Exhibit 1.01
GENERAL CABLE CORPORATION
Conflict Minerals Report
For the Calendar Year Ended December 31, 2015
This Conflict Minerals Report (“CMR”) for the calendar year ended December 31, 2015 has been prepared by General Cable Corporation to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Securities and Exchange Commission (“SEC”) adopted the Rule 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. The Rule imposes annual reporting obligations on SEC registrants whose manufactured products contain certain minerals that are necessary to the functionality or production of those products. The subject minerals are gold as well as cassiterite, columbite-tantalite, and wolframite and their derivatives, which are limited to tin, tantalum and tungsten. These minerals and their derivatives are collectively referred to in this CMR as the “Conflict Minerals.”
General Cable Corporation and its consolidated entities are collectively referred to in this CMR as “General Cable”, “Company,” “we”, “us” and “our” unless the context indicates otherwise.
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| 1. | Company Overview & Products Covered by This Report |
General Cable is a global leader in the development, design, manufacture, marketing and distribution of copper, aluminum, and fiber optic wire and cable products for use in the energy, industrial, construction, specialty and communications markets. The Company also engages in the design, integration, and installation on a turn-key basis of products such as high and extra-high voltage terrestrial and submarine systems. Additional information about General Cable and our products may be obtained by accessing our website at www.generalcable.com. However, the content of any of our website material referred to in this CMR is included for general information only and is not incorporated herein by reference.
Throughout calendar year 2015, some of the Company’s operations manufactured or contracted to manufacture the aforementioned types of products for which Conflict Minerals are necessary to the products’ functionality or production (collectively, the “Covered Products”).
We engaged a third party consultant to assist us with our reasonable country of origin inquiry process, due diligence, and the overall effectiveness of General Cable’s Conflict Minerals program.
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| 2. | Reasonable Country of Origin Inquiry (“RCOI”) Process |
General Cable typically does not purchase any raw ore or unrefined Conflict Minerals directly from mines, smelters or refiners. Therefore, we determined that the identification of smelters or refiners (“SORs”) by our direct suppliers is the most reasonable and reliable means for us to address the source and chain of custody of Conflict Minerals in our supply chain. Accordingly, we must rely on our direct suppliers to provide information on the origin of any Conflict Minerals contained in materials and components they supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers.
We performed a RCOI by using the Conflict Free Sourcing Initiative’s (“CFSI’s”) Conflict Minerals Reporting Template (“CMRT”) to survey a sample of direct suppliers of metallic materials and components (the “Supplier Group”). Our RCOI was designed to determine whether any of the Conflict Minerals in the Covered Products originated from the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania (each a “Covered Country” and, collectively, the “Covered Countries”).
Based on our assessment of the responses from our suppliers, we have reason to believe that some of the necessary Conflict Minerals used in our products may have originated in a Covered Country and may not have come from recycled or scrap sources. Therefore, we proceeded to perform the due diligence described below.
3. Due Diligence Process
3.1 Due Diligence Framework
We designed our due diligence measures to conform, in all material respects, to each of the requirements shown below from the five-step framework in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from the Conflict-Affected and High-Risk Areas: Second Edition (2013), including the related supplements for gold and tin (collectively, the “OECD Framework”).
3.2 Due Diligence Performed
3.2.1 Establish Strong Company Management Systems
(a) Conflict Minerals Policy
We have adopted a conflict minerals policy that includes a statement on General Cable’s commitment to working with our global supply chain to ensure compliance with the Rule. General Cable’s expectations for its suppliers to participate in our conflict minerals compliance program are also set forth in the policy. The policy is publicly available on our website at the following link: http://www.generalcablecsr.com/citizenship/conflictminerals.asp.
(b) Internal Conflict Minerals Compliance Team
We maintain a cross-functional conflict minerals team, including senior executive and other representatives from legal, sales, technology, manufacturing, and supply chain, to direct the execution of our conflict minerals compliance program.
(c) Establish a System of Controls and Transparency over the Mineral Supply Chain
Because we typically do not have direct relationships with SORs, we surveyed the Supplier Group using the CFSI Template which requires the Supplier Group to work with their upstream supply chains to identify the SORs that process the Conflict Minerals used in our products.
(d) Strengthen Company Engagement with Suppliers
As part of our RCOI, we emailed the respective members of the Supplier Group to (i) explain General Cable’s obligations under the Rule, (ii) outline General Cable’s expectations for the Supplier Group to cooperate with General Cable’s requests for assistance, and (iii) provide links to online training and other resources regarding conflict minerals compliance requirements.
(e) Establish or Publish a Grievance Mechanism
General Cable maintains a compliance helpline whereby employees, suppliers and other third parties can report any questions, concerns or violations of the Company’s standards of conduct, policies, and applicable laws and regulations. We have also established an email account which any parties can use to report questions or concerns specifically related to our conflict minerals policy.
3.2.2 Identify and Assess Risk in the Supply Chain
In our efforts to determine the mine or location of origin of any Conflict Minerals in our supply chain with the greatest possible specificity, we emailed each member of the Supplier Group and requested them to complete a CMRT with information pertaining to the source of Conflict Minerals in their materials and/or components, including the source of Conflict Minerals contained in any recycled or scrap materials. Responses were tracked, accompanying information or documentation was reviewed, and additional requests for information were sent, as deemed necessary. Follow-up was performed pursuant to our due diligence program with non-responders and suppliers that provided incomplete responses, based on internally defined criteria, in an effort to obtain more detailed information. Any named SORs in the responses were reviewed against the CFSI Conflict-Free Smelter Program’s (“CFSI Program”) list of conflict-free SORS to confirm conflict-free status.
3.2.3 Design and Implement a Strategy to Respond to Identified Risks
We have a risk management plan to address concerns that a supplier may be selling items to General Cable that contain Conflict Minerals sourced from the Covered Countries. If a supplier indicates that items it sells to General Cable may contain Conflict Minerals sourced from the Covered Countries, we will follow up with the supplier to obtain more information, including the basis for the information provided as well as information regarding the source and chain of custody for the subject Conflict Minerals. Identified risks will be reported to General Cable’s Vice President of Sourcing who will work with other members of senior management to determine appropriate follow-up actions, if any, to mitigate risks.
Our conflict minerals policy states that, if a supplier is unwilling to support General Cable in its conflict minerals compliance efforts, General Cable may take remediation steps, up to and including terminating the supplier and pursuing alternative sourcing arrangements. We also state in our policy that General Cable may take remediation steps if a supplier cannot determine whether its materials or products contain Conflict Minerals sourced from the Covered Countries.
We plan to place increased priority in calendar year 2016 on those members of the Supplier Group who did not respond to our survey request or who provided incomplete or inconsistent information.
3.2.4 Carry Out Independent Third-Party Audits of Due Diligence Practices at Smelters and Refiners
We typically do not have any direct relationships with SORs and, therefore, rely upon the Conflict Free Smelter program and other industry validation efforts to perform this audit requirement. We validate whether or not any Conflict Minerals sourced from the Covered Countries is conflict-free based on information provided by the Supplier Group and on the information available on CFSI’s public website.
3.2.5 Report on Supply Chain Due Diligence
Our due diligence program includes filing our Form SD with the SEC on an annual basis, as well as publishing our CMR on our website at http://www.generalcablecsr.com/citizenship/conflictminerals.asp.
4. Due Diligence Results
4.1 Supplier Group Survey Results
The results of our supply chain surveys and conclusion of our reasonable country of origin inquiry are as follows:
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| • | Ninety-seven percent (97%) of the Supplier Group responded to our survey request. |
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| • | One of the responding suppliers provided an incomplete response (based on internally defined criteria) and did not respond to our requests for additional information. |
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| • | Five (5) of the responding suppliers indicated they have not yet received data or information from all relevant suppliers in their respective supply chains. |
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| • | The responding suppliers identified two hundred and three (203) SORs which may process the necessary Conflict Minerals contained in the materials and/or components provided to us. |
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| • | We know or have reason to believe that a portion of the Conflict Minerals processed by four (4) of these 203 SORs may have originated in the Covered Countries and may not be solely from recycled or scrap sources, but we have not identified any instances of sourcing that directly or indirectly supported conflict in the Covered Countries. |
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| • | Many of the responses we received from the Supplier Group continue to provide data at a company level. Therefore, we cannot definitively determine whether many of the Conflict Minerals reported by the suppliers were contained in materials and/or components supplied to us, nor can we validate that all of the reported SORs are actually in our supply chain. |
4.2 Conclusion
We do not have sufficient information from suppliers or other sources regarding all of the SORs that processed the necessary Conflict Minerals in our Covered Products. Therefore, we cannot conclude whether all Conflict Minerals in our Covered Products originated in the Covered Countries and, if so, whether those Conflict Minerals were from recycled or scrap sources or other conflict-free sources.
4.2.1 Facilities That May Have Been Used to Process Necessary Conflict Minerals
As stated above, the Supplier Group identified a total of two hundred and three (203) SORs that may have been used to process necessary Conflict Minerals in our Covered Products. These SORs are listed in Exhibit I of this CMR. Certain suppliers identified entities that we could not validate as SORs and we have not included those entities in Exhibit I.
Many suppliers provided their SOR information at a company-level rather than a product-level. Therefore, while the SORs may be the source of Conflict Minerals for the respective suppliers’ entire product lines, we do not know if Conflict Minerals from all of the SORs listed in Exhibit I are actually in our Covered Products.
Of the two hundred and three (203) SORs identified by the Supplier Group, as of May 29, 2016:
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| • | One hundred thirty-seven (137) SORs are included on the CFSI’s conflict-free smelter or refiner lists; |
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| • | Twenty-five (25) SORs have not received a conflict-free designation, but have begun participating in an independent third party audit program; and |
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| • | Forty-one (41) SORs have not begun participating in an independent third party audit program. |
It should be noted that, pursuant to CFSI program rules and the certification process thereunder, some SORs may not have been compliant for the whole year, some may have failed their re-audit since our due diligence was performed and are in the process of addressing relevant issues, and/or some SORs’ certifications may have expired since our due diligence was performed and a re-audit may be in process.
4.2.2 Countries of Origin of the Necessary Conflict Minerals
Our efforts to determine the mine or location of origin of the necessary Conflict Minerals in our Covered Products with the greatest possible specificity consisted of the due diligence measures described above in this CMR. However, most of our suppliers did not identify the counties of origin for the necessary Conflict Minerals processed by the SORs listed in Exhibit I. Exhibit II of this CMR contains a list countries of origin for the necessary Conflict Minerals that were identified by our Supplier Group or that we identified through our internet research. Conflict Minerals contained in our Covered Products did not necessarily originate in the countries listed in Exhibit II because our suppliers generally provided SOR and country of origin information at the company level rather than limiting their responses to products they supply to us specifically.
5. Risk Mitigation Steps
We intend to take the following steps to improve due diligence conducted and to further mitigate any future risk that our products contain Conflict Minerals that could benefit armed groups in the Covered Countries:
(a) Continue to communicate to our Supplier Group our expectations and information requirements for our conflict minerals compliance program;
(b) Continue to work with and train our in-scope suppliers in order to (i) increase our survey response rate and (ii) obtain complete and consistent information on the origin and chain of custody of Conflict Minerals contained in items sold to General Cable;
(c) Whenever practicable, include provisions in new or renewed purchase agreements with relevant suppliers to establish obligations for such suppliers to cooperate with General Cable’s conflict minerals compliance efforts as required by the Rule; and
(d) Review the potential opportunities and advantages of using automated tools to assist with RCOI and/or due diligence efforts.
6. Independent Audit
This CMR is not subject to an independent audit under the Rule because we are not declaring that our products are DRC Conflict-Free.
Forward-Looking Statements
This CMR contains certain statements relating to future results, which are forward-looking statements as that term is defined in the Private Securities Litigation Reform Act of 1995. These forward-looking statements are based on beliefs of Company management, as well as assumptions and estimates based on information currently available to the Company, and are subject to certain risks and uncertainties that could cause actual results to differ materially from historical results or those anticipated, including those factors discussed under Item 1A, entitled “Risk Factors”, included in the Company’s Form 10-K for the fiscal year ended December 31, 2015. Should one or more of these risks or uncertainties materialize adversely, or should underlying assumptions or estimates prove incorrect, actual results may vary materially from those described. These events and uncertainties are difficult or impossible to predict accurately and many are beyond the Company’s control. The Company assumes no obligation to update any forward-looking statements to reflect events or circumstances after the date of such statements or to reflect the occurrence of anticipated or unanticipated events. For additional information, see the comments included in General Cable’s filings with the SEC.
Exhibit I
Facilities That May Have Been Used to Process Necessary Conflict Minerals
(Note: The SOR facility names, locations and statuses shown below are as reported by the CFSI as of May 29, 2016)
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| Metal | | Smelter or Refiner Facility Name | | Identification # | Location of Facility | Status* |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CID000228 | CHINA | 2 |
| Tin | | Jiangxi Ketai Advanced Material Co., Ltd. | | CID000244 | CHINA | 1 |
| Tin | | CNMC (Guangxi) PGMA Co., Ltd. | | CID000278 | CHINA | 3 |
| Tin | | Alpha | | CID000292 | UNITED STATES | 1 |
| Tin | | Cooperativa Metalurgica de Rondônia Ltda. | | CID000295 | BRAZIL | 1 |
| Tin | | CV Gita Pesona | | CID000306 | INDONESIA | 1 |
| Tin | | PT Justindo | | CID000307 | INDONESIA | 1 |
| Tin | | PT Aries Kencana Sejahtera | | CID000309 | INDONESIA | 1 |
| Tin | | CV Serumpun Sebalai | | CID000313 | INDONESIA | 1 |
| Tin | | CV United Smelting | | CID000315 | INDONESIA | 1 |
| Tin | | Dowa | | CID000402 | JAPAN | 1 |
| Tin | | EM Vinto | | CID000438 | BOLIVIA | 1 |
| Tin | | Estanho de Rondônia S.A. | | CID000448 | BRAZIL | 3 |
| Tin | | Feinhütte Halsbrücke GmbH | | CID000466 | GERMANY | 3 |
| Tin | | Fenix Metals | | CID000468 | POLAND | 1 |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | CID000538 | CHINA | 1 |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | CID000555 | CHINA | 3 |
| Tin | | Huichang Jinshunda Tin Co., Ltd. | | CID000760 | CHINA | 3 |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | CID000942 | CHINA | 2 |
| Tin | | Linwu Xianggui Ore Smelting Co., Ltd. | | CID001063 | CHINA | 3 |
| Tin | | China Tin Group Co., Ltd. | | CID001070 | CHINA | 1 |
| Tin | | Malaysia Smelting Corporation (MSC) | | CID001105 | MALAYSIA | 1 |
| Tin | | Metallic Resources, Inc. | | CID001142 | UNITED STATES | 1 |
| Tin | | Mineração Taboca S.A. | | CID001173 | BRAZIL | 1 |
| Tin | | Minsur | | CID001182 | PERU | 1 |
| Tin | | Mitsubishi Materials Corporation | | CID001191 | JAPAN | 1 |
| Tin | | Nankang Nanshan Tin Manufactory Co., Ltd. | | CID001231 | CHINA | 3 |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | CID001314 | THAILAND | 1 |
| Tin | | Operaciones Metalurgical S.A. | | CID001337 | BOLIVIA | 1 |
| Tin | | PT Alam Lestari Kencana | | CID001393 | INDONESIA | 3 |
| Tin | | PT Artha Cipta Langgeng | | CID001399 | INDONESIA | 1 |
| Tin | | PT Babel Inti Perkasa | | CID001402 | INDONESIA | 1 |
| Tin | | PT Bangka Kudai Tin | | CID001409 | INDONESIA | 3 |
| Tin | | PT Bangka Timah Utama Sejahtera | | CID001416 | INDONESIA | 3 |
| Tin | | PT Bangka Tin Industry | | CID001419 | INDONESIA | 1 |
| Tin | | PT Belitung Industri Sejahtera | | CID001421 | INDONESIA | 1 |
| Tin | | PT BilliTin Makmur Lestari | | CID001424 | INDONESIA | 1 |
| Tin | | PT Bukit Timah | | CID001428 | INDONESIA | 1 |
| Tin | | PT DS Jaya Abadi | | CID001434 | INDONESIA | 1 |
| Tin | | PT Eunindo Usaha Mandiri | | CID001438 | INDONESIA | 1 |
| Tin | | PT Fang Di MulTindo | | CID001442 | INDONESIA | 3 |
| Tin | | PT Karimun Mining | | CID001448 | INDONESIA | 2 |
| Tin | | PT Mitra Stania Prima | | CID001453 | INDONESIA | 1 |
| Tin | | PT Panca Mega Persada | | CID001457 | INDONESIA | 1 |
| Tin | | PT Prima Timah Utama | | CID001458 | INDONESIA | 1 |
| Tin | | PT Refined Bangka Tin | | CID001460 | INDONESIA | 1 |
| Tin | | PT Sariwiguna Binasentosa | | CID001463 | INDONESIA | 1 |
| Tin | | PT Seirama Tin Investment | | CID001466 | INDONESIA | 3 |
| Tin | | PT Stanindo Inti Perkasa | | CID001468 | INDONESIA | 1 |
| Tin | | PT Sumber Jaya Indah | | CID001471 | INDONESIA | 1 |
| Tin | | PT Timah (Persero) Tbk Kundur | | CID001477 | INDONESIA | 1 |
| Tin | | PT Timah (Persero) Tbk Mentok | | CID001482 | INDONESIA | 1 |
| Tin | | PT Pelat Timah Nusantara Tbk | | CID001486 | INDONESIA | 3 |
| Tin | | PT Tinindo Inter Nusa | | CID001490 | INDONESIA | 1 |
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| Tin | | PT Tommy Utama | | CID001493 | INDONESIA | 1 |
| Tin | | Rui Da Hung | | CID001539 | TAIWAN | 1 |
| Tin | | Soft Metais Ltda. | | CID001758 | BRAZIL | 1 |
| Tin | | Thaisarco | | CID001898 | THAILAND | 1 |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | CID001908 | CHINA | 2 |
| Tin | | VQB Mineral and Trading Group JSC | | CID002015 | VIET NAM | 1 |
| Tin | | White Solder Metalurgia e Mineração Ltda. | | CID002036 | BRAZIL | 1 |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | CID002158 | CHINA | 2 |
| Tin | | Yunnan Tin Company Limited | | CID002180 | CHINA | 1 |
| Tin | | CV Venus Inti Perkasa | | CID002455 | INDONESIA | 1 |
| Tin | | Magnu’s Minerais Metais e Ligas Ltda. | | CID002468 | BRAZIL | 1 |
| Tin | | PT Tirus Putra Mandiri | | CID002478 | INDONESIA | 3 |
| Tin | | PT Wahana Perkit Jaya | | CID002479 | INDONESIA | 1 |
| Tin | | Melt Metais e Ligas S.A. | | CID002500 | BRAZIL | 1 |
| Tin | | PT ATD Makmur Mandiri Jaya | | CID002503 | INDONESIA | 1 |
| Tin | | Phoenix Metal Ltd. | | CID002507 | RWANDA | 2 |
| Tin | | O.M. Manufacturing Philippines, Inc. | | CID002517 | PHILIPPINES | 1 |
| Tin | | PT Inti Stania Prima | | CID002530 | INDONESIA | 1 |
| Tin | | CV Ayi Jaya | | CID002570 | INDONESIA | 1 |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | CID002572 | VIETNAM | 2 |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | CID002573 | VIETNAM | 2 |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | CID002574 | VIETNAM | 2 |
| Tin | | PT Cipta Persada Mulia | | CID002696 | INDONESIA | 1 |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | CID002703 | VIETNAM | 2 |
| Tin | | Resind Indústria e Comércio Ltda. | | CID002706 | BRAZIL | 1 |
| Tin | | Metallo-Chimique N.V. | | CID002773 | BELGIUM | 1 |
| Tin | | Elmet S.L.U. | | CID002774 | SPAIN | 1 |
| Tin | | PT Bangka Prima Tin | | CID002776 | INDONESIA | 1 |
| Gold | | Advanced Chemical Company | | CID000015 | UNITED STATES | 2 |
| Gold | | Aida Chemical Industries Co., Ltd. | | CID000019 | JAPAN | 1 |
| Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | CID000035 | GERMANY | 1 |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | CID000041 | UZBEKISTAN | 2 |
| Gold | | AngloGold Ashanti Córrego do Sítio Mineração | | CID000058 | BRAZIL | 1 |
| Gold | | Argor-Heraeus S.A. | | CID000077 | SWITZERLAND | 1 |
| Gold | | Asahi Pretec Corp. | | CID000082 | JAPAN | 1 |
| Gold | | Asaka Riken Co., Ltd. | | CID000090 | JAPAN | 1 |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | CID000103 | TURKEY | 3 |
| Gold | | Aurubis AG | | CID000113 | GERMANY | 1 |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | CID000128 | PHILIPPINES | 1 |
| Gold | | Boliden AB | | CID000157 | SWEDEN | 1 |
| Gold | | C. Hafner GmbH + Co. KG | | CID000176 | GERMANY | 1 |
| Gold | | Caridad | | CID000180 | MEXICO | 3 |
| Gold | | CCR Refinery - Glencore Canada Corporation | | CID000185 | CANADA | 1 |
| Gold | | Cendres + Métaux S.A. | | CID000189 | SWITZERLAND | 2 |
| Gold | | Yunnan Copper Industry Co., Ltd. | | CID000197 | CHINA | 3 |
| Gold | | Chimet S.p.A. | | CID000233 | ITALY | 1 |
| Gold | | Chugai Mining | | CID000264 | JAPAN | 3 |
| Gold | | Daejin Indus Co., Ltd. | | CID000328 | KOREA, REPUBLIC OF | 2 |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | | CID000343 | CHINA | 3 |
| Gold | | DSC (Do Sung Corporation) | | CID000359 | KOREA, REPUBLIC OF | 2 |
| Gold | | DODUCO GmbH | | CID000362 | GERMANY | 1 |
| Gold | | Dowa | | CID000401 | JAPAN | 1 |
| Gold | | Eco-System Recycling Co., Ltd. | | CID000425 | JAPAN | 1 |
| Gold | | OJSC Novosibirsk Refinery | | CID000493 | RUSSIAN FEDERATION | 1 |
| Gold | | Gansu Seemine Material Hi-Tech Co., Ltd. | | CID000522 | CHINA | 3 |
| Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | CID000651 | CHINA | 3 |
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| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | CID000671 | CHINA | 3 |
| Gold | | Heimerle + Meule GmbH | | CID000694 | GERMANY | 1 |
| Gold | | Heraeus Ltd. Hong Kong | | CID000707 | CHINA | 1 |
| Gold | | Heraeus Precious Metals GmbH & Co. KG | | CID000711 | GERMANY | 1 |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | | CID000767 | CHINA | 3 |
| Gold | | Hwasung CJ Co., Ltd. | | CID000778 | KOREA, REPUBLIC OF | 3 |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | CID000801 | CHINA | 1 |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | CID000807 | JAPAN | 1 |
| Gold | | Istanbul Gold Refinery | | CID000814 | TURKEY | 1 |
| Gold | | Japan Mint | | CID000823 | JAPAN | 1 |
| Gold | | Jiangxi Copper Co., Ltd. | | CID000855 | CHINA | 1 |
| Gold | | Asahi Refining USA Inc. | | CID000920 | UNITED STATES | 1 |
| Gold | | Asahi Refining Canada Ltd. | | CID000924 | CANADA | 1 |
| Gold | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | CID000927 | RUSSIAN FEDERATION | 1 |
| Gold | | JSC Uralelectromed | | CID000929 | RUSSIAN FEDERATION | 1 |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | CID000937 | JAPAN | 1 |
| Gold | | Kazakhmys Smelting LLC | | CID000956 | KAZAKHSTAN | 3 |
| Gold | | Kazzinc | | CID000957 | KAZAKHSTAN | 1 |
| Gold | | Kennecott Utah Copper LLC | | CID000969 | UNITED STATES | 1 |
| Gold | | Kojima Chemicals Co., Ltd. | | CID000981 | JAPAN | 1 |
| Gold | | Korea Metal Co., Ltd. | | CID000988 | KOREA, REPUBLIC OF | 3 |
| Gold | | Kyrgyzaltyn JSC | | CID001029 | KYRGYZSTAN | 3 |
| Gold | | L’azurde Company For Jewelry | | CID001032 | SAUDI ARABIA | 3 |
| Gold | | Lingbao Gold Co., Ltd. | | CID001056 | CHINA | 3 |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | CID001058 | CHINA | 3 |
| Gold | | LS-NIKKO Copper Inc. | | CID001078 | KOREA, REPUBLIC OF | 1 |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | CID001093 | CHINA | 3 |
| Gold | | Materion | | CID001113 | UNITED STATES | 1 |
| Gold | | Matsuda Sangyo Co., Ltd. | | CID001119 | JAPAN | 1 |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | CID001147 | CHINA | 2 |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | CID001149 | CHINA | 1 |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | CID001152 | SINGAPORE | 1 |
| Gold | | Metalor Technologies S.A. | | CID001153 | SWITZERLAND | 1 |
| Gold | | Metalor USA Refining Corporation | | CID001157 | UNITED STATES | 1 |
| Gold | | Metalúrgica Met-Mex Peñoles S.A. De C.V. | | CID001161 | MEXICO | 1 |
| Gold | | Mitsubishi Materials Corporation | | CID001188 | JAPAN | 1 |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | CID001193 | JAPAN | 1 |
| Gold | | Moscow Special Alloys Processing Plant | | CID001204 | RUSSIAN FEDERATION | 1 |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.Ş. | | CID001220 | TURKEY | 1 |
| Gold | | Navoi Mining and Metallurgical Combinat | | CID001236 | UZBEKISTAN | 2 |
| Gold | | Nihon Material Co., Ltd. | | CID001259 | JAPAN | 1 |
| Gold | | Elemetal Refining, LLC | | CID001322 | UNITED STATES | 1 |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | CID001325 | JAPAN | 1 |
| Gold | | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | | CID001326 | RUSSIAN FEDERATION | 1 |
| Gold | | PAMP S.A. | | CID001352 | SWITZERLAND | 1 |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | CID001362 | CHINA | 3 |
| Gold | | Prioksky Plant of Non-Ferrous Metals | | CID001386 | RUSSIAN FEDERATION | 1 |
| Gold | | PT Aneka Tambang (Persero) Tbk | | CID001397 | INDONESIA | 1 |
| Gold | | PX Précinox S.A. | | CID001498 | SWITZERLAND | 1 |
| Gold | | Rand Refinery (Pty) Ltd. | | CID001512 | SOUTH AFRICA | 1 |
|
| | | | | | |
| Gold | | Royal Canadian Mint | | CID001534 | CANADA | 1 |
| Gold | | Sabin Metal Corp. | | CID001546 | UNITED STATES | 3 |
| Gold | | Samduck Precious Metals | | CID001555 | KOREA, REPUBLIC OF | 2 |
| Gold | | SAMWON Metals Corp. | | CID001562 | KOREA, REPUBLIC OF | 3 |
| Gold | | Schone Edelmetaal B.V. | | CID001573 | NETHERLANDS | 1 |
| Gold | | SEMPSA Joyería Platería S.A. | | CID001585 | SPAIN | 1 |
| Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | CID001619 | CHINA | 3 |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | CID001622 | CHINA | 1 |
| Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | CID001736 | CHINA | 1 |
| Gold | | So Accurate Group, Inc. | | CID001754 | UNITED STATES | 3 |
| Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | CID001756 | RUSSIAN FEDERATION | 1 |
| Gold | | Solar Applied Materials Technology Corp. | | CID001761 | TAIWAN | 1 |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | CID001798 | JAPAN | 1 |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | CID001875 | JAPAN | 1 |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | | CID001909 | CHINA | 3 |
| Gold | | The Refinery of Shandong Gold Mining Co., Ltd. | | CID001916 | CHINA | 1 |
| Gold | | Tokuriki Honten Co., Ltd. | | CID001938 | JAPAN | 1 |
| Gold | | Tongling Nonferrous Metals Group Co., Ltd. | | CID001947 | CHINA | 3 |
| Gold | | Torecom | | CID001955 | KOREA, REPUBLIC OF | 2 |
| Gold | | Umicore Brasil Ltda. | | CID001977 | BRAZIL | 1 |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | CID001980 | BELGIUM | 1 |
| Gold | | United Precious Metal Refining, Inc. | | CID001993 | UNITED STATES | 1 |
| Gold | | Valcambi S.A. | | CID002003 | SWITZERLAND | 1 |
| Gold | | Western Australian Mint trading as The Perth Mint | | CID002030 | AUSTRALIA | 1 |
| Gold | | Yamamoto Precious Metal Co., Ltd. | | CID002100 | JAPAN | 1 |
| Gold | | Yokohama Metal Co., Ltd. | | CID002129 | JAPAN | 1 |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | CID002224 | CHINA | 1 |
| Gold | | Zijin Mining Group Co., Ltd. Gold Refinery | | CID002243 | CHINA | 1 |
| Gold | | Morris and Watson | | CID002282 | NEW ZEALAND | 3 |
| Gold | | Guangdong Jinding Gold Limited | | CID002312 | CHINA | 3 |
| Gold | | Umicore Precious Metals Thailand | | CID002314 | THAILAND | 1 |
| Gold | | Faggi Enrico S.p.A. | | CID002355 | ITALY | 2 |
| Gold | | Geib Refining Corporation | | CID002459 | UNITED STATES | 2 |
| Gold | | MMTC-PAMP India Pvt., Ltd. | | CID002509 | INDIA | 1 |
| Gold | | Republic Metals Corporation | | CID002510 | UNITED STATES | 1 |
| Gold | | KGHM Polska Miedź Spółka Akcyjna | | CID002511 | POLAND | 2 |
| Gold | | Fidelity Printers and Refiners Ltd. | | CID002515 | ZIMBABWE | 3 |
| Gold | | Singway Technology Co., Ltd. | | CID002516 | TAIWAN | 1 |
| Gold | | T.C.A S.p.A | | CID002580 | ITALY | 1 |
| Gold | | Korea Zinc Co., Ltd. | | CID002605 | KOREA, REPUBLIC OF | 2 |
| Gold | | SAXONIA Edelmetalle GmbH | | CID002777 | GERMANY | 2 |
| Gold | | WIELAND Edelmetalle GmbH | | CID002778 | GERMANY | 2 |
| Gold | | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | | CID002779 | AUSTRIA | 1 |
* Status Legend:
| |
| 1. | Included on the CFSI’s conflict-free smelter or refiner list. |
| |
| 2. | Has not received a conflict-free designation, but has begun participating in an independent third party audit program. |
| |
| 3. | Has not begun participating in an independent third party audit program. |
Exhibit II
Countries of Origin for the Necessary Conflict Minerals
Based on our due diligence, some of the above SORs process conflict minerals from one or more of the following countries of origin:
Bolivia
Burundi
Democratic Republic of the Congo
Indonesia
Peru
Rwanda
