EX-1.01 2 kmb_exhibit101x2015.htm CONFLICT MINERALS REPORT
Exhibit 1.01
Kimberly-Clark Corporation
Conflict Minerals Report
for the Year Ended December 31, 2015
This Conflict Minerals Report of Kimberly-Clark Corporation has been prepared for the period from January 1, 2015 to December 31, 2015. Unless the context indicates otherwise, “Kimberly-Clark,” “we,” “us” and “our” refer to Kimberly-Clark Corporation and its consolidated subsidiaries.
During 2015, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs (as defined below) are necessary to their functionality or production (“Covered Products”). The term “3TGs” refers to columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten. The vast majority of our products do not contain 3TGs and our revenue from sales of Covered Products in 2015 was immaterial relative to our total net sales. In 2015, we manufactured or contracted for manufacture Covered Products primarily through our K-C Professional business. We have no reason to believe that any of the Covered Products are in our consumer businesses, which include our Personal Care and Consumer Tissue operating segments.
Electronic components account for a significant majority of any 3TGs present in our Covered Products. Electronic components commonly contain 3TGs for a variety of reasons (for example tin is usually present in solder). The Covered Products include dispensers (e.g., for hand sanitizers, soaps and paper products) which contain electronic sensors and actuators. In addition, certain of our welding kits may contain tin and tungsten in metal components of the kits.
We have developed a conflict minerals compliance program reasonably designed to identify whether the 3TGs in our Covered Products originated in the Democratic Republic of the Congo or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia) (collectively, the “Covered Countries”), or whether any of the 3TGs in our Covered Products are from recycled or scrap sources. Our conflict minerals compliance program is overseen by an internal team of subject matter experts from key functions (“Core Team”), with assistance from a third-party consulting firm that executed certain procedures under our direction, supervision and oversight.
Description of Our Reasonable Country of Origin Inquiry
We have conducted a reasonable country of origin inquiry (“RCOI”) that was designed to determine whether any of the 3TGs in our Covered Products originated from one of the Covered Countries or was from recycled or scrap sources.
In conducting our RCOI, we used a risk-based approach. First, we identified our product materials which contain or potentially contain 3TGs necessary to their functionality or production. Second, we identified the direct suppliers of the materials, components and finished goods supplied to us for those products. Third, we categorized each supplier’s “supplier risk” as “high risk,” “medium risk,” “low risk” and “very low risk,” based on the supplier’s annual revenues and whether they are a U.S. publically held company. Fourth, we similarly risk-stratified each supplier’s “materials risk” based on the likelihood that the product materials they supply to us contain 3TGs. Fifth, we conducted a supply chain survey of our direct suppliers to provide information on the origin of any 3TGs contained in materials supplied to us in our Covered Products, including sources of 3TGs supplied to these direct suppliers from second-tier suppliers, as well as suppliers further upstream. In 2015, the Core Team reviewed the complete list of material groups to confirm that no additional suppliers were added to the supply chain as well as to confirm prior conclusions of which material groups were likely to contain 3TGs.
Our survey included those suppliers rated with a materials risk of high risk and medium risk. As we determined that it would not be necessary to survey all of our low risk and very low risk rated suppliers, in the first year of the conflict minerals program we developed a representative sample of those suppliers, taking into account the risk-based approach outlined above. This sampling program allowed us to confirm that the materials associated with our low risk and very low risk suppliers do not contain 3TGs. We continued to survey the sampling group in 2015 and, in addition, we conducted a supply-chain survey of all low risk and very low risk suppliers that failed to respond previously.
We implemented and administered our supply chain survey with the assistance of our third-party consultant. The survey employed the Conflict Minerals Reporting Template (the “CMRT”) developed by the Conflict-Free Sourcing Initiative (“CFSI”) of the Electronic Industry Citizenship Coalition - Global eSustainability Initiative. The
1

CMRT was developed to facilitate general disclosures and information regarding smelters that provide materials to the supplier. It includes questions regarding the supplier’s conflict-free minerals policy, the engagement process with its direct suppliers and identification of the smelters used by the supplier.
As of May 9, 2016, approximately 98% of our direct suppliers included in the supply chain survey have responded, including all of our high risk and medium risk suppliers. Nine suppliers indicated that their supply chain includes smelters or refiners sourcing from the Covered Countries; however, we have validated in the due diligence process described below that each of these smelters and refiners has been certified as “conflict-free” by an internationally-recognized validation scheme for 3TG smelters and refiners. A significant majority of the responses received were unable to specify all smelters or refiners used for materials supplied to us. Furthermore, many of the responses were provided at the company or division level, rather than the product level, and indicated that the origin of 3TGs was “unknown.”
Due Diligence Process
Following our RCOI, we conducted a due diligence review of the source and chain of custody of the 3TGs contained in our Covered Products. Our due diligence measures were designed to conform in all material respects with the framework in 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 the related Supplements for gold and for tin, tantalum and tungsten.
Management Systems and Controls
Internal Team
The Company has a centralized, cross-functional conflict minerals Core Team to oversee the implementation and daily administration of the program, which includes geographically diverse representation from the following departments: Procurement; Legal; Finance; Internal Audit; Environmental, Health, Safety & Sustainability; and Corporate Social Compliance. The Core Team periodically reports to senior management on program developments and progress. The Company’s Senior Vice President & Chief Supply Chain Officer serves as the executive sponsor of the Conflict Minerals Compliance program. Members of the Core Team have formed and have participated in industry groups, forums, and conferences focused on compliance with responsible sourcing of conflict minerals and related legal requirements.
Control Systems
We address 3TGs sourced from the Covered Countries in our Supplier Social Compliance Standards, which are embedded in our Purchase Order Terms and Conditions and certain of our supplier agreements, as well as posted on our corporate website at: http://www.kimberly-clark.com/sustainability/people/CSC.aspx
Our suppliers are required to source responsibly and adhere to our Supplier Social Compliance Standards, which require suppliers to source 3TGs from smelters and refiners who source outside of the Covered Countries or that are designated as “conflict-free” by the CFSI. These standards further require our suppliers to develop and provide written evidence of their own due diligence programs to promote “conflict-free” supply chains. We engage independent third-party audit firms to conduct Supplier Social Compliance audits (on-site inspections) of suppliers of certain commodity categories, particularly contract manufacturers. If an assessment reveals that the supplier is in violation of our Supplier Social Compliance Standards, we require that the supplier submit documentation showing that violations have been addressed and remediated. We conduct additional follow-up audits at our discretion to confirm compliance with our Supplier Social Compliance Standards. Any concerns regarding suppliers or our compliance program can be reported to our Corporate Social Compliance team as specified on our Corporate Social Compliance website. During 2015, we conducted 155 supplier audits covering 132 suppliers.
In 2015, we engaged a third party to reach out to a number of our stakeholders and seek input on how well our sustainability report provided transparent, comprehensive and accessible coverage of key issues. In addition, we asked stakeholders for their views on the sustainability issues they expect would have a significant impact on Kimberly-Clark in the future. We engaged stakeholders from eight groups (business partners, suppliers, customers, employees, investors, socially responsible investors, NGOs and academics) through interviews and written questionnaires.
2

Supplier Engagement
We rely on our direct (tier one) suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us - including sources of 3TGs that are supplied to them from upstream suppliers.
In addition, to ensure our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party consultant have provided training to our suppliers through webinars, videos and substantial one-on-one discussions. The Company conducts periodic in-house training of its key business units, e.g., Research and Engineering; Procurement; and Environmental, Health, Safety and Sustainability, to educate employees to identify 3TGs in products and to work more closely with our suppliers to encourage responsible sourcing.
As part of our on-going stakeholder engagement efforts, we require key contract manufacturing facilities to certify that they would participate in our Corporate Social Compliance Program and adhere to our Supplier Social Compliance Standards. In 2015, the Company achieved 100% participation from its key contract manufacturers.
Grievance Mechanism
Kimberly-Clark maintains a comprehensive and multi-faceted system for the reporting of Code of Conduct violations, concerns and grievances. To ensure that every employee (and every stakeholder) has the ability to report concerns on an anonymous basis, we have established a Code of Conduct telephone hotline which is staffed by a professional independent company. This line is available 24 hours a day, 365 days a year, and one can give a report in any language. The reporting process and hotline contact information are posted on our external website. In addition, we sent our Code of Conduct, which includes information about the hotline, to all key suppliers during 2015.
Calls are investigated by various internal subject matter experts in our Compliance, Internal Audit, Global Security, Human Resources and Legal departments. We report summary results and statistics to our executive leadership and our Board of Directors as deemed appropriate.
Maintenance of Records
We have adopted a policy to retain relevant documentation for a minimum of five years.
Identify and Assess Risk in the Supply Chain
As part of our due diligence process, we reviewed our suppliers’ responses to the supply chain survey against criteria developed to determine which responses required further engagement. These criteria included untimely or incomplete responses, as well as inconsistencies within the reported data.
Certain of the responses to the surveys included the names of facilities listed by the suppliers as smelters or refiners. We compared each facility listed in the responses to the lists of smelters and refiners maintained by the CFSI to verify the existence of the facility and to determine whether the facility is certified as conflict-free.
We classify each listed smelter or refiner as high, medium or low risk based on three scoring criteria: recognition by the CFSI, geographic proximity to the Covered Countries, and certification by the CFSI as conflict-free. If any smelter or refiner is not recognized by the CFSI, we conduct outreach and research to gain more information about whether they are a smelter or a refiner, sourcing practices, location, and country of origin. Additionally, if any smelter is not certified conflict-free, we conduct outreach providing education on the Conflict-Free Smelter Program and encouraging them to join this program.
Design and Implement a Strategy to Respond to Identified Risks
We have developed a risk management plan that includes the following elements:

• | Communication directly with executive officers of our suppliers of our conflict minerals requirements under our Supplier Social Compliance Standards, as described above.

• | Communication with suppliers who do not satisfy our due diligence requests to obtain more complete and accurate responses.

• | Additional follow up, due diligence, and/or risk mitigation activities, as appropriate, upon learning of changes in supplier circumstances or information.

3

Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We encourage targeted suppliers and/or facilities to participate in comparable due diligence validation activities. We do not typically have a direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain.
Report Annually on Supply Chain Due Diligence
The Company reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC.
Due Diligence Results
Attachment A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains and indicates which of these smelters and refiners have been certified as conflict-free. The majority of the responses received either provided data at a company or divisional level or did not specify the smelters or refiners used for materials supplied to us. We are therefore unable to determine whether the smelters or refiners reported by certain suppliers processed the 3TGs in the materials supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. Attachment B contains an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the CFSI.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products with the greatest possible specificity, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners using the CFSI list, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
This Report has not been audited, nor is an independent private sector audit required for this Report.
Risk Mitigation and Due Diligence Improvement
We have taken or intend to take the following steps to further mitigate the risk that the 3TGs in our Covered Products could benefit armed groups in the Covered Countries:

• | Continue to review the refinement and expansion of the CFSI list of smelters and refiners to validate the smelters and refiners provided by suppliers.

• | Educate and train suppliers with respect to developments in conflict minerals compliance programs and encourage them to establish procedures to identify the origin of 3TGs.

• | Continue to engage with direct suppliers and direct them to training resources in order to increase the survey response rate and improve response content.

• | Expand capabilities of the Core Team by including additional subject matter experts in geographic regions such as Europe, the Middle East and Africa.

• | Provide continuing education of the Core Team and stakeholders on their on-going responsibilities with respect to conflict minerals compliance and any legislative or organizational developments.

• | Encourage suppliers that provided company or division level information for 2015 to provide product level information for 2016 through ongoing communications with these suppliers.

• | Maintain a global supplier screening program that requires our suppliers to provide information regarding 3TGs and requires each new in-scope direct supplier we add to our supply chain to provide a completed CMRT.

4

Attachment A
2015 Facility List
The following lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains and indicates (with the * symbol) which of these smelters and refiners have been certified as conflict-free.

Metal |  | Standard Smelter Name |  | Smelter Facility Location
Gold |  | Advanced Chemical Company |  | UNITED STATES
Gold |  | Aida Chemical Industries Co., Ltd. * |  | JAPAN
Gold |  | Aktyubinsk Copper Company TOO |  | KAZAKHSTAN
Gold |  | Al Etihad Gold Refinery DMCC |  | UNITED ARAB EMIRATES
Gold |  | Allgemeine Gold-und Silberscheideanstalt A.G. * |  | GERMANY
Gold |  | Almalyk Mining and Metallurgical Complex (AMMC) |  | UZBEKISTAN
Gold |  | AngloGold Ashanti Córrego do Sítio Mineração * |  | BRAZIL
Gold |  | Argor-Heraeus SA * |  | SWITZERLAND
Gold |  | Asahi Pretec Corporation * |  | JAPAN
Gold |  | Asahi Refining Canada Limited * |  | CANADA
Gold |  | Asahi Refining USA Inc. * |  | UNITED STATES
Gold |  | Asaka Riken Co., Ltd. * |  | JAPAN
Gold |  | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |  | TURKEY
Gold |  | Aurubis AG * |  | GERMANY
Gold |  | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) * |  | PHILIPPINES
Gold |  | Bauer Walser AG |  | GERMANY
Gold |  | Boliden AB * |  | SWEDEN
Gold |  | C. Hafner GmbH + Co. KG * |  | GERMANY
Gold |  | Caridad |  | MEXICO
Gold |  | CCR Refinery - Glencore Canada Corporation * |  | CANADA
Gold |  | Cendres + Métaux SA |  | SWITZERLAND
Gold |  | Chimet S.p.A. * |  | ITALY
Gold |  | Chugai Mining |  | JAPAN
Gold |  | Daejin Indus Co., Ltd. |  | KOREA, REPUBLIC OF
Gold |  | Daye Non-Ferrous Metals Mining Ltd. |  | CHINA
Gold |  | Do Sung Corporation |  | KOREA, REPUBLIC OF
Gold |  | DODUCO GmbH * |  | GERMANY
Gold |  | Dowa * |  | JAPAN
Gold |  | Eco-System Recycling Co., Ltd. * |  | JAPAN
Gold |  | Elemetal Refining, LLC * |  | UNITED STATES
Gold |  | Emirates Gold DMCC * |  | UNITED ARAB EMIRATES
Gold |  | Faggi Enrico S.p.A. |  | ITALY
Gold |  | Fidelity Printers and Refiners Ltd. |  | ZIMBABWE
Gold |  | Gansu Seemine Material Hi-Tech Co., Ltd. |  | CHINA
Gold |  | Geib Refining Corporation |  | UNITED STATES
Gold |  | Great Wall Precious Metals Co., Ltd. of CBPM |  | CHINA
Gold |  | Guangdong Jinding Gold Limited |  | CHINA
Gold |  | Guoda Safina High-Tech Environmental Refinery Co., Ltd. |  | CHINA
Gold |  | Hangzhou Fuchunjiang Smelting Co., Ltd. |  | CHINA

5

Metal |  | Standard Smelter Name |  | Smelter Facility Location
Gold |  | Heimerle + Meule GmbH * |  | GERMANY
Gold |  | Heraeus Ltd. Hong Kong * |  | CHINA
Gold |  | Heraeus Precious Metals GmbH & Co. KG * |  | GERMANY
Gold |  | Hunan Chenzhou Mining Co., Ltd. |  | CHINA
Gold |  | Hwasung CJ Co., Ltd. |  | KOREA, REPUBLIC OF
Gold |  | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited * |  | CHINA
Gold |  | Ishifuku Metal Industry Co., Ltd. * |  | JAPAN
Gold |  | Istanbul Gold Refinery * |  | TURKEY
Gold |  | Japan Mint * |  | JAPAN
Gold |  | Jiangxi Copper Company Limited * |  | CHINA
Gold |  | JSC Ekaterinburg Non-Ferrous Metal Processing Plant * |  | RUSSIAN FEDERATION
Gold |  | JSC Uralelectromed * |  | RUSSIAN FEDERATION
Gold |  | JX Nippon Mining & Metals Co., Ltd. * |  | JAPAN
Gold |  | Kaloti Precious Metals |  | UNITED ARAB EMIRATES
Gold |  | Kazakhmys Smelting LLC |  | KAZAKHSTAN
Gold |  | Kazzinc * |  | KAZAKHSTAN
Gold |  | Kennecott Utah Copper LLC * |  | UNITED STATES
Gold |  | KGHM Polska MiedŸ Spólka Akcyjna |  | POLAND
Gold |  | Kojima Chemicals Co., Ltd. * |  | JAPAN
Gold |  | Korea Metal Co., Ltd. |  | KOREA, REPUBLIC OF
Gold |  | Korea Zinc Co. Ltd. |  | KOREA, REPUBLIC OF
Gold |  | Kyrgyzaltyn JSC |  | KYRGYZSTAN
Gold |  | L' azurde Company For Jewelry |  | SAUDI ARABIA
Gold |  | Lingbao Gold Company Limited |  | CHINA
Gold |  | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |  | CHINA
Gold |  | LS-NIKKO Copper Inc. * |  | KOREA, REPUBLIC OF
Gold |  | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |  | CHINA
Gold |  | Materion * |  | UNITED STATES
Gold |  | Matsuda Sangyo Co., Ltd. * |  | JAPAN
Gold |  | Metahub Industries Sdn. Bhd. |  | MALAYSIA
Gold |  | Metalor Technologies (Hong Kong) Ltd. * |  | CHINA
Gold |  | Metalor Technologies (Singapore) Pte., Ltd. * |  | SINGAPORE
Gold |  | Metalor Technologies (Suzhou) Ltd. |  | CHINA
Gold |  | Metalor Technologies SA * |  | SWITZERLAND
Gold |  | Metalor USA Refining Corporation * |  | UNITED STATES
Gold |  | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V * |  | MEXICO
Gold |  | Mitsubishi Materials Corporation * |  | JAPAN
Gold |  | Mitsui Mining and Smelting Co., Ltd. * |  | JAPAN
Gold |  | MMTC-PAMP India Pvt., Ltd. * |  | INDIA
Gold |  | Morris and Watson |  | NEW ZEALAND
Gold |  | Moscow Special Alloys Processing Plant * |  | RUSSIAN FEDERATION
Gold |  | Nadir Metal Rafineri San. Ve Tic. A.S. * |  | TURKEY
Gold |  | Navoi Mining and Metallurgical Combinat |  | UZBEKISTAN
Gold |  | Nihon Material Co., Ltd. * |  | JAPAN
Gold |  | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH * |  | AUSTRIA

6

Metal |  | Standard Smelter Name |  | Smelter Facility Location
Gold |  | Ohura Precious Metal Industry Co., Ltd. * |  | JAPAN
Gold |  | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) * |  | RUSSIAN FEDERATION
Gold |  | OJSC Kolyma Refinery |  | RUSSIAN FEDERATION
Gold |  | OJSC Novosibirsk Refinery * |  | RUSSIAN FEDERATION
Gold |  | PAMP SA * |  | SWITZERLAND
Gold |  | Penglai Penggang Gold Industry Co., Ltd. |  | CHINA
Gold |  | Prioksky Plant of Non-Ferrous Metals * |  | RUSSIAN FEDERATION
Gold |  | PT Aneka Tambang (Persero) Tbk * |  | INDONESIA
Gold |  | PX Précinox SA * |  | SWITZERLAND
Gold |  | Rand Refinery (Pty) Ltd. * |  | SOUTH AFRICA
Gold |  | Republic Metals Corporation * |  | UNITED STATES
Gold |  | Royal Canadian Mint * |  | CANADA
Gold |  | Sabin Metal Corp. |  | UNITED STATES
Gold |  | Samduck Precious Metals |  | KOREA, REPUBLIC OF
Gold |  | SAMWON Metals Corp. |  | KOREA, REPUBLIC OF
Gold |  | SAXONIA Edelmetalle GmbH |  | GERMANY
Gold |  | Schone Edelmetaal B.V. * |  | NETHERLANDS
Gold |  | SEMPSA Joyería Platería SA * |  | SPAIN
Gold |  | Shandong Tiancheng Biological Gold Industrial Co., Ltd. |  | CHINA
Gold |  | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. * |  | CHINA
Gold |  | Sichuan Tianze Precious Metals Co., Ltd. * |  | CHINA
Gold |  | Singway Technology Co., Ltd. * |  | TAIWAN
Gold |  | So Accurate Group, Inc. |  | UNITED STATES
Gold |  | SOE Shyolkovsky Factory of Secondary Precious Metals * |  | RUSSIAN FEDERATION
Gold |  | Solar Applied Materials Technology Corp. * |  | TAIWAN
Gold |  | Sudan Gold Refinery |  | SUDAN
Gold |  | Sumitomo Metal Mining Co., Ltd. * |  | JAPAN
Gold |  | T.C.A S.p.A * |  | ITALY
Gold |  | Tanaka Kikinzoku Kogyo K.K. * |  | JAPAN
Gold |  | The Refinery of Shandong Gold Mining Co., Ltd. * |  | CHINA
Gold |  | Tokuriki Honten Co., Ltd. * |  | JAPAN
Gold |  | Tongling Nonferrous Metals Group Co., Ltd. |  | CHINA
Gold |  | Torecom |  | KOREA, REPUBLIC OF
Gold |  | Umicore Brasil Ltda. * |  | BRAZIL
Gold |  | Umicore Precious Metals Thailand * |  | THAILAND
Gold |  | Umicore SA Business Unit Precious Metals Refining * |  | BELGIUM
Gold |  | United Precious Metal Refining, Inc. * |  | UNITED STATES
Gold |  | Valcambi SA * |  | SWITZERLAND
Gold |  | Western Australian Mint trading as The Perth Mint * |  | AUSTRALIA
Gold |  | WIELAND Edelmetalle GmbH |  | GERMANY
Gold |  | Yamamoto Precious Metal Co., Ltd. * |  | JAPAN
Gold |  | Yokohama Metal Co., Ltd. * |  | JAPAN
Gold |  | Yunnan Copper Industry Co., Ltd. |  | CHINA
Gold |  | Zhongyuan Gold Smelter of Zhongjin Gold Corporation * |  | CHINA
Gold |  | Zijin Mining Group Co., Ltd. Gold Refinery * |  | CHINA

7

Metal |  | Standard Smelter Name |  | Smelter Facility Location
Tantalum |  | Avon Specialty Metals Ltd |  | UNITED KINGDOM
Tantalum |  | Changsha South Tantalum Niobium Co., Ltd. * |  | CHINA
Tantalum |  | Conghua Tantalum and Niobium Smeltry * |  | CHINA
Tantalum |  | D Block Metals, LLC * |  | UNITED STATES
Tantalum |  | Duoluoshan * |  | CHINA
Tantalum |  | Exotech Inc. * |  | UNITED STATES
Tantalum |  | F&X Electro-Materials Ltd. * |  | CHINA
Tantalum |  | FIR Metals & Resource Ltd. * |  | CHINA
Tantalum |  | Global Advanced Metals Aizu * |  | JAPAN
Tantalum |  | Global Advanced Metals Boyertown * |  | UNITED STATES
Tantalum |  | Guangdong Zhiyuan New Material Co., Ltd. * |  | CHINA
Tantalum |  | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch |  | CHINA
Tantalum |  | H.C. Starck Co., Ltd. * |  | THAILAND
Tantalum |  | H.C. Starck GmbH Goslar * |  | GERMANY
Tantalum |  | H.C. Starck GmbH Laufenburg * |  | GERMANY
Tantalum |  | H.C. Starck Hermsdorf GmbH * |  | GERMANY
Tantalum |  | H.C. Starck Inc. * |  | UNITED STATES
Tantalum |  | H.C. Starck Ltd. * |  | JAPAN
Tantalum |  | H.C. Starck Smelting GmbH & Co.KG * |  | GERMANY
Tantalum |  | Hengyang King Xing Lifeng New Materials Co., Ltd. * |  | CHINA
Tantalum |  | Hi-Temp Specialty Metals, Inc. * |  | UNITED STATES
Tantalum |  | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. * |  | CHINA
Tantalum |  | JiuJiang JinXin Nonferrous Metals Co., Ltd. * |  | CHINA
Tantalum |  | Jiujiang Tanbre Co., Ltd. * |  | CHINA
Tantalum |  | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. * |  | CHINA
Tantalum |  | KEMET Blue Metals * |  | MEXICO
Tantalum |  | KEMET Blue Powder * |  | UNITED STATES
Tantalum |  | King-Tan Tantalum Industry Ltd. * |  | CHINA
Tantalum |  | LSM Brasil S.A. * |  | BRAZIL
Tantalum |  | Metallurgical Products India Pvt., Ltd. * |  | INDIA
Tantalum |  | Mineração Taboca S.A. * |  | BRAZIL
Tantalum |  | Mitsui Mining & Smelting * |  | JAPAN
Tantalum |  | Molycorp Silmet A.S. * |  | ESTONIA
Tantalum |  | Ningxia Orient Tantalum Industry Co., Ltd. * |  | CHINA
Tantalum |  | Plansee SE Liezen * |  | AUSTRIA
Tantalum |  | Plansee SE Reutte * |  | AUSTRIA
Tantalum |  | QuantumClean * |  | UNITED STATES
Tantalum |  | Resind Indústria e Comércio Ltda. * |  | BRAZIL
Tantalum |  | RFH Tantalum Smeltry Co., Ltd. * |  | CHINA
Tantalum |  | Solikamsk Magnesium Works OAO * |  | RUSSIAN FEDERATION
Tantalum |  | Taki Chemicals * |  | JAPAN
Tantalum |  | Telex Metals * |  | UNITED STATES
Tantalum |  | Tranzact, Inc. * |  | UNITED STATES
Tantalum |  | Ulba Metallurgical Plant JSC * |  | KAZAKHSTAN
Tantalum |  | XinXing HaoRong Electronic Material Co., Ltd. * |  | CHINA

8

Metal |  | Standard Smelter Name |  | Smelter Facility Location
Tantalum |  | Yichun Jin Yang Rare Metal Co., Ltd. * |  | CHINA
Tantalum |  | Zhuzhou Cemented Carbide * |  | CHINA
Tin |  | Alpha * |  | UNITED STATES
Tin |  | An Thai Minerals Company Limited |  | VIET NAM
Tin |  | An Vinh Joint Stock Mineral Processing Company |  | VIET NAM
Tin |  | Chenzhou Yun Xiang mining limited liability company |  | CHINA
Tin |  | China Tin Group Co., Ltd. * |  | CHINA
Tin |  | CNMC (Guangxi) PGMA Co., Ltd. |  | CHINA
Tin |  | Cooperativa Metalurgica de Rondônia Ltda. * |  | BRAZIL
Tin |  | CV Ayi Jaya * |  | INDONESIA
Tin |  | CV Dua Sekawan * |  | INDONESIA
Tin |  | CV Gita Pesona * |  | INDONESIA
Tin |  | CV Serumpun Sebalai * |  | INDONESIA
Tin |  | CV Tiga Sekawan |  | INDONESIA
Tin |  | CV United Smelting * |  | INDONESIA
Tin |  | CV Venus Inti Perkasa * |  | INDONESIA
Tin |  | Dowa * |  | JAPAN
Tin |  | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |  | VIETNAM
Tin |  | Elmet S.L.U. (Metallo Group) * |  | SPAIN
Tin |  | EM Vinto * |  | BOLIVIA
Tin |  | Estanho de Rondônia S.A. |  | BRAZIL
Tin |  | Feinhütte Halsbrücke GmbH |  | GERMANY
Tin |  | Fenix Metals * |  | POLAND
Tin |  | Gejiu Fengming Metalurgy Chemical Plant |  | CHINA
Tin |  | Gejiu Kai Meng Industry and Trade LLC |  | CHINA
Tin |  | Gejiu Non-Ferrous Metal Processing Co., Ltd. * |  | CHINA
Tin |  | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |  | CHINA
Tin |  | Gejiu Zili Mining And Metallurgy Co., Ltd. |  | CHINA
Tin |  | Guanyang Guida Nonferrous Metal Smelting Plant |  | CHINA
Tin |  | HuiChang Hill Tin Industry Co., Ltd. |  | CHINA
Tin |  | Huichang Jinshunda Tin Co., Ltd. |  | CHINA
Tin |  | Jiangxi Ketai Advanced Material Co., Ltd. * |  | CHINA
Tin |  | Linwu Xianggui Ore Smelting Co., Ltd. |  | CHINA
Tin |  | Magnu's Minerais Metais e Ligas Ltda. * |  | BRAZIL
Tin |  | Malaysia Smelting Corporation (MSC) * |  | MALAYSIA
Tin |  | Melt Metais e Ligas S/A * |  | BRAZIL
Tin |  | Metahub Industries Sdn. Bhd. |  | MALAYSIA
Tin |  | Metallic Resources, Inc. * |  | UNITED STATES
Tin |  | Metallo-Chimique N.V. * |  | BELGIUM
Tin |  | Mineração Taboca S.A. * |  | BRAZIL
Tin |  | Minsur * |  | PERU
Tin |  | Mitsubishi Materials Corporation * |  | JAPAN
Tin |  | Nankang Nanshan Tin Manufactory Co., Ltd. |  | CHINA
Tin |  | Nghe Tinh Non-Ferrous Metals Joint Stock Company |  | VIET NAM
Tin |  | O.M. Manufacturing (Thailand) Co., Ltd. * |  | THAILAND

9

Metal |  | Standard Smelter Name |  | Smelter Facility Location
Tin |  | O.M. Manufacturing Philippines, Inc. * |  | PHILIPPINES
Tin |  | Operaciones Metalurgical S.A. * |  | BOLIVIA
Tin |  | Phoenix Metal Ltd. |  | RWANDA
Tin |  | PT Alam Lestari Kencana |  | INDONESIA
Tin |  | PT Aries Kencana Sejahtera * |  | INDONESIA
Tin |  | PT Artha Cipta Langgeng * |  | INDONESIA
Tin |  | PT ATD Makmur Mandiri Jaya * |  | INDONESIA
Tin |  | PT Babel Inti Perkasa * |  | INDONESIA
Tin |  | PT Bangka Kudai Tin |  | INDONESIA
Tin |  | PT Bangka Prima Tin * |  | INDONESIA
Tin |  | PT Bangka Timah Utama Sejahtera |  | INDONESIA
Tin |  | PT Bangka Tin Industry * |  | INDONESIA
Tin |  | PT Belitung Industri Sejahtera * |  | INDONESIA
Tin |  | PT BilliTin Makmur Lestari * |  | INDONESIA
Tin |  | PT Bukit Timah * |  | INDONESIA
Tin |  | PT Cipta Persada Mulia * |  | INDONESIA
Tin |  | PT DS Jaya Abadi * |  | INDONESIA
Tin |  | PT Eunindo Usaha Mandiri * |  | INDONESIA
Tin |  | PT Fang Di MulTindo |  | INDONESIA
Tin |  | PT Inti Stania Prima * |  | INDONESIA
Tin |  | PT Justindo * |  | INDONESIA
Tin |  | PT Karimun Mining |  | INDONESIA
Tin |  | PT Kijang Jaya Mandiri |  | INDONESIA
Tin |  | PT Mitra Stania Prima * |  | INDONESIA
Tin |  | PT Panca Mega Persada * |  | INDONESIA
Tin |  | PT Pelat Timah Nusantara Tbk |  | INDONESIA
Tin |  | PT Prima Timah Utama * |  | INDONESIA
Tin |  | PT Refined Bangka Tin * |  | INDONESIA
Tin |  | PT Sariwiguna Binasentosa * |  | INDONESIA
Tin |  | PT Seirama Tin Investment |  | INDONESIA
Tin |  | PT Stanindo Inti Perkasa * |  | INDONESIA
Tin |  | PT Sukses Inti Makmur * |  | INDONESIA
Tin |  | PT Sumber Jaya Indah * |  | INDONESIA
Tin |  | PT Timah (Persero) Tbk Kundur * |  | INDONESIA
Tin |  | PT Timah (Persero) Tbk Mentok * |  | INDONESIA
Tin |  | PT Tinindo Inter Nusa * |  | INDONESIA
Tin |  | PT Tirus Putra Mandiri |  | INDONESIA
Tin |  | PT Tommy Utama * |  | INDONESIA
Tin |  | PT Wahana Perkit Jaya * |  | INDONESIA
Tin |  | Resind Indústria e Comércio Ltda. * |  | BRAZIL
Tin |  | Rui Da Hung * |  | TAIWAN
Tin |  | Soft Metais Ltda. * |  | BRAZIL
Tin |  | Thaisarco * |  | THAILAND
Tin |  | Tuyen Quang Non-Ferrous Metals Joint Stock Company |  | VIET NAM
Tin |  | VQB Mineral and Trading Group JSC * |  | VIET NAM

10

Metal |  | Standard Smelter Name |  | Smelter Facility Location
Tin |  | White Solder Metalurgia e Mineração Ltda. * |  | BRAZIL
Tin |  | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |  | CHINA
Tin |  | Yunnan Tin Group (Holding) Company Limited * |  | CHINA
Tungsten |  | A.L.M.T. TUNGSTEN Corp. * |  | JAPAN
Tungsten |  | Asia Tungsten Products Vietnam Ltd. * |  | VIET NAM
Tungsten |  | Chenzhou Diamond Tungsten Products Co., Ltd. * |  | CHINA
Tungsten |  | Chongyi Zhangyuan Tungsten Co., Ltd. * |  | CHINA
Tungsten |  | Dayu Jincheng Tungsten Industry Co., Ltd. |  | CHINA
Tungsten |  | Dayu Weiliang Tungsten Co., Ltd. |  | CHINA
Tungsten |  | Fujian Jinxin Tungsten Co., Ltd. * |  | CHINA
Tungsten |  | Ganxian Shirui New Material Co., Ltd. |  | CHINA
Tungsten |  | Ganzhou Huaxing Tungsten Products Co., Ltd. * |  | CHINA
Tungsten |  | Ganzhou Jiangwu Ferrotungsten Co., Ltd. * |  | CHINA
Tungsten |  | Ganzhou Non-ferrous Metals Smelting Co., Ltd. |  | CHINA
Tungsten |  | Ganzhou Seadragon W & Mo Co., Ltd. * |  | CHINA
Tungsten |  | Ganzhou Yatai Tungsten Co., Ltd. * |  | CHINA
Tungsten |  | Global Tungsten & Powders Corp. * |  | UNITED STATES
Tungsten |  | Guangdong Xianglu Tungsten Co., Ltd. * |  | CHINA
Tungsten |  | H.C. Starck GmbH * |  | GERMANY
Tungsten |  | H.C. Starck Smelting GmbH & Co.KG * |  | GERMANY
Tungsten |  | Hunan Chenzhou Mining Co., Ltd. * |  | CHINA
Tungsten |  | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |  | CHINA
Tungsten |  | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin |  | CHINA
Tungsten |  | Hunan Chunchang Nonferrous Metals Co., Ltd. * |  | CHINA
Tungsten |  | Hydrometallurg, JSC * |  | RUSSIAN FEDERATION
Tungsten |  | Japan New Metals Co., Ltd. * |  | JAPAN
Tungsten |  | Jiangwu H.C. Starck Tungsten Products Co., Ltd. |  | CHINA
Tungsten |  | Jiangxi Gan Bei Tungsten Co., Ltd. * |  | CHINA
Tungsten |  | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |  | CHINA
Tungsten |  | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |  | CHINA
Tungsten |  | Jiangxi Xinsheng Tungsten Industry Co., Ltd. |  | CHINA
Tungsten |  | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. * |  | CHINA
Tungsten |  | Jiangxi Yaosheng Tungsten Co., Ltd. |  | CHINA
Tungsten |  | Kennametal Fallon |  | UNITED STATES
Tungsten |  | Kennametal Huntsville * |  | UNITED STATES
Tungsten |  | Malipo Haiyu Tungsten Co., Ltd. * |  | CHINA
Tungsten |  | Niagara Refining LLC * |  | UNITED STATES
Tungsten |  | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC * |  | VIET NAM
Tungsten |  | Pobedit, JSC |  | RUSSIAN FEDERATION
Tungsten |  | Sanher Tungsten Vietnam Co., Ltd. |  | VIET NAM
Tungsten |  | Tejing (Vietnam) Tungsten Co., Ltd. * |  | VIET NAM
Tungsten |  | Vietnam Youngsun Tungsten Industry Co., Ltd. * |  | VIET NAM
Tungsten |  | Wolfram Bergbau und Hütten AG * |  | AUSTRIA
Tungsten |  | Xiamen Tungsten (H.C.) Co., Ltd. * |  | CHINA
Tungsten |  | Xiamen Tungsten Co., Ltd. * |  | CHINA

11

Metal |  | Standard Smelter Name |  | Smelter Facility Location
Tungsten |  | Xinhai Rendan Shaoguan Tungsten Co., Ltd. * |  | CHINA

12

Attachment B
Countries of Origin
The following lists the countries of origin from which the reported facilities in Attachment A collectively source conflict minerals based on information provided by our suppliers and the CFSI.

AUSTRALIA | PHILIPPINES
AUSTRIA | POLAND
BELGIUM | RUSSIAN FEDERATION
BOLIVIA | RWANDA
BRAZIL | SAUDI ARABIA
CANADA | SINGAPORE
CHINA | SOUTH AFRICA
ESTONIA | SPAIN
GERMANY | SUDAN
INDIA | SWEDEN
INDONESIA | SWITZERLAND
ITALY | TAIWAN
JAPAN | THAILAND
KAZAKHSTAN | TURKEY
KOREA, REPUBLIC OF | UNITED ARAB EMIRATES
KYRGYZSTAN | UNITED KINGDOM
MALAYSIA | UNITED STATES
MEXICO | UZBEKISTAN
NETHERLANDS | VIET NAM
NEW ZEALAND | ZIMBABWE
PERU |

13