Document

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 FORM SD
SPECIALIZED DISCLOSURE REPORT
TRIMBLE INC.
(Exact name of registrant as specified in its charter)
Delaware 001-14845 94-2802192
(State or other jurisdiction of incorporation) (Commission
File Number)
 (IRS. Employer
Identification No.)

935 Stewart Drive
Sunnyvale, CA 94085
(Address of principal executive offices)

James A. Kirkland
Senior Vice President, General Counsel and Secretary
(408) 481-8000
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
x
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.




Section 1 - Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit
A copy of Trimble Inc.’s Conflict Minerals Report is provided as Exhibit 1.01 to this Report and is available at the following address:
    http://www.trimble.com/Corporate/Compliance/compliance_resources
Section 2 - Exhibits
Item 2.0.1 Exhibits
Exhibit No.Description
1.01




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.
 
TRIMBLE INC.
/s/ JAMES A. KIRKLAND
By: James A. Kirkland, Senior Vice President, General Counsel and Secretary
Date: June 1, 2021

Document

Exhibit 1.01
Trimble Inc.
Conflict Minerals Report for the Year Ended December 31, 2020
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 publicly 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 2020 calendar year in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.
Rule 13p-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, construction, survey and 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 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.
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 our current Conflict Minerals Report, are published on our public website and available at:
www.trimble.com/Corporate/Compliance/compliance_resources
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 such in-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 deemed out-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 its in-scope suppliers to use, the Responsible Minerals Initiative’s (“RMI”) reporting template to identify whether in-source suppliers source 3TG from the Covered Countries or from recycled or scrap sources. The RMI reporting template 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 RMI reporting template by our supply chain, as well as smelter information provided by the RMI 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 are in-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. Additionally, we have established a Supplier Code of Conduct, which is based upon the Responsible Business Alliance’s Code of Conduct.
Trimble requires in-scope suppliers to source from smelters that are either conformant with the Responsible Minerals Assurance Process (“RMAP”), have undergone another recognized third-party audit program (such as the London Bullion Market Association (LBMA) or the Responsible Jewellery Council (RJC)), or are in the process of achieving audit conformance. In the event of non-conformance by an in-scope supplier, we require the supplier to pursue corrective actions, and, in the event of continued non-conformance, we may consider 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 our in-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 conducting our three-phase assessment, we requested in-scope suppliers to provide us with information using the RMI reporting template. We received a 95% response rate, which is similar to our previous year’s response rate. Based on the responses from our in-scope suppliers and a review and analysis of the responses against RMI’s RMAP Conformant Smelters & Refiners list, which provides sourcing information and audit status for certified smelters (as well as sourcing information for LBMA and RJC audited smelters) we concluded that, of the identified smelters:
82% were identified as being Conformant (i.e. smelters that have completed an audit and conform with RMAP or another third-party program).
Of these Conformant smelters, 36% reported sourcing from Covered Countries.
Based on our internal assessment of in-scope suppliers and the RMI reporting template information we received back from our in-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 (Third Edition),” and the related supplements, published by the Organisation for Economic Co-operation and Development (OECD).



The worldwide COVID-19 coronavirus pandemic in 2020 significantly impacted the operation of mines and processing facilities and disrupted mineral resource supply chains. In addition to facility closures and disruption to international shipments of minerals, there was also a significant impact on the ability of organizations to assess smelters and conduct audits in the face of local quarantines and closures. This impacted the accuracy and completeness of information available to us in conducting our due diligence activities for 2020.
The following describes Trimble’s due diligence activities for the 2020 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 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 conflict minerals training and orientation materials to assist our suppliers in completing the RMI reporting template and provide support to answer suppliers’ questions. We maintain a conflict minerals resource page with links to resources about the conflict minerals law, the reporting template and our contact information for conflict minerals related inquiries: www.trimble.com/Corporate/Compliance/compliance_resources.
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.
Step 2: Identify and Assess Risk in the Supply Chain
We requested each in-scope supplier to complete and return a reporting template 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 standardized reporting template developed by RMI as the best method for collecting information about Trimble’s suppliers to identify and assess risks.
We tracked responses from in-scope suppliers and initially categorized suppliers according to whether they provided in their responses: (i) legitimate smelter information, or (ii) inconsistent or incomplete information about smelters that required further investigation.
We used RMI’s smelters and refiners database to obtain conflict minerals sourcing information for the smelters identified on the completed reporting templates from our in-scope suppliers.
We followed a defined process for reviewing and evaluating reporting template responses, including procedures to address incomplete or vague answers and to follow up with suppliers, as necessary.
We identified any “high risk” suppliers that require additional attention by focusing on suppliers that: (i) list smelters that are in the Covered Countries and are not found on the RMAP Conformant Smelters & Refiners list. (ii) list smelters that have been found to be non-conformant with the RMAP or similar third- party audit programs, (iii) list unresponsive smelters that are unwilling to undertake compliance with the



RMAP or another third-party audit program, or (iv) list smelters that we identified through our trade compliance screening as smelters that may be financed by a U.S.-embargoed or -sanctioned country, or that are identified as potentially supporting armed conflict or human rights violations.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
We obtained updated smelter status data from RMI’s smelters and refiners database and compared supplier provided information against such data. Smelters found not in conformance with the RMAP or other independent third-party audit programs (such as the Tin Supply Chain Initiative List and the London Bullion Market Good Delivery Lists) were flagged for further due diligence.
Any supplier that Trimble identified as “high risk” underwent further investigation and was subject to additional risk mitigation requests by Trimble.
We informed our in-scope suppliers of identified high risk smelters and requested our suppliers to conduct further due diligence and to work with their supply chains to ensure compliance, such as by requesting impacted suppliers to utilize RMI’s smelter outreach letter in reaching out to non-certified smelters and press them for compliance, or to find substitute smelters.
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 participate in and support RMI’s working groups on smelter due diligence practices for risk mitigation.
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 RMI and rely on RMI’s data to validate the audit status and sourcing information of smelters.
We conduct our own due diligence through publicly available information regarding identified high risk smelters to validate the existence and assess the conflict status of smelters.
We address conflict minerals in our general supplier audits, focusing on supplier reporting template responses and due diligence programs.
Step 5: Report on supply chain due diligence
Our annual Conflict Minerals Report is publicly accessible on our website.
We remind “high risk” suppliers of our expectations for the upcoming 2021 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 333 smelters within our supply chain that were potential sources of 3TG for our suppliers.
We utilized RMI’s smelters database to obtain recent smelter audit status as of February 22, 2021. The table below summarizes the status of smelters that were identified through the information provided by our in-scope suppliers. Trimble has adopted the same audit status designations utilized by RMI to categorize audit compliance status. “Conformant” smelters are those that have completed an audit and conform with RMAP or other third party programs. “Active” smelters are those that are engaging with RMAP or other third party auditors to achieve compliance. “In Communication” refers to smelters that are not certified, but which demonstrate interest in participating in an audit program. “Alleged” are smelters that are not certified and have not yet even been verified to be a true smelter or still in business. “Non- Conformant” are those smelters that have been identified as having non-conformant audit results.
Schedule A lists all of the verified smelters reported by our in-scope suppliers that we believe processed 3TG which may have been used in Trimble products during the 2020 reporting period.



2020 Trimble Smelters or Refiners Audit Status

Metal: Smelter Status:
Conformant SmeltersActive SmeltersIn Communication SmeltersAlleged SmeltersNon-Conformant Smelters
Gold108 13 42 
Tantalum37 — — — — 
Tin54 
Tungsten41 — 
Total240 18 16 51 8 

Of the 333 entities identified as smelters or alleged smelters, 240 smelters had associated mine disclosure information that was provided to us by RMI. From this information, we determined that 135 of those smelters did not source 3TG from the Covered Countries. For the 105 smelters that sourced 3TG from Covered Countries, we determined that they were certified as Conformant by RMI.
Trimble identified certain smelters as potentially high risk in its supply chain, and requested follow-up actions from 53 in-scope suppliers that listed at least one of the smelters identified as high risk. All 53 suppliers have either completed due diligence follow-up actions, acknowledged Trimble’s requests and outlined their action plans for further due diligence, or have reported utilizing smelters that are not located in Covered Countries. Trimble continues to monitor the progress of these suppliers and will consider additional 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 RMAP Conformant 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 RMI 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 RMI 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 in Schedule 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 Conformant by RMI. In addition, we are not aware of any instance where 3TG sourced from the Covered Countries directly or indirectly financed or benefited armed groups.
Future Due Diligence Measures
We intend to take the following measures in 2021 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 work to increase the response rate and quality of supplier responses by: working directly with our suppliers on the completion of their RMI reporting templates including direct engagement of our strategic key suppliers and providing additional conflict minerals training to suppliers who have been unable to provide sufficient response quality.
Encourage suppliers to adopt best practices for the responsible sourcing of materials, and to direct all smelters in their supply chains to participate in the RMAP or similar third-party audit program.
Monitor the progress of suppliers with high risk smelters identified within their supply chains.
Continue to communicate with our suppliers regarding Trimble’s Conflict Minerals Policy and Supplier Requirements for the Sourcing of Conflict Minerals 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.



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.
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.



Schedule A
Verified Smelters and Refiners

Metal
Smelter Name
Country
Gold
8853 S.P.A.
ITALY
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 Refinery Dmcc
UNITED ARAB EMIRATES
Gold
Alexy Metals
UNITED STATES OF AMERICA
Gold
Allgemeine Gold-Und Silberscheideanstalt A.G.
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
Asahi Refining Canada Ltd.
CANADA
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
Au Traders And Refiners
SOUTH AFRICA
Gold
Augmont Enterprises Private Limited
INDIA
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
Caridad
MEXICO
Gold
Cendres + Metaux S.A.
SWITZERLAND
Gold
Chimet S.P.A.
ITALY
Gold
Chugai Mining
JAPAN
Gold
Dijllah Gold Refinery Fzc
UNITED ARAB EMIRATES
Gold
Doduco Contacts And Refining Gmbh
GERMANY
Gold
Dowa Metals & Mining Co. Ltd
JAPAN
Gold
Ds Pretech Co., Ltd.
KOREA, REPUBLIC OF
Gold
Dsc (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
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
Emirates Gold Dmcc
UNITED ARAB EMIRATES
Gold
Fidelity Printers And Refiners Ltd.
ZIMBABWE
Gold
Gcc Gujrat Gold Centre Pvt. Ltd.
INDIA
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
Henan Zhongyuan Gold Smelter Of Zhongjin Gold Corporation Limited
CHINA
Gold
Heraeus Ltd. Hong Kong
CHINA
Gold
Hunan Chenzhou
GERMANY
Gold
Hwaseong Cj Co., Ltd.
KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold And Silver Refinery Share Co., Ltd.
CHINA
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Italpreziosi
ITALY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
Johnson Matthey Inc. (Usa)
UNITED STATES OF AMERICA
Gold
Jsc Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
Jsc Uralelectromed
RUSSIAN FEDERATION
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting Llc
KAZAKHSTAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper Llc
UNITED STATES OF AMERICA
Gold
Kghm Polska Miedz Spolka Akcyjna
POLAND
Gold
Kojima Kagaku Yakuhin Co., Ltd
JAPAN
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn Jsc
KYRGYZSTAN
Gold
Lazurde Company For Jewelry
SAUDI ARABIA
Gold
L'Orfebre S.A.
ANDORRA
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
Md Overseas
INDIA
Gold
Metal Concentrators Sa (Pty) Ltd.
SOUTH AFRICA
Gold
Metallix Refining Inc.
UNITED STATES OF AMERICA
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
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mmtc-Pamp India Pvt., Ltd.
INDIA
Gold
Modeltech Sdn Bhd
MALAYSIA
Gold
Morris And Watson
NEW ZEALAND
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
Nh Recytech Company
KOREA, REPUBLIC OF



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 Krasnoyarsk Non-Ferrous Metals Plant" (Ojsc Krastsvetmet)
RUSSIAN FEDERATION
Gold
Ojsc Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
Pamp S.A.
SWITZERLAND
Gold
Pan Pacific Copper Co Ltd.
JAPAN
Gold
Planta Recuperadora De Metales Spa
CHILE
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
Remondis Pmr B.V.
NETHERLANDS
Gold
Royal Canadian Mint
CANADA
Gold
Saamp
FRANCE
Gold
Safimet S.P.A
ITALY
Gold
Safina A.S.
CZECHIA
Gold
Samdok Metal
KOREA, REPUBLIC OF
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Gold
Sancus Zfs (L’Orfebre, Sa)
COLOMBIA
Gold
Saxonia Edelmetalle Gmbh
GERMANY
Gold
Sempsa Joyeria Plateria S.A.
SPAIN
Gold
Shyolkovsky
RUSSIAN FEDERATION
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
C.I Metales Procesados Industriales SAS
COLOMBIA
Gold
Kundan Care Products Ltd.
INDIA
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
Sungeel Himetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
T.C.A S.P.A
ITALY
Gold
Takehara Refinery
JAPAN
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
Too Tau-Ken-Altyn
KAZAKHSTAN
Gold
Torecom
KOREA, REPUBLIC OF
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
Xstrata
CANADA
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Zhao Yuan Gold Smelter Of Zhongjin
CHINA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
Cid000092
JAPAN
Tantalum
D Block Metals, Llc
UNITED STATES OF AMERICA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
F & X
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 Tantalum And Niobium Gmbh
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
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
Lsm Brasil S.A.
BRAZIL
Tantalum
Metallurgical Products India Pvt. Ltd. (Mpil)
INDIA
Tantalum
Mineracao Taboca Sa
BRAZIL
Tantalum
Mitsui Mining And Smelting Co., Ltd.
JAPAN
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
Npm Silmet As
ESTONIA
Tantalum
Power Resources Ltd.
NORTH MACEDONIA, REPUBLIC OF
Tantalum
Quantumclean
UNITED STATES OF AMERICA
Tantalum
Resind Indústria E Comércio Ltda.
BRAZIL
Tantalum
Rfh Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Solikamsk Metal Works
RUSSIAN FEDERATION
Tantalum
Taki Chemicals
JAPAN
Tantalum
Taniobis Smelting Gmbh & Co. Kg
GERMANY
Tantalum
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tantalum
Ulba
KAZAKHSTAN
Tantalum
Xinxing Haorong Electronic Material Co., Ltd.
CHINA
Tin
Brand Rbt
INDONESIA
Tin
Chenzhou Yunxiang Mining And Metallurgy Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
Cookson
UNITED STATES OF AMERICA



Tin
Crm Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
BRAZIL
Tin
Crm Synergies
SPAIN
Tin
Cv Venus Inti Perkasa
INDONESIA
Tin
Dongguan Ciexpo Environmental Engineering Co., Ltd.
CHINA
Tin
Dowa Metaltech Co., Ltd.
JAPAN
Tin
Electro-Mechanical Facility Of The Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Tin
Enaf
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Estanho De Rondonia S.A.
BRAZIL
Tin
Fenix Metals
POLAND
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Tin
Gejiu Kai Meng Industry And Trade Llc
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co. Ltd.
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
Gejiu Zi-Li
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Tin
Huichang Hill Tin Industry Co., Ltd.
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
Liuzhhou China Tin
CHINA
Tin
Maanshan Weitai Tin 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 Belgium N.V.
BELGIUM
Tin
Metallo Spain S.L.U.
SPAIN
Tin
Mineração Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Modeltech Sdn Bhd
MALAYSIA
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Precious Minerals And Smelting Limited
INDIA
Tin
Pt Aries Kencana Sejahtera
INDONESIA
Tin
Pt Artha Cipta Langgeng
INDONESIA
Tin
Pt Atd Makmur Mandiri Jaya
INDONESIA
Tin
Pt Bangka Serumpun
INDONESIA
Tin
Pt Menara Cipta Mulia
INDONESIA
Tin
Pt Mitra Stania Prima
INDONESIA
Tin
Pt Prima Timah Utama
INDONESIA
Tin
Pt Timah (Persero) Tbk Mentok
INDONESIA
Tin
Pt Timah Tbk Kundur
INDONESIA
Tin
Pt Tinindo Inter Nusa
INDONESIA
Tin
Resind Indústria E Comércio Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
PT Babel Surya Alam Lestari
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Timah Nusantara
INDONESIA
Tin
PT Rajehan Ariq
INDONESIA
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Tin
PT Rajawali Rimba Perkasa
INDONESIA
Tin
Novosibirsk Processing Plant Ltd.
RUSSIAN FEDERATION
Tin
Luna Smelter, Ltd.
RWANDA
Tin
Soft Metais Ltda.
BRAZIL
Tin
Super Ligas
BRAZIL
Tin
Thai Nguyen Mining And Metallurgy Co., Ltd.
VIET NAM



Tin
Thaisarco
THAILAND
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
White Solder Metalurgia E Mineracao Ltda.
BRAZIL
Tin
Yunnan Chengfeng
CHINA
Tin
Yunnan Tin Company, Ltd.
CHINA
Tin
Yunnan Yunfan Non-Ferrous Metals Co., Ltd.
CHINA
Tungsten
A.L.M.T. Tungsten Corp.
JAPAN
Tungsten
Acl Metais Eireli
BRAZIL
Tungsten
Artek Llc
RUSSIAN FEDERATION
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
China Molybdenum Co., Ltd.
CHINA
Tungsten
Cronimet Brasil Ltda
BRAZIL
Tungsten
Fujian Ganmin Raremetal Co., Ltd.
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co Ltd
CHINA
Tungsten
Gtp
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
Human Chun-Chang Non-Ferrous Smelting & Concentrating Co., Ltd.
CHINA
Tungsten
Hunan Chenzhou Mining Group Co., Ltd.
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Tungsten
Hunan Litian Tungsten Industry 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 Minmetals Gaoan Non-Ferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-Ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
Jsc "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
Kgets Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Masan Tungsten Chemical Llc (Mtc)
VIET NAM
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
Niagara Refining Llc
UNITED STATES OF AMERICA
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
Tungsten
GEM Co., Ltd.
CHINA
Tungsten
NPP Tyazhmetprom LLC
RUSSIAN FEDERATION
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Unecha Refractory Metals Plant
RUSSIAN FEDERATION
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
Tungsten
Zhangyuan Tungsten Co Ltd
CHINA





Schedule B
Countries of Origin List

Australia
Mauritania
Austria
Mongolia
Benin
Mozambique
Bolivia
Myanmar
Bolivia (Plurinational State of)
Nicaragua
Brazil
Niger
Burundi
Nigeria
Chile
Peru
China
Portugal
Colombia
Russian Federation
Congo, Democratic Republic of
Rwanda
Ecuador
Sierra Leon
Eritrea
South Africa
Ethiopia
Spain
Ghana
Swaziland
Guinea
Taiwan
Guyana
Thailand
India
Togo
Indonesia
Uganda
Laos
United Kingdom of Great Britain and Northern Ireland
Madagascar
Uzbekistan
Malaysia
Venezuela
Mali
Vietnam