Form SD TRIMBLE INC.
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E-mailUNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
TRIMBLE INC.
(Exact name of registrant as specified in its charter)
| Delaware | 001-14845 | 94-2802192 | ||||||||||||
| (State or other jurisdiction of incorporation) | (Commission File Number) | (IRS. Employer Identification No.) | ||||||||||||
935 Stewart Drive
Sunnyvale, CA 94085
(Address of principal executive offices)
James A. Kirkland
Senior Vice President, General Counsel and Secretary
(408) 481-8000
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022.
☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended .
Section 1 - Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit
A copy of Trimble Inc.’s Conflict Minerals Report is provided as Exhibit 1.01 to this Report and is available at the following address:
https://www.trimble.com/en/our-commitment/responsible-business/product-compliance/conflict-minerals-policy
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable.
Section 3 - Exhibits
Item 3.0.1 Exhibits
| Exhibit No. | Description | ||||
| 1.01 | |||||
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| TRIMBLE INC. | ||||||||
| /s/ JAMES A. KIRKLAND | ||||||||
| By: | James A. Kirkland, Senior Vice President, General Counsel and Secretary | |||||||
| Date: | May , 2022 | |||||||
Exhibit 1.01
Trimble Inc.
Conflict Minerals Report for the Year Ended December 31, 2021
The following conflict minerals report contains forward-looking statements about our plans to take additional actions or to implement additional policies or procedures with respect to our due diligence efforts to determine the origin of conflict minerals contained in our products. We undertake no obligation to publicly update or revise any forward-looking statement, whether as a result of new information, future events or otherwise. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report.
This is the Conflict Minerals Report of Trimble Inc. for the 2021 calendar year in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.
Rule 13p-1 requires that all public companies report annually on the presence of certain minerals, characterized as conflict minerals, including tin, tantalum, tungsten or gold (“3TG” or “conflict minerals”), in the products that they manufacture or contract to manufacture, and demonstrate the proper level of due diligence in determining whether these minerals originated from the Democratic Republic of the Congo or an adjoining country (collectively, “Covered Countries”) or from scrap or recycled sources, and whether they directly or indirectly finance or benefit armed groups in the Covered Countries.
Introduction
Trimble provides technology solutions that enable professionals and field mobile workers to improve or transform their work processes. Our solutions, which can include a combination of hardware, software and services, are used across a range of industries including agriculture, architecture, civil engineering, construction, survey and geospatial, government, natural resources, transportation and utilities.
Representative Trimble customers include engineering and construction firms, contractors, surveying companies, farmers and agricultural companies, enterprise firms with large-scale fleets, energy and utility companies, and state, federal and municipal governments.
We design and manufacture, or have manufactured on our behalf, thousands of different hardware products ranging across multiple business divisions within our key business segments of Buildings and Infrastructure, Geospatial, Resources and Utilities, and Transportation. Many of these hardware products, which are typically based upon positioning or location technologies, including Global Navigation Satellite Systems (GNSS), lasers and optics, are built by our contract manufacturing partners.
Our contract manufacturing partners are responsible for significant material procurement, assembly, and testing. We generally manage product design and are involved in qualifying suppliers and key components used in our products. We are many levels removed from the mining or processing of minerals in our supply chain, however, and we do not directly source, or manage the sourcing of, raw materials, including conflict minerals.
Many of our hardware products are designed with printed circuit boards, connectors, sheet metal and other electrical mechanical assemblies that may contain conflict minerals. The components used in our products that contain these metals are required for the functionality of our products.
Trimble’s Conflict Minerals Program
Trimble is committed to sourcing components and materials from companies that share our values concerning human rights, ethics and environmental responsibility. Our Conflict Minerals Policy Statement, as well as our current Conflict Minerals Report, are published on our public website and available at:
www.trimble.com/en/our-commitment/responsible-business/product-compliance/conflict-minerals-policy
We focus our due diligence efforts on determining the source and chain of custody of conflict minerals in the components and materials that are supplied to us. Tracing conflict minerals back to their country of origin, though, is a complex task that requires, among other things, screening for the possible presence of 3TG in parts or
materials provided by our contract manufacturers and direct suppliers (which we refer to as “in-scope suppliers”), and then surveying such in-scope suppliers to understand what programs they have in place for tracing the source of minerals included in products or components supplied to us. Suppliers are deemed out-of- scope and not surveyed if they only provide software, plastic, packaging materials or other items that do not contain 3TG.
Trimble uses as its standard reporting template, and requires its in-scope suppliers to use, the Responsible Minerals Initiative’s (“RMI”) reporting template to identify whether in-source suppliers source 3TG from the Covered Countries or from recycled or scrap sources. The RMI reporting template (known as the Conflict Minerals Reporting Template or “CMRT”) is a key part of our due diligence efforts and is used to determine the source and chain of custody of 3TG in the components and materials that are supplied to us. We rely on the information provided through the CMRT by our supply chain, as well as smelter information provided by the RMI and other industry organizations, to complete our Conflict Minerals Report.
As part of our supplier risk assessment, we require new suppliers to go through a screening and approval process so we can assess their use of 3TG and determine whether they are in-scope suppliers. We provide an initial survey to assess their use of 3TG and to understand their business processes. We also inform new suppliers of our “Supplier Requirements for the Sourcing of Conflict Minerals,” which further describe our Conflict Minerals Program goals and expectations. Additionally, we have established a Supplier Code of Conduct, which is based upon the Responsible Business Alliance (RBA) Code of Conduct. We require our suppliers to adhere to our Supplier Code of Conduct and RBA standards, including any subsequent amendments or updates.
Trimble requires in-scope suppliers to source from smelters that are either conformant with the Responsible Minerals Assurance Process (“RMAP”), have undergone another recognized third-party audit program (such as the London Bullion Market Association (LBMA) or the Responsible Jewellery Council (RJC)), or are in the process of achieving audit conformance. In the event of non-conformance by an in-scope supplier, we require the supplier to pursue corrective actions, and, in the event of continued non-conformance, we may consider termination of the supplier.
Reasonable Country of Origin Inquiry (“RCOI”)
Since conflict minerals are necessary to the functionality of many of our hardware products, we conducted an RCOI to determine the origin of the 3TG present in our products delivered to customers.
Given the complex nature of our supply chain and our extensive parts inventory, we assess our in-scope suppliers in three separate phases: (i) we first assess suppliers of parts containing 3TG that are used in the bill of materials for products that we are actively producing; (ii) we then review those suppliers that manufacture and sell to us their parts and components; and (iii) finally, we review suppliers of the companies and businesses that we acquire.
After conducting our three-phase assessment, we conduct an annual supply chain survey requesting in-scope suppliers to provide a conflict minerals declaration, using the CMRT. This survey is intended to identify the conflict minerals contained in the products that suppliers provide to Trimble, the smelters and the refiners that processed those conflict minerals, and the country of origin of those conflict minerals. In 2021, we received a 95% response rate, which is similar to our previous year’s response rate. Based on the responses from our in-scope suppliers and a review and analysis of the responses against RMI’s RMAP Conformant Smelters & Refiners list, which provides sourcing information and audit status for certified smelters (as well as sourcing information for LBMA and RJC audited smelters) we concluded that, of the identified smelters:
•79% were identified as being Conformant (i.e. smelters that have completed an audit and conform with RMAP or another third-party program) or otherwise validated as existing smelters.
•Of these smelters, 32% reported sourcing from Covered Countries.
Based on our internal assessment of in-scope suppliers and the CMRT information we received back from our in-scope suppliers, we determined that it was necessary to exercise due diligence to determine the source and chain of custody of the conflict minerals contained in our products.
Trimble Due Diligence
We have designed our due diligence program to conform, in all material respects, with the framework in the “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition),” and the related supplements, published by the Organisation for Economic Co-operation and Development (OECD).
The ongoing worldwide COVID-19 coronavirus pandemic in 2021 continued to significantly impact the operation of mines and processing facilities and disrupted mineral resource supply chains. In addition to facility closures and disruption to international shipments of minerals, there was also a significant impact on the ability of organizations to assess smelters and conduct audits in the face of local quarantines and closures. This impacted the accuracy and completeness of information available to us in conducting our due diligence activities for 2021.
Additionally, the war in Ukraine and resulting U.S. government sanctions against Russia have impacted the information we have about, and the status of, certain Russian-based smelters. The RMI smelters database has been updated to reflect the LBMA's Good Delivery List suspensions for six Russia-based gold refiners, which are now classified as high risk by the Responsible Business Alliance (RBA) and its Responsible Minerals Initiative (RMI). These smelters are also included on Trimble’s list of high risk suppliers.
The following describes Trimble’s due diligence activities for the 2021 reporting year.
Step 1: Establish Strong Company Management Systems
•We have made our Conflict Minerals Policy, described above, publicly available on our website.
•We have established a team that is responsible for administering our Conflict Minerals Program. Our team is supported by, and works closely with, our third-party vendor, Assent Compliance. Our team consists of personnel from our corporate operation’s group, including representatives from our quality, internal audit and global commodity management departments, and works with our specific business area buyers and product managers to address supplier risks and disclosure issues.
•If suppliers are unresponsive or do not provide the requested information, we have a process for escalating the matter to increasingly senior levels of management and considering corrective actions for suppliers that do not meet our stated expectations.
•We have established “Supplier Requirements for the Sourcing of Conflict Minerals,” which we communicate to our suppliers and require them to follow. We also engage suppliers by providing conflict minerals training and orientation materials to assist our suppliers in completing the RMI reporting template and provide support to answer suppliers’ questions. We maintain a conflict minerals resource page with links to resources about the conflict minerals law, the reporting template and our contact information for conflict minerals related inquiries:
www.trimble.com/Our Commitment/Responsible Business/Product Compliance/Conflict Minerals Policy
•Our template terms of purchase require suppliers to assist us in complying with applicable provisions of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act such as notifying us of their use of conflict minerals.
•We report on the status and progress of our Conflict Minerals Program during our operation group’s quarterly business and executive-level review meetings.
•Our Conflict Minerals Program, as an established internal process, is subject to oversight by our internal audit group.
Step 2: Identify and Assess Risk in the Supply Chain
•We requested each in-scope supplier to complete and return a reporting template so that we could survey our supply chain and obtain information about the smelters and refiners (which we collectively refer to as “smelters” throughout this report), and mines or locations of origin, of the 3TG used in our products. We identified the standardized reporting template developed by RMI as the best method for collecting information about Trimble’s suppliers to identify and assess risks.
•We tracked responses from in-scope suppliers and initially categorized suppliers according to whether they provided in their responses: (i) legitimate smelter information, or (ii) inconsistent or incomplete information about smelters that required further investigation.
•We used RMI’s smelters and refiners database to obtain conflict minerals sourcing information for the smelters identified on the completed reporting templates from our in-scope suppliers.
•We followed a defined process for reviewing and evaluating reporting template responses, including procedures to address incomplete or vague answers and to follow up with suppliers, as necessary.
•We identified any “high risk” suppliers that require additional attention by focusing on suppliers that: (i) list smelters that are in the Covered Countries and are not found on the RMAP Conformant Smelters & Refiners list. (ii) list smelters that have been found to be non-conformant with the RMAP or similar third- party audit programs, (iii) list unresponsive smelters that are unwilling to undertake compliance with the RMAP or another third-party audit program, or (iv) list smelters that we identified through our trade compliance screening as smelters that may be financed by a U.S.-embargoed or -sanctioned country, or that are identified as potentially supporting armed conflict or human rights violations.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
•We obtained updated smelter status data from RMI’s smelters and refiners database and compared supplier provided information against such data. Smelters found not in conformance with the RMAP or other independent third-party audit programs (such as the Tin Supply Chain Initiative List and the London Bullion Market Good Delivery Lists) were flagged for further due diligence.
•Any supplier that Trimble identified as “high risk” underwent further investigation and was subject to additional risk mitigation requests by Trimble.
•We informed our in-scope suppliers of identified high risk smelters and requested our suppliers to conduct further due diligence and to work with their supply chains to ensure compliance, such as by requesting impacted suppliers to utilize RMI’s smelter outreach letter in reaching out to non-certified smelters and press them for compliance, or to find substitute smelters.
•We require high risk suppliers to commit to and implement a corrective action plan within a reasonable time frame, and if such plan is deemed ineffective or there is no progress made, at the discretion of management, the supplier is subject to suspension or termination.
•We participate in and support RMI’s working groups on smelter due diligence practices for risk mitigation.
Step 4: Carry Out Independent Third-party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
•We are a member of RMI and rely on RMI’s data to validate the audit status and sourcing information of smelters.
•With the assistance of Assent, we conduct our in-scope due diligence of suppliers, through publicly available information regarding identified high risk smelters, to validate the existence and assess the conflict status of smelters.
•We address conflict minerals in our general supplier audits, focusing on supplier reporting template responses and due diligence programs.
Step 5: Report on supply chain due diligence
•Our annual Conflict Minerals Report is publicly accessible on our website.
•We remind “high risk” suppliers of our expectations for the upcoming 2022 conflict minerals reporting period and emphasize our requirements and goals.
Results of Due Diligence
Based on the responses received from suppliers, we identified a total of 339 smelters within our supply chain that were potential sources of 3TG for our suppliers.
We utilized RMI’s smelters database to obtain recent smelter audit status as of March 10, 2022. The table below summarizes the status of smelters that were identified through the information provided by our in-scope suppliers. Trimble has adopted the same audit status designations utilized by RMI to categorize audit compliance status. “Conformant” smelters are those that have completed an audit and conform with RMAP or other third party programs. “Active” smelters are those that are engaging with RMAP or other third party auditors to achieve compliance. “In Communication” refers to smelters that are not certified, but which demonstrate interest in participating in an audit program. “Alleged” are smelters that are not certified and have not yet even been verified to be a true smelter or still in business. “Non- Conformant” are those smelters that have been identified as having non-conformant audit results.
Schedule A lists all of the verified smelters reported by our in-scope suppliers that we believe processed 3TG which may have been used in Trimble products during the 2021 reporting period.
2021 Trimble Smelters or Refiners Audit Status
| Smelter Status | ||||||||||||||||||||||||||||||||
| Conformant Smelters | Active Smelters | In Communication Smelters | Alleged Smelters | Non-Conformant Smelters | ||||||||||||||||||||||||||||
| Metal: | ||||||||||||||||||||||||||||||||
| Gold | 101 | 6 | 12 | 43 | 11 | |||||||||||||||||||||||||||
| Tantalum | 36 | — | — | — | — | |||||||||||||||||||||||||||
| Tin | 54 | 10 | 2 | 9 | 6 | |||||||||||||||||||||||||||
| Tungsten | 42 | 4 | — | 3 | — | |||||||||||||||||||||||||||
| Total | 233 | 20 | 14 | 55 | 17 | |||||||||||||||||||||||||||
Of the 339 entities identified as smelters or alleged smelters, 233 smelters had associated mine disclosure information that was provided to us by RMI. From this information, we determined that 139 of those smelters did not source 3TG from the Covered Countries. For the 94 smelters that sourced 3TG from Covered Countries, we determined that they were certified as Conformant by RMI.
Trimble identified certain smelters as potentially high risk in its supply chain and requested follow-up actions from 56 in-scope suppliers that listed at least one of the smelters identified as high risk. All 56 suppliers have either completed due diligence follow-up actions, acknowledged Trimble’s requests and outlined their action plans for further due diligence, or have reported utilizing smelters that are not located in Covered Countries. Trimble continues to monitor the progress of these suppliers and will consider additional action if warranted.
Determination
Based on the measures we have taken, as described above, we do not have sufficient information to determine the country of origin of all of the 3TG contained in our products. Not all of the RMAP Conformant smelters disclosed the origin of their minerals. In addition, the information provided by some suppliers was incomplete and unverifiable, and certain smelters identified by suppliers were not recognized by RMI or were unknown to us so we were unable to determine the origin of minerals processed by such smelters.
However, based on the information provided by our suppliers, as well as information from RMI and other third party sources, we believe the origin of 3TG processed by smelters known to us and contained in our products include the countries listed in Schedule B. As discussed above, the known smelters for which we had mine disclosure information, and that we believe processed 3TG originating from the Covered Countries, were all certified Conformant by RMI. In addition, we are not aware of any instance where 3TG sourced from the Covered Countries directly or indirectly financed or benefited armed groups.
Future Due Diligence Measures
We intend to take the following measures in 2022 to further mitigate the risk that conflict minerals in our products could directly or indirectly finance or benefit armed groups in the Covered Countries:
•Continue to maintain a high response rate from suppliers and increase the quality of supplier responses, where needed, by working with our suppliers on the completion of their CMRTs.
•Encourage suppliers to adopt best practices for the responsible sourcing of materials, and to direct all smelters in their supply chains to participate in the RMAP or similar third-party audit program.
•Monitor the progress of suppliers with high risk smelters identified within their supply chains.
•Continue to direct our suppliers to Trimble’s Conflict Minerals Policy and Supplier Requirements for the Sourcing of Conflict Minerals to ensure that suppliers appropriately assess their supply chains, in keeping with the principles of responsible sourcing and corporate social responsibility underlying Trimble’s Conflict Minerals Program.
•Review our supplier risk mitigation process to assess remedial and corrective actions that we may take to address situations where suppliers are unresponsive, provide incomplete information or continue to source from unknown smelters.
•Continue monitoring our supply chain activities, keep current with changes or updates in relevant laws and guidance, and update our related policies and procedures as appropriate.
Schedule A
Verified Smelters and Refiners
| Metal | Smelter Name | Country | ||||||
| Gold | Advanced Chemical Company | United States Of America | ||||||
| Gold | Aida Chemical Industries Co., Ltd. | Japan | ||||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | ||||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | ||||||
| Gold | Argor-Heraeus S.A. | Switzerland | ||||||
| Gold | Asahi Pretec Corp. | Japan | ||||||
| Gold | Asaka Riken Co., Ltd. | Japan | ||||||
| Gold | Aurubis AG | Germany | ||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||||||
| Gold | Boliden AB | Sweden | ||||||
| Gold | C. Hafner GmbH + Co. KG | Germany | ||||||
| Gold | CCR Refinery – Glencore Canada Corporation | Canada | ||||||
| Gold | Cendres + Metaux S.A. | Switzerland | ||||||
| Gold | Chimet S.p.A. | Italy | ||||||
| Gold | Chugai Mining | Japan | ||||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | ||||||
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of | ||||||
| Gold | DODUCO Contacts and Refining GmbH | Germany | ||||||
| Gold | Dowa | Japan | ||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | ||||||
| Gold | OJSC Novosibirsk Refinery | Russian Federation | ||||||
| Gold | LT Metal Ltd. | Korea, Republic Of | ||||||
| Gold | Heimerle + Meule GmbH | Germany | ||||||
| Gold | Heraeus Metals Hong Kong Ltd. | China | ||||||
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | ||||||
| Gold | 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 | Japan Mint | Japan | ||||||
| Gold | Jiangxi Copper Co., Ltd. | China | ||||||
| Gold | Asahi Refining USA Inc. | United States Of America | ||||||
| Gold | Asahi Refining Canada Ltd. | Canada | ||||||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | ||||||
| Gold | JSC Uralelectromed | Russian Federation | ||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | ||||||
| Gold | Kazakhmys Smelting LLC | Kazakhstan | ||||||
| Gold | Kazzinc | Kazakhstan | ||||||
| Gold | Kennecott Utah Copper LLC | United States Of America | ||||||
| Gold | Kojima Chemicals Co., Ltd. | Japan | ||||||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | ||||||
| Gold | L’azurde Company For Jewelry | Saudi Arabia | ||||||
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | ||||||
| Gold | Materion | United States Of America | ||||||
| Gold | Matsuda Sangyo Co., Ltd. | Japan | ||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | China | ||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | ||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | ||||||
| Gold | Metalor Technologies S.A. | Switzerland | ||||||
| Gold | Metalor USA Refining Corporation | United States Of America | ||||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | ||||||
| Gold | Mitsubishi Materials Corporation | Japan | ||||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | ||||||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | ||||||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | ||||||
| Gold | Nihon Material Co., Ltd. | Japan | ||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | ||||||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | Russian Federation | ||||||
| Gold | PAMP S.A. | Switzerland | ||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | ||||||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | ||||||
| Gold | PX Precinox S.A. | Switzerland | ||||||
| Gold | Rand Refinery (Pty) Ltd. | South Africa | ||||||
| Gold | Royal Canadian Mint | Canada | ||||||
| Gold | Sabin Metal Corp. | United States Of America | ||||||
| Gold | Samduck Precious Metals | Korea, Republic Of | ||||||
| Gold | Samwon Metals Corp. | Korea, Republic Of | ||||||
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | ||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | ||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | ||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | ||||||
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | ||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | ||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | ||||||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | ||||||
| Gold | Tokuriki Honten Co., Ltd. | Japan | ||||||
| Gold | Torecom | Korea, Republic Of | ||||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | ||||||
| Gold | United Precious Metal Refining, Inc. | United States Of America | ||||||
| Gold | Valcambi S.A. | Switzerland | ||||||
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | ||||||
| Gold | Yamakin Co., Ltd. | Japan | ||||||
| Gold | Yokohama Metal Co., Ltd. | Japan | ||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | ||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | ||||||
| Gold | Morris and Watson | New Zealand | ||||||
| Gold | SAFINA A.S. | Czechia | ||||||
| Gold | Umicore Precious Metals Thailand | Thailand | ||||||
| Gold | Geib Refining Corporation | United States Of America | ||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | India | ||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | ||||||
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | ||||||
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | ||||||
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | ||||||
| Gold | Emirates Gold DMCC | United Arab Emirates | ||||||
| Gold | International Precious Metal Refiners | United Arab Emirates | ||||||
| Gold | Kaloti Precious Metals | United Arab Emirates | ||||||
| Gold | T.C.A S.p.A | Italy | ||||||
| Gold | REMONDIS PMR B.V. | Netherlands | ||||||
| Gold | Industrial Refining Company | Belgium | ||||||
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | ||||||
| Gold | Marsam Metals | Brazil | ||||||
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | ||||||
| Gold | Abington Reldan Metals, LLC | United States Of America | ||||||
| Gold | SAAMP | France | ||||||
| Gold | L’Orfebre S.A. | Andorra | ||||||
| Gold | 8853 S.p.A. | Italy | ||||||
| Gold | Italpreziosi | Italy | ||||||
| Gold | SAXONIA Edelmetalle GmbH | Germany | ||||||
| Gold | WIELAND Edelmetalle GmbH | Germany | ||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | ||||||
| Gold | AU Traders and Refiners | South Africa | ||||||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | ||||||
| Gold | Modeltech Sdn Bhd | Malaysia | ||||||
| Gold | Bangalore Refinery | India | ||||||
| Gold | Pease & Curren | United States Of America | ||||||
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | ||||||
| Gold | Planta Recuperadora de Metales SpA | Chile | ||||||
| Gold | Safimet S.p.A | Italy | ||||||
| Gold | NH Recytech Company | Korea, Republic Of | ||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | ||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | ||||||
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | ||||||
| Gold | C.I Metales Procesados Industriales SAS | Colombia | ||||||
| Gold | Augmont Enterprises Private Limited | India | ||||||
| Gold | Kundan Care Products Ltd. | India | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India | ||||||
| Gold | Alexy Metals | United States Of America | ||||||
| Gold | Sancus ZFS (L’Orfebre, SA) | Colombia | ||||||
| Gold | Sellem Industries Ltd. | Mauritania | ||||||
| Gold | MD Overseas | India | ||||||
| Gold | Metallix Refining Inc. | United States Of America | ||||||
| Gold | WEEEREFINING | France | ||||||
| Gold | Value Trading | Belgium | ||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | ||||||
| Tantalum | Exotech Inc. | United States Of America | ||||||
| Tantalum | F&X Electro-Materials Ltd. | China | ||||||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | ||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | ||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | ||||||
| Tantalum | LSM Brasil S.A. | Brazil | ||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | ||||||
| Tantalum | Mineracao Taboca S.A. | Brazil | ||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | ||||||
| Tantalum | NPM Silmet AS | Estonia | ||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | ||||||
| Tantalum | QuantumClean | United States Of America | ||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | ||||||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | ||||||
| Tantalum | Taki Chemical Co., Ltd. | Japan | ||||||
| Tantalum | Telex Metals | United States Of America | ||||||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | ||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||||||
| Tantalum | D Block Metals, LLC | United States Of America | ||||||
| Tantalum | FIR Metals & Resource Ltd. | China | ||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | ||||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | ||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | ||||||
| Tantalum | KEMET Blue Metals | Mexico | ||||||
| Tantalum | H.C. Starck Co., Ltd. | Thailand | ||||||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | ||||||
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany | ||||||
| Tantalum | H.C. Starck Inc. | United States Of America | ||||||
| Tantalum | H.C. Starck Ltd. | Japan | ||||||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | ||||||
| Tantalum | Global Advanced Metals Boyertown | United States Of America | ||||||
| Tantalum | Global Advanced Metals Aizu | Japan | ||||||
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | ||||||
| Tantalum | Jiangxi Tuohong New Raw Material | China | ||||||
| Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | China | ||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | ||||||
| Tin | Alpha | United States Of America | ||||||
| Tin | PT Aries Kencana Sejahtera | Indonesia | ||||||
| Tin | Dowa | Japan | ||||||
| Tin | EM Vinto | Bolivia | ||||||
| Tin | Estanho de Rondonia S.A. | Brazil | ||||||
| Tin | Fenix Metals | Poland | ||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | ||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | ||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | ||||||
| Tin | China Tin Group Co., Ltd. | China | ||||||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | ||||||
| Tin | Metallic Resources, Inc. | United States Of America | ||||||
| Tin | Mineracao Taboca S.A. | Brazil | ||||||
| Tin | Minsur | Peru | ||||||
| Tin | Mitsubishi Materials Corporation | Japan | ||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | China | ||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||||||
| Tin | Operaciones Metalurgicas S.A. | Bolivia | ||||||
| Tin | PT Artha Cipta Langgeng | Indonesia | ||||||
| Tin | PT Babel Inti Perkasa | Indonesia | ||||||
| Tin | PT Babel Surya Alam Lestari | Indonesia | ||||||
| Tin | PT Bukit Timah | Indonesia | ||||||
| Tin | PT Mitra Stania Prima | Indonesia | ||||||
| Tin | PT Prima Timah Utama | Indonesia | ||||||
| Tin | PT Refined Bangka Tin | Indonesia | ||||||
| Tin | PT Sariwiguna Binasentosa | Indonesia | ||||||
| Tin | PT Stanindo Inti Perkasa | Indonesia | ||||||
| Tin | PT Timah Tbk Kundur | Indonesia | ||||||
| Tin | PT Timah Tbk Mentok | Indonesia | ||||||
| Tin | PT Tinindo Inter Nusa | Indonesia | ||||||
| Tin | PT Tommy Utama | Indonesia | ||||||
| Tin | Rui Da Hung | Taiwan, Province Of China | ||||||
| Tin | Soft Metais Ltda. | Brazil | ||||||
| Tin | Thaisarco | Thailand | ||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | ||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | ||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | ||||||
| Tin | Yunnan Tin Company Limited | China | ||||||
| Tin | CV Venus Inti Perkasa | Indonesia | ||||||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | Brazil | ||||||
| Tin | Melt Metais e Ligas S.A. | Brazil | ||||||
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | ||||||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | ||||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | ||||||
| Tin | PT Cipta Persada Mulia | Indonesia | ||||||
| Tin | Resind Industria e Comercio Ltda. | Brazil | ||||||
| Tin | Super Ligas | Brazil | ||||||
| Tin | Metallo Belgium N.V. | Belgium | ||||||
| Tin | Metallo Spain S.L.U. | Spain | ||||||
| Tin | PT Sukses Inti Makmur | Indonesia | ||||||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam | ||||||
| Tin | PT Menara Cipta Mulia | Indonesia | ||||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | ||||||
| Tin | Modeltech Sdn Bhd | Malaysia | ||||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | ||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | ||||||
| Tin | PT Bangka Serumpun | Indonesia | ||||||
| Tin | Tin Technology & Refining | United States Of America | ||||||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | ||||||
| Tin | Ma’anshan Weitai Tin Co., Ltd. | China | ||||||
| Tin | PT Rajawali Rimba Perkasa | Indonesia | ||||||
| Tin | Luna Smelter, Ltd. | Rwanda | ||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | ||||||
| Tin | Precious Minerals and Smelting Limited | India | ||||||
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | ||||||
| Tin | Novosibirsk Processing Plant Ltd. | Russian Federation | ||||||
| Tin | PT Mitra Sukses Globalindo | Indonesia | ||||||
| Tin | PT Timah Nusantara | Indonesia | ||||||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | ||||||
| Tin | CRM Synergies | Spain | ||||||
| Tin | PT Masbro Alam Stania | Indonesia | ||||||
| Tin | Estanho de Rondonia S.A. | Brazil | ||||||
| Tin | CRM Synergies | Spain | ||||||
| Tungsten | A.L.M.T. Corp. | Japan | ||||||
| Tungsten | Kennametal Huntsville | United States Of America | ||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | ||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | ||||||
| Tungsten | Global Tungsten & Powders Corp. | United States Of America | ||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | ||||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | ||||||
| Tungsten | Japan New Metals Co., Ltd. | Japan | ||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | ||||||
| Tungsten | Kennametal Fallon | United States Of America | ||||||
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | ||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | ||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | ||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | ||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | ||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | ||||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | ||||||
| Tungsten | H.C. Starck Tungsten GmbH | Germany | ||||||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | ||||||
| Tungsten | Masan Tungsten Chemical LLC (MTC) | Viet Nam | ||||||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | ||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||||||
| Tungsten | Niagara Refining LLC | United States Of America | ||||||
| Tungsten | China Molybdenum Co., Ltd. | China | ||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | ||||||
| Tungsten | Hydrometallurg, JSC | Russian Federation | ||||||
| Tungsten | Unecha Refractory metals plant | Russian Federation | ||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | ||||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | ||||||
| Tungsten | ACL Metais Eireli | Brazil | ||||||
| Tungsten | Moliren Ltd. | Russian Federation | ||||||
| Tungsten | KGETS Co., Ltd. | Korea, Republic Of | ||||||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China | ||||||
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | ||||||
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | ||||||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | ||||||
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | ||||||
| Tungsten | GEM Co., Ltd. | China | ||||||
| Tungsten | Cronimet Brasil Ltda | Brazil | ||||||
| Tungsten | Fujian Xinlu Tungsten | China | ||||||
| Tungsten | OOO “Technolom” 2 | Russian Federation | ||||||
| Tungsten | OOO “Technolom” 1 | Russian Federation | ||||||
| Tungsten | GEM Co., Ltd. | China | ||||||
Schedule B
Countries of Origin List
| Andorra | Mauritania | ||||
| Australia | Mexico | ||||
| Austria | Netherlands | ||||
| Belgium | New Zealand | ||||
| Bolivia | Peru | ||||
| Bolivia (Pluractional State of) | Philippines | ||||
| Brazil | Poland | ||||
| Canada | Russian Federation | ||||
| Chile | Rwanda | ||||
| China | Saudi Arabia | ||||
| Colombia | Singapore | ||||
| Czech Republic | South Africa | ||||
| Estonia | Spain | ||||
| France | Sweden | ||||
| Germany | Switzerland | ||||
| India | Taiwan | ||||
| Indonesia | Thailand | ||||
| Italy | Turkey | ||||
| Japan | United Arab Emirates | ||||
| Kazakhstan | United States of America | ||||
| Korea, Republic Of | Uzbekistan | ||||
| Kyrgyzstan | Vietnam | ||||
| Malaysia | Zimbabwe | ||||
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