Document

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D. C. 20549


FORM SD
Specialized Disclosure Report


Acacia Communications, Inc.
(Exact name of registrant as specified in its charter)
Massachusetts001-3777127-0291921
(State or other jurisdiction(Commission File Number)(IRS Employer Identification No.)
of incorporation or organization)
3 Mill and Main Place, Suite 400Maynard, MA01754
(Address of principal executive officers)(Zip Code)

Janene I. Asgeirsson, 978-938-4896
(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, 2019.





SECTION 1 – Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Acacia Communications, Inc. (“Acacia,” the “Company,” “we,” “us” or “our”) is filing this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 for the reporting period January 1, 2019 to December 31, 2019. We have included the Conflict Minerals Report as Exhibit 1.01 to this Form SD and it is publicly available at http://ir.acacia-inc.com/financial-information/sec-filings.*

For the year 2019, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs, as defined below, are necessary to their functionality or production (“Covered Products”). Conflict minerals are defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (together with gold collectively referred to as “3TGs”), or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia, collectively, with the DRC, the “Covered Countries”). Accordingly, we have conducted a reasonable country of origin inquiry that was designed to determine whether any of the 3TGs in our Covered Products originated in a Covered Country or were from recycled or scrap sources.

_____________________________________
*  The reference to Acacia’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD and the Conflict Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.

SECTION 2 – Exhibits

Item 2.01 Exhibits.

The following exhibit is filed as part of this Form SD.
Exhibit
Number
Description



















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.
Acacia Communications, Inc.
Date: May 29, 2020By:/s/ Janene I. Ásgeirrson
Janene I. Ásgeirrson
Vice President, General Counsel and Secretary





acacia2020cmrwdeskload-u
Exhibit 1.01 Acacia Communications, Inc. Conflict Minerals Report For the Calendar Year Ended December 31, 2019 Introduction and Summary This Conflict Minerals Report for the year ended December 31, 2019 (this “Report”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements pursuant to Section 13(p) of the Securities Exchange Act of 1934 (“Section 13(p)”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. The term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite- tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (“3TGs” or “conflict minerals”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The adjoining countries include: Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia (collectively, with the DRC, the “Covered Countries”). In conducting due diligence on our supply chain for purposes of complying with Rule 13p-1, we designed our efforts in conformity with the internationally recognized due diligence framework provided by the Organization for Economic Co-Operation and Development (“OECD”). Specifically, our diligence efforts were based on and designed to comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (2016), including the related supplements on tantalum, tin, tungsten and gold (the “OECD Guidance”). Overview Company Profile Acacia Communications, Inc. (“Acacia,” the “Company,” “we,” “us,” or “our”) develops, manufactures and sells high-speed coherent optical interconnect products that are designed to transform communications networks through improvements in performance, capacity and cost. By implementing optical interconnect technology in a silicon- based platform, a process Acacia refers to as the “siliconization of optical interconnect,” Acacia is able to offer products at higher speeds and density with lower power consumption, that meet the needs of cloud and service providers and can be easily integrated in a cost-effective manner with existing network equipment.


 
The Acacia products covered by this Conflict Minerals Report include (i) embedded modules; (ii) pluggable modules; (iii) semiconductors; and (iv) integrated optical modules. Such products are collectively referred to herein as the “Covered Products.” We have determined that hardware components incorporated into the Covered Products contain one or more conflict minerals and are covered products under the scope of Rule 13p-1. This Report has been prepared by the management of Acacia. The information in this Report includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated. Conflict Minerals Program & Policy The Company has actively engaged with our customers and suppliers for several years with respect to the use of conflict minerals. Our actions are a result of the Company’s responsible and inclusive culture and longstanding leadership in corporate responsibility. We adopted a Conflict Minerals Policy articulating our conflict minerals supply chain due diligence process and our commitment to our reporting obligations regarding conflict minerals. Our policy is available on our website: https://acacia-inc.com/conflict-minerals-policy-statement/. Reasonable Country of Origin Inquiry Based on our determination that during calendar year 2019 (the “Reporting Period”) we manufactured (or contracted to manufacture) Covered Products for which conflict minerals are necessary to the functionality or production, in accordance with Rule 13p-1, we conducted a good faith reasonable country of origin (“RCOI”) to determine whether the required conflict minerals may have originated in the Covered Countries or come from recycled scrap sources. Our RCOI process utilized Conflict Minerals Reporting Template (“CMRT”) version 5.12 or higher developed by the Responsible Minerals Initiative (“RMI”) to conduct a survey of all in scope suppliers. We also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process. Acacia also uses Assent, a third-party service provider, to assist us with evaluating supply chain information regarding 3TGs and in the development and implementation of additional due diligence steps that we will undertake with suppliers with regard to conflict minerals. Assent requested that all suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of the template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. Acacia directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested that such suppliers complete the CMRT and submit such CMRT to Assent.


 
Based on the RCOI conducted, Acacia was unable to exclude the possibility that the 3TGs in some of its Covered Products originated, or may have originated, in the Covered Countries and did not, or may not, have originated from recycled or scrap sources. Therefore, in accordance with the Rule, Acacia performed due diligence on the source and chain of custody of the 3TGs in question. Design of Due Diligence We designed our conflict minerals program and due diligence measures to conform, in all material respects, with the OECD Guidance. The OECD Guidance sets out a five-step framework for due diligence and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely: 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 due diligence; and 5. Publicly reporting on our supply chain due diligence. We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into the Covered Products. Furthermore, Acacia does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict minerals containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure. The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us. Due Diligence Performed 1) Establish Strong Company Management Systems Internal Compliance Team


 
Acacia’s Conflict Minerals Compliance Team is led by the Export Control and Compliance Manager, with input from representatives from our purchasing, operations and finance teams. The Conflict Minerals Compliance Team is responsible for implementing our conflict minerals compliance strategy and briefing senior management about the results of our due diligence efforts. Supplier Engagement Acacia engages with suppliers directly to request that they complete a valid CMRT for the products that they supply to Acacia. With respect to the OECD requirement to strengthen engagement with suppliers, Acacia is committed to supplier engagement escalation such as in-person meetings and corrective actions. Feedback from this engagement has allowed Acacia to oversee improvements in supplier responses and supplier compliance for this initiative. Conflict Minerals Policy; Grievance Mechanisms Acacia’s Conflict Minerals Policy is available on our website at: https://acacia-inc.com/conflict-minerals-policy- statement/. In addition, Acacia has mechanisms for reporting violations of Acacia’s policies, including with respect to conflict minerals. Suppliers and others outside of Acacia may contact our Conflict Minerals Compliance Team to communicate with us, including to report grievances, via a dedicated email address that is published in our Conflict Minerals Policy and in other communications with our suppliers. Our employees may anonymously report suspected violations using our Whistleblower Hotline - 844-403-4965 - which is available 24 hours a day, seven days a week. Records Maintenance Acacia has adopted a policy to retain conflict minerals related documents, including supplier responses to CMRTs, and other relevant documentation for a period of five years. Under our direction and guidance, Assent stores all of the information and findings from this process in a database that can be audited by internal or external parties. 2) Identify and Assess Risk in the Supply Chain Risks are identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. The facilities listed in the CMRT were compared to the list of smelters and refiners maintained by theRMI to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the Reporting Period. Identified Direct Suppliers


 
Due to our downstream position in the supply chain, Acacia relies on our direct suppliers to provide accurate information on the origin of conflict minerals in the materials supplied to us. We reviewed all companies selling materials to Acacia to capture all direct, or first tier, suppliers who have provided materials that contain 3TG in the Covered Products during the Reporting Period. Conducted RCOI We relied on the industry wide standard CMRT to poll our direct suppliers for information relevant to our conflict minerals inquiry. Similarly, we require our direct suppliers to incorporate their upstream supplier responses into their CMRT. We reviewed the information contained in the CMRTs we received from our direct suppliers to determine our reporting obligation based on this RCOI. Completed additional follow-up We reviewed the CMRT submissions to validate that they were complete and to identify any contradictions or inconsistencies. We also have worked with suppliers to secure updated responses where necessary. Identify smelters/refiners We collected a list of smelters/refiners that may have processed conflict minerals in our supply chain by utilizing the responses to the CMRT. We reconciled this list to the list of smelter facilities designated by the RMI Responsible Minerals Assurance Process (formerly the Conflict-Free Smelter Program). We have provided that list in this report. In order to assess the risk that any particular smelters pose to our supply chain, we determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists. We 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 3TGs.


 
3) Design and Implement a Strategy to Respond to Identified Risks We developed processes to assess and respond to the risks identified in our supply chain in consultation with our third-party conflict minerals service provider. In response to this risk assessment, Acacia has in place a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a CMRT response and to outline the required cooperation for compliance with the Rule. We engage any of our suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict. 4) Carry Out Independent Third-Party Audit of Supply Chain Due Diligence We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program. 5) Report on Supply Chain Due Diligence We have published our Form SD for the year ended December 31, 2019 and this Report in the Investor Relations section of our website at http://ir.acacia-inc.com. Information found on or accessed through our website is not considered part of this Report and is not incorporated by reference herein. We have also publicly filed our Form SD and this Report with the SEC. Results of RCOI and Due Diligence Survey Results For the 2019 reporting period, Acacia received CMRT forms from 84% of the suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. At the end of our program, three suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. We surveyed a total of 150 in scope suppliers and received 102 CMRT submissions by May 22, 2020. Smelters and Refiners Our suppliers identified a total of 282 smelters and refiners that appear on the list maintained by RMI. Of these 282 smelters and refiners, 238 are validated as conflict free by RMI, and, based on information provided by RMI, a further 4 have agreed to undergo or are currently undergoing a third-party audit. All smelters and refiners identified


 
by our suppliers that we believe may source 3TGs from the Covered Countries appear on RMI’s list of validated conflict free smelters and refiners; however, due to the provision of primarily company or division level CMRTs, we cannot definitively determine their connection to the Covered Products. Attached as Appendix A is a list of all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Since 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, we are not able to identify which smelters or refiners listed on Appendix A actually processed the 3TGs contained in the Covered Products. Therefore, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that actually processed the conflict minerals contained in the Covered Products. We have identified five smelters that potentially pose a risk. We assessed risk based on factors including location of the smelters and publicly available statements that call into question the status of the facilities. For suppliers that identified these specific smelters of concern on their CMRT, we created a new escalation plan. These suppliers were contacted by Assent and Acacia to evaluate whether or not these smelters could be connected to Acacia products. The suppliers were asked to complete a product-level CMRT, rather than a company or division level CMRT, to better identify the connection to products that they supply to Acacia. Other suppliers were evaluated internally to determine if they were in fact still active suppliers. If not, they were removed from the scope of data collection. Countries of Origin 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 above under “Smelters and Refiners,” many responses were provided at the company or division level, therefore, Appendix B may contain more countries than those the Covered Products are being sourced from. Steps Taken or to be Taken to Mitigate Risk We have taken or intend to take the following steps to further mitigate the risk that the necessary 3TGs in the Covered Products could benefit armed groups in the Covered Countries: • Work closely with our third-party conflict minerals service provider to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TGs contained in the Covered Products; • Engage with our suppliers and provide suppliers with more information and training resources regarding responsible sourcing of 3TGs, in particular, place a strong emphasis on supplier education and training that can be tracked and evaluated based on completion of training modules. To accomplish this, we utilize Assent’s learning management system, Assent University, and provide all in-scope suppliers with access to Assent’s conflict minerals training course and to encourage all suppliers to complete all modules therein;


 
• Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers; • Include a conflict minerals flow-down clause in new or renewed supplier contracts as well as in the terms and conditions of each purchase order issued; • Emphasize clean and validated smelter and refiner information from our supply chain as the list of conflict- free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program; and • Incorporate Acacia’s Conflict Minerals Policy by reference into all new supplier contracts and encourage and direct new suppliers to read and accept this policy and to provide information about the source of 3TGs and smelters. Basis for Information Reported; Forward Looking Statements The statements included in this Report are based on the RCOI process and due diligence performed in good faith by or on behalf of Acacia. These statements are based on the information available at the time of filing this Form SD and Conflict Minerals Report. A number of factors could introduce errors or otherwise affect our disclosures. These factors include, but are not limited to, gaps in supplier or smelter data, errors or omissions by suppliers or smelters and uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules. Some suppliers and smelters are unfamiliar with the diligence process and information required to be provided under the SEC’s reporting requirements, which could lead to inaccurate responses or failure to timely provide data. Further, information that is in the public domain may not be discovered despite having conducted a reasonable search, there may be errors in publicly available information, language barriers or errors in translation could lead to inaccurate information, there could be oversights or errors in conflict free smelter audits, materials sourced from the Covered Countries could be inaccurately categorized as out of scope, illegally tagged conflict minerals could be introduced into our supply chain without our knowledge or the knowledge of our suppliers, we may face difficulties obtaining information from companies that are no longer in business and smuggling of conflict minerals outside the Covered Countries may make identification of their origin more difficult. Additionally, this Report includes statements concerning Acacia Communications and its future expectations, plans and prospects that constitute “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. For this purpose, any statements contained herein that are not statements of historical fact may be deemed to be forward-looking statements. Without limiting the foregoing, the words “may,” “should,” “expects,” “plans,” “anticipates,” “could,” “intends,” “believes,” “potential,” “will” or “continue” or the negative of these terms or other similar expressions are intended to help you identify forward-looking statements. Any forward-looking statements in this press release are based on its current expectations and projections about future events . These forward-looking statements speak only as of the date of this press release and are subject to a number of risks, uncertainties and assumptions including the Company’s expectations with regard to its supply chain and manufacturing, and risks set forth under the caption “Risk Factors” in the Company’s public reports filed with the SEC, including the Company’s Annual Report on Form 10-K for the year ended December 31, 2019 and its Quarterly Report on Form 10-Q for the fiscal quarter ended March 31, 2020, and in other filings that the Company may make with the SEC in the future. Because forward-looking statements are inherently subject to risks and uncertainties, some of which cannot be predicted, you


 
should not rely on these forward-looking statements as indicative of future events. Acacia Communications assumes no obligation to publicly update or revise any forward-looking statements contained in this press release as a result of new information, future events or otherwise, except as may be required by law.


 
Appendix A - Smelter List Metal Standard Smelter Name Smelter Facility Location RMI Status Gold 8853 S.p.A. ITALY Conformant Gold Abington Reldan Metals, LLC UNITED STATES OF AMERICA Non Conformant Gold Advanced Chemical Company UNITED STATES OF AMERICA Conformant Gold Aida Chemical Industries Co., Ltd. JAPAN Conformant Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES Conformant Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY Conformant Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN Conformant Gold AngloGold Ashanti Corrego do Sitio Mineracao BRAZIL Conformant Gold Argor-Heraeus S.A. SWITZERLAND Conformant Gold Asahi Pretec Corp. JAPAN Conformant Gold Asahi Refining Canada Ltd. CANADA Conformant Gold Asahi Refining USA Inc. UNITED STATES OF AMERICA Conformant Gold Asaka Riken Co., Ltd. JAPAN Conformant Due Diligence Vetting Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY Process Gold AU Traders and Refiners SOUTH AFRICA Conformant Gold Aurubis AG GERMANY Conformant Gold Bangalore Refinery INDIA Conformant Bangko Sentral ng Pilipinas (Central Bank of the Gold Philippines) PHILIPPINES Conformant Gold Boliden AB SWEDEN Conformant Gold C. Hafner GmbH + Co. KG GERMANY Conformant Communication Suspended - Not Gold Caridad MEXICO Interested Gold CCR Refinery - Glencore Canada Corporation CANADA Conformant Gold Cendres + Metaux S.A. SWITZERLAND Conformant Gold Chimet S.p.A. ITALY Conformant Gold Chugai Mining JAPAN Conformant Gold Daye Non-Ferrous Metals Mining Ltd. CHINA In Communication Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY Outreach Required Gold DODUCO Contacts and Refining GmbH GERMANY Conformant Gold Dowa JAPAN Conformant Gold DS PRETECH Co., Ltd. KOREA, REPUBLIC OF Conformant


 
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF Conformant Gold Eco-System Recycling Co., Ltd. East Plant JAPAN Conformant Gold Eco-System Recycling Co., Ltd. North Plant JAPAN Conformant Gold Eco-System Recycling Co., Ltd. West Plant JAPAN Conformant Gold Emirates Gold DMCC UNITED ARAB EMIRATES Conformant Gold GCC Gujrat Gold Centre Pvt. Ltd. INDIA In Communication Gold Geib Refining Corporation UNITED STATES OF AMERICA Conformant Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA Conformant Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA Outreach Required Gold Guangdong Jinding Gold Limited CHINA Outreach Required Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA Outreach Required Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA Outreach Required Gold Heimerle + Meule GmbH GERMANY Conformant Gold Heraeus Metals Hong Kong Ltd. CHINA Conformant Gold Heraeus Precious Metals GmbH & Co. KG GERMANY Conformant Gold Hunan Chenzhou Mining Co., Ltd. CHINA Outreach Required Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. CHINA Outreach Required Communication Suspended - Not Gold HwaSeong CJ CO., LTD. KOREA, REPUBLIC OF Interested Inner Mongolia Qiankun Gold and Silver Refinery Share Gold Co., Ltd. CHINA Conformant Gold Ishifuku Metal Industry Co., Ltd. JAPAN Conformant Gold Istanbul Gold Refinery TURKEY Conformant Gold Italpreziosi ITALY Conformant Gold Japan Mint JAPAN Conformant Gold Jiangxi Copper Co., Ltd. CHINA Conformant Gold JSC Uralelectromed RUSSIAN FEDERATION Conformant Gold JX Nippon Mining & Metals Co., Ltd. JAPAN Conformant Gold Kazakhmys Smelting LLC KAZAKHSTAN In Communication Gold Kazzinc KAZAKHSTAN Conformant Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA Conformant Gold KGHM Polska Miedz Spolka Akcyjna POLAND Conformant Gold Kojima Chemicals Co., Ltd. JAPAN Conformant Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF Conformant Gold Kyrgyzaltyn JSC KYRGYZSTAN Conformant Gold Kyshtym Copper-Electrolytic Plant ZAO RUSSIAN FEDERATION Outreach Required


 
RMI Due Diligence Review - Unable to Gold L'azurde Company For Jewelry SAUDI ARABIA Proceed Gold Lingbao Gold Co., Ltd. CHINA Outreach Required Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA Outreach Required Gold L'Orfebre S.A. ANDORRA Conformant Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF Conformant Gold LT Metal Ltd. KOREA, REPUBLIC OF Conformant Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA Outreach Required Gold Marsam Metals BRAZIL Conformant Gold Materion UNITED STATES OF AMERICA Conformant Gold Matsuda Sangyo Co., Ltd. JAPAN Conformant Gold Metalor Technologies (Hong Kong) Ltd. CHINA Conformant Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE Conformant Gold Metalor Technologies (Suzhou) Ltd. CHINA Conformant Gold Metalor Technologies S.A. SWITZERLAND Conformant Gold Metalor USA Refining Corporation UNITED STATES OF AMERICA Conformant Gold Metalurgica Met-Mex Penoles S.A. De C.V. MEXICO Conformant Gold Mitsubishi Materials Corporation JAPAN Conformant Gold Mitsui Mining and Smelting Co., Ltd. JAPAN Conformant Gold MMTC-PAMP India Pvt., Ltd. INDIA Conformant Gold Modeltech Sdn Bhd MALAYSIA Non Conformant Communication Suspended - Not Gold Morris and Watson NEW ZEALAND Interested Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION Conformant Gold Nadir Metal Rafineri San. Ve Tic. A.S. TURKEY Conformant Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN Outreach Required Gold NH Recytech Company KOREA, REPUBLIC OF Non Conformant Gold Nihon Material Co., Ltd. JAPAN Conformant Ogussa Osterreichische Gold- und Silber-Scheideanstalt Gold GmbH AUSTRIA Conformant Gold Ohura Precious Metal Industry Co., Ltd. JAPAN Conformant OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" Gold (OJSC Krastsvetmet) RUSSIAN FEDERATION Conformant Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION Conformant Gold PAMP S.A. SWITZERLAND Conformant Gold Pease & Curren UNITED STATES OF AMERICA Outreach Required


 
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA Outreach Required Gold Planta Recuperadora de Metales SpA CHILE Conformant Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION Conformant Gold PT Aneka Tambang (Persero) Tbk INDONESIA Conformant Gold PX Precinox S.A. SWITZERLAND Conformant Gold QG Refining, LLC UNITED STATES OF AMERICA Outreach Required Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA Conformant Gold Refinery of Seemine Gold Co., Ltd. CHINA Outreach Required Gold REMONDIS PMR B.V. NETHERLANDS Conformant Gold Royal Canadian Mint CANADA Conformant Gold SAAMP FRANCE Conformant Gold Sabin Metal Corp. UNITED STATES OF AMERICA Outreach Required Gold Safimet S.p.A ITALY Conformant Gold SAFINA A.S. CZECH REPUBLIC Active Gold Sai Refinery INDIA Outreach Required Gold Samduck Precious Metals KOREA, REPUBLIC OF Conformant Communication Suspended - Not Gold Samwon Metals Corp. KOREA, REPUBLIC OF Interested Gold SAXONIA Edelmetalle GmbH GERMANY Conformant Gold SEMPSA Joyeria Plateria S.A. SPAIN Conformant Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA Outreach Required Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA Conformant Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA Conformant TAIWAN, PROVINCE OF Gold Singway Technology Co., Ltd. CHINA Conformant Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION Conformant TAIWAN, PROVINCE OF Gold Solar Applied Materials Technology Corp. CHINA Conformant State Research Institute Center for Physical Sciences and Gold Technology LITHUANIA Outreach Required Gold Sumitomo Metal Mining Co., Ltd. JAPAN Conformant Gold SungEel HiMetal Co., Ltd. KOREA, REPUBLIC OF Conformant Gold T.C.A S.p.A ITALY Conformant Gold Tanaka Kikinzoku Kogyo K.K. JAPAN Conformant Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA Conformant Gold Tokuriki Honten Co., Ltd. JAPAN Conformant Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA Outreach Required


 
Gold TOO Tau-Ken-Altyn KAZAKHSTAN Conformant Gold Torecom KOREA, REPUBLIC OF Conformant Gold Umicore Brasil Ltda. BRAZIL Conformant Gold Umicore Precious Metals Thailand THAILAND Conformant Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM Conformant Gold United Precious Metal Refining, Inc. UNITED STATES OF AMERICA Conformant Gold Valcambi S.A. SWITZERLAND Conformant Gold Western Australian Mint (T/a The Perth Mint) AUSTRALIA Conformant Gold WIELAND Edelmetalle GmbH GERMANY Conformant Gold Yamakin Co., Ltd. JAPAN Conformant Gold Yokohama Metal Co., Ltd. JAPAN Conformant Gold Yunnan Copper Industry Co., Ltd. CHINA Outreach Required Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA Conformant Tantalum Asaka Riken Co., Ltd. JAPAN Conformant Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA Conformant Tantalum CP Metals Inc. UNITED STATES OF AMERICA Conformant Tantalum D Block Metals, LLC UNITED STATES OF AMERICA Conformant Tantalum Exotech Inc. UNITED STATES OF AMERICA Conformant Tantalum F&X Electro-Materials Ltd. CHINA Conformant Tantalum FIR Metals & Resource Ltd. CHINA Conformant Tantalum Global Advanced Metals Aizu JAPAN Conformant Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA Conformant Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA Conformant Tantalum H.C. Starck Co., Ltd. THAILAND Conformant Tantalum H.C. Starck Hermsdorf GmbH GERMANY Conformant Tantalum H.C. Starck Inc. UNITED STATES OF AMERICA Conformant Tantalum H.C. Starck Ltd. JAPAN Conformant Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY Conformant Tantalum H.C. Starck Tantalum and Niobium GmbH GERMANY Conformant Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA Conformant Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA Conformant Tantalum Jiangxi Tuohong New Raw Material CHINA Conformant Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA Conformant Tantalum Jiujiang Tanbre Co., Ltd. CHINA Conformant Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA Conformant


 
Tantalum KEMET Blue Metals MEXICO Conformant Tantalum LSM Brasil S.A. BRAZIL Conformant Tantalum Metallurgical Products India Pvt., Ltd. INDIA Conformant Tantalum Mineracao Taboca S.A. BRAZIL Conformant Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN Conformant Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA Conformant Tantalum NPM Silmet AS ESTONIA Conformant NORTH MACEDONIA, Tantalum PRG Dooel REPUBLIC OF Conformant Tantalum QuantumClean UNITED STATES OF AMERICA Conformant Tantalum Resind Industria e Comercio Ltda. BRAZIL Conformant Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION Conformant Tantalum Taki Chemical Co., Ltd. JAPAN Conformant Tantalum Telex Metals UNITED STATES OF AMERICA Conformant Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN Conformant Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA Conformant Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. CHINA Conformant Tin Alpha UNITED STATES OF AMERICA Conformant Tin An Vinh Joint Stock Mineral Processing Company VIET NAM Outreach Required Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA Conformant Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA Conformant Tin China Tin Group Co., Ltd. CHINA Conformant Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. CHINA Non Conformant Tin Dowa JAPAN Conformant Electro-Mechanical Facility of the Cao Bang Minerals & Tin Metallurgy Joint Stock Company VIET NAM Non Conformant BOLIVIA (PLURINATIONAL Tin EM Vinto STATE OF) Conformant Tin Estanho de Rondonia S.A. BRAZIL In Communication Tin Fenix Metals POLAND Conformant Tin Gejiu Kai Meng Industry and Trade LLC CHINA Conformant Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA Conformant Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA Conformant Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA Conformant Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA Conformant Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA Conformant Tin HuiChang Hill Tin Industry Co., Ltd. CHINA Conformant


 
Tin Huichang Jinshunda Tin Co., Ltd. CHINA Conformant Tin Jiangxi New Nanshan Technology Ltd. CHINA Conformant Tin Ma'anshan Weitai Tin Co., Ltd. CHINA Conformant Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL Conformant Tin Malaysia Smelting Corporation (MSC) MALAYSIA Conformant Tin Melt Metais e Ligas S.A. BRAZIL Conformant Tin Metallic Resources, Inc. UNITED STATES OF AMERICA Conformant Tin Metallo Belgium N.V. BELGIUM Conformant Tin Metallo Spain S.L.U. SPAIN Conformant Tin Mineracao Taboca S.A. BRAZIL Conformant Tin Minsur PERU Conformant Tin Mitsubishi Materials Corporation JAPAN Conformant Tin Modeltech Sdn Bhd MALAYSIA Non Conformant Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIET NAM Outreach Required Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND Conformant Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES Conformant BOLIVIA (PLURINATIONAL Tin Operaciones Metalurgicas S.A. STATE OF) Conformant Tin Pongpipat Company Limited MYANMAR Outreach Required Tin Precious Minerals and Smelting Limited INDIA Active Tin PT Artha Cipta Langgeng INDONESIA Conformant Tin PT ATD Makmur Mandiri Jaya INDONESIA Conformant Tin PT Menara Cipta Mulia INDONESIA Conformant Tin PT Mitra Stania Prima INDONESIA Conformant Tin PT Refined Bangka Tin INDONESIA Conformant Tin PT Timah Tbk Kundur INDONESIA Conformant Tin PT Timah Tbk Mentok INDONESIA Conformant Tin Resind Industria e Comercio Ltda. BRAZIL Conformant TAIWAN, PROVINCE OF Tin Rui Da Hung CHINA Conformant Tin Soft Metais Ltda. BRAZIL Conformant Tin Super Ligas BRAZIL Outreach Required Tin Thai Nguyen Mining and Metallurgy Co., Ltd. VIET NAM Conformant Tin Thaisarco THAILAND Conformant Tin Tin Technology & Refining UNITED STATES OF AMERICA Conformant Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIET NAM Outreach Required


 
Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL Conformant Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA Conformant Tin Yunnan Tin Company Limited CHINA Conformant Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. CHINA Conformant Tungsten A.L.M.T. Corp. JAPAN Conformant Tungsten ACL Metais Eireli BRAZIL Conformant Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM Conformant Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA Conformant Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA Conformant Tungsten Fujian Ganmin RareMetal Co., Ltd. CHINA Conformant Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA Conformant Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA Conformant Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA Conformant Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA Conformant Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA Conformant Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA Conformant Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA Conformant Tungsten H.C. Starck Smelting GmbH & Co. KG GERMANY Conformant Tungsten H.C. Starck Tungsten GmbH GERMANY Conformant Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA Conformant Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA Conformant Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA Conformant Tungsten Hunan Litian Tungsten Industry Co., Ltd. CHINA Conformant Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION Conformant Tungsten Japan New Metals Co., Ltd. JAPAN Conformant Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA Conformant Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA Conformant Communication Suspended - Not Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. CHINA Interested Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Tungsten Ltd. CHINA Conformant Tungsten Jiangxi Xianglu Tungsten Co., Ltd. CHINA Active Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA Conformant Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA Conformant Tungsten JSC "Kirovgrad Hard Alloys Plant" RUSSIAN FEDERATION Active Tungsten Kennametal Fallon UNITED STATES OF AMERICA Conformant


 
Tungsten Kennametal Huntsville UNITED STATES OF AMERICA Conformant Tungsten KGETS Co., Ltd. KOREA, REPUBLIC OF Conformant TAIWAN, PROVINCE OF Tungsten Lianyou Metals Co., Ltd. CHINA Conformant Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA Conformant Tungsten Masan Tungsten Chemical LLC (MTC) VIET NAM Conformant Tungsten Moliren Ltd. RUSSIAN FEDERATION Conformant Tungsten Niagara Refining LLC UNITED STATES OF AMERICA Conformant Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES Conformant Tungsten Tejing (Vietnam) Tungsten Co., Ltd. VIET NAM Conformant Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION Conformant Tungsten Wolfram Bergbau und Hutten AG AUSTRIA Conformant Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF Conformant Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA Conformant Tungsten Xiamen Tungsten Co., Ltd. CHINA Conformant Xinfeng Huarui Tungsten & Molybdenum New Material Co., Tungsten Ltd. CHINA Conformant Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA Conformant


 
Appendix B - Countries of Origin This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products. Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Djibouti, Dominican Republic, DRC or an adjoining country (Covered Countries), Ecuador, Egypt, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic Of Korea, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Suri, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, USA, Uzbekistan, Vietnam, Zambia, Zimbabwe