Donaldson Co. Inc.

05/28/2026 | Press release | Distributed by Public on 05/28/2026 09:04

Specialized Disclosure Report (Form SD)



Conflict Minerals Report of Donaldson Company, Inc.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934

1. Introduction and Summary

This report for the year ended December 31, 2025 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements pursuant to Section 13(p) of the Securities and Exchange Act of 1934 (Section 13(p)). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. The term "conflict minerals" is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (Conflict Minerals); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (DRC) or any adjoining country that shares an internationally recognized border with the DRC (collectively referred to as the Covered Countries). These requirements apply to registrants regardless of the geographic origin of the Conflict Minerals or whether they fund armed conflict.

Donaldson Company, Inc. (Donaldson or the Company) determined Conflict Minerals were necessary to the functionality or production of products we manufactured or contracted to be manufactured during the 2025 calendar year. Therefore, Donaldson conducted a reasonable country of origin inquiry (RCOI) in good faith to determine whether any of the Conflict Minerals in its products originated in the Covered Countries. Based on its RCOI, Donaldson has concluded that it cannot exclude the possibility that its products contain Conflict Minerals that originated in the Covered Countries and, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the Conflict Minerals in question to determine whether its products are "DRC Conflict Free". Donaldson designed its due diligence measures to conform, in all material respects, with the nationally recognized due diligence framework in The Organization for Economic Co-Operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, second edition and the related Supplements for gold and for tin, tantalum and tungsten (the OECD Guidance). As a result of our due diligence efforts, the Company has concluded some of the Conflict Minerals for the Company's products originated in, or may have originated in, the Covered Countries and were not from recycled or scrap sources. The Company did not receive responses from all companies in its supply chain and most of the responses were at the company or division level.

2. Company Overview

Founded in 1915, Donaldson is a global leader in the filtration industry with sales, manufacturing, and distribution locations around the world. Donaldson's innovative technologies are designed to solve complex filtration challenges and enhance customers' equipment.

3. Product Description

The Company's reportable segments are Mobile Solutions, Industrial Solutions and Life Sciences.

The Mobile Solutions segment is organized based on a combination of customers and products and consists of the Off-Road, On-Road and Aftermarket business units. Within these business units, products consist of replacement filters for both air and liquid filtration applications as well as exhaust and emissions. Applications include air filtration systems, fuel and lube systems, exhaust and emissions systems, and sensors, indicators and monitoring systems. Mobile Solutions sells to OEMs in the construction, mining, agriculture and transportation end markets and to independent distributors and OEM dealer networks.



The Industrial Solutions segment is organized based on product type and consists of Industrial Air Filtration, Industrial Gasses, Industrial Hydraulics, Power Generation and Aerospace and Defense products. These products are further organized by the Industrial Filtration Solutions and Aerospace and Defense business units. Within our industrial portfolio, Donaldson provides the widest product offering in the market to industrial customers consisting of equipment, ancillary components, replacement parts, performance monitoring and service globally, that cost-effectively enhances productivity and manufacturing efficiency. Industrial Air Filtration, Industrial Gasses and Industrial Hydraulics products consist of dust, fume and mist collectors, compressed air and industrial gasses purification systems, hydraulic and lubricated rotating filtration applications as well as gas and liquid filtration for industrial processes. Power Generation products consist of air inlet systems and filtration sold to gas compression, power generation and natural gas liquification industries. Aerospace and Defense products consist of air, fuel, lubrication and hydraulic filtration for fixed-wing and rotorcraft aerospace applications and ground defense vehicle and naval platforms. Industrial Solutions businesses sell through multiple channels which include OEMs, distributors and direct-to-consumer in some markets.

The Life Sciences segment is organized by end market and consists of the Bioprocessing Equipment and Consumables, Food and Beverage, Vehicle Electrification and Medical Device, Microelectronics and Disk Drive markets. Within these markets, products consist of micro-environment gas and liquid filtration for food and beverage and industrial processes, bioprocessing equipment, including bioreactors and fermenters, bioprocessing consumables including chromatography devices, reagents and filters, polytetrafluoroethylene membrane-based products, as well as specialized air and gas filtration systems for applications including hard disk drives, semiconductor manufacturing, sensors, battery systems and powertrain components. Life Sciences primarily sells to large OEMs and directly to various end users requiring cell growth, separation, purification, high purity filtration and device protection.

The Company manufactures and contracts to manufacture products containing certain minerals and their derivatives, generally described as tantalum, tin, tungsten, and gold (Conflict Minerals). Conflict Minerals were identified in products from all of the Company's reporting segments, Mobile Solutions, Industrial Solutions and Life Sciences.

The Company has adopted a Conflict Minerals Policy articulating our conflict minerals supply chain due diligence process and our commitment to our reporting obligations regarding conflict minerals:

Conflict Minerals Program & Policy

The ongoing conflict in the Democratic Republic of the Congo (DRC) is fueled in part by the trade of "conflict minerals," which are defined as tantalum, tin, tungsten, and gold or any of their derivatives. Donaldson will work with our supply chain partners to take reasonable steps to ensure Conflict Minerals are not sourced by Donaldson or our supply chain partners in a way that would directly or indirectly benefit armed groups responsible for serious human rights abuses in the DRC or adjoining countries. Donaldson expects that our suppliers will comply with our requests to provide statements and perform due diligence about the source of any Conflict Minerals in their products that are provided to us.

The Conflict Minerals policy is posted on the Company's website:
https://www.donaldson.com/en-us/conflict-minerals-policy/

4. Reasonable Country of Origin Inquiry

The Company developed a supply chain transparency program utilizing internal resources and a third-party vendor, Assent Inc. ("Assent"), to allow for the identification of each Smelter or Refiner (SOR) in the suppliers' mineral supply chains.

Suppliers received an email via the third-party vendor system Assent Sustainability Manager ("ASM"), a software-as-a-service (SaaS) platform provided by Assent that enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. Suppliers were requested to provide such SOR information through the Responsible Business Alliance - RBA and Global e-Sustainability Initiative (GeSI) Conflict Minerals Reporting Template (CMRT), version 6.5 or higher.

An escalation process was initiated for suppliers who continued to be non-responsive after the above contacts were made. This process included direct emails to the non-responsive suppliers.

The Company's program continues to include 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. This data validation is based on questions within the declaration tab of the CMRT, which helps identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of Tier 1 suppliers. The results of this data validation contribute to the program's health assessment and are shared with the suppliers to ensure they address items such as the following:

•Incomplete data including missing SORs
•Responses that indicated a sourcing location without complete supporting information or
•Failure to meet acceptance criteria.



Certain of the responses provided by suppliers on the CMRT included the names of facilities listed by the suppliers as SORs. Donaldson Company, Inc. does not typically have a direct relationship with Conflict Minerals SORs and does not perform or direct audits of these entities within our supply chain. The Company's third-party vendor Assent Inc. compared the facilities listed in the responses to the list of smelters maintained by the Responsible Minerals Initiative (RMI). If a supplier indicated the facility was certified as "Conflict-Free," the third-party vendor confirmed the name was listed by RMI. Organizations that were identified by suppliers as SORs, but were invalid or undetermined, were contacted directly to clarify their status as an SOR.

All submitted declaration forms are accepted so that data is retained, but they are classified as valid or invalid based on a set criteria of validation errors (see Appendix C for CMRT validation criteria). Suppliers are contacted regarding invalid forms and are encouraged to correct validated errors to resubmit a valid form. Suppliers are provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses, and direct engagement help through Assent's multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, Donaldson tracks program gaps to account for future improvement opportunities.

5. Due Diligence

The Company's due diligence process is based on the OECD's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, second edition and accompanying Supplements. It is important to note the OECD Guidance was written for both upstream and downstream companies in the supply chain. Upstream companies refer to those between the mines and SORs. As such, the companies typically include mine operators, local traders, or exporters from the country of mineral origin, international concentrate traders, and SORs. Downstream companies refer to those entities between the SOR and the retailer. As such, the companies typically include metal traders and exchanges, component manufacturers, product manufacturers, OEMs, and retailers. As the Company is a downstream company in the supply chain, its due diligence practices were tailored accordingly.

A summary of the due diligence measures undertaken by the Company is below:

I) Establish Strong Company Management Systems:

Internal Compliance Team

The Company's management systems for Conflict Minerals covering the 2025 calendar year were sponsored by a Steering Committee whose members included the Chief Financial Officer, Chief Legal Officer and Corporate Secretary, President Mobile Solutions, President Industrial Solutions, President Life Sciences, President Enterprise Operations and Supply Chain, Chief Technology Officer. Steering Committee members provide reports directly to the Audit Committee of the Board of Directors. The Steering Committee was supported by a Process Development Team consisting of subject matter experts from relevant functions such as Legal, Materials Compliance, Procurement, Sales, Engineering, and Internal Audit.

Conflict Minerals Policy
The Company's Conflict Minerals policy is publicly available at:
https://www.donaldson.com/en-us/conflict-minerals-policy/

Control Systems

Donaldson Company Inc. expects all suppliers to have policies and procedures in place to ensure that they conduct due diligence on the source and chain of custody of the 3TGs used in the production of the products sold to the company. Since we do not typically have a direct relationship with Conflict Minerals SORs, we are engaged and actively cooperate with other major manufacturers in our business sector and other sectors, through our own efforts and those organized by trade associations. We also participate in or actively monitor the following industry-wide initiatives to disclose upstream parties in the supply chain: Member of the Responsible Business Alliance - RBA-GeSI RMI as well as other manufacturing industry consortiums including the National Association of Manufacturers, and the Manufacturers Alliance for Productivity and Innovation.

Supplier Engagement

Donaldson Company, Inc. has a strong relationship with Tier 1 direct suppliers. As an extremely important part of the supply chain, Donaldson Company, Inc. has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support, and other multilingual resources. Donaldson Company's suppliers are able to leverage Assent's team of supplier support specialists to ensure they receive appropriate support and understand how to properly fill a CMRT. Suppliers are provided guidance in their native language if needed.



With respect to the OECD requirement to strengthen engagement with suppliers to request a valid (free of validated errors) CMRT for the products that they supply to the Company, we have utilized the CMRT version 6.5 or higher and Assent's web-based reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests. We continue to observe a need to follow up with suppliers to educate them on the Rule, Donaldson's Conflict Minerals policy, and our expectations for their supply chain due diligence and reporting.

We have developed an internal procedure that includes a supplier risk identification process that then leads to further steps of supplier engagement in the form of escalations, such as in-person meetings and/or corrective actions. Feedback from this engagement process has allowed the Company to oversee improvements in supplier responses and supplier compliance for this initiative. Additionally, the Company's Conflict Minerals Policy is included in supplier contracts, requiring new suppliers to read and accept the policy as a requirement of doing business with Donaldson Company, Inc.

The Company continues to place a strong emphasis on supplier education and training. To accomplish this, our third-party provider Assent's online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and 1:1 support resources. Donaldson Company, Inc. believes that the combination of the Supplier Code of Conduct, Conflict Minerals Policy, and direct engagement with suppliers for conflict minerals training and support constitute a strong supplier engagement program.

Grievance Mechanism

The Company continues to maintain multiple, third-party hosted, longstanding grievance mechanisms whereby employees and suppliers can report violations of Donaldson Company's policies, including conflict minerals. Suppliers and others outside of Donaldson Company, Inc. may contact the Conflict Minerals Team, including to report grievances, via a dedicated email address that is published in the Conflict Minerals Policy and in other communications with suppliers. In addition, employees may anonymously report suspected violations using this process. Any violations are reported to the Corporate Compliance Committee.

Violations or grievances at the industry level can be reported to the RMI directly as well. This can be done at https://secure.ethicspoint.com/domain/media/en/gui/19744/index.html

Maintain Records

Donaldson maintains a policy that documentation related to our Conflict Minerals compliance process will be retained for a period of at least five years. Through Assent, a document retention policy to retain conflict minerals-related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented and stores all of the information and findings from this process in a database that can be audited by internal or external parties.

II) Identifying and Assess Risks in the Supply Chain:

Risks associated with Tier 1 suppliers' due diligence processes were assessed by their declaration responses on a CMRT, which the Assent Sustainability Manager identifies automatically based on established criteria. These risks are addressed by Assent staff and members of the Company's internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier's conformity status, which is referred to as "conflict minerals status."

Supplier Risk Evaluation

Risks associated with Tier 1 suppliers' due diligence processes were assessed by their declaration responses on a CMRT, which the Assent Compliance Manager identifies automatically based on established criteria. These risks are addressed by Assent staff and members of the Company's internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier's conformity status, which is referred to as "conflict minerals status."

Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, the Company is unable to determine if all of the specified smelters/refiners were used for 3TGs in the products supplied to the Company.

Assent's supplier risk assessment (flagging suppliers' risk as high, medium, or low) identifies problematic suppliers in a company's supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis that takes into account multiple conflict minerals factors.

Smelter Risk Evaluation

The SORs and countries of origin listed by suppliers were matched against a database of verified SORs and associated mines. Verified SORs were matched against available lists of processors that have been certified by RMI's internationally recognized industry validation scheme, the Responsible Minerals Assurance Process - RMAP.



If the SOR was not certified by the RMAP, research was conducted to gain more information about the SOR's sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes the SOR had taken to track the chain-of-custody on the source of its mineral ores.

Based on the smelter lists provided by suppliers via the CMRTs and the RMI-provided SOR sourcing information, the Company is aware that, in their supply chain, there are seventeen identified smelters sourcing from the Covered Countries that are certified conflict-free and a number of other smelters sourcing from other countries that are not disclosed at this time but are also certified conflict-free smelters. Many of the responses provided by suppliers are at the company or division level indicating they are still unable to provide SORs specific to the materials supplied to Donaldson.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. These risks are addressed by Assent staff and members of the Company's internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier's conformity status, which is referred to as "conflict minerals status." Smelters not being certified DRC-Conflict Free pose a risk to the supply chain. Each facility that meets the RMI definition of a SOR of a Conflict Mineral is assigned a risk of high, medium, or low based on five scoring criteria:

•Geographic proximity to the DRC and covered countries;
•known mineral source country of origin;
•RMAP audit status;
•credible evidence of unethical or conflict sourcing; and
•peer assessments conducted by credible third-party sources.
•Sanctions risks

Per these criteria the following facilities have been identified as being of the highest concern to the supply chain:

Metal
Smelter Name
Smelter Facility Location
Smelter ID
Tin Jiangxi New Nanshan Technology Ltd. China CID001231
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil CID003486
Tantalum Jiangxi Sanshi Nonferrous Metals Co., Ltd China CID004813
Tungsten Uzbek Refractory and Heat-Resistant Metals Uzbekistan CID002660
Gold SOLEIL METALS (Chala One Plant) Peru CID004704
Gold SOLEIL METALS (YAKARI Plant) Peru CID004705
Tin PT Artha Cipta Langgeng Indonesia CID001399
Tin Conecsus LLC United States Of America CID003504

When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our third-party vendor Assent, submissions that include any of the above facilities immediately receive a response instructing the supplier to take their own risk mitigation actions, including submission of product-specific CMRT to better identify the connection to products they supply to Donaldson.

Additionally, suppliers are evaluated on program strength, which further assists in identifying risk in the supply chain. At this stage in Conflict Minerals compliance it is well-known that many companies are in the middle of the process and do not have many answers beyond "unknown". It has been decided that penalizing or failing them for working through the process is likely not the best approach as it does not meet the goals or spirit of the Rule; however, evaluating and tracking the strength of the program does meet the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier's program are:
•Does the supplier have a policy in place that includes DRC conflict-free sourcing?
•Has the supplier implemented due diligence measures for conflict-free sourcing?
•Does the supplier verify due diligence information received from its suppliers?
•Does the supplier's verification process include corrective action management?

When a supplier meets these criteria, the supplier is deemed to have a strong program. When a supplier does not meet these criteria, the supplier is deemed to have a weaker program.

We calculate supplier risk based on the chances a supplier provides Conflict Minerals that may originate from non-conflict-free sources. The value of this risk is calculated based on the risk ratings of the SORs declared by that supplier on their CMRT.



As part of our risk management plan and to ensure suppliers understand our expectations, we have, through our third party, provided video and written training on Conflict Minerals and the CMRT. This training includes instructions on completing the form as well as Assent's staff and members of the Company's internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier's conformity status, which is referred to as "conflict minerals status."

III) Design and Implement a Strategy to Respond to Identified Risks:

The Company, in conjunction with Assent, identified, assessed and responded to risks in the supply chain. The status of this process is reported on a regular basis to the Company's senior management.

The Company worked with its third-party vendor Assent to help improve the quality of the information provided to the Company by its supply chain and to help strengthen its Conflict Minerals programs through education and direct support. Where SOR risks were identified the actions taken were consistent with the Company's Conflict Minerals policy. Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, the Company will assess if replacing that supplier is feasible.

As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier's specific context. Suppliers are given clear performance objectives within reasonable timeframes with the goal of progressive elimination of these risks from the supply chain. In addition, feedback on supplier submissions is given directly to suppliers who are guided to the educational tools available to engage in mitigating the risk of SORs on the supply chain.

IV) Carry Out Independent Third-Party Audit of Smelter/Refiners' Due Diligence Practices:

The Company does not have any direct relationship with SORs and does not perform or direct audits on SORs identified by our supply chain. Instead, Donaldson relies on third-party audits performed by an internationally recognized validation organization. Donaldson is a member of RMI and therefore has access to RMI's audit program. Through the Company's membership with the RMI, smelters/refiners have been encouraged to participate in the RMAP. Any smelters/refiners that were reported by suppliers who were not part of the RMAP were also contacted directly by Assent to encourage them to participate in the RMAP as stated earlier.

V) Report Annually on Supply Chain Due Diligence:

The Form Specialized Disclosure (Form SD) and CMR for the year ended December 31, 2025, are contained herein and are publicly available at: https://ir.donaldson.com/financials/sec-filings/default.aspx. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein.

The Company believes the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the Conflict Minerals in our Covered Products (the products purchased or manufactured by Donaldson where conflict minerals are necessary to the functionality or production of the product).

Due Diligence Results

Supply Chain Outreach results

Using the data collected by our suppliers via the CMRT, we have compiled all reported legitimate SORs in the attached Appendix A. These facilities were assessed for risk level and further due diligence was completed for any supplier identifying smelters of concern. Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source Conflict Minerals, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. Our goal is to continue to improve the responsiveness of our supply chain year over year and to mitigate the risk of suppliers sourcing from non-conformant facilities.

Supply chain outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten and gold. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. The following is the result of the outreach conducted by Donaldson for the 2025 reporting year.

Supply Chain Outreach Metrics

Year Number of in-scope suppliers Response rate
2025 988 68%
2024 1075 63%
2023 1081 63%
2022 1020 60%

Upstream Data Transparency



◦Appendix A includes all smelters/refiners that suppliers listed in completed CMRTs that met the recognized definition of a 3TGs processing facility and were operational during the 2025 calendar year. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which company's product lines the materials may end up in. As a result, those providing the smelters/refiners have the practice to list all smelters/refiners they may purchase from within the reporting period. Therefore, the smelters/refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters/refiners that processed the 3TGs contained in the Company's products.
◦Suppliers that identified these specific smelters of concern on their CMRT were contacted in accordance with the OECD Guidance, as stipulated in the previous sections.
Status Number of identified smelters/refiners
RMAP Conformant 207
RMAP Active 8
Not Enrolled 84
Non-Conformant 39

SORs

Attached as Appendix A is a list of the validated SORs as identified by the Company's supply chain in their submitted CMRTs that appear on the RMI list. Because most of the CMRTs we received from our suppliers were made on a company or division-level basis, rather than on a product-level basis, we are not able to identify which SORs listed on Appendix A actually processed the Conflict Minerals contained in our products. Therefore, our list of processing SORs disclosed in Appendix A may contain more facilities than those that actually processed the Conflict Minerals contained in our products.

However, the Assent Compliance Manager also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier's declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations, are managed through this platform.

Country of Origin

Through reasonable due diligence practices, Donaldson Company, Inc. was able to take advantage of a broader set of country-of-origin data to complement efforts in establishing transparency in the supply chain. Based on the findings, Donaldson Company, Inc. was able to determine all the possible countries minerals (such as 3TGs) used in its product originated from. As such, Donaldson Company, Inc. can perform further due diligence on the source and chain of custody of the minerals in question.

Attached as Appendix B is a list of the countries of origin as identified by the RMI for the SORs included in Appendix A.

6. Steps to Mitigate Risk

Donaldson has taken, or intends to take, the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in the Company's products could originate from Conflict-Affected and High-Risk Areas:

•Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to:
◦Using a comprehensive smelter and refiner library with detailed status and notes for each entity.
◦Scanning for verifiable media sources on each smelter and refiner to flag risk issues.
◦Comparing the list of smelters/refiners against government watch and denied parties lists.
•Engage with suppliers more closely and provide more information and training resources regarding responsible sourcing of 3TGs.
•Encourage suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.
•Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts, as well as included in the terms and conditions of each purchase order issued.
•Following the OECD Guidance process, increase the emphasis on clean and validated smelter and refiner information from the supply chain through feedback and detailed smelter analysis.



Appendix A - Smelter List
Metal Smelter Name Smelter Facility Location Smelter ID RMAP Audit Status Risk Status
Gold Advanced Chemical Company United States Of America CID000015 Conformant Low Risk
Gold Aida Chemical Industries Co., Ltd. Japan CID000019 Conformant Low Risk
Gold Argor-Heraeus S.A. Switzerland CID000077 Conformant Low Risk
Gold Asaka Riken Co., Ltd. Japan CID000090 Conformant Low Risk
Gold CCR Refinery - Glencore Canada Corporation Canada CID000185 Conformant Low Risk
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China CID000228 Conformant Medium Risk
Gold Chimet S.p.A. Italy CID000233 Conformant Low Risk
Gold Chugai Mining Japan CID000264 Conformant Low Risk
Tin Alpha Assembly Solutions Inc United States Of America CID000292 Conformant Low Risk
Gold DSC (Do Sung Corporation) Korea, Republic Of CID000359 Conformant Low Risk
Gold Dowa Japan CID000401 Conformant Medium Risk
Tin Dowa Japan CID000402 Conformant Low Risk
Gold Eco-System Recycling Co., Ltd. East Plant Japan CID000425 Conformant Low Risk
Tin EM Vinto Bolivia (Plurinational State Of) CID000438 Conformant Low Risk
Tin Fenix Metals Poland CID000468 Conformant Low Risk
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. China CID000538 Conformant Medium Risk
Gold LT Metal Ltd. Korea, Republic Of CID000689 Conformant Low Risk
Gold Heimerle + Meule GmbH Germany CID000694 Conformant Low Risk
Gold Heraeus Metals Hong Kong Ltd. China CID000707 Conformant Low Risk
Gold Heraeus Germany GmbH Co. KG Germany CID000711 Conformant Low Risk
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China CID000801 Conformant Low Risk
Gold Jiangxi Copper Co., Ltd. China CID000855 Conformant Low Risk
Gold Asahi Refining USA Inc. United States Of America CID000920 Conformant Low Risk
Gold Asahi Refining Canada Ltd. Canada CID000924 Conformant Low Risk
Gold Kennecott Utah Copper LLC United States Of America CID000969 Conformant Low Risk
Tin China Tin Group Co., Ltd. China CID001070 Conformant Medium Risk
Gold Materion United States Of America CID001113 Conformant Low Risk
Tin Metallic Resources, Inc. United States Of America CID001142 Conformant Low Risk
Gold Metalor Technologies (Suzhou) Ltd. China CID001147 Conformant Low Risk
Gold Metalor Technologies (Singapore) Pte., Ltd. Singapore CID001152 Conformant Low Risk
Gold Metalor Technologies S.A. Switzerland CID001153 Conformant Low Risk
Gold Metalor USA Refining Corporation United States Of America CID001157 Conformant Low Risk
Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico CID001161 Conformant Low Risk
Tin Mineracao Taboca S.A. Brazil CID001173 Conformant Low Risk
Tin Minsur Peru CID001182 Conformant Low Risk
Tin Mitsubishi Materials Corporation Japan CID001191 Conformant Low Risk
Gold Mitsui Mining and Smelting Co., Ltd. Japan CID001193 Conformant Low Risk
Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand CID001314 Conformant Low Risk
Gold Ohura Precious Metal Industry Co., Ltd. Japan CID001325 Conformant Low Risk


Metal Smelter Name Smelter Facility Location Smelter ID RMAP Audit Status Risk Status
Tin Operaciones Metalurgicas S.A. Bolivia (Plurinational State Of) CID001337 Conformant Low Risk
Tin PT Mitra Stania Prima Indonesia CID001453 Conformant Medium Risk
Tin PT Prima Timah Utama Indonesia CID001458 Conformant Medium Risk
Tin PT Timah Tbk Kundur Indonesia CID001477 Conformant Medium Risk
Tin PT Timah Tbk Mentok Indonesia CID001482 Conformant Medium Risk
Gold Royal Canadian Mint Canada CID001534 Conformant Low Risk
Tin Rui Da Hung Taiwan, Province Of China CID001539 Conformant Medium Risk
Gold SEMPSA Joyeria Plateria S.A. Spain CID001585 Conformant Low Risk
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China CID001622 Conformant Medium Risk
Tin Thaisarco Thailand CID001898 Conformant Medium Risk
Gold Shandong Gold Smelting Co., Ltd. China CID001916 Conformant Medium Risk
Gold Umicore S.A. Business Unit Precious Metals Refining Belgium CID001980 Conformant Low Risk
Gold United Precious Metal Refining, Inc. United States Of America CID001993 Conformant Low Risk
Gold Western Australian Mint (T/a The Perth Mint) Australia CID002030 Conformant Low Risk
Tin White Solder Metalurgia e Mineracao Ltda. Brazil CID002036 Conformant Low Risk
Gold Yamakin Co., Ltd. Japan CID002100 Conformant Low Risk
Gold Yokohama Metal Co., Ltd. Japan CID002129 Conformant Medium Risk
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. China CID002180 Conformant Low Risk
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation China CID002224 Conformant Low Risk
Gold Gold Refinery of Zijin Mining Group Co., Ltd. China CID002243 Conformant Medium Risk
Gold SAFINA A.S. Czechia CID002290 Conformant Low Risk
Tin PT ATD Makmur Mandiri Jaya Indonesia CID002503 Conformant Medium Risk
Tin O.M. Manufacturing Philippines, Inc. Philippines CID002517 Conformant Medium Risk
Gold REMONDIS PMR B.V. Netherlands CID002582 Conformant Low Risk
Tin PT Rajehan Ariq Indonesia CID002593 Conformant Medium Risk
Tin Aurubis Beerse Belgium CID002773 Conformant Low Risk
Tin Aurubis Berango Spain CID002774 Conformant Low Risk
Gold WIELAND Edelmetalle GmbH Germany CID002778 Conformant Low Risk
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China CID003116 Conformant Medium Risk
Tin Tin Technology & Refining United States Of America CID003325 Conformant Low Risk
Tin Luna Smelter, Ltd. Rwanda CID003387 Conformant Medium Risk
Tin PT Mitra Sukses Globalindo Indonesia CID003449 Conformant Low Risk
Tungsten A.L.M.T. Corp. Japan CID000004 Conformant Medium Risk
Gold Agosi AG Germany CID000035 Conformant Low Risk
Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan CID000041 Conformant Medium Risk
Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil CID000058 Conformant Low Risk
Gold Asahi Pretec Corp. Japan CID000082 Conformant Low Risk
Tungsten Kennametal Huntsville United States Of America CID000105 Conformant Low Risk
Gold Aurubis AG Germany CID000113 Conformant Low Risk
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines CID000128 Conformant Low Risk
Gold Boliden Ronnskar Sweden CID000157 Conformant Low Risk
Gold C. Hafner GmbH + Co. KG Germany CID000176 Conformant Low Risk
Tungsten Guangdong Xianglu Tungsten Co., Ltd. China CID000218 Conformant Low Risk


Metal Smelter Name Smelter Facility Location Smelter ID RMAP Audit Status Risk Status
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China CID000258 Conformant Medium Risk
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. China CID000291 Conformant Medium Risk
Tin PT Premium Tin Indonesia Indonesia CID000313 Conformant Medium Risk
Tin Dongguan Best Alloys Co., Ltd. China CID000377 Conformant Low Risk
Tin Estanho de Rondonia S.A. Brazil CID000448 Conformant Low Risk
Tantalum F&X Electro-Materials Ltd. China CID000460 Conformant Medium Risk
Tungsten Global Tungsten & Powders LLC United States Of America CID000568 Conformant Low Risk
Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED China CID000616 Conformant Medium Risk
Gold Ishifuku Metal Industry Co., Ltd. Japan CID000807 Conformant Low Risk
Gold Istanbul Gold Refinery Turkey CID000814 Conformant Low Risk
Gold Japan Mint Japan CID000823 Conformant Low Risk
Tungsten Japan New Metals Co., Ltd. Japan CID000825 Conformant Medium Risk
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. China CID000914 Conformant Medium Risk
Tantalum Jiujiang Tanbre Co., Ltd. China CID000917 Conformant Medium Risk
Gold JX Nippon Mining & Metals Co., Ltd. Japan CID000937 Conformant Low Risk
Gold Kazzinc Kazakhstan CID000957 Conformant Low Risk
Tungsten Kennametal Fallon United States Of America CID000966 Conformant Low Risk
Gold Kojima Chemicals Co., Ltd. Japan CID000981 Conformant Low Risk
Tantalum AMG Brasil Brazil CID001076 Conformant Low Risk
Gold LS MnM Inc. Korea, Republic Of CID001078 Conformant Low Risk
Gold Matsuda Sangyo Co., Ltd. Japan CID001119 Conformant Low Risk
Gold Metalor Technologies (Hong Kong) Ltd. China CID001149 Conformant Medium Risk
Tantalum Metallurgical Products India Pvt., Ltd. India CID001163 Conformant Low Risk
Tantalum Mineracao Taboca S.A. Brazil CID001175 Conformant Low Risk
Gold Mitsubishi Materials Corporation Japan CID001188 Conformant Medium Risk
Tantalum Mitsui Mining and Smelting Co., Ltd. Japan CID001192 Conformant Medium Risk
Tantalum NPM Silmet AS Estonia CID001200 Conformant Low Risk
Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey CID001220 Conformant Low Risk
Tin Jiangxi New Nanshan Technology Ltd. China CID001231 Active Medium Risk
Gold Navoi Mining and Metallurgical Combinat Uzbekistan CID001236 Conformant Low Risk
Gold Nihon Material Co., Ltd. Japan CID001259 Conformant Medium Risk
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. China CID001277 Conformant Medium Risk
Gold MKS PAMP SA Switzerland CID001352 Conformant Low Risk
Gold PT Aneka Tambang (Persero) Tbk Indonesia CID001397 Conformant Low Risk
Gold PX Precinox S.A. Switzerland CID001498 Conformant Low Risk
Gold Rand Refinery (Pty) Ltd. South Africa CID001512 Conformant Medium Risk
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China CID001522 Conformant Low Risk
Gold Sichuan Tianze Precious Metals Co., Ltd. China CID001736 Conformant Low Risk
Gold Solar Applied Materials Technology Corp. Taiwan, Province Of China CID001761 Conformant Low Risk
Gold Sumitomo Metal Mining Co., Ltd. Japan CID001798 Conformant Low Risk
Tantalum Taki Chemical Co., Ltd. Japan CID001869 Conformant Low Risk
Gold Tanaka Kikinzoku Kogyo K.K. Japan CID001875 Conformant Low Risk
Tantalum Telex Metals United States Of America CID001891 Conformant Low Risk
Gold Tokuriki Honten Co., Ltd. Japan CID001938 Conformant Low Risk
Tantalum Ulba Metallurgical Plant JSC Kazakhstan CID001969 Conformant Low Risk


Metal Smelter Name Smelter Facility Location Smelter ID RMAP Audit Status Risk Status
Gold Valcambi S.A. Switzerland CID002003 Conformant Low Risk
Tungsten Wolfram Bergbau und Hutten AG Austria CID002044 Conformant Low Risk
Tungsten Xiamen Tungsten Co., Ltd. China CID002082 Conformant Medium Risk
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China CID002158 Non Conformant High Risk
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China CID002315 Non Conformant High Risk
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China CID002316 Conformant Low Risk
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China CID002317 Conformant Medium Risk
Tungsten Malipo Haiyu Tungsten Co., Ltd. China CID002319 Conformant Medium Risk
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China CID002320 Conformant Medium Risk
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China CID002321 Conformant Medium Risk
Tin Magnu's Minerais Metais e Ligas Ltda. Brazil CID002468 Conformant Low Risk
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China CID002492 Conformant Low Risk
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China CID002494 Conformant Medium Risk
Tungsten Asia Tungsten Products Vietnam Ltd. Viet Nam CID002502 Conformant Medium Risk
Tantalum D Block Metals, LLC United States Of America CID002504 Conformant Low Risk
Tantalum FIR Metals & Resource Ltd. China CID002505 Conformant Low Risk
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China CID002506 Conformant Medium Risk
Gold MMTC-PAMP India Pvt., Ltd. India CID002509 Conformant Medium Risk
Gold KGHM Polska Miedz Spolka Akcyjna Poland CID002511 Conformant Low Risk
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China CID002512 Conformant Low Risk
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch China CID002513 Non Conformant High Risk
Tantalum KEMET de Mexico Mexico CID002539 Conformant Low Risk
Tungsten H.C. Starck Tungsten GmbH Germany CID002541 Conformant Low Risk
Tungsten TANIOBIS Smelting GmbH & Co. KG Germany CID002542 Conformant Low Risk
Tungsten Masan High-Tech Materials Viet Nam CID002543 Conformant Medium Risk
Tantalum TANIOBIS Co., Ltd. Thailand CID002544 Conformant Medium Risk
Tantalum TANIOBIS GmbH Germany CID002545 Conformant Low Risk
Tantalum Materion Newton Inc. United States Of America CID002548 Conformant Low Risk
Tantalum TANIOBIS Japan Co., Ltd. Japan CID002549 Conformant Medium Risk
Tantalum TANIOBIS Smelting GmbH & Co. KG Germany CID002550 Conformant Low Risk
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China CID002551 Conformant Medium Risk
Tantalum Global Advanced Metals Boyertown United States Of America CID002557 Conformant Low Risk
Tantalum Global Advanced Metals Aizu Japan CID002558 Conformant Medium Risk
Gold T.C.A S.p.A Italy CID002580 Conformant Low Risk
Tungsten Niagara Refining LLC United States Of America CID002589 Conformant Low Risk
Gold Korea Zinc Co., Ltd. Korea, Republic Of CID002605 Conformant Low Risk
Gold TOO Tau-Ken-Altyn Kazakhstan CID002615 Conformant Low Risk
Tungsten China Molybdenum Tungsten Co., Ltd. China CID002641 Conformant Low Risk
Tin PT Cipta Persada Mulia Indonesia CID002696 Conformant Low Risk
Tin Resind Industria e Comercio Ltda. Brazil CID002706 Conformant Low Risk
Tantalum Resind Industria e Comercio Ltda. Brazil CID002707 Conformant Low Risk
Gold Abington Reldan Metals, LLC United States Of America CID002708 Conformant Low Risk
Tin Super Ligas Brazil CID002756 Conformant Low Risk
Gold Italpreziosi Italy CID002765 Conformant Low Risk
Tin PT Bangka Prima Tin Indonesia CID002776 Conformant Medium Risk


Metal Smelter Name Smelter Facility Location Smelter ID RMAP Audit Status Risk Status
Tantalum Jiangxi Tuohong New Raw Material China CID002842 Conformant Low Risk
Gold Bangalore Refinery India CID002863 Conformant Low Risk
Gold SungEel HiMetal Co., Ltd. Korea, Republic Of CID002918 Conformant Low Risk
Gold Planta Recuperadora de Metales SpA Chile CID002919 Conformant Low Risk
Gold NH Recytech Company Korea, Republic Of CID003189 Conformant Low Risk
Tin Chifeng Dajingzi Tin Industry Co., Ltd. China CID003190 Conformant Low Risk
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China CID003397 Conformant Medium Risk
Tungsten Lianyou Metals Co., Ltd. Taiwan, Province Of China CID003407 Conformant Low Risk
Tungsten Hubei Green Tungsten Co., Ltd. China CID003417 Conformant Low Risk
Gold Eco-System Recycling Co., Ltd. North Plant Japan CID003424 Conformant Low Risk
Gold Eco-System Recycling Co., Ltd. West Plant Japan CID003425 Conformant Low Risk
Tungsten Cronimet Brasil Ltda Brazil CID003468 Conformant Low Risk
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil CID003486 Active Low Risk
Tin CRM Synergies Spain CID003524 Conformant Low Risk
Gold Metal Concentrators SA (Pty) Ltd. South Africa CID003575 Conformant Low Risk
Tungsten Fujian Xinlu Tungsten Co., Ltd. China CID003609 Non Conformant Medium Risk
Gold WEEEREFINING France CID003615 Non Conformant Medium Risk
Gold Gold by Gold Colombia Colombia CID003641 Conformant Low Risk
Tin PT Putera Sarana Shakti (PT PSS) Indonesia CID003868 Conformant Low Risk
Tungsten Tungsten Vietnam Joint Stock Company Viet Nam CID003993 Conformant Low Risk
Gold Coimpa Industrial LTDA Brazil CID004010 Conformant Low Risk
Tantalum PowerX Ltd. Rwanda CID004054 Conformant Low Risk
Tin Mining Minerals Resources SARL Congo, Democratic Republic Of The CID004065 Conformant Medium Risk
Tungsten Lianyou Resources Co., Ltd. Taiwan, Province Of China CID004397 Conformant Low Risk
Tin Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. Japan CID004403 Conformant Low Risk
Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. China CID004430 Conformant Low Risk
Tin Malaysia Smelting Corporation Berhad (Port Klang) Malaysia CID004434 Conformant Low Risk
Tungsten Philippine Carreytech Metal Corp. Philippines CID004438 Non Conformant Medium Risk
Gold TITAN COMPANY LIMITED, JEWELLERY DIVISION India CID004491 Non Conformant Medium Risk
Gold GG Refinery Ltd. Tanzania, United Republic Of CID004506 Conformant Low Risk
Tungsten KENEE MINING VIETNAM COMPANY LIMITED Viet Nam CID004619 Conformant Low Risk
Gold Impala Platinum - Platinum Metals Refinery (PMR) South Africa CID004714 Conformant Low Risk
Tin Woodcross Smelting Company Limited Uganda CID004724 Conformant Low Risk
Tin Global Advanced Metals Greenbushes Pty Ltd. Australia CID004754 Conformant Low Risk
Gold Elite Industech Co., Ltd. Taiwan, Province Of China CID004755 Conformant Low Risk
Tungsten Philippine Bonway Manufacturing Industrial Corporation Philippines CID004797 Conformant Low Risk
Tungsten Jing Yuan Tungsten Technology Co., Ltd. Taiwan, Province Of China CID005012 Conformant Low Risk
Gold Minera Titán del Perú SRL (MTP) - Belen Plant Peru CID005014 Non Conformant Medium Risk
Tungsten S.P.T. spol.s r.o. Czechia CID005068 Conformant Low Risk


Metal Smelter Name Smelter Facility Location Smelter ID RMAP Audit Status Risk Status
Tin P Kay Metal, Inc United States Of America CID005189 Conformant Low Risk
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China CID002313 Communication Suspended - Not Interested Medium Risk
Gold Caridad Mexico CID000180 Outreach Required Low Risk
Gold Cendres + Metaux S.A. Switzerland CID000189 Non Conformant Medium Risk
Gold Yunnan Copper Industry Co., Ltd. China CID000197 Outreach Required High Risk
Gold Daye Non-Ferrous Metals Mining Ltd. China CID000343 Outreach Required Medium Risk
Gold JSC Novosibirsk Refinery Russian Federation CID000493 RMI Due Diligence Review - Unable to Proceed High Risk
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. China CID000555 Non Conformant High Risk
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. China CID000671 Outreach Required Medium Risk
Gold Hunan Chenzhou Mining Co., Ltd. China CID000767 Outreach Required Medium Risk
Tungsten Hunan Jintai New Material Co., Ltd. China CID000769 Non Conformant High Risk
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China CID000773 Outreach Required Medium Risk
Gold HwaSeong CJ CO., LTD. Korea, Republic Of CID000778 Communication Suspended - Not Interested Medium Risk
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation CID000927 RMI Due Diligence Review - Unable to Proceed High Risk
Gold JSC Uralelectromed Russian Federation CID000929 RMI Due Diligence Review - Unable to Proceed High Risk
Tin Gejiu Kai Meng Industry and Trade LLC China CID000942 Non Conformant High Risk
Gold Kazakhmys Smelting LLC Kazakhstan CID000956 Outreach Required Low Risk
Gold Kyrgyzaltyn JSC Kyrgyzstan CID001029 Non Conformant Medium Risk
Gold Lingbao Gold Co., Ltd. China CID001056 Outreach Required High Risk
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China CID001093 Outreach Required Medium Risk
Gold Moscow Special Alloys Processing Plant Russian Federation CID001204 RMI Due Diligence Review - Unable to Proceed High Risk
Tin Novosibirsk Tin Combine Russian Federation CID001305 RMI Due Diligence Review - Unable to Proceed High Risk
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation CID001326 RMI Due Diligence Review - Unable to Proceed High Risk
Gold Penglai Penggang Gold Industry Co., Ltd. China CID001362 Outreach Required Medium Risk
Gold Prioksky Plant of Non-Ferrous Metals Russian Federation CID001386 RMI Due Diligence Review - Unable to Proceed High Risk
Gold Sabin Metal Corp. United States Of America CID001546 Communication Suspended - Not Interested Medium Risk
Gold Samduck Precious Metals Korea, Republic Of CID001555 Non Conformant High Risk


Metal Smelter Name Smelter Facility Location Smelter ID RMAP Audit Status Risk Status
Gold Samwon Metals Corp. Korea, Republic Of CID001562 Communication Suspended - Not Interested Medium Risk
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China CID001619 Outreach Required Medium Risk
Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation CID001756 RMI Due Diligence Review - Unable to Proceed High Risk
Tantalum Solikamsk Magnesium Works OAO Russian Federation CID001769 RMI Due Diligence Review - Unable to Proceed High Risk
Gold Super Dragon Technology Co., Ltd. Taiwan, Province Of China CID001810 Outreach Required Medium Risk
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China CID001908 Non Conformant Medium Risk
Gold Great Wall Precious Metals Co., Ltd. of CBPM China CID001909 Outreach Required Medium Risk
Gold Tongling Nonferrous Metals Group Co., Ltd. China CID001947 Outreach Required Medium Risk
Gold Torecom Korea, Republic Of CID001955 Non Conformant Medium Risk
Tin VQB Mineral and Trading Group JSC Viet Nam CID002015 Outreach Required High Risk
Gold Morris and Watson New Zealand CID002282 Outreach Required Low Risk
Gold Umicore Precious Metals Thailand Thailand CID002314 Non Conformant Medium Risk
Tin Melt Metais e Ligas S.A. Brazil CID002500 Non Conformant Medium Risk
Gold Fidelity Printers and Refiners Ltd. Zimbabwe CID002515 RMI Due Diligence Review - Unable to Proceed High Risk
Gold Singway Technology Co., Ltd. Taiwan, Province Of China CID002516 Non Conformant Medium Risk
Gold Shandong Humon Smelting Co., Ltd. China CID002525 Outreach Required Medium Risk
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China CID002527 Outreach Required Medium Risk
Gold Al Etihad Gold Refinery DMCC United Arab Emirates CID002560 Non Conformant Medium Risk
Gold Emirates Gold DMCC United Arab Emirates CID002561 Non Conformant High Risk
Gold International Precious Metal Refiners United Arab Emirates CID002562 Outreach Required Medium Risk
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Viet Nam CID002572 Non Conformant Medium Risk
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company Viet Nam CID002573 Outreach Required High Risk
Gold Fujairah Gold FZC United Arab Emirates CID002584 Outreach Required Medium Risk
Gold Shirpur Gold Refinery Ltd. India CID002588 Outreach Required Medium Risk
Gold Marsam Metals Brazil CID002606 Non Conformant Medium Risk
Tungsten Hydrometallurg, JSC Russian Federation CID002649 RMI Due Diligence Review - Unable to Proceed High Risk
Tin An Vinh Joint Stock Mineral Processing Company Viet Nam CID002703 Outreach Required Medium Risk
Tungsten Unecha Refractory metals plant Russian Federation CID002724 Non Conformant High Risk
Gold Shenzhen CuiLu Gold Co., Ltd. China CID002750 Outreach Required Medium Risk
Gold Albino Mountinho Lda. Portugal CID002760 Outreach Required Low Risk
Gold SAAMP France CID002761 Non Conformant Medium Risk
Gold L'Orfebre S.A. Andorra CID002762 Non Conformant Medium Risk
Gold 8853 S.p.A. Italy CID002763 Non Conformant Medium Risk
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria CID002779 Conformant Low Risk
Tungsten Moliren Ltd. Russian Federation CID002845 RMI Due Diligence Review - Unable to Proceed High Risk
Gold AU Traders and Refiners South Africa CID002850 Non Conformant High Risk
Gold GGC Gujrat Gold Centre Pvt. Ltd. India CID002852 Non Conformant High Risk


Metal Smelter Name Smelter Facility Location Smelter ID RMAP Audit Status Risk Status
Gold Modeltech Sdn Bhd Malaysia CID002857 Non Conformant Medium Risk
Tin Modeltech Sdn Bhd Malaysia CID002858 Non Conformant Medium Risk
Gold Kyshtym Copper-Electrolytic Plant ZAO Russian Federation CID002865 RMI Due Diligence Review - Unable to Proceed High Risk
Gold Degussa Sonne / Mond Goldhandel GmbH Germany CID002867 Outreach Required Low Risk
Gold Pease & Curren United States Of America CID002872 Communication Suspended - Not Interested Medium Risk
Gold JALAN & Company India CID002893 Outreach Required Medium Risk
Gold ABC Refinery Pty Ltd. Australia CID002920 Outreach Required Low Risk
Gold Safimet S.p.A Italy CID002973 Non Conformant Medium Risk
Gold State Research Institute Center for Physical Sciences and Technology Lithuania CID003153 Outreach Required Medium Risk
Gold African Gold Refinery Uganda CID003185 RMI Due Diligence Review - Unable to Proceed High Risk
Gold Gold Coast Refinery Ghana CID003186 Outreach Required Medium Risk
Gold QG Refining, LLC United States Of America CID003324 Outreach Required Medium Risk
Gold Dijllah Gold Refinery FZC United Arab Emirates CID003348 Outreach Required Medium Risk
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China CID003356 Non Conformant Medium Risk
Tin Ma'anshan Weitai Tin Co., Ltd. China CID003379 Non Conformant Medium Risk
Gold CGR Metalloys Pvt Ltd. India CID003382 Outreach Required Medium Risk
Gold Sovereign Metals India CID003383 Outreach Required High Risk
Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation CID003408 RMI Due Diligence Review - Unable to Proceed High Risk
Tin Precious Minerals and Smelting Limited India CID003409 Non Conformant Medium Risk
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China CID003410 Outreach Required Medium Risk
Tungsten NPP Tyazhmetprom LLC Russian Federation CID003416 RMI Due Diligence Review - Unable to Proceed High Risk
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil CID003427 Non Conformant Medium Risk
Gold Augmont Enterprises Private Limited India CID003461 Non Conformant Medium Risk
Gold Kundan Care Products Ltd. India CID003463 Outreach Required High Risk
Gold Emerald Jewel Industry India Limited (Unit 1) India CID003487 Outreach Required Medium Risk
Gold Emerald Jewel Industry India Limited (Unit 2) India CID003488 Outreach Required Medium Risk
Gold Emerald Jewel Industry India Limited (Unit 3) India CID003489 Outreach Required Medium Risk
Gold Emerald Jewel Industry India Limited (Unit 4) India CID003490 Outreach Required Medium Risk
Gold K.A. Rasmussen Norway CID003497 Outreach Required Medium Risk
Gold Alexy Metals United States Of America CID003500 Non Conformant Medium Risk
Gold MD Overseas India CID003548 Outreach Required Medium Risk


Metal Smelter Name Smelter Facility Location Smelter ID RMAP Audit Status Risk Status
Gold Metallix Refining Inc. United States Of America CID003557 Outreach Required Low Risk
Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil CID003582 Conformant Low Risk
Tungsten OOO "Technolom" 2 Russian Federation CID003612 RMI Due Diligence Review - Unable to Proceed High Risk
Tungsten OOO "Technolom" 1 Russian Federation CID003614 RMI Due Diligence Review - Unable to Proceed High Risk
Tungsten YUDU ANSHENG TUNGSTEN CO., LTD. China CID003662 Outreach Required Medium Risk
Gold Dongwu Gold Group China CID003663 Outreach Required Medium Risk
Gold Sam Precious Metals United Arab Emirates CID003666 Outreach Required Medium Risk
Gold NOBLE METAL SERVICES United States Of America CID003690 Outreach Required Low Risk
Tantalum 5D Production OU Estonia CID003926 Outreach Required Low Risk
Tungsten Nam Viet Cromit Joint Stock Company Viet Nam CID004034 Outreach Required Medium Risk
Gold SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. China CID004435 Outreach Required Medium Risk
Tin RIKAYAA GREENTECH PRIVATE LIMITED India CID004692 Outreach Required Medium Risk
Gold Attero Recycling Pvt Ltd India CID004697 Outreach Required Medium Risk
Tin Longnan Chuangyue Environmental Protection Technology Development Co., Ltd China CID004796 Outreach Required Medium Risk
Tantalum Jiangxi Sanshi Nonferrous Metals Co., Ltd China CID004813 Active Medium Risk
Gold Gasabo Gold Refinery Ltd Rwanda CID005006 RMI Due Diligence Review - Unable to Proceed High Risk
Tungsten Tungamoy Metals Inc. Korea, Republic Of CID005248 Conformant Low Risk
Tin PT Aries Kencana Sejahtera Indonesia CID000309 In Communication Medium Risk
Tantalum XinXing HaoRong Electronic Material Co., Ltd. China CID002508 Conformant Low Risk
Tin CV Ayi Jaya Indonesia CID002570 Conformant Medium Risk
Tungsten Uzbek Refractory and Heat-Resistant Metals Uzbekistan CID002660 Active Medium Risk
Tin PT Masbro Alam Stania Indonesia CID003380 Non Conformant Medium Risk
Gold SOLEIL METALS (Chala One Plant) Peru CID004704 Active Low Risk
Gold SOLEIL METALS (YAKARI Plant) Peru CID004705 Active Low Risk
Tin PT Artha Cipta Langgeng Indonesia CID001399 Active Medium Risk
Tin PT Mitra Graha Raya Indonesia CID004685 In Communication Medium Risk
Tin Conecsus LLC United States Of America CID003504 Active Low Risk
Gold Atlantic Copper Spain CID003350 Outreach Required Low Risk
Tungsten Geo Enterprise Georgia CID005373 Outreach Required Low Risk
Gold Naoshima Smelter & Refinery Japan CID005396 Outreach Required Medium Risk
Gold KGHM Polska Miedz S.A. Oddzial Huta Miedzi, Glogow Poland CID005401 Outreach Required Low Risk
Gold Aurubis AG, Hamburg Germany CID005476 Outreach Required Low Risk


Appendix B: Countries of Origin

Below is an aggregated list of the countries of origin from which the reported facilities collectively source 3TGs, based on information provided by suppliers and from the RMI.

Albania
Cyprus
Ireland
Nicaragua
Sweden
Andorra
Democratic Republic of Congo
Israel
Niger
Switzerland
Angola
Djibouti
Italy
Nigeria
Taiwan
Argentina
Dominica
Japan
Norway
Tajikistan
Armenia
Dominican Republic
Jersey
Oman
Tanzania
Australia
Ecuador
Kazakhstan
Panama
Thailand
Austria
Egypt
Kenya
Papua New Guinea
Turkey
Azerbaijan
El Salvador
Korea
Peru
Uganda
Belarus
Eritrea
Kyrgyzstan
Philippines
United Arab Emirates
Belgium
Estonia
Liberia
Poland
United Kingdom
Benin
Ethiopia
Liechtenstein
Portugal
United States of America
Bermuda
Fiji
Lithuania
Russian Federation
Uruguay
Bolivia (Plurinational State of)
Finland
Luxembourg
Rwanda
Uzbekistan
Botswana
France
Madagascar
Saudi Arabia
VietNam
Brazil
Georgia
Malaysia
Senegal
Zambia
Bulgaria
Germany
Mali
Serbia
Zimbabwe
Burkina Faso
Ghana
Mauritania
Sierra Leone
Burundi
Guatemala
Mexico
Singapore
Cambodia
Guinea
Mongolia
Slovakia
Canada
Guyana
Morocco
Solomon Islands
Central African Republic
Honduras
Mozambique
South Africa
Chile
Hong Kong
Myanmar
South Sudan
China
Hungary
Namibia
Spain
Colombia
India
Netherlands
Sudan
Congo
Indonesia
New Zealand
Suriname



Appendix C: CMRT Declaration Rejection/Approval Criteria

Assent Sustainability Platform Logic Structure

The following tables map the Assent Sustainability Platform's status outputs and CMRT logic structure when determining supplier conflict mineral statuses as displayed on the dashboard. Using this table, and referencing the CMRT questions listed above, users will be able to determine what answers were provided by their suppliers to earn their conflict minerals statuses.

Dashboard Supplier Response Statuses

Supplier Status
Description
Not Submitted
A CMRT has not been submitted by the supplier
Complete
A CMRT has been submitted, and is valid and complete
Incomplete
A supplier with parts associated to them has submitted a partially completed Product-Level or User-Defined CMRT
Invalid Submission
A CMRT has been submitted and deemed invalid based on contradicting responses in the template
Out of Scope
The supplier is out of scope for conflict minerals and does not need to be contacted

Donaldson Co. Inc. published this content on May 28, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on May 28, 2026 at 15:04 UTC. If you believe the information included in the content is inaccurate or outdated and requires editing or removal, please contact us at [email protected]