Exhibit 1.01
Conflict Minerals Report of General Cable Corporation in Accordance with Rule
13p-1 under the Securities Exchange Act of 1934
Introduction
This Conflict Minerals Report (this “Report”) of General Cable Corporation (“General Cable,” “we,” “us,” or “our”) for calendar year 2017 has been prepared in accordance with Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended. Please refer to the Rule, Form SD and Release No. 34-67716 issued by the Securities and Exchange Commission (“SEC”) on August 22, 2012 for definitions to the terms used in this Report, unless otherwise defined herein.
The 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 certain reporting obligations on SEC registrants who manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, “3TG metals”) for the purposes of this assessment. The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. General Cable has determined that certain of its operations manufacture, or contract to manufacture products, which contain 3TG metals that are necessary to the functionality or production of such products.
Description of General Cable’s Products Covered by this Report
This Report relates to products (i) for which conflict minerals are necessary to the functionality or production of those products, (ii) that were manufactured or contracted for manufacture by General Cable, and (iii) for which the manufacture was completed during calendar year 2017 (the “Covered Products”).
Reasonable Country of Origin Inquiry
In accordance with the Rule, General Cable conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the 3TG metals contained in the Covered Products. This good faith RCOI was reasonably designed to determine whether any of such 3TG metals originated in the Covered Countries and whether any of such 3TG metals may be from scrap/recycled sources.
In 2017, General Cable engaged Assent Compliance Inc. (“Assent”) to assist General Cable with its RCOI. Acting on General Cable’s behalf, Assent conducted the supplier survey portion of General Cable’s RCOI. The survey employed the Conflict Minerals Reporting Template (the “CMRT”) developed by the Responsible Minerals Initiative, formerly the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative. The CMRT was created as a common means for the collection of sourcing information related to 3TG metals. It includes questions regarding the supplier’s conflict-free sourcing policy, the engagement process with its direct suppliers, and identification of the smelters used by the supplier.
Suppliers were asked to complete and submit, within a certain time frame, the CMRT. During General Cable’s RCOI, Assent contacted non-responsive suppliers to ensure maximum compliance. Members of Assent made at least three follow-up inquiries to each “failed” supplier who did not respond to the initial survey, by phone or email. Assent reviewed the responses against criteria developed to determine which required further engagement with General Cable’s suppliers. These criteria included incomplete responses as well as inconsistencies within the data reported in the CMRT. Assent worked directly with those suppliers to provide revised responses. General Cable received survey responses from 96 of its 128 total, in-scope, suppliers. Survey responses collectively identified 76 suppliers as potentially having 3TG metals in the products they supply to General Cable.
Through General Cable’s RCOI, some of its suppliers disclosed that scrap/recycled sources of 3TG metals were identified in their supply chains and did not require due diligence. After reviewing the balance of the results of the RCOI and comparing the smelters/refiners identified in the supply-chain survey against verified lists produced by the Responsible Minerals Initiative (RMI), General Cable determined that it had reason to believe that some of the 3TG metals necessary for the functionality of its Covered Products may have originated in a Covered Country. Therefore, General Cable determined that the Rule required that we exercise due diligence on the source and chain of custody of such 3TG metals.
Design of Due Diligence Framework
General Cable designed its due diligence program to conform in all material respects with the OECD (2016) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, an internationally recognized due diligence framework.
Due Diligence Measures Performed
General Cable's due diligence measures included, but were not limited to:
Establishing 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. If a supplier is unwilling to support General Cable in its conflict minerals program efforts, General Cable may take remediation steps, up to and including alternative sourcing arrangements. General Cable may also take remediation steps if a supplier cannot determine whether its materials or products contain Conflict Minerals.
Education and training to company personnel. General Cable has conducted training of personnel who have influence over sourcing decisions on conflict mineral awareness. This training allows General Cable personnel to understand General Cable’s conflict minerals program.
Maintaining a multi-disciplinary internal team to implement our 3TG metals due diligence measures. General Cable maintains a cross-functional conflict minerals team (“Conflict Minerals Team”), including, but not limited to representatives from legal and supply chain, to direct the execution of our conflict minerals compliance program.
Conducting an internal assessment to identify materials that could contain 3TG metals and suppliers who sourced those materials to General Cable. The Conflict Minerals Team reviews changes in the business to determine if material changes have been made in the way General Cable produces its products and/or if changes have been made in the materials used in its products. When new suppliers are added, the Conflict Minerals Team reviews the suppliers for compliance with its Conflict Minerals Policy. General Cable maintains a compliance helpline whereby employees, suppliers, and other third-parties can report concerns or violations of General Cable’s policies. General Cable also maintains an email address (ConflictMinerals@generalcable.com) for parties to report any questions or concerns related to its Conflict Minerals Policy.
Using a third party service, comparing smelters/refiners identified by suppliers to the RMI lists of
verified facilities. In total, General Cable’s suppliers named 7,143 potential smelters/refiners as a result of our survey. For all responses that indicated a smelter/refiner, Assent compared the facilities listed to the list of smelters/refiners maintained by the Responsible Minerals Initiative (RMI). Many of the responses received were duplicates. After eliminating all duplicate and invalid responses, General Cable identified 235 smelters/refiners that may have supplied 3TG metals to its suppliers. Exhibit A contains a list of such known smelters/
refiners reported by General Cable’s suppliers which may have been used to process the 3TG metals utilized in the Covered Products.
If a supplier indicated that the facility was certified as “conflict-free,” Assent confirmed that the name was listed by RMI as a certified conflict-free smelter. Of the 235 smelters/refiners identified by our suppliers, as of May 18, 2018:
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| • | 176 are included on RMI’s conflict-free smelter/refiner lists; |
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| • | 10 have not received a conflict-free designation, but have begun participating in an independent third party audit program; and |
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| • | 49 have not begun participating in an independent third party audit program. |
The vast majority of the responses received provided data at the supplier company level or a division/segment level relative to the supplier, rather than at a level directly relating to a part number that the supplier supplies to General Cable, or were otherwise unable to specify the smelters/refiners used for components supplied to General Cable. General Cable was therefore unable to determine whether any of the 3TG metals that these suppliers reported were contained in components or parts that the suppliers supplied to General Cable or to validate that any of these smelters/refiners were actually in General Cable’s supply chain. Accordingly, we have been unable to definitely link the identified smelters/refiners to only those products/materials in our supply chain; therefore our smelter/refiner list likely contains more processing facilities than are actually in our supply chain or Covered Products. However, based on the information that was obtained, General Cable has reasonably determined that countries of origin of the Conflict Minerals may include the countries listed within Exhibit A.
General Cable is several levels removed from the sources of ores from which 3TG metals contained in the Covered Products are produced and the smelters/refiners that process those ores. General Cable does not make purchases of raw ore or unrefined 3TG metals and makes no purchases in the Covered Countries. General Cable must therefore rely on its suppliers to provide information regarding the origin of the 3TG metals contained in the Covered Products. Accordingly, the efforts we have undertaken to identify the source and chain of custody of the 3TG metals in the Covered Products reflect our circumstances and position in the supply chain. As a result, our inquiry can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the 3TG metals necessary to the functionality of the Covered Products. Our process relies on data obtained directly from our suppliers who seek similar information within their supply chain to identify the original sources of the necessary 3TG metals. Such sources of information may yield inaccurate or incomplete information.
Future Due Diligence Measures
General Cable will continue to take steps to enhance its due diligence program to mitigate the risk that the necessary 3TG metals contained in the Covered Products finance or benefit armed groups in the Covered Countries. The steps include but are not limited to:
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| • | Continuing to engage with suppliers to obtain current, accurate and complete information about the supply chain; |
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| • | Continuing to identify alternative suppliers for vendors not responding timely and sufficiently; |
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| • | Continuing to identify alternative sources for 3TG metals materials; and |
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| • | Continuing to provide internal education and training to company personnel. |
Exhibit A
The information below includes smelter/refiners reported by General Cable’s suppliers, as of May 18, 2018, which may have been used to process the 3TG metals in the Covered Products. However, General Cable cannot confirm which of these smelters/refiners, if any, provided 3TG metals that may be contained in the Covered Products, as General Cable is unable to determine the upstream chain of custody of raw materials in General Cable’s supply chain.
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| Metal | Smelter/Refiner | Status |
| Gold | Abington Reldan Metals, LLC | 3 |
| Gold | Advanced Chemical Company | 1 |
| Gold | African Gold Refinery | 3 |
| Gold | Aida Chemical Industries Co., Ltd. | 1 |
| Gold | Al Etihad Gold LLC | 1 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | 1 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | 1 |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | 1 |
| Gold | Argor-Heraeus S.A. | 1 |
| Gold | Asahi Pretec Corp. | 1 |
| Gold | Asahi Refining Canada Ltd. | 1 |
| Gold | Asahi Refining USA Inc. | 1 |
| Gold | Asaka Riken Co., Ltd. | 1 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | 3 |
| Gold | AU Traders and Refiners | 1 |
| Gold | Aurubis AG | 1 |
| Gold | Bangalore Refinery | 2 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | 1 |
| Gold | Boliden AB | 1 |
| Gold | C. Hafner GmbH + Co. KG | 1 |
| Gold | Caridad | 3 |
| Gold | CCR Refinery - Glencore Canada Corporation | 1 |
| Gold | Cendres + Métaux S.A. | 1 |
| Gold | Chimet S.p.A. | 1 |
| Gold | Chugai Mining | 3 |
| Gold | Daejin Indus Co., Ltd. | 1 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | 3 |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | 3 |
| Gold | DODUCO Contacts and Refining GmbH | 1 |
| Gold | Dowa | 1 |
| Gold | DS PRETECH Co., Ltd. | 2 |
| Gold | DSC (Do Sung Corporation) | 1 |
| Gold | Eco-System Recycling Co., Ltd. | 1 |
| Gold | Elemetal Refining, LLC | 3 |
| Gold | Emirates Gold DMCC | 1 |
| Gold | Fidelity Printers and Refiners Ltd. | 3 |
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| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | 3 |
| Gold | Geib Refining Corporation | 1 |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | 1 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | 3 |
| Gold | Guangdong Jinding Gold Limited | 3 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | 3 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | 3 |
| Gold | HeeSung | 1 |
| Gold | Heimerle + Meule GmbH | 1 |
| Gold | Heraeus Metals Hong Kong Ltd. | 1 |
| Gold | Heraeus Precious Metals GmbH & Co. KG | 1 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | 3 |
| Gold | Hwasung CJ Co., Ltd. | 3 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | 1 |
| Gold | Ishifuku Metal Industry Co., Ltd. | 1 |
| Gold | Istanbul Gold Refinery | 1 |
| Gold | Italpreziosi | 1 |
| Gold | Japan Mint | 1 |
| Gold | Jiangxi Copper Co., Ltd. | 1 |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | 1 |
| Gold | JSC Uralelectromed | 1 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | 1 |
| Gold | Kaloti Precious Metals | 3 |
| Gold | Kazakhmys Smelting LLC | 3 |
| Gold | Kazzinc | 1 |
| Gold | Kennecott Utah Copper LLC | 1 |
| Gold | KGHM Polska Miedz Spolka Akcyjna | 2 |
| Gold | Kojima Chemicals Co., Ltd. | 1 |
| Gold | Korea Zinc Co., Ltd. | 1 |
| Gold | Kyrgyzaltyn JSC | 1 |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | 3 |
| Gold | L'azurde Company For Jewelry | 3 |
| Gold | Lingbao Gold Co., Ltd. | 3 |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | 3 |
| Gold | L'Orfebre S.A. | 2 |
| Gold | LS-NIKKO Copper Inc. | 1 |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | 3 |
| Gold | Marsam Metals | 1 |
| Gold | Materion | 1 |
| Gold | Matsuda Sangyo Co., Ltd. | 1 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | 1 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | 1 |
| Gold | Metalor Technologies (Suzhou) Ltd. | 1 |
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| Gold | Metalor Technologies S.A. | 1 |
| Gold | Metalor USA Refining Corporation | 1 |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | 1 |
| Gold | Mitsubishi Materials Corporation | 1 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | 1 |
| Gold | MMTC-PAMP India Pvt., Ltd. | 1 |
| Gold | Modeltech Sdn Bhd | 2 |
| Gold | Morris and Watson | 3 |
| Gold | Morris and Watson Gold Coast | 3 |
| Gold | Moscow Special Alloys Processing Plant | 1 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | 1 |
| Gold | Navoi Mining and Metallurgical Combinat | 3 |
| Gold | NH Recytech Company | 2 |
| Gold | Nihon Material Co., Ltd. | 1 |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | 1 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | 1 |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | 1 |
| Gold | OJSC Novosibirsk Refinery | 1 |
| Gold | PAMP S.A. | 1 |
| Gold | Pease & Curren | 3 |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | 3 |
| Gold | Planta Recuperadora de Metales SpA | 1 |
| Gold | Prioksky Plant of Non-Ferrous Metals | 1 |
| Gold | PT Aneka Tambang (Persero) Tbk | 1 |
| Gold | PX Précinox S.A. | 1 |
| Gold | Rand Refinery (Pty) Ltd. | 1 |
| Gold | Refinery of Seemine Gold Co., Ltd. | 3 |
| Gold | Remondis Argentia B.V. | 2 |
| Gold | Republic Metals Corporation | 1 |
| Gold | Royal Canadian Mint | 1 |
| Gold | SAAMP | 1 |
| Gold | Sabin Metal Corp. | 3 |
| Gold | Safimet S.p.A | 1 |
| Gold | SAFINA A.S. | 2 |
| Gold | Sai Refinery | 3 |
| Gold | Samduck Precious Metals | 1 |
| Gold | SAMWON Metals Corp. | 3 |
| Gold | SAXONIA Edelmetalle GmbH | 1 |
| Gold | Schone Edelmetaal B.V. | 1 |
| Gold | SEMPSA Joyería Platería S.A. | 1 |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | 3 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | 1 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | 1 |
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| Gold | Singway Technology Co., Ltd. | 1 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | 1 |
| Gold | Solar Applied Materials Technology Corp. | 1 |
| Gold | State Research Institute Center for Physical Sciences and Technology | 3 |
| Gold | Sudan Gold Refinery | 3 |
| Gold | Sumitomo Metal Mining Co., Ltd. | 1 |
| Gold | SungEel HiTech | 1 |
| Gold | T.C.A S.p.A | 1 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | 1 |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | 1 |
| Gold | Tokuriki Honten Co., Ltd. | 1 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | 3 |
| Gold | Tony Goetz NV | 3 |
| Gold | TOO Tau-Ken-Altyn | 3 |
| Gold | Torecom | 1 |
| Gold | Umicore Brasil Ltda. | 1 |
| Gold | Umicore Precious Metals Thailand | 1 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | 1 |
| Gold | United Precious Metal Refining, Inc. | 1 |
| Gold | Universal Precious Metals Refining Zambia | 3 |
| Gold | Valcambi S.A. | 1 |
| Gold | Western Australian Mint trading as The Perth Mint | 1 |
| Gold | WIELAND Edelmetalle GmbH | 1 |
| Gold | Yamamoto Precious Metal Co., Ltd. | 1 |
| Gold | Yokohama Metal Co., Ltd. | 1 |
| Gold | Yunnan Copper Industry Co., Ltd. | 3 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | 1 |
| Tin | Alpha | 1 |
| Tin | An Vinh Joint Stock Mineral Processing Company | 3 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | 1 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | 2 |
| Tin | China Tin Group Co., Ltd. | 1 |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | 3 |
| Tin | CV Ayi Jaya | 1 |
| Tin | CV Dua Sekawan | 1 |
| Tin | CV Gita Pesona | 1 |
| Tin | CV Tiga Sekawan | 1 |
| Tin | CV United Smelting | 1 |
| Tin | CV Venus Inti Perkasa | 1 |
| Tin | Dowa | 1 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | 3 |
| Tin | EM Vinto | 1 |
| Tin | Estanho de Rondônia S.A. | 3 |
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| Tin | Fenix Metals | 1 |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | 1 |
| Tin | Gejiu Jinye Mineral Company | 1 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | 1 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | 1 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | 1 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | 3 |
| Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | 1 |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | 1 |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | 1 |
| Tin | Huichang Jinshunda Tin Co., Ltd. | 1 |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | 1 |
| Tin | Jiangxi New Nanshan Technology Ltd. | 1 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | 1 |
| Tin | Malaysia Smelting Corporation (MSC) | 1 |
| Tin | Melt Metais e Ligas S.A. | 1 |
| Tin | Metallic Resources, Inc. | 1 |
| Tin | Metallo Belgium N.V. | 1 |
| Tin | Metallo Spain S.L.U. | 1 |
| Tin | Mineracao Taboca S.A. | 1 |
| Tin | Minsur | 1 |
| Tin | Mitsubishi Materials Corporation | 1 |
| Tin | Modeltech Sdn Bhd | 2 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | 3 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | 1 |
| Tin | O.M. Manufacturing Philippines, Inc. | 1 |
| Tin | Operaciones Metalurgical S.A. | 1 |
| Tin | Pongpipat Company Limited | 3 |
| Tin | PT Aries Kencana Sejahtera | 1 |
| Tin | PT Artha Cipta Langgeng | 1 |
| Tin | PT ATD Makmur Mandiri Jaya | 1 |
| Tin | PT Babel Inti Perkasa | 1 |
| Tin | PT Bangka Prima Tin | 1 |
| Tin | PT Bangka Serumpun | 1 |
| Tin | PT Bangka Tin Industry | 1 |
| Tin | PT Belitung Industri Sejahtera | 1 |
| Tin | PT Bukit Timah | 1 |
| Tin | PT DS Jaya Abadi | 1 |
| Tin | PT Eunindo Usaha Mandiri | 1 |
| Tin | PT Inti Stania Prima | 1 |
| Tin | PT Karimun Mining | 1 |
| Tin | PT Kijang Jaya Mandiri | 1 |
| Tin | PT Lautan Harmonis Sejahtera | 1 |
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| Tin | PT Menara Cipta Mulia | 1 |
| Tin | PT Mitra Stania Prima | 1 |
| Tin | PT O.M. Indonesia | 1 |
| Tin | PT Panca Mega Persada | 1 |
| Tin | PT Premium Tin Indonesia | 1 |
| Tin | PT Prima Timah Utama | 1 |
| Tin | PT Refined Bangka Tin | 1 |
| Tin | PT Sariwiguna Binasentosa | 1 |
| Tin | PT Stanindo Inti Perkasa | 1 |
| Tin | PT Sukses Inti Makmur | 1 |
| Tin | PT Sumber Jaya Indah | 1 |
| Tin | PT Timah (Persero) Tbk Kundur | 1 |
| Tin | PT Timah (Persero) Tbk Mentok | 1 |
| Tin | PT Tinindo Inter Nusa | 1 |
| Tin | PT Tommy Utama | 1 |
| Tin | Resind Industria e Comercio Ltda. | 1 |
| Tin | Rui Da Hung | 1 |
| Tin | Soft Metais Ltda. | 1 |
| Tin | Super Ligas | 3 |
| Tin | Thaisarco | 1 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | 3 |
| Tin | White Solder Metalurgia e Mineração Ltda. | 1 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | 1 |
| Tin | Yunnan Tin Company Limited | 1 |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | 1 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | 1 |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | 1 |
* Status Legend:
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| 1. | Included on RMI’s conflict-free smelter/refiner list. |
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| 2. | Has not received a conflict-free designation, but has begun participating in an independent third party audit program. |
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| 3. | Has not begun participating in an independent third party audit program. |
Countries of origin identified:
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.
Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe
