EX-1.01 2 ntgr-20190524xexhibit101co.htm EXHIBIT 1.01 Exhibit
Exhibit 1.01





CONFLICT MINERALS REPORT
ntgrblacklogoa01.jpg
NETGEAR, INC.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934
for the Calendar Year Ended December 31, 2018

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 (DRC) 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 2018 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, 2018.

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 products to consumers, businesses and service providers. 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

During 2018, NETGEAR's product portfolio was 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 3TGs 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 Tier 1* suppliers of such products should be surveyed on the sourcing of those 3TGs.

*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, the price negotiation is during the reporting year for production order. This excludes the following suppliers: Suppliers where strategic purchasing only performs a reference price check; Plastics and software suppliers; Packaging suppliers; and Suppliers whose materials declarations confirm gold, tantalum, tin and tungsten are not contained in the applicable component.

NETGEAR utilized the CMRT version 5.11 or higher to conduct a survey of all in scope suppliers. The CMRT is a free, standardized reporting template developed by the Responsible Minerals Initiative that is known as the industry standard in conflict minerals data collection. During the supplier survey process, we contacted all Tier 1 suppliers and required that they complete a valid CMRT and provide it to the Company for assessment.

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

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3rd party may have had. NETGEAR’s Conflict Minerals Program team was also in-charge of all the communication with direct suppliers.

NETGEAR Conflict Minerals Team and their third party service provider 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 57 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 April 3rd, 2019 there was no invalid supplier submission 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

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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
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As a member of the RBA (Responsible Business Alliance, previously known as the EICC or the Electronic Industry Citizenship Coalition), required that our suppliers and contract manufacturers acknowledge and implement the RBA’s Code of Conduct, which includes an obligation to conduct due diligence regarding conflict minerals.
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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 Responsible Minerals Initiative (“RMI”), 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.
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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 publicly available at http://www.netgear.com/about/corporate-social-responsibility/ethics/
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Established an internal audit to review conflict minerals due diligence process against NETGEAR’s documented procedure and data accuracy in NETGEAR CMRT.
•
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

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Identified relevant Tier 1 suppliers that supplied products containing 3TG.
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Requested such suppliers to provide information regarding smelters or refiners in our supply chain by using the CMRT.
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Reviewed supplier responses for completeness and accuracy.
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Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations.
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Compared information in supplier responses with the list of 3TG processing facilities that received a “conflict-free” designation, produced by the RMAP (Responsible Minerals Assurance Process).
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Each facility that meets the RMI definition of a smelter or refiner of a 3TG is assessed according to red flag indicators defined in the OECD Guidance. To determine the level of risk that each smelter posed to the supply chain the Company assessed three criteria: geographic proximity to the Covered Countries, RMAP audit status, and credible evidence of unethical or conflict sourcing.
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Contacted non-responsive suppliers, requesting their responses.
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Provided suppliers with feedback on responses containing errors, inconsistencies or incomplete information and encouraged them to resubmit a valid response.
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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 based on these four questions in the CMRT:
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Have you established a conflict minerals sourcing policy?
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Have you implemented due diligence measures for conflict-free sourcing?
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Do you review due diligence information received from your suppliers against your company’s expectations?
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Does your review process include corrective action management?

3.3 Design and implement a strategy to respond to risk

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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.
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Reported progress during the team meeting or quarterly basis to our Chief Operations Officer
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Identified high risk smelters in NETGEAR’s supply chain by using smelter database from the RMI that includes information on smelter’s chain of custody of minerals. NETGEAR’s smelter risk calculation is based on the following criteria:
▪
Geographic proximity to the DRC and covered countries;
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Known mineral source country of origin;
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RMAP audit status;
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Credible evidence of unethical or conflict sourcing; and
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Peer Assessments conducted by credible third-party sources.
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Through the use of the Company’s third party service provider, contacted non-RMAP facilities to encourage them to join the program and undergo an audit
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Implemented an escalation plan for non-responsive suppliers and/or address incomplete or inaccurate supply chain information.
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Requested that certain suppliers remove specific smelters or refiners from their supply chain that we deemed to be high-risk or invalid.
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Engaged any suppliers whom we have reason to believe are supplying the Company with 3TGs from sources that may be considered a red-flag and encourage them to establish alternative sources of 3TGs.
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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.
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Conducted Conflict Minerals Program due diligence process audit of NETGEAR’s ODM partners.


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3.4 Audit of smelter/refiner’s due diligence practices

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Relied on the RMAP, 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.
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Provided indirect financial support for such third-party audits through our continued membership in the RBA and RMI.
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Participated in RBA & RMI work groups, including smelter engagement and outreach.

3.5 Report annually on supply chain due diligence

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Publicly communicated Conflict Minerals Policy on company website at http://www.netgear.com/images/conflict_minerals_policy_statement.pdf
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Filed our Form SD for the reporting period from January 1, 2018 to December 31, 2018, 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
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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 2018, NETGEAR conducted supply chain surveys, using the CMRT, of Tier 1 suppliers that we identified may contribute necessary 3TGs in our products. NETGEAR surveyed 57 Tier 1 suppliers and the results of our supply chain survey and the conclusion of our reasonable country of origin inquiry are as follows:
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100 % of NETGEAR surveyed suppliers provided a response using accepted version of the CMRT.
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None of the 57 CMRTs collected have been deemed invalid.
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The surveyed suppliers identified 281 legitimate smelters and refiner facilities which may process the necessary 3TGs contained in the products manufactured.
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Of these 281 smelters and refiners, 251 are validated as conflict free by RMI, and, based on information provided by the RMI through RMAP, a further 4 have agreed to undergo or are currently undergoing a third-party audit.
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We know or have reason to believe that a portion of the minerals processed by 20 of these 281 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 RMI. 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 57 Tier 1 suppliers, one supplier received a risk score that is less than NETGEAR’s benchmark score. NETGEAR has sent out a performance feedback report with improvement action items for the next reporting period.


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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 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:

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Continue to work with the RMI 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.
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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.
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Increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program.
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Emphasize the need for cooperation and support by our Tier 1 suppliers by implementing more direct Netgear-led escalations throughout the program.
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Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers and follow up with suppliers who appear to have gaps in their internal processes for conflict minerals.
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Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of 3TGs.
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Engage Tier 1 suppliers to encourage smelters or refiners in supply chain, not yet identified by the RMAP or equivalent independent third-party audit, to undergo smelter audits and verify compliance.
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Support our third party service provider in their smelter due diligence activities by signing a letter to be sent to smelters who have yet to enroll in RMAP, encouraging them to do so.

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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:

Smelter ID
Mineral
Smelter Name
Facility Location
CID000015
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
CID000019
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID002560
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
CID000035
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000041
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000058
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
CID000077
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000082
Gold
Asahi Pretec Corp.
JAPAN
CID000924
Gold
Asahi Refining Canada Ltd.
CANADA
CID000920
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
CID000090
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000103
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID002850
Gold
AU Traders and Refiners
SOUTH AFRICA
CID000113
Gold
Aurubis AG
GERMANY
CID002863
Gold
Bangalore Refinery
INDIA
CID000128
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000157
Gold
Boliden AB
SWEDEN
CID000176
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000180
Gold
Caridad
MEXICO
CID000185
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000189
Gold
Cendres + Metaux S.A.
SWITZERLAND
CID000233
Gold
Chimet S.p.A.
ITALY
CID000264
Gold
Chugai Mining
JAPAN
CID000328
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000343
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000362
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000401
Gold
Dowa
JAPAN
CID000359
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000425
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID002561
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002459
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
CID002243
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID001909
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID002312
Gold
Guangdong Jinding Gold Limited
CHINA
CID000651
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000689
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
CID000694
Gold
Heimerle + Meule GmbH
GERMANY
CID000707
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000711
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000767
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000778
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
CID000801
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA

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CID000807
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000814
Gold
Istanbul Gold Refinery
TURKEY
CID002765
Gold
Italpreziosi
ITALY
CID000823
Gold
Japan Mint
JAPAN
CID000855
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000927
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000929
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000937
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000957
Gold
Kazzinc
KAZAKHSTAN
CID000969
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
CID002511
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID000981
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID002605
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID001029
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001032
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001056
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001058
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID002762
Gold
L'Orfebre S.A.
ANDORRA
CID001078
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID002606
Gold
Marsam Metals
BRAZIL
CID001113
Gold
Materion
UNITED STATES OF AMERICA
CID001119
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001149
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001152
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001147
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001153
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001157
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
CID001161
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
CID001188
Gold
Mitsubishi Materials Corporation
JAPAN
CID001193
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID002509
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID001204
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001220
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
CID001236
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001259
Gold
Nihon Material Co., Ltd.
JAPAN
CID002779
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID001325
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001326
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID000493
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID001352
Gold
PAMP S.A.
SWITZERLAND
CID002919
Gold
Planta Recuperadora de Metales SpA
CHILE
CID001386
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001397
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001498
Gold
PX Precinox S.A.
SWITZERLAND
CID001512
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID000522
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID002582
Gold
Remondis Argentia B.V.
NETHERLANDS
CID001534
Gold
Royal Canadian Mint
CANADA
CID002761
Gold
SAAMP
FRANCE
CID001546
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA

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CID002973
Gold
Safimet S.p.A
ITALY
CID001555
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001562
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
CID002777
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID001585
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
CID001622
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001736
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID002516
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
CID001756
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001761
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
CID001798
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID002918
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
CID002580
Gold
T.C.A S.p.A
ITALY
CID001875
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001916
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001938
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001947
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001955
Gold
Torecom
KOREA, REPUBLIC OF
CID001977
Gold
Umicore Brasil Ltda.
BRAZIL
CID002314
Gold
Umicore Precious Metals Thailand
THAILAND
CID001980
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001993
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
CID002003
Gold
Valcambi S.A.
SWITZERLAND
CID002030
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
CID002778
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002100
Gold
Yamakin Co., Ltd.
JAPAN
CID002129
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID000197
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID002224
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID000092
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000211
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID002504
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
CID000456
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
CID000460
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID002505
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002558
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002557
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
CID000291
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000616
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID002544
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002547
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002548
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
CID002549
Tantalum
H.C. Starck Ltd.
JAPAN
CID002550
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002545
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002492
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002512
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002842
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID003191
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
CID000914
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000917
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA

9
    


CID002506
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002539
Tantalum
KEMET Blue Metals
MEXICO
CID002568
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
CID001076
Tantalum
LSM Brasil S.A.
BRAZIL
CID001163
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001175
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001192
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001277
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001200
Tantalum
NPM Silmet AS
ESTONIA
CID002847
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
CID001508
Tantalum
QuantumClean
UNITED STATES OF AMERICA
CID002707
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID001522
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
CID001769
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001869
Tantalum
Taki Chemical Co., Ltd.
JAPAN
CID001891
Tantalum
Telex Metals
UNITED STATES OF AMERICA
CID001969
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID002508
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID000292
Tin
Alpha
UNITED STATES OF AMERICA
CID002703
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID000228
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID003190
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID001070
Tin
China Tin Group Co., Ltd.
CHINA
CID002570
Tin
CV Ayi Jaya
INDONESIA
CID002592
Tin
CV Dua Sekawan
INDONESIA
CID000306
Tin
CV Gita Pesona
INDONESIA
CID002593
Tin
CV Tiga Sekawan
INDONESIA
CID000315
Tin
CV United Smelting
INDONESIA
CID002455
Tin
CV Venus Inti Perkasa
INDONESIA
CID000402
Tin
Dowa
JAPAN
CID002572
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID000438
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
CID000448
Tin
Estanho de Rondonia S.A.
BRAZIL
CID000468
Tin
Fenix Metals
POLAND
CID002848
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID000942
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000538
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID001908
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID000555
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID003116
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
CID002849
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002844
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID000760
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID001231
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID002468
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID001105
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID002500
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID001142
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA

10
    


CID002773
Tin
Metallo Belgium N.V.
BELGIUM
CID002774
Tin
Metallo Spain S.L.U.
SPAIN
CID001173
Tin
Mineracao Taboca S.A.
BRAZIL
CID001182
Tin
Minsur
PERU
CID001191
Tin
Mitsubishi Materials Corporation
JAPAN
CID002858
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002573
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID001314
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID002517
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID001337
Tin
Operaciones Metalurgical S.A.
BOLIVIA (PLURINATIONAL STATE OF)
CID003208
Tin
Pongpipat Company Limited
MYANMAR
CID000309
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID001399
Tin
PT Artha Cipta Langgeng
INDONESIA
CID002503
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID001402
Tin
PT Babel Inti Perkasa
INDONESIA
CID002776
Tin
PT Bangka Prima Tin
INDONESIA
CID003205
Tin
PT Bangka Serumpun
INDONESIA
CID001419
Tin
PT Bangka Tin Industry
INDONESIA
CID001421
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001428
Tin
PT Bukit Timah
INDONESIA
CID001434
Tin
PT DS Jaya Abadi
INDONESIA
CID002530
Tin
PT Inti Stania Prima
INDONESIA
CID001448
Tin
PT Karimun Mining
INDONESIA
CID002829
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002870
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002835
Tin
PT Menara Cipta Mulia
INDONESIA
CID001453
Tin
PT Mitra Stania Prima
INDONESIA
CID001457
Tin
PT Panca Mega Persada
INDONESIA
CID000313
Tin
PT Premium Tin Indonesia
INDONESIA
CID001458
Tin
PT Prima Timah Utama
INDONESIA
CID001460
Tin
PT Refined Bangka Tin
INDONESIA
CID001463
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001468
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID002816
Tin
PT Sukses Inti Makmur
INDONESIA
CID001471
Tin
PT Sumber Jaya Indah
INDONESIA
CID001477
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
CID001482
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
CID001490
Tin
PT Tinindo Inter Nusa
INDONESIA
CID002478
Tin
PT Tirus Putra Mandiri
INDONESIA
CID001493
Tin
PT Tommy Utama
INDONESIA
CID002706
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID001539
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
CID001758
Tin
Soft Metais Ltda.
BRAZIL
CID002756
Tin
Super Ligas
BRAZIL
CID001898
Tin
Thaisarco
THAILAND
CID003325
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
CID002574
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002036
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
CID002158
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002180
Tin
Yunnan Tin Company Limited
CHINA

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CID002859
Tin
Gejiu Jinye Mineral Company
CHINA
CID000004
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
CID002833
Tungsten
ACL Metais Eireli
BRAZIL
CID002513
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID000258
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000499
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID002645
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID002315
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002494
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID000568
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
CID000218
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID002542
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002541
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID000766
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID002579
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID000769
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID002649
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID000825
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID002551
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002321
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002318
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002317
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002316
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID000966
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
CID000105
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
CID002319
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002845
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
CID002589
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
CID002543
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
CID002827
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002815
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID001889
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID002724
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002044
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
CID002843
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002320
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002082
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002830
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002095
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA


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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 are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries.
Argentina, Armenia, Australia, Austria, Azerbaijan, Benin, Bolivia, Botswana, Brazil, Burkina Faso, Canada, Chile, China, Colombia, Cyprus, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Finland, Georgia, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Iran, Ivory Coast, Kazakhstan, Kyrgyzstan, Laos, Lebanon, Madagascar, Malaysia, Mali, Mauritania, Mauritius, Mexico, Mongolia, Morocco, Myanmar, Namibia, Nicaragua, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Portugal, Puerto Rico, Russian Federation, Saudi Arabia, Senegal, Sierra Leone, Slovakia, Solomon Islands, Spain, Suriname, Swaziland, Sweden, Taiwan, Thailand, Togo, Turkey, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Zimbabwe

•
Level 2 countries are known or plausible countries for smuggling, export out of region or transit of materials containing tantalum, tin, tungsten or gold.
Kenya, Mozambique, South Africa

•
Level 3 countries are defined as the DRC and its nine adjoining countries.
Burundi, Congo, Democratic Republic of the, Rwanda, Tanzania, Uganda, Zambia




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