Exhibit 1.01
CONFLICT MINERALS REPORT
ARLO TECHNOLOGIES, INC.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934
for the Calendar Year Ended December 31, 2022
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, after conducting a reasonable country-of-origin inquiry, 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 adjoining countries (collectively, the “Covered Countries”), or if it is unable to determine the country of origin of the 3TG in its products, or that the 3TG in its products are 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 2022 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, 2022.
This CMR 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.
This CMR contains forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, Section 21E of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and the Private Securities Litigation Reform Act of 1995. 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. Forward-looking statements include statements regarding Arlo’s intentions and expectations regarding further supplier engagement and escalation, steps to mitigate risk and improve due diligence, and future reporting. Any statements contained herein that are not statements of historical fact may also be deemed to be forward-looking statements. For example, the words “believes,” “anticipates,” “plans,” “expects,” “intends,” “could,” “may,” “will,” and similar expressions are intended to identify forward-looking statements. Factors that could cause or contribute to material 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 Annual Report on Form 10-K for the year ended December 31, 2022 and Quarterly Report on Form 10-Q for the period ended April 2, 2023, including those related to our customer concentration, the impact of COVID-19 on the Company's business, our dependence on a limited number of third-party
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suppliers 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
Arlo Technologies, Inc. (“we” or “Arlo”) combines an intelligent cloud infrastructure and mobile app with a variety of smart connected devices that are transforming 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. Our 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. Since the launch of our first product in December 2014, we have shipped over 27.5 million smart connected devices. As of December 31, 2022, the Arlo platform had approximately 7.2 million cumulative registered accounts across more than 100 countries around the world, 1.9 million of which were paid services subscribers. To date, we have launched several categories of award-winning smart connected devices, including wired and wire-free smart Wi-Fi and LTE-enabled cameras, video doorbells, floodlight cameras and home security systems. In addition, Arlo’s broad compatibility allows the platform to seamlessly integrate with third-party internet-of-things (“IoT”) products and protocols, such as Amazon Alexa, Apple HomeKit, Apple TV, Google Assistant, IFTTT, Stringify and Samsung SmartThings. We plan to continue to introduce new smart connected devices to the Arlo platform both in cameras and other categories, increase the number of registered accounts on our platform, keep them highly engaged through our mobile app and generate incremental recurring revenue by offering them paid subscription services.
Arlo’s internet address is www.arlo.com. This CMR will be posted on the Company’s website with other SEC filings under https://investor.arlo.com/financials-and-filings/sec-filings/default.aspx 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 – wired and wire-free smart Wi-Fi and LTE-enabled cameras, video doorbells, floodlight cameras, and home security system
• Arlo accessories – charging accessories and Arlo mounts
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 all Arlo hardware products.
1.2 Conflict Minerals Report
This CMR relates to all of our hardware products in the product categories listed under section 1.1 the manufacture of which was completed during 2022. We have been unable to conclusively determine countries of origin of the 3TG those products contain, or to conclusively determine the extent to which the 3TG came from recycled or scrap sources; the facilities used to process them; or their mine or location of origin. Sixty percent 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 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.
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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
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 its hardware 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.
*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 2022.
Arlo utilized the CMRT version 6.22 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 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 28 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, 2023, there were no supplier submissions that the automated data validation system had determined to be invalid 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, some of which are performed by Arlo’s third-party service provider, as they relate to the five-step framework set forth in the OECD Guidance:
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3.1 Establish strong company management systems
•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
•Required that our suppliers and contract manufacturers implement the Responsible Business Alliance’s (“RBA”) Code of Conduct, which includes an obligation to conduct due diligence regarding Conflict Minerals.
•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.
•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.
•Provided updates on our Conflict Minerals due diligence progress and status to Arlo’s Chief Financial Officer.
•Educated and trained those personnel responsible to work on Arlo’s Conflict Minerals Program.
•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 and Supplier Code of Conduct. These policies are publicly available at https://www.arlo.com/en-us/about/corporate-social-responsibility/ethics/
•Established an internal audit to review our internal Conflict Minerals risk assessment and due diligence processes against Arlo’s documented procedure.
•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
•Identified relevant Tier 1 suppliers that supplied products containing 3TG.
•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 analyzing data from suppliers that listed mineral processing facilities (smelters or refiners) on their CMRT declarations.
•Compared information in supplier responses with the list of 3TG processing facilities that received a “conflict-free” designation, produced by the RMAP.
•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 the 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.
•Provided suppliers with feedback on responses containing errors, inconsistencies or incomplete information and encouraged them to resubmit a valid response.
•Requested suppliers to remove specific smelters or refiners from their supply chain that we deemed to be high-risk.
•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.
•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 of 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:
◦Have you established a conflict minerals sourcing policy?
◦Have you implemented due diligence measures for conflict-free sourcing?
◦Do you review due diligence information received from your suppliers against your company’s expectations?
◦Does your review process include corrective action management?
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3.3 Design and implement a strategy to respond to risk
•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.
•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.
•Based the smelter and refiner risk calculation on the following criteria:
◦Geographic proximity to the Covered Countries;
◦RMAP audit status; and
◦Credible evidence of unethical or conflict sourcing.
•Maintained 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.
•Conducted Conflict Minerals Program due diligence process survey 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
•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.
3.5 Report annually on supply chain due diligence
•Publicly communicated Conflict Minerals Policy on company website at:
https://www.arlo.com/images/pdf/Arlo-Conflict-Minerals-Sourcing-Policy.pdf
•Will file our Form SD for the reporting period from January 01, 2022 to December 31, 2022, 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
•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 2022, 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 28 Tier 1 suppliers and conclusion of our RCOI are as follows:
•100% of Arlo-surveyed suppliers provided responses using an accepted version of the CMRT.
•None of the 28 CMRTs collected have been deemed invalid against criteria defined by Arlo.
•The surveyed suppliers identified 252 legitimate smelters and refiner facilities that may process the necessary 3TG contained in the products manufactured.
•Of these 252 legitimate smelters and refiners, 221 were validated as conflict-free by RMAP, based on information provided by the RMI through RMAP.
•31 of these 252 legitimate smelters and refiners may have used 3TG that originated in the Covered Countries and are not validated as conflict-free by RMAP and are not solely from recycled or scrap sources.
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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 prepared 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, identified by our suppliers, 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.
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 and to further mitigate any risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries:
•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.
•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.
•Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of 3TG.
•Request suppliers to remove specific smelters or refiners from their supply chain that we deemed to be high-risk.
•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.
•Engage any suppliers that we have reason to believe are supplying Arlo with 3TG from sources that may be considered red flag sources and encourage them to establish alternative sources of 3TG.
•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.
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Table A
Smelter & Refiners Reported to be in Supply Chain of Arlo
Below is a 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 2022:
| Metal | Smelter or Refiner Facility Name | Location of Facility | ||||||
| Gold | Advanced Chemical Company | United States of America | ||||||
| Gold | Aida Chemical Industries Co., Ltd. | Japan | ||||||
| Gold | Asaka Riken Co., Ltd. | Japan | ||||||
| Gold | Chugai Mining | Japan | ||||||
| Gold | DSC (Do Sung Corporation) | Korea, Republic of | ||||||
| Gold | Dowa | Japan | ||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | ||||||
| Gold | LT Metal Ltd. | Korea, Republic of | ||||||
| Gold | Heraeus Germany GmbH Co. KG | Germany | ||||||
| Gold | Kojima Chemicals Co., Ltd. | Japan | ||||||
| Gold | Materion | United States of America | ||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | ||||||
| Gold | Samduck Precious Metals | Korea, Republic of | ||||||
| Gold | Torecom | Korea, Republic of | ||||||
| Gold | United Precious Metal Refining, Inc. | United States of America | ||||||
| Gold | Yamakin Co., Ltd. | Japan | ||||||
| Gold | Yokohama Metal Co., Ltd. | Japan | ||||||
| Gold | SAFINA A.S. | Czechia | ||||||
| Gold | Geib Refining Corporation | United States of America | ||||||
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | ||||||
| Gold | Emirates Gold DMCC | United Arab Emirates | ||||||
| Gold | REMONDIS PMR B.V. | Netherlands | ||||||
| Gold | Korea Zinc Co., Ltd. | Korea, Republic of | ||||||
| Gold | L'Orfebre S.A. | Andorra | ||||||
| Gold | Bangalore Refinery | India | ||||||
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of | ||||||
| Gold | Planta Recuperadora de Metales SpA | Chile | ||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | ||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | ||||||
| Gold | Agosi AG | Germany | ||||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | ||||||
| Gold | Argor-Heraeus S.A. | Switzerland | ||||||
| Gold | Asahi Pretec Corp. | Japan | ||||||
| Gold | Aurubis AG | Germany | ||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||||||
| Gold | Boliden AB | Sweden | ||||||
| Gold | C. Hafner GmbH + Co. KG | Germany | ||||||
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | ||||||
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| Gold | Cendres + Metaux S.A. | Switzerland | ||||||
| Gold | Chimet S.p.A. | Italy | ||||||
| Gold | JSC Novosibirsk Refinery | Russian Federation | ||||||
| Gold | Heimerle + Meule GmbH | Germany | ||||||
| Gold | Heraeus Metals Hong Kong Ltd. | China | ||||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | ||||||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | ||||||
| Gold | Istanbul Gold Refinery | Turkey | ||||||
| Gold | Japan Mint | Japan | ||||||
| Gold | Jiangxi Copper Co., Ltd. | China | ||||||
| Gold | Asahi Refining USA Inc. | United States of America | ||||||
| Gold | Asahi Refining Canada Ltd. | Canada | ||||||
| Gold | JSC Uralelectromed | Russian Federation | ||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | ||||||
| Gold | Kazzinc | Kazakhstan | ||||||
| Gold | Kennecott Utah Copper LLC | United States of America | ||||||
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of | ||||||
| Gold | Matsuda Sangyo Co., Ltd. | Japan | ||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | China | ||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | ||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | ||||||
| Gold | Metalor Technologies S.A. | Switzerland | ||||||
| Gold | Metalor USA Refining Corporation | United States of America | ||||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | ||||||
| Gold | Mitsubishi Materials Corporation | Japan | ||||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | ||||||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | ||||||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | ||||||
| Gold | Nihon Material Co., Ltd. | Japan | ||||||
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | ||||||
| Gold | MKS PAMP SA | Switzerland | ||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | ||||||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | ||||||
| Gold | PX Precinox S.A. | Switzerland | ||||||
| Gold | Rand Refinery (Pty) Ltd. | South Africa | ||||||
| Gold | Royal Canadian Mint | Canada | ||||||
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | ||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | ||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | ||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | ||||||
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province of China | ||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | ||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | ||||||
| Gold | Shandong Gold Smelting Co., Ltd. | China | ||||||
| Gold | Tokuriki Honten Co., Ltd. | Japan | ||||||
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| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | ||||||
| Gold | Valcambi S.A. | Switzerland | ||||||
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | ||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | ||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | ||||||
| Gold | Umicore Precious Metals Thailand | Thailand | ||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | India | ||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | ||||||
| Gold | Singway Technology Co., Ltd. | Taiwan, Province of China | ||||||
| Gold | T.C.A S.p.A | Italy | ||||||
| Gold | Marsam Metals | Brazil | ||||||
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | ||||||
| Gold | SAAMP | France | ||||||
| Gold | 8853 S.p.A. | Italy | ||||||
| Gold | Italpreziosi | Italy | ||||||
| Gold | WIELAND Edelmetalle GmbH | Germany | ||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | ||||||
| Gold | Safimet S.p.A | Italy | ||||||
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | ||||||
| Gold | NH Recytech Company | Korea, Republic of | ||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | ||||||
| Tantalum | F&X Electro-Materials Ltd. | China | ||||||
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | ||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | ||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | ||||||
| Tantalum | AMG Brasil | Brazil | ||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | ||||||
| Tantalum | Mineracao Taboca S.A. | Brazil | ||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | ||||||
| Tantalum | NPM Silmet AS | Estonia | ||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | ||||||
| Tantalum | QuantumClean | United States of America | ||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | ||||||
| Tantalum | Taki Chemical Co., Ltd. | Japan | ||||||
| Tantalum | Telex Metals | United States of America | ||||||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | ||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||||||
| Tantalum | D Block Metals, LLC | United States of America | ||||||
| Tantalum | FIR Metals & Resource Ltd. | China | ||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | ||||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | ||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | ||||||
| Tantalum | KEMET de Mexico | Mexico | ||||||
| Tantalum | TANIOBIS Co., Ltd. | Thailand | ||||||
| Tantalum | TANIOBIS GmbH | Germany | ||||||
| Tantalum | Materion Newton Inc. | United States of America | ||||||
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| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | ||||||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | ||||||
| Tantalum | Global Advanced Metals Boyertown | United States of America | ||||||
| Tantalum | Global Advanced Metals Aizu | Japan | ||||||
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | ||||||
| Tantalum | Jiangxi Tuohong New Raw Material | China | ||||||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | ||||||
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | ||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | ||||||
| Tin | Alpha | United States of America | ||||||
| Tin | Dowa | Japan | ||||||
| Tin | EM Vinto | Bolivia (Plurinational State of) | ||||||
| Tin | Fenix Metals | Poland | ||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | ||||||
| Tin | China Tin Group Co., Ltd. | China | ||||||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | ||||||
| Tin | Metallic Resources, Inc. | United States of America | ||||||
| Tin | Mineracao Taboca S.A. | Brazil | ||||||
| Tin | Minsur | Peru | ||||||
| Tin | Mitsubishi Materials Corporation | Japan | ||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | China | ||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||||||
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State of) | ||||||
| Tin | PT Artha Cipta Langgeng | Indonesia | ||||||
| Tin | PT Babel Inti Perkasa | Indonesia | ||||||
| Tin | PT Babel Surya Alam Lestari | Indonesia | ||||||
| Tin | PT Mitra Stania Prima | Indonesia | ||||||
| Tin | PT Prima Timah Utama | Indonesia | ||||||
| Tin | PT Refined Bangka Tin | Indonesia | ||||||
| Tin | PT Sariwiguna Binasentosa | Indonesia | ||||||
| Tin | PT Stanindo Inti Perkasa | Indonesia | ||||||
| Tin | PT Timah Tbk Kundur | Indonesia | ||||||
| Tin | PT Timah Tbk Mentok | Indonesia | ||||||
| Tin | Rui Da Hung | Taiwan, Province of China | ||||||
| Tin | Thaisarco | Thailand | ||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | ||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | ||||||
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | ||||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | ||||||
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | ||||||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | ||||||
| Tin | Resind Industria e Comercio Ltda. | Brazil | ||||||
| Tin | Aurubis Beerse | Belgium | ||||||
| Tin | Aurubis Berango | Spain | ||||||
| Tin | PT Sukses Inti Makmur | Indonesia | ||||||
| Tin | PT Menara Cipta Mulia | Indonesia | ||||||
10
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | ||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | ||||||
| Tin | PT Bangka Serumpun | Indonesia | ||||||
| Tin | Tin Technology & Refining | United States of America | ||||||
| Tin | PT Rajawali Rimba Perkasa | Indonesia | ||||||
| Tin | Luna Smelter, Ltd. | Rwanda | ||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | ||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | ||||||
| Tin | PT Tinindo Inter Nusa | Indonesia | ||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | ||||||
| Tin | CV Venus Inti Perkasa | Indonesia | ||||||
| Tin | Melt Metais e Ligas S.A. | Brazil | ||||||
| Tin | PT Rajehan Ariq | Indonesia | ||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | ||||||
| Tin | PT Aries Kencana Sejahtera | Indonesia | ||||||
| Tin | PT Bukit Timah | Indonesia | ||||||
| Tin | PT Timah Nusantara | Indonesia | ||||||
| Tin | PT Cipta Persada Mulia | Indonesia | ||||||
| Tin | CRM Synergies | Spain | ||||||
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | ||||||
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | ||||||
| Tin | Estanho de Rondonia S.A. | Brazil | ||||||
| Tin | PT Mitra Sukses Globalindo | Indonesia | ||||||
| Tin | PT Belitung Industri Sejahtera | Indonesia | ||||||
| Tin | PT Panca Mega Persada | Indonesia | ||||||
| Tin | PT Tommy Utama | Indonesia | ||||||
| Tin | PT Tirus Putra Mandiri | Indonesia | ||||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | ||||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | ||||||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | ||||||
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | ||||||
| Tin | Super Ligas | Brazil | ||||||
| Tin | Modeltech Sdn Bhd | Malaysia | ||||||
| Tin | Pongpipat Company Limited | Myanmar | ||||||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | ||||||
| Tungsten | A.L.M.T. Corp. | Japan | ||||||
| Tungsten | Kennametal Huntsville | United States of America | ||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | ||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | ||||||
| Tungsten | Global Tungsten & Powders LLC | United States of America | ||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | ||||||
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | ||||||
| Tungsten | Japan New Metals Co., Ltd. | Japan | ||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | ||||||
| Tungsten | Kennametal Fallon | United States of America | ||||||
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| Tungsten | Wolfram Bergbau und Hutten AG | Austria | ||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | China | ||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | ||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | ||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | ||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | ||||||
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | ||||||
| Tungsten | H.C. Starck Tungsten GmbH | Germany | ||||||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | ||||||
| Tungsten | Masan High-Tech Materials | Viet Nam | ||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||||||
| Tungsten | Niagara Refining LLC | United States of America | ||||||
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China | ||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | ||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | ||||||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China | ||||||
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province of China | ||||||
| Tungsten | Cronimet Brasil Ltda | Brazil | ||||||
| Tungsten | Hydrometallurg, JSC | Russian Federation | ||||||
| Tungsten | Unecha Refractory metals plant | Russian Federation | ||||||
| Tungsten | ACL Metais Eireli | Brazil | ||||||
| Tungsten | Moliren Ltd. | Russian Federation | ||||||
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | ||||||
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | ||||||
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals 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, 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 (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, Burundi, Rwanda, Tanzania, Uganda, Zambia
13