Exhibit 1.01

CLEAN ENERGY FUELS CORP.

Conflict Minerals Report

For the Reporting Period from January 1, 2018 to December 31, 2018

This Conflict Minerals Report (the “Report”) of Clean Energy Fuels Corp. (together with its consolidated subsidiaries, the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2018 to December 31, 2018 (the “Reporting Period”). As permitted by applicable guidance of the Securities and Exchange Commission, the Company did not obtain an independent private sector audit within the meaning of the Rule.

Overview of the Company and the Rule

The Company is the leading provider of natural gas as an alternative fuel for vehicle fleets in the United States and Canada, based on the number of stations operated and the amount of gasoline gallon equivalents (“GGEs”) of renewable natural gas (“RNG”), compressed natural gas (“CNG”) and liquefied natural gas (“LNG”) delivered. The Company’s principal business is supplying RNG, CNG and LNG (RNG can be delivered in the form of CNG or LNG) for light, medium and heavy-duty vehicles and providing operation and maintenance (“O&M”) services for vehicle fleet customer stations. As a comprehensive solution provider, the Company also designs, builds, operates and maintains fueling stations; sells and services natural gas fueling compressors and other equipment used in CNG stations and LNG stations; offers assessment, design and modification solutions to provide operators with code-compliant service and maintenance facilities for natural gas vehicle fleets; transports and sells CNG and LNG via “virtual” natural gas pipelines and interconnects; procures and sells RNG; sells tradable credits it generates by selling RNG and conventional natural gas as a vehicle fuel, including Renewable Identification Numbers under the federal Renewable Fuel Standard Phase 2 and credits under the California and Oregon Low Carbon Fuel Standards; helps its customers acquire and finance natural gas vehicles; and obtains federal, state and local tax credits, grants and incentives. As of March 31, 2019, the Company served over 1,000 fleet customers operating over 47,000 natural gas vehicles, and the Company owned, operated or supplied approximately 530 natural gas fueling stations in 41 states in the United States and four provinces in Canada.

The Rule requires disclosure of certain information if a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of the products. The Rule also requires such companies to conduct certain inquiries reasonably designed to determine whether such minerals originated in the countries specified in the Rule. The minerals specified in the Rule, which are collectively referred to in this Report as the “Conflict Minerals,” consist of gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The countries specified in the Rule, which are collectively referred to in this Report as the “Covered Countries,” consist of the Democratic Republic of the Congo and all countries that share an international border with the Democratic Republic of the Congo, which presently consists of the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain aspects of the Company’s operations involve the manufacture, or contracting for manufacture, of products for which the Conflict Minerals are necessary to the functionality or production of the products.

When this Report uses the term “Conformant,” it means the applicable mine, smelter or refiner has been verified as complying with the Responsible Minerals Assurance Process (“RMAP,” formerly the Conflict-Free Smelter Program or CFSP) of the Responsible Mining Initiative (“RMI,” formerly the Conflict-Free Sourcing Initiative or CFSI) or an equivalent third-party audit program, and when this Report uses the term “Active,” it means the applicable mine, smelter or refiner has agreed to participate in the RMAP but has not yet completed the program to become Conformant.

The Company’s Products Covered by this Report

This Report covers products: (i) for which one or more Conflict Minerals is necessary to the functionality or production of the product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during the Reporting Period. These products, which are collectively referred to in this Report as the “Covered Products,” consist of the following:

 

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LNG Pumps – This product category includes products that offload LNG from cryogenic tanker trailers into storage tanks at LNG fueling stations and deliver LNG to dispensers from storage tanks, as well as replacement parts for such products.

 

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LNG Dispensers – This product category includes products that dispense LNG into vehicles, as well as replacement parts for such products.

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Fueling Station Support Panels – This product category includes electrical storage panels used in natural gas fueling stations, as well as replacement parts for such products. A fueling station support panel houses the point of sale system that tracks dispenser transactions, the communications system, purge fans, a digital video recorder and camera to record activities at the station and power circuits for station lighting and electrical control.

Third-party products the Company sells at retail but does not manufacture or contract to manufacture are outside the scope of this Report.

Overview of the Company’s Supply Chain

The Company’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the original sources of Conflict Minerals and the ultimate manufacture of the Covered Products. In this regard, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of Conflict Minerals that are necessary to the functionality or production of the Covered Products. Moreover, the Company believes the mines, smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and therefore the Company has sought to identify the applicable mines, smelters and refiners of Conflict Minerals in the Company’s supply chain.

The Company’s Conflict Minerals Policy

The Company maintains a policy relating to the sourcing of Conflict Minerals (the “Company Policy”), which provides as follows:

 

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The Company is guided by its core beliefs and values as stated in the Company’s Code of Ethics. The Company is committed to ethical practices and compliance with applicable laws and regulations wherever it does business. The Company believes that its commitment to integrity and citizenship extends to its worldwide supply base. The Company is committed to sourcing its products responsibly, and it expects its suppliers to also source materials from responsible suppliers.

 

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The Company expects its suppliers to partner with it to comply with the Rule. The Company expects its suppliers to:

 

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Complete the Company’s Conflict Minerals survey, identifying whether any Conflict Mineral is present in the material that they sell to the Company and the smelter, refiner or mine that originally provided it (for this purpose, the Company’s direct suppliers may have to require successive upstream suppliers to complete the Company’s Conflict Minerals survey until the applicable smelter, refiner or mine is identified);

 

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Agree to cooperate fully with the Company in connection with any due diligence that the Company chooses to perform with respect to its inquiries; and

 

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When the Company deems it necessary, to provide reasonable proof of the due diligence performed by the supplier to support the information provided by the supplier to the Company.

 

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The Company evaluates its relationships with its suppliers on an ongoing basis, and reserves the right to consider the extent to which a supplier has failed to reasonably comply with the Company Policy in the course of such evaluation.

The Company has designed its Conflict Minerals reporting efforts, including the design and implementation of the Company Policy, to align and comply with the Rule. The full text of the Company Policy is available at http://investors.cleanenergyfuels.com/corporate-governance.cfm. The foregoing website reference and all other such references in this Report are intended to be inactive textual references, and the contents of the Company’s website are not intended to be incorporated into this Report.

The Company’s Reasonable Country of Origin Inquiry

The Company has conducted in good faith a reasonable country of origin inquiry (“RCOI”) regarding the Conflict Minerals. This RCOI was reasonably designed to determine whether any of the Conflict Minerals necessary to the functionality or production of a Covered Product originated in the Covered Countries or may be from recycled or scrap sources. Based on the RCOI, the Company has reason to believe that some of the necessary Conflict Minerals contained in the Covered Products may have originated from the Covered Countries or may not be from recycled or scrap sources. As a result, the Company exercised due diligence on the source and chain of custody of such Conflict Minerals, as described below.

Due Diligence Process

Due diligence process design

The Company’s due diligence measures have been designed to conform, in all material respects, to the framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas: Third Edition (2016), including the related supplements on gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”).

Due diligence performed

Below is a summary of the Company’s due diligence process performed in the Reporting Period regarding the sourcing of the necessary Conflict Minerals contained in the Covered Products. The description below is intended to provide a summary of the Company’s due diligence process, and thus the measures described below are not the only measures the Company took in the Reporting Period in furtherance of the Company Policy or pursuant to the Rule and the OECD Guidance.

OECD Guidance Step 1: Maintain a management system

 

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The Company continued to make the Company Policy publicly available.

 

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The Company maintained a working group that oversaw its due diligence process (the “Working Group”). The Working Group was led by the Company’s Senior Vice President, Corporate Transactions and Chief Legal Officer, and also included the Company’s Director, Supply Chain; the Supply Chain Manager of the Company’s subsidiary Clean Energy Cryogenics; and the Company’s Director, Legal Affairs. The Company also engaged an external service provider to support the due diligence process.

 

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The Company continued to use RMI’s Conflict Minerals Reporting Template (the “Template”) as a means for collecting information related to the use and origin of Conflict Minerals (including smelter data) in the Company’s supply chain.

OECD Guidance Step 2: Identify and assess risks

 

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The Company contacted its 18 identified in-scope suppliers and provided them with a summary of the Rule, links to the Template and the Company Policy, and contact information for the Company.

 

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To aid in the identification and assessment of potentially adverse impacts, the Company defined several “Red Flags,” or indicators that one or more items in a supplier’s completed Template or other response to the Company’s due diligence inquiries are worthy of further action by the Company. The Red Flags were designed to ensure that the Template has been completed in full, and also to capture (i) the reasonableness of responses using logic checks; (ii) whether a supplier has initiated its own due diligence on minerals sourcing; (iii) whether any Conflict Minerals are sourced from one of the Covered Countries, and (iv) whether the mines, smelters or refiners identified by suppliers are Conformant or Active.

 

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Suppliers that did not submit the Template by the requested deadline or presented Red Flags were contacted by members of the Working Group.

OECD Guidance Step 3: Design and implement strategy to respond to risk

 

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The Working Group reported the findings of the due diligence process to the Company’s senior management and Board of Directors.

 

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The Company maintained a risk management plan that establishes supplier risk management strategies, and followed up with suppliers as needed in accordance with this plan.

OECD Guidance Step 4: Carry out independent third-party audits of the supply chain

 

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The Company relied on the RMI and that organization’s RMAP for independent third-party audits of the mines, smelters and refiners in its supply chain.

 

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As noted above, and in accordance with applicable guidance, the Company did not obtain an independent private sector audit within the meaning of the Rule.

OECD Guidance Step 5: Report on supply chain due diligence

 

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The Company is reporting the results of the due diligence it performed by providing this Report as Exhibit 1.01 to a Form SD filed with the Securities and Exchange Commission. The Company also has made this Report publicly available on its website.

Results of Due Diligence Performed

The Company’s efforts to determine the mine or location of origin of the necessary Conflict Minerals contained in the Covered Products with the greatest possible specificity consisted primarily of the due diligence measures described in this Report. The Company received responses from 72% of its identified in-scope suppliers.

Based on the information provided by the Company’s suppliers, and taking into account the supplier responses described in the preceding paragraph, the Company believes the facilities that may have been used to process the necessary Conflict Minerals contained in the

Covered Products include the processing facilities listed in Tables 1, 2 and 3 in Appendix A to this Report. Of the 300 processing facilities identified by the Company’s suppliers as being in the supply chain for the Covered Products, 249 have been validated as Conformant, four have been confirmed as Active, and 47 have not been confirmed as Conformant or Active.

Based on its due diligence efforts, the Company does not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals in the Covered Products. Based on the information provided by the Company’s suppliers, however, the Company has reason to believe that some of the necessary Conflict Minerals contained in the Covered Products may have originated from the Covered Countries or may not be from recycled or scrap sources.

Additional Future Measures

The Company aims to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Covered Products finance or benefit armed groups (perpetrators of serious human rights abuses) in the Covered Countries:

 

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Continue to enhance its employee training relating to the Rule, the Company Policy and the Company’s procedures to identify and work with in-scope suppliers.

 

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Continue to engage with suppliers to help them better understand the Rule and the Company Policy and to obtain accurate and complete information about the origin of Conflict Minerals in the Company’s supply chain, including improving the quality of the processing facility data provided by suppliers.

 

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Seek opportunities to assist suppliers in building capabilities with a view to improving due diligence performance.

 

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Continue its initiative to include language in its new supply contracts that requires suppliers to comply with the Company Policy.

 

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Continue to engage in industry initiatives that encourage Conformant supply chains.

Inherent Limitations on Due Diligence Measures

As a downstream purchaser of products that contain Conflict Minerals, the Company’s due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals contained in the Covered Products. The supply chain of commodities such as the Conflict Minerals is a complex and multi-step process that involves a number of different parties. Because the Company does not have direct contractual relationships with mines, smelters and refiners, its due diligence processes must rely on information provided by its direct suppliers, as well as similar information provided to those suppliers within their supply chains, to identify the original sources of the necessary Conflict Minerals contained in the Covered Products. The results of the Company’s due diligence efforts could contain inaccuracies or incomplete information due to this process of collecting information. Further, many suppliers’ responses represent the supply chain at a company-level rather than being product-specific, and as a result, the list of processing facilities disclosed in this Report may contain facilities that did not actually process the Conflict Minerals contained in the Covered Products. In addition, the Company relies on information collected and provided by independent third-party audit programs, such as the RMAP of the RMI, and these sources of information may yield unreliable, inaccurate or incomplete information due to a variety of factors, including human or other errors or fraudulent actions.

Forward-Looking Statements

This Report contains forward-looking statements regarding the Company’s business, products and Conflict Minerals efforts, including steps the Company intends to take to improve its due diligence measures. Words such as “expects,” “believes,” “aims” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this Report. All statements made in this Report concerning future matters that are not historical in nature are forward-looking statements. Although forward-looking statements in this Report reflect the Company’s good faith judgment, such statements can only be based on facts and assumptions currently known by the Company. Consequently, forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated or implied by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include, among others: the risk that information reported to the Company by its suppliers, or other industry information used by the Company, may be inaccurate; the risk that mines, smelters or refiners may not participate in the RMAP or equivalent third-party audit programs, which are voluntary initiatives; and risks related to the Company’s compliance with government regulations and policies, which, among other risks, are discussed under “Risk Factors” in the Company’s most recent annual report on Form 10-K and the other filings it makes with the U.S. Securities and Exchange Commission from time to time, including any subsequently filed quarterly and current reports. Forward-looking statements are not predictions of future events, and readers should not rely on them as such. All forward-looking statements included in this Report speak only as of the date of this Report, and the Company undertakes no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this Report.

Appendix A

Tables of Our Conflict Minerals Processing Facilities

Table 1. Conformant processing facilities as of March 7, 2019.

The following processing facilities that were reported as being in the Company’s supply chain have been validated as Conformant:

 

Metal		Processing Facility Name		Processing Facility Location
Gold		Advanced Chemical Company		Rhode Island
Gold		Aida Chemical Industries Co., Ltd.		Tokyo
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		Baden-Württemberg
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		Toshkent
Gold		AngloGold Ashanti Corrego do Sitio Mineracao		Minas Gerais
Gold		Argor-Heraeus S.A.		Ticino
Gold		Asahi Pretec Corp.		Hyogo
Gold		Asaka Riken Co., Ltd.		Fukushima
Gold		Aurubis AG		Hamburg
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		Rizal
Gold		Boliden AB		Västerbottens län [SE-24]
Gold		C. Hafner GmbH + Co. KG		Baden-Württemberg
Gold		CCR Refinery—Glencore Canada Corporation		Quebec
Gold		Cendres + Metaux S.A.		Bern
Gold		Chimet S.p.A.		Toscana
Gold		Daejin Indus Co., Ltd.		Incheon-gwangyeoksi
Gold		DSC (Do Sung Corporation)		Gyeonggi-do
Gold		DODUCO Contacts and Refining GmbH		Baden-Württemberg
Gold		Dowa		Akita
Gold		Eco-System Recycling Co., Ltd.		Saitama

 

A-1

Metal		Processing Facility Name		Processing Facility Location
Gold		OJSC Novosibirsk Refinery		Novosibirskaya oblast’
Gold		HeeSung Metal Ltd.		Incheon-gwangyeoksi
Gold		Heimerle + Meule GmbH		Baden-Württemberg
Gold		Heraeus Metals Hong Kong Ltd.		Hong Kong
Gold		Heraeus Precious Metals GmbH & Co. KG		Hessen
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.		Nei Mongol
Gold		Ishifuku Metal Industry Co., Ltd.		Saitama
Gold		Istanbul Gold Refinery		İstanbul
Gold		Japan Mint		Osaka
Gold		Jiangxi Copper Co., Ltd.		Jiangxi
Gold		Asahi Refining USA Inc.		Utah
Gold		Asahi Refining Canada Ltd.		Ontario
Gold		JSC Uralelectromed		Sverdlovskaya oblast’
Gold		JX Nippon Mining & Metals Co., Ltd.		Ôita
Gold		Kazzinc		Qaraghandy oblysy
Gold		Kennecott Utah Copper LLC		Utah
Gold		Kojima Chemicals Co., Ltd.		Saitama
Gold		Kyrgyzaltyn JSC		Chüy
Gold		LS-NIKKO Copper Inc.		Ulsan-gwangyeoksi
Gold		Materion		New York
Gold		Matsuda Sangyo Co., Ltd.		Saitama
Gold		Metalor Technologies (Suzhou) Ltd.		Jiangsu
Gold		Metalor Technologies (Hong Kong) Ltd.		Hong Kong
Gold		Metalor Technologies (Singapore) Pte., Ltd.		South West
Gold		Metalor Technologies S.A.		Neuchâtel
Gold		Metalor USA Refining Corporation		Massachusetts

 

A-2

Metal		Processing Facility Name		Processing Facility Location
Gold		Metalurgica Met-Mex Penoles S.A. De C.V.		Coahuila de Zaragoza
Gold		Mitsubishi Materials Corporation		Kagawa
Gold		Mitsui Mining and Smelting Co., Ltd.		Hiroshima
Gold		Moscow Special Alloys Processing Plant		Moskva
Gold		Nadir Metal Rafineri San. Ve Tic. A.S.		İstanbul
Gold		Nihon Material Co., Ltd.		Chiba
Gold		Ohura Precious Metal Industry Co., Ltd.		Nara
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)		Krasnoyarskiy kray
Gold		PAMP S.A.		Ticino
Gold		Prioksky Plant of Non-Ferrous Metals		Ryazanskaya oblast’
Gold		PT Aneka Tambang (Persero) Tbk		Jakarta Raya
Gold		PX Precinox S.A.		Neuchâtel
Gold		Rand Refinery (Pty) Ltd.		Gauteng
Gold		Royal Canadian Mint		Ontario
Gold		Samduck Precious Metals		Incheon-gwangyeoksi
Gold		SEMPSA Joyeria Plateria S.A.		Madrid, Comunidad de
Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.		Shandong
Gold		Sichuan Tianze Precious Metals Co., Ltd.		Sichuan
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		Moskovskaja oblast’
Gold		Solar Applied Materials Technology Corp.		Tainan
Gold		Sumitomo Metal Mining Co., Ltd.		Ehime
Gold		Tanaka Kikinzoku Kogyo K.K.		Kanagawa
Gold		The Refinery of Shandong Gold Mining Co., Ltd.		Shandong
Gold		Tokuriki Honten Co., Ltd.		Saitama
Gold		Torecom		Chungcheongnam-do

 

A-3

Metal		Processing Facility Name		Processing Facility Location
Gold		Umicore Brasil Ltda.		São Paulo
Gold		Umicore S.A. Business Unit Precious Metals Refining		Antwerpen
Gold		United Precious Metal Refining, Inc.		New York
Gold		Valcambi S.A.		Ticino
Gold		Western Australian Mint (T/a The Perth Mint)		Western Australia
Gold		Yamakin Co., Ltd.		Kochi
Gold		Yokohama Metal Co., Ltd.		Kanagawa
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		Henan
Gold		Gold Refinery of Zijin Mining Group Co., Ltd.		Fujian
Gold		Umicore Precious Metals Thailand		Krung Thep Maha Nakhon
Gold		Geib Refining Corporation		Rhode Island
Gold		MMTC-PAMP India Pvt., Ltd.		Haryana
Gold		Singway Technology Co., Ltd.		Taoyuan
Gold		Al Etihad Gold LLC		Dubayy
Gold		Emirates Gold DMCC		Dubayy
Gold		T.C.A S.p.A		Toscana
Gold		Remondis Argentia B.V.		Noord-Brabant
Gold		Korea Zinc Co., Ltd.		Seoul-teukbyeolsi
Gold		Marsam Metals		São Paulo
Gold		SAAMP		Île-de-France
Gold		L’Orfebre S.A.		Andorra la Vella
Gold		Italpreziosi		Toscana
Gold		SAXONIA Edelmetalle GmbH		Sachsen
Gold		WIELAND Edelmetalle GmbH		Baden-Württemberg
Gold		Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH		Wien
Gold		AU Traders and Refiners		Gauteng

 

A-4

Metal		Processing Facility Name		Processing Facility Location
Gold		SungEel HiMetal Co., Ltd.		Jeollabuk-do
Gold		Planta Recuperadora de Metales SpA		Antofagasta
Gold		Safimet S.p.A		Toscana
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		Hunan
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		Ningxia
Tantalum		Asaka Riken Co., Ltd.		Fukushima
Tantalum		Guangdong Rising Rare Metals-EO Materials Ltd.		Guangdong
Tantalum		Exotech Inc.		Florida
Tantalum		F&X Electro-Materials Ltd.		Guangdong
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		Guangdong
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		Jiangxi
Tantalum		Jiujiang Tanbre Co., Ltd.		Jiangxi
Tantalum		LSM Brasil S.A.		Minas Gerais
Tantalum		Metallurgical Products India Pvt., Ltd.		Maharashtra
Tantalum		Mineracao Taboca S.A.		Amazonas
Tantalum		Mitsui Mining and Smelting Co., Ltd.		Fukuoka
Tantalum		NPM Silmet AS		Ida-Virumaa
Tantalum		QuantumClean		California
Tantalum		RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.		Hunan
Tantalum		Solikamsk Magnesium Works OAO		Permskiy kray
Tantalum		Taki Chemical Co., Ltd.		Hyogo
Tantalum		Telex Metals		Pennsylvania
Tantalum		Ulba Metallurgical Plant JSC		Qaraghandy oblysy
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		Hunan
Tantalum		D Block Metals, LLC		North Carolina

 

A-5

Metal		Processing Facility Name		Processing Facility Location
Tantalum		FIR Metals & Resource Ltd.		Hunan
Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		Jiangxi
Tantalum		XinXing HaoRong Electronic Material Co., Ltd.		Guangdong
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		Jiangxi
Tantalum		KEMET Blue Metals		Tamaulipas
Tantalum		H.C. Starck Co., Ltd.		Rayong
Tantalum		H.C. Starck Tantalum and Niobium GmbH		Niedersachsen
Tantalum		H.C. Starck Hermsdorf GmbH		Thüringen
Tantalum		H.C. Starck Inc.		Massachusetts
Tantalum		H.C. Starck Ltd.		Ibaraki
Tantalum		H.C. Starck Smelting GmbH & Co. KG		Baden-Württemberg
Tantalum		Global Advanced Metals Boyertown		Pennsylvania
Tantalum		Global Advanced Metals Aizu		Fukushima
Tantalum		KEMET Blue Powder		Nevada
Tantalum		Resind Industria e Comercio Ltda.		Minas gerais
Tantalum		Jiangxi Tuohong New Raw Material		Jiangxi
Tantalum		Power Resources Ltd.		Skopje
Tantalum		Jiujiang Janny New Material Co., Ltd.		Jiangxi
Tin		Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.		Hunan
Tin		Alpha		Pennsylvania
Tin		CV Gita Pesona		Kepulauan Bangka Belitung
Tin		PT Aries Kencana Sejahtera		Kepulauan Bangka Belitung
Tin		PT Premium Tin Indonesia		Kepulauan Bangka Belitung
Tin		CV United Smelting		Kepulauan Bangka Belitung
Tin		Dowa		Akita
Tin		EM Vinto		Oruro

 

A-6

Metal		Processing Facility Name		Processing Facility Location
Tin		Fenix Metals		Podkarpackie
Tin		Gejiu Non-Ferrous Metal Processing Co., Ltd.		Yunnan
Tin		Huichang Jinshunda Tin Co., Ltd.		Jiangxi
Tin		Gejiu Kai Meng Industry and Trade LLC		Yunnan
Tin		China Tin Group Co., Ltd.		Guangxi
Tin		Malaysia Smelting Corporation (MSC)		Pulau Pinang
Tin		Metallic Resources, Inc.		Ohio
Tin		Mineracao Taboca S.A.		São Paulo
Tin		Minsur		Ika
Tin		Mitsubishi Materials Corporation		Hyogo
Tin		Jiangxi New Nanshan Technology Ltd.		Jiangxi
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		Chon Buri
Tin		Operaciones Metalurgical S.A.		Oruro
Tin		PT Artha Cipta Langgeng		Kepulauan Bangka Belitung
Tin		PT Babel Inti Perkasa		Kepulauan Bangka Belitung
Tin		PT Bangka Tin Industry		Kepulauan Bangka Belitung
Tin		PT Belitung Industri Sejahtera		Kepulauan Bangka Belitung
Tin		PT Bukit Timah		Kepulauan Bangka Belitung
Tin		PT DS Jaya Abadi		Kepulauan Bangka Belitung
Tin		PT Karimun Mining		Kepulauan Riau
Tin		PT Mitra Stania Prima		Kepulauan Bangka Belitung
Tin		PT Panca Mega Persada		Kepulauan Bangka Belitung
Tin		PT Prima Timah Utama		Kepulauan Bangka Belitung
Tin		PT Refined Bangka Tin		Kepulauan Bangka Belitung
Tin		PT Sariwiguna Binasentosa		Kepulauan Bangka Belitung
Tin		PT Stanindo Inti Perkasa		Kepulauan Bangka Belitung

 

A-7

Metal		Processing Facility Name		Processing Facility Location
Tin		PT Sumber Jaya Indah		Kepulauan Bangka Belitung
Tin		PT Timah (Persero) Tbk Kundur		Riau
Tin		PT Timah (Persero) Tbk Mentok		Kepulauan Bangka Belitung
Tin		PT Tinindo Inter Nusa		Kepulauan Bangka Belitung
Tin		PT Tommy Utama		Kepulauan Bangka Belitung
Tin		Rui Da Hung		Taoyuan
Tin		Soft Metais Ltda.		São Paulo
Tin		Thaisarco		Phuket
Tin		Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.		Yunnan
Tin		White Solder Metalurgia e Mineracao Ltda.		Rondônia
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		Yunnan
Tin		Yunnan Tin Company Limited		Yunnan
Tin		CV Venus Inti Perkasa		Kepulauan Bangka Belitung
Tin		Magnu’s Minerais Metais e Ligas Ltda.		Minas Gerais
Tin		Melt Metais e Ligas S.A.		Rondônia
Tin		PT ATD Makmur Mandiri Jaya		Kepulauan Bangka Belitung
Tin		O.M. Manufacturing Philippines, Inc.		Cavite
Tin		PT Inti Stania Prima		Kepulauan Bangka Belitung
Tin		CV Ayi Jaya		Kepulauan Bangka Belitung
Tin		CV Dua Sekawan		Kepulauan Bangka Belitung
Tin		CV Tiga Sekawan		Kepulauan Bangka Belitung
Tin		Resind Industria e Comercio Ltda.		Minas gerais
Tin		Metallo Belgium N.V.		Antwerpen
Tin		Metallo Spain S.L.U.		Bizkaia
Tin		PT Bangka Prima Tin		Kepulauan Bangka Belitung
Tin		PT Sukses Inti Makmur		Kepulauan Bangka Belitung

 

A-8

Metal		Processing Facility Name		Processing Facility Location
Tin		PT Kijang Jaya Mandiri		Kepulauan Bangka Belitung
Tin		PT Menara Cipta Mulia		Kepulauan Bangka Belitung
Tin		HuiChang Hill Tin Industry Co., Ltd.		Jiangxi
Tin		Gejiu Fengming Metallurgy Chemical Plant		Yunnan
Tin		Guanyang Guida Nonferrous Metal Smelting Plant		Guangxi
Tin		Modeltech Sdn Bhd		Melaka
Tin		PT Lautan Harmonis Sejahtera		Kepulauan Bangka Belitung
Tin		Guangdong Hanhe Non-Ferrous Metal Co., Ltd.		Guangdong
Tin		Chifeng Dajingzi Tin Industry Co., Ltd.		Nei Mongol
Tin		PT Bangka Serumpun		Kepulauan Bangka Belitung
Tungsten		H.C. Starck Smelting GmbH & Co. KG		Baden-Württemberg
Tungsten		A.L.M.T. TUNGSTEN Corp.		Toyama
Tungsten		Kennametal Huntsville		Alabama
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		Guangdong
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		Jiangxi
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		Fujian
Tungsten		Global Tungsten & Powders Corp.		Pennsylvania
Tungsten		Hunan Chenzhou Mining Co., Ltd.		Hunan
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		Hunan
Tungsten		Japan New Metals Co., Ltd.		Akita
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		Jiangxi
Tungsten		Kennametal Fallon		Nevada
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		Tây Ninh
Tungsten		Wolfram Bergbau und Hutten AG		Steiermark
Tungsten		Xiamen Tungsten Co., Ltd.		Fujian
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		Guangdong

 

A-9

Metal		Processing Facility Name		Processing Facility Location
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		Jiangxi
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		Jiangxi
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		Jiangxi
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		Jiangxi
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		Yunnan
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		Fujian
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		Jiangxi
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		Jiangxi
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		Hunan
Tungsten		H.C. Starck Tungsten GmbH		Niedersachsen
Tungsten		Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC		Thái Nguyên
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		Jiangxi
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		Hunan
Tungsten		Niagara Refining LLC		New York
Tungsten		Ganzhou Haichuang Tungsten Co., Ltd.		Jiangxi
Tungsten		Hydrometallurg, JSC		Kabardino-Balkarskaya Respublika
Tungsten		Unecha Refractory metals plant		Bryanskaya oblast’
Tungsten		South-East Nonferrous Metal Company Limited of Hengyang City		Hunan
Tungsten		Philippine Chuangxin Industrial Co., Inc.		Bulacan
Tungsten		Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.		Jiangxi
Tungsten		ACL Metais Eireli		São Paulo
Tungsten		Woltech Korea Co., Ltd.		Gyeongsangbuk-do
Tungsten		Moliren Ltd.		Moskovskaja oblast’

 

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Table 2. Active processing facilities as of March 7, 2019.

The following processing facilities that were reported as being in the Company’s supply chain have been confirmed as Active:

 

Metal		Processing Facility Name		Processing Facility Location
Gold		Chugai Mining		Tokyo
Gold		KGHM Polska Miedz Spolka Akcyjna		Dolnośląskie
Gold		Bangalore Refinery		Karnataka
Tin		Gejiu Zili Mining And Metallurgy Co., Ltd.		Yunnan

Table 3. Processing facilities not Conformant or Active as of March 7, 2019.

The following processing facilities that were reported as being in the Company’s supply chain have not been confirmed as Conformant or Active:

 

Metal		Processing Facility Name		Processing Facility Location
Gold		Abington Reldan Metals, LLC		Pennsylvania
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		İstanbul
Gold		Caridad		Sonora
Gold		Yunnan Copper Industry Co., Ltd.		Yunnan
Gold		Daye Non-Ferrous Metals Mining Ltd.		Hubei
Gold		Refinery of Seemine Gold Co., Ltd.		Gansu
Gold		Guoda Safina High-Tech Environmental Refinery Co., Ltd.		Shandong

 

A-11

Metal		Processing Facility Name		Processing Facility Location
Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.		Zhejiang
Gold		Hunan Chenzhou Mining Co., Ltd.		Hunan
Gold		HwaSeong CJ CO., LTD.		Gyeonggi-do
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		Sverdlovskaya oblast’
Gold		Kazakhmys Smelting LLC		Qaraghandy oblysy
Gold		L’azurde Company For Jewelry		Ar Riyad
Gold		Lingbao Gold Co., Ltd.		Henan
Gold		Lingbao Jinyuan Tonghui Refinery Co., Ltd.		Henan
Gold		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.		Henan
Gold		Navoi Mining and Metallurgical Combinat		Navoiy
Gold		Penglai Penggang Gold Industry Co., Ltd.		Shandong
Gold		Sabin Metal Corp.		North Dakota
Gold		Samwon Metals Corp.		Gyeongsangnam-do
Gold		Shandong Tiancheng Biological Gold Industrial Co., Ltd.		Shandong
Gold		Great Wall Precious Metals Co., Ltd. of CBPM		Sichuan
Gold		Tongling Nonferrous Metals Group Co., Ltd.		Anhui
Gold		Morris and Watson		Auckland

 

A-12

Metal		Processing Facility Name		Processing Facility Location
Gold		SAFINA A.S.		Praha-západ
Gold		Guangdong Jinding Gold Limited		Guangdong
Gold		Fidelity Printers and Refiners Ltd.		Harare
Gold		Kaloti Precious Metals		Dubayy
Gold		Sudan Gold Refinery		Khartoum
Gold		Tony Goetz NV		Antwerpen
Gold		TOO Tau-Ken-Altyn		Almaty
Gold		GCC Gujrat Gold Centre Pvt. Ltd.		Gujarat
Gold		Sai Refinery		Himachal Pradesh
Gold		Universal Precious Metals Refining Zambia		Lusaka
Gold		Modeltech Sdn Bhd		Melaka
Gold		Kyshtym Copper-Electrolytic Plant ZAO		Chelyabinskaya oblast’
Gold		Morris and Watson Gold Coast		Queensland
Gold		Degussa Sonne / Mond Goldhandel GmbH		Baden-Württemberg
Gold		Pease & Curren		Rhode Island
Gold		State Research Institute Center for Physical Sciences and Technology		Vilnius
Tin		Estanho de Rondonia S.A.		Rondônia
Tin		Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company		Cao Bang

 

A-13

Metal		Processing Facility Name		Processing Facility Location
Tin		Nghe Tinh Non-Ferrous Metals Joint Stock Company		Nghe An
Tin		Tuyen Quang Non-Ferrous Metals Joint Stock Company		Tuyên Quang
Tin		An Vinh Joint Stock Mineral Processing Company		Nghe An
Tin		Super Ligas		São Paulo
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		Jiangxi

 

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