Exhibit 1.01
Badger Meter, Inc.
Conflict Minerals Report
For the Reporting Period from January 1, 2017 to December 31, 2017
This report for the period from January 1, 2017 to December 31, 2017 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (the Rule). The Rule was adopted to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Rule imposes reporting obligations on Securities and Exchange Commission (SEC) registrants whose manufactured products contain certain minerals which are necessary to the functionality or production of their products.
If a registrant determines that any columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten (Subject Minerals), are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured, the registrant must conduct in good faith a Reasonable Country of Origin Inquiry (RCOI) regarding those Subject Minerals that is reasonably designed to determine whether any of the Subject Minerals originated in the Democratic Republic of the Congo or an adjoining country (Covered Countries) or are from recycled or scrap sources.
If, following the completion of the RCOI, a registrant knows that any of the necessary Subject Minerals originated in a Covered Country and are not from recycled or scrap sources, or has reason to believe that its necessary Subject Minerals may have originated in the Covered Countries and has reason to believe that its necessary Subject Minerals did not come from recycled or scrap sources, then the registrant must exercise due diligence on the source and chain of custody of the Subject Minerals that conforms to a nationally or internationally recognized due diligence framework and describe such due diligence in this separate Conflict Minerals Report.
In accordance with the Organisation for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, the related supplements on tin, tungsten, tantalum and gold (the Guidance) and the Rule, this report is available on our website at https://www.badgermeter.com/supply-chain/.
Consistent with the provisions of the Rule, the SEC’s Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule, dated April 29, 2014, the SEC’s Order Issuing Stay, dated May 2, 2014, and the SEC’s Updated Statement on the Effect of the Court of Appeals Decision on the Conflict Minerals Rule, dated April 7, 2017, this Conflict Minerals Report has not been audited by a third party.
1. Company Overview
This report has been prepared by the management of Badger Meter, Inc. (herein referred to as Badger Meter, the Company, we, us or our). The information includes the activities of all majority-owned subsidiaries that are required to be consolidated.
Badger Meter is an innovator in flow measurement, control and communications solutions, serving water utilities, municipalities and commercial and industrial customers worldwide. Our products measure water, oil, chemicals and other fluids, and are known for accuracy, long-lasting durability and for providing and communicating valuable and timely measurement data. Our product lines fall into two categories: sales of water meters and related technologies to municipal water utilities (municipal water) and sales of meters to various industries for water and other fluids (flow instrumentation). We estimate that over 85% of our products are used in water applications when both categories are grouped together.
Supply Chain
Because Badger Meter does not deal directly with mineral processors like smelters and refiners, we rely on our direct suppliers to provide origin information on all applicable minerals contained in components or materials supplied to us. We also request that our suppliers advise Badger Meter of any sources of conflict minerals that are supplied to them from their suppliers.
2. Reasonable Country of Origin Inquiry
In order to determine the origin of the Subject Minerals used in the manufacture of our products, Badger Meter conducted a RCOI in good faith. To complete the RCOI, Badger Meter surveyed its suppliers using the Responsible Minerals Initiative (RMI)’s Conflict Minerals Reporting Template (further described in Section 3 below).
It is not practical to survey the entirety of our supplier base; therefore, we restricted our survey to suppliers providing products containing Subject Minerals. We then prioritized our list of suppliers by spending and administered the surveys. The goal was to capture information from the suppliers representing the majority of Badger Meter’s purchases of these products.
Survey Responses
As part of our RCOI, Badger Meter surveyed 1,089 direct suppliers. We received responses from 71% of the suppliers surveyed (which represents 79% of our overall purchases). We reviewed these responses to ensure each response was complete and consistent with the reported data and followed up with suppliers whose responses did not meet these criteria to obtain more accurate responses.
A majority of the responses received were provided at a company level, many of which did not specify the smelters or refiners used for components supplied to Badger Meter. For responses that did not specify smelters or refiners, Badger Meter contacted the corresponding suppliers to request complete information.
Among the supplier responses we received that we determined contained complete, valid information, we received the following information:
| · | Approximately 85% of supplier responses indicated that, to the best of such supplier’s knowledge, the Subject Minerals in the components and materials that it supplied to Badger Meter in 2017 did not originate from a Covered Country; and |
| · | Approximately 15% of supplier responses indicated that, to the best of such supplier’s knowledge, the Subject Minerals in the components and materials that it supplied to Badger Meter in 2017 may have originated in a Covered Country. |
Based on the results above, Badger Meter determined that it had reason to believe that, during 2017, Subject Minerals necessary for the functionality or production of its products may have originated from a Covered Country and may not be from recycled or scrap sources. Badger Meter conducted its RCOI in good faith, and it believes that such inquiry was reasonable to allow it to make the determination. Accordingly, Badger Meter proceeded to exercise due diligence on the source and chain of custody of the Subject Minerals (further described in Section 3 below).
3. Due Diligence Process
Our due diligence measures have been designed to conform to the framework provided in the Guidance.
| 3.1 | Establish Strong Company Management Systems |
Conflict Minerals Policy
We have adopted the following conflict minerals policy:
Badger Meter is committed to working with our global supply chain to ensure compliance with the SEC’s conflict minerals rules. We have established a conflict minerals compliance program that is designed to follow the framework established by the OECD. Our enterprise is fully engaged in implementing that program.
Our standard purchase order terms and conditions, used with suppliers, have been updated to include conflict mineral due diligence and reporting requirements. Any direct sourcing by Badger Meter of tin, tungsten, tantalum and gold will not be intentionally sourced from conflict sources. As we become aware of instances where minerals in our supply chain potentially finance armed groups, as discussed in the Rule, we will work with our suppliers to find alternate conflict-free sources.
We are committed to promoting economic development in Africa through responsible commercial engagement, driving employee awareness, as well as through our corporate citizenship activities.
Management Team
Badger Meter has designated its Import/Export, Purchasing, and Cost Accounting departments as the departments responsible for overseeing our conflict minerals due diligence efforts. The Import/Export department is responsible for reporting on due diligence efforts to Badger Meter’s senior management, as well as coordinating due diligence efforts with Badger Meter’s suppliers and third-party consultants.
Supply Chain Controls
As discussed above, Badger Meter does not deal directly with the smelters and refiners in our supply chain. Instead, we rely on the information provided to us by our direct suppliers, as well as third-party verification programs like the RMI’s Responsible Minerals Assurance Process, to identify and verify the smelters and refiners in our supply chain.
Engagement with Suppliers
Badger Meter continually strives to make conflict minerals compliance an integral part of its relationships with its direct suppliers. Through a third party, we communicate our expectations regarding conflict minerals compliance to our direct suppliers on an annual basis, and undertake multiple rounds of engagement with suppliers who are unable or unwilling to meet the requirements of our conflict minerals policy. Additionally, as part of our current sourcing processes, we conduct a review of a new supplier’s conflict mineral due diligence practices prior to sourcing material from them.
Grievance Mechanisms
Any individual or company that has a reasonable suspicion that conflict minerals are present in Badger Meter’s supply chain should alert Badger Meter or our third-party conflict mineral management team of the specifics regarding the suspicion. Badger Meter will perform due diligence on any reasonable inquiries, and will address any conflict minerals that are identified with the offending supplier.
| 3.2 | Identify and Assess Risk in the Supply Chain |
To identify and assess the risk in our supply chain, Badger Meter contracted with a third-party company to manage our conflict mineral survey process. The third-party contractor was responsible for contacting suppliers, collecting responses and reviewing the responses for completeness, inconsistencies, errors and applicability. In performing its survey, the contractor used the RMI’s Conflict Minerals Reporting Template, which was developed to facilitate disclosure and communication of information regarding refiners and smelters that provide material to a company’s supply chain.
After determining the full list of smelters and refiners (as reported by our suppliers) involved in processing the minerals used in materials and components supplied to Badger Meter, we cross-checked those smelters and refiners against lists published by various third-party audit programs, such as the RMI’s Responsible Minerals Assurance Process, as well as the U.S. Department of Commerce’s list of all known mineral processing facilities worldwide, published in September 2014. Based on these cross-checks, we were able to determine the relative level of risk with respect to conflict minerals within our supply chain.
| 3.3 | Design and Implement a Strategy to Respond to Risks |
After identifying the relative level of risk within our supply chain, we designed and implemented a strategy to respond to those risks.
In the event that we could not verify that a particular smelter or refiner was conflict-free based on third-party audit programs, we (1) engaged with the smelter or refiner, either directly or through our supplier, to determine the status of its efforts to become verified as conflict-free and (2) directed our suppliers to ensure that all smelters and refiners in their supply chains are either verified as conflict-free or publicly committed to becoming so. Suppliers and smelters or refiners who refuse to move toward conflict-free status run the risk of being removed from our supply chain.
| 3.4 | Third-Party Audits of Supply Chain Due Diligence at Identified Points in the Supply Chain |
As discussed above, Badger Meter does not have a direct relationship with the smelters and refiners in its supply chain and does not perform or direct audits of those entities. Instead, Badger Meter supports third-party audits through engagement with its direct suppliers and makes use of the resources provided by third-party audit programs like the RMI’s Responsible Minerals Assurance Process.
| 3.5 | Report on Supply Chain Due Diligence |
This Conflict Minerals Report is being filed with the SEC as an exhibit to Badger Meter’s specialized disclosure report on Form SD and is available on our website at https://www.badgermeter.com/supply-chain/.
4. Due Diligence Results
As a result of the due diligence measures described above, Badger Meter believes that, to the best of its knowledge, the smelters and refiners listed in Annex I to this report may have processed the Subject Minerals in products manufactured by Badger Meter. Because a majority of the responses received were provided at a company level, we are unable to associate specific smelters or refiners with specific components supplied to—and therefore specific products manufactured by—Badger Meter.
Badger Meter does not have sufficient information to conclusively determine the countries of origin of the Subject Minerals used in its products. However, based on the information provided by the suppliers, smelters and refiners in Badger Meter’s supply chain, as well as other publicly available sources of information, Badger Meter believes that the countries of origin of its Subject Minerals include the countries listed in Annex II to this report. Badger Meter also believes that some of the Subject Minerals in its products may have come from scrap or recycled sources.
Of the 383 smelters and refiners identified for calendar year 2017, 196 were verified as conformant under the Responsible Minerals Assurance Process, while 187 have not been verified as conformant under the Responsible Minerals Assurance Process. Of the 187 smelters and refiners that have not been verified as conformant, Badger Meter identified one tantalum smelter that may be sourcing its ore from the Covered Countries. Overall, based on information received from the suppliers, smelters and refiners in its supply chain, Badger Meter has no reason to believe any of the facilities not verified as conformant with the Responsible Minerals Assurance Process have sourced Subject Minerals that directly or indirectly finance or benefit armed groups.
5. Steps Taken to Mitigate Risk
Since the end of the period covered in our most recent Conflict Minerals Report, which was filed with the SEC on May 31, 2017, we have implemented the following continuous processes to improve our due diligence and mitigate the risk of conflict minerals entering our supply chain:
| · | Continue working with suppliers to help them understand Badger Meter’s expectations regarding due diligence over the Subject Minerals in our supply chain, including our suppliers’ due diligence over their own supply chains; |
| · | Communicate our expectation to our suppliers that they transition their supply chain toward smelters and refiners verified as conformant by the RMI’s Responsible Minerals Assurance Process; |
| · | For suppliers who cannot immediately transition to a conflict-free supply chain, request that those suppliers develop, communicate, and implement a plan to source from conflict-free smelters and refiners in the future; and |
| · | Engage with industry programs to encourage the adoption and improvement of relevant tools and standards. |
In addition, we are considering contacting smelters and refiners identified in our due diligence whom have not been verified by RMI as conformant with the Responsible Minerals Assurance Process with the goal of improving our supply chain and decreasing the potential for conflict material to enter our supply chain.
6. Forward-Looking Statements
Certain statements contained in this Conflict Minerals Report may contain forward-looking statements that involve risks and uncertainties that could cause actual results to differ materially from those in the forward-looking statements. The words “anticipate,” “believe,” “estimate,” “expect,” “think,” “should,” “could” and “objective” or similar expressions are intended to identify forward-looking statements. All such forward-looking statements are based on our then-current views and assumptions and involve risks and uncertainties. Some risks and uncertainties that could cause actual results to differ materially from those expressed or implied in forward looking statements include, among other things, our suppliers’ willingness and ability to comply with our conflict minerals-related compliance requests, the degree to which we are able to determine our suppliers’ use of conflict-free smelters and refiners, the impact of industry-wide initiatives like the Responsible Minerals Assurance Process, smelters’ and refiners’ willingness and ability to comply with the Responsible Minerals Assurance Process, our effectiveness in managing the conflict minerals RCOI and due diligence processes, and the costs of our compliance. All of these factors are beyond our control to varying degrees. Shareholders, potential investors and other readers are urged to consider these factors carefully in evaluating the forward-looking statements contained in this Conflict Minerals Report and are cautioned not to place undue reliance on such forward-looking statements. The forward-looking statements made in this document are made only as of the date of this document and we assume no obligation, and disclaim any obligation, to update any such forward-looking statements to reflect subsequent events or circumstances.
Annex I
List of Smelters and Refiners
| Mineral | Smelter or Refiner Name | Location |
| Gold | Abington Reldan Metals, LLC | United States |
| Gold | Advanced Chemical Company | United States |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Aktyubinsk Copper Company TOO | Kazakhstan |
| Gold | Al Etihad Gold LLC | United Arab Emirates |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | Brazil |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Gold | Asahi Pretec Corp. | Japan |
| Gold | Asahi Refining Canada Ltd. | Canada |
| Gold | Asahi Refining USA Inc. | United States |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | AU Traders and Refiners | South Africa |
| Gold | AURA-II | United States |
| Gold | Aurubis AG | Germany |
| Gold | Bangalore Refinery | India |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philppines |
| Gold | Bauer Walser AG | Germany |
| Gold | Boliden AB | Sweden |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | Caridad | Mexico |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Cendres + Métaux S.A. | Switzerland |
| Gold | Chimet S.p.A. | Italy |
| Gold | China Gold International Resources Corp. Ltd. | China |
| Gold | Chugai Mining | Japan |
| Gold | Codelco | Chile |
| Gold | Daejin Indus Co., Ltd. | Korea, Republic of |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | DODUCO GmbH | Germany |
| Gold | Dowa | Japan |
| Gold | DSC (Do Sung Corporation) | Korea, Republic of |
| Gold | Eco-System Recycling Co., Ltd. | Japan |
| Gold | Elemetal Refining, LLC | United States |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | Faggi Enrico S.p.A. | Italy |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | China |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Geib Refining Corporation | United States |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | Harmony Gold Refinery | South Africa |
| Gold | HeeSung Metal Ltd. | Korea, Republic of |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Heraeus Ltd. Hong Kong | China |
| Gold | Heraeus USA | United States |
| Gold | Hon Shen Co., Ltd. | Taiwan |
| Gold | HwaSeong CJ Co., Ltd. | Korea, Republic of |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Italpreziosi | Italy |
| Gold | Japan Mint | Japan |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Kaloti Precious Metals | United Arab Emirates |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Kazzinc | Kazakhstan |
| Gold | Kennecott Utah Copper LLC | United States |
| Gold | KGHM Polska Miedź Spółka Akcyjna | Poland |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Korea Metal Co., Ltd. | Korea, Republic of |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic of |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | KYSHTYM COPPER-ELECTROLYTIC PLANT ZAO | Russian Federation |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | L'Orfebre S.A. | Andorra |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Marsam Metals | Brazil |
| Gold | Materion | United States |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold | Metalor Technologies (Suzhou) Ltd. | China |
| Gold | Metalor Technologies SA | Switzerland |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | Mexico |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | Morris and Watson | New Zealand |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| 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 | Japan |
| Gold | Pease & Curren | United States |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| 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 Précinox S.A. | Switzerland |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | Remondis Argentia B.V. | Netherlands |
| Gold | Republic Metals Corporation | United States |
| Gold | Royal Canadian Mint | Canada |
| Gold | SAAMP | France |
| Gold | Sabin Metal Corp. | United States |
| Gold | SAFINA A.S. | Czech Republic |
| Gold | Sai Refinery | India |
| Gold | Samduck Precious Metals | Korea, Republic of |
| Gold | Samwon Metals Corp. | Korea, Republic of |
| Gold | SAXONIA Edelmetalle GmbH | Germany |
| Gold | Schone Edelmetaal B.V. | Netherlands |
| Gold | SEMPSA Joyería Platería S.A. | Spain |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Shangdong Zhaojin Gold & Silver Refinery Co. Ltd. | China |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | Singway Technology Co., Ltd. | Taiwan |
| Gold | So Accurate Group, Inc. | United States |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Solar Applied Materials Technology Corp. | Taiwan |
| Gold | Souzhou XingRui Noble | China |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | SungEel HiTech | Korea, Republic of |
| Gold | T.C.A S.p.A | Italy |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | The Great Wall Gold and Silver Refinery of China | China |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| 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 |
| Gold | Valcambi S.A. | Switzerland |
| Gold | Western Australian Mint trading as The Perth Mint | Australia |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | China |
| Tantalum | A&M Minerals Ltd. | Rwanda |
| Tantalum | Avon Specialty Metals Ltd | United Kingdom |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
| Tantalum | Changsha Southern | China |
| Tantalum | D Block Metals, LLC | United States |
| Tantalum | Duoluoshan | China |
| Tantalum | E.S.R. Electronics | United States |
| Tantalum | Exotech Inc. | United States |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Tantalum | Gannon & Scott | United States |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | China |
| Tantalum | H.C. Starck Co., Ltd. | Thailand |
| Tantalum | H.C. Starck GmbH Goslar | Germany |
| Tantalum | H.C. Starck Inc. | United States |
| Tantalum | H.C. Starck Ltd. | Japan |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | Hi-Temp Specialty Metals, Inc. | United States |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | KEMET Blue Metals | Mexico |
| Tantalum | KEMET Blue Powder | United States |
| Tantalum | King-Tan Tantalum Industry Ltd. | China |
| Tantalum | LSM Brasil S.A. | Brazil |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | Mineração Taboca S.A. | Brazil |
| Tantalum | Molycorp Silmet A.S. | Estonia |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | Plansee | Austria |
| Tantalum | Plansee SE Liezen | Austria |
| Tantalum | Plansee SE Reutte | Austria |
| Tantalum | Power Resources Ltd. | Macedonia |
| Tantalum | QuantumClean | United States |
| Tantalum | Resind Indústria e Comércio Ltda. | Brazil |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | Tantalite Resources | South Africa |
| Tantalum | Telex Metals | United States |
| Tantalum | Tranzact, Inc. | United States |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | China |
| Tin | 5NPlus | United Kingdom |
| Tin | Alpha | United States |
| Tin | Alpha Metals Korea Ltd. | Korea, Republic of |
| Tin | Aluminium Alloy Smelter Ind. Sdn. Bhd. | Malaysia |
| Tin | Amalgamated Metal Corporation Ketabang | United Kingdom |
| Tin | American Iron & Metal | Canada |
| Tin | An Thai Minerals Co., Ltd. | Vietnam |
| Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam |
| Tin | Ausmelt Limited | Australia |
| Tin | Baoshida Swissmetal | Switzerland |
| Tin | BNT Chemicals Gmbh | Germany |
| Tin | BRITANNIA REFINED METALS LTD. | United Kingdom |
| Tin | Butterworth Smelter | Malaysia |
| Tin | Chengli Hanxi Co.Ltd | China |
| Tin | China Hongqiao Group Limited | China |
| Tin | China Tin Group Co., Ltd. | China |
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | China |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tin | Colonial Metals Co | United States |
| Tin | Cookson | United States |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | Brazil |
| Tin | CUSTOM ALLOY LIGHT METALS INC | United States |
| Tin | CV Ayi Jaya | Indonesia |
| Tin | CV Dua Sekawan | Indonesia |
| Tin | CV Gita Pesona | Indonesia |
| Tin | CV JusTindo | Indonesia |
| Tin | CV Serumpun Sebalai | Indonesia |
| Tin | CV Tiga Sekawan | Indonesia |
| Tin | CV United Smelting | Indonesia |
| Tin | CV Venus Inti Perkasa | Indonesia |
| Tin | Da Nang Processing Import and Export Joint Stock | Vietnam |
| Tin | Daewoo International | Korea, Republic of |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam |
| Tin | Elmet S.L.U. | Spain |
| Tin | EM Vinto | Bolivia |
| Tin | Estanho de Rondônia S.A. | Brazil |
| Tin | Feinhütte Halsbrücke GmbH | Germany |
| Tin | Fenix Metals | Poland |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | China |
| Tin | Gejiu Jinye Mineral Company | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
| Tin | Guangxi Crystal Union Photoelectric Materials Co., Ltd. | China |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China |
| Tin | Heraesu Materials Technology GmbH & Co.Ltd | China |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
| Tin | Huichang Jinshunda Tin Co., Ltd. | China |
| Tin | Hyundai-Steel | Korea, Republic of |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | China |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | MALAYSIAN ALUMINIUM & ALLOYS SDN BHD | Malaysia |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | Metahub Industries Sdn. Bhd. | Malaysia |
| Tin | Metallic Resources, Inc. | United States |
| Tin | Metallo Belgium NV | Belgium |
| Tin | Metallo Chimique N.V. | Belgium |
| Tin | Mimmetal | China |
| Tin | Mineração Taboca S.A. | Brazil |
| Tin | Minsur S.A. Tin Metal | Peru |
| Tin | Modeltech Sdn Bhd | Malaysia |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | China |
| Tin | Nathan Trotter & Co | United States |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | Nikkei MC Aluminum Co., Ltd | Japan |
| Tin | Novosibirsk Processing Plant Ltd. | Russian Federation |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | Operaciones Metalurgical S.A. | Bolivia |
| Tin | Phoenix Metal Ltd. | Rwanda |
| Tin | PT Alam Lestari Kencana | Indonesia |
| Tin | PT Aries Kencana Sejahtera | Indonesia |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin | PT Babel Inti Perkasa | Indonesia |
| Tin | PT Bangka Kudai Tin | Indonesia |
| Tin | PT Bangka Prima Tin | Indonesia |
| Tin | PT Bangka Putra Karya | Indonesia |
| Tin | PT Bangka Timah Utama Sejahtera | Indonesia |
| Tin | PT Bangka Tin Industry | Indonesia |
| Tin | PT Belitung Industri Sejahtera | Indonesia |
| Tin | PT BilliTin Makmur Lestari | Indonesia |
| Tin | PT Bukit Timah | Indonesia |
| Tin | PT Cipta Persada Mulia | Indonesia |
| Tin | PT DS Jaya Abadi | Indonesia |
| Tin | PT Eunindo Usaha Mandiri | Indonesia |
| Tin | PT Fang Di MulTindo | Indonesia |
| Tin | PT Inti Stania Prima | Indonesia |
| Tin | PT Karimun Mining | Indonesia |
| Tin | PT Kijang Jaya Mandiri | Indonesia |
| Tin | PT Koba Tin | Indonesia |
| Tin | PT Lautan Harmonis Sejahtera | Indonesia |
| Tin | PT Menara Cipta Mulia | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | PT O.M. Indonesia | Indonesia |
| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Pelat Timah Nusantara Tbk | Indonesia |
| Tin | PT Prima Timah Utama | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
| Tin | PT Sariwiguna Binasentosa | Indonesia |
| Tin | PT Seirama Tin Investment | Indonesia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
| Tin | PT Sukses Inti Makmur | Indonesia |
| Tin | PT Sumber Jaya Indah | Indonesia |
| Tin | PT Supra Sukses Trinusa | Indonesia |
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia |
| Tin | PT Timah (Persero), Tbk | Indonesia |
| Tin | PT Tinindo Inter Nusa | Indonesia |
| Tin | PT Tirus Putra Mandiri | Indonesia |
| Tin | PT Tommy Utama | Indonesia |
| Tin | PT Wahana Perkit Jaya | Indonesia |
| Tin | PT Yinchendo Mining Industry | Indonesia |
| Tin | Rui Da Hung | Taiwan |
| Tin | SENJU METAL INDUSTRY CO.,LTD. | Japan |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | Super Ligas | Brazil |
| Tin | TCC Steel | Korea, Republic of |
| Tin | Thailand Smelting & Refining Co., Ltd. | Thailand |
| Tin | Thaisarco | Thailand |
| Tin | Tianjin Yishang chemical trade Co.,LTD | China |
| Tin | Tong Ding Metal Materials Co., Ltd. | China |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | VQB Mineral and Trading Group JSC | Vietnam |
| Tin | Yannan Tin Group (Holding) Co., Ltd | China |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Tin | Yunnan Tin Group (Holding) Company Limited | China |
| Tungsten | Hitachi Metals, Ltd.,
Yasugi Works | Japan |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Alldyne Powder Technologies | United States |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam |
| Tungsten | Axis Material Limited | Japan |
| Tungsten | Buffalo Tungsten Inc | United States |
| Tungsten | ChangChun up-optech | China |
| Tungsten | Chenbdu Hongbo Industrial Co.,ltd | China |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | CWB | United States |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | China |
| Tungsten | Ganzhou Haichuang Tungsten Industry 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 | Ganzhou Yatai Tungsten Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders Corp. | United States |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | HC Stack | United States |
| Tungsten | Hitachi Metals, Ltd., Yasugi Works | Japan |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Tungsten | Hunan Chunchang Nonferrous Metals 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 Dayu Longxintai Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Jiangxi Rare Earth & Rare Metals Tungsten Group Corp | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | Kennametal Fallon | United States |
| Tungsten | Kennametal Huntsville | United States |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Metal Management Aerospace | United States |
| Tungsten | Moliren Ltd | Russian Federation |
| Tungsten | Niagara Refining LLC | United States |
| Tungsten | North American Tungsten Corporation Ltd. | Canada |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philppines |
| Tungsten | Pobedit, JSC | Russian Federation |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam |
| Tungsten | Voss Metals Company, Inc. | Japan |
| Tungsten | Wolfram Bergbau und Hütten AG | Austria |
| Tungsten | Woltech Korea Co., Ltd. | Korea, Republic of |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
Annex II
List of Countries of Origin for Subject Minerals
| Andorra | New Zealand |
| Australia | Peru |
| Austria | Philippines |
| Belgium | Poland |
| Bolivia | Russian Federation |
| Brazil | Rwanda |
| Canada | Saudi Arabia |
| Chile | Singapore |
| China | South Africa |
| Czech Republic | South Korea |
| Estonia | Spain |
| France | Sudan |
| Germany | Sweden |
| India | Switzerland |
| Indonesia | Taiwan |
| Italy | Thailand |
| Japan | Turkey |
| Kazakhstan | United Arab Emirates |
| Kyrgyzstan | United Kingdom |
| Lithuania | United States of America |
| Macedonia | Uzbekistan |
| Malaysia | Vietnam |
| Mexico | Zimbabwe |
| Netherlands | |
