Specialized Disclosure Report
Peloton Interactive Inc.
(Exact name of registrant as specified in its charter)
Delaware 001-3905847-3533761
(State or other Jurisdiction of Incorporation)
(Commission File Number)
(I.R.S. Employer Identification No.)
441 Ninth Avenue, Sixth Floor
New York, New York
(Address of principal executive offices) (Zip Code)
Tammy Albarrán
Chief Legal Officer
(929) 567-0006
(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:
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022.

Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the reporting period from January 1 to December 31, 2022.

Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
In accordance with the disclosure requirements promulgated by the U.S. Securities and Exchange Commission, Peloton Interactive, Inc. (the “Company”) has undertaken efforts to determine our conflict minerals1 reporting requirements for the period from January 1 to December 31, 2022.
The Company has filed this Specialized Disclosure Report and the associated Conflict Minerals Report, which appears as Exhibit 1.01 hereto and is publicly available on the Company’s website at
Item 1.02 Exhibit
The Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto.
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report.
Not applicable.
Section 3 – Exhibits
Item 3.01 Exhibits
The following exhibit is filed as part of this report.
Exhibit 1.01 – The Company's Conflict Minerals Report for the period January 1 to December 31, 2022.


1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country.

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.
Peloton Interactive, Inc.
/s/ Tammy Albarrán
Date: May 31, 2023
Chief Legal Officer

Exhibit 1.01

        Peloton Interactive, Inc.
This is the Conflict Minerals1 Report of Peloton Interactive, Inc. (“we,” “our,” “us,” “Peloton,” or the “Company”) prepared for calendar year 2022 in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and SEC Release No. 34-67716 (August 22, 2012) under the Act (the “Adopting Release”). The reader is referred to these sources for the definitions of defined terms contained herein.
In accordance with Rule 13p-1, we undertook efforts to determine the presence and source of the conflict minerals within our products. The Company designed its efforts in conformity with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas2 (“OECD Due Diligence Guidance”) and related Supplements.
The statements below are based on the activities performed to date in good faith by the Company and are based on the infrastructure and information available at the time of this filing. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving identification of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding the SEC final rules, and other issues.
Company Profile
Peloton Interactive, Inc. (“Peloton” or the “Company”) is the largest interactive fitness platform in the world. Founded in 2012 and headquartered in New York City, Peloton has a highly engaged community of nearly 7 million Members across the US, UK, Canada, Germany, and Australia. Peloton provides Members with expert instruction, world-class content and the fitness industry’s leading music library to create impactful and entertaining workout experiences for anyone, anywhere and at any stage in their fitness journey. At home, outdoors, traveling, or at the gym, Peloton offers an immersive and personalized experience, with or without equipment. Peloton can be accessed via the Peloton Bike, Bike+, Tread, Guide, Row or the Peloton App, now with multiple membership tiers.
1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country.
2 OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, Paris.

Exhibit 1.01
On April 1, 2021, the Company acquired Precor Incorporated (“Precor”), a global commercial fitness equipment provider headquartered in Greater Seattle, Washington. Precor products and services span across all major categories, including cardio, strength, functional fitness and connected solutions. Precor is included in this Conflict Minerals Report for the first time for the 2022 calendar year. We are subject to this rule as we have determined that, during 2022, conflict minerals were likely necessary to the functionality or production of products that Peloton, and its wholly-owned subsidiary, Precor, manufactured or contracted to manufacture. The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals and we conduct no purchasing activities directly in the DRC or adjoining countries.
Conflict Minerals Policy
The Company developed a policy statement to support the goals expressed by Congress in enacting Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The policy highlights the Company’s commitment to complying with the reporting and due diligence obligations required by the SEC rule and the Company’s expectations from its suppliers. In addition, the policy includes language encouraging suppliers to source responsibly and supports efforts to reduce violence and human rights violations in the DRC or adjoining countries. The policy resides on our investor relations website ( and is reviewed and updated periodically as needed.
Reasonable Country of Origin Inquiry Information
We have conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the necessary conflict minerals originated in the DRC or an adjoining country or came from recycled or scrap sources.
The Company’s RCOI process included reviewing the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release and conducting an inquiry of our direct suppliers of the in-scope products using the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Based on the results of our RCOI which indicated sourcing from the DRC or adjoining countries, we exercised due diligence on the source and chain of custody of the conflict minerals in accordance with the OECD Due Diligence Guidance. Our due diligence efforts are discussed further in this Conflict Minerals Report.
Due Diligence Program Design
The Company designed its conflict minerals program to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as they relate to our position in the minerals supply chain as a “downstream” company:
Step 1:     Establish strong company management systems
Step 2:     Identify and assess risks in the supply chain
Step 3:     Design and implement a strategy to respond to identified risks

Exhibit 1.01
Step 4:    Carry out independent third-party audit of smelter/refiner's due diligence practices
Step 5:     Report annually on supply chain due diligence
III.Due Diligence Measures Performed by The Company
The following describes the measures taken to reasonably determine the country of origin and to exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance.
Step 1: Establish strong company management systems
a.Conflict minerals team – The Company has a conflict minerals team that includes individuals from the relevant business units and departments, including the compliance, sourcing and procurement and legal teams. The team is structured to include the involvement from those in upper management roles to help ensure that critical information, including the Company’s conflict minerals policy, reaches relevant employees and suppliers.
b.Conflict minerals policy – The Company maintains a policy establishing the expectations of our suppliers. The policy resides on our investor relations website at
c.Internal engagement – The Company administers a role-based training program to educate employees on its conflict minerals process, the goals of its program, and its reporting obligations as a supplier and a public filer.
d.Supplier engagement – The Company communicates its conflict minerals policy and provides educational materials to its in-scope suppliers. Suppliers were provided educational materials when the request for information was initiated on the conflict minerals disclosure requirements, which included recommendations for developing, implementing, and documenting a conflict minerals compliance program.
e.Company level grievance mechanism – As recommended by the OECD Due Diligence Guidance, the Company has a grievance mechanism in place as a risk-awareness system for conflict minerals issues. Stakeholders, internal and external, can communicate directly and confidentially with Company compliance officers by reporting through available channels.
f.Records management – The Company maintains records relating to its conflict minerals program in accordance with the recommended record retention guidelines of five years.
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk assessment process:
a.Identified products in scope – Our conflict minerals team conducted a detailed review of the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release.
b.Conducted RCOI – The Company utilized the most recent version of the industry-developed CMRT to query our suppliers for conflict minerals information. We requested this information from the Tier 1 suppliers who provide materials and components for the products deemed in-scope by our conflict minerals team. We evaluated the responses from the templates submitted by our suppliers to

Exhibit 1.01
determine our reporting obligation based on this RCOI. See Appendix I for a list of countries of origin identified through the RCOI process.
c.Completed additional follow-up –The Company contacted direct suppliers multiple times to request detailed conflict minerals information. We also worked to clarify and validate the accuracy of information provided by our suppliers by responding with standardized feedback questions to address any issues or uncertainty with the template provided when necessary and/or obtained additional information upon request (product identification, order numbers, or shipping addresses) to help ensure we are receiving conflict minerals information specific to our supply-chain.
d.Identified smelters or refiners (“SORs”) – The Company compiled a list of SORs in our supply chain using our suppliers’ responses in their CMRTs. The Company reconciled this list to the list of smelter facilities designated by the RMI’s Responsible Minerals Assurance Process (“RMAP”). The RMAP completes independent, third-party audits of smelters and refiners to determine which can be validated as having systems in place that help ensure the minerals are responsibly sourced according to the OECD Due Diligence Guidance. The Company also utilized information provided by the London Bullion Market Association (LBMA), and Responsible Jewelry Council (RJC) cross-recognition audit programs. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs. We have provided that list in this Report within section IV – Product Description; Processing Facilities.

Step 3: Design and implement a strategy to respond to identified risks
We performed the following steps as part of our risk management plan:
a.Reporting results to senior management – The Conflict Minerals team reports the results of our RCOI to senior management at multiple points in time throughout the data collection period. These communications included the team’s plan to respond to risks identified in the due diligence processes.
b.Designed and implemented a plan – The Company used established risk rating criteria to evaluate suppliers based on the responses provided within their CMRT, as well as any additional documentation furnished to support those responses and the suppliers’ due diligence processes. The resulting risk ratings were used to develop specific supplier outreach and training to address the identified risks and to take corrective actions with suppliers found not in compliance with the Company’s conflict minerals policy. This includes additional outreach to suppliers who failed to respond to our multiple requests for information, suppliers who provided inconsistent or erroneous information, and suppliers who indicated they had received responses from less than 50% of their in-scope suppliers. Our team further reviews the responses to verify the validity of SORs reported by our suppliers, the audit status of such SORs and the country of origin of the minerals processed at such facilities.
c.Provided educational materials – The Company provided each supplier with educational materials that explain Section 1502 of the Dodd-Frank Act, the OECD framework, the RCOI process, and general information on the contents of the most recent revision of the CMRT (including definitions of common phrases and frequently asked questions). The educational material serves as a point of reference for suppliers that are unfamiliar with the rule and helps limit the risk of obtaining inaccurate information from them. Throughout the process we offer assistance to our suppliers to improve the quality of the information provided to us.

Exhibit 1.01
d.Identified SORs – As part of the risk mitigation process, the Company reconciled the list of SORs collected from suppliers to the list of smelter facilities validated by the RMI. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs.
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
The Company is using information provided by independent third-party audit programs, including the RMI RMAP, LBMA, and RJC, to confirm the existence and verify the OECD-conformance status of SORs identified during our due diligence.
For SORs that had not been audited as conformant, the Company sent a communication to encourage participation in the RMAP and requested the SOR to provide the mines and/or locations the SOR sources from to assist in identifying all countries of origin. Additionally, the Company sent communications to all suppliers that reported SORs that had not been audited as conformant to request that these suppliers contact the SORs to encourage participation in the RMAP.
The Company is also a member of the RMI (under member ID PLTN). As a member, the Company financially supports the development of the RMAP through member dues and utilizes the RMI data to determine the country of origin of conflict minerals in the Company’s products in addition to the Company’s efforts of reaching out to smelters. The efforts to determine location of origin through the RMI are described on the RMI website at:
Step 5: Report annually on supply chain due diligence
Accordingly, this Conflict Minerals Report has been filed with the SEC and is available on our investor relations website at
IV.Product Description; Processing Facilities
Product Description
Peloton’s Product and Services
Peloton’s business is managed and our financial results are reported on a segment basis, with those segments being Connected Fitness Products & Subscriptions. Our Connected Fitness Products are subject to this rule and include:
Our current Bike features a carbon steel frame, a nearly silent belt drive, durable magnetic resistance, and a 22” high-definition touchscreen with built-in stereo speakers to stream live and on-demand classes, all in a compact, 4’ by 2’ footprint. Our Bike is available in the United States, Canada, the United Kingdom, Germany, and Australia.

Exhibit 1.01
Our Bike+ provides an immersive cardio experience and seamless transition to floor-based exercises with its 24”, 360-degree rotating display. Members can easily pivot and tilt the screen to add strength, yoga, and stretching to their routine or take our Bike Bootcamp class series. Resistance on Bike+ is controlled digitally allowing Members to “Auto Follow” their instructors’ class programs and control resistance from the touchscreen. A powerful built-in soundbar and subwoofer system offers an improved audio experience. Bike+ is currently available for purchase in the United States, Canada, the United Kingdom, Germany, and Australia.
Tread+ features a shock-absorbing rubber-slat belt and ball bearing system, ideal for low-impact training. Pace and incline ergonomic control knobs allow for seamless adjustments, and the 32” high-definition touchscreen features a 20-watt sound bar. Tread+ is currently subject to a voluntary product recall, which we are conducting in collaboration with the Consumer Product Safety Commission ("CPSC"). At this time, we are not able to forecast a date for sales to resume. Prior to the recall, Tread+ had only been available for sale in the United States.
The newest addition to our Tread line has the essential elements of the Tread+ experience but in a more affordable and compact form factor – maintaining ample running surface area and runner comfort. The Tread features a sleek belt drive, 24” touchscreen with integrated soundbar and subwoofer, and ergonomic pace and incline control knobs and jump buttons. With an immersive audio and video experience and heart rate monitor integration, Peloton Tread is designed for both on-Tread as well as floor-based bootcamp content. Tread is currently available for purchase in the United States, Canada, the United Kingdom, Australia, and in Germany.
Guide is our first connected fitness strength product designed to further enhance the full-body workout experience through a number of unique product features. Guide is supported with dedicated content, including exclusive programs for all levels, live body-training classes with instructors, and an extensive move library to help Members learn and perfect proper form. Guide is currently available for purchase in the United States, Canada, the United Kingdom, and Australia.
Peloton Row
Row combines the innovative software, premium hardware design, and exclusive content that make up the signature Peloton experience, providing Members with a unique low-impact, full-body cardio and strength rowing workout. Row is currently available for purchase in the United States.
Precor Products and Services
Precor products and services span across all major categories, including cardio, connected fitness consoles, strength, and functional fitness. Precor cardio products include treadmills, elliptical fitness crosstrainers, adaptive motion trainers, bikes, and a stairclimber. Cardio products may be equipped with

Exhibit 1.01
touchscreen internet-connected fitness consoles, or non-internet-connected LED consoles. Precor strength products include a variety of selectorized and plate-loaded machines, as well as functional multi-station units, benches, racks, and stretching equipment.
Processing FacilitiesBased on our due diligence process and the information received from our suppliers, the facilities listed in the table below were identified by the Company’s suppliers as the smelters and refiners of the tin, tantalum, tungsten and/or gold present in and necessary to the functionality of products manufactured by the Company in the calendar year ended December 31, 2022. The information from our suppliers is still evolving and may contain company-level declarations. As such, this smelter list is presented in good faith as the best information we have to date. For 2022, we identified 202 SORs in our supply chain, 186 of which have been audited as conformant with the RMAP. The following pie chart shows the audit status of all SORs identified in 2022. This list may contain smelters that are not in our supply chain and/or there may be other smelters in our supply chain which have not yet been identified by our due diligence process. We will continue to update the list as our information and the relevant third-party data from RMI, LBMA, and RJC improves.
MetalSmelter NameCountrySmelter ID
Gold8853 S.p.A.ITALYCID002763
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICACID000015
GoldAgosi AGGERMANYCID000035
GoldAida Chemical Industries Co., Ltd.JAPANCID000019
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESCID002560
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILCID000058
GoldArgor-Heraeus S.A.SWITZERLANDCID000077
GoldAsahi Pretec Corp.JAPANCID000082

Exhibit 1.01
GoldAsahi Refining Canada Ltd.CANADACID000924
GoldAsaka Riken Co., Ltd.JAPANCID000090
GoldAurubis AGGERMANYCID000113
GoldBangalore RefineryINDIACID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESCID000128
GoldBoliden ABSWEDENCID000157
GoldC. Hafner GmbH + Co. KGGERMANYCID000176
GoldCCR Refinery - Glencore Canada CorporationCANADACID000185
Cendres + Métaux S.A.
GoldChimet S.p.A.ITALYCID000233
GoldChugai MiningJAPANCID000264
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFCID000359
GoldEco-System Recycling Co., Ltd. East PlantJAPANCID000425
GoldEco-System Recycling Co., Ltd. North PlantJAPANCID003424
GoldEco-System Recycling Co., Ltd. West PlantJAPANCID003425
GoldGeib Refining CorporationUNITED STATES OF AMERICACID002459
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINACID002243
GoldHeimerle + Meule GmbHGERMANYCID000694
GoldHeraeus Germany GmbH Co. KGGERMANYCID000711
GoldHeraeus Metals Hong Kong Ltd.CHINACID000707
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINACID000801
GoldIshifuku Metal Industry Co., Ltd.JAPANCID000807
GoldIstanbul Gold RefineryTURKEYCID000814
GoldJapan MintJAPANCID000823
GoldJiangxi Copper Co., Ltd.CHINACID000855
GoldJX Nippon Mining & Metals Co., Ltd.JAPANCID000937
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICACID000969
KGHM Polska Miedź Spółka Akcyjna
GoldKojima Chemicals Co., Ltd.JAPANCID000981
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFCID002605
GoldL'Orfebre S.A.ANDORRACID002762
GoldMarsam MetalsBRAZILCID002606
GoldMatsuda Sangyo Co., Ltd.JAPANCID001119
GoldMetal Concentrators SA (Pty) Ltd.SOUTH AFRICACID003575
GoldMetalor Technologies (Hong Kong) Ltd.CHINACID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORECID001152

Exhibit 1.01
GoldMetalor Technologies (Suzhou) Ltd.CHINACID001147
GoldMetalor Technologies S.A.SWITZERLANDCID001153
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICACID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOCID001161
GoldMitsubishi Materials CorporationJAPANCID001188
GoldMitsui Mining and Smelting Co., Ltd.JAPANCID001193
GoldMMTC-PAMP India Pvt., Ltd.INDIACID002509
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYCID001220
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANCID001236
GoldNH Recytech CompanyKOREA, REPUBLIC OFCID003189
GoldNihon Material Co., Ltd.JAPANCID001259
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
GoldOhura Precious Metal Industry Co., Ltd.JAPANCID001325
GoldPlanta Recuperadora de Metales SpACHILECID002919
GoldPT Aneka Tambang (Persero) TbkINDONESIACID001397
GoldPX Precinox S.A.SWITZERLANDCID001498
GoldRand Refinery (Pty) Ltd.SOUTH AFRICACID001512
GoldRoyal Canadian MintCANADACID001534
GoldSafimet S.p.AITALYCID002973
GoldSamduck Precious MetalsKOREA, REPUBLIC OFCID001555
GoldSEMPSA Joyeria Plateria S.A.SPAINCID001585
GoldShandong Gold Smelting Co., Ltd.CHINACID001916
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACID001622
GoldSichuan Tianze Precious Metals Co., Ltd.CHINACID001736
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINACID002516
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINACID001761
GoldSumitomo Metal Mining Co., Ltd.JAPANCID001798
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFCID002918
GoldT.C.A S.p.AITALYCID002580
GoldTanaka Kikinzoku Kogyo K.K.JAPANCID001875
GoldTokuriki Honten Co., Ltd.JAPANCID001938
GoldTOO Tau-Ken-AltynKAZAKHSTANCID002615
GoldUmicore Precious Metals ThailandTHAILANDCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMCID001980
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICACID001993
GoldValcambi S.A.SWITZERLANDCID002003
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIACID002030
GoldWIELAND Edelmetalle GmbHGERMANYCID002778
GoldYamakin Co., Ltd.JAPANCID002100

Exhibit 1.01
GoldYokohama Metal Co., Ltd.JAPANCID002129
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACID002224
TantalumAMG BrasilBRAZILCID001076
TantalumF&X Electro-Materials Ltd.CHINACID000460
TantalumFIR Metals & Resource Ltd.CHINACID002505
TantalumGlobal Advanced Metals AizuJAPANCID002558
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICACID002557
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINACID002492
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACID002512
TantalumJiangxi Tuohong New Raw MaterialCHINACID002842
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACID000914
TantalumJiujiang Tanbre Co., Ltd.CHINACID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACID002506
TantalumKEMET de MexicoMEXICOCID002539
TantalumMaterion Newton Inc.UNITED STATES OF AMERICACID002548
TantalumMetallurgical Products India Pvt., Ltd.INDIACID001163
TantalumMineracao Taboca S.A.BRAZILCID001175
TantalumMitsui Mining and Smelting Co., Ltd.JAPANCID001192
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINACID001277
TantalumNPM Silmet ASESTONIACID001200
Resind Indústria e Comércio Ltda.
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONCID001769
TantalumTaki Chemical Co., Ltd.JAPANCID001869
TantalumTANIOBIS Japan Co., Ltd.JAPANCID002549
TantalumTANIOBIS Smelting GmbH & Co. KGGERMANYCID002550
TantalumUlba Metallurgical Plant JSCKAZAKHSTANCID001969
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINACID002508
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINACID001522
TinAurubis BeerseBELGIUMCID002773
TinAurubis BerangoSPAINCID002774
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINACID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINACID003190
TinChina Tin Group Co., Ltd.CHINACID001070
Estanho de Rondônia S.A.
TinFenix MetalsPOLANDCID000468

Exhibit 1.01
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINACID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINACID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINACID000555
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACID003116
TinJiangxi New Nanshan Technology Ltd.CHINACID001231
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILCID002468
TinMalaysia Smelting Corporation (MSC)MALAYSIACID001105
TinMelt Metais e Ligas S.A.BRAZILCID002500
TinMetallic Resources, Inc.UNITED STATES OF AMERICACID001142
TinMineracao Taboca S.A.BRAZILCID001173
TinMitsubishi Materials CorporationJAPANCID001191
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDCID001314
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESCID002517
TinPT Bangka SerumpunINDONESIACID003205
TinPT Mitra Stania PrimaINDONESIACID001453
PT Raihan Ariq
TinPT Refined Bangka TinINDONESIACID001460
TinPT Timah Tbk KundurINDONESIACID001477
TinPT Timah Tbk MentokINDONESIACID001482
Resind Indústria e Comércio Ltda.
TinTin Smelting Branch of Yunnan Tin Co., Ltd.CHINACID002180
TinTin Technology & RefiningUNITED STATES OF AMERICACID003325
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACID002158
TungstenA.L.M.T. Corp.JAPANCID000004
TungstenACL Metais EireliBRAZILCID002833
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMCID002502
TungstenChina Molybdenum Tungsten Co., Ltd.CHINACID002641
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINACID000258
TungstenCronimet Brasil LtdaBRAZILCID003468
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINACID002645
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINACID000875
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINACID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINACID002494
TungstenGlobal Tungsten & Powders LLCUNITED STATES OF AMERICACID000568
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINACID000218
TungstenH.C. Starck Tungsten GmbHGERMANYCID002541
TungstenHunan Chenzhou Mining Co., Ltd.CHINACID000766
TungstenHunan Jintai New Material Co., Ltd.CHINACID000769
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchCHINACID002513
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONCID002649

Exhibit 1.01
TungstenJapan New Metals Co., Ltd.JAPANCID000825
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINACID002551
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINACID002321
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINACID002318
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINACID002317
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINACID002316
TungstenKennametal FallonUNITED STATES OF AMERICACID000966
TungstenKennametal HuntsvilleUNITED STATES OF AMERICACID000105
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINACID002319
TungstenMasan High-Tech MaterialsVIET NAMCID002543
TungstenMoliren Ltd.RUSSIAN FEDERATIONCID002845
TungstenNiagara Refining LLCUNITED STATES OF AMERICACID002589
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESCID002827
TungstenTANIOBIS Smelting GmbH & Co. KGGERMANYCID002542
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONCID002724
TungstenWolfram Bergbau und Hutten AGAUSTRIACID002044
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINACID002320
TungstenXiamen Tungsten Co., Ltd.CHINACID002082

V.Future Due Diligence
We will continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If a supplier does not meet our expectations regarding responsible sourcing, we will work with the supplier, including by leveraging industry-wide programs as appropriate, to build its capacity for responsible sourcing. We expect our suppliers to take similar measures with their suppliers to help ensure alignment throughout the supply chain.
In addition to those above, the Company will undertake the following steps during the next compliance period:
Review the conflict minerals policy statement and update if necessary.
Review supplier and employee training materials and update if necessary.
Continue to collect responses from suppliers using the most recent revision of the CMRT.
Engage with suppliers that did not provide a response in prior year(s) or provided incomplete responses to enhance our data collection for 2023.
Monitor and track performance of risk mitigation efforts.
Continue engagement with smelters by sending letters to those that have not been audited as conformant and asking our suppliers to do the same.
Collect from suppliers product-level or user-defined level responses where useful.
Compare and validate RCOI results to information collected via independent third-party audit programs, such as the RMI, and through our Company’s own coordinated outreach to smelters.

Exhibit 1.01
Encourage responsible sourcing from the DRC and adjoining countries and continue to monitor global developments and the emergence of additional requirements or standards related to the sourcing of minerals or other materials from all regions to continually improve our conflict minerals program.
Stay aware of new and related sourcing challenges that affect smelter RMI audit status.
Continue to support efforts of industry groups, like the RMI, to strengthen due diligence efforts.


Exhibit 1.01
APPENDIX I – Countries of Origin
The information provided in this Appendix is based on the information collected from the Company’s suppliers.

Bolivia (Plurinational State of)Nicaragua
CanadaPapua New Guinea
Chinese TaipeiPortugal
ColombiaRussian Federation
Congo, Democratic Republic of theRwanda
EcuadorSierra Leone
EritreaSouth Africa
EthiopiaSouth Korea
KazakhstanUnited Kingdom of Great Britain and Northern Ireland
KyrgyzstanUnited States of America