Exhibit 1.01
CONMED Corporation
Conflict Minerals Report
For The Year Ended December 31, 2017
We have made statements in this Conflict Minerals Report that may constitute forward-looking statements about our plans to take additional actions or to implement additional procedures with respect to our due diligence efforts to determine the origin of conflict minerals included in our products. There can be no assurance that these future events will occur as anticipated. Forward-looking statements speak only as of the date they were made, and we undertake no obligation to publicly update them. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report.
1. Introduction
CONMED Corporation (“CONMED”, the “Company”, “we”, “our” or “us”) is filing this Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the year ended December 31, 2017.
This Conflict Minerals Report describes our reasonable country of origin inquiry (“RCOI”), the results thereof, and the design of our due diligence measures to determine whether 3TGs in products that CONMED manufactures or contracts to manufacture originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”). The Covered Countries include Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. The term “Conflict Minerals” is defined as: columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten. For purposes of this CMR, tin, tungsten, tantalum and gold will collectively be referred to as the 3TGs. This report also provides an account of how these due diligence measures were implemented in 2017.
This report is available on our website athttp://www.conmed.com/en/about-us/investors/investor-relations in the SEC Filings section.
2. Company Overview
CONMED is a medical technology company that provides surgical devices and equipment for minimally invasive procedures. The Company’s products are used by surgeons and physicians in a variety of specialties including orthopedics, general surgery, gynecology, neurosurgery, and gastroenterology.
Products
Our product lines consist of orthopedic surgery and general surgery. Orthopedic surgery consists of sports medicine instrumentation and small bone, large bone and specialty powered surgical instruments as well as imaging systems for use in minimally invasive surgery procedures including 2DHD and 3DHD vision technologies and service fees related to the promotion and marketing of sports medicine allograft tissue. General surgery consists of a complete line of endo-mechanical instrumentation for minimally invasive laparoscopic and gastrointestinal procedures, a line of cardiac monitoring products as well as electrosurgical generators and related instruments. 3TGs are in a significant portion of CONMED products due to electronics being a vital component to many of our product offerings. All types of 3TGs may be found within various electrical components that make up CONMED products, such as capacitors, rectifiers, relays, and electrical connectors.
Conflict Minerals Policy
In addition to the measures described above, we have adopted a conflict minerals supply policy. This policy is available on our website athttp://www.conmed.com/en/about-us/investors/investor-relations in the Corporate Governance section.
3. Reasonable Country of Origin Inquiry
Because conflict minerals are necessary to the functionality or production of products that we manufacture, we are required to conduct in good faith a reasonable country of origin inquiry regarding those conflict minerals. The RCOI is reasonably designed to determine whether any of the conflict minerals originated in the DRC, or the Covered Countries, or are from recycled or scrap sources.
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Our RCOI employed a combination of measures to determine whether the 3TGs necessary for the functionality or production of CONMED products originated from the DRC or any of the Covered Countries. The Company’s primary means of determining country of origin of the necessary 3TGs was by conducting a supply chain survey with direct suppliers using the Responsible Business Alliance’s Conflict Minerals Reporting Template (“CMRT”). This supply chain survey was implemented with the assistance of a third-party service provider, which is also assisting us with the development and implementation of additional steps that we are undertaking with suppliers in regards to conflict minerals.
As an initial step, we identified all first-tier suppliers that provided items to CONMED that were used in final products in 2017. The total number of suppliers in 2017 was 1,108. This list included many suppliers that did not disclose the use of any 3TGs. Any suppliers that appeared on this initial list could be placed out of scope during the supplier survey process. For example, if they were included on the initial list in error and they did not in fact provide components or 3TG components used in our products or, as the CMRT allows, because any 3TGs in those components are unnecessary to the functionality or production of the supplier’s products, they were listed as out of scope.
The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide 3TG materials to a company’s supply chain. It includes questions regarding a supplier’s “conflict-free” policy, engagement with its direct suppliers, and a listing of the smelters used in products provided to CONMED. In addition, the template contains questions about the origin of 3TGs included in the supplier’s products, as well as supplier due diligence. To ensure our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party consultant have provided training to our suppliers through webinars, videos and substantial one-on-one discussions.
This year’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. As of May 15, 2018, we still had 19 invalid supplier submissions that were not yet corrected despite our efforts to secure responses.
Over 80% of the CONMED suppliers contacted provided a response. Non-responsive suppliers were contacted numerous times by both our third-party consultant and CONMED personnel. The majority of CMRTs provided by CONMED suppliers are at the company level and therefore cannot be definitively linked to any specific CONMED product.
On the basis of the responses to our RCOI, CONMED is unable to determine that 3TGs necessary to the functionality or production of our products did not originate in the DRC or any of the Covered Countries. Accordingly, CONMED engaged in the due diligence measures on the source and chain of custody of those 3TGs, as described in the next section of this Conflict Minerals Report.
4.0 Design of Due Diligence Measures
Our due diligence measures have been designed to conform, in all material respects, with the framework established in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold, tin, tantalum and tungsten.
4.1 Management Systems
As described above, CONMED has adopted a conflict minerals policy, which is located in the Corporate Governance section of the CONMED Corporation website (http://www.conmed.com/en/about-us/investors/investor-relations ).
Internal Team
CONMED has established a management system regarding the sourcing of 3TGs. Our management system includes both internal and external resources led by a project manager and subject matter experts at each of our manufacturing locations. This group is responsible for implementing our conflict minerals strategy. Senior management is briefed about the results of our due diligence efforts on a regular basis. We also use a third-party service provider to assist us with evaluating supply chain information regarding 3TGs and in the development and implementation of additional due diligence steps that we expect and intend to undertake with suppliers in regard to conflict minerals.
Control Systems
As we do not typically have a direct relationship with 3TG smelters and refiners, and due to our position in the supply chain and limited insight into deeper levels of the supply chain, we are engaged and actively cooperate with other major manufacturers in the medical device industry regarding 3TG sourcing matters.
With regard to our suppliers, controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all CONMED employees; our supplier approval and review process, as well as contractual protections, as described further below; and business relationships with our suppliers.
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Supply Chain Due Diligence
We obtain various component products from suppliers that we use in manufacturing our products. Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, among other reasons, it is difficult for us to identify actors upstream from our direct suppliers. As part of our supply chain procedures, we require in our supply contracts that our direct suppliers 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 all applicable lower tier suppliers. Contracts with our direct suppliers are frequently multi-year term contracts. In those cases, although we generally are unable to unilaterally impose new contract terms and flow-down requirements prior to expiration of the contract, we work individually with key selected suppliers to insure they provide 3TG sourcing information for all current contracts, and in all new contracts in the future. We have approached existing suppliers to adopt amendments regarding 3TGs, and as we renew contracts or enter into new ones, we expect to seek to add a clause that requires all applicable suppliers to provide information about the source of 3TGs and information about the smelters from which 3TGs are sourced. In light of existing contract term durations, it will take some time to ensure that all supplier contracts contain what we believe are appropriate “flow-down” clauses. In the meantime, and in parallel, all purchase orders for direct materials used in the composition of our products require that suppliers provide CONMED with Conflict Minerals information on the current Conflict Minerals Reporting Template, or CMRT (as described further below), and that components must be free of Conflict Minerals.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we use a Supplier Approval Process that evaluates our suppliers based on their quality systems and their readiness to provide CONMED all of the required services and support documents. In addition, key suppliers are evaluated on the “Supplier Report Card” as to their performance in all aspects of the supply contract. This review includes, but is not limited to: product quality, supplier performance and ensuring conflict mineral avoidance.
This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized our third-party consultant’s learning management system and provided all in-scope suppliers access to conflict minerals training courses. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within these courses.
Grievance Mechanism
Various communication channels exist to serve as grievance mechanisms for early-warning risk awareness. We have multiple longstanding grievance mechanisms whereby employees (internal) and suppliers (external) can report violations of CONMED’s policies. This includes, but is not limited to our whistleblower hotline that is part of our Code of Business Conduct and Ethics policy located in the Corporate Governance section of our website athttp://www.conmed.com/en/about-us/investors/investor-relations in the Corporate Governance section.
Maintain Records
We have adopted a policy to retain relevant documentation, including the records of our due diligence process, for a minimum period of five years.
4.2 Risk Identification, Assessment and Response
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as DRC-Conflict Free by third party sources such as the Responsible Minerals Initiative (“RMI”) pose a significant risk. Where a smelter is not identified as Conflict Free by such sources, we assess them according to red flag indicators defined in the OECD Guidance. This rating is based on various factors, including Responsible Minerals Assurance Process (RMAP) audit status, smelter’s geographic location and including proximity to the Covered Countries and credible evidence of unethical or conflict sourcing.
We calculate supplier risk based on the chances that a supplier provides 3TGs that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:
| · | Have you established a conflict minerals sourcing policy? |
| · | Have you implemented due diligence measures for conflict-free sourcing? |
| · | Do you review due diligence information received from your suppliers against your company’s expectations? |
| · | Does your review process include corrective action management? |
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When suppliers answer yes, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
As part of our risk management plan and to ensure suppliers understand our expectations, we have, through a third party, provided video and written training on conflict minerals and the CMRT. This includes instructions on completing the form, and one-on-one email and phone discussions with supplier personnel.
As described in our Conflict Minerals Policy, we engage any of our suppliers whom we have reason to believe are supplying us with 3TGs from sources that may support conflict in the DRC or any of the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we will then take steps to terminate a contract and find replacement suppliers.
Additionally, in designing and implementing our strategy to respond to the supply chain risks that we identified, CONMED analyzed various industry approaches and consulted with other companies in our industry.
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TGs in our supply chain. This was done by adopting methodology outlined by the RMI’s joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this joint industry effort, we made reasonable determinations of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict Free” lists of sourced metals.
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. This includes: (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 with the expanding RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
4.3 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We support independent third-party audits through our participation in the RMI. 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.
4.4 Report Annually on Supply Chain Due Diligence
CONMED reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC. CONMED’s Form SD and Conflict Minerals Report can be found in the SEC Filings section of the CONMED site athttp://www.conmed.com/en/about-us/investors/investor-relations.
5. Due Diligence Results
As described above, as part of our supply chain due diligence process, we identified suppliers likely to utilize 3TGs in the products that they provide to us. We utilized the CMRT to facilitate disclosure and communication of information regarding smelters that provide 3TGs used in products supplied to us by those suppliers for incorporation into our products.
The quality of the responses that we received from our surveyed suppliers also continue to be varied. Many responses provided by suppliers (via the CMRT) included the names of facilities listed by the suppliers as smelters or refiners. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our third-party provider follows up on these, urging suppliers to resubmit with increased smelter information. There are still suppliers unable to provide the smelters or refiners used for materials supplied to us.
For all responses that indicated a smelter, our third-party consultant compared the facilities listed to the list of smelters maintained by the Conflict-Free Sourcing Initiative (“RMI”). If a supplier indicated that the facility was certified as “Conflict-Free,” our third-party consultant confirmed that the name was listed by RMI as a “Conflict-Free” smelter. As of May 15, 2018, we have validated 321 legitimate smelters or refiners and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 257 smelters that are deemed “Responsible Minerals Assurance Process (RMAP) Conformant” - this indicates these smelters and refiners are conformant with the RMAP assessment protocols. There are 11 more smelters or refiners that are deemed “RMAP Active” - Smelters and refiners on the Active list have committed to undergo a RMAP audit. The remaining 53 smelters listed have not yet been confirmed as Conflict-Free. We have assessed these facilities and determined that most of these are of low risk due to their geographic location. Attachment A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Attachment A any smelters or refiners that we have not been able to validate. Attachment A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and RMI.
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Many responses received either provided data at a company or subsidiary level and chose not to provide information at the component level, or did not specify the smelters or refiners used for components supplied to CONMED. Accordingly, we are unable to determine, in those cases, whether any of the 3TGs reported by the suppliers were contained in components or parts supplied to us, or to validate that any of the smelters or refiners identified are actually in our supply chain.
We expect any of our suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. During 2017, we have found no instances where it was necessary to terminate a contract or find a replacement supplier.
6. Steps to Improve Future Due Diligence and Supply Chain Risk Mitigation
We are taking the following steps to improve our due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the DRC or Covered Countries:
| a. | Continue to include a conflict minerals clause in all new or renewed supplier contracts. |
| b. | Continue to engage with suppliers and direct them to training resources as mentioned in Section 4.1, Supplier Engagement, to attempt to increase the response rate and improve the content of the supplier survey responses. |
| · | All suppliers that were non-responsive will be further contacted to encourage reply. |
| · | All suppliers that did not know the origin of the 3TGs in products will be further encouraged to examine their supply chain and enact due diligence measures as per the OECD Due Diligence Guidelines. |
| c. | Engage any of our suppliers found to be supplying us with 3TGs from sources that support conflict in the DRC or any of the Covered Countries to establish an alternative source of 3TGs that do not support such conflict. |
| d. | Monitor industry best practices, and continue to work with a third-party service provider to enhance our due diligence and supply chain management process, as appropriate. This includes requesting Conflict Free sourcing by our suppliers as further described in our Conflicts Mineral Policy and in the contractual provisions described above in our Supply Chain section under Management Systems. |
| e. | Consider replacing suppliers that remain non-responsive, or that are unable to enact due diligence measures as per the OECD Due Diligence Guidelines. |
| f. | Work with suppliers to move to the latest CMRT where new smelter IDs are constantly being added. |
| g. | Require the use of smelter identification numbers. Supplier responses will not be considered complete without identification numbers. |
| h. | Suppliers will also be requested to inform CONMED of the correlation between these smelters and the products and parts they supply to CONMED. |
7. Independent Audit
In accordance with guidance issued by the SEC staff, we are not required to obtain an independent private sector audit of this Conflict Minerals Report for the year ended December 31, 2017.
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Attachment A
| Metal | Standard Smelter Name | Smelter Facility Location | RMAP Status
|
| Gold | Abington Reldan Metals, LLC | UNITED STATES | Not RMAP Conformant or Active |
| Gold | Advanced Chemical Company | UNITED STATES | Conformant |
| Gold | African Gold Refinery | UGANDA | Not RMAP Conformant or Active |
| 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 RMAP Conformant or Active |
| Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant |
| Gold | Aurubis AG | GERMANY | Conformant |
| Gold | Bangalore Refinery | INDIA | Active |
| 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 RMAP Conformant or Active |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
| Gold | Cendres + Métaux S.A. | SWITZERLAND | Conformant |
| Gold | Chimet S.p.A. | ITALY | Conformant |
| Gold | Chugai Mining | JAPAN | Not RMAP Conformant or Active |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not RMAP Conformant or Active |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not RMAP Conformant or Active |
| E-6 |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant |
| Gold | Dowa | JAPAN | Conformant |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | Active |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant |
| Gold | Elemetal Refining, LLC | UNITED STATES | Not RMAP Conformant or Active |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Not RMAP Conformant or Active |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Not RMAP Conformant or Active |
| 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 RMAP Conformant or Active |
| Gold | Guangdong Jinding Gold Limited | CHINA | Not RMAP Conformant or Active |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| Gold | HeeSung | KOREA, REPUBLIC OF | Conformant |
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Not RMAP Conformant or Active |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
| 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 |
| E-7 |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Not RMAP Conformant or Active |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not RMAP Conformant or Active |
| 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. | KOREA, REPUBLIC OF | Conformant |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Not RMAP Conformant or Active |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Not RMAP Conformant or Active |
| Gold | Lingbao Gold Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| Gold | L'Orfebre S.A. | ANDORRA | Active |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| 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 | Active |
| E-8 |
| Gold | Morris and Watson | NEW ZEALAND | Not RMAP Conformant or Active |
| Gold | Morris and Watson Gold Coast | AUSTRALIA | Not RMAP Conformant or Active |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Not RMAP Conformant or Active |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | 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 |
| Gold | Pease & Curren | UNITED STATES | Not RMAP Conformant or Active |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| 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 | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| Gold | Remondis Argentia B.V. | NETHERLANDS | Active |
| Gold | Republic Metals Corporation | UNITED STATES | Conformant |
| Gold | Royal Canadian Mint | CANADA | Conformant |
| Gold | SAAMP | FRANCE | Conformant |
| Gold | Sabin Metal Corp. | UNITED STATES | Not RMAP Conformant or Active |
| Gold | Safimet S.p.A | ITALY | Conformant |
| Gold | SAFINA A.S. | CZECH REPUBLIC | Active |
| Gold | Sai Refinery | INDIA | Not RMAP Conformant or Active |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant |
| E-9 |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Not RMAP Conformant or Active |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Conformant |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | Conformant |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| 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 | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Not RMAP Conformant or Active |
| Gold | Sudan Gold Refinery | SUDAN | Not RMAP Conformant or Active |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
| Gold | SungEel HiTech | KOREA, REPUBLIC OF | 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 RMAP Conformant or Active |
| Gold | Tony Goetz NV | BELGIUM | Not RMAP Conformant or Active |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Not RMAP Conformant or Active |
| Gold | Torecom | KOREA, REPUBLIC OF | 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 RMAP Conformant or Active |
| Gold | Valcambi S.A. | SWITZERLAND | Conformant |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Conformant |
| E-10 |
| 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 RMAP Conformant or Active |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | D Block Metals, LLC | UNITED STATES | Conformant |
| Tantalum | Duoluoshan | CHINA | Not RMAP Conformant or Active |
| 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 | King-Tan Tantalum Industry Ltd. | CHINA | Conformant |
| E-11 |
| 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 |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Conformant |
| Tin | Alpha | UNITED STATES | Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Not RMAP Conformant or Active |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Active |
| Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| 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 | Dowa | JAPAN | Conformant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Not RMAP Conformant or Active |
| Tin | EM Vinto | BOLIVIA | Conformant |
| Tin | Estanho de Rondônia S.A. | BRAZIL | Not RMAP Conformant or Active |
| E-12 |
| Tin | Fenix Metals | POLAND | Conformant |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant |
| Tin | Gejiu Jinye Mineral Company | 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 | Not RMAP Conformant or Active |
| 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 Ketai Advanced Material 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 | Active |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Not RMAP Conformant or Active |
| 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 RMAP Conformant or Active |
| 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 |
| E-13 |
| 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 Eunindo Usaha Mandiri | INDONESIA | Conformant |
| Tin | PT Inti Stania Prima | INDONESIA | Conformant |
| Tin | PT Karimun Mining | INDONESIA | Conformant |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Conformant |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Conformant |
| Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
| Tin | PT O.M. Indonesia | 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 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 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 RMAP Conformant or Active |
| Tin | Thaisarco | THAILAND | Conformant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Not RMAP Conformant or Active |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| E-14 |
| 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. | VIET NAM | Conformant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Active |
| 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 | Not RMAP Conformant or Active |
| 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 | Conformant |
| 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 RMAP Conformant or Active |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not RMAP Conformant or Active |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Kennametal Fallon | UNITED STATES | Conformant |
| E-15 |
| 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 | VIET NAM | 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. | VIET NAM | Conformant |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Conformant |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Conformant |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | 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 |
| E-16 |
Appendix B:
This 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.
Andorra, Australia, Austria, Bolivia (Plurinational State of), Belgium, Brazil, Canada, Chile, China, Czech Republic, Estonia, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Korea, Republic of, Kyrgyzstan, Lithuania, Macedonia, Malaysia, Mexico, Myanmar, Netherlands, New Zealand, Peru, Philippines, Poland, Russian Federation, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, Uganda, United Arab Emirates, United States of America, Uzbekistan, Viet Nam, Zambia, Zimbabwe
| E-17 |
