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ORMAT TECHNOLOGIES, INC. — Environmental & Social Information 2021
May 30, 2021
6968_rns_2021-05-30_310f7474-3e47-439b-83d5-513ded8fee99.pdf
Environmental & Social Information
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Ormat Technologies, Inc.
(Exact name of registrant as specified in its charter)
State or other jurisdiction of incorporation or organization)
Delaware 001-32347 88-0326081 (Commission file number) (IRS Employer Identification No.)
6140 Plumas Street, Reno, Nevada 89519-6075 (Address of principal executive offices) (Zip Code)
Assaf Ginzburg, CFO (775) 356-9029
(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:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.
Section 1 – Conflict Minerals Disclosure
1.01– Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Specialized Disclosure Report on Form SD (this "Form SD") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the reporting period from January 1, 2020 to December 31, 2020 is presented to comply with Rule 13p-1 ("Rule 13p-1") promulgated under the Exchange Act of 1934, as amended (the "Exchange Act"). In accordance with Rule 13p-1 and our Conflict Minerals Policy, published at:
https://www.ormat.com/Warehouse/userUploadFiles/Image/Ormat%20Conflict%20Minerals%20Policy.pdf, we have concluded, in good faith, that during the 2020 calendar year, (i) we have manufactured and contracted to manufacture products (the "Covered Products") containing Conflict Minerals, and, for which (ii) the use of these minerals is necessary to the functionality or production of such products. Based on our good faith reasonable country of origin inquiry, the Company has reason to believe that Conflict Minerals necessary to the functionality or production of the Covered Products may have originated in the Democratic Republic of the Congo (the "DRC") and certain adjoining countries (collectively with the DRC, the "Covered Countries") and that such Conflict Minerals may not be entirely from recycled or scrap sources. As defined by the Rule 13p-1, and for the purposes of this Conflict Minerals Report (the "Report"), the Conflict Minerals are cassiterite, columbitetantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, the "Conflict Minerals" or "3TG").
On the basis of these conclusions, the Company proceeded to exercise due diligence on its minerals supply chain in order to determine, with a reasonable degree of certainty given the information provided by our suppliers, the source and chain of custody of the Conflict Minerals contained in its Covered Products that were manufactured or contracted to manufacture in 2020. Therefore, and in order to present our findings, the Company submits this Report as an exhibit to this Form SD for the reporting period from January 1, 2020 to December 31, 2020. The Report describes the Conflict Minerals due diligence that the Company has designed and performed, which was designed according to the Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) and related Supplements (the "OECD Due Diligence Guidance"). The Report has not been subject to an independent private sector audit.
Based on the information obtained by the Company during the due diligence process, the Company does not have sufficient information, with respect to the Covered Products, to determine the country of origin, or likely country of origin, for each of the Conflict Minerals in each of the Covered Products. However, based on the information that has been obtained during the due diligence process, to the extent reasonably determinable by the Company with respect to the smelters or refiners identified by the Company's suppliers, the likely countries of origin of the Conflict Minerals used in Covered Products in 2020 are listed in Annex 2 to the Company's Report, attached to this Form SD as Exhibit 1.01.
Copies of this Form SD and the Report are also published on a publicly available Internet site at
https://investor.ormat.com/sec-filings/documents/sec-filings-details/default.aspx?FilingId=14182469
. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference herein.
Item 1.02 – Exhibit See Exhibit 1.01 – Conflict Minerals Report.
Section 2 – Exhibits Item 2.01 Exhibits
List below the following exhibit filed as part of this report.
Exhibit 1.01 – Conflict Minerals Report for Ormat Technologies, Inc.
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.
ORMAT TECHNOLOGIES, INC. By: /s/Assaf Ginzburg Name: Assaf Ginzburg Title: Chief Financial Officer Date: May 28, 2021
Conflict Minerals Report of Ormat Technologies, Inc. For the Year Ended December 31, 2020
Introduction:
We are a Delaware corporation, whose shares of common stock are listed on the New York Stock Exchange and on the Tel Aviv Stock Exchange and are registered with the Securities and Exchange Commission (the "SEC").
We are a leading vertically integrated company, that is primarily engaged in the geothermal and recovered energy-based power businesses. Ormat leveraged its core capabilities and global presence to expand its activity into different energy storage services and solar photovoltaic (PV) (including hybrid geothermal and solar PV as well as energy storage plus Solar PV).
Ormat aims to become a leading global provider of renewable energy and has adopted a strategic plan to focus on several key initiatives to expand its business.
This is the Conflict Minerals Report (this "Report") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the reporting period from January 1, 2020 to December 31, 2020, which has been prepared in accordance with Rule13p-1 ("Rule 13p-1"), promulgated under the Securities Exchange Act of 1934, as amended (the "Exchange Act"). Rule 13p-1 requires every registrant that files reports with the SEC under Sections 13(a) or 15 (d) of the Exchange Act to disclose certain information when the registrant manufactures or contracts to manufacture products and when the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The specified minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, the "Conflict Minerals" or "3TG"), that originate, or are likely originate, in the Democratic Republic of the Congo (the "DRC") and certain adjoining countries (collectively with the DRC, the "Covered Countries"). As part of the Company's desire to take responsibility for and concern itself with human rights issues, the Company decided to review its supply chain according to the EU regulation's guidance, and within that have included conflict-affected or high-risk areas ("CAHRAs") when approaching suppliers for information.
As part of Ormat's sustainability approach, our Code of Conduct outlines the Company's overall principles and commitments to legal compliance, ethical conduct, human rights, anti-corruption, labor rights and environmental protection. These high expectations extend to Ormat's partners, subcontractors and suppliers. We have adopted a policy (the "Conflict Minerals Policy") with respect to our sourcing of Conflict Minerals, which was developed in accordance with the OECD guidance, and we implement a comprehensive Conflict Minerals program aimed to ensure responsible sourcing. Our Conflict Minerals Policy is available at http://www.ormat.com/social-responsibility-and-sustainability.
Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in Rule 13p-1 and Form SD.
1. Overview
Company Overview
Ormat and its subsidiaries currently conduct business activities in the following three business segments:
- Electricity Segment: In this segment, we develop, build, own and operate geothermal, solar PV and recovered energy-based power plants in the United States and geothermal power plants in other countries around the world and sell the electricity they generate.
- Product Segment: In this segment, we design, manufacture and sell equipment for geothermal and recovered energy-based electricity generation and remote power units and provide services relating to the engineering, procurement, and construction of geothermal, and recovered energy-based power plants.
- Energy Storage Segment: In this segment, we mainly provide energy storage, related services, as well as services relating to the engineering, procurement, construction, operation and maintenance of energy storage units.
Our customers for the Product segment are contractors, geothermal power plant owners and geothermal power plant developers and operators.
For more information about Ormat, please visit www.ormat.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein
Supply Chain
In accordance with applicable SEC rules, we conducted due diligence on the source and chain of custody of the Conflict Minerals used in our Product Segment. We concluded that no such examination is necessary with respect to the Electricity Segment or the Energy Storage and Management Services Segment because neither of these segments involves the sale of products by the Company.
In connection with our manufacturing activities in the Product Segment, we identified certain Conflict Minerals that are used by us and that are necessary to the functionality and production of our products with regards to the following raw materials or components: steel (low and high grade), electronic cards and electronic cables (including tin plating). These materials are purchased from our network of suppliers. As a downstream company that does not work directly with the smelters or refiners of the necessary Conflict Minerals, we work with our large network of international suppliers to obtain information on the likely source and chain of custody of those necessary Conflict Minerals and often there are multiple tiers between the gold, tin, tantalum and tungsten ("3TG") mines and our direct suppliers. Therefore, we rely on our direct Tier 1 suppliers to cooperate with us and work with their own upstream suppliers or subcontractors to provide us with information on the origin of the 3TG in the components we purchase from them that are necessary to the functionality or production of our products. In order to overcome certain challenges in receiving accurate information from a complex supply chain, Ormat has communicated its Conflict Minerals Policy to our suppliers, and has adopted the Responsible Minerals Initiative's ("RMI") reporting template for surveying suppliers, i.e. the Conflict Minerals Reporting Template ("CMRT") of at least version 6.01or above.
2. Reasonable Country of Origin Inquiry (RCOI)
Ormat has conducted a reasonable country of origin inquiry ("RCOI") in good faith to determine whether any of the necessary Conflict Minerals originated, or likely originated, in the DRC or Covered Countries or originated entirely from "recycled or scrap sources" (as such terms are defined in Rule 13p-1). In parallel, we conduct due diligence on our mineral supply chain in order to investigate, to a reasonable degree of accuracy, the likely source and chain of custody of the necessary Conflict Minerals used in our products or product components that is sourced from our global network of suppliers.
As part of our RCOI, we employed several methods to assess whether the necessary Conflict Minerals in our products originated, or likely originated, in the DRC or the Covered Countries, including the following:
- Conducted an internal assessment and analysis of our products manufactured or contracted to manufacture in 2020 to determine which products contain or may contain Conflict Minerals that are necessary to the functionality or production of those products.
- Compiled a list of applicable suppliers based on relevant product categories that Ormat purchased from during the calendar year 2020, which list was issued using the Ormat Management System ("OMS") by information technology developers and according to the criteria defined by the OMS manager and the purchasing manager. The list include[d?] a total of 1,296 suppliers. Each supplier has a "Purchase Types" field, which contains one of the following values: Services, BOM, Office supplier, Goods and Capital Expenditure. Only the suppliers with "BOM" values in the "Purchase Types" field were applicable for the RCOI under Rule 13p-1.
- In order to identify and assess risks in the supply chain, we undertook a risk-based approach and engaged the suppliers representing approximately 90% of our 2020 expenditures on procurement for the Product Segment. On that basis, Ormat's final direct Tier 1 suppliers list ("relevant suppliers") include[d?] a total of 122 suppliers, from which duplicate suppliers were removed to arrive at a total of 115 relevant suppliers for the calendar year 2020 supply chain inquiry.
- Contracted a third-party service provider to assist us with the survey of suppliers. Through this third-party service provider, we sent letters to our relevant suppliers to explain Rule 13p-1 and to refer the suppliers to online training materials and instructions.
- Solicited information from our relevant suppliers of raw materials and components of products using the standard template of the independent third-party audit body, the Responsible Minerals Initiative ("RMI"), known as the Conflict Minerals Reporting Template ("CMRT"). We requested that our suppliers provide at least version 6.01 of the CMRT. The CMRT is designed to facilitate the transfer of information through the supply chain regarding each mineral's country of origin, or likely country of origin, and the relevant smelters or refiners. The CMRT requires suppliers to make representations regarding: (i) the country of origin, or likely country of origin, for the Conflict Minerals contained in the components or products it provides to the Company; (ii) all of the smelters or refiners in the supplier's supply chain for such Conflict Minerals; (iii) whether such smelters or refiners have been validated as being in compliance with the RMI's Responsible Minerals Assurance Process (the "RMAP"); (iv) whether the supplier has its own Conflict Minerals Policy that requires its own direct suppliers to be "DRC conflict-free"; and (v) whether the supplier collects Conflict Minerals information in a standardized format, such as the CMRT, from its own suppliers. Communications from the Company to its suppliers and responses received from the suppliers are stored electronically by the Company, together with copies of internal communications that relate to the Company's due diligence, for a period of up to five years, as recommended by the relevant OECD Guidance.
- Reviewed the responses that we received and followed up on inconsistent, incomplete, and inaccurate responses. We sent reminders to suppliers who did not respond to our requests for information or to suppliers whose responses required further clarification, as per the expectations noted above. We compared information received from our direct suppliers on their relevant smelters or refiners against the list of facilities that have been validated by RMAP, receiving a "conformant" or "active" status, as well as the documented country of origin information as provided in the declarations from the suppliers. The complete list of smelters or refiners identified in the scope of our supply chain inquiry is included as Annex 1 hereto and the complete list of counties of origin, or likely countries of origin, to the best of our knowledge, is included in Annex 2 hereto.
Currently, we do not have sufficient information from our suppliers to determine the complete list of countries of origin of 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 Covered Countries or are not entirely from recycled or scrap sources.
Based on these results, Ormat conducted due diligence activities and described these activities in this Report.
3. Due Diligence Framework
We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten We design our due diligence measures according to the recommendations of the OECD Guidance for downstream companies that have no direct relationships to smelters or refiners.
4. Due Diligence Measures
Our due diligence efforts for the reporting period from January 1, 2020 to December 31, 2020 included the following steps:
4.1 Establish strong Company management systems for Conflict Minerals supply chain due diligence and reporting compliance
The Company implemented the following measures:
- Established a cross-functional Conflict Minerals steering committee comprised of representatives from procurement, legal and finance departments to direct the overall efforts of the Conflict Minerals compliance program, with the Senior Vice President of Finance as the process owner.
- Continued to implement our Conflict Minerals Policy with respect to sourcing of minerals from the DRC and the Covered Countries. Our Conflict Minerals Policy provides further clarification to the principles of the Code of Conduct and Ormat's Human Rights Approach, as outlined in our Human Rights & Labor Policy, regarding illegal trade of natural resources and promotes the procurement of minerals from credible and conflict-free sources. Pursuant to our Conflict Minerals Policy, we strive to ensure that purchased metals originate only from smelters or refiners that have been validated as being "conformant" or "active" by the RMI's RMAP; however the Company does not seek to eliminate sourcing from the DRC, Covered Countries or CAHRAs. In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and encourage them to define, implement and communicate to their sub-suppliers their own policies outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. The Company's Conflict Minerals Policy is available at: http://www.ormat.com/social-responsibility-and-sustainability.
- Maintain a grievance mechanism through which concerns and violations of the Conflict Minerals Policy can be reported to Ormat:
- online via our website www.ormat.com; or
- by electronic mail to the following address: [email protected].
- Strengthened our engagement with suppliers by referring suppliers to training materials that included an overview of the applicable SEC rules and instructions on how to respond to the survey.
- Required our suppliers to provide us the information required to perform our analysis of Conflict Minerals.
- Implemented a requirement to maintain records relating to Conflict Minerals due diligence and responsible mineral sourcing for a minimum of five years.
4.2 Identify and assess risks in the supply chain
To identify risks in our supply chain, we undertook the following measures:
- We identified two risks in the supply chain: (i) the risk of not receiving timely and accurate information from the supplier; and (ii) the risk of not being able to replace a supplier, when aiming to move towards the goal of responsible sourcing of Conflict Minerals to ensure that the purchase and sourcing of such minerals does not benefit or fund the armed conflict and human rights abuses on-going in the DRC, Covered Countries, CAHRAs or in other conflict-affected areas. We have segmented our suppliers into three risk levels (high, medium and low) by referring to Conflict Minerals-related risks based on suppliers' characteristics, including the extent to which the Company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers. This segmentation allowed us to focus our risk mitigation efforts according to the supplier level of risk.
- As part of the risk assessment phase, Ormat decided to focus on the top approximately 90% of the purchasing spend in 2020. We have determined that, out of the responses received, 61.7% of Ormat's relevant suppliers have a policy in place that addresses the sourcing of Conflict Minerals.
- Responses received were subject to a "red flag" review. Responses that we identified as incomplete or inconsistent based on the red flag review process were marked for follow up. We identified the smelters or refiners that are likely a part of our mineral supply chain by conducting a supply chain survey using the CMRT (at least version 6.01 or higher), requesting suppliers to identify relevant smelters or refiners and country of origin, or likely country of origin, of the Conflict Minerals in products supplied to Ormat in 2020. In addition, we compared smelters and refiners identified by the supply chain survey against the list of facilities that received RMAP's "conformant" and "active" designations. The RMAP is a program in which the RMI works with independent third-party auditors or crosscertification programs to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters and refiners that agree to undergo an audit or to take part in a cross-certification program.
- A smelter or refiner receives an RMAP "conformant" designation from the RMI if the smelter or refiner (i) completes an independent third-party audit, (ii) adheres to the RMAP's assessment protocols by disclosing to auditors the identities and locations of the mines from which it sources Conflict Minerals, (iii) has been found by its independent third-party auditor to possess the systems and processes to support responsible sourcing of Conflict Minerals and can provide evidence to support its sourcing activities and (iv) maintains good standing in the program, through a continual validation process. The RMI's RMAP "conformant" list provides the names, locations and links to Conflict Minerals policies of all smelters and refiners deemed compliant with the RMAP's assessment protocols. Smelters and refiners with a "re-audit in progress" are still considered to be RMAP "conformant."
- Smelters and refiners labeled as RMAP "active" by the RMI have committed to undergo an audit, which may be in progress, or are participating in one of the cross-recognized certification programs, namely, the London Bullion Market Association Responsible Gold Certification or Responsible Jewelry Program Chainof-Custody Certification. "Active" smelters and refiners may be at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase. They may not retain their "active" status if, among other things, they are unresponsive to requests for re-audit or corrective action past a certain time.
- Companies that have been determined to be downstream of smelters or refiners may not take part in the RMAP. However, they may participate in the RMI's Downstream Audit Program, an independent validation of companies' sourcing practices outside of the RMAP audit process.
4.3 Design and implement a strategy to respond to identified risks
To address the risks in our supply chain, Ormat maintains a risk mitigation plan, which includes the following:
- Ormat expects its suppliers to define, implement and communicate to sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, and legal compliance and measures for implementation. We also ask suppliers to work with sub-tier suppliers to ensure traceability of these materials at least to the smelter or refiner level (e.g., by using a recent version of the CMRT).
- Ormat's senior management, including the CEO, CFO and Chief Compliance Officer, President Head of Products and Operations, EVP Electricity Segment, EVP Energy Storage and Business Development, and the Legal Counsel , was updated with the risk analysis and risk management actions and outcomes.
- Suppliers who provided incomplete or inconsistent responses were sent a corrective action letter for follow up, requesting clarification.
- Suppliers that did not respond to our initial survey request were sent follow-up letters requesting that they provide the necessary information.
- Should the Company find uncertified SoRs in its suppliers' responses, it will follow up with the supplier and ask for further clarifications or corrective action plans
Supply chain due diligence is a dynamic process that requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process and update the risk mitigation strategy accordingly.
4.4 Carry out independent third-party audit of smelter/refiner's due diligence practices
We do not typically have direct relationships with 3TG smelters or refiners of Conflict Minerals and therefore do not perform direct audits of these entities. As a result, our due diligence efforts relied on independent third-party audit body and cross- industry initiatives, such as those led by the RMI, to conduct smelter or refiner due diligence.
4.5 Report annually on supply chain due diligence
Our Conflict Minerals Policy was adopted with a view to assuring compliance with Section 1502 of the Dodd Frank Act, which requires the filing of a Form SD and this Report with the SEC and disclosure of them on its publicly available Internet website. The Company's Conflict Minerals Reports can be viewed at: https://d18rn0p25nwr6d.cloudfront.net/CIK-0001296445/f4ff3164-7606-4d15-ac83-7643b36391cd.pdf
5 The Company's Due Diligence Findings and Conclusions
We conducted a supply-chain survey of the 115 relevant suppliers that we identified as potentially contributing the necessary Conflict Minerals contained in our products in 2020. The overall response rate to this survey was approximately 50%. The responses included the names and locations of smelters or refiners (see Annex 1) and possible countries of origin, according to the information provided in our suppliers' declarations (see Annex 2).
As a downstream purchaser of products which contain conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. Our supply chain is complex and there are multiple tiers between the Company and the mines or facilities that process the necessary Conflict Minerals. Accordingly, we rely on our suppliers to provide information on the origin of the 3TG contained in components that are supplied to us to be included in our products.
Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers and the entire supply chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners. We ask that the data cover the entire reporting year, and we seek to use contract provisions requiring the suppliers to promptly update us in the event that the sourcing data changes.
Despite receiving responses from suppliers listing smelter or refiner names in their supply chain, the suppliers were unable to conclusive determine the specific smelters or refiners that were part of the supply chain of the components sold to Ormat in 2020.
In light of inconclusive information, we are unable to determine and to describe the full list of facilities used to process 3TG in the Covered Products or their countries of origin.
Smelters or refiners verified as RMAP Conformant or Active:
| Tantalum | 37 of 38 (97.4%) |
|---|---|
| Tin | 48 of 58 (82.75%) |
| Tungsten | 43 of 49 (87.75%) |
| Gold | 108 of 153 (70.59%) |
| Total | 236 of 298 (79.19%) |
Status of identified smelters or refiners:
| 2020 | |
|---|---|
| "RMAP Conformant" | 229 |
| "RMAP Active" | 7 |
| "Not RMAP Conformant or Active" | 62 |
| Total | 298 |
6. Steps to be taken to mitigate risk
The Company has taken, and intends to continue to take, steps to improve its due diligence processes. Due diligence is an ongoing, proactive and reactive process, and the Company is continually working to improve its methods and processes for identifying the source or likely source of the Conflict Minerals contained in its Covered Products. The Company plans to continue to inform suppliers of their role in the Company's Conflict Minerals compliance program and to engage its suppliers to obtain current, accurate and complete information regarding their mineral supply chains. The Company intends to monitor the performance and efficiency of its due diligence efforts to ensure responsible sourcing in compliance with its Conflict Minerals Policy and increase transparency in its supply chain.
Specific steps the Company has taken and continues to take to manage risks include:
- Continue to work with our global supply chain to obtain current, accurate and complete information about the supply chain, ensure responsible sourcing, while also assuring compliance with certain international regulations.
- Continue to strengthen communications with suppliers in order to improve the number of suppliers that respond to the company's supply chain surveys and requests for information.
- Continue to improve due diligence efforts to ensure responsible sourcing in compliance with the Conflict Minerals Policy.
- Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts.
Cautionary Note Concerning Forward- Looking Statements
Information provided in this Report may contain statements relating to current expectations and plans that are "forward- looking statements" as defined in the Private Securities Litigation Reform Act of 1995. These forward- looking statements generally relate to Ormat's plans, objectives and expectations for future plans and events and are based upon its management's current estimates. These statements are subject to risks and uncertainties and may not prove to be accurate. These risks and uncertainties include those 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 our ability to verify the accuracy or completeness of any supply chain information provided by suppliers and other factors discussed under the heading "Risk Factors" as described in Ormat Technologies, Inc.'s Annual Report on Form 10- K filed with the Securities and Exchange Commission on February 26, 2021 and other documents subsequently filed with or furnished to the U.S. Securities and Exchange Commission. These forward- looking statements are made only as of the date hereof, and, except as required by applicable law, we undertake no obligation to update or revise the forward- looking statements, whether as a result of new information, future events or otherwise.
Annex 1- Smelter or Refiner Names in Supply Chain
| Metal | Smelter Name | Smelter Country | Smelter Status |
|---|---|---|---|
| Gold | 8853 S.p.A. | ITALY | Conformant |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Not certified |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant |
| Gold | African Gold Refinery | UGANDA | Not certified |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Conformant |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
| Gold | Asahi Pretec Corp. | JAPAN | Conformant |
| Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Not certified |
| Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant |
| Gold | Augmont Enterprises Private Limited | INDIA | Active |
| Gold | Aurubis AG | GERMANY | Conformant |
| Gold | Bangalore Refinery | INDIA | Conformant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
| Gold | Boliden AB | SWEDEN | Conformant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
| Gold | Caridad | MEXICO | Not certified |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant |
| Gold | CGR Metalloys Pvt Ltd. | INDIA | Not certified |
| Gold | Chimet S.p.A. | ITALY | Conformant |
| Gold | Chugai Mining | JAPAN | Conformant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not certified |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not certified |
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | Not certified |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant |
| Gold | Dowa | JAPAN | Conformant |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant |
|---|---|---|---|
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Not certified |
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | Not certified |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Not certified |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not certified |
| Gold | Guangdong Jinding Gold Limited | CHINA | Not certified |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not certified |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not certified |
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Active |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | Not certified |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | Not certified |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | Active |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | Istanbul Gold Refinery | TURKEY | Conformant |
| Gold | Italpreziosi | ITALY | Conformant |
| Gold | Japan Mint | JAPAN | Conformant |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Not certified |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Not certified |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not certified |
| Gold | Kazzinc | KAZAKHSTAN | Conformant |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Conformant |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Not certified |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Not certified |
|---|---|---|---|
| Gold | Lingbao Gold Co., Ltd. | CHINA | Not certified |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not certified |
| Gold | L'Orfebre S.A. | ANDORRA | Conformant |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not certified |
| Gold | Marsam Metals | BRAZIL | Conformant |
| Gold | Materion | UNITED STATES OF AMERICA | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant |
| Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
| Gold | Modeltech Sdn Bhd | MALAYSIA | Not certified |
| Gold | Morris and Watson | NEW ZEALAND | Not certified |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | Not certified |
| Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
| OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC | |||
| Gold | Krastsvetmet) | RUSSIAN FEDERATION | Conformant |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant |
| Gold | PAMP S.A. | SWITZERLAND | Conformant |
| Gold | Pease & Curren | UNITED STATES OF AMERICA | Not certified |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not certified |
| Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
| Gold | PX Precinox S.A. | SWITZERLAND | Conformant |
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | Not certified |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
|---|---|---|---|
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Not certified |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | Conformant |
| Gold | Royal Canadian Mint | CANADA | Conformant |
| Gold | SAAMP | FRANCE | Conformant |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Not certified |
| Gold | Safimet S.p.A | ITALY | Conformant |
| Gold | SAFINA A.S. | CZECHIA | Conformant |
| Gold | Sai Refinery | INDIA | Not certified |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | Not certified |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant |
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | Not certified |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not certified |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Gold | Sovereign Metals | INDIA | Not certified |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Not certified |
| Gold | Sudan Gold Refinery | SUDAN | Not certified |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | T.C.A S.p.A | ITALY | Conformant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not certified |
| Gold | Tony Goetz NV | BELGIUM | Not certified |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant |
| Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
| Gold | Umicore Brasil Ltda. | BRAZIL | Not certified |
| Gold | Umicore Precious Metals Thailand | THAILAND | Conformant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
|---|---|---|---|
| Gold | Valcambi S.A. | SWITZERLAND | Conformant |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
| Gold | Yamakin Co., Ltd. | JAPAN | Conformant |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not certified |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA | Not certified |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant |
| Tantalum | H.C. Starck Ltd. | JAPAN | Conformant |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | KEMET Blue Metals | MEXICO | Conformant |
| Tantalum | LSM Brasil S.A. | BRAZIL | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
| Tantalum | NPM Silmet AS | ESTONIA | Conformant |
|---|---|---|---|
| MACEDONIA, THE FORMER YUGOSLAV | |||
| Tantalum | Power Resources Ltd. | REPUBLIC OF | Conformant |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium | |||
| Tantalum | Co., Ltd. | CHINA | Conformant |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
| Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Not certified |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | Not certified |
| Tin | Dowa | JAPAN | Conformant |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint | |||
| Tin | Stock Company | VIET NAM | Not certified |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | Estanho de Rondonia S.A. | BRAZIL | Active |
| Tin | Fenix Metals | POLAND | Conformant |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd." | CHINA | Not certified |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Conformant |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | Conformant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
|---|---|---|---|
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
| Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
| Tin | Metallo Spain S.L.U. | SPAIN | Conformant |
| Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tin | Minsur | PERU | Conformant |
| Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Tin | Modeltech Sdn Bhd | MALAYSIA | Not certified |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Not certified |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | Pongpipat Company Limited | MYANMAR | Not certified |
| Tin | Precious Minerals and Smelting Limited | INDIA | Not certified |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
| Tin | PT Bangka Serumpun | INDONESIA | Conformant |
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | Not certified |
| Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
| Tin | PT Timah Tbk Kundur | INDONESIA | Conformant |
| Tin | PT Timah Tbk Mentok | INDONESIA | Conformant |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tin | Soft Metais Ltda. | BRAZIL | Conformant |
| Tin | Super Ligas | BRAZIL | Active |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | Conformant |
| Tin | Thaisarco | THAILAND | Conformant |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Not certified |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tin | Yunnan Tin Company Limited | CHINA | Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tungsten | A.L.M.T. Corp. | JAPAN | Conformant |
| Tungsten | ACL Metais Eireli | BRAZIL | Conformant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
|---|---|---|---|
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not certified |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | Active |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | Conformant |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Not certified |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Not certified |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not certified |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | Active |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | Conformant |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Conformant |
|---|---|---|---|
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Not certified |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Conformant |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Not certified |
Annex 2- Country of Origin (COO) Inquiry Results*
| GOLD | TANTALUM | TIN | TUNGSTEN |
|---|---|---|---|
| ANDORRA | BRAZIL | BELGIUM | AUSTRIA |
| AUSTRALIA | CHINA | BOLIVIA (PLURINATIONAL STATE OF) | BRAZIL |
| AUSTRIA | ESTONIA | BRAZIL | CHINA |
| BELGIUM | GERMANY | CHINA | GERMANY |
| BRAZIL | INDIA | INDIA | JAPAN |
| CANADA | JAPAN | INDONESIA | KOREA, REPUBLIC OF |
| CHILE | KAZAKHSTAN | JAPAN | PHILIPPINES |
| CHINA | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | MALAYSIA | RUSSIAN FEDERATION |
| CZECHIA | MEXICO | MYANMAR | TAIWAN, PROVINCE OF CHINA |
| FRANCE | RUSSIAN FEDERATION | PERU | UNITED STATES OF AMERICA |
| GERMANY | THAILAND | PHILIPPINES | VIET NAM |
| INDIA | UNITED STATES OF AMERICA | POLAND | |
| INDONESIA | SPAIN | ||
| ITALY | TAIWAN, PROVINCE OF CHINA | ||
| JAPAN | THAILAND | ||
| KAZAKHSTAN | UNITED STATES OF AMERICA | ||
| KOREA, REPUBLIC OF | Vietnam | ||
| KYRGYZSTAN | |||
| LITHUANIA |
| MALAYSIA | ||
|---|---|---|
| MEXICO | ||
| NETHERLANDS | ||
| NEW ZEALAND | ||
| PHILIPPINES | ||
| POLAND | ||
| RUSSIAN FEDERATION | ||
| SAUDI ARABIA | ||
| SINGAPORE | ||
| SOUTH AFRICA | ||
| SPAIN | ||
| SUDAN | ||
| SWEDEN | ||
| SWITZERLAND | ||
| TAIWAN, PROVINCE OF | ||
| CHINA | ||
| THAILAND | ||
| TURKEY | ||
| UGANDA | ||
| UNITED ARAB | ||
| EMIRATES | ||
| UNITED STATES OF | ||
| AMERICA | ||
| UZBEKISTAN | ||
| ZIMBABWE |
* As some SORs did not provide complete information on the Location of Mine in their CMRTs, and the Company was not able to establish with complete certainty, based on the suppliers' 3TG sourcing information, the exact location for the processing of the minerals. Therefore, we have listed in the COO the closest indication provided as to the source of Conflict Minerals, i.e. the Smelter Country as reported in our relevant suppliers' CMRT declarations, if provided.