UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM SD

SPECIALIZED DISCLOSURE REPORT

 

 

H.B. FULLER COMPANY

 
 

(Exact name of the registrant as specified in its charter)

 
     
     

Minnesota

001-09225 

41-0268370

(State or other jurisdiction of

(Commission 

(IRS Employer

incorporation or organization)

File Number)

Identification No.)

     

1200 Willow Lake Boulevard, P.O. Box 64683 St. Paul, MN 

55164-0683

(Address of principle executive offices)   

 

(Zip code)

     

John J. Corkrean, Executive Vice President and Chief Financial Officer (651) 236-5900

(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, 2023.

Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the reporting period from January 1 to December 31, 2023.

 

1

 

 

Section 1 Conflict Minerals Disclosure

 

Item 1.01 Conflicts Minerals Disclosure and Report

 

This Form SD of H.B. Fuller Company (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023.

 

A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available at www.hbfuller.com.

 

Item 1.02 Exhibit

 

As specified in Item 1.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.

 

Section 2 Resource Extraction Issuer Disclosure

 

Item 2.01. Resource Extraction Issuer Disclosure and Report

 

Not applicable

 

Section 3 -- Exhibits

 

Item 3.01 Exhibits

 

The following exhibit is filed as part of this report.

 

 

 

Exhibit No.

 

Description

       
 

1.01

 

Conflict Minerals Report of H.B. Fuller Company

 

2

 

 

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.

 

May 31, 2024

 

H.B. FULLER COMPANY

 

By:

/s/ John J. Corkrean  
 

John J. Corkrean

Executive Vice President and Chief Financial Officer

 

3
 

 

Exhibit 1.01

 

H.B. FULLER COMPANY

Conflict Minerals Report

For the reporting period from January 1, 2023 to December 31, 2023

 

 

This Conflict Minerals Report (the “Report”) of H.B. Fuller Company (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities and Exchange Act of 1934, as amended, for the reporting period from January 1, 2023 to December 31, 2023.

 

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which we collectively refer to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain of the Company’s operations manufacture, or contract to manufacture, products, and the Conflict Minerals are necessary to the functionality of those products.

 

If a registrant has reason to believe that any of the Conflict Minerals necessary to the functionality or production of their products may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the source of the Conflict Minerals. The registrant must annually submit a report, Conflict Minerals Report (a “CMR”), to the U.S. Securities and Exchange Commission (the “SEC”) that includes a description of those due diligence measures.

 

1.

Introduction.

 

 

a.

Company Overview. The Company is a leading worldwide formulator, manufacturer and marketer of adhesives, sealants and other specialty chemical products. Sales operations span 35 countries in North America, Europe, Latin America, the Asia Pacific region, India, the Middle East and Africa. Industrial adhesives represent our core product offering. Customers use our adhesives products in manufacturing common consumer and industrial goods, including food and beverage containers, disposable diapers, medical products, windows, doors, appliances, sportswear, footwear, multi-wall bags, water filtration products, insulation, textiles, automobiles, recreational vehicles, buses, trucks and trailers, marine products, solar energy systems, electronics and products for the aerospace and defense industries. In addition, we have established a variety of product offerings for residential, commercial and industrial construction markets, including sealing and waterproofing solutions for airports, roads, highways, bridges and utilities; pressure-sensitive adhesives, tapes and sealants for the commercial roofing industry; and level-setting products, ready-to-use grouts, mortars, and pressure sensitive adhesives that enable contractors and do-it-yourself consumers to quickly install flooring and tiling applications more reliably and efficiently. We also provide our customers with technical support and unique solutions designed to address their specific needs.

 

 

b.

Conflict Minerals Compliance Program (CMCP) Description. The SEC Final Conflict Minerals Rule (the “SEC Final Rule”) requires a three-step compliance process: the first step is determining the applicability of the Rule; the second step is conducting a “reasonable country of origin inquiry” (RCOI) to determine whether or not there is reason to believe that tin, tantalum, tungsten, or gold (3TG), also referred to as Conflict Minerals, from the Democratic Republic of the Congo or adjoining countries are present in the company’s products; and if so, the third step is conducting due diligence to determine the source and origin of those Conflict Minerals based on the facilities (smelter or refiners, “SORs”) in which they were processed. Companies requiring due diligence must use a nationally or internationally recognized standard such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance1) to meet the SEC regulatory requirements. The sections below describe our approach to meet each of the three steps in the SEC Final Rule compliance process; these activities were completed in concert with a third party vendor.

 

 


1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf  

 

1

 

2.

Applicability of the Conflict Minerals Rule.

 

 

a.

Product Overview. This report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2023. These products (referred to collectively as “Covered Products” in this Report) are the following:

 

 

Certain equipment used or sold in our Adhesive Coated Products business, which the Company manufactures or contracts to manufacture, which contain electronic components and materials.

 

 

Certain products manufactured or assembled by Engent, Inc. ("Engent"), a subsidiary of the Company, for its customers which contain electronic components and materials. Engent, Inc. is a wholly owned subsidiary of the Company and is a provider of manufacturing, research and development services to the electronics industry.

 

 

Certain equipment manufactured or assembled by Tonsan Adhesive, Inc. ("Tonsan"), a subsidiary of the Company, for its customers which contain electronic components and materials. Tonsan, which is based in Beijing, China, manufactures engineering adhesives across numerous industries including photovoltaic, electronics, automotive, heavy machinery and transportation.

 

3.     Reasonable Country of Origin Inquiry (RCOI). The Company has conducted a good faith reasonable country of origin inquiry regarding the Conflict Minerals. This good faith reasonable country of origin inquiry was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap resources.

 

To complete the RCOI required by the SEC Final Rule, we engaged the Company’s applicable suppliers to collect information about the presence and sourcing of tantalum, tin, tungsten and gold (3TG) used in the products and components supplied to H.B. Fuller. The program utilized the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (CMRT). Only CMRT version 6.31 or higher was accepted. Suppliers were offered two options to submit the required information: either by uploading the CMRT in MS Excel format or by completing an online survey version of this template directly in the vendor platform. In certain cases, if a supplier was unable to complete on the platform, H.B. Fuller or its third-party vendor uploaded the CMRT on their behalf.

 

The RCOI began with an introduction email sent by H.B. Fuller to its relevant suppliers describing the Conflict Minerals Compliance Program (CMCP) and identifying our vendor as a partner in the process. This letter also contained a registration and survey request link for the on-line data collection platform.

 

Subsequent engagement followed these steps:

 

 

Following the initial introductions to the program and information request, up to three reminder emails were sent to each non-responsive supplier requesting survey completion.

 

 

For suppliers who remained non-responsive to these email reminders, an escalation process was initiated.  The Company contacted the non-responsive suppliers to request their participation in the program.

 

Suppliers were asked to provide information regarding the sourcing of their materials with the goal of identifying the 3TG smelters or refiners (“SORs”) and associated mine countries of origin. Suppliers who had already performed a RCOI through the use of the CMRT were asked to upload this document into the vendor system or to provide this information in the online survey version.

 

The Company gave its suppliers the ability to share information at a level with which they were most comfortable (i.e. company, product or user-defined), but the declaration scope had to be specified.

 

Suppliers were requested to provide an electronic signature before submitting their data to the Company to verify that all answers submitted were accurate to the best of the supplier’s knowledge, but the suppliers were not required to provide an electronic signature to submit their data.

 

2

 

 

Supplier responses were evaluated for plausibility, consistency, and gaps. If any of the following “quality control” (QC) flags were raised, suppliers were contacted by the vendor on a bi-weekly basis up to three times.

 

 

One or more smelter or refiners (SORs) were listed for an unused metal;

 

 

SOR information was not provided for a used metal, or SOR information provided was not a verified metal processor;

 

 

Supplier answered yes to sourcing from the Democratic Republic of the Congo or adjoining countries (“DRC”), but none of the SORs listed are known to source from the region;

 

 

Supplier indicated that they have not received Conflict Minerals data for each metal from all relevant suppliers;

 

 

Supplier indicated they have not identified all of the SORs used for the products included in the declaration scope;

 

 

Supplier indicated they have not provided all applicable SOR information received; and;

 

 

Supplier indicated 100% of the 3TG for products covered by the declaration originates from scrap/recycled sources, but one or more SORs listed are not known to be exclusive recyclers.

 

In response to our RCOI, most smelters in our supply chain that refined Conflict Minerals sourced these materials from countries other than Covered Countries. Some Conflict Minerals in our supply chain may have originated from the Covered Countries. The majority of smelters in our supply chain are certified as noted on Schedule 1.

 

4.     Design of Due Diligence Framework. The Company’s due diligence measures have been designed to conform to the framework in the OECD Guidance in all material respects.

 

5.     Due Diligence Measures Performed. The Company has adopted a policy relating to Conflict Minerals (the “Company Policy”), incorporating the standards set forth in the OECD Guidance. The policy generally states that the Company is committed to ethical practices and compliance with applicable laws and regulations, including the SEC’s regulations and the Conflict Minerals Rules. The Company does not generally source Conflict Minerals directly from the source of supply (mines, smelters, refiners) and the Company is therefore generally removed by several levels from sources of supply of Conflict Minerals. The Company Policy commits the Company to diligently work with its global supply chain partners to identify the origin of any Conflict Minerals they may supply to the Company. The Company is committed to compliance with the Conflict Minerals Rules, including understanding the Conflict Minerals Rules, communicating and educating our personnel, suppliers and customers regarding the Conflict Minerals Rules and to create processes and procedures to conduct supply chain due diligence and comply with reporting requirements. The Company values its supplier and customer relationships and will work with our suppliers over time to ensure our compliance with the Conflict Minerals Rules.

 

The Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals and has therefore asked its suppliers to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain. Most of the suppliers who provided information regarding smelters provided this information on a company level versus a product level. Therefore, we do not know if the materials from the smelters we have included in this Conflict Minerals Report are in our products. It is possible that we may not get product level information.

 

The Company has a steering committee which oversees the activities of a multi-functional group of personnel who have worked on due diligence and compliance related to Conflict Minerals. The composition of the steering committee includes two executive level officers. The multi-functional group includes employees from the Company covering areas such as regulatory, sourcing, finance, legal, and operations.

 

In general, in our initial compliance efforts, a review of products and raw materials contained therein (including chemical composition) or components (for equipment) was completed and a list of suppliers of raw materials or components where Conflict Minerals were determined to be potentially present was assembled. New products and the raw materials used in those products are reviewed as such products are developed. The focus has been on top-tier suppliers of these raw materials or components. For these top-tier suppliers, the Company used a third-party vendor to send out questionnaires including the EICC®-GeSI form (“Supplier Questionnaire”) to inquire about the country of origin of Conflict Minerals potentially included in the Company’s Covered Products. This template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a supplier’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the supplier and its suppliers use. In addition, the template contains questions about the origin of Conflict Minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are available on EICC’s website. Responses to these questionnaires were monitored and follow-up communication was sent if a response was not received. The Company has not had any direct contact with mines, smelters or refiners.

 

3

 

The Company has undertaken an internal education process to ensure that relevant personnel are aware of the Conflict Minerals Rules and it has conducted training of several employee groups since the inception of due diligence efforts. In addition, it has designated personnel to respond to customer and supplier inquiries regarding the Conflict Minerals Rules. These personnel are part of the multi-functional group working on due diligence and compliance efforts.

 

The Company will continue to review any suppliers who are materially non-compliant with our Conflict Minerals Policy and communicate the Company’s expectation regarding compliance with our Conflict Minerals Policy. The Company will make reasonable efforts to find suppliers who comply with our Conflict Minerals Policy and who will meet our needs. The products that we manufacture that are subject to the reporting obligations of the Rule contain 3TG of unknown origin. We have not been able to determine whether the 3TG used in our products came from recycled or scrap sources, or if not, whether the 3TG originated from a Covered Country, or the specific facilities used to process these minerals, or their specific country, location or mine of origin.

 

Facilities That May Have Been Used to Process Necessary Conflict Minerals, if Known, for H.B. Fuller Products.

 

Schedule 1 to this Conflict Minerals Report includes a list of facilities that may have been used to process necessary Conflict Minerals for Company products. This list is based on our due diligence for 2023. Most of the information was provided to us on a company level versus a product level, and the suppliers did not generally limit their responses to facility information for Conflict Minerals in products they supply to us specifically.

 

Countries of Origin of the Conflict Minerals Processed by These Facilities.

 

Schedule 2 to this Conflict Minerals Report includes a list of potential countries of origin for each facility noted on the Schedule to the extent identified by the applicable smelter. Conflict Minerals contained in our Covered Products did not necessarily originate in the countries listed on Schedule 2. This is because our suppliers and manufacturers generally provided smelter and country of origin information in the survey responses at the company level (representing the suppliers’ and manufacturers’ entire product lines), and generally did not limit their responses to countries of origin for products they supply to us specifically. 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.

 

 

a.

Summary of Survey Results and Conclusion.

 

Based on the due diligence efforts and the absence of full supply chain visibility, the Company is unable to determine the source of origin of the Conflict Minerals and does not have sufficient information to conclusively determine the countries of origin of 3TG in the Company’s Covered Products.

 

As set forth above, the Company will continue to engage with its suppliers to obtain complete and accurate information about its supply chain as it relates to Conflict Minerals and their origins. 

 

Forward-Looking Statements

 

This Conflict Minerals Report contains forward-looking statements, which are based on our current expectations and involve numerous risks and uncertainties that may cause these forward-looking statements to be inaccurate. These statements include statements regarding our goals for future improvements to our due diligence process and to mitigate the risk about the sourcing of our Conflict Minerals. All forward-looking statements involve risk and uncertainty. Risks that may cause these forward-looking statements to be inaccurate include, without limitation: failure to carry out these plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; and lack of progress by smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities).  In addition, you should also consider the important factors described in reports and documents that we file from time to time with the SEC, including the factors described under the sections titled “Risk Factors” in our most recently submitted Annual and Quarterly Reports on Form 10-K and Form 10-Q, respectively, and there may be other risks and uncertainties that we are unable to identify at this time. We do not undertake to update or revise any forward-looking statements, except as required by law.

 

4

 

 

Schedule 1 

 

Metal

Standard Smelter or Refiner Name

Facility Location (Country)

Certified Smelter*

Gold

8853 S.p.A.

Italy

NO

Gold

ABC Refinery Pty Ltd.

Australia

NO

Gold

Abington Reldan Metals, LLC

United States

YES

Gold

Advanced Chemical Company

United States

NO

Gold

African Gold Refinery

Uganda

NO

Gold

Agosi AG

Germany

YES

Gold

Aida Chemical Industries Co., Ltd.

Japan

YES

Gold

Al Etihad Gold Refinery DMCC

United Arab Emirates

NO

Gold

Albino Mountinho Lda.

Portugal

NO

Gold

Alexy Metals

United States

NO

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

Uzbekistan

YES

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

Brazil

YES

Gold

Argor-Heraeus S.A.

Switzerland

YES

Gold

Asahi Pretec Corp.

Japan

YES

Gold

Asahi Refining Canada Ltd.

Canada

YES

Gold

Asahi Refining USA Inc.

United States

YES

Gold

Asaka Riken Co., Ltd.

Japan

YES

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

Turkey

NO

Gold

AU Traders and Refiners

South Africa

NO

Gold

Augmont Enterprises Private Limited

India

NO

Gold

Aurubis AG

Germany

YES

Gold

Bangalore Refinery

India

NO

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Philippines

YES

Gold

Boliden AB

Sweden

YES

Gold

C. Hafner GmbH + Co. KG

Germany

YES

Gold

Caridad

Mexico

NO

Gold

CCR Refinery - Glencore Canada Corporation

Canada

YES

Gold

Cendres + Metaux S.A.

Switzerland

NO

Gold

CGR Metalloys Pvt Ltd.

India

NO

Gold

Chimet S.p.A.

Italy

YES

Gold

Chugai Mining

Japan

YES

Gold

Coimpa Industrial LTDA

Brazil

YES

Gold

Daye Non-Ferrous Metals Mining Ltd.

China

NO

Gold

Degussa Sonne / Mond Goldhandel GmbH

Germany

NO

Gold

Dijllah Gold Refinery FZC

United Arab Emirates

NO

Gold

Dongwu Gold Group

China

NO

Gold

Dowa

Japan

YES

Gold

DSC (Do Sung Corporation)

Republic of Korea

YES

Gold

Eco-System Recycling Co., Ltd. East Plant

Japan

YES

Gold

Eco-System Recycling Co., Ltd. North Plant

Japan

YES

Gold

Eco-System Recycling Co., Ltd. West Plant

Japan

YES

Gold

Emerald Jewel Industry India Limited (Unit 1)

India

NO

Gold

Emerald Jewel Industry India Limited (Unit 2)

India

NO

Gold

Emerald Jewel Industry India Limited (Unit 3)

India

NO

Gold

Emerald Jewel Industry India Limited (Unit 4)

India

NO

Gold

Emirates Gold DMCC

United Arab Emirates

NO

Gold

Fidelity Printers and Refiners Ltd.

Zimbabwe

NO

Gold

Fujairah Gold FZC

United Arab Emirates

NO

Gold

GGC Gujrat Gold Centre Pvt. Ltd.

India

NO

Gold

Gold by Gold Colombia

Colombia

YES

 

5

 

Gold

Gold Coast Refinery

Ghana

NO

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

China

YES

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

China

YES

Gold

Guangdong Jinding Gold Limited

China

NO

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

China

NO

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

China

NO

Gold

Heimerle + Meule GmbH

Germany

YES

Gold

Heraeus Germany GmbH Co. KG

Germany

YES

Gold

Heraeus Metals Hong Kong Ltd.

China

YES

Gold

Hunan Chenzhou Mining Co., Ltd.

China

NO

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

China

NO

Gold

HwaSeong CJ CO., LTD.

Republic of Korea

NO

Gold

Industrial Refining Company

Belgium

NO

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

China

YES

Gold

International Precious Metal Refiners

United Arab Emirates

NO

Gold

Ishifuku Metal Industry Co., Ltd.

Japan

YES

Gold

Istanbul Gold Refinery

Turkey

YES

Gold

Italpreziosi

Italy

YES

Gold

JALAN & Company

India

NO

Gold

Japan Mint

Japan

YES

Gold

Jiangxi Copper Co., Ltd.

China

YES

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Russian Federation

NO

Gold

JSC Novosibirsk Refinery

Russian Federation

NO

Gold

JSC Uralelectromed

Russian Federation

NO

Gold

JX Nippon Mining & Metals Co., Ltd.

Japan

YES

Gold

K.A. Rasmussen

Norway

NO

Gold

Kaloti Precious Metals

United Arab Emirates

NO

Gold

Kazakhmys Smelting LLC

Kazakhstan

NO

Gold

Kazzinc

Kazakhstan

YES

Gold

Kennecott Utah Copper LLC

United States

YES

Gold

KGHM Polska Miedz Spolka Akcyjna

Poland

YES

Gold

Kojima Chemicals Co., Ltd.

Japan

YES

Gold

Korea Zinc Co., Ltd.

Republic of Korea

YES

Gold

Kundan Care Products Ltd.

India

NO

Gold

Kyrgyzaltyn JSC

Kyrgyzstan

NO

Gold

Kyshtym Copper-Electrolytic Plant ZAO

Russian Federation

NO

Gold

L'azurde Company For Jewelry

Saudi Arabia

NO

Gold

Lingbao Gold Co., Ltd.

China

NO

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

China

NO

Gold

L'Orfebre S.A.

Andorra

YES

Gold

LS-NIKKO Copper Inc.

Republic of Korea

YES

Gold

LT Metal Ltd.

Republic of Korea

YES

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

China

NO

Gold

Marsam Metals

Brazil

NO

Gold

Materion

United States

YES

Gold

Matsuda Sangyo Co., Ltd.

Japan

YES

Gold

MD Overseas

India

NO

Gold

Metal Concentrators SA (Pty) Ltd.

South Africa

YES

Gold

Metallix Refining Inc.

United States

NO

Gold

Metalor Technologies (Hong Kong) Ltd.

China

YES

Gold

Metalor Technologies (Singapore) Pte., Ltd.

Singapore

YES

Gold

Metalor Technologies (Suzhou) Ltd.

China

YES

Gold

Metalor Technologies S.A.

Switzerland

YES

Gold

Metalor USA Refining Corporation

United States

YES

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

Mexico

YES

 

6

 

Gold

Mitsubishi Materials Corporation

Japan

YES

Gold

Mitsui Mining and Smelting Co., Ltd.

Japan

YES

Gold

MKS PAMP SA

Switzerland

YES

Gold

MMTC-PAMP India Pvt., Ltd.

India

YES

Gold

Modeltech Sdn Bhd

Malaysia

NO

Gold

Morris and Watson

New Zealand

NO

Gold

Moscow Special Alloys Processing Plant

Russian Federation

NO

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

Turkey

YES

Gold

Navoi Mining and Metallurgical Combinat

Uzbekistan

YES

Gold

NH Recytech Company

Republic of Korea

YES

Gold

Nihon Material Co., Ltd.

Japan

YES

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

Austria

YES

Gold

Ohura Precious Metal Industry Co., Ltd.

Japan

YES

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

Russian Federation

NO

Gold

Pease & Curren

United States

NO

Gold

Penglai Penggang Gold Industry Co., Ltd.

China

NO

Gold

Planta Recuperadora de Metales SpA

Chile

YES

Gold

Prioksky Plant of Non-Ferrous Metals

Russian Federation

NO

Gold

PT Aneka Tambang (Persero) Tbk

Indonesia

YES

Gold

PX Precinox S.A.

Switzerland

YES

Gold

QG Refining, LLC

United States

NO

Gold

Rand Refinery (Pty) Ltd.

South Africa

YES

Gold

Refinery of Seemine Gold Co., Ltd.

China

NO

Gold

REMONDIS PMR B.V.

Netherlands

YES

Gold

Royal Canadian Mint

Canada

YES

Gold

SAAMP

France

NO

Gold

Sabin Metal Corp.

United States

NO

Gold

Safimet S.p.A

Italy

NO

Gold

SAFINA A.S.

Czech Republic

YES

Gold

Sai Refinery

India

NO

Gold

Sam Precious Metals

United Arab Emirates

NO

Gold

Samduck Precious Metals

Republic of Korea

NO

Gold

SAMWON METALS Corp.

Republic of Korea

NO

Gold

SEMPSA Joyeria Plateria S.A.

Spain

YES

Gold

Shandong Gold Smelting Co., Ltd.

China

YES

Gold

Shandong Humon Smelting Co., Ltd.

China

NO

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

China

NO

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

China

YES

Gold

Shenzhen CuiLu Gold Co., Ltd.

China

NO

Gold

Shenzhen Zhonghenglong Real Industry Co., Ltd.

China

NO

Gold

Shirpur Gold Refinery Ltd.

India

NO

Gold

Sichuan Tianze Precious Metals Co., Ltd.

China

YES

Gold

Singway Technology Co., Ltd.

Taiwan, Province of China

NO

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

Russian Federation

NO

Gold

Solar Applied Materials Technology Corp.

Taiwan, Province of China

YES

Gold

Sovereign Metals

India

NO

Gold

State Research Institute Center for Physical Sciences and Technology

Lithuania

NO

Gold

Sudan Gold Refinery

Sudan

NO

Gold

Sumitomo Metal Mining Co., Ltd.

Japan

YES

Gold

SungEel HiMetal Co., Ltd.

Republic of Korea

YES

Gold

Super Dragon Technology Co., Ltd.

Taiwan, Province of China

NO

Gold

T.C.A S.p.A

Italy

YES

Gold

Tanaka Kikinzoku Kogyo K.K.

Japan

YES

Gold

Tokuriki Honten Co., Ltd.

Japan

YES

Gold

Tongling Nonferrous Metals Group Co., Ltd.

China

NO

 

7

 

Gold

TOO Tau-Ken-Altyn

Kazakhstan

YES

Gold

Torecom

Republic of Korea

YES

Gold

Umicore Precious Metals Thailand

Thailand

NO

Gold

Umicore S.A. Business Unit Precious Metals Refining

Belgium

YES

Gold

United Precious Metal Refining, Inc.

United States

YES

Gold

Valcambi S.A.

Switzerland

YES

Gold

WEEEREFINING

France

YES

Gold

Western Australian Mint (T/a The Perth Mint)

Australia

YES

Gold

WIELAND Edelmetalle GmbH

Germany

YES

Gold

Yamakin Co., Ltd.

Japan

YES

Gold

Yokohama Metal Co., Ltd.

Japan

YES

Gold

Yunnan Copper Industry Co., Ltd.

China

NO

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

China

YES

Tantalum

5D Production OU

Estonia

NO

Tantalum

AMG Brasil

Brazil

YES

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

China

YES

Tantalum

D Block Metals, LLC

United States

YES

Tantalum

F&X Electro-Materials Ltd.

China

YES

Tantalum

FIR Metals & Resource Ltd.

China

YES

Tantalum

Global Advanced Metals Aizu

Japan

YES

Tantalum

Global Advanced Metals Boyertown

United States

YES

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

China

NO

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

China

YES

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

China

YES

Tantalum

Jiangxi Tuohong New Raw Material

China

YES

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

China

YES

Tantalum

Jiujiang Tanbre Co., Ltd.

China

YES

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

China

YES

Tantalum

KEMET de Mexico

Mexico

YES

Tantalum

Materion Newton Inc.

United States

YES

Tantalum

Metallurgical Products India Pvt., Ltd.

India

YES

Tantalum

Mineracao Taboca S.A.

Brazil

YES

Tantalum

Mitsui Mining and Smelting Co., Ltd.

Japan

YES

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

China

YES

Tantalum

NPM Silmet AS

Estonia

YES

Tantalum

PowerX Ltd.

Rwanda

YES

Tantalum

QuantumClean

United States

YES

Tantalum

Resind Industria e Comercio Ltda.

Brazil

YES

Tantalum

RFH Yancheng Jinye New Material Technology Co., Ltd.

China

YES

Tantalum

Solikamsk Magnesium Works OAO

Russian Federation

NO

Tantalum

Taki Chemical Co., Ltd.

Japan

YES

Tantalum

TANIOBIS Co., Ltd.

Thailand

YES

Tantalum

TANIOBIS GmbH

Germany

YES

Tantalum

TANIOBIS Japan Co., Ltd.

Japan

YES

Tantalum

TANIOBIS Smelting GmbH & Co. KG

Germany

YES

Tantalum

Telex Metals

United States

YES

Tantalum

Ulba Metallurgical Plant JSC

Kazakhstan

YES

Tantalum

XIMEI RESOURCES (GUANGDONG) LIMITED

China

YES

Tantalum

XinXing Haorong Electronic Material Co., Ltd.

China

YES

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

China

YES

Tin

Alpha

United States

YES

Tin

An Vinh Joint Stock Mineral Processing Company

Vietnam

NO

Tin

Aurubis Beerse

Belgium

YES

Tin

Aurubis Berango

Spain

YES

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

China

YES

 

8

 

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

China

YES

Tin

China Tin Group Co., Ltd.

China

YES

Tin

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

Brazil

YES

Tin

CRM Synergies

Spain

YES

Tin

CV Ayi Jaya

Indonesia

YES

Tin

CV Venus Inti Perkasa

Indonesia

YES

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

China

NO

Tin

Dowa

Japan

YES

Tin

DS Myanmar

Myanmar

YES

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

Vietnam

NO

Tin

EM Vinto

Bolivia

YES

Tin

Estanho de Rondonia S.A.

Brazil

YES

Tin

Fabrica Auricchio Industria e Comercio Ltda.

Brazil

YES

Tin

Fenix Metals

Poland

YES

Tin

Gejiu City Fuxiang Industry and Trade Co., Ltd.

China

NO

Tin

Gejiu Kai Meng Industry and Trade LLC

China

NO

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

China

YES

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

China

NO

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

China

NO

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

China

YES

Tin

HuiChang Hill Tin Industry Co., Ltd.

China

YES

Tin

Jiangxi New Nanshan Technology Ltd.

China

YES

Tin

Luna Smelter, Ltd.

Rwanda

YES

Tin

Ma'anshan Weitai Tin Co., Ltd.

China

NO

Tin

Magnu's Minerais Metais e Ligas Ltda.

Brazil

YES

Tin

Malaysia Smelting Corporation (MSC)

Malaysia

YES

Tin

Melt Metais e Ligas S.A.

Brazil

NO

Tin

Metallic Resources, Inc.

United States

YES

Tin

Mineracao Taboca S.A.

Brazil

YES

Tin

Mining Minerals Resources SARL

DRC- Congo (Kinshasa)

YES

Tin

Minsur

Peru

YES

Tin

Mitsubishi Materials Corporation

Japan

YES

Tin

Modeltech Sdn Bhd

Malaysia

NO

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

Vietnam

NO

Tin

Novosibirsk Tin Combine

Russian Federation

NO

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

Thailand

YES

Tin

O.M. Manufacturing Philippines, Inc.

Philippines

YES

Tin

Operaciones Metalurgicas S.A.

Bolivia

YES

Tin

Pongpipat Company Limited

Myanmar

NO

Tin

Precious Minerals and Smelting Limited

India

NO

Tin

PT Aries Kencana Sejahtera

Indonesia

YES

Tin

PT Artha Cipta Langgeng

Indonesia

YES

Tin

PT ATD Makmur Mandiri Jaya

Indonesia

YES

Tin

PT Babel Inti Perkasa

Indonesia

YES

Tin

PT Babel Surya Alam Lestari

Indonesia

YES

Tin

PT Bangka Prima Tin

Indonesia

YES

Tin

PT Bangka Serumpun

Indonesia

YES

Tin

PT Bangka Tin Industry

Indonesia

NO

Tin

PT Belitung Industri Sejahtera

Indonesia

NO

Tin

PT Bukit Timah

Indonesia

YES

Tin

PT Cipta Persada Mulia

Indonesia

YES

Tin

PT Menara Cipta Mulia

Indonesia

YES

Tin

PT Mitra Stania Prima

Indonesia

YES

Tin

PT Mitra Sukses Globalindo

Indonesia

YES

 

9

 

Tin

PT Panca Mega Persada

Indonesia

NO

Tin

PT Premium Tin Indonesia

Indonesia

YES

Tin

PT Prima Timah Utama

Indonesia

YES

Tin

PT Putera Sarana Shakti (PT PSS)

Indonesia

YES

Tin

PT Rajawali Rimba Perkasa

Indonesia

YES

Tin

PT Rajehan Ariq

Indonesia

YES

Tin

PT Refined Bangka Tin

Indonesia

YES

Tin

PT Sariwiguna Binasentosa

Indonesia

YES

Tin

PT Stanindo Inti Perkasa

Indonesia

YES

Tin

PT Sukses Inti Makmur

Indonesia

YES

Tin

PT Timah Tbk Kundur

Indonesia

YES

Tin

PT Timah Tbk Mentok

Indonesia

YES

Tin

PT Tinindo Inter Nusa

Indonesia

YES

Tin

PT Tirus Putra Mandiri

Indonesia

NO

Tin

PT Tommy Utama

Indonesia

YES

Tin

Resind Industria e Comercio Ltda.

Brazil

YES

Tin

Rui Da Hung

Taiwan, Province of China

YES

Tin

Super Ligas

Brazil

YES

Tin

Thaisarco

Thailand

YES

Tin

Tin Smelting Branch of Yunnan Tin Co., Ltd.

China

YES

Tin

Tin Technology & Refining

United States

YES

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

Vietnam

NO

Tin

VQB Mineral and Trading Group JSC

Vietnam

NO

Tin

White Solder Metalurgia e Mineracao Ltda.

Brazil

YES

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

China

YES

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

China

YES

Tungsten

A.L.M.T. TUNGSTEN Corp.

Japan

YES

Tungsten

ACL Metais Eireli

Brazil

NO

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

Brazil

NO

Tungsten

Artek LLC

Russian Federation

NO

Tungsten

Asia Tungsten Products Vietnam Ltd.

Vietnam

YES

Tungsten

China Molybdenum Co., Ltd.

China

YES

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

China

YES

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

China

NO

Tungsten

Cronimet Brasil Ltda

Brazil

YES

Tungsten

DONGKUK INDUSTRIES CO., LTD.

Republic of Korea

NO

Tungsten

Fujian Xinlu Tungsten Co., Ltd.

China

YES

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

China

YES

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

China

YES

Tungsten

Global Tungsten & Powders Corp.

United States

YES

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

China

YES

Tungsten

H.C. Starck Tungsten GmbH

Germany

YES

Tungsten

HANNAE FOR T Co., Ltd.

Republic of Korea

NO

Tungsten

Hubei Green Tungsten Co., Ltd.

China

YES

Tungsten

Hunan Chenzhou Mining Co., Ltd.

China

YES

Tungsten

Hunan Jintai New Material Co., Ltd.

China

NO

Tungsten

Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch

China

YES

Tungsten

Hydrometallurg, JSC

Russian Federation

NO

Tungsten

Japan New Metals Co., Ltd.

Japan

YES

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

China

YES

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

China

YES

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

China

NO

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

China

YES

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

China

YES

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

China

YES

 

10

 

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

Russian Federation

NO

Tungsten

Kennametal Fallon

United States

YES

Tungsten

Kennametal Huntsville

United States

YES

Tungsten

Lianyou Metals Co., Ltd.

Taiwan, Province of China

YES

Tungsten

LLC Vostok

Russian Federation

NO

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

China

YES

Tungsten

Masan High-Tech Materials

Vietnam

YES

Tungsten

Moliren Ltd.

Russian Federation

NO

Tungsten

Nam Viet Cromit Joint Stock Company

Vietnam

NO

Tungsten

Niagara Refining LLC

United States

YES

Tungsten

NPP Tyazhmetprom LLC

Russian Federation

NO

Tungsten

OOO “Technolom” 1

Russian Federation

NO

Tungsten

OOO “Technolom” 2

Russian Federation

NO

Tungsten

Philippine Chuangxin Industrial Co., Inc.

Philippines

YES

Tungsten

Shinwon Tungsten (Fujian Shanghang) Co., Ltd.

China

YES

Tungsten

TANIOBIS Smelting GmbH & Co. KG

Germany

YES

Tungsten

Tungsten Vietnam Joint Stock Company

Vietnam

YES

Tungsten

Unecha Refractory Metals Plant

Russian Federation

NO

Tungsten

Wolfram Bergbau und Hutten AG

Austria

YES

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

China

YES

Tungsten

Xiamen Tungsten Co., Ltd.

China

YES

Tungsten

YUDU ANSHENG TUNGSTEN CO., LTD.

China

NO

 

* A “Yes” in this column indicates that the smelter (i) has an active certification with the Responsible Minerals Assurance Process (“RMAP”) or is in the process of renewing their certification, (ii) is actively moving through the RMAP certification process, (iii) is a tungsten smelter that has committed to obtain a RMAP certification within 2 years of membership with the Tungsten Industry-Conflict Minerals Committee (TI-CMC), (iv) has obtained a Responsible Gold Certification from the London Bullion Market Association (LBMA), or (v) has obtained a Chain-of-Custody Certification from the Responsible Jewelry Council (RJC).

A “No” in this column indicates that we are unaware of one of the above-referenced certifications for this smelter.

 

Schedule 2

 

The following list of potential countries of origin is 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.

 

Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Republic of the Congo, Czech Republic, Democratic Republic of the Congo, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong SAR, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Jersey, Kazakhstan, Kenya, Republic of Korea, Kyrgyzstan, Laos, Luxembourg, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Sweden, Switzerland, Taiwan (Province of China), Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Vietnam, Zambia, Zimbabwe.

 

11

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