EX-1.01 2 ntgr-20170526xexhibit101co.htm EXHIBIT 1.01 Exhibit
Exhibit 1.01





CONFLICT MINERALS REPORT
netgearimage.jpg
NETGEAR, INC.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934
for the Calendar Year Ended December 31, 2016

Introduction

Rule 13p-1 was adopted by the United States Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to Conflict Minerals as directed by Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010. Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain Conflict Minerals necessary to the functionality or production of their products. Conflict Minerals are defined by Rule 13p-1 as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tungsten, tantalum, and gold (collectively, “3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Covered Countries (as defined below).

If a registrant has reason to believe that any 3TGs in their supply chain may have originated in the Democratic Republic of the Congo or an adjoining country ("Covered Countries"), or if they are unable to determine the country of origin of the 3TGs in their products, or that their products are manufactured entirely from recycled and scrap sources, then the issuer must exercise due diligence on the source and chain of custody of the 3TGs. The registrant must annually submit a Form SD and Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures. NETGEAR, Inc. ("NETGEAR" or the "Company") has determined that 3TGs are necessary to the functionality or production of some of its products during the 2016 calendar year and therefore, is required to perform due diligence and file this report annually. This report is NETGEAR's CMR for the reporting calendar year ended December 31, 2016.

This report is not audited, as Rule 13p-1 and current SEC guidance provide that if the registrant is not declaring products as "DRC Conflict Free," the CMR is not subject to an independent private sector audit.

Section 1 - Company Overview

NETGEAR was incorporated in Delaware in January 1996. The Company is a global networking company that delivers innovative networking and Internet connected products to consumers and growing businesses. The Company's products are built on a variety of proven technologies such as wireless (WiFi and LTE), Ethernet and powerline, with a focus on reliability and ease-of-use. The product line consists of wired and wireless devices that enable networking, broadband access and network connectivity. These products are available in multiple configurations to address the needs of the end-users in each geographic region in which the Company's products are sold. NETGEAR utilizes contract manufacturers, original design manufacturers and component vendors to supply components, assemblies and finished products.

NETGEAR’s internet address is www.netgear.com. This CMR will be posted on the Company’s website with other SEC filings under About Us/Investor Relations as soon as reasonably practicable after it is electronically filed with the SEC.

1.1 NETGEAR Products

NETGEAR's product portfolio is comprised of the following product categories:

Ethernet switches, which are multiple port devices used to network computing devices and peripherals via Ethernet wiring;
Wireless controllers and access points, which are devices used to manage and control multiple WiFi base stations on a campus or a facility providing WiFi connections to smart phones, tablets, laptops and other computing devices;
Internet security appliances, which provide Internet access through capabilities such as anti-virus and anti-spam;

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Unified storage, which delivers file and block based data into a single shared storage system, meeting the demands of small enterprises, education, hospitality and health markets through an easy-to-use interface for managing multiple storage protocols;
Broadband modems, which are devices that convert the broadband signals into Ethernet data that feeds Internet into homes and offices;
WiFi Gateways, which are WiFi routers with an integrated broadband modem, for broadband Internet access;
WiFi Hotspots, which create mobile WiFi Internet access that utilizes 3G and 4G LTE data networks for use on the go, and at home in place of traditional wired broadband, Internet access;
WiFi routers, which create a local area network (LAN) for home or office computer, mobile and Smart Home devices to connect and share a broadband Internet connection;
WiFi range extenders, which extend the range of an existing WiFi network to eliminate WiFi dead spots;
Powerline adapters and bridges, which extend wired and WiFi Internet connections to any AC outlet using existing electrical wiring;
Remote video security systems, which provide WiFi video and audio monitoring and recordings, accessible by smart phones, tablets or PCs and MACs; and
WiFi network adapters, which enable computing devices to be connected to the network via WiFi.

We conducted an analysis of NETGEAR products and found that small quantities of 3TG, necessary to their functionality or production, are found in substantially all NETGEAR products.

1.2 Conflict Minerals Report

For all product categories listed under 1.1, we have been unable to conclusively determine the origin of the 3TG that our products contain, or to conclusively determine to what extent they come from recycled or scrap sources; the facilities used to process them; their country of origin; or their mine or location of origin. Our suppliers reported at broad levels, often with the declaration scope as “Company” in their Conflict Minerals Reporting Template (“CMRT”).

This report describes our Reasonable Country of Origin Inquiry (“RCOI”) efforts, the due diligence measures we took on the 3TG source and chain of custody, the results of our due diligence efforts, expected risk assessment and mitigation steps.
 
1.3 Conflict Minerals Policy

NETGEAR has published its conflict minerals policy on its webpage located at:
http://www.netgear.com/images/conflict_minerals_policy_statement.pdf

Section 2 - Reasonable Country of Origin Inquiry (“RCOI”)

To determine whether the necessary 3TG in our products originated in Covered Countries, we first needed to determine the scope of our Conflict Minerals program. As determined and explained above, NETGEAR has determined that nearly all of its products contain one or more 3TGs and therefore, we determined that all suppliers of such products should be surveyed on the sourcing of those 3TGs. From there, we composed a list of suppliers associated with the covered products. We deemed it impractical to filter this list further to exclude some possibly irrelevant suppliers because we could not determine definitively the presence or absence of 3TGs in all parts supplied to manufacture of our products.

NETGEAR utilized the CMRT version 4.10 or higher to conduct a survey of all in scope suppliers. During the supplier survey process, we contacted all direct suppliers and required that they complete a valid CMRT and provide it to the Company for assessment. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, question 1 of the CMRT asks suppliers whether any of the 3TGs they use are necessary to the functionality or production of their products.

On an average, NETGEAR direct suppliers were contacted at least 3 times through email and/or phone call for follow up on their CMRT submission or for clarifying any questions that NETGEAR Conflict Minerals Program team or their designated 3rd party may have had. NETGEAR’s Conflict Minerals Program team member was also in-charge of all the communication with direct suppliers.


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NETGEAR Conflict Minerals Team also hosted training and Q&A session for all its direct suppliers to address their queries related to Conflict Minerals program and NETGEAR expectations.

We received completed CMRTs from all 59 in scope suppliers. Once all CMRTs were collected they were evaluated using automated data validation. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on their answers to questions 1 through 6.

All submitted forms are accepted and classified as valid or invalid so that data is still retained. As of May 25th, 2017, here were no invalid supplier submissions that could not be corrected.

Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries. Therefore, in accordance with the Rule, the Company performed due diligence on the source and chain of custody of the 3TGs in question.

Section 3 - Conflict Minerals Due Diligence Program Design

NETGEAR’s conflict minerals due diligence program is designed to conform in all material aspects with the framework recommended by the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, also known as OECD Guidance, as it relates to NETGEAR’s supply chain position as a “downstream” or finished product manufacturer and purchaser.

Summarized below are the components of Company’s program as they relate to the five-step framework set forth in the OECD Guidance:

3.1 Establish strong company management systems

Adopted and publicly communicated a conflict minerals company policy which is posted on NETGEAR website at http://www.netgear.com/images/conflict_minerals_policy_statement.pdf
As a member of the EICC (Electronic Industry Citizenship Coalition), required that our suppliers and contract manufacturers acknowledge and implement the EICC’s Code of Conduct, which includes an obligation to conduct due diligence regarding conflict minerals.
Assembled internal conflict minerals team, with representation from NETGEAR’s Operations, Legal, Procurement, Finance and Internal Audit.
Established a system of control through the use of Supplier Code of Conduct and transparency over NETGEAR’s conflict minerals supply chain by engaging first-tier suppliers and requesting relevant information through the use of a third-party supplier management vendor which utilized due diligence tools created by the Conflict Free Sourcing Initiative ("CFSI"), including the CMRT.
Provided updates on our conflict minerals due diligence progress and status to certain members of NETGEAR’s senior management.
Educated and trained those personnel responsible to work on NETGEAR’s Conflict Minerals Program. This includes internal team members and suppliers.
Established a grievance mechanism to allow employees, suppliers, and others to report suspected non-compliance with legal requirement and/or suspected non-compliance with NETGEAR’s Code of Ethics and Supplier Code of Conduct. These policies are publically available at http://www.netgear.com/about/corporate-social-responsibility/ethics/
Established an internal audit of our conflict minerals due diligence process.
Identified business records relating to conflict minerals due diligence, including records of due diligence processes, findings and resulting decisions, that will be retained in accordance with our records retention policies.


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3.2 Identify and manage risk in the supply chain

Identified relevant Tier 1* suppliers that supplied products containing 3TG by reference to bills of materials.
Requested such suppliers to provide information regarding smelters or refiners in our supply chain by using the CMRT.
Reviewed supplier responses for completeness and accuracy.
Compared information in supplier responses with the list of 3TG processing facilities that received a “conflict-free” designation, produced by the CFSP (Conflict Free Smelter Program).
Each facility that meets the CFSI definition of a smelter or refiner of a 3TG is assigned a risk of high, medium, or low based on three scoring criteria: geographic proximity to the Covered Countries, CFSP audit status, and known or plausible evidence of unethical or conflict sourcing.
Contacted non-responsive suppliers, requesting their responses.
Provided suppliers with feedback on responses containing errors, inconsistencies or incomplete information.
Evaluated suppliers on the strength of their internal conflict minerals programs. When suppliers meet or exceed the below criteria (yes to all four questions) they are deemed to have a strong program. When they do not meet those criteria they are deemed to have a weak program. The criteria used to evaluate the strength of their programs are:
Do you have a policy that includes DRC conflict-free sourcing?
Have you implemented due diligence measures for conflict-free sourcing?
Do you verify due diligence information received from your suppliers?
Does your verification process include corrective action management?

*NETGEAR’s definition of Tier 1 Supplier - ODM (Original Design Manufacturer), CM (Contract Manufacturer) and NETGEAR’s AVL (Approved Vendor List) with whom NETGEAR has directly negotiated the price of goods & services and has direct control or business relationship, but excluding the following suppliers: Plastics and software suppliers; Packaging suppliers; and Suppliers whose materials declarations confirm gold, tantalum, tin and tungsten are not contained in the applicable component.

3.3 Design and implement a strategy to respond to risk

Conducted regular conflict minerals team meetings to review, among other things, NETGEAR’s conflict minerals program, any potential or actual risks identified during due diligence, and the status of supplier responses.
Reported progress on a quarterly basis to our Senior Vice President, Worldwide Operations & Support.
Identified high risk smelters in NETGEAR’s supply chain by using smelter database from CFSI that includes information on smelter’s chain of custody of minerals. NETGEAR’s smelter risk calculation is based on 3 scoring criteria:
Geographic proximity to the DRC and covered countries;
Conflict-Free Smelter Program (CFSP) audit status; and
Known or plausible evidence of unethical or conflict sourcing.
Implemented an escalation plan for non-responsive suppliers and/or address incomplete or inaccurate supply chain information.
Requested that certain suppliers remove specific smelters or refiners from their supply chain that we deemed to be high-risk or invalid.
Informed non-responsive suppliers that we will assess, and potentially withhold, future business with them if they do not provide their supply chain conflict minerals information using the CMRT.
Conducted Conflict Minerals Program due diligence process audit of NETGEAR’s ODM partners.

3.4 Audit of smelter/refiner’s due diligence practices

Relied on the CFSP, the London Bullion Market Association, and the Responsible Jewellery Council to coordinate third-party audits of smelters and refiners to validate the sourcing practices of such facilities in our supply chain.
Provided indirect financial support for such third-party audits through our continued membership in the EICC and CFSI.
Participated in EICC & CFSI work groups, including smelter engagement and outreach.


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3.5 Report annually on supply chain due diligence

Publicly communicated Conflict Minerals Policy on company website at http://www.netgear.com/images/conflict_minerals_policy_statement.pdf
Filed our Form SD for the reporting period from January 1, 2016 to December 31, 2016, including this Conflict Minerals Report, with the Securities Exchange Commission and made it available on the Investor Relations pages of our website at http://investor.netgear.com/sec.cfm
Reported supply chain smelter information in this Conflict Minerals Report.

The content of any website referred to in this report is included for general information only and is not incorporated by reference in this report.

Section 4 - Due Diligence Results

NETGEAR does not have direct contractual relationships with smelters and refiners, therefore, we relied on our direct suppliers and the entire supply chain to gather and provide specific information on 3TGs used in NETGEAR products.

4.1 Survey Results

In 2016, NETGEAR conducted supply chain surveys, using the CMRT, of Tier 1 suppliers that we identified may contribute necessary 3TGs in our products. NETGEAR surveyed 59 Tier 1 suppliers and the results of our supply chain survey and the conclusion of our reasonable country of origin inquiry are as follows:
100% of NETGEAR surveyed suppliers provided a response using accepted version of the CMRT.
None of the 59 CMRTs collected have been deemed invalid.
The surveyed suppliers identified 305 legitimate smelters and refiner facilities which may process the necessary 3TGs contained in the products manufactured.
Of these 305 smelters and refiners, 249 are validated as conflict free by CFSI, and, based on information provided by CFSI, a further 10 have agreed to undergo or are currently undergoing a third-party audit.
We know or have reason to believe that a portion of the minerals processed by 24 of these 305 smelters and refiners may have originated in the Covered Countries and are not solely from recycled or scrap sources.
 
Attached as Table A is a list of all legitimate smelters and refiners listed by our suppliers in their CMRTs that appear on the list maintained by the CFSI. Since many of the CMRTs we received from suppliers were made at the company level bases, rather than on a product-level basis, we are not able to identify which smelters or refiners listed in Table A actually processed the 3TGs contained in our products. Therefore, the list of processing smelters and refiners disclosed in Table A may contain more facilities than those that actually processed the minerals contained in our products.

A list of potential countries of origin of from which the reported smelters and refiners collectively source from is provided in Table B. As with the list of smelters and refiners, many responses were provided at the company level and therefore, this list of countries may contain more than those that our products are being sourced from.

NETGEAR developed a point based supplier risk assessment system, specifically for our Conflict Minerals Program, to assess supplier risks based on multiple criteria. Of the 59 Tier 1 suppliers, no supplier received a risk score that is less than NETGEAR’s benchmark score.

Section 5 - Risk Mitigation and Due Diligence Improvement Plan    

5.1 Inherent limitation on due diligence measures

Because of our manufacturing business model, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals in the products we contract to have manufactured. Given our place in the supply chain, we have no direct relationships with smelters, refiners, and therefore possess no independent means of determining the source and origin of conflict mineral ores processed by smelters or refiners. Our due diligence processes are based on the necessity of seeking data from our suppliers and component manufacturers and

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those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by independent third-party audit programs.

5.2 Steps to be taken to mitigate risk and improve Due Diligence Process

We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the DRC or adjoining countries:

Continue to work with the CFSI and/or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance and/or other SEC recognized framework.
Engage with Tier 1 suppliers supplying us with 3TG from sources that support conflict in any covered country to establish an acceptable alternative source of 3TG.
Continue to work with Tier 1 suppliers to ensure that they have robust due diligence practices.
Continue to request Tier 1 suppliers to provide accurate, valid, and complete smelter information.
Provide our Tier 1 suppliers with training resources to educate and create awareness about Conflict Minerals, their role in mitigating the risk and creating transparent supply chain.
Engage Tier 1 suppliers to encourage smelters or refiners in supply chain, not yet identified by the CFSP or equivalent independent third-party audit, to undergo smelter audits and verify compliance.


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Table A
Smelter & Refiners Reported to be in Supply Chain of NETGEAR

Below list of smelters and refiners have been identified by our Tier 1 suppliers and may have been used in processing of necessary 3TGs contained in NETGEAR products:

Metal
Smelter or Refiner Facility Name
Location of Facility
Gold
Bangalore Refinery
India
Gold
Modeltech Sdn Bhd
Malaysia
Gold
Gujarat Gold Centre
India
Gold
AU Traders and Refiners
South Africa
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
Austria
Gold
WIELAND Edelmetalle GmbH
Germany
Gold
SAXONIA Edelmetalle Gmbh
Germany
Gold
SAAMP
France
Gold
TOO Tau-Ken-Altyn
Kazakhstan
Gold
Korea Zinc Co., Ltd.
Korea (Republic Of)
Gold
Remondis Argentia B.V.
Netherlands
Gold
T.C.A S.p.A
Italy
Gold
Kaloti Precious Metals
United Arab Emirates
Gold
Emirates Gold DMCC
United Arab Emirates
Gold
Al Etihad Gold Refinery DMCC
United Arab Emirates
Gold
Singway Technology Co., Ltd.
Taiwan, Province Of China
Gold
KGHM Polska Miedź Spółka Akcyjna
Poland
Gold
Republic Metals Corporation
United States Of America
Gold
MMTC-PAMP India Pvt., Ltd.
India
Gold
Geib Refining Corporation
United States Of America
Gold
Umicore Precious Metals Thailand
Thailand
Gold
Guangdong Jinding Gold Limited
China
Gold
SAFINA A.S.
Czech Republic
Gold
Morris and Watson
New Zealand
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
China
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Gold
Yokohama Metal Co., Ltd.
Japan
Gold
Yamamoto Precious Metal Co., Ltd.
Japan
Gold
Western Australian Mint trading as The Perth Mint
Australia
Gold
Valcambi S.A.
Switzerland
Gold
United Precious Metal Refining, Inc.
United States Of America
Gold
Umicore S.A. Business Unit Precious Metals Refining
Belgium
Gold
Umicore Brasil Ltda.
Brazil
Gold
Torecom
Korea (Republic Of)
Gold
Tongling Nonferrous Metals Group Co., Ltd.
China
Gold
Tokuriki Honten Co., Ltd.
Japan
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
China
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
China
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
Gold
Sumitomo Metal Mining Co., Ltd.
Japan

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Metal
Smelter or Refiner Facility Name
Location of Facility
Gold
Solar Applied Materials Technology Corp.
Taiwan, Province Of China
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Russian Federation
Gold
So Accurate Group, Inc.
United States Of America
Gold
Sichuan Tianze Precious Metals Co., Ltd.
China
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
China
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
China
Gold
SEMPSA Joyería Platería S.A.
Spain
Gold
Schone Edelmetaal B.V.
Netherlands
Gold
Samwon Metals Corp.
Korea (Republic Of)
Gold
Samduck Precious Metals
Korea (Republic Of)
Gold
Sabin Metal Corp.
United States Of America
Gold
Royal Canadian Mint
Canada
Gold
Rand Refinery (Pty) Ltd.
South Africa
Gold
PX Précinox S.A.
Switzerland
Gold
PT Aneka Tambang (Persero) Tbk
Indonesia
Gold
Prioksky Plant of Non-Ferrous Metals
Russian Federation
Gold
Penglai Penggang Gold Industry Co., Ltd.
China
Gold
PAMP S.A.
Switzerland
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Russian Federation
Gold
Ohura Precious Metal Industry Co., Ltd.
Japan
Gold
Elemetal Refining, LLC
United States Of America
Gold
Nihon Material Co., Ltd.
Japan
Gold
Navoi Mining and Metallurgical Combinat
Uzbekistan
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
Turkey
Gold
Moscow Special Alloys Processing Plant
Russian Federation
Gold
Mitsui Mining and Smelting Co., Ltd.
Japan
Gold
Mitsubishi Materials Corporation
Japan
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
Mexico
Gold
Metalor USA Refining Corporation
United States Of America
Gold
Metalor Technologies S.A.
Switzerland
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Singapore
Gold
Metalor Technologies (Hong Kong) Ltd.
China
Gold
Metalor Technologies (Suzhou) Ltd.
China
Gold
Matsuda Sangyo Co., Ltd.
Japan
Gold
Materion
United States Of America
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
China
Gold
LS-NIKKO Copper Inc.
Korea (Republic Of)
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
China
Gold
Lingbao Gold Co., Ltd.
China
Gold
L'azurde Company For Jewelry
Saudi Arabia
Gold
Kyrgyzaltyn JSC
Kyrgyzstan
Gold
Kojima Chemicals Co., Ltd.
Japan
Gold
Kennecott Utah Copper LLC
United States Of America
Gold
Kazzinc
Kazakhstan
Gold
Kazakhmys Smelting LLC
Kazakhstan

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Metal
Smelter or Refiner Facility Name
Location of Facility
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
Gold
JSC Uralelectromed
Russian Federation
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Russian Federation
Gold
Asahi Refining Canada Ltd.
Canada
Gold
Asahi Refining USA Inc.
United States Of America
Gold
Jiangxi Copper Co., Ltd.
China
Gold
Japan Mint
Japan
Gold
Istanbul Gold Refinery
Turkey
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
China
Gold
HwaSeong CJ CO., LTD.
Korea (Republic Of)
Gold
Hunan Chenzhou Mining Co., Ltd.
China
Gold
Heraeus Precious Metals GmbH & Co. KG
Germany
Gold
Heraeus Metals Hong Kong Ltd.
China
Gold
Heimerle + Meule GmbH
Germany
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
China
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
China
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
China
Gold
OJSC Novosibirsk Refinery
Russian Federation
Gold
Eco-System Recycling Co., Ltd.
Japan
Gold
Dowa
Japan
Gold
DODUCO GmbH
Germany
Gold
DSC (Do Sung Corporation)
Korea (Republic Of)
Gold
Daye Non-Ferrous Metals Mining Ltd.
China
Gold
Daejin Indus Co., Ltd.
Korea (Republic Of)
Gold
Chugai Mining
Japan
Gold
Chimet S.p.A.
Italy
Gold
Yunnan Copper Industry Co., Ltd.
China
Gold
Cendres + Métaux S.A.
Switzerland
Gold
CCR Refinery - Glencore Canada Corporation
Canada
Gold
Caridad
Mexico
Gold
C. Hafner GmbH + Co. KG
Germany
Gold
Boliden AB
Sweden
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
Gold
Aurubis AG
Germany
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Turkey
Gold
Asaka Riken Co., Ltd.
Japan
Gold
Asahi Pretec Corp.
Japan
Gold
Argor-Heraeus S.A.
Switzerland
Gold
AngloGold Ashanti Córrego do Sítio Mineração
Brazil
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Uzbekistan
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Germany
Gold
Aida Chemical Industries Co., Ltd.
Japan
Gold
Advanced Chemical Company
United States Of America
Gold
Kyshtym Copper-Electrolytic Plant ZAO
Russian Federation
Tantalum
Power Resources Ltd.
Macedonia

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Metal
Smelter or Refiner Facility Name
Location of Facility
Tantalum
Jiangxi Tuohong New Raw Material
China
Tantalum
Resind Indústria e Comércio Ltda.
Brazil
Tantalum
Tranzact, Inc.
United States Of America
Tantalum
KEMET Blue Powder
United States Of America
Tantalum
Global Advanced Metals Aizu
Japan
Tantalum
Global Advanced Metals Boyertown
United States Of America
Tantalum
Plansee SE Reutte
Austria
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Germany
Tantalum
H.C. Starck Ltd.
Japan
Tantalum
H.C. Starck Inc.
United States Of America
Tantalum
H.C. Starck Hermsdorf GmbH
Germany
Tantalum
H.C. Starck GmbH Laufenburg
Germany
Tantalum
H.C. Starck GmbH Goslar
Germany
Tantalum
H.C. Starck Co., Ltd.
Thailand
Tantalum
Plansee SE Liezen
Austria
Tantalum
KEMET Blue Metals
Mexico
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
China
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
China
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
China
Tantalum
FIR Metals & Resource Ltd.
China
Tantalum
D Block Metals, LLC
United States Of America
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
China
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
China
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
China
Tantalum
Ulba Metallurgical Plant JSC
Kazakhstan
Tantalum
Telex Metals
United States Of America
Tantalum
Taki Chemical Co., Ltd.
Japan
Tantalum
Solikamsk Magnesium Works OAO
Russian Federation
Tantalum
RFH Tantalum Smeltry Co., Ltd.
China
Tantalum
QuantumClean
United States Of America
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China
Tantalum
NPM Silmet AS
Estonia
Tantalum
Mitsui Mining and Smelting Co., Ltd.
Japan
Tantalum
Mineração Taboca S.A.
Brazil
Tantalum
Metallurgical Products India Pvt., Ltd.
India
Tantalum
LSM Brasil S.A.
Brazil
Tantalum
King-Tan Tantalum Industry Ltd.
China
Tantalum
Jiujiang Tanbre Co., Ltd.
China
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
China
Tantalum
Hi-Temp Specialty Metals, Inc.
United States Of America
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
China
Tantalum
F&X Electro-Materials Ltd.
China
Tantalum
Exotech Inc.
United States Of America
Tantalum
Duoluoshan
China
Tantalum
Conghua Tantalum and Niobium Smeltry
China
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
China

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Metal
Smelter or Refiner Facility Name
Location of Facility
Tin
Gejiu Jinye Mineral Company
China
Tin
Modeltech Sdn Bhd
Malaysia
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
China
Tin
Gejiu Fengming Metallurgy Chemical Plant
China
Tin
HuiChang Hill Tin Industry Co., Ltd.
China
Tin
PT Kijang Jaya Mandiri
Indonesia
Tin
An Thai Minerals Co., Ltd.
Viet Nam
Tin
PT Sukses Inti Makmur
Indonesia
Tin
PT Bangka Prima Tin
Indonesia
Tin
Elmet S.L.U.
Spain
Tin
Metallo-Chimique N.V.
Belgium
Tin
PT O.M. Indonesia
Indonesia
Tin
Resind Indústria e Comércio Ltda.
Brazil
Tin
An Vinh Joint Stock Mineral Processing Company
Viet Nam
Tin
PT Cipta Persada Mulia
Indonesia
Tin
CV Tiga Sekawan
Indonesia
Tin
CV Dua Sekawan
Indonesia
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Viet Nam
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Viet Nam
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Viet Nam
Tin
CV Ayi Jaya
Indonesia
Tin
PT Inti Stania Prima
Indonesia
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
Tin
Phoenix Metal Ltd.
Rwanda
Tin
PT ATD Makmur Mandiri Jaya
Indonesia
Tin
Melt Metais e Ligas S.A.
Brazil
Tin
PT Wahana Perkit Jaya
Indonesia
Tin
Magnu's Minerais Metais e Ligas Ltda.
Brazil
Tin
CV Venus Inti Perkasa
Indonesia
Tin
Yunnan Tin Company Limited
China
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
China
Tin
White Solder Metalurgia e Mineração Ltda.
Brazil
Tin
VQB Mineral and Trading Group JSC
Viet Nam
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
China
Tin
Thaisarco
Thailand
Tin
Soft Metais Ltda.
Brazil
Tin
Rui Da Hung
Taiwan, Province Of China
Tin
PT Tommy Utama
Indonesia
Tin
PT Tinindo Inter Nusa
Indonesia
Tin
PT Timah (Persero) Tbk Mentok
Indonesia
Tin
PT Timah (Persero) Tbk Kundur
Indonesia
Tin
PT Sumber Jaya Indah
Indonesia
Tin
PT Stanindo Inti Perkasa
Indonesia
Tin
PT Sariwiguna Binasentosa
Indonesia
Tin
PT Refined Bangka Tin
Indonesia

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Metal
Smelter or Refiner Facility Name
Location of Facility
Tin
PT Prima Timah Utama
Indonesia
Tin
PT Panca Mega Persada
Indonesia
Tin
PT Mitra Stania Prima
Indonesia
Tin
PT Karimun Mining
Indonesia
Tin
PT Eunindo Usaha Mandiri
Indonesia
Tin
PT DS Jaya Abadi
Indonesia
Tin
PT Bukit Timah
Indonesia
Tin
PT Belitung Industri Sejahtera
Indonesia
Tin
PT Bangka Tin Industry
Indonesia
Tin
PT Babel Inti Perkasa
Indonesia
Tin
PT Artha Cipta Langgeng
Indonesia
Tin
Operaciones Metalurgical S.A.
Bolivia
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
China
Tin
Mitsubishi Materials Corporation
Japan
Tin
Minsur
Peru
Tin
Mineração Taboca S.A.
Brazil
Tin
Metallic Resources, Inc.
United States Of America
Tin
Malaysia Smelting Corporation (MSC)
Malaysia
Tin
China Tin Group Co., Ltd.
China
Tin
Gejiu Kai Meng Industry and Trade LLC
China
Tin
Huichang Jinshunda Tin Co., Ltd.
China
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
China
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
China
Tin
Fenix Metals
Poland
Tin
Estanho de Rondônia S.A.
Brazil
Tin
EM Vinto
Bolivia
Tin
Dowa
Japan
Tin
CV United Smelting
Indonesia
Tin
CV Serumpun Sebalai
Indonesia
Tin
PT Aries Kencana Sejahtera
Indonesia
Tin
PT Justindo
Indonesia
Tin
CV Gita Pesona
Indonesia
Tin
Cooperativa Metalurgica de Rondônia Ltda.
Brazil
Tin
Alpha
United States Of America
Tin
CNMC (Guangxi) PGMA Co., Ltd.
China
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
China
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
China
Tungsten
Moliren Ltd
Russian Federation
Tungsten
Woltech Korea Co., Ltd.
Korea (Republic Of)
Tungsten
ACL Metais Eireli
Brazil
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
China
Tungsten
Philippine Chuangxin Industrial Co., Inc.
Philippines
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
China
Tungsten
Unecha Refractory metals plant
Russian Federation
Tungsten
Hydrometallurg, JSC
Russian Federation

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Metal
Smelter or Refiner Facility Name
Location of Facility
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
China
Tungsten
Niagara Refining LLC
United States Of America
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
China
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
China
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Viet Nam
Tungsten
H.C. Starck Smelting GmbH & Co.KG
Germany
Tungsten
H.C. Starck GmbH
Germany
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
China
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
China
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
China
Tungsten
Asia Tungsten Products Vietnam Ltd.
Viet Nam
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
China
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
China
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
China
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
China
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
China
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
China
Tungsten
Xiamen Tungsten Co., Ltd.
China
Tungsten
Wolfram Bergbau und Hütten AG
Austria
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
Viet Nam
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Viet Nam
Tungsten
Kennametal Fallon
United States Of America
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
China
Tungsten
Japan New Metals Co., Ltd.
Japan
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
China
Tungsten
Hunan Chenzhou Mining Co., Ltd.
China
Tungsten
Global Tungsten & Powders Corp.
United States Of America
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
China
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
China
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China
Tungsten
Kennametal Huntsville
United States Of America
Tungsten
A.L.M.T. Tungsten Corp.
Japan




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Table B

Countries of Origin

Below is the list of country of origin for the conflict minerals as a result of the RCOI, includes but may not be limited to:

Level 1 countries - countries of origin that are not identified as conflict regions or plausible countries for the export, smuggling or transit of conflict minerals, namely, Argentina, Australia, Austria, Belgium, Brazil, Canada, Chile, China, Columbia, Cote D’Ivoire, Czech Republic, Djibouti, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungry, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Lao People’s Democratic Republic, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Plurinational State of Bolivia, Portugal, Republic of Korea, Russian Federation, Sierra Leone, Singapore, Slovakia, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom of Great Britain, United States of America, Vietnam and Zimbabwe.

Level 2 countries - countries of origin that are known or plausible countries for the export, smuggling or transit of conflict minerals, namely, Kenya, Mozambique and South Africa.

Level 3 countries - countries of origin that are the DRC or its adjoining countries, namely, the DRC, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.

Recycled/Scrap - smelters or refiners that only process recycled or scrap materials.







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