Exhibit 1.01

ASV Holdings, Inc.

Conflict Minerals Report

For Calendar Year Ended December 31, 2019

Introduction and Summary

This report 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 was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements pursuant to Section 13(p) of the Securities and Exchange Act of 1934 (“Section 13(p)”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. The term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (“3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The adjoining countries include: The Republic of the Congo, the Central African Republic, South Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania and Angola.

ASV Holdings, Inc. (herein referred to as “ASV”, the “Company”, “we”, “us”, or “our”) determined that 3TG were necessary to the functionality or production of products that we manufactured or contracted to be manufactured during the 2019 calendar year. Therefore, ASV conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the 3TG in its products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”). Based on its RCOI, ASV believes that its products could contain 3TG that may have originated in the Covered Countries and, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the 3TG in question to determine whether its products are “DRC Conflict Free”. The Company designed its due diligence measures to conform, in all material respects, with the nationally recognized due diligence 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 gold and for tin, tantalum and tungsten (the “OECD Guidance”).

Company Overview

This report has been prepared by the management of ASV. The information includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated.

ASV designs and manufactures a broad range of high-quality compact track loader (“CTL”) and skid steer loader (“SSL”) equipment, marketed through a distribution network in North America, Australia, and New Zealand. We also serve as a private label original equipment manufacturer for several manufacturers. Our products are used principally in the construction, agriculture, and forest industries. As a full-service manufacturer, we provide pre- and post-sale dealer support, after-sale technical support, and replacement parts supplied from our dedicated logistics center.

Conflict Minerals Program & Policy

ASV has actively engaged with our customers and suppliers for several years with respect to the use of conflict minerals. Our actions are a result of ASV’s responsible and inclusive culture and longstanding leadership in corporate responsibility.

We adopted a Conflict Minerals Policy articulating our conflict minerals supply chain due diligence process and our commitment to our reporting obligations regarding conflict minerals.

Reasonable Country of Origin Inquiry

To determine whether the necessary 3TG in our products originated in Covered Countries, we retained Assent Compliance (“Assent”), our third-party service provider, to assist us in reviewing our supply chain. We provided a list composed of suppliers associated with the Covered Products to Assent for upload to the Assent Compliance Manager tool (“ACM”). We deemed it impractical to filter this list further to exclude some possibly irrelevant suppliers because we could not determine definitively the presence or absence of conflict minerals in all parts supplied to ASV for our products.

ASV utilized the RBA-GeSI Conflict Minerals Reporting Template (“CMRT”) version 5.11 or higher to conduct a survey of all in scope suppliers. During the supplier survey, we contacted suppliers via the ACM, a SaaS platform provided by Assent that enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRTs directly to the platform for assessment and management. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, question 1 of the CMRT asks suppliers whether any of the 3TGs they use are necessary to the functionality or production of their products. We also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process. We conducted this analysis based on the following criteria:

• The company supplies packaging only (excluding labels)

• The company supplies us with items that do not end up in our products (including equipment used to make our products)

• The company is a test lab

• The company is a service provider only

Assent requested that all suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. ASV directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested such suppliers to complete the CMRT form and submit such form to Assent.

Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on:

• Questions 1 and 2 are minimum requirements for the CMRT

^○  If suppliers state (via Q1 and Q2) that their products do not contain 3TGs necessary to the function or production of said products, then no further information is required and no further data validation is completed.

• Question 3 – Do any of your 3TGs originate from the covered countries?

^○  Any supplier that has any 3TGs from the covered countries, even 1 positive response from their supply chain must answer yes.

• Question 4– is 100% of the 3TG in question from a recycled source?

• Question 5 – Have you received info from all relevant 3TG Suppliers?

^○  If you are not at 100%, then you can’t make definitive statements for Questions 3, 4 and 6

• Question 6 – Have you identified all your Smelters and refiners?

^○  If the answer here is yes, then question 5 must be yes. This also impacts question 3.

All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. As of May 20^th, 2020, there were 5 invalid supplier submissions that could not be corrected.

Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the Responsible Minerals Initiative(“RMI”) and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TG. Our suppliers identified a total of 303 smelters and refiners that appear on the list maintained by RMI. Of these 303 smelters and refiners, 235 are validated as conflict free by RMI, and, based on information provided by RMI, a further 6 have agreed to undergo or are currently undergoing a third-party audit. Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers processed the 3TG contained in our products. All smelters and refiners identified by our suppliers that we believe may source 3TG from the Covered Countries appear on RMI’s list of validated conflict free smelters and refiners.

Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the conflict minerals in question.

Design of Due Diligence

We designed our due diligence measures to conform, in all material respects, with the framework in

OECD Guidance for gold, tin, tantalum and tungsten. The OECD Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:

1. Establishing strong company management systems regarding conflict minerals;

2. Identifying and assessing risks in our supply chain;

3. Designing and implementing a strategy to respond to identified risks in our supply chain;

4. Utilizing independent third-party audits of supply chain diligence; and

5. Publicly reporting on our supply chain due diligence

We are a downstream supplier, many steps removed from the mining of 3TG. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, ASV does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.

The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based

on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.

Due Diligence Performed

1) Establish Strong Company Management Systems

Internal Compliance Team

ASV established a cross-functional Conflict Minerals Compliance Team, sponsored by our VP of Operations and Supply Chain, comprising representatives from our purchasing, subcontracts, legal and finance teams. Subject matter experts from relevant functions such as purchasing, subcontracts, and engineering support this team. The Conflict Minerals Compliance Team is responsible for implementing our conflict minerals compliance strategy and briefing senior management about the results of our due diligence efforts.

ASV also uses a third-party service provider, Assent Compliance, to assist us with evaluating supply chain information regarding 3TGs and in the development and implementation of additional due diligence steps that we will undertake with suppliers regarding conflict minerals.

Control Systems

ASV expects all of its suppliers to have policies and procedures in place to ensure that any 3TGs used in the production of the products sold to ASV are DRC conflict-free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries.

Other controls include, but are not limited to, our Code of Conduct which outlines certain expected behaviors for all employees. In addition, 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.

Supplier Engagement

ASV engages with suppliers directly to request that they complete a valid CMRT for the products that they supply to ASV. With respect to the OECD requirement to strengthen engagement with suppliers, ASV has, through Assent, provided education on the Conflict Minerals regulation as well as the expectations of the law and for a continued business relationship, leveraged the existing communications with the company, specifically procurement through the Purchase Order terms and conditions, which were updated to include Conflict Minerals compliance requirements. Feedback from this engagement has allowed ASV to oversee improvements in supplier responses and supplier compliance for this initiative. It has also allowed for our supplier communications to be more focused and ensure expectations are clear.

This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized Assent’s Learning Management System, Assent University, and provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.

Grievance Mechanisms

We established multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of ASV’s policies, including with respect to conflict minerals. In addition, our employees may anonymously report suspected violations using our EthicsPoint hotline, available 24 hours a day, seven days a week. ASV’s EthicsPoint hotline is staffed by non-ASV personnel, who share any information reported with our Corporate Compliance Committee.

Maintain Records

ASV has adopted a policy to retain relevant documentation for a period of 5 years. We implemented a document retention policy through Assent to retain conflict minerals related documents, including supplier responses to CMRTs. We store all of the information and findings from this process in a database that can be audited by internal or external parties.

2) Identifying and Assessing Risk in the Supply Chain

Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in the Assent Compliance Manager system based on criteria established for supplier responses in the System. These risks are addressed by Assent Compliance Supply Chain staff and members of our Conflict Minerals team internally who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.

The primary risk we identified with respect to the reporting period ended May 20^th, 2020 related to the nature of the responses received. A large number of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG in the components supplied to ASV. Additionally, many suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.

In accordance with OECD Guidelines, it is important to identify and assess risks associated with conflict minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the 2019 calendar year.

In order to assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the RMAP. 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. Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.

As of May 20^th, 2020, we have validated 303 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primarily supplier-level CMRTs, we cannot definitely determine their connection to the Covered Products.

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.

• Geographic proximity to the DRC and covered countries;

• Responsible Minerals Assurance Process (RMAP) audit status;

• Credible evidence of unethical or conflict sourcing.

Based on these criteria the following facilities have been identified with red-flag risks in their supply chain:

• Tony Goetz NV - CID002587

• African Gold Refinery Limited (AGR) - CID003185

• Kaloti Precious Metals - CID002563

• Fidelity Printers and Refiners - CID002515

• Sudan Gold Refinery - CID002567

As part of our risk management plan under the OECD Guidance, when these facilities are reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier 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 ASV, and escalating up to removal of these red flag smelters from their supply chain.

As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. 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.

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:

A. Have you established a conflict minerals sourcing policy?

E. Have you implemented due diligence measures for conflict-free sourcing?

G. Do you review due diligence information received from your suppliers against your company’s expectations?

H. Does your review process include corrective action management?

When suppliers meet or exceed those criteria (Yes to at least A, E, G, and H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. At this time, 15 of our responsive suppliers have been identified as having a weak program.

3) Design and Implement a Strategy to Respond to Risks

Together with Assent, we developed processes to assess and respond to the risks identified in our supply chain. In response to this risk assessment, ASV has a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the Conflict Minerals rules.

We encourage any of our suppliers whom we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD Guidance.

4) Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.

5) Public Reporting on Supply Chain Due Diligence

We have publicly filed our Form SD and this report with the Securities and Exchange Commission.

Information found on or accessed through our website is not considered part of this report and is not incorporated by reference herein.

Through our membership with the RMI, we encouraged smelters or refiners to participate in the RMAP. Any smelters or refiners that were reported by our suppliers who were not part of the RMAP, were also contacted directly by Assent to encourage them to participate in the RMAP.

Due Diligence Results

Survey Results

For the 2019 reporting year, ASV received CMRT forms from 79% of the suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. Two suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. We surveyed a total of 209 in scope suppliers and received 165 CMRT submissions by May 20^th, 2020.

Smelters and Refiners

Attached as Appendix A is a list of all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Since most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed on Appendix A actually processed the 3TGs contained in our products. Therefore, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that actually processed the conflict minerals contained in our products.

From the responses that we received, we identified 5 smelters that potentially posed a risk. These concerns stem from location of the facilities and claims that fall outside of the scope of the conflict minerals law. For suppliers that identified these specific smelters of concern on their CMRT, we created a new escalation plan. These suppliers were contacted by Assent and ASV to evaluate whether or not these smelters could be connected to ASV products. The suppliers were asked to complete a product-level CMRT, rather than a company-level, to better identify the connection to products that they supply to ASV. Other suppliers were evaluated internally to determine if they were in fact still active suppliers. If not, they were removed from the scope of data collection.

Countries of Origin

Appendix B 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 the RMI. As mentioned in the above section, many responses were provided at the company level, therefore, Appendix B may contain more countries than those that our products are being sourced from.

Steps to be Taken to Mitigate Risk

Since June 30, 2017, we have taken or intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the DRC or adjoining countries:

• Work more closely with our third-party conflict minerals service provider to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TGs contained in our products.

• Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of 3TGs.

• Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.

• Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts as well as included in the terms and conditions of each purchase order issued

• Increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program.

Appendix A - smelter list

• Includes: mineral, smelter/refinery name, location

Metal		Standard Smelter Name		Smelter Facility Location
Gold		8853 S.p.A.		ITALY
Gold		Abington Reldan Metals, LLC		UNITED STATES OF AMERICA
Gold		Advanced Chemical Company		UNITED STATES OF AMERICA
Gold		African Gold Refinery		UGANDA
Gold		Aida Chemical Industries Co., Ltd.		JAPAN
Gold		Al Etihad Gold Refinery DMCC		UNITED ARAB EMIRATES
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		GERMANY
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		UZBEKISTAN
Gold		AngloGold Ashanti Corrego do Sitio Mineracao		BRAZIL
Gold		Argor-Heraeus S.A.		SWITZERLAND
Gold		Asahi Pretec Corp.		JAPAN
Gold		Asahi Refining Canada Ltd.		CANADA
Gold		Asahi Refining USA Inc.		UNITED STATES OF AMERICA
Gold		Asaka Riken Co., Ltd.		JAPAN
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		TURKEY
Gold		AU Traders and Refiners		SOUTH AFRICA
Gold		Aurubis AG		GERMANY
Gold		Bangalore Refinery		INDIA
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		PHILIPPINES
Gold		Boliden AB		SWEDEN
Gold		C. Hafner GmbH + Co. KG		GERMANY
Gold		C.I Metales Procesados Industriales SAS		COLOMBIA

Gold		Caridad		MEXICO
Gold		CCR Refinery - Glencore Canada Corporation		CANADA
Gold		Cendres + Metaux S.A.		SWITZERLAND
Gold		CGR Metalloys Pvt Ltd.		INDIA
Gold		Chimet S.p.A.		ITALY
Gold		Chugai Mining		JAPAN
Gold		Daye Non-Ferrous Metals Mining Ltd.		CHINA
Gold		Degussa Sonne / Mond Goldhandel GmbH		GERMANY
Gold		Dijllah Gold Refinery FZC		UNITED ARAB EMIRATES
Gold		DODUCO Contacts and Refining GmbH		GERMANY
Gold		Dowa		JAPAN
Gold		DS PRETECH Co., Ltd.		KOREA, REPUBLIC OF
Gold		DSC (Do Sung Corporation)		KOREA, REPUBLIC OF
Gold		Eco-System Recycling Co., Ltd. East Plant		JAPAN
Gold		Eco-System Recycling Co., Ltd. North Plant		JAPAN
Gold		Eco-System Recycling Co., Ltd. West Plant		JAPAN
Gold		Emirates Gold DMCC		UNITED ARAB EMIRATES
Gold		Fidelity Printers and Refiners Ltd.		ZIMBABWE
Gold		Fujairah Gold FZC		UNITED ARAB EMIRATES
Gold		GCC Gujrat Gold Centre Pvt. Ltd.		INDIA
Gold		Geib Refining Corporation		UNITED STATES OF AMERICA
Gold		Gold Coast Refinery		GHANA
Gold		Gold Refinery of Zijin Mining Group Co., Ltd.		CHINA
Gold		Great Wall Precious Metals Co., Ltd. of CBPM		CHINA
Gold		Guangdong Jinding Gold Limited		CHINA
Gold		Guoda Safina High-Tech Environmental Refinery Co., Ltd.		CHINA
Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.		CHINA
Gold		Heimerle + Meule GmbH		GERMANY
Gold		Heraeus Metals Hong Kong Ltd.		CHINA
Gold		Heraeus Precious Metals GmbH & Co. KG		GERMANY
Gold		Hunan Chenzhou Mining Co., Ltd.		CHINA
Gold		Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.		CHINA
Gold		HwaSeong CJ CO., LTD.		KOREA, REPUBLIC OF

Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.		CHINA
Gold		International Precious Metal Refiners		UNITED ARAB EMIRATES
Gold		Ishifuku Metal Industry Co., Ltd.		JAPAN
Gold		Istanbul Gold Refinery		TURKEY
Gold		Italpreziosi		ITALY
Gold		JALAN & Company		INDIA
Gold		Japan Mint		JAPAN
Gold		Jiangxi Copper Co., Ltd.		CHINA
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		RUSSIAN FEDERATION
Gold		JSC Uralelectromed		RUSSIAN FEDERATION
Gold		JX Nippon Mining & Metals Co., Ltd.		JAPAN
Gold		Kaloti Precious Metals		UNITED ARAB EMIRATES
Gold		Kazakhmys Smelting LLC		KAZAKHSTAN
Gold		Kazzinc		KAZAKHSTAN
Gold		Kennecott Utah Copper LLC		UNITED STATES OF AMERICA
Gold		KGHM Polska Miedz Spolka Akcyjna		POLAND
Gold		Kojima Chemicals Co., Ltd.		JAPAN
Gold		Korea Zinc Co., Ltd.		KOREA, REPUBLIC OF
Gold		Kyrgyzaltyn JSC		KYRGYZSTAN
Gold		Kyshtym Copper-Electrolytic Plant ZAO		RUSSIAN FEDERATION
Gold		L’azurde Company For Jewelry		SAUDI ARABIA
Gold		Lingbao Gold Co., Ltd.		CHINA
Gold		Lingbao Jinyuan Tonghui Refinery Co., Ltd.		CHINA
Gold		L’Orfebre S.A.		ANDORRA
Gold		LS-NIKKO Copper Inc.		KOREA, REPUBLIC OF
Gold		LT Metal Ltd.		KOREA, REPUBLIC OF

Gold		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.		CHINA
Gold		Marsam Metals		BRAZIL
Gold		Materion		UNITED STATES OF AMERICA
Gold		Matsuda Sangyo Co., Ltd.		JAPAN
Gold		Metalor Technologies (Hong Kong) Ltd.		CHINA
Gold		Metalor Technologies (Singapore) Pte., Ltd.		SINGAPORE
Gold		Metalor Technologies (Suzhou) Ltd.		CHINA
Gold		Metalor Technologies S.A.		SWITZERLAND
Gold		Metalor USA Refining Corporation		UNITED STATES OF AMERICA
Gold		Metalurgica Met-Mex Penoles S.A. De C.V.		MEXICO
Gold		Mitsubishi Materials Corporation		JAPAN
Gold		Mitsui Mining and Smelting Co., Ltd.		JAPAN
Gold		MMTC-PAMP India Pvt., Ltd.		INDIA
Gold		Modeltech Sdn Bhd		MALAYSIA
Gold		Morris and Watson		NEW ZEALAND
Gold		Moscow Special Alloys Processing Plant		RUSSIAN FEDERATION
Gold		Nadir Metal Rafineri San. Ve Tic. A.S.		TURKEY
Gold		Navoi Mining and Metallurgical Combinat		UZBEKISTAN
Gold		NH Recytech Company		KOREA, REPUBLIC OF
Gold		Nihon Material Co., Ltd.		JAPAN
Gold		Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH		AUSTRIA
Gold		Ohura Precious Metal Industry Co., Ltd.		JAPAN
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)		RUSSIAN FEDERATION

Gold		OJSC Novosibirsk Refinery		RUSSIAN FEDERATION
Gold		PAMP S.A.		SWITZERLAND
Gold		Pease & Curren		UNITED STATES OF AMERICA
Gold		Penglai Penggang Gold Industry Co., Ltd.		CHINA
Gold		Planta Recuperadora de Metales SpA		CHILE
Gold		Prioksky Plant of Non-Ferrous Metals		RUSSIAN FEDERATION
Gold		PT Aneka Tambang (Persero) Tbk		INDONESIA
Gold		PX Precinox S.A.		SWITZERLAND
Gold		QG Refining, LLC		UNITED STATES OF AMERICA
Gold		Rand Refinery (Pty) Ltd.		SOUTH AFRICA
Gold		Refinery of Seemine Gold Co., Ltd.		CHINA
Gold		REMONDIS PMR B.V.		NETHERLANDS
Gold		Royal Canadian Mint		CANADA
Gold		SAAMP		FRANCE
Gold		Sabin Metal Corp.		UNITED STATES OF AMERICA
Gold		Safimet S.p.A		ITALY
Gold		SAFINA A.S.		CZECH REPUBLIC
Gold		Sai Refinery		INDIA
Gold		Samduck Precious Metals		KOREA, REPUBLIC OF
Gold		Samwon Metals Corp.		KOREA, REPUBLIC OF
Gold		SAXONIA Edelmetalle GmbH		GERMANY
Gold		SEMPSA Joyeria Plateria S.A.		SPAIN
Gold		Shandong Humon Smelting Co., Ltd.		CHINA

Gold		Shandong Tiancheng Biological Gold Industrial Co., Ltd.		CHINA
Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.		CHINA
Gold		Sichuan Tianze Precious Metals Co., Ltd.		CHINA
Gold		Singway Technology Co., Ltd.		TAIWAN, PROVINCE OF CHINA
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		RUSSIAN FEDERATION
Gold		Solar Applied Materials Technology Corp.		TAIWAN, PROVINCE OF CHINA
Gold		Sovereign Metals		INDIA
Gold		State Research Institute Center for Physical Sciences and Technology		LITHUANIA
Gold		Sudan Gold Refinery		SUDAN
Gold		Sumitomo Metal Mining Co., Ltd.		JAPAN
Gold		SungEel HiMetal Co., Ltd.		KOREA, REPUBLIC OF
Gold		T.C.A S.p.A		ITALY
Gold		Tanaka Kikinzoku Kogyo K.K.		JAPAN
Gold		The Refinery of Shandong Gold Mining Co., Ltd.		CHINA
Gold		Tokuriki Honten Co., Ltd.		JAPAN
Gold		Tongling Nonferrous Metals Group Co., Ltd.		CHINA
Gold		Tony Goetz NV		BELGIUM
Gold		TOO Tau-Ken-Altyn		KAZAKHSTAN
Gold		Torecom		KOREA, REPUBLIC OF
Gold		Umicore Brasil Ltda.		BRAZIL
Gold		Umicore Precious Metals Thailand		THAILAND
Gold		Umicore S.A. Business Unit Precious Metals Refining		BELGIUM
Gold		United Precious Metal Refining, Inc.		UNITED STATES OF AMERICA
Gold		Valcambi S.A.		SWITZERLAND
Gold		Western Australian Mint (T/a The Perth Mint)		AUSTRALIA
Gold		WIELAND Edelmetalle GmbH		GERMANY
Gold		Yamakin Co., Ltd.		JAPAN
Gold		Yokohama Metal Co., Ltd.		JAPAN
Gold		Yunnan Copper Industry Co., Ltd.		CHINA

Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		CHINA
Tantalum		Asaka Riken Co., Ltd.		JAPAN
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		CHINA
Tantalum		CP Metals Inc.		UNITED STATES OF AMERICA
Tantalum		D Block Metals, LLC		UNITED STATES OF AMERICA
Tantalum		Exotech Inc.		UNITED STATES OF AMERICA
Tantalum		F&X Electro-Materials Ltd.		CHINA
Tantalum		FIR Metals & Resource Ltd.		CHINA
Tantalum		Global Advanced Metals Aizu		JAPAN
Tantalum		Global Advanced Metals Boyertown		UNITED STATES OF AMERICA
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		CHINA

Tantalum		H.C. Starck Co., Ltd.		THAILAND
Tantalum		H.C. Starck Hermsdorf GmbH		GERMANY
Tantalum		H.C. Starck Inc.		UNITED STATES OF AMERICA
Tantalum		H.C. Starck Ltd.		JAPAN
Tantalum		H.C. Starck Smelting GmbH & Co. KG		GERMANY
Tantalum		H.C. Starck Tantalum and Niobium GmbH		GERMANY
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		CHINA
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		CHINA
Tantalum		Jiangxi Tuohong New Raw Material		CHINA
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		CHINA
Tantalum		Jiujiang Tanbre Co., Ltd.		CHINA

Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		CHINA
Tantalum		KEMET Blue Metals		MEXICO
Tantalum		LSM Brasil S.A.		BRAZIL
Tantalum		Metallurgical Products India Pvt., Ltd.		INDIA
Tantalum		Mineracao Taboca S.A.		BRAZIL
Tantalum		Mitsui Mining and Smelting Co., Ltd.		JAPAN
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		CHINA
Tantalum		NPM Silmet AS		ESTONIA
Tantalum		PRG Dooel		NORTH MACEDONIA, REPUBLIC OF
Tantalum		QuantumClean		UNITED STATES OF AMERICA
Tantalum		Resind Industria e Comercio Ltda.		BRAZIL

Tantalum		Solikamsk Magnesium Works OAO		RUSSIAN FEDERATION
Tantalum		Taki Chemical Co., Ltd.		JAPAN
Tantalum		Telex Metals		UNITED STATES OF AMERICA
Tantalum		Ulba Metallurgical Plant JSC		KAZAKHSTAN
Tantalum		XinXing HaoRong Electronic Material Co., Ltd.		CHINA
Tantalum		Yanling Jincheng Tantalum & Niobium Co., Ltd.		CHINA
Tin		Alpha		UNITED STATES OF AMERICA
Tin		An Vinh Joint Stock Mineral Processing Company		VIET NAM
Tin		Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.		CHINA
Tin		Chifeng Dajingzi Tin Industry Co., Ltd.		CHINA
Tin		China Tin Group Co., Ltd.		CHINA
Tin		Dongguan CiEXPO Environmental Engineering Co., Ltd.		CHINA
Tin		Dowa		JAPAN
Tin		Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company		VIET NAM

Tin		EM Vinto		BOLIVIA (PLURINATIONAL STATE OF)
Tin		Estanho de Rondonia S.A.		BRAZIL
Tin		Fenix Metals		POLAND
Tin		Gejiu City Fuxiang Industry and Trade Co., Ltd.		CHINA
Tin		Gejiu Kai Meng Industry and Trade LLC		CHINA
Tin		Gejiu Non-Ferrous Metal Processing Co., Ltd.		CHINA
Tin		Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.		CHINA
Tin		Gejiu Zili Mining And Metallurgy Co., Ltd.		CHINA
Tin		Guangdong Hanhe Non-Ferrous Metal Co., Ltd.		CHINA
Tin		Guanyang Guida Nonferrous Metal Smelting Plant		CHINA
Tin		HuiChang Hill Tin Industry Co., Ltd.		CHINA
Tin		Huichang Jinshunda Tin Co., Ltd.		CHINA
Tin		Jiangxi New Nanshan Technology Ltd.		CHINA
Tin		Luna Smelter, Ltd.		RWANDA
Tin		Ma’anshan Weitai Tin Co., Ltd.		CHINA
Tin		Magnu’s Minerais Metais e Ligas Ltda.		BRAZIL
Tin		Malaysia Smelting Corporation (MSC)		MALAYSIA
Tin		Melt Metais e Ligas S.A.		BRAZIL

Tin		Metallic Resources, Inc.		UNITED STATES OF AMERICA
Tin		Metallo Belgium N.V.		BELGIUM
Tin		Metallo Spain S.L.U.		SPAIN
Tin		Mineracao Taboca S.A.		BRAZIL
Tin		Minsur		PERU
Tin		Mitsubishi Materials Corporation		JAPAN
Tin		Modeltech Sdn Bhd		MALAYSIA
Tin		Nghe Tinh Non-Ferrous Metals Joint Stock Company		VIET NAM
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		THAILAND
Tin		O.M. Manufacturing Philippines, Inc.		PHILIPPINES
Tin		Operaciones Metalurgicas S.A.		BOLIVIA (PLURINATIONAL STATE OF)
Tin		Pongpipat Company Limited		MYANMAR
Tin		Precious Minerals and Smelting Limited		INDIA
Tin		PT Artha Cipta Langgeng		INDONESIA
Tin		PT ATD Makmur Mandiri Jaya		INDONESIA
Tin		PT Menara Cipta Mulia		INDONESIA

Tin		PT Mitra Stania Prima		INDONESIA
Tin		PT Refined Bangka Tin		INDONESIA
Tin		PT Timah Tbk Kundur		INDONESIA
Tin		PT Timah Tbk Mentok		INDONESIA
Tin		Resind Industria e Comercio Ltda.		BRAZIL
Tin		Rui Da Hung		TAIWAN, PROVINCE OF CHINA
Tin		Soft Metais Ltda.		BRAZIL
Tin		Super Ligas		BRAZIL
Tin		Thai Nguyen Mining and Metallurgy Co., Ltd.		VIET NAM
Tin		Thaisarco		THAILAND
Tin		Tin Technology & Refining		UNITED STATES OF AMERICA
Tin		Tuyen Quang Non-Ferrous Metals Joint Stock Company		VIET NAM
Tin		White Solder Metalurgia e Mineracao Ltda.		BRAZIL
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		CHINA
Tin		Yunnan Tin Company Limited		CHINA
Tin		Yunnan Yunfan Non-ferrous Metals Co., Ltd.		CHINA
Tungsten		A.L.M.T. Corp.		JAPAN
Tungsten		ACL Metais Eireli		BRAZIL
Tungsten		Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.		BRAZIL

Tungsten		Asia Tungsten Products Vietnam Ltd.		VIET NAM
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		CHINA
Tungsten		China Molybdenum Co., Ltd.		CHINA
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		CHINA
Tungsten		CNMC (Guangxi) PGMA Co., Ltd.		CHINA
Tungsten		CP Metals Inc.		UNITED STATES OF AMERICA
Tungsten		Fujian Ganmin RareMetal Co., Ltd.		CHINA
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		CHINA
Tungsten		Ganzhou Haichuang Tungsten Co., Ltd.		CHINA
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		CHINA
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		CHINA
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		CHINA
Tungsten		Global Tungsten & Powders Corp.		UNITED STATES OF AMERICA

Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		CHINA
Tungsten		H.C. Starck Smelting GmbH & Co. KG		GERMANY
Tungsten		H.C. Starck Tungsten GmbH		GERMANY
Tungsten		Hunan Chenzhou Mining Co., Ltd.		CHINA
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		CHINA
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		CHINA
Tungsten		Hunan Litian Tungsten Industry Co., Ltd.		CHINA
Tungsten		Hydrometallurg, JSC		RUSSIAN FEDERATION
Tungsten		Japan New Metals Co., Ltd.		JAPAN
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		CHINA

Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		CHINA
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		CHINA
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		CHINA
Tungsten		Jiangxi Xianglu Tungsten Co., Ltd.		CHINA
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		CHINA
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		CHINA
Tungsten		JSC “Kirovgrad Hard Alloys Plant”		RUSSIAN FEDERATION
Tungsten		Kennametal Fallon		UNITED STATES OF AMERICA
Tungsten		Kennametal Huntsville		UNITED STATES OF AMERICA
Tungsten		KGETS Co., Ltd.		KOREA, REPUBLIC OF
Tungsten		Lianyou Metals Co., Ltd.		TAIWAN, PROVINCE OF CHINA
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		CHINA
Tungsten		Masan Tungsten Chemical LLC (MTC)		VIET NAM
Tungsten		Moliren Ltd.		RUSSIAN FEDERATION
Tungsten		Niagara Refining LLC		UNITED STATES OF AMERICA
Tungsten		Philippine Chuangxin Industrial Co., Inc.		PHILIPPINES
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		VIET NAM
Tungsten		Unecha Refractory metals plant		RUSSIAN FEDERATION

Tungsten		Wolfram Bergbau und Hutten AG		AUSTRIA
Tungsten		Woltech Korea Co., Ltd.		KOREA, REPUBLIC OF
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		CHINA
Tungsten		Xiamen Tungsten Co., Ltd.		CHINA
Tungsten		Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.		CHINA
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		CHINA

Appendix B - countries of origin

• Includes: list of countries

Based on the RMI RCOI Data and the smelters or refiners identified by our Direct Suppliers (listed in the tables below), the countries of origin of the conflict minerals in our products may include:

• Level 1 countries – countries of origin that are not identified as conflict regions or plausible countries for the export, smuggling or transit of conflict minerals, namely, Argentina, Australia, Austria, Belgium, Brazil, Canada, Chile, China, Columbia, Cote D’Ivoire, Czech Republic, Djibouti, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungry, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Lao People’s Democratic Republic, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Plurinational State of Bolivia, Portugal, Republic of Korea, Russian Federation, Sierra Leone, Singapore, Slovakia, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom of Great Britain, United States of America, Vietnam and Zimbabwe.

• Level 2 countries – countries of origin that are known or plausible countries for the export, smuggling or transit of conflict minerals, namely, Kenya, Mozambique and South Africa.

• Level 3 countries – countries of origin that are the DRC or its adjoining countries, namely, the DRC, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.

• Recycled/Scrap – smelters or refiners that only process recycled or scrap materials.