UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
SILICON LABORATORIES INC.
(Exact name of registrant as specified in its charter)
Delaware000-2982374-2793174
(State or Other Jurisdiction
of Incorporation)
(Commission File Number)(IRS Employer
Identification No.)
400 West Cesar Chavez, Austin, TX78701
(Address of Principal Executive Offices)(Zip Code)
Dean Butler(512) 416-8500
(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:
þ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
o Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended _____.



Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

Introduction

This Specialized Disclosure Report on Form SD (“Form SD”) of Silicon Laboratories Inc. (“Silicon Laboratories” or “the Company”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act. Conflict minerals are defined by the SEC as cassiterite, columbite-tantalite, gold and wolframite, as well as their derivatives (including tantalum, tin and tungsten) and any other mineral or its derivatives determined by the United States Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (collectively, “Covered Countries”).

The Rule imposes certain reporting obligations on SEC registrants that file reports under Section 13(a) or Section 15(d) of the Exchange Act whose products contain conflict minerals that are necessary to the functionality or production of their products. For products which contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the conflict minerals originated in the Covered Countries.

Reasonable Country of Origin Inquiry

Description of Reasonable Country of Origin Inquiry Efforts

The following is a brief description of the RCOI process the Company undertook in accordance with the Rule:

The Company reviewed the components of the products provided by its suppliers to determine if such products contained conflict minerals.
The Company conducted a supply chain survey with suppliers to obtain country of origin information, which was provided by suppliers on an aggregate basis in certain cases, for the necessary conflict minerals in the Company’s products using the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”).
The Company reviewed the completed CMRT surveys for compliance with the Company’s internal policy.
The Company compared the smelters and refiners identified by the CMRT surveys against the list of facilities that have received a “conflict free” designation from the Responsible Minerals Assurance Process (“RMAP”).
The Company assessed whether the smelters and refiners had carried out all elements of reasonable due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

Results of the Reasonable Country of Origin Inquiry and Determination of Products

Based on the results of the Company’s RCOI, the following was determined:

A portion of the necessary conflict minerals contained in the Company’s products originated or may have originated in the Covered Countries and those necessary conflict minerals may not be solely from recycled or scrap sources. The Company performed due diligence measures on these conflict minerals as described in Exhibit 1.01.
A portion of the necessary conflict minerals contained in the Company’s products are from recycled or scrap sources. Conflict minerals obtained from recycled or scrap sources are considered DRC conflict free pursuant to Rule 13p-1.







Conflict Minerals Report

On May 23, 2024, Silicon Laboratories issued its Conflict Minerals Report for the calendar year ended December 31, 2023. Such report is filed herewith as Exhibit 1.01 and is also available in the Investor Relations section of Silicon Laboratories’ website under “Corporate Governance” at www.silabs.com. Silicon Laboratories’ website and the information contained therein or connected thereto are not intended to be incorporated into this Report on Form SD.

Item 1.02 Exhibit

The Conflict Minerals Report for the calendar year ended December 31, 2023 is filed as Exhibit 1.01.
Section 2 - Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.
Section 3 - Exhibits
Item 3.01 Exhibits



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 undersigned hereunto duly authorized.
SILICON LABORATORIES INC.
May 24, 2024/s/ Dean Butler
DateDean Butler
Senior Vice President and
Chief Financial Officer


Exhibit 1.01

Silicon Laboratories Inc.
Conflict Minerals Report
Calendar Year Ended December 31, 2023

This Conflict Minerals Report of Silicon Laboratories Inc. (“Silicon Laboratories” or “the Company”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). Conflict minerals are defined by the SEC as cassiterite, columbite-tantalite, gold and wolframite, as well as their derivatives (including tantalum, tin and tungsten) and any other mineral or its derivatives determined by the United States Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, “Covered Countries”).  

The Rule imposes certain reporting obligations on SEC registrants that file reports under Section 13(a) or Section 15(d) of the Exchange Act whose products contain conflict minerals that are necessary to the functionality or production of their products. For products which contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the conflict minerals originated in the Covered Countries.  If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals contained in its products originated or may have originated in a Covered Country and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources, the registrant must conduct due diligence as to whether the necessary conflict minerals contained in those products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries.  Products which do not contain necessary conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries are considered “DRC conflict free.”

Certain of the Company’s products contain conflict minerals, including gold, tantalum, tin and/or tungsten. These minerals are necessary to the functionality of the products contracted by the Company to be manufactured. Pursuant to the Rule, the Company undertook due diligence measures on the source and chain of custody of the conflict minerals in its products that the Company had reason to believe may have originated from the Covered Countries and may not have come from recycled or scrap sources to determine whether such products were DRC conflict free.

The following describes: (a) the design of the Company’s Conflict Minerals Program; (b) the Company’s conclusion based on its RCOI; (c) the measures the Company has taken to exercise due diligence on the source and chain of custody of the conflict minerals contained in its products; and (d) the Company’s products, including information on the facilities used to process the necessary conflict minerals in those products, the country of origin of the necessary conflict minerals in those products and the Company’s efforts to determine the mine or location of origin of those conflict minerals with the greatest possible specificity.

Part 1 – Due Diligence

Design of Conflict Minerals Program
 
The design of the Company’s conflict minerals program is in conformity with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, “OECD Guidance”), as it relates to the Company’s position in the minerals supply chain. Summarized below are the design components of the Company’s conflict minerals program as they relate to the five-step framework set forth in the OECD Guidance:

1.Establish strong company management systems.
Adopt and commit to a supply chain policy for minerals originating from conflict-affected and high-risk areas.
1



-The Company’s supply chain policy requires all suppliers to maintain a conflict-free sourcing policy and to comply with the Company’s internal policy based on the OECD Guidance.
Structure internal management systems to support supply chain due diligence.
-Vendors that supply the Company with products containing conflict minerals are required to complete a Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”), a supply chain survey designed to identify the smelters, refiners and countries of origin of the conflict minerals in products the vendors supply to a customer.
Establish a system of controls and transparency over the mineral supply chain.
-The Company maintains a dedicated internal system to track, analyze and approve supplier responses to supply chain surveys. The Company maintains records relating to its conflict minerals program in accordance with its record retention guidelines.
Strengthen Company engagement with suppliers.
-The Company has created an internal system of controls to ensure that both current and new suppliers report information regarding their supply chain.
Establish a Company level grievance mechanism.
-The Company maintains an external reporting system for individuals to report concerns of actions (including compliance with the Company’s conflict minerals program) that may not comply with the Company’s standards, contractual, regulatory or legal requirements.

2.Identify and assess risks in the Company’s supply chain.
Identify risks in the supply chain as recommended in the OECD Guidance Supplements.
-The Company reviews the components of the products provided by its suppliers to determine if such products may contain conflict minerals.
-The Company requests suppliers that provide products which may contain conflict minerals to complete the CMRT survey. The Company contacts vendors that do not respond to the supply chain survey by a specified date, requesting their responses. If necessary, the Company escalates its requests to management or other appropriate personnel as described in its supply chain policy.
Assess risks of adverse impacts in light of the standards of the Company’s supply chain policy consistent with the due diligence recommendations in the OECD Guidance.
-The Company reviews completed CMRT surveys for compliance with the Company’s internal policy based on the OECD Guidance.
-The Company compares the smelters and refiners identified by the CMRT surveys against the list of facilities that have received a “conformant” designation from the RMI’s Responsible Minerals Assurance Process (“RMAP”).
-The Company assesses whether the smelters and refiners have carried out all elements of reasonable due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

3.Design and implement a strategy to respond to identified risks.
Devise and adopt a risk management plan.
-The Company has adopted a risk management plan, which includes measures for risk mitigation for suppliers using smelters and refiners that have not received a conformant designation from the RMAP.
Implement the risk management plan, monitor and track performance of risk mitigation efforts and report back to designated senior management.
-The Company’s risk mitigation efforts for smelters and refiners that have not received a conformant designation from the RMAP include: (a) reviewing the mine location; (b) requesting and reviewing Certificate of Origin documents from the supplier; (c) requesting an action plan from the supplier; and (d) performing a risk assessment with an internal management team for further consideration of risk mitigation.
2



Undertake additional fact and risk assessments for risks requiring mitigation, or after a change of circumstances.
-The Company’s conflict minerals policy is an on-going program for both current and new suppliers. Any change in the Company’s supply chain may require that certain steps be repeated in order to prevent or mitigate adverse impacts.
Report findings of the supply chain risk assessment to the designated senior management of the Company.
-The Company reports findings from its supply chain risk assessment to its Executive Quality Council, which consists of members of the Company’s executive management.
If and when required by the Rule, obtain an independent private sector audit of the Company’s Conflict Minerals Report.

4.Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.
-The Company supports development and implementation of due diligence practices and tools, including:
oThe CMRT survey completed by the Company’s suppliers,
oThe RMAP assessment process used by the Company to determine facilities that have received a conformant designation.
-The Company encourages all of its conflict mineral suppliers to use facilities that have received a conformant designation.
-The Company requests its suppliers to remove sanctioned smelters and refiners from their supply chain to ensure compliance with U.S. sanctions and the OECD Due Diligence Framework.

5.Report on supply chain due diligence.
-The Company publicly reports on its supply chain due diligence policies and practices in the Investor Relations section of its website at www.silabs.com.

Conclusion Based on Reasonable Country of Origin Inquiry

Step 2 of the Company’s Conflict Minerals Program, Identify and assess risks in the Company’s supply chain, represents its RCOI. This step is designed to determine whether any of the conflict minerals in the Company’s products originated in the Covered Countries. Based on the results of the Company’s RCOI, the following was determined:

A portion of the necessary conflict minerals contained in the Company’s products originated or may have originated in the Covered Countries and those necessary conflict minerals may not be solely from recycled or scrap sources. The Company performed due diligence measures on these conflict minerals.
A portion of the necessary conflict minerals contained in the Company’s products are from recycled or scrap sources. Conflict minerals obtained from recycled or scrap sources are considered DRC conflict free pursuant to Rule 13p-1.

Description of Due Diligence Measures Performed

Steps 3 and 4 of the Company’s Conflict Minerals Program, Design and implement a strategy to respond to identified risks and Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain, respectively, represent the due diligence measures performed by the Company. The purpose of these measures is to determine whether the necessary conflict minerals contained in the Company’s products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries in order to conclude whether such products were DRC conflict free.

3



Below is a description of the measures the Company performed to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in its products:

Adopted a risk management plan, which included measures for risk mitigation for suppliers using smelters and refiners that have not received a conformant designation from the RMAP.
Requested the Company’s existing and new conflict mineral suppliers to use facilities that have received a conformant designation. Suppliers that use facilities without such designation may be removed as an approved vendor.
Monitored and tracked suppliers to ensure compliance with the Company’s Conflict Minerals Sourcing Policy.
Performed risk mitigation efforts with suppliers identified to be in conformity with the Conflict Minerals Sourcing Policy by working with them to bring them into compliance.
Reported findings from the Company’s supply chain risk assessment to its Executive Quality Council.

Results of Due Diligence Measures and Product Determination
 
The Company received responses from all of its direct suppliers subject to the supply chain survey for 2023. Collectively, their responses listed 226 smelters and refiners within their supply chains. The tables below list the smelters and refiners of conflict minerals within the Company’s supply chain for 2023. Efforts to determine this population are described above under the caption Description of Due Diligence Measures Performed. The information presented is derived from information provided by the Company’s direct suppliers and the RMAP.

Independent Private Sector Audit

An independent private sector audit is not required for 2023.

Future Due Diligence Measures

For the next reporting period, the Company is continuing to engage in the activities described above in Design of Conflict Minerals Program to mitigate the risk that its necessary conflict minerals benefit armed groups. The Company will continue to contact suppliers that use smelters and refiners identified in its supply chain survey process that have not received a conformant designation and request their participation in the RMAP or other independent third party audit program in order for them to obtain such a conformant designation.

Part 2 – Product Description

Description of the Company’s products

Silicon Laboratories is a leader in secure, intelligent wireless technology for a more connected world. The Company’s integrated hardware and software platform, intuitive development tools, industry leading ecosystem and robust support enable customers in building advanced industrial, commercial, home and life applications. The Company’s semiconductor devices leverage standard complementary metal oxide semiconductor (CMOS), a low cost, widely available process technology. 

As a fabless semiconductor company, the Company relies on third-party semiconductor fabricators to manufacture the silicon wafers that reflect its integrated chip (“IC”) designs. Each wafer contains numerous die, which are cut from the wafer to create a chip for an IC. The Company relies on third parties to assemble, package, and, in most cases, test these devices and ship these units to its customers.


4



The following facilities, to the extent known, are used to process the necessary conflict minerals in the Company’s products:

MetalFacility Name
GoldAbington Reldan Metals, LLC
GoldAgosi AG
GoldAida Chemical Industries Co., Ltd.
GoldAl Etihad Gold Refinery DMCC
GoldAlmalyk Mining and Metallurgical Complex (AMMC)
GoldAngloGold Ashanti Corrego do Sitio Mineracao
GoldArgor-Heraeus S.A.
GoldAsahi Pretec Corp.
GoldAsahi Refining Canada Ltd.
GoldAsahi Refining USA Inc.
GoldAsaka Riken Co., Ltd.
GoldAurubis AG
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)
GoldBoliden AB
GoldC. Hafner GmbH + Co. KG
GoldCCR Refinery - Glencore Canada Corporation
GoldChimet S.p.A.
GoldChugai Mining
GoldCoimpa Industrial Ltda
GoldDowa
GoldDSC (Do Sung Corporation)
GoldEco-System Recycling Co., Ltd. East Plant
GoldEco-System Recycling Co., Ltd. North Plant
GoldEco-System Recycling Co., Ltd. West Plant
GoldGeib Refining Corporation
GoldGold by Gold Colombia
GoldGold Refinery of Zijin Mining Group Co., Ltd.
GoldHeimerle + Meule GmbH
GoldHeraeus Germany GmbH Co. KG
GoldHeraeus Metals Hong Kong Ltd.
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
GoldIshifuku Metal Industry Co., Ltd.
GoldIstanbul Gold Refinery
GoldItalpreziosi
GoldJapan Mint
GoldJiangxi Copper Co., Ltd.
GoldJX Nippon Mining & Metals Co., Ltd.
GoldKazzinc
GoldKennecott Utah Copper LLC
GoldKGHM Polska Miedz Spolka Akcyjna
GoldKojima Chemicals Co., Ltd.
5



GoldKorea Zinc Co., Ltd.
GoldL'Orfebre S.A.
GoldLS-NIKKO Copper Inc.
GoldLT Metal Ltd.
GoldMaterion
GoldMatsuda Sangyo Co., Ltd.
GoldMetal Concentrators SA (Pty) Ltd.
GoldMetalor Technologies (Hong Kong) Ltd.
GoldMetalor Technologies (Singapore) Pte., Ltd.
GoldMetalor Technologies (Suzhou) Ltd.
GoldMetalor Technologies S.A.
GoldMetalor USA Refining Corporation
GoldMetalurgica Met-Mex Penoles S.A. De C.V.
GoldMitsubishi Materials Corporation
GoldMitsui Mining and Smelting Co., Ltd.
GoldMKS PAMP SA
GoldMMTC-PAMP India Pvt., Ltd.
GoldNadir Metal Rafineri San. Ve Tic. A.S.
GoldNavoi Mining and Metallurgical Combinat
GoldNH Recytech Company
GoldNihon Material Co., Ltd.
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
GoldOhura Precious Metal Industry Co., Ltd.
GoldPlanta Recuperadora de Metales SpA
GoldPT Aneka Tambang (Persero) Tbk
GoldPX Precinox S.A.
GoldRand Refinery (Pty) Ltd.
GoldREMONDIS PMR B.V.
GoldRoyal Canadian Mint
GoldSafina A.S.
GoldSancus ZFS (L’Orfebre, SA)
GoldSEMPSA Joyeria Plateria S.A.
GoldShandong Gold Smelting Co., Ltd.
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.
GoldSichuan Tianze Precious Metals Co., Ltd.
GoldSolar Applied Materials Technology Corp.
GoldSumitomo Metal Mining Co., Ltd.
GoldSungEel HiMetal Co., Ltd.
GoldT.C.A S.p.A
GoldTanaka Kikinzoku Kogyo K.K.
GoldTokuriki Honten Co., Ltd.
GoldTOO Tau-Ken-Altyn
GoldTorecom
GoldUmicore S.A. Business Unit Precious Metals Refining
GoldUnited Precious Metal Refining, Inc.
6



GoldValcambi S.A.
GoldWEEEREFINING
GoldWestern Australian Mint (T/a The Perth Mint)
GoldWIELAND Edelmetalle GmbH
GoldYamakin Co., Ltd.
GoldYokohama Metal Co., Ltd.
GoldZhongyuan Gold Smelter of Zhongjin Gold Corporation
TantalumAMG Brasil
TantalumD Block Metals, LLC
TantalumF&X Electro-Materials Ltd.
TantalumFIR Metals & Resource Ltd.
TantalumGlobal Advanced Metals Aizu
TantalumGlobal Advanced Metals Boyertown
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.
TantalumJiangxi Tuohong New Raw Material
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.
TantalumJiujiang Tanbre Co., Ltd.
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.
TantalumKEMET de Mexico
TantalumMaterion Newton Inc.
TantalumMetallurgical Products India Pvt., Ltd.
TantalumMineracao Taboca S.A.
TantalumMitsui Mining and Smelting Co., Ltd.
TantalumNingxia Orient Tantalum Industry Co., Ltd.
TantalumNPM Silmet AS
TantalumPowerX Ltd.
TantalumQuantumClean
TantalumResind Industria e Comercio Ltda.
TantalumRFH Yancheng Jinye New Material Technology Co., Ltd.
TantalumTaki Chemical Co., Ltd.
TantalumTANIOBIS Co., Ltd.
TantalumTANIOBIS GmbH
TantalumTANIOBIS Japan Co., Ltd.
TantalumTANIOBIS Smelting GmbH & Co. KG
TantalumTelex Metals
TantalumUlba Metallurgical Plant JSC
TantalumXimei Resources (Guangdong) Limited
TantalumXinXing Haorong Electronic Material Co., Ltd.
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.
TinAlpha
TinAurubis Beerse
TinAurubis Berango
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.
TinChifeng Dajingzi Tin Industry Co., Ltd.
7



TinChina Tin Group Co., Ltd.
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
TinCRM Synergies
TinCV Ayi Jaya
TinCV Venus Inti Perkasa
TinDowa
TinDS Myanmar
TinEM Vinto
TinEstanho de Rondonia S.A.
TinFabrica Auricchio Industria e Comercio Ltda.
TinFenix Metals
TinGejiu Non-Ferrous Metal Processing Co., Ltd.
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.
TinHuiChang Hill Tin Industry Co., Ltd.
TinJiangxi New Nanshan Technology Ltd.
TinLuna Smelter, Ltd.
TinMagnu's Minerais Metais e Ligas Ltda.
TinMalaysia Smelting Corporation (MSC)
TinMetallic Resources, Inc.
TinMineracao Taboca S.A.
TinMining Minerals Resources SARL
TinMinsur
TinMitsubishi Materials Corporation
TinO.M. Manufacturing (Thailand) Co., Ltd.
TinO.M. Manufacturing Philippines, Inc.
TinOperaciones Metalurgicas S.A.
TinPT Aries Kencana Sejahtera
TinPT Artha Cipta Langgeng
TinPT ATD Makmur Mandiri Jaya
TinPT Babel Inti Perkasa
TinPT Babel Surya Alam Lestari
TinPT Bangka Prima Tin
TinPT Bangka Serumpun
TinPT Bukit Timah
TinPT Cipta Persada Mulia
TinPT Menara Cipta Mulia
TinPT Mitra Stania Prima
TinPT Mitra Sukses Globalindo
TinPT Premium Tin Indonesia
TinPT Prima Timah Utama
TinPT Putera Sarana Shakti (PT PSS)
TinPT Rajawali Rimba Perkasa
TinPT Rajehan Ariq
TinPT Refined Bangka Tin
TinPT Sariwiguna Binasentosa
8



TinPT Stanindo Inti Perkasa
TinPT Sukses Inti Makmur (SIM)
TinPT Timah Nusantara
TinPT Timah Tbk Kundur
TinPT Timah Tbk Mentok
TinPT Tinindo Inter Nusa
TinPT Tommy Utama
TinResind Industria e Comercio Ltda.
TinRui Da Hung
TinSuper Ligas
TinThaisarco
TinTin Smelting Branch of Yunnan Tin Co., Ltd.
TinTin Technology & Refining
TinWhite Solder Metalurgia e Mineração Ltda.
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.
TungstenA.L.M.T. Corp.
TungstenAsia Tungsten Products Vietnam Ltd.
TungstenChina Molybdenum Tungsten Co., Ltd.
TungstenChongyi Zhangyuan Tungsten Co., Ltd.
TungstenCronimet Brasil Ltda
TungstenFujian Xinlu Tungsten Co., Ltd.
TungstenGanzhou Haichuang Tungsten Co., Ltd.
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.
TungstenGanzhou Seadragon W & Mo Co., Ltd.
TungstenGlobal Tungsten & Powders Corp.
TungstenGuangdong Xianglu Tungsten Co., Ltd.
TungstenH.C. Starck Tungsten GmbH
TungstenHubei Green Tungsten Co., Ltd.
TungstenHunan Chenzhou Mining Co., Ltd.
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
TungstenJapan New Metals Co., Ltd.
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.
TungstenJiangxi Gan Bei Tungsten Co., Ltd.
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.
TungstenJiangxi Yaosheng Tungsten Co., Ltd.
TungstenKennametal Fallon
TungstenKennametal Huntsville
TungstenLianyou Metals Co., Ltd.
TungstenMalipo Haiyu Tungsten Co., Ltd.
TungstenMasan High-Tech Materials
TungstenNiagara Refining LLC
TungstenPhilippine Chuangxin Industrial Co., Inc.
TungstenShinwon Tungsten (Fujian Shanghang) Co., Ltd.
9



TungstenTANIOBIS Smelting GmbH & Co. KG
TungstenTungsten Vietnam Joint Stock Company
TungstenWolfram Bergbau und Hutten AG
TungstenXiamen Tungsten (H.C.) Co., Ltd.
TungstenXiamen Tungsten Co., Ltd.

Country of Origin Information

Below is a summary of the mineral country of origin information collected as a result of the Company’s due diligence activities. RMI provides a list of potential countries of origin, which includes all countries of origin compiled from RMI’s member participants. The inclusion of a country on the list from RMI is not a final indicator that the Company utilized materials sourced from this country.

Andorra, Antigua, Argentina, Australia, Austria, Bahamas, Bangladesh, Barbados, Belarus, Belgium, Benin, Bolivia, Bosnia, Brazil, Bulgaria, Burkina Faso, Burundi, Cameroon, Canada, Cayman Islands, Chile, China, Columbia, Costa Rica, Côte d’Ivoire, Croatia, Curacao, Cyprus, Czech Republic, Democratic Republic of Congo, Denmark, Dominican Republic, Egypt, El Salvador, Estonia, Ethiopia, Finland, France, Germany, Ghana, Greece, Grenada, Guatemala, Guinea, Guyana, Honduras, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Kuwait, Laos, Latvia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Malta, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Oman, Pakistan, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Puerto Rico, Romania, Russian Federation, Rwanda, Saint Kitts, Saint Maarten, Saint Vincent, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, South Korea, Spain, Sweden, Switzerland, Tanzania, Thailand, Trinidad, Tunisia, Turkey, Turks and Caicos, Uganda, United Arab Emirates, United Kingdom, United States, Uruguay, Uzbekistan, Vietnam and Zimbabwe.

Efforts to determine the mine or location of origin with the greatest possible specificity of the necessary conflict minerals in the Company’s products:

In an effort to determine the mine or location of origin of the necessary conflict minerals in its products that are DRC conflict free with the greatest possible specificity, the Company developed and conducted the due diligence measures described in Part 1 of this Conflict Minerals Report.

10


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