BioTelemetry, Inc.

Conflict Minerals Report for the year ended December 31, 2015

This Conflict Minerals Report of BioTelemetry, Inc. for the year ended December 31, 2015 is provided pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the U.S. Securities and Exchange Commission (the “SEC”) to implement disclosure and reporting requirements pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. As permitted by the Rule and in accordance with guidance issued by the SEC on April 29, 2014, this report has not been subject to an independent private sector audit.

1. Introduction

BioTelemetry, Inc. (hereinafter “BioTelemetry”, the “Company”, “we”, “us”, or “our”) provides cardiac monitoring services, cardiac monitoring device manufacturing, and centralized cardiac core laboratory services. Since the Company became focused on cardiac monitoring in 1999, the Company has developed a proprietary integrated patient management platform that incorporates a wireless
data transmission network, Food and Drug Administration (“FDA”) cleared algorithms and medical devices, and 24-hour digital monitoring service centers.

This report has been prepared by the management of BioTelemetry. This report does not include the activities of entities that are not required to be consolidated in our financial statements.

In accordance with the Rule, this report is available on our website: http://investors.gobio.com/wp-content/uploads/2016/05/FORMSD-Exhibit-1.01.pdf

2. Supply chain description and Reasonable Country of Origin Inquiry

2.1 General information on BioTelemetry’s supply chain

The hardware provided by BioTelemetry largely consists of electronics. Our supply chain is complex with multiple tiers of suppliers and we are a remote downstream participant. For manufacturing, BioTelemetry purchases customized and standardized components from several global providers as well as from local and regional suppliers, either off-the-shelf or in accordance with Biotelemetry’s
design or specifications. Certain types of components are produced in-house. The production of printed circuit boards and molded plastic components is mostly outsourced to manufacturing services companies. Final configuration of products is largely done in-house and on-demand. This consists of assembling and testing modules and integrating them into complete units.

2.2 Overview of BioTelemetry’s Conflict Minerals Program and Reasonable Country of Origin Inquiry 2015

BioTelemetry gathers conflict minerals information from our suppliers. Through this we know that many of our products contain tin, tantalum, tungsten and gold (“3TG”) that are necessary to the functionality of those products.

As part of BioTelemetry’s commitment to responsible sourcing, human rights and sustainability, it is our goal that the 3TG in our products should not, directly or indirectly, finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries (the “DRC”). At the same time, we aim to continue supporting responsible mineral sourcing in the region. BioTelemetry’s efforts with respect to 3TG are aligned to the work of the Conflict-Free Sourcing Initiative (“CFSI”) and our aim is to improve the traceability in our supply chain.

BioTelemetry does not ban materials from the DRC or avoid using 3TGs. The Company has a program team and utilizes outside advisors to fulfill compliance with the Rule, perform the Reasonable Country of Origin Inquiry and report on 3TG. This team is responsible for BioTelemetry’s 3TG implementation work and senior management is regularly informed about matters relating to 3TG.

BioTelemetry relies on its first tier suppliers to provide information on the origin of 3TG contained in components and parts included in BioTelemetry’s products. This includes sources of 3TG that are supplied to them from sub-suppliers. Our first tier suppliers are similarly reliant upon information provided by their upstream suppliers. Certain of BioTelemetry’s large hardware suppliers are also
SEC registrants and subject to the Rule.

The identification of first tier suppliers of BioTelemetry that are in scope under the Rule involves different regions, business units and production sites that are part of BioTelemetry’s global organization. The sourcing organization has an important role in leading and coordinating the work. Suppliers identified to be in scope are first tier suppliers of BioTelemetry supplying (i) products containing 3TG that BioTelemetry contracts to manufacture, (ii) materials, parts, components and other products, containing 3TG, that are incorporated into or included in a product manufactured by BioTelemetry, or (iii) materials used in the production of BioTelemetry’s products where 3TG becomes part of the final product. Suppliers of products that BioTelemetry does not contract to manufacture (i.e.products purchased “off-the shelf”) and not included in, or incorporated into, a BioTelemetry product have been considered out of scope for purposes of the Rule. In our annual inquiry we survey first tier suppliers identified to be in scope and analyze and follow up upon responses as we deem appropriate. Accordingly, during 2015, BioTelemetry conducted a reasonable country of origin inquiry to determine the origin of the 3TG in BioTelemetry’s products.

BioTelemetry believes that industry cooperation is one of the best ways to address issues related to 3TG in an efficient and transparent way. BioTelemetry is engaged and actively cooperates with supply-chain participants and supports the 3TG industry initiatives such as the CFSI driven by the Global e-Sustainability Initiative (GeSI) and the Electronic Industry Citizenship Coalition (EICC).

In accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”), we support the CFSI’s audit of smelters’ and refiners’ due diligence activities. In our internal processes, we use information obtained using CFSI’s Reasonable
Country of Origin Inquiry Data for BioTelemetry.

The Company has identified the following products that may contain Conflict Minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by Universal Medical, Inc.: Pacetrak Plus, Pacetrak ENR, Pacetrak Speaks, Heartrak Smart, Heartrak Smart AF, Heartrak 2, Heartrak ECAT, Heartrak TCAT, Heartrak ECAT2, Heartrak Smart Wireless, and
Cardiostation Transtelephonic Module.

The Company has identified the following products that may contain Conflict Minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by Braemar: DL800, DL900, DL1200, DTXT, PORT/DOCK, ER8, ER9, ER920W, LOOPER, PER900, Fusion, C5, PSITECIII, CardioKey, and EZPUMP.

3. Due Diligence

BioTelemetry has processes in place for the purpose of exercising due diligence in the supply chain. The design of the due diligence processes conforms substantially to the OECD Guidance as it relates to “downstream” purchasers of products and components. Our position in the supply chain is remote. We do not have a direct relationship with mining companies or with 3TG smelters and refiners,
nor do we perform direct audits of these entities that provide our supply chain with 3TG. We rely upon industry efforts to influence smelters and refiners to be audited and certified through CFSI’s Conflict Free Smelter Program.

The due diligence processes have been described below under sub-headings corresponding to the five-step framework of the OECD Guidance.

3.1 Maintain strong management systems

The first step relates to strong management systems. As mentioned above, BioTelemetry has established a program team for reporting on 3TG and compliance with the Rule. This team is responsible for the 3TG implementation work and senior management is regularly informed about matters relating to 3TG. Controls include, but are not limited to, supplier requirements relating to 3TG as described above and are integrated in our template supplier agreements.

With respect to 2015, identification of smelters/refiners in our supply chain was made via the use of due diligence tools created by the CFSI, including the EICC/GeSI Conflict Minerals Reporting Template 4.01 (the “Template”). The Template is a supply chain survey designed to identify the smelters and refiners that process the necessary 3TG contained in our supply chain. The information from our suppliers, in combination with information from the CFSI, helps BioTelemetry to obtain information on the origin of minerals processed. Data obtained was reviewed and analyzed by BioTelemetry.

We have grievance mechanisms, notably a whistleblower tool, managed by an external service provider, for the reporting of alleged violations of laws or the Code of Business Ethics that relate to corruption, questionable accounting, or auditing matters that seriously affect vital interests of the Group or Compliance, in general. Violations reported through the whistleblower tool are handled by
BioTelemetry’s Group Compliance Forum, consisting of representatives from BioTelemetry’s Group Function Legal Affairs and Group Function Human Resources. Information regarding incidents is reported to the Compliance and Audit Committees. Reports include measures taken, details of the responsible Group function and the status of any investigation.

3.2 Identify and assess risk in the supply chain

In the second step, risks are identified and assessed. Downstream companies should, with help from their first tier suppliers, identify smelters and refiners in the supply chain.

In BioTelemetry’s 2015 survey, first tier suppliers identified to be in scope were requested by BioTelemetry to provide information on 3TG in their supply chain through completing and submitting the Template. Suppliers were provided with support material, including the generally available instructions and training illustrating the use of the tool that is available on CFSI’s website. To ensure sufficient quality, a high response rate and to minimize risks, the responses received were continuously analyzed and followed up as deemed appropriate. The data obtained was saved, reviewed and analyzed by BioTelemetry. Supplier responses were reviewed against criteria
developed to determine which responses required further engagement with our suppliers. These criteria were developed to identify whether the responses from suppliers were incomplete and where further inquiries were necessary. Suppliers were contacted via email or telephone to improve the quality of responses and increase the response rate.

We have had a risk based approach focused on suppliers with incomplete data since they are typically deemed to constitute a higher risk. As part of the risk mitigation efforts, additional efforts were mainly targeted at suppliers that are awarded large parts of our business on an ongoing basis.

3.3 Design and implement a strategy to respond to identified risks

Under the third step companies are encouraged to design and implement a strategy to respond to identified risks. Due diligence within BioTelemetry is an on-going process, both proactive and reactive, where suppliers are continuously evaluated against BioTelemetry’s requirements to ensure that these requirements are systematically incorporated in the suppliers’ processes.

We continuously work to improve our due diligence processes with respect to 3TG, mainly focusing on the quality of data received from suppliers surveyed. This includes communication and collaboration with suppliers for purposes of improving the response rate of surveyed suppliers and improving the reliability and quality of the information provided. As described above, we have a risk based approach when reviewing and following up supplier responses and we generally prioritize suppliers that we frequently purchase from.

3.4 Independent third party audit of smelters’/refiners’ due diligence practices

The fourth step focuses on analysis of smelters’/refiners’ due diligence practices. We support the Conflict Free Smelter Program (“CFSP”) as well as the development and implementation of due diligence practices and tools such as the Template. Due to the structure of our supply chain, there can be many tiers of suppliers between BioTelemetry and the smelters and refiners in the supply chain. We analyze the received data on smelters and refiners and compare such information against the list of facilities that have received a “conflict free” designation from the CFSP. Via the CFSI we also can access information on country of origin and due diligence information on the 3TG sourced by such facilities.

3.5 Report annually on supply chain due diligence

The fifth step encourages reporting on supply chain due diligence. We have a public statement on 3TG on our external website and strive to continuously increase 3TG awareness within BioTelemetry and among suppliers. BioTelemetry’s public statement on the sourcing of 3TG is available on our website: http://investors.gobio.com/wp-content/uploads/2016/05/FORM-SD-Exhibit-1.01.pdf
In accordance with the Rule, we make our Conflict Minerals Report available on our website: http://investors.gobio.com/wpcontent/uploads/2015/05/Product-Components-and-Conflict-Minerals-Policy1.pdf

4. 2015 due diligence results

For the calendar year 2015, our inquiries were made on the supplier level. Inquiries also include responses where suppliers were unable to specify the smelters or refiners used for components supplied to us and certain responses included names of smelters or refiners that we believe may have been misidentified as smelters or refiners that we believe are not operational. Such names have not
been listed among identified smelters and refiners.

The response rate among suppliers surveyed in 2015 was 89.4%. A higher response rate was achieved in the group of suppliers that are awarded a larger part of our business. Among the supplier responses, we identified approximately 400 unique smelters as potential sources of 3TG that were reported to be in the supply chain at some point during the 2015 calendar year. The following table presents, by mineral, the percentages of identified smelters or refiners in our supply chain that have been verified as conflict-free or pledged or committed to CFSI validation.

We have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the locations of origin of the 3TG in our supply chain. A list of identified smelters, by mineral, is contained in “Annex 1.”

During 2016, we expect to continue to review and evolve our due diligence processes with respect to 3TG. As part of these efforts, we expect to collaborate with suppliers for purposes of further improving the supplier response rate and the reliability and quality of information provided.

Due to the size, breadth and complexity of our products, and the constant evolution of our supply chain, the process of successfully tracing all of the conflict minerals used in our products back to their country of origin will require additional time and resources. We are committed to implementing processes to improve the quantity and quality of responses from our supply chain and to verifying the
accuracy and completeness of the information we receive directly from suppliers or which is otherwise available to us through industry and other initiatives.

Our ability to make determinations about the presence and source of origin of 3TGs in our products depends upon a number of factors including, but not limited to, (i) the respective due diligence efforts of our tier one suppliers and their supply chain, as well as their willingness to disclose such information to us, and (ii) the ability and willingness of our supply chain to adopt the OECD Guidance and other initiatives or guidance that may develop over time with respect to responsible sourcing. The failure to obtain reliable information from any level of our supply chain could have a material impact on our ability to provide meaningful information on the presence and origin of 3TGs in our products’ supply chain with any reasonable degree of certainty. There can be no assurance that our suppliers will continue to cooperate with our diligence inquiries and our requests for certifications or to provide us with the documentation or other evidence that we consider reliable or in a time frame sufficient to allow us to make a reasonable and reliable assessment following appropriate further diligence measures, as may be required.

5. Forward Looking Statements

Certain of the matters discussed in this report, including in particular our due diligence processes with respect to 3TG, include forward-looking statements. Readers of this document are cautioned that our forward-looking statements are not guarantees of our future actions, which may differ materially from the expectations expressed in the forward-looking statements. We expressly disclaim a duty to provide updates to these forward-looking statements after the date of this filing to reflect events or changes in circumstances or changes in expectations or the occurrence of anticipated events. The information included on any websites that appear in this report and other materials referenced to is not incorporated by reference in this report.


Smelter List and Country of Origin List

Metal Smelter Name (* indicates CFSI Compliant Conflict-Free Smelter, ** indicates CFSI Active Smelter)

Gold Advanced Chemical Company **
Gold Aida Chemical Industries Co. Ltd.*
Gold Al Etihad Gold Refinery DMCC
Gold Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold Almalyk Mining and Metallurgical Complex (AMMC)**
Gold AngloGold Ashanti Córrego do Sítio Minerção*
Gold Argor-Heraeus SA*
Gold Asahi Pretec Corp*
Gold Asaka Riken Co Ltd*
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold Aurubis AG*
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*
Gold Boliden AB*
Gold C. Hafner GmbH + Co. KG*
Gold Caridad Gold CCR Refinery – Glencore Canada Corporation*
Gold Cendres + Métaux SA**
Gold Chimet S.p.A.*
Gold Chugai Mining
Gold Daejin Indus Co., Ltd.**
Gold Daye Non-Ferrous Metals Mining Ltd.
Gold Do Sung Corporation**
Gold Doduco*
Gold Dowa*
Gold Eco-System Recycling Co., Ltd.*
Gold Emirates Gold DMCC*
Gold Faggi Enrico S.p.A.**
Gold Fidelity Printers and Refiners Ltd.
Gold FSE Novosibirsk Refinery*
Gold Gansu Seemine Material Hi-Tech Co., Ltd.
Gold Geib Refining Corporation**
Gold Great Wall Precious Metals Co., Ltd. of CBPM
Gold Guangdong Jinding Gold Limited
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold Heimerle + Meule GmbH*
Gold Heraeus Ltd. Hong Kong*
Gold Heraeus Precious Metals GmbH & Co. KG*
Gold Hunan Chenzhou Mining Group Co., Ltd.
Gold Hwasung CJ Co., Ltd.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited*
Gold Ishifuku Metal Industry Co., Ltd.*
Gold Istanbul Gold Refinery*
Gold Japan Mint*
Gold Jiangxi Copper Company Limited*
Gold Johnson Matthey Inc*
Gold Johnson Matthey Ltd*
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
Gold JSC Uralectromed*
Gold JX Nippon Mining & Metals Co., Ltd*
Gold Kaloti Precious Metals
Gold Kazakhmys Smelting LLC
Gold Kazzinc Ltd*
Gold Kennecott Utah Copper LLC*
Gold Gold Kojima Chemicals Co., Ltd*
Gold Korea Zinc Co. Ltd.**
Gold Kyrgyzaltyn JSC
Gold L' azurde Company For Jewelry
Gold Lingbao Gold Company Limited 
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold LS-NIKKO Copper Inc.*
Gold Luoyang Zijin Yinhui Gold Refinery 
Co., Ltd. Gold Materion*
Gold Matsuda Sangyo Co., Ltd.*
Gold Met-Mex Peñoles, S.A.*
Gold Metalor Technologies (Hong Kong) Ltd*
Gold Metalor Technologies (Singapore) Pte. Ltd.*
Gold Metalor Technologies (Suzhou) Ltd.**
Gold Metalor Technologies SA*
Gold Metalor USA Refining Corporation*
Gold Mitsubishi Materials Corporation*
Gold Mitsui Mining and Smelting Co., Ltd.*
Gold MMTC-PAMP India Pvt., Ltd.*
Gold Morris and Watson
Gold Moscow Special Alloys Processing Plant*
Gold Gold Navoi Mining and Metallurgical Combinat**
Gold Nihon Material Co. LTD*
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
Gold Ohio Precious Metals, LLC*
Gold Ohura Precious Metal Industry Co., Ltd*
Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
Gold PAMP SA*
Gold Penglai Penggang Gold Industry Co., Ltd. 
Gold Prioksky Plant of Non-Ferrous Metals*
Gold PT Aneka Tambang (Persero) Tbk*
Gold PX Précinox SA*
Gold Rand Refinery (Pty) Ltd*
Gold Republic Metals Corporation*
Gold Royal Canadian Mint*
Gold Sabin Metal Corp.
Gold Samduck Precious Metals**
Gold SAMWON METALS Corp.
Gold SAXONIA Edelmetalle GmbH**
Gold Schone Edelmetaal*
Gold SEMPSA Joyería Platería SA*
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co. Ltd*
Gold Sichuan Tianze Precious Metals Co., Ltd.*
Gold Singway Technology Co., Ltd.*
Gold So Accurate Group, Inc.
Gold SOE Shyolkovsky Factory of Secondary Precious Metals*
Gold Solar Applied Materials Technology Corp.*
Gold Sumitomo Metal Mining Co., Ltd.*
Gold T.C.A S.p.A*
Gold Tanaka Kikinzoku Kogyo K.K.*
Gold The Refinery of Shandong Gold Mining Co. Ltd*
Gold Tokuriki Honten Co. Ltd*
Gold Tongling nonferrous Metals Group Co.,Ltd
Gold Torecom**
Gold Umicore Brasil Ltda*
Gold Umicore Precious Metals Thailand*
Gold Umicore SA Business Unit Precious Metals Refining*
Gold United Precious Metal Refining, Inc.*
Gold Valcambi SA*
Gold Western Australian Mint trading as The Perth Mint*
Gold WIELAND Edelmetalle GmbH**
Gold YAMAMOTO PRECIOUS METAL CO., LTD.*
Gold Yokohama Metal Co Ltd*
Gold Yunnan Copper Industry Co Ltd
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
Gold Zijin Mining Group Co. Ltd*

Tantalum Changsha South
Tantalum Niobium Co., Ltd.*
Tantalum Conghua Tantalum and Niobium Smeltry*
Tantalum D Block Metals, LLC*
Tantalum Duoluoshan*
Tantalum Exotech Inc.*
Tantalum F&X Electro-Materials Ltd.*
Tantalum FIR Metals & Resource Ltd.*
Tantalum Global Advanced Metals Boyertown*
Tantalum Global Advanced Metals*
Tantalum Guangdong Zhiyuan New Material Co., Ltd.*
Tantalum H.C. Starck Co., Ltd.*
Tantalum H.C. Starck GmbH Goslar*
Tantalum H.C. Starck GmbH Laufenburg*
Tantalum H.C. Starck Hermsdorf GmbH*
Tantalum H.C. Starck Inc.*
Tantalum H.C. Starck Ltd.*
Tantalum H.C. Starck Smelting GmbH & Co.KG*
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd.*
Tantalum Hi-Temp* Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Tantalum Jiujiang Tanbre Co., Ltd.*
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
Tantalum KEMET Blue Metals*
Tantalum Kemet Blue Powder*
Tantalum King-Tan Tantalum Industry Ltd* Tantalum LSM Brasil S.A.* Tantalum Metallurgical Products India (Pvt.) Ltd.*
Tantalum Mineração Taboca S.A.*
Tantalum Mitsui Mining & Smelting*
Tantalum Molycorp Silmet A.S.*
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.*
Tantalum Plansee SE Liezen* Tantalum Plansee SE Reutte*
Tantalum QuantumClean* Tantalum Resind Indústria e Comércio Ltda.*
Tantalum RFH Tantalum Smeltry Co., Ltd* Tantalum Solikamsk Metal Works* Tantalum Taki Chemicals* Tantalum Telex*
Tantalum Tranzact, Inc.* Tantalum Ulba*
Tantalum XinXing HaoRong Electronic Material Co., Ltd.*
Tantalum Yichun Jin Yang Rare Metal Co., Ltd.*
Tantalum Zhuzhou Cement Carbide* Tin Alpha*

Tin An Vinh Joint Stock Mineral Processing Company**
Tin Chenzhou Yunxiang Mining Smelting Company LTD**
Tin China Tin Group Co., Ltd.*
Tin CNMC (Guangxi) PGMA Co. Ltd. Tin Cooper Santa*
Tin CV Ayi Jaya* Tin CV Gita Pesona* Tin CV JusTindo*
Tin CV Nurjanah*
Tin CV Serumpun Sebalai* Tin CV United Smelting*
Tin CV Venus Inti Perkasa* Tin Dowa*
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company**
Tin Elmet S.L.U. (Metallo Group)*
Tin EM Vinto*
Tin Estanho de Rondônia S.A.
Tin Fenix Metals*
Tin Gejiu Jin Ye Mineral Co., Ltd.**
Tin Gejiu Kai Meng Industry and Trade LLC**
Tin Gejiu Non-Ferrous Metal Processing Co. Ltd.*
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.**
Tin Gejiu Zi-Li Tin Huichang Jinshunda Tin Co. Ltd
Tin Jiangxi Ketai Advanced Material Co., Ltd.*
Tin Jiangxi Nanshan Tin Linwu Xianggui Ore Smelting Co., Ltd.
Tin Magnu's Minerais Metais e Ligas LTDA*
Tin Malaysia Smelting Corporation (MSC)*
Tin Melt Metais e Ligas S/A*
Tin Metallic Resources Inc*
Tin METALLO-CHIMIQUE N.V. (MC)*
Tin Mineração Taboca S.A.* Tin Minsur*
Tin Mitsubishi Materials Corporation*
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company**
Tin O.M. Manufacturing (Thailand) Co., Ltd.*
Tin O.M. Manufacturing Philippines, Inc.*
Tin Operaciones Metalurgical S.A.*
Tin Phoenix Metal Ltd.**
Tin PT Artha Cipta Langgeng*
Tin PT ATD Makmur Mandiri Jaya*
Tin PT Babel Inti Perkasa*
Tin PT Bangka Prima Tin*
Tin PT Bangka Tin Industry*
Tin PT Belitung Industri Sejahtera*
Tin PT BilliTin Makmur Lestari*
Tin PT Bukit Timah*
Tin PT Cipta Persada Mulia*
Tin PT DS Jaya Abadi*
Tin PT DS Jaya Abadi**
Tin PT Eunindo Usaha Mandiri*
Tin PT Inti Stania Prima*
Tin PT Karimun Mining**
Tin PT Mitra Stania Prima*
Tin PT Panca Mega Persada*
Tin PT Prima Timah Utama*
Tin PT REFINED BANGKA TIN*
Tin PT Sariwiguna Binasentosa*
Tin PT Stanindo Inti Perkasa*
Tin PT Sukses Inti Makmur*
Tin PT Sumber Jaya Indah*
Tin PT Tambang Timah*
Tin PT Timah (Persero) Tbk Mentok*
Tin PT Tinindo Inter Nusa*
Tin PT Tirus Putra Mandiri Tin PT Tommy Utama*
Tin PT Wahana Perkit Jaya*
Tin Resind Indústria e Comércio Ltda.*
Tin Rui Da Hung* Tin Soft Metais, Ltda.* Tin Thaisarco*
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company**
Tin VQB Mineral and Trading Group JSC*
Tin White Solder Metalurgia e Mineração Ltda.*
Tin Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.**
Tin Yunnan Tin Company, Ltd.* Tungsten A.L.M.T. Corp.*

Tungsten Asia Tungsten Products Vietnam Ltd.*
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd.*
Tungsten Chongyi Zhangyuan Tungsten Co Ltd*
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten Dayu Weiliang Tungsten Co., Ltd.
Tungsten Fujian Jinxin Tungsten Co., Ltd.*
Tungsten Ganxian Shirui New Material Co., Ltd.
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd.*
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.**
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.*
Tungsten Ganzhou Yatai Tungsten Co., Ltd.*
Tungsten Global Tungsten & Powders Corp.*
Tungsten Guangdong Xianglu Tungsten Co., Ltd.*
Tungsten H.C. Starck GmbH*
Tungsten H.C. Starck Smelting GmbH & Co.KG*
Tungsten Hunan Chenzhou Mining Group Co., Ltd.*
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
Tungsten Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.* Tungsten Hydrometallurg, JSC*
Tungsten Japan New Metals Co Ltd*
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.**
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.*
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.**
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.*
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd.**
Tungsten Kennametal Fallon**
Tungsten Kennametal Huntsville*
Tungsten Malipo Haiyu Tungsten Co., Ltd.*
Tungsten Niagara Refining LLC*
Tungsten Nui Phao H.C. Starck
Tungsten Chemicals Manufacturing LLC*
Tungsten Tejing (Vietnam) Tungsten Co., Ltd.*
Tungsten Vietnam Youngsun
Tungsten Industry Co., Ltd*
Tungsten Wolfram Bergbau und Hütten AG*
Tungsten Wolfram Company CJSC Tungsten Xiamen Tungsten (H.C.) Co., Ltd.* Tungsten Xiamen Tungsten Co., Ltd*
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd.*

Country of Origin List 3
Angola France Portugal Argentina Germany Republic of Congo Australia Guyana Russia Austria Hungary Rwanda Belgium India Sierra Leone Bolivia Indonesia Singapore Brazil Ireland Slovakia Burundi Israel South Africa Cambodia Japan South Korea Canada Kazakhstan South Sudan Central African Republic Kenya Spain Chile Laos Suriname China Luxembourg Switzerland Colombia Madagascar Taiwan Côte D'Ivoire Malaysia Tanzania Czech Republic Mongolia Thailand Democratic Republic of Congo Mozambique Uganda Djibouti Myanmar United Kingdom Ecuador Namibia United States of America Egypt Netherlands Vietnam Estonia Nigeria Zambia Ethiopia Peru Zimbabwe

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