Document

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM SD

Specialized Disclosure Report

AVANOS MEDICAL, INC.

(Exact name of registrant as specified in its charter)

DELAWARE

001-36440

46-4987888

(State or other jurisdiction of
incorporation)

(Commission File Number)

(I.R.S. Employer
Identification No.)

5405 Windward Parkway
Suite 100 South
Alpharetta, Georgia

30004

(Address of principal executive officers)

(Zip Code)

Michael C. Greiner
Senior Vice President - Chief Financial Officer
(470) 448-5000

(Name and Telephone number, including area code, of the person to contact in connection with this report)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.

SECTION 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

This Specialized Disclosure Report on Form SD by Avanos Medical, Inc. is for the period from January 1, 2019 to December 31, 2019. Unless the context otherwise indicates, “Avanos,” “Company,” “we,” “us” and “our” refer to Avanos Medical, Inc. and its consolidated subsidiaries.

During 2019, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs, as defined below, are necessary to their functionality or production (“Covered Products”). Conflict minerals are defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (together with gold collectively referred to as “3TGs”), 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. Accordingly, we have conducted a reasonable country of origin inquiry (“RCOI”) that was designed to determine whether any of the 3TGs in our Covered Products originated in the DRC or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia), or were from recycled or scrap sources.

A summary of our RCOI, as well as the steps taken to exercise due diligence on the source and chain of custody of any 3TGs in our Covered Products, is included in our Conflict Minerals Report (“Report”), which is filed as Exhibit 1.01 to this Form SD. In addition, our Report and Form SD is publicly available on our Company website at https://avanos.investorroom.com.

Forward-Looking Statements

The Report contains forward-looking statements that express a belief, expectation or intention, including statements relating to our compliance efforts and expected actions. The words “expects,” “intends,” “plans,” “believes,” “anticipates” and similar expressions can indicate forward-looking statements. These statements are not guarantees of future actions or performance and are subject to various risks, uncertainties and assumptions. Future actions or performance may differ materially from those in the forward-looking statements. Undue reliance should not be placed on these statements, which are only effective as of the date of this Report, and the Company undertakes no obligation to publicly update or revise any forward-looking statement.

Item 1.02 Exhibit.

We have filed our Conflict Minerals Report as Exhibit 1.01 to this Form SD.

Item 2.01 Exhibits.

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01. and 1.02 of Form SD.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

AVANOS MEDICAL, INC.

DATE: May 27, 2020

By:

/s/ Michael C. Greiner

Michael C. Greiner
Senior Vice President and Chief Financial Officer

EXHIBIT INDEX


Exhibit Number						Description
1.01						Conflict Minerals Report for the year ended December 31, 2019 as required by Items 1.01 and 1.02 of this Form.

Document

EXHIBIT 1.01

Avanos Medical, Inc.

Conflict Minerals Report

For the Year Ended December 31, 2019

I.Introduction

This Conflict Minerals Report (“Report”) by Avanos Medical, Inc., is for the period from January 1, 2019 to December 31, 2019 (“Reporting Period”). Unless the context otherwise indicates, “Avanos,” “Company,” “we,” “us,” and “our” mean Avanos Medical, Inc. and its consolidated and combined subsidiaries.

This Report is intended to comply with Rule 13p-1 of the Securities Exchange Act of 1934, as amended (“Rule”). The Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines “conflict minerals” as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold (“3TGs”) that are necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.

As described in this report, Avanos has reason to believe that some of the 3TGs present in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, “Covered Countries”). Therefore, we performed a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TGs in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries, and we proceeded to conduct due diligence on our supplier base. The results of our due diligence are discussed below.

II.Company Overview

A.Our Business

Avanos is a medical technology company focused on delivering clinically superior breakthrough medical device solutions to improve patients’ quality of life. Avanos is committed to addressing some of today’s most important healthcare needs, such as reducing the use of opioids while helping patients move from surgery to recovery. Avanos develops, manufactures and markets its recognized brands in more than 90 countries.

The address of Avanos’ principal executive office is 5405 Windward Parkway, Suite 100 South, Alpharetta, Georgia 30004, and our telephone number is (404) 448-5000.

B.Business Segment

We conduct our business in one operating and reportable segment that provides our medical device products to healthcare providers and patients, and we have manufacturing facilities in the United States, Mexico, France, Germany and Tunisia. We provide a portfolio of innovative product offerings focused on chronic care and pain management to improve patient outcomes and reduce the cost of care.

Chronic Care is a portfolio of products that includes (i) digestive health products and (ii) respiratory health products. The digestive health product category accounted for 38% of our consolidated net sales in the year ended December 31, 2019. Digestive health products include our MIC-KEY enteral feeding tubes, CORPAK patient feeding solutions and our recently acquired NEOMED neonatal and pediatric feeding solutions. The respiratory health product category accounted for 21% of our consolidated net sales in the year ended December 31, 2019. Respiratory health products include closed airway suction systems and other airway management devices under the BALLARD and MICROCUFF brands.

Pain Management is a portfolio of products that includes (i) acute pain products and (ii) interventional pain solutions. The acute pain product category accounted for 27% of our consolidated net sales in the year ended December 31, 2019. Acute pain includes ON-Q and our recently acquired AMBIT surgical pain pumps and GAME READY cold and compression therapy systems. Our interventional pain product category accounted for 14% of our consolidated net sales in the year ended December 31, 2019. Interventional pain provides minimally invasive pain relieving therapies, such as our COOLIEF pain relief therapy.

C.Our Products

For the Reporting Period, as applicable, we conducted an analysis of our Chronic Care and Pain Management products to determine which, if any, were likely to contain 3TGs. The analysis identified that 3TGs were necessary to the functionality or

production of certain products that we manufactured or contracted to manufacture during the Reporting Period. This was the case especially for the electrical components of such products.

III.Description of Reasonable Country of Origin Inquiry (“RCOI”)

We began our scoping process by developing a list of our suppliers that provide us with products that may contain one or more of the 3TGs. We then populated the list with contact information and provided it to our third-party service provider (“Service Provider”). The supplier list was then uploaded to our Service Provider’s software tool that allows us to store and manage supplier requests and documentation.

Our Service Provider then conducted the supplier survey portion of the RCOI utilizing the Conflict Minerals Reporting Template (“CMRT”), version 5.12 or higher, developed by the Responsible Business Alliance and The Global e-Sustainability Initiative. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, due diligence process, and supply chain, including such supply chain information as the names and locations of smelters and refiners.

As part of the supplier survey, suppliers were asked to complete the CMRT. All communications were tracked and monitored in the Service Provider’s software tool. Non-responsive suppliers were contacted a minimum of 3 times. Any suppliers that continued to be non-responsive were advanced to an escalation phase and further contacted on an individual basis.

To ensure that our suppliers understood our expectations regarding the sourcing of 3TGs, we and our Service Provider offered training to them though webinars, videos, documents, and one-on-one discussions. The offering included our Service Provider’s Learning Management System, which allowed access to our Service Provider’s Conflict Minerals training course. This training was tracked based on completion. All suppliers were encouraged to complete all the modules in the course.

The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions. All submitted CMRTs were classified as valid or invalid. All suppliers who submitted CMRTs that were classified as invalid were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our Service Provider’s software system. As of May 11, 2020, there were only 12 invalid submissions that had not been corrected by suppliers.

Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we conducted due diligence on our supplier base.

IV.Due Diligence

A.Design of Due Diligence

We designed our due diligence procedures to conform, in all material respects, with the due diligence framework presented by the Organisation for Economic Co-operation and Development (“OECD”) in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, and the related Supplements for tin, tantalum, tungsten and gold.

Avanos’ conflict minerals due diligence process includes the five steps described in the Guidance, namely: (1) establishing strong company management systems, (2) identifying and assessing risks in our supply chain, (3) designing and implementing a strategy to respond to identified risks, (4) utilizing independent third-party audits, and (5) publicly reporting on our supply chain due diligence. A summary of our due diligence measures is outlined below.

B.Performance of Due Diligence

Step 1. Establishing Strong Company Management Systems

a.Internal Team

We organized a Conflict Minerals Committee comprised of individuals in management positions across multiple departments, namely Legal, Procurement, and Finance. The Committee members are the (1) Vice President, Deputy General Counsel and Corporate Secretary, (2) Director – Global Procurement, and (3) Vice President – Finance Planning and Analysis. The Committee leads our conflict minerals compliance effort and is responsible for implementing our conflict minerals compliance strategy and for overseeing the program.

b.Control Systems

We have applicable policies and statements such as a Code of Conduct that outlines expected behaviors for all Avanos employees, a Supplier Social Compliance Standard that outlines expected behaviors for all Avanos vendors, and a Conflict

Minerals Policy Statement (“Statement”). All three items are available on our website. The Statement, in particular, can be found in the Investor Relations section of our website, under Corporate Governance, at https://avanos.investorroom.com.

c.Supplier Engagement

We utilized our Service Provider’s software reporting tool, and the CMRT version 5.12 to collect Conflict Minerals declarations from our supply base. The software tool allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we received from our suppliers to our survey requests. We also communicated with relevant suppliers our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information from them to support the chain of custody of the 3TGs identified in our products.

d.Grievance Mechanisms

We have several mechanisms that allow people to alert Company management about any concerns they may have about our compliance or ethics. Our Code of Conduct sets out ways to report concerns, including a Code of Conduct Hotline and Online Reporting tool, which both allow reports, in any language, to be made confidentially and anonymously at the election of the person making the report. We also have made publicly available on our website policies for communicating with our Board of Directors and with our compliance-oversight Committees of the Board, namely the Audit Committee and the Compliance Committee. These mechanisms are available to people who may be concerned about compliance with our conflict minerals program or with any other compliance matter.

e.Maintain Records

We maintain a company-wide document retention policy. The policy extends to the documents accumulated in performing our due diligence for this Report and requires that the documents be retained for a period of ten years. As well, our Service Provider stores all of the information and findings from this process in a database that can be audited by internal or external parties.

Step 2. Identify and Assess Risks in the Supply Chain

Due to the complexity of our products and supply chain, it is difficult for us to identify indirect suppliers. We have relied on responses from our direct suppliers to provide us with information about the source of conflict minerals contained in the parts and components they supply to us. Similarly, our direct suppliers also rely on information provided to them by their suppliers. This chain of information creates a level of uncertainty and risk about the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to recognized industry best practices.

In accordance with the Guidance, it is important to understand risk levels associated with conflict minerals in the supply chain. Each facility that meets the Responsible Minerals Initiative (“RMI”) definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 5 scoring criteria, namely: (1) geographic proximity to the DRC and Covered Countries; (2) known mineral source country of origin; (3) responsible Minerals Assurance Process audit status; (4) credible evidence of unethical or conflict sourcing; and (5) peer assessments conducted by credible third-party sources.

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

•Tony Goetz NV - Belgium - CID002587

•Kaloti Metals - UAE - CID002563

•African Gold Refinery - Uganda - CID003185

•Universal Precious Metals Refining - Zambia - CID002854

•Fidelity Printers - Zimbabwe - CID002515

•Sudan Gold Refinery - CID002567

If any of these facilities were reported on a CMRT by one of our suppliers, our Service Provider initiated risk mitigation activities, including instructing the supplier to submit a product-specific CMRT to better identify any connection between the facilities and our products and to consider removal of these facilities from our supply chain.

Additionally, we evaluated suppliers on their conflict minerals program strength. Many companies continue to develop their programs and still provide an answer of “unknown” in response to our survey questions. We used the following criteria to evaluate the strength of their programs, with the capital letters, below, corresponding to the ones in the CMRT declaration tab:

A. Have you established a conflict minerals sourcing policy?

E. Have you implemented due diligence measures for conflict-free sourcing?

G. Do you review due diligence information received from your suppliers against your company’s expectations?

H. Does your review process include corrective action management?

When suppliers meet or exceed those criteria (Yes to at least A, E, G, H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.

Our identification and risk assessment process also involves: (1) seeking information about 3TG smelters and refiners in our supply chain by requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable. We believe that the inquiries and analysis described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products.

Step 3. Design and Implement a Strategy to Respond to Identified Risks

Our Supplier Social Compliance Standards and Conflict Minerals Policy Statement set out our expectations for our suppliers. If these expectations are not met, the business relationship between us and the supplier will be evaluated. For example, if we find that we source 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries, we will encourage the applicable supplier to establish an alternative source of the minerals that does not support such conflict. If an alternative source cannot be found or the supplier chooses not to respond to this risk, we will assess whether or not we can replace the supplier. We have found no instance to date where we believed it was necessary to implement such risk mitigation efforts.

Step 4. Utilize Independent Third-Party Audits

We do not have a direct relationship with smelters and refiners (“SORs”) and do not perform or direct audits of these entities. Instead, we rely on third party assurances and certifications such as from the RMI’s Responsible Minerals Assurance Process.

Step 5. Publicly Report on Supply Chain Due Diligence

This Report, which constitutes our annual report on our due diligence efforts, is available on our website in the Investor Relations section, under SEC Filings, at https://avanos.investorroom.com. This Report also is filed with the SEC.

V.Results of Due Diligence

A.Survey Results

As of May 11, 2020, we received responses from 63% of our 268 surveyed suppliers. Of those, 130 claimed no 3TGs, in their products, and 39 claimed that they did have 3TGs. Of the 39 claiming to have 3TGs, 12 indicated that they had tantalum, 27 indicated tin, 15 indicated gold, and 15 indicated tungsten. (The numbers do not sum to 39 because some of the suppliers claimed to have multiple 3TGs in their products.)

As described above, we surveyed our supply chain and reviewed the responses to determine whether further engagement with our suppliers was required. The determination to further engage with them was based on criteria such as untimely responses, incomplete responses, and inconsistencies within the data reported. Suppliers who provided a CMRT were asked to submit SOR information. The results are discussed in the Smelters and Refiners section below.

B.Efforts to Determine Mine or Location of Origin

Because we do not have relationships with the smelters and refiners, we relied on requests to our suppliers that they complete the RMI template. We believe that process suffices as a good faith effort to determine the identity of the mines or the locations of origin of 3TGs in our supply chain.

C.Smelters and Refiners

Of the suppliers we surveyed, many completed the RMI template at the company or business unit level, and they were unable to verify that 3TGs from the processing facilities they listed were in components they supplied to us. The quality of the responses we received from suppliers varied. Many responses provided via the CMRT included the names of facilities listed by the suppliers as SORs. The CMRT responses that did not list at least one smelter for each 3TG were considered invalid, and our Service Provider followed up on these responses, urging suppliers to resubmit the form and include the smelter information. There are still suppliers that were unable to provide SORs used for the materials supplied to us.

For all the CMRT responses that indicated a smelter, our Service Provider compared them to the list of smelters maintained by the RMI. As of May 11, 2020, we validated 300 SORs. Appendix A lists only the SORs that our suppliers reported as being in their supply chains and that we validated. Appendix B is a compilation of countries of origin, setting out the countries from

which the reported facilities source their conflict minerals.

As our suppliers have been largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to provide additional SOR names or country of origin information at this time. We will continue to work with our suppliers to obtain smelter information at the product level.

VI.Future Steps to be Taken

We are committed to complying with the provisions of the Rule and expect to continue our efforts to improve our conflict minerals program. As we further develop our program, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to, the following:

•Further engage with suppliers and direct them to training resources to increase our survey response rate and improve the content of the responses;

•Continue to invest in due diligence tools for our conflict minerals program;

•If applicable, engage any of our suppliers found to be supplying us with 3TGs from sources that support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict;

•Continue to respond to industry trends and legal requirements to improve the traceability of 3TGs in our supply chain; and

•Further encourage suppliers to provide responses at the product level to enable us to determine which smelters and refiners actually process 3TGs contained in our products.

APPENDIX A

The table below lists, the smelters or refiners (“SORs”) identified by our direct suppliers that may have been used to process 3TGs necessary to the functionality or production of our products in 2019. Facilities that have been certified as conflict-free by an internationally-recognized validation organization for 3TG SORs are designated in the column furthest to the right, where the word “Yes” indicates that such an organization validated them as conflict-free.

Metal

Standard Smelter Name

Smelter Facility Location

Smelter ID

Conflict Free?

Gold

8853 S.p.A.

ITALY

CID002763

Yes

Gold

Abington Reldan Metals, LLC

UNITED STATES

CID002708

Unknown

Gold

Advanced Chemical Company

UNITED STATES

CID000015

Yes

Gold

African Gold Refinery

UGANDA

CID003185

Unknown

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

CID000019

Yes

Gold

Al Etihad Gold LLC

UNITED ARAB EMIRATES

CID002560

Yes

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

CID000035

Yes

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

CID000041

Yes

Gold

AngloGold Ashanti Córrego do Sítio Mineração

BRAZIL

CID000058

Yes

Gold

Argor-Heraeus S.A.

SWITZERLAND

CID000077

Yes

Gold

Asahi Pretec Corp.

JAPAN

CID000082

Yes

Gold

Asahi Refining Canada Ltd.

CANADA

CID000924

Yes

Gold

Asahi Refining USA Inc.

UNITED STATES

CID000920

Yes

Gold

Asaka Riken Co., Ltd.

JAPAN

CID000090

Yes

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

CID000103

Unknown

Gold

AU Traders and Refiners

SOUTH AFRICA

CID002850

Yes

Gold

Aurubis AG

GERMANY

CID000113

Yes

Gold

Bangalore Refinery

INDIA

CID002863

Unknown

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

CID000128

Yes

Gold

Boliden AB

SWEDEN

CID000157

Yes

Gold

C. Hafner GmbH + Co. KG

GERMANY

CID000176

Yes

Gold

Caridad

MEXICO

CID000180

Unknown

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

CID000185

Yes

Gold

Cendres + Métaux S.A.

SWITZERLAND

CID000189

Yes

Gold

CGR Metalloys Pvt Ltd

INDIA

CID003382

Unknown

Gold

Chimet S.p.A.

ITALY

CID000233

Yes

Gold

Chugai Mining

JAPAN

CID000264

Unknown

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

CID000343

Unknown

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

CID002867

Unknown

Gold

Dijllah Gold Refinery FZC

UNITED ARAB EMIRATES

CID003348

Unknown

Gold

DODUCO Contacts and Refining GmbH

GERMANY

CID000362

Yes

Gold

Dowa

JAPAN

CID000401

Yes

Gold

DS PRETECH Co., Ltd.

KOREA, REPUBLIC OF

CID003195

Yes

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

CID000359

Yes

Gold

Eco-System Recycling Co., Ltd.

JAPAN

CID000425

Yes

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

CID002561

Yes

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

CID002515

Unknown

Gold

Fujairah Gold FZE

UNITED ARAB EMIRATES

CID002584

Unknown

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

CID002852

Unknown

Gold

Geib Refining Corporation

UNITED STATES

CID002459

Yes

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

CID002243

Yes

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

CID001909

Unknown

Gold

Guangdong Jinding Gold Limited

CHINA

CID002312

Unknown

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

CID000651

Unknown

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

CID000671

Unknown

Gold

Heimerle + Meule GmbH

GERMANY

CID000694

Yes

Metal

Standard Smelter Name

Smelter Facility Location

Smelter ID

Conflict Free?

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

CID000707

Yes

Gold

Heraeus Precious Metals GmbH & Co. KG

GERMANY

CID000711

Yes

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000767

Unknown

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

CHINA

CID000773

Unknown

Gold

HwaSeong CJ Co., Ltd.

KOREA, REPUBLIC OF

CID000778

Unknown

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

CID000801

Yes

Gold

International Precious Metal Refiners

UNITED ARAB EMIRATES

CID002562

Unknown

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

CID000807

Yes

Gold

Istanbul Gold Refinery

TURKEY

CID000814

Yes

Gold

Italpreziosi

ITALY

CID002765

Yes

Gold

Japan Mint

JAPAN

CID000823

Yes

Gold

Jiangxi Copper Co., Ltd.

CHINA

CID000855

Yes

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

CID000927

Unknown

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

CID000929

Yes

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

CID000937

Yes

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

CID002563

Unknown

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

CID000956

Unknown

Gold

Kazzinc

KAZAKHSTAN

CID000957

Yes

Gold

Kennecott Utah Copper LLC

UNITED STATES

CID000969

Yes

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

CID002511

Unknown

Gold

Kojima Chemicals Co., Ltd.

JAPAN

CID000981

Yes

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

CID002605

Yes

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

CID001029

Yes

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

CID002865

Unknown

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

CID001032

Unknown

Gold

Lingbao Gold Co., Ltd.

CHINA

CID001056

Unknown

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

CID001058

Unknown

Gold

L'Orfebre S.A.

ANDORRA

CID002762

Yes

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

CID001078

Yes

Gold

LT Metal, Ltd.

KOREA, REPUBLIC OF

CID000689

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

CID001093

Unknown

Gold

Marsam Metals

BRAZIL

CID002606

Yes

Gold

Materion

UNITED STATES

CID001113

Yes

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

CID001119

Yes

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

CID001149

Yes

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

CID001152

Yes

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

CID001147

Yes

Gold

Metalor Technologies S.A.

SWITZERLAND

CID001153

Yes

Gold

Metalor USA Refining Corporation

UNITED STATES

CID001157

Yes

Gold

Metalúrgica Met-Mex Peñoles S.A. De C.V.

MEXICO

CID001161

Yes

Gold

Mitsubishi Materials Corporation

JAPAN

CID001188

Yes

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001193

Yes

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

CID002509

Yes

Gold

Modeltech Sdn Bhd

MALAYSIA

CID002857

Unknown

Gold

Morris and Watson

NEW ZEALAND

CID002282

Unknown

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

CID001204

Yes

Gold

Nadir Metal Rafineri San. Ve Tic. A.ª.

TURKEY

CID001220

Yes

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

CID001236

Unknown

Gold

NH Recytech Company

KOREA, REPUBLIC OF

CID003189

Unknown

Gold

Nihon Material Co., Ltd.

JAPAN

CID001259

Yes

Gold

Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

CID002779

Yes

Metal

Standard Smelter Name

Smelter Facility Location

Smelter ID

Conflict Free?

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

CID001325

Yes

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

RUSSIAN FEDERATION

CID001326

Yes

Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

CID000493

Yes

Gold

PAMP S.A.

SWITZERLAND

CID001352

Yes

Gold

Pease & Curren

UNITED STATES

CID002872

Unknown

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

CID001362

Unknown

Gold

Planta Recuperadora de Metales SpA

CHILE

CID002919

Yes

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

CID001386

Yes

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

CID001397

Yes

Gold

PX Précinox S.A.

SWITZERLAND

CID001498

Yes

Gold

QG Refining, LLC

UNITED STATES OF AMERICA

CID003324

Unknown

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

CID001512

Yes

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

CID000522

Unknown

Gold

Remondis Argentia B.V.

NETHERLANDS

CID002582

Yes

Gold

Republic Metals Corporation

UNITED STATES

CID002510

Yes

Gold

Royal Canadian Mint

CANADA

CID001534

Yes

Gold

SAAMP

FRANCE

CID002761

Yes

Gold

Sabin Metal Corp.

UNITED STATES

CID001546

Unknown

Gold

Safimet S.p.A

ITALY

CID002973

Yes

Gold

SAFINA A.S.

CZECH REPUBLIC

CID002290

Unknown

Gold

Sai Refinery

INDIA

CID002853

Unknown

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

CID001555

Unknown

Gold

SAMWON Metals Corp.

KOREA, REPUBLIC OF

CID001562

Unknown

Gold

SAXONIA Edelmetalle GmbH

GERMANY

CID002777

Yes

Gold

SEMPSA Joyería Platería S.A.

SPAIN

CID001585

Yes

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

CID001619

Unknown

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

CID001622

Yes

Gold

Shangdong Humon Smelting Co., Ltd.

CHINA

CID002525

Unknown

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

CID001736

Yes

Gold

Singway Technology Co., Ltd.

TAIWAN

CID002516

Yes

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

CID001756

Yes

Gold

Solar Applied Materials Technology Corp.

TAIWAN

CID001761

Yes

Gold

Sovereign Metals

INDIA

CID003383

Unknown

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

CID003153

Unknown

Gold

Sudan Gold Refinery

SUDAN

CID002567

Unknown

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

CID001798

Yes

Gold

SungEel HiTech

KOREA, REPUBLIC OF

CID002918

Yes

Gold

T.C.A S.p.A

ITALY

CID002580

Yes

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

CID001875

Yes

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

CID001916

Yes

Gold

Tokuriki Honten Co., Ltd.

JAPAN

CID001938

Yes

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

CID001947

Unknown

Gold

Tony Goetz NV

BELGIUM

CID002587

Unknown

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

CID002615

Unknown

Gold

Torecom

KOREA, REPUBLIC OF

CID001955

Yes

Gold

Umicore Brasil Ltda.

BRAZIL

CID001977

Yes

Gold

Umicore Precious Metals Thailand

THAILAND

CID002314

Yes

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

CID001980

Yes

Gold

United Precious Metal Refining, Inc.

UNITED STATES

CID001993

Yes

Metal

Standard Smelter Name

Smelter Facility Location

Smelter ID

Conflict Free?

Gold

Valcambi S.A.

SWITZERLAND

CID002003

Yes

Gold

Western Australian Mint trading as The Perth Mint

AUSTRALIA

CID002030

Yes

Gold

WIELAND Edelmetalle GmbH

GERMANY

CID002778

Yes

Gold

Yamakin Co., Ltd.

JAPAN

CID002100

Yes

Gold

Yokohama Metal Co., Ltd.

JAPAN

CID002129

Yes

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

CID000197

Unknown

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

CID002224

Yes

Tantalum

Asaka Riken Co., Ltd.

JAPAN

CID000092

Yes

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

CID000211

Yes

Tantalum

CP Metals Inc.

UNITED STATES

CID003402

Yes

Tantalum

D Block Metals, LLC

UNITED STATES

CID002504

Yes

Tantalum

Exotech Inc.

UNITED STATES

CID000456

Yes

Tantalum

F&X Electro-Materials Ltd.

CHINA

CID000460

Yes

Tantalum

FIR Metals & Resource Ltd.

CHINA

CID002505

Yes

Tantalum

Global Advanced Metals Aizu

JAPAN

CID002558

Yes

Tantalum

Global Advanced Metals Boyertown

UNITED STATES

CID002557

Yes

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

CID000616

Yes

Tantalum

H.C. Starck Co., Ltd.

THAILAND

CID002544

Yes

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

CID002547

Yes

Tantalum

H.C. Starck Inc.

UNITED STATES

CID002548

Yes

Tantalum

H.C. Starck Ltd.

JAPAN

CID002549

Yes

Tantalum

H.C. Starck Smelting GmbH & Co. KG

GERMANY

CID002550

Yes

Tantalum

H.C. Starck Tantalum and Niobium GmbH

GERMANY

CID002545

Yes

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

CID002492

Yes

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

CID002512

Yes

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

CID002842

Yes

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

CID000914

Yes

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

CID000917

Yes

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002506

Yes

Tantalum

KEMET Blue Metals

MEXICO

CID002539

Yes

Tantalum

LSM Brasil S.A.

BRAZIL

CID001076

Yes

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

CID001163

Yes

Tantalum

Mineracao Taboca S.A.

BRAZIL

CID001175

Yes

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001192

Yes

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

CID001277

Yes

Tantalum

NPM Silmet AS

ESTONIA

CID001200

Yes

Tantalum

Power Resources Ltd.

MACEDONIA

CID002847

Yes

Tantalum

QuantumClean

UNITED STATES

CID001508

Yes

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

CID002707

Yes

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

CID001769

Yes

Tantalum

Taki Chemicals

JAPAN

CID001869

Yes

Tantalum

Telex Metals

UNITED STATES

CID001891

Yes

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

CID001969

Yes

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

CID002508

Yes

Tantalum

Yangling Jincheng Tantalum & Niobium Co., Ltd.

CHINA

CID001522

Yes

Tin

Alpha

UNITED STATES

CID000292

Yes

Tin

An Vinh Joint Stock Mineral Processing Company

VIETNAM

CID002703

Unknown

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

CID000228

Yes

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

CID003190

Yes

Tin

China Tin Group Co., Ltd.

CHINA

CID001070

Yes

Metal

Standard Smelter Name

Smelter Facility Location

Smelter ID

Conflict Free?

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

CHINA

CID003356

Unknown

Tin

Dowa

JAPAN

CID000402

Yes

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

VIETNAM

CID002572

Unknown

Tin

EM Vinto

BOLIVIA

CID000438

Yes

Tin

Estanho de Rondônia S.A.

BRAZIL

CID000448

Unknown

Tin

Fenix Metals

POLAND

CID000468

Yes

Tin

Gejiu Fengming Metallurgy Chemical Plant

CHINA

CID002848

Yes

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

CID000942

Yes

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

CID000538

Yes

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

CID001908

Yes

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

CID000555

Yes

Tin

Guangdong Hanhe Non-ferrous Metal Limited Company

CHINA

CID003116

Yes

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

CHINA

CID002849

Yes

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

CID002844

Unknown

Tin

Huichang Jinshunda Tin Co., Ltd.

CHINA

CID000760

Yes

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

CID001231

Yes

Tin

Luna Smelter, Ltd.

RWANDA

CID003387

Yes

Tin

Ma'anshan Weitai Tin Co., Ltd.

CHINA

CID003379

Yes

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

CID002468

Yes

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

CID001105

Yes

Tin

Melt Metais e Ligas S.A.

BRAZIL

CID002500

Yes

Tin

Metallic Resources, Inc.

UNITED STATES

CID001142

Yes

Tin

Metallo Belgium N.V.

BELGIUM

CID002773

Yes

Tin

Metallo Spain S.L.U.

SPAIN

CID002774

Yes

Tin

Mineracao Taboca S.A.

BRAZIL

CID001173

Yes

Tin

Minsur

PERU

CID001182

Yes

Tin

Mitsubishi Materials Corporation

JAPAN

CID001191

Yes

Tin

Modeltech Sdn Bhd

MALAYSIA

CID002858

Yes

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIETNAM

CID002573

Unknown

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

CID001314

Yes

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID002517

Yes

Tin

Operaciones Metalurgical S.A.

BOLIVIA

CID001337

Yes

Tin

Pongpipat Company Limited

MYANMAR

CID003208

Unknown

Tin

Precious Minerals and Smelting Limited

INDIA

CID003409

Unknown

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

CID002503

Yes

Tin

PT Menara Cipta Mulia

INDONESIA

CID002835

Yes

Tin

PT Mitra Stania Prima

INDONESIA

CID001453

Yes

Tin

PT Refined Bangka Tin

INDONESIA

CID001460

Yes

Tin

PT Timah (Persero) Tbk Kundur

INDONESIA

CID001477

Yes

Tin

PT Timah (Persero) Tbk Mentok

INDONESIA

CID001482

Yes

Tin

Resind Industria e Comersio Ltda.

BRAZIL

CID002706

Yes

Tin

Rui Da Hung

TAIWAN

CID001539

Yes

Tin

Soft Metais Ltda.

BRAZIL

CID001758

Yes

Tin

Super Ligas

BRAZIL

CID002756

Unknown

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

VIETNAM

CID002834

Yes

Tin

Thaisarco

THAILAND

CID001898

Yes

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

CID003325

Yes

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIETNAM

CID002574

Unknown

Tin

White Solder Metalurgia e Mineração Ltda.

BRAZIL

CID002036

Yes

Metal

Standard Smelter Name

Smelter Facility Location

Smelter ID

Conflict Free?

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

CID002158

Yes

Tin

Yunnan Tin Company Limited

CHINA

CID002180

Yes

Tin

Yunnan Yunfan Non-Ferrous Metals Co., Ltd.

CHINA

CID003397

Yes

Tungsten

A.L.M.T. TUNGSTEN Corp.

JAPAN

CID000004

Yes

Tungsten

ACL Metais Eireli

BRAZIL

CID002833

Yes

Tungsten

Albasteel Industria e Comercio de Legas Para Funding

BRAZIL

CID003427

Yes

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIETNAM

CID002502

Yes

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

CID002513

Yes

Tungsten

China Molybdenum Co., Ltd.

CHINA

CID002641

Unknown

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID000258

Yes

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

CID000281

Unknown

Tungsten

CP Metals Inc.

UNITED STATES

CID003448

Unknown

Tungsten

Fujian Ganmin RareMetals Co.

CHINA

CID003401

Yes

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

CHINA

CID000499

Yes

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

CID002645

Yes

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

CID000875

Yes

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

CID002315

Yes

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

CID002494

Yes

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES

CID000568

Yes

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

CID000218

Yes

Tungsten

H.C. Starck Smelting GmbH & Co.KG

GERMANY

CID002542

Yes

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

CID002541

Yes

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000766

Yes

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CHINA

CID002579

Yes

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

CID000769

Yes

Tungsten

Hunan Litian Tungsten Industry Co., Ltd.

CHINA

CID003182

Unknown

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

CID002649

Yes

Tungsten

Japan New Metals Co., Ltd.

JAPAN

CID000825

Yes

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

CID002551

Yes

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

CID002321

Yes

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

CID002313

Unknown

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

CID002318

Yes

Tungsten

Jiangxi Xianghu Tungsten Co., Ltd.

CHINA

CID002647

Unknown

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

CID002317

Yes

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

CID002316

Yes

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

RUSSIAN FEDERATION

CID003408

Unknown

Tungsten

Kennametal Fallon

UNITED STATES

CID000966

Yes

Tungsten

Kennametal Huntsville

UNITED STATES

CID000105

Yes

Tungsten

KGETS Co., Ltd.

KOREA, REPUBLIC OF

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF CHINA

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002319

Yes

Tungsten

Masan Tungsten Chemical LLC (MTC)

VIETNAM

CID002543

Yes

Tungsten

Moliren Ltd

RUSSIAN FEDERATION

CID002845

Yes

Tungsten

Niagara Refining LLC

UNITED STATES

CID002589

Yes

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

CID002827

Yes

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

VIETNAM

CID001889

Yes

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

CID002724

Yes

Tungsten

Wolfram Bergbau und Hütten AG

AUSTRIA

CID002044

Yes

Tungsten

Woltech Korea Co., Ltd.

KOREA, REPUBLIC OF

CID002843

Yes

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

CID002320

Yes

Metal

Standard Smelter Name

Smelter Facility Location

Smelter ID

Conflict Free?

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

CID002082

Yes

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CHINA

CID002830

Yes

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CHINA

CID002095

Yes

APPENDIX B

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

Argentina, Armenia, Australia, Austria, Azerbaijan, Benin, Bolivia, Botswana, Brazil, Burkina Faso, Canada, Chile, China, Colombia, Cyprus, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Finland, Georgia, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Iran, Ivory Coast, Kazakhstan, Kyrgyzstan, Laos, Lebanon, Madagascar, Malaysia, Mali, Mauritania, Mauritius, Mexico, Mongolia, Morocco, Myanmar, Namibia, Nicaragua, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Portugal, Puerto Rico, Russian Federation, Saudi Arabia, Senegal, Sierra Leone, Slovakia, Solomon Islands, Spain, Suriname, Swaziland, Sweden, Taiwan, Thailand, Togo, Turkey, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Zimbabwe