Exhibit 1.01
Conflict Minerals Report of Stratasys Ltd.
This is the Conflict Minerals Report of Stratasys Ltd. (“Stratasys”, “we”, “us”, or the “Company”) for calendar year 2024 in accordance with Rule 13p-1 of the Securities Exchange Act of 1934 (“Rule 13p-1”) and Form SD. Rule 13p-1 was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to “Conflict Minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). Conflict Minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain Conflict Minerals that are necessary for the functionality or production of their products. If the SEC registrant has reason to believe that any of those Conflict Minerals may have originated in the Democratic Republic of the Congo (the “DRC”) or a country that shares an internationally recognized border with the Democratic Republic of the Congo (collectively, “Covered Countries”) or is unable to determine the country of origin of those Conflict Minerals, the SEC registrant is required to submit a Conflict Minerals Report to the SEC that includes a description of the measures it took to exercise due diligence on the Conflict Minerals’ source and chain of custody. As part of the Company’s commitment to human rights, it has reviewed the supply chain for its products in accordance with the guidance provided by EU regulations and has contacted its suppliers for information regarding Conflict Minerals that may have been sourced from conflict-affected or high-risk areas (“CAHRAs”).
Business Overview
We are a global leader in polymer-based 3D printing solutions, which we provide at every stage of the product life cycle, with multiple technologies and complete solutions for superior application fit, across industrial, healthcare and consumer fields. We focus, in particular, on polymer 3D printing solutions that address the fastest growing manufacturing solutions, which we view as the biggest potential growth opportunity in the 3D printing industry. Leveraging distinct competitive advantages that include a broad set of best-in-class 3D printing platforms, software, materials and technology partner ecosystems, innovative leadership, and a global GTM infrastructure, we are positioned to further expand our leadership in this significant and growing global marketplace.
Our approximately 2,300 granted and pending additive technology patents currently held (in addition to many others previously held) have been used to create models, prototypes, manufacturing tools, and production parts for a multitude of industries including aerospace, automotive, transportation, healthcare, consumer products, dental, medical, fashion and education. Our products and comprehensive solutions improve product quality, development time, cost, time-to-market and patient care. Our additive manufacturing ecosystem of solutions and expertise includes materials, software, expert services, and on-demand parts production.
In recent years we have expanded our leadership through innovation in the fast-growing mass production parts segment through our next-generation photopolymer platform. Our pioneering approach to additive manufacturing of end-use parts enables us to serve a large market with manufacturing-grade 3D printers, utilizing P3™ Programmable PhotoPolymerization technology, which precisely controls light, heat, and force, among other variables, to produce parts with exceptional accuracy and consistency and unique production grade properties.
We have also introduced our Neo® line of systems to the global market, which feature dynamic laser beam technology that enables build accuracy, feature detail, and low variability across the full extent of a large build platform. As an open resin system, the Neo products provide customers materials with a wide range of properties such as chemical resistance, heat tolerance, flexibility, durability, and optical clarity, and can produce large parts providing a significant build area in a small footprint.
Similarly, we have accelerated our growth in production-scale 3D printing having introduced the Stratasys H350™ 3D printer, the first system powered by Xaar’s powder-based SAF™ technology, which is designed to deliver cost-competitive parts at production-level throughput. H Series™ Production Platform printers such as the H350 are designed to deliver part quality, consistency, and reliability for high production yield, utilizing a uniform thermal experience for all printed parts regardless of their placement in the build, representing a significant improvement over traditional powder-bed fusion processes.
We now offer a broader range of systems, consumables and services for additive manufacturing. Our wide range of solutions, based on our proprietary 3D printing technologies and materials, enhances the ability of designers, engineers and manufacturers to:
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•visualize and communicate product ideas and designs; |
•verify the form, fit and function of prototypes; |
•manufacture tools, jigs, fixtures, casts and injection molds used in the process of manufacturing end-products; |
•manufacture customized and short-to-medium-run end-products more efficiently and with greater agility, and more sustainably; and |
•produce objects that could not otherwise be manufactured through subtractive manufacturing methodologies. |
We benefit from recurring revenues from the sale of resin and plastic consumables and related services. We provide products and services to our global customer base throughout our offices in North America and internationally, including: Baden-Baden, Germany; Shanghai, China; and Tokyo, Japan, as well as through our worldwide network of over 130 resellers and channel partners who are exclusive to us and our additive manufacturing technologies. We have 1,779 employees worldwide, including what we believe is one of the largest additive manufacturing service bureaus in the United States.
Conflict Minerals
As we offer our clients products that might include Conflict Minerals that are necessary to the production or functionality of our manufactured products, we are subject to the reporting requirements associated with Conflict Minerals under Section 1502 of the Dodd-Frank Act and Rule 13p-1. We are committed to responsible sourcing, as outlined in our Conflict Minerals Policy. Further we are committed to conducting supply chain due diligence practices in alignment with the smelter or refiner verification program set up by third party audit bodies, such as the Responsible Minerals Initiative (“RMI”), and the London Bullion Market Association (“LBMA”). We are also committed to ensuring human rights are upheld in all respects, including the elimination of child or forced labor conditions in our supply chain, generally, and more specifically in CAHRAs. However, as we are “downstream”, in that we or our suppliers purchase cassiterite, columbite-tantalite (coltan), wolframite, gold, or their derivatives, which presently are limited to tin, tantalum, tungsten, and gold (collectively “3TG”) -related materials after processing by smelters or refiners, we can only report with reasonable certainty the origins or likely origins of the necessary 3TG in our minerals supply chain.
We furthermore do not directly purchase or procure raw materials from the mineral sites.
Our commitment to proper Conflict Mineral conduct is an element of our overall corporate responsibility. It relates, in part, to fair wages and working conditions (social and human capital care), and environmental stewardship (protection of our people and planet).
1. Reasonable Country of Origin Inquiry
In accordance with our Conflict Minerals Policy, we have concluded in good faith that during calendar year 2024, we have manufactured and contracted to manufacture products containing 3TG and have determined that the use of these minerals is necessary to the functionality or production of these products.
We performed a reasonable country of origin inquiry (“RCOI”) simultaneously with the due diligence phase in which we engaged to determine whether the Conflict Minerals necessary to the functionality or production of our products did or did not originate from the CAHRAs, as defined per Rule 13p-1. We integrated aspects of the RCOI into the design of our policies and management systems on Conflict Minerals and carry out the RCOI in the due diligence phase in which we engaged our relevant upstream suppliers to determine whether the Conflict Minerals necessary to the functionality or production of our products originated from the CAHRAs, as defined per Rule 13p-1. The RCOI and the due diligence process were done simultaneously due to the large number of applicable suppliers from which we source materials. We operate significantly downstream from the sources of the minerals necessary to the production and/or functionality of our products’ components. As such, we rely upon the due diligence conducted by our own applicable suppliers. The RCOI that we conducted therefore has certain limitations
that limit the total degree of certainty, and we cannot determine with absolute certainty the exact source location of all of the necessary Conflict Minerals used in our products in 2024. However, the RCOI we conducted employed several methods to assess whether the necessary Conflict Minerals in our products may have originated from the CAHRAs. These measures consisted primarily of the following actions:
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| a) | We performed internal assessments of our products and components to determine which of them contain, or for which the necessary Conflict Minerals were employed, in the production and manufacturing phases. |
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| b) | We identified a list of suppliers we purchased from directly during calendar year 2024 ("in-scope suppliers") and segmented the list according to the type of material the supplier provides. Some of the suppliers’ categories were excluded for the following reasons: they were not necessary to the functionality or production of the products, they did not contain the necessary Conflict Minerals, or the supplier provided a commercial off the shelf product. . Using a risk-based approach, the company then identified the 117 most significant suppliers, representing 95% of the company's spend on conflict minerals-containing components. The final list of suppliers we approached consists of 117 suppliers |
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| c) | We solicited survey responses using the standardized template designed by the Responsible Minerals Initiative (“RMI”), (the “Conflict Minerals Reporting Template version 6.4 and above” (“CMRT”)). We engaged our supply chain to respond to the CMRT by referring suppliers to training materials that included an overview of the law and instructions on how to complete the CMRT. These are part of our on-going efforts to ensure compliance with our responsible sourcing program among our suppliers, as well as contributing to our goal of increasing the number of relevant smelters or refiners that cooperate with Third Party Audit bodies, such as the RMI. |
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| d) | We assessed the responses received from our relevant suppliers of the necessary 3TG for information that would be identified as inconsistent, incomplete, or inaccurate. In addition, we validate CMRTs received from suppliers to identify deviation from the RMI’s requirements as per its Responsible Minerals Assurance Program (“RMAP”). Responses that failed any of the “red flag” review tests were identified for additional follow up. |
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| e) | To non-responsive in-scope suppliers, we sent periodic reminders to provide surveys or updated responses according to our expectations regarding the CMRT, such as provision of a current version (i.e., 6.4 or above). |
Based on the RCOI conducted, Stratasys has reason to believe that a portion of the Conflict Minerals necessary to the functionality of its products or its components is likely to have originated in the CAHRAs and has reason to believe, that those necessary Conflict Minerals may not be entirely from recycled or scrap sources. Based on this result, Stratasys conducted due diligence activities and details these efforts in this Conflict Minerals Report and in accordance with Stratasys’ Conflict Minerals Policy and general sourcing expectations from its suppliers.
2. Due Diligence
Due diligence design
In accordance with Rule 13p-1 and Form SD, we undertook to perform robust due diligence on the source and chain of custody of the 3TG-related materials included in our products to determine whether the Conflict Minerals necessary to the functionality or production of our products or products’ components originated from the DRC or the Covered Countries, or financially benefitted the armed groups in those countries in any way, as defined per Rule 13p-1. Because we have no direct relationships with smelters or refiners and therefore believe that we are a “downstream company”, we designed our due diligence measures according to the recommendations of the Organization for Economic Cooperation 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”) for downstream companies.
The five steps defined in the OECD Due Diligence Guidance are: (1) establishment of strong internal company management systems; (2) identification and assessment of risks in the supply chain; (3) design and implementation of a strategy to respond to risks as they are identified; (4) carry out independent third-party audits of smelters’ and refiners’ due diligence practices; and (5) report annually on supply chain due diligence.
We have undertaken (and continue to undertake) the foregoing five steps of due diligence as described below:
a. OECD Step 1: Establishment of strong company management systems
We review and maintain our management system to support supply chain due diligence related to the 3TG. Our management system includes a steering committee sponsored by the senior responsible executive and a team of subject matter experts from various functions such as supplier management, engineering, and legal. The team subject matter experts are responsible for implementing the Company’s Conflict Minerals compliance strategy. As part of responsible sourcing and supply chain due diligence, the Company has established the following actions: | | | | | |
| ● | Renewed our commitment to ethical business practices through the annual global training on our Code of Business Conduct and Ethics (“Code”) to all employees, which also includes a specific reference to Stratasys’ efforts as it relates to conflict minerals. Our Code is available at https://investors.stratasys.com/corporate-governance/governance-documents. |
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| ● | Continued focus on integrating social impact programs and practices as part of our business model and culture through the Stratasys Corporate Social Responsibility (“CSR”) Program, under our ESG & Sustainability umbrella. We are advancing additive manufacturing by securing access to our unique capabilities, making our technology more widely available to support quality education, healthcare and medical needs for those in need, and all-in-all putting into practice our 4 Stratasys defined UN Sustainable Development Goals with a global network of volunteers and NGO partners, we are proud to 3D Print a Better Tomorrow – together with our local communities. |
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| ● | We strive to ensure that purchased metals originate, to the greatest degree possible, only from smelters or refiners have been validated as conformant or active according to the RMI’s RMAP or other third-party audit programs, such as the LBMA. |
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| ● | In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and any other applicable policy and encourage them to define, implement and communicate to their sub-suppliers their own policy, outlining their commitment to responsible sourcing of 3TG and other minerals from conflict-afflicted areas, legal compliance and measures for implementation of the supply chain due diligence. Our Conflict Minerals Policy is available at https://investors.stratasys.com/corporate-governance/governance-documents. |
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| ● | Maintained the Company’s Conflict Minerals Governance Charter that sets out the Conflict Minerals annual due diligence plan including establishing steps for compliance, objectives, timelines, internal management and the cross functional team with identified roles and responsibilities to support supply chain due diligence. |
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| ● | Conducted ongoing communication of the cross functional Conflict Minerals team, for the purpose of sharing best practices and monitoring our progress regarding the various steps required for achieving compliance among our suppliers. |
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| ● | Engaged with in-scope suppliers of the necessary 3TG and referred them to training materials online, including an overview of relevant Conflict Minerals regulations and compliance measures, and instructions on how to respond to the due diligence survey (based on receiving at a minimum version 6.4 of the CMRT or higher). |
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| ● | Continued to include a Conflict Minerals provision in our standard Purchasing Terms and Conditions for Goods and Services to require suppliers to comply with our Conflict Minerals Policy and requirements. |
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| ● | Communicated the due diligence efforts both internally and externally to relevant direct suppliers, surveyed suppliers, customers, employees, senior management, and all Company stakeholders, as requested and applicable. |
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| ● | Maintained a grievance mechanism whereby concerns and violations of the Conflict Minerals Policy should be reported to Stratasys’ Compliance Officer / Chief Legal Officer. |
b. OECD Step 2: Identify and assess risk in the supply chain
As part of our risk-based approach for the management of a responsible supply chain, Stratasys identified the suppliers from which it made purchases over a specified amount during 2024. We assessed two primary risks in our supply chain while trying to move towards the goal of sourcing the necessary Conflict Minerals from smelters or refiners that have received a conformant or active designation from the RMI or other Third Party Audit bodies, such as the LBMA: (1) the risk of not receiving timely and accurate information from the supplier; and (2) the risk of not being able to replace a supplier due to reasons such as volume, ease of replacement, complexity of relationship and criticality to business operations.
In order to segment our suppliers into three risk levels (high, medium and low) we have identified and assessed Conflict Minerals-related risks based on suppliers’ and manufacturers’ characteristics, such as the amount we have spent with a supplier during calendar year 2024 and the extent to which we are dependent upon any particular manufacturer or supplier as well as the availability of alternative suppliers. This segmentation allowed us to prioritize our risk mitigation efforts based on the level of supplier risk.
We have identified, to the best of our efforts, the smelters or refiners in our minerals supply chain by conducting a supply chain inquiry using, at a minimum, version 6.4 or higher of the CMRT, requesting suppliers and manufactures to identify smelters or refiners and the likely country of origin of the Conflict Minerals in products or product components that they supply to Stratasys. In addition, Stratasys compared smelters or refiners identified by the supply chain survey against the list of facilities that have received a conformant or active designation under the RMI’s RMAP and other independent third-party audit programs.
As part of the risk assessment phase, we identified that 67.61% of our in-scope suppliers have a policy in place that addresses the Conflict Minerals sourcing and 55.68% do not provide us with products containing Conflict Minerals.
c. OECD Step 3: Design and implement a strategy to respond to identified risks
The findings of the supply chain risk assessment were and continue to be reported to designated members of our senior management. As part of our risk management strategy, we continue to work with the in-scope suppliers while we advance our efforts to investigate our supply chain as follows: | | | | | |
| ● | Continued periodic reporting to the Conflict Minerals team sponsor to track progress, assess risks and provide management support as needed. |
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| ● | Contacted in-scope suppliers whose responses were identified as incomplete, inconsistent or inaccurate. |
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| ● | Reviewed in-scope suppliers’ responses to track smelters or refiners in our supply chain that supply us with Conflict Minerals and have not received a conformant or active designation from the RMI’s RMAP program or other independent third-party audit programs. |
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| ● | Referred in-scope suppliers to online training materials that included an overview of Rule 13p-1 and instructions on how to complete the CMRT. |
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| ● | As part of our continued risk management efforts, we send follow-up letters to high-risk, non-responsive in-scope suppliers, as well as to in-scope suppliers who have declared the existence of conflict minerals in their supply chain from smelters or refiners in CAHRAs that do not participate in the RMAP. Additionally, we have sent risk management letters to suppliers providing an outdated version of the CMRT, and to those declaring the presence of conflict minerals from uncertified smelters not located in the covered countries. We also require verification from suppliers who have declared their products to be “conflict-free.” we remain committed to the responsible sourcing of conflict minerals, we do not seek to eliminate sourcing from the CAHRAs. Instead, we continue to engage with our suppliers to address the identified risks and ensure compliance with Rule 13p-1. |
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 occasionally and update the risk mitigation strategy accordingly while consulting and communicating with relevant stakeholders.
d. OECD Step 4: Review independent third-party audits of smelter or refiner due diligence practices
Stratasys is a downstream consumer of necessary Conflict Minerals and is many steps removed from the smelters or refiners who process, provide and mine the minerals and ores. Therefore, Stratasys does not perform direct audits of smelters or refiners within its supply chain. Instead, our due diligence efforts rely on cross-industry initiatives, such as those led by the RMI (i.e., the RMAP) to conduct smelter or refiner due diligence to verify and audit the status of the smelters or refiners.
e. OECD Step 5: Prepare this annual report on supply chain due diligence
Stratasys’ Conflict Mineral Policy states that we will comply with Section 1502 of the Dodd Frank Act which includes filing a Form SD and this Conflict Minerals report with the SEC and posting publicly on the Internet (https://investors.stratasys.com/corporate-governance/governance-documents).
3. Results of the Assessment
We conducted a supply chain survey of the 84 in-scope suppliers that we identified may contribute necessary Conflict Minerals to our products. In calendar year 2024 we included metal, electronics and plastic suppliers and manufacturers and took a risk-based approach which focused on suppliers and manufacturers with which we have spent a majority of our manufacturing-related expenses.
We received responses from in-scope suppliers representing approximately an 80.73% response rate, containing the names and locations of reported smelters or refiners (see Annex 1) and the potential countries of origin (see Annex 2) of the mines or facilities that process Conflict Minerals, compared to approximately an 84.34% response rate attained for reporting year 2023.
Of the 80.73% (88 from 113) of suppliers and manufacturers that responded: | | | | | |
| ● | 0% of in-scope suppliers were classified as “DRC conflict free” |
| ● | 9% of in-scope suppliers were classified as “Not from DRC” |
| ● | 56% of in-scope suppliers were classified as “Free no 3TG” |
| ● | 7% of in-scope suppliers were classified as “Undetermined not from DRC” |
| ● | 8% of in-scope suppliers were classified as “Undetermined from DRC” |
| ● | 21% of in-scope suppliers were classified as “Undefined from DRC” |
The terms above have the following meaning as part of our due diligence efforts: | | | | | |
| ● | “DRC conflict free” indicates the in-scope suppliers that reported that Conflict Minerals used in the products provided to Stratasys originate from the DRC or one of the Covered Countries, but that the smelters are approved by the RMAP, the RMI’s Responsible Minerals Assurance Program. |
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| ● | “Not from DRC” indicates the in-scope suppliers reported that they source Conflict Minerals, but from countries other than the DRC or Covered Countries. |
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| ● | “Free no 3TG” indicates the in-scope suppliers reported that Conflict Minerals are not contained in the product, or which are not necessary for the functionality or are not included in the production of the products, provided to Stratasys. |
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| ● | “Undetermined not from DRC” indicates the in-scope suppliers that reported that Conflict Minerals being used in the products do not originate from the DRC or one of the Covered Countries, but they have not yet concluded their due diligence process so this determination could potentially change. Due diligence for these in-scope suppliers will continue until their status is confirmed. |
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| ● | “Undetermined from DRC” indicates the in-scope suppliers that reported that Conflict Minerals used originate from the DRC or one of the Covered Countries and that the smelters or refiners are approved by the RMAP, but they have not yet concluded their due diligence process so this determination could potentially change. Due diligence for these in-scope suppliers will continue until the status is confirmed. |
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| ● | “Undefined from DRC” indicates the in-scope suppliers that reported that Conflict Minerals used originate from the DRC or one of the Covered Countries and that the smelters or refiners are not yet approved by the RMAP. Due diligence for these in-scope suppliers will continue until the status is confirmed. |
Despite in-scope suppliers indicating that they source Conflict Minerals from the DRC and Covered Countries, these in-scope suppliers were unable to accurately report which specific smelters or refiners were part of the supply chain in terms of the components sold to Stratasys in 2024.
As a result of this lack of information, we are unable to determine with complete accuracy the full list of facilities used to process those necessary Conflict Minerals or their likely country of origin, and therefore, we are unable to conclude whether or not the Conflict Minerals used in our products may have directly or indirectly financed armed groups in the CAHRAs. Our efforts to determine the likely mine(s) or location of origin for the necessary Conflict Minerals are realized through the due diligence measures described above.
Smelters or refiners verified as conflict-free or in the audit process:
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| Tin | 72 of 93 (77.42%) |
| Tantalum | 34 of 36 (94.44%) |
| Tungsten | 37 of 56 (66.10%) |
| Gold | 95 of 183 (51.91%) |
| Total | 238 of 368 (64.67%) |
Status of identified smelters or refiners:
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| Verified Conflict Free (RMI Compliant) | 234 of 368 (63.59%) |
| Participating in an audit process (RMI Active) | 4 of 368 (1.09%) |
Total (Conflict Free and under Audit process) | 238 of 368 (64.67%) |
| Not Participating | 130 of 368 (35.33%) |
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Stratasys. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect our conclusions.
These factors include, but are not limited to, gaps in product or product content information, gaps in supplier data, errors or omissions by or of suppliers, confusion over requirements of SEC final rules, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier unfamiliarity with Rule 13p-1 and or with our Conflict Minerals Policy, conflict-area sourced materials being declared as secondary materials, companies going out of business in 2024 and the potential smuggling of conflict-area Conflict Minerals to countries beyond the CAHRAs.
We do not gather information from our suppliers on a continuous or real-time basis, but rather information is gathered from suppliers at the time that it is provided in a CMRT of at least version 6.4 or higher.
We cannot be completely certain of our conclusions regarding the source and chain of custody of the necessary Conflict Minerals used or necessary to the production or for the functionality of our products or product components in 2024, as the information comes from direct and secondary suppliers and independent third-party audit programs.
Continuous improvement efforts to mitigate risk
Stratasys continues to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals, as required by Rule 13p-1. Stratasys continues to take, as applicable, the following steps to improve the due diligence process and mitigate the possibility that we are utilizing Conflict Minerals that, directly or indirectly, benefit armed groups propagating human rights violations in the CAHRAs: | | | | | |
| ● | Work with in-scope suppliers that did not respond to Stratasys’ surveys to help them understand the importance of this initiative to Stratasys and to encourage their participation in 2025. |
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| ● | Attempt to validate in-scope supplier responses using information collected via independent, conflict-free smelter validation programs such as the RMAP. |
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| ● | Send follow-up letters to high risk non-responsive in-scope suppliers and to in-scope suppliers with Conflict Minerals from the CAHRAs, as well as from smelters or refiners that do not participate in the RMI’s RMAP. |
In addition to the above steps, Stratasys continues to implement its Conflict Minerals Policy and Code of Conduct to the best of its abilities, namely via communication to its stakeholders and suppliers regarding its Conflict Minerals Policy.
This report contains “forward-looking statements” within the meaning of U.S. federal securities laws. These forward-looking statements can generally be identified as such because the context of the statement will include words such as “may”, “will,” “intends,” “plans,” “believes,” “anticipates,” “expects,” “estimates,” “predicts,” “potential,” “continue,” or “opportunity,” the negative of these words or words of similar import. Examples of forward-looking statements include statements relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may or may not prove to be accurate. Forward-looking statements are subject to risks, uncertainties and other factors that could cause actual results to differ materially from those stated in such statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by U.S. federal securities laws.
Annex 1
Names and Locations of Smelters or Refiners
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| Metal | Smelter Name | Smelter Country |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Agosi AG | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden Ronnskar | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Caridad | MEXICO |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Dowa | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
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| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Gold Co., Ltd. | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | Materion | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | MKS PAMP SA | SWITZERLAND |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| | | | | | | | |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
| Gold | Yamakin Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
| Gold | Morris and Watson | NEW ZEALAND |
| Gold | SAFINA A.S. | CZECHIA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Sudan Gold Refinery | SUDAN |
| Gold | T.C.A S.p.A | ITALY |
| Gold | REMONDIS PMR B.V. | NETHERLANDS |
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| | | | | | | | |
| Gold | Industrial Refining Company | BELGIUM |
| Gold | Shirpur Gold Refinery Ltd. | INDIA |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Marsam Metals | BRAZIL |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA |
| Gold | Albino Mountinho Lda. | PORTUGAL |
| Gold | SAAMP | FRANCE |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | 8853 S.p.A. | ITALY |
| Gold | Italpreziosi | ITALY |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | Sai Refinery | INDIA |
| Gold | Modeltech Sdn Bhd | MALAYSIA |
| Gold | Bangalore Refinery | INDIA |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| Gold | Pease & Curren | UNITED STATES OF AMERICA |
| Gold | JALAN & Company | INDIA |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | ABC Refinery Pty Ltd. | AUSTRALIA |
| Gold | Safimet S.p.A | ITALY |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | African Gold Refinery | UGANDA |
| Gold | Gold Coast Refinery | GHANA |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA |
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| Gold | CGR Metalloys Pvt Ltd. | INDIA |
| Gold | Sovereign Metals | INDIA |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Gold | Augmont Enterprises Private Limited | INDIA |
| Gold | Kundan Care Products Ltd. | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
| | | | | | | | |
| Gold | K.A. Rasmussen | NORWAY |
| Gold | Alexy Metals | UNITED STATES OF AMERICA |
| Gold | MD Overseas | INDIA |
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| Gold | WEEEREFINING | FRANCE |
| Gold | Gold by Gold Colombia | COLOMBIA |
| Gold | Dongwu Gold Group | CHINA |
| Gold | Sam Precious Metals | UNITED ARAB EMIRATES |
| Gold | NOBLE METAL SERVICES | UNITED STATES OF AMERICA |
| Gold | Coimpa Industrial LTDA | BRAZIL |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | CHINA |
| Gold | GG Refinery Ltd. | TANZANIA, UNITED REPUBLIC OF |
| Gold | Impala Refineries – Base Metals Refinery (BMR) | SOUTH AFRICA |
| Gold | Impala Rustenburg | SOUTH AFRICA |
| Gold | Attero Recycling Pvt Ltd | INDIA |
| Gold | Inca One (Chala One Plant) | PERU |
| Gold | Inca One (Koricancha Plant) | PERU |
| Gold | Impala Refineries – Platinum Metals Refinery (PMR) | SOUTH AFRICA |
| Gold | Elite Industech Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | AMG Brasil | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | NPM Silmet AS | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| | | | | | | | |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET de Mexico | MEXICO |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND |
| Tantalum | TANIOBIS GmbH | GERMANY |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| Tantalum | 5D Production OU | ESTONIA |
| Tantalum | PowerX Ltd. | RWANDA |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | Alpha | UNITED STATES OF AMERICA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Premium Tin Indonesia | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Estanho de Rondonia S.A. | BRAZIL |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | Novosibirsk Tin Combine | RUSSIAN FEDERATION |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| | | | | | | | |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| Tin | PT Timah Nusantara | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Thaisarco | THAILAND |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | PT Tirus Putra Mandiri | INDONESIA |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | PT Rajehan Ariq | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Super Ligas | BRAZIL |
| Tin | Aurubis Beerse | BELGIUM |
| Tin | Aurubis Berango | SPAIN |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Sukses Inti Makmur (SIM) | INDONESIA |
| | | | | | | | |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Modeltech Sdn Bhd | MALAYSIA |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | PT Bangka Serumpun | INDONESIA |
| Tin | Pongpipat Company Limited | MYANMAR |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | Luna Smelter, Ltd. | RWANDA |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Precious Minerals and Smelting Limited | INDIA |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| Tin | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | CRM Synergies | SPAIN |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL |
| Tin | DS Myanmar | MYANMAR |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | JAPAN |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA |
| Tin | PT Mitra Graha Raya | INDONESIA |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | INDIA |
| Tin | Woodcross Smelting Company Limited | UGANDA |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | AUSTRALIA |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | CHINA |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| | | | | | | | |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | Masan High-Tech Materials | VIET NAM |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tungsten | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | Artek LLC | RUSSIAN FEDERATION |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA |
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION |
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION |
| Tungsten | LLC Vostok | RUSSIAN FEDERATION |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CHINA |
| Tungsten | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF |
| | | | | | | | |
| Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM |
| Tungsten | Nam Viet Cromit Joint Stock Company | VIET NAM |
| Tungsten | MALAMET SMELTING SDN. BHD. | MALAYSIA |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | KOREA, REPUBLIC OF |
| Tungsten | Lianyou Resources Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CHINA |
| Tungsten | Philippine Carreytech Metal Corp. | PHILIPPINES |
| Tungsten | Kenee Mining Corporation Vietnam | VIET NAM |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation | PHILIPPINES |
Annex 2
Country of Origin (COO)*
| | | | | | | | | | | |
| Gold | Tantalum | Tin | Tungsten |
| ANDORRA | BRAZIL | AUSTRALIA | AUSTRIA |
| AUSTRALIA | CHINA | BELGIUM | BRAZIL |
| AUSTRIA | ESTONIA | BOLIVIA (PLURINATIONAL STATE OF) | CHINA |
| BELGIUM | GERMANY | BRAZIL | GERMANY |
| BRAZIL | INDIA | CHINA | JAPAN |
| CANADA | JAPAN | CONGO, DEMOCRATIC REPUBLIC OF THE | KOREA, REPUBLIC OF |
| CHILE | KAZAKHSTAN | INDIA | MALAYSIA |
| CHINA | MEXICO | INDONESIA | PHILIPPINES |
| COLOMBIA | RUSSIAN FEDERATION | JAPAN | RUSSIAN FEDERATION |
| CZECHIA | RWANDA | MALAYSIA | TAIWAN, PROVINCE OF CHINA |
| FRANCE | THAILAND | MYANMAR | UNITED STATES OF AMERICA |
| GERMANY | UNITED STATES OF AMERICA | PERU | VIET NAM |
| GHANA | | PHILIPPINES | |
| INDIA | | POLAND | |
| INDONESIA | | RUSSIAN FEDERATION | |
| ITALY | | RWANDA | |
| JAPAN | | SPAIN | |
| KAZAKHSTAN | | TAIWAN, PROVINCE OF CHINA | |
| KOREA, REPUBLIC OF | | THAILAND | |
| KYRGYZSTAN | | UGANDA | |
| LITHUANIA | | UNITED STATES OF AMERICA | |
| MALAYSIA | | VIET NAM | |
| MEXICO | | | |
| NETHERLANDS | | | |
| NEW ZEALAND | | | |
| NORWAY | | | |
| PERU | | | |
| PHILIPPINES | | | |
| POLAND | | | |
| PORTUGAL | | | |
| RUSSIAN FEDERATION | | | |
| SAUDI ARABIA | | | |
| SINGAPORE | | | |
| | | | | | | | | | | |
| SOUTH AFRICA | | | |
| SPAIN | | | |
| SUDAN | | | |
| SWEDEN | | | |
| SWITZERLAND | | | |
| TAIWAN, PROVINCE OF CHINA | | | |
| TANZANIA, UNITED REPUBLIC OF | | | |
| THAILAND | | | |
| TURKEY | | | |
| UGANDA | | | |
| UNITED ARAB EMIRATES | | | |
| UNITED STATES OF AMERICA | | | |
| UZBEKISTAN | | | |
| ZIMBABWE | | | |
*As not all of the smelters or refiners (SORs) reported by our suppliers or manufacturers in the supply chain inquiry provided information on the Location of Mine in their CMRTs, and we were not able to establish from the SORs complete sourcing information on their Conflict Minerals, we have indicated for the COO the closest indication provided as to the source of Conflict Minerals, i.e., the Smelter Country as reported in the suppliers’ CMRT.