC COP or CoC “RECOGNIZED” |
| Tin | | White Solder Metalurgia e Mineracao Ltda. | | BRAZIL | | CONFORMANT |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | CHINA | | CONFORMANT |
| Tin | | Yunnan Tin Company Limited | | CHINA | | CONFORMANT |
| Tin | | CV Venus Inti Perkasa | | INDONESIA | | CONFORMANT |
| Tin | | Magnu's Minerais Metais e Ligas Ltda. | | BRAZIL | | CONFORMANT |
| Tin | | PT ATD Makmur Mandiri Jaya | | INDONESIA | | CONFORMANT |
| Tin | | O.M. Manufacturing Philippines, Inc. | | PHILIPPINES | | CONFORMANT |
| Tin | | CV Ayi Jaya | | INDONESIA | | CONFORMANT |
| Tin | | PT Rajehan Ariq | | INDONESIA | | CONFORMANT |
| Tin | | PT Cipta Persada Mulia | | INDONESIA | | CONFORMANT |
| Tin | | Resind Industria e Comercio Ltda. | | BRAZIL | | CONFORMANT |
| Tin | | Metallo Belgium N.V. | | BELGIUM | | CONFORMANT |
| Tin | | Metallo Spain S.L.U. | | SPAIN | | CONFORMANT |
| Tin | | PT Bangka Prima Tin | | INDONESIA | | CONFORMANT |
| Tin | | PT Sukses Inti Makmur | | INDONESIA | | CONFORMANT |
| Tin | | Thai Nguyen Mining and Metallurgy Co., Ltd. | | VIETNAM | | CONFORMANT |
| Tin | | PT Menara Cipta Mulia | | INDONESIA | | CONFORMANT |
| Tin | | HuiChang Hill Tin Industry Co., Ltd. | | CHINA | | CONFORMANT |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | China | | CONFORMANT |
| Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | CHINA | | CONFORMANT |
| Tin | | PT Bangka Serumpun | | INDONESIA | | CONFORMANT |
| Tin | | Tin Technology & Refining | | UNITED STATES | | CONFORMANT |
| Tin | | Ma'anshan Weitai Tin Co., Ltd. | | CHINA | | CONFORMANT |
| Tin | | PT Rajawali Rimba Perkasa | | INDONESIA | | CONFORMANT |
| Tin | | Luna Smelter, Ltd. | | RWANDA | | CONFORMANT |
| Tin | | PT Mitra Sukses Globalindo | | INDONESIA | | CONFORMANT |
| Tin | | CRM Synergies | | SPAIN | | CONFORMANT |
| Tin | | Fabrica Auricchio Industria e Comercio Ltda. | | BRAZIL | | CONFORMANT |
| Tin | | PT Putera Sarana Shakti (PT PSS) | | INDONESIA | | CONFORMANT |
| Tungsten | | A.L.M.T. Corp. | | JAPAN | | CONFORMANT |
| Tungsten | | Kennametal Huntsville | | UNITED STATES | | CONFORMANT |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES | | CONFORMANT |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | CHINA | | UNKNOWN |
| Tungsten | | Japan New Metals Co., Ltd. | | JAPAN | | CONFORMANT |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Kennametal Fallon | | UNITED STATES | | CONFORMANT |
| Tungsten | | Wolfram Bergbau und Hutten AG | | AUSTRIA | | CONFORMANT |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA | | CONFORMANT |
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| Metal | | Standard Smelter Name | | Smelter Facility Location | | RMI Conformance Level or LMBA/ RJC COP or CoC “RECOGNIZED” |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Asia Tungsten Products Vietnam Ltd. | | VIETNAM | | CONFORMANT |
| Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | H.C. Starck Tungsten GmbH | | GERMANY | | CONFORMANT |
| Tungsten | | TANIOBIS Smelting GmbH & Co. KG | | GERMANY | | CONFORMANT |
| Tungsten | | Masan High-Tech Materials | | VIETNAM | | CONFORMANT |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Niagara Refining LLC | | UNITED STATES | | CONFORMANT |
| Tungsten | | China Molybdenum Tungsten Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | PHILIPPINES | | CONFORMANT |
| Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | ACL Metais Eireli | | BRAZIL | | UNKNOWN |
| Tungsten | | KGETS Co., Ltd. | | SOUTH KOREA | | CONFORMANT |
| Tungsten | | Fujian Ganmin RareMetal Co., Ltd. | | CHINA | | CONFORMANT |
| Tungsten | | Lianyou Metals Co., Ltd. | | TAIWAN | | CONFORMANT |
| Tungsten | | Cronimet Brasil Ltda | | BRAZIL | | CONFORMANT |
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Attachment B
2022 Countries of Origin
The following lists the countries of origin from which the reported facilities in Attachment A collectively source conflict minerals based on information provided by our suppliers and the RMI.
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| ANDORRA | | INDIA | | SOUTH AFRICA |
| AUSTRALIA | | INDONESIA | | SOUTH KOREA |
| AUSTRIA | | ITALY | | SPAIN |
| BELGIUM | | JAPAN | | SWEDEN |
| BOLIVIA | | KAZAKHSTAN | | SWITZERLAND |
| BRAZIL | | MALAYSIA | | TAIWAN |
| CANADA | | MEXICO | | THAILAND |
| CHILE | | NETHERLANDS | | TURKEY |
| CHINA | | PERU | | UNITED ARAB EMIRATES |
| ESTONIA | | PHILIPPINES | | UNITED STATES |
| FRANCE | | POLAND | | UZBEKISTAN |
| GERMANY | | RWANDA | | VIETNAM |
| GHANA | | SINGAPORE | | |
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