EX-1.01 2 ntgr-ex101_6.htm EX-1.01 ntgr-ex101_6.htm

Exhibit 1.01

 

 

 

 

CONFLICT MINERALS REPORT

NETGEAR, INC.

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934

for the Calendar Year Ended December 31, 2020

 

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 2020 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, 2020.

 

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 2020, 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;

 

•

WiFi network adapters, which enable computing devices to be connected to the network via WiFi.

 

•

Meural, a network-connected LCD display that can download and display arts from Netgear/Meural digital library as well as any personal content that the individual has uploaded to the Netgear/Meural cloud or the LCD display

 

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, NETGEAR retained Assent Compliance (“Assent”), a third-party service provider, to assist us in reviewing the supply chain and identifying risks. We provided a list composed of suppliers and parts associated with the in-scope products to Assent.

 

To collect data on the materials’ sources of origin procured by the supply chain, NETGEAR utilized the Conflict Minerals Reporting Template (“CMRT”) version 6.0 or higher to conduct a survey of all in scope Tier 1* suppliers.

 

*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 placed purchase order directly. 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.

 

During the supplier survey, the Company contacted suppliers via platform provided by third-party Assent that enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The platform also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.

 

 

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NETGEAR requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. All communications in the third-party’s platform for future reporting and transparency are monitored and tracked. NETGEAR directly contacted suppliers that were unresponsive to third-party’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to our third-party.

 

The Company’s program continues to include automated data validation on all submitted CMRTs. 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 questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

 

All submitted forms are accepted and classified as valid or invalid so that data is retained. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Third Party’s multilingual Supplier Experience team.

 

As of March 18th, 2021, there were 23 suppliers in scope of the conflict minerals program and all of them provided a completed CMRT. NETGEAR’s total response rate for this reporting year was 100%.

 

Based on the findings through the RCOI process, the Company was able to determine the countries of origin for a large portion of the 3TGs in its products. As such, NETGEAR continued to perform further due diligence on the source and chain of custody of the minerals in question.

 

Section 3 - Conflict Minerals Due Diligence Program

 

NETGEAR designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance and the Company continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.

 

Due diligence requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot fully be owned by the Company. However, through continued outreach and process validation, this aligns with industry standards and market expectations for downstream companies’ due diligence.

 

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

 

•

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.

 

•

Assembled internal conflict minerals team, with representation from NETGEAR’s Operations, Legal, Procurement, Finance and Internal Audit.

 

•

Established a system of controls through the use of Supplier Code of Conduct and transparency over NETGEAR’s conflict minerals supply chain by engaging Tier 1 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/

 

•

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.

 

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.

 

•

Reviewed supplier responses for completeness and accuracy.

 

•

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 following criteria: geographic proximity to the Covered Countries, known mineral source country of origin, RMAP audit status, credible evidence of unethical or conflict sourcing, and Peer assessments conducted by credible third-party sources.

 

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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, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.

 

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:

 

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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.

 

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NETGEAR designated third-party also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. NETGEAR is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance.

 

3.5 Report annually on supply chain due diligence

 

 

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NETGEAR has published the Form SD for the year ended December 31, 2020. This report is available on the Investor Relations pages of our website at http://investor.netgear.com/sec.cfm. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein. NETGEAR has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission.

 

 

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This year the Company has also considered impacts from the European Union Conflict Minerals Rule when disclosing details with regards to due diligence efforts. The Company will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public 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 Supply Chain Outreach Results

 

Supply chain outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten and gold. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. The following is the result of the outreach conducted by NETGEAR for the 2020 reporting year.

 

Supply Chain Outreach Metrics

 

Number of In-Scope Suppliers

Response Rate

Valid Response Rate

23

100%

100%

 

Upstream Data Transparency

 

All smelters and refiners listed by suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are attached in Appendix A. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing the smelters and refiners have the practice to list all smelters and refiners they may purchase from within the reporting period. Therefore, the smelters or refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters or refiners which actually processed the 3TGs contained in the Company’s products.

 

Suppliers that identified these specific smelters of concern on their CMRT were contacted in accordance with the OECD Guidance to inform them of the potential for risk, and to evaluate whether or not these smelters could be connected to NETGEAR’s products. The suppliers were asked to complete a user-defined or product-level CMRT specific to the materials, products or piece parts purchased by NETGEAR, rather than a company-level CMRT, to better identify the

 

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connection to products that they supply to NETGEAR. Other suppliers were evaluated internally to determine if they were in fact still active suppliers. If not, they were removed from the scope of data collection.

 

 

 

Status

Number of Identified Smelters and Refiners

RMAP Conformant

235

RMAP Active

9

Not Enrolled

16

Non-Conformant

1

 

Countries of Origin

 

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. As mentioned in the above section, it is understood that many responses may provide more data than can be directly linked to products sold by NETGEAR, therefore, Appendix B may contain more countries than those that the Company’s products are being sourced from.

 

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 manufacture. 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.

 

 

 

 

5.3 Smelter & Refiner Risk Evaluation

Understanding the risks associated with the smelters and refiners potentially providing material into NETGEAR’s supply chain is an important part of the due diligence process. Through our third-party service provider Assent, comprehensive and ongoing analysis is conducted to assess sourcing risk. This information is used to:

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Provide supplier feedback.

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Determine the health of the Company’s overall program.

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Conduct outreach to smelters, refiners and their respective associations.

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Provide detailed analysis in this report.

 

The following risk categories are used for smelter evaluation and risk determination:

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Geo-Risk

 

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Did the mineral originate from or has been transported through a conflict-affected area as defined by Section 1502 of the Dodd-Frank Act (the DRC and its nine adjoining countries; Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia)?

 

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Audit Status

 

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Has the refiner’s due diligence practices been audited against a standard in conformance with the OECD Guidance?

 

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Assent relies on the RMI audit standard, including cross-recognition of the London Bullion Market Association (“LBMA”) Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance.

 

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Sourcing Risk

 

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Has evidence of any other red flag that is supported by credible sources been identified?

 

 

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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

Standard Smelter Name

Smelter Facility Location

CID002763

Gold

8853 S.p.A.

ITALY

CID000015

Gold

Advanced Chemical Company

UNITED STATES OF AMERICA

CID000019

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

CID002560

Gold

Al Etihad Gold Refinery DMCC

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

CID000343

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

CID000362

Gold

DODUCO Contacts and Refining GmbH

GERMANY

CID000401

Gold

Dowa

JAPAN

CID003195

Gold

DS PRETECH Co., Ltd.

KOREA, REPUBLIC OF

CID000359

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

CID000425

Gold

Eco-System Recycling Co., Ltd. East Plant

JAPAN

CID003424

Gold

Eco-System Recycling Co., Ltd. North Plant

JAPAN

CID003425

Gold

Eco-System Recycling Co., Ltd. West Plant

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

 

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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

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

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

CID000689

Gold

LT Metal Ltd.

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

 

9

 

 

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

CID002582

Gold

REMONDIS PMR B.V.

NETHERLANDS

CID001534

Gold

Royal Canadian Mint

CANADA

CID002761

Gold

SAAMP

FRANCE

CID001546

Gold

Sabin Metal Corp.

UNITED STATES OF AMERICA

CID002973

Gold

Safimet S.p.A

ITALY

CID002290

Gold

SAFINA A.S.

CZECHIA

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

CID002615

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

CID001955

Gold

Torecom

KOREA, REPUBLIC OF

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

 

10

 

 

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

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

CID000914

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

CID000917

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

CID002506

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002539

Tantalum

KEMET Blue Metals

MEXICO

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

PRG Dooel

NORTH MACEDONIA

CID001508

Tantalum

QuantumClean

UNITED STATES OF AMERICA

CID002707

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

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

CID001522

Tantalum

Yanling Jincheng Tantalum & Niobium 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

Smelter Not Listed

INDONESIA

CID002455

Tin

Smelter Not Listed

INDONESIA

 

11

 

 

CID000402

Tin

Dowa

JAPAN

CID000438

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

CID000468

Tin

Fenix Metals

POLAND

CID002848

Tin

Smelter Not Listed

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

CID002844

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

CID001231

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

CID003387

Tin

Luna Smelter, Ltd.

RWANDA

CID003379

Tin

Ma'anshan Weitai Tin Co., 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

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

CID001314

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

CID002517

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID001337

Tin

Operaciones Metalurgicas S.A.

BOLIVIA (PLURINATIONAL STATE OF)

CID000309

Tin

Smelter Not Listed

INDONESIA

CID001399

Tin

PT Artha Cipta Langgeng

INDONESIA

CID002503

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

CID001402

Tin

Smelter Not Listed

INDONESIA

CID001406

Tin

Smelter Not Listed

INDONESIA

CID003205

Tin

PT Bangka Serumpun

INDONESIA

CID001428

Tin

Smelter Not Listed

INDONESIA

CID002870

Tin

Smelter Not Listed

INDONESIA

CID002835

Tin

Smelter Not Listed

INDONESIA

CID001453

Tin

PT Mitra Stania Prima

INDONESIA

CID001458

Tin

Smelter Not Listed

INDONESIA

CID003381

Tin

Smelter Not Listed

INDONESIA

CID002593

Tin

Smelter Not Listed

INDONESIA

CID001460

Tin

PT Refined Bangka Tin

INDONESIA

CID001468

Tin

Smelter Not Listed

INDONESIA

CID001477

Tin

PT Timah Tbk Kundur

INDONESIA

CID001482

Tin

PT Timah Tbk Mentok

INDONESIA

CID001490

Tin

Smelter Not Listed

INDONESIA

CID002706

Tin

Resind Industria e Comercio Ltda.

BRAZIL

 

12

 

 

CID001539

Tin

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

CID001758

Tin

Soft Metais Ltda.

BRAZIL

CID002834

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

VIET NAM

CID001898

Tin

Thaisarco

THAILAND

CID003325

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

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

CID003397

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

CHINA

CID000004

Tungsten

A.L.M.T. Corp.

JAPAN

CID002833

Tungsten

ACL Metais Eireli

BRAZIL

CID003427

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

BRAZIL

CID002502

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIET NAM

CID002513

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

CID000258

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID003401

Tungsten

Fujian Ganmin RareMetal 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

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

CID003408

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

RUSSIAN FEDERATION

CID000966

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

CID000105

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

CID003388

Tungsten

KGETS Co., Ltd.

KOREA, REPUBLIC OF

CID003407

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID002319

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002543

Tungsten

Masan Tungsten Chemical LLC (MTC)

VIET NAM

CID002845

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

CID002589

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

 

13

 

 

CID002827

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

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

 

 

 

 

 

14

 

 

 

Table B

 

Countries of Origin

 

Below list of countries that declared smelters are known to source from:

 

 

 

 

•

Afghanistan

 

•

Albania

 

•

Angola

 

•

Argentina

 

•

Armenia

 

•

Australia

 

•

Austria

 

•

Belarus

 

•

Belgium

 

•

Bermuda

 

•

Bolivia

 

•

Brazil

 

•

Bulgaria

 

•

Burundi

 

•

Cambodia

 

•

Canada

 

•

Central African Republic

 

•

Chile

 

•

China

 

•

Colombia

 

•

Czech Republic

 

•

Djibouti

 

•

Dominican Republic

 

•

DRC or an adjoining country (Covered Countries)

 

•

Ecuador

 

•

Egypt

 

•

England

 

•

Estonia

 

•

Ethiopia

 

•

Excludes

 

•

Finland

 

•

France

 

•

Germany

 

•

Ghana

 

•

Guinea

 

•

Guyana

 

•

Hungary

 

•

India

 

•

Indonesia

 

•

Ireland

 

•

Israel

 

•

Italy

 

•

Ivory Coast

 

•

Japan

 

•

Kazakhstan

 

•

Kenya

 

•

Kyrgyzstan

 

•

Laos

 

•

Liberia

 

•

Luxembourg

 

•

Madagascar

 

•

Malaysia

 

•

Mali

 

•

Mauritania

 

•

Mexico

 

•

Mongolia

 

•

Morocco

 

•

Mozambique

 

•

Myanmar

 

•

Namibia

 

•

Netherlands

 

•

New Zealand

 

•

Niger

 

•

Nigeria

 

•

Papua New Guinea

 

•

Peru

 

•

Philippines

 

•

Poland

 

•

Portugal

 

•

Republic Of Korea

 

•

Russia

 

•

Rwanda

 

•

Saudi Arabia

 

•

Sierra Leone

 

•

Singapore

 

•

Slovakia

 

•

Slovenia

 

•

South Africa

 

•

Spain

 

•

Suri

 

•

Suriname

 

•

Sweden

 

•

Switzerland

 

•

Tanzania

 

•

Thailand

 

•

Turkey

 

•

Uganda

 

•

United Arab Emirates

 

•

United Kingdom

 

•

USA

 

•

Uzbekistan

 

•

Vietnam

 

•

Zambia

 

•

Zimbabwe

 

15