Audiocodes Ltd. — Environmental & Social Information 2025

May 21, 2025

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

FORM SD SPECIALIZED DISCLOSURE REPORT

AudioCodes Ltd.

(Exact name of registrant as specified in its charter)

ISRAEL 0-30070

(State or other jurisdiction of (Commission file number) incorporation or organization)

6 Ofra Haza Street, Or Yehuda, Israel

(Address of principal executive offices)

Ofer Nimtsovich, 972-3-9764000

(Name and telephone number, including area code, of the person to contact in connection with this report)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2024.

Section 1 – Conflict Minerals Disclosure

This Specialized Disclosure Report on Form SD (this "Form SD") of AudioCodes Ltd. ("AudioCodes," "we," "us," or "our") for the year ended December 31, 2024 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.

Item 1.01 Conflict Minerals Disclosure and Report

AudioCodes evaluated its current product lines and determined that certain products we manufacture or contract to manufacture contain tin, tungsten, tantalum and/or gold, which are defined as "conflict minerals" by the United States Securities and Exchange Commission, that are necessary to the functionality or production of our products. Accordingly, AudioCodes is filing this disclosure along with a Conflict Minerals Report to disclose the measures we have taken to determine the origin of the conflict minerals used in our products.

Conflict Minerals Disclosure

We undertook due diligence measures, including surveying our direct suppliers through an industry-standard survey template for conflict minerals, to try to determine the sources of these minerals, which we purchase through a complex supply chain. Currently, we do not have sufficient information from all our suppliers or other sources to determine the country of origin of the conflict minerals used in our products or identify the facilities used to process those conflict minerals.

A copy of our Conflict Minerals Report is filed as Exhibit 1.01 hereto. Our Conflict Minerals Report, as well as our Conflict Minerals Policy, are publicly available on our website at https://www.audiocodes.com/corporate/audiocodes-going-sustainable under the heading "Conflict Minerals". Except as expressly provided herein, the information on, or that can be accessed through, our website is not part of (nor is it included in) this Form SD.

Item 1.02 Exhibit

See Item 2.01 below.

Section 2 – Exhibits

Item 2.01. Exhibits

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.

Signatures

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

AUDIOCODES LTD.

By: /s/ Ofer Nimtsovich Name: Ofer Nimtsovich Title: Chief Operating Officer (COO)

May 21, 2025

Exhibit 1.01

AudioCodes Ltd. Conflict Minerals Report For The Year Ended December 31, 2024

1. Introduction

This is the Conflict Minerals Report (this "Report") for AudioCodes Ltd. (herein referred to as "AudioCodes," the "Company," "we," "us" or "our") filed with the United States Securities and Exchange Commission (the "SEC") pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule"), for the reporting period from January 1, 2024 to December 31, 2024. The Rule was adopted by the SEC to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, as amended. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. "Conflict minerals" are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold for the purpose of this assessment.

If a registrant can establish that the conflict minerals in its products originated from sources other than the Democratic Republic of the Congo (the "DRC") or an adjoining country (collectively, the "Covered Countries"), or from recycled and scrap sources, the registrant must submit a specialized disclosure report under Form SD that describes the steps that the registrant took to determine the origin of the conflict minerals in its products.

If a registrant has reason to believe that any of the conflict minerals in its supply chain may have originated in a Covered Country, or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals' source and chain of custody, and the registrant must annually submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.

This Report is not audited by an independent private sector auditor in reliance on recent SEC guidance to the effect that the requirement of such an audit has been stayed except if the registrant elects to describe its products as "DRC conflict-free" in its Conflicts Minerals Report.

2. Company Overview

This Report has been prepared by AudioCodes. The information includes the activities of all of our majority-owned subsidiaries that are required to be consolidated.

AudioCodes designs, develops and sells advanced Voice over-IP (VoIP) and converged VoIP and data networking solutions, products and applications that facilitate secured, resilient and highquality Unified Communications (UC) and Contact Center (CC) services whether deployed onpremises or delivered from the cloud. Providing IP Phones, Customer Premise Equipment (CPE), and cloud-based platforms and applications, our solutions and products are geared to meet the growing needs of enterprises and service providers realigning their operations towards the transition to All-IP networks and hosted business services. AudioCodes is a VoIP technology market leader focused on converged VoIP and data communications offering technology, products and solutions for Enterprise Unified Communications, contact centers, service provider business services, mobile VoIP and Cloud virtualized Data Centers. Our products are deployed globally in enterprise, service provider cloud networks. AudioCodes' products include IP phones, session border controllers (SBC), media gateways, Multi-Service Business Routers (MSBRs), residential gateways, media servers, mobile communications solutions, value added applications, life cycle management solutions and professional services. AudioCodes high definition (HD) VoIP technologies and products provide enhanced intelligibility and a better end user experience in emerging voice communications services.

3. Products Overview

Our principal hardware product lines are essentially classified into the following categories: session border controllers, media gateways, multi-service business routers, IP phones, cloud connector appliances, survivable branch appliances, call recorders, fax servers and SOHO routers.

4. Supply Chain Overview

Because our supply chain is complex, AudioCodes relies upon our suppliers to provide information with respect to 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. Our suppliers are expected to provide conflict minerals sourcing information to us pursuant to our Conflict Minerals Policy.

We have performed a comprehensive analysis of the components used in our products, and the role that suppliers play throughout our manufacturing and product delivery processes. We defined the scope of our conflict minerals due diligence by identifying and contacting our current suppliers that provide components or engage in manufacturing activities that are likely to contain conflict minerals. We adopted the standard Conflict Mineral Reporting Templates ("CMRT") established by the Conflict Free Sourcing Initiative (the "CFSI") and sent our conflict minerals due diligence communication survey to these suppliers.

With respect to the Organisation for Economic Cooperation and Development ("OECD") requirement to strengthen engagement with suppliers, we have engaged a third-party data collection vendor to conduct, collect and archive suppliers' responses. Feedback from this engagement has allowed us to render the conclusions and statements in this Report.

5. Reasonable Country of Origin Inquiry ("RCOI") and RCOI Conclusion

• 5.1 We conducted an analysis of our products and found that "conflict minerals" (as defined under the Rule), including tin, tantalum, tungsten and gold, can be found in our products and are necessary to the functionality or production of those products. Therefore, we are subject to the reporting obligations of the Rule.
• 5.2 A list of all the suppliers and manufacturers that AudioCodes contracts with during the period covered by this Report to purchase all the items used in constructing its products was prepared by our Purchasing Department. The list was then reviewed and non-relevant suppliers and manufacturers of items which definitively do not contain tin, tantalum, tungsten or gold were deleted. The final list was evaluated by our Purchasing Director and Quality Assurance & Environmental Management Manager.
• 5.3 Due to the breadth and complexity of AudioCodes' products and supply chain, it will take time for many of our suppliers to verify the origin of all conflict minerals. Using our supply chain due diligence processes and efforts, we hope to further develop transparency into our supply chain.
• 5.4 Steps conducted this year include:
  • a. Performing internal applicability assessments of products and suppliers to determine which products and/or suppliers actually contain (or may contain) necessary conflict minerals.
  • b. Supplier engagement:
    • · Solicitation of survey responses from specified suppliers;
    • · Assessment of suppliers' responses, including identifying inconsistent, incomplete or inaccurate responses;
• · Engaging our Purchasing Department to directly contact and make followup inquiries of non-responsive suppliers; and
• · As part of our validation process, circulation of training materials to suppliers, including an overview of the law and instructions on how to complete the CMRT, if relevant.
• c. As part of our effort to identify smelters and refiners, suppliers were requested to complete CMRTs template of version 6.01 or above.

5.5 Currently, we do not have sufficient information from our suppliers to determine the country of origin of all the conflict minerals used in our products or the facilities used to process those conflict minerals. Therefore, we cannot exclude the possibility that some of these conflict minerals may have originated in the DRC or an adjoining country, and are not from recycled or scrap sources. Based on this result, AudioCodes conducted due diligence activities on the conflict minerals' source and chain of custody and have described these activities in this Report.

6. Due Diligence Design

6.1 Our due diligence processes and efforts have been developed in conjunction with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Guidance") and the related supplements for gold, tin, tantalum and tungsten.

7. Due Diligence Performed

7.1 Establish Strong Company Management Systems

7.1.1 Conflict Minerals Policy

AudioCodes is committed to working collaboratively with our global supply chain to ensure compliance with the SEC's conflict minerals rules (including the Rule). Our conflict minerals policy is publicly available on our website at https://www.audiocodes.com/corporate/audiocodesgoing-sustainable under the heading "Conflict Minerals Act". Except as expressly provided herein, the information on, or that can be accessed through, our website is not part of (nor is it included in) this Report.

7.1.2 Internal Team

AudioCodes has established a task force with representatives from our Legal, Finance, Purchasing and Quality departments to implement our conflict minerals compliance policy. Senior management is briefed about the results of our due diligence efforts on a regular basis.

7.1.3 Control Systems

AudioCodes has established our due diligence compliance process and set forth documentation and record maintenance mechanisms to ensure the retention of relevant documentation in a structured electronic database. Database content enables real-time identification of all countries of origin of the minerals as well as the status of smelters and refiners. Since our databases are regularly backed up, this data retention ensures availability with no significant time limitation.

Company-level CMRT are amended by AudioCodes on a monthly basis, as our sub-contractor collects new and/or corrected suppliers' reports. AudioCodes makes its latest company-level CMRT available to its customers upon request.

7.1.4 Supplier Engagement

AudioCodes' Requirements from AudioCodes' Suppliers Process Specification (P-08-03E) (the "Process Specification") includes a paragraph detailing our mandatory requirement to comply with the Rule and to strictly follow the framework established by the OECD. The Process Specification is referenced in each purchase order issued to our suppliers. Except as expressly provided herein, the information on, or that can be accessed through, our website is not part of (nor is it included in) this Report.

7.1.5 Grievance Mechanism

Grievance mechanism & reporting are defined in our Conflict Minerals Policy.

7.2 Identify and Assess Risk in the Supply Chain

• 7.2.1 As part of our risk-based approach, AudioCodes identified the suppliers from which it made purchases over a specified amount during the year ended 2024. While trying to move towards the goal of being a conflict minerals-free company, we assessed two primary risks in our supply chain: (1) the risk of not receiving prompt and accurate information from a particular supplier; and (2) the risk of not being able to readily replace a particular supplier. The result was the segmentation of our suppliers into three categories/levels of risks— "high", "medium" and "low"—enabling the Company to focus and tailor its risk mitigation efforts according to the supplier's level of risk.
• 7.2.2 Our Purchasing Department was engaged to urge and make follow-up inquiries of reluctant suppliers and to focus our escalation efforts, with a priority on the "high" risk suppliers.
• 7.2.3 To the best of our knowledge and efforts, we have identified most of the smelters and refiners in our supply chain.

7.3 Design and Implement Strategy to Respond to Risks

• 7.3.1 Suppliers are requested to supply their conflict minerals compliance declarations using the CMRT template. Such declarations are reviewed by AudioCodes (or its assigned subcontractor) and verified for completeness and inconsistencies.
• 7.3.2 Any declaration determined to be inconsistent or missing data is returned to the supplier to be corrected and completed.
• 7.3.3 We also track smelters and refiners that have not received a conflict-free designation based on the CFSI/CFSP or other independent third-party validation program, and compare smelters and refiners identified by the supply chain survey against the list of facilities that have received a "conflict free" designation.
• 7.3.4 Red flags analysis on the topics listed below were defined to better identify suspicious behavior and activities:
  • a. Data completion;
  • b. Locations of mineral origin; and
  • c. Existence of Company Policy.
• 7.3.5 Our escalation process was documented and implemented, which defines how to address non-responsive and problematic suppliers. The escalation process defines the conditions under which our Purchasing Department should ultimately consider suspending or discontinuing engagement with such suppliers.
• 7.3.6 Our VP, Operations, was informed of (i) the risk analysis efforts and results and (ii) the actions taken in response to such analysis and results.

7.4 Carrying Out of Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

• 7.4.1 AudioCodes does not have a direct relationship with smelters and refiners of conflict minerals, nor do we perform direct audits of these entities that provide our supply chain with conflict minerals. However, we do rely upon the industry efforts and tools (for example, the CFSI CMRT) in our evaluations.
• 7.5 Report Annually on Supply Chain Due Diligence

7.5.1 AudioCodes' CMRT is amended on a monthly basis and is available to all requestors. The Company's annual Conflict Minerals Report is made available on AudioCodes' website at https://www.audiocodes.com/corporate/audiocodes-going-sustainable under the heading "Conflict Minerals Act" and filed with the SEC on Form SD. Except as expressly provided herein, the information on, or that can be accessed through, our website is not part of (nor is it included in) this Report.

8. Results of Assessments

8.1 Survey Responses

• 8.1.1 Because of our size, the breadth and complexity of our products, and constant changes to our supply chain in the ordinary course of business, it is difficult to identify entities downstream from our direct suppliers. We therefore rely on our direct suppliers to provide us with information about the source of conflict minerals contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers.
• 8.1.2 Despite receiving responses from suppliers listing the smelter's or refiner's names in their supply chain, a few suppliers were unable to accurately report which specific smelters were part of the supply chain of the components that were sold to AudioCodes in the year ended 2024. Therefore, we are not able to determine the facilities that processed the conflict minerals in such products.

8.1.3 We received responses from 100% of the suppliers we surveyed. We reviewed the responses against criteria we developed to determine which responses necessitated further engagement with such suppliers. These criteria included untimely or incomplete responses, as well as inconsistencies within the data reported in the template. We are collaborating directly with these suppliers to have them provide updated responses.

Declaration Scopes of Delivered Consolidated Manufacturers
Reported at company level	61%
Reported user defined	16%
Reported product list/product	23%

8.1.4 Most CMRTs were reported at the company level (see the table immediately below):

8.1.5 As of the date hereof, the responses received from our suppliers can be further categorized as described in the table immediately below. CMRTs with major issues are CMRTs with (i) significant incompleteness, (ii) inaccuracies or (iii) contradictory information submitted. For example, tantalum, tin, gold or tungsten were declared used, but no smelters were entered for these metals.

Consolidated Manufacturers Sub-Collection Status
MFRs delivered satisfactory CMRT	100%
MFRs delivered CMRT with major issues	0%
MFRs whose CMRT was escalated*	0%
MFRs still in process	0%

* Manufacturer ("MFR") with at least one or multiple escalations (but no major issues noted). Escalated by the subcontractor to AudioCodes to supply enhanced/corrected contact information, to contact the MFR directly or otherwise, due to the MFR's poor responsiveness.

8.1.6 The smelter analysis of the responsive MFR is set forth below. The list of smelters is set forth in Appendix A attached hereto. The list of the countries of origin of mines is set forth in Appendix B attached hereto.

Smelters Analysis
With certification
CFSP/RJC/LBMA/DMCC (1) Certified smelters -	59%
CFSP/RJC/LBMA/DMCC (1) Non-certified smelters -	41%
Legitimacy of smelters (out of the total number of smelters analyzed)
Number of alleged smelters FSI/RJC/LBMA/DMCC/DOC/APPLE/INTEL/GS (1)	88%
Unknown smelters	12%

(1) Initials of credible sources for conflict minerals information (organizations or company names).

• 8.1.7 Based on the information obtained through the due diligence process, AudioCodes does not have sufficient information as of the date hereof to determine the country of origin of all the conflict minerals contained in our products.
• 8.1.8 The majority of the responses we received provided data at a company or divisional level or, as described above, were unable to specify the smelters or refiners used for components supplied to AudioCodes. We are therefore unable to determine whether any of the conflict minerals reported by the suppliers were contained in components or parts supplied to us, or to validate that any of these smelters or refiners are actually within our supply chain.
• 8.1.9 We do not gather information from our suppliers on a continuous, real-time basis.
• 8.1.10 The Company can only provide reasonable, but not absolute, assurances regarding the source and chain of custody of the necessary conflict minerals, since the information is obtained from direct and secondary suppliers and independent third-party audit programs.

8.2 Efforts to Determine Country of Origin of Mine or Conflict Minerals

8.2.1 Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. By adopting a methodology based on the OECD Guidance and the CFSI template, we have determined that the information we gathered from the smelters and refiners in our supply chain represents the most reasonable known mine of origin information available to us.

9. Continuous Improvement Efforts to Mitigate Risks

• 9.1 AudioCodes will continue working with its global supply chain to ensure responsible sourcing and compliance with international regulations.
• 9.2 AudioCodes will strengthen communications with suppliers in order to improve the number of suppliers that respond to the company's supply chain surveys.

9.3 AudioCodes will analyze its database and sort out all non-active parts, to focus on an accurate suppliers' database.

10. Cautionary Statement Concerning Forward-Looking Statements

This Report contains "forward-looking statements" within the meaning of U.S. federal securities laws. These forward-looking statements can generally be identified as such because the context of the statement will include words such as "may," "will," "intends," "plans," "believes," "anticipates," "expects," "estimates," "predicts," "potential," "continue," or "opportunity," the negative of these words or words of similar import. Examples of forward-looking statements include, but are not limited to, statements relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. Forward-looking statements are subject to risks, uncertainties and other factors that could cause actual results to differ substantially and materially from those stated in such statements, including, but not limited to, the risks described in our Form 20-F and other filings we make with the SEC from time to time. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by U.S. federal securities laws. AudioCodes may not update these forward-looking statements, even if its situation changes in the future. AudioCodes' management cautions against putting undue reliance on forward-looking statements or projecting any future results based on such statements or present or prior earnings levels.

Appendix A: Smelters List

1. GOLD

Met al	Smelter Name	Country
Gold	8853 S.p.A.	ITALY
Gold	ABC Refinery Pty Ltd.	AUSTRALIA
Gold	Abington Reldan Metals, LLC	UNITED STATES OF AMERICA
Gold	Advanced Chemical Company	UNITED STATES OF AMERICA
Gold	Agosi AG	GERMANY
Gold	Aida Chemical Industries Co., Ltd.	JAPAN
Gold	Al Etihad Gold Refinery DMCC	UNITED ARAB EMIRATES
Gold	Albino Mountinho Lda.	PORTUGAL
Gold	Alexy Metals	UNITED STATES OF AMERICA
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	Attero Recycling Pvt Ltd	INDIA
Gold	AU Traders and Refiners	SOUTH AFRICA

Met al	Smelter Name	Country
Gold	Augmont Enterprises Private Limited	INDIA
Gold	Aurubis AG	GERMANY
Gold	Bangalore Refinery	INDIA
Gold	Bangko Sentral ng Pilipinas (Central Bank of the Philippines)	PHILIPPINES
Gold	Boliden Ronnskar	SWEDEN
Gold	C. Hafner GmbH + Co. KG	GERMANY
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	Coimpa Industrial LTDA	BRAZIL
Gold	Daye Non-Ferrous Metals Mining Ltd.	CHINA
Gold	Degussa Sonne / Mond Goldhandel GmbH	GERMANY

Gol d	Dijllah Gold Refinery FZC	UNITED ARAB EMIRATES
Gol d	Dongwu Gold Group	CHINA
Gol d	Dowa	JAPAN
Gol d	DSC (Do Sung Corporation)	KOREA, REPUBLIC OF
Gol d	Eco-System Recycling Co., Ltd. East Plant	JAPAN
Gol d	Eco-System Recycling Co., Ltd. North Plant	JAPAN
Gol d	Eco-System Recycling Co., Ltd. West Plant	JAPAN
Gol d	Elite Industech Co., Ltd.	TAIWAN, PROVINCE OF CHINA
Gol d	Emerald Jewel Industry India Limited (Unit 1)	INDIA
Gol d	Emerald Jewel Industry India Limited (Unit 2)	INDIA
Gol d	Emerald Jewel Industry India Limited (Unit 3)	INDIA
Gol d	Emerald Jewel Industry India Limited (Unit 4)	INDIA
Gol d	Emirates Gold DMCC	UNITED ARAB EMIRATES
Gol d	Fidelity Printers and Refiners Ltd.	ZIMBABWE
Gol d	Fujairah Gold FZC	UNITED ARAB EMIRATES

Gol d	GG Refinery Ltd.	TANZANIA, UNITED REPUBLIC OF
Gol d	GGC Gujrat Gold Centre Pvt. Ltd.	INDIA
Gol d	Gold by Gold Colombia	COLOMBIA
Gol d	Gold Coast Refinery	GHANA
Gol d	Great Wall Precious Metals Co., Ltd. of CBPM	CHINA
Gol d	Guangdong Jinding Gold Limited	CHINA
Gol d	Guoda Safina High-Tech Environmental Refinery Co., Ltd.	CHINA
Gol d	Hangzhou Fuchunjiang Smelting Co., Ltd.	CHINA
Gol d	Heimerle + Meule GmbH	GERMANY
Gol d	Heraeus Germany GmbH Co. KG	GERMANY
Gol d	Heraeus Metals Hong Kong Ltd.	CHINA
Gol d	Hunan Chenzhou Mining Co., Ltd.	CHINA
Gol d	Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.	CHINA
Gol d	HwaSeong CJ Co., Ltd.	KOREA, REPUBLIC OF
Gol d	Impala Refineries – Base Metals Refinery (BMR)	SOUTH AFRICA
Gol d	Impala Refineries – Platinum Metals Refinery (PMR)	SOUTH AFRICA
Gol d	Impala Rustenburg	SOUTH AFRICA

Gol d	Inca One (Chala One Plant)	PERU
Gol d	Inca One (Koricancha Plant)	PERU
Gol d	Industrial Refining Company	BELGIUM
Gol d	Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.	CHINA
Gol d	International Precious Metal Refiners	UNITED ARAB EMIRATES
Gol d	Ishifuku Metal Industry Co., Ltd.	JAPAN
Gol d	Istanbul Gold Refinery	TURKEY
Gol d	Italpreziosi	ITALY
Gol d	JALAN & Company	INDIA

Gold	Japan Mint	JAPAN
Gold	Jiangxi Copper Co., Ltd.	CHINA
Gold	JX Nippon Mining & Metals Co., Ltd.	JAPAN
Gold	K.A. Rasmussen	NORWAY
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	Kundan Care Products Ltd.	INDIA
Gold	Kyrgyzaltyn JSC	KYRGYZSTAN
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 MnM 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	MD Overseas	INDIA
Gold	Metal Concentrators SA (Pty) Ltd.	SOUTH AFRICA
Gold	Metallix Refining Inc.	UNITED STATES OF AMERICA
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	MKS PAMP SA	SWITZERLAND
Gold	MMTC-PAMP India Pvt., Ltd.	INDIA
Gold	Modeltech Sdn Bhd	MALAYSIA
Gold	Morris and Watson	NEW ZEALAND
Gold	Nadir Metal Rafineri San. Ve Tic. A.S.	TURKEY
Gold	Navoi Mining and Metallurgical Combinat	UZBEKISTAN
Gold	NH Recytech Company	KOREA, REPUBLIC OF

Gol d	Nihon Material Co., Ltd.	JAPAN
Gol d	Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH	AUSTRIA
Gol d	Ohura Precious Metal Industry Co., Ltd.	JAPAN
Gol d	Pease & Curren	UNITED STATES OF AMERICA
Gol d	Penglai Penggang Gold Industry Co., Ltd.	CHINA
Gol d	Planta Recuperadora de Metales SpA	CHILE
Gol d	PT Aneka Tambang (Persero) Tbk	INDONESIA
Gol d	PX Precinox S.A.	SWITZERLAND
Gol d	QG Refining, LLC	UNITED STATES OF AMERICA
Gol d	Rand Refinery (Pty) Ltd.	SOUTH AFRICA
Gol d	Refinery of Seemine Gold Co., Ltd.	CHINA
Gol d	REMONDIS PMR B.V.	NETHERLANDS
Gol d	Royal Canadian Mint	CANADA
Gol d	SAAMP	FRANCE
Gol d	Sabin Metal Corp.	UNITED STATES OF AMERICA

Gol d	Safimet S.p.A	ITALY
Gol d	Safina a.s.	CZECHIA
Gol d	Sai Refinery	INDIA
Gol d	Sam Precious Metals	UNITED ARAB EMIRATES
Gol d	Samduck Precious Metals	KOREA, REPUBLIC OF
Gol d	SAMWON METALS Corp.	KOREA, REPUBLIC OF
Gol d	SEMPSA Joyeria Plateria S.A.	SPAIN
Gol d	Shandong gold smelting Co., Ltd.	CHINA
Gol d	Shandong Humon Smelting Co., Ltd.	CHINA
Gol d	Shandong Tiancheng Biological Gold Industrial Co., Ltd.	CHINA
Gol d	Shandong Zhaojin Gold & Silver Refinery Co., Ltd.	CHINA
Gol d	Shenzhen CuiLu Gold Co., Ltd.	CHINA
Gol d	SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD.	CHINA
Gol d	Shenzhen Zhonghenglong Real Industry Co., Ltd.	CHINA
Gol d	Shirpur Gold Refinery Ltd.	INDIA
Gol d	Sichuan Tianze Precious Metals Co., Ltd.	CHINA
Gol d	Singway Technology Co., Ltd.	TAIWAN, PROVINCE OF CHINA

Gol d	Solar Applied Materials Technology Corp.	TAIWAN, PROVINCE OF CHINA
Gol d	Sovereign Metals	INDIA
Gol d	State Research Institute Center for Physical Sciences and Technology	LITHUANIA
Gol d	Sudan Gold Refinery	SUDAN
Gol d	Sumitomo Metal Mining Co., Ltd.	JAPAN
Gol d	SungEel HiMetal Co., Ltd.	KOREA, REPUBLIC OF
Gol d	Super Dragon Technology Co., Ltd.	TAIWAN, PROVINCE OF CHINA
Gol d	T.C.A S.p.A	ITALY

Gol d	Tanaka Kikinzoku Kogyo K.K.	JAPAN
Gol d	Tokuriki Honten Co., Ltd.	JAPAN
Gol d	Tongling Nonferrous Metals Group Co., Ltd.	CHINA
Gol d	TOO Tau-Ken-Altyn	KAZAKHSTAN
Gol d	Torecom	KOREA, REPUBLIC OF
Gol d	Umicore Precious Metals Thailand	THAILAND
Gol d	Umicore S.A. Business Unit Precious Metals Refining	BELGIUM
Gol d	United Precious Metal Refining, Inc.	UNITED STATES OF AMERICA
Gol d	Valcambi S.A.	SWITZERLAND
Gol d	WEEEREFINING	FRANCE
Gol d	Western Australian Mint (T/a The Perth Mint)	AUSTRALIA
Gol d	WIELAND Edelmetalle GmbH	GERMANY
Gol d	Yamakin Co., Ltd.	JAPAN
Gol d	Yokohama Metal Co., Ltd.	JAPAN
Gol d	Yunnan Copper Industry Co., Ltd.	CHINA

Gol	Zhongyuan Gold Smelter of Zhongjin Gold	CHINA
d	Corporation

2. TANTALUM

Metal	Smelter Name	Country
Tantalu m	5D Production OU	ESTONIA
Tantalu m	AMG Brasil	BRAZIL
Tantalu m	D Block Metals, LLC	UNITED STATES OF AMERICA
Tantalu m	F&X Electro-Materials Ltd.	CHINA
Tantalu m	FIR Metals & Resource Ltd.	CHINA
Tantalu m	Global Advanced Metals Aizu	JAPAN
Tantalu m	Global Advanced Metals Boyertown	UNITED STATES OF AMERICA
Tantalu m	Guangdong Rising Rare Metals-EO Materials Ltd.	CHINA
Tantalu m	Hengyang King Xing Lifeng New Materials Co., Ltd.	CHINA
Tantalu m	Jiangxi Dinghai Tantalum & Niobium Co., Ltd.	CHINA
Tantalu m	Jiangxi Tuohong New Raw Material	CHINA
Tantalu m	JiuJiang JinXin Nonferrous Metals Co., Ltd.	CHINA
Tantalu m	Jiujiang Tanbre Co., Ltd.	CHINA
Tantalu m	Jiujiang Zhongao Tantalum & Niobium Co., Ltd.	CHINA

Tantalu m	KEMET de Mexico	MEXICO
Tantalu m	Materion Newton Inc.	UNITED STATES OF AMERICA
Tantalu m	Metallurgical Products India Pvt., Ltd.	INDIA
Tantalu m	Mineracao Taboca S.A.	BRAZIL
Tantalu m	Mitsui Mining and Smelting Co., Ltd.	JAPAN
Tantalu m	Ningxia Orient Tantalum Industry Co., Ltd.	CHINA
Tantalu m	NPM Silmet AS	ESTONIA
Tantalu m	PowerX Ltd.	RWANDA
Tantalu m	QuantumClean	UNITED STATES OF AMERICA
Tantalu m	Resind Industria e Comercio Ltda.	BRAZIL
Tantalu m	RFH Yancheng Jinye New Material Technology Co., Ltd.	CHINA
Tantalu m	Taki Chemical Co., Ltd.	JAPAN
Tantalu m	TANIOBIS Co., Ltd.	THAILAND
Tantalu m	TANIOBIS GmbH	GERMANY
Tantalu m	TANIOBIS Japan Co., Ltd.	JAPAN
Tantalu m	TANIOBIS Smelting GmbH & Co. KG	GERMANY
Tantalu m	Telex Metals	UNITED STATES OF AMERICA

Tantalu m	Ulba Metallurgical Plant JSC	KAZAKHSTAN
Tantalu m	XIMEI RESOURCES (GUANGDONG) LIMITED	CHINA
Tantalu m	XinXing HaoRong Electronic Material Co., Ltd.	CHINA
Tantalu m	Yanling Jincheng Tantalum & Niobium Co., Ltd.	CHINA

3. TIN

Metal	Smelter Name	Country
Tin	Alpha	UNITED STATES OF
		AMERICA
Tin	An Vinh Joint Stock Mineral Processing Company	VIETNAM
Tin	Aurubis Beerse	BELGIUM
Tin	Aurubis Berango	SPAIN
Tin	Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.	CHINA
Tin	Chifeng Dajingzi Tin Industry Co., Ltd.	CHINA
Tin	China Tin Group Co., Ltd.	CHINA
	CRM Fundicao De Metais E Comercio De
Tin	Equipamentos Eletronicos Do Brasil Ltda	BRAZIL
Tin	CRM Synergies	SPAIN
Tin	CV Ayi Jaya	INDONESIA
Tin	CV Venus Inti Perkasa	INDONESIA
	Dongguan CiEXPO Environmental Engineering	CHINA
Tin	Co., Ltd.
Tin	Dowa	JAPAN
Tin	DS Myanmar	MYANMAR
Tin	Electro-Mechanical Facility of the Cao Bang Minerals &	VIETNAM
	Metallurgy Joint Stock Company
	EM Vinto	BOLIVIA
Tin		(PLURINATIONAL
		STATE OF)
Tin	Estanho de Rondonia S.A.	BRAZIL
Tin	Fabrica Auricchio Industria e Comercio Ltda.	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	Global Advanced Metals Greenbushes Pty Ltd.	AUSTRALIA
Tin	Guangdong Hanhe Non-Ferrous Metal Co., Ltd.	CHINA
Tin	HuiChang Hill Tin Industry 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	Malaysia Smelting Corporation Berhad (Port Klang)	MALAYSIA
Tin	Melt Metais e Ligas S.A.	BRAZIL
Tin	Metallic Resources, Inc.	UNITED STATES OF AMERICA
Tin	Mineracao Taboca S.A.	BRAZIL

Tin	Mining Minerals Resources SARL	CONGO, DEMOCRATIC REPUBLIC OF THE
Tin	Minsur	PERU
Tin	Mitsubishi Materials Corporation	JAPAN
Tin	Modeltech Sdn Bhd	MALAYSIA
Tin	Nghe Tinh Non-Ferrous Metals Joint Stock Company	VIETNAM
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 Aries Kencana Sejahtera	INDONESIA
Tin	PT Artha Cipta Langgeng	INDONESIA
Tin	PT ATD Makmur Mandiri Jaya	INDONESIA
Tin	PT Babel Inti Perkasa	INDONESIA
Tin	PT Babel Surya Alam Lestari	INDONESIA
Tin	PT Bangka Prima Tin	INDONESIA
Tin	PT Bangka Serumpun	INDONESIA
Tin	PT Bangka Tin Industry	INDONESIA
Tin	PT Belitung Industri Sejahtera	INDONESIA
Tin	PT Bukit Timah	INDONESIA
Tin	PT Cipta Persada Mulia	INDONESIA
Tin	PT Menara Cipta Mulia	INDONESIA
Tin	PT Mitra Stania Prima	INDONESIA
Tin	PT Mitra Sukses Globalindo	INDONESIA
Tin	PT Panca Mega Persada	INDONESIA
Tin	PT Premium Tin Indonesia	INDONESIA
Tin	PT Prima Timah Utama	INDONESIA

Tin	PT Putera Sarana Shakti (PT PSS)	INDONESIA
Tin	PT Rajawali Rimba Perkasa	INDONESIA
Tin	PT Rajehan Ariq	INDONESIA
Tin	PT REFINED BANGKA TIN	INDONESIA
Tin	PT Sariwiguna Binasentosa	INDONESIA
Tin	PT Stanindo Inti Perkasa	INDONESIA
Tin	PT Sukses Inti Makmur (SIM)	INDONESIA
Tin	PT Timah Nusantara	INDONESIA
Tin	PT Timah Tbk Kundur	INDONESIA
Tin	PT Timah Tbk Mentok	INDONESIA
Tin	PT Tinindo Inter Nusa	INDONESIA
Tin	PT Tirus Putra Mandiri	INDONESIA
Tin	PT Tommy Utama	INDONESIA

Tin	Resind Industria e Comercio Ltda.	BRAZIL
Tin	Rui Da Hung	TAIWAN, PROVINCE OF CHINA
Tin	Super Ligas	BRAZIL
Tin	Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.	JAPAN
Tin	Thaisarco	THAILAND
Tin	Tin Smelting Branch of Yunnan Tin Co., Ltd.	CHINA
Tin	Tin Technology & Refining	UNITED STATES OF AMERICA
Tin	Tuyen Quang Non-Ferrous Metals Joint Stock Company	VIETNAM
Tin	VQB Mineral and Trading Group JSC	VIETNAM
Tin	White Solder Metalurgia e Mineracao Ltda.	BRAZIL
Tin	Woodcross Smelting Company Limited	UGANDA
Tin	Yunnan Chengfeng Non-ferrous Metals Co., Ltd.	CHINA
Tin	Yunnan Yunfan Non-ferrous Metals Co., Ltd.	CHINA

4. TUNGSTEN

Metal	Smelter Name	Country
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.	VIETNAM
Tungsten	China Molybdenum Tungsten Co., Ltd.	CHINA
Tungsten	Chongyi Zhangyuan Tungsten Co., Ltd.	CHINA
Tungsten	CNMC (Guangxi) PGMA Co., Ltd.	CHINA
Tungsten	Cronimet Brasil Ltda	BRAZIL
Tungsten	DONGKUK INDUSTRIES CO., LTD.	KOREA, REPUBLIC OF
Tungsten	Fujian Xinlu Tungsten Co., Ltd.	CHINA
Tungsten	Ganzhou Jiangwu Ferrotungsten Co., Ltd.	CHINA
Tungsten	Ganzhou Seadragon W & Mo Co., Ltd.	CHINA
Tungsten	Global Tungsten & Powders LLC	UNITED STATES OF AMERICA
Tungsten	Guangdong Xianglu Tungsten Co., Ltd.	CHINA
Tungsten	H.C. Starck Tungsten GmbH	GERMANY
Tungsten	HANNAE FOR T Co., Ltd.	KOREA, REPUBLIC OF
Tungsten	Hubei Green Tungsten Co., Ltd.	CHINA
Tungsten	Hunan Chenzhou Mining Co., Ltd.	CHINA
Tungsten	Hunan Jintai New Material Co., Ltd.	CHINA
Tungsten	Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch	CHINA
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

Metal	Smelter Name	Country
Tungsten	Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.	CHINA
Tungsten	Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.	CHINA
Tungsten	Jiangxi Xinsheng Tungsten Industry Co., Ltd.	CHINA
Tungsten	Jiangxi Yaosheng Tungsten Co., Ltd.	CHINA
Tungsten	Kenee Mining Corporation Vietnam	VIETNAM
Tungsten	Kennametal Fallon	UNITED STATES OF AMERICA
Tungsten	Kennametal Huntsville	UNITED STATES OF AMERICA
Tungsten	Lianyou Metals Co., Ltd.	TAIWAN, PROVINCE OF CHINA
Tungsten	Lianyou Resources Co., Ltd.	TAIWAN, PROVINCE OF CHINA
Tungsten	Malipo Haiyu Tungsten Co., Ltd.	CHINA
Tungsten	Masan High-Tech Materials	VIETNAM

Tungsten	Nam Viet Cromit Joint Stock Company	VIETNAM
Tungsten	Niagara Refining LLC	UNITED STATES OF
		AMERICA
Tungsten	Philippine Chuangxin Industrial Co., Inc.	PHILIPPINES
Tungsten	Shinwon Tungsten (Fujian Shanghang) Co., Ltd.	CHINA
Tungsten	TANIOBIS Smelting GmbH & Co. KG	GERMANY
Tungsten	Tungsten Vietnam Joint Stock Company	VIETNAM
Tungsten	Wolfram Bergbau und Hutten AG	AUSTRIA
Tungsten	Xiamen Tungsten (H.C.) Co., Ltd.	CHINA
Tungsten	Xiamen Tungsten Co., Ltd.	CHINA
Tungsten	YUDU ANSHENG TUNGSTEN CO., LTD.	CHINA

Appendix B: Mines Country of Origin List

Andorra
Argentina
Australia
Austria
Belarus
Belgium
Bolivia
Brazil
Burundi
Cambodia
Canada
Chile
China
Colombia
Democratic Republic of Congo
Ecuador
Egypt
Estonia
Ethiopia
France
Germany
Ghana
Guinea
Guyana
Hong Kong
Hungary
India

Ireland
Italy
Japan
Kazakhstan
Korea
Luxembourg
Madagascar
Malaysia
Mexico
Mongolia
Morocco

Mozambique
Myanmar
Namibia
Netherlands
Nicaragua
Nigeria
Panama
Papua New Guinea
Peru
Philippines
Poland
Portugal
Russia
Rwanda
Saudi Arabia
Sierra Leone
Singapore
Slovakia
South Africa
Spain
Sudan
Sweden
Switzerland
Taiwan
Tanzania
Thailand
Togo
Turkey
Uganda
United Kingdom

United States of America
Uzbekistan
Vietnam
Zambia
Zimbabwe