UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Sangoma Technologies Corporation
(Exact name of registrant as specified in its charter)
| Ontario, Canada |
001-41175 |
Not Applicable |
(State or other jurisdiction of incorporation or
organization) |
(Commission File Number) |
(IRS Employer
Identification No.) |
100 Renfrew Drive, Suite 100, Markham,
Ontario, L3R 9R6
(Address of principal executive offices) (Zip Code)
Samantha Reburn, Chief Legal Officer and Corporate
Secretary
Tel: 905-474-1990 ext. 4134
(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, 2023
¨
Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended 2023.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This
Form SD of Sangoma Technologies Corporation (the “Company”) is filed pursuant
to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, and Form SD for the reporting period from January 1,
2023 to December 31, 2023. The Company has filed herewith as Exhibit 1.01 its Conflict Minerals Report for the calendar year
ended December 31, 2023, which is incorporated herein by reference. The Conflict Minerals Report is also available at https://www.sangoma.com/why-sangoma/investor-relations/.
The foregoing reference to the Company’s website is provided for convenience only. The contents of the Company’s website are
not incorporated by reference into this Form SD, including any attachments hereto, in any respects, nor are they deemed to be filed
with the United States Securities and Exchange Commission.
Item 1.02 Exhibit
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01
to this Form SD.
Section 2
Not applicable.
Section 3 - Exhibits
Item 3.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report for the calendar year ended December 31, 2023
SIGNATURE
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 undersigned hereunto duly authorized.
| SANGOMA TECHNOLOGIES CORPORATION |
|
| |
|
|
| By: |
/s/ Samantha Reburn |
|
| May 22, 2024 |
|
| Samantha Reburn |
|
| Chief Legal Officer and Corporate Secretary |
|
Exhibit 1.01
Sangoma Technologies Corporation
Conflict Minerals Report
For the Calendar Year Ended December 31,
2023
This conflict minerals report (this “Conflict
Minerals Report”) for Sangoma Technologies Corporation (collectively, the “Company”, “Sangoma”, “we”,
“our” or “us”) is being filed with the United States Securities and Exchange Commission (the “SEC”)
pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”),
and Form SD for the reporting period from January 1, 2023 to December 31, 2023. The Rule was adopted by the SEC to
implement reporting and disclosure requirements related to Conflict Minerals (as defined below) as directed by Section 1502 of the
Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants
whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. “Conflict
Minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives (collectively, “Conflict
Minerals”), which are limited to tin, tantalum, tungsten, and gold (“3TG”) for purposes of this Conflict Minerals Report.
For products which contain Conflict Minerals, registrants must conduct in good faith a reasonable country of origin inquiry (an “RCOI”)
designed to determine whether any of the Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country
(which encompasses Angola, Burundi, The Central African Republic, The Republic of the Congo, Rwanda,
South Sudan, Tanzania, Uganda and Zambia) (collectively, the “Covered Countries”). Numerous terms in this Conflict
Minerals Report are defined in the Rule and SEC Release No. 34-67716 issued by the SEC on August 22, 2012, and the reader
of this Conflict Minerals Report is referred to these materials for such definitions. This Conflict Minerals Report is not audited as
provided by the April 2014 public statement made by the SEC’s Division of Corporation Finance.
Conflict Minerals Disclosure
1. Company Overview
The Company
is a trusted leader in delivering value-based Communications as a Service (CaaS) solutions for businesses of all sizes. The Company simplifies
communications by providing businesses with the industry’s most comprehensive suite of cloud-native communications solutions, which
work together seamlessly to streamline business processes. The Company provides businesses with a complete solution, including cloud software,
endpoints, and connectivity – all delivered and supported by the Company’s expert team.
2. Overview of Products
In
addition to the CaaS solutions, the Company also offers network interconnection products, such as session border controller (SBCs), gateways
and PSTN interface and media processing boards. The Company contracts to manufacture certain of its network interconnection products
that contain Conflict Minerals that are necessary to the functionality or production of such products (together, the “Covered Products”).
For a further discussion of the Company’s products, including the Covered Products, please refer to the Annual Information Form of
the Company for the year ended June 30, 2023 (filed as Exhibit 99.1 to the Company's Annual Report on Form 40-F for the
year ended June 30, 2023, which was filed with the SEC on September 27, 2023 (the “Annual Report”)).
3. Supply Chain Overview and Due Diligence
The Company does not engage in the actual mining
of Conflict Minerals nor does it make purchases of raw ore or unrefined Conflict Minerals, and makes no purchases in the Covered Countries.
Rather, the Company’s manufacturing process is significantly removed from the mining, smelting and/or refining of 3TG minerals,
and there are numerous third parties in the supply chain between the original sources of 3TG minerals and the ultimate manufacture of
our products. Therefore, tracing these minerals to their sources is a challenge that requires the Company to rely on its direct and indirect
suppliers in its efforts to achieve supply chain transparency, including obtaining information regarding the origin of the 3TG minerals.
More specifically, the Company continues to rely upon its direct and indirect suppliers to provide information on the origin of Conflict
Minerals contained in the Covered Products, including the sources of Conflict Minerals that are supplied to those manufacturers.
The Company has taken certain measures to identify
the source of Conflict Minerals used in its products, including:
| · | Assessing whether the Conflict Minerals were necessary to the functionality or production of the products; |
| · | Conducting an RCOI by requiring our direct and indirect suppliers to complete the Responsible
Minerals Initiative’s Conflict Minerals Reporting Template (the “CMRT”), which is regarded as the most common reporting
tool for Conflict Minerals content and sourcing information worldwide; |
| · | Including Conflict Minerals-related requirements in our purchasing documents to direct suppliers; |
| · | Reviewing responses received from suppliers and following up on incomplete responses; |
| · | Sending reminders to suppliers who did not respond to the Company’s requests; and |
| · | Filing an annual report with the SEC on Form SD that includes a conflict minerals report. |
4. Reasonable Country of Origin Inquiry Results and Conclusion
As required
by the Rule, the Company undertook an analysis and determined that the Covered Products contain one or more Conflict Minerals, which are
necessary to the Covered Products’ functionality or production. Accordingly, as required by the Rule, the Company conducted in good
faith an RCOI regarding those Conflict Minerals, which was designed to determine whether any of those Conflict Minerals originated a Covered
Country or are from recycled or scrap sources, as each defined in the Rule. To this end, the Company sent communications to each third-party
manufacturer of the Covered Products explaining the requirements of the Rule and its applicability to the Company and seeking the
certification from each third-party manufacturer that the Conflict Minerals in the applicable Covered Product did not originate in a Covered
Country and/or to provide answers to the CMRT reflecting the Company’s position on the supply chain.
The Company received back a majority of responses
to its requests for information from these third-party suppliers. A list of smelters and refiners
that sourced 3TG for our products contracted to be manufactured during the reporting period covered by this Conflict Minerals Report is
attached hereto as Exhibit A. Each CMRT received from third-party suppliers identified lists of smelters or refiners, and
their countries of origin, which may supply Conflict Minerals utilized in the Covered Products. The Company exercised due diligence
to determine the source and chain of custody of the 3TG necessary to the functionality or production of the Covered Products as required
by the Rule. Certain responses to the Company’s RCOI regarding the origin or source of the 3TG contained in the components sold
to the Company by its third-party suppliers did not provide the Company with sufficient information to conclusively determine whether
the 3TG originated from a Covered Country, or whether such 3TG came from recycled or scrap sources. However, based on the information
that has been obtained from the Company’s third-party suppliers as of the date hereof, the
Company has reason to believe that a portion of the Conflict Minerals used in the Covered Products may have originated in the Covered
Countries set forth on Exhibit B and may not be exclusively from scrap or recycled sources. Furthermore, the necessary 3TG
in our products which may have originated from outside the Covered Countries came from one or more of the countries listed in the attached
Exhibit C.
We
believe our RCOI process was reasonably designed and performed in good faith, but there are inherent limitations in the information provided
to us by third parties, including the possibility of information being inaccurate, incomplete or falsified despite our efforts to validate
and confirm the information. Because of the relatively small amount of the Company’s components that contain Conflict Minerals
and the fact that the Company’s third-party suppliers are several steps removed from the applicable smelters and refiners, the Company
has assessed, and will continue to assess, if any additional actions can or should be implemented that would improve the information gathered
from its due diligence to ensure compliance with its reporting requirements under the Rule.
5. Non-Conformant or Sanctioned Smelters
Our version 6.31 CMRT (the “v6.31 CMRT”)
consists of a compilation of 3TG Smelters or Refiners (“SORs”) received from our suppliers for the 2023 reporting period.
The CMRT is regularly updated, and we required use of version 6.31, which was released on May 26, 2023, for reporting. We are aware
that some of these SORs are no longer considered RMAP eligible and may no longer have an audit status of conformant. Some of these
SORs on the v6.31 CMRT were either active or conformant for at least part of the 2023 reporting period and were reported by our suppliers
as used in their supply chains; therefore, we must continue to report them on our CMRT. Sangoma has no direct affiliation or business
with the SORs and instead relies on information from a multi-level upstream supply base. Based on these factors and the size of our
supply chain, we are unable to provide a specific removal date at this time as we have no direct influence over (i) the supply base
purchasing sources and (ii) related budgetary constraints.
We are committed to responsible sourcing and conformance
with global standards. As part of our due diligence procedures, we conduct a review of the supply chain and seek to promote supplier
direct/indirect contact with the smelters to encourage RMAP conformance and/or participation. In the case of smelters which are unable
(or unwilling) to conform to RMAP audit standards, we will thereafter work collaboratively with our supply chain to disengage from these
smelters and/or find alternative sourcing locations should they remain non-conformant. We reviewed the smelters of concern and have
provided comments below regarding the RMAP “non-conformant” and/or “high risk” smelters. Each of the sanctioned
SORs identified in our due diligence process are listed on Exhibit D attached hereto.
| · | Russia Sanctioned Smelters: Government sanctions against Russia took
effect beginning as of March 2022 in connection with the Russian-Ukrainian conflict. The Responsible Minerals Initiative (“RMI”)
has noted the Russia-related sanctions are not retroactive and became effective as of March 2022 to present date. Due to the
continued Russian presence and ongoing conflict in Ukraine, and ceased RMAP assessments in Russia, the amount of ineligible, sanctioned
and/or non-conformant smelters significantly increased during the 2023 reporting cycle. We must report applicable smelters in our CMRT
after they are identified in the supply chain by one (or more) of our suppliers. As part of our due diligence procedures for the 2023
reporting period, we have contacted the applicable suppliers regarding next steps, remediation and/or disengagement procedures from these
sanctioned smelters, and will continue to collaborate with our supply chain in an attempt to disengage from these smelters and/or find
alternative sourcing locations should they remain ineligible due to government sanctions. |
| · | RMAP Non-Conformant Smelters: The SORs in these categories are
not necessarily a “high risk” due to sourcing locations; instead, “high risk” constitutes a non-conformant category
due to the RMAP audit status. In particular, these SORs are non-conformant due to ineligibility to participate in RMAP or failed RMAP
inspections. The applicable SOR is deemed non-conformant if (i) its systems, processes, and practices significantly deviate
from the standard requirements or assessment criteria, (ii) sanctions are imposed on the smelter, (iii) the smelter refuses
to participate in the assessment process, or (iv) the smelter does not provide adequate access to facilities, personnel and/or evidence
to complete the assessment. The CMRT contains smelters that are non-conformant, and we are therefore engaging with our suppliers
to encourage RMAP conformance. Proof of participation in audit programs, conflict free evidence and/or corrective action plans are requested
from our suppliers. As part of our due diligence procedures, we will collaborate with our suppliers to remove the applicable non-conformant
SORs from their supply chains should they remain non-conformant with RMAP audit standards. |
| · | Democratic Republic of the Congo (the “DRC”) and
Conflict Affected and High-Risk Areas (“CAHRAs”) Regions: SORs that are RMI compliant can source from the
DRC and CAHRAs, but must continue to demonstrate the undertaking of due diligence actions to reasonably ensure that minerals are
sourced responsibly and align with the European policies on conflict prevention and the development of local communities. When
non-conformant status is noted for SORs sourcing from the DRC and/or CAHRAs, due diligence efforts are performed to advise the
supplier of the non-conformant status. This notification includes the referenced CMRT along with the high-risk and/or non-conformant
smelter report. Suppliers are encouraged to contact SORs directly (and indirectly) to encourage RMAP conformance and/or
participation, and to provide proposed next steps, due diligence procedures and/or corrective actions that are being taken for these
SORs. Additionally, alternative supply chain sourcing is encouraged for SORs, which remain non-conformant or are unwilling (or
unable) to participate in the RMAP. |
| · | Uyghur Forced Labor Prevention Act (the “UFLPA”): Some
SORs have been identified as having possible links to sourcing and/or refining operations in China’s Xinjiang Uyghur Autonomous
Region, which makes them subject to the UFLPA. Suppliers have been recontacted for due diligence programs or compliance procedures
regarding responsible sourcing from these areas. |
| · | Office of Foreign Assets Control Sanctions: One of our SORs, African
Gold Refinery, was identified as being sanctioned by the U.S. Department of the Treasury’s Office of Foreign Assets Control. While
Sangoma has no direct business with this SOR, such SOR was reported as being utilized by certain of our suppliers in their supply chains.
As part of our escalation process, we contacted the applicable suppliers regarding next steps, remediation and/or disengagement procedures
from the sanctioned SOR, and will seek to collaborate with our supply chain to disengage from such SOR. Several of our suppliers have
removed the applicable SOR from their supply chain, and the escalation process remains ongoing with respect to certain other suppliers. |
6. Continued Steps to Mitigate Risk
We intend to continue improving our RCOI process
and to further mitigate risk that any Conflict Minerals in our products could benefit armed groups in a Covered Country contributing to
human rights violations through the following measures:
| · | Continuing to conduct and report annually on supply chain RCOI for the applicable Conflict Minerals; |
| · | Examining the possibility of including Conflict Mineral-related clauses in new or renewed supplier agreements
such as requiring representations of compliance; and |
| · | Engaging with suppliers and using commercially reasonable efforts to direct them, where appropriate, to
training resources to attempt to improve the content of the supplier survey results. |
Moreover, we continually look to improve on our
due diligence processes. As the SEC and Organization for Economic Co-operation and Development provide more guidance on this process,
we will implement necessary measures to report on our Conflict Minerals status. We will work with our direct suppliers to get more relevant
and complete data on the source and chain of custody of the Conflict Minerals used in our products and will continue to refine the list
of relevant suppliers.
7. Cautionary Note Regarding Forward-Looking Statements
Certain statements contained in this Conflict
Minerals Report constitute forward-looking statements within the meaning of Canadian securities legislation, Section 21E of the Exchange
Act and Section 27A of the Securities Act of 1933, as amended. Please see “Forward Looking Information” in the Annual
Information Form of the Company for the year ended June 30, 2023 filed as Exhibit 99.1 to the Annual Report for a discussion
of the risks, uncertainties, assumptions and other factors that could cause the actual results and performance of the Company to vary
and deviate from those forward-looking statements. Readers are cautioned that such risks, uncertainties and assumptions are not exhaustive,
and the Company does not undertake any obligation to update, modify or revise any forward-looking statements, whether as a result of future
events, newly obtained information or otherwise, except as may be required by applicable laws. Moreover, given that forward-looking statements
involve significant and inherent risks, uncertainties and assumptions, readers of this Conflict Minerals Report are strongly advised not
to place any undue reliance on any such information.
Exhibit A
Smelters and Refiners Reported in the Company’s
Supply Chain as of May 13, 2024
| Metal |
Smelter Name |
Smelter Country |
| Gold |
Advanced Chemical Company |
UNITED STATES OF AMERICA |
| Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN |
| Gold |
Agosi AG |
GERMANY |
| Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
UZBEKISTAN |
| Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
BRAZIL |
| Gold |
Argor-Heraeus S.A. |
SWITZERLAND |
| Gold |
Asahi Pretec Corp. |
JAPAN |
| Gold |
Asaka Riken Co., Ltd. |
JAPAN |
| Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
TURKEY |
| Gold |
Aurubis AG |
GERMANY |
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES |
| Gold |
Boliden AB |
SWEDEN |
| Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
| Gold |
Caridad |
MEXICO |
| Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA |
| Gold |
Cendres + Metaux S.A. |
SWITZERLAND |
| Gold |
Yunnan Copper Industry Co., Ltd. |
CHINA |
| Gold |
Chimet S.p.A. |
ITALY |
| Gold |
Chugai Mining |
JAPAN |
| Gold |
Daye Non-Ferrous Metals Mining Ltd. |
CHINA |
| Gold |
DSC (Do Sung Corporation) |
KOREA, REPUBLIC OF |
| Gold |
Dowa |
JAPAN |
| Gold |
Eco-System Recycling Co., Ltd. East Plant |
JAPAN |
| Gold |
JSC Novosibirsk Refinery |
RUSSIAN FEDERATION |
| Gold |
Refinery of Seemine Gold Co., Ltd. |
CHINA |
| Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
CHINA |
| Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
CHINA |
| Gold |
LT Metal Ltd. |
KOREA, REPUBLIC OF |
| Gold |
Heimerle + Meule GmbH |
GERMANY |
| Gold |
Heraeus Metals Hong Kong Ltd. |
CHINA |
| Gold |
Heraeus Germany GmbH Co. KG |
GERMANY |
| Metal |
Smelter Name |
Smelter Country |
| Gold |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
| Gold |
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
CHINA |
| Gold |
HwaSeong CJ CO., LTD. |
KOREA, REPUBLIC OF |
| Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CHINA |
| Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN |
| Gold |
Istanbul Gold Refinery |
TURKEY |
| Gold |
Japan Mint |
JAPAN |
| Gold |
Jiangxi Copper Co., Ltd. |
CHINA |
| Gold |
Asahi Refining USA Inc. |
UNITED STATES OF AMERICA |
| Gold |
Asahi Refining Canada Ltd. |
CANADA |
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
RUSSIAN FEDERATION |
| Gold |
JSC Uralelectromed |
RUSSIAN FEDERATION |
| Gold |
JX Nippon Mining & Metals Co., Ltd. |
JAPAN |
| Gold |
Kazakhmys Smelting LLC |
KAZAKHSTAN |
| Gold |
Kazzinc |
KAZAKHSTAN |
| Gold |
Kennecott Utah Copper LLC |
UNITED STATES OF AMERICA |
| Gold |
Kojima Chemicals Co., Ltd. |
JAPAN |
| Gold |
Kyrgyzaltyn JSC |
KYRGYZSTAN |
| Gold |
L'azurde Company For Jewelry |
SAUDI ARABIA |
| Gold |
Lingbao Gold Co., Ltd. |
CHINA |
| Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
CHINA |
| Gold |
LS-NIKKO Copper Inc. |
KOREA, REPUBLIC OF |
| Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
CHINA |
| Gold |
Materion |
UNITED STATES OF AMERICA |
| Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN |
| Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA |
| Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA |
| Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE |
| Gold |
Metalor Technologies S.A. |
SWITZERLAND |
| Gold |
Metalor USA Refining Corporation |
UNITED STATES OF AMERICA |
| Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. |
MEXICO |
| Gold |
Mitsubishi Materials Corporation |
JAPAN |
| Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
| Metal |
Smelter Name |
Smelter Country |
| Gold |
Moscow Special Alloys Processing Plant |
RUSSIAN FEDERATION |
| Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. |
TURKEY |
| Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN |
| Gold |
Nihon Material Co., Ltd. |
JAPAN |
| Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN |
| Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
RUSSIAN FEDERATION |
| Gold |
MKS PAMP SA |
SWITZERLAND |
| Gold |
Penglai Penggang Gold Industry Co., Ltd. |
CHINA |
| Gold |
Prioksky Plant of Non-Ferrous Metals |
RUSSIAN FEDERATION |
| Gold |
PT Aneka Tambang (Persero) Tbk |
INDONESIA |
| Gold |
PX Precinox S.A. |
SWITZERLAND |
| Gold |
Rand Refinery (Pty) Ltd. |
SOUTH AFRICA |
| Gold |
Royal Canadian Mint |
CANADA |
| Gold |
Sabin Metal Corp. |
UNITED STATES OF AMERICA |
| Gold |
Samduck Precious Metals |
KOREA, REPUBLIC OF |
| Gold |
Samwon Metals Corp. |
KOREA, REPUBLIC OF |
| Gold |
SEMPSA Joyeria Plateria S.A. |
SPAIN |
| Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
CHINA |
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CHINA |
| Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
CHINA |
| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
RUSSIAN FEDERATION |
| Gold |
Solar Applied Materials Technology Corp. |
TAIWAN, PROVINCE OF CHINA |
| Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
| Gold |
Super Dragon Technology Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
| Gold |
Tanaka Kikinzoku Kogyo K.K. |
JAPAN |
| Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
CHINA |
| Gold |
Shandong Gold Smelting Co., Ltd. |
CHINA |
| Gold |
Tokuriki Honten Co., Ltd. |
JAPAN |
| Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
CHINA |
| Gold |
Torecom |
KOREA, REPUBLIC OF |
| Gold |
Umicore S.A. Business Unit Precious Metals Refining |
BELGIUM |
| Metal |
Smelter Name |
Smelter Country |
| Gold |
United Precious Metal Refining, Inc. |
UNITED STATES OF AMERICA |
| Gold |
Valcambi S.A. |
SWITZERLAND |
| Gold |
Western Australian Mint (T/a The Perth Mint) |
AUSTRALIA |
| Gold |
Yamakin Co., Ltd. |
JAPAN |
| Gold |
Yokohama Metal Co., Ltd. |
JAPAN |
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA |
| Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
CHINA |
| Gold |
Morris and Watson |
NEW ZEALAND |
| Gold |
SAFINA A.S. |
CZECHIA |
| Gold |
Guangdong Jinding Gold Limited |
CHINA |
| Gold |
Umicore Precious Metals Thailand |
THAILAND |
| Gold |
Geib Refining Corporation |
UNITED STATES OF AMERICA |
| Gold |
MMTC-PAMP India Pvt., Ltd. |
INDIA |
| Gold |
KGHM Polska Miedz Spolka Akcyjna |
POLAND |
| Gold |
Fidelity Printers and Refiners Ltd. |
ZIMBABWE |
| Gold |
Singway Technology Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
| Gold |
Shandong Humon Smelting Co., Ltd. |
CHINA |
| Gold |
Shenzhen Zhonghenglong Real Industry Co., Ltd. |
CHINA |
| Gold |
Al Etihad Gold Refinery DMCC |
UNITED ARAB EMIRATES |
| Gold |
Emirates Gold DMCC |
UNITED ARAB EMIRATES |
| Gold |
International Precious Metal Refiners |
UNITED ARAB EMIRATES |
| Gold |
Kaloti Precious Metals |
UNITED ARAB EMIRATES |
| Gold |
Sudan Gold Refinery |
SUDAN |
| Gold |
T.C.A S.p.A |
ITALY |
| Gold |
REMONDIS PMR B.V. |
NETHERLANDS |
| Gold |
Fujairah Gold FZC |
UNITED ARAB EMIRATES |
| Gold |
Industrial Refining Company |
BELGIUM |
| Gold |
Shirpur Gold Refinery Ltd. |
INDIA |
| Gold |
Korea Zinc Co., Ltd. |
KOREA, REPUBLIC OF |
| Gold |
Marsam Metals |
BRAZIL |
| Gold |
TOO Tau-Ken-Altyn |
KAZAKHSTAN |
| Gold |
Abington Reldan Metals, LLC |
UNITED STATES OF AMERICA |
| Gold |
Shenzhen CuiLu Gold Co., Ltd. |
CHINA |
| Gold |
Albino Mountinho Lda. |
PORTUGAL |
| Gold |
SAAMP |
FRANCE |
| Metal |
Smelter Name |
Smelter Country |
| Gold |
L'Orfebre S.A. |
ANDORRA |
| Gold |
8853 S.p.A. |
ITALY |
| Gold |
Italpreziosi |
ITALY |
| Gold |
WIELAND Edelmetalle GmbH |
GERMANY |
| Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
AUSTRIA |
| Gold |
AU Traders and Refiners |
SOUTH AFRICA |
| Gold |
GGC Gujrat Gold Centre Pvt. Ltd. |
INDIA |
| Gold |
Sai Refinery |
INDIA |
| Gold |
Modeltech Sdn Bhd |
MALAYSIA |
| Gold |
Bangalore Refinery |
INDIA |
| Gold |
Kyshtym Copper-Electrolytic Plant ZAO |
RUSSIAN FEDERATION |
| Gold |
Degussa Sonne / Mond Goldhandel GmbH |
GERMANY |
| Gold |
Pease & Curren |
UNITED STATES OF AMERICA |
| Gold |
JALAN & Company |
INDIA |
| Gold |
SungEel HiMetal Co., Ltd. |
KOREA, REPUBLIC OF |
| Gold |
Planta Recuperadora de Metales SpA |
CHILE |
| Gold |
ABC Refinery Pty Ltd. |
AUSTRALIA |
| Gold |
Safimet S.p.A |
ITALY |
| Gold |
State Research Institute Center for Physical Sciences and Technology |
LITHUANIA |
| Gold |
African Gold Refinery |
UGANDA |
| Gold |
Gold Coast Refinery |
GHANA |
| Gold |
NH Recytech Company |
KOREA, REPUBLIC OF |
| Gold |
QG Refining, LLC |
UNITED STATES OF AMERICA |
| Gold |
Dijllah Gold Refinery FZC |
UNITED ARAB EMIRATES |
| Gold |
CGR Metalloys Pvt Ltd. |
INDIA |
| Gold |
Sovereign Metals |
INDIA |
| Gold |
C.I Metales Procesados Industriales SAS |
COLOMBIA |
| Gold |
Eco-System Recycling Co., Ltd. North Plant |
JAPAN |
| Gold |
Eco-System Recycling Co., Ltd. West Plant |
JAPAN |
| Gold |
Augmont Enterprises Private Limited |
INDIA |
| Gold |
Kundan Care Products Ltd. |
INDIA |
| Gold |
Emerald Jewel Industry India Limited (Unit 1) |
INDIA |
| Gold |
Emerald Jewel Industry India Limited (Unit 2) |
INDIA |
| Gold |
Emerald Jewel Industry India Limited (Unit 3) |
INDIA |
| Gold |
Emerald Jewel Industry India Limited (Unit 4) |
INDIA |
| Metal |
Smelter Name |
Smelter Country |
| Gold |
K.A. Rasmussen |
NORWAY |
| Gold |
Alexy Metals |
UNITED STATES OF AMERICA |
| Gold |
Sancus ZFS (L’Orfebre, SA) |
COLOMBIA |
| Gold |
Sellem Industries Ltd. |
MAURITANIA |
| Gold |
MD Overseas |
INDIA |
| Gold |
Metallix Refining Inc. |
UNITED STATES OF AMERICA |
| Gold |
Metal Concentrators SA (Pty) Ltd. |
SOUTH AFRICA |
| Gold |
WEEEREFINING |
FRANCE |
| Gold |
Gold by Gold Colombia |
COLOMBIA |
| Gold |
Dongwu Gold Group |
CHINA |
| Gold |
Sam Precious Metals |
UNITED ARAB EMIRATES |
| Gold |
Coimpa Industrial LTDA |
BRAZIL |
| Tantalum |
Guangdong Rising Rare Metals-EO Materials Ltd. |
CHINA |
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
CHINA |
| Tantalum |
F&X Electro-Materials Ltd. |
CHINA |
| Tantalum |
XIMEI RESOURCES (GUANGDONG) LIMITED |
CHINA |
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA |
| Tantalum |
Jiujiang Tanbre Co., Ltd. |
CHINA |
| Tantalum |
AMG Brasil |
BRAZIL |
| Tantalum |
Metallurgical Products India Pvt., Ltd. |
INDIA |
| Tantalum |
Mineracao Taboca S.A. |
BRAZIL |
| Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
| Tantalum |
NPM Silmet AS |
ESTONIA |
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA |
| Tantalum |
QuantumClean |
UNITED STATES OF AMERICA |
| Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
CHINA |
| Tantalum |
Solikamsk Magnesium Works OAO |
RUSSIAN FEDERATION |
| Tantalum |
Taki Chemical Co., Ltd. |
JAPAN |
| Tantalum |
Telex Metals |
UNITED STATES OF AMERICA |
| Tantalum |
Ulba Metallurgical Plant JSC |
KAZAKHSTAN |
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA |
| Tantalum |
D Block Metals, LLC |
UNITED STATES OF AMERICA |
| Tantalum |
FIR Metals & Resource Ltd. |
CHINA |
| Metal |
Smelter Name |
Smelter Country |
| Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CHINA |
| Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. |
CHINA |
| Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CHINA |
| Tantalum |
KEMET de Mexico |
MEXICO |
| Tantalum |
TANIOBIS Co., Ltd. |
THAILAND |
| Tantalum |
TANIOBIS GmbH |
GERMANY |
| Tantalum |
Materion Newton Inc. |
UNITED STATES OF AMERICA |
| Tantalum |
TANIOBIS Japan Co., Ltd. |
JAPAN |
| Tantalum |
TANIOBIS Smelting GmbH & Co. KG |
GERMANY |
| Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES OF AMERICA |
| Tantalum |
Global Advanced Metals Aizu |
JAPAN |
| Tantalum |
Resind Industria e Comercio Ltda. |
BRAZIL |
| Tantalum |
Jiangxi Tuohong New Raw Material |
CHINA |
| Tantalum |
RFH Yancheng Jinye New Material Technology Co., Ltd. |
CHINA |
| Tantalum |
5D Production OU |
ESTONIA |
| Tantalum |
PowerX Ltd. |
RWANDA |
| Tin |
PT Rajehan Ariq |
INDONESIA |
| Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA |
| Tin |
Alpha |
UNITED STATES OF AMERICA |
| Tin |
PT Aries Kencana Sejahtera |
INDONESIA |
| Tin |
PT Premium Tin Indonesia |
INDONESIA |
| Tin |
Dowa |
JAPAN |
| Tin |
EM Vinto |
BOLIVIA (PLURINATIONAL STATE OF) |
| Tin |
Estanho de Rondonia S.A. |
BRAZIL |
| Tin |
Fenix Metals |
POLAND |
| Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA |
| Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CHINA |
| Tin |
Gejiu Kai Meng Industry and Trade LLC |
CHINA |
| Tin |
China Tin Group Co., Ltd. |
CHINA |
| Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
| Tin |
Metallic Resources, Inc. |
UNITED STATES OF AMERICA |
| Tin |
Mineracao Taboca S.A. |
BRAZIL |
| Metal |
Smelter Name |
Smelter Country |
| Tin |
Minsur |
PERU |
| Tin |
Mitsubishi Materials Corporation |
JAPAN |
| Tin |
Jiangxi New Nanshan Technology Ltd. |
CHINA |
| Tin |
Novosibirsk Tin Combine |
RUSSIAN FEDERATION |
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
| Tin |
Operaciones Metalurgicas S.A. |
BOLIVIA (PLURINATIONAL STATE OF) |
| Tin |
PT Artha Cipta Langgeng |
INDONESIA |
| Tin |
PT Babel Inti Perkasa |
INDONESIA |
| Tin |
PT Babel Surya Alam Lestari |
INDONESIA |
| Tin |
PT Bangka Tin Industry |
INDONESIA |
| Tin |
PT Belitung Industri Sejahtera |
INDONESIA |
| Tin |
PT Bukit Timah |
INDONESIA |
| Tin |
PT Mitra Stania Prima |
INDONESIA |
| Tin |
PT Panca Mega Persada |
INDONESIA |
| Tin |
PT Prima Timah Utama |
INDONESIA |
| Tin |
PT Refined Bangka Tin |
INDONESIA |
| Tin |
PT Sariwiguna Binasentosa |
INDONESIA |
| Tin |
PT Stanindo Inti Perkasa |
INDONESIA |
| Tin |
PT Timah Tbk Kundur |
INDONESIA |
| Tin |
PT Timah Tbk Mentok |
INDONESIA |
| Tin |
PT Timah Nusantara |
INDONESIA |
| Tin |
PT Tinindo Inter Nusa |
INDONESIA |
| Tin |
PT Tommy Utama |
INDONESIA |
| Tin |
Rui Da Hung |
TAIWAN, PROVINCE OF CHINA |
| Tin |
Thaisarco |
THAILAND |
| Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CHINA |
| Tin |
VQB Mineral and Trading Group JSC |
VIET NAM |
| Tin |
White Solder Metalurgia e Mineracao Ltda. |
BRAZIL |
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CHINA |
| Tin |
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
CHINA |
| Tin |
CV Venus Inti Perkasa |
INDONESIA |
| Tin |
Magnu's Minerais Metais e Ligas Ltda. |
BRAZIL |
| Tin |
PT Tirus Putra Mandiri |
INDONESIA |
| Tin |
Melt Metais e Ligas S.A. |
BRAZIL |
| Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
| Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
| Metal |
Smelter Name |
Smelter Country |
| Tin |
CV Ayi Jaya |
INDONESIA |
| Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
VIET NAM |
| Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
VIET NAM |
| Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
VIET NAM |
| Tin |
PT Cipta Persada Mulia |
INDONESIA |
| Tin |
An Vinh Joint Stock Mineral Processing Company |
VIET NAM |
| Tin |
Resind Industria e Comercio Ltda. |
BRAZIL |
| Tin |
Super Ligas |
BRAZIL |
| Tin |
Aurubis Beerse |
BELGIUM |
| Tin |
Aurubis Berango |
SPAIN |
| Tin |
PT Bangka Prima Tin |
INDONESIA |
| Tin |
PT Sukses Inti Makmur |
INDONESIA |
| Tin |
PT Menara Cipta Mulia |
INDONESIA |
| Tin |
Modeltech Sdn Bhd |
MALAYSIA |
| Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
CHINA |
| Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
CHINA |
| Tin |
PT Bangka Serumpun |
INDONESIA |
| Tin |
Pongpipat Company Limited |
MYANMAR |
| Tin |
Tin Technology & Refining |
UNITED STATES OF AMERICA |
| Tin |
Dongguan CiEXPO Environmental Engineering Co., Ltd. |
CHINA |
| Tin |
PT Rajawali Rimba Perkasa |
INDONESIA |
| Tin |
Luna Smelter, Ltd. |
RWANDA |
| Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
CHINA |
| Tin |
Precious Minerals and Smelting Limited |
INDIA |
| Tin |
Gejiu City Fuxiang Industry and Trade Co., Ltd. |
CHINA |
| Tin |
PT Mitra Sukses Globalindo |
INDONESIA |
| Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
BRAZIL |
| Tin |
CRM Synergies |
SPAIN |
| Tin |
Fabrica Auricchio Industria e Comercio Ltda. |
BRAZIL |
| Tin |
DS Myanmar |
MYANMAR |
| Tin |
PT Putera Sarana Shakti (PT PSS) |
INDONESIA |
| Tin |
Mining Minerals Resources SARL |
CONGO, DEMOCRATIC REPUBLIC OF THE |
| Metal |
Smelter Name |
Smelter Country |
| Tungsten |
A.L.M.T. Corp. |
JAPAN |
| Tungsten |
Kennametal Huntsville |
UNITED STATES OF AMERICA |
| Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CHINA |
| Tungsten |
CNMC (Guangxi) PGMA Co., Ltd. |
CHINA |
| Tungsten |
Global Tungsten & Powders Corp. |
UNITED STATES OF AMERICA |
| Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
| Tungsten |
Hunan Jintai New Material Co., Ltd. |
CHINA |
| Tungsten |
Japan New Metals Co., Ltd. |
JAPAN |
| Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
CHINA |
| Tungsten |
Kennametal Fallon |
UNITED STATES OF AMERICA |
| Tungsten |
Wolfram Bergbau und Hutten AG |
AUSTRIA |
| Tungsten |
Xiamen Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
CHINA |
| Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA |
| Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
CHINA |
| Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA |
| Tungsten |
Asia Tungsten Products Vietnam Ltd. |
VIET NAM |
| Tungsten |
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
CHINA |
| Tungsten |
H.C. Starck Tungsten GmbH |
GERMANY |
| Tungsten |
TANIOBIS Smelting GmbH & Co. KG |
GERMANY |
| Tungsten |
Masan High-Tech Materials |
VIET NAM |
| Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA |
| Tungsten |
Niagara Refining LLC |
UNITED STATES OF AMERICA |
| Tungsten |
China Molybdenum Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Ganzhou Haichuang Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Hydrometallurg, JSC |
RUSSIAN FEDERATION |
| Tungsten |
Unecha Refractory metals plant |
RUSSIAN FEDERATION |
| Metal |
Smelter Name |
Smelter Country |
| Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
PHILIPPINES |
| Tungsten |
ACL Metais Eireli |
BRAZIL |
| Tungsten |
Moliren Ltd. |
RUSSIAN FEDERATION |
| Tungsten |
Fujian Ganmin RareMetal Co., Ltd. |
CHINA |
| Tungsten |
Lianyou Metals Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
| Tungsten |
JSC "Kirovgrad Hard Alloys Plant" |
RUSSIAN FEDERATION |
| Tungsten |
NPP Tyazhmetprom LLC |
RUSSIAN FEDERATION |
| Tungsten |
Hubei Green Tungsten Co., Ltd. |
CHINA |
| Tungsten |
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
BRAZIL |
| Tungsten |
Cronimet Brasil Ltda |
BRAZIL |
| Tungsten |
Artek LLC |
RUSSIAN FEDERATION |
| Tungsten |
Fujian Xinlu Tungsten Co., Ltd. |
CHINA |
| Tungsten |
OOO “Technolom” 2 |
RUSSIAN FEDERATION |
| Tungsten |
OOO “Technolom” 1 |
RUSSIAN FEDERATION |
| Tungsten |
LLC Vostok |
RUSSIAN FEDERATION |
| Tungsten |
YUDU ANSHENG TUNGSTEN CO., LTD. |
CHINA |
| Tungsten |
HANNAE FOR T Co., Ltd. |
KOREA, REPUBLIC OF |
| Tungsten |
Tungsten Vietnam Joint Stock Company |
VIET NAM |
| Tungsten |
Nam Viet Cromit Joint Stock Company |
VIET NAM |
| Tungsten |
DONGKUK INDUSTRIES CO., LTD. |
KOREA, REPUBLIC OF |
EXHIBIT B
Covered Countries from Which the Company’s
Necessary 3TG
May Have Originated as of May 13,
2024
| 1. | Democratic Republic of Congo |
EXHIBIT C
Countries, Outside of the Covered Countries,
from Which the Company’s Necessary 3TG May Have Originated as of May 13, 2024
Andorra
Australia
Austria
Belgium
Bolivia
Brazil
Canada
Chile
China
Colombia
Czechia
Estonia
France
Germany
Ghana
India
Indonesia
Italy
Japan
Kazakhstan
Republic of Korea
Kyrgystan
Lithuania
Macedonia
Malaysia
Mauritania
Mexico
Myanmar
Netherlands
New Zealand
Norway
Peru
Philippines
Poland
Portugal
Russian Federation
Saudi Arabia
Singapore
South Africa
Spain
Sudan
Sweden
Switzerland
Taiwan
Thailand
Turkey
United Arab Emirates
United States of America
Uzbekistan
Vietnam
Zimbabwe
EXHIBIT D
Non-Conformant or Sanctioned SORs as of May 13,
2024
| Mineral |
Smelter Name |
Location |
| Gold |
OJSC Novosibirsk Refinery |
RUSSIAN FEDERATION |
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
RUSSIAN FEDERATION |
| Gold |
JSC Uralelectromed |
RUSSIAN FEDERATION |
| Gold |
Moscow Special Alloys Processing Plant |
RUSSIAN FEDERATION |
| Tin |
Novosibirsk Processing Plant Ltd. |
RUSSIAN FEDERATION |
| Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
RUSSIAN FEDERATION |
| Gold |
Prioksky Plant of Non-Ferrous Metals |
RUSSIAN FEDERATION |
| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
RUSSIAN FEDERATION |
| Tantalum |
Solikamsk Magnesium Works OAO |
RUSSIAN FEDERATION |
| Gold |
Fidelity Printers and Refiners Ltd. |
ZIMBABWE |
| Tungsten |
Hydrometallurg, JSC |
RUSSIAN FEDERATION |
| Tungsten |
Moliren Ltd. |
RUSSIAN FEDERATION |
| Gold |
Kyshtym Copper-Electrolytic Plant ZAO |
RUSSIAN FEDERATION |
| Gold |
African Gold Refinery |
UGANDA |
| Tungsten |
JSC "Kirovgrad Hard Alloys Plant" |
RUSSIAN FEDERATION |
| Tungsten |
NPP Tyazhmetprom LLC |
RUSSIAN FEDERATION |
| Tungsten |
Artek LLC |
RUSSIAN FEDERATION |
| Tungsten |
OOO “Technolom” 2 |
RUSSIAN FEDERATION |
| Tungsten |
OOO “Technolom” 1 |
RUSSIAN FEDERATION |
| Tungsten |
LLC Vostok |
RUSSIAN FEDERATION |
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