Exhibit 1.01
Trimble Inc.
Conflict Minerals Report For The Year Ended December 31, 2016
The following conflict minerals report contains forward-looking statements about our plans to take additional actions or to implement additional policies or procedures with respect to our due diligence efforts to determine the origin of conflict minerals contained in our products. We undertake no obligation to publically update or revise any forward-looking statement, whether as a result of new information, future events or otherwise. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report.
This is the Conflict Minerals Report of Trimble Inc. for the 2016 calendar year in accordance with Rule13p-1 under the Securities Exchange Act of 1934, as amended.
Rule13p-1 requires that all public companies report annually on the presence of certain minerals, characterized as conflict minerals, including tin, tantalum, tungsten or gold (“3TG” or“conflict minerals”), in the products that they manufacture or contract to manufacture, and demonstrate the proper level of due diligence in determining whether these minerals originated from the Democratic Republic of the Congo or an adjoining country (collectively,“Covered Countries”) or from scrap or recycled sources and whether they directly or indirectly finance or benefit armed groups in the Covered Countries.
Introduction
Trimble provides technology solutions that enable professionals and field mobile workers to improve or transform their work processes. Our solutions, which can include a combination of hardware, software and services, are used across a range of industries including agriculture, architecture, civil engineering, survey and land administration, construction, geospatial, government, natural resources, transportation and utilities. Representative Trimble customers include engineering and construction firms, contractors, surveying companies, farmers and agricultural companies, enterprise firms with large-scale fleets, energy, mining and utility companies, and state, federal and municipal governments.
We design and manufacture, or have manufactured on our behalf, thousands of different hardware products ranging across multiple business divisions within our key business segments of Buildings and Infrastructure, Geospatial, Resources and Utilities, and Transportation. Many of these hardware products, which are typically based upon positioning or location technologies, including Global Navigation Satellite Systems (GNSS), lasers and optics, are built by our contract manufacturing partners.
Our contract manufacturing partners are responsible for significant material procurement, assembly, and testing. We generally manage product design and are involved in qualifying suppliers and key components used in our products. We are many levels removed from the mining or processing of minerals in our supply chain, however, and we do not directly source, or manage the sourcing of, raw materials, including conflict minerals.
Many of our hardware products are designed with printed circuit boards, connectors, sheet metal and other electrical mechanical assemblies that may contain conflict minerals. The components used in our products that contain these metals are required for the functionality of our products.
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Trimble’s Conflict Minerals Program
Trimble is committed to sourcing components and materials from companies that share our values concerning human rights, ethics and environmental responsibility. Our Conflict Minerals Policy Statement, as well as all of our Conflict Minerals Reports, are published on our public website and available at:
https://www.trimble.com/Corporate/Environmental_Compliance.aspx?tab=Conflict_Minerals_Policy_~_Disclosure.
We focus our due diligence efforts on determining the source and chain of custody of conflict minerals in the components and materials that are supplied to us. Tracing conflict minerals back to their country of origin, though, is a complex task that requires, among other things, screening for the possible presence of 3TG in parts or materials provided by our contract manufacturers and direct suppliers (which we refer to as “in-scope suppliers”), and then surveying suchin-scope suppliers to understand what programs they have in place for tracing the source of minerals included in products or components supplied to us. Suppliers are deemedout-of-scope and not surveyed if they only provide software, plastic, packaging materials or other items that do not contain 3TG.
Trimble uses as its standard reporting template, and requires itsin-scope suppliers to use, the Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template(“CMRT”) to identify whetherin-source suppliers source 3TG from the Covered Countries or from recycled or scrap sources. The CMRT is a key part of our due diligence efforts and is used to determine the source and chain of custody of 3TG in the components and materials that are supplied to us. We rely on the information provided through the CMRT by our supply chain, as well as smelter information provided by the CFSI and other industry organizations, to complete our Conflict Minerals Report.
As part of our supplier risk assessment, we require new suppliers to go through a screening and approval process so we can assess their use of 3TG and determine whether they arein-scope suppliers. We provide an initial survey to assess their use of 3TG and to understand their business processes. We also inform new suppliers of our “Supplier Requirements for the Sourcing of Conflict Minerals,” which further describe our Conflict Minerals Program goals and expectations.
Trimble requiresin-scope suppliers to source from smelters that are certified by CFSI’s Conflict Free Smelter Program (“CFSP”) or that have undergone a third-party audit by a recognized provider. In the event ofnon-compliance byin-scope suppliers, we pursue corrective actions, which may include termination of the supplier.
Reasonable Country of Origin Inquiry (“RCOI”)
Since conflict minerals are necessary to the functionality of many of our hardware products, we conducted an RCOI to determine the origin of the 3TG present in our products delivered to customers. Given the complex nature of our supply chain and our extensive parts inventory, we assess ourin-scope suppliers in three separate phases: (i) we first assess suppliers of parts containing 3TG that are used in the bill of materials for products that we are actively producing; (ii) we then review those suppliers that manufacture and sell to us their parts and components; and (iii) finally, we review suppliers of the companies and businesses that we acquire.
After our three phase assessment, we requested thatin-scope suppliers provide us with information using the CMRT. We received a 96% response rate. Based on the CMRT responses from ourin-scope suppliers and a review and analysis of the responses against CFSI’s RCOI list, which provides conflict minerals sourcing information for smelters, we concluded that 48% of the identified smelters directly sourced minerals from conflict free regions, 8% of smelters directly sourced from Covered Countries, but were compliant and 44% of the identified smelters were undisclosed or undetermined.
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Based on our internal assessment ofin-scope suppliers and the CMRT information we received back from ourin-scope suppliers, we determined that it was necessary to exercise due diligence to determine the source and chain of custody of the conflict minerals contained in our products.
Trimble Due Diligence
We have designed our due diligence program to conform, in all material respects, with the framework in the “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Second Edition),” and the related supplements, published by the Organization for EconomicCo-operation and Development. The following describes Trimble’s due diligence activities for the 2016 reporting year.
Step 1: Establish Strong Company Management Systems
• | We have made our Conflict Minerals Policy, described above, publicly available on our website. |
• | We have established a team that is responsible for administering our Conflict Minerals Program. Our team is supported by, and works closely with, our third-party vendor, MetricStream. Our team consists of personnel from our corporate operation’s group, including representatives from our quality, internal audit and global commodity management departments, and works closely with our specific business area buyers and product managers to address supplier risks and disclosure issues. |
• | If suppliers are unresponsive or do not provide the requested information, we have a process for escalating the matter to increasingly senior levels of management and considering corrective actions for suppliers that do not meet our stated expectations. |
• | We have established “Supplier Requirements for the Sourcing of Conflict Minerals,” which we communicate to our suppliers and require them to follow. We also engage suppliers by providing conflicts mineral training and orientation materials to assist our suppliers in completing the CMRTs, and provide support to answer suppliers’ questions. We maintain a conflict minerals resource page with links to resources about the conflict minerals law, the CMRT and our contact information for conflict minerals related inquiries: http://www.trimble.com/Corporate/Compliance/compliance_resources.aspx. |
• | Our template terms of purchase require suppliers to assist us in complying with applicable provisions of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act such as notifying us of their use of conflict minerals. |
• | We report on the status and progress of our Conflict Minerals Program during our operation group’s quarterly business and executive-level review meetings. |
• | Our Conflict Minerals Program, as an established internal process, is subject to oversight by our internal audit group. |
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Step 2: Identify and Assess Risk in the Supply Chain
• | We requested eachin-scope supplier to complete and return a CMRT so that we could survey our supply chain and obtain information about the smelters and refiners (which we collectively refer to as“smelters” throughout this report), and mines or locations of origin, of the 3TG used in our products. We identified the CMRT, the standardized reporting template developed by the CFSI, as the best method for collecting information about Trimble’s suppliers in order to identify and assess risks. |
• | Working with MetricStream, we tracked responses fromin-scope suppliers and initially categorized suppliers according to whether they provided in their CMRT responses: (i) legitimate smelter information, or (ii) inconsistent or incomplete information about smelters that required further investigation. |
• | We use CFSI’s RCOI list to obtain conflict minerals sourcing information for the CFSP certified smelters identified on the CMRTs from ourin-scope suppliers. |
• | We have a defined process for reviewing and evaluating CMRT responses, including procedures to address incomplete or vague answers and to follow up with suppliers, as necessary. |
• | We identify any “high risk” suppliers that require additional attention by focusing on suppliers that: (i) list smelters in the Covered Countries that were not certified as conflict-free by the CFSP; (ii) list smelters that are not recognized by the CFSP or another independent third-party source; (iii) identify smelters that may be financed by a U.S.-embargoed or -sanctioned country; or (iv) are unresponsive or do not provide any smelter information. |
• | We leverage CFSI’s smelter database to validate the audit status of the smelters provided by ourin-scope suppliers. |
Step 3: Design and Implement a Strategy to Respond to Identified Risks
• | We obtained updated smelter status data from the CFSP through our membership with CFSI and compared supplier provided information against such data. Smelters found not in compliance with the CFSP or equivalent independent third-party audit programs (such as the Tin Supply Chain Initiative List and the London Bullion Market Good Delivery Lists) were flagged. |
• | Any smelter or supplier that Trimble identified as “high risk” underwent further investigation and was subject to additional risk mitigation requests by Trimble. |
• | We require high risk suppliers to commit to and implement a corrective action plan within a reasonable time frame, and if such plan is deemed ineffective or there is no progress made, at the discretion of management, the supplier is subject to suspension or termination. |
• | We inform ourin-scope suppliers of our identified high risk smelters and request our suppliers to work through their supply chain to find substitute smelters. |
• | We participate in and support CFSI working groups on smelter due diligence practices for risk mitigation. |
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Step 4: Carry Out Independent Third-party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
• | We are a member of the CFSI and rely on CFSI data to validate the conflict status of smelters to verify whether a smelter has been certified as “conflict free.” |
• | Our third-party vendor, MetricStream, utilizes publicly available information regarding identified smelters to validate the existence and assess the conflict status of smelters. |
• | We address conflict minerals in our general supplier audits, focusing on supplier CMRT responses and due diligence programs. |
Step 5: Report on supply chain due diligence
• | Our annual Conflict Minerals Reports are publicly accessible on our website. |
• | We remind “high risk” suppliers of our expectations for the upcoming 2017 conflict minerals reporting period and emphasize our requirements and goals. |
Results of Due Diligence
Based on the responses received from suppliers, we identified a total of 310 smelters within our supply chain that were potential sources of 3TG for our suppliers. Trimble has adopted the same audit status designations utilized by CFSI to categorize the audit compliance status of smelters. We utilized CFSI’s smelter database to obtain recent smelter audit status as of March 29, 2017. The table below summarizes the status of smelters that were identified through the information provided by ourin-scope suppliers.“Compliant Smelters” are those that have been certified as conflict-free.“Active Smelters” are existing smelters that are not yet certified, but which are engaged with CFSP or other third party auditors to achieve compliance.“In Communication” smelters are existing smelters that are not yet certified, but which demonstrate interest in participating in an audit program and are engaged with CFSP and/or other third party auditing organizations.“Alleged Smelters” are smelters that may or may not exist, and which are unknown to Trimble, CFSI or other sources.Schedule A lists the Compliant, Active, and In Communication Smelters reported by ourin-scope suppliers that we believe processed 3TG which may have been used in Trimble products during the 2016 reporting period.
2016 Trimble Smelters Audit Status in reference to CFSI’s Smelter Database (as of March 29, 2017) | ||||||||
Metal: | Compliant Smelters: | Active Smelters: | In Communication: | Alleged Smelters | ||||
Gold | 94 | 10 | 8 | 27 | ||||
Tantalum | 44 | 1 | — | — | ||||
Tin | 69 | 6 | 2 | 5 | ||||
Tungsten | 39 | — | 1 | 4 | ||||
Total: | 246 | 17 | 11 | 36 |
Of the total number of smelters identified, 175 smelters had associated mine disclosure information that was provided to us by CFSI. From this information, we determined that 151 of those smelters did not source 3TG from the Covered Countries. We also determined that the remaining 24 smelters sourced 3TG from Covered Countries and were certified as “conflict-free” by CFSI.
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Additionally, we identified 4“In Communication” status smelters initially as “high risk” due to their failure to successfully complete a CFSP audit. After further investigation, these smelters were removed from high risk status because they engaged with CFSI or other recognized audit organizations and made progress towards completing a smelter audit or otherwise taking requested corrective actions. Trimble issued a corrective action to the supplier that had listed such smelters. Such supplier has taken remedial actions to address conflict minerals in its processes and work with its supply chain to mitigate risk. Trimble continues to closely monitor the progress of this supplier and will consider additional corrective action if warranted.
Determination
Based on the measures we have taken, as described above, we do not have sufficient information to determine the country of origin of all of the 3TG contained in our products. Not all of the CFSP compliant smelters disclosed the origin of their minerals. In addition, the information provided by some suppliers was incomplete and unverifiable, and certain smelters identified by suppliers were not recognized by CFSI or were unknown to us so we were unable to determine the origin of minerals processed by such smelters.
However, based on the information provided by our suppliers, as well as information from CFSI and other third party sources, we believe the origin of 3TG processed by smelters known to us and contained in our products include the countries listed inSchedule B. As discussed above, the known smelters for which we had mine disclosure information, and that we believe processed 3TG originating from the Covered Countries, were all certified conflict-free by CFSI. In addition, we are not aware of any instance where 3TG sourced from the Covered Countries may have directly or indirectly financed or benefited armed groups.
Future Due Diligence Measures
We intend to take the following measures in 2017 to further mitigate the risk that conflict minerals in our products could directly or indirectly finance or benefit armed groups in the Covered Countries:
• | Continue to communicate with our suppliers regarding Trimble’s Conflict Mineral Policy and Supplier Requirements to ensure that suppliers appropriately assess their supply chains, in keeping with the principles of responsible sourcing and corporate social responsibility underlying Trimble’s Conflict Minerals Program; |
• | Continue to motivate suppliers to provide accurate, valid and complete smelter information; |
• | Require our suppliers to source from smelters that are certified as conflict-free or that are currently undergoing, or willing to undergo, an audit through the CFSP or another third party; |
• | Provide conflict minerals training to Trimble’s new suppliers and other suppliers that appear to need assistance; |
• | Review our supplier risk mitigation process to assess remedial and corrective actions that we may take to address situations where suppliers are unresponsive, provide incomplete information or continue to source from unknown smelters; and |
• | Continue monitoring our supply chain activities, keep current with changes or updates in relevant laws and guidance, and update our related policies and procedures as appropriate. |
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Schedule A
Compliant, Active, and In Communication Smelters
Metal | Smelter Name | Country | ||
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | ||
Gold | AllgemeineGold-und Silberscheideanstalt A.G. | GERMANY | ||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | ||
Gold | Argor-Heraeus S.A. | SWITZERLAND | ||
Gold | Asahi Pretec Corp. | JAPAN | ||
Gold | Asahi Refining Canada Ltd. | CANADA | ||
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||
Gold | Asaka Riken Co., Ltd. | JAPAN | ||
Gold | AU Traders and Refiners | SOUTH AFRICA | ||
Gold | Aurubis AG | GERMANY | ||
Gold | Bangalore Refinery | INDIA | ||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||
Gold | Boliden AB | SWEDEN | ||
Gold | C. Hafner GmbH + Co. KG | GERMANY | ||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||
Gold | Cendres + Métaux S.A. | SWITZERLAND | ||
Gold | Chimet S.p.A. | ITALY | ||
Gold | Chugai Mining | JAPAN | ||
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | DODUCO GmbH | GERMANY | ||
Gold | Dowa | JAPAN | ||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||
Gold | Eco-System Recycling Co., Ltd. | JAPAN | ||
Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | ||
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | ||
Gold | Heimerle + Meule GmbH | GERMANY | ||
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||
Gold | Istanbul Gold Refinery | TURKEY | ||
Gold | Japan Mint | JAPAN | ||
Gold | Jiangxi Copper Co., Ltd. | CHINA | ||
Gold | JSC EkaterinburgNon-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | ||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
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Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||
Gold | Kazzinc | KAZAKHSTAN | ||
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||
Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | ||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||
Gold | Marsam Metals | BRAZIL | ||
Gold | Materion | UNITED STATES OF AMERICA | ||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||
Gold | Metalor Technologies S.A. | SWITZERLAND | ||
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||
Gold | MetalúrgicaMet-Mex Peñoles S.A. De C.V. | MEXICO | ||
Gold | Mitsubishi Materials Corporation | JAPAN | ||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | ||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||
Gold | Nihon Material Co., Ltd. | JAPAN | ||
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||
Gold | OJSC “The Gulidov KrasnoyarskNon-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||
Gold | PAMP S.A. | SWITZERLAND | ||
Gold | Planta Recuperadora de Metales SpA | CHILE | ||
Gold | Prioksky Plant ofNon-Ferrous Metals | RUSSIAN FEDERATION | ||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||
Gold | PX Précinox S.A. | SWITZERLAND | ||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||
Gold | Remondis Argentia B.V. | NETHERLANDS | ||
Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | ||
Gold | Royal Canadian Mint | CANADA | ||
Gold | SAAMP | FRANCE | ||
Gold | SAFINA A.S. | CZECH REPUBLIC | ||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||
Gold | Schone Edelmetaal B.V. | NETHERLANDS | ||
Gold | SEMPSA Joyería Platería S.A. | SPAIN | ||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
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Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||
Gold | SungEel HiTech | KOREA, REPUBLIC OF | ||
Gold | T.C.A S.p.A | ITALY | ||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||
Gold | Tony Goetz NV | BELGIUM | ||
Gold | TOOTau-Ken-Altyn | KAZAKHSTAN | ||
Gold | Torecom | KOREA, REPUBLIC OF | ||
Gold | Umicore Brasil Ltda. | BRAZIL | ||
Gold | Umicore Precious Metals Thailand | THAILAND | ||
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||
Gold | Valcambi S.A. | SWITZERLAND | ||
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||
Gold | WIELAND Edelmetalle GmbH | GERMANY | ||
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | ||
Gold | Yokohama Metal Co., Ltd. | JAPAN | ||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||
Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | ||
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||
Tantalum | Duoluoshan | CHINA | ||
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||
Tantalum | F&X Electro-Materials Ltd. | CHINA | ||
Tantalum | FIR Metals & Resource Ltd. | CHINA | ||
Tantalum | Global Advanced Metals Aizu | JAPAN | ||
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||
Tantalum | H.C. Starck Co., Ltd. | THAILAND | ||
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||
Tantalum | H.C. Starck Ltd. | JAPAN | ||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | ||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES OF AMERICA | ||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | ||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||
Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | CHINA | ||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||
Tantalum | KEMET Blue Metals | MEXICO | ||
Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | ||
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | ||
Tantalum | LSM Brasil S.A. | BRAZIL | ||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||
Tantalum | Mineração Taboca S.A. | BRAZIL | ||
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
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Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||
Tantalum | NPM Silmet AS | ESTONIA | ||
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | ||
Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | ||
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | ||
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||
Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||
Tantalum | Telex Metals | UNITED STATES OF AMERICA | ||
Tantalum | Tranzact, Inc. | UNITED STATES OF AMERICA | ||
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | ||
Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | ||
Tin | Alpha | UNITED STATES OF AMERICA | ||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||
Tin | China Tin Group Co., Ltd. | CHINA | ||
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | ||
Tin | CV Ayi Jaya | INDONESIA | ||
Tin | CV Dua Sekawan | INDONESIA | ||
Tin | CV Gita Pesona | INDONESIA | ||
Tin | CV Serumpun Sebalai | INDONESIA | ||
Tin | CV Tiga Sekawan | INDONESIA | ||
Tin | CV United Smelting | INDONESIA | ||
Tin | CV Venus Inti Perkasa | INDONESIA | ||
Tin | Da Nang Processing Import and Export Joint Stock | VIET NAM | ||
Tin | Dowa | JAPAN | ||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||
Tin | Elmet S.L.U. | SPAIN | ||
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||
Tin | Fenix Metals | POLAND | ||
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||
Tin | Gejiu Jinye Mineral Company | CHINA | ||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||
Tin | GejiuNon-Ferrous Metal Processing Co., Ltd. | CHINA | ||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||
Tin | Guangdong HanheNon-Ferrous Metal Co., Ltd. | CHINA | ||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | ||
Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | ||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||
Tin | Melt Metais e Ligas S.A. | BRAZIL | ||
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||
Tin | Metallo-Chimique N.V. | BELGIUM | ||
Tin | Mineração Taboca S.A. | BRAZIL | ||
Tin | Minsur | PERU |
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Tin | Mitsubishi Materials Corporation | JAPAN | ||
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | ||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||
Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||
Tin | PT Aries Kencana Sejahtera | INDONESIA | ||
Tin | PT Artha Cipta Langgeng | INDONESIA | ||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||
Tin | PT Babel Inti Perkasa | INDONESIA | ||
Tin | PT Bangka Prima Tin | INDONESIA | ||
Tin | PT Bangka Tin Industry | INDONESIA | ||
Tin | PT Belitung Industri Sejahtera | INDONESIA | ||
Tin | PT Bukit Timah | INDONESIA | ||
Tin | PT Cipta Persada Mulia | INDONESIA | ||
Tin | PT DS Jaya Abadi | INDONESIA | ||
Tin | PT Eunindo Usaha Mandiri | INDONESIA | ||
Tin | PT Inti Stania Prima | INDONESIA | ||
Tin | PT Justindo | INDONESIA | ||
Tin | PT Karimun Mining | INDONESIA | ||
Tin | PT Kijang Jaya Mandiri | INDONESIA | ||
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | ||
Tin | PT Menara Cipta Mulia | INDONESIA | ||
Tin | PT Mitra Stania Prima | INDONESIA | ||
Tin | PT O.M. Indonesia | INDONESIA | ||
Tin | PT Panca Mega Persada | INDONESIA | ||
Tin | PT Prima Timah Utama | INDONESIA | ||
Tin | PT Refined Bangka Tin | INDONESIA | ||
Tin | PT Sariwiguna Binasentosa | INDONESIA | ||
Tin | PT Stanindo Inti Perkasa | INDONESIA | ||
Tin | PT Sukses Inti Makmur | INDONESIA | ||
Tin | PT Sumber Jaya Indah | INDONESIA | ||
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | ||
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | ||
Tin | PT Tinindo Inter Nusa | INDONESIA | ||
Tin | PT Tommy Utama | INDONESIA | ||
Tin | Resind Indústria e Comércio Ltda. | BRAZIL | ||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||
Tin | Soft Metais Ltda. | BRAZIL | ||
Tin | Thaisarco | THAILAND | ||
Tin | VQB Mineral and Trading Group JSC | VIET NAM | ||
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | ||
Tin | Yunnan ChengfengNon-ferrous Metals Co., Ltd. | CHINA | ||
Tin | Yunnan Tin Company Limited | CHINA | ||
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | ||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
A-5
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | ||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||
Tungsten | Jiangxi TongguNon-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | ||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | ||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | ||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | ||
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | ||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
A-6
Schedule B
Countries of Origin List
Australia | Rwanda | |
Bolivia | Colombia | |
Brazil | Indonesia | |
China | Laos | |
Ethiopia | Mongolia | |
France | Myanmar | |
Guinea | Peru | |
Guyana | Portugal | |
India | Vietnam | |
Madagascar | Uganda | |
Malaysia | Austria | |
Namibia | Cambodia | |
Nigeria | Canada | |
Russia | Japan | |
Sierra Leone | Mexico | |
Thailand | Spain | |
United States of America | Uzbekistan | |
Zimbabwe | DRC | |
Burundi |
B-1