EX-1.01 2 cy15cmr-ex101.htm EXHIBIT 1.01 Exhibit

PLANTRONICS, INC.
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2015

Introduction

This Conflict Minerals Report for the calendar year ended December 31, 2015 (“CY 2015”) is presented by Plantronics, Inc. (“we” or the “Company”) to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Exchange Act”).

Plantronics is a global company that manufactures and contracts to manufacture communications headsets and related equipment, as listed on our Form SD of which this report is a part, from a global supply chain with many levels. We work with our supplier base to identify the facilities processing Tin, Tantalum, Tungsten and Gold (3TG) in our supply chain.

As part of the RCOI described in Form SD, Plantronics performed a supplier survey using the Conflict Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Template (CMRT) during the second half of CY 2015. All 78 direct suppliers providing components used in Plantronics products within scope of the rule as described further in the Form SD) were included in the survey utilized for both RCOI and Due Diligence. The information obtained in the survey indicated that there was reason to believe that a portion of the 3TG used in Plantronics products may have originated in the Democratic Republic of Congo or the adjoining countries (the “covered countries”) and were not exclusively from scrap or recycled sources, triggering the due diligence steps described in the following sections.

Design and Execution of Due Diligence

We designed and implemented the majority of our due diligence measures prior to the current reporting year CY 2015. These measures were continued in CY 2015 and are described herein. They are designed to conform, in all material respects, to the framework in The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD 2012) including the Supplement on Tin, Tantalum and Tungsten, as well as those portions of the OECD Supplement on Gold applicable to downstream companies (collectively the “OECD Guidance”). In accordance with the five step OECD Guidance, our measures are designed to determine, to the best of our ability, the source and chain of custody of the 3TG materials necessary for the functionality and/or production of our products, to ascertain if the materials originated in one of the covered countries, and if so, whether armed groups directly or indirectly benefited as a result.
  
1.Establish Strong Company Management Systems
Plantronics has a company Conflict Minerals team consisting of representatives from the Engineering Compliance, Legal, Operations/Materials, Quality and Supplier Quality Engineering departments.
Plantronics has a conflict minerals policy statement publicly available at http://www.plantronics.com/us/company/global-citizenship/#section5.
We maintain a grievance reporting system open to both employees and suppliers through our ethics reporting system at http://www.plantronics.com/us/company/global-citizenship/#section5.
In addition to any annual survey using the CMRT, supplier obligations and requirements in this regard have been incorporated into the Supplier Code of Conduct, which is available on the corporate governance section of our website. In addition, Conflict Minerals Requirements, including due diligence and participation in annual supplier survey, are included in our controlled “Purchasing & Supplier Management” methods and procedures document.
Plantronics purchase orders and contracts include a supplier Conflict Minerals Due Diligence expectations clause.



Plantronics establishes and maintains long term relationships with the majority of our first tier Original Design, Contract, and Custom Part Manufacturers to facilitate engagement with suppliers to improve due diligence performance.
Since we have limited direct relationships with any facilities processing 3TG, we are an active participant in the Conflict Free Sourcing Initiative (CFSI) (http://www.conflictfreesourcing.org/about/members-and-collaborations/) to aid the development of conflict free supply chains at the smelter or refiner level and further upstream.
Conflict Minerals materials records are maintained pursuant to our records retention policy.
The Conflict Minerals Team issues a formal report of progress and findings to upper management quarterly.
We created a controlled Methods and Procedures document regarding Conflict Minerals Due Diligence Procedures.
For CY2014 we purchased and installed a software tool to improve management and auditability of supplier communications, as well as to receive, evaluate, store, and determine statistics on incoming CMRTs which we continued to use in CY 2015.
Starting in CY 2015 our supplier quality team conducted audits of selected first tier suppliers’ conflict minerals due diligence programs. These audits assessed policy, training, record retention and data validation. Eight such audits were performed in 2015, three audits resulted in supplier corrective action plans, all of which were successfully completed.

2.Identified and Assessed Risk in the Supply Chain
We conducted a supplier survey of the 78 direct first tier suppliers providing products or components within scope of the rule; necessary for the functionality of our products and likely to contain 3TG. Prior to conducting the survey we conducted one-on-one training with selected critical suppliers in Asia, either in person or by web. The survey required that the supplier return the then current version of the CMRT (4.0x). Our request included information to inform the suppliers of Plantronics’ Conflict Minerals Rule reporting obligations as well as the assistance required from our supply chain, and the resulting expectations for the sourcing of conflict minerals. A link to the Plantronics’ Conflict Minerals policy was included in the request.
Reminders, late notices and finally delinquent notices were sent to non-responsive suppliers. Commodity Managers were involved in escalation at the time of the delinquent notices. We did not find it necessary to restrict business or disengage from any supplier due to failure to respond to the survey.
All incoming CMRTs underwent a two-step review process. The first step is a PASS/FAIL check by our Conflict Minerals software for completeness and internal consistency of the declaration and submitted smelter list. A message was automatically sent by the system to suppliers submitting CMRTs containing errors with an explanation of the error and a request for corrective action and re-submission.
Once CMRTs passed this first evaluation, they were then evaluated by internal compliance engineers on an ACCEPT/MODIFY basis for consistency with the known content and complexity of the products or components provided. A message was sent to suppliers submitting CMRTs found insufficient or incomplete with an explanation and request for corrective action. We continued to communicate with those suppliers to improve the content and quality of their responses. 100% of the suppliers responded by returning a CMRT, and eventually 97% of the responses were accepted.
In addition, we used a data mining service to obtain conflict minerals information, also using the CFSI CMRT, from manufacturers of off-the-shelf components with whom we had no direct relationship.
Facilities processing 3TG reported by the supply chain were categorized, based on information available through CFSI, as
Legitimate Smelters or Refiners (“SORs”),
Entities known to Not be legitimate SORs.
In addition to SORs known to, or believed to, source from the covered countries who were not validated as conflict free, Plantronics identified non-smelters as a source of risk, since the actual source of the 3TG is not known.




3.Designed and Implemented a Strategy to Respond to Identified Risks
We have continuously conducted research into “alleged” SORs - companies reported that were not on any list of known SORs- reported in our supplier survey to determine the nature of these entities’ business. This effort is done both through collaborative efforts in CFSI, and our own independent research in areas where we have associates that speak the local language. Through these efforts the final number of “alleged” SORs has been significantly reduced progressively from the number in previous reporting years, from 83 in CY2013 to 46 in CY2014 to none in the final CY 2015 survey results. This is attributable to determining that many of the alleged SORs were indeed legitimate SORs or legitimate SOR aliases, or determination of the company’s actual business, as well as improved supplier reporting.
We also asked suppliers initially reporting non-smelters or alleged smelters to verify the information and if possible, identify actual smelters. We gave feedback concerning the actual nature of a non-smelter’s business to the supplier when such information was available, primarily through CFSI collaborative efforts.
We continued to work within CFSI teams to determine the legitimacy of any “alleged SORs” reported by our supply chain. We encouraged known smelters not yet validated as Conflict Free to participate in Conflict Free Smelter Program (CFSP).

4.Carry out independent 3rd Party Audit of Smelters’/Refiners’ Due Diligence Practices
Because Plantronics has few direct business relationships with smelters, we worked within industry initiatives to implement validation of DRC conflict free smelters as outlined in OECD Guidance for downstream companies. We relied on the results of audits conducted by CFSP to determine smelters’ Due Diligence Practices. As an active contributing member of the CFSI, we actively participated in outreach to confirmed smelters to encourage participation in CFSP.
A Plantronics associate acted as a single point of contact to directly help two smelters prepare for the CFSP audit.

5.Report Annually on Supply Chain Due Diligence
Our Form SD and this Report together constitute our annual report on our Conflict Minerals Due Diligence. These have been filed with the SEC and are available on our website at http://www.plantronics.com/us/company/global-citizenship/#section5.

Results of due diligence performed

Most of our direct supplier responses represented their supply chain at a company-level rather than being product-specific. Therefore, the list of processing facilities contained in this report may contain more facilities than those that actually process the conflict minerals contained in our products. The total number of unique entities reported as smelters or refiners by the Plantronics supplier base as result of CY 2015 Supplier Survey was 299. Of these, 279 have been confirmed as being legitimate SORs by the CFSI, 20 are known to not be legitimate SORs, and there were no reported entities whose status could not be confirmed as of our cutoff date of April 15, 2016.
Of the 279 legitimate SORs reported by the supplier base, 210 had been validated by CFSP as being in conformance with a CFSP recognized conflict free audit protocol (CFSP, London Bullion Market Association, or Responsible Jewelry Council). Another 46 were in process or communication with CFSP, or participating in another recognized program, but had not achieved validated status as of April 30, 2016.
The twenty entities reported by our supply chain that are not legitimate smelters fell into three categories: companies that are group companies with a number of legitimate smelter locations (9), formerly legitimate smelters that had either temporarily or permanently suspended operations (4) or companies downstream of the actual smelter (7).




The remaining legitimate smelters require outreach to encourage participation in a conflict free program. Plantronics actively participates in CFSI targeted outreach through email and, in countries where we have associates that speak the local language, telephone calls. We have also begun to interact directly with selected smelters to help guide them through the CFSP audit process.
Of the 279 legitimate SORs reported by the supplier base, we determined during RCOI that there was no reason to believe that 136 of the SORs sourced or may have sourced any minerals from the covered countries.
Of the remaining smelters with definitive RCOI information available through CFSI or other publicly available information, 19 were known or reasonably believed to source minerals from the DRC, the surrounding countries or countries known as possible routes for smuggling or export of minerals out of the DRC. All 19 are CFSP validated. The facilities not eliminated during RCOI, along with the location of the facility and the conflict free status are listed in Table I. The countries believed to be the source of 3TG in our products are listed in Table II.
While we did not find any information that would give us reason to believe armed groups directly or indirectly benefitted as a result of the mining, transport for processing of 3TG in our products, the smelter information collected from our suppler base included non-smelters as well as a number of legitimate smelters or refiners that had not been audited and validated as DRC Conflict Free by the CFSP, or any other recognized organization. For these reasons, we are unable to determine that any of our products or product categories are DRC Conflict Free.

Steps to be taken to further mitigate risk

We intend to continue taking the following steps to build on momentum established in the past two years to improve the due diligence conducted, and to further mitigate the risk that the necessary conflict minerals in our products benefit armed groups in the Covered Countries:

Improve the accuracy of our smelter list by requesting that the suppliers providing Parent companies of SORs determine which smelter site is involved, verify that materials from smelters that have ceased operations are still in their supply chain, and try to obtain smelter information from downstream companies named on their CMRT.
Try to increase the number of off-the-shelf part manufacturers from whom conflict minerals data is obtained.
Maintain membership and active participation within CFSI, conducting research into smelter operations, sourcing and compliance. Continue to conduct coordinated outreach to encourage more smelters to participate in recognized conflict free validation programs such as the Conflict Free Smelter Program.
Continue to engage directly with selected smelters to help guide them through the CFSP audit process.
Encourage our supply chain to use validated conflict free smelters, in particular those sourcing responsibly within the DRC and adjoining countries, to the greatest extent possible.





Table I. Plantronics Smelter List

List and status of SORs are as of April 30, 2016 and status data is from CFSI. The list includes 143 recognized SORs that are either known to obtain at least some minerals from the covered countries or are SORs where the source of the minerals was not disclosed and could not be determined. It does not include those SORs that source only from outside the covered countries as determined through RCOI, or process only recycled or scrap materials. “Country” refers to the location of the facility, not the source of minerals. The smelter location was not used for RCOI, since it does not necessarily determine the source of the ore, although location near abundant mineral resources can be an indicator of mineral sourcing. The general geographical breakdown of all the reported smelters is as follows:

Region
Number
Asia
175
Europe
36
North America
31
South America
16
Russia and Central Asia
15
Middle East
4
Africa
2

Status is defined as:

Compliant: Smelters or refiners that have been audited and have been validated as compliant with the Conflict-Free Smelter Program or cross recognized (LBMA, RJC) assessment protocols.

Not Validated: Legitimate Smelters or refiners who have not yet completed a CFSP or cross recognized audit validating a conflict free process.

CFSP Active: Smelters and refiners on the Active list have committed to undergo a CFSP audit.

Status data from CFSI as of April 30, 2016:

Metal
Smelter Name
Country
CFSI Smelter ID
Conflict Free Status
Gold
Advanced Chemical Company
UNITED STATES
CID000015
CFSP Active
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
CFSP Active
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
CID000058
Compliant
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Compliant
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Compliant
Gold
Asahi Refining USA Inc.
UNITED STATES
CID000920
Compliant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
Compliant
Gold
Aurubis AG
GERMANY
CID000113
Compliant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Compliant
Gold
Boliden AB
SWEDEN
CID000157
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Compliant
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Compliant
Gold
Cendres + Métaux S.A.
SWITZERLAND
CID000189
CFSP Active



Metal
Smelter Name
Country
CFSI Smelter ID
Conflict Free Status
Gold
Chimet S.p.A.
ITALY
CID000233
Compliant
Gold
Chugai Mining
JAPAN
CID000264
Not Validated
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
CFSP Active
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Not Validated
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
CFSP Active
Gold
Faggi Enrico S.p.A.
ITALY
CID002355
CFSP Active
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
CID000522
Not Validated
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
Not Validated
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
Not Validated
Gold
Heraeus Ltd. Hong Kong
CHINA
CID000707
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Compliant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
Not Validated
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
CID000778
Not Validated
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Not Validated
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Compliant
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Compliant
Gold
Japan Mint
JAPAN
CID000823
Compliant
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Compliant
Gold
Kazzinc
KAZAKHSTAN
CID000957
Compliant
Gold
Kennecott Utah Copper LLC
UNITED STATES
CID000969
Compliant
Gold
Korea Metal Co., Ltd.
KOREA, REPUBLIC OF
CID000988
Not Validated
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Not Validated
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
Not Validated
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
Not Validated
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
Not Validated
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Compliant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Not Validated
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Compliant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Compliant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
CFSP Active



Metal
Smelter Name
Country
CFSI Smelter ID
Conflict Free Status
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Compliant
Gold
Metalor USA Refining Corporation
UNITED STATES
CID001157
Compliant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
CID001161
Compliant
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Compliant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Compliant
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.?.
TURKEY
CID001220
Compliant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
CFSP Active
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Compliant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Compliant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Compliant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Compliant
Gold
PAMP S.A.
SWITZERLAND
CID001352
Compliant
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Not Validated
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Compliant
Gold
PX Précinox S.A.
SWITZERLAND
CID001498
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Compliant
Gold
Republic Metals Corporation
UNITED STATES
CID002510
Compliant
Gold
Royal Canadian Mint
CANADA
CID001534
Compliant
Gold
Sabin Metal Corp.
UNITED STATES
CID001546
Not Validated
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
CFSP Active
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
CID001562
Not Validated
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
CFSP Active
Gold
Schone Edelmetaal B.V.
NETHERLANDS
CID001573
Compliant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
CID001585
Compliant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
Not Validated
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Compliant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Compliant
Gold
So Accurate Group, Inc.
UNITED STATES
CID001754
Not Validated
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Compliant
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Compliant
Gold
T.C.A S.p.A
ITALY
CID002580
Compliant



Metal
Smelter Name
Country
CFSI Smelter ID
Conflict Free Status
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Compliant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Compliant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Not Validated
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
CFSP Active
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Compliant
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Compliant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Compliant
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Compliant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
CID002030
Compliant
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
CFSP Active
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Not Validated
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Compliant
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
CID002243
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
CID000291
Compliant
Tantalum
Duoluoshan
CHINA
CID000410
Compliant
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Compliant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
CID002557
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Compliant
Tantalum
H.C. Starck GmbH Goslar
GERMANY
CID002545
Compliant
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
CID002546
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Compliant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Compliant
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Compliant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Compliant
Tantalum
Mitsui Mining & Smelting
JAPAN
CID001192
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Compliant
Tantalum
Taki Chemicals
JAPAN
CID001869
Compliant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Compliant
Tantalum
Zhuzhou Cemented Carbide
CHINA
CID002232
Compliant
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
CFSP Active
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
CID000278
Not Validated
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC
VIET NAM
CID002572
CFSP Active



Metal
Smelter Name
Country
CFSI Smelter ID
Conflict Free Status
Tin
Estanho de Rondônia S.A.
BRAZIL
CID000448
Not Validated
Tin
Feinhütte Halsbrücke GmbH
GERMANY
CID000466
CFSP Active
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
CFSP Active
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Not Validated
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Not Validated
Tin
Linwu Xianggui Ore Smelting Co., Ltd.
CHINA
CID001063
Not Validated
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Compliant
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
CID001231
Not Validated
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
CFSP Active
Tin
Phoenix Metal Ltd.
RWANDA
CID002507
CFSP Active
Tin
PT Alam Lestari Kencana
INDONESIA
CID001393
Not Validated
Tin
PT Bangka Kudai Tin
INDONESIA
CID001409
Not Validated
Tin
PT Bangka Timah Utama Sejahtera
INDONESIA
CID001416
Not Validated
Tin
PT Fang Di MulTindo
INDONESIA
CID001442
Not Validated
Tin
PT Karimun Mining
INDONESIA
CID001448
CFSP Active
Tin
PT Pelat Timah Nusantara Tbk
INDONESIA
CID001486
Not Validated
Tin
PT Seirama Tin Investment
INDONESIA
CID001466
Not Validated
Tin
Thaisarco
THAILAND
CID001898
Compliant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
CFSP Active
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
CFSP Active
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Compliant
Tungsten
Ganxian Shirui New Material Co., Ltd.
CHINA
CID002531
Not Validated
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313
Not Validated
Tungsten
Sanher Tungsten Vietnam Co., Ltd.
VIET NAM
CID002538
CFSP Active
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
CID002011
Compliant
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
CID002044
Compliant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Compliant

Table II. The Countries of Origin for the minerals present in Plantronics products are believed to potentially include, but may not be limited to the following. Information is from smelters, news reports, industry associations, metals brokers’ reports, and USGS reports (Countries listed for 3T are reported to account for ~98% of global mined ore):

Tungsten: China, Vietnam, Russia, Canada, Bolivia, Rwanda, Austria, Spain, Portugal, United Kingdom, Republic of Korea, Untied States, DRC

Tantalum: Rwanda, DRC, Brazil, Mozambique, Chain, Nigeria, Ethiopia, Burundi, Canada, Australia, Uganda




Tin: China, Indonesia, Myanmar, Peru, Bolivia, Brazil, DRC, Australia, Malaysia, Nigeria, Russia, Rwanda, Thailand, Vietnam, Russia, Portugal

Gold: China, Australia, Russia, United States, Peru, Canada, South Africa, Mexico, Uzbekistan, Ghana, Brazil, Papua New Guinea; DRC, Kazakhstan, Argentina, Tanzania, Mali, Dominican Republic, Columbia, Philippines Chile, Burkina Faso, Ivory Coast, Mongolia, Turkey, Guinea