EX-1.01 2 ex1012022conflictmineralsr.htm EX-1.01
Exhibit 1.01
Conflict Minerals Report
For the Year Ended December 31, 2022
This is the Conflict Minerals Report (this “Report”) of Powell Industries, Inc. (referred to herein as, “Powell”, the “Company”, “we”, “us” or “our”) for calendar year 2022 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Please refer to Section 13(p) of the Exchange Act and the general instructions to the Specialized Disclosure Report on Form SD for definitions of certain terms used in this Report, unless otherwise defined herein.
This Report for the year ended December 31, 2022 is presented to comply with Rule 13p-1 under the Exchange Act (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 of 2010 (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold. For the purposes of this Report, tin, tantalum, tungsten and gold shall be collectively referred to as the 3TGs. These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.
Company Overview
Powell Industries, Inc. was incorporated in the state of Delaware in 2004 as a successor to a Nevada company incorporated in 1968. The Nevada company was the successor to a company founded by William E. Powell in 1947, which merged into the Company in 1977. We are headquartered in Houston, Texas, and our major subsidiaries, all of which are wholly owned, include: Powell Electrical Systems, Inc.; Powell (UK) Limited; Powell Canada Inc. and Powell Industries International, B.V.
Our website is www.powellind.com. We make available, free of charge on or through our website, copies of our Annual Reports on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934 as soon as is reasonably practicable after we electronically file such material with, or furnish it to, the Securities and Exchange Commission (SEC). Additionally, all of our reports filed with the SEC are available via their website at http://www.sec.gov. We have also posted on our company website Powell’s Conflict Minerals policy statement at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."
We develop design, manufacture and service custom-engineered equipment and systems which (1) distribute, control and monitor the flow of electrical energy and (2) provide protection to motors, transformers and other electrically powered equipment. Our principal products include integrated power control room substations (PCRs®), custom-engineered modules, electrical houses (E-Houses), traditional and arc-resistant distribution switchgear and control gear, medium-voltage circuit breakers, monitoring and control communications systems, motor control centers and bus duct systems. These products are designed for application voltages ranging from 480 volts to 38,000 volts and are used in oil and gas refining, onshore and offshore oil and gas production, petrochemical, liquid natural gas terminals, pipeline, terminal, mining and metals, light rail traction power, electric utility, pulp and paper and other heavy industrial markets. Our product scope includes designs tested to meet both U.S. standards and international standards, under both the American National Standards Institute (ANSI) and International Electrotechnical Commission (IEC). We assist customers by providing value-added services such as spare parts, field service inspection, installation, commissioning, modification and repair, retrofit and retrofill components for existing systems and replacement circuit breakers for switchgear that is obsolete or that is no longer produced by the original manufacturer. We seek to establish long-term relationships with the end users of our systems as well as the design and construction engineering firms contracted by those end users. We believe that our culture of safety and focus on customer satisfaction, along with our financial strength, allow us to continue to capitalize on opportunities in the industries we serve.
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Product Description
Our broad and complex product range may contain conflict minerals within the following components:

• | Tantalum, used in capacitors,
• | Tin, used in soldered components,
• | Tungsten, used in coatings, alloys, heating elements and electrodes,
• | Gold, used in circuit boards, electrodes and electronic components.

Description of Reasonable Country of Origin Inquiry (RCOI)
In conducting the RCOI, Powell engaged a third-party service provider. Assent Compliance (“Assent”) to assist with the effectiveness of our conflict minerals program. We identified the scope of our inquiry by first completing a supplier list extraction from our preferred vendor list. This list was then filtered to remove service providers, indirect materials suppliers and inactive suppliers (minimum of one year since last purchase). This was intended to ensure that all suppliers surveyed provided items to Powell that were used in final products in the year 2022. Once the filtering was completed, we populated the list with contact information. This list, composed of 566 suppliers, was then provided to Assent for upload to their Assent Sustainability Manager software system (the “Assent Sustainability Manager”).
Assent conducted the supplier survey portion of the RCOI. The supplier survey utilized a template developed by the Responsible Business Alliance® and The Global e-Sustainability Initiative (RBA/GeSI) called the Conflict Mineral Report Template (CMRT). The 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.
Non-responsive suppliers were contacted a minimum of eight times. We conducted a total of 10 campaigns (7 standard + 3 escalation), 3 rounds of invalid CMRT follow ups, and 2 rounds of phone calls to incomplete CMRT suppliers. After four months of non-responsiveness, top suppliers were then contacted by Powell management, as an escalation to encourage their response to Assent.
Assent communications included training and education on the completion of the CMRT form as well as access to Assent’s learning management system, Assent University. All in-scope suppliers were provided access to the Conflict Minerals Training course and this training was monitored and tracked in Assent's system for future reporting and transparency.
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The below metrics provide a summary of the data collected, number of suppliers in scope and responses.
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The below summarizes the status of the smelters or refiners, the level of risk and top source countries.
Due Diligence Process
Powell’s due diligence measures have been designed to conform, in all material respects, with the framework in the Organization 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 3TG (collectively, the “OECD Guidance”). In 2022, the due diligence process was aimed to help Powell assess and respond to risk in its supply chain by investigating the source of its products down the chain to the smelters and refiners and the strength of its suppliers’ conflict minerals programs. The following is a brief summary of certain aspects of our due diligence process.
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A. | Establish Strong Powell Management Systems

In accordance with our due diligence framework and compliance efforts:

| • |  | We have communicated to all of our in-scope suppliers our efforts to comply with Section 1502 of the Dodd-Frank Act pursuant to a compliance statement and other communications (together, the “Compliance Statement”). We requested that our in-scope suppliers provide a comprehensive conflict minerals declaration for all conflict minerals in the form of the CMRT version 6.2 or higher. We provide our Compliance Statement to all new suppliers and plan to provide annual related compliance statement communications to our entire supply base.
| • |  | We implemented internal compliance efforts, including internal reporting requirements, to support our supply chain due diligence process.
| • |  | We implemented a risk mitigation response plan to address business relationships with suppliers that are DRC conflict undeterminable (as defined in Item 1.01(d)(5) of Form SD). Our program includes continuous monitoring to adjust our strategies as sourcing data improves and new information is received.

Powell has adopted a company policy with respect to conflict minerals which is posted on our website at www.powellind.com. Select the section entitled "Supply Chain Management", then "Supply Chain Policy Statements". Internal Team
Powell has established a management system for conflict minerals. Our management system is sponsored by the Chief Financial Officer as well as executive-level representatives and a team of subject matter experts from relevant functions, such as our Supply Chain Director, Corporate Controller, Vice President of Research and Product Development, Trade Compliance and Category Managers.
The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and senior management is briefed about the results of our due diligence efforts.
Control Systems
Controls include, but are not limited to, our code of conduct which outlines expected behaviors for all Powell employees and a conflict minerals policy which can be found on our website.
We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers. Contracts with our suppliers are frequently in force for three to five years or more and we cannot unilaterally impose new contract terms and flow-down requirements. As we enter into new contracts, or our contracts renew, we are adding a clause to require suppliers to provide information about the source of 3TG and smelters. It will take a number of years to ensure that all our supplier contracts contain appropriate flow-down clauses. In the meantime, as described below, we are working with selected suppliers to ensure they provide the 3TG sourcing information until the contracts can be amended.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have, through Assent, provided education on the conflict minerals regulation. We have leveraged the existing communications within the Company, specifically the procurement department, to encourage supplier interactions with Assent as well as to help suppliers understand the requirement for completion of their CMRTs. Feedback from this engagement has allowed us to enhance the training and focus and adapt it to each user’s needs. It has also allowed for our supplier communications to be more focused and to clarify expectations.
Grievance Mechanisms
We have multiple longstanding grievance mechanisms whereby employees, contractors, suppliers and agents can report violations of Powell’s policies. There are established escalation protocols for reporting grievances internally,
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as well as the EthicsPoint hotline, which is independently managed. Our ethics and reporting Hotline can be found at https://powellind.ethicspoint.com.
Maintain Records
We have also adopted a policy to retain relevant documentation. Such documentation will be retained for minimum of five years in company secured shared drive files.

B. | Identify and Assess Risks in Our Supply Chain

We identified direct material suppliers to capture possible 3TG risk suppliers. As we progress, we expect that transparency in our supply chain will increase to allow for better risk assessment at more detailed levels of our supply chain. We intend to continue communicating with our suppliers regarding conflict minerals.
Based on assessed risks, our RCOI covered applicable suppliers.
Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance: Assent uses 3 factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags.
1.Geographic proximity to the DRC and covered countries;
2.Responsible Minerals Assurance Process (RMAP) audit status;
3.Credible evidence of unethical or conflict sourcing.
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Based on this criteria the following facilities have been identified as being of highest concern to the supply chain:
As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by some of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above facilities produce a receipt instructing the suppliers to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Powell. As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context.
In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

C. | Design and Implement a Strategy to Respond to Identified Risks

We believe that our RCOI was reasonably designed and executed in good faith to determine the existence and source of the 3TGs in our supply chain, including from recycled or scrap sources (as defined in Item 1.01(d)(6) of Form SD). We utilized the CMRT template version 6.2 or higher for our RCOI. We conducted our effort to send surveys in good faith, utilizing up to three rounds of communications with our suppliers. We evaluated survey responses to identify: (i) the use and source of the 3TGs; and (ii) any warning signs indicating that conflict minerals may have come from one of the Covered Countries. We intend to make additional inquiries on a case-by-case basis during 2022 to clarify or obtain more information as necessary. We tracked results of our supply chain diligence process and periodically reported the results to our executive leadership team.
Because of Powell’s size, the complexity of its products, and the depth, breadth, and constant evolution of its supply chain, it is difficult to identify parties upstream from its direct suppliers. Powell continues to work with suppliers to identify the upstream sources of the 3TGs through the CMRTs, follow up on invalid responses on the CMRTs, use of a risk-based assessment of identified smelters and assessment of the conflict minerals programs of its suppliers, as
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described below in this Report. Information and findings from this process are stored in the Assent Sustainability Manager, a database that can be tracked and audited.
Certain of the responses to the surveys included the names of facilities listed by the suppliers as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. We and our consultant compared these facilities listed in the responses to the list of smelters maintained by the Responsible Minerals Initiative (RMI) and, if a supplier indicated that the facility was certified as “Conflict-Free,” we confirmed that the name was listed by the RMI.
In accordance with OECD Guidance, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free pose a significant risk to the supply chain. In the Assent Sustainability Manager, risk is classified based on 3 scoring criteria that we outlined in the previous section.
Powell does not have a direct relationship with conflict minerals smelters and refiners and, as a result, does not perform or direct audits of these entities within its supply chain. Powell captured smelter and refiner information as part of the CMRT, as some suppliers provided the names of facilities it used as smelters or refiners. Assent compared the facilities identified by the suppliers to the list of smelters maintained by the RMI.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). At this stage in conflict minerals compliance it is well-known that many companies are in the middle of the process and do not have many answers beyond “unknown”. The criteria from the questionnaire used to evaluate the strength of the program are:
•Have you established a conflict minerals sourcing policy?
•Have you implemented due diligence measures for conflict-free sourcing?
•Do you review due diligence information received from your suppliers against your company’s expectations?
•Does your review process include corrective action management?
When suppliers meet or exceed those criteria (Yes to at least A, E, G, H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
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 applicable products, including (1) seeking information about 3TG smelters and refiners in our supply chain by requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI lists, (3) conducting the due diligence review and (4) obtaining additional documentation and verification, as applicable. As mentioned above, our existing policy related to relevant documentation of our conflict mineral compliance process requires that documentation will be retained for a period of at least five years.

D. | Implement Targeted Independent Third-Party Due Diligence

We engaged Assent to assist in the RCOI, data collection and survey process. Assent supports industry associations that administer independent third-party smelter and refinery audit programs and encourages targeted suppliers and/or facilities to participate in comparable due diligence validation activities.

E. | Report on Supply Chain Due Diligence

We have responded to various customer requests for information regarding our conflict minerals determination.
Powell reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC. We also disclose our company policy with respect to conflict minerals on our website at www.powellind.com. Select the section entitled "Our Company", then "Supply Chain."
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Due Diligence Results
For the 2022 reporting year, Powell received CMRT forms from 64% of the suppliers surveyed. All submitted forms are accepted and classified as valid or invalid in order to retain all data. Suppliers were contacted if they submitted invalid forms and were encouraged to resubmit a valid form. As of May 19, 2023, there were 12 invalid or incomplete supplier submissions.
While due diligence is ongoing and the information received continues to improve in quantity and quality, the majority of the responses received provided data at a company or divisional level or did not specify the smelters or refiners used for materials specifically supplied to us. We have decided to disclose validated smelters provided to us by our supply chain. However, we cannot definitively determine whether any of the 3TGs reported by the suppliers were contained in materials supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. As a result, we are unable to identify all smelters and refiners as well as all the countries of origin of the 3TGs that are contained in the applicable products
As of May 19, 2023, Powell validated 343 smelters or refiners identified within its supply chain. If a supplier indicated that the facility was certified as “conflict-free,” such status was confirmed by Assent if the facility was listed by the RMI as certified.
Many suppliers within Powell’s supply chain are still unable to provide the smelters or refiners used for products supplied. Furthermore, many of the suppliers provided responses at the company or division level and indicated an “unknown” status in terms of determining the origin of the 3TGs. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our Assent follows up on these, urging suppliers to resubmit with increased smelter information. There are still suppliers unable to provide the smelters or refiners used for materials supplied to us.
In cases where any red-flagged smelters were reported on a CMRT by a supplier, risk mitigation activities were initiated. Through Assent, the suppliers were asked to submit a product-level CMRT to better identify the connection between the smelters or refiners they listed and the products they provide to us. Suppliers were also guided to Assent University where they were provided with educational materials on mitigating the risk of smelters or refiners in the supply chain.
Appendix I lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix I any smelters or refiners that we have not been able to validate. Appendix II also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and RMI. Powell supports the refinement and expansion of the list of participating smelters through our membership in the RMI program.
The large majority of the responses received either provided data at a company or subsidiary level and chose not to provide information at the component level, or did not specify the smelters or refiners used for components supplied to Powell. Accordingly, we are unable to determine, in those cases, whether any of the 3TGs reported by the suppliers were contained in components or parts supplied to us, or to validate that any of the smelters or refiners identified are actually in our supply chain.
Steps to Improve Future Due Diligence and Supply Chain Risk Mitigation
Powell takes the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in its products could benefit armed groups in the Covered Countries:
•Reinforce conflict minerals policy statement on website and specified requirements in standard terms and conditions for any new or renewed supplier contracts.
•New and existing suppliers must certify compliance with Powell’s Supplier Code of Conduct and Ethics, which includes due diligence for Responsible Sourcing (requirement implemented in June, 2022).
•Continue engagement with suppliers and direct them to training resources to increase the response rate and improve the content of the supplier survey responses.
•Engage any suppliers found to be supplying Powell with conflict minerals to establish an alternative source of conflict minerals that does not support the conflict in the Covered Countries.
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•Define and improve best practices and build leverage over its supply chain in accordance with the OECD Guidance.
•Smelter Risk Evaluation through Assent, comprehensive and ongoing analysis is conducted by their smelter library manager to assess sourcing risk. The information is then used to provide supplier feedback and conduct outreach with higher risk suppliers.
Based on its due diligence process as of the date of this Report, Powell has found no instances where it was necessary to terminate a supplier contract or to find a replacement supply of any conflict minerals.
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Appendix I

Metal | Smelter Name | Smelter Facility Location | Smelter ID
Tin | EM Vinto | Bolivia (Plurinational State Of) | CID000438
Tin | Fenix Metals | Poland | CID000468
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | CID000538
Tin | China Tin Group Co., Ltd. | China | CID001070
Tin | Malaysia Smelting Corporation (MSC) | Malaysia | CID001105
Tin | Mineracao Taboca S.A. | Brazil | CID001173
Tin | Minsur | Peru | CID001182
Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | CID001337
Tin | PT Mitra Stania Prima | Indonesia | CID001453
Tin | PT Refined Bangka Tin | Indonesia | CID001460
Tin | PT Timah Tbk Kundur | Indonesia | CID001477
Tin | PT Timah Tbk Mentok | Indonesia | CID001482
Tin | Thaisarco | Thailand | CID001898
Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | CID002036
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | CID002158
Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | CID002180
Tin | PT ATD Makmur Mandiri Jaya | Indonesia | CID002503
Tin | Aurubis Beerse | Belgium | CID002773

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Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | CID003116
Tin | PT Bangka Serumpun | Indonesia | CID003205
Tungsten | A.L.M.T. Corp. | Japan | CID000004
Gold | Advanced Chemical Company | United States Of America | CID000015
Gold | Aida Chemical Industries Co., Ltd. | Japan | CID000019
Gold | Agosi AG | Germany | CID000035
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | CID000041
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | CID000058
Gold | Argor-Heraeus S.A. | Switzerland | CID000077
Gold | Asahi Pretec Corp. | Japan | CID000082
Gold | Asaka Riken Co., Ltd. | Japan | CID000090
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | CID000103
Tungsten | Kennametal Huntsville | United States Of America | CID000105
Gold | Aurubis AG | Germany | CID000113
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | CID000128
Gold | Boliden AB | Sweden | CID000157
Gold | C. Hafner GmbH + Co. KG | Germany | CID000176
Gold | Caridad | Mexico | CID000180
Gold | CCR Refinery - Glencore Canada Corporation | Canada | CID000185
Gold | Cendres + Metaux S.A. | Switzerland | CID000189
Gold | Yunnan Copper Industry Co., Ltd. | China | CID000197
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | CID000218
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | CID000228

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Gold | Chimet S.p.A. | Italy | CID000233
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | CID000258
Gold | Chugai Mining | Japan | CID000264
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | CID000281
Tin | Alpha | United States Of America | CID000292
Tin | PT Aries Kencana Sejahtera | Indonesia | CID000309
Tin | PT Premium Tin Indonesia | Indonesia | CID000313
Gold | Daye Non-Ferrous Metals Mining Ltd. | China | CID000343
Gold | DSC (Do Sung Corporation) | Korea, Republic Of | CID000359
Gold | Dowa | Japan | CID000401
Tin | Dowa | Japan | CID000402
Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | CID000425
Tin | Estanho de Rondonia S.A. | Brazil | CID000448
Tantalum | F&X Electro-Materials Ltd. | China | CID000460
Gold | JSC Novosibirsk Refinery | Russian Federation | CID000493
Gold | Refinery of Seemine Gold Co., Ltd. | China | CID000522
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | CID000555
Tungsten | Global Tungsten & Powders LLC | United States Of America | CID000568
Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | CID000616
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | CID000651
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | CID000671
Gold | LT Metal Ltd. | Korea, Republic Of | CID000689
Gold | Heimerle + Meule GmbH | Germany | CID000694
Gold | Heraeus Metals Hong Kong Ltd. | China | CID000707
Gold | Heraeus Germany GmbH Co. KG | Germany | CID000711

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Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | CID000766
Gold | Hunan Chenzhou Mining Co., Ltd. | China | CID000767
Tungsten | Hunan Jintai New Material Co., Ltd. | China | CID000769
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | CID000773
Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | CID000778
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | CID000801
Gold | Ishifuku Metal Industry Co., Ltd. | Japan | CID000807
Gold | Istanbul Gold Refinery | Turkey | CID000814
Gold | Japan Mint | Japan | CID000823
Tungsten | Japan New Metals Co., Ltd. | Japan | CID000825
Gold | Jiangxi Copper Co., Ltd. | China | CID000855
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | CID000875
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | CID000914
Tantalum | Jiujiang Tanbre Co., Ltd. | China | CID000917
Gold | Asahi Refining USA Inc. | United States Of America | CID000920
Gold | Asahi Refining Canada Ltd. | Canada | CID000924
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | CID000927
Gold | JSC Uralelectromed | Russian Federation | CID000929
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | CID000937
Tin | Gejiu Kai Meng Industry and Trade LLC | China | CID000942
Gold | Kazakhmys Smelting LLC | Kazakhstan | CID000956
Gold | Kazzinc | Kazakhstan | CID000957
Tungsten | Kennametal Fallon | United States Of America | CID000966
Gold | Kennecott Utah Copper LLC | United States Of America | CID000969

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Gold | Kojima Chemicals Co., Ltd. | Japan | CID000981
Gold | Kyrgyzaltyn JSC | Kyrgyzstan | CID001029
Gold | L'azurde Company For Jewelry | Saudi Arabia | CID001032
Gold | Lingbao Gold Co., Ltd. | China | CID001056
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | CID001058
Tantalum | AMG Brasil | Brazil | CID001076
Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | CID001078
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | CID001093
Gold | Materion | United States Of America | CID001113
Gold | Matsuda Sangyo Co., Ltd. | Japan | CID001119
Tin | Metallic Resources, Inc. | United States Of America | CID001142
Gold | Metalor Technologies (Suzhou) Ltd. | China | CID001147
Gold | Metalor Technologies (Hong Kong) Ltd. | China | CID001149
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | CID001152
Gold | Metalor Technologies S.A. | Switzerland | CID001153
Gold | Metalor USA Refining Corporation | United States Of America | CID001157
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | CID001161
Tantalum | Metallurgical Products India Pvt., Ltd. | India | CID001163
Tantalum | Mineracao Taboca S.A. | Brazil | CID001175
Gold | Mitsubishi Materials Corporation | Japan | CID001188
Tin | Mitsubishi Materials Corporation | Japan | CID001191
Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001192
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001193

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Tantalum | NPM Silmet AS | Estonia | CID001200
Gold | Moscow Special Alloys Processing Plant | Russian Federation | CID001204
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | CID001220
Tin | Jiangxi New Nanshan Technology Ltd. | China | CID001231
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | CID001236
Gold | Nihon Material Co., Ltd. | Japan | CID001259
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | CID001277
Tin | Novosibirsk Tin Combine | Russian Federation | CID001305
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | CID001314
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | CID001325
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | CID001326
Gold | MKS PAMP SA | Switzerland | CID001352
Gold | Penglai Penggang Gold Industry Co., Ltd. | China | CID001362
Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | CID001386
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | CID001397
Tin | PT Artha Cipta Langgeng | Indonesia | CID001399
Tin | PT Babel Inti Perkasa | Indonesia | CID001402
Tin | PT Babel Surya Alam Lestari | Indonesia | CID001406
Tin | PT Bangka Tin Industry | Indonesia | CID001419
Tin | PT Belitung Industri Sejahtera | Indonesia | CID001421
Tin | PT Bukit Timah | Indonesia | CID001428
Tin | PT Panca Mega Persada | Indonesia | CID001457
Tin | PT Prima Timah Utama | Indonesia | CID001458
Tin | PT Sariwiguna Binasentosa | Indonesia | CID001463

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Tin | PT Stanindo Inti Perkasa | Indonesia | CID001468
Tin | PT Timah Nusantara | Indonesia | CID001486
Tin | PT Tinindo Inter Nusa | Indonesia | CID001490
Tin | PT Tommy Utama | Indonesia | CID001493
Gold | PX Precinox S.A. | Switzerland | CID001498
Tantalum | QuantumClean | United States Of America | CID001508
Gold | Rand Refinery (Pty) Ltd. | South Africa | CID001512
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | CID001522
Gold | Royal Canadian Mint | Canada | CID001534
Tin | Rui Da Hung | Taiwan, Province Of China | CID001539
Gold | Sabin Metal Corp. | United States Of America | CID001546
Gold | Samduck Precious Metals | Korea, Republic Of | CID001555
Gold | Samwon Metals Corp. | Korea, Republic Of | CID001562
Gold | SEMPSA Joyeria Plateria S.A. | Spain | CID001585
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | CID001619
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | CID001622
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | CID001736
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | CID001756
Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | CID001761
Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | CID001769
Gold | Sumitomo Metal Mining Co., Ltd. | Japan | CID001798
Gold | Super Dragon Technology Co., Ltd. | China | CID001810
Tantalum | Taki Chemical Co., Ltd. | Japan | CID001869

Page 17 of 26

Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | CID001875
Tantalum | Telex Metals | United States Of America | CID001891
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | CID001908
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | CID001909
Gold | Shandong Gold Smelting Co., Ltd. | China | CID001916
Gold | Tokuriki Honten Co., Ltd. | Japan | CID001938
Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | CID001947
Gold | Torecom | Korea, Republic Of | CID001955
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | CID001969
Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | CID001980
Gold | United Precious Metal Refining, Inc. | United States Of America | CID001993
Gold | Valcambi S.A. | Switzerland | CID002003
Tin | VQB Mineral and Trading Group JSC | Viet Nam | CID002015
Gold | Western Australian Mint (T/a The Perth Mint) | Australia | CID002030
Tungsten | Wolfram Bergbau und Hutten AG | Austria | CID002044
Tungsten | Xiamen Tungsten Co., Ltd. | China | CID002082
Gold | Yamakin Co., Ltd. | Japan | CID002100
Gold | Yokohama Metal Co., Ltd. | Japan | CID002129
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | CID002224
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | CID002243
Gold | Morris and Watson | New Zealand | CID002282
Gold | SAFINA A.S. | Czechia | CID002290

Page 18 of 26

Gold | Guangdong Jinding Gold Limited | China | CID002312
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | CID002313
Gold | Umicore Precious Metals Thailand | Thailand | CID002314
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | CID002315
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | CID002316
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | CID002317
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | CID002318
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | CID002319
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | CID002320
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | CID002321
Tin | CV Venus Inti Perkasa | Indonesia | CID002455
Gold | Geib Refining Corporation | United States Of America | CID002459
Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | CID002468
Tin | PT Tirus Putra Mandiri | Indonesia | CID002478
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | CID002492
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | CID002494
Tin | Melt Metais e Ligas S.A. | Brazil | CID002500
Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | CID002502
Tantalum | D Block Metals, LLC | United States Of America | CID002504
Tantalum | FIR Metals & Resource Ltd. | China | CID002505
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | CID002506
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | CID002508

Page 19 of 26

Gold | MMTC-PAMP India Pvt., Ltd. | India | CID002509
Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | CID002511
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | CID002512
Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | CID002513
Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | CID002515
Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | CID002516
Tin | O.M. Manufacturing Philippines, Inc. | Philippines | CID002517
Gold | Shandong Humon Smelting Co., Ltd. | China | CID002525
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | CID002527
Tantalum | KEMET de Mexico | Mexico | CID002539
Tungsten | H.C. Starck Tungsten GmbH | Germany | CID002541
Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002542
Tungsten | Masan High-Tech Materials | Viet Nam | CID002543
Tantalum | TANIOBIS Co., Ltd. | Thailand | CID002544
Tantalum | TANIOBIS GmbH | Germany | CID002545
Tantalum | Materion Newton Inc. | United States Of America | CID002548
Tantalum | TANIOBIS Japan Co., Ltd. | Japan | CID002549
Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002550
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | CID002551
Tantalum | Global Advanced Metals Boyertown | United States Of America | CID002557

Page 20 of 26

Tantalum | Global Advanced Metals Aizu | Japan | CID002558
Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | CID002560
Gold | Emirates Gold DMCC | United Arab Emirates | CID002561
Gold | International Precious Metal Refiners | United Arab Emirates | CID002562
Gold | Kaloti Precious Metals | United Arab Emirates | CID002563
Gold | Sudan Gold Refinery | Sudan | CID002567
Tin | CV Ayi Jaya | Indonesia | CID002570
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | CID002572
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002573
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002574
Gold | T.C.A S.p.A | Italy | CID002580
Gold | REMONDIS PMR B.V. | Netherlands | CID002582
Gold | Fujairah Gold FZC | United Arab Emirates | CID002584
Gold | Industrial Refining Company | Belgium | CID002587
Gold | Shirpur Gold Refinery Ltd. | India | CID002588
Tungsten | Niagara Refining LLC | United States Of America | CID002589
Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | CID002605
Gold | Marsam Metals | Brazil | CID002606
Gold | TOO Tau-Ken-Altyn | Kazakhstan | CID002615
Tungsten | China Molybdenum Tungsten Co., Ltd. | China | CID002641
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | CID002645
Tungsten | Hydrometallurg, JSC | Russian Federation | CID002649
Tin | PT Cipta Persada Mulia | Indonesia | CID002696
Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | CID002703
Tin | Resind Industria e Comercio Ltda. | Brazil | CID002706
Tantalum | Resind Industria e Comercio Ltda. | Brazil | CID002707
Gold | Abington Reldan Metals, LLC | United States Of America | CID002708

Page 21 of 26

Tungsten | Unecha Refractory metals plant | Russian Federation | CID002724
Gold | Shenzhen CuiLu Gold Co., Ltd. | China | CID002750
Tin | Super Ligas | Brazil | CID002756
Gold | Albino Mountinho Lda. | Portugal | CID002760
Gold | SAAMP | France | CID002761
Gold | L'Orfebre S.A. | Andorra | CID002762
Gold | 8853 S.p.A. | Italy | CID002763
Gold | Italpreziosi | Italy | CID002765
Tin | Aurubis Berango | Spain | CID002774
Tin | PT Bangka Prima Tin | Indonesia | CID002776
Gold | WIELAND Edelmetalle GmbH | Germany | CID002778
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | CID002779
Tin | PT Sukses Inti Makmur | Indonesia | CID002816
Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | CID002827
Tungsten | ACL Metais Eireli | Brazil | CID002833
Tin | PT Menara Cipta Mulia | Indonesia | CID002835
Tantalum | Jiangxi Tuohong New Raw Material | China | CID002842
Tungsten | Moliren Ltd. | Russian Federation | CID002845
Gold | AU Traders and Refiners | South Africa | CID002850
Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India | CID002852
Gold | Sai Refinery | India | CID002853
Gold | Modeltech Sdn Bhd | Malaysia | CID002857
Tin | Modeltech Sdn Bhd | Malaysia | CID002858
Gold | Bangalore Refinery | India | CID002863
Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | CID002865
Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | CID002867
Gold | Pease & Curren | United States Of America | CID002872
Gold | JALAN & Company | India | CID002893

Page 22 of 26

Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | CID002918
Gold | Planta Recuperadora de Metales SpA | Chile | CID002919
Gold | ABC Refinery Pty Ltd. | Australia | CID002920
Gold | Safimet S.p.A | Italy | CID002973
Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | CID003153
Gold | African Gold Refinery | Uganda | CID003185
Gold | Gold Coast Refinery | Ghana | CID003186
Gold | NH Recytech Company | Korea, Republic Of | CID003189
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | CID003190
Tin | Pongpipat Company Limited | Myanmar | CID003208
Gold | QG Refining, LLC | United States Of America | CID003324
Tin | Tin Technology & Refining | United States Of America | CID003325
Gold | Dijllah Gold Refinery FZC | United Arab Emirates | CID003348
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | CID003356
Tin | PT Rajawali Rimba Perkasa | Indonesia | CID003381
Gold | CGR Metalloys Pvt Ltd. | India | CID003382
Gold | Sovereign Metals | India | CID003383
Tin | Luna Smelter, Ltd. | Rwanda | CID003387
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | CID003397
Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | CID003407
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | CID003408
Tin | Precious Minerals and Smelting Limited | India | CID003409
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | CID003410
Tungsten | NPP Tyazhmetprom LLC | Russian Federation | CID003416
Tungsten | Hubei Green Tungsten Co., Ltd. | China | CID003417
Gold | C.I Metales Procesados Industriales SAS | Colombia | CID003421
Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | CID003424
Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | CID003425
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | CID003427
Tin | PT Mitra Sukses Globalindo | Indonesia | CID003449
Gold | Augmont Enterprises Private Limited | India | CID003461

Page 23 of 26

Gold | Kundan Care Products Ltd. | India | CID003463
Tungsten | Cronimet Brasil Ltda | Brazil | CID003468
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | CID003486
Gold | Emerald Jewel Industry India Limited (Unit 1) | India | CID003487
Gold | Emerald Jewel Industry India Limited (Unit 2) | India | CID003488
Gold | Emerald Jewel Industry India Limited (Unit 3) | India | CID003489
Gold | Emerald Jewel Industry India Limited (Unit 4) | India | CID003490
Gold | K.A. Rasmussen | Norway | CID003497
Gold | Alexy Metals | United States Of America | CID003500
Tin | CRM Synergies | Spain | CID003524
Gold | Sancus ZFS (L’Orfebre, SA) | Colombia | CID003529
Gold | Sellem Industries Ltd. | Mauritania | CID003540
Gold | MD Overseas | India | CID003548
Tungsten | Artek LLC | Russian Federation | CID003553
Gold | Metallix Refining Inc. | United States Of America | CID003557
Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | CID003575
Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | CID003582
Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | CID003583
Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | CID003609
Tungsten | OOO “Technolom” 2 | Russian Federation | CID003612
Tungsten | OOO “Technolom” 1 | Russian Federation | CID003614
Gold | WEEEREFINING | France | CID003615
Gold | Gold by Gold Colombia | Colombia | CID003641
Tungsten | LLC Vostok | Russian Federation | CID003643
Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China | CID003662
Gold | Dongwu Gold Group | China | CID003663
Tin | DS Myanmar | Myanmar | CID003831
Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | CID003868
Tantalum | 5D Production OU | Estonia | CID003926
Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic Of | CID003978
Tin | PT Rajehan Ariq | Indonesia | CID002593
Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of | CID004060
Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam | CID003993

Page 24 of 26

Appendix II
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

Country of Origin
Afghanistan | Finland | Nicaragua
Ãland Islands | France | Niger
Albania | Georgia | Nigeria
American Samoa | Germany | Norway
Andorra | Ghana | Panama
Angola | Guam | Papua New Guinea
Argentina | Guatemala | Peru
Armenia | Guinea | Philippines
Aruba | Guyana | Poland
Australia | Honduras | Portugal
Austria | Hong Kong | Russian Federation
Azerbaijan | Hungary | Rwanda
Bahamas | India | Samoa
Barbados | Indonesia | Saudi Arabia
Belarus | Ireland | Senegal
Belgium | Israel | Sierra Leone
Benin | Italy | Singapore
Bermuda | Japan | Slovakia
Bolivia | Jersey | Slovenia
Brazil | Kazakhstan | South Africa
Bulgaria | Kenya | South Sudan
Burkina Faso | Korea | Spain
Burundi | Kyrgyzstan | Sudan
Cambodia | Liberia | Suriname
Canada | Liechtenstein | Sweden
Central African Republic | Lithuania | Switzerland
Chile | Luxembourg | Taiwan
China | Madagascar | Tajikistan
Colombia | Malaysia | Tanzania
Congo | Mali | Thailand
Czechia | Mauritania | Turkey
Democratic Republic of Congo | Mexico | Uganda
Djibouti | Mongolia | United Arab Emirates
Dominica | Morocco | United Kingdom
Dominican Republic | Mozambique | United States

Page 25 of 26

Ecuador | Myanmar | Uzbekistan
Egypt | Namibia | Viet Nam
Eritrea | Netherlands | Zambia
Estonia | New Zealand | Zimbabwe
Ethiopia |  |

Page 26 of 26