EX-1.01 2 exhibit101conflictminerals.htm EX-1.01
Exhibit 1.01
Malibu Boats, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2019
Introduction
This Conflict Minerals Report (“CMR”) for the year ended December 31, 2019 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 a diverse range of recreational powerboats, including performance sport boats, sterndrive and outboard boats. Our boats are used for water sports, general recreational boating and fishing. Our high performance boats are sold under four brands: Malibu; Axis; Cobalt and Pursuit. We manufacture our own Malibu, Axis, Cobalt and Pursuit 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 electronic controls. Pursuant to our engine integration strategy, beginning with our model year 2019 boats we are purchasing engines from General Motors LLC and preparing them for marine use. We determined that Conflict Minerals were necessary to the functionality and/or production of such products during calendar year 2019.
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 298 smelters and refineries (“smelters”). Of these 298 smelters, Malibu Boats identified 41 as sourcing (or there was a reason to believe they may be sourcing) from the Covered Countries. Malibu Boats’ due diligence review indicated that 33 of these smelters have been audited and recognized as conflict free by the Responsible Minerals Assurance Process (“RMAP”) and designated as RMAP Conformant by the Responsible Minerals Initiative. The remaining eight 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.
Although we requested information at a product level, many suppliers returned information at a company or division level, not at a product level. Such suppliers were unable to specify the smelters used for components supplied to Malibu Boats. Therefore the information provided was not necessarily limited to smelters contained in components supplied to us and confirmed to be in the Company’s 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:
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Exhibit 1.01
◦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 https://investors.malibuboats.com/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;
▪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 RMAP’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 2019 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 298 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
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Exhibit 1.01
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:
◦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:
▪attempted to engage 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 RMAP; and
▪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 RMAP.
▪For high risk smelters that have not been audited and recognized as conflict free by the RMAP, 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 2019 reporting period, Malibu Boats’ RCOI and due diligence process was executed by Claigan Environmental Inc.
Malibu Boats’ suppliers identified 298 smelters. Malibu Boats identified 41 smelters that source, or there is a reason to believe they source, from the Covered Countries.
Malibu Boats determined that 33 of these 41 smelters have been audited and recognized as conflict free by the RMAP or RMAP Conformant. Malibu Boats conducted risk mitigation on the remaining eight smelters as discussed below.
Risk Mitigation
Malibu Boats conducted risk mitigation on eight smelters that were not recognized as conflict free by the RMAP 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;
◦attempted to verify with internal stakeholders and relevant suppliers whether 3TGs from the specific smelter were actually in Malibu Boats’ supply chain in the 2019 reporting period; and
◦engaged directly with each high risk smelter to verify risk and to encourage the smelter to become conflict free.
As discussed above, as many suppliers return information at a company or division level, and not at a product level, we are not able to determine if the eight remaining smelters are confirmed to be in Malibu Boats’ supply chain. We will continue to work with our suppliers to determine if these eight smelters can be directly linked to the actual parts or products sold to Malibu Boats.
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Exhibit 1.01
In addition, as part of our risk mitigation process we have engaged with each of them to verify risk and to encourage the smelter to become conflict free. We are continuing to work with the suppliers who currently have these eight smelters in their supply chain to evaluate the removal of these smelters from their supply chain.
Improvement Plan
Malibu Boats is dedicated to eliminating the use of Conflict Minerals that originate from mines controlled by non-governmental groups in the Covered Countries, who contribute to human rights abuses including human trafficking, inhumane treatment, forced labor, child labor, war crimes or crimes against humanity.
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;
◦continuing to work with our suppliers to encourage the removal of any high risk smelters;
◦evaluating ongoing supplier relationships with those suppliers that do not comply with our conflict minerals policy;
◦engaging smelters sourcing from the Covered Countries to become audited and certified to a protocol recognized by the RMAP; and
◦following up in 2020 on the smelter requiring risk mitigation, but not removal from Malibu Boats’ supply chain.
List of Smelters and Refineries
Below are the 298 smelters reported to Malibu Boats as likely to be in Malibu Boats’ supply chain in the 2019 reporting period. 41 of the smelters below are declared to be sourcing or there was reason to believe they may be sourcing from the Covered Countries. Under the SEC Final Rule, the requirement is to identify whether or not a smelter is sourcing from the Covered Countries; there is no requirement to identify the specific covered country by smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified Covered Countries are The Democratic Republic of the Congo, Rwanda, Burundi, and Tanzania. As noted above, Malibu Boats has determined that of these 41 smelters, 33 have been audited and recognized as conflict free by the RMAP and Malibu Boats conducted risk mitigation on the remaining eight smelters.
Metal Smelter Name

Gold | 8853 S.p.A.
Gold | Abington Reldan Metals, LLC
Gold | Advanced Chemical Company
Gold | African Gold Refinery
Gold | Aida Chemical Industries Co., Ltd.
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 S.A.
Gold | Asahi Pretec Corp.
Gold | Asahi Refining Canada Ltd.
Gold | Asahi Refining USA Inc.
Gold | Asaka Riken Co., Ltd.
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold | AU Traders and Refiners
Gold | Aurubis AG
Gold | Bangalore Refinery
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

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Exhibit 1.01

Gold | Boliden AB
Gold | C. Hafner GmbH + Co. KG
Gold | Caridad
Gold | CCR Refinery - Glencore Canada Corporation
Gold | Cendres + Métaux S.A.
Gold | CGR Metalloys Pvt Ltd.
Gold | Chimet S.p.A.
Gold | Chugai Mining
Gold | Daye Non-Ferrous Metals Mining Ltd.
Gold | Degussa Sonne / Mond Goldhandel GmbH
Gold | Dijllah Gold Refinery FZC
Gold | DODUCO Contacts and Refining GmbH
Gold | Dowa
Gold | DS PRETECH Co., Ltd.
Gold | DSC (Do Sung Corporation)
Gold | Eco-System Recycling Co., Ltd. East Plant
Gold | Eco-System Recycling Co., Ltd. North Plant
Gold | Eco-System Recycling Co., Ltd. West Plant
Gold | Emirates Gold DMCC
Gold | Fidelity Printers and Refiners Ltd.
Gold | Fujairah Gold FZC
Gold | Geib Refining Corporation
Gold | Gold Refinery of Zijin Mining Group Co., Ltd.
Gold | Great Wall Precious Metals Co., Ltd. of CBPM
Gold | Guangdong Jinding Gold Limited
Gold | Gujarat Gold Centre
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold | HeeSung Metal Ltd.
Gold | Heimerle + Meule GmbH
Gold | Heraeus Metals Hong Kong Ltd.
Gold | Heraeus Precious Metals GmbH & Co. KG
Gold | Hunan Chenzhou Mining Co., Ltd.
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
Gold | HwaSeong CJ Co., Ltd.
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold | International Precious Metal Refiners
Gold | Ishifuku Metal Industry Co., Ltd.
Gold | Istanbul Gold Refinery
Gold | Italpreziosi
Gold | Japan Mint
Gold | Jiangxi Copper Co., Ltd.
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold | JSC Novosibirsk Refinery
Gold | JSC Uralelectromed
Gold | JX Nippon Mining & Metals Co., Ltd.
Gold | Kaloti Precious Metals
Gold | Kazakhmys Smelting LLC
Gold | Kazzinc

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Exhibit 1.01

Gold | Kennecott Utah Copper LLC
Gold | KGHM Polska Miedź Spółka Akcyjna
Gold | Kojima Chemicals Co., Ltd.
Gold | Korea Zinc Co., Ltd.
Gold | Kyrgyzaltyn JSC
Gold | Kyshtym Copper-Electrolytic Plant ZAO
Gold | L'azurde Company For Jewelry
Gold | L'Orfebre S.A.
Gold | Lingbao Gold Co., Ltd.
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold | LS-NIKKO Copper Inc.
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Gold | Marsam Metals
Gold | Materion
Gold | Matsuda Sangyo Co., Ltd.
Gold | Metalor Technologies (Hong Kong) Ltd.
Gold | Metalor Technologies (Singapore) Pte., Ltd.
Gold | Metalor Technologies (Suzhou) Ltd.
Gold | Metalor Technologies S.A.
Gold | Metalor USA Refining Corporation
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V.
Gold | Mitsubishi Materials Corporation
Gold | Mitsui Mining and Smelting Co., Ltd.
Gold | MMTC-PAMP India Pvt., Ltd.
Gold | Modeltech Sdn Bhd
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 | NH Recytech Company
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 Krastsvetmet)
Gold | PAMP S.A.
Gold | Pease & Curren
Gold | Penglai Penggang Gold Industry Co., Ltd.
Gold | Planta Recuperadora de Metales SpA
Gold | Prioksky Plant of Non-Ferrous Metals
Gold | PT Aneka Tambang (Persero) Tbk
Gold | PX Précinox S.A.
Gold | QG Refining, LLC
Gold | Rand Refinery (Pty) Ltd.
Gold | Refinery of Seemine Gold Co., Ltd.
Gold | REMONDIS PMR B.V.
Gold | Royal Canadian Mint
Gold | SAAMP
Gold | Sabin Metal Corp.
Gold | Safimet S.p.A

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Exhibit 1.01

Gold | SAFINA A.S.
Gold | Sai Refinery
Gold | Samduck Precious Metals
Gold | SAMWON Metals Corp.
Gold | SAXONIA Edelmetalle GmbH
Gold | SEMPSA Joyería Platería S.A.
Gold | Shandong Humon Smelting Co., Ltd.
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 | SOE Shyolkovsky Factory of Secondary Precious Metals
Gold | Solar Applied Materials Technology Corp.
Gold | Sovereign Metals
Gold | State Research Institute Center for Physical Sciences and Technology
Gold | Sudan Gold Refinery
Gold | Sumitomo Metal Mining Co., Ltd.
Gold | SungEel HiMetal Co., Ltd.
Gold | T.C.A S.p.A
Gold | Tanaka Kikinzoku Kogyo K.K.
Gold | The Refinery of Shandong Gold Mining Co., Ltd.
Gold | Tokuriki Honten Co., Ltd.
Gold | Tongling Nonferrous Metals Group Co., Ltd.
Gold | Tony Goetz NV
Gold | TOO Tau-Ken-Altyn
Gold | Torecom
Gold | Umicore Brasil Ltda.
Gold | Umicore Precious Metals Thailand
Gold | Umicore S.A. Business Unit Precious Metals Refining
Gold | United Precious Metal Refining, Inc.
Gold | Valcambi S.A.
Gold | Western Australian Mint (T/a The Perth Mint)
Gold | WIELAND Edelmetalle GmbH
Gold | Yamakin Co., Ltd.
Gold | Yokohama Metal Co., Ltd.
Gold | Yunnan Copper Industry Co., Ltd.
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Tantalum | Asaka Riken Co., Ltd.
Tantalum | Changsha South Tantalum Niobium Co., Ltd.
Tantalum | CP Metals Inc.
Tantalum | D Block Metals, LLC
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 | H.C. Starck Co., Ltd.
Tantalum | H.C. Starck Hermsdorf GmbH

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Exhibit 1.01

Tantalum | H.C. Starck Inc.
Tantalum | H.C. Starck Ltd.
Tantalum | H.C. Starck Smelting GmbH & Co. KG
Tantalum | H.C. Starck Tantalum and Niobium GmbH
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum | Jiangxi Tuohong New Raw Material
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 | LSM Brasil S.A.
Tantalum | Metallurgical Products India Pvt., Ltd.
Tantalum | Mineração Taboca S.A.
Tantalum | Mitsui Mining & Smelting
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum | NPM Silmet AS
Tantalum | Power Resources Ltd.
Tantalum | QuantumClean
Tantalum | Resind Indústria e Comércio Ltda.
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
Tantalum | Solikamsk Magnesium Works OAO
Tantalum | Taki Chemical Co., Ltd.
Tantalum | Telex Metals
Tantalum | Ulba Metallurgical Plant JSC
Tantalum | XinXing HaoRong Electronic Material Co., Ltd.
Tin | Alpha
Tin | An Vinh Joint Stock Mineral Processing Company
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin | Chifeng Dajingzi Tin Industry Co., Ltd.
Tin | China Tin Group Co., Ltd.
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd.
Tin | Dowa
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin | EM Vinto
Tin | Estanho de Rondônia S.A.
Tin | Fenix Metals
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd.
Tin | Gejiu Fengming Metallurgy Chemical Plant
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 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
Tin | Guanyang Guida Nonferrous Metal Smelting Plant
Tin | HuiChang Hill Tin Industry Co., Ltd.
Tin | Huichang Jinshunda Tin Co., Ltd.
Tin | Jiangxi New Nanshan Technology Ltd.

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Exhibit 1.01

Tin | Ma'anshan Weitai Tin 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 Belgium N.V.
Tin | Metallo Spain S.L.U.
Tin | Mineração Taboca S.A.
Tin | Minsur
Tin | Mitsubishi Materials Corporation
Tin | Modeltech Sdn Bhd
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin | O.M. Manufacturing (Thailand) Co., Ltd.
Tin | O.M. Manufacturing Philippines, Inc.
Tin | Operaciones Metalúrgicas S.A.
Tin | Pongpipat Company Limited
Tin | Precious Minerals and Smelting Limited
Tin | PT Artha Cipta Langgeng
Tin | PT ATD Makmur Mandiri Jaya
Tin | PT Menara Cipta Mulia
Tin | PT Mitra Stania Prima
Tin | PT Refined Bangka Tin
Tin | PT Timah Tbk Kundur
Tin | PT Timah Tbk Mentok
Tin | Resind Indústria e Comércio Ltda.
Tin | Rui Da Hung
Tin | Soft Metais Ltda.
Tin | Super Ligas
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd.
Tin | Thaisarco
Tin | Tin Technology & Refining
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tin | White Solder Metalurgia e Mineração Ltda.
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin | Yunnan Tin Company Limited
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd.
Tungsten | A.L.M.T. TUNGSTEN Corp.
Tungsten | ACL Metais Eireli
Tungsten | Asia Tungsten Products Vietnam Ltd.
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten | CNMC (Guangxi) PGMA Co., Ltd.
Tungsten | Fujian Ganmin RareMetal Co., Ltd.
Tungsten | Fujian Jinxin Tungsten Co., Ltd.
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd.
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten | Global Tungsten & Powders Corp.

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Exhibit 1.01

Tungsten | Guangdong Xianglu Tungsten Co., Ltd.
Tungsten | H.C. Starck Smelting GmbH & Co. KG
Tungsten | H.C. Starck Tungsten GmbH
Tungsten | Hunan Chenzhou Mining Co., Ltd.
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten | Hunan Litian Tungsten Industry Co., Ltd.
Tungsten | Hydrometallurg, JSC
Tungsten | Japan New Metals Co., Ltd.
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten | Jiangxi Dayu Longxintai Tungsten 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 Yaosheng Tungsten Co., Ltd.
Tungsten | JSC "Kirovgrad Hard Alloys Plant"
Tungsten | Kennametal Fallon
Tungsten | Kennametal Huntsville
Tungsten | KGETS Co., Ltd.
Tungsten | Lianyou Metals Co., Ltd.
Tungsten | Malipo Haiyu Tungsten Co., Ltd.
Tungsten | Masan Tungsten Chemical LLC (MTC)
Tungsten | Moliren Ltd.
Tungsten | Niagara Refining LLC
Tungsten | Philippine Chuangxin Industrial Co., Inc.
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten | Unecha Refractory Metals Plant
Tungsten | Wolfram Bergbau und Hütten AG
Tungsten | Woltech Korea Co., Ltd.
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten | Xiamen Tungsten Co., Ltd.
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.

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