F5 Networks Inc.

05/31/2023 | Press release | Distributed by Public on 05/31/2023 13:50

Specialized Disclosure Report - Form SD

F5, Inc.
Conflict Minerals Report
Year Ended December 31, 2022
This Conflict Minerals Report (the "Report") for F5, Inc. ("F5," the "Company," "we," "us," and "our") is presented for the reporting period from January 1, 2022 to December 31, 2022 to comply with Rule 13p-1 (the "Rule") under the Securities Exchange Act of 1934. For the purpose of the Reasonable Country of Origin Inquiry ("RCOI"), we initiated supply chain inquiries on November 15, 2022 and continued to receive data through May 5, 2023. F5 maintains an ongoing data gathering and refresh program to ensure up-to-date data is captured throughout the year. For the purpose of this report, conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, "3TG").
F5 increased the number of actively purchased suppliers listed on our bills of materials by 14% in the 2022 reporting year, due to the global supply chain constraints in the wake of the COVID-19 pandemic. F5 requested 100% of these suppliers to participate in our Conflict Minerals program for the 2022 reporting year.
89% of our in-scope suppliers participated in our 2022 program, through the collection of Conflict Minerals Reporting Template ("CMRT") responses. After validation and removal of incomplete or invalid submissions, we received acceptable, completed CMRTs from 80% of our in-scope suppliers, and were able to determine 11% of suppliers were not using any 3TG. 9% of the suppliers provided incomplete or invalid submissions.
As a downstream user of conflict minerals, we are dependent on our suppliers for information, and the list of smelters reported by F5 should be viewed as a list of possible sources, rather than a complete record of known source locations. More information on how we determined which suppliers were in scope is available in this report.
A smelter list, CMRT form, conflict minerals policy, and other environmental, social and governance information is available online at https://support.f5.com/csp/article/K51230228.
Forward Looking Statements
This report includes forward looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, that involve risks and uncertainties. Forward looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. Forward looking statements can also be identified by words such as "expects," "plans," "intends," "will," "may," and similar terms. Forward looking statements are not guarantees of future performance. F5 assumes no obligation to revise or update any forward-looking statements for any reason, except as required by law. Subsequent events may affect F5's future determinations under Rule 13p-1.
About F5
F5 is a multi-cloud application services and security company committed to bringing a better digital world to life. F5 partners with the world's largest, most advanced organizations to secure and optimize apps and APIs anywhere-on premises, in the cloud, or at the edge. F5 enables organizations to provide exceptional, secure digital experiences for their customers and continuously stay ahead of threats. For more information, go to f5.com. (NASDAQ: FFIV)
Supply Chain Overview
F5 relies upon our suppliers to provide material declarations and information on the origin of 3TG contained in components and materials supplied to us, including materials and 3TG from sub-tier suppliers. As most suppliers provide company-level declarations, there are many smelters listed that may not actually be in the supply chain of the components used by F5.
We contracted with Assent Compliance ("Assent") to gather data from our suppliers as well as to provide our suppliers with training on the reporting rules and guidance on completing the CMRT form. We utilized the standard Responsible Business Alliance Global e-Sustainability Initiative ("RBA-GeSI") Conflict Minerals Reporting Template version 6.22 developed by the Responsible Minerals Initiative ("RMI") and requested that all suppliers complete the form. Suppliers that are known or suspected to provide components that contain 3TG were considered undetermined unless a completed CMRT form was received. Suppliers known not to use metal in products sourced by F5 were asked to provide a CMRT form, even if only to state

no use. In cases where these suppliers did not provide a CMRT form, but a material declaration or comparable documentation is on file demonstrating no 3TG use, they were considered out of scope. Packaging suppliers are out of scope, and though we have asked for CMRT forms for our own records they are excluded from this declaration and the data provided herein.
Reasonable Country of Origin Inquiry
To determine whether necessary 3TG in our products originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (the "Covered Countries"), we provided a list of suppliers associated with the Covered Products to Assent for upload to the Assent Sustainability Manager.
We utilized the RBA-GeSI CMRT version 6.22 to conduct a survey of all in scope suppliers. During the supplier survey, we contacted suppliers via the Assent Sustainability Manager, to which suppliers uploaded their completed CMRTs for assessment and management by Assent. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, Question 1 of the CMRT asks suppliers whether any of the 3TGs they use are necessary to the functionality or production of their products. We also periodically reviewed the supplier list to ensure that irrelevant or "out of scope" suppliers were removed from the survey process. We conducted this analysis based on the following criteria:
•The company supplies packaging
•The company supplies us with items that do not end up in our products (including equipment used to make our products or those used strictly on prototypes)
•The company is a service provider only
•The company is listed as a supplier, but no components were purchased for use in F5 products during the reporting period and preceding 12 months.
We requested that all suppliers complete a CMRT and included training and education (provided by Assent) to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the Assent Sustainability Manager for future reporting and transparency. We directly contacted suppliers that were unresponsive to Assent's communications during the diligence process and requested such suppliers to complete the CMRT form and submit their form to Assent.
For calendar year 2022, we included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on:
•Questions 1 and 2 are minimum requirements for the CMRT
▪If suppliers state (via Question 1 and Question 2) that their products do not contain 3TGs necessary to the function or production of said products, then no further information is required, and no further data validation is completed.
•Question 3 - Do any of your 3TGs originate from the Covered Countries?
▪Any supplier that has any 3TGs from the Covered Countries, even one positive response from their supply chain must answer yes.
•Question 4 - Do any of the smelters in your supply chain source the 3TG from conflict-affected and high-risk areas?
•Question 5 - Have you received information from all relevant 3TG Suppliers?
▪If you are not at 100%, then you cannot make definitive statements for Questions 3 and 4.
•Question 6 - What percentage of relevant suppliers have provided a response to your supply chain survey?
•Question 7 - Have you identified all your Smelters and refiners?
▪If the answer here is yes, then question 5 must be yes. This also impacts question 3.
All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted with regards to invalid forms and are encouraged to submit a valid form. As of May 5, 2023, there were 22 invalid or incomplete supplier submissions that could not be corrected.

Assent compared the list of smelters and refiners provided in our suppliers' responses to the lists of smelters maintained by the RMI and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI's list of validated conflict free smelters and refiners of 3TG. Our suppliers identified a total of 344 smelters and refiners. Of those, 224 are currently conformant to the Responsible Minerals Audit Process ("RMAP") run by RMI. Based on information provided by RMI, a further 8 are actively engaged with RMI's audit program. Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TG contained in our products.
Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries. In accordance with the Rule, we performed due diligence on the source and chain of custody of the conflict minerals in question.
Design of Due Diligence
We designed our due diligence measures to conform, in all material respects, with the framework in the Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas (the "Guidance") and the related Supplements for gold, tin, tantalum, and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps:
1.Establishing strong company management systems regarding conflict minerals;
2.Identifying and assessing risks in our supply chain;
3.Designing and implementing a strategy to respond to identified risks in our supply chain;
4.Utilizing independent third-party audits of supply chain diligence; and
5.Publicly reporting on our supply chain due diligence.
Company Management System
Company Policies
All suppliers in our manufacturing supply chain are required to provide products that meet the requirements laid out in F5's Conflict Minerals Policy which can be found here: https://support.f5.com/csp/article/K51230228.
Conflict Minerals Policy (as of May 10, 2023):
As a global company, we know the business of F5 has impacts throughout our worldwide value chain. The Dodd- Frank Consumer Protection and Wall Street Reform Act (the "Dodd-Frank Act") found that the exploitation and trade of Tin, Tantalum, Tungsten, and Gold ("conflict minerals") were helping to finance extreme levels of violence in the DRC. The Dodd-Frank Act requires public companies to conduct due diligence and make certain disclosures regarding use of the conflict minerals.
F5 requires suppliers using any of the four conflict minerals sourced from the DRC or an adjoining country to use only materials which are certified Conflict Free through the Conflict Free Smelter Initiative or a comparable process.
We are committed to eliminating conflict minerals from our manufacturing supply chain through use of widely adopted best practices, including:
1.Establishing a conflict minerals compliance program consistent with the OECD Due Diligence guidance for downstream companies
2.Determining which F5 suppliers use the above-mentioned conflict minerals and targeting our efforts accordingly
3.Requiring all affected suppliers to provide a Conflict Minerals Reporting Template to the manufacturing supply chain team for review
4.When instances of non-compliant suppliers arise, working with those suppliers through our manufacturing supply chain team to ensure corrective actions are undertaken promptly and effectively

5.Filing an annual Form SD with the Securities and Exchange Commission through our financial reporting group, which will include updates on progress towards being conflict free and details of any corrective actions taken in the reporting year
Developing total transparency in the supply chain takes time, and correcting suppliers' use of non-certified conflict minerals as it arises requires commitment. We are confident our efforts, combined with the rest of the industry will result in substantive impacts for the people of the DRC and surrounding region.
Management Team
Management for the conflict minerals program at F5 is the supply chain team (within manufacturing). This team works closely with peers in manufacturing, manufacturing supply chain, product design and environmental, social and governance (ESG).
The supply chain team oversees gathering CMRTs, performing assessments of the CMRTs, following up with suppliers, filing the conflict minerals report, working with F5's contract manufacturer to determine purchase history and supplier use, and maintaining up-to-date information on conflict minerals regulations. As discussed earlier in this report, some of those responsibilities have been outsourced to Assent.
The supply chain team is responsible for keeping up-to-date contacts with suppliers and managing contracts with suppliers with which F5 has contracts. F5 does not have contracts with all suppliers, but all contracts that are in place include conflict minerals requirements.
The product development team, particularly the team of component engineers, is responsible for maintaining up-to-date supplier lists and bill of materials. When a new supplier is added, they notify the supply chain team so due diligence can commence. When a supplier must be removed due to conflict minerals use, the supply chain team engages the component engineering and product development teams to develop and implement a phase-out plan including timeline and alternate supplier qualification.
Grievance Mechanism
Suppliers and other parties may contact us with conflict minerals questions or concerns.
•Via email: [email protected]
Reports also may be made anonymously to the F5 Business Integrity Hotline.
•Online at f5.ethicspoint.com
•By telephone at +1 (855) 409-0947
Supplier Engagement
Design Process
F5 selects suppliers for a variety of performance criteria, including compliance. Initial screening of suppliers covers basic compliance criteria, including an ability to provide a CMRT to F5, though that CMRT is not reviewed as part of the new supplier process.
After selection, parts are integrated into prototype bills of materials and then integrated into regular, ongoing data collection performed by the supply chain team. This includes conflict minerals compliance and full material declarations.
Incorporation into Production Bill of Materials
Once listed on a prototype or production bill of materials, a supplier is added to our surveys of compliance information. It is at this point Assent is engaged to procure a CMRT from the supplier. Assent utilizes contact information provided by F5 as well as contacts from other downstream users to initiate contact with a supplier. In the event a supplier is unfamiliar with conflict minerals reporting, Assent provides training on how to properly fill out a CMRT and guidance on how that supplier can perform their own supply chain due diligence.
Maintenance of Data
After completion, F5 holds CMRTs in the Assent Sustainability Manager. These documents will be held, at a minimum, for the required period as dictated by the SEC.

As long as a supplier remains on a bill of materials for a product still in production and with an active purchase history within the prior two years, F5 will continue to gather a new CMRT every year. This ensures changes in suppliers' practices have not resulted in a change in conflict mineral sourcing status.
Due Diligence for Calendar Year 2022
Risk Assessment
Of the suppliers deemed in scope, we found the majority to be responsive with continually improving data and coverage year-over-year.
Once received, a CMRT is reviewed for a variety of red flags including those listed in the OECD guidance for downstream companies. This includes, but is not limited to:
•Determining the legitimacy of all smelters listed through a variety of validated smelter lists such as those maintained by the RMI.
•Maintaining an up-to-date list of certified conflict-free smelters and checking reported smelters against that list.
•Determining if a smelter, even if outside the Covered Countries, lists source material from the Covered Countries.
•Flagging smelters and suppliers listing recycled, scrap, or bank sources of materials.
•Flagging smelters and suppliers with unfixed inconsistencies in their forms.
Assent provides potential corrective action guidance to suppliers with data inconsistencies and errors; the average CMRT has been reviewed three times by Assent and the providing supplier prior to receipt of that CMRT by F5. F5 monitors this process through updates from Assent and advises on action for suppliers whose data has not met Assent's basic threshold for trustworthiness.
Supplier Risk
Suppliers that have not improved the percent of their supply chain surveyed, provided data showing they are not conflict free, or provided metals from other sanctioned countries were considered high-risk.
High-risk suppliers have been contacted throughout calendar year 2022 so F5 can monitor progress on removing smelters not shown to be conflict free or sourcing material from sanctioned countries.
As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier's specific context. Suppliers are given clear performance objectives within reasonable timeframes with the goal of progressive elimination of these risks from the supply chain.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. At this time, 22 of our suppliers have been identified as having a weak program.
Smelter Risk
Furthermore, smelters or refiners not being certified DRC Conflict Free pose a significant risk to the supply chain. Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
•Geographic proximity to the DRC and Covered Countries;
•Responsible Minerals Assurance Process (RMAP) audit status; and
•Known or plausible evidence of unethical or conflict sourcing.
Based on these criteria, the following facilities have been identified with a red-flag risks of highest concern into their supply chain:
•African Gold Refinery - CID003185

•Fidelity Printers and Refiners Ltd. - CID002515
•Sudan Gold Refinery - CID002567
•Industrial Refining Company - CID002587
•Kaloti Precious Metals - CID002563
•Kyrgyzaltyn JSC - CID001029
When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our third-party vendor, Assent, submissions that include any facilities with the above conditions immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to F5, and escalating up to removal of these high-risk smelters from their supply chain.
Strategy to Respond to Risks
Together with Assent, we developed processes to assess and respond to the risks identified in our supply chain.
Non-Responsive Suppliers
As the conflict minerals due diligence progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the Conflict Minerals rules. Assent provides training on conflict minerals and filling out a CMRT.
Various reasons have been presented for why a supplier does not respond, but the most frequent is out of date contact information. In this case, F5's supply chain team gathers up-to-date supplier contact information. F5's contract manufacturer, Flex, may also be asked to provide their contact with suppliers. Working with Flex also helps eliminate some confusion with suppliers requiring purchase orders to provide information; Flex is typically the purchaser of record, even though F5 maintains design control.
Suppliers with Persistent Issues
When suppliers continue to provide CMRTs to Assent or F5 that list high risk, out of date, or other illegitimate smelters, F5 will follow up with that supplier and request that supplier work to remove those smelters from their supply chain. If a supplier submits a CMRT with issues and those issues persist over an 18-month period without being addressed, F5 will take corrective actions with that supplier up to and including removing them as an Approved Vendor from F5's Approved Vendor List. For components that have multiple sources; preference will be given to suppliers that have submitted clear CMRTs.
Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facility's sourcing practices on behalf of its compliance partners. In the event after multiple attempts, a smelter does not engage in the RMAP, and a supplier continues to use metal from that smelter, F5 may entirely phase out the supplier.
While we were not successful in completely eliminating those smelters from our supply chain, we have seen a sizable reduction in the number of suppliers claiming those smelters.
Public Reporting on Supply Chain Due Diligence
During the 2022 reporting period, F5 had 269 actively purchased suppliers listed on our bills of materials and 100% of our active suppliers from our supply chain were invited to complete a CMRT.
Upon collection of CMRT responses, 243 active suppliers were considered in scope and 26 suppliers were deemed out of scope. Of the total of 243 total active, in-scope suppliers, F5 accepted completed CMRTs from 194 suppliers and 22 suppliers provided incomplete or invalid submissions. This represents an 88.89% response rate. With coverage above 85%, we believe we have met an acceptable threshold for F5 to consider the data gathering for the period to be complete and a success.

For comparison, F5 increased the number of in scope suppliers by 88% year-over-year, from 129 suppliers in 2021 to 243 suppliers in 2022. F5 also increased the number of CMRTs collected by 76% this year, from 123 collected in 2021 compared to 216 CMRTs collected in 2022.
Attached as Appendix A is a list of all smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis. Because we rely on data from our suppliers and not all suppliers are in each product, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than contained in any one of our products.
Appendix B includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI. As mentioned in the above section, many responses were provided at the company level, therefore, Appendix B may contain more countries than those that our products are being sourced from.
Determination of Conflict Status
For the reporting period ending December 31, 2022, F5 has not been found to be conflict free. This determination stems primarily from two sources of concern:
•We still have smelters not listed as conflict free that are either located in or sourcing material in the conflict region.
•We did not undergo an independent third-party audit for the reporting period, and thus cannot declare ourselves conflict free.
As a downstream user of materials, F5 does not purchase directly from smelters, or even directly from metals suppliers. As such, we are primarily reliant on entities in our supply chain to perform actual in-person audits of smelters. We search through listings on industry group sites, including the RMI and iTSCi and leverage the findings of those groups in our reporting.
Next Steps
For the 2022 reporting year, we expanded our supplier response rate by 76% year-over-year and enhanced our due diligence actions from prior reporting periods. Specifically, our account representatives from Assent, on behalf of F5, identified the entire subset of suppliers who had claimed smelters with discernible risk indicators in their CMRT submissions and engaged them on a monthly basis for an individualized follow-up. In these communications, the supplier was requested to verify materiality and relevance of their CMRT submission specific to the chain of custody for minerals in products sold to F5, and not their products as a whole, and to provide us with a revised User-Defined CMRT if it has been determined that the prior submission was not specific to F5's exclusive supply chain. Alternatively, if a supplier was unable to proceed with the above step, then F5 required - at the bare minimum - for each supplier to provide a written statement on how their organization intends to move away from the use of those facilities as part of their long-term strategic sourcing practices.
In 2023, we will continue to engage suppliers and conduct the additional due diligence practices we introduced in 2022 in order to further mitigate any risk that the necessary 3TGs in F5's products could originate from conflict-affected and high-risk areas.

Appendix A
Below is the list of smelters listed on CMRTs of suppliers used by F5 during calendar year 2022.
Smelter Name
Smelter Facility Location
Smelter ID
Tungsten A.L.M.T. Corp. Japan CID000004
Gold Advanced Chemical Company United States Of America CID000015
Gold Aida Chemical Industries Co., Ltd. Japan CID000019
Gold Agosi AG Germany CID000035
Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan CID000041
Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil CID000058
Gold Argor-Heraeus S.A. Switzerland CID000077
Gold Asahi Pretec Corp. Japan CID000082
Gold Asaka Riken Co., Ltd. Japan CID000090
Tungsten Kennametal Huntsville United States Of America CID000105
Gold Aurubis AG Germany CID000113
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines CID000128
Gold Boliden AB Sweden CID000157
Gold C. Hafner GmbH + Co. KG Germany CID000176
Gold CCR Refinery - Glencore Canada Corporation Canada CID000185
Gold Cendres + Metaux S.A. Switzerland CID000189
Tantalum Changsha South Tantalum Niobium Co., Ltd. China CID000211
Tungsten Guangdong Xianglu Tungsten Co., Ltd. China CID000218
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China CID000228
Gold Chimet S.p.A. Italy CID000233
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China CID000258
Gold Chugai Mining Japan CID000264
Tin Alpha United States Of America CID000292
Tin PT Aries Kencana Sejahtera Indonesia CID000309
Gold DSC (Do Sung Corporation) Korea CID000359
Gold Dowa Japan CID000401
Tin Dowa Japan CID000402
Gold Eco-System Recycling Co., Ltd. East Plant Japan CID000425
Tin EM Vinto Bolivia CID000438
Tantalum F&X Electro-Materials Ltd. China CID000460
Tin Fenix Metals Poland CID000468
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. China CID000538
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. China CID000555
Tungsten Global Tungsten & Powders LLC United States Of America CID000568
Gold LT Metal Ltd. Korea CID000689
Gold Heimerle + Meule GmbH Germany CID000694
Gold Heraeus Metals Hong Kong Ltd. China CID000707
Gold Heraeus Germany GmbH Co. KG Germany CID000711
Tungsten Hunan Jintai New Material Co., Ltd. China CID000769
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China CID000801
Gold Ishifuku Metal Industry Co., Ltd. Japan CID000807
Gold Istanbul Gold Refinery Turkey CID000814
Gold Japan Mint Japan CID000823
Tungsten Japan New Metals Co., Ltd. Japan CID000825
Gold Jiangxi Copper Co., Ltd. China CID000855
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. China CID000875
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. China CID000914
Tantalum Jiujiang Tanbre Co., Ltd. China CID000917

Smelter Name
Smelter Facility Location
Smelter ID
Gold Asahi Refining USA Inc. United States Of America CID000920
Gold Asahi Refining Canada Ltd. Canada CID000924
Gold JX Nippon Mining & Metals Co., Ltd. Japan CID000937
Gold Kazzinc Kazakhstan CID000957
Gold Kennecott Utah Copper LLC United States Of America CID000969
Gold Kojima Chemicals Co., Ltd. Japan CID000981
Tin China Tin Group Co., Ltd. China CID001070
Gold LS-NIKKO Copper Inc. Korea CID001078
Tin Malaysia Smelting Corporation (MSC) Malaysia CID001105
Gold Materion United States Of America CID001113
Gold Matsuda Sangyo Co., Ltd. Japan CID001119
Tin Metallic Resources, Inc. United States Of America CID001142
Gold Metalor Technologies (Suzhou) Ltd. China CID001147
Gold Metalor Technologies (Hong Kong) Ltd. China CID001149
Gold Metalor Technologies (Singapore) Pte., Ltd. Singapore CID001152
Gold Metalor Technologies S.A. Switzerland CID001153
Gold Metalor USA Refining Corporation United States Of America CID001157
Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico CID001161
Tantalum Metallurgical Products India Pvt., Ltd. India CID001163
Tin Mineracao Taboca S.A. Brazil CID001173
Tin Minsur Peru CID001182
Gold Mitsubishi Materials Corporation Japan CID001188
Tin Mitsubishi Materials Corporation Japan CID001191
Tantalum Mitsui Mining and Smelting Co., Ltd. Japan CID001192
Gold Mitsui Mining and Smelting Co., Ltd. Japan CID001193
Tantalum NPM Silmet AS Estonia CID001200
Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey CID001220
Tin Jiangxi New Nanshan Technology Ltd. China CID001231
Gold Navoi Mining and Metallurgical Combinat Uzbekistan CID001236
Gold Nihon Material Co., Ltd. Japan CID001259
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. China CID001277
Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand CID001314
Gold Ohura Precious Metal Industry Co., Ltd. Japan CID001325
Tin Operaciones Metalurgicas S.A. Bolivia CID001337
Gold MKS PAMP SA Switzerland CID001352
Gold PT Aneka Tambang (Persero) Tbk Indonesia CID001397
Tin PT Artha Cipta Langgeng Indonesia CID001399
Tin PT Babel Inti Perkasa Indonesia CID001402
Tin PT Babel Surya Alam Lestari Indonesia CID001406
Tin PT Bukit Timah Indonesia CID001428
Tin PT Mitra Stania Prima Indonesia CID001453
Tin PT Prima Timah Utama Indonesia CID001458
Tin PT Refined Bangka Tin Indonesia CID001460
Tin PT Sariwiguna Binasentosa Indonesia CID001463
Tin PT Stanindo Inti Perkasa Indonesia CID001468
Tin PT Timah Tbk Kundur Indonesia CID001477
Tin PT Timah Tbk Mentok Indonesia CID001482
Tin PT Timah Nusantara Indonesia CID001486
Tin PT Tinindo Inter Nusa Indonesia CID001490
Tin PT Tommy Utama Indonesia CID001493
Gold PX Precinox S.A. Switzerland CID001498
Gold Rand Refinery (Pty) Ltd. South Africa CID001512
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China CID001522

Smelter Name
Smelter Facility Location
Smelter ID
Gold Royal Canadian Mint Canada CID001534
Tin Rui Da Hung Taiwan, Province Of China CID001539
Gold Samduck Precious Metals Korea CID001555
Gold SEMPSA Joyeria Plateria S.A. Spain CID001585
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China CID001622
Gold Sichuan Tianze Precious Metals Co., Ltd. China CID001736
Gold Solar Applied Materials Technology Corp. Taiwan, Province Of China CID001761
Gold Sumitomo Metal Mining Co., Ltd. Japan CID001798
Tantalum Taki Chemical Co., Ltd. Japan CID001869
Gold Tanaka Kikinzoku Kogyo K.K. Japan CID001875
Tin Thaisarco Thailand CID001898
Gold Shandong Gold Smelting Co., Ltd. China CID001916
Gold Tokuriki Honten Co., Ltd. Japan CID001938
Gold Torecom Korea CID001955
Tantalum Ulba Metallurgical Plant JSC Kazakhstan CID001969
Gold Umicore S.A. Business Unit Precious Metals Refining Belgium CID001980
Gold United Precious Metal Refining, Inc. United States Of America CID001993
Gold Valcambi S.A. Switzerland CID002003
Gold Western Australian Mint (T/a The Perth Mint) Australia CID002030
Tin White Solder Metalurgia e Mineracao Ltda. Brazil CID002036
Tungsten Wolfram Bergbau und Hutten AG Austria CID002044
Tungsten Xiamen Tungsten Co., Ltd. China CID002082
Gold Yamakin Co., Ltd. Japan CID002100
Gold Yokohama Metal Co., Ltd. Japan CID002129
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China CID002158
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. China CID002180
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation China CID002224
Gold Gold Refinery of Zijin Mining Group Co., Ltd. China CID002243
Gold SAFINA A.S. Czechia CID002290
Gold Umicore Precious Metals Thailand Thailand CID002314
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China CID002317
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China CID002318
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China CID002320
Tin CV Venus Inti Perkasa Indonesia CID002455
Gold Geib Refining Corporation United States Of America CID002459
Tin Magnu's Minerais Metais e Ligas Ltda. Brazil CID002468
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China CID002492
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China CID002494
Tin PT ATD Makmur Mandiri Jaya Indonesia CID002503
Tantalum D Block Metals, LLC United States Of America CID002504
Tantalum FIR Metals & Resource Ltd. China CID002505
Gold MMTC-PAMP India Pvt., Ltd. India CID002509
Gold KGHM Polska Miedz Spolka Akcyjna Poland CID002511
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China CID002512
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch China CID002513
Gold Singway Technology Co., Ltd. Taiwan, Province Of China CID002516
Tin O.M. Manufacturing Philippines, Inc. Philippines CID002517
Tungsten H.C. Starck Tungsten GmbH Germany CID002541
Tungsten TANIOBIS Smelting GmbH & Co. KG Germany CID002542
Tungsten Masan High-Tech Materials Viet Nam CID002543
Tantalum TANIOBIS Co., Ltd. Thailand CID002544
Tantalum TANIOBIS GmbH Germany CID002545

Smelter Name
Smelter Facility Location
Smelter ID
Tantalum Materion Newton Inc. United States Of America CID002548
Tantalum TANIOBIS Japan Co., Ltd. Japan CID002549
Tantalum TANIOBIS Smelting GmbH & Co. KG Germany CID002550
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China CID002551
Tantalum Global Advanced Metals Boyertown United States Of America CID002557
Tantalum Global Advanced Metals Aizu Japan CID002558
Gold Al Etihad Gold Refinery DMCC United Arab Emirates CID002560
Gold Emirates Gold DMCC United Arab Emirates CID002561
Gold T.C.A S.p.A Italy CID002580
Gold REMONDIS PMR B.V. Netherlands CID002582
Tungsten Niagara Refining LLC United States Of America CID002589
Gold Korea Zinc Co., Ltd. Korea CID002605
Gold TOO Tau-Ken-Altyn Kazakhstan CID002615
Tin PT Cipta Persada Mulia Indonesia CID002696
Tin Resind Industria e Comercio Ltda. Brazil CID002706
Gold SAAMP France CID002761
Gold L'Orfebre S.A. Andorra CID002762
Gold 8853 S.p.A. Italy CID002763
Gold Italpreziosi Italy CID002765
Tin Aurubis Beerse Belgium CID002773
Tin Aurubis Berango Spain CID002774
Gold WIELAND Edelmetalle GmbH Germany CID002778
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria CID002779
Tin PT Sukses Inti Makmur Indonesia CID002816
Tin PT Menara Cipta Mulia Indonesia CID002835
Tantalum Jiangxi Tuohong New Raw Material China CID002842
Gold Bangalore Refinery India CID002863
Gold SungEel HiMetal Co., Ltd. Korea CID002918
Gold Planta Recuperadora de Metales SpA Chile CID002919
Gold Safimet S.p.A Italy CID002973
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China CID003116
Gold NH Recytech Company Korea CID003189
Tin Chifeng Dajingzi Tin Industry Co., Ltd. China CID003190
Tin PT Bangka Serumpun Indonesia CID003205
Tin Tin Technology & Refining United States Of America CID003325
Tin PT Rajawali Rimba Perkasa Indonesia CID003381
Tin Luna Smelter, Ltd. Rwanda CID003387
Gold Eco-System Recycling Co., Ltd. North Plant Japan CID003424
Gold Eco-System Recycling Co., Ltd. West Plant Japan CID003425
Tin PT Mitra Sukses Globalindo Indonesia CID003449
Gold Metal Concentrators SA (Pty) Ltd. South Africa CID003575
Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil CID003582
Tin PT Putera Sarana Shakti (PT PSS) Indonesia CID003868
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China CID001908
Tin Melt Metais e Ligas S.A. Brazil CID002500
Gold Marsam Metals Brazil CID002606
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey CID000103
Gold Caridad Mexico CID000180
Gold Yunnan Copper Industry Co., Ltd. China CID000197
Tungsten CNMC (Guangxi) PGMA Co., Ltd. China CID000281
Tin PT Premium Tin Indonesia Indonesia CID000313
Gold Daye Non-Ferrous Metals Mining Ltd. China CID000343
Tin Estanho de Rondonia S.A. Brazil CID000448

Smelter Name
Smelter Facility Location
Smelter ID
Gold JSC Novosibirsk Refinery Russian Federation CID000493
Gold Refinery of Seemine Gold Co., Ltd. China CID000522
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. China CID000651
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. China CID000671
Tungsten Hunan Chenzhou Mining Co., Ltd. China CID000766
Gold Hunan Chenzhou Mining Co., Ltd. China CID000767
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China CID000773
Gold HwaSeong CJ CO., LTD. Korea CID000778
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation CID000927
Gold JSC Uralelectromed Russian Federation CID000929
Tin Gejiu Kai Meng Industry and Trade LLC China CID000942
Gold Kazakhmys Smelting LLC Kazakhstan CID000956
Tungsten Kennametal Fallon United States Of America CID000966
Gold Kyrgyzaltyn JSC Kyrgyzstan CID001029
Gold L'azurde Company For Jewelry Saudi Arabia CID001032
Gold Lingbao Gold Co., Ltd. China CID001056
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. China CID001058
Tantalum AMG Brasil Brazil CID001076
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China CID001093
Tantalum Mineracao Taboca S.A. Brazil CID001175
Gold Moscow Special Alloys Processing Plant Russian Federation CID001204
Tin Novosibirsk Tin Combine Russian Federation CID001305
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation CID001326
Gold Penglai Penggang Gold Industry Co., Ltd. China CID001362
Gold Prioksky Plant of Non-Ferrous Metals Russian Federation CID001386
Tin PT Bangka Tin Industry Indonesia CID001419
Tin PT Belitung Industri Sejahtera Indonesia CID001421
Tin PT Panca Mega Persada Indonesia CID001457
Tantalum QuantumClean United States Of America CID001508
Gold Sabin Metal Corp. United States Of America CID001546
Gold Samwon Metals Corp. Korea CID001562
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China CID001619
Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation CID001756
Tantalum Solikamsk Magnesium Works OAO Russian Federation CID001769
Gold Super Dragon Technology Co., Ltd. Taiwan, Province Of China CID001810
Tantalum Telex Metals United States Of America CID001891
Gold Great Wall Precious Metals Co., Ltd. of CBPM China CID001909
Gold Tongling Nonferrous Metals Group Co., Ltd. China CID001947
Tin VQB Mineral and Trading Group JSC Viet Nam CID002015
Gold Morris and Watson New Zealand CID002282
Gold Guangdong Jinding Gold Limited China CID002312
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China CID002313
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China CID002315
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China CID002316
Tungsten Malipo Haiyu Tungsten Co., Ltd. China CID002319
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China CID002321
Tin PT Tirus Putra Mandiri Indonesia CID002478
Tungsten Asia Tungsten Products Vietnam Ltd. Viet Nam CID002502
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China CID002506
Tantalum XinXing HaoRong Electronic Material Co., Ltd. China CID002508
Gold Fidelity Printers and Refiners Ltd. Zimbabwe CID002515
Gold Shandong Humon Smelting Co., Ltd. China CID002525
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China CID002527

Smelter Name
Smelter Facility Location
Smelter ID
Tantalum KEMET de Mexico Mexico CID002539
Gold International Precious Metal Refiners United Arab Emirates CID002562
Gold Kaloti Precious Metals United Arab Emirates CID002563
Gold Sudan Gold Refinery Sudan CID002567
Tin CV Ayi Jaya Indonesia CID002570
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Viet Nam CID002572
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company Viet Nam CID002573
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company Viet Nam CID002574
Gold Fujairah Gold FZC United Arab Emirates CID002584
Gold Industrial Refining Company Belgium CID002587
Gold Shirpur Gold Refinery Ltd. India CID002588
Tungsten China Molybdenum Tungsten Co., Ltd. China CID002641
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. China CID002645
Tungsten Hydrometallurg, JSC Russian Federation CID002649
Tin An Vinh Joint Stock Mineral Processing Company Viet Nam CID002703
Tantalum Resind Industria e Comercio Ltda. Brazil CID002707
Gold Abington Reldan Metals, LLC United States Of America CID002708
Tungsten Unecha Refractory metals plant Russian Federation CID002724
Gold Shenzhen CuiLu Gold Co., Ltd. China CID002750
Tin Super Ligas Brazil CID002756
Gold Albino Mountinho Lda. Portugal CID002760
Tin PT Bangka Prima Tin Indonesia CID002776
Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines CID002827
Tungsten ACL Metais Eireli Brazil CID002833
Tungsten Moliren Ltd. Russian Federation CID002845
Gold AU Traders and Refiners South Africa CID002850
Gold GGC Gujrat Gold Centre Pvt. Ltd. India CID002852
Gold Sai Refinery India CID002853
Gold Modeltech Sdn Bhd Malaysia CID002857
Tin Modeltech Sdn Bhd Malaysia CID002858
Gold Kyshtym Copper-Electrolytic Plant ZAO Russian Federation CID002865
Gold Degussa Sonne / Mond Goldhandel GmbH Germany CID002867
Gold Pease & Curren United States Of America CID002872
Gold JALAN & Company India CID002893
Gold ABC Refinery Pty Ltd. Australia CID002920
Gold State Research Institute Center for Physical Sciences and Technology Lithuania CID003153
Gold African Gold Refinery Uganda CID003185
Gold Gold Coast Refinery Ghana CID003186
Tin Pongpipat Company Limited Myanmar CID003208
Gold QG Refining, LLC United States Of America CID003324
Gold Dijllah Gold Refinery FZC United Arab Emirates CID003348
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China CID003356
Gold CGR Metalloys Pvt Ltd. India CID003382
Gold Sovereign Metals India CID003383
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China CID003397
Tungsten Fujian Ganmin RareMetal Co., Ltd. China CID003401
Tungsten Lianyou Metals Co., Ltd. Taiwan, Province Of China CID003407
Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation CID003408
Tin Precious Minerals and Smelting Limited India CID003409
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China CID003410
Tungsten NPP Tyazhmetprom LLC Russian Federation CID003416
Tungsten Hubei Green Tungsten Co., Ltd. China CID003417
Gold C.I Metales Procesados Industriales SAS Colombia CID003421

Smelter Name
Smelter Facility Location
Smelter ID
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil CID003427
Gold Augmont Enterprises Private Limited India CID003461
Gold Kundan Care Products Ltd. India CID003463
Tungsten Cronimet Brasil Ltda Brazil CID003468
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil CID003486
Gold Emerald Jewel Industry India Limited (Unit 1) India CID003487
Gold Emerald Jewel Industry India Limited (Unit 2) India CID003488
Gold Emerald Jewel Industry India Limited (Unit 3) India CID003489
Gold Emerald Jewel Industry India Limited (Unit 4) India CID003490
Gold K.A. Rasmussen Norway CID003497
Gold Alexy Metals United States Of America CID003500
Tin CRM Synergies Spain CID003524
Gold Sancus ZFS (L'Orfebre, SA) Colombia CID003529
Gold Sellem Industries Ltd. Mauritania CID003540
Gold MD Overseas India CID003548
Tungsten Artek LLC Russian Federation CID003553
Gold Metallix Refining Inc. United States Of America CID003557
Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. China CID003583
Tungsten Fujian Xinlu Tungsten Co., Ltd. China CID003609
Tungsten OOO "Technolom" 2 Russian Federation CID003612
Tungsten OOO "Technolom" 1 Russian Federation CID003614
Gold WEEEREFINING France CID003615
Gold Gold by Gold Colombia Colombia CID003641
Tungsten LLC Vostok Russian Federation CID003643
Gold Dongwu Gold Group China CID003663
Tin DS Myanmar Myanmar CID003831
Tantalum 5D Production OU Estonia CID003926
Tungsten HANNAE FOR T Co., Ltd. Korea CID003978
Tin PT Rajehan Ariq Indonesia CID002593
Tungsten Tungsten Vietnam Joint Stock Company Viet Nam CID003993

Appendix B - Countries of origin
This list of potential countries of origin is populated based on RMI validated smelters listed in our RCOI.
Country of Origin
United States
Russian Federation
Democratic Republic of Congo
Hong Kong

Country of Origin
South Africa
Sierra Leone
United Kingdom
South Sudan
Viet Nam
Papua New Guinea
Saudi Arabia
United Arab Emirates
Burkina Faso
Ãland Islands
New Zealand

Country of Origin
American Samoa
Central African Republic
Dominican Republic