0000050863-14-000040.txt : 20140522 0000050863-14-000040.hdr.sgml : 20140522 20140522084237 ACCESSION NUMBER: 0000050863-14-000040 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 3 13p-1 1.01 20131231 1.02 20131231 FILED AS OF DATE: 20140522 DATE AS OF CHANGE: 20140522 FILER: COMPANY DATA: COMPANY CONFORMED NAME: INTEL CORP CENTRAL INDEX KEY: 0000050863 STANDARD INDUSTRIAL CLASSIFICATION: SEMICONDUCTORS & RELATED DEVICES [3674] IRS NUMBER: 941672743 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-06217 FILM NUMBER: 14862310 BUSINESS ADDRESS: STREET 1: 2200 MISSION COLLEGE BLVD STREET 2: RNB-4-151 CITY: SANTA CLARA STATE: CA ZIP: 95054 BUSINESS PHONE: 4087658080 MAIL ADDRESS: STREET 1: 2200 MISSION COLLEGE BLVD STREET 2: RNB-4-151 CITY: SANTA CLARA STATE: CA ZIP: 95054 SD 1 formsd.htm FORM SD formsd.htm


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
FORM SD
Specialized Disclosure Report
 
logo
 

 
 
INTEL CORPORATION
(Exact name of the registrant as specified in its charter)
 
Delaware
000-06217
94-1672743
(State or other jurisdiction of incorporation)
(Commission File Number)
(IRS Employer Identification No.)
 
 
2200 Mission College Boulevard, Santa Clara, California
 
95054-1549
(Address of principal executive offices)
 
(Zip code)
 
Cary I. Klafter
 
(408) 765-8080
(Name and telephone number, including area code, of the person to contact in connection with this report.)
 
 
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
 

   √               Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013
 
 
 
 
 

 
 
Introduction

This Specialized Disclosure Report on Form SD (“Form SD”) of Intel Corporation (“Intel” or “we”) for the year ended December 31, 2013 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten.  The Rule imposes certain reporting obligations on SEC registrants whose products contain conflict minerals that are necessary to the functionality or production of their products (such minerals are referred to as “necessary conflict minerals”), excepting conflict minerals that, prior to January 31, 2013, were located “outside of the supply chain” (as defined in the Rule). For products which contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country, collectively defined as the “Covered Countries”.  If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals contained in its products originated or may have originated in a Covered Country and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources, the registrant must conduct due diligence as a method to conclude if the necessary conflict minerals contained in those products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries.  Products which do not contain necessary conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries are considered “DRC conflict free”. We use the term “conflict free” in this Form SD in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the Covered Countries. Numerous terms in this Form SD are defined in the Rule and the reader is referred to that source and to SEC Release No. 34-67716 issued by the Securities and Exchange Commission on August 22, 2012 for such definitions.
 
Company Overview
 
We design and manufacture advanced integrated digital technology platforms. A platform consists of a microprocessor and chipset, and may be enhanced by additional hardware, software, and services. We sell these platforms primarily to original equipment manufacturers (“OEMs”), original design manufacturers (“ODMs”), and industrial and communications equipment manufacturers in the computing and communications industries. Our platforms are used in a wide range of computing applications, such as notebooks (including Ultrabook™ devices and 2 in 1 systems), desktops, servers, tablets, smartphones, automobile infotainment systems, automated factory systems, and medical devices. We also develop and sell software and services primarily focused on security and technology integration.
 
Overview of Intel’s Conflict Minerals Program
 
As a semiconductor manufacturer, we are knowledgeable of the design of our products including the materials needed to construct them.  We design the manufacturing processes to build those products and in some cases, design the detailed materials to manufacture those products. As a result, we know that many of our hardware products contain tantalum, tin, tungsten and/or gold that is necessary to the functionality or production of those products. Conflict minerals are obtained from sources worldwide, and our desire is not to eliminate those originating in the Covered Countries but rather to obtain conflict minerals from sources that do not directly or indirectly finance or benefit armed groups in the Covered Countries. We believe that it is important for us and other companies to support responsible in-region mineral sourcing from the Covered Countries in order to not negatively affect the economies of such countries.
 
For over five years, we have worked extensively to help put processes and systems in place for our company and others to manufacture products that are DRC conflict free. We have co-chaired industry working groups, recognizing that broad collaborative efforts are needed to solve this complex problem. In addition to working with others in the electronics industry, we have worked on initiatives with other industries that use necessary conflict minerals (e.g., jewelry, automotive, medical instrumentation, and others) to help create “conflict free” supply chains. We have been recognized as a leader for our work in support of conflict free supply chains and products and believe we were the first electronics company to publish goals related to manufacturing DRC conflict free products.
 
 
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Below is a summary of some of our milestones, accomplishments and current efforts regarding conflict minerals:
In 2008, we established the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”) Extractives Working Group and co-chaired this working group through 2013. At Intel, an internal team was established with the goal of establishing conflict free supply chains.
In 2009, we engaged with the non-governmental organization “The Enough Project” to consider steps to be taken to establish a conflict free supply chain. As part of the initial efforts of the Intel team, we conducted our first conflict minerals supply chain survey and undertook our first smelter visit that year.
Since 2009, we visited over 85 smelters and refiners in 21 countries with the goal of providing education on conflict minerals, collecting country of origin and chain of custody information regarding the necessary conflict minerals in our supply chain, and encouraging participation in the Conflict-Free Smelter Program (“CFSP”), an initiative organized by the EICC and GeSI.
In 2010, we first visited the DRC to conduct on-the-ground reviews of the conflict minerals trade in the region.  Our second visit to the DRC took place in 2013.
In 2010, we developed the first version of our conflict minerals sourcing policy, entitled “Socially Responsible Sourcing Statement”.
In 2010 and 2011, under our leadership and with the collaboration of EICC and GeSI member companies and other industry groups, the Conflict-Free Smelter Program released the audit protocols for tantalum, tin, tungsten and gold smelters.
In 2011, we supported in-region mining efforts by participating in the “Solutions for Hope” pilot to obtain tantalum from conflict free sources in the DRC and in the Public-Private Alliance for Responsible Minerals Trade.
In 2012, we demonstrated our commitment to continuing action by signing a multi-stakeholder statement called the “Challenge to the Conflict Mineral Rule”.
In 2012, to continue to drive responsible sourcing programs forward, we co-founded a Smelter Incentive Program which helped pay for smelter audits, reducing the direct financial burden to smelters and refiners to help encourage their early participation.  In 2013, we also donated funds directly to the Conflict Free Sourcing Initiative to continue to fund smelter and refiner audits.
In 2012, we achieved our goal of manufacturing microprocessors with tantalum sourced from conflict free supply chains.
In 2013, we accomplished our goal of manufacturing microprocessors that are DRC conflict free.
In 2014, we are continuing our work to establish conflict free supply chains for these conflict minerals.

 
Conflict Minerals Sourcing Policy
 
Intel’s policy with respect to the sourcing of conflict minerals is as follows:
 
Conflict minerals originating from the DRC are sometimes mined and sold, “under the control of armed groups”, to “finance conflict characterized by extreme levels of violence”. Some of these minerals can make their way into the supply chains of the products used around the world, including those in the electronics industry. Intel’s suppliers acquire and use conflict minerals from multiple sources worldwide. As part of Intel’s commitment to corporate responsibility and respecting human rights in our own operations and in our global supply chain, it is Intel’s goal to use tantalum, tin, tungsten and gold in our products that do not directly or indirectly finance or benefit armed groups in the Covered Countries while continuing to support responsible mineral sourcing in the region.
 
Intel expects our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict minerals are DRC conflict free.  Intel expects our suppliers to comply with the EICC Code of Conduct and conduct their business in alignment with Intel’s supply chain responsibility expectations.
 
In support of this policy, Intel will:
Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers.
Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm the tantalum, tin, tungsten and gold in our supply chain are conflict free.
Collaborate with our suppliers and others on industry-wide solutions to enable products that are DRC conflict free.
Commit to transparency in the implementation of this policy by making available reports on our progress to relevant stakeholders and the public.
 
The full text of our Conflict Minerals Sourcing Policy is available at www.intel.com/conflictfree.  The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
 
 
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Supply Chain Description
 
Most of our hardware products, primarily microprocessors, chipsets and their packages, are manufactured in Intel’s own network of fabrication facilities (“fabs”).  Although many of our hardware products contain conflict minerals, Intel does not purchase ore or unrefined conflict minerals from mines and is many steps removed in the supply chain from the mining of the conflict minerals. We purchase materials used in our products from a large network of suppliers; some of those materials contribute necessary conflict minerals to our products. The origin of conflict minerals cannot be determined with any certainty once the ores are smelted, refined and converted to ingots, bullion or other conflict minerals containing derivatives. The smelters and refiners (sometimes referred to as “facilities”) are consolidating points for ore and are in the best position in the total supply chain to know the origin of the ores.  We rely on our suppliers to assist with our reasonable country of origin inquiry and due diligence efforts, including the identification of smelters and refiners, for the conflict minerals contained in the materials which they supply to us.  Intel is more knowledgeable about the source and chain of custody of the necessary conflict minerals contained in products we fully manufacture in our fabs as compared to products which we manufacture but which include ready-made component parts which we purchase, or products which we contract to manufacture with our direct suppliers.
 
SECTION 1 - CONFLICT MINERALS DISCLOSURE
 
Item 1.01                      Conflict Minerals Disclosure and Report
 
Conclusion Based on Reasonable Country of Origin Inquiry
 
Intel has concluded in good faith that during 2013,
 
a)
Intel has manufactured and contracted to manufacture products as to which conflict minerals are necessary to the functionality or production of our products.
b)
Based on a reasonable country of origin inquiry (“RCOI”), Intel knows or has reason to believe that a portion of its necessary conflict minerals originated or may have originated in the Covered Countries and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources.
 
Description of Reasonable Country of Origin Inquiry Efforts
 
Below is a description of our efforts to determine whether any of the necessary conflict minerals in our products originated in the Covered Countries.
 
Activities Prior to 2013
 
Our efforts to obtain information on the origin of the necessary conflict minerals began in 2009 when we first asked our suppliers to complete a survey on the origin of the conflict minerals supplied to Intel. Our initial survey results demonstrated significant variance in the amount of information suppliers knew about the origin of the minerals used in their supply chains. We determined that a validation process at the smelter and refiner level, where ore is refined , was the most effective method for obtaining country of origin information given that once a mineral is processed by such a facility, it is extremely difficult or impossible to know what country or mine the mineral originated from. We conducted our first on-site conflict minerals smelter review in 2009 and as of the date of this Form SD, we have visited over 85 smelters and refiners in 21 countries with the goal of collecting country of origin and chain of custody information regarding the necessary conflict minerals in our supply chain.
 
We have co-chaired the EICC and GeSI Extractives Working Group since 2008, which led to the creation of the Conflict Free Sourcing Initiative (“CFSI”), a joint initiative of which Intel is a member that has currently over 180 participating companies from seven different industries. We worked with the EICC and GeSI to develop the Conflict Minerals Reporting Template, a standardized reporting template to facilitate the transfer of information through the supply chain regarding mineral country of origin and identity of the smelters and refiners which processed the necessary conflict minerals contained in a registrant’s products. We also worked with these organizations to develop the Conflict-Free Smelter Program (“CFSP”), an audit program designed to validate smelters’ and refiners’ sourcing practices. Through the CFSP validation process, which is voluntary, an independent third party audits the procurement and processing activities of a smelter or refiner to determine if it showed sufficient documentation to demonstrate with reasonable confidence that the minerals the smelter or refiner processed originated from conflict free sources. CFSP compliant smelters and refiners receive a “conflict free” designation from CFSI. Lists of CFSP compliant smelters and refiners are available at the CFSI website at http://www.conflictfreesourcing.org/.

 
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RCOI for 2013 Reporting Year
 
For 2013, we conducted a supply chain survey with our direct suppliers to obtain country of origin information for the necessary conflict minerals in our products using the Conflict Minerals Reporting Template. That supply chain survey requests direct suppliers to identify the smelters and refiners and countries of origin of the conflict minerals in products they supply to Intel. We compared the smelters and refiners identified in the surveys against the lists of facilities which have received a “conflict free” designation by the CFSP or other independent third party audit program such as the London Bullion Market Association’s Responsible Gold Programme and the Responsible Jewellery Council’s Chain-of-Custody Certification program, which designations provide country of origin information on the conflict minerals sourced by such facilities. If a smelter or refiner in our supply chain was not listed as having received a “conflict free” designation, we proactively contacted such facility and requested country of origin information for the necessary conflict minerals that it processed.  We documented country of origin information for the smelters and refiners identified by the supply-chain survey as provided from multiple sources including the supply-chain survey, independent third party audit programs and directly from smelters and refiners that Intel contacted.
 
There is significant overlap between our RCOI efforts and our due diligence measures performed. Our due diligence measures performed are discussed further in the Conflict Minerals Report filed as Exhibit 1.02 hereto.
 
Below is a summary of the country of origin information collected as a result of our RCOI efforts.
 
Conflict Mineral
Countries of origin and other sources may include the following
Tantalum
Australia, Brazil, Burundi, Canada, China, DRC, Egypt, Estonia, Ethiopia, Germany, India, Japan, Kazakhstan, Malaysia, Mozambique, Niger, Nigeria, Russian Federation, Rwanda, South Africa, Thailand, United States, Zimbabwe and recycled or scrap sources
Tin
Australia, Belgium, Bolivia, Brazil, Canada, China, DRC, India, Indonesia, Japan, Malaysia, Mexico, Peru, Philippines, Russian Federation, Rwanda, Thailand, United States and recycled or scrap sources
Tungsten
Australia, Austria, Bolivia, Brazil, Burundi, Cambodia, Canada, China, Colombia, Germany, Indonesia, Japan, Mexico, Nigeria, Peru, Portugal, Russian Federation, Rwanda, South Africa, Spain, Thailand, United States, Vietnam and recycled or scrap sources
Gold
Argentina, Armenia, Australia, Bolivia, Brazil, Bulgaria, Canada, Chile, China, Colombia,
Ecuador, Egypt, Eritrea, Ethiopia, Fiji, Finland, Georgia, Germany, Ghana, Guatemala,
Honduras, Hong Kong, Indonesia, Japan, Kazakhstan, Republic of Korea, Lao People's Democratic Republic, Malaysia, Mali, Mexico, Mongolia, New Zealand, Nicaragua, Panama, Papua New Guinea, Peru, Philippines, Russian Federation, Saudi Arabia, Singapore, Solomon Islands, Somalia, South Africa, South Sudan, Suriname, Switzerland, Taiwan, United Republic of Tanzania, Thailand, Turkey, United Kingdom, United States, Uruguay, Uzbekistan, Venezuela and recycled or scrap sources

Conflict Minerals Disclosure
 
This Form SD and the Conflict Minerals Report, filed as Exhibit 1.02 hereto, are publicly available at www.intc.com and www.intel.com/conflictfree as well as the SEC’s EDGAR database at www.sec.gov.
 
Item 1.02
Exhibit
 
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.02 to this Form SD.
 
SECTION 2 – EXHIBITS
 
Item 2.01
Exhibits
 
Exhibit 1.02 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
 
___________________
 
Intel, the Intel logo, and Ultrabook are trademarks of Intel Corporation in the U.S. and/or other countries.

 
  5

 

 



 
SIGNATURES
 
 
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
 
 
INTEL CORPORATION
(Registrant)
 
   
 
By:
 
/s/ Brian M. Krzanich
 
 
May 22, 2014
 
Brian M. Krzanich
Chief Executive Officer
 
(Date)
 
 



 
  6

 


 
 
EX-1.02 2 exh102.htm EXHIBIT 1.02 exh102.htm
Exhibit 1.02
 
Conflict Minerals Report
   
 
Intel Corporation
in accord with Rule 13p-1 under the Securities Exchange Act of 1934

This Conflict Minerals Report (“Report”) of Intel Corporation (“Intel” or “we”) for the year ended December 31, 2013 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule”).  Numerous terms in this Report are defined in the Rule and our Specialized Disclosure Report on Form SD and the reader is referred to those sources and to SEC Release No. 34-67716 issued by the Securities and Exchange Commission on August 22, 2012 for such definitions.
 
Pursuant to the Rule, we undertook due diligence measures on the source and chain of custody of the necessary conflict minerals in our products that we had reason to believe may have originated from the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively defined as the “Covered Countries”) and may not have come from recycled or scrap sources, to determine whether such products were “DRC conflict free”. We use the term “conflict free” in this Report in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the Covered Countries.
 
Design of Conflict Minerals Program
 
The design of our conflict minerals program is in conformity with the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, “OECD Guidance”), specifically as it relates to our position in the minerals supply chain as a “downstream” purchaser. Summarized below are the design components of our conflict minerals program as they relate to the five-step framework set forth in the OECD Guidance:
 
1.  
Establish strong company management systems:
Operate an internal “Conflict Minerals” team led by our Global Sourcing and Procurement organization to implement our Conflict Minerals Sourcing Policy, which policy is set forth in our Form SD.  Regularly review such implementation efforts with our Chief Executive Officer (“CEO”) and senior management of our Technology and Manufacturing Group (“TMG”).
Implement a supply chain system of controls and transparency through the use of due diligence tools created by the Conflict-Free Sourcing Initiative (“CFSI”) which includes the Conflict Minerals Reporting Template (“CMRT”), a supply chain survey designed to identify the smelters and refiners that process the necessary conflict minerals contained in our products.
Incorporate requirements related to conflict minerals in our standard template for supplier contracts and specifications so that current and future suppliers are obligated to comply with our policies on conflict minerals, including participation in a supply chain survey and related due diligence activities.
Maintain records relating to our conflict minerals program in accordance with our record retention guidelines.
Enable employees, suppliers and other stakeholders to report any concerns relating to our conflict minerals program through our online corporate responsibility reporting and grievance mechanism.
 

2.  
Identify and assess risks in our supply chain:
Identify direct suppliers that supply products to Intel that may contain conflict minerals.
Conduct a supply chain survey using the CMRT, requesting direct suppliers to identify smelters and refiners and country of origin of the conflict minerals in products they supply to Intel.
Contact direct suppliers that do not respond to the supply chain survey by a specified date, requesting their responses.
Compare smelters and refiners identified by the supply chain survey against the list of facilities that have received a “conflict free” designation from the Conflict Free Smelter Program (“CFSP”) or other independent third party audit program, which designations provide country of origin and due diligence information on the conflict minerals sourced by such facilities.
Document country of origin information for the smelters and refiners identified by the supply chain survey as provided from multiple sources including the supply chain survey, the CFSI and directly from smelters and refiners that Intel contacts.

 
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3.  
Design and implement a strategy to respond to identified risks:
Design and adopt a risk management plan that includes due diligence reviews of suppliers, smelters and refiners that may be sourcing or processing conflict minerals from the Covered Countries which may not be from recycled or scrap sources. Our due diligence measures are significantly based on multi-industry due diligence initiatives to evaluate the procurement practices of the smelters and refiners that process and provide those conflict minerals to our supply chain.
Implement a risk mitigation response plan to monitor and track suppliers, smelters and refiners identified as not meeting the requirements set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements.
Perform risk mitigation efforts to bring suppliers into conformity with our Conflict Minerals Sourcing Policy and contractual requirements, which efforts may include working with direct suppliers to consider an alternative source for the necessary conflict minerals.
Contact selected smelter and refiner facilities that have not received a “conflict free” designation from an independent third party audit program to encourage their participation in such a program and request country of origin and chain of custody information.
Provide progress reports to our CEO and TMG senior management summarizing our risk mitigation efforts.
As required by the Rule, obtain an independent private sector audit of this Report.
 
4.  
Support the development and implementation of independent third party audits of smelters’ and refiners’ sourcing:
Support development and implementation of due diligence practices and tools such as the CMRT through our membership, participation and leadership within the CFSI and CFSI sub-teams.
Support development and implementation of the CFSP by writing the CFSP audit protocol and procedures in conjunction with CFSI member companies and other industry groups.
 
5.  
Report on supply chain due diligence:
Publicly communicate our Conflict Minerals Sourcing Policy on our company website at www.intel.com/conflictfree.
Report annually on our supply chain due diligence activities in our white paper titled “Intel’s Efforts to Achieve a ‘Conflict-Free’ Supply Chain” and Corporate Social Responsibility Report available on our company website at www.intel.com/conflictfree.
 
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.
 
Description of Due Diligence Measures Performed
 
Below is a description of the measures we performed for the reporting period to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products that we had reason to believe may have originated from the Covered Countries and may not have come from recycled or scrap sources:
 
Designed and adopted a risk management plan that includes due diligence reviews of suppliers, smelters and refiners which we identified may be sourcing or processing conflict minerals from the Covered Countries which may not be from recycled or scrap sources.
Contacted direct suppliers on responses to supply chain surveys that we identified contained incomplete or potentially inaccurate information to seek additional clarifying information.
Compared smelters and refiners identified by the supply chain survey against the list of facilities that have received a “conflict free” designation from the CFSP or other independent third party audit program.
Implemented a risk mitigation response plan to monitor and track suppliers, smelters and refiners identified as not meeting the requirements set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements.
Performed risk mitigation efforts with suppliers we identified to be not in conformity with our Conflict Minerals Sourcing Policy and contractual requirements by working with them to bring them into compliance.
Contacted smelters and refiners that had not received a “conflict free” designation to encourage their participation in the CFSP or other independent third party audit program.
In 2013, visited 29 smelter and refiner facilities to review their country of origin and chain of custody information.
Provided monthly progress reports to TMG senior management that summarized the status of smelters and refiners subject to our due diligence efforts.
As required by the Rule, obtained an independent private sector audit of this Report, which is set forth as Exhibit A to this Report.
 
 
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Products
 
During this reporting period, we identified the following products that may contain necessary conflict minerals that we manufactured or contracted to manufacture:
 
“Client Microprocessors and Chipsets”: Desktop and mobile microprocessors and chipsets that are solely manufactured by Intel, which are comprised of the following:  Celeron®, Pentium®, Intel® Core i3™, Intel® Core™ i5, Intel® Core™ i7, Intel® Quark™, and Intel® Atom processors (except Intel Atom processors for servers, storage and communications).
 
“All Other”: All other Intel® products that may contain necessary conflict minerals that we manufactured or contracted to manufacture, which products are comprised of the following:
o  
Server: Enterprise branded microprocessors, chipsets, motherboards, server and micro-server systems which contain components manufactured by Intel and other components purchased by Intel including Intel® Xeon Phi™, Intel® Xeon®, Itanium® and Intel Atom processors for servers and storage.
o  
Mobile: Wireless platforms including Intel® mobile phone platforms and mobile communications platforms such as Intel® XMM™ slim modems.
o  
Networking: Ethernet network adapters, controllers and wireless products which enable the computers and networks to exchange data including Thunderbolt™ technology, Intel® Centrino® technology, Intel® WiMAX and Intel® WiFi products.
o  
Boards and Other Components: Desktop printed circuit boards and other components including Intel® Desktop Boards, Intel® Galileo boards and Intel® NUC (next unit of computing).
o  
Storage and Other: Memory products including Intel® Solid-State Drives (Intel® SSDs) and Intel Atom processors for storage and communications.
 
Results of our Due Diligence Measures
 
Inherent Limitations on Due Diligence Measures
 
As a downstream purchaser of conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals.  Our due diligence processes are based on the necessity of seeking data from our direct suppliers 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.   Such sources of information, as well as our smelters and refiner facility visits, may yield inaccurate or incomplete information and may be subject to fraud.
 
Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. Under the Dodd-Frank Act and the Rule, a product is “DRC conflict free” if it meets the required standard every day of the reporting year; conversely, a product would “not be found to be DRC conflict free” if it does not meet the required standard even one day of the reporting year. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use.  Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners.  We ask that the data cover the entire reporting year, and we seek to use contract provisions requiring the suppliers to promptly update us in the event that the sourcing data changes.

 
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Supplier Chain Survey Responses
 
As a result of the supply chain surveys that we conducted, approximately 83% of our direct suppliers that contribute necessary conflict minerals to our products have provided a response to the supply chain survey. All our direct suppliers that contribute necessary conflict minerals to our Client Microprocessor and Chipset products have provided a response to our supply chain survey.
 
Product Determination
 
On the basis of the due diligence measures described in this Report, Intel has concluded in good faith that during this reporting period, the necessary conflict minerals contained in our products that originated or may have originated from the Covered Countries are either DRC conflict free or DRC conflict undeterminable as described below.
 
DRC conflict free
 
Our Client Microprocessor and Chipset products are DRC conflict free.  Our suppliers have identified the smelters and refiners in the supply chain that are sources of the necessary conflict minerals for our Client Microprocessor and Chipset products.  All such smelters and refiners have either received a “conflict free” designation from the CFSP or other independent third party audit program and/or have been visited by Intel personnel to review country of origin and chain of custody information which resulted in our reasonable determination that our Client Microprocessor and Chipset products are DRC conflict free.
 
DRC conflict undeterminable
 
All Other products are DRC conflict undeterminable.  We are making this determination because we do not have sufficient information from suppliers or other sources regarding all of the smelters and refiners that processed the necessary conflict minerals in All Other products to conclude whether the conflict minerals originated in the Covered Countries and, if so, whether the conflict minerals were from recycled or scrap sources or were or were not from other conflict free sources.
 
Our efforts to determine the mine or location of origin of the necessary conflict minerals in our products that are DRC conflict undeterminable with the greatest possible specificity consisted of the due diligence measures described in this Report. In particular, because independent third party audit programs validate whether sufficient evidence exists regarding country, mine and/or location of origin of the conflict minerals that the audited smelter or refiner facilities have processed, we relied on the information made available by such programs for the smelters and refiners in our supply chain. For smelters or refiners in our supply chain that had not received a “conflict free” designation by any independent third party audit programs, we contacted such facilities and requested country, mine and/or location of origin of the necessary conflict minerals processed by them, and in many cases, visited the facilities to perform an on-site review of this information.  We were unable to ascertain the country of origin and/or chain of custody of all necessary conflict minerals processed by the facilities that contributed to All Other products because, for this reporting period, certain smelter and refiner facilities (1) had not yet received a “conflict free” designation from an independent third party audit program and (2) did not respond to our requests for country of origin or chain of custody information and/or were unwilling to allow Intel to visit the facility to conduct an on-site review of such information.
 
 
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Table 1 below lists the facilities which, to the extent known, processed the necessary conflict minerals in All Other products.

Metal
Smelter or Refiner Facility Name
Gold
Aida Chemical Industries Co. Ltd.
Gold
Allgemeine Gold-und Silberscheideanstalt A.G. *
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Gold
AngloGold Ashanti Córrego do Sítio Minerção *
Gold
Argor-Heraeus SA *
Gold
Asahi Pretec Corporation *
Gold
Asaka Riken Co Ltd
Gold
Aurubis AG
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold
Boliden AB
Gold
Caridad
Gold
CCR Refinery – Glencore Canada Corporation *
Gold
Cendres + Métaux SA
Gold
Chimet S.p.A. *
Gold
Dowa *
Gold
FSE Novosibirsk Refinery
Gold
Heimerle + Meule GmbH *
Gold
Heraeus Ltd. Hong Kong *
Gold
Heraeus Precious Metals GmbH & Co. KG *
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
Gold
Ishifuku Metal Industry Co., Ltd. *
Gold
Japan Mint
Gold
Jiangxi Copper Company Limited
Gold
Johnson Matthey Inc *
Gold
Johnson Matthey Ltd *
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold
JSC Uralectromed
Gold
JX Nippon Mining & Metals Co., Ltd. *
Gold
Kazzinc Ltd
Gold
Kennecott Utah Copper LLC *
Gold
Kojima Chemicals Co., Ltd *
Gold
Kyrgyzaltyn JSC
Gold
LS-NIKKO Copper Inc. *
Gold
Materion *
Gold
Matsuda Sangyo Co., Ltd. *
Gold
Metalor Technologies (Hong Kong) Ltd *
Gold
Metalor Technologies SA *
Gold
Metalor USA Refining Corporation *
Gold
Met-Mex Peñoles, S.A.
Gold
Mitsubishi Materials Corporation *
Gold
Mitsui Mining and Smelting Co., Ltd. *
Gold
Moscow Special Alloys Processing Plant
Gold
Navoi Mining and Metallurgical Combinat
Gold
Nihon Material Co. LTD *
Gold
Ohio Precious Metals, LLC *
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
Gold
OJSC Kolyma Refinery
Gold
PAMP SA *
Gold
Prioksky Plant of Non-Ferrous Metals
Gold
PT Aneka Tambang (Persero) Tbk
Gold
PX Précinox SA
Gold
Rand Refinery (Pty) Ltd *
Gold
Royal Canadian Mint *
Gold
Sabin Metal Corp.
Gold
Schone Edelmetaal
Gold
SEMPSA Joyería Platería SA *
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Gold
Solar Applied Materials Technology Corp. *
Gold
Sumitomo Metal Mining Co., Ltd. *
Gold
Tanaka Kikinzoku Kogyo K.K. *
Gold
The Great Wall Gold and Silver Refinery of China
Gold
The Refinery of Shandong Gold Mining Co. Ltd
Gold
Tokuriki Honten Co., Ltd *
Gold
Umicore Brasil Ltda *
Gold
Umicore SA Business Unit Precious Metals Refining *
 
 
 
5

 


Metal
Smelter or Refiner Facility Name
Gold
United Precious Metal Refining, Inc. *
Gold
Valcambi SA
Gold
Western Australian Mint trading as The Perth Mint *
Gold
Yokohama Metal Co Ltd
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Gold
Zijin Mining Group Co. Ltd
Tantalum
Conghua Tantalum and Niobium Smeltry *
Tantalum
Duoluoshan *
Tantalum
Exotech Inc. *
Tantalum
F&X Electro-Materials Ltd. *
Tantalum
Global Advanced Metals
Tantalum
H.C. Starck Group *
Tantalum
Hi-Temp *
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd. *
Tantalum
Jiujiang Tanbre Co., Ltd. *
Tantalum
Kemet Blue Powder *
Tantalum
Metallurgical Products India (Pvt.) Ltd. *
Tantalum
Mitsui Mining & Smelting *
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd. *
Tantalum
Plansee *
Tantalum
RFH Tantalum Smeltry Co., Ltd *
Tantalum
Solikamsk Magnesium Works *
Tantalum
Taki Chemicals *
Tantalum
Tantalite Resources *
Tantalum
Telex *
Tantalum
Ulba *
Tantalum
Zhuzhou Cement Carbide *
Tin
Alpha *
Tin
China Tin Group Co., Ltd.
Tin
CNMC (Guangxi) PGMA Co. Ltd.
Tin
Cooper Santa
Tin
CV Serumpun Sebalai
Tin
CV United Smelting
Tin
EM Vinto
Tin
Fenix Metals
Tin
Gejiu Non-Ferrous Metal Processing Co. Ltd. *
Tin
Gejiu Zi-Li
Tin
Huichang Jinshunda Tin Co. Ltd
Tin
Jiangxi Nanshan
Tin
Kai Unita Trade Limited Liability Company
Tin
Linwu Xianggui Smelter Co
Tin
Malaysia Smelting Corporation (MSC) *
Tin
Metallo Chimique
Tin
Mineração Taboca S.A. *
Tin
Minmetals Ganzhou Tin Co. Ltd.
Tin
Minsur *
Tin
Mitsubishi Materials Corporation
Tin
Novosibirsk Integrated Tin Works
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Tin
OMSA *
Tin
PT Artha Cipta Langgeng
Tin
PT Babel Inti Perkasa
Tin
PT Bangka Putra Karya
Tin
PT Belitung Industri Sejahtera
Tin
PT Bukit Timah *
Tin
PT DS Jaya Abadi
Tin
PT Eunindo Usaha Mandiri
Tin
PT Mitra Stania Prima
Tin
PT Prima Timah Utama
Tin
PT Refined Bangka Tin
Tin
PT Sariwiguna Binasentosa
Tin
PT Stanindo Inti Perkasa
Tin
PT Tambang Timah *
Tin
PT Timah *
Tin
PT Tinindo Inter Nusa
Tin
Rui Da Hung
Tin
Soft Metais, Ltda.
Tin
Thaisarco *
Tin
White Solder Metalurgia e Mineração Ltda. *
Tin
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.
 
 

 
6

 

 
Metal
Smelter or Refiner Facility Name
Tin
Yunnan Tin Company, Ltd. *
Tungsten
A.L.M.T. Corp.
Tungsten
China Minmetals Nonferrous Metals Co., Ltd.
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
Ganzhou Grand Sea W & Mo Group Co., Ltd.
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten
Global Tungsten & Powders Corp. *
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
Tungsten
H.C. Starck Group
Tungsten
Hunan Chenzhou Mining Group Co., Ltd.
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten
Japan New Metals Co., Ltd.
Tungsten
Kennametal Inc.
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten
Wolfram Bergbau und Hütten AG
Tungsten
Wolfram Company CJSC
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten
Xiamen Tungsten Co., Ltd.
Tungsten
Zhuzhou Cemented Carbide Group Co., Ltd.
 
Countries of origin of the conflict minerals these facilities process are believed to include:
Argentina, Armenia, Australia, Austria, Belgium, Bolivia, Brazil, Bulgaria, Burundi, Cambodia, Canada, Chile, China, Colombia, DRC, Ecuador, Egypt, Eritrea, Estonia, Ethiopia, Fiji, Finland, Georgia, Germany, Ghana, Guatemala, Honduras, Hong Kong, India, Indonesia, Japan, Kazakhstan, Republic of Korea, Laos People’s Democratic Republic, Malaysia, Mali, Mexico, Mongolia, Mozambique, New Zealand, Nicaragua, Niger, Nigeria, Panama, Papua New Guinea, Peru, Philippines, Portugal, Russian Federation, Rwanda, Saudi Arabia, Singapore, Solomon Islands, Somalia, South Africa, Spain, South Sudan, Suriname, Switzerland, Taiwan, United Republic of Tanzania, Thailand, Turkey, United Kingdom, United States, Uruguay, Uzbekistan, Venezuela, Vietnam, Zimbabwe
 
 
 
 
Smelter and refiner facility names as reported by the CFSI as of May 15, 2014.
 
 
*
Denotes smelters and refiners which have received a “conflict free” designation from an independent third party audit program as of May 15, 2014.
 
 
Future Due Diligence Measures
 
During the reporting period for the calendar year ending December 31, 2014, we are continuing to engage in the activities described above in “Design of Conflict Minerals Program” and “Description of Due Diligence Measures Performed.” In our efforts to attain a conflict-free supply chain for our products, we intend to continue to contact smelters and refiners identified in our supply chain survey process that have not received a “conflict free” designation and request their participation in the CFSP or other independent third party audit program in order for them to obtain such a “conflict free” designation.
 
Independent Private Sector Audit of this Report
 
We obtained an independent private sector audit of this Report by Ernst & Young LLP, which is set forth as Exhibit A to this Report.
 
 
 
____________________________
 
Intel and the Intel logo, Intel Atom, Intel Core, Intel Xeon, Intel Xeon Phi, Centrino, Celeron, Itanium, Pentium, Quark, Thunderbolt, and XMM are trademarks of Intel Corporation in the U.S. and/or other countries.

 
7

 

 
Exhibit A
 
 
Report of Independent Accountants
 
Board of Directors and Stockholders of Intel Corporation
 
We have examined whether the design of Intel Corporation’s (the “Company”) due diligence framework as set forth in the Design of Conflict Minerals Program section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2013, is in conformity, in all material respects, with the criteria set forth in the Organisation of Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition 2013 (“OECD Due Diligence Guidance”), and whether the Company’s description of the due diligence measures it performed, as set forth in Description of Due Diligence Measures Performed section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2013, is consistent, in all material respects, with the due diligence process that the Company undertook.
 
Management is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. Our responsibility is to express an opinion on the design of the Company’s due diligence framework and on the description of the due diligence measures the Company performed, based on our examination. Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards applicable to attestation engagements contained in Government Auditing Standards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our opinion.
 
Our examination was not conducted for the purpose of evaluating:
►  
The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance
►  
The completeness of the Company’s description of the due diligence measures performed
►  
The suitability of the design or operating effectiveness of the Company’s due diligence process
►  
Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance
►  
The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof
►  
The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products
 
Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than the design of the Company’s due diligence framework as set forth in the Design of Conflict Minerals Program section and the Company’s description of the due diligence measures it performed, as set forth in the Description of Due Diligence Measures Performed section referenced in the first paragraph above.
 
In our opinion, the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2013, as set forth in the Design of Conflict Minerals Program section of the Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and the Company’s description of the due diligence measures it performed as set forth in the Description of Due Diligence Measures Performed section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2013, is consistent, in all material respects, with the due diligence process that the Company undertook.
 
/s/ Ernst & Young LLP
 
San Jose, California
May 22, 2014


 

 

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