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Nova Ltd. Environmental & Social Information 2024

May 29, 2024

6955_rns_2024-05-29_2e79d3fb-55d4-4679-9540-7acc18940de8.pdf

Environmental & Social Information

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

FORM SD SPECIALIZED DISCLOSURE REPORT

Nova Ltd.

(Exact name of registrant as specified in its charter)

incorporation or organization)

Israel 000-30668 98-0601172 (State or other jurisdiction of (Commission file number) (IRS Employer Identification No.)

5 David Fikes St., Rehovot 7632805, Israel (Address of principal executive offices) (Zip code)

Dror David, +972-73-2295670, +972-8-9407776

(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, 2023.

SECTION 1 – CONFLICT MINERALS DISCLOSURE

Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

In accordance with Rule 13p-1 of the Securities Exchange Act of 1934, as amended, Nova Ltd. (the "Company") hereby files this Specialized Disclosure Report on Form SD and the Conflict Minerals Report attached hereto as Exhibit 1.01. The Specialized Disclosure Report on Form SD and Conflict Minerals Report are also available on the Company's website at: : https://www.novami.com/investors/cg/ under "Investors" —"Corporate Governance" – "Conflict Minerals". The content of any website referred to in this Form SD (including the exhibit hereto) is included for general information only and is not incorporated by reference into this document.

SECTION 2 – RESOURCE EXTRACTION ISSUER DISCLOSURE

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

SECTION 3 – EXHIBITS

Item 3.01 Exhibits

Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2023 to December 31, 2023.

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.

Nova Ltd.

(Registrant)

By: /s/ Dror David______________________ May 29, 2024 Dror David Date Chief Financial Officer

Nova Ltd. Conflict Minerals Report For the Reporting Period January 1, 2023 to December 31, 2023

Introduction

This Conflict Minerals Report of Nova Ltd. (the "Company", "our Company", "Nova", "we", "us" or "our") for the reporting period from January 1, 2023 to December 31, 2023 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule"). The Rule was adopted by the Securities and Exchange Commission (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. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold ("Conflict Minerals"), and which are necessary to the functionality or production of their products. The Rule requires each of these registrants to conduct a reasonable country of origin inquiry ("RCOI") with respect to the sourcing of the Conflict Minerals that such company uses in its products and, if it has no reason to believe that the Conflict Minerals originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (the "Covered Countries"), file a description of the inquiry performed and the results of such inquiry on Form SD. If after conducting a RCOI as required by SEC rules a registrant has reason to believe that any of the Conflict Minerals in its supply chain may have originated in the DRC or Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the registrant must exercise due diligence with respect to the source and chain of custody of the Conflict Minerals in order to determine whether or not such Conflict Minerals directly or indirectly financed or benefited armed groups in the DRC or Covered Countries, and describe such due diligence measures in a Conflict Minerals Report that is included as an exhibit to its Form SD.

Nova is committed to responsible sourcing of minerals and has taken action to increase transparency in its supply chain and ensure responsible procurement by its suppliers and sub-suppliers. Nova has adopted a policy with respect to the sourcing of Conflict Minerals, which is available on its website at: https://www.novami.com/investors/cg/ under "Investors" — "Corporate Governance" – "Conflict Minerals". The content of any website referred to in this Conflict Minerals Report is included for general information only and is not incorporated by reference into this document.

Consistent with the Rule and the SEC's statement on April 29, 2014 relating to the Rule, this Conflict Minerals Report has not been audited by an independent private sector auditor.

Company and Products Overview

We are a leading innovator and a key provider of metrology solutions for advanced process control used in semiconductor manufacturing. We offer several metrology solutions, mainly by using optical and x-ray technologies, delivering unique measurement solutions to measure the most advanced semiconductor technology nodes. Our metrology systems measure various film thickness and composition properties as well as critical-dimension (CD) variables during various front-end and back-end of line steps in the semiconductor wafer fabrication process, allowing semiconductor manufacturers to improve quality, productivity and yields, lower manufacturing costs and increase profitability. We supply our metrology solutions to major semiconductor manufacturers worldwide and serve customers from offices in Taiwan, the Republic of Korea, China, Japan, the United States and Europe.

The scope of this report includes all of our consolidated businesses and subsidiaries for the year 2023, including one manufacturing facility for our Optical CD product lines, which is located in Ness-Ziona, Israel, and one manufacturing facility for our x-ray product line, which is located in Fremont, California, in the United States. This report refers to the purchase of parts and sub-assemblies ("Components") used for our manufacturing facilities in both Israel and California. During 2023, all such Components were purchased from third parties and were delivered to these facilities, where they were integrated into complete systems that constitute the tools that we sold to others. Following the acquisition of ancosys GmbH in January 2022, and its merger into Nova Measuring Instruments GmbH in June 2023, we have expanded our technology offering by adding Chemical Analytical methods with applications of Chemical metrology in various steps..

Because metals such as tin, tantalum, tungsten and gold that are included in the definition of Conflict Minerals are generally contained in our Components, we believe that our products contain Conflict Minerals that are necessary for the functionality or production of our products.

Reasonable Country of Origin Inquiry ("RCOI")

Because we believe that Conflict Minerals were necessary to the functionality or production of products manufactured, or contracted to be manufactured, by us during 2023, we performed an RCOI to determine whether the Conflict Minerals in such products originated from the DRC or Covered Countries and whether such Conflict Minerals come from recycled or scrap sources.

The products that we manufacture, or contract to manufacture, are highly complex, and typically contain thousands of Components from many manufacturers. We have an extensive and varied supply chain and do not have a direct relationship with Conflict Minerals smelters or refiners. In this regard, we do not purchase Conflict Minerals directly from mines, smelters or refiners, and there are many third parties in the supply chain between the original sources of Conflict Minerals and the ultimate manufacture of our products. Accordingly, to gather information from our suppliers, we utilize a standard template for Conflict Minerals reporting designed by the Responsible Minerals Initiative ("RMI") known as the Conflict Minerals Reporting Template (the "CMRT"). We relied on our suppliers to complete the CMRT in order to provide information on the origin of the Conflict Minerals contained in Components supplied to us – including information regarding the sources of Conflict Minerals that are supplied to our suppliers from lower tiers in the chain (i.e., sub-suppliers). In addition, with respect to the certification of smelters or refiners as conflict-free, we have relied upon the latest findings of the RMI's Responsible Minerals Assurance Process (the "RMAP").

The RCOI undertaken by us in 2023 consisted of sending letters and CMRTs to 39 of our largest first-tier suppliers that we concluded were providing us with Components that do, or may, contain Conflict Minerals that are necessary for the functionality or production of our products and that accounted for approximately 85% of all our applicable 2023 product material expenditures. These suppliers include our turnkey suppliers, which means that they are in direct contact with our supply chain management team, and are considered to be our strategic partners, having long-term relationships with our Company. The letters we sent to such suppliers explained the Rule and referred the suppliers to online training materials and instructions, sought their support and cooperation in our efforts in connection with Conflict Minerals, provided a copy of our Conflict Minerals policy, and asked them to complete the CMRT. Working with a third-party service provider to conduct the survey and compile the survey results, we reviewed the responses and followed up as necessary by sending periodic reminders to non-responsive suppliers and following up on responses that appeared to be inconsistent, incomplete or inaccurate. In the end, the response rate from suppliers asked to participate was 89%.

Based on information obtained in the RCOI, and taking into account the complexities of our supply chain, we concluded that we did not have sufficient information to determine the country of origin of the Conflict Minerals in our products and were unable to rule out the possibility that Conflict Minerals used in our products originated, or may have originated, from the DRC or Covered Countries. Therefore, in accordance with the Rule, we undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of our products during 2023. There is significant overlap between our RCOI efforts and our due diligence measures performed.

Due Diligence

Design of Due Diligence Framework

Our due diligence measures have been designed, in all material respects, to conform as far as practicable with the internationally recognized due diligence framework prescribed by the Organization for Economic Co-operation and Development ("OECD"), known as "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas" and related supplements for Conflict Minerals (the "OECD Guidance").

Due Diligence Measures Performed

In substantial conformance with the OECD Guidance, our due diligence efforts for calendar year 2023 included the following steps:

Step 1. Establish Strong Company Management Systems

  • Conflict Minerals steering committee: A cross-functional Conflict Minerals steering committee operates our Conflict Minerals program. The committee consists of representatives from the following areas: operations (purchasing and engineering); and legal and compliance. Regular meetings of our Conflict Minerals steering committee were held, and the committee periodically updated representatives of our senior management on the status of the Conflict Minerals program.
  • Conflict Minerals Policy: Our Conflict Minerals policy (the "Policy"), adopted in 2015, has been communicated both throughout our Company and to suppliers, and is publicly available on our Company's website at: : https://www.novami.com/investors/cg/ under "Investors" —"Corporate Governance" – "Conflict Minerals".
  • Supplier engagement: We sent letters and CMRTs to a substantial portion of our first-tier suppliers identified during an applicability assessment phase as providing Components that do, or may, contain Conflict Minerals that are necessary for the functionality or production of our products. The aforementioned letters advised the suppliers of our commitment to responsible sourcing of minerals and indicated that their cooperation in the due diligence efforts is expected, including by completion of the CMRT.

In addition, we made training materials available to those first-tier suppliers that included an overview of the Rule and instructions on how to complete the CMRT survey.

For each purchase order issued by our computerized purchase order system for purchasing Components, suppliers are required to accept our terms and conditions, which include, among others, that (i) upon request, a supplier shall provide us with information regarding its products that contain Conflict Minerals, and (ii) in certain cases, we reserve the right to immediately terminate the purchase order and cease all procurement activity with the supplier.

Step 2. Identify and Assess Risks in the Supply Chain

We identified and assessed risk in our supply chain as follows: First, we identified our major first-tier (i.e., direct) suppliers that provide Components that potentially incorporate Conflict Minerals that are necessary to the functionality or production of our products that we manufactured, or contracted to manufacture, in 2023 (and which accounted for a substantial portion of all applicable expenditures on Components by our Company in 2023). We then requested information from relevant suppliers regarding the source and chain of custody of Conflict Minerals in their supply chain. To facilitate the collection of complete, accurate, standardized and verifiable information, we relied primarily on the CMRT, which seeks information regarding country of origin of Conflict Minerals, mine location and smelters or refiners used.

We reviewed suppliers' responses in order to track information regarding smelters or refiners of Conflict Minerals in our supply chain that have not received a conflict-free designation based on the RMAP.

Step 3. Design and Implement a Strategy to Respond to Identified Risks

We initiated a supply chain survey with selected suppliers using the CMRT in order to identify those smelters or refiners that supplied Conflict Minerals used in our products. We monitored and tracked our performance in this area by reviewing supplier responses. Each CMRT completed by a supplier was entered into a database maintained by a third-party service provider and reviewed. For suppliers that provided unclear or incomplete responses, an escalation process was used in order to obtain complete and accurate required information, sometimes requiring multiple telephone and/or email contacts to further the data collection process. Our Conflict Minerals steering committee held regular meetings to review progress and assess the risks identified.

In addition, smelters or refiners that were identified in the suppliers' responses were compared against the list of facilities that have received a conflict-free designation from the RMAP ("conflict-free" meaning generally that they did not directly or indirectly finance or benefit armed groups in the Covered Countries), and country of origin information for the smelters or refiners identified by the supply chain responses were reviewed using RMAP data. In accordance with our risk management plan, we contacted suppliers that have been identified as having non-certified smelters or refiners within the smelters or refiners list that they have provided to us.

Finally, representatives of our senior management were briefed about our due diligence efforts and findings on a regular basis.

Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices

We are several steps away in the supply chain from smelters or refiners that process the Conflict Minerals used in our products, do not have any direct relationships with such smelters or refiners and did not obtain from a third party or perform ourselves a direct audit of smelters or refiners within our supply chain. Instead, we relied on conflict-free designations based on the activities of other organizations such as the RMI (through the RMAP).

Step 5. Report Annually on Supply Chain Due Diligence

We report annually on our supply chain due diligence, as required by the Rule, and have posted our Form SD and Conflict Minerals Report on our website at: : https://www.novami.com/investors/cg/ under "Investors" —"Corporate Governance" – "Conflict Minerals".

Results of Assessment

On account of incomplete information, we are unable at this time to determine and describe with complete certainty in this report a complete list of either the facilities used to process the Conflict Minerals used in our products or the countries of origin of those Conflict Minerals. We have, nevertheless, described below the results of our assessment on the source of the Conflict Minerals, to the extent that we received information from our relevant suppliers through our due diligence efforts.

As indicated above, the products that we manufacture, or contract to manufacture, are highly complex, and typically contain thousands of Components from many suppliers. Because there are generally multiple tiers between the mines that extract Conflict Minerals and our suppliers, we relied on our suppliers to provide information on the origin of the Conflict Minerals contained in Components supplied to us.

In all, we surveyed 39 suppliers to whom we paid approximately 85% of the applicable expenditures by our Company on Component costs for our products in 2023. 89% of the suppliers whom we surveyed provided a complete response.

As part of our due diligence efforts and based on the information received from our suppliers, we identified 349 smelters or refiners of Conflict Minerals used generally in their supply chains, of which 64% have been certified as conflict free by the RMI's RMAP, and of which 1.15% are currently engaged in the RMI audit process. A list of these identified smelters or refiners is provided in Appendix A hereto.

Some suppliers were unable to provide a complete list of smelters or refiners. In addition, despite receiving information regarding smelters or refiners used generally by some suppliers in their supply chains, these suppliers were unable to report which smelters or refiners were part of the supply chain applicable to the specific Components that were sold to us. Furthermore, for the significant majority of smelters reported by these suppliers, there is inadequate information available to assess the source of the conflict minerals that they process. As a result, we are unable to identify with complete accuracy the country of origin of the Conflict Minerals used in our products in 2023 and we concluded in good faith that we lack sufficient information to trace the chain of custody of any Conflict Minerals contained in our products in 2023 up through the supply chain to a specific smelter or, in turn, to a country or mine of origin. We have, however, become aware that certain smelters or refiners from Covered Countries that have been identified as part of the supply chain of our suppliers have not been certified as conflict free under the RMI's RMAP. We have therefore activated our risk management procedures in respect of those smelters or refiners, and have approached the supplier that provided us the relevant Conflict Minerals sourced from those smelters or refiners and have asked for corrective action to be taken.

We furthermore note that information is not gathered from our suppliers on a continuous, real-time basis. We can therefore only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals used in our products, since the information comes from direct suppliers, not the underlying smelters or refiners, and is based on independent third-party audit programs, not our own auditing.

Continuous Efforts to Mitigate Risk

We intend to maintain our approach for responsible sourcing of the minerals used in our products and to continue to comply with any applicable regulations related to the sourcing of, and disclosure concerning, the Conflict Minerals that may be contained in our products.

Forward Looking Statements

Forward-looking statements in this Conflict Minerals Report are made pursuant to the safe harbor provisions of Section 21E of the Securities Exchange Act of 1934, as amended, and other federal securities laws. Investors are cautioned that statements in this Conflict Minerals Report that are not strictly historical statements, including without limitation, the Company's intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts and strategy, constitute forward looking statements that involve risks and uncertainties. Actual results could differ materially from the forward-looking statements. Words such as "expects," "anticipates," "intends," variations of these words, and similar expressions, are intended to identify such forward looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company's ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others. Except as otherwise required by law, the Company undertakes no obligation to update publicly the information contained in this Conflict Minerals Report, or any forward-looking statements, to reflect new information, events or circumstances after the date they were made, or to reflect the occurrence of unanticipated events.

Appendix A

List of Identified Smelters or Refiners

Smelter Metal Smelter Look-up (known smelters by RMI) Smelter Country
Gold Advanced Chemical Company UNITED STATES OF AMERICA
Gold Aida Chemical Industries Co., Ltd. JAPAN
Gold Agosi AG 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 Asaka Riken Co., Ltd. JAPAN
Gold Atasay Kuyumculuk
Sanayi Ve Ticaret A.S.
TURKEY
Gold Aurubis AG GERMANY
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES
Gold Boliden AB 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 Yunnan Copper Industry Co., Ltd. CHINA
Gold Chimet S.p.A. ITALY
Gold Chugai Mining JAPAN
Gold Daye Non-Ferrous Metals Mining Ltd. CHINA
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF
Gold Dowa JAPAN
Gold Eco-System Recycling Co., Ltd. East Plant JAPAN
Gold JSC Novosibirsk Refinery RUSSIAN FEDERATION
Gold Refinery of Seemine Gold Co., Ltd. CHINA
Gold Guoda
Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA
Gold LT Metal Ltd. KOREA, REPUBLIC OF
Gold Heimerle + Meule GmbH GERMANY
Gold Heraeus Metals Hong Kong Ltd. CHINA
Gold Heraeus Germany 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 Ishifuku Metal Industry Co., Ltd. JAPAN
Gold Istanbul Gold Refinery TURKEY
Gold Japan Mint JAPAN
Gold Jiangxi Copper Co., Ltd. CHINA
Gold Asahi Refining USA Inc. UNITED STATES OF AMERICA
Gold Asahi Refining Canada Ltd. CANADA
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION
Gold JSC Uralelectromed RUSSIAN FEDERATION
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN
Gold Kazakhmys Smelting LLC KAZAKHSTAN
Gold Kazzinc KAZAKHSTAN
Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA
Gold Kojima Chemicals Co., Ltd. JAPAN
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 LS-NIKKO Copper Inc. KOREA, REPUBLIC OF
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA
Gold Materion UNITED STATES OF AMERICA
Gold Matsuda Sangyo Co., Ltd. JAPAN
Gold Metalor
Technologies (Suzhou) Ltd.
CHINA
Gold Metalor Technologies (Hong Kong) Ltd. CHINA
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE
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 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 Nihon Material Co., Ltd. JAPAN
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN
OJSC "The Gulidov
Krasnoyarsk Non-Ferrous Metals Plant" (OJSC
Gold Krastsvetmet) RUSSIAN FEDERATION
Gold MKS PAMP SA SWITZERLAND
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA
Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION
Gold PT Aneka Tambang (Persero) Tbk INDONESIA
Gold PX Precinox S.A. SWITZERLAND
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA
Gold Royal Canadian Mint CANADA
Gold Sabin Metal Corp. UNITED STATES OF AMERICA
Gold Samduck Precious Metals KOREA, REPUBLIC OF
Gold Samwon Metals Corp. KOREA, REPUBLIC OF
Gold SEMPSA Joyeria Plateria S.A. SPAIN
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 SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION
Gold Solar Applied Materials Technology Corp. TAIWAN, PROVINCE OF CHINA
Gold Sumitomo Metal Mining Co., Ltd. JAPAN
Gold Super Dragon Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN
Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA
Gold Shandong Gold Smelting Co., Ltd. CHINA
Gold Tokuriki Honten Co., Ltd. JAPAN
Gold Tongling
Nonferrous Metals Group Co., Ltd.
CHINA
Gold Torecom KOREA, REPUBLIC OF
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 Yamakin Co., Ltd. JAPAN
Gold Yokohama Metal Co., Ltd. JAPAN
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA
Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA
Gold Morris and Watson NEW ZEALAND
Gold SAFINA A.S. CZECHIA
Gold Guangdong Jinding Gold Limited CHINA
Gold Umicore Precious Metals Thailand THAILAND
Gold Geib Refining Corporation UNITED STATES OF AMERICA
Gold MMTC-PAMP India Pvt., Ltd. INDIA
Gold KGHM Polska Miedz Spolka Akcyjna POLAND
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE
Gold Singway Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA
Gold Shandong Humon Smelting Co., Ltd. CHINA
Gold Shenzhen Zhonghenglong
Real Industry Co., Ltd.
CHINA
Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES
Gold Emirates Gold DMCC UNITED ARAB EMIRATES
Gold International Precious Metal Refiners UNITED ARAB EMIRATES
Gold Kaloti Precious Metals UNITED ARAB EMIRATES
Gold Sudan Gold Refinery SUDAN
Gold T.C.A S.p.A ITALY
Gold REMONDIS PMR B.V. NETHERLANDS
Gold Fujairah Gold FZC UNITED ARAB EMIRATES
Gold Industrial Refining Company BELGIUM
Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF
Gold Marsam Metals BRAZIL
Gold TOO Tau-Ken-Altyn KAZAKHSTAN
Gold Abington Reldan Metals, LLC UNITED STATES OF AMERICA
Gold SAAMP FRANCE
Gold L'Orfebre S.A. ANDORRA
Gold 8853 S.p.A. ITALY
Gold Italpreziosi ITALY
Gold WIELAND Edelmetalle GmbH GERMANY
Gold Ogussa Osterreichische Gold-
und Silber-Scheideanstalt GmbH
AUSTRIA
Gold AU Traders and Refiners SOUTH AFRICA
Gold GGC Gujrat Gold Centre Pvt. Ltd. INDIA
Gold Sai Refinery INDIA
Gold Modeltech Sdn Bhd MALAYSIA
Gold Bangalore Refinery INDIA
Gold Kyshtym Copper-Electrolytic Plant ZAO RUSSIAN FEDERATION
Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY
Gold Pease & Curren UNITED STATES OF AMERICA
Gold SungEel HiMetal Co., Ltd. KOREA, REPUBLIC OF
Gold Planta Recuperadora de Metales SpA CHILE
Gold Safimet S.p.A ITALY
State Research Institute Center for Physical Sciences and
Gold Technology LITHUANIA
Gold African Gold Refinery UGANDA
Gold NH Recytech Company KOREA, REPUBLIC OF
Gold QG Refining, LLC UNITED STATES OF AMERICA
Gold Dijllah Gold Refinery FZC UNITED ARAB EMIRATES
Gold Coimpa Industrial LTDA BRAZIL
Gold Dongwu Gold Group CHINA
Gold Gold by Gold Colombia COLOMBIA
Gold Value Trading BELGIUM
Gold WEEEREFINING FRANCE
Gold Metal Concentrators SA (Pty) Ltd. SOUTH AFRICA
Gold Metallix Refining Inc. UNITED STATES OF AMERICA
Gold MD Overseas INDIA
Gold Sellem Industries Ltd. MAURITANIA
Gold Sancus ZFS (L COLOMBIA
Gold Alexy Metals UNITED STATES OF AMERICA
Gold K.A. Rasmussen NORWAY
Gold Emerald Jewel Industry India Limited (Unit 4) INDIA
Gold Emerald Jewel Industry India Limited (Unit 3) INDIA
Gold Emerald Jewel Industry India Limited (Unit 2) INDIA
Gold Emerald Jewel Industry India Limited (Unit 1) INDIA
Gold Kundan Care Products Ltd. INDIA
Gold Augmont Enterprises Private Limited INDIA
Gold Eco-System Recycling Co., Ltd. West Plant JAPAN
Gold Eco-System Recycling Co., Ltd. North Plant JAPAN
Gold C.I Metales Procesados Industriales SAS COLOMBIA
Gold Sovereign Metals INDIA
Gold CGR Metalloys Pvt Ltd. INDIA
Gold DS PRETECH Co., Ltd. KOREA, REPUBLIC OF
Gold Gold Coast Refinery GHANA
Gold ABC Refinery Pty Ltd. AUSTRALIA
Gold JALAN & Company INDIA
Gold Morris and Watson Gold Coast AUSTRALIA
Gold Universal Precious Metals Refining Zambia ZAMBIA
Gold Metahub Industries Sdn. Bhd. MALAYSIA
Gold SAXONIA Edelmetalle GmbH GERMANY
Gold Albino Mountinho Lda. PORTUGAL
Gold Shenzhen CuiLu Gold Co., Ltd. CHINA
Gold Shirpur Gold Refinery Ltd. INDIA
Gold Republic Metals Corporation UNITED STATES OF AMERICA
Gold Faggi Enrico S.p.A. ITALY
Gold Umicore Brasil Ltda. BRAZIL
Gold So Accurate Group, Inc. UNITED STATES OF AMERICA
Gold Schone Edelmetaal B.V. NETHERLANDS
Gold OJSC Kolyma Refinery RUSSIAN FEDERATION
Gold Elemetal Refining, LLC UNITED STATES OF AMERICA
Gold Korea Metal Co., Ltd. KOREA, REPUBLIC OF
Gold DODUCO Contacts and Refining GmbH GERMANY
Gold Daejin Indus Co., Ltd. KOREA, REPUBLIC OF
Gold Bauer Walser AG GERMANY
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY
Gold Aktyubinsk Copper Company TOO KAZAKHSTAN
Gold KP Sanghvi International Airport INDIA
TANZANIA, UNITED REPUBLIC
Gold GG Refinery Ltd. OF
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA
Tantalum F&X Electro-Materials Ltd. CHINA
Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED CHINA
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA
Tantalum Jiujiang Tanbre Co., Ltd. CHINA
Tantalum AMG Brasil BRAZIL
Tantalum Metallurgical Products India Pvt., Ltd. INDIA
Tantalum Mineracao Taboca S.A. BRAZIL
Tantalum NPM Silmet AS ESTONIA
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA
Tantalum QuantumClean UNITED STATES OF AMERICA
Tantalum Yanling
Jincheng Tantalum & Niobium Co., Ltd.
CHINA
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 Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA
Tantalum D Block Metals, LLC UNITED STATES OF AMERICA
Tantalum FIR Metals & Resource Ltd. CHINA
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA
Tantalum KEMET de Mexico MEXICO
Tantalum TANIOBIS Co., Ltd. THAILAND
Tantalum TANIOBIS GmbH GERMANY
Tantalum Materion Newton Inc. UNITED STATES OF AMERICA
Tantalum TANIOBIS Japan Co., Ltd. JAPAN
Tantalum TANIOBIS Smelting GmbH & Co. KG GERMANY
Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA
Tantalum Global Advanced Metals Aizu JAPAN
Tantalum Resind Industria
e Comercio Ltda.
BRAZIL
Tantalum Jiangxi Tuohong New Raw Material CHINA
Tantalum PowerX Ltd. RWANDA
Tantalum XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD. CHINA
Tantalum 5D Production OU ESTONIA
Tantalum Yancheng Jinye
New Material Technology Co., Ltd.
CHINA
Tantalum V&D New Materials (Jiangsu) Co., Ltd. CHINA
Tantalum CP Metals Inc. UNITED STATES OF AMERICA
Tantalum Jiujiang Janny New Material Co., Ltd. CHINA
Tantalum RFH Metals & Chemicals Co., Ltd. CHINA
MACEDONIA, THE FORMER
Tantalum Power Resources Ltd. YUGOSLAV REPUBLIC OF
UNITED KINGDOM OF GREAT
Tantalum Avon Specialty Metals Ltd BRITAIN AND NORTHERN
Tantalum E.S.R. Electronics UNITED STATES OF AMERICA
Tantalum Tranzact, Inc. UNITED STATES OF AMERICA
Tantalum KEMET Blue Powder UNITED STATES OF AMERICA
Tantalum Taike Technology(Suzhou)Co.,Ltd. CHINA
Tantalum Plansee SE Reutte AUSTRIA
Tantalum H.C. Starck Hermsdorf GmbH GERMANY
Tantalum H.C. Starck GmbH Laufenburg GERMANY
Tantalum Plansee SE Liezen AUSTRIA
Tantalum Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch CHINA
Tantalum Yichun Jin Yang Rare Metal Co., Ltd. CHINA
Tantalum Zhuzhou Cemented Carbide Group Co., Ltd. CHINA
Tantalum King-Tan Tantalum Industry Ltd. CHINA
Tantalum Hi-Temp Specialty Metals, Inc. UNITED STATES OF AMERICA
Tantalum Exotech Inc. UNITED STATES OF AMERICA
Tantalum Duoluoshan CHINA
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. CHINA
Tantalum H.C. Starck GmbH GERMANY
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA
Tin Alpha UNITED STATES OF AMERICA
Tin PT Aries Kencana Sejahtera INDONESIA
BOLIVIA (PLURINATIONAL
Tin EM Vinto STATE OF)
Tin Estanho de Rondonia S.A. BRAZIL
Tin Fenix Metals POLAND
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA
Tin Gejiu Kai Meng Industry and Trade LLC CHINA
Tin China Tin Group Co., Ltd. CHINA
Tin Malaysia Smelting Corporation (MSC) MALAYSIA
Tin Metallic Resources, Inc. UNITED STATES OF AMERICA
Tin Minsur PERU
Tin Jiangxi New Nanshan Technology Ltd. CHINA
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND
BOLIVIA (PLURINATIONAL
Tin Operaciones Metalurgicas S.A. STATE OF)
Tin PT Artha Cipta Langgeng INDONESIA
Tin PT Babel Inti Perkasa INDONESIA
Tin PT Babel Surya Alam Lestari INDONESIA
Tin PT Belitung Industri Sejahtera INDONESIA
Tin PT Bukit Timah INDONESIA
Tin PT Mitra Stania Prima INDONESIA
Tin PT Panca Mega Persada INDONESIA
Tin PT Prima Timah Utama INDONESIA
Tin PT Refined Bangka Tin INDONESIA
Tin PT Sariwiguna Binasentosa INDONESIA
Tin PT Stanindo Inti Perkasa INDONESIA
Tin PT Timah Tbk Kundur INDONESIA
Tin PT Timah Tbk Mentok INDONESIA
Tin PT Tinindo Inter Nusa INDONESIA
Tin PT Tommy Utama INDONESIA
Tin Rui Da Hung TAIWAN, PROVINCE OF CHINA
Tin Thaisarco THAILAND
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA
Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. CHINA
Tin CV Venus Inti Perkasa INDONESIA
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL
Tin PT Tirus Putra Mandiri INDONESIA
Tin Melt Metais e Ligas S.A. BRAZIL
Tin PT ATD Makmur Mandiri Jaya INDONESIA
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy
Tin Joint Stock Company VIETNAM
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIETNAM
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIETNAM
Tin An Vinh Joint Stock Mineral Processing Company VIETNAM
Tin Super Ligas BRAZIL
Tin Aurubis Beerse BELGIUM
Tin Aurubis Berango SPAIN
Tin PT Sukses
Inti Makmur
INDONESIA
Tin PT Menara Cipta Mulia INDONESIA
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA
Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA
Tin PT Bangka Serumpun INDONESIA
Tin Pongpipat Company Limited MYANMAR
Tin Tin Technology & Refining UNITED STATES OF AMERICA
CONGO, DEMOCRATIC
Tin Mining Minerals Resources SARL REPUBLIC OF THE
Tin PT Putera Sarana Shakti (PT PSS) INDONESIA
Tin DS Myanmar MYANMAR
Tin Fabrica Auricchio Industria e Comercio Ltda. BRAZIL
Tin Rian Resources SDN. BHD. MALAYSIA
Tin Dragon Silver Holdings Limited CHINA
Tin CRM Synergies SPAIN
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos
Tin Do Brasil Ltda BRAZIL
Tin TRATHO Metal Quimica BRAZIL
Tin PT Mitra Sukses Globalindo INDONESIA
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. CHINA
Tin Precious Minerals and Smelting Limited INDIA
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. CHINA
Tin Luna Smelter, Ltd. RWANDA
Tin PT Rajawali
Rimba Perkasa
INDONESIA
Tin PT Masbro Alam Stania INDONESIA
Tin Ma'anshan Weitai Tin Co., Ltd. CHINA
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. CHINA
Tin PT Lautan Harmonis Sejahtera INDONESIA
Tin Gejiu Jinye
Mineral Company
CHINA
Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA
Tin
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
PT Kijang Jaya Mandiri
VIET NAM
INDONESIA
Tin An Thai Minerals Co., Ltd. VIET NAM
Tin PT O.M. Indonesia INDONESIA
Tin PT Cipta Persada Mulia INDONESIA
Tin CV Dua Sekawan INDONESIA
Tin PT Inti Stania Prima INDONESIA
Tin Phoenix Metal Ltd. RWANDA
Tin PT Wahana Perkit Jaya INDONESIA
Tin VQB Mineral and Trading Group JSC VIET NAM
Tin Soft Metais Ltda. BRAZIL
Tin PT Timah Nusantara INDONESIA
Tin PT Sumber Jaya Indah INDONESIA
Tin PT Seirama Tin Investment INDONESIA
Tin PT Koba Tin INDONESIA
Tin PT Karimun Mining INDONESIA
Tin PT Fang Di MulTindo INDONESIA
Tin PT Eunindo Usaha Mandiri INDONESIA
Tin PT DS Jaya Abadi INDONESIA
Tin PT BilliTin Makmur Lestari INDONESIA
Tin PT Bangka Timah Utama Sejahtera INDONESIA
Tin PT Bangka Putra Karya INDONESIA
Tin PT Bangka Kudai Tin INDONESIA
Tin PT Alam Lestari Kencana INDONESIA
Tin Novosibirsk Processing Plant Ltd. RUSSIAN FEDERATION
Tin Linwu Xianggui Ore Smelting Co., Ltd. CHINA
Tin Huichang Jinshunda
Tin Co., Ltd.
CHINA
Tin Feinhutte Halsbrucke GmbH GERMANY
Tin CV United Smelting INDONESIA
Tin PT Justindo INDONESIA
Tin CV Gita Pesona INDONESIA
Tin Cooperativa Metalurgica de Rond BRAZIL
Tin CNMC (Guangxi) PGMA Co., Ltd. CHINA
Tin Jiangxi Ketai Advanced Material Co., Ltd. CHINA
Takehara PVD Materials Plant / PVD Materials Division of MITSUI
Tin MINING & SMELTING CO., LTD. JAPAN
Tin yunnan xi ye gufen youxian gongsi CHINA
Tin Malaysia Smelting Corporation Berhad (Port Klang) MALAYSIA
Tungsten A.L.M.T. Corp. JAPAN
Tungsten Kennametal Huntsville UNITED STATES OF AMERICA
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA
Tungsten Chongyi Zhangyuan
Tungsten Co., Ltd.
CHINA
Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA
Tungsten Hunan Jintai New Material Co., Ltd. CHINA
Tungsten Japan New Metals Co., Ltd. JAPAN
Tungsten Ganzhou Huaxing
Tungsten Products Co., Ltd.
CHINA
Tungsten Kennametal Fallon UNITED STATES OF AMERICA
Tungsten Wolfram Bergbau und Hutten AG AUSTRIA
Tungsten Xiamen Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Minmetals Gao'an
Non-ferrous Metals Co., Ltd.
CHINA
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA
Tungsten Jiangxi Tonggu
Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA
Tungsten Ganzhou Seadragon
W & Mo Co., Ltd.
CHINA
Tungsten Asia Tungsten Products Vietnam Ltd. VIETNAM
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten
Tungsten Products Branch CHINA
Tungsten H.C. Starck Tungsten GmbH GERMANY
Tungsten Masan High-Tech Materials VIET NAM
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA
Tungsten Niagara Refining LLC UNITED STATES OF AMERICA
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES
Tungsten ACL Metais Eireli BRAZIL
Tungsten Moliren Ltd. RUSSIAN FEDERATION
Tungsten HANNAE FOR T Co., Ltd. KOREA, REPUBLIC OF
Tungsten YUDU ANSHENG TUNGSTEN CO., LTD. CHINA
Tungsten LLC Vostok RUSSIAN FEDERATION
Tungsten OOO RUSSIAN FEDERATION
Tungsten Fujian Xinlu Tungsten CHINA
Tungsten Ganzhou Sunny Non-Ferrous Metals Co., Ltd. CHINA
Tungsten Artek LLC RUSSIAN FEDERATION
Tungsten Cronimet Brasil Ltda BRAZIL
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. BRAZIL
Tungsten GEM Co., Ltd. CHINA
Tungsten NPP Tyazhmetprom LLC RUSSIAN FEDERATION
Tungsten JSC "Kirovgrad
Hard Alloys Plant"
RUSSIAN FEDERATION
Tungsten Lianyou Metals Co., Ltd. TAIWAN, PROVINCE OF CHINA
Tungsten Fujian Ganmin RareMetal Co., Ltd. CHINA
Tungsten KGETS Co., Ltd. KOREA, REPUBLIC OF
Tungsten Hunan Litian
Tungsten Industry Co., Ltd.
CHINA
Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA
Tungsten South-East Nonferrous Metal Company Limited of Hengyang City CHINA
Tungsten Jiangxi Dayu Longxintai Tungsten Co., Ltd. CHINA
Tungsten China Molybdenum Co., Ltd. CHINA
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin CHINA
Tungsten Sanher
Tungsten Vietnam Co., Ltd.
VIETNAM
Tungsten Ganzhou Yatai Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CHINA
Tungsten Pobedit, JSC RUSSIAN FEDERATION
Tungsten Ganxian Shirui
New Material Co., Ltd.
CHINA
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd. CHINA
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd. VIETNAM
Tungsten Tejing
(Vietnam) Tungsten Co., Ltd.
VIETNAM
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd. CHINA
Tungsten Ganzhou Grand Sea W & Mo Group Co Ltd CHINA
Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA
Tungsten Dayu Weiliang
Tungsten Co., Ltd.
CHINA
Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. CHINA
Tungsten Kenee Mining Corporation Vietnam VIETNAM

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

FORM SD SPECIALIZED DISCLOSURE REPORT

Nova Ltd.

(Exact name of registrant as specified in its charter)

Israel 000-30668 98-0601172

(State or other jurisdiction of (Commission file number) (IRS Employer Identification No.) incorporation or organization)

5 David Fikes St., Rehovot 7632805, Israel

(Address of principal executive offices) (Zip code)

Dror David, +972-73-2295670, +972-8-9407776

(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, 2023.

SECTION 1 – CONFLICT MINERALS DISCLOSURE

Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

In accordance with Rule 13p-1 of the Securities Exchange Act of 1934, as amended, Nova Ltd. (the "Company") hereby files this Specialized Disclosure Report on Form SD and the Conflict Minerals Report attached hereto as Exhibit 1.01. The Specialized Disclosure Report on Form SD and Conflict Minerals Report are also available on the Company's website at: : https://www.novami.com/investors/cg/ under "Investors" —"Corporate Governance" – "Conflict Minerals". The content of any website referred to in this Form SD (including the exhibit hereto) is included for general information only and is not incorporated by reference into this document.

SECTION 2 – RESOURCE EXTRACTION ISSUER DISCLOSURE

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

SECTION 3 – EXHIBITS

Item 3.01 Exhibits

Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2023 to December 31, 2023.

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.

Nova Ltd.

(Registrant)

By: /s/ Dror David______________________ May 29, 2024 Dror David Date Chief Financial Officer

Nova Ltd. Conflict Minerals Report For the Reporting Period January 1, 2023 to December 31, 2023

Introduction

This Conflict Minerals Report of Nova Ltd. (the "Company", "our Company", "Nova", "we", "us" or "our") for the reporting period from January 1, 2023 to December 31, 2023 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule"). The Rule was adopted by the Securities and Exchange Commission (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. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold ("Conflict Minerals"), and which are necessary to the functionality or production of their products. The Rule requires each of these registrants to conduct a reasonable country of origin inquiry ("RCOI") with respect to the sourcing of the Conflict Minerals that such company uses in its products and, if it has no reason to believe that the Conflict Minerals originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (the "Covered Countries"), file a description of the inquiry performed and the results of such inquiry on Form SD. If after conducting a RCOI as required by SEC rules a registrant has reason to believe that any of the Conflict Minerals in its supply chain may have originated in the DRC or Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the registrant must exercise due diligence with respect to the source and chain of custody of the Conflict Minerals in order to determine whether or not such Conflict Minerals directly or indirectly financed or benefited armed groups in the DRC or Covered Countries, and describe such due diligence measures in a Conflict Minerals Report that is included as an exhibit to its Form SD.

Nova is committed to responsible sourcing of minerals and has taken action to increase transparency in its supply chain and ensure responsible procurement by its suppliers and sub-suppliers. Nova has adopted a policy with respect to the sourcing of Conflict Minerals, which is available on its website at: https://www.novami.com/investors/cg/ under "Investors" — "Corporate Governance" – "Conflict Minerals". The content of any website referred to in this Conflict Minerals Report is included for general information only and is not incorporated by reference into this document.

Consistent with the Rule and the SEC's statement on April 29, 2014 relating to the Rule, this Conflict Minerals Report has not been audited by an independent private sector auditor.

Company and Products Overview

We are a leading innovator and a key provider of metrology solutions for advanced process control used in semiconductor manufacturing. We offer several metrology solutions, mainly by using optical and x-ray technologies, delivering unique measurement solutions to measure the most advanced semiconductor technology nodes. Our metrology systems measure various film thickness and composition properties as well as critical-dimension (CD) variables during various front-end and back-end of line steps in the semiconductor wafer fabrication process, allowing semiconductor manufacturers to improve quality, productivity and yields, lower manufacturing costs and increase profitability. We supply our metrology solutions to major semiconductor manufacturers worldwide and serve customers from offices in Taiwan, the Republic of Korea, China, Japan, the United States and Europe.

The scope of this report includes all of our consolidated businesses and subsidiaries for the year 2023, including one manufacturing facility for our Optical CD product lines, which is located in Ness-Ziona, Israel, and one manufacturing facility for our x-ray product line, which is located in Fremont, California, in the United States. This report refers to the purchase of parts and sub-assemblies ("Components") used for our manufacturing facilities in both Israel and California. During 2023, all such Components were purchased from third parties and were delivered to these facilities, where they were integrated into complete systems that constitute the tools that we sold to others. Following the acquisition of ancosys GmbH in January 2022, and its merger into Nova Measuring Instruments GmbH in June 2023, we have expanded our technology offering by adding Chemical Analytical methods with applications of Chemical metrology in various steps..

Because metals such as tin, tantalum, tungsten and gold that are included in the definition of Conflict Minerals are generally contained in our Components, we believe that our products contain Conflict Minerals that are necessary for the functionality or production of our products.

Reasonable Country of Origin Inquiry ("RCOI")

Because we believe that Conflict Minerals were necessary to the functionality or production of products manufactured, or contracted to be manufactured, by us during 2023, we performed an RCOI to determine whether the Conflict Minerals in such products originated from the DRC or Covered Countries and whether such Conflict Minerals come from recycled or scrap sources.

The products that we manufacture, or contract to manufacture, are highly complex, and typically contain thousands of Components from many manufacturers. We have an extensive and varied supply chain and do not have a direct relationship with Conflict Minerals smelters or refiners. In this regard, we do not purchase Conflict Minerals directly from mines, smelters or refiners, and there are many third parties in the supply chain between the original sources of Conflict Minerals and the ultimate manufacture of our products. Accordingly, to gather information from our suppliers, we utilize a standard template for Conflict Minerals reporting designed by the Responsible Minerals Initiative ("RMI") known as the Conflict Minerals Reporting Template (the "CMRT"). We relied on our suppliers to complete the CMRT in order to provide information on the origin of the Conflict Minerals contained in Components supplied to us – including information regarding the sources of Conflict Minerals that are supplied to our suppliers from lower tiers in the chain (i.e., sub-suppliers). In addition, with respect to the certification of smelters or refiners as conflict-free, we have relied upon the latest findings of the RMI's Responsible Minerals Assurance Process (the "RMAP").

The RCOI undertaken by us in 2023 consisted of sending letters and CMRTs to 39 of our largest first-tier suppliers that we concluded were providing us with Components that do, or may, contain Conflict Minerals that are necessary for the functionality or production of our products and that accounted for approximately 85% of all our applicable 2023 product material expenditures. These suppliers include our turnkey suppliers, which means that they are in direct contact with our supply chain management team, and are considered to be our strategic partners, having long-term relationships with our Company. The letters we sent to such suppliers explained the Rule and referred the suppliers to online training materials and instructions, sought their support and cooperation in our efforts in connection with Conflict Minerals, provided a copy of our Conflict Minerals policy, and asked them to complete the CMRT. Working with a third-party service provider to conduct the survey and compile the survey results, we reviewed the responses and followed up as necessary by sending periodic reminders to non-responsive suppliers and following up on responses that appeared to be inconsistent, incomplete or inaccurate. In the end, the response rate from suppliers asked to participate was 89%.

Based on information obtained in the RCOI, and taking into account the complexities of our supply chain, we concluded that we did not have sufficient information to determine the country of origin of the Conflict Minerals in our products and were unable to rule out the possibility that Conflict Minerals used in our products originated, or may have originated, from the DRC or Covered Countries. Therefore, in accordance with the Rule, we undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of our products during 2023. There is significant overlap between our RCOI efforts and our due diligence measures performed.

Due Diligence

Design of Due Diligence Framework

Our due diligence measures have been designed, in all material respects, to conform as far as practicable with the internationally recognized due diligence framework prescribed by the Organization for Economic Co-operation and Development ("OECD"), known as "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas" and related supplements for Conflict Minerals (the "OECD Guidance").

Due Diligence Measures Performed

In substantial conformance with the OECD Guidance, our due diligence efforts for calendar year 2023 included the following steps:

Step 1. Establish Strong Company Management Systems

  • Conflict Minerals steering committee: A cross-functional Conflict Minerals steering committee operates our Conflict Minerals program. The committee consists of representatives from the following areas: operations (purchasing and engineering); and legal and compliance. Regular meetings of our Conflict Minerals steering committee were held, and the committee periodically updated representatives of our senior management on the status of the Conflict Minerals program.
  • Conflict Minerals Policy: Our Conflict Minerals policy (the "Policy"), adopted in 2015, has been communicated both throughout our Company and to suppliers, and is publicly available on our Company's website at: : https://www.novami.com/investors/cg/ under "Investors" —"Corporate Governance" – "Conflict Minerals".
  • Supplier engagement: We sent letters and CMRTs to a substantial portion of our first-tier suppliers identified during an applicability assessment phase as providing Components that do, or may, contain Conflict Minerals that are necessary for the functionality or production of our products. The aforementioned letters advised the suppliers of our commitment to responsible sourcing of minerals and indicated that their cooperation in the due diligence efforts is expected, including by completion of the CMRT.

In addition, we made training materials available to those first-tier suppliers that included an overview of the Rule and instructions on how to complete the CMRT survey.

For each purchase order issued by our computerized purchase order system for purchasing Components, suppliers are required to accept our terms and conditions, which include, among others, that (i) upon request, a supplier shall provide us with information regarding its products that contain Conflict Minerals, and (ii) in certain cases, we reserve the right to immediately terminate the purchase order and cease all procurement activity with the supplier.

Step 2. Identify and Assess Risks in the Supply Chain

We identified and assessed risk in our supply chain as follows: First, we identified our major first-tier (i.e., direct) suppliers that provide Components that potentially incorporate Conflict Minerals that are necessary to the functionality or production of our products that we manufactured, or contracted to manufacture, in 2023 (and which accounted for a substantial portion of all applicable expenditures on Components by our Company in 2023). We then requested information from relevant suppliers regarding the source and chain of custody of Conflict Minerals in their supply chain. To facilitate the collection of complete, accurate, standardized and verifiable information, we relied primarily on the CMRT, which seeks information regarding country of origin of Conflict Minerals, mine location and smelters or refiners used.

We reviewed suppliers' responses in order to track information regarding smelters or refiners of Conflict Minerals in our supply chain that have not received a conflict-free designation based on the RMAP.

Step 3. Design and Implement a Strategy to Respond to Identified Risks

We initiated a supply chain survey with selected suppliers using the CMRT in order to identify those smelters or refiners that supplied Conflict Minerals used in our products. We monitored and tracked our performance in this area by reviewing supplier responses. Each CMRT completed by a supplier was entered into a database maintained by a third-party service provider and reviewed. For suppliers that provided unclear or incomplete responses, an escalation process was used in order to obtain complete and accurate required information, sometimes requiring multiple telephone and/or email contacts to further the data collection process. Our Conflict Minerals steering committee held regular meetings to review progress and assess the risks identified.

In addition, smelters or refiners that were identified in the suppliers' responses were compared against the list of facilities that have received a conflict-free designation from the RMAP ("conflict-free" meaning generally that they did not directly or indirectly finance or benefit armed groups in the Covered Countries), and country of origin information for the smelters or refiners identified by the supply chain responses were reviewed using RMAP data. In accordance with our risk management plan, we contacted suppliers that have been identified as having non-certified smelters or refiners within the smelters or refiners list that they have provided to us.

Finally, representatives of our senior management were briefed about our due diligence efforts and findings on a regular basis.

Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices

We are several steps away in the supply chain from smelters or refiners that process the Conflict Minerals used in our products, do not have any direct relationships with such smelters or refiners and did not obtain from a third party or perform ourselves a direct audit of smelters or refiners within our supply chain. Instead, we relied on conflict-free designations based on the activities of other organizations such as the RMI (through the RMAP).

Step 5. Report Annually on Supply Chain Due Diligence

We report annually on our supply chain due diligence, as required by the Rule, and have posted our Form SD and Conflict Minerals Report on our website at: : https://www.novami.com/investors/cg/ under "Investors" —"Corporate Governance" – "Conflict Minerals".

Results of Assessment

On account of incomplete information, we are unable at this time to determine and describe with complete certainty in this report a complete list of either the facilities used to process the Conflict Minerals used in our products or the countries of origin of those Conflict Minerals. We have, nevertheless, described below the results of our assessment on the source of the Conflict Minerals, to the extent that we received information from our relevant suppliers through our due diligence efforts.

As indicated above, the products that we manufacture, or contract to manufacture, are highly complex, and typically contain thousands of Components from many suppliers. Because there are generally multiple tiers between the mines that extract Conflict Minerals and our suppliers, we relied on our suppliers to provide information on the origin of the Conflict Minerals contained in Components supplied to us.

In all, we surveyed 39 suppliers to whom we paid approximately 85% of the applicable expenditures by our Company on Component costs for our products in 2023. 89% of the suppliers whom we surveyed provided a complete response.

As part of our due diligence efforts and based on the information received from our suppliers, we identified 349 smelters or refiners of Conflict Minerals used generally in their supply chains, of which 64% have been certified as conflict free by the RMI's RMAP, and of which 1.15% are currently engaged in the RMI audit process. A list of these identified smelters or refiners is provided in Appendix A hereto.

Some suppliers were unable to provide a complete list of smelters or refiners. In addition, despite receiving information regarding smelters or refiners used generally by some suppliers in their supply chains, these suppliers were unable to report which smelters or refiners were part of the supply chain applicable to the specific Components that were sold to us. Furthermore, for the significant majority of smelters reported by these suppliers, there is inadequate information available to assess the source of the conflict minerals that they process. As a result, we are unable to identify with complete accuracy the country of origin of the Conflict Minerals used in our products in 2023 and we concluded in good faith that we lack sufficient information to trace the chain of custody of any Conflict Minerals contained in our products in 2023 up through the supply chain to a specific smelter or, in turn, to a country or mine of origin. We have, however, become aware that certain smelters or refiners from Covered Countries that have been identified as part of the supply chain of our suppliers have not been certified as conflict free under the RMI's RMAP. We have therefore activated our risk management procedures in respect of those smelters or refiners, and have approached the supplier that provided us the relevant Conflict Minerals sourced from those smelters or refiners and have asked for corrective action to be taken.

We furthermore note that information is not gathered from our suppliers on a continuous, real-time basis. We can therefore only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals used in our products, since the information comes from direct suppliers, not the underlying smelters or refiners, and is based on independent third-party audit programs, not our own auditing.

Continuous Efforts to Mitigate Risk

We intend to maintain our approach for responsible sourcing of the minerals used in our products and to continue to comply with any applicable regulations related to the sourcing of, and disclosure concerning, the Conflict Minerals that may be contained in our products.

Forward Looking Statements

Forward-looking statements in this Conflict Minerals Report are made pursuant to the safe harbor provisions of Section 21E of the Securities Exchange Act of 1934, as amended, and other federal securities laws. Investors are cautioned that statements in this Conflict Minerals Report that are not strictly historical statements, including without limitation, the Company's intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts and strategy, constitute forward looking statements that involve risks and uncertainties. Actual results could differ materially from the forward-looking statements. Words such as "expects," "anticipates," "intends," variations of these words, and similar expressions, are intended to identify such forward looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company's ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others. Except as otherwise required by law, the Company undertakes no obligation to update publicly the information contained in this Conflict Minerals Report, or any forward-looking statements, to reflect new information, events or circumstances after the date they were made, or to reflect the occurrence of unanticipated events.

Appendix A

List of Identified Smelters or Refiners

Smelter Metal Smelter Look-up (known smelters by RMI) Smelter Country
Gold Advanced Chemical Company UNITED STATES OF AMERICA
Gold Aida Chemical Industries Co., Ltd. JAPAN
Gold Agosi AG 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 Asaka Riken Co., Ltd. JAPAN
Gold Atasay Kuyumculuk
Sanayi Ve Ticaret A.S.
TURKEY
Gold Aurubis AG GERMANY
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES
Gold Boliden AB 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 Yunnan Copper Industry Co., Ltd. CHINA
Gold Chimet S.p.A. ITALY
Gold Chugai Mining JAPAN
Gold Daye Non-Ferrous Metals Mining Ltd. CHINA
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF
Gold Dowa JAPAN
Gold Eco-System Recycling Co., Ltd. East Plant JAPAN
Gold JSC Novosibirsk Refinery RUSSIAN FEDERATION
Gold Refinery of Seemine Gold Co., Ltd. CHINA
Gold Guoda
Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA
Gold LT Metal Ltd. KOREA, REPUBLIC OF
Gold Heimerle + Meule GmbH GERMANY
Gold Heraeus Metals Hong Kong Ltd. CHINA
Gold Heraeus Germany 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 Ishifuku Metal Industry Co., Ltd. JAPAN
Gold Istanbul Gold Refinery TURKEY
Gold Japan Mint JAPAN
Gold Jiangxi Copper Co., Ltd. CHINA
Gold Asahi Refining USA Inc. UNITED STATES OF AMERICA
Gold Asahi Refining Canada Ltd. CANADA
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION
Gold JSC Uralelectromed RUSSIAN FEDERATION
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN
Gold Kazakhmys Smelting LLC KAZAKHSTAN
Gold Kazzinc KAZAKHSTAN
Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA
Gold Kojima Chemicals Co., Ltd. JAPAN
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 LS-NIKKO Copper Inc. KOREA, REPUBLIC OF
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA
Gold Materion UNITED STATES OF AMERICA
Gold Matsuda Sangyo Co., Ltd. JAPAN
Gold Metalor
Technologies (Suzhou) Ltd.
CHINA
Gold Metalor Technologies (Hong Kong) Ltd. CHINA
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE
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 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 Nihon Material Co., Ltd. JAPAN
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN
OJSC "The Gulidov
Krasnoyarsk Non-Ferrous Metals Plant" (OJSC
Gold Krastsvetmet) RUSSIAN FEDERATION
Gold MKS PAMP SA SWITZERLAND
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA
Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION
Gold PT Aneka Tambang (Persero) Tbk INDONESIA
Gold PX Precinox S.A. SWITZERLAND
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA
Gold Royal Canadian Mint CANADA
Gold Sabin Metal Corp. UNITED STATES OF AMERICA
Gold Samduck Precious Metals KOREA, REPUBLIC OF
Gold Samwon Metals Corp. KOREA, REPUBLIC OF
Gold SEMPSA Joyeria Plateria S.A. SPAIN
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 SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION
Gold Solar Applied Materials Technology Corp. TAIWAN, PROVINCE OF CHINA
Gold Sumitomo Metal Mining Co., Ltd. JAPAN
Gold Super Dragon Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN
Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA
Gold Shandong Gold Smelting Co., Ltd. CHINA
Gold Tokuriki Honten Co., Ltd. JAPAN
Gold Tongling
Nonferrous Metals Group Co., Ltd.
CHINA
Gold Torecom KOREA, REPUBLIC OF
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 Yamakin Co., Ltd. JAPAN
Gold Yokohama Metal Co., Ltd. JAPAN
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA
Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA
Gold Morris and Watson NEW ZEALAND
Gold SAFINA A.S. CZECHIA
Gold Guangdong Jinding Gold Limited CHINA
Gold Umicore Precious Metals Thailand THAILAND
Gold Geib Refining Corporation UNITED STATES OF AMERICA
Gold MMTC-PAMP India Pvt., Ltd. INDIA
Gold KGHM Polska Miedz Spolka Akcyjna POLAND
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE
Gold Singway Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA
Gold Shandong Humon Smelting Co., Ltd. CHINA
Gold Shenzhen Zhonghenglong
Real Industry Co., Ltd.
CHINA
Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES
Gold Emirates Gold DMCC UNITED ARAB EMIRATES
Gold International Precious Metal Refiners UNITED ARAB EMIRATES
Gold Kaloti Precious Metals UNITED ARAB EMIRATES
Gold Sudan Gold Refinery SUDAN
Gold T.C.A S.p.A ITALY
Gold REMONDIS PMR B.V. NETHERLANDS
Gold Fujairah Gold FZC UNITED ARAB EMIRATES
Gold Industrial Refining Company BELGIUM
Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF
Gold Marsam Metals BRAZIL
Gold TOO Tau-Ken-Altyn KAZAKHSTAN
Gold Abington Reldan Metals, LLC UNITED STATES OF AMERICA
Gold SAAMP FRANCE
Gold L'Orfebre S.A. ANDORRA
Gold 8853 S.p.A. ITALY
Gold Italpreziosi ITALY
Gold WIELAND Edelmetalle GmbH GERMANY
Gold Ogussa Osterreichische Gold-
und Silber-Scheideanstalt GmbH
AUSTRIA
Gold AU Traders and Refiners SOUTH AFRICA
Gold GGC Gujrat Gold Centre Pvt. Ltd. INDIA
Gold Sai Refinery INDIA
Gold Modeltech Sdn Bhd MALAYSIA
Gold Bangalore Refinery INDIA
Gold Kyshtym Copper-Electrolytic Plant ZAO RUSSIAN FEDERATION
Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY
Gold Pease & Curren UNITED STATES OF AMERICA
Gold SungEel HiMetal Co., Ltd. KOREA, REPUBLIC OF
Gold Planta Recuperadora de Metales SpA CHILE
Gold Safimet S.p.A ITALY
State Research Institute Center for Physical Sciences and
Gold Technology LITHUANIA
Gold African Gold Refinery UGANDA
Gold NH Recytech Company KOREA, REPUBLIC OF
Gold QG Refining, LLC UNITED STATES OF AMERICA
Gold Dijllah Gold Refinery FZC UNITED ARAB EMIRATES
Gold Coimpa Industrial LTDA BRAZIL
Gold Dongwu Gold Group CHINA
Gold Gold by Gold Colombia COLOMBIA
Gold Value Trading BELGIUM
Gold WEEEREFINING FRANCE
Gold Metal Concentrators SA (Pty) Ltd. SOUTH AFRICA
Gold Metallix Refining Inc. UNITED STATES OF AMERICA
Gold MD Overseas INDIA
Gold Sellem Industries Ltd. MAURITANIA
Gold Sancus ZFS (L COLOMBIA
Gold Alexy Metals UNITED STATES OF AMERICA
Gold K.A. Rasmussen NORWAY
Gold Emerald Jewel Industry India Limited (Unit 4) INDIA
Gold Emerald Jewel Industry India Limited (Unit 3) INDIA
Gold Emerald Jewel Industry India Limited (Unit 2) INDIA
Gold Emerald Jewel Industry India Limited (Unit 1) INDIA
Gold Kundan Care Products Ltd. INDIA
Gold Augmont Enterprises Private Limited INDIA
Gold Eco-System Recycling Co., Ltd. West Plant JAPAN
Gold Eco-System Recycling Co., Ltd. North Plant JAPAN
Gold C.I Metales Procesados Industriales SAS COLOMBIA
Gold Sovereign Metals INDIA
Gold CGR Metalloys Pvt Ltd. INDIA
Gold DS PRETECH Co., Ltd. KOREA, REPUBLIC OF
Gold Gold Coast Refinery GHANA
Gold ABC Refinery Pty Ltd. AUSTRALIA
Gold JALAN & Company INDIA
Gold Morris and Watson Gold Coast AUSTRALIA
Gold Universal Precious Metals Refining Zambia ZAMBIA
Gold Metahub Industries Sdn. Bhd. MALAYSIA
Gold SAXONIA Edelmetalle GmbH GERMANY
Gold Albino Mountinho Lda. PORTUGAL
Gold Shenzhen CuiLu Gold Co., Ltd. CHINA
Gold Shirpur Gold Refinery Ltd. INDIA
Gold Republic Metals Corporation UNITED STATES OF AMERICA
Gold Faggi Enrico S.p.A. ITALY
Gold Umicore Brasil Ltda. BRAZIL
Gold So Accurate Group, Inc. UNITED STATES OF AMERICA
Gold Schone Edelmetaal B.V. NETHERLANDS
Gold OJSC Kolyma Refinery RUSSIAN FEDERATION
Gold Elemetal Refining, LLC UNITED STATES OF AMERICA
Gold Korea Metal Co., Ltd. KOREA, REPUBLIC OF
Gold DODUCO Contacts and Refining GmbH GERMANY
Gold Daejin Indus Co., Ltd. KOREA, REPUBLIC OF
Gold Bauer Walser AG GERMANY
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY
Gold Aktyubinsk Copper Company TOO KAZAKHSTAN
Gold KP Sanghvi International Airport INDIA
TANZANIA, UNITED REPUBLIC
Gold GG Refinery Ltd. OF
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA
Tantalum F&X Electro-Materials Ltd. CHINA
Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED CHINA
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA
Tantalum Jiujiang Tanbre Co., Ltd. CHINA
Tantalum AMG Brasil BRAZIL
Tantalum Metallurgical Products India Pvt., Ltd. INDIA
Tantalum Mineracao Taboca S.A. BRAZIL
Tantalum NPM Silmet AS ESTONIA
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA
Tantalum QuantumClean UNITED STATES OF AMERICA
Tantalum Yanling
Jincheng Tantalum & Niobium Co., Ltd.
CHINA
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 Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA
Tantalum D Block Metals, LLC UNITED STATES OF AMERICA
Tantalum FIR Metals & Resource Ltd. CHINA
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA
Tantalum KEMET de Mexico MEXICO
Tantalum TANIOBIS Co., Ltd. THAILAND
Tantalum TANIOBIS GmbH GERMANY
Tantalum Materion Newton Inc. UNITED STATES OF AMERICA
Tantalum TANIOBIS Japan Co., Ltd. JAPAN
Tantalum TANIOBIS Smelting GmbH & Co. KG GERMANY
Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA
Tantalum Global Advanced Metals Aizu JAPAN
Tantalum Resind Industria
e Comercio Ltda.
BRAZIL
Tantalum Jiangxi Tuohong New Raw Material CHINA
Tantalum PowerX Ltd. RWANDA
Tantalum XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD. CHINA
Tantalum 5D Production OU ESTONIA
Tantalum Yancheng Jinye
New Material Technology Co., Ltd.
CHINA
Tantalum V&D New Materials (Jiangsu) Co., Ltd. CHINA
Tantalum CP Metals Inc. UNITED STATES OF AMERICA
Tantalum Jiujiang Janny New Material Co., Ltd. CHINA
Tantalum RFH Metals & Chemicals Co., Ltd. CHINA
MACEDONIA, THE FORMER
Tantalum Power Resources Ltd. YUGOSLAV REPUBLIC OF
UNITED KINGDOM OF GREAT
Tantalum Avon Specialty Metals Ltd BRITAIN AND NORTHERN
Tantalum E.S.R. Electronics UNITED STATES OF AMERICA
Tantalum Tranzact, Inc. UNITED STATES OF AMERICA
Tantalum KEMET Blue Powder UNITED STATES OF AMERICA
Tantalum Taike Technology(Suzhou)Co.,Ltd. CHINA
Tantalum Plansee SE Reutte AUSTRIA
Tantalum H.C. Starck Hermsdorf GmbH GERMANY
Tantalum H.C. Starck GmbH Laufenburg GERMANY
Tantalum Plansee SE Liezen AUSTRIA
Tantalum Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch CHINA
Tantalum Yichun Jin Yang Rare Metal Co., Ltd. CHINA
Tantalum Zhuzhou Cemented Carbide Group Co., Ltd. CHINA
Tantalum King-Tan Tantalum Industry Ltd. CHINA
Tantalum Hi-Temp Specialty Metals, Inc. UNITED STATES OF AMERICA
Tantalum Exotech Inc. UNITED STATES OF AMERICA
Tantalum Duoluoshan CHINA
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. CHINA
Tantalum H.C. Starck GmbH GERMANY
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA
Tin Alpha UNITED STATES OF AMERICA
Tin PT Aries Kencana Sejahtera INDONESIA
BOLIVIA (PLURINATIONAL
Tin EM Vinto STATE OF)
Tin Estanho de Rondonia S.A. BRAZIL
Tin Fenix Metals POLAND
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA
Tin Gejiu Kai Meng Industry and Trade LLC CHINA
Tin China Tin Group Co., Ltd. CHINA
Tin Malaysia Smelting Corporation (MSC) MALAYSIA
Tin Metallic Resources, Inc. UNITED STATES OF AMERICA
Tin Minsur PERU
Tin Jiangxi New Nanshan Technology Ltd. CHINA
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND
BOLIVIA (PLURINATIONAL
Tin Operaciones Metalurgicas S.A. STATE OF)
Tin PT Artha Cipta Langgeng INDONESIA
Tin PT Babel Inti Perkasa INDONESIA
Tin PT Babel Surya Alam Lestari INDONESIA
Tin PT Belitung Industri Sejahtera INDONESIA
Tin PT Bukit Timah INDONESIA
Tin PT Mitra Stania Prima INDONESIA
Tin PT Panca Mega Persada INDONESIA
Tin PT Prima Timah Utama INDONESIA
Tin PT Refined Bangka Tin INDONESIA
Tin PT Sariwiguna Binasentosa INDONESIA
Tin PT Stanindo Inti Perkasa INDONESIA
Tin PT Timah Tbk Kundur INDONESIA
Tin PT Timah Tbk Mentok INDONESIA
Tin PT Tinindo Inter Nusa INDONESIA
Tin PT Tommy Utama INDONESIA
Tin Rui Da Hung TAIWAN, PROVINCE OF CHINA
Tin Thaisarco THAILAND
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA
Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. CHINA
Tin CV Venus Inti Perkasa INDONESIA
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL
Tin PT Tirus Putra Mandiri INDONESIA
Tin Melt Metais e Ligas S.A. BRAZIL
Tin PT ATD Makmur Mandiri Jaya INDONESIA
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy
Tin Joint Stock Company VIETNAM
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIETNAM
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIETNAM
Tin An Vinh Joint Stock Mineral Processing Company VIETNAM
Tin Super Ligas BRAZIL
Tin Aurubis Beerse BELGIUM
Tin Aurubis Berango SPAIN
Tin PT Sukses
Inti Makmur
INDONESIA
Tin PT Menara Cipta Mulia INDONESIA
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA
Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA
Tin PT Bangka Serumpun INDONESIA
Tin Pongpipat Company Limited MYANMAR
Tin Tin Technology & Refining UNITED STATES OF AMERICA
CONGO, DEMOCRATIC
Tin Mining Minerals Resources SARL REPUBLIC OF THE
Tin PT Putera Sarana Shakti (PT PSS) INDONESIA
Tin DS Myanmar MYANMAR
Tin Fabrica Auricchio Industria e Comercio Ltda. BRAZIL
Tin Rian Resources SDN. BHD. MALAYSIA
Tin Dragon Silver Holdings Limited CHINA
Tin CRM Synergies SPAIN
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos
Tin Do Brasil Ltda BRAZIL
Tin TRATHO Metal Quimica BRAZIL
Tin PT Mitra Sukses Globalindo INDONESIA
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. CHINA
Tin Precious Minerals and Smelting Limited INDIA
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. CHINA
Tin Luna Smelter, Ltd. RWANDA
Tin PT Rajawali
Rimba Perkasa
INDONESIA
Tin PT Masbro Alam Stania INDONESIA
Tin Ma'anshan Weitai Tin Co., Ltd. CHINA
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. CHINA
Tin PT Lautan Harmonis Sejahtera INDONESIA
Tin Gejiu Jinye
Mineral Company
CHINA
Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA
Tin
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
PT Kijang Jaya Mandiri
VIET NAM
INDONESIA
Tin An Thai Minerals Co., Ltd. VIET NAM
Tin PT O.M. Indonesia INDONESIA
Tin PT Cipta Persada Mulia INDONESIA
Tin CV Dua Sekawan INDONESIA
Tin PT Inti Stania Prima INDONESIA
Tin Phoenix Metal Ltd. RWANDA
Tin PT Wahana Perkit Jaya INDONESIA
Tin VQB Mineral and Trading Group JSC VIET NAM
Tin Soft Metais Ltda. BRAZIL
Tin PT Timah Nusantara INDONESIA
Tin PT Sumber Jaya Indah INDONESIA
Tin PT Seirama Tin Investment INDONESIA
Tin PT Koba Tin INDONESIA
Tin PT Karimun Mining INDONESIA
Tin PT Fang Di MulTindo INDONESIA
Tin PT Eunindo Usaha Mandiri INDONESIA
Tin PT DS Jaya Abadi INDONESIA
Tin PT BilliTin Makmur Lestari INDONESIA
Tin PT Bangka Timah Utama Sejahtera INDONESIA
Tin PT Bangka Putra Karya INDONESIA
Tin PT Bangka Kudai Tin INDONESIA
Tin PT Alam Lestari Kencana INDONESIA
Tin Novosibirsk Processing Plant Ltd. RUSSIAN FEDERATION
Tin Linwu Xianggui Ore Smelting Co., Ltd. CHINA
Tin Huichang Jinshunda
Tin Co., Ltd.
CHINA
Tin Feinhutte Halsbrucke GmbH GERMANY
Tin CV United Smelting INDONESIA
Tin PT Justindo INDONESIA
Tin CV Gita Pesona INDONESIA
Tin Cooperativa Metalurgica de Rond BRAZIL
Tin CNMC (Guangxi) PGMA Co., Ltd. CHINA
Tin Jiangxi Ketai Advanced Material Co., Ltd. CHINA
Tin Takehara PVD Materials Plant / PVD Materials Division of MITSUI
MINING & SMELTING CO., LTD.
JAPAN
Tin yunnan xi ye gufen youxian gongsi CHINA
Tin Malaysia Smelting Corporation Berhad (Port Klang) MALAYSIA
Tungsten A.L.M.T. Corp. JAPAN
Tungsten Kennametal Huntsville UNITED STATES OF AMERICA
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA
Tungsten Chongyi Zhangyuan
Tungsten Co., Ltd.
CHINA
Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA
Tungsten Hunan Jintai New Material Co., Ltd. CHINA
Tungsten Japan New Metals Co., Ltd. JAPAN
Tungsten Ganzhou Huaxing
Tungsten Products Co., Ltd.
CHINA
Tungsten Kennametal Fallon UNITED STATES OF AMERICA
Tungsten Wolfram Bergbau und Hutten AG AUSTRIA
Tungsten Xiamen Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Minmetals Gao'an
Non-ferrous Metals Co., Ltd.
CHINA
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA
Tungsten Jiangxi Tonggu
Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA
Tungsten Ganzhou Seadragon
W & Mo Co., Ltd.
CHINA
Tungsten Asia Tungsten Products Vietnam Ltd. VIETNAM
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten
Tungsten Products Branch CHINA
Tungsten H.C. Starck Tungsten GmbH GERMANY
Tungsten Masan High-Tech Materials VIET NAM
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA
Tungsten Niagara Refining LLC UNITED STATES OF AMERICA
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES
Tungsten ACL Metais Eireli BRAZIL
Tungsten Moliren Ltd. RUSSIAN FEDERATION
Tungsten HANNAE FOR T Co., Ltd. KOREA, REPUBLIC OF
Tungsten YUDU ANSHENG TUNGSTEN CO., LTD. CHINA
Tungsten LLC Vostok RUSSIAN FEDERATION
Tungsten OOO RUSSIAN FEDERATION
Tungsten Fujian Xinlu Tungsten CHINA
Tungsten Ganzhou Sunny Non-Ferrous Metals Co., Ltd. CHINA
Tungsten Artek LLC RUSSIAN FEDERATION
Tungsten Cronimet Brasil Ltda BRAZIL
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. BRAZIL
Tungsten GEM Co., Ltd. CHINA
Tungsten NPP Tyazhmetprom LLC RUSSIAN FEDERATION
Tungsten JSC "Kirovgrad
Hard Alloys Plant"
RUSSIAN FEDERATION
Tungsten Lianyou Metals Co., Ltd. TAIWAN, PROVINCE OF CHINA
Tungsten Fujian Ganmin RareMetal Co., Ltd. CHINA
Tungsten KGETS Co., Ltd. KOREA, REPUBLIC OF
Tungsten Hunan Litian
Tungsten Industry Co., Ltd.
CHINA
Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA
Tungsten South-East Nonferrous Metal Company Limited of Hengyang City CHINA
Tungsten Jiangxi Dayu Longxintai Tungsten Co., Ltd. CHINA
Tungsten China Molybdenum Co., Ltd. CHINA
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin CHINA
Tungsten Sanher
Tungsten Vietnam Co., Ltd.
VIETNAM
Tungsten Ganzhou Yatai Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CHINA
Tungsten Pobedit, JSC RUSSIAN FEDERATION
Tungsten Ganxian Shirui
New Material Co., Ltd.
CHINA
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd. CHINA
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd. VIETNAM
Tungsten Tejing
(Vietnam) Tungsten Co., Ltd.
VIETNAM
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd. CHINA
Tungsten Ganzhou Grand Sea W & Mo Group Co Ltd CHINA
Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA
Tungsten Dayu Weiliang
Tungsten Co., Ltd.
CHINA
Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. CHINA
Tungsten Kenee Mining Corporation Vietnam VIETNAM