Exhibit 1.01
Trimble Inc.
Conflict Minerals Report for the Year Ended December 31, 2020
The following conflict minerals report contains forward-looking statements about our plans to take additional actions or to implement additional policies or procedures with respect to our due diligence efforts to determine the origin of conflict minerals contained in our products. We undertake no obligation to publicly update or revise any forward-looking statement, whether as a result of new information, future events or otherwise. 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.
This is the Conflict Minerals Report of Trimble Inc. for the 2020 calendar year in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.
Rule 13p-1 requires that all public companies report annually on the presence of certain minerals, characterized as conflict minerals, including tin, tantalum, tungsten or gold (“3TG” or “conflict minerals”), in the products that they manufacture or contract to manufacture, and demonstrate the proper level of due diligence in determining whether these minerals originated from the Democratic Republic of the Congo or an adjoining country (collectively, “Covered Countries”) or from scrap or recycled sources, and whether they directly or indirectly finance or benefit armed groups in the Covered Countries.
Introduction
Trimble provides technology solutions that enable professionals and field mobile workers to improve or transform their work processes. Our solutions, which can include a combination of hardware, software and services, are used across a range of industries including agriculture, architecture, civil engineering, construction, survey and geospatial, government, natural resources, transportation and utilities.
Representative Trimble customers include engineering and construction firms, contractors, surveying companies, farmers and agricultural companies, enterprise firms with large-scale fleets, energy and utility companies, and state, federal and municipal governments.
We design and manufacture, or have manufactured on our behalf, thousands of different hardware products ranging across multiple business divisions within our key business segments of Buildings and Infrastructure, Geospatial, Resources and Utilities, and Transportation. Many of these hardware products, which are typically based upon positioning or location technologies, including Global Navigation Satellite Systems (GNSS), lasers and optics, are built by our contract manufacturing partners.
Our contract manufacturing partners are responsible for significant material procurement, assembly, and testing. We generally manage product design and are involved in qualifying suppliers and key components used in our products. We are many levels removed from the mining or processing of minerals in our supply chain, however, and we do not directly source, or manage the sourcing of, raw materials, including conflict minerals.
Many of our hardware products are designed with printed circuit boards, connectors, sheet metal and other electrical mechanical assemblies that may contain conflict minerals. The components used in our products that contain these metals are required for the functionality of our products.
Trimble’s Conflict Minerals Program
Trimble is committed to sourcing components and materials from companies that share our values concerning human rights, ethics and environmental responsibility. Our Conflict Minerals Policy Statement, as well as our current Conflict Minerals Report, are published on our public website and available at:
www.trimble.com/Corporate/Compliance/compliance_resources
We focus our due diligence efforts on determining the source and chain of custody of conflict minerals in the components and materials that are supplied to us. Tracing conflict minerals back to their country of origin, though, is a complex task that requires, among other things, screening for the possible presence of 3TG in parts or materials provided by our contract manufacturers and direct suppliers (which we refer to as “in-scope suppliers”), and then
surveying such in-scope suppliers to understand what programs they have in place for tracing the source of minerals included in products or components supplied to us. Suppliers are deemed out-of- scope and not surveyed if they only provide software, plastic, packaging materials or other items that do not contain 3TG.
Trimble uses as its standard reporting template, and requires its in-scope suppliers to use, the Responsible Minerals Initiative’s (“RMI”) reporting template to identify whether in-source suppliers source 3TG from the Covered Countries or from recycled or scrap sources. The RMI reporting template is a key part of our due diligence efforts and is used to determine the source and chain of custody of 3TG in the components and materials that are supplied to us. We rely on the information provided through the RMI reporting template by our supply chain, as well as smelter information provided by the RMI and other industry organizations, to complete our Conflict Minerals Report.
As part of our supplier risk assessment, we require new suppliers to go through a screening and approval process so we can assess their use of 3TG and determine whether they are in-scope suppliers. We provide an initial survey to assess their use of 3TG and to understand their business processes. We also inform new suppliers of our “Supplier Requirements for the Sourcing of Conflict Minerals,” which further describe our Conflict Minerals Program goals and expectations. Additionally, we have established a Supplier Code of Conduct, which is based upon the Responsible Business Alliance’s Code of Conduct.
Trimble requires in-scope suppliers to source from smelters that are either conformant with the Responsible Minerals Assurance Process (“RMAP”), have undergone another recognized third-party audit program (such as the London Bullion Market Association (LBMA) or the Responsible Jewellery Council (RJC)), or are in the process of achieving audit conformance. In the event of non-conformance by an in-scope supplier, we require the supplier to pursue corrective actions, and, in the event of continued non-conformance, we may consider termination of the supplier.
Reasonable Country of Origin Inquiry (“RCOI”)
Since conflict minerals are necessary to the functionality of many of our hardware products, we conducted an RCOI to determine the origin of the 3TG present in our products delivered to customers.
Given the complex nature of our supply chain and our extensive parts inventory, we assess our in-scope suppliers in three separate phases: (i) we first assess suppliers of parts containing 3TG that are used in the bill of materials for products that we are actively producing; (ii) we then review those suppliers that manufacture and sell to us their parts and components; and (iii) finally, we review suppliers of the companies and businesses that we acquire.
After conducting our three-phase assessment, we requested in-scope suppliers to provide us with information using the RMI reporting template. We received a 95% response rate, which is similar to our previous year’s response rate. Based on the responses from our in-scope suppliers and a review and analysis of the responses against RMI’s RMAP Conformant Smelters & Refiners list, which provides sourcing information and audit status for certified smelters (as well as sourcing information for LBMA and RJC audited smelters) we concluded that, of the identified smelters:
82% were identified as being Conformant (i.e. smelters that have completed an audit and conform with RMAP or another third-party program).
Of these Conformant smelters, 36% reported sourcing from Covered Countries.
Based on our internal assessment of in-scope suppliers and the RMI reporting template information we received back from our in-scope suppliers, we determined that it was necessary to exercise due diligence to determine the source and chain of custody of the conflict minerals contained in our products.
Trimble Due Diligence
We have designed our due diligence program to conform, in all material respects, with the framework in the “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition),” and the related supplements, published by the Organisation for Economic Co-operation and Development (OECD).
The worldwide COVID-19 coronavirus pandemic in 2020 significantly impacted the operation of mines and processing facilities and disrupted mineral resource supply chains. In addition to facility closures and disruption to international shipments of minerals, there was also a significant impact on the ability of organizations to assess smelters and conduct audits in the face of local quarantines and closures. This impacted the accuracy and completeness of information available to us in conducting our due diligence activities for 2020.
The following describes Trimble’s due diligence activities for the 2020 reporting year.
Step 1: Establish Strong Company Management Systems
•We have made our Conflict Minerals Policy, described above, publicly available on our website.
•We have established a team that is responsible for administering our Conflict Minerals Program. Our team is supported by, and works closely with, our third-party vendor, MetricStream. Our team consists of personnel from our corporate operation’s group, including representatives from our quality, internal audit and global commodity management departments, and works with our specific business area buyers and product managers to address supplier risks and disclosure issues.
•If suppliers are unresponsive or do not provide the requested information, we have a process for escalating the matter to increasingly senior levels of management and considering corrective actions for suppliers that do not meet our stated expectations.
•We have established “Supplier Requirements for the Sourcing of Conflict Minerals,” which we communicate to our suppliers and require them to follow. We also engage suppliers by providing conflict minerals training and orientation materials to assist our suppliers in completing the RMI reporting template and provide support to answer suppliers’ questions. We maintain a conflict minerals resource page with links to resources about the conflict minerals law, the reporting template and our contact information for conflict minerals related inquiries: www.trimble.com/Corporate/Compliance/compliance_resources.
•Our template terms of purchase require suppliers to assist us in complying with applicable provisions of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act such as notifying us of their use of conflict minerals.
•We report on the status and progress of our Conflict Minerals Program during our operation group’s quarterly business and executive-level review meetings.
•Our Conflict Minerals Program, as an established internal process, is subject to oversight by our internal audit group.
Step 2: Identify and Assess Risk in the Supply Chain
•We requested each in-scope supplier to complete and return a reporting template so that we could survey our supply chain and obtain information about the smelters and refiners (which we collectively refer to as “smelters” throughout this report), and mines or locations of origin, of the 3TG used in our products. We identified the standardized reporting template developed by RMI as the best method for collecting information about Trimble’s suppliers to identify and assess risks.
•We tracked responses from in-scope suppliers and initially categorized suppliers according to whether they provided in their responses: (i) legitimate smelter information, or (ii) inconsistent or incomplete information about smelters that required further investigation.
•We used RMI’s smelters and refiners database to obtain conflict minerals sourcing information for the smelters identified on the completed reporting templates from our in-scope suppliers.
•We followed a defined process for reviewing and evaluating reporting template responses, including procedures to address incomplete or vague answers and to follow up with suppliers, as necessary.
•We identified any “high risk” suppliers that require additional attention by focusing on suppliers that: (i) list smelters that are in the Covered Countries and are not found on the RMAP Conformant Smelters & Refiners list. (ii) list smelters that have been found to be non-conformant with the RMAP or similar third- party audit programs, (iii) list unresponsive smelters that are unwilling to undertake compliance with the
RMAP or another third-party audit program, or (iv) list smelters that we identified through our trade compliance screening as smelters that may be financed by a U.S.-embargoed or -sanctioned country, or that are identified as potentially supporting armed conflict or human rights violations.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
•We obtained updated smelter status data from RMI’s smelters and refiners database and compared supplier provided information against such data. Smelters found not in conformance with the RMAP or other independent third-party audit programs (such as the Tin Supply Chain Initiative List and the London Bullion Market Good Delivery Lists) were flagged for further due diligence.
•Any supplier that Trimble identified as “high risk” underwent further investigation and was subject to additional risk mitigation requests by Trimble.
•We informed our in-scope suppliers of identified high risk smelters and requested our suppliers to conduct further due diligence and to work with their supply chains to ensure compliance, such as by requesting impacted suppliers to utilize RMI’s smelter outreach letter in reaching out to non-certified smelters and press them for compliance, or to find substitute smelters.
•We require high risk suppliers to commit to and implement a corrective action plan within a reasonable time frame, and if such plan is deemed ineffective or there is no progress made, at the discretion of management, the supplier is subject to suspension or termination.
•We participate in and support RMI’s working groups on smelter due diligence practices for risk mitigation.
Step 4: Carry Out Independent Third-party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
•We are a member of RMI and rely on RMI’s data to validate the audit status and sourcing information of smelters.
•We conduct our own due diligence through publicly available information regarding identified high risk smelters to validate the existence and assess the conflict status of smelters.
•We address conflict minerals in our general supplier audits, focusing on supplier reporting template responses and due diligence programs.
Step 5: Report on supply chain due diligence
•Our annual Conflict Minerals Report is publicly accessible on our website.
•We remind “high risk” suppliers of our expectations for the upcoming 2021 conflict minerals reporting period and emphasize our requirements and goals.
Results of Due Diligence
Based on the responses received from suppliers, we identified a total of 333 smelters within our supply chain that were potential sources of 3TG for our suppliers.
We utilized RMI’s smelters database to obtain recent smelter audit status as of February 22, 2021. The table below summarizes the status of smelters that were identified through the information provided by our in-scope suppliers. Trimble has adopted the same audit status designations utilized by RMI to categorize audit compliance status. “Conformant” smelters are those that have completed an audit and conform with RMAP or other third party programs. “Active” smelters are those that are engaging with RMAP or other third party auditors to achieve compliance. “In Communication” refers to smelters that are not certified, but which demonstrate interest in participating in an audit program. “Alleged” are smelters that are not certified and have not yet even been verified to be a true smelter or still in business. “Non- Conformant” are those smelters that have been identified as having non-conformant audit results.
Schedule A lists all of the verified smelters reported by our in-scope suppliers that we believe processed 3TG which may have been used in Trimble products during the 2020 reporting period.
2020 Trimble Smelters or Refiners Audit Status
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| Metal: | Smelter Status: |
| Conformant Smelters | | Active Smelters | | In Communication Smelters | | Alleged Smelters | | Non-Conformant Smelters |
| Gold | 108 | | | 4 | | | 13 | | | 42 | | | 4 | |
| Tantalum | 37 | | | — | | | — | | | — | | | — | |
| Tin | 54 | | | 8 | | | 2 | | | 7 | | | 4 | |
| Tungsten | 41 | | | 6 | | | 1 | | | 2 | | | — | |
| Total | 240 | | | 18 | | | 16 | | | 51 | | | 8 | |
Of the 333 entities identified as smelters or alleged smelters, 240 smelters had associated mine disclosure information that was provided to us by RMI. From this information, we determined that 135 of those smelters did not source 3TG from the Covered Countries. For the 105 smelters that sourced 3TG from Covered Countries, we determined that they were certified as Conformant by RMI.
Trimble identified certain smelters as potentially high risk in its supply chain, and requested follow-up actions from 53 in-scope suppliers that listed at least one of the smelters identified as high risk. All 53 suppliers have either completed due diligence follow-up actions, acknowledged Trimble’s requests and outlined their action plans for further due diligence, or have reported utilizing smelters that are not located in Covered Countries. Trimble continues to monitor the progress of these suppliers and will consider additional action if warranted.
Determination
Based on the measures we have taken, as described above, we do not have sufficient information to determine the country of origin of all of the 3TG contained in our products. Not all of the RMAP Conformant smelters disclosed the origin of their minerals. In addition, the information provided by some suppliers was incomplete and unverifiable, and certain smelters identified by suppliers were not recognized by RMI or were unknown to us so we were unable to determine the origin of minerals processed by such smelters.
However, based on the information provided by our suppliers, as well as information from RMI and other third party sources, we believe the origin of 3TG processed by smelters known to us and contained in our products include the countries listed in Schedule B. As discussed above, the known smelters for which we had mine disclosure information, and that we believe processed 3TG originating from the Covered Countries, were all certified Conformant by RMI. In addition, we are not aware of any instance where 3TG sourced from the Covered Countries directly or indirectly financed or benefited armed groups.
Future Due Diligence Measures
We intend to take the following measures in 2021 to further mitigate the risk that conflict minerals in our products could directly or indirectly finance or benefit armed groups in the Covered Countries:
•Continue to work to increase the response rate and quality of supplier responses by: working directly with our suppliers on the completion of their RMI reporting templates including direct engagement of our strategic key suppliers and providing additional conflict minerals training to suppliers who have been unable to provide sufficient response quality.
•Encourage suppliers to adopt best practices for the responsible sourcing of materials, and to direct all smelters in their supply chains to participate in the RMAP or similar third-party audit program.
•Monitor the progress of suppliers with high risk smelters identified within their supply chains.
•Continue to communicate with our suppliers regarding Trimble’s Conflict Minerals Policy and Supplier Requirements for the Sourcing of Conflict Minerals to ensure that suppliers appropriately assess their supply chains, in keeping with the principles of responsible sourcing and corporate social responsibility underlying Trimble’s Conflict Minerals Program.
•Review our supplier risk mitigation process to assess remedial and corrective actions that we may take to address situations where suppliers are unresponsive, provide incomplete information or continue to source from unknown smelters.
•Continue monitoring our supply chain activities, keep current with changes or updates in relevant laws and guidance, and update our related policies and procedures as appropriate.
Schedule A
Verified Smelters and Refiners
| | | | | | | | |
| Metal | Smelter Name | Country |
| Gold | 8853 S.P.A. | ITALY |
| Gold | Abington Reldan Metals, Llc | UNITED STATES OF AMERICA |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Al Etihad Gold Refinery Dmcc | UNITED ARAB EMIRATES |
| Gold | Alexy Metals | UNITED STATES OF AMERICA |
| Gold | Allgemeine Gold-Und Silberscheideanstalt A.G. | GERMANY |
| Gold | Almalyk Mining And Metallurgical Complex (Ammc) | UZBEKISTAN |
| Gold | Anglogold Ashanti Corrego Do Sitio Mineracao | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | Au Traders And Refiners | SOUTH AFRICA |
| Gold | Augmont Enterprises Private Limited | INDIA |
| 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 | Caridad | MEXICO |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | Chimet S.P.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Dijllah Gold Refinery Fzc | UNITED ARAB EMIRATES |
| Gold | Doduco Contacts And Refining Gmbh | GERMANY |
| Gold | Dowa Metals & Mining Co. Ltd | JAPAN |
| Gold | Ds Pretech Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Dsc (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
| Gold | Emirates Gold Dmcc | UNITED ARAB EMIRATES |
| Gold | Fidelity Printers And Refiners Ltd. | ZIMBABWE |
| Gold | Gcc Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Gold Refinery Of Zijin Mining Group Co., Ltd. | CHINA |
| Gold | Heesung Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Heimerle + Meule Gmbh | GERMANY |
| | | | | | | | |
| Gold | Henan Zhongyuan Gold Smelter Of Zhongjin Gold Corporation Limited | CHINA |
| Gold | Heraeus Ltd. Hong Kong | CHINA |
| Gold | Hunan Chenzhou | GERMANY |
| Gold | Hwaseong Cj Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Inner Mongolia Qiankun Gold And Silver Refinery Share Co., Ltd. | CHINA |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| 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 | Johnson Matthey Inc. (Usa) | UNITED STATES OF AMERICA |
| Gold | Jsc Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | Jsc Uralelectromed | RUSSIAN FEDERATION |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting Llc | KAZAKHSTAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kennecott Utah Copper Llc | UNITED STATES OF AMERICA |
| Gold | Kghm Polska Miedz Spolka Akcyjna | POLAND |
| Gold | Kojima Kagaku Yakuhin Co., Ltd | JAPAN |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn Jsc | KYRGYZSTAN |
| Gold | Lazurde Company For Jewelry | SAUDI ARABIA |
| 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 | Md Overseas | INDIA |
| Gold | Metal Concentrators Sa (Pty) Ltd. | SOUTH AFRICA |
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor Usa Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mmtc-Pamp India Pvt., Ltd. | INDIA |
| Gold | Modeltech Sdn Bhd | MALAYSIA |
| Gold | Morris And Watson | NEW ZEALAND |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Gold | Navoi Mining And Metallurgical Combinat | UZBEKISTAN |
| Gold | Nh Recytech Company | KOREA, REPUBLIC OF |
| | | | | | | | |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ögussa Österreichische 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 | Ojsc Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | Pamp S.A. | SWITZERLAND |
| Gold | Pan Pacific Copper Co Ltd. | JAPAN |
| 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 | Safina A.S. | CZECHIA |
| Gold | Samdok Metal | KOREA, REPUBLIC OF |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | Sancus Zfs (L’Orfebre, Sa) | COLOMBIA |
| Gold | Saxonia Edelmetalle Gmbh | GERMANY |
| Gold | Sempsa Joyeria Plateria S.A. | SPAIN |
| Gold | Shyolkovsky | RUSSIAN FEDERATION |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA |
| Gold | Kundan Care Products Ltd. | INDIA |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Sungeel Himetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | T.C.A S.P.A | ITALY |
| Gold | Takehara Refinery | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K | JAPAN |
| Gold | The Refinery Of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Tony Goetz Nv | BELGIUM |
| Gold | Too Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | Western Australian Mint (T/A The Perth Mint) | AUSTRALIA |
| Gold | Wieland Edelmetalle Gmbh | GERMANY |
| | | | | | | | |
| Gold | Xstrata | CANADA |
| Gold | Yamakin Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Zhao Yuan Gold Smelter Of Zhongjin | CHINA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Cid000092 | JAPAN |
| Tantalum | D Block Metals, Llc | UNITED STATES OF AMERICA |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
| Tantalum | F & X | 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 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 Nonferrous Metals Smelting Company Limited | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Kemet Blue Metals | MEXICO |
| Tantalum | Lsm Brasil S.A. | BRAZIL |
| Tantalum | Metallurgical Products India Pvt. Ltd. (Mpil) | INDIA |
| Tantalum | Mineracao Taboca Sa | BRAZIL |
| Tantalum | Mitsui Mining And Smelting Co., Ltd. | JAPAN |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | Npm Silmet As | ESTONIA |
| Tantalum | Power Resources Ltd. | NORTH MACEDONIA, REPUBLIC OF |
| Tantalum | Quantumclean | UNITED STATES OF AMERICA |
| Tantalum | Resind Indústria E Comércio Ltda. | BRAZIL |
| Tantalum | Rfh Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Solikamsk Metal Works | RUSSIAN FEDERATION |
| Tantalum | Taki Chemicals | JAPAN |
| Tantalum | Taniobis Smelting Gmbh & Co. Kg | GERMANY |
| Tantalum | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tantalum | Ulba | KAZAKHSTAN |
| Tantalum | Xinxing Haorong Electronic Material Co., Ltd. | CHINA |
| Tin | Brand Rbt | INDONESIA |
| Tin | Chenzhou Yunxiang Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | Cookson | UNITED STATES OF AMERICA |
| | | | | | | | |
| Tin | Crm Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | Crm Synergies | SPAIN |
| Tin | Cv Venus Inti Perkasa | INDONESIA |
| Tin | Dongguan Ciexpo Environmental Engineering Co., Ltd. | CHINA |
| Tin | Dowa Metaltech Co., Ltd. | JAPAN |
| Tin | Electro-Mechanical Facility Of The Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | Enaf | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Estanho De Rondonia S.A. | BRAZIL |
| Tin | Fenix Metals | POLAND |
| 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 Zi-Li | 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 | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | Liuzhhou China Tin | CHINA |
| Tin | Maanshan 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 | Mineração Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Modeltech Sdn Bhd | MALAYSIA |
| 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 | Precious Minerals And Smelting Limited | INDIA |
| Tin | Pt Aries Kencana Sejahtera | INDONESIA |
| Tin | Pt Artha Cipta Langgeng | INDONESIA |
| Tin | Pt Atd Makmur Mandiri Jaya | INDONESIA |
| Tin | Pt Bangka Serumpun | INDONESIA |
| Tin | Pt Menara Cipta Mulia | INDONESIA |
| Tin | Pt Mitra Stania Prima | INDONESIA |
| Tin | Pt Prima Timah Utama | INDONESIA |
| Tin | Pt Timah (Persero) Tbk Mentok | INDONESIA |
| Tin | Pt Timah Tbk Kundur | INDONESIA |
| Tin | Pt Tinindo Inter Nusa | INDONESIA |
| Tin | Resind Indústria E Comércio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Timah Nusantara | INDONESIA |
| Tin | PT Rajehan Ariq | INDONESIA |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| Tin | Luna Smelter, Ltd. | RWANDA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Super Ligas | 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 Chengfeng | CHINA |
| Tin | Yunnan Tin Company, Ltd. | CHINA |
| Tin | Yunnan Yunfan Non-Ferrous Metals Co., Ltd. | CHINA |
| Tungsten | A.L.M.T. Tungsten Corp. | JAPAN |
| Tungsten | Acl Metais Eireli | BRAZIL |
| Tungsten | Artek Llc | RUSSIAN FEDERATION |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | China Molybdenum Co., Ltd. | CHINA |
| Tungsten | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | Fujian Ganmin Raremetal Co., Ltd. | CHINA |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co Ltd | CHINA |
| Tungsten | Gtp | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck Smelting Gmbh & Co. Kg | GERMANY |
| Tungsten | H.C. Starck Tungsten Gmbh | GERMANY |
| Tungsten | Human Chun-Chang Non-Ferrous Smelting & Concentrating Co., Ltd. | CHINA |
| Tungsten | Hunan Chenzhou Mining Group 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 Minmetals Gaoan Non-Ferrous Metals 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 | Jsc "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville | 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 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tungsten | GEM Co., Ltd. | CHINA |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Unecha Refractory Metals Plant | RUSSIAN FEDERATION |
| Tungsten | Wolfram Bergbau Und Hütten 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 | Zhangyuan Tungsten Co Ltd | CHINA |
Schedule B
Countries of Origin List
| | | | | |
| Australia | Mauritania |
| Austria | Mongolia |
| Benin | Mozambique |
| Bolivia | Myanmar |
| Bolivia (Plurinational State of) | Nicaragua |
| Brazil | Niger |
| Burundi | Nigeria |
| Chile | Peru |
| China | Portugal |
| Colombia | Russian Federation |
| Congo, Democratic Republic of | Rwanda |
| Ecuador | Sierra Leon |
| Eritrea | South Africa |
| Ethiopia | Spain |
| Ghana | Swaziland |
| Guinea | Taiwan |
| Guyana | Thailand |
| India | Togo |
| Indonesia | Uganda |
| Laos | United Kingdom of Great Britain and Northern Ireland |
| Madagascar | Uzbekistan |
| Malaysia | Venezuela |
| Mali | Vietnam |
