UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Graco Inc.
(Exact name of registrant as specified in its charter)
Minnesota | 001-09249 | 41-0285640 | ||||||||||||
| (State or other Jurisdiction of Incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) | ||||||||||||
88 – 11th Avenue Northeast Minneapolis, Minnesota | 55413 | |||||||||||||||||||||||||
| (Address of principal executive offices) | (Zip Code) | |||||||||||||||||||||||||
| Joseph James Humke, (612) 623-6000 | ||
| (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:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of Graco Inc. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period of January 1 to December 31, 2022.
A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD and is publicly available at www.graco.com.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 - Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report.
| Exhibit No. | Description | |||||||
| Conflict Minerals Report of Graco Inc. | ||||||||
Signature
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.
| GRACO INC. | ||||||||||||||||||||||||||||||||
| Date: | May 31, 2023 | By: | /s/ Joseph James Humke | |||||||||||||||||||||||||||||
| Joseph James Humke | ||||||||||||||||||||||||||||||||
| Executive Vice President, General Counsel and Corporate Secretary | ||||||||||||||||||||||||||||||||
Exhibit 1.01 GRACO INC. Conflict Minerals Report For the reporting period from January 1, 2022 to December 31, 2022 This is the Conflict Minerals Report (“Report”) of Graco Inc. (“Graco,” “we,” “our” or “us”) for the 2022 calendar year, pursuant to Rule 13p-1 of the Securities Exchange Act of 1934 (the “Rule”). Certain capitalized terms used but not defined herein have the meanings assigned to them in the Rule. This Report includes the activities of all subsidiaries of Graco that were required to be consolidated during the reporting period, other than any acquired companies that are not yet required by the Rule to be included in this Report. The Rule requires certain SEC reporting companies that manufacture or contract to be manufactured products for which tantalum, tin, tungsten or gold (“3TG”) are necessary to the functionality or production of such products to disclose annually whether any of the 3TG in such products originated in the Democratic Republic of the Congo or one of its adjoining countries (collectively, the “Covered Countries”). If the company knows that the 3TG necessary to its products originated in the Covered Countries, or has reason to believe that the 3TG may have originated in the Covered Countries and did not or may not have come from scrap or recycled sources, the company must exercise due diligence on the source and chain of custody of the 3TG and prepare and file a Report describing its due diligence measures. In addition, our review of the conflict minerals surveys received from our suppliers and related conflict minerals reports for the 2022 calendar year found information indicating that some of the smelters or refiners in our supply chain identified the Russian Federation as a possible sourcing location. The information regarding these Russian-origin metals came from third-party suppliers, which in turn obtained the information through their own suppliers in these highly-attenuated, multi-tiered global supply chains. We remain committed to compliance with U.S. and other applicable trade law and sanctions programs, including those targeting Russian parties. Graco Overview Graco is a multi-national manufacturer of systems and equipment that move, measure, control, dispense and spray fluid and powder materials. Our systems and equipment are used in the manufacturing, processing, construction and maintenance industries. Our primary products include air, electric, gas and hydraulic pumps and sprayers; electronic and mechanical controls and sensors; and automatic and manual dispense valves, meters and spray guns. Our products that contain control boards, certain other electronic components, motors, engines, batteries, spray tips, and certain pumps and valves contain 3TG.
Company Management Systems We have established management systems to support the execution of our Conflict Minerals program and to ensure it operates effectively and is sustainable into the future. Our management systems include the following: Conflict Minerals Policy We have adopted a policy affirming our commitment to conducting business fairly and ethically with respect for human rights and in compliance with all applicable laws and regulations, including the Rule. Our policy also affirms our support for the responsible sourcing of 3TG through our global supply chain, and states that we are actively and diligently working with our global supply chain partners to determine the origin of any 3TG they may supply to us, and that we will continue to work with them towards the goal of providing greater supply chain transparency and responsible sourcing. Our policy is available on our website at http://www.graco.com/us/en/about-graco/conflict-minerals.html. Internal Team We have a cross-functional team with executive-level sponsorship and support that implemented and oversees our Conflict Minerals compliance program. The cross-functional team includes employees from functional groups such as procurement, finance, operations, legal and information systems. We report our Conflict Minerals findings to our team and designated members of senior management. Control Systems We have contributed to industry efforts to support the responsible sourcing of 3TG through our membership in the Responsible Minerals Initiative (RMI), which has helped develop standards, best practices and tools that benefit all companies working to end the link between 3TG and conflict in the Covered Countries. In prior years, we have also participated in the National Association of Manufacturers Conflict Minerals Working Group, the Manufacturers Alliance for Productivity and Innovation Conflict Minerals Forum and the Twin Cities Conflict Minerals Task Force. In addition, we retained a third-party service provider to assist with collecting, evaluating and retaining supply chain information, identifying potential supply chain risks, and developing and implementing additional engagement steps with suppliers. Supplier Engagement We have a process in place to engage relevant first-tier suppliers to educate them about the Rule and request information from them regarding 3TG. Graco engages with suppliers directly or through our third-party service provider to request a CMRT for products they supply to us. To assist in the process, we established a direct email address (conflictminerals@graco.com) to provide our suppliers a streamlined method of communicating conflict mineral information to Graco. We also have a process in place to try to improve the number and quality of supplier responses year over year. To help ensure suppliers understand the
Rule and how to properly respond to requests for information from us regarding 3TG, we provide our suppliers access to online Conflict Minerals support materials, help desk support and other multilingual resources. We also follow up the communications in multiple languages to our suppliers through the third-party service provider. In addition, we respond to supplier inquiries during the information gathering process and take steps to address supplier issues that arise during that process. Grievance Mechanism We have an established grievance mechanism through which employees, suppliers, customers and other interested parties may communicate their concerns to us. Records Management We have a process in place to collect, analyze and retain Conflict Minerals information received from our suppliers. We will maintain records relating to Conflict Minerals supply chain due diligence in accordance with our records retention policy, which provides for retention of such records for five (5) years. Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. As a member of the RMI, we support the RMI’s efforts to carry out independent third-party audits of smelter and refiner due diligence activities and contribute to the improvement of smelter and refiner and upstream due diligence practices. Report on Supply Chain Due Diligence Graco has filed a Form SD and this Report with the Securities and Exchange Commission. The filing is available on our website at https://www.graco.com/us/en/about- graco/conflict-minerals.html. Reasonable Country of Origin Inquiry Supply Chain We do not directly source 3TG and as a purchaser, Graco is many steps removed from the mining of 3TG. We purchase components and raw materials from third party suppliers who are also generally multiple layers removed from the smelters and refiners of the 3TG that are in the components and raw materials ultimately supplied to us. We evaluated our products and determined that certain products manufactured during calendar year 2022 were manufactured with components and raw materials that contain or likely contain 3TG. Given that 3TG are necessary to the functionality or production of certain products that we manufacture, we determined it was required that we conduct a good faith reasonable country of inquiry (“RCOI”)
regarding those conflict minerals. To implement the RCOI process, our Sourcing Department determined what components and raw materials potentially contain 3TG and the first-tier suppliers of those components and raw materials. Request for Information Based upon the result of the component and raw material analysis, we then used a third- party service provider to engage our in-scope first tier suppliers to conduct a RCOI for the components and raw materials they provide to Graco. The third-party service provider surveyed all of our in-scope first tier suppliers using the Conflict Minerals Report Template (CMRT) (version 6.22) developed by RMI. We also provided these suppliers with access to online Conflict Minerals support materials to help educate them on the Rule and to aid them in responding to the survey. This third-party service provider sent multiple emails and followed up with phone calls with our suppliers in an attempt to gather the completed CMRT forms. For the 2022 reporting period, through the use of the third-party service provider, Graco requested completed CMRT forms from our in-scope first tier suppliers. Graco received responses from over 50% of the in- scope suppliers. Survey Responses All submitted CMRTs were reviewed. We tracked supplier responses and identified instances where suppliers submitted an invalid response (due to missing information or inconsistencies across responses) or did not provide us with a timely response, and followed up with those suppliers directly or through our third-party service provider and requested that they submit a valid CMRT. Suppliers were provided with guidance on how to correct any validation errors in the form of feedback to their CMRT submissions, training courses and direct engagement help from a multilingual service team. As of May 23, 2023, there was a small percentage of invalid supplier CMRTs that were not corrected. We compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters and refiners maintained by the RMI to determine the validity and the RMAP assessment status of each of the smelters and refiners identified by our suppliers. Our suppliers identified a total of 370 smelters and refiners that appear on the lists maintained by the RMI. Of these 370 smelters and refiners, 234 have been deemed conformant with the RMAP assessment protocols by an independent third party auditor according to the RMI list of conformant smelters and refiners. Most of the CMRTs we received were completed on a company or supplier-defined level, which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TG contained in our products. Identification and Assessment of Risk Risks are identified based on criteria established from CMRTs provided by our suppliers. We analyze the CRMT responses for completeness and consistency. Risks are addressed by contacting the supplier, gathering pertinent information, and performing an assessment of the
supplier’s Conflict Minerals status. The primary risk identified relates to the nature of responses received. Many suppliers provided information at a company or supplier-defined level, which prevents us from determining whether the smelters or refiners listed by those suppliers actually processed the 3TG contained in the components and raw materials supplied to us. Smelters and refiners that are not conformant with the RMAP assessment protocols or have not committed to undergo an RMAP assessment also pose a risk. When a CMRT is received, the smelters and refiners that are reported are examined. Each facility that meets the RMI definition of a smelter or refiner of 3TG is evaluated for risk based on: (i) geographic proximity to the Covered Countries; (ii) known mineral source country of origin; (iii) RMI Responsible Minerals Assurance Process (RMAP) audit status; (iv) credible evidence of unethical or conflict sourcing; and (v) peer assessments conducted by credible third-party sources. When certain high risk facilities are reported, risk mitigation activities are initiated with the supplier so that they can take risk mitigation actions. In addition, suppliers are evaluated on the strength of their Conflict Minerals programs based on whether: (i) they have a conflict minerals sourcing policy; (ii) their responsible minerals sourcing policy is available on their website; (iii) they require their direct suppliers to source the 3TG from smelters whose due diligence practices have been validated by an independent third party audit program; (iv) they have implemented due diligence measures for responsible sourcing; (v) they conduct Conflict Minerals survey(s) of their relevant suppliers; (vi) they review information received from their suppliers against their own expectations; (vii) their review process includes corrective action management; and (viii) they are required to file an annual conflict minerals disclosure. We evaluate and track the strength of their programs so we can make risk mitigation decisions as their programs progress. Through our membership with the RMI, we encourage smelters and refiners to participate in the RMAP. Any smelters and refiners that were reported by our suppliers that were not part of the RMAP were also contacted directly to encourage them to participate in the RMAP. Design of Due Diligence Measures Our due diligence measures have been designed to be in conformity, in all material respects, with the applicable provisions of the internationally recognized framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas: Third Edition, and the related supplements on 3TG. Due Diligence Measures Performed The due diligence measures we performed include defining roles and responsibilities for our cross-functional Conflict Minerals team and designated members of senior management; reporting our Conflict Minerals findings to our cross-functional Conflict Minerals team and designated members of senior management; and comparing the smelter and refiner information received from our suppliers against the RMI list of smelters and refiners that are conformant with the RMAP assessment protocols, the RMI list of smelters and refiners that have committed to undergo an RMAP audit, and the RMI reference list of known smelters and refiners. With respect to smelters and refiners that were on the RMI list of known smelters and refiners and
certain other smelters and refiners that were not on the RMI list of known smelters and refiners, we reviewed certain other publicly available sources of information. In addition, we retained a third-party service provider to assist with collecting, evaluating and retaining supply chain information, identifying potential supply chain risks, and developing and implementing additional engagement steps with suppliers. Due Diligence Results For the 2022 reporting period, Graco requested completed CMRT forms from our in- scope first tier suppliers and received responses from over 50% of the in-scope suppliers. The majority of those who responded provided data at a company or supplier-defined level rather than at a product level, and reported that their products do not contain 3TG or, if they do, the 3TG in their products does not come from the Covered Countries. A number of suppliers reported that they do not know whether the 3TG in their products comes from the Covered Countries or from scrap or recycled sources. A small number of suppliers reported that the 3TG in their products comes from or may come from the Covered Countries, and some of these suppliers further reported that some of the 3TG in their products comes from scrap or recycled sources. Through the third-party service provider, our suppliers identified 585 entities in their supply chains as part of their smelter or refiner list; however, 201 of those entities were identified as a non-smelter or a non-refiner. Of the known smelters or refiners, 234 have been deemed conformant with the RMAP assessment protocols by an independent third party auditor according to the RMI list of conformant smelters and refiners. 7 of the smelters and refiners have not yet been deemed conformant, but have committed to undergo a RMAP audit. 3 of the smelters and refiners identified by our suppliers have failed an RMAP audit, refused to participate in the RMAP assessment process, or have failed to provide adequate access to their facilities to complete the RMAP assessment process. Schedule 1 to this Report contains a list of legitimate smelters and refiners identified by our suppliers, and whose materials and components may or may not be in our products. (Schedule 1 excludes any smelters and refiners identified by our suppliers that do not appear on the RMI list of known smelters and refiners.) Schedule 2 to this Report includes an aggregate list of the countries of origin from which the smelters and refiners identified on Schedule 1 collectively source 3TG, based on information provided by the RMI. Given that the majority of suppliers who responded to the survey provided their responses at a company or supplier-defined level rather than at a level specific to the materials and components they supplied to us, we were unable to determine which, if any, of the smelters and refiners listed in their responses were the actual source of the 3TG they supplied. Determination Given that a number of suppliers did not respond to our survey, the majority of responses we received were provided at a company or supplier-defined level not specific to the components
and raw materials supplied to us, and that a number of suppliers do not know the origin of the 3TG in their products, we do not have sufficient information to determine the origin of the 3TG in our products subject to this Report, whether the 3TG came from scrap or recycled sources, the specific facilities used to process the 3TG, or the country of origin or the mine or location of origin of the 3TG. Steps to be Taken to Mitigate Risk in 2023 We intend to take the following steps to improve and enhance our due diligence process to further mitigate the risk that the necessary 3TG in our products finance or benefit armed groups in the Covered Countries: Continue to increase conflict minerals awareness and compliance requirements with Graco’s supply chain personnel and Graco suppliers; Continue to engage with our direct suppliers to increase the response rate to our survey and improve the content and quality of their responses; Continue to engage with our direct suppliers to receive more information farther upstream regarding the source and chain of custody of the 3TG in the components and raw materials they supply to us; and Continue to educate and encourage our suppliers to work with their supply chains to source responsibly, including utilizing conflict-free smelters and refiners.
Schedule 1 Metal Smelter Name Smelter Country Gold Dongwu Gold Group China Gold Gold by Gold Colombia Colombia Gold Value Trading Belgium Gold WEEEREFINING France Gold Metal Concentrators SA (Pty) Ltd. South Africa Gold Metallix Refining Inc. United States Of America Gold MD Overseas India Gold Sellem Industries Ltd. Mauritania Gold Sancus ZFS (L’Orfebre, SA) Colombia Gold Alexy Metals United States Of America Gold K.A. Rasmussen Norway Gold Emerald Jewel Industry India Limited (Unit 4) India Gold Emerald Jewel Industry India Limited (Unit 3) India Gold Emerald Jewel Industry India Limited (Unit 2) India Gold Emerald Jewel Industry India Limited (Unit 1) India Gold Kundan Care Products Ltd. India Gold Augmont Enterprises Private Limited India Gold Eco-System Recycling Co., Ltd. West Plant Japan Gold Eco-System Recycling Co., Ltd. North Plant Japan Gold C.I Metales Procesados Industriales SAS Colombia Gold Sovereign Metals India Gold CGR Metalloys Pvt Ltd. India Gold Dijllah Gold Refinery FZC United Arab Emirates Gold QG Refining, LLC United States Of America Gold NH Recytech Company Korea, Republic Of Gold Gold Coast Refinery Ghana Gold African Gold Refinery Uganda Gold State Research Institute Center for Physical Sciences and Technology Lithuania Gold Safimet S.p.A Italy Gold ABC Refinery Pty Ltd. Australia Gold Planta Recuperadora de Metales SpA Chile
Gold SungEel HiMetal Co., Ltd. Korea, Republic Of Gold JALAN & Company India Gold Pease & Curren United States Of America Gold Degussa Sonne / Mond Goldhandel GmbH Germany Gold Kyshtym Copper-Electrolytic Plant ZAO Russian Federation Gold Bangalore Refinery India Gold Modeltech Sdn Bhd Malaysia Gold Sai Refinery India Gold GGC Gujrat Gold Centre Pvt. Ltd. India Gold AU Traders and Refiners South Africa Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria Gold WIELAND Edelmetalle GmbH Germany Gold Italpreziosi Italy Gold 8853 S.p.A. Italy Gold L'Orfebre S.A. Andorra Gold SAAMP France Gold Albino Mountinho Lda. Portugal Gold Shenzhen CuiLu Gold Co., Ltd. China Gold Abington Reldan Metals, LLC United States Of America Gold TOO Tau-Ken-Altyn Kazakhstan Gold Marsam Metals Brazil Gold Korea Zinc Co., Ltd. Korea, Republic Of Gold Shirpur Gold Refinery Ltd. India Gold Industrial Refining Company Belgium Gold Fujairah Gold FZC United Arab Emirates Gold Remondis Pmr B.V. Netherlands Gold T.C.A S.p.A Italy Gold Sudan Gold Refinery Sudan Gold Kaloti Precious Metals United Arab Emirates Gold International Precious Metal Refiners United Arab Emirates Gold Emirates Gold DMCC United Arab Emirates Gold Al Etihad Gold Refinery DMCC United Arab Emirates Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China Gold Shandong Humon Smelting Co., Ltd. China Gold Singway Technology Co., Ltd. Taiwan, Province Of China Gold Fidelity Printers and Refiners Ltd. Zimbabwe Gold KGHM Polska Miedz Spolka Akcyjna Poland
Gold MMTC-PAMP India Pvt., Ltd. India Gold Geib Refining Corporation United States Of America Gold Umicore Precious Metals Thailand Thailand Gold Guangdong Jinding Gold Limited China Gold Safina a.s. Czechia Gold Morris and Watson New Zealand Gold Gold Refinery of Zijin Mining Group Co., Ltd. China Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation China Gold Yokohama Metal Co., Ltd. Japan Gold Yamakin Co., Ltd. Japan Gold Western Australian Mint (T/a The Perth Mint) Australia Gold Valcambi S.A. Switzerland Gold United Precious Metal Refining, Inc. United States Of America Gold Umicore S.A. Business Unit Precious Metals Refining Belgium Gold Torecom Korea, Republic Of Gold Tongling Nonferrous Metals Group Co., Ltd. China Gold Tokuriki Honten Co., Ltd. Japan Gold Shandong gold smelting Co., Ltd. China Gold Great Wall Precious Metals Co., Ltd. of CBPM China Gold Tanaka Kikinzoku Kogyo K.K. Japan Gold Super Dragon Technology Co., Ltd. Taiwan, Province Of China Gold Sumitomo Metal Mining Co., Ltd. Japan Gold Solar Applied Materials Technology Corp. Taiwan, Province Of China Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation Gold Sichuan Tianze Precious Metals Co., Ltd. China Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China Gold SEMPSA Joyeria Plateria S.A. Spain Gold SAMWON METALS Corp. Korea, Republic Of Gold Samduck Precious Metals Korea, Republic Of Gold Sabin Metal Corp. United States Of America Gold Royal Canadian Mint Canada Gold Rand Refinery (Pty) Ltd. South Africa
Gold PX Precinox S.A. Switzerland Gold PT Aneka Tambang (Persero) Tbk Indonesia Gold Prioksky Plant of Non-Ferrous Metals Russian Federation Gold Penglai Penggang Gold Industry Co., Ltd. China Gold PAMP S.A. Switzerland Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation Gold Ohura Precious Metal Industry Co., Ltd. Japan Gold Nihon Material Co., Ltd. Japan Gold Navoi Mining and Metallurgical Combinat Uzbekistan Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey Gold Moscow Special Alloys Processing Plant Russian Federation Gold Mitsui Mining and Smelting Co., Ltd. Japan Gold Mitsubishi Materials Corporation Japan Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico Gold Metalor USA Refining Corporation United States Of America Gold Metalor Technologies S.A. Switzerland Gold Metalor Technologies (Singapore) Pte., Ltd. Singapore Gold Metalor Technologies (Hong Kong) Ltd. China Gold Metalor Technologies (Suzhou) Ltd. China Gold Matsuda Sangyo Co., Ltd. Japan Gold Materion United States Of America Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China Gold LS-NIKKO Copper Inc. Korea, Republic Of Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. China Gold Lingbao Gold Co., Ltd. China Gold L'azurde Company For Jewelry Saudi Arabia Gold Kyrgyzaltyn JSC Kyrgyzstan Gold Kojima Chemicals Co., Ltd. Japan Gold Kennecott Utah Copper LLC United States Of America Gold Kazzinc Kazakhstan Gold Kazakhmys Smelting LLC Kazakhstan Gold JX Nippon Mining & Metals Co., Ltd. Japan
Gold JSC Uralelectromed Russian Federation Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation Gold Asahi Refining Canada Ltd. Canada Gold Asahi Refining USA Inc. United States Of America Gold Jiangxi Copper Co., Ltd. China Gold Japan Mint Japan Gold Istanbul Gold Refinery Turkey Gold Ishifuku Metal Industry Co., Ltd. Japan Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China Gold HwaSeong CJ Co., Ltd. Korea, Republic Of Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China Gold Hunan Chenzhou Mining Co., Ltd. China Gold Heraeus Germany GmbH Co. KG Germany Gold Heraeus Metals Hong Kong Ltd. China Gold Heimerle + Meule GmbH Germany Gold LT Metal Ltd. Korea, Republic Of Gold Hangzhou Fuchunjiang Smelting Co., Ltd. China Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. China Gold Refinery of Seemine Gold Co., Ltd. China Gold JSC Novosibirsk Refinery Russian Federation Gold Eco-System Recycling Co., Ltd. East Plant Japan Gold Dowa Japan Gold DSC (Do Sung Corporation) Korea, Republic Of Gold Daye Non-Ferrous Metals Mining Ltd. China Gold Chugai Mining Japan Gold Chimet S.p.A. Italy Gold Yunnan Copper Industry Co., Ltd. China Gold Cendres + Metaux S.A. Switzerland Gold CCR Refinery - Glencore Canada Corporation Canada Gold Caridad Mexico Gold C. Hafner GmbH + Co. KG Germany Gold Boliden AB Sweden Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines Gold Aurubis AG Germany
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey Gold Asaka Riken Co., Ltd. Japan Gold Asahi Pretec Corp. Japan Gold Argor-Heraeus S.A. Switzerland Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan Gold Agosi AG Germany Gold Aida Chemical Industries Co., Ltd. Japan Gold Advanced Chemical Company United States Of America Gold Baiyin Nonferrous Group Co.,Ltd China Gold Bauer Walser AG Germany Gold China Gold Deal Investment Co., Ltd. China Gold Faggi Enrico S.p.A. Italy Gold Henan Yuguang Gold & Lead Co., Ltd. China Gold Jinlong Copper Co.,Ltd. China Gold MK Electron co., Ltd. Korea, Republic Of Gold N.E.Chemcat Corporation Japan Gold ScotiaMocatta, The Bank of Nova Scotia Hong Kong Gold Shandong Yanggu Xiangguang Co. Ltd. China Gold Shandong Zhongkuang Group Co.,Ltd. China Gold So Accurate Group, Inc. United States Of America Gold Standard Bank Group Hong Kong Tantalum 5D Production OU Estonia Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. China Tantalum Jiangxi Tuohong New Raw Material China Tantalum Resind Industria e Comercio Ltda. Brazil Tantalum Global Advanced Metals Aizu Japan Tantalum Global Advanced Metals Boyertown United States Of America Tantalum TANIOBIS Smelting GmbH & Co. KG Germany Tantalum TANIOBIS Japan Co., Ltd. Japan Tantalum H.C. Starck Inc. United States Of America Tantalum TANIOBIS GmbH Germany Tantalum TANIOBIS Co., Ltd. Thailand Tantalum KEMET de Mexico Mexico
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China Tantalum XinXing HaoRong Electronic Material Co., Ltd. China Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China Tantalum FIR Metals & Resource Ltd. China Tantalum D Block Metals, LLC United States Of America Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China Tantalum Ulba Metallurgical Plant JSC Kazakhstan Tantalum Telex Metals United States Of America Tantalum Taki Chemical Co., Ltd. Japan Tantalum Solikamsk Magnesium Works OAO Russian Federation Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China Tantalum QuantumClean United States Of America Tantalum Ningxia Orient Tantalum Industry Co., Ltd. China Tantalum NPM Silmet AS Estonia Tantalum Mitsui Mining and Smelting Co., Ltd. Japan Tantalum Mineracao Taboca S.A. Brazil Tantalum Metallurgical Products India Pvt., Ltd. India Tantalum AMG Brasil Brazil Tantalum Jiujiang Tanbre Co., Ltd. China Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. China Tantalum Ximei Resources (Guangdong) Limited China Tantalum F&X Electro-Materials Ltd. China Tin PT Putera Sarana Shakti (PT PSS) Indonesia Tin DS Myanmar Myanmar Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil Tin CRM Synergies Spain Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil Tin PT Mitra Sukses Globalindo Indonesia Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China Tin Precious Minerals and Smelting Limited India Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China
Tin Luna Smelter, Ltd. Rwanda Tin PT Rajawali Rimba Perkasa Indonesia Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China Tin Tin Technology & Refining United States Of America Tin Pongpipat Company Limited Myanmar Tin PT Bangka Serumpun Indonesia Tin Chifeng Dajingzi Tin Industry Co., Ltd. China Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China Tin Modeltech Sdn Bhd Malaysia Tin PT Menara Cipta Mulia Indonesia Tin PT Sukses Inti Makmur Indonesia Tin Metallo Spain S.L.U. Spain Tin Metallo Belgium N.V. Belgium Tin Super Ligas Brazil Tin Resind Industria e Comercio Ltda. Brazil Tin An Vinh Joint Stock Mineral Processing Company Viet Nam Tin PT Cipta Persada Mulia Indonesia Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company Viet Nam Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company Viet Nam Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Viet Nam Tin O.M. Manufacturing Philippines, Inc. Philippines Tin PT ATD Makmur Mandiri Jaya Indonesia Tin Melt Metais e Ligas S.A. Brazil Tin PT Tirus Putra Mandiri Indonesia Tin Magnu's Minerais Metais e Ligas Ltda. Brazil Tin CV Venus Inti Perkasa Indonesia Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. China Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China Tin White Solder Metalurgia e Mineracao Ltda. Brazil Tin VQB Mineral and Trading Group JSC Viet Nam Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China Tin Thaisarco Thailand
Tin Rui Da Hung Taiwan, Province Of China Tin PT Tommy Utama Indonesia Tin PT Tinindo Inter Nusa Indonesia Tin PT Timah Nusantara Indonesia Tin PT Timah Tbk Mentok Indonesia Tin PT Timah Tbk Kundur Indonesia Tin PT Stanindo Inti Perkasa Indonesia Tin PT Sariwiguna Binasentosa Indonesia Tin PT REFINED BANGKA TIN Indonesia Tin PT Prima Timah Utama Indonesia Tin PT Panca Mega Persada Indonesia Tin PT Mitra Stania Prima Indonesia Tin PT Bukit Timah Indonesia Tin PT Belitung Industri Sejahtera Indonesia Tin PT Babel Surya Alam Lestari Indonesia Tin PT Babel Inti Perkasa Indonesia Tin PT Artha Cipta Langgeng Indonesia Tin Operaciones Metalurgicas S.A. Bolivia (Plurinational State Of) Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand Tin Novosibirsk Processing Plant Ltd. Russian Federation Tin Jiangxi New Nanshan Technology Ltd. China Tin Mitsubishi Materials Corporation Japan Tin Minsur Peru Tin Mineracao Taboca S.A. Brazil Tin Metallic Resources, Inc. United States Of America Tin Malaysia Smelting Corporation (MSC) Malaysia Tin China Tin Group Co., Ltd. China Tin Gejiu Kai Meng Industry and Trade LLC China Tin Gejiu Zili Mining And Metallurgy Co., Ltd. China Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. China Tin Fenix Metals Poland Tin Estanho de Rondonia S.A. Brazil Tin EM Vinto Bolivia (Plurinational State Of) Tin Dowa Japan Tin PT Aries Kencana Sejahtera Indonesia
Tin Alpha United States Of America Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China Tin CV Ayi Jaya Indonesia Tin DingNan JiaWang HuanBao Co. LTD China Tin Feinhütte Halsbrücke GmbH Germany Tin GuangDong Jiatian Stannum Products Co., Ltd China Tin Guangxi Zhongshan Jin Yi Smelting Co., Ltd China Tin Hunan Xianghualing Tin Co. ltd China Tin Kovohute Pribram nastupnicka, a. s. Czechia Tin Materials Eco-Refining CO.,LTD Japan Tin Medeko cast, s.r.o. Slovakia Tin PT Bangka Prima Tin Indonesia Tin PT Bangka Tin Industry Indonesia Tin PT Premium Tin Indonesia Indonesia Tin PT Rajehan Ariq Indonesia Tin Shangrao Xuri Smelting Factory China Tungsten Hannae For T Co., Ltd. Korea, Republic Of Tungsten Yudu Ansheng Tungsten Co., Ltd. China Tungsten LLC Vostok Russian Federation Tungsten OOO “Technolom” 1 Russian Federation Tungsten OOO “Technolom” 2 Russian Federation Tungsten Fujian Xinlu Tungsten China Tungsten Artek LLC Russian Federation Tungsten Cronimet Brasil Ltda Brazil Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil Tungsten Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd. China Tungsten NPP Tyazhmetprom LLC Russian Federation Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation Tungsten Lianyou Metals Co., Ltd. Taiwan, Province Of China Tungsten Moliren Ltd. Russian Federation Tungsten ACL Metais Eireli Brazil Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines Tungsten Unecha Refractory metals plant Russian Federation Tungsten Hydrometallurg, JSC Russian Federation Tungsten Ganzhou Haichuang Tungsten Co., Ltd. China
Tungsten China Molybdenum Tungsten Co., Ltd. China Tungsten Niagara Refining LLC United States Of America Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China Tungsten Masan High-Tech Materials Viet Nam Tungsten TANIOBIS Smelting GmbH & Co. KG Germany Tungsten H.C. Starck Tungsten GmbH Germany Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. China Tungsten Asia Tungsten Products Vietnam Ltd. Viet Nam Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China Tungsten Malipo Haiyu Tungsten Co., Ltd. China Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China Tungsten Xiamen Tungsten Co., Ltd. China Tungsten Wolfram Bergbau und Hutten AG Austria Tungsten Kennametal Fallon United States Of America Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. China Tungsten Japan New Metals Co., Ltd. Japan Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. China Tungsten Hunan Chenzhou Mining Co., Ltd. China Tungsten Global Tungsten & Powders Corp. United States Of America Tungsten CNMC (Guangxi) PGMA Co., Ltd. China Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China Tungsten Guangdong Xianglu Tungsten Co., Ltd. China Tungsten Kennametal Huntsville United States Of America Tungsten A.L.M.T. Corp. Japan Tungsten Beseem Mining Co., Ltd. China Tungsten Dongkuk Industries Co., Ltd. Korea, Republic Of
Tungsten Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd. China Tungsten Nanchang Cemented Carbide Limited Liability Company China Tungsten TaeguTec Ltd. Korea, Republic Of Tungsten Tungsten Vietnam Joint Stock Company Viet Nam
Schedule 2 The following 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. Andorra, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Colombia, Czechia, Denmark, Estonia, France, Germany, Ghana, India, Indonesia, Italy, Japan, Kazakhstan, Korea (Republic of), Kyrgyzstan, Lithuania, Macedonia, Malaysia, Mauritania, Mexico, Myanmar, Netherlands, New Zealand, North Macedonia, Norway, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Singapore, Slovakia, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zambia, Zimbabwe