EX-1.01 2 arlo20210528-ex101conflict.htm EX-1.01 Document
Exhibit 1.01



CONFLICT MINERALS REPORT
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ARLO TECHNOLOGIES, 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 “Conflict Minerals”); 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 3TG in its supply chain may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country (collectively, the "Covered Countries"), or if it is unable to determine the country of origin of the 3TG in its products, or that its products are manufactured entirely from recycled and scrap sources, then the issuer must conduct due diligence on the source and chain of custody of the 3TG. 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. Arlo Technologies, Inc. ("Arlo" or the "Company") has determined that Conflict Minerals that may have originated from the Covered Countries are necessary to the functionality or production of some or all of its products, the manufacturing of which was completed during the 2020 calendar year and therefore, is required to perform due diligence and file this report. This report is Arlo'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.

Although forward-looking statements in this report reflect our good faith judgment, such statements can only be based on facts and factors currently known by us. Consequently, forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include without limitation: the risk that information reported to us by our suppliers from which we directly procure finished goods, components, materials and/or services for our products (direct suppliers), or industry information used by us, may be inaccurate or incomplete; the risk that smelters or refiners (processing facilities) may not participate in the Responsible Minerals Assurance Process (RMAP), formerly the Conflict-Free Smelter Program, which is a voluntary initiative in which independent third parties audit processing facilities’ procurement and processing activities and determine if the processing facilities maintain sufficient documentation to reasonably demonstrate conflict free sourcing; as well as risks discussed under the heading “Risk Factors” in our most recent Quarterly Report on Form 10-Q, including those related to our customer concentration, our dependence on a limited number of third-party suppliers, the effects of the COVID-19 pandemic on our business, operations and the markets and communities in which we, our partners and customers operate and our being subject to government regulations and policies. Readers are urged not to place undue reliance on forward-looking statements, which speak only as of the date of this report. We undertake no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this report. Throughout this report, whenever a reference is made to our website, such reference does not incorporate information from the website by reference into this report unless specifically identified as such.

Section 1 - Company Overview

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Arlo combines an intelligent cloud infrastructure and mobile app with a variety of smart connected devices that transform the way people experience the connected lifestyle. Arlo’s deep expertise in product design, wireless connectivity, cloud infrastructure and cutting-edge AI capabilities focuses on delivering a seamless, smart home experience for Arlo users that is easy to setup and interact with every day. Its cloud-based platform provides users with visibility, insight and a powerful means to help protect and connect in real-time with the people and things that matter most, from any location with a Wi-Fi or a cellular connection. To date, Arlo has launched several categories of award-winning smart connected devices, including wired and wire-free smart Wi-Fi and LTE-enabled cameras, audio and video doorbells, and floodlight cameras. In addition, Arlo’s broad compatibility allows the platform to seamlessly integrate with third-party internet-of-things products and protocols, such as Amazon Alexa, Apple HomeKit, Apple TV, Google Assistant, IFTTT, Stringify and Samsung SmartThings.

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

1.1 Arlo Products

All of our hardware products fall within the scope of Rule 13p-1 as they contain one or more Conflict Minerals. The following product line descriptions provide additional details:

• Smart connected devices - cameras, security light, audio & video doorbell and Arlo chime
• Arlo accessories - charging accessories, Arlo mounts and Arlo skins

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

1.2 Conflict Minerals Report

This CMR relates to all of our products in the product categories listed under section 1.1 the manufacture of which was completed during 2020. We have been unable to conclusively determine countries of origin of the 3TG those products contain, or to conclusively determine the extent to which they came from recycled or scrap sources; the facilities used to process them; or their mine or location of origin. More than 35% of our suppliers reported at broad levels, often declaring the scope of their Conflict Minerals Reporting Template (“CMRT”) as “company-wide,” not at the level of products actually provided to us.

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

Arlo has published its conflict minerals policy on its webpage located at: https://www.arlo.com/images/pdf/Arlo-Conflict-Minerals-Sourcing-Policy.pdf

We are contributing to industry efforts to address conflict minerals through our involvement as a member of the Responsible Business Alliance (“RBA”), and the Responsible Minerals Initiative (“RMI”).

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

To determine whether the necessary 3TG in our products originated in any of the Covered Countries, we first needed to determine the scope of our Conflict Minerals program. As determined and explained above, Arlo has determined that nearly all of its products contain one or more Conflict Minerals and, therefore, we determined that all Tier 1* suppliers of such products should be surveyed directly by Arlo on the sourcing of 3TG.

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*Arlo’s definition of Tier 1 Supplier - ODM (Original Design Manufacturer), CM (Contract Manufacturer) and Arlo’s AVL (Approved Vendor List) with which Arlo has directly negotiated the price of goods and services and has a direct control or business relationship, but excluding the following suppliers: plastics and software suppliers; packaging suppliers; and suppliers that are not used for production orders completed in reporting year 2020.

Arlo utilized the CMRT version 6.01 or higher to conduct a survey of all in-scope suppliers. The CMRT is a free, standardized reporting template developed by the RMI that is widely considered 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 Arlo for assessment.

On average, Arlo direct suppliers were contacted at least three times through email and/or phone calls for follow-up on their CMRT submissions or for clarifying any questions that the Arlo Conflict Minerals Program team or Arlo’s third-party service provider may have had. Arlo’s Conflict Minerals Program team was also in charge of all the communication with direct suppliers.

We received completed CMRTs from all 32 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 the suppliers’ answers to questions 1 through 6 of the CMRT.

All submitted forms were accepted and classified as valid or invalid so that data is still retained. As of March 31, 2021, there were no invalid supplier submissions that had not been corrected.

Based on the RCOI, we had reason to believe that some of the 3TG used in the products 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 3TG used in the manufacture of Arlo products.

Section 3 - Conflict Minerals Due Diligence Program Design

Arlo’s conflict minerals due diligence program is designed to conform in all material aspects with the framework recommended by 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, including supplements, also known as the OECD Guidance, as it relates to Arlo’s supply chain position as a “downstream” or finished product manufacturer and purchaser.

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

3.1 Establish strong company management systems

1.Adopted and publicly communicated a Conflict Minerals company policy which is posted on the Arlo website at https://www.arlo.com/images/pdf/Arlo-Conflict-Minerals-Sourcing-Policy.pdf
2.As a member of the RBA, 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.
3.Assembled our internal Conflict Minerals Program team, led by our Quality & Compliance team and supported by a cross-functional team consisting of representatives from Operations, Supply Chain, Legal, Finance and Internal Audit functions.
4.Established a system of control through the use of our Supplier Code of Conduct and transparency over Arlo’s Conflict Minerals supply chain by engaging first-tier suppliers and requesting relevant information through the use of a third-party service provider, which utilized due diligence tools created by the RMI, including the CMRT.
5.Provided updates on our Conflict Minerals due diligence progress and status on a quarterly basis to Arlo’s Chief Financial Officer.
6.Educated and trained those personnel responsible to work on Arlo’s Conflict Minerals Program.
7.Established a grievance mechanism to allow employees, suppliers, and others to report suspected non-compliance with the applicable legal requirement and/or suspected non-compliance with Arlo’s Code of Ethics
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and Supplier Code of Conduct. These policies are publicly available at https://www.arlo.com/en-us/about/corporate-social-responsibility/ethics/
8.Established an internal audit to review the Conflict Minerals risk assessment report and due diligence process against Arlo’s documented procedure.
9.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

1.Identified relevant Tier 1 suppliers that supplied products containing 3TG.
2.Requested such suppliers to provide information regarding smelters or refiners in our supply chain by using the CMRT.
3.Reviewed supplier responses for completeness and accuracy.
4.Risks were identified by analyzing data from suppliers that listed mineral processing facilities on their CMRT declarations.
5.Compared information in supplier responses with the list of 3TG processing facilities that received a “conflict-free” designation, produced by the RMAP.
6.Each facility that meets the RMI definition of a smelter or refiner of a Conflict Mineral 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, we assessed three 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.
7.Contacted non-responsive suppliers, requesting their responses.
8.Provided suppliers with feedback on responses containing errors, inconsistencies or incomplete information and encouraged them to resubmit a valid response.
9.Evaluated suppliers on the strength of their internal Conflict Minerals programs. When suppliers met or exceeded the below criteria (that is, responded “yes” to all four questions listed below), they were deemed to have a strong program. When they responded “No” to any one or more to the questions, they were 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:
a.Have you established a conflict minerals sourcing policy?
b.Have you implemented due diligence measures for conflict-free sourcing?
c.Do you review due diligence information received from your suppliers against your company’s expectations?
d.Does your review process include corrective action management?

3.3 Design and implement a strategy to respond to risk

1.Conducted regular Conflict Minerals Program team meetings to review, among other things, Arlo’s Conflict Minerals program, any potential or actual risks identified during due diligence, and the status of supplier responses.
2.Identified high-risk smelters and refiners in Arlo’s supply chain by using the smelter and refiner database from the RMI that includes information on each smelter’s and refiner’s chain of custody of minerals. Arlo’s smelter and refiner risk calculation is based on three criteria:
a.Geographic proximity to the Covered Countries;
b.RMAP audit status; and
c.Credible evidence of unethical or conflict sourcing.
3.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.
4.Drafted an escalation plan in the event that we have to address non-responsive suppliers and/or to contact suppliers that provided incomplete or inaccurate supply chain information.
5.Requested that certain suppliers remove specific smelters or refiners from their supply chain that we deemed to be high-risk.
6.Engaged any suppliers that we had reason to believe are supplying Arlo with 3TG from sources that may be considered red-flag sources and encouraged them to establish alternative sources of 3TG.
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7.Informed non-responsive suppliers, near to deadline set by Arlo to accept CMRT from 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.
8.Conducted Conflict Minerals Program due diligence process audit of Arlo’s ODM partners that accounted for at least 80% of Arlo’s purchase in reporting year.

3.4 Audit of smelter/refiner’s due diligence practices

1.Relied on the RMAP, to coordinate third-party audits of smelters and refiners to validate the sourcing practices of such facilities in our supply chain.
2.Provided indirect financial support for these third-party audits through our continued membership in the RBA and RMI.
3.Participated in RBA and RMI work groups, including smelter engagement and outreach.

3.5 Report annually on supply chain due diligence

1.Publicly communicated Conflict Minerals Policy on company website at: https://www.arlo.com/images/pdf/Arlo-Conflict-Minerals-Sourcing-Policy.pdf
1.Will file our Form SD for the reporting period from January 01, 2020 to December 31, 2020, including this Conflict Minerals Report, with the SEC and make it available on the Investor Relations pages of our website at https://investor.arlo.com/financials-and-filings/sec-filings/default.aspx
2.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

Arlo 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 3TG used in Arlo products.

4.1 Survey Results

In 2020, Arlo conducted supply chain surveys, using the CMRT, of Tier 1 suppliers that we identified that may contribute necessary 3TG in our products. The results of our supply chain survey of our 32 Tier 1 suppliers and conclusion of our RCOI are as follows:
1.100% of Arlo-surveyed suppliers provided responses using an accepted version of the CMRT.
2.None of the 32 CMRTs collected have been deemed invalid against criteria defined by Arlo.
3.The surveyed suppliers identified 253 legitimate smelters and refiner facilities that may process the necessary 3TG contained in the products manufactured.
4.Of these 253 smelters and refiners, 236 were validated as conflict-free by RMAP, based on information provided by the RMI through RMAP.
17 of these 253 smelters and refiners may have originated in the Covered Countries not validated as conflict-free by RMAP and are not solely from recycled or scrap sources.

Attached as Table A is a list of all smelters and refiners identified by our suppliers in their CMRTs that appear on the list of legitimate smelters and refiners maintained by the RMI. Since many of the CMRTs we received from suppliers were made on a company-level basis, rather than on a product-level basis, we were not able to identify which smelters or refiners listed in Table A actually processed the 3TG contained in our products. Therefore, the list of processing smelters and refiners disclosed in Table A may identify more facilities than those that actually processed the minerals contained in our products.

A list of potential countries of origin from which the reported smelters and refiners collectively sourced 3TG 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 identify more countries of origin than were actually the source of the 3TG in our products.
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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 or 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 we depend on those suppliers seeking similar information within their supply chains to identify the original sources of the necessary Conflict Minerals. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. Because of our relative location within the supply chain in relation to the actual extraction, transport, smelting, and refinement of 3TG, our ability to verify the accuracy of information reported by suppliers is limited. 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 Covered Countries:

1.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.
2.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.
3.Emphasize the need for cooperation and support by our Tier 1 suppliers by implementing more direct Arlo-led escalations throughout the program.
4.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 that appear to have gaps in their internal processes for conflict minerals.
5.Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of 3TG.
6.Work more closely with our third-party Conflict Minerals service provider to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TG contained in our products.
7.Engage Tier 1 suppliers to encourage smelters or refiners in our supply chain, not yet certified/identified by the RMAP or an equivalent independent third-party audit, to undergo smelter audits and verify compliance.
8.Support our third-party service provider in its smelter due diligence activities by identifying the suppliers who is sourcing from high risk smelters that 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 Arlo

Below list of smelters and refiners have been identified by our Tier 1 suppliers and may have been used in processing of necessary 3TG contained in Arlo products, the manufacture of which was completed during calendar year 2020:

Metal
Standard Smelter/Refiner Name
Smelter/Refiner Facility Location
Gold8853 S.p.A.ITALY
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICA
GoldAida Chemical Industries Co., Ltd.JAPAN
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATES
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANY
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTAN
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZIL
GoldArgor-Heraeus S.A.SWITZERLAND
GoldAsahi Pretec Corp.JAPAN
GoldAsahi Refining Canada Ltd.CANADA
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICA
GoldAsaka Riken Co., Ltd.JAPAN
GoldAU Traders and RefinersSOUTH AFRICA
GoldAurubis AGGERMANY
GoldBangalore RefineryINDIA
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINES
GoldBoliden ABSWEDEN
GoldC. Hafner GmbH + Co. KGGERMANY
GoldCCR Refinery - Glencore Canada CorporationCANADA
GoldCendres + Metaux S.A.SWITZERLAND
GoldChimet S.p.A.ITALY
GoldChugai MiningJAPAN
GoldDODUCO Contacts and Refining GmbHGERMANY
GoldDowaJAPAN
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OF
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OF
GoldEco-System Recycling Co., Ltd. East PlantJAPAN
GoldEco-System Recycling Co., Ltd. North PlantJAPAN
GoldEco-System Recycling Co., Ltd. West PlantJAPAN
GoldEmirates Gold DMCCUNITED ARAB EMIRATES
GoldGeib Refining CorporationUNITED STATES OF AMERICA
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINA
GoldHeimerle + Meule GmbHGERMANY
GoldHeraeus Metals Hong Kong Ltd.CHINA
GoldHeraeus Precious Metals GmbH & Co. KGGERMANY
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINA
GoldIshifuku Metal Industry Co., Ltd.JAPAN
GoldIstanbul Gold RefineryTURKEY
GoldItalpreziosiITALY
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GoldJapan MintJAPAN
GoldJiangxi Copper Co., Ltd.CHINA
GoldJSC UralelectromedRUSSIAN FEDERATION
GoldJX Nippon Mining & Metals Co., Ltd.JAPAN
GoldKazzincKAZAKHSTAN
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICA
GoldKGHM Polska Miedz Spolka AkcyjnaPOLAND
GoldKojima Chemicals Co., Ltd.JAPAN
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OF
GoldKyrgyzaltyn JSCKYRGYZSTAN
GoldL'Orfebre S.A.ANDORRA
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OF
GoldLT Metal Ltd.KOREA, REPUBLIC OF
GoldMarsam MetalsBRAZIL
GoldMaterionUNITED STATES OF AMERICA
GoldMatsuda Sangyo Co., Ltd.JAPAN
GoldMetalor Technologies (Hong Kong) Ltd.CHINA
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORE
GoldMetalor Technologies (Suzhou) Ltd.CHINA
GoldMetalor Technologies S.A.SWITZERLAND
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICA
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICO
GoldMitsubishi Materials CorporationJAPAN
GoldMitsui Mining and Smelting Co., Ltd.JAPAN
GoldMMTC-PAMP India Pvt., Ltd.INDIA
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATION
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEY
GoldNavoi Mining and Metallurgical CombinatUZBEKISTAN
GoldNihon Material Co., Ltd.JAPAN
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIA
GoldOhura Precious Metal Industry Co., Ltd.JAPAN
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant"RUSSIAN FEDERATION
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATION
GoldPAMP S.A.SWITZERLAND
GoldPlanta Recuperadora de Metales SpACHILE
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATION
GoldPT Aneka Tambang (Persero) TbkINDONESIA
GoldPX Precinox S.A.SWITZERLAND
GoldRand Refinery (Pty) Ltd.SOUTH AFRICA
GoldREMONDIS PMR B.V.NETHERLANDS
GoldRoyal Canadian MintCANADA
GoldSAAMPFRANCE
GoldSafimet S.p.AITALY
GoldSAFINA A.S.CZECH REPUBLIC
GoldSamduck Precious MetalsKOREA, REPUBLIC OF
GoldSAXONIA Edelmetalle GmbHGERMANY
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GoldSEMPSA Joyeria Plateria S.A.SPAIN
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINA
GoldSichuan Tianze Precious Metals Co., Ltd.CHINA
GoldSingway Technology Co., Ltd.
TAIWAN,
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATION
GoldSolar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
GoldSumitomo Metal Mining Co., Ltd.JAPAN
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OF
GoldT.C.A S.p.AITALY
GoldTanaka Kikinzoku Kogyo K.K.JAPAN
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINA
GoldTokuriki Honten Co., Ltd.JAPAN
GoldTOO Tau-Ken-AltynKAZAKHSTAN
GoldTorecomKOREA, REPUBLIC OF
GoldUmicore Precious Metals ThailandTHAILAND
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUM
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICA
GoldValcambi S.A.SWITZERLAND
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIA
GoldWIELAND Edelmetalle GmbHGERMANY
GoldYamakin Co., Ltd.JAPAN
GoldYokohama Metal Co., Ltd.JAPAN
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINA
TantalumAsaka Riken Co., Ltd.JAPAN
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINA
TantalumD Block Metals, LLCUNITED STATES OF AMERICA
TantalumExotech Inc.UNITED STATES OF AMERICA
TantalumF&X Electro-Materials Ltd.CHINA
TantalumFIR Metals & Resource Ltd.CHINA
TantalumGlobal Advanced Metals AizuJAPAN
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICA
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINA
TantalumGuangdong Rising Rare Metals-EO Materials LtdCHINA
TantalumH.C. Starck Co., Ltd.THAILAND
TantalumH.C. Starck Hermsdorf GmbHGERMANY
TantalumH.C. Starck Inc.UNITED STATES OF AMERICA
TantalumH.C. Starck Ltd.JAPAN
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANY
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANY
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINA
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINA
TantalumJiangxi Tuohong New Raw MaterialCHINA
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINA
TantalumJiujiang Tanbre Co., Ltd.CHINA
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINA
TantalumKEMET Blue MetalsMEXICO
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TantalumLSM Brasil S.A.BRAZIL
TantalumMetallurgical Products India Pvt., Ltd.INDIA
TantalumMineracao Taboca S.A.BRAZIL
TantalumMitsui Mining and Smelting Co., Ltd.JAPAN
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINA
TantalumNPM Silmet ASESTONIA
Tantalum
PRG DooelPower Resource Ltd
NORTH MACEDONIA, REPUBLIC OF
TantalumQuantumCleanUNITED STATES OF AMERICA
TantalumResind Industria e Comercio Ltda.BRAZIL
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATION
TantalumTaki Chemical Co., Ltd.JAPAN
TantalumTelex MetalsUNITED STATES OF AMERICA
TantalumUlba Metallurgical Plant JSCKAZAKHSTAN
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINA
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINA
TinAlphaUNITED STATES OF AMERICA
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAM
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINA
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINA
TinChina Tin Group Co., Ltd.CHINA
TinCV Ayi JayaINDONESIA
TinCV Venus Inti PerkasaINDONESIA
TinDowaJAPAN
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAM
TinEM VintoBOLIVIA
TinEstanho de Rondonia S.A.BRAZIL
TinFenix MetalsPOLAND
TinGejiu Fengming Metallurgy Chemical PlantCHINA
TinGejiu Kai Meng Industry and Trade LLCCHINA
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINA
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINA
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINA
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINA
TinHuiChang Hill Tin Industry Co., Ltd.CHINA
TinJiangxi New Nanshan Technology Ltd.CHINA
TinLuna Smelter, Ltd.RWANDA
TinMa'anshan Weitai Tin Co., Ltd.CHINA
TinMagnu's Minerais Metais e Ligas Ltda.BRAZIL
TinMalaysia Smelting Corporation (MSC)MALAYSIA
TinMelt Metais e Ligas S.A.BRAZIL
TinMetallic Resources, Inc.UNITED STATES OF AMERICA
TinMetallo Belgium N.V.BELGIUM
TinMetallo Spain S.L.U.SPAIN
TinMineracao Taboca S.A.BRAZIL
TinMinsurPERU
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TinMitsubishi Materials CorporationJAPAN
TinModeltech Sdn BhdMALAYSIA
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAM
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILAND
TinO.M. Manufacturing Philippines, Inc.PHILIPPINES
TinOperaciones Metalurgicas S.A.BOLIVIA
TinPongpipat Company LimitedMYANMAR
TinPT Aries Kencana SejahteraINDONESIA
TinPT Artha Cipta LanggengINDONESIA
TinPT ATD Makmur Mandiri JayaINDONESIA
TinPT Babel Inti PerkasaINDONESIA
TinPT Babel Surya Alam LestariINDONESIA
TinPT Bangka SerumpunINDONESIA
TinPT Bukit TimahINDONESIA
TinPT Menara Cipta MuliaINDONESIA
TinPT Mitra Stania PrimaINDONESIA
TinPT Prima Timah UtamaINDONESIA
TinPT Rajawali Rimba PerkasaINDONESIA
TinPT Rajehan AriqINDONESIA
TinPT Refined Bangka TinINDONESIA
TinPT Stanindo Inti PerkasaINDONESIA
TinPT Timah Tbk KundurINDONESIA
TinPT Timah Tbk MentokINDONESIA
TinPT Tinindo Inter NusaINDONESIA
TinResind Industria e Comercio Ltda.BRAZIL
TinRui Da Hung
TAIWAN, PROVINCE OF CHINA
TinSoft Metais Ltda.BRAZIL
TinSuper LigasBRAZIL
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAM
TinThaisarcoTHAILAND
TinTin Technology & RefiningUNITED STATES OF AMERICA
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAM
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZIL
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINA
TinYunnan Tin Company LimitedCHINA
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINA
TungstenA.L.M.T. Corp.JAPAN
TungstenACL Metais EireliBRAZIL
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZIL
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAM
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINA
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINA
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINA
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINA
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINA
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TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINA
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICA
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINA
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANY
TungstenH.C. Starck Tungsten GmbHGERMANY
TungstenHunan Chenzhou Mining Co., Ltd.CHINA
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINA
TungstenHydrometallurg, JSCRUSSIAN FEDERATION
TungstenJapan New Metals Co., Ltd.JAPAN
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINA
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINA
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINA
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINA
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINA
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINA
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATION
TungstenKennametal FallonUNITED STATES OF AMERICA
TungstenKennametal HuntsvilleUNITED STATES OF AMERICA
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OF
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINA
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINA
TungstenMasan Tungsten Chemical LLC (MTC)VIET NAM
TungstenMoliren Ltd.RUSSIAN FEDERATION
TungstenNiagara Refining LLCUNITED STATES OF AMERICA
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINES
TungstenUnecha Refractory metals plantRUSSIAN FEDERATION
TungstenWolfram Bergbau und Hutten AGAUSTRIA
TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OF
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINA
TungstenXiamen Tungsten Co., Ltd.CHINA
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINA


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Table B

Countries of Origin

The list of countries of origin for the Conflict Minerals, identified as a result of our RCOI, that may have been used in our products includes, but may not be limited to:

Level 1 countries (not identified as conflict regions or plausible areas of smuggling or export from the Covered Countries): Argentina, Armenia, Australia, Austria, Bolivia, Brazil, Canada, Chile, China, Colombia, Dominican Republic, Ecuador, Egypt, ,England Ethiopia, Finland, Ghana, Guinea, Guyana, India, Indonesia, Ivory Coast, Kazakhstan, Kyrgyzstan, Laos, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Myanmar, Namibia,, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Portugal, Saudi Arabia,, Sierra Leone, Slovakia, , Spain, Suriname, Sweden, Taiwan, Thailand, Turkey, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Zimbabwe

Level 2 countries (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 (the Covered Countries): DRC or an adjoining country (Covered Countries), Burundi, Rwanda, Tanzania, Uganda, Zambia





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