Washington, D.C. 20549
(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:
☒    Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022.
☐    Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended .

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:
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable.
Section 3 - Exhibits
Item 3.0.1 Exhibits
Exhibit No.Description

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.

By: James A. Kirkland, Senior Vice President, General Counsel and Secretary
Date: May , 2022


Exhibit 1.01
Trimble Inc.
Conflict Minerals Report for the Year Ended December 31, 2021
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 2021 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.
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:
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 (known as the Conflict Minerals Reporting Template or “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 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 (RBA) Code of Conduct. We require our suppliers to adhere to our Supplier Code of Conduct and RBA standards, including any subsequent amendments or updates.
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 conduct an annual supply chain survey requesting in-scope suppliers to provide a conflict minerals declaration, using the CMRT. This survey is intended to identify the conflict minerals contained in the products that suppliers provide to Trimble, the smelters and the refiners that processed those conflict minerals, and the country of origin of those conflict minerals. In 2021, 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:
79% were identified as being Conformant (i.e. smelters that have completed an audit and conform with RMAP or another third-party program) or otherwise validated as existing smelters.
Of these smelters, 32% reported sourcing from Covered Countries.
Based on our internal assessment of in-scope suppliers and the CMRT 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 ongoing worldwide COVID-19 coronavirus pandemic in 2021 continued to significantly impact 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 2021.
Additionally, the war in Ukraine and resulting U.S. government sanctions against Russia have impacted the information we have about, and the status of, certain Russian-based smelters. The RMI smelters database has been updated to reflect the LBMA's Good Delivery List suspensions for six Russia-based gold refiners, which are now classified as high risk by the Responsible Business Alliance (RBA) and its Responsible Minerals Initiative (RMI). These smelters are also included on Trimble’s list of high risk suppliers.
The following describes Trimble’s due diligence activities for the 2021 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, Assent Compliance. 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: Commitment/Responsible Business/Product Compliance/Conflict Minerals Policy
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.
With the assistance of Assent, we conduct our in-scope due diligence of suppliers, 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 2022 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 339 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 March 10, 2022. 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 2021 reporting period.
2021 Trimble Smelters or Refiners Audit Status
Smelter Status
Conformant SmeltersActive SmeltersIn Communication SmeltersAlleged SmeltersNon-Conformant Smelters
Of the 339 entities identified as smelters or alleged smelters, 233 smelters had associated mine disclosure information that was provided to us by RMI. From this information, we determined that 139 of those smelters did not source 3TG from the Covered Countries. For the 94 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 56 in-scope suppliers that listed at least one of the smelters identified as high risk. All 56 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.
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 2022 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 maintain a high response rate from suppliers and increase the quality of supplier responses, where needed, by working with our suppliers on the completion of their CMRTs.
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 direct our suppliers to 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
MetalSmelter NameCountry
GoldAdvanced Chemical CompanyUnited States Of America
GoldAida Chemical Industries Co., Ltd.Japan
GoldAllgemeine Gold-und Silberscheideanstalt A.G.Germany
GoldAlmalyk Mining and Metallurgical Complex (AMMC)Uzbekistan
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazil
GoldArgor-Heraeus S.A.Switzerland
GoldAsahi Pretec Corp.Japan
GoldAsaka Riken Co., Ltd.Japan
GoldAurubis AGGermany
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)Philippines
GoldBoliden ABSweden
GoldC. Hafner GmbH + Co. KGGermany
GoldCCR Refinery – Glencore Canada CorporationCanada
GoldCendres + Metaux S.A.Switzerland
GoldChimet S.p.A.Italy
GoldChugai MiningJapan
GoldDaye Non-Ferrous Metals Mining Ltd.China
GoldDSC (Do Sung Corporation)Korea, Republic Of
GoldDODUCO Contacts and Refining GmbHGermany
GoldEco-System Recycling Co., Ltd. East PlantJapan
GoldOJSC Novosibirsk RefineryRussian Federation
GoldLT Metal Ltd.Korea, Republic Of
GoldHeimerle + Meule GmbHGermany
GoldHeraeus Metals Hong Kong Ltd.China
GoldHeraeus Precious Metals GmbH & Co. KGGermany
GoldHwaSeong CJ CO., LTD.Korea, Republic Of
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.China
GoldIshifuku Metal Industry Co., Ltd.Japan
GoldIstanbul Gold RefineryTurkey
GoldJapan MintJapan
GoldJiangxi Copper Co., Ltd.China
GoldAsahi Refining USA Inc.United States Of America
GoldAsahi Refining Canada Ltd.Canada
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRussian Federation
GoldJSC UralelectromedRussian Federation
GoldJX Nippon Mining & Metals Co., Ltd.Japan
GoldKazakhmys Smelting LLCKazakhstan
GoldKennecott Utah Copper LLCUnited States Of America
GoldKojima Chemicals Co., Ltd.Japan
GoldKyrgyzaltyn JSCKyrgyzstan
GoldL’azurde Company For JewelrySaudi Arabia
GoldLS-NIKKO Copper Inc.Korea, Republic Of

GoldMaterionUnited States Of America
GoldMatsuda Sangyo Co., Ltd.Japan
GoldMetalor Technologies (Suzhou) Ltd.China
GoldMetalor Technologies (Hong Kong) Ltd.China
GoldMetalor Technologies (Singapore) Pte., Ltd.Singapore
GoldMetalor Technologies S.A.Switzerland
GoldMetalor USA Refining CorporationUnited States Of America
GoldMetalurgica Met-Mex Penoles S.A. De C.V.Mexico
GoldMitsubishi Materials CorporationJapan
GoldMitsui Mining and Smelting Co., Ltd.Japan
GoldMoscow Special Alloys Processing PlantRussian Federation
GoldNadir Metal Rafineri San. Ve Tic. A.S.Turkey
GoldNavoi Mining and Metallurgical CombinatUzbekistan
GoldNihon Material Co., Ltd.Japan
GoldOhura Precious Metal Industry Co., Ltd.Japan
GoldOJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)Russian Federation
GoldPAMP S.A.Switzerland
GoldPrioksky Plant of Non-Ferrous MetalsRussian Federation
GoldPT Aneka Tambang (Persero) TbkIndonesia
GoldPX Precinox S.A.Switzerland
GoldRand Refinery (Pty) Ltd.South Africa
GoldRoyal Canadian MintCanada
GoldSabin Metal Corp.United States Of America
GoldSamduck Precious MetalsKorea, Republic Of
GoldSamwon Metals Corp.Korea, Republic Of
GoldSEMPSA Joyeria Plateria S.A.Spain
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.China
GoldSichuan Tianze Precious Metals Co., Ltd.China
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian Federation
GoldSolar Applied Materials Technology Corp.Taiwan, Province Of China
GoldSumitomo Metal Mining Co., Ltd.Japan
GoldTanaka Kikinzoku Kogyo K.K.Japan
GoldThe Refinery of Shandong Gold Mining Co., Ltd.China
GoldTokuriki Honten Co., Ltd.Japan
GoldTorecomKorea, Republic Of
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgium
GoldUnited Precious Metal Refining, Inc.United States Of America
GoldValcambi S.A.Switzerland
GoldWestern Australian Mint (T/a The Perth Mint)Australia
GoldYamakin Co., Ltd.Japan
GoldYokohama Metal Co., Ltd.Japan
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChina
GoldGold Refinery of Zijin Mining Group Co., Ltd.China
GoldMorris and WatsonNew Zealand
GoldSAFINA A.S.Czechia
GoldUmicore Precious Metals ThailandThailand
GoldGeib Refining CorporationUnited States Of America

GoldMMTC-PAMP India Pvt., Ltd.India
GoldKGHM Polska Miedz Spolka AkcyjnaPoland
GoldFidelity Printers and Refiners Ltd.Zimbabwe
GoldSingway Technology Co., Ltd.Taiwan, Province Of China
GoldAl Etihad Gold Refinery DMCCUnited Arab Emirates
GoldEmirates Gold DMCCUnited Arab Emirates
GoldInternational Precious Metal RefinersUnited Arab Emirates
GoldKaloti Precious MetalsUnited Arab Emirates
GoldT.C.A S.p.AItaly
GoldREMONDIS PMR B.V.Netherlands
GoldIndustrial Refining CompanyBelgium
GoldKorea Zinc Co., Ltd.Korea, Republic Of
GoldMarsam MetalsBrazil
GoldTOO Tau-Ken-AltynKazakhstan
GoldAbington Reldan Metals, LLCUnited States Of America
GoldL’Orfebre S.A.Andorra
Gold8853 S.p.A.Italy
GoldSAXONIA Edelmetalle GmbHGermany
GoldWIELAND Edelmetalle GmbHGermany
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustria
GoldAU Traders and RefinersSouth Africa
GoldGCC Gujrat Gold Centre Pvt. Ltd.India
GoldModeltech Sdn BhdMalaysia
GoldBangalore RefineryIndia
GoldPease & CurrenUnited States Of America
GoldSungEel HiMetal Co., Ltd.Korea, Republic Of
GoldPlanta Recuperadora de Metales SpAChile
GoldSafimet S.p.AItaly
GoldNH Recytech CompanyKorea, Republic Of
GoldEco-System Recycling Co., Ltd. North PlantJapan
GoldEco-System Recycling Co., Ltd. West PlantJapan
GoldMetal Concentrators SA (Pty) Ltd.South Africa
GoldC.I Metales Procesados Industriales SASColombia
GoldAugmont Enterprises Private LimitedIndia
GoldKundan Care Products Ltd.India
GoldEmerald Jewel Industry India Limited (Unit 1)India
GoldEmerald Jewel Industry India Limited (Unit 2)India
GoldEmerald Jewel Industry India Limited (Unit 3)India
GoldEmerald Jewel Industry India Limited (Unit 4)India
GoldAlexy MetalsUnited States Of America
GoldSancus ZFS (L’Orfebre, SA)Colombia
GoldSellem Industries Ltd.Mauritania
GoldMD OverseasIndia
GoldMetallix Refining Inc.United States Of America
GoldValue TradingBelgium

TantalumChangsha South Tantalum Niobium Co., Ltd.China
TantalumExotech Inc.United States Of America
TantalumF&X Electro-Materials Ltd.China
TantalumGuangdong Zhiyuan New Material Co., Ltd.China
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.China
TantalumJiujiang Tanbre Co., Ltd.China
TantalumLSM Brasil S.A.Brazil
TantalumMetallurgical Products India Pvt., Ltd.India
TantalumMineracao Taboca S.A.Brazil
TantalumMitsui Mining and Smelting Co., Ltd.Japan
TantalumNPM Silmet ASEstonia
TantalumNingxia Orient Tantalum Industry Co., Ltd.China
TantalumQuantumCleanUnited States Of America
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.China
TantalumSolikamsk Magnesium Works OAORussian Federation
TantalumTaki Chemical Co., Ltd.Japan
TantalumTelex MetalsUnited States Of America
TantalumUlba Metallurgical Plant JSCKazakhstan
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.China
TantalumD Block Metals, LLCUnited States Of America
TantalumFIR Metals & Resource Ltd.China
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.China
TantalumXinXing HaoRong Electronic Material Co., Ltd.China
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.China
TantalumKEMET Blue MetalsMexico
TantalumH.C. Starck Co., Ltd.Thailand
TantalumH.C. Starck Tantalum and Niobium GmbHGermany
TantalumH.C. Starck Hermsdorf GmbHGermany
TantalumH.C. Starck Inc.United States Of America
TantalumH.C. Starck Ltd.Japan
TantalumH.C. Starck Smelting GmbH & Co. KGGermany
TantalumGlobal Advanced Metals BoyertownUnited States Of America
TantalumGlobal Advanced Metals AizuJapan
TantalumResind Industria e Comercio Ltda.Brazil
TantalumJiangxi Tuohong New Raw MaterialChina
TantalumYancheng Jinye New Material Technology Co., Ltd.China
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.China
TinAlphaUnited States Of America
TinPT Aries Kencana SejahteraIndonesia
TinEM VintoBolivia
TinEstanho de Rondonia S.A.Brazil
TinFenix MetalsPoland
TinGejiu Non-Ferrous Metal Processing Co., Ltd.China
TinGejiu Zili Mining And Metallurgy Co., Ltd.China
TinGejiu Kai Meng Industry and Trade LLCChina
TinChina Tin Group Co., Ltd.China
TinMalaysia Smelting Corporation (MSC)Malaysia

TinMetallic Resources, Inc.United States Of America
TinMineracao Taboca S.A.Brazil
TinMitsubishi Materials CorporationJapan
TinJiangxi New Nanshan Technology Ltd.China
TinO.M. Manufacturing (Thailand) Co., Ltd.Thailand
TinOperaciones Metalurgicas S.A.Bolivia
TinPT Artha Cipta LanggengIndonesia
TinPT Babel Inti PerkasaIndonesia
TinPT Babel Surya Alam LestariIndonesia
TinPT Bukit TimahIndonesia
TinPT Mitra Stania PrimaIndonesia
TinPT Prima Timah UtamaIndonesia
TinPT Refined Bangka TinIndonesia
TinPT Sariwiguna BinasentosaIndonesia
TinPT Stanindo Inti PerkasaIndonesia
TinPT Timah Tbk KundurIndonesia
TinPT Timah Tbk MentokIndonesia
TinPT Tinindo Inter NusaIndonesia
TinPT Tommy UtamaIndonesia
TinRui Da HungTaiwan, Province Of China
TinSoft Metais Ltda.Brazil
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.China
TinWhite Solder Metalurgia e Mineracao Ltda.Brazil
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.China
TinYunnan Tin Company LimitedChina
TinCV Venus Inti PerkasaIndonesia
TinMagnu’s Minerais Metais e Ligas Ltda.Brazil
TinMelt Metais e Ligas S.A.Brazil
TinPT ATD Makmur Mandiri JayaIndonesia
TinO.M. Manufacturing Philippines, Inc.Philippines
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyViet Nam
TinPT Cipta Persada MuliaIndonesia
TinResind Industria e Comercio Ltda.Brazil
TinSuper LigasBrazil
TinMetallo Belgium N.V.Belgium
TinMetallo Spain S.L.U.Spain
TinPT Sukses Inti MakmurIndonesia
TinThai Nguyen Mining and Metallurgy Co., Ltd.Viet Nam
TinPT Menara Cipta MuliaIndonesia
TinHuiChang Hill Tin Industry Co., Ltd.China
TinModeltech Sdn BhdMalaysia
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.China
TinChifeng Dajingzi Tin Industry Co., Ltd.China
TinPT Bangka SerumpunIndonesia
TinTin Technology & RefiningUnited States Of America

TinDongguan CiEXPO Environmental Engineering Co., Ltd.China
TinMa’anshan Weitai Tin Co., Ltd.China
TinPT Rajawali Rimba PerkasaIndonesia
TinLuna Smelter, Ltd.Rwanda
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.China
TinPrecious Minerals and Smelting LimitedIndia
TinFabrica Auricchio Industria e Comercio Ltda.Brazil
TinNovosibirsk Processing Plant Ltd.Russian Federation
TinPT Mitra Sukses GlobalindoIndonesia
TinPT Timah NusantaraIndonesia
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBrazil
TinCRM SynergiesSpain
TinPT Masbro Alam StaniaIndonesia
TinEstanho de Rondonia S.A.Brazil
TinCRM SynergiesSpain
TungstenA.L.M.T. Corp.Japan
TungstenKennametal HuntsvilleUnited States Of America
TungstenGuangdong Xianglu Tungsten Co., Ltd.China
TungstenChongyi Zhangyuan Tungsten Co., Ltd.China
TungstenGlobal Tungsten & Powders Corp.United States Of America
TungstenHunan Chenzhou Mining Co., Ltd.China
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.China
TungstenJapan New Metals Co., Ltd.Japan
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.China
TungstenKennametal FallonUnited States Of America
TungstenWolfram Bergbau und Hutten AGAustria
TungstenXiamen Tungsten Co., Ltd.China
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.China
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.China
TungstenJiangxi Yaosheng Tungsten Co., Ltd.China
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.China
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.China
TungstenMalipo Haiyu Tungsten Co., Ltd.China
TungstenXiamen Tungsten (H.C.) Co., Ltd.China
TungstenJiangxi Gan Bei Tungsten Co., Ltd.China
TungstenGanzhou Seadragon W & Mo Co., Ltd.China
TungstenAsia Tungsten Products Vietnam Ltd.Viet Nam
TungstenChenzhou Diamond Tungsten Products Co., Ltd.China
TungstenH.C. Starck Tungsten GmbHGermany
TungstenH.C. Starck Smelting GmbH & Co. KGGermany
TungstenMasan Tungsten Chemical LLC (MTC)Viet Nam
TungstenH.C. Starck Smelting GmbH & Co. KGGermany
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.China
TungstenNiagara Refining LLCUnited States Of America
TungstenChina Molybdenum Co., Ltd.China
TungstenGanzhou Haichuang Tungsten Co., Ltd.China
TungstenHydrometallurg, JSCRussian Federation

TungstenUnecha Refractory metals plantRussian Federation
TungstenPhilippine Chuangxin Industrial Co., Inc.Philippines
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.China
TungstenACL Metais EireliBrazil
TungstenMoliren Ltd.Russian Federation
TungstenKGETS Co., Ltd.Korea, Republic Of
TungstenFujian Ganmin RareMetal Co., Ltd.China
TungstenLianyou Metals Co., Ltd.Taiwan, Province Of China
TungstenJSC "Kirovgrad Hard Alloys Plant"Russian Federation
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.Brazil
TungstenNPP Tyazhmetprom LLCRussian Federation
TungstenGEM Co., Ltd.China
TungstenCronimet Brasil LtdaBrazil
TungstenFujian Xinlu TungstenChina
TungstenOOO “Technolom” 2Russian Federation
TungstenOOO “Technolom” 1Russian Federation
TungstenGEM Co., Ltd.China

Schedule B
Countries of Origin List
BelgiumNew Zealand
Bolivia (Pluractional State of)Philippines
CanadaRussian Federation
ChinaSaudi Arabia
Czech RepublicSouth Africa
JapanUnited Arab Emirates
KazakhstanUnited States of America
Korea, Republic OfUzbekistan