EX-1.01 2 exhitbit101conflictmineral.htm EXHIBIT 1.01
Exhibit 1.01
Malibu Boats, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2015
Introduction
This Conflict Minerals Report (“CMR”) for the year ended December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) issuers if they manufacture or contract to manufacture products that contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). The Rule focuses on 3TG emanating from the Democratic Republic of Congo (“DRC”) region and nine adjoining countries (together, the “Covered Countries”). If an issuer has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries and are not from recycled or scrap sources, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody and file a CMR as an exhibit to the Form SD with the SEC that includes a description of those due diligence measures.
Company Overview
Malibu Boats, Inc., also referred to as “Malibu Boats”, “we”, “our”, and “us” is a leading designer, manufacturer and marketer of performance sport boats. Our boats are used for water sports, including water skiing, wakeboarding and wake surfing, as well as general recreational boating. Our high performance boats are sold under two brands: Malibu and Axis Wake Research, or Axis. We manufacture our own Malibu and Axis performance boats and components such as trailers, towers and tower accessories. In addition, we contract with other third-party vendors to manufacture other components for installation on our boats, such as engines and electronic controls. We determined that Conflict Minerals were necessary to the functionality and/or production of such products during calendar year 2015.
Executive Summary
Malibu Boats does not directly source any Conflict Minerals that may be used in the products we manufacture or contract to manufacture. Therefore we relied upon our suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us, including sources of Conflict Minerals that are supplied to them from sub-tier suppliers. Malibu Boats performed a Reasonable Country of Origin Inquiry (“RCOI”) on suppliers believed to provide Malibu Boats with materials or components containing necessary 3TGs.
Malibu Boats’ suppliers identified 293 valid smelters and refineries (“smelters”). Of these 293 smelters, Malibu Boats identified 39 as sourcing (or there was a reason to believe they may be sourcing) from the Covered Countries. Malibu Boats’ due diligence review indicated that 37 of these smelters have been audited and recognized as conflict free by the Conflict Free Smelter Program (“CFSP”). The remaining two smelters sourcing from the Covered Countries were subjected to Malibu Boats’ risk mitigation process in accordance with the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (“OECD Due Diligence Guidance”), as described below and did not require removal from Malibu Boats’ supply chain.
Company Management Systems
Malibu Boats established strong management systems according to Step 1 of the OECD Due Diligence Guidance. Malibu Boats implemented the following:

• | Step 1A - Adopted, and clearly communicated to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. Malibu Boats:

◦ | implemented a conflict minerals policy, which is publicly available at http://investors.malibuboats.com/investors/corporate-governance/governance-documents; and

◦ | communicated the policy directly to suppliers as part of the RCOI process.

• | Step 1B - Structured internal management to support supply chain due diligence. Malibu Boats:

◦ | maintained an internal cross functional team to support supply chain due diligence;

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Exhibit 1.01

◦ | appointed a member of the senior staff with the necessary competence, knowledge, and experience to oversee supply chain due diligence; and

◦ | applied the resources necessary to support the operation and monitoring of these processes including internal resources and external consulting support.

• | Step 1C - Established a system of transparency, information collection and control over the supply chain. Malibu Boats:

◦ | implemented a process to collect required supplier and smelter RCOI and due diligence data.

• | Step 1D - Strengthened company engagement with suppliers. Malibu Boats:

◦ | engaged directly with suppliers during the RCOI process;

◦ | reviewed supplier responses as part of the RCOI process;

◦ | added conflict minerals compliance to new supplier contracts and Malibu Boats’ supplier code of conduct; and

◦ | implemented a plan to improve the quantity and quality of supplier and smelter responses year over year.

• | Step 1E - Established a company and/or mine level grievance mechanism. Malibu Boats:

◦ | recognized the CFSP’s three audit protocols for gold, tin/tantalum, and tungsten as valid sources of smelter or mine level grievances; and

◦ | reviewed Malibu Boats’ ethics violations reporting system to ensure that it allows employees to voice confidentially without any fear of retribution, any concerns with the violations of the Malibu Boats’ conflict minerals policy.

Reasonable Country of Origin Inquiry
Malibu Boats designed its RCOI process in accordance with Steps 2A and 2B of the OECD Due Diligence Guidance. Malibu Boats’ RCOI process involved two stages:

• | Stage 1 - Supplier RCOI (Step 2A of the OECD Due Diligence Guidance)

• | Stage 2 - Smelter RCOI (Step 2B of the OECD Due Diligence Guidance)

Supplier RCOI
Malibu Boats designed its supplier RCOI process to identify, to the best of Malibu Boats’ efforts, the smelters in Malibu Boats’ supply chain in accordance with Step 2A of the OECD Due Diligence Guidance. Malibu Boats’ supplier RCOI process for the 2015 reporting period included the following:

• | developed a list of suppliers providing components containing 3TG to Malibu Boats;

• | contacted each supplier and requested the industry standard Conflict Minerals Reporting Template including smelter information;

• | reviewed supplier responses for accuracy and completeness;

• | amalgamated supplier provided smelters into a single list of smelters meeting the definition of a smelter under one of three industry recognized audit protocols; and

• | reviewed the final smelter list (and compared it to industry peers) to determine if Malibu Boats identified reasonably all of the smelters in their supply chain.

Malibu Boats’ suppliers identified 293 smelters in their supply chain. The specific list of smelters is included in “List of Smelter and Refineries” at the end of this report.
Smelter RCOI
Due to the overlap between smelter RCOI and smelter due diligence, the smelter RCOI process is summarized in the due diligence section of this report.
Due Diligence
Malibu Boats’ due diligence process was designed in accordance with the applicable sections of Steps 2, 3, and 4 of the OECD Due Diligence Guidance.
Smelter RCOI and Due Diligence
Malibu Boats’ smelter RCOI and due diligence process were designed to:
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Exhibit 1.01

• | identify the scope of the risk assessment of the mineral supply chain (OECD Due Diligence Guide Step 2B);

• | assess whether the smelters have carried out all elements of due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Due Diligence Guide Step 2C); and

• | carry out, where necessary, including through participation in industry-driven programs, joint spot checks at the mineral smelter’s own facilities (OECD Due Diligence Guide Step 2D).

Malibu Boats’ smelter RCOI and due diligence process included the following:

• | For each smelter identified in Malibu Boats’ supply chain, Malibu Boats:

◦ | engaged directly with the smelter to determine whether or not the smelter sources from the Covered Countries;

◦ | reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration for smelters that declared directly or through their relevant industry association that they did not source from the Covered Countries, and were not recognized as conflict free by the CFSP.

◦ | reviewed publicly available sources to determine if there was any reason to believe that the smelter may have sourced from the Covered Countries during the reporting period for smelters that did not respond to our direct engagement.

• | For high risk smelters (smelters that are sourcing from or there is reason to believe they may be sourcing from the Covered Countries), Malibu Boats determined if the smelter was audited and recognized as conflict free by the CFSP.

◦ | For high risk smelters that have not been audited and recognized as conflict free by the CFSP, Malibu Boats communicated the risk to a designated member of senior management (OECD Due Diligence Guide Step 3A) and conducted risk mitigation on the smelter according to OECD Due Diligence Guide Step 3B.

For the 2015 reporting period, Malibu Boats’ RCOI and due diligence process was executed by Claigan Environmental Inc. (“Claigan”). In 2015, Claigan received an independent auditor’s opinion that the design of Claigan’s RCOI and due diligence process was in compliance with the requirements of Step 2 of the OECD Due Diligence Guidance.
Malibu Boats’ suppliers identified 293 smelters. Malibu Boats identified 39 smelters that source, or there is a reason to believe they source, from the Covered Countries.
Malibu Boats determined that 37 of these 39 smelters have been audited and recognized as conflict free by the CFSP. Malibu Boats conducted risk mitigation on the remaining two smelters as discussed below.
Risk Mitigation
Malibu Boats conducted risk mitigation on two smelters that were not recognized as conflict free by the CFSP and were sourcing from the Covered Countries. Malibu Boats’ risk mitigation was designed in accordance with Step 3B of the OECD Due Diligence Guidance and was reported to our Chief Financial Officer in accordance with Step 3A of the OECD Due Diligence Guidance. Malibu Boats’ risk mitigation process included the following:

• | conducted additional due diligence to determine if there was any reason to believe the smelter directly or indirectly financed or benefited armed groups in the Covered Countries;

• | verified with internal stakeholders and relevant suppliers whether 3TGs from the specific smelter were actually in Malibu Boats’ supply chain in the 2015 reporting period; and

• | engaged directly with each high risk smelter to verify risk and to encourage the smelter to become conflict free.

Malibu Boats did not require the removal of smelters subject to Malibu Boats’ risk mitigation process if there was no reason to believe they were directly or indirectly financing or benefiting armed groups in the Covered Countries. These smelters are scheduled to be re-visited in connection with the preparation of our CMR for calendar year 2016. This process is consistent with Step 3B of the OECD Due Diligence Guidance.
Risk mitigation was required for the following two smelters verified by suppliers likely to be in Malibu Boats’ supply chain.
Tin Smelter - Rwanda
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Exhibit 1.01
In accordance with the OECD Due Diligence Guidance, we do not believe this tin smelter has to be removed from our supply chain. We will review the smelter’s status in connection with the preparation of our CMR for calendar year 2016. The following were our findings on this smelter:

• | the smelter provided a very detailed due diligence report for 2014;

• | the smelter was recognized by the CFSP as ‘active’ (undergoing an independent audit to an industry recognized protocol);

• | the CFSP does not encourage the removal of a smelter from the supply chain as long as the smelter is recognized as active; and

• | there was no reason to believe, from publicly available sources and the smelter’s due diligence report, that the tin smelter directly or indirectly financed or benefitted armed groups in the Covered Countries.

Gold Smelter - United Arab Emirates
In accordance with the OECD Due Diligence Guidance, we do not believe this gold smelter has to be removed from our supply chain. We will review the smelter’s status in connection with the preparation of our CMR for calendar year 2016. The following were our findings on this smelter:

• | the smelter provided a very detailed due diligence report for 2014;

• | the smelter was audited and successfully certified to the Dubai Multi Commodities Centre’s (“DMCC”) responsible sourcing of precious metals;

• | the DMCC responsible sourcing audit is not yet recognized by the CFSP, but is to be reviewed for recognition by the CFSP in 2016; and

• | there was no reason to believe, from publicly available sources and the smelter’s due diligence report, that the gold smelter directly or indirectly financed or benefited armed groups in the Covered Countries.

Improvement Plan
Malibu Boats is taking and will continue to take the following steps to improve the due diligence conducted to further mitigate any risk that the Conflict Minerals contained in the products manufactured or contracted for manufacture by Malibu Boats could directly or indirectly benefit or finance armed groups in the Covered Countries:

• | including a conflict minerals clause in all new and renewing supplier contracts;

• | continuing to drive our suppliers to obtain current, accurate, and complete information about the smelters in their supply chain;

• | engaging smelters sourcing from the Covered Countries to become audited and certified to a protocol recognized by the CFSP; and

• | following up in 2016 on smelters requiring risk mitigation, but not removal from Malibu Boats’ supply chain.

List of Smelters and Refineries
Below are the 293 smelters reported to Malibu Boats as likely to be in Malibu Boats’ supply chain in the 2015 reporting period. 39 of the smelters below are declared to be sourcing or there was reason to believe they may be sourcing from the Covered Countries, specifically from the DRC, Rwanda, Burundi, and Tanzania. As noted above, Malibu Boats has determined that of these 39 smelters, 37 have been audited and recognized as conflict free by the CFSP and Malibu Boats conducted risk mitigation on the remaining two smelters.
Metal Smelter Name
Gold Advanced Chemical Company
Gold Aida Chemical Industries Co., Ltd.
Gold Aktyubinsk Copper Company TOO
Gold Al Etihad Gold Refinery DMCC
Gold Allgemeine Gold-und Silberscheideanstalt A.G.
Gold Almalyk Mining and Metallurgical Complex (AMMC)
Gold AngloGold Ashanti Córrego do Sítio Mineração
Gold Argor-Heraeus SA
Gold Asahi Pretec Corporation
Gold Asahi Refining Canada Limited
Gold Asahi Refining USA Inc.
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Exhibit 1.01
Gold Asaka Riken Co., Ltd.
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold Aurubis AG
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold Bauer Walser AG
Gold Boliden AB
Gold C. Hafner GmbH + Co. KG
Gold Caridad
Gold CCR Refinery - Glencore Canada Corporation
Gold Cendres + Métaux SA
Gold Chimet S.p.A.
Gold Chugai Mining
Gold Daejin Indus Co., Ltd.
Gold Daye Non-Ferrous Metals Mining Ltd.
Gold Do Sung Corporation
Gold Doduco
Gold Dowa
Gold Eco-System Recycling Co., Ltd.
Gold Elemetal Refining, LLC
Gold Emirates Gold DMCC
Gold Faggi Enrico S.p.A.
Gold Fidelity Printers and Refiners Ltd.
Gold Gansu Seemine Material Hi-Tech Co., Ltd.
Gold Geib Refining Corporation
Gold Guangdong Jinding Gold Limited
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold Heimerle + Meule GmbH
Gold Heraeus Ltd. Hong Kong
Gold Heraeus Precious Metals GmbH & Co. KG
Gold Hunan Chenzhou Mining Group Co., Ltd.
Gold Hwasung CJ Co., Ltd.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
Gold Ishifuku Metal Industry Co., Ltd.
Gold Istanbul Gold Refinery
Gold Japan Mint
Gold Jiangxi Copper Company Limited
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold JSC Uralelectromed
Gold JX Nippon Mining & Metals Co., Ltd.
Gold Kazakhmys Smelting LLC
Gold Kazzinc
Gold Kennecott Utah Copper LLC
Gold KGHM Polska Miedź Spółka Akcyjna
Gold Kojima Chemicals Co., Ltd.
Gold Korea Metal Co., Ltd.
Gold Korea Zinc Co. Ltd.
Gold Kyrgyzaltyn JSC
Gold L' azurde Company For Jewelry
Gold Lingbao Gold Company Limited
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold LS-NIKKO Copper Inc.
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Gold Materion
Gold Matsuda Sangyo Co., Ltd.
Gold METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
Gold Metalor Technologies (Hong Kong) Ltd.
Gold Metalor Technologies (Singapore) Pte., Ltd.
Gold Metalor Technologies (Suzhou) Ltd.
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Exhibit 1.01
Gold Metalor Technologies SA
Gold Metalor USA Refining Corporation
Gold Mitsubishi Materials Corporation
Gold Mitsui Mining and Smelting Co., Ltd.
Gold MMTC-PAMP India Pvt., Ltd.
Gold Morris and Watson
Gold Moscow Special Alloys Processing Plant
Gold Nadir Metal Rafineri San. Ve Tic. A.Ş.
Gold Navoi Mining and Metallurgical Combinat
Gold Nihon Material Co., Ltd.
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
Gold Ohura Precious Metal Industry Co., Ltd.
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastvetmet)
Gold OJSC Kolyma Refinery
Gold OJSC Novosibirsk Refinery
Gold PAMP SA
Gold Penglai Penggang Gold Industry Co., Ltd.
Gold Prioksky Plant of Non-Ferrous Metals
Gold PT Aneka Tambang (Persero) Tbk
Gold PX Précinox SA
Gold Rand Refinery (Pty) Ltd.
Gold Republic Metals Corporation
Gold Royal Canadian Mint
Gold Sabin Metal Corp.
Gold Samduck Precious Metals
Gold SAMWON Metals Corp.
Gold SAXONIA Edelmetalle GmbH
Gold Schone Edelmetaal B.V.
Gold SEMPSA Joyería Platería SA
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold Sichuan Tianze Precious Metals Co., Ltd.
Gold Singway Technology Co., Ltd.
Gold So Accurate Group, Inc.
Gold SOE Shyolkovsky Factory of Secondary Precious Metals
Gold Solar Applied Materials Technology Corp.
Gold Sumitomo Metal Mining Co., Ltd.
Gold T.C.A S.p.A
Gold Tanaka Kikinzoku Kogyo K.K.
Gold The Great Wall Gold and Silver Refinery of China
Gold The Refinery of Shandong Gold Mining Co., Ltd.
Gold Tokuriki Honten Co., Ltd.
Gold Tongling Nonferrous Metals Group Co., Ltd.
Gold Torecom
Gold Umicore Brasil Ltda.
Gold Umicore Precious Metals Thailand
Gold Umicore SA Business Unit Precious Metals Refining
Gold United Precious Metal Refining, Inc.
Gold Valcambi SA
Gold Western Australian Mint trading as The Perth Mint
Gold Yamamoto Precious Metal Co., Ltd.
Gold Yokohama Metal Co., Ltd.
Gold Yunnan Copper Industry Co., Ltd.
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Gold Zijin Mining Group Co., Ltd. Gold Refinery
Tantalum Changsha South Tantalum Niobium Co., Ltd.
Tantalum Conghua Tantalum and Niobium Smeltry
Tantalum Duoluoshan
Tantalum D Block Metals, LLC
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Exhibit 1.01
Tantalum Exotech Inc.
Tantalum F&X Electro-Materials Ltd.
Tantalum FIR Metals & Resource Ltd.
Tantalum Global Advanced Metals Aizu
Tantalum Global Advanced Metals Boyertown
Tantalum Guangdong Zhiyuan New Material Co., Ltd.
Tantalum Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
Tantalum H.C. Starck Co., Ltd.
Tantalum H.C. Starck GmbH Goslar
Tantalum H.C. Starck GmbH Laufenburg
Tantalum H.C. Starck Hermsdorf GmbH
Tantalum H.C. Starck Inc.
Tantalum H.C. Starck Ltd.
Tantalum H.C. Starck Smelting GmbH & Co.KG
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum Hi-Temp Specialty Metals, Inc.
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum Jiujiang Tanbre Co., Ltd.
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Tantalum KEMET Blue Metals
Tantalum KEMET Blue Powder
Tantalum King-Tan Tantalum Industry Ltd.
Tantalum LSM Brasil S.A.
Tantalum Metallurgical Products India Pvt., Ltd.
Tantalum Mineração Taboca S.A.
Tantalum Mitsui Mining & Smelting
Tantalum Molycorp Silmet A.S.
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum Plansee SE Liezen
Tantalum Plansee SE Reutte
Tantalum QuantumClean
Tantalum Resind Indústria e Comércio Ltda.
Tantalum RFH Tantalum Smeltry Co., Ltd.
Tantalum Solikamsk Magnesium Works OAO
Tantalum Taki Chemicals
Tantalum Telex Metals
Tantalum Tranzact, Inc.
Tantalum Ulba Metallurgical Plant JSC
Tantalum XinXing HaoRong Electronic Material Co., Ltd.
Tantalum Yichun Jin Yang Rare Metal Co., Ltd.
Tantalum Zhuzhou Cemented Carbide
Tin Alpha
Tin An Thai Minerals Company Limited
Tin An Vinh Joint Stock Mineral Processing Company
Tin China Tin Group Co., Ltd.
Tin CNMC (Guangxi) PGMA Co., Ltd.
Tin Cooperativa Metalurgica de Rondônia Ltda.
Tin CV Ayi Jaya
Tin CV Gita Pesona
Tin CV Serumpun Sebalai
Tin CV United Smelting
Tin CV Venus Inti Perkasa
Tin Dowa
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin Elmet S.L.U (Metallo Group)
Tin EM Vinto
Tin Estanho de Rondônia S.A.
Tin Feinhütte Halsbrücke GmbH
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Exhibit 1.01
Tin Fenix Metals
Tin Gejiu Kai Meng Industry and Trade LLC
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin Gejiu Zili Mining And Metallurgy Co., Ltd.
Tin Huichang Jinshunda Tin Co., Ltd.
Tin Jiangxi Ketai Advanced Material Co., Ltd.
Tin Linwu Xianggui Ore Smelting Co., Ltd.
Tin Magnu's Minerais Metais e Ligas Ltda.
Tin Malaysia Smelting Corporation (MSC)
Tin Melt Metais e Ligas S/A
Tin Metallic Resources, Inc.
Tin Metallo-Chimique N.V.
Tin Mineração Taboca S.A.
Tin Minsur
Tin Mitsubishi Materials Corporation
Tin Nankang Nanshan Tin Manufactory Co., Ltd.
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin O.M. Manufacturing Philippines, Inc.
Tin O.M. Manufacturing (Thailand) Co., Ltd.
Tin Operaciones Metalurgical S.A.
Tin Phoenix Metal Ltd.
Tin PT Alam Lestari Kencana
Tin PT Aries Kencana Sejahtera
Tin PT Artha Cipta Langgeng
Tin PT ATD Makmur Mandiri Jaya
Tin PT Babel Inti Perkasa
Tin PT Bangka Prima Tin
Tin PT Bangka Timah Utama Sejahtera
Tin PT Bangka Tin Industry
Tin PT Belitung Industri Sejahtera
Tin PT BilliTin Makmur Lestari
Tin PT Bukit Timah
Tin PT Cipta Persada Mulia
Tin PT DS Jaya Abadi
Tin PT Eunindo Usaha Mandiri
Tin PT Fang Di MulTindo
Tin PT Inti Stania Prima
Tin PT Justindo
Tin PT Karimun Mining
Tin PT Mitra Stania Prima
Tin PT Panca Mega Persada
Tin PT Pelat Timah Nusantara Tbk
Tin PT Prima Timah Utama
Tin PT Refined Bangka Tin
Tin PT Sariwiguna Binasentosa
Tin PT Stanindo Inti Perkasa
Tin PT Sumber Jaya Indah
Tin PT Timah (Persero) Tbk Kundur
Tin PT Timah (Persero) Tbk Mentok
Tin PT Tinindo Inter Nusa
Tin PT Tirus Putra Mandiri
Tin PT Wahana Perkit Jaya
Tin Resind Indústria e Comércio Ltda.
Tin Rui Da Hung
Tin Soft Metais Ltda.
Tin Thaisarco
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tin VQB Mineral and Trading Group JSC
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Exhibit 1.01
Tin White Solder Metalurgia e Mineração Ltda.
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin Yunnan Tin Group (Holding) Company Limited
Tungsten A.L.M.T. TUNGSTEN Corp.
Tungsten Asia Tungsten Products Vietnam Ltd.
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten Dayu Weiliang Tungsten Co., Ltd.
Tungsten Fujian Jinxin Tungsten Co., Ltd.
Tungsten Ganxian Shirui New Material Co., Ltd.
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten Ganzhou Yatai Tungsten Co., Ltd.
Tungsten Global Tungsten & Powders Corp.
Tungsten Guangdong Xianglu Tungsten Co., Ltd.
Tungsten H.C. Starck GmbH
Tungsten H.C. Starck Smelting GmbH & Co.KG
Tungsten Hunan Chenzhou Mining Group Co., Ltd.
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten Hydrometallurg, JSC
Tungsten Japan New Metals Co., Ltd.
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten Kennametal Fallon
Tungsten Kennametal Huntsville
Tungsten Malipo Haiyu Tungsten Co., Ltd.
Tungsten Niagara Refining LLC
Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Tungsten Pobedit, JSC
Tungsten Sanher Tungsten Vietnam Co., Ltd.
Tungsten Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd.
Tungsten Wolfram Bergbau und Hütten AG
Tungsten Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten Xiamen Tungsten Co., Ltd.
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd.
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