EX-1.01 2 d740383dex101.htm EX-1.01 EX-1.01

Exhibit 1.01

CONFLICT MINERALS REPORT

 

LOGO

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, 2018 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting requirements related to “conflict minerals,” defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, and 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 (referred to as “necessary conflict minerals”). For products that contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the necessary conflict minerals originated in the Democratic Republic of the Congo (DRC) or an adjoining country (collectively, the “Covered Countries”). If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals originated or may have originated in a Covered Country and may not be solely from recycled or scrap sources, the registrant must conduct due diligence to determine if the necessary conflict minerals directly or indirectly financed or benefited armed groups (as defined by the SEC in Form SD) in the Covered Countries.

Overview of Intel’s Conflict Minerals Program

Many of our hardware products contain tantalum, tin, tungsten and/or gold 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.

We have worked extensively for over eleven years on the issue of conflict minerals, as part of our work on responsible mineral sourcing, which we define as sourcing done in an ethical and sustainable manner that safeguards the human rights of those involved in our global supply chain. We recognize that broad collaborative efforts among governments, non-governmental organizations and industry are needed to identify and mitigate the risk of contributing to serious human rights abuses and conflict related to mineral extraction in the Covered Countries. Intel is a member of the Responsible Minerals Initiative (RMI), unique member code INTC, and the European Partnership for Responsible Minerals (EPRM), where we collaborate with companies in the electronics and other industries (e.g. jewelry, automotive, medical instrumentation, and others) and other stakeholders, such as public authorities and civil society groups, to address responsible mineral sourcing issues. Additionally, we are members of, and provide support to, the International Tin Association’s International Tin Supply Chain Initiative (iTSCi) and the Public-Private Alliance for Responsible Minerals Trade (PPA), which promote responsibly sourced minerals from the Covered Countries. We are also part of the CRAFT Code Committee, which assisted in the development of the Code of Risk-mitigation for Artisanal and Small-Scale Mining engaging in Formal Trade (CRAFT).

Supply Chain Description

Most of our hardware products, primarily microprocessors, chipsets and their packages, are manufactured in our own network of fabrication facilities (fabs). Although many of our hardware products contain conflict minerals, we do not purchase ore or unrefined conflict minerals from mines. We are many steps removed in the supply chain from the mining of conflict minerals and are therefore considered a “downstream” purchaser. 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 derivatives. The smelters and refiners (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

 

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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. We are 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 also include ready-made component parts we purchase from third parties, or products that are manufactured for us by other companies.

Design of Conflict Minerals Program

The design of Intel’s 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 (CAHRAs), Third 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 from the OECD Guidance:

 

  1.

Maintain strong company management systems:

 

   

Conflict Minerals Sourcing Policy: Maintain a supply chain policy for conflict minerals originating from the Covered Countries that includes our commitment to exercise due diligence consistent with the OECD Guidance. That policy is available at www.intel.com/conflictfree and has been updated as of March 2019 to include our expanded commitment to collaborate with customers, suppliers, and industry associations on long-term solutions to enable responsible mineral sourcing.

 

   

Internal Responsible Minerals team: Operate an internal Responsible Minerals team led by our Global Supply Management organization to implement our Conflict Minerals Sourcing Policy. We review such efforts with our Chief Executive Officer (CEO) and senior management of our Technology and Manufacturing Group (TMG).

 

   

Supply chain control system: Employ a supply chain system of controls and transparency through the use of due diligence tools such as the Conflict Minerals Reporting Template (CMRT), a supply chain survey designed by the RMI to identify the smelters and refiners that process the necessary conflict minerals contained in our products and the country of origin of those conflict minerals. We employ a database to assess due diligence information and maintain records relating to our responsible minerals program for at least five years, in accordance with our record retention guidelines.

 

   

Supplier engagement: Feature 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. We communicate our Conflict Minerals Sourcing Policy and contractual requirements to relevant suppliers annually.

 

   

Company grievance mechanism: 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 found on our company website at https://www.intel.com/content/www/us/en/corporate-responsibility/corporate-responsibility.html.

 

  2.

Identify and assess risks in our supply chain:

 

   

Identify smelters/refiners in our supply chain: Identify direct suppliers that supply products to Intel that may contribute necessary conflict minerals to our products. Conduct an annual supply chain survey requesting those direct suppliers to provide a conflict minerals declaration, using the CMRT, designed to identify the conflict minerals contained in the products they supply to Intel, the smelters and refiners that processed those conflict minerals, and the country of origin of those conflict minerals. We evaluate the completeness and accuracy of the suppliers’ survey responses and contact suppliers whose survey response we identified as having contained incomplete or potentially inaccurate information in order to seek additional clarifying information.

 

   

Identify the scope of the risk assessment: Our risk assessment is designed to identify risks in our supply chain. This includes direct suppliers not meeting our contractual requirements related to conflict minerals as well as smelters and refiners that are not conformant to a responsible mineral sourcing validation program or that we have reason to believe may source conflict minerals from the Covered Countries. We document mineral country of origin information for the smelters and refiners

 

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identified by the supply chain survey, as provided from sources including the supply chain survey, responsible mineral sourcing validation programs, direct contact with smelters and refiners, and from publicly available sources such as smelter and refiner websites.

 

   

Assess due diligence practices of smelters and refiners: Compare smelters and refiners identified by the supply chain survey against the list of facilities that are conformant to a responsible mineral sourcing validation program such as the RMI’s Responsible Minerals Assurance Program (RMAP), or other RMI cross-recognized, independent third party audit programs.

 

   

Carry out spot checks of smelters and refiners: Conduct spot checks of smelter and refiner due diligence practices by attempting to visit those facilities that are not conformant to a responsible mineral sourcing validation program and which allowed our visit. Our smelter and refiner visits are designed to assess their due diligence practices, request country of origin and chain of custody information for the conflict minerals processed by the facilities and encourage and assist their participation in such a program.

 

  3.

Execute a strategy to respond to identified risks:

 

   

Report findings to senior management: Provide progress reports to our CEO and TMG senior management summarizing information gathered during our annual supply chain survey, results from the risk assessment process and status of our risk mitigation efforts.

 

   

Devise and adopt a risk management plan: Maintain 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 responsible mineral sourcing validation programs that evaluate the procurement practices of the smelters and refiners that process and provide those conflict minerals to our supply chain.

 

   

Implement a risk management plan: Perform risk mitigation efforts to bring suppliers into conformity with our Conflict Minerals Sourcing Policy or contractual requirements, which efforts may include working with direct suppliers to consider an alternative source for the necessary conflict minerals. Attempt to contact smelter and refiner facilities that are not conformant to a responsible mineral sourcing validation program to assess their due diligence practices, request country of origin and chain of custody information for the conflict minerals processed by the facilities and encourage and assist their participation in such a program.

 

   

Ongoing risk monitoring: 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.

 

  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 leadership in the RMI’s Steering Committee and participation within RMI sub-teams.

 

   

Support development and implementation of the RMAP by defining the terms of the RMAP audit protocol in conjunction with RMI member companies and other industry groups.

 

   

Support responsible mineral sourcing validation programs that carry out independent third party audits of smelter and refiner facilities, such as the RMAP, through our membership in and financial support of the RMI (unique member code INTC).

 

  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 Responsibly Sourced Mineral Supply Chain” and Corporate Responsibility Report available on our company website at www.intel.com/conflictfree.

 

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Obtain an independent private sector audit of applicable sections of this Report and file a Form SD with the SEC. This information is publicly 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 Reasonable Country of Origin Inquiry Efforts

For 2018, our reasonable country of origin inquiry (RCOI) efforts included conducting a supply chain survey of our direct suppliers (referred to as “surveyed suppliers”) using the CMRT. The supply chain surveys requested our suppliers to identify the smelters and refiners and countries of origin of the conflict minerals in products they supply to us. We compared the smelters and refiners identified in the surveys against the lists of facilities which are conformant to a responsible mineral sourcing validation program, such as the RMAP or RMI cross-recognized programs. We also proactively attempted to contact smelter and refiner facilities identified by our surveyed suppliers where we did not have mineral country of origin information and requested each facility contacted to identify the types of raw materials processed by the facility and the mineral country of origin for ore processed by that facility. We documented country of origin information for the smelter and refiner facilities identified by surveyed suppliers as provided from sources including the supply chain survey, responsible mineral sourcing validation programs, direct contact with smelters and refiners, and from publicly available sources such as smelter and refiner websites, if we determined such publicly available sources to be reliable.

Results of Reasonable Country of Origin Inquiry Efforts

For 2018, Intel conducted a supply chain survey of 277 suppliers that we identified may contribute necessary conflict minerals to our products.

The results of our RCOI as of March 1, 2019 are as follows:

 

   

98% of surveyed suppliers provided a CMRT in response to our supply chain survey request.

 

   

The surveyed suppliers identified 257 operational smelter and refiner facilities which may process the necessary conflict minerals contained in the products provided to us.

 

   

We know or have reason to believe that a portion of the conflict minerals processed by 42 of these 257 smelters and refiners may have originated in the Covered Countries and may not be solely from recycled or scrap sources.

This data includes suppliers to Mobileye, a company Intel acquired in 2017. Mobileye conflict mineral due diligence efforts are completely incorporated into our responsible minerals program. Of the 277 surveyed suppliers, 53 were suppliers to Mobileye that were not otherwise part of the Intel supply chain (“Mobileye-unique” suppliers). As of March 1, 2019, 47 of the 53 Mobileye-unique suppliers, approximately 89%, had provided a CMRT in response to our supply chain survey request (compared with 68% in the previous year’s Report). The information provided by those suppliers is included in the results of our RCOI and the Results of our Due Diligence Measures below. Our response rate for Mobileye-unique suppliers has improved since last year, but is not meeting the overall goal that Intel expects from its supply chain (excluding Mobileye-unique suppliers, our supplier response rate was 100%). Intel’s supplier due diligence with these remaining suppliers is ongoing and we are continuing work on our escalation paths to increase the response rate.

Conclusion Based on Reasonable Country of Origin Inquiry

We have concluded in good faith that during 2018:

 

a)

Intel manufactured and contracted with others to manufacture products as to which conflict minerals are necessary to the functionality or production of our products.

 

b)

Based on our RCOI, we know or have reason to believe that a portion of the necessary conflict minerals contained in our products originated or may have originated in the Covered Countries and know or have reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources.

As a result of the above conclusion and pursuant to the Rule, we undertook due diligence measures on the source and chain of custody of the necessary conflict minerals in our products which we had reason to believe may have originated from the Covered Countries and which may not have come from recycled or scrap sources. There is significant overlap between our RCOI efforts and our due diligence measures performed.

 

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Description of Due Diligence Measures Performed

Below is a description of the measures performed for this reporting period, as of March 1, 2019, to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products:

 

   

Conducted a supply chain survey of suppliers which we identified may be supplying Intel with products that contain necessary conflict minerals using the CMRT, requesting country of origin information regarding the necessary conflict minerals and identification of smelters and refiners that process such minerals.

 

   

Contacted surveyed suppliers on responses to supply chain surveys that we identified as having contained incomplete or potentially inaccurate information to seek additional clarifying information.

 

   

Received a CMRT from 98% of our surveyed suppliers in response to our supply chain survey request.

 

   

Compared smelters and refiners identified by surveyed suppliers against the list of facilities that are conformant to a responsible mineral sourcing validation program.

 

   

Monitored and tracked surveyed suppliers, and smelters and refiners identified by surveyed suppliers, which we identified as not meeting our conflict minerals policy or contractual requirements, to determine their progress in meeting those requirements.

 

   

Performed risk mitigation efforts with surveyed suppliers we identified as not in conformity with our conflict minerals policy or contractual requirements by working with them to bring them into compliance.

 

   

In 2018, visited 2 smelters and refiners that were not conformant with a responsible mineral sourcing validation program to collect country of origin information and encourage and assist their participation in such a program.

 

   

Provided 12 progress reports to TMG senior management and 2 progress reports to our CEO that summarized the status of our conflict minerals program.

 

   

Obtained an independent private sector audit of applicable sections of this Report, which is set forth as Exhibit A to this Report.

Results of our Due Diligence Measures

Inherent Limitations on Due Diligence Measures

As a downstream purchaser of products which contain 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 responsible mineral sourcing validation programs. Such sources of information, as well as our smelters and refiner facility visits and publicly available sources, 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. 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 and the entire supply chain 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.

Surveyed Supplier Due Diligence Results

Intel evaluated the accuracy and completeness of the responses to our supply chain surveys by our surveyed suppliers. We identified 34 surveyed suppliers whose initial survey response contained incomplete or potentially inaccurate information. We used various methods to identify the incomplete or inaccurate information in the surveyed supplier’s response, including verification checks conducted by third party software or by members of our internal Responsible

 

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Minerals team. When an incomplete or inaccurate response was identified, we contacted the applicable surveyed supplier, identified the incomplete or inaccurate information and requested that the surveyed supplier correct the incomplete or potentially inaccurate information and provide an updated response. 33 of these 34 surveyed suppliers provided an updated CMRT which we determined, using the same evaluation criteria, to be complete and accurate. We continue to work with the remaining supplier on capacity building to ensure accuracy of future declarations.

Upon receiving a survey response identified to be complete and accurate based on our evaluation criteria, we further evaluated each response for conformity with our conflict minerals policy or contractual requirements. These requirements include that our surveyed suppliers must maintain a publicly available conflict minerals sourcing policy, provide a CMRT upon our request, and use smelters and refiners which are either conformant to a responsible mineral sourcing validation program, have begun participating in such a program, or are included among the facilities that we have reasonably concluded, through our own due diligence activities, do not process conflict minerals which originated from the Covered Countries. We identified surveyed suppliers which were not fully compliant with all applicable requirements and monitored and tracked these suppliers’ progress in meeting the applicable requirements. We performed risk mitigation efforts by contacting each supplier, identifying actions items which we requested the supplier complete, and asking the supplier to provide an updated CMRT. Our risk mitigation efforts are specifically related to meeting our conflict minerals policy or contractual requirements, with the goal of bringing each surveyed supplier into compliance with such requirements.

As a result of these supplier due diligence activities, Intel determined that approximately 98% of the surveyed suppliers that had provided a CMRT as of March 1, 2019 (267 out of 271) are in compliance with our conflict minerals policy or contractual requirements. Of the four suppliers not meeting our requirements, two are no longer in our supply chain, and we are continuing to work with the other two suppliers to drive compliance.

Smelter and Refiner Due Diligence Results

As a result of the supply chain survey, our surveyed suppliers identified an aggregate of 257 operational smelter and refiner facilities which may process the necessary conflict minerals contained in the products these surveyed suppliers provided to Intel.

Intel conducted due diligence on these smelters and refiners. Our due diligence activities are dominated by a continual process to determine and monitor whether the identified smelters and refiners are operational and therefore may contribute necessary conflict minerals to our final products, and whether they are conformant to a responsible mineral sourcing validation program or have begun participating in such a program. We also sought reliable information on the source and chain of custody of the conflict minerals processed by such facilities, including from publicly available sources, with the goal to determine if any of these facilities processed conflict minerals that may have originated from the Covered Countries and may not be solely from recycled or scrap sources.

If a smelter or refiner in our supply chain was not yet conformant to a responsible mineral sourcing validation program or had not yet begun participating in such a program, Intel and other RMI member companies proactively attempted to contact such facilities to request country of origin information for the conflict minerals the facilities processed, as well as to encourage and assist their participation in a responsible mineral sourcing validation program and, in some cases, visited such facilities on-site. We monitored and tracked smelters and refiners which we identified as not being conformant to a responsible mineral sourcing validation program or not having begun participating in such a program.

During this reporting year, we identified 26 smelter and refiner facilities that were not conformant to a responsible mineral sourcing validation program. These facilities were the focus of our smelter and refiner due diligence activities for this reporting period and, as a result of our activities, we reasonably concluded that as of March 1, 2019:

 

   

12 of these 26 smelter and refiner facilities had later become conformant to a responsible mineral sourcing program.

 

   

4 of these 26 smelter and refiner facilities have begun participating in a responsible mineral sourcing validation program but are not yet conformant. Intel has performed due diligence on these 4 smelters and has reasonably concluded that they do not process conflict minerals originating from the Covered Countries.

 

   

The remaining 10 of these 26 smelter and refiner facilities do not process conflict minerals which originated from the Covered Countries (referred to below as “Intel Validated”).

As result of our due diligence activities summarized above, we determined the following as of March 1, 2019:

 

   

All 257 smelters and refiners identified by our surveyed suppliers were either conformant to a responsible mineral sourcing validation program, have begun participating in such a program, or are facilities that, based on our own due diligence activities, we have reasonably concluded do not process conflict minerals which originated from the Covered Countries.

 

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All 42 smelters and refiners which we know or have reason to believe may source conflict minerals from the Covered Countries which may not be solely from recycled or scrap sources are conformant to a responsible mineral sourcing validation program.

 

   

We have no reason to believe that any of the 257 smelter and refiner facilities directly or indirectly finance or benefit armed groups in the Covered Countries.

Below is a summary of the mineral country of origin information collected as of March 1, 2019 as a result of our due diligence activities:

 

Argentina    Finland    Mauritania    Slovakia
Armenia    Georgia    Mauritius    Solomon Islands
Australia    Ghana    Mexico    South Africa
Austria    Guatemala    Mongolia    Spain
Azerbaijan    Guinea    Morocco    Suriname
Benin    Guyana    Mozambique    Swaziland
Bolivia    Honduras    Myanmar    Sweden
Botswana    India    Namibia    Taiwan
Brazil    Indonesia    Nicaragua    Tanzania
Burkina Faso    Iran*    Niger    Thailand
Burundi    Ivory Coast    Nigeria    Togo
Canada    Japan    Papua New Guinea    Turkey
Chile    Kazakhstan    Peru    Uganda
China    Kenya    Philippines    United Kingdom
Colombia    Republic of Korea    Poland    United States of America
Congo, Democratic Republic of the    Kyrgyzstan    Portugal    Uruguay
Cyprus    Laos People’s Democratic Republic    Puerto Rico    Uzbekistan
Dominican Republic    Lebanon    Russian Federation    Venezuela
Ecuador    Liberia    Rwanda    Vietnam
Egypt    Madagascar    Saudi Arabia    Zambia
Eritrea    Malaysia    Senegal    Zimbabwe
Ethiopia    Mali    Sierra Leone   

 

*

Minerals from this country were substantially transformed before being incorporated into finished products. Such a substantial transformation of the minerals happened outside of the United States in a third country by a person other than a United States person.

Summary of Smelter and Refiner Status

The charts below summarize, by conflict mineral, the numbers of operational smelter and refiner facilities, identified by our surveyed suppliers, that as of March 1, 2019:

 

  (i)

are conformant to a responsible mineral sourcing validation program (referred to as “Conformant”),

 

  (ii)

Intel has reasonably concluded, based on our due diligence activities, do not process conflict minerals which originated from the Covered Countries (referred to as “Intel Validated”), or

 

  (iii)

have begun participating in a responsible mineral sourcing validation program (referred to as “Active”; as noted above, we have reasonably concluded, based on our due diligence, that none of these facilities process conflict minerals originating from the Covered Countries).

 

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Status of Identified Smelters and Refiners

 

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The table below lists the facilities which, to the extent known, processed the necessary conflict minerals in our products based on responses received from our surveyed suppliers as of March 1, 2019. Intel conducts no direct transactions and has no contractual relationship with these smelter and refiner facilities nor their sources of ore.

 

Metal

  

Smelter or Refinery Facility Name†

  

Country†

Gold    Advanced Chemical Company*    United States of America
Gold    Aida Chemical Industries Co., Ltd.*    Japan
Gold    Al Etihad Gold Refinery DMCC*    United Arab Emirates
Gold    Allgemeine Gold-und Silberscheideanstalt A.G.*    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    Asahi Refining Canada Ltd.*    Canada
Gold    Asahi Refining USA Inc.*    United States of America
Gold    Asaka Riken Co., Ltd.*    Japan
Gold    Atasay Kuyumculuk Sanayi Ve Ticaret A.S.    Turkey
Gold    AU Traders and Refiners*    South Africa
Gold    Aurubis AG*    Germany
Gold    Bangalore Refinery**    India

 

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Metal

  

Smelter or Refinery Facility Name†

  

Country†

Gold    Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*    Philippines
Gold    Boliden AB*    Sweden
Gold    C. Hafner GmbH + Co. KG*    Germany
Gold    Caridad    Mexico
Gold    CCR Refinery - Glencore Canada Corporation*    Canada
Gold    Cendres + Metaux S.A.*    Switzerland
Gold    Chimet S.p.A.*    Italy
Gold    Chugai Mining**    Japan
Gold    Daejin Indus Co., Ltd.*    Korea, Republic of
Gold    Daye Non-Ferrous Metals Mining Ltd.*    China
Gold    DODUCO Contacts and Refining GmbH*    Germany
Gold    Dowa*    Japan
Gold    DSC (Do Sung Corporation)*    Korea, Republic of
Gold    Eco-System Recycling Co., Ltd.*    Japan
Gold    Emirates Gold DMCC*    United Arab Emirates
Gold    GCC Gujrat Gold Centre Pvt. Ltd.    India
Gold    Geib Refining Corporation*    United States Of America
Gold    Gold Refinery of Zijin Mining Group Co., Ltd.*    China
Gold    Great Wall Precious Metals Co., Ltd. of CBPM*    China
Gold    HeeSung Metal Ltd.*    Korea, Republic of
Gold    Heimerle + Meule GmbH*    Germany
Gold    Heraeus Metals Hong Kong Ltd.*    China
Gold    Heraeus Precious Metals GmbH & Co. KG*    Germany
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    Italpreziosi*    Italy
Gold    Japan Mint*    Japan
Gold    Jiangxi Copper Co., Ltd.*    China
Gold    JSC Uralelectromed*    Russian Federation
Gold    JX Nippon Mining & Metals Co., Ltd.*    Japan
Gold    Kazakhmys Smelting LLC    Kazakhstan
Gold    Kazzinc*    Kazakhstan
Gold    Kennecott Utah Copper LLC*    United States of America
Gold    KGHM Polska Miedz Spolka Akcyjna    Poland
Gold    Kojima Chemicals Co., Ltd.*    Japan
Gold    Korea Zinc Co., Ltd.*    Korea, Republic of
Gold    Kyrgyzaltyn JSC*    Kyrgyzstan
Gold    L’Orfebre S.A.*    Andorra
Gold    LS-NIKKO Copper Inc.*    Korea, Republic of
Gold    Marsam Metals*    Brazil
Gold    Materion*    United States of America
Gold    Matsuda Sangyo Co., Ltd.*    Japan
Gold    Metalor Technologies (Hong Kong) Ltd.*    China
Gold    Metalor Technologies (Singapore) Pte., Ltd.*    Singapore

 

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Metal

  

Smelter or Refinery Facility Name†

  

Country†

Gold    Metalor Technologies (Suzhou) Ltd.*    China
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    MMTC-PAMP India Pvt., Ltd.*    India
Gold    Modeltech Sdn Bhd    Malaysia
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    Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH*    Austria
Gold    Ohura Precious Metal Industry Co., Ltd.*    Japan
Gold    OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)*    Russian Federation
Gold    OJSC Novosibirsk Refinery*    Russian Federation
Gold    PAMP S.A.*    Switzerland
Gold    Penglai Penggang Gold Industry Co., Ltd.    China
Gold    Planta Recuperadora de Metales SpA*    Chile
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    REMONDIS PMR B.V.*    Netherlands
Gold    Royal Canadian Mint*    Canada
Gold    SAAMP*    France
Gold    Sabin Metal Corp.    United States of America
Gold    Safimet S.p.A*    Italy
Gold    Samduck Precious Metals*    Korea, Republic of
Gold    SAXONIA Edelmetalle GmbH*    Germany
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    Singway Technology Co., Ltd.*    Taiwan
Gold    SOE Shyolkovsky Factory of Secondary Precious Metals*    Russian Federation
Gold    Solar Applied Materials Technology Corp.*    Taiwan
Gold    Sumitomo Metal Mining Co., Ltd.*    Japan
Gold    SungEel HiMetal Co., Ltd.*    Korea, Republic of
Gold    T.C.A S.p.A*    Italy
Gold    Tanaka Kikinzoku Kogyo K.K.*    Japan
Gold    The Refinery of Shandong Gold Mining Co., Ltd.*    China
Gold    Tokuriki Honten Co., Ltd.*    Japan
Gold    TOO Tau-Ken-Altyn    Kazakhstan
Gold    Torecom*    Korea, Republic of

 

10


Metal

  

Smelter or Refinery Facility Name†

  

Country†

Gold    Umicore Brasil Ltda.*    Brazil
Gold    Umicore Precious Metals Thailand*    Thailand
Gold    Umicore S.A. Business Unit Precious Metals Refining*    Belgium
Gold    United Precious Metal Refining, Inc.*    United States of America
Gold    Valcambi S.A.*    Switzerland
Gold    Western Australian Mint (T/a The Perth Mint)*    Australia
Gold    WIELAND Edelmetalle GmbH*    Germany
Gold    Yamakin Co., Ltd.*    Japan
Gold    Yokohama Metal Co., Ltd.*    Japan
Gold    Zhongyuan Gold Smelter of Zhongjin Gold Corporation*    China
Tantalum    Asaka Riken Co., Ltd.*    Japan
Tantalum    Changsha South Tantalum Niobium Co., Ltd.*    China
Tantalum    D Block Metals, LLC*    United States of America
Tantalum    Exotech Inc.*    United States of America
Tantalum    F&X Electro-Materials Ltd.*    China
Tantalum    FIR Metals & Resource Ltd.*    China
Tantalum    Global Advanced Metals Aizu*    Japan
Tantalum    Global Advanced Metals Boyertown*    United States of America
Tantalum    Guangdong Rising Rare Metals-EO Materials Ltd.*    China
Tantalum    Guangdong Zhiyuan New Material Co., Ltd.*    China
Tantalum    H.C. Starck Co., Ltd.*    Thailand
Tantalum    H.C. Starck Hermsdorf GmbH*    Germany
Tantalum    H.C. Starck Inc.*    United States of America
Tantalum    H.C. Starck Ltd.*    Japan
Tantalum    H.C. Starck Smelting GmbH & Co. KG*    Germany
Tantalum    H.C. Starck Tantalum and Niobium GmbH*    Germany
Tantalum    Hengyang King Xing Lifeng New Materials Co., Ltd.*    China
Tantalum    Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*    China
Tantalum    Jiangxi Tuohong New Raw Material*    China
Tantalum    Jiujiang Janny New Material Co., Ltd.*    China
Tantalum    JiuJiang JinXin Nonferrous Metals Co., Ltd.*    China
Tantalum    Jiujiang Tanbre Co., Ltd.*    China
Tantalum    Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*    China
Tantalum    KEMET Blue Metals*    Mexico
Tantalum    KEMET Blue Powder*    United States of America
Tantalum    LSM Brasil S.A.*    Brazil
Tantalum    Metallurgical Products India Pvt., Ltd.*    India
Tantalum    Mineracao Taboca S.A.*    Brazil
Tantalum    Mitsui Mining and Smelting Co., Ltd.*    Japan
Tantalum    Ningxia Orient Tantalum Industry Co., Ltd.*    China
Tantalum    NPM Silmet AS*    Estonia
Tantalum    Power Resources Ltd.*    North Macedonia
Tantalum    QuantumClean*    United States of America
Tantalum    Resind Industria e Comercio Ltda.*    Brazil

 

11


Metal

  

Smelter or Refinery Facility Name†

  

Country†

Tantalum    RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.*    China
Tantalum    Solikamsk Magnesium Works OAO*    Russian Federation
Tantalum    Taki Chemical Co., Ltd.*    Japan
Tantalum    Telex Metals*    United States of America
Tantalum    Ulba Metallurgical Plant JSC*    Kazakhstan
Tantalum    XinXing HaoRong Electronic Material Co., Ltd.*    China
Tin    Alpha*    United States of America
Tin    An Vinh Joint Stock Mineral Processing Company    Vietnam
Tin    Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.*    China
Tin    Chifeng Dajingzi Tin Industry Co., Ltd.*    China
Tin    China Tin Group Co., Ltd.*    China
Tin    CV Ayi Jaya*    Indonesia
Tin    CV Dua Sekawan*    Indonesia
Tin    CV Gita Pesona*    Indonesia
Tin    CV United Smelting*    Indonesia
Tin    CV Venus Inti Perkasa*    Indonesia
Tin    Dowa*    Japan
Tin    EM Vinto*    Bolivia
Tin    Estanho de Rondonia S.A.    Brazil
Tin    Fenix Metals*    Poland
Tin    Gejiu Fengming Metallurgy Chemical Plant*    China
Tin    Gejiu Kai Meng Industry and Trade LLC*    China
Tin    Gejiu Non-Ferrous Metal Processing Co., Ltd.*    China
Tin    Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.*    China
Tin    Gejiu Zili Mining And Metallurgy Co., Ltd.**    China
Tin    Guangdong Hanhe Non-Ferrous Metal Co., Ltd.*    China
Tin    Guanyang Guida Nonferrous Metal Smelting Plant*    China
Tin    HuiChang Hill Tin Industry Co., Ltd.*    China
Tin    Huichang Jinshunda Tin Co., Ltd.*    China
Tin    Magnu’s Minerais Metais e Ligas Ltda.*    Brazil
Tin    Malaysia Smelting Corporation (MSC)*    Malaysia
Tin    Melt Metais e Ligas S.A.*    Brazil
Tin    Metallic Resources, Inc.*    United States of America
Tin    Metallo Belgium N.V.*    Belgium
Tin    Metallo Spain S.L.U.*    Spain
Tin    Mineracao Taboca S.A.*    Brazil
Tin    Minsur*    Peru
Tin    Mitsubishi Materials Corporation*    Japan
Tin    Modeltech Sdn Bhd*    Malaysia
Tin    O.M. Manufacturing (Thailand) Co., Ltd.*    Thailand
Tin    O.M. Manufacturing Philippines, Inc.*    Philippines
Tin    Operaciones Metalurgicas S.A.*    Bolivia
Tin    PT Aries Kencana Sejahtera*    Indonesia
Tin    PT Artha Cipta Langgeng*    Indonesia

 

12


Metal

  

Smelter or Refinery Facility Name†

  

Country†

Tin    PT ATD Makmur Mandiri Jaya*    Indonesia
Tin    PT Babel Inti Perkasa*    Indonesia
Tin    PT Bangka Prima Tin*    Indonesia
Tin    PT Bangka Serumpun*    Indonesia
Tin    PT Bangka Tin Industry*    Indonesia
Tin    PT Belitung Industri Sejahtera*    Indonesia
Tin    PT Bukit Timah*    Indonesia
Tin    PT DS Jaya Abadi*    Indonesia
Tin    PT Inti Stania Prima*    Indonesia
Tin    PT Karimun Mining*    Indonesia
Tin    PT Kijang Jaya Mandiri*    Indonesia
Tin    PT Menara Cipta Mulia*    Indonesia
Tin    PT Mitra Stania Prima*    Indonesia
Tin    PT Panca Mega Persada*    Indonesia
Tin    PT Premium Tin Indonesia*    Indonesia
Tin    PT Prima Timah Utama*    Indonesia
Tin    PT Rajehan Ariq*    Indonesia
Tin    PT Refined Bangka Tin*    Indonesia
Tin    PT Sariwiguna Binasentosa*    Indonesia
Tin    PT Stanindo Inti Perkasa*    Indonesia
Tin    PT Sukses Inti Makmur*    Indonesia
Tin    PT Sumber Jaya Indah*    Indonesia
Tin    PT Timah Tbk Kundur*    Indonesia
Tin    PT Timah Tbk Mentok*    Indonesia
Tin    PT Tinindo Inter Nusa*    Indonesia
Tin    PT Tommy Utama*    Indonesia
Tin    Resind Industria e Comercio Ltda.*    Brazil
Tin    Rui Da Hung*    Taiwan
Tin    Soft Metais Ltda.*    Brazil
Tin    Thaisarco*    Thailand
Tin    White Solder Metalurgia e Mineracao Ltda.*    Brazil
Tin    Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*    China
Tin    Yunnan Tin Company Limited*    China
Tungsten    A.L.M.T. Corp.*    Japan
Tungsten    Chenzhou Diamond Tungsten Products Co., Ltd.*    China
Tungsten    Chongyi Zhangyuan Tungsten Co., Ltd.*    China
Tungsten    Fujian Jinxin Tungsten Co., Ltd.*    China
Tungsten    Ganzhou Haichuang Tungsten Co., Ltd.*    China
Tungsten    Ganzhou Huaxing Tungsten Products Co., Ltd.*    China
Tungsten    Ganzhou Seadragon W & Mo Co., Ltd.*    China
Tungsten    Global Tungsten & Powders Corp.*    United States of America
Tungsten    Guangdong Xianglu Tungsten Co., Ltd.*    China
Tungsten    H.C. Starck Smelting GmbH & Co. KG*    Germany
Tungsten    H.C. Starck Tungsten GmbH*    Germany
Tungsten    Hunan Chenzhou Mining Co., Ltd.*    China

 

13


Metal

  

Smelter or Refinery Facility Name†

  

Country†

Tungsten    Hunan Chunchang Nonferrous Metals Co., Ltd.*    China
Tungsten    Hydrometallurg, JSC*    Russian Federation
Tungsten    Japan New Metals Co., Ltd.*    Japan
Tungsten    Jiangwu H.C. Starck Tungsten Products Co., Ltd.*    China
Tungsten    Jiangxi Gan Bei Tungsten Co., Ltd.*    China
Tungsten    Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.*    China
Tungsten    Jiangxi Xinsheng Tungsten Industry Co., Ltd.*    China
Tungsten    Jiangxi Yaosheng Tungsten Co., Ltd.*    China
Tungsten    Kennametal Huntsville*    United States of America
Tungsten    Malipo Haiyu Tungsten Co., Ltd.*    China
Tungsten    Masan Tungsten Chemical LLC (MTC)*    Vietnam
Tungsten    Niagara Refining LLC*    United States of America
Tungsten    Philippine Chuangxin Industrial Co., Inc.*    Philippines
Tungsten    South-East Nonferrous Metal Company Limited of Hengyang City*    China
Tungsten    Tejing (Vietnam) Tungsten Co., Ltd.*    Vietnam
Tungsten    Wolfram Bergbau und Hutten AG*    Austria
Tungsten    Xiamen Tungsten (H.C.) Co., Ltd.*    China
Tungsten    Xiamen Tungsten Co., Ltd.*    China
Tungsten    Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*    China
Tungsten    Xinhai Rendan Shaoguan Tungsten Co., Ltd.*    China

 

Smelter and refiner facility names and locations as reported by the RMI as of March 1, 2019.

*

Denotes smelters and refiners which are conformant to a responsible mineral sourcing validation program as of March 1, 2019.

**

Denotes smelters and refiners which are participating in a responsible mineral sourcing validation program as of March 1, 2019.

Product Conclusions

For this reporting period, we identified the following products which we manufactured or contracted with others to manufacture that may contain necessary conflict minerals. On the basis of our due diligence measures as described in this Report as of March 1, 2019, we have made the following conclusions in good faith for this reporting period.    

Our Microprocessors, FPGA Products and Chipsets Solely Manufactured by Intel consisting of Celeron®, Pentium®, Intel® Core, Intel® Xeon®, Intel® Quark and Intel Atom® processors; Intel® Stratix®, Intel® Arria®, and Intel® Cyclone® FPGAs; Intel® MAX® CPLD; Intel® Enpirion® Power Solutions and Mobileye EyeQ* family of system-on-chip (SoC) devices: All surveyed suppliers which we identified as contributing necessary conflict minerals to these products have identified the smelters and refiners in the supply chain that are the sources of the necessary conflict minerals, and all of these smelters and refiners are conformant to a responsible mineral sourcing validation program. We have therefore reasonably concluded that these necessary conflict minerals did not directly or indirectly finance or benefit armed groups in the Covered Countries based on our due diligence measures performed.

Our Other Products consisting of other server products and networking, boards and kits, memory storage products, and other Mobileye products: With the exception of six Mobileye-unique suppliers with whom our due diligence is ongoing as described above, all of the surveyed suppliers which we identified as contributing necessary conflict minerals to these products provided a CMRT in response to our supply chain survey request. Of these surveyed suppliers, 96% were in compliance with our conflict minerals policy or contractual requirements. All of the smelters and refiners identified by these surveyed suppliers were either conformant to a responsible mineral sourcing validation program, have begun participating in such a program, or are facilities that, based on our own due diligence activities, we have reasonably concluded do not process conflict minerals which originated from the Covered Countries. We have no reason to believe the necessary conflict minerals in our Other Products directly or indirectly finance or benefit armed groups in the Covered Countries based on our due diligence measures performed.

 

14


Our efforts to determine the mine or location of origin of the necessary conflict minerals in all of our products with the greatest possible specificity consisted of the due diligence measures described in this Report. In particular, we relied on the information made available by responsible mineral sourcing validation programs for the smelters and refiners in our supply chain because such programs review and audit whether sufficient evidence exists regarding the mine and/or location of origin of the conflict minerals that the audited smelter or refiner facilities have processed. We also sought source and chain of custody information directly from smelters and refiners and from publicly available sources and, if we determined such information to be reliable, we used the information to make reasonable conclusions on the source and chain of custody of the conflict minerals processed by facilities which were not conformant to or participating in a responsible mineral sourcing validation program.

Future Due Diligence Measures

During the reporting period for the calendar year ending December 31, 2019, we are continuing to engage in the activities described above in “Design of Conflict Minerals Program.” We intend to continue to contact smelters and refiners identified in our supply chain survey process that are not yet conformant to a responsible mineral sourcing validation program and request their participation in such a program, supporting our efforts to build ethical and socially responsible supply chains for our company.

Additionally, Intel’s responsible minerals program is evolving to address a broader range of minerals originating from Conflict-Affected and High-Risk Areas (CAHRAs), as defined by the OECD Guidance. We are assessing the risks of other minerals in our products and updating our due diligence practices to address CAHRAs when conducting country of origin analysis in our supply chain. We also have updated our minerals sourcing policy to reflect this expansion in scope. One example of this expansion effort is our integration of cobalt into our responsible minerals program by surveying our direct suppliers to identify cobalt refiners in our microprocessor supply chain. We then conduct due diligence on the identified refineries and actively focus our outreach efforts to onboard them into the RMAP. Participation in such a program verifies these facilities have management systems in place to ensure the cobalt they process is responsibly sourced. Additionally, Intel is participating in developing industry-wide standards to better align, and thus strengthen, the collective approach to responsible cobalt sourcing. Intel is continuing to partner with the RMI and other key industry associations to expand and improve all aspects of responsible mineral sourcing.

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, Xeon, Celeron, Pentium, Quark, Stratix, Arria, Cyclone, MAX, and Enpirion are trademarks of Intel Corporation or its subsidiaries in the U.S. and/or other countries.

 

*

Other names and brands may be claimed as the property of others.

 

15


Exhibit A

Report of Independent Accountants

To the stockholders and The Board of Directors 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, 2018, 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, Third Edition 2016, (“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, 2018, 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, 2018, 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, 2018, is consistent, in all material respects, with the due diligence process that the Company undertook.

/s/ Ernst & Young LLP

San Jose, California

May 16, 2019