UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
Form SD
 
SPECIALIZED DISCLOSURE REPORT

 
Welbilt, Inc.
(Exact Name of Registrant as Specified in Charter)
_______________________

Delaware 		1-37548 		47-4625716	
(State or Other Jurisdiction
of Incorporation)
 	 
 	(Commission File No.)
 	 
 	(I.R.S. Employer
Identification Number)

									
2227 Welbilt Boulevard
New Port Richey, Florida 	 
 	34655 	
(Address of Principal Executive Offices)
 	 
 	(Zip Code)

			
Joel H. Horn
Executive Vice President, General Counsel and Corporate Secretary 
(727) 375-7010	
(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:
 
x  Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.

Section 1 – Conflict Minerals Disclosure
 
Item 1.01     Conflict Minerals Disclosure and Report
 
As required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report is provided as an exhibit to this Form SD and is available at the following website: ir.welbilt.com/investor-relations/financial-information/sec-filings/default.aspx. The information found on our website is not incorporated by reference into this Form SD or the attached Conflict Minerals Report.

Item 1.02     Exhibits

The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 2 – Exhibits

Item 2.01     Exhibits

Exhibit 1.01 - Welbilt, Inc. Conflict Minerals Report for the Year Ended December 31, 2020.

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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.

WELBILT, INC.  			
			
By 	/s/ Joel H. Horn 		May 28, 2021	
	Joel H. Horn 		(Date)	
	Executive Vice President, General Counsel and Corporate Secretary 			

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Exhibit 1.01
 
Welbilt, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2020
 
This Conflict Minerals Report (this "Report") for the year ended December 31, 2020 is presented to comply with Rule 13p-1 ("Rule 13p-1") under the Securities Exchange Act of 1934, as amended. Unless otherwise expressly stated or the context otherwise requires, references to "we," "our," "us," the "Company" or "Welbilt," refer to Welbilt, Inc. and its consolidated subsidiaries.

This Report has been prepared by our management for calendar year 2020 in accordance with Rule 13p-1. This Report discusses our efforts related to determining whether any of the products we manufacture or that we have contracted to be manufactured contain tin, tantalum, tungsten and gold (collectively, the "3TG Minerals") that are necessary to the functionality or production of such products that may have originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (collectively, the "Covered Countries") or are from recycled or scrap sources.

Forward-Looking Statements

Certain statements contained in, or incorporated into, this Report constitute "forward-looking statements" within the meaning of the U.S. Private Securities Litigation Reform Act of 1995. Statements that are not historical fact are forward-looking statements and include, for example, descriptions of our supply chain improvement efforts and risk mitigation strategies. Certain of these forward-looking statements can be identified by the use of words such as "anticipates," "believes," "intends," "estimates," "targets," "expects," "could," "will," "may," "plans," "projects," "assumes," "should" or other similar expressions. Such forward-looking statements involve known and unknown risks and uncertainties, and our actual results could differ materially from future results expressed or implied in these forward-looking statements. The forward-looking statements included in this report are based on our current beliefs and expectations and speak only as of the date of this report. These statements are not guarantees or indicators of future performance. Important assumptions and other important factors that could cause actual results to differ materially from these forward-looking statements include, but are not limited to, those risks, uncertainties and factors described in more detail under the caption "Risk Factors" in our Annual Report on Form 10-K for the year ended December 31, 2020, our Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2021 and in our other filings with the U.S. Securities and Exchange Commission (the "SEC"). We do not intend, and, except as required by law, we undertake no obligation, to update any of our forward-looking statements after the date of this report to reflect any future events or circumstances. Given these risks and uncertainties, readers are cautioned not to place undue reliance on such forward-looking statements.

1. Company Overview

We are one of the world's leading commercial foodservice equipment companies leveraging a full suite of equipment capable of storing, cooking, holding, displaying, dispensing and serving in both hot and cold foodservice categories. Headquartered in New Port Richey, Florida, Welbilt was incorporated in Delaware in 2015 and became publicly traded in March 2016 after a spin-off from its former parent. We operate 19 manufacturing facilities globally at which we design, manufacture and supply best-in-class equipment for the global commercial foodservice market, consisting of commercial and institutional foodservice operators represented by full-service restaurants, quick-service restaurant ("QSR") chains, hotels, resorts, cruise ships, caterers, supermarkets, convenience stores, hospitals, schools and other institutions. We sell our products through a global network of over 5,000 distributors, dealers, buying groups and manufacturers' representatives. Our portfolio of award-winning product brands includes Cleveland™, Convotherm®, Crem®, Delfield®, Frymaster®, Garland®, Kolpak®, Lincoln™, Manitowoc® Ice, Merco®, Merrychef® and Multiplex®. These product brands are supported by three service brands: FitKitchen®, our fully-integrated kitchen systems business, KitchenConnect®, our digital cloud-based application offering and KitchenCare®, our aftermarket parts and service business. Through these operations, we provide our customers with a full portfolio of products, platforms and solutions specific to meet our customers' needs, drive brand loyalty and maintain high customer satisfaction. With our in-house culinary staff and skilled engineers, we are also able to develop innovative solutions and tailor our product offerings to support our customers’ evolving menu choices and strategic plans, which serves to further strengthen our customer relationships

As a downstream supplier, many steps removed from the mining of 3TG Minerals, we do not purchase any 3TG Minerals directly from smelters or refiners and do not knowingly purchase any 3TG Minerals in their raw material form. We are committed to the responsible sourcing of our products and we expect the same from our suppliers, including ensuring that the products or components supplied to us do not directly or indirectly finance or benefit armed groups in the Covered Countries. Our suppliers are required to support our efforts to comply with Rule 13p-1. We have a Conflict Minerals Policy, which is available on our website (welbilt.com) under Investor Relations - Corporate Governance - Governance Documents. In addition, our standard supplier terms and conditions address our expectations related to any 3TG Minerals supplied to us.

2.  Reasonable Country of Origin Inquiry
We undertook a reasonable country of origin inquiry ("RCOI") in good faith to determine whether the 3TG Minerals in the products we manufacture, or contract to manufacture, that are necessary to the functionality or production of our products may have originated in the Covered Countries or may have come from recycled or scrap sources.

To assist in determining whether 3TG Minerals in our products originated in Covered Countries, we retained Assent Compliance, Inc. ("Assent"), a third-party service provider. We provided a list of direct suppliers that provide us with products and components used in our
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manufacturing process that contain, or had a high probability of containing, one or more 3TG Minerals (the "in-scope suppliers") to Assent. We also periodically reviewed the supplier list to ensure that irrelevant or "out-of-scope" suppliers were removed from the survey process.

We utilized the RBA-GeSI Conflict Minerals Reporting Template ("CMRT") to conduct a survey of all in-scope suppliers. During the supplier survey, we contacted 449 suppliers via the Assent Compliance Manager (the "ACM"), a software platform maintained by Assent that enables its users to complete and track supplier communications as well as allows suppliers to upload completed CMRTs directly to the platform for assessment and management.

Assent requested that all suppliers complete a CMRT and provided training resources to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. We directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested such suppliers complete the CMRT form and submit such form to Assent. Assent's program also includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. Suppliers with invalid CMRTs were contacted and asked to resubmit after correcting the errors. As of May 13, 2021, there were 8 invalid and 1 incomplete supplier submissions that could not be corrected.

Based on the RCOI, we have reason to believe that some of the 3TG Minerals in our products may have originated from the Covered Countries or may have come from recycled or scrap sources, therefore, in accordance with Rule 13p-1, we performed further due diligence on the source and chain of custody of the 3TG Minerals in question.

3. Due Diligence Process

We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence 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 ("OECD Guidance"), and the related supplements for each of the 3TG Minerals.

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 the implementation of 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 further 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.

We integrated the five steps recommended by the OECD Guidance as follows:
 
Step 1: Establish Strong Company Management Systems

Internal Team. We maintained an internal team, led by our procurement group, to manage our conflict minerals compliance program and related engagement with our suppliers. This includes integrating new suppliers, working with our employees to provide training and guidance, implementing reporting systems and facilitating cross-departmental communications to ensure compliance with the SEC’s reporting requirements regarding conflict minerals.

Controls and Policies. As stated above, we have a Conflict Minerals Policy, which is available on our website (welbilt.com) under Investor Relations - Corporate Governance - Governance Documents. In addition, our standard supplier terms and conditions address our expectations related to any 3TG Minerals supplied to us. Our controls also include our Code of Conduct and our Supplier Code of Conduct, which outline expected behaviors for our employees and suppliers.

Grievance Mechanisms. We maintain a hotline that provides employees with a mechanism to report violations or concerns related to our policies, including our Conflict Minerals Policy, Code of Conduct and our Supplier Code of Conduct. Such reporting may be made on an anonymous basis if employees wish.

Supplier Engagement. With respect to the OECD requirement to strengthen engagement with suppliers, we engaged Assent to assist with supplier engagement, evaluating supply chain information regarding 3TG Minerals and to assist with the development and implementation of additional due diligence steps. We also use Assent’s online learning management system and have provided all in-scope suppliers access to Assent's Conflict Minerals training course.

Step 2: Identify and Assess Risks in Our Supply Chain

In accordance with OECD Guidance, it is important to identify and assess risks associated with 3TG Minerals in the supply chain. Certain risks are identified automatically in the ACM system based on pre-established criteria. These risks are addressed by Assent's compliance staff and members of our internal conflict minerals compliance team who contacted the supplier to gather pertinent data and perform an assessment.

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Many of the responses provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG Minerals in the components supplied to us. Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.

Risks were 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. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the Responsible Minerals Initiative ("RMI") to ensure that the facilities met the RMI definition of a 3TG Minerals processing facility that was operational during the 2020 calendar year.

In order to assess the risk that any of these smelters posed to our supply chain, Assent considered whether the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process ("RMAP"). 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 do not typically have a direct relationship with 3TG Minerals smelters and refiners and do not perform or direct audits of these entities within our supply chain.

Each facility that meets the RMI definition of a smelter or refiner of a 3TG Mineral is assessed according to red flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

•Geographic proximity to the Covered Countries;
•Known mineral source country of origin;
•Responsible Minerals Assurance Process audit status;
•Credible evidence of unethical or conflict sourcing;
•Peer assessments conducted by credible third-party sources.

Consistent with of our risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent, submissions that include any red flag facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product-specific CMRT to better identify the connection to products that they supply to us, and escalating up to removal of these red flag smelters from their supply chain.

As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable time frames with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to Assent's online learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Guidance and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:

1.Do you have a conflict minerals sourcing policy in place?
2.Have you implemented due diligence measures for conflict-free sourcing?
3.Do you review due diligence information received from your suppliers against your company’s expectations?
4.Does your review process include corrective action management?

Suppliers who respond affirmatively to each of the above questions are deemed to have a strong program in place. If they do not meet this criteria, they are identified as having a weak program, and follow-up emails are sent in order to provide them guidance on how to improve their program going forward.

Step 3: Design and Implement a Strategy to Respond to Identified Risks
 
We completed a management reporting dashboard on a periodic basis summarizing the results of the risk assessment process. Other elements of our due diligence process designed to respond to identified risks included the following:

•Suppliers that did not respond to our initial survey request were sent escalation communications requesting that they provide the information requested.
•Suppliers who provided incomplete or inconsistent responses were sent follow-up communications asking for clarification. Based on the type of red flag identified during a review of supplier responses, suppliers were sent a corrective action communication.

Step 4: Utilize Third-Party Audits of Supply Chain Due Diligence

We do not have a direct relationship with 3TG Minerals smelters or refiners, and we do not perform or direct audits of these entities within our supply chain. We rely on third-party audits of smelters and refiners conducted as part of the RMAP, 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.

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Step 5: Report Annually on Supply Chain Due Diligence

We report annually on our conflict minerals due diligence program by filing a Form SD and a Conflict Minerals Report with the SEC. Our Form SD and this Report can be found on our website at: ir.welbilt.com/investor-relations/financial-information/sec-filings/default.aspx

4.  Due Diligence Results
   
For the 2020 reporting year, we received completed CMRTs from approximately 71% of the 446 in-scope suppliers surveyed, which includes 3% of our in-scope suppliers that were unable to correct their CMRT and are deemed invalid submissions.

Appendix A to this Report lists the legitimate smelters and refiners that our in-scope suppliers reported as being in used their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix A also includes an aggregated list of the potential countries of origin from which the reported facilities may collectively source 3TG Minerals, based on information provided by our suppliers and RMI.

The majority of the responses we received from our suppliers were made on a company or division level, rather than on a product-level basis. Accordingly, the smelters or refiners identified by our suppliers in Appendix A may include smelters or refiners that processed 3TG Minerals supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the smelters or refiners included in Appendix A were used to process the 3TG Minerals necessary to the functionality or production of Welbilt products during 2020. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed in Appendix A was a country of origin of 3TG Minerals used in our products during 2020 and therefore unable to conclusively determine the source and chain of custody of those 3TG Minerals.

In addition, the third-party audits conducted by the RMI, and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete 3TG Minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMAP and, as a result, are not responsible for the quality of these audits or the audit findings.

5. Risk Mitigation and Continuous Improvement Efforts

In addition to the commitments set forth in our Conflict Minerals Policy, we intend to take the following steps to improve our conflict minerals program and further mitigate the risk that our products contain 3TG Minerals from sources that support conflict in the Covered Countries:

•Engage with suppliers to provide better resources for responsible sourcing of 3TG Minerals and implementing improved due diligence procedures for their supply chains;
•Collaborate with Assent to improve supplier survey response rates and implement stronger supplier education practices;
•Improve training programs to educate Welbilt employees who may be in direct contact with suppliers or other third parties regarding the Company’s conflict minerals compliance efforts; and
•Attempt to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TG Minerals contained in our products.

Appendix A

Metal	Facility Name	Smelter ID	
Gold	8853 S.p.A.	CID002763	
Gold	Abington Reldan Metals, LLC	CID002708	
Gold	Advanced Chemical Company	CID000015	
Gold	African Gold Refinery	CID003185	
Gold	Aida Chemical Industries Co., Ltd.	CID000019	
Gold	Al Etihad Gold Refinery DMCC	CID002560	
Gold	Alexy Metals	CID003500	
Gold	Allgemeine Gold-und Silberscheideanstalt A.G.	CID000035	
Gold	Almalyk Mining and Metallurgical Complex (AMMC)	CID000041	
Gold	AngloGold Ashanti Corrego do Sitio Mineracao	CID000058	
Gold	Argor-Heraeus S.A.	CID000077	
Gold	Asahi Pretec Corp.	CID000082	
Gold	Asahi Refining Canada Ltd.	CID000924	
4

									
Gold	Asahi Refining USA Inc.	CID000920	
Gold	Asaka Riken Co., Ltd.	CID000090	
Gold	Atasay Kuyumculuk Sanayi Ve Ticaret A.S.	CID000103	
Gold	AU Traders and Refiners	CID002850	
Gold	Augmont Enterprises Private Limited	CID003461	
Gold	Aurubis AG	CID000113	
Gold	Bangalore Refinery	CID002863	
Gold	Bangko Sentral ng Pilipinas (Central Bank of the Philippines)	CID000128	
Gold	Boliden AB	CID000157	
Gold	C. Hafner GmbH + Co. KG	CID000176	
Gold	C.I Metales Procesados Industriales SAS	CID003421	
Gold	Caridad	CID000180	
Gold	CCR Refinery - Glencore Canada Corporation	CID000185	
Gold	Cendres + Metaux S.A.	CID000189	
Gold	CGR Metalloys Pvt Ltd.	CID003382	
Gold	Chimet S.p.A.	CID000233	
Gold	Chugai Mining	CID000264	
Gold	Daye Non-Ferrous Metals Mining Ltd.	CID000343	
Gold	Degussa Sonne / Mond Goldhandel GmbH	CID002867	
Gold	Dijllah Gold Refinery FZC	CID003348	
Gold	DODUCO Contacts and Refining GmbH	CID000362	
Gold	Dowa	CID000401	
Gold	DS PRETECH Co., Ltd.	CID003195	
Gold	DSC (Do Sung Corporation)	CID000359	
Gold	Eco-System Recycling Co., Ltd. East Plant	CID000425	
Gold	Eco-System Recycling Co., Ltd. North Plant	CID003424	
Gold	Eco-System Recycling Co., Ltd. West Plant	CID003425	
Gold	Emerald Jewel Industry India Limited (Unit 1)	CID003487	
Gold	Emerald Jewel Industry India Limited (Unit 2)	CID003488	
Gold	Emerald Jewel Industry India Limited (Unit 3)	CID003489	
Gold	Emerald Jewel Industry India Limited (Unit 4)	CID003490	
Gold	Emirates Gold DMCC	CID002561	
Gold	Fidelity Printers and Refiners Ltd.	CID002515	
Gold	Fujairah Gold FZC	CID002584	
Gold	GCC Gujrat Gold Centre Pvt. Ltd.	CID002852	
Gold	Geib Refining Corporation	CID002459	
Gold	Gold Coast Refinery	CID003186	
Gold	Gold Refinery of Zijin Mining Group Co., Ltd.	CID002243	
Gold	Great Wall Precious Metals Co., Ltd. of CBPM	CID001909	
Gold	Guangdong Jinding Gold Limited	CID002312	
Gold	Guoda Safina High-Tech Environmental Refinery Co., Ltd.	CID000651	
Gold	Hangzhou Fuchunjiang Smelting Co., Ltd.	CID000671	
Gold	Heimerle + Meule GmbH	CID000694	
Gold	Heraeus Metals Hong Kong Ltd.	CID000707	
Gold	Heraeus Precious Metals GmbH & Co. KG	CID000711	
Gold	Hunan Chenzhou Mining Co., Ltd.	CID000767	
Gold	Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.	CID000773	
5

									
Gold	HwaSeong CJ CO., LTD.	CID000778	
Gold	Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.	CID000801	
Gold	International Precious Metal Refiners	CID002562	
Gold	Ishifuku Metal Industry Co., Ltd.	CID000807	
Gold	Istanbul Gold Refinery	CID000814	
Gold	Italpreziosi	CID002765	
Gold	JALAN & Company	CID002893	
Gold	Japan Mint	CID000823	
Gold	Jiangxi Copper Co., Ltd.	CID000855	
Gold	JSC Ekaterinburg Non-Ferrous Metal Processing Plant	CID000927	
Gold	JSC Uralelectromed	CID000929	
Gold	JX Nippon Mining & Metals Co., Ltd.	CID000937	
Gold	K.A. Rasmussen	CID003497	
Gold	Kaloti Precious Metals	CID002563	
Gold	Kazakhmys Smelting LLC	CID000956	
Gold	Kazzinc	CID000957	
Gold	Kennecott Utah Copper LLC	CID000969	
Gold	KGHM Polska Miedz Spolka Akcyjna	CID002511	
Gold	Kojima Chemicals Co., Ltd.	CID000981	
Gold	Korea Zinc Co., Ltd.	CID002605	
Gold	Kundan Care Products Ltd.	CID003463	
Gold	Kyrgyzaltyn JSC	CID001029	
Gold	Kyshtym Copper-Electrolytic Plant ZAO	CID002865	
Gold	L'azurde Company For Jewelry	CID001032	
Gold	Lingbao Gold Co., Ltd.	CID001056	
Gold	Lingbao Jinyuan Tonghui Refinery Co., Ltd.	CID001058	
Gold	L'Orfebre S.A.	CID002762	
Gold	LS-NIKKO Copper Inc.	CID001078	
Gold	LT Metal Ltd.	CID000689	
Gold	Luoyang Zijin Yinhui Gold Refinery Co., Ltd.	CID001093	
Gold	Marsam Metals	CID002606	
Gold	Materion	CID001113	
Gold	Matsuda Sangyo Co., Ltd.	CID001119	
Gold	MD Overseas	CID003548	
Gold	Metal Concentrators SA (Pty) Ltd.	CID003575	
Gold	Metallix Refining Inc.	CID003557	
Gold	Metalor Technologies (Hong Kong) Ltd.	CID001149	
Gold	Metalor Technologies (Singapore) Pte., Ltd.	CID001152	
Gold	Metalor Technologies (Suzhou) Ltd.	CID001147	
Gold	Metalor Technologies S.A.	CID001153	
Gold	Metalor USA Refining Corporation	CID001157	
Gold	Metalurgica Met-Mex Penoles S.A. De C.V.	CID001161	
Gold	Mitsubishi Materials Corporation	CID001188	
Gold	Mitsui Mining and Smelting Co., Ltd.	CID001193	
Gold	MMTC-PAMP India Pvt., Ltd.	CID002509	
Gold	Modeltech Sdn Bhd	CID002857	
Gold	Morris and Watson	CID002282	
6

									
Gold	Moscow Special Alloys Processing Plant	CID001204	
Gold	Nadir Metal Rafineri San. Ve Tic. A.S.	CID001220	
Gold	Navoi Mining and Metallurgical Combinat	CID001236	
Gold	NH Recytech Company	CID003189	
Gold	Nihon Material Co., Ltd.	CID001259	
Gold	Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH	CID002779	
Gold	Ohura Precious Metal Industry Co., Ltd.	CID001325	
Gold	OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)	CID001326	
Gold	OJSC Novosibirsk Refinery	CID000493	
Gold	PAMP S.A.	CID001352	
Gold	Pease & Curren	CID002872	
Gold	Penglai Penggang Gold Industry Co., Ltd.	CID001362	
Gold	Planta Recuperadora de Metales SpA	CID002919	
Gold	Prioksky Plant of Non-Ferrous Metals	CID001386	
Gold	PT Aneka Tambang (Persero) Tbk	CID001397	
Gold	PX Precinox S.A.	CID001498	
Gold	QG Refining, LLC	CID003324	
Gold	Rand Refinery (Pty) Ltd.	CID001512	
Gold	Refinery of Seemine Gold Co., Ltd.	CID000522	
Gold	REMONDIS PMR B.V.	CID002582	
Gold	Royal Canadian Mint	CID001534	
Gold	SAAMP	CID002761	
Gold	Sabin Metal Corp.	CID001546	
Gold	Safimet S.p.A	CID002973	
Gold	SAFINA A.S.	CID002290	
Gold	Sai Refinery	CID002853	
Gold	Samduck Precious Metals	CID001555	
Gold	Samwon Metals Corp.	CID001562	
Gold	Sancus ZFS (L’Orfebre, SA)	CID003529	
Gold	SAXONIA Edelmetalle GmbH	CID002777	
Gold	Sellem Industries Ltd.	CID003540	
Gold	SEMPSA Joyeria Plateria S.A.	CID001585	
Gold	Shandong Humon Smelting Co., Ltd.	CID002525	
Gold	Shandong Tiancheng Biological Gold Industrial Co., Ltd.	CID001619	
Gold	Shandong Zhaojin Gold & Silver Refinery Co., Ltd.	CID001622	
Gold	Shenzhen Zhonghenglong Real Industry Co., Ltd.	CID002527	
Gold	Shirpur Gold Refinery Ltd.	CID002588	
Gold	Sichuan Tianze Precious Metals Co., Ltd.	CID001736	
Gold	Singway Technology Co., Ltd.	CID002516	
Gold	Smelter Not Listed	CID001810	
Gold	SOE Shyolkovsky Factory of Secondary Precious Metals	CID001756	
Gold	Solar Applied Materials Technology Corp.	CID001761	
Gold	Sovereign Metals	CID003383	
Gold	State Research Institute Center for Physical Sciences and Technology	CID003153	
Gold	Sudan Gold Refinery	CID002567	
Gold	Sumitomo Metal Mining Co., Ltd.	CID001798	
Gold	SungEel HiMetal Co., Ltd.	CID002918	
7

									
Gold	T.C.A S.p.A	CID002580	
Gold	Tanaka Kikinzoku Kogyo K.K.	CID001875	
Gold	The Refinery of Shandong Gold Mining Co., Ltd.	CID001916	
Gold	Tokuriki Honten Co., Ltd.	CID001938	
Gold	Tongling Nonferrous Metals Group Co., Ltd.	CID001947	
Gold	Tony Goetz NV	CID002587	
Gold	TOO Tau-Ken-Altyn	CID002615	
Gold	Torecom	CID001955	
Gold	Umicore Precious Metals Thailand	CID002314	
Gold	Umicore S.A. Business Unit Precious Metals Refining	CID001980	
Gold	United Precious Metal Refining, Inc.	CID001993	
Gold	Valcambi S.A.	CID002003	
Gold	Western Australian Mint (T/a The Perth Mint)	CID002030	
Gold	WIELAND Edelmetalle GmbH	CID002778	
Gold	Yamakin Co., Ltd.	CID002100	
Gold	Yokohama Metal Co., Ltd.	CID002129	
Gold	Yunnan Copper Industry Co., Ltd.	CID000197	
Gold	Zhongyuan Gold Smelter of Zhongjin Gold Corporation	CID002224	
Tantalum	Asaka Riken Co., Ltd.	CID000092	
Tantalum	Changsha South Tantalum Niobium Co., Ltd.	CID000211	
Tantalum	D Block Metals, LLC	CID002504	
Tantalum	Exotech Inc.	CID000456	
Tantalum	F&X Electro-Materials Ltd.	CID000460	
Tantalum	FIR Metals & Resource Ltd.	CID002505	
Tantalum	Global Advanced Metals Aizu	CID002558	
Tantalum	Global Advanced Metals Boyertown	CID002557	
Tantalum	Guangdong Zhiyuan New Material Co., Ltd.	CID000616	
Tantalum	H.C. Starck Co., Ltd.	CID002544	
Tantalum	H.C. Starck Hermsdorf GmbH	CID002547	
Tantalum	H.C. Starck Inc.	CID002548	
Tantalum	H.C. Starck Ltd.	CID002549	
Tantalum	H.C. Starck Smelting GmbH & Co. KG	CID002550	
Tantalum	H.C. Starck Tantalum and Niobium GmbH	CID002545	
Tantalum	Hengyang King Xing Lifeng New Materials Co., Ltd.	CID002492	
Tantalum	Jiangxi Dinghai Tantalum & Niobium Co., Ltd.	CID002512	
Tantalum	Jiangxi Tuohong New Raw Material	CID002842	
Tantalum	JiuJiang JinXin Nonferrous Metals Co., Ltd.	CID000914	
Tantalum	Jiujiang Tanbre Co., Ltd.	CID000917	
Tantalum	Jiujiang Zhongao Tantalum & Niobium Co., Ltd.	CID002506	
Tantalum	KEMET Blue Metals	CID002539	
Tantalum	LSM Brasil S.A.	CID001076	
Tantalum	Metallurgical Products India Pvt., Ltd.	CID001163	
Tantalum	Mineracao Taboca S.A.	CID001175	
Tantalum	Mitsui Mining and Smelting Co., Ltd.	CID001192	
Tantalum	Ningxia Orient Tantalum Industry Co., Ltd.	CID001277	
Tantalum	NPM Silmet AS	CID001200	
Tantalum	Power Resources Ltd.	CID002847	
8

									
Tantalum	QuantumClean	CID001508	
Tantalum	Resind Industria e Comercio Ltda.	CID002707	
Tantalum	Solikamsk Magnesium Works OAO	CID001769	
Tantalum	Taki Chemical Co., Ltd.	CID001869	
Tantalum	Telex Metals	CID001891	
Tantalum	Ulba Metallurgical Plant JSC	CID001969	
Tantalum	XinXing HaoRong Electronic Material Co., Ltd.	CID002508	
Tantalum	Yanling Jincheng Tantalum & Niobium Co., Ltd.	CID001522	
Tin	Alpha	CID000292	
Tin	An Vinh Joint Stock Mineral Processing Company	CID002703	
Tin	Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.	CID000228	
Tin	Chifeng Dajingzi Tin Industry Co., Ltd.	CID003190	
Tin	China Tin Group Co., Ltd.	CID001070	
Tin	CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda	CID003486	
Tin	CRM Synergies	CID003524	
Tin	CV Ayi Jaya	CID002570	
Tin	CV Venus Inti Perkasa	CID002455	
Tin	Dongguan CiEXPO Environmental Engineering Co., Ltd.	CID003356	
Tin	Dowa	CID000402	
Tin	Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company	CID002572	
Tin	EM Vinto	CID000438	
Tin	Estanho de Rondonia S.A.	CID000448	
Tin	Fenix Metals	CID000468	
Tin	Gejiu City Fuxiang Industry and Trade Co., Ltd.	CID003410	
Tin	Gejiu Fengming Metallurgy Chemical Plant	CID002848	
Tin	Gejiu Kai Meng Industry and Trade LLC	CID000942	
Tin	Gejiu Non-Ferrous Metal Processing Co., Ltd.	CID000538	
Tin	Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.	CID001908	
Tin	Gejiu Zili Mining And Metallurgy Co., Ltd.	CID000555	
Tin	Guangdong Hanhe Non-Ferrous Metal Co., Ltd.	CID003116	
Tin	HuiChang Hill Tin Industry Co., Ltd.	CID002844	
Tin	Jiangxi New Nanshan Technology Ltd.	CID001231	
Tin	Luna Smelter, Ltd.	CID003387	
Tin	Ma'anshan Weitai Tin Co., Ltd.	CID003379	
Tin	Magnu's Minerais Metais e Ligas Ltda.	CID002468	
Tin	Malaysia Smelting Corporation (MSC)	CID001105	
Tin	Melt Metais e Ligas S.A.	CID002500	
Tin	Metallic Resources, Inc.	CID001142	
Tin	Metallo Belgium N.V.	CID002773	
Tin	Metallo Spain S.L.U.	CID002774	
Tin	Mineracao Taboca S.A.	CID001173	
Tin	Minsur	CID001182	
Tin	Mitsubishi Materials Corporation	CID001191	
Tin	Modeltech Sdn Bhd	CID002858	
Tin	Nghe Tinh Non-Ferrous Metals Joint Stock Company	CID002573	
Tin	Novosibirsk Processing Plant Ltd.	CID001305	
Tin	O.M. Manufacturing (Thailand) Co., Ltd.	CID001314	
9

									
Tin	O.M. Manufacturing Philippines, Inc.	CID002517	
Tin	Operaciones Metalurgicas S.A.	CID001337	
Tin	Pongpipat Company Limited	CID003208	
Tin	Precious Minerals and Smelting Limited	CID003409	
Tin	PT Aries Kencana Sejahtera	CID000309	
Tin	PT Artha Cipta Langgeng	CID001399	
Tin	PT ATD Makmur Mandiri Jaya	CID002503	
Tin	PT Babel Surya Alam Lestari	CID001406	
Tin	PT Bangka Serumpun	CID003205	
Tin	PT Lautan Harmonis Sejahtera	CID002870	
Tin	PT Menara Cipta Mulia	CID002835	
Tin	PT Mitra Stania Prima	CID001453	
Tin	PT Mitra Sukses Globalindo	CID003449	
Tin	PT Prima Timah Utama	CID001458	
Tin	PT Rajawali Rimba Perkasa	CID003381	
Tin	PT Rajehan Ariq	CID002593	
Tin	PT Refined Bangka Tin	CID001460	
Tin	PT Stanindo Inti Perkasa	CID001468	
Tin	PT Timah Nusantara	CID001486	
Tin	PT Timah Tbk Kundur	CID001477	
Tin	PT Timah Tbk Mentok	CID001482	
Tin	PT Tinindo Inter Nusa	CID001490	
Tin	Resind Industria e Comercio Ltda.	CID002706	
Tin	Rui Da Hung	CID001539	
Tin	Smelter Not Listed	CID002816	
Tin	Smelter Not Listed	CID001402	
Tin	Smelter Not Listed	CID001428	
Tin	Smelter Not Listed	CID002696	
Tin	Soft Metais Ltda.	CID001758	
Tin	Super Ligas	CID002756	
Tin	Thai Nguyen Mining and Metallurgy Co., Ltd.	CID002834	
Tin	Thaisarco	CID001898	
Tin	Tin Technology & Refining	CID003325	
Tin	Tuyen Quang Non-Ferrous Metals Joint Stock Company	CID002574	
Tin	VQB Mineral and Trading Group JSC	CID002015	
Tin	White Solder Metalurgia e Mineracao Ltda.	CID002036	
Tin	Yunnan Chengfeng Non-ferrous Metals Co., Ltd.	CID002158	
Tin	Yunnan Tin Company Limited	CID002180	
Tin	Yunnan Yunfan Non-ferrous Metals Co., Ltd.	CID003397	
Tungsten	A.L.M.T. Corp.	CID000004	
Tungsten	ACL Metais Eireli	CID002833	
Tungsten	Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.	CID003427	
Tungsten	Artek LLC	CID003553	
Tungsten	Asia Tungsten Products Vietnam Ltd.	CID002502	
Tungsten	Chenzhou Diamond Tungsten Products Co., Ltd.	CID002513	
Tungsten	China Molybdenum Co., Ltd.	CID002641	
Tungsten	Chongyi Zhangyuan Tungsten Co., Ltd.	CID000258	
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Tungsten	CNMC (Guangxi) PGMA Co., Ltd.	CID000281	
Tungsten	Cronimet Brasil Ltda	CID003468	
Tungsten	Fujian Ganmin RareMetal Co., Ltd.	CID003401	
Tungsten	Ganzhou Haichuang Tungsten Co., Ltd.	CID002645	
Tungsten	Ganzhou Huaxing Tungsten Products Co., Ltd.	CID000875	
Tungsten	Ganzhou Jiangwu Ferrotungsten Co., Ltd.	CID002315	
Tungsten	Ganzhou Seadragon W & Mo Co., Ltd.	CID002494	
Tungsten	GEM Co., Ltd.	CID003417	
Tungsten	Global Tungsten & Powders Corp.	CID000568	
Tungsten	Guangdong Xianglu Tungsten Co., Ltd.	CID000218	
Tungsten	H.C. Starck Smelting GmbH & Co. KG	CID002542	
Tungsten	H.C. Starck Tungsten GmbH	CID002541	
Tungsten	Hunan Chenzhou Mining Co., Ltd.	CID000766	
Tungsten	Hunan Chunchang Nonferrous Metals Co., Ltd.	CID000769	
Tungsten	Hydrometallurg, JSC	CID002649	
Tungsten	Japan New Metals Co., Ltd.	CID000825	
Tungsten	Jiangwu H.C. Starck Tungsten Products Co., Ltd.	CID002551	
Tungsten	Jiangxi Gan Bei Tungsten Co., Ltd.	CID002321	
Tungsten	Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.	CID002313	
Tungsten	Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.	CID002318	
Tungsten	Jiangxi Xinsheng Tungsten Industry Co., Ltd.	CID002317	
Tungsten	Jiangxi Yaosheng Tungsten Co., Ltd.	CID002316	
Tungsten	JSC "Kirovgrad Hard Alloys Plant"	CID003408	
Tungsten	Kennametal Fallon	CID000966	
Tungsten	Kennametal Huntsville	CID000105	
Tungsten	KGETS Co., Ltd.	CID003388	
Tungsten	Lianyou Metals Co., Ltd.	CID003407	
Tungsten	Malipo Haiyu Tungsten Co., Ltd.	CID002319	
Tungsten	Masan Tungsten Chemical LLC (MTC)	CID002543	
Tungsten	Moliren Ltd.	CID002845	
Tungsten	Niagara Refining LLC	CID002589	
Tungsten	NPP Tyazhmetprom LLC	CID003416	
Tungsten	Philippine Chuangxin Industrial Co., Inc.	CID002827	
Tungsten	Unecha Refractory metals plant	CID002724	
Tungsten	Wolfram Bergbau und Hutten AG	CID002044	
Tungsten	Xiamen Tungsten (H.C.) Co., Ltd.	CID002320	
Tungsten	Xiamen Tungsten Co., Ltd.	CID002082	
Tungsten	Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.	CID002830	

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Potential Countries of Origin: 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, Sudan, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Vietnam, Zambia, and Zimbabwe. 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 listing is based on public information and company level responses as further described in the Report, and therefore, it is not certain which of these countries of origin can be linked to our products.

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