August 4, 2022
Kennametal Inc. Public Due Diligence Report for reporting period from January 1, 2021 to December 31,2021
The included Public Due Diligence Report, commonly referred to as the Step 5 Report is structured as
closely as possible to the Public Due Diligence Report Writing Guidance of the Responsible Minerals
Assurance Process (RMAP) published by the Responsible Minerals Initiative (RMI) at
www.responsiblemineralsinitiative.org under Public Reporting.
1. Company Information:a. Company Name:b. RMI smelter ID number(s):c. Company Location(s):d. 3TG material processed:
e. Report Period:
a.
b.
c.
d.
e.

Company Name:RMI smelter ID number(s):Company Location(s):3TG material processed:
Report Period:

Kennametal Inc.
CID000105
7300 Madison Blvd., Huntsville, AL
Tungsten
Jan. 1, 2021 – Dec. 31, 2021
Kennametal Inc.
CID000966
347 N. Taylor St, Fallon, NV
Tungsten
Jan. 1, 2021-Dec. 31, 2021

2. RMAP Assessment Summary
Kennametal Inc. (hereinafter “Kennametal” or the “Company”) has two tungsten smelting operations, one
located in Huntsville, AL and a second located in Fallon, NV. The last assessment took place inFebruary of 2022 and processes and results were found to be conformant to the RMAP standard and acertificate of conformance was awarded. The last RMAP assessment took place on the below listed
dates. The assessment was performed by a third-party auditor assigned by the Responsible Mineral
Initiative organization.
Huntsville AL Plant – Assessment Date: February 9, 2022
Fallon, NV Plant – Assessment Date: February 1, 2022
The last assessment summary report is available to the public via the Responsible Minerals Initiative
website as part of the Conformant Tungsten Smelter listing and at www.kennametal.com. The next
assessment is to take place on or before February 1, 2025.
3. Company Supply Chain PolicyTo avoid the use of conflict minerals, which directly or indirectly finance, or benefit armed groups and/orinvolve other serious human right abuses in high-risk and conflict affected regions, the Company has
developed a Conflict Mineral Supply Chain Policy (“Policy”). The Policy covers the risks identified inAnnex II of the OECD Guidance and its geographic scope is global. The Company is committed toaddressing any Annex II risks if identified. The Policy has been widely disseminated to relevant
stakeholders and is available on the Company website at under “About Us” / ”Doing Business withKennametal.”
4. Company Management Systems
Management Structure
The Company follows through on its commitments in the Policy and has developed an internal procedure
for the due diligence with the following aspects:•The Company has structured it tungsten raw material procurement with the Metallurgical
Procurement and Sourcing Team led by the Director of Metallurgical Sourcing (Director-MET) asthe Subject Matter Expert (SME). The Metallurgical Sourcing Team is the gatekeeper for theCompany and ensure all purchases of tungsten raw materials are fully documented and that noconflict containing minerals enter the Company supply chain. The Director-MET is a board
member of the Tungsten Industry Conflict Mineral Council (Ti-CMC). Maintaining a conflict free
supply chain for the Company is part of the annual goals for the Metallurgical Sourcing Team.

•The Company conducts Conflict Mineral training once a year for relevant employees from all
relevant departments as required. If there is an update of the program, the Company provides
communication, updates training material accordingly, and conducts additional training asnecessary. A list of those completing training is maintained and reviewed.

Controls and Transparency•

The Company has established and maintains its due diligence management system to be alignedwith the OECD Guidance.

•The Company has a grievance mechanism available to the public via their website and has aprocedure and system in place to follow-up on grievances.

•The Company conducts intensive legal review of potential contracts, and the Company has a
Delegation of Authority Policy in place to ensure appropriate review and approval.

•All purchases and receipts of material are recorded in our material resource planning system.
When material is received each incoming lot is weighed, sampled, and labelled. Prior to issuing
the material to the plant the material must pass quality control.

•The Company requires full documentation on all shipments (e.g. original country of origin
certificate, transportation documentation including shipping bills of lading).

•The Company uses SAP for tracking and recording of all raw material suppliers from purchase(i.e. entering expected material in SAP), logistics (material receiving and sampling), analyses andconsumption. Kennametal uses distinct part numbers for each raw material type which ensurethat purchased raw material type per PO is identical to received material type. The Company
receiving department is highly trained and experienced in identifying raw material types and any
discrepancies are reported to the supply chain manager. All incoming raw materials are sampled2

and analyzed and any discrepancies between expected and actual received material quality. All
discrepancies between expected supply quantity and quality are treated as a “red-flag” andrequire further review prior to processing at the Company.
•The Company has updated the Conflict Mineral Supply Chain Policy to be aligned with the OECDGuidance. Compliance to the Policy is included in the Company purchase order Terms andConditions.

•The Company sources intermediate and downstream containing tungsten products (sodiumtungstate, oxide, and tungsten carbide) from other tungsten smelters. We source these products
only from smelters that are validated under the Responsible Minerals Assurance Process(RMAP).

•

Any issues or concerns related to Kennametal material, including responsible sourcing concerns,
are to be reported directly to the Director of Metallurgical Sourcing.

•In addition, internal employees and external stakeholders can anonymously communicate theirconcerns through the Kennametal ethics and compliance hotline.

•Any concerns are taken seriously and are investigated and followed up by the Kennametal Officeof Ethics and Compliance. An ethics and case compliance procedure is established and followed
for all helpline reports. Records regarding helpline reports and investigations are retained for five(5) years. Conflict Mineral related grievances are reviewed quarterly with the Director ofMetallurgical Sourcing.

•In addition, the Company had an independent third party (IPOINT) perform a review of theCompanies Due Diligence Program and they found the Companies program to be in compliant
with relevant legislation. The Company’s Due Diligence Procedures were also audited by anindependent third party as part of the Responsible Material Assurance Procedure audit and aletter of Conformance was awarded.

5. Risk Assessment & Identification
The primary focus is on primary raw materials (tungsten concentrates). Intermediates are solely sourced
from RMAP compliant facilities, and unless red flags are found, the Company will continue to rely on theassessments of RMI. Material determined to be of secondary nature (recycling) is outside of the scopeof responsible sourcing of minerals. The Company has a robust process to identify risks in the supplychain.
First, referring to the risks in the Company’s tungsten supply chain policy, the Company has establisheda procedure to identify Conflict Affected High-Risk Areas (CAHRAs) pursuant to the requirements of theEuropean Union. The procedure includes the resources used, the criteria to define a CAHRA as well as
the frequency with which our determination is reviewed. The Company uses the following resources todetermine CAHRAs:
1. Check the countries of origin, transit and incorporation of its suppliers of non-secondary feed tothe ammonium paratungstate (APT) plant against the “Covered Countries” under Dodd-Frank Act,section 1502;
2. Check those countries or subnational entities against the “European Union list”, and3

3. Check whether there are other factual circumstances that indicate that the area in question isether a CAHRA by itself or known or suspected to be used to conceal the true origin of tungsten
materials from neighboring CAHRAs.
Second, new suppliers will only be approved upon a formal review of the supplier including a “Know-Your
Supplier (KYS) questionnaire. New suppliers are required to comply to the Principles of Supplier
Conduct and Conflict Mineral Supply Chain Policy. New suppliers are then reviewed against the list ofCAHRAs. Existing suppliers are monitored by software.
Third, the Company performs an annual Reasonable Country of Origin Inquiry to review the country oforigin. The Company has a defined approach to risk identification and process management.
6. Risk Mitigation
The Company takes a number of actions to mitigate risks:•The Company follows a procedure to mitigate risks if a source is found to be in an identifiedCAHRA;•Supplier visits with meeting minutes and a dedicated Metallurgical Sourcing Team to manage
sources of supply;•Annual review of Reasonable Country of Origin Inquiry;•The Company requires suppliers to comply to the Conflict Mineral Supply Chain Policy andPrinciples of Supplier Conduct;•A procedure to assess high-risk sources of supply is in place; and•Application of supplier monitoring software to monitor suppliers in relation to sanction lists.

Mitch Lenhard
Director – Metallurgical Sourcing

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