ORMAT TECHNOLOGIES, INC. — Regulatory Filings 2019

May 31, 2019

SD 1 ora20190530_sd.htm

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)

	Delaware

Delaware 001-32347 88-0326081

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

Identification No.)

6140 Plumas Street, Reno, Nevada	89519-6075
(Address of principal executive offices)	(Zip Code)

Doron Blachar, 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, 2018.

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, 2018 to December 31, 2018 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: http://www.ormat.com/socialresponsibility-and-sustainability, we have concluded, in good faith, that during the 2018 calendar year, (i) we have manufactured and contracted to manufacture products (the "Covered Products") containing conflict minerals and that (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, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, the "Conflict Minerals").

On the basis of these conclusions, the Company proceeded to exercise due diligence with respect to the source and chain of custody of the Conflict Minerals contained in its Covered Products and has submitted its Report as an exhibit to this Form SD for the reporting period from January 1, 2018 to December 31, 2018. The Report describes the conflict minerals due diligence that the Company has designed and performed. 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 of all of the Conflict Minerals in all of the Covered Products. However, based on the information that has been obtained, to the extent reasonably determinable by the Company, with respect to the smelters and refiners identified by the Company, the possible countries of origin of the Conflict Minerals used in Covered Products 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 http://www.ormat.com/social-responsibility-and-sustainability. 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/Doron Blachar Name: Doron Blachar Title: Chief Financial Officer Date: May 30, 2019

EX-1.01 2 ex_146179.htm

EX-1.01 (Exhibit 1.01)

Conflict Minerals Report of Ormat Technologies, Inc. For the Year Ended December 31, 2018

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, currently engaged primarily in the geothermal and recovered energy power business, with the objective of becoming a leading global provider of renewable energy.

This is the Conflict Minerals Report (this "Report") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the reporting period from January 1, 2018 to December 31, 2018, 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 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"), that originated in the Democratic Republic of the Congo (the "DRC") and certain adjoining countries (collectively with the DRC, the "Covered Countries").

As part of Ormat's sustainability approach, our Code of Conduct outlines the Company's overall principles and commitment towards legal compliance, ethical conduct, human rights, anti-corruption work 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/socialresponsibility-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 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, construction, operation and maintenance of geothermal, Solar PV and recovered energy-based power plants.
• Other Segment: In this segment, we provide energy storage, demand response and energy management related services, as well as services relating to engineering, procurement, construction, operation and maintenance of energy storage units through our Viridity business.

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 Other Segment because neither of these segments involves the sale of products by the Company.

In connection to our manufacturing activities in the Product Segment, we identified certain Conflict Minerals that are used by us and 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). All such raw materials are purchased from various suppliers. We work with a large number of international suppliers and often there are multiple tiers between the gold, tin, tantalum and tungsten ("3TG") mines and our direct suppliers. Therefore, we rely on our Tier 1 suppliers to cooperate with us and work with their own upstream suppliers or subcontractors to provide us with accurate information on the origin of the 3TG in the components we purchase from them that are included in our products. In order to overcome the difficulties of receiving accurate information from a complex supply chain, Ormat has communicated its Conflict Minerals Policy and activities to its 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 5.01 or 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 Conflict Minerals originated in the Covered Countries or are from "recycled or scrap sources" (as such terms are defined in Rule 13p-1). In parallel, we conducted due diligence on the source and chain of custody of those Conflict Minerals with a large number of suppliers we identified as those from whom we source materials or components that may contain 3TG.

As part of our RCOI, we employed several methods to assess whether the necessary Conflict Minerals in our products originated in the Covered Countries, including the following:

• Internal assessment and analysis of our products to determine which products contain or may contain Conflict Minerals that are necessary to the functionality or production of such products.
• Compiled a list of suppliers based on the applicable suppliers list that Ormat purchased from during the calendar year 2018, which 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 includes a total of 1,489 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 2018 expenditures on procurement for the Product Segment. On that basis, Ormat's final Tier 1 suppliers list ("relevant suppliers") includes a total of 127 suppliers.
• 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.
• We solicited information from our relevant suppliers of raw materials and components of products using the standard template of the Responsible Business Alliance (formerly, the Electronic Industry Citizenship Coalition) (the "RBA") known as the CMRT. The RBA oversees the RMI. The CMRT is designed to facilitate the transfer of information through the supply chain regarding each mineral's country of origin and the smelters and refiners being utilized for the mineral. The CMRT requires suppliers to make representations regarding: (i) the country of origin for the Conflict Minerals contained in the components or products it provides to the Company; (ii) all of the smelters in the supplier's supply chain for such Conflict Minerals; (iii) whether such smelters 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 uses CMRT with its own suppliers to gather similar information. 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.
• Reviewed the responses that we received and followed up on inconsistent, incomplete, and inaccurate responses, and sent reminders to suppliers who did not respond to our requests for information or whose responses required further clarification. Compared smelters or refiners that were identified by our suppliers against the list of facilities that have been validated by RMAP, receiving a "conformant" or "active" status, as well as documented country of origin information as provided in the declarations from the suppliers. The complete list of identified suppliers is included as Annex 1 hereto and the complete list of counties 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 Covered Countries and 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.

4. Due Diligence Measures

Our due diligence efforts for the reporting period from January 1, 2018 to December 31, 2018 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 VP finance and accounting as the process owner.

• Continued to implement our Conflict Minerals Policy with respect to sourcing of minerals from the DRC and its adjoining countries. Our Conflict Minerals Policy provides further clarification to the principles of the Code of Conduct and Ormat's Human Rights Approach 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 validated as being "conformant" or "active" by the RMI's RMAP; however the Company does not seek to eliminate sourcing from the Covered Countries. 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 subsuppliers 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: ormat@ormat.com.
• Strengthened its 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.
• Incorporated a conflict minerals clause in our master purchasing agreements for all new contracts, requiring our suppliers to cooperate with us and 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, while trying to move towards the goal of being a conflict-free company. 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 2018. We have identified that out of the responses received, 38% of Ormat's relevant suppliers have a policy in place that addresses conflict minerals sourcing.
• 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 and refiners in the supply chain by conducting a supply chain survey using the CMRT (at least version 5.01 or higher), requesting suppliers to identify smelters and refiners and country of origin of the Conflict Minerals in products supplied to Ormat. 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 cross-certification 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 Chain-of-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 level, e.g. by using the CMRT.
• Ormat's senior management, including the CEO, CFO, EVP Electricity, EVP Products and Operations, EVP Business Development and Marketing, and the Legal Counsel and Chief Compliance Officer, 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.

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 and refiners and therefore do not perform direct audits of these entities. As a result, our due diligence efforts relied on cross- industry initiatives, such as those led by the RMI, to conduct smelter and refiner due diligence.

4.5 Report on supply chain due diligence

Our Conflict Minerals Policy states that we will comply with Section 1502 of the Dodd Frank Act that includes filing a Form SD and this Report with the SEC and publishing it so that it may be publicly available on the Internet. The Company's Conflict Minerals Reports can also be viewed at: http://www.ormat.com/socialresponsibility-and-sustainability.

5 The Company's Due Diligence Findings and Conclusions

We conducted a supply-chain survey of the 127 relevant suppliers that we identified as potentially contributing necessary Conflict Minerals to our products. The overall response rate to this survey was approximately 43.31%. The responses included the names and locations of smelters and refiners (see Annex 1) and possible countries of origin, according to the information provided in our suppliers' declarations that process Conflict Minerals (see Annex 2).

Our supply chain is complex and there are multiple tiers between the Company and the mines 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.

Despite receiving responses from suppliers listing smelter or refiner names in their supply chain, the suppliers were largely unable to accurately report which specific smelters were part of the supply chain of the components that were sold to Ormat in 2018.

In light of inconclusive information, we are unable to determine and to describe the full list of facilities used to process 3TG or their countries of origin. In addition, the information gathered from our suppliers is not gathered on a continuous real-time basis.

Tantalum	40 of 42 (95.2%)
Tin	72 of 83 (86.7%)
Tungsten	40 of 46 (87.0%)
Gold	104 of 151 (68.9%)
Total	256 of 322 (79.5%)

Smelters or refiners verified as RMAP Conformant or Active:

Status of identified smelters or refiners:

	2018
"RMAP Conformant"1	250
"RMAP Active"2	6
"Not RMAP Conformant or Active"3	66
Total	322

" 1

" 2

" 3

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 the process to identify Conflict Minerals in its Covered Products. The Company plans to continue to inform suppliers about their role in the Company's conflict minerals compliance program and to engage with its suppliers to obtain current, accurate and complete information about the supply chain. 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 working with our global supply chain to obtain current, accurate and complete information about the supply chain and ensure responsible sourcing and assure compliance with 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.
• Continue to improve due diligence efforts to ensure responsible sourcing in compliance with the Conflict Minerals Policy.

Caution 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 forwardlooking 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. For a discussion of such risks and uncertainties, see "Risk Factors" as described in Ormat Technologies, Inc.'s Annual Report on Form 10- K filed with the Securities and Exchange Commission on March 1, 2019 and its other filings. 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.

Metal	Smelter Name	Smelter Country	Smelter Status
Gold	Abington Reldan Metals, LLC	UNITED STATES OF AMERICA	Uncertified
Gold	Advanced Chemical Company	UNITED STATES OF AMERICA	Conformant
Gold	African Gold Refinery	UGANDA	Uncertified
Gold	AGR Mathey	AUSTRALIA	Conformant
Gold	Aida Chemical Industries Co., Ltd.	JAPAN	Conformant
Gold	Al Etihad Gold LLC	UNITED ARAB EMIRATES	Conformant
Gold	Allgemeine Gold-und Silberscheideanstalt A.G.	GERMANY	Conformant
Gold	Almalyk Mining and Metallurgical Complex (AMMC)	UZBEKISTAN	Conformant
Gold	Amagasaki Factory, Hyogo Prefecture, Japan	JAPAN	Conformant
Gold	AngloGold Ashanti C?rrego do S?tio Minera??o	BRAZIL	Conformant
Gold	Anhui Tongling Nonferrous Metal Mining Co., Ltd.	CHINA	Uncertified
Gold	Argor-Heraeus S.A.	SWITZERLAND	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	ATAkulche	TURKEY	Uncertified
Gold	AU Traders and Refiners	SOUTH AFRICA	Conformant
Gold	Aurubis AG	GERMANY	Conformant
Gold	BALORE REFINERSGA	INDIA	Active
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	Uncertified
Gold	CCR	CANADA	Conformant
Gold	Cendres + M?taux SA	SWITZERLAND	Conformant
Gold	CHALCO Yunnan Copper Co. Ltd.	CHINA	Uncertified

Annex 1- Smelter or Refiner Names in Supply Chain
---------------------------------------------------	--	--	--	--

Gold	Chimet S.p.A.	ITALY	Conformant
Gold	China Henan Zhongyuan Gold Smelter	CHINA	Conformant
Gold	Chugai Mining	JAPAN	Active
Gold	Daejin Indus Co., Ltd.	KOREA, REPUBLIC OF	Conformant
Gold	Daye Non-Ferrous Metals Mining Ltd.	CHINA	Uncertified
Gold	Degussa Sonne / Mond Goldhandel GmbH	GERMANY	Uncertified
Gold	Do Sung Corporation	KOREA, REPUBLIC OF	Conformant
Gold	DODUCO Contacts and Refining GmbH	GERMANY	Conformant
Gold	Dowa	JAPAN	Conformant
Gold	DS PRETECH Co., Ltd.	KOREA, REPUBLIC OF	Conformant
Gold	Eco-System Recycling Co., Ltd.	JAPAN	Conformant
Gold	Elemetal Refining, LLC	UNITED STATES OF AMERICA	Uncertified
Gold	Emirates Gold DMCC	UNITED ARAB EMIRATES	Conformant
Gold	Fidelity Printers and Refiners Ltd.	ZIMBABWE	Uncertified
Gold	FSE Novosibirsk Refinery	RUSSIAN FEDERATION	Conformant
Gold	Fujian Zijin mining stock company gold smelter	CHINA	Conformant
Gold	Geib Refining Corporation	UNITED STATES OF AMERICA	Conformant
Gold	Gold Mining in Shandong (Laizhou) Limited Company	CHINA	Conformant
Gold	Great Wall Precious Metals Co,. LTD.	CHINA	Uncertified
Gold	Guangdong Gaoyao Co	CHINA	Uncertified
Gold	Gujarat Gold Centre	INDIA	Uncertified
Gold	Guoda Safina High-Tech Environmental Refinery Co., Ltd.	CHINA	Uncertified
Gold	Hangzhou Fuchunjiang Smelting Co., Ltd.	CHINA	Uncertified
Gold	HeeSung Metal Ltd.	KOREA, REPUBLIC OF	Conformant
Gold	Heimerle + Meule GmbH	GERMANY	Conformant
Gold	Heraeus Ltd. Hong Kong	CHINA	Conformant
Gold	Heraeus Precious Metals GmbH & Co. KG	GERMANY	Conformant
Gold	Hunan Chenzhou Mining Group Co., Ltd.	CHINA	Uncertified

Gold	Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.	CHINA	Uncertified
Gold	HwaSeong CJ CO., LTD.	KOREA, REPUBLIC OF	Uncertified
Gold	Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.	CHINA	Conformant
Gold	Ishifuku Metal Industry Co., Ltd.	JAPAN	Conformant
Gold	Istanbul Gold Refinery	TURKEY	Conformant
Gold	Italpreziosi	ITALY	Conformant
Gold	Japan Mint	JAPAN	Conformant
Gold	JCC	CHINA	Conformant
Gold	JSC Ekaterinburg Non-Ferrous Metal Processing Plant	RUSSIAN FEDERATION	Uncertified
Gold	JSC Uralelectromed	RUSSIAN FEDERATION	Conformant
Gold	Kaloti Precious Metals	UNITED ARAB EMIRATES	Uncertified
Gold	Kazakhmys Smelting LLC	KAZAKHSTAN	Uncertified
Gold	Kazzinc	KAZAKHSTAN	Conformant
Gold	Kennecott Utah Copper LLC	UNITED STATES OF AMERICA	Conformant
Gold	KGHM Polska Miedz S.A.	POLAND	Active
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	Uncertified
Gold	L'azurde Company For Jewelry	SAUDI ARABIA	Uncertified
Gold	Lingbao Gold Co., Ltd.	CHINA	Uncertified
Gold	Lingbao Jinyuan Tonghui Refinery Co., Ltd.	CHINA	Uncertified
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	Uncertified
Gold	Marsam Metals	BRAZIL	Conformant
Gold	Materion	UNITED STATES OF AMERICA	Conformant
Gold	Matsuda Sangyo Co., Ltd.	JAPAN	Conformant
Gold	MEM(Sumitomo Group)	JAPAN	Conformant
Gold	Metalor Technologies (Hong Kong) Ltd.	CHINA	Conformant

	Metalor Technologies
Gold	(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 Kinzoku Co., Ltd.	JAPAN	Conformant
Gold	MMTC-PAMP India Pvt., Ltd.	INDIA	Conformant
Gold	Modeltech Sdn Bhd	MALAYSIA	Uncertified
Gold	Morris and Watson	NEW ZEALAND	Uncertified
Gold	Morris and Watson Gold Coast	AUSTRALIA	Uncertified
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	Uncertified
Gold	NH Recytech Company	KOREA, REPUBLIC OF	Active
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
Gold	OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)	RUSSIAN FEDERATION	Conformant
Gold	PAMP S.A.	SWITZERLAND	Conformant
Gold	Pan Pacific Copper Co Ltd.	JAPAN	Conformant
Gold	Pease & Curren	UNITED STATES OF AMERICA	Uncertified
Gold	Penglai Penggang Gold Industry Co., Ltd.	CHINA	Uncertified
Gold	Planta Recuperadora de Metales SpA	CHILE	Conformant
Gold	Prioksky Plant of Non-Ferrous Metals	RUSSIAN FEDERATION	Conformant

Gold	PX Pr?cinox S.A.	SWITZERLAND	Conformant
Gold	QG Refining, LLC	UNITED STATES OF AMERICA	Uncertified
Gold	Rand Refinery (Pty) Ltd.	SOUTH AFRICA	Conformant
Gold	Refinery of Seemine Gold Co., Ltd.	CHINA	Uncertified
Gold	Remondis Argentia B.V.	NETHERLANDS	Conformant
Gold	Republic Metals Corporation	UNITED STATES OF AMERICA	Uncertified
Gold	Royal Canadian Mint	CANADA	Conformant
Gold	SAAMP	FRANCE	Conformant
Gold	Sabin Metal Corp.	UNITED STATES OF AMERICA	Uncertified
Gold	Safimet S.p.A	ITALY	Conformant
Gold	SAFINA A.S.	CZECH REPUBLIC	Uncertified
Gold	Sai Refinery	INDIA	Uncertified
Gold	Samdok Metal	KOREA, REPUBLIC OF	Uncertified
Gold	Samwon Metals Corp.	KOREA, REPUBLIC OF	Uncertified
Gold	SAXONIA Edelmetalle GmbH	GERMANY	Conformant
Gold	Schone Edelmetaal B.V.	NETHERLANDS	Uncertified
Gold	SEMPSA Joyeria Plateria S.A.	SPAIN	Conformant
Gold	Shandong Tiancheng Biological Gold Industrial Co., Ltd.	CHINA	Uncertified
Gold	Shandong Zhaojin Gold & Silver Refinery Co., Ltd.	CHINA	Conformant
Gold	Shonan Plant Tanaka Kikinzoku	JAPAN	Conformant
Gold	Shyolkovsky	RUSSIAN FEDERATION	Conformant
Gold	Sichuan Tianze Precious Metals Co., Ltd.	CHINA	Conformant
Gold	Singway Technology Co., Ltd.	TAIWAN, PROVINCE OF CHINA	Conformant
Gold	Solar Applied Materials Technology Corp.	TAIWAN, PROVINCE OF CHINA	Conformant
Gold	State Research Institute Center for Physical Sciences and Technology	LITHUANIA	Uncertified
Gold	Sudan Gold Refinery	SUDAN	Uncertified
Gold	SungEel HiTech	KOREA, REPUBLIC OF	Conformant
Gold	T.C.A S.p.A	ITALY	Conformant
Gold	Tokuriki Honten Co., Ltd.	JAPAN	Conformant
Gold	Tony Goetz NV	BELGIUM	Uncertified
Gold	TOO Tau-Ken-Altyn	KAZAKHSTAN	Uncertified

Gold	Torecom	KOREA, REPUBLIC OF	Conformant
Gold	Umicore Brasil Ltda.	BRAZIL	Conformant
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	Universal Precious Metals Refining Zambia	ZAMBIA	Uncertified
Gold	Valcambi S.A.	SWITZERLAND	Conformant
Gold	WIELAND Edelmetalle GmbH	GERMANY	Conformant
Gold	Yamamoto Precious Co., Ltd.	JAPAN	Conformant
Gold	Yokohama Metal Co., Ltd.	JAPAN	Conformant
Tantalum	Asaka Riken Co., Ltd.	JAPAN	Conformant
Tantalum	Changsha South Tantalum Niobium Co., Ltd.	CHINA	Conformant
Tantalum	Conghua Tantalum and Niobium Smeltry	CHINA	Conformant
Tantalum	D Block Metals, LLC	UNITED STATES OF AMERICA	Conformant
Tantalum	Douluoshan Sapphire Rare Metal Co Ltd	CHINA	Uncertified
Tantalum	Exotech Inc.	UNITED STATES OF AMERICA	Conformant
Tantalum	F & X	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 Janny New Material Co., Ltd.	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	KEMET Blue Powder	UNITED STATES OF AMERICA	Conformant
Tantalum	LSM Brasil S.A.	BRAZIL	Conformant
Tantalum	Metallurgical Products India Pvt. Ltd. (MPIL)	INDIA	Conformant
Tantalum	Mineracao Taboca S.A.	BRAZIL	Conformant
Tantalum	Mitsui Mining & Smelting	JAPAN	Conformant
Tantalum	Molycorp Silmet A.S.	ESTONIA	Conformant
Tantalum	Ningxia Orient Tantalum Industry Co., Ltd.	CHINA	Conformant
Tantalum	Power Resources Ltd.	MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF	Conformant
Tantalum	QuantumClean	UNITED STATES OF AMERICA	Conformant
Tantalum	Resind Industria e Comercio Ltda.	BRAZIL	Conformant
Tantalum	RFH Tantalum Smeltry Co., Ltd.	CHINA	Conformant
Tantalum	Solikamsk	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
Tantalum	Yichun Jin Yang Rare Metal Co., Ltd.	CHINA	Uncertified

Tin	Alent plc	UNITED STATES OF AMERICA	Conformant
Tin	An Vinh Joint Stock Mineral Processing Company	VIET NAM	Uncertified
Tin	Brand IMLI	INDONESIA	Conformant
Tin	Brand RBT	INDONESIA	Conformant
Tin	Chengfeng Metals Co Pte Ltd	CHINA	Conformant
Tin	Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.	CHINA	Conformant
Tin	Chifeng Dajingzi Tin Industry Co., Ltd.	CHINA	Conformant
Tin	China Rare Metal Material Co., Ltd.	CHINA	Uncertified
Tin	China Tin (Hechi)	CHINA	Conformant
Tin	China Yunnan Tin Co Ltd.	CHINA	Conformant
Tin	CNMC (Guangxi) PGMA Co., Ltd.	CHINA	Uncertified
Tin	CV Ayi Jaya	INDONESIA	Conformant
Tin	CV Dua Sekawan	INDONESIA	Conformant
Tin	CV Gita Pesona	INDONESIA	Conformant
Tin	CV Nurjanah	INDONESIA	Conformant
Tin	CV Serumpun Sebalai	INDONESIA	Conformant
Tin	CV Tiga Sekawan	INDONESIA	Conformant
Tin	CV United Smelting	INDONESIA	Conformant
Tin	CV Venus Inti Perkasa	INDONESIA	Conformant
Tin	Dowa	JAPAN	Conformant
Tin	Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company	VIET NAM	Uncertified
Tin	EM Vinto	BOLIVIA (PLURINATIONAL STATE OF)	Conformant
Tin	Estanho de Rondonia S.A.	BRAZIL	Uncertified
Tin	Fenix Metals	POLAND	Conformant
Tin	Funsur Smelter	PERU	Conformant
Tin	Gejiu Fengming Metallurgy Chemical Plant	CHINA	Conformant
Tin	Gejiu Jinye Mineral Company	CHINA	Conformant
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 Zi-Li	CHINA	Active
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	Uncertified
Tin	Huichang Jinshunda Tin Co., Ltd.	CHINA	Conformant
Tin	INDONESIAN STATE TIN CORPORATION MENTOK SMELTER	INDONESIA	Conformant
Tin	Jiangxi Nanshan	CHINA	Conformant
Tin	Kundur Smelter	INDONESIA	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	Mitsubishi Materials Corporation	JAPAN	Conformant
Tin	Modeltech Sdn Bhd	MALAYSIA	Conformant
Tin	Nghe Tinh Non-Ferrous Metals Joint Stock Company	VIET NAM	Uncertified
Tin	O.M. Manufacturing (Thailand) Co., Ltd.	THAILAND	Conformant
Tin	O.M. Manufacturing Philippines, Inc.	PHILIPPINES	Conformant
Tin	OMSA	BOLIVIA (PLURINATIONAL STATE OF)	Conformant
Tin	Pongpipat Company Limited	MYANMAR	Uncertified
Tin	PT Artha Cipta Langgeng	INDONESIA	Conformant
Tin	PT ATD Makmur Mandiri Jaya	INDONESIA	Conformant
Tin	PT Babel Inti Perkasa	INDONESIA	Conformant

Tin	PT Bangka Prima Tin	INDONESIA	Conformant
Tin	PT Bangka Serumpun	INDONESIA	Conformant
Tin	PT Bangka Tin Industry	INDONESIA	Conformant
Tin	PT Belitung Industri Sejahtera	INDONESIA	Conformant
Tin	PT DS Jaya Abadi	INDONESIA	Conformant
Tin	PT Eunindo Usaha Mandiri	INDONESIA	Uncertified
Tin	PT Inti Stania Prima	INDONESIA	Conformant
Tin	PT Karimun Mining	INDONESIA	Conformant
Tin	PT Kijang Jaya Mandiri	INDONESIA	Conformant
Tin	PT Lautan Harmonis Sejahtera	INDONESIA	Conformant
Tin	PT Menara Cipta Mulia	INDONESIA	Conformant
Tin	PT Mitra Stania Prima	INDONESIA	Conformant
Tin	PT Panca Mega Persada	INDONESIA	Conformant
Tin	PT Prima Timah Utama	INDONESIA	Conformant
Tin	PT Sariwiguna Binasentosa	INDONESIA	Conformant
Tin	PT Stanindo Inti Perkasa	INDONESIA	Conformant
Tin	PT Sukses Inti Makmur	INDONESIA	Conformant
Tin	PT Sumber Jaya Indah	INDONESIA	Conformant
Tin	PT Tinindo Inter Nusa	INDONESIA	Conformant
Tin	PT Tommy Utama	INDONESIA	Conformant
Tin	Resind Ind e Com Ltda.	BRAZIL	Conformant
Tin	Rui Da Hung	TAIWAN, PROVINCE OF CHINA	Conformant
Tin	Soft Metais Ltda.	BRAZIL	Conformant
Tin	Super Ligas	BRAZIL	Uncertified
Tin	Thailand Smelting & Refining Co Ltd	THAILAND	Conformant
Tin	Tin Technology & Refining	UNITED STATES OF AMERICA	Conformant
Tin	Tuyen Quang Non-Ferrous Metals Joint Stock Company	VIET NAM	Uncertified
Tin	White Solder Metalurgia e Mineracao Ltda.	BRAZIL	Conformant
Tungsten	A.L.M.T. TUNGSTEN Corp.	JAPAN	Conformant
Tungsten	ACL Metais Eireli	BRAZIL	Conformant
Tungsten	Asia Tungsten Products Vietnam Ltd.	VIET NAM	Uncertified
Tungsten	ATI Metalworking Products	UNITED STATES OF AMERICA	Conformant

Tungsten	Chaozhou Xianglu Tungsten Industry Co., Ltd.	CHINA	Conformant
Tungsten	Chenzhou Diamond Tungsten Products Co., Ltd.	CHINA	Conformant
Tungsten	China National Non Ferrous	CHINA	Conformant
Tungsten	Chongyi Zhangyuan Tungsten Co., Ltd.	CHINA	Conformant
Tungsten	Fujian Jinxin Tungsten Co., Ltd.	CHINA	Conformant
Tungsten	Ganzhou Haichuang Tungsten Co., Ltd.	CHINA	Conformant
Tungsten	Ganzhou Jiangwu Ferrotungsten Co., Ltd.	CHINA	Conformant
Tungsten	Ganzhou Seadragon W & Mo Co., Ltd.	CHINA	Conformant
Tungsten	Ganzhou Yatai Tungsten Co., Ltd.	CHINA	Uncertified
Tungsten	Global Tungsten & Powders Corp.	UNITED STATES OF AMERICA	Conformant
Tungsten	H.C. Starck Smelting GmbH & Co. KG	GERMANY	Conformant
Tungsten	H.C. Starck Tungsten GmbH	GERMANY	Conformant
Tungsten	Human Chun-Chang non-ferrous Smelting & Concentrating Co., Ltd.	CHINA	Conformant
Tungsten	Hunan Chenzhou Mining Group Co., Ltd.	CHINA	Conformant
Tungsten	Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji	CHINA	Conformant
Tungsten	Hunan Litian Tungsten Industry Co., Ltd.	CHINA	Active
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	Uncertified
Tungsten	Jiangxi Gan Bei Tungsten Co., Ltd.	CHINA	Conformant
Tungsten	Jiangxi Minmetals Gao'an Non ferrous Metals Co., Ltd.	CHINA	Uncertified

Tungsten	Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.	CHINA	Conformant
Tungsten	Jiangxi Xinsheng Tungsten Industry Co., Ltd.	CHINA	Conformant
Tungsten	Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.	CHINA	Uncertified
Tungsten	Jiangxi Yaosheng Tungsten Co., Ltd.	CHINA	Conformant
Tungsten	Kennametal Fallon	UNITED STATES OF AMERICA	Conformant
Tungsten	Malipo Haiyu Tungsten Co., Ltd.	CHINA	Conformant
Tungsten	Moliren Ltd.	RUSSIAN FEDERATION	Conformant
Tungsten	Niagara Refining LLC	UNITED STATES OF AMERICA	Conformant
Tungsten	Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC	VIET NAM	Conformant
Tungsten	Philippine Chuangxin Industrial Co., Inc.	PHILIPPINES	Conformant
Tungsten	Shaoguan Xinhai Rendan Tungsten Industry Co. Ltd	CHINA	Conformant
Tungsten	South-East Nonferrous Metal Company Limited of Hengyang City	CHINA	Conformant
Tungsten	Tejing (Vietnam) Tungsten Co., Ltd.	VIET NAM	Conformant
Tungsten	Unecha Refractory metals plant	RUSSIAN FEDERATION	Conformant
Tungsten	Vietnam Youngsun Tungsten Industry Co., Ltd.	VIET NAM	Uncertified
Tungsten	WBH	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

GOLD	TANTALUM	TIN	TUNGSTEN
ANDORRA	BRAZIL	BELGIUM	AUSTRIA
AUSTRALIA	CHINA	BOLIVIA	BRAZIL
		(PLURINATIONAL
		STATE OF)
AUSTRIA	ESTONIA	BRAZIL	CHINA
BELGIUM	GERMANY	CHINA	GERMANY
BRAZIL	INDIA	INDONESIA	JAPAN
CANADA	JAPAN	JAPAN	KOREA,
			REPUBLIC OF
CHILE	KAZAKHSTAN	MALAYSIA	PHILIPPINES
CHINA	MACEDONIA, THE FORMER	MYANMAR	RUSSIAN
	YUGOSLAV REPUBLIC OF		FEDERATION
CZECH REPUBLIC	MEXICO	PERU	UNITED STATES
			OF AMERICA
FRANCE	RUSSIAN FEDERATION	PHILIPPINES	VIET NAM
GERMANY	THAILAND	POLAND
INDIA	UNITED STATES OF AMERICA	SPAIN
INDONESIA		TAIWAN, PROVINCE
		OF CHINA
ITALY		THAILAND
JAPAN		UNITED STATES OF
		AMERICA
KAZAKHSTAN		VIET NAM
KOREA,
REPUBLIC OF
KYRGYZSTAN
LITHUANIA
MALAYSIA
MEXICO
NETHERLANDS
NEW ZEALAND
PHILIPPINES
POLAND
RUSSIAN
FEDERATION

Annex 2- Country of Origin (COO) Inquiry Results*

SAUDI ARABIA
SINGAPORE
SOUTH AFRICA
SPAIN
SUDAN
SWEDEN
SWITZERLAND
TAIWAN,
PROVINCE OF
CHINA
THAILAND
TURKEY
UGANDA
UNITED ARAB
EMIRATES
UNITED STATES
OF AMERICA
UZBEKISTAN
ZAMBIA
ZIMBABWE

* As SORs did not provide information on Location of Mine in their CMRTs, and the Company was not able to establish from the SORs sourcing information on their 3TG, 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 the suppliers' CMRT.