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

	

FORM SD
Specialized Disclosure Report

	

MALIBU BOATS, INC.
(Exact Name of Registrant as specified in its charter)
001-36290
(Commission File Number)

Wayne Wilson, (865) 458-5478
(Name and telephone number, including area code, of the person to contact in connection with this report.)

	
					
Delaware	 	5075 Kimberly Way
Loudon, Tennessee 37774	 	46-4024640	
(State or other jurisdiction of
incorporation or organization)	 	(Address of principal executive offices,
including zip code)	 	(I.R.S. Employer
Identification No.)	

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;

þ Rule 13p-1 under the Securities Exchange Act (17 CFR240.13p-1) for the reporting period from January 1 to December 31, 2016.

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

On May 25, 2017, Malibu Boats, Inc. (the “Company”) filed a Conflict Minerals Report for the reporting period from January 1, 2016 to December 31, 2016 (the "2016 Conflict Minerals Report"), which is referenced in Item 1.02 below, filed as an exhibit to this Form SD. The 2016 Conflict Minerals Report is also publicly available on our website at http://investors.malibuboats.com/investors/corporate-governance/governance-documents . The Company's reasonable country of origin inquiry and due diligence efforts are described further in the 2016 Conflict Minerals Report and incorporated herein by reference.

Item 1.02 Exhibits

A copy of the Company's 2016 Conflict Minerals Report is filed as Exhibit 1.01 attached to this Form SD.

Section 2 - Exhibits

Item 2.01 Exhibits     
The following exhibit is being filed as part of this report:

	
			
Exhibit No.	 	Description	
 	 	 	
Exhibit 1.01	 	Conflict Minerals Report as required by Items 1.01 and 1.02 of the Form SD.	

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.

			
 	 	Malibu Boats, Inc.	
 	 	 	
Date: May 25, 2017	 	/s/ Wayne Wilson	
 	 	Wayne Wilson	
 	 	Chief Financial Officer	

Exhibit 1.01

Malibu Boats, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2016

Introduction     
    
This Conflict Minerals Report (“ CMR ”) for the year ended December 31, 2016 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “ Rule ”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“ SEC ”) issuers if they manufacture or contract to manufacture products that contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“ 3TG ” or “ Conflict Minerals ”). The Rule focuses on 3TG emanating from the Democratic Republic of Congo (“ DRC ”) region and nine adjoining countries (together, the “ Covered Countries ”). If an issuer has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries and are not from recycled or scrap sources, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody and file a CMR as an exhibit to the Form SD with the SEC that includes a description of those due diligence measures.

Company Overview

Malibu Boats, Inc., also referred to as “Malibu Boats”, “we”, “our”, and “us” is a leading designer, manufacturer and marketer of performance sport boats. Our boats are used for water sports, including water skiing, wakeboarding and wake surfing, as well as general recreational boating. Our high performance boats are sold under two brands: Malibu and Axis Wake Research, or Axis. We manufacture our own Malibu and Axis performance boats and components such as trailers, towers and tower accessories. In addition, we contract with other third-party vendors to manufacture other components for installation on our boats, such as engines and electronic controls. We determined that Conflict Minerals were necessary to the functionality and/or production of such products during calendar year 2016.

Executive Summary

Malibu Boats does not directly source any Conflict Minerals that may be used in the products we manufacture or contract to manufacture. Therefore we relied upon our suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us, including sources of Conflict Minerals that are supplied to them from sub-tier suppliers. Malibu Boats performed a Reasonable Country of Origin Inquiry (“ RCOI ”) on suppliers believed to provide Malibu Boats with materials or components containing necessary 3TGs.

Malibu Boats’ suppliers identified 308 valid smelters and refineries (“ smelters ”). Of these 308 smelters, Malibu Boats identified 37 as sourcing (or there was a reason to believe they may be sourcing) from the Covered Countries. Malibu Boats’ due diligence review indicated that 33 of these smelters have been audited and recognized as conflict free by the Conflict Free Smelter Program (“ CFSP ”). The remaining four smelters sourcing from the Covered Countries were subjected to Malibu Boats’ risk mitigation process in accordance with the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (“ OECD Due Diligence Guidance ”), as described below.

Although we requested information at a product level, many suppliers returned information at a company or division level, not at a product level. Such suppliers were unable to specify the smelters used for components supplied to Malibu Boats. Therefore the information provided was not necessarily limited to smelters contained in components supplied to us and confirmed to be in the Company’s supply chain.

Company Management Systems

Malibu Boats established strong management systems according to Step 1 of the OECD Due Diligence Guidance. Malibu Boats implemented the following:

•	Step 1A - Adopted, and clearly communicated to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. Malibu Boats:	

1

Exhibit 1.01

◦	implemented a conflict minerals policy, which is publicly available at http://investors.malibuboats.com/investors/corporate-governance/governance-documents; and	
		
◦	communicated the policy directly to suppliers as part of the RCOI process.	
		
•	Step 1B - Structured internal management to support supply chain due diligence. Malibu Boats:	
		
◦	maintained an internal cross functional team to support supply chain due diligence;	
		
◦	appointed a member of the senior staff with the necessary competence, knowledge, and experience to oversee supply chain due diligence; and	
		
◦	applied the resources necessary to support the operation and monitoring of these processes including internal resources and external consulting support.	
		
•	Step 1C - Established a system of transparency, information collection and control over the supply chain. Malibu Boats:	
		
◦	implemented a process to collect required supplier and smelter RCOI and due diligence data.	
		
•	Step 1D - Strengthened company engagement with suppliers. Malibu Boats:	
		
◦	engaged directly with suppliers during the RCOI process;	
		
◦	reviewed supplier responses as part of the RCOI process;	
		
◦	added conflict minerals compliance to new supplier contracts and Malibu Boats’ supplier code of conduct; and	
		
◦	implemented a plan to improve the quantity and quality of supplier and smelter responses year over year.	
		
•	Step 1E - Established a company and/or mine level grievance mechanism. Malibu Boats:	
		
◦	recognized the CFSP’s three audit protocols for gold, tin/tantalum, and tungsten as valid sources of smelter or mine level grievances; and	
		
◦	reviewed Malibu Boats’ ethics violations reporting system to ensure that it allows employees to voice confidentially without any fear of retribution, any concerns with the violations of the Malibu Boats’ conflict minerals policy.	

Reasonable Country of Origin Inquiry

Malibu Boats designed its RCOI process in accordance with Steps 2A and 2B of the OECD Due Diligence Guidance. Malibu Boats’ RCOI process involved two stages:

•	Stage 1 - Supplier RCOI (Step 2A of the OECD Due Diligence Guidance)	
		
•	Stage 2 - Smelter RCOI (Step 2B of the OECD Due Diligence Guidance)	

Supplier RCOI

Malibu Boats designed its supplier RCOI process to identify, to the best of Malibu Boats’ efforts, the smelters in Malibu Boats’ supply chain in accordance with Step 2A of the OECD Due Diligence Guidance. Malibu Boats’ supplier RCOI process for the 2016 reporting period included the following:

•	developed a list of suppliers providing components containing 3TG to Malibu Boats;	
		
•	contacted each supplier and requested the industry standard Conflict Minerals Reporting Template including smelter information;	
		
•	reviewed supplier responses for accuracy and completeness;	
		
•	amalgamated supplier provided smelters into a single list of smelters meeting the definition of a smelter under one of three industry recognized audit protocols; and	
		
•	reviewed the final smelter list (and compared it to industry peers) to determine if Malibu Boats identified reasonably all of the smelters in their supply chain.	

Malibu Boats’ suppliers identified 308 smelters in their supply chain. The specific list of smelters is included in “List of Smelter and Refineries” at the end of this report.

Smelter RCOI

Due to the overlap between smelter RCOI and smelter due diligence, the smelter RCOI process is summarized in the due diligence section of this report.

Due Diligence

2

Exhibit 1.01

Malibu Boats’ due diligence process was designed in accordance with the applicable sections of Steps 2, 3, and 4 of the OECD Due Diligence Guidance.

Smelter RCOI and Due Diligence

Malibu Boats’ smelter RCOI and due diligence process were designed to:

•	identify the scope of the risk assessment of the mineral supply chain (OECD Due Diligence Guide Step 2B);	
		
•	assess whether the smelters have carried out all elements of due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Due Diligence Guide Step 2C); and	
		
•	carry out, where necessary, including through participation in industry-driven programs, joint spot checks at the mineral smelter’s own facilities (OECD Due Diligence Guide Step 2D).	

Malibu Boats’ smelter RCOI and due diligence process included the following:

•	For each smelter identified in Malibu Boats’ supply chain, Malibu Boats:	
		
◦	attempted to engage directly with the smelter to determine whether or not the smelter sources from the Covered Countries;	
		
◦	reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration for smelters that declared directly or through their relevant industry association that they did not source from the Covered Countries, and were not recognized as conflict free by the CFSP; and	
		
◦	reviewed publicly available sources to determine if there was any reason to believe that the smelter may have sourced from the Covered Countries during the reporting period for smelters that did not respond to our direct engagement.	

•	For high risk smelters (smelters that are sourcing from or there is reason to believe they may be sourcing from the Covered Countries), Malibu Boats determined if the smelter was audited and recognized as conflict free by the CFSP.	
		
◦	For high risk smelters that have not been audited and recognized as conflict free by the CFSP, Malibu Boats communicated the risk to a designated member of senior management (OECD Due Diligence Guide Step 3A) and conducted risk mitigation on the smelter according to OECD Due Diligence Guide Step 3B.	

For the 2016 reporting period, Malibu Boats’ RCOI and due diligence process was executed by Claigan Environmental Inc.

Malibu Boats’ suppliers identified 308 smelters. Malibu Boats identified 37 smelters that source, or there is a reason to believe they source, from the Covered Countries.

Malibu Boats determined that 33 of these 37 smelters have been audited and recognized as conflict free by the CFSP. Malibu Boats conducted risk mitigation on the remaining four smelters as discussed below.

Risk Mitigation

Malibu Boats conducted risk mitigation on four smelters that were not recognized as conflict free by the CFSP and were sourcing from the Covered Countries. Malibu Boats’ risk mitigation was designed in accordance with Step 3B of the OECD Due Diligence Guidance and was reported to our Chief Financial Officer in accordance with Step 3A of the OECD Due Diligence Guidance. Malibu Boats’ risk mitigation process included the following:

•	conducted additional due diligence to determine if there was any reason to believe the smelter directly or indirectly financed or benefited armed groups in the Covered Countries;	
		
•	attempted to verify with internal stakeholders and relevant suppliers whether 3TGs from the specific smelter were actually in Malibu Boats’ supply chain in the 2016 reporting period; and	
		
•	engaged directly with each high risk smelter to verify risk and to encourage the smelter to become conflict free.	

Of the four smelters subject to Malibu Boats’ risk mitigation process, one of the smelters has been recognized by the CFSP as “active” and undergoing an independent audit to an industry recognized protocol and there was no reason to believe it was directly or indirectly financing or benefiting armed groups in Covered Countries. As such, in accordance with the OECD Due Diligence Guidance, we do not believe this smelter has to be removed from our supply chain. This smelter is scheduled to be

3

Exhibit 1.01

re-visited in connection with the preparation of our CMR for calendar year 2017. This process is consistent with Step 3B of the OECD Due Diligence Guidance.

As discussed above, as many suppliers return information at a company or division level, and not at a product level, we are not able to determine if the three remaining smelters are confirmed to be in Malibu Boats’ supply chain. We will continue to work with our suppliers to determine if these three smelters can be directly linked to the actual parts or products sold to Malibu Boats.

In addition, as part of our risk mitigation process we have engaged with each of them to verify risk and to encourage the smelter to become conflict free. We are continuing to work with the suppliers who currently have these three smelters in their supply chain to evaluate the removal of these smelters from their supply chain.

Improvement Plan

Malibu Boats is taking and will continue to take the following steps to improve the due diligence conducted to further mitigate any risk that the Conflict Minerals contained in the products manufactured or contracted for manufacture by Malibu Boats could directly or indirectly benefit or finance armed groups in the Covered Countries:

•	including a conflict minerals clause in all new and renewing supplier contracts;	
		
•	continuing to drive our suppliers to obtain current, accurate, and complete information about the smelters in their supply chain;	
		
•	continuing to work with our suppliers to encourage the removal of any high risk smelters;	
		
•	evaluating ongoing supplier relationships with those suppliers that do not comply with our conflict minerals policy;	
		
•	engaging smelters sourcing from the Covered Countries to become audited and certified to a protocol recognized by the CFSP; and	
		
•	following up in 2017 on the smelter requiring risk mitigation, but not removal from Malibu Boats’ supply chain.	

List of Smelters and Refineries

Below are the smelters reported to Malibu Boats as likely to be in Malibu Boats’ supply chain in the 2016 reporting period. 37 of the smelters below are declared to be sourcing or there was reason to believe they may be sourcing from the Covered Countries. Under the SEC Final Rule, the requirement is to identify whether or not a smelter is sourcing from the Covered Countries; there is no requirement to identify the specific covered country by smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified Covered Countries are The Democratic Republic of the Congo, Rwanda, Burundi, and Tanzania. As noted above, Malibu Boats has determined that of these 37 smelters, 33 have been audited and recognized as conflict free by the CFSP and Malibu Boats conducted risk mitigation on the remaining four smelters.

Metal          Smelter Name

		
Gold	Abington Reldan Metals, LLC	
Gold	Advanced Chemical Company	
Gold	Aida Chemical Industries Co., Ltd.	
Gold	Al Etihad Gold Refinery DMCC	
Gold	Allgemeine Gold-und Silberscheideanstalt A.G.	
Gold	Almalyk Mining and Metallurgical Complex (AMMC)	
Gold	AngloGold Ashanti Córrego do Sítio Mineração	
Gold	Argor-Heraeus S.A.	
Gold	Asahi Pretec Corp.	
Gold	Asahi Refining Canada Ltd.	
Gold	Asahi Refining USA Inc.	
Gold	Asaka Riken Co., Ltd.	
Gold	Atasay Kuyumculuk Sanayi Ve Ticaret A.S.	
Gold	AU Traders and Refiners	
Gold	Aurubis AG	
Gold	Bangalore Refinery	

4

Exhibit 1.01

	
		
Gold	Bangko Sentral ng Pilipinas (Central Bank of the Philippines)	
Gold	Boliden AB	
Gold	C. Hafner GmbH + Co. KG	
Gold	Caridad	
Gold	CCR Refinery - Glencore Canada Corporation	
Gold	Cendres + Métaux S.A.	
Gold	Chimet S.p.A.	
Gold	Chugai Mining	
Gold	Daejin Indus Co., Ltd.	
Gold	Daye Non-Ferrous Metals Mining Ltd.	
Gold	Degussa Sonne / Mond Goldhandel GmbH	
Gold	DODUCO GmbH	
Gold	Dowa	
Gold	DSC (Do Sung Corporation)	
Gold	Eco-System Recycling Co., Ltd.	
Gold	Elemetal Refining, LLC	
Gold	Emirates Gold DMCC	
Gold	Fidelity Printers and Refiners Ltd.	
Gold	Gansu Seemine Material Hi-Tech Co., Ltd.	
Gold	Geib Refining Corporation	
Gold	Great Wall Precious Metals Co., Ltd. of CBPM	
Gold	Guangdong Jinding Gold Limited	
Gold	Gujarat Gold Centre	
Gold	Guoda Safina High-Tech Environmental Refinery Co., Ltd.	
Gold	Hangzhou Fuchunjiang Smelting Co., Ltd.	
Gold	Heimerle + Meule GmbH	
Gold	Henan Yuguang Gold & Lead Co., Ltd.	
Gold	Heraeus Ltd. Hong Kong	
Gold	Heraeus Precious Metals GmbH & Co. KG	
Gold	Hunan Chenzhou Mining Co., Ltd.	
Gold	Hwasung CJ Co., Ltd.	
Gold	Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.	
Gold	Ishifuku Metal Industry Co., Ltd.	
Gold	Istanbul Gold Refinery	
Gold	Japan Mint	
Gold	Jiangxi Copper Co., Ltd.	
Gold	JSC Ekaterinburg Non-Ferrous Metal Processing Plant	
Gold	JSC Uralelectromed	
Gold	JX Nippon Mining & Metals Co., Ltd.	
Gold	Kaloti Precious Metals	
Gold	Kazakhmys Smelting LLC	
Gold	Kazzinc	
Gold	Kennecott Utah Copper LLC	
Gold	KGHM Polska MiedŸ Spó³ka Akcyjna	
Gold	Kojima Chemicals Co., Ltd.	
Gold	Korea Zinc Co., Ltd.	
Gold	Kyrgyzaltyn JSC	
Gold	Kyshtym Copper-Electrolytic Plant ZAO	
Gold	L'azurde Company For Jewelry	
Gold	Lingbao Gold Co., Ltd.	

5

Exhibit 1.01

	
		
Gold	Lingbao Jinyuan Tonghui Refinery Co., Ltd.	
Gold	LS-NIKKO Copper Inc.	
Gold	Luoyang Zijin Yinhui Gold Refinery Co., Ltd.	
Gold	Materion	
Gold	Matsuda Sangyo Co., Ltd.	
Gold	Metalor Technologies (Hong Kong) Ltd.	
Gold	Metalor Technologies (Singapore) Pte., Ltd.	
Gold	Metalor Technologies (Suzhou) Ltd.	
Gold	Metalor Technologies S.A.	
Gold	Metalor USA Refining Corporation	
Gold	Metalúrgica Met-Mex Peñoles S.A. De C.V.	
Gold	Mitsubishi Materials Corporation	
Gold	Mitsui Mining and Smelting Co., Ltd.	
Gold	MMTC-PAMP India Pvt., Ltd.	
Gold	Modeltech Sdn Bhd	
Gold	Morris and Watson	
Gold	Moscow Special Alloys Processing Plant	
Gold	Nadir Metal Rafineri San. Ve Tic. A.ª.	
Gold	Navoi Mining and Metallurgical Combinat	
Gold	Nihon Material Co., Ltd.	
Gold	Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH	
Gold	Ohura Precious Metal Industry Co., Ltd.	
Gold	OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)	
Gold	OJSC Novosibirsk Refinery	
Gold	PAMP S.A.	
Gold	Penglai Penggang Gold Industry Co., Ltd.	
Gold	Prioksky Plant of Non-Ferrous Metals	
Gold	PT Aneka Tambang (Persero) Tbk	
Gold	PX Précinox S.A.	
Gold	Rand Refinery (Pty) Ltd.	
Gold	The Refinery of Shandong Gold Mining Co., Ltd.	
Gold	Remondis Argentia B.V.	
Gold	Republic Metals Corporation	
Gold	Royal Canadian Mint	
Gold	SAAMP	
Gold	Sabin Metal Corp.	
Gold	SAFINA A.S.	
Gold	Sai Refinery	
Gold	Samduck Precious Metals	
Gold	SAMWON Metals Corp.	
Gold	SAXONIA Edelmetalle GmbH	
Gold	Schone Edelmetaal B.V.	
Gold	SEMPSA Joyería Platería S.A.	
Gold	Shandong Tiancheng Biological Gold Industrial Co., Ltd.	
Gold	Shandong Zhaojin Gold & Silver Refinery Co., Ltd.	
Gold	Sichuan Tianze Precious Metals Co., Ltd.	
Gold	Singway Technology Co., Ltd.	
Gold	So Accurate Group, Inc.	
Gold	SOE Shyolkovsky Factory of Secondary Precious Metals	
Gold	Solar Applied Materials Technology Corp.	

6

Exhibit 1.01

	
		
Gold	Sudan Gold Refinery	
Gold	Sumitomo Metal Mining Co., Ltd.	
Gold	T.C.A S.p.A	
Gold	Tanaka Kikinzoku Kogyo K.K.	
Gold	Tokuriki Honten Co., Ltd.	
Gold	Tongling Nonferrous Metals Group Co., Ltd.	
Gold	Tony Goetz NV	
Gold	TOO Tau-Ken-Altyn	
Gold	Torecom	
Gold	Umicore Brasil Ltda.	
Gold	Umicore Precious Metals Thailand	
Gold	Umicore S.A. Business Unit Precious Metals Refining	
Gold	United Precious Metal Refining, Inc.	
Gold	Universal Precious Metals Refining Zambia	
Gold	Valcambi S.A.	
Gold	Western Australian Mint trading as The Perth Mint	
Gold	WIELAND Edelmetalle GmbH	
Gold	Yamamoto Precious Metal Co., Ltd.	
Gold	Yokohama Metal Co., Ltd.	
Gold	Yunnan Copper Industry Co., Ltd.	
Gold	Zhongyuan Gold Smelter of Zhongjin Gold Corporation	
Gold	Zijin Mining Group Co., Ltd. Gold Refinery	
Tantalum	Changsha South Tantalum Niobium Co., Ltd.	
Tantalum	Conghua Tantalum and Niobium Smeltry	
Tantalum	D Block Metals, LLC	
Tantalum	Duoluoshan	
Tantalum	Exotech Inc.	
Tantalum	F&X Electro-Materials Ltd.	
Tantalum	FIR Metals & Resource Ltd.	
Tantalum	Global Advanced Metals Aizu	
Tantalum	Global Advanced Metals Boyertown	
Tantalum	Guangdong Zhiyuan New Material Co., Ltd.	
Tantalum	H.C. Starck Co., Ltd.	
Tantalum	H.C. Starck GmbH Goslar	
Tantalum	H.C. Starck Hermsdorf GmbH	
Tantalum	H.C. Starck Inc.	
Tantalum	H.C. Starck Ltd.	
Tantalum	H.C. Starck Smelting GmbH & Co. KG	
Tantalum	Hengyang King Xing Lifeng New Materials Co., Ltd.	
Tantalum	Hi-Temp Specialty Metals, Inc.	
Tantalum	Jiangxi Dinghai Tantalum & Niobium Co., Ltd.	
Tantalum	Jiangxi Tuohong New Raw Material	
Tantalum	JiuJiang JinXin Nonferrous Metals Co., Ltd.	
Tantalum	Jiujiang Tanbre Co., Ltd.	
Tantalum	Jiujiang Zhongao Tantalum & Niobium Co., Ltd.	
Tantalum	KEMET Blue Metals	
Tantalum	KEMET Blue Powder	
Tantalum	King-Tan Tantalum Industry Ltd.	
Tantalum	LSM Brasil S.A.	
Tantalum	Metallurgical Products India Pvt., Ltd.	

7

Exhibit 1.01

	
		
Tantalum	Mineração Taboca S.A.	
Tantalum	Mitsui Mining & Smelting	
Tantalum	Molycorp Silmet A.S.	
Tantalum	Ningxia Orient Tantalum Industry Co., Ltd.	
Tantalum	Power Resources Ltd.	
Tantalum	QuantumClean	
Tantalum	Resind Indústria e Comércio Ltda.	
Tantalum	RFH Tantalum Smeltry Co., Ltd.	
Tantalum	Solikamsk Magnesium Works OAO	
Tantalum	Taki Chemicals	
Tantalum	Telex Metals	
Tantalum	Tranzact, Inc.	
Tantalum	Ulba Metallurgical Plant JSC	
Tantalum	XinXing HaoRong Electronic Material Co., Ltd.	
Tantalum	Yichun Jin Yang Rare Metal Co., Ltd.	
Tantalum	Zhuzhou Cemented Carbide	
Tin	Alpha	
Tin	An Thai Minerals Co., Ltd.	
Tin	An Vinh Joint Stock Mineral Processing Company	
Tin	Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.	
Tin	China Tin Group Co., Ltd.	
Tin	CNMC (Guangxi) PGMA Co., Ltd.	
Tin	Cooperativa Metalurgica de Rondônia Ltda.	
Tin	CV Ayi Jaya	
Tin	CV Dua Sekawan	
Tin	CV Gita Pesona	
Tin	CV Serumpun Sebalai	
Tin	CV Tiga Sekawan	
Tin	CV United Smelting	
Tin	CV Venus Inti Perkasa	
Tin	Dowa	
Tin	Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company	
Tin	Elmet S.L.U.	
Tin	EM Vinto	
Tin	Estanho de Rondônia S.A.	
Tin	Fenix Metals	
Tin	Gejiu Jinye Mineral Company	
Tin	Gejiu Kai Meng Industry and Trade LLC	
Tin	Gejiu Non-Ferrous Metal Processing Co., Ltd.	
Tin	Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.	
Tin	Gejiu Zili Mining And Metallurgy Co., Ltd.	
Tin	HuiChang Hill Tin Industry Co., Ltd.	
Tin	Huichang Jinshunda Tin Co., Ltd.	
Tin	Jiangxi Ketai Advanced Material Co., Ltd.	
Tin	Magnu's Minerais Metais e Ligas Ltda.	
Tin	Malaysia Smelting Corporation (MSC)	
Tin	Melt Metais e Ligas S.A.	
Tin	Metallic Resources, Inc.	
Tin	Metallo-Chimique N.V.	
Tin	Mineração Taboca S.A.	

8

Exhibit 1.01

	
		
Tin	Minsur	
Tin	Mitsubishi Materials Corporation	
Tin	Modeltech Sdn Bhd	
Tin	Nankang Nanshan Tin Manufactory Co., Ltd.	
Tin	Nghe Tinh Non-Ferrous Metals Joint Stock Company	
Tin	O.M. Manufacturing (Thailand) Co., Ltd.	
Tin	O.M. Manufacturing Philippines, Inc.	
Tin	Operaciones Metalurgical S.A.	
Tin	PT Aries Kencana Sejahtera	
Tin	PT Artha Cipta Langgeng	
Tin	PT ATD Makmur Mandiri Jaya	
Tin	PT Babel Inti Perkasa	
Tin	PT Bangka Prima Tin	
Tin	PT Bangka Tin Industry	
Tin	PT Belitung Industri Sejahtera	
Tin	PT Bukit Timah	
Tin	PT Cipta Persada Mulia	
Tin	PT DS Jaya Abadi	
Tin	PT Eunindo Usaha Mandiri	
Tin	PT Inti Stania Prima	
Tin	PT Justindo	
Tin	PT Karimun Mining	
Tin	PT Kijang Jaya Mandiri	
Tin	PT Lautan Harmonis Sejahtera	
Tin	PT Menara Cipta Mulia	
Tin	PT Mitra Stania Prima	
Tin	PT O.M. Indonesia	
Tin	PT Panca Mega Persada	
Tin	PT Prima Timah Utama	
Tin	PT Refined Bangka Tin	
Tin	PT Sariwiguna Binasentosa	
Tin	PT Sukses Inti Makmur	
Tin	PT Sumber Jaya Indah	
Tin	PT Timah (Persero) Tbk Kundur	
Tin	PT Timah (Persero) Tbk Mentok	
Tin	PT Tinindo Inter Nusa	
Tin	PT Tommy Utama	
Tin	Resind Indústria e Comércio Ltda.	
Tin	Rui Da Hung	
Tin	Soft Metais Ltda.	
Tin	Thaisarco	
Tin	Tuyen Quang Non-Ferrous Metals Joint Stock Company	
Tin	VQB Mineral and Trading Group JSC	
Tin	White Solder Metalurgia e Mineração Ltda.	
Tin	Yunnan Chengfeng Non-ferrous Metals Co., Ltd.	
Tin	Yunnan Tin Company Limited	
Tungsten	A.L.M.T. TUNGSTEN Corp.	
Tungsten	ACL Metais Eireli	
Tungsten	Asia Tungsten Products Vietnam Ltd.	
Tungsten	Chenzhou Diamond Tungsten Products Co., Ltd.	

9

Exhibit 1.01

	
		
Tungsten	Chongyi Zhangyuan Tungsten Co., Ltd.	
Tungsten	Fujian Jinxin Tungsten Co., Ltd.	
Tungsten	Ganzhou Haichuang Tungsten Industry Co., Ltd.	
Tungsten	Ganzhou Huaxing Tungsten Products Co., Ltd.	
Tungsten	Ganzhou Jiangwu Ferrotungsten Co., Ltd.	
Tungsten	Ganzhou Seadragon W & Mo Co., Ltd.	
Tungsten	Ganzhou Yatai Tungsten Co., Ltd.	
Tungsten	Global Tungsten & Powders Corp.	
Tungsten	Guangdong Xianglu Tungsten Co., Ltd.	
Tungsten	H.C. Starck GmbH	
Tungsten	H.C. Starck Smelting GmbH & Co.KG	
Tungsten	Hunan Chenzhou Mining Co., Ltd.	
Tungsten	Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji	
Tungsten	Hunan Chunchang Nonferrous Metals Co., Ltd.	
Tungsten	Hydrometallurg, JSC	
Tungsten	Japan New Metals Co., Ltd.	
Tungsten	Jiangwu H.C. Starck Tungsten Products Co., Ltd.	
Tungsten	Jiangxi Dayu Longxintai Tungsten Co., Ltd.	
Tungsten	Jiangxi Gan Bei Tungsten Co., Ltd.	
Tungsten	Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.	
Tungsten	Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.	
Tungsten	Jiangxi Xinsheng Tungsten Industry Co., Ltd.	
Tungsten	Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.	
Tungsten	Jiangxi Yaosheng Tungsten Co., Ltd.	
Tungsten	Kennametal Fallon	
Tungsten	Kennametal Huntsville	
Tungsten	Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd	
Tungsten	Malipo Haiyu Tungsten Co., Ltd.	
Tungsten	Moliren Ltd	
Tungsten	Niagara Refining LLC	
Tungsten	Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC	
Tungsten	Philippine Chuangxin Industrial Co., Inc.	
Tungsten	South-East Nonferrous Metal Company Limited of Hengyang City	
Tungsten	Tejing (Vietnam) Tungsten Co., Ltd.	
Tungsten	Unecha Refractory Metals Plant	
Tungsten	Vietnam Youngsun Tungsten Industry Co., Ltd.	
Tungsten	Wolfram Bergbau und Hütten AG	
Tungsten	Woltech Korea Co., Ltd.	
Tungsten	Xiamen Tungsten (H.C.) Co., Ltd.	
Tungsten	Xiamen Tungsten Co., Ltd.	
Tungsten	Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.	
Tungsten	Xinhai Rendan Shaoguan Tungsten Co., Ltd.	

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