Alphabet Inc.
Conflict Minerals Report
For The Year Ended December 31, 2017
This Conflict Minerals Report for the year ended December 31, 2017 (this “CMR”) is presented tocomply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”),
which requires certain reporting and disclosure related to conflict minerals. Conflict minerals
are currently defined as cassiterite, columbite-tantalite, wolframite, gold, or their derivatives,
1
which are limited to tin, tantalum, tungsten, and gold (“3TG”) ​for the purpose of thisassessment. These requirements apply to registrants whatever the geographic origin of theirconflict minerals and whether or not their conflict minerals fund armed conflict. Please refer tothe Rule, Form SD, and SEC Release No. 34-67716 for definitions to the terms used in this CMR,
unless otherwise defined herein.
Statements in this CMR are based on our due diligence activities performed in good faith for thecalendar year 2017 and are based on information available at the time of this filing, unlessotherwise indicated. Factors that could affect the accuracy of these statements include, but are
not limited to, incomplete supplier data or available smelter and refiner (collectively referred toas “smelters”) data, errors or omissions by suppliers or smelters, ongoing certifications of
smelters, continued guidance or amendments to the Rule, and other issues. Additionally, thisCMR may contain forward-looking statements that reflect what we strive to achieve in the future
as we continue to improve our responsible sourcing program. These forward-looking
statements are based on current expectations and assumptions that are subject to risks anduncertainties.
References to our websites and information available through these websites are notincorporated into this CMR.
Throughout this CMR, we use “Alphabet,” “we,” “our,” “us” and similar terms to refer to Alphabet
Inc. and its subsidiaries (collectively, “Alphabet”), unless otherwise indicated, and use “Google”
to refer to Google LLC, a wholly owned subsidiary of Alphabet.
1. Overview(A) Company
Alphabet is a collection of businesses -- the largest of which, of course, is Google​. It also
includes businesses that are generally pretty far afield of our main Internet products, such as
Access, Calico, CapitalG, GV, Verily, Waymo, and X. We report all non-Google businesses​The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer
Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted);cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is
extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the U.S. Secretary of State tobe financing conflict in the Democratic Republic of the Congo or an adjoining country.
1collectively as Other Bets. Our Alphabet structure is about helping each of our businesses
prosper through strong leaders and independence.
Our Google segment represented approximately 99% of our consolidated revenues in 2017. It
generates revenues primarily by delivering online advertising that consumers find relevant andthat advertisers find cost-effective. Our Other Bets are early-stage businesses, and our goal isfor them to become thriving, successful businesses in the medium to long term. This CMR
covers all products as described below from Google and Other Bets.
(B) In-Scope Products
While we generate revenues primarily from advertising, we also generate revenues from the saleof hardware and other devices. The hardware and other devices considered in scope for thisCMR pertain to consumer-facing devices such as healthcare technology, home assistants,
phones, smoke alarms, streaming devices, tablets, thermostats, video cameras, ​and otherelectronics.
(C) Supply Chain
Our supply chain consists of a diverse range of suppliers and several manufacturing models.
The products described above were manufactured by other companies on our behalf. Whether
we are working with Original Equipment Manufacturers or more closely with the product design,
we do not directly purchase raw materials and are several tiers away from the smelter andcountry of origin of the 3TG used in our products. In addition, many of the suppliers we workwith are not directly subject to the Rule and its corresponding requirements. To influence
activities through multiple tiers of the supply chain, we actively engage with a variety of industry
members, including the Responsible Minerals Initiative (the “RMI”) - formally known as the
Conflict-Free Smelter Initiative. Our engagement with RMI includes using tools such as the
Conflict Minerals Reporting Template (the “CMRT”) and participating in programs such as the
Responsible Minerals Assurance Process (the “RMAP”) - formally known as the Conflict-Free
Smelter Program.
(D) Conflict Minerals Policy
We believe it is essential to establish validated conflict-free sources of 3TG within the
Democratic Republic of the Congo (the “DRC”) and adjoining countries (together, with the DRC,
the “Covered Countries”), so that these minerals can be procured in a way that contributes toeconomic growth and development in the regions. To aid in this effort, we have established aconflict minerals policy and an internal team to implement the policy. Our conflict minerals
policy is accessible on our website at ​https://abc.xyz/investor/conflictminerals/​.
We expect our suppliers to source 3TG from conformant conflict-free smelters such as those
audited through the RMI’s RMAP ​(h​ ttp://www.responsiblemineralsinitiative.org​), perform due
diligence on the source and chain of custody of the 3TG used in our products, and provide theirdue diligence measures to us upon request.

2. Reasonable Country of Origin Inquiry
To identify which of our suppliers to survey regarding the source of the 3TG used in our
products, we inventoried our products to determine which products were either manufactured orcontracted for manufacture by us between January 1, 2017 and December 31, 2017, and if they
were intended to enter the stream of commerce. ​For products in scope, we identified andcompiled a list of our suppliers (our “in-scope suppliers”) from whom we requested information
regarding their sourcing of 3TG.
We requested that such identified in-scope suppliers provide us with information regarding their
supply chain using the CMRT from the RMI. The CMRT included questions about location ormine of origin of the 3TG in the products, and requested in-scope suppliers to make similar
efforts to survey their supply chains and report the smelters and location or mine of origin ofnecessary 3TG. We reviewed and monitored responses from our in-scope suppliers andfollowed up if we identified information to be incomplete or inconsistent with the information
we would expect from the supplier. We reviewed and monitored responses for completenessand red flags, and took the following actions:●●●

If an in-scope supplier did not respond, we made at least three attempts to contact thein-scope supplier via multiple methods.
If an in-scope supplier had inconsistent or incomplete information, we contacted the
supplier to request updated information, and provided additional training, as necessary.
We communicated with suppliers that reported smelters who were not yet identified as
RMAP conformant. We worked with such suppliers to improve their responses andcommitment to conflict-free sourcing at both company and product levels. We also
encouraged suppliers to join in-region collaborations.

We received a high response rate from our in-scope suppliers who provided data to us at either
the company or product level. Some of our in-scope suppliers indicated that they are still in theprocess of gathering information from their suppliers. We continue to work with our in-scope
suppliers to ensure that all of their suppliers are represented.
Some in-scope supplier responses indicated that some of the smelters used by them at various
levels of our supply chain obtain 3TG from the Covered Countries. Some in-scope supplier
responses also indicated sourcing 3TG from outside of the Covered Countries, from recycled or
scrap sources, and from unknown origins. Based on the results of our supply chain survey andthe nature of our supply chain as described in Section 1(C) above, we were unable to verify withabsolute certainty the source and chain of custody of all of the 3TG used by our suppliers and in
our products. Due to the fact that 10% of the smelters, all of which are conformant, disclosed by
our in-scope suppliers have been reported by the RMI to source from the Covered Countries, we
proceeded by conducting due diligence as described in Section 3 below.

3. Due Diligence
Our due diligence measures were designed in accordance with the framework set forth in the
Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, ​Third
Edition, 2016​ (“OECD Guidance”), and the related Supplements for 3TG.
Below is a description of our due diligence activities performed for the 2017 reporting year as
they relate to the five-step framework set forth in the OECD Guidance.
OECD Step 1 - Establish strong company management systems● Our conflict minerals policy described in Section 1(D) is publicly available on our
website.
● We have an internal team, which includes representatives from supply chain, legal, andfinance organizations, that is responsible for executing our conflict minerals program.
● Our governance structure includes senior management from our in-scope supply chains,
legal and finance organizations who are responsible for monitoring our due diligence
activities. Oversight of the program consists of our CFO, vice presidents from supply
chain and business operations, finance, and legal.
● We include responsible sourcing and due diligence requirements in Google’s Supplier
Code of Conduct and in supplier contract templates. Our suppliers are expected tosource from conflict-free sources.
● We communicate with our in-scope suppliers to use the CMRT to disclose sourcing
information about the 3TG in their products.
● Our product areas utilize a system that includes online platforms for storing andmanaging our conflict minerals due diligence activities, communications, and results.
● We have a document retention policy for maintaining conflict minerals program
documentation for a minimum of five years.
● We have a grievance mechanism for reporting violations of our policies.
OECD Step 2 - Identify and assess risk in the supply chain● We requested that our in-scope suppliers provide a CMRT in order to collect information
about the smelters of 3TG used in our products.
● We assessed the CMRTs received from our in-scope suppliers for completeness andreasonableness based on internally defined review criteria.
● We validated whether each smelter disclosed by our in-scope suppliers was aconformant, active or standard smelter by checking against the smelter data provided by
the RMI to its members.
● We provided conflict minerals feedback to in-scope suppliers that were audited by the
Responsible Supply Chain audit program. Feedback included follow-up such as when asupplier declared no use of 3TG, but we suspected there was 3TG in the component. We
used these audit opportunities to request more schematics on processes andmanufacturing to clarify supplier use of 3TG, and educate them on the importance of
conflict-free sourcing commitments.

●●●

We engaged a third party to provide an assessment of 100% of the smelters disclosed
by our in-scope suppliers.
To further our understanding of mining conditions, we visited mine sites and trading
routes of 3TG in Rwanda, the DRC, and Peru.
We communicated with in-scope suppliers that reported smelters who were not yet
identified as RMAP conformant. We worked with in-scope suppliers to improve their
responses and commitment to conflict-free at both company and product levels. We
also encouraged these suppliers to join in-region collaborations. We developed a plan forin-scope suppliers not sourcing exclusively from conformant smelters for products,
including a timeline for achieving conformance.

OECD Step 3 - Design and implement a strategy to respond to identified risks● We provided regular updates to our responsible supply chain team on our due diligence
activities and Conflict Minerals Report.
● We updated our Audit Committee on our due diligence activities and CMR.
● We prepared an annual list of supplier performance for all suppliers that achieved
conformance to in-scope product areas. We use this list to guide our continuingbusiness with known conflict-free sourcing suppliers. This list is also utilized for productdecisions to discontinue sourcing relationships.
● We contacted standard smelters that were not yet conformant or active to emphasize
the importance of being certified by the RMI as conflict-free.
● We continued to support sourcing from the Covered Countries and supported in-region
projects through our contributions to the Public-Private Alliance for Responsible
Minerals Trade (PPA), Responsible Artisanal Gold Solutions Forum (RAGS), and Pact toaddress the child labor issues in the DRC, and the RMAP’s Initial Audit Fund.
● We were confirmed to the Governance Committee of the PPA, and joined the Projects
and Resources Work Group. We participated in eight RMI advisory and sub-committeegroups (Smelter Engagement Team, Due Diligence Practices Team, Blockchain, Plenary,Gold, CMRT, Multi-Stakeholder, and Grievance Platform), which focused on coordinating
outreach to smelters and collaboration with RMI staff and fellow suppliers.
● We participated in two RAGS committees (RAGS Forum and Virtual Reality Task Team).
● We reviewed known incidents and allegations in the supply chain. In the DRC, we joined
the RMI in local and regional government meetings that were organized around
identified incidents and allegations, and conflict-free sourcing objectives (including
anti-corruption). We observed traceability schemes in operation, and discussed chain ofcustody due diligence with minerals traders. We had stakeholder meetings in the DRC
with RMI to validate chain of custody systems, understand concerns with artisanal andsmall scale mining communities, and concerns from communities around industrial
mine sites.
OECD Step 4 - Carry out independent third-party audits of supply chain due diligence at identified
points in the supply chain● We joined the RMI in 2013 (member ID: GOOG), and we continue to be a member.
● We relied upon the RMI to validate that companies meet the criteria of smelter and thencertify them as conformant via the RMAP.

●●●

We worked with a third party to provide an assessment of smelters not participating in
RMI to give Alphabet visibility on all smelters identified in supplier outreach.
We conducted sustainable supply chain audits with independent third parties on a
portion of our suppliers, which included reviewing their conflict minerals programs.
We completed four onsite standard smelter and refiner visits to encourage participationin the RMAP, and to better understand issues smelters face in the compliance process,and management systems used for compliance and in-region due diligence. As a result,
We are considering pilot projects to support on chain of custody enhancements(including blockchain) that improve visibility and accountability throughout the supply
chain.

OECD Step 5 - Report annually on supply chain due diligence● We publish a CMR annually, and our reports are accessible on our website athttps://abc.xyz/investor/conflictminerals/​.
● We published our first ​Responsible Supply Chain Report​, which also included an update
on our conflict minerals program.

4. Due Diligence Results
Smelter Disclosure
Based on our due diligence of the information provided by our in-scope suppliers for the 2017
reporting period, we have reason to believe that a portion of the 3TG used in our products
originated from the Covered Countries. While we have not identified any instances of sourcingthat directly or indirectly supported conflict in the Covered Countries, we are not declaring any ofour products to be “DRC Conflict Free.” In some instances, information provided by our in-scope
suppliers was unverifiable or incomplete and, as such, we were unable to verify with certainty
the source and chain of custody of all of the necessary 3TG in our products. Based on our due
diligence, we identified 306 smelters and evaluated each of them based on third party audits
and/or assessments; 253 are considered “conformant” and 8 are considered “active” on the RMI
website. Based on our third party assessment and RCOI, we identified an additional 42 smelters
as not sourcing from the Covered Countries (or no reason to believe they are sourcing from the
Covered Countries) bringing the total number of smelters identified as “conformant”, “active” ornot sourcing from the DRC to 303 (99%).

The results of our due diligence on the 3TG used in our in-scope products are noted below:
2017 Smelters

Tin

Total number of smelters77

44

70 (91%)41 (93%)

Number (%) of smelters listed as “active”
by RMI

1 (1%)

1 (2%)

0 (0%)

6 (5%)

8 (2%)

Number (%) of smelters confirmed by anindependent third party to not be sourcing
from the Covered Countries

6 (8%)

2 (5%)

0 (0%)

34 (23%)42 (14%)

Number (%) of smelters listed as“conformant” by RMI

Tungsten Tantalum
40

Gold

Total

145

306

40 (100%) 102 (70%) 253 (83%)

Number (%) of smelters that are
2
conformant, active, or not sourcing from 77 (100%) 44 (100%) 40 (100%) 142 (98% ) 303 (99%)
the Covered Countries

Efforts to Determine Mine or Location of Origin
As part of our due diligence process described in Section 3 above, we worked to ensure that ourefforts to identify mines and the countries of origin of the 3TG in our products have beenreasonable and aligned with industry practices through our support of processes and tools
developed by the RMI. Appendix II includes the country of origin data provided to the RMI for
conformant smelters only.
5. Continuous Improvement in Understanding Source of Material
We recognize that efforts to reduce violence associated with conflict minerals are ongoing andrequire continually adapting to changing situations. We are committed to improving ourcompliance processes as well as actively engaging upstream directly in-region. We will continue
to improve our compliance processes including, but not limited to, taking the following steps forthe 2018 reporting year:●●●

We will continue to engage with in-scope suppliers to gain better visibility of the countryof origin and chain of custody of the 3TG used in our products.
We will support an education campaign around the VR collaboration with RAGS toencourage more visibility and action around conflict-free gold sourcing in the DRC andCovered Countries.
We will use and encourage our in-scope suppliers to use publicly available tools from the
RMI; we will continue to work with our in-scope suppliers and engage with our supply
chain to increase the quality of the data provided to us.

​Three gold smelters that have not been yet been determined to be conformant, active or confirmed by an independent third party,
as not sourcing from Covered Countries, are in the early stages of outreach with RMI.
2

●
●
●

●

●

●

We will continue to be a ​member of the RMI and contribute to the various initiatives, as
described above.
We will continue to encourage our in-scope suppliers to source from conflict-freesmelters that are listed as conformant by the RMI.
As we enter into co​ntracts with new suppliers and renew contracts with existing
suppliers, we will continue to include requirements that our suppliers support ourconflict minerals policy and due diligence efforts.
We will continue to explore additional opportunities to support livelihoods and health,improve conservation outcomes, improve stability, and support renewable energy
projects to enhance conflict-free mining operations.
We will continue to address incidents and allegations through collaboration with relevant
stakeholders while also working to support stronger chain of custody and traceability
systems.
We will continue to work with stakeholders to increase transparency and accountability
for conflict-free sourcing.

APPENDIX I Smelter List

Metal

Smelter ID

Smelter Location Country

Gold

Abington Reldan Metals, LLC

United States Of America

Gold

Advanced Chemical Company

United States Of America

Gold

Aida Chemical Industries Co., Ltd.

Japan

Gold

Al Etihad Gold LLC

United Arab Emirates

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GermanyGold

Almalyk Mining and Metallurgical Complex (AMMC)

Uzbekistan

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

BrazilGold

Argor-Heraeus S.A.

SwitzerlandGold

Asahi Pretec Corp.

Japan

Gold

Asahi Refining Canada Ltd.

CanadaGold

Asahi Refining USA Inc.

United States Of America

Gold

Asaka Riken Co., Ltd.

Japan

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TurkeyGold

AU Traders and Refiners

South Africa

Gold

Aurubis AG

GermanyGold

Bangalore Refinery

India

Gold

Bangko Sentral ng Pilipinas (Central Bank of thePhilippines)

PhilippinesGold

Boliden AB

SwedenGold

C. Hafner GmbH + Co. KG

GermanyGold

CaridadMexicoGold

CCR Refinery - Glencore Canada Corporation

CanadaGold

Cendres + Metaux S.A.

Switzerland

Gold

Chimet S.p.A.

Italy

Gold

Chugai Mining

Japan

Gold

Daejin Indus Co., Ltd.

Korea, Republic Of

Gold

Daye Non-Ferrous Metals Mining Ltd.

China

Gold

Degussa Sonne / Mond Goldhandel GmbHGermanyGold

DODUCO Contacts and Refining GmbHGermany

Gold

Dowa

Japan

Gold

DSC (Do Sung Corporation)

Korea, Republic Of

Gold

Eco-System Recycling Co., Ltd.

Japan

Gold

Emirates Gold DMCC

United Arab EmiratesGold

Fidelity Printers and Refiners Ltd.

ZimbabweGold

GCC Gujrat Gold Centre Pvt. Ltd.

India

Gold

Geib Refining Corporation

United States Of America

GoldGold Refinery of Zijin Mining Group Co., Ltd.

China

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

China

Gold

Guangdong Jinding Gold Limited

China

Gold

Guoda Safina High-Tech Environmental RefineryCo., Ltd.

China

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

China

Gold

HeeSung Metal Ltd.

Korea, Republic Of

Gold

Heimerle + Meule GmbHGermanyGold

Heraeus Metals Hong Kong Ltd.

China

Gold

Heraeus Precious Metals GmbH & Co. KG

GermanyGold

Hunan Chenzhou Mining Co., Ltd.

China

Gold

HwaSeong CJ CO., LTD.

Korea, Republic Of

Gold

Inner Mongolia Qiankun Gold and Silver Refinery

ChinaShare Co., Ltd.
Gold

Ishifuku Metal Industry Co., Ltd.

Japan

Gold

Istanbul Gold Refinery

TurkeyGold

Italpreziosi

Italy

Gold

Japan Mint

Japan

Gold

Jiangxi Copper Co., Ltd.

China

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing
Plant

Russian FederationGold

JSC Uralelectromed

Russian FederationGold

JX Nippon Mining & Metals Co., Ltd.

Japan

Gold

Kaloti Precious Metals

United Arab Emirates

Gold

Kazakhmys Smelting LLC

KazakhstanGold

Kazzinc

KazakhstanGold

Kennecott Utah Copper LLC

United States Of America

Gold

KGHM Polska Miedz Spolka Akcyjna

PolandGold

Kojima Chemicals Co., Ltd.

Japan

Gold

Korea Zinc Co., Ltd.

Korea, Republic OfGold

Kyrgyzaltyn JSC

Kyrgyzstan

Gold

Kyrgyzaltyn JSC

Kyrgyzstan

Gold

Kyshtym Copper-Electrolytic Plant ZAO

Russian FederationGold

L'azurde Company For Jewelry

Saudi Arabia

Gold

L'Orfebre S.A.

AndorraGold

Lingbao Gold Co., Ltd.

China

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

China

Gold

LS-NIKKO Copper Inc.

Korea, Republic Of

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

China

Gold

Marsam Metals

BrazilGold

Materion

United States Of America

Gold

Matsuda Sangyo Co., Ltd.

Japan

Gold

Metalor Technologies (Hong Kong) Ltd.

China

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SingaporeGold

Metalor Technologies (Suzhou) Ltd.

China

Gold

Metalor Technologies S.A.

Switzerland

Gold

Metalor USA Refining Corporation

United States Of America

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

MexicoGold

Mitsubishi Materials Corporation

Japan

Gold

Mitsui Mining and Smelting Co., Ltd.

Japan

Gold

MMTC-PAMP India Pvt., Ltd.

India

Gold

Modeltech Sdn Bhd

Malaysia

Gold

Morris and Watson

New ZealandGold

Morris and Watson Gold Coast

Australia

Gold

Moscow Special Alloys Processing Plant

Russian Federation

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

TurkeyGold

Navoi Mining and Metallurgical Combinat

Uzbekistan

Gold

Nihon Material Co., Ltd.

Japan

Gold

Ogussa Osterreichische Gold- undSilber-Scheideanstalt GmbH

AustriaGold

Ohura Precious Metal Industry Co., Ltd.

Japan

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous
Metals Plant" (OJSC Krastsvetmet)

Russian FederationGold

OJSC Novosibirsk Refinery

Russian Federation

Gold

PAMP S.A.

Switzerland

Gold

Pease & Curren

United States Of America

Gold

Penglai Penggang Gold Industry Co., Ltd.

China

Gold

Planta Recuperadora de Metales SpA

Chile

Gold

Prioksky Plant of Non-Ferrous Metals

Russian FederationGold

PT Aneka Tambang (Persero) Tbk

IndonesiaGold

PX Precinox S.A.

SwitzerlandGold

Rand Refinery (Pty) Ltd.

South Africa

Gold

Refinery of Seemine Gold Co., Ltd.

China

Gold

Remondis Argentia B.V.

Netherlands

Gold

Republic Metals Corporation

United States Of America

Gold

Royal Canadian Mint

Canada

Gold

SAAMP

FranceGold

Sabin Metal Corp.

United States Of America

Gold

Safimet S.p.A

Italy

Gold

SAFINA A.S.

Czech RepublicGold

Sai Refinery

India

Gold

Samduck Precious Metals

Korea, Republic Of

Gold

Samwon Metals Corp.

Korea, Republic Of

Gold

SAXONIA Edelmetalle GmbHGermanyGold

Schone Edelmetaal B.V.

Netherlands

Gold

SEMPSA Joyeria Plateria S.A.

Spain

Gold

Shandong Tiancheng Biological Gold Industrial Co.,
Ltd.

China

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

China

Gold

Sichuan Tianze Precious Metals Co., Ltd.

China

Gold

Singway Technology Co., Ltd.

Taiwan, Province Of China

Gold

SOE Shyolkovsky Factory of Secondary Precious
MetalsRussian FederationGold

Solar Applied Materials Technology Corp.

Taiwan, Province Of China

Gold

State Research Institute Center for PhysicalSciences and Technology

Lithuania

Gold

Sudan Gold Refinery

Sudan

Gold

Sumitomo Metal Mining Co., Ltd.

Japan

Gold

SungEel HiMetal Co., Ltd.

Korea, Republic Of

Gold

T.C.A S.p.A

Italy

Gold

Tanaka Kikinzoku Kogyo K.K.

Japan

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

China

Gold

Tokuriki Honten Co., Ltd.

Japan

Gold

Tongling Nonferrous Metals Group Co., Ltd.

China

Gold

TOO Tau-Ken-Altyn

Kazakhstan

Gold

Torecom

Korea, Republic Of

Gold

Umicore Brasil Ltda.

BrazilGold

Umicore Precious Metals Thailand

ThailandGold

Umicore S.A. Business Unit Precious Metals
Refining

BelgiumGold

United Precious Metal Refining, Inc.

United States Of America

Gold

Valcambi S.A.

Switzerland

Gold

Western Australian Mint (T/a The Perth Mint)

AustraliaGold

WIELAND Edelmetalle GmbHGermanyGold

Yamakin Co., Ltd.

Japan

Gold

Yokohama Metal Co., Ltd.

Japan

Gold

Yunnan Copper Industry Co., Ltd.

China

Gold

Zhongyuan Gold Smelter of Zhongjin Gold

China

Corporation
Tantalum

Asaka Riken Co., Ltd.

Japan

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

China

Tantalum

D Block Metals, LLC

United States Of America

Tantalum

Exotech Inc.

United States Of America

Tantalum

F&X Electro-Materials Ltd.

China

Tantalum

FIR Metals & Resource Ltd.

China

Tantalum

Global Advanced Metals Aizu

Japan

Tantalum

Global Advanced Metals Boyertown

United States Of America

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

China

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

China

Tantalum

H.C. Starck Co., Ltd.

Thailand

Tantalum

H.C. Starck Hermsdorf GmbHGermany

Tantalum

H.C. Starck Inc.

United States Of America

Tantalum

H.C. Starck Ltd.

Japan

Tantalum

H.C. Starck Smelting GmbH & Co. KG

Germany

Tantalum

H.C. Starck Tantalum and Niobium GmbHGermany

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

China

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

China

Tantalum

Jiangxi Tuohong New Raw Material

China

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

China

Tantalum

Jiujiang Tanbre Co., Ltd.

China

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

China

Tantalum

KEMET Blue Metals

MexicoTantalum

KEMET Blue Powder

United States Of America

Tantalum

LSM Brasil S.A.

BrazilTantalum

Metallurgical Products India Pvt., Ltd.

India

Tantalum

Mineracao Taboca S.A.

BrazilTantalum

Mitsui Mining and Smelting Co., Ltd.

Japan

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

China

Tantalum

NPM Silmet AS

Estonia

Tantalum

Power Resources Ltd.

Macedonia, The Former
Yugoslav Republic Of

Tantalum

QuantumClean

United States Of America

TantalumResind Industria e Comercio Ltda.

BrazilTantalum

RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng
Tantalum & Niobium Co., Ltd.

China

Tantalum

Solikamsk Magnesium Works OAO

Russian Federation

Tantalum

Taki Chemical Co., Ltd.

Japan

Tantalum

Telex Metals

United States Of America

Tantalum

Ulba Metallurgical Plant JSC

Kazakhstan

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

China

Tantalum

Yichun Jin Yang Rare Metal Co., Ltd.

China

Tin

Alpha

United States Of America

Tin

An Vinh Joint Stock Mineral Processing Company

Viet Nam

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

China

Tin

China Tin Group Co., Ltd.

China

Tin

CV Ayi Jaya

Indonesia

Tin

CV Dua Sekawan

Indonesia

Tin

CV Gita Pesona

Indonesia

Tin

CV United Smelting

Indonesia

Tin

CV Venus Inti Perkasa

Indonesia

Tin

Dowa

Japan

Tin

EM Vinto

Bolivia (Plurinational State
Of)

Tin

Estanho de Rondonia S.A.

BrazilTin

Fenix Metals

PolandTin

Gejiu Fengming Metallurgy Chemical Plant

China

Tin

Gejiu Jinye Mineral Company

China

Tin

Gejiu Kai Meng Industry and Trade LLC

China

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

China

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

China

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

China

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

China

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

China

Tin

HuiChang Hill Tin Industry Co., Ltd.

China

Tin

Huichang Jinshunda Tin Co., Ltd.

China

Tin

Jiangxi Ketai Advanced Material Co., Ltd.

China

Tin

Jiangxi New Nanshan Technology Ltd.

China

Tin

Magnu's Minerais Metais e Ligas Ltda.

BrazilTin

Malaysia Smelting Corporation (MSC)

Malaysia

Tin

Melt Metais e Ligas S.A.

BrazilTin

Metallic Resources, Inc.

United States Of America

Tin

Metallo Belgium N.V.

Belgium

Tin

Metallo Spain S.L.U.

Spain

Tin

Mineracao Taboca S.A.

BrazilTin

MinsurPeru

Tin

Mitsubishi Materials Corporation

Japan

Tin

Modeltech Sdn Bhd

Malaysia

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock
Company

Viet Nam

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

ThailandTin

O.M. Manufacturing Philippines, Inc.

Philippines

Tin

Operaciones Metalurgical S.A.

Bolivia (Plurinational State
Of)

Tin

PT Aries Kencana Sejahtera

Indonesia

Tin

PT Artha Cipta Langgeng

Indonesia

Tin

PT ATD Makmur Mandiri Jaya

Indonesia

Tin

PT Babel Inti Perkasa

Indonesia

Tin

PT Bangka Prima Tin

Indonesia

Tin

PT Bangka Tin Industry

Indonesia

Tin

PT Belitung Industri Sejahtera

Indonesia

Tin

PT Bukit Timah

Indonesia

Tin

PT DS Jaya Abadi

Indonesia

Tin

PT Eunindo Usaha Mandiri

Indonesia

Tin

PT Inti Stania Prima

Indonesia

Tin

PT Karimun Mining

Indonesia

Tin

PT Kijang Jaya Mandiri

Indonesia

Tin

PT Lautan Harmonis Sejahtera

Indonesia

Tin

PT Menara Cipta Mulia

Indonesia

Tin

PT Mitra Stania Prima

Indonesia

Tin

PT Panca Mega Persada

Indonesia

Tin

PT Premium Tin Indonesia

Indonesia

Tin

PT Prima Timah Utama

Indonesia

Tin

PT Rajehan Ariq

Indonesia

Tin

PT Refined Bangka Tin

Indonesia

Tin

PT Sariwiguna Binasentosa

Indonesia

Tin

PT Stanindo Inti Perkasa

Indonesia

Tin

PT Sukses Inti Makmur

Indonesia

Tin

PT Sumber Jaya Indah

Indonesia

Tin

PT Timah (Persero) Tbk Kundur

Indonesia

Tin

PT Timah (Persero) Tbk Mentok

Indonesia

Tin

PT Tinindo Inter Nusa

Indonesia

Tin

PT Tommy Utama

Indonesia

Tin

Resind Industria e Comercio Ltda.

BrazilTin

Rui Da Hung

Taiwan, Province Of China

Tin

Soft Metais Ltda.

BrazilTin

Super Ligas

BrazilTin

Thaisarco

ThailandTin

Tuyen Quang Non-Ferrous Metals Joint Stock
Company

Viet Nam

Tin

White Solder Metalurgia e Mineracao Ltda.

BrazilTin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

China

Tin

Yunnan Tin Company Limited

China

Tungsten

A.L.M.T. TUNGSTEN Corp.

Japan

Tungsten

ACL Metais Eireli

BrazilTungsten

Asia Tungsten Products Vietnam Ltd.

Viet Nam

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

China

TungstenChongyi Zhangyuan Tungsten Co., Ltd.

China

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

China

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

China

TungstenGanzhou Huaxing Tungsten Products Co., Ltd.

China

TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.

China

TungstenGanzhou Seadragon W & Mo Co., Ltd.

China

Tungsten

Global Tungsten & Powders Corp.

United States Of America

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

China

Tungsten

H.C. Starck Smelting GmbH & Co. KG

Germany

Tungsten

H.C. Starck Tungsten GmbHGermany

Tungsten

Hunan Chenzhou Mining Co., Ltd.

China

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

China

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

China

TungstenHydrometallurg, JSC

Russian Federation

TungstenJapan New Metals Co., Ltd.

Japan

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

China

Tungsten

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

China

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

China

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co.,
Ltd.

China

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical &Chemical Co., Ltd.

China

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

China

Tungsten

Jiangxi Xiushui Xianggan Nonferrous Metals Co.,
Ltd.

China

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

China

Tungsten

Kennametal Fallon

United States Of America

Tungsten

Kennametal Huntsville

United States Of America

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

China

Tungsten

Moliren Ltd.

Russian Federation

Tungsten

Niagara Refining LLC

United States Of America

Tungsten

Nui Phao H.C. Starck Tungsten Chemicals
Manufacturing LLC

Viet Nam

Tungsten

Philippine Chuangxin Industrial Co., Inc.

Philippines

TungstenSouth-East Nonferrous Metal Company Limited ofHengyang City

China

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

Viet Nam

Tungsten

Unecha Refractory metals plant

Russian Federation

Tungsten

Vietnam Youngsun Tungsten Industry Co., Ltd.

Viet Nam

Tungsten

Wolfram Bergbau und Hutten AG

Austria

Tungsten

Woltech Korea Co., Ltd.

Korea, Republic Of

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

China

Tungsten

Xiamen Tungsten Co., Ltd.

China

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New
Material Co., Ltd.

China

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

China

3

APPENDIX II Country of Origin List

Argentina

Ghana

Nigeria

Australia

GuatemalaPanamaAustria

Guinea

Peru

Benin

GuyanaPortugal

Bolivia (Plurinational StateOf)
Honduras

Russian Federation

Brazil

India

RwandaBurkina Faso

Indonesia

SenegalBurundiJapan

Sierra Leone

Cambodia

Kazakhstan

South Africa

Canada

Laos

Spain

Chile

Madagascar

ThailandChina

Malaysia

Togo

Colombia

Mali

UgandaCongo, Democratic
Republic Of The

MexicoUnited Kingdom Of GreatBritain And Northern
IrelandEcuadorMongolia

United States Of America

Eritrea

Mozambique

Uzbekistan

Ethiopia

MyanmarViet NamFranceNamibia

Zimbabwe

Germany

Nicaragua

3

The RMI generally does not specify individual countries of origin of the conflict minerals processed by
conformant smelters and refiners and thus we were not able to determine with certainty the specificcountries of origin of the conflict minerals processed by the listed conformant smelters and refiners. In
addition, for some of the listed conformant smelters and refiners, origin information is not disclosed. The
list is based on the country of origin data provided to the RMI for conformant smelters only.