Exhibit 1.01 to Form SD
NORTONLIFELOCK INC.
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD JANUARY 1 TO DECEMBER 31, 2019
This Conflict Minerals Report has been prepared by NortonLifeLock Inc. (formerly known as Symantec Corporation and herein referred to, alternatively, as “NortonLifeLock,” “we” and “our”). NortonLifeLock changed its name from Symantec Corporation to NortonLifeLock Inc. on November 4, 2019. This Conflict Minerals Report for the reporting period January 1 to December 31, 2019 is presented to comply with the final Conflict Minerals implementing rules (the “Conflict Minerals Rules”) promulgated by the Securities and Exchange Commission (“SEC”), as modified by SEC guidance issued on April 29, 2014 and the SEC order issued on May 2, 2014. The Conflict Minerals Rules were adopted by the SEC to implement reporting and disclosure requirements related to Conflict Minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 as codified in Section 13(p) of the Securities Exchange Act of 1934. The Conflict Minerals Rules impose certain reporting obligations on SEC registrants whose manufactured products contain Conflict Minerals that are necessary to the functionality or production of their products. “Conflict Minerals” are currently defined by the SEC as cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, which the SEC has currently limited to tin, tantalum, tungsten and gold (“3TG”).
To comply with the Conflict Minerals Rules, we conducted due diligence on the origin, source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of the products that we manufactured or contracted to manufacture to ascertain whether these Conflict Minerals originated in the Democratic Republic of Congo (“DRC”) or adjoining countries (collectively, the “Covered Countries”) and financed or benefited armed groups (as defined in Section 1, Item 1.01(d)(2) of Form SD) in any of these countries.
Pursuant to SEC guidance issued April 29, 2014 and the SEC order issued May 2, 2014, NortonLifeLock is not required to describe any of its products as “DRC conflict free” (as defined in Section 1, Item 1.01(d)(4) of Form SD), “DRC conflict undeterminable” (as defined in Section 1, Item 1.01(d)(5) of Form SD) or “having not been found to be ‘DRC conflict free,’” and therefore makes no conclusion in this regard in the report presented herein. Furthermore, given that NortonLifeLock has not voluntarily elected to describe any of its products as “DRC conflict free,” an independent private sector audit of the report presented herein has not been conducted.
| I. | Company Overview |
Founded in 1982, NortonLifeLock has evolved to become a global leader in Cyber Safety. In November 2019, Symantec Corporation sold certain of its enterprise security assets to Broadcom Inc. (the “Broadcom Sale”).
Other than the information expressly set forth in this report, the information contained or referred to on our website is not part of this report.
| II. | Products Overview |
NortonLifeLock’s Cyber Safety solutions (delivered via Norton and LifeLock brands) help consumers protect their information, identity, devices, and networks at home and online. All tier one suppliers of physical products that were manufactured in 2019 (whether before or after the consummation of the Broadcom Sale) are considered in-scope suppliers, and are referred to herein as “suppliers.” These suppliers manufacture (i) appliances and (ii) tokens.
| III. | Supply Chain Overview |
All of NortonLifeLock’s product manufacturing is outsourced to Subcontract Manufacturing and Logistic Partners. Our 2019 suppliers are located in North America, South America, EMEA, Russia and Asia. NortonLifeLock distributed the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (the “Survey”) to 11 suppliers, and nine of those suppliers responded. As of April 9, 2020, these suppliers had identified 338 3TG smelter or refiner facilities from which they sourced Conflict Minerals, and 330 of those facilities had successfully completed an assessment against the applicable RMI Responsible Minerals Assurance Process (“RMAP') standard or an equivalent cross-recognized assessment.
| IV. | Conflict Minerals Analysis and Reasonable Country of Origin Inquiry |
Based upon a review of our product categories and our reasonable country of origin inquiry (“RCOI”), we have concluded that:
| · | Our appliance and token products contain Conflict Minerals that are necessary to the production or functionality of such products; and |
| · | We are unable to determine whether the Conflict Minerals present in such products originate in the Covered Countries. |
We are therefore required pursuant to the Conflict Minerals Rules to file with the SEC a Form SD and a Conflict Minerals Report as an exhibit thereto.
| V. | Design of Due Diligence Measures |
NortonLifeLock designed its due diligence with respect to the source and chain of custody of the Conflict Minerals contained in its products based on the five-step framework set forth in the Third Edition of the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- affected and High-Risk Areas and the supplements thereto.
| VI. | Due Diligence Measures Performed by NortonLifeLock |
Step #1: Establish Strong Company Management Systems
| · | NortonLifeLock maintains a policy on Conflict Minerals (the “Policy”). The Policy can be viewed at https://www.nortonlifelock.com/about/corporate-responsibility/resources/corporate-responsibility-policies.The Policy has been communicated to relevant personnel, and it is available to all NortonLifeLock employees and the public via NortonLifeLock’s website. |
| · | NortonLifeLock’s Conflict Minerals Team (the “Team”) is responsible for Conflict Minerals due diligence, governance and reporting. The Team consists of representatives from Global Supply Chain Management, Finance, Legal and Corporate Responsibility, all of whom have experience and expertise with respect to the requirements of the Conflict Minerals Rules, and is supported by external consultants. Oversight of NortonLifeLock’s Conflict Minerals due diligence, governance and reporting is exercised by the Disclosure Committee and the Nominating and Governance Committee of the Company’s Board of Directors. The Team is supported by a member of NortonLifeLock’s Senior Management Team. |
| · | To make training regarding Conflict Minerals compliance available to suppliers, NortonLifeLock refers suppliers to the RMI’s website atwww.responsiblemineralsinitiative.org/training-and-resources,which contains Conflict Minerals training materials and resources for suppliers. |
| · | NortonLifeLock’s Policy is available to existing suppliers and was made available to new suppliers as part of the “new supplier” onboarding process. In addition, NortonLifeLock incorporated a provision requiring compliance with the Conflict Minerals Rules and the Policy into (i) new supplier agreements and (ii) existing supplier agreements when such agreements were negotiated for renewal. |
| · | Pursuant to the Policy, concerned parties may contact NortonLifeLock regarding complaints related to Conflict Minerals compliance by contacting NortonLifeLock’s Ethics Line via telephone by choosing a number fromhttps://secure.ethicspoint.com/domain/media/en/gui/28771/index.htmlor by sending an e-mail to the Office of Ethics and Compliance atethicsandcompliance@nortonlifelock.com. Suppliers may also contact their supply chain representative in their region. |
| · | All documentation and records, including all material communications with suppliers, are retained electronically for a period of five (5) years. |
Step #2: Identify and Assess Risk in the Supply Chain
| · | NortonLifeLock maintains a Conflict Minerals Compliance Program (the “Program”) that outlines the process for supplier due diligence and engagement. |
| · | The Program includes the identification of the suppliers that provide inputs to NortonLifeLock’s products that may contain Conflict Minerals. This analysis is performed on an annual basis, as well as through the ongoing supplier approval and onboarding process, with data pulled from the global supplier database. |
| · | The Corporate Responsibility Team works with Global Supply Chain Management, Legal and Finance to determine the enterprise reporting entity for compliance purposes. This includes the determination of whether any of NortonLifeLock’s subsidiaries, joint ventures, or acquired companies are in-scope or out-of-scope for the respective reporting year pursuant to the Conflict Minerals Rules. |
| · | On an annual basis, any new subsidiaries and joint ventures are evaluated for inclusion as an in-scope entity for the purposes of compliance with the Conflict Minerals Rules. |
| · | For acquisitions, due diligence is conducted to determine whether the newly acquired organization is subject to the Conflict Minerals Rules. |
| · | For out-of-scope entities, if the entity supplies NortonLifeLock in-scope entities with products NortonLifeLock contracts to manufacture, then the entity is considered a supplier and is surveyed as part of the RCOI process. |
| · | The Survey is emailed annually by the Global Supply Chain Team to all in-scope suppliers along with an introductory email. |
Step #3: Design and Implement a Strategy to Respond to Identified Risks
| · | NortonLifeLock has designed a Due Diligence Decision Tree that sets forth steps to be taken to mitigate risk based on a supplier’s Survey responses. Suppliers are ranked for risk, ranging from Low to High, based upon red flags and issues raised by suppliers’ Survey responses (the “Risk Levels”). |
Step #4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
| · | As a downstream actor in the supply chain, we do not have a direct relationship with the smelters and refiners that process the Conflict Minerals that are present in our products, and for thisreasonwe rely on the RMI to conduct third-party audits of smelters and refiners. |
Step #5: Report on Supply Chain Due Diligence
| · | As required by the Conflict Minerals Rules, we have filed a Form SD and a Conflict MineralsReport as an exhibit thereto for the 2019 reporting year. The Form SD and Conflict Minerals Report are also available on our website athttps://www.nortonlifelock.com/about/corporate-responsibility/resources/corporate-responsibility-policies. |
| VII. | Supplier Survey Responses and Smelter and Refiner Information |
The supplier Survey results were as follows:
| · | 82% of in-scope suppliers responded using the Survey. |
| · | 100% of in-scope suppliers who responded provide products that contain Conflict Minerals. |
| · | 78% of in-scope suppliers who responded source from the Covered Countries. |
| · | 100% of in-scope suppliers who responded have a Conflict Minerals policy in place, and 67% of such in-scope suppliers have made their policy available to the public. |
| · | 89% of in-scope suppliers who respondedrequiretheir direct suppliers to be DRC conflict-free (as defined in the Survey). |
| · | 100% of in-scope suppliers who responded have implemented due diligence measures for conflict-free sourcing. |
| · | 100% of in-scope suppliers who responded collect conflict minerals due diligence information from their suppliersthat is in conformance with the IPC-1755 Conflict Minerals Data Exchange Standard. |
| · | 100% of in-scope suppliers who responded only require their direct suppliers to source the 3TG from smelters whose due diligence practices have been validated by an independent third-party audit program. |
| · | 89% of in-scope suppliers who responded review due diligence information received from their suppliers against their company’s expectations. |
| · | 78% of in-scope suppliers who responded have a review process in placethatincludes corrective action management. |
| · | 33% of in-scopesuppliers who responded are subject to the Conflict MineralsRules. |
In addition, Addendum A to this Conflict Minerals Report contains smelter eligibility, audit and location information and a list of those smelters reported by our suppliers that appear on the RMI’s Standard Smelter List.
| VIII. | Steps to Mitigate Risk |
NortonLifeLock intends to take the following steps to mitigate the risk thatits necessary Conflict Minerals benefit armed groups:
| · | Follow up with suppliers to improve the quality of their Surveys and continue to engage with them to obtain complete Surveys in a timely manner; |
| · | Support the development of supplier capabilities to perform Conflict Minerals-related due diligence by means of the implementation of risk mitigation measures, as appropriate; and |
| · | provide ongoing training regarding emerging best practices and other relevant topics to NortonLifeLock personnel responsible for Conflict Minerals compliance. |
FORWARD-LOOKING STATEMENTS
Statements relating to due diligence improvements and certain other statements herein are forward-looking in nature and are based on NortonLifeLock’s management's current expectations or beliefs. These forward-looking statements are not a guarantee of performance and are subject to a number of uncertainties and other factors that may be outside of NortonLifeLock’s control and that could cause actual events to differ materially from those expressed or implied by the statements made herein.
DOCUMENTS INCORPORATED BY REFERENCE
Unless otherwise stated herein, any documents, third-party materials or references to websites (including NortonLifeLock’s) are not incorporated by reference in, or considered to be a part of, this Conflict Minerals Report, unless expressly incorporated by reference herein.
Addendum A
The smelter information below was reported by NortonLifeLock suppliers using the RMI’s Conflict Minerals Reporting Template, Revision 5.12.
Data collection was completed between January 2020 and April 2020.
For more detail and the most current status of each smelter, please visit the RMI’s website atwww.responsiblemineralsinitiative.org.
For the purposes of the table and chart immediately below, smelter eligibility status refers to whether or not the entity meets the definition of a smelter / refiner under the RMAP standards and is subsequently eligible for an audit; please refer tohttp://www.responsiblemineralsinitiative.org/members/database-field-definitions.
| Smelter Eligibility Status | Definition | |
| Alleged | Unknown if entity is a smelter / refiner; more research is needed; not included in the CMRT Standard Smelter List | |
| Eligible | Meets the definition of a smelter / refiner; included in the CMRT Standard Smelter List | |
| Not Eligible | Does not meet the definition of a smelter / refiner or is otherwise ineligible for the program; not included in the CMRT Standard Smelter List |
| Smelter Audit Status | Definition | |
| Active | Engaged in the RMAP but not yet conformant | |
| Communication Suspended – Not Interested | Facility has strongly communicated a lack of interest in participation in the RMAP | |
| Communication Suspended – Temporarily Ceased Operation | Facility has temporarily ceased operations | |
| Conformant | Audited and found conformant with the relevant RMAP standard | |
| Due Diligence Vetting Process | Facility does not meet RMI’s requirements for participation according to the due diligence vetting process | |
| In Communication | Not yet active but in communication with RMAP and/or member company | |
| Non-Conformant | Audited but found not conformant with the relevant RMAP standard | |
| Not Applicable | Not eligible for the RMAP | |
| Outreach Required | Outreach needed by RMI member companies to contact entity and encourage its participation in RMAP audit | |
| RMI Due Diligence Review – Unable to Proceed | For facilities that have not met the threshold for Due Diligence Vetting Process after a period of six months. Status may change if additional information is submitted. |
2019 Smelter List
| Metal | Smelter Name as Provided by Supplier | Country Location |
| Gold | 8853 S.p.A. | ITALY |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangalore Refinery | INDIA |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | Chugai Mining | JAPAN |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY |
| Gold | Dowa | JAPAN |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Italpreziosi | ITALY |
| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | Marsam Metals | BRAZIL |
| Gold | Materion | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | PAMP S.A. | SWITZERLAND |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | REMONDIS PMR B.V. | NETHERLANDS |
| Gold | Royal Canadian Mint | CANADA |
| Gold | SAAMP | FRANCE |
| Gold | Safimet S.p.A | ITALY |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Yamakin Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
| Tantalum | H.C. Starck Ltd. | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | NPM Silmet AS | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | Power Resources Ltd. | NORTH MACEDONIA, REPUBLIC OF |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tin | Alpha | UNITED STATES OF AMERICA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | Yunnan Tin Company Limited | CHINA |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Dua Sekawan | INDONESIA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Premium Tin Indonesia | INDONESIA |
| Tin | PT Rajehan Ariq | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Fenix Metals | POLAND |
| Tin | Minsur | PERU |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Metallo Belgium N.V. | BELGIUM |
| Tin | Metallo Spain S.L.U. | SPAIN |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Bangka Serumpun | INDONESIA |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT DS Jaya Abadi | INDONESIA |
| Tin | PT Inti Stania Prima | INDONESIA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Kijang Jaya Mandiri | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Sukses Inti Makmur | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tirus Putra Mandiri | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM |
| Tin | Thaisarco | THAILAND |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Luna Smelter, Ltd. | RWANDA |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |