EX-1.01 2 exhibit101conflictminerals.htm EXHIBIT 1.01 Exhibit 1.01 Conflict Minerals


EXHIBIT 1.01

Micron Technology, Inc.
Conflict Minerals Report
Calendar Year 2014


We prepared this Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”).1 This CMR covers the 2014 calendar year reporting period and is filed as an exhibit to our Form SD.2 This CMR includes a description of the measures we have taken to exercise due diligence on the source and chain of custody of conflict minerals (specifically gold, and the derivatives tin, tantalum, and tungsten (collectively “3TG metals”)) necessary to manufacture our products in 2014.

In 2014 we increased our conflict mineral program resources and improved our internal conflict minerals data management system. These measures helped us to further improve our conflict mineral outreach and to better track and communicate our progress toward a conflict-free supply chain for our products.3 Of the 257 smelters reported in our 2014 supply chain, 122 were validated as conflict-free while another 55 were actively participating in a conflict-free auditing program.4 This represents a 65% increase in the number of conflict-free validated smelters reported in 2014 over 2013.

In 2015, we are continuing to take active measures to encourage 3TG metals smelters in our product supply chain to become conflict-free validated. These measures include direct outreach to suppliers and smelters.5 Smelters that refuse to participate in conflict-free auditing programs following reasonable engagement efforts will be targeted for removal from our supply chain.

As a Conflict-Free Sourcing Initiative (“CFSI”) founding member (member ID MICR), we continue to support the CFSI and its conflict-free third-party auditing program, the Conflict-Free Sourcing Program (“CFSP”), as part of our commitment to drive ethical sourcing of 3TG metals throughout the supply chain.




__________________________

1 In this CMR, unless otherwise indicated or the context otherwise requires “we,” “us,” “our,” “Micron” and the “Company” refers to Micron Technology, Inc. and its subsidiaries.
2 Unless otherwise noted, any designation of years refers to calendar years.
3 The term “conflict-free” herein means the relevant smelters are verified as compliant with the Conflict-Free Sourcing Initiative’s (CFSI) Conflict-Free Smelter Program (“CFSP”) or an equivalent third-party auditing program.
4 The term “smelters” herein refers to both smelters and refiners of 3TG metals.
5 The term suppliers, herein refers to suppliers and contract manufacturers that are likely to provide us with products containing 3TG metals that are necessary to the function or manufacture of our products.

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1.
Our Conflict Mineral Due Diligence Program Design

We have designed our conflict mineral due diligence program in conformance with the principles of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (Second Edition) and the supplements thereto (“OECD Guidance”) as applied to downstream companies.

2.
Our Conflict Mineral Due Diligence for 2014 Products

2.1
Our Management System
In 2014 we maintained a Conflict Minerals Policy and communicated this policy to our suppliers and the public via the conflict minerals portion of our company website. Our cross-disciplinary Conflict Mineral Team met to review our conflict mineral program implementation. Executives from our Procurement, Supply Chain, Quality, Finance, Sales and Legal departments also reviewed our program progress. Our Supplier Quality Requirements Document set forth our supplier expectations with respect to 3TG metals. We continued to incorporate these requirements into the terms and conditions of our supplier agreements. We also maintained internal and third-party access to our ethics and compliance hotline, which can be used to report issues relating to conflict minerals. Our program included a five-year record retention policy for our conflict minerals documents.
2.2
Our Risk Assessment
We sent our 2014 suppliers letters requesting that they complete the CFSI CMRT. We reviewed the CMRT responses and determined whether the disclosed smelters were recognized by CFSI as processors of 3TG metals, and if so, whether they had been validated as compliant or listed as active with the CFSP.
2.3
Our Risk Management
We are members of several CFSI working committees, including the CFSI Smelter Engagement Team, which was tasked with identifying and influencing key smelters in the supply chains of CFSI members to join the CFSP. Additionally, we worked with a smelter who we identified as key to our supply chain to encourage their participation in the CFSP. They subsequently joined the CFSP.
2.4
Smelter/Refiner Auditing
As we do not source 3TG Metals directly from smelters, we rely on third-party auditing programs, like the CFSP, to coordinate audits of smelters in our supply chain.
2.5
Reporting
We report our annual due diligence results to the SEC and make the report available on our company website.

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3.
Our Product Descriptions

Overview

We offer a broad portfolio of DRAM, NAND, and NOR semiconductor memory products. We conducted due diligence, as described in this CMR, to try to determine the source and chain of custody of the necessary 3TG metals contained in these products. We were unable to determine the country of origin of some of the 3TG metals in our 2014 products and/or whether our 2014 products contain 3TG metals that may have directly or indirectly financed or benefited armed groups in the Democratic Republic of the Congo or an adjoining country.

Description of Products

In 2014, we manufactured or contracted to manufacture the following products containing necessary 3TG metals:

Dynamic Random Access Memory ("DRAM")
DRAM products are high-density, low-cost-per-bit, random access memory devices that provide high-speed data storage and retrieval. DRAM products are used in computers, servers, tablets, mobile phones, communication equipment, computer peripherals, industrial, automotive and other electronic devices. We offer DRAM products with a variety of performance, pricing and other characteristics including high-volume DDR4, DDR3 and DDR2 products as well as specialty DRAM memory products including Mobile Low Power DRAM, DDR, SDRAM, Reduced Latency DRAM and Pseudo-static DRAM.

NAND Flash Memory
NAND Flash products are electrically re-writeable, non-volatile semiconductor memory devices that retain content when power is turned off. NAND Flash is ideal for mass-storage devices due to its fast erase and write times, high density and low cost per bit relative to other solid-state memories. Embedded NAND Flash-based storage devices are utilized in mobile phones, solid-state drives, tablets, computers, industrial and automotive applications, MP3/4 players and other personal and consumer applications. Removable storage devices, such as USB and Flash memory cards, are used with applications such as PCs, digital still cameras, MP3/4 players and mobile phones.

NOR Flash Memory
NOR Flash products are electrically re-writeable, non-volatile semiconductor memory devices that retain content when power is turned off, offer fast read times due to random access capability and have execute-in-place capability that enables processors to read NOR Flash without first accessing RAM. These capabilities make NOR ideal for storing program code in wireless and embedded applications.

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Reported Smelters Used to Process 3TG Metals

We identified 257 smelters that are recognized by CFSI to be processors of 3TG metals and that were reported by our suppliers as potentially in our supply chain. Of these, 122 were listed by CFSI as conflict-free under the CFSP. Another 55 were committed to pursuing audits as reflected by their CFSP participation or membership with the Tungsten Industry-Conflict Minerals Council (“TI-CMC”). Many of our suppliers reported smelter information at the company level rather than limiting their response to smelters affiliated with products sold to Micron. As a result, some smelters reported may not be affiliated with our products. We were unable to determine the origin of 3TG metals processed by the 135 smelters that had not undergone a third-party audit as of December 31, 2014. We were further unable to determine whether any of the 3TG metals affiliated with these smelters may have directly or indirectly financed or benefited armed groups in the Covered Countries. These 135 smelters are listed in Appendix A.
Aggregated Countries of Origin of 3TG Metals

Our due diligence efforts did not result in sufficient information to conclusively determine the countries of origin of 3TG metals in our products. Appendix B sets forth a list of countries of origin of 3TG metals that may be in our products based on information provided to us by CFSI, which was available to us on an aggregated basis only for CFSP conflict-free smelters.

Efforts to Determine the Mine or Location of Origin

CFSI has an established audit protocol to assess whether smelters of 3TG metals employed policies, practices and procedures to source conflict-free minerals. CFSI, through the CFSP, collects and provides access for its members to certain information regarding the origin of minerals processed at CFSP conflict-free smelters.
We required our suppliers to complete the CMRT, which requested information regarding the mine or location of origin of necessary conflict minerals processed by the smelters our suppliers identified as potentially associated with our 3TG metals supply chain. We reviewed the supplier responses as well as information available through the CFSI on the mine or location of origin of 3TG metals processed by these smelters collectively. Because we were unable to confirm the supplier data, our list of the countries of origin in Appendix B reflects the aggregated list of countries provided by CFSI for CFSP conflict-free smelters.

4.     2015 Due Diligence Measures

For 2015, we have dedicated increased budget for smelter engagement to encourage smelters in our supply chain to join the CFSP audit program. As of the date of this filing, we have engaged three smelters in face-to-face meetings to help facilitate their conflict-free validation. Additionally, we have bolstered our supplier engagement, directing suppliers that they must encourage smelters in their supply chain that are not yet part of a smelter validation program to participate in a program such as the CFSP. Finally, we have directed suppliers reporting smelters that have resisted repeated CFSI engagement efforts to move away from such smelters by a defined date.

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*****
This Conflict Minerals Report contains forward looking statements related to our conflict minerals diligence programs for 2015. We wish to caution you that such statements are predictions and that actual events or results may differ materially.  We refer you to the documents the Company files on a consolidated basis from time to time with Securities and Exchange Commission, specifically the Company’s most recent Form 10-K and Form 10-Q.  These documents contain and identify important factors that could cause the actual results for the Company on a consolidated basis to differ materially from those contained in our projections or forward-looking statements.  These certain factors can be found at http://investors.micron.com/riskFactors.cfm.  Although we believe that the expectations reflected in the forward-looking statements are reasonable, we cannot guarantee future results, levels of activity, performance or achievements. We are under no duty to update any of the forward-looking statements after the date of the presentation to conform these statements to actual results.










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Appendix A
 
Reported 3TG Smelters List

This table provides the names of the smelters reported by our suppliers that are also recognized by CFSI to be processors of 3TG metals, but that have not been listed by CFSI as compliant with the CFSP or an equivalent smelter auditing program as of December 31, 2014. The smelter names appear as they are listed on the CFSI Smelter or Refiner Information Exchange. We cannot confirm that any or all smelters in this table processed the necessary 3TG metals contained in our products, as many of our in scope suppliers identified all smelters in their total supply chain rather than just those smelters affiliated with products sold to us.

Smelters noted with an asterisk (*) in this table were listed by CFSI as active with the CFSP or an equivalent smelter auditing program as of December 22, 2014. Given the ongoing work within the CFSP to perform audits of participating smelters, and the efforts of many smelters to successfully complete the auditing process, it is likely that a number of these smelters have since become validated as conflict free. Up to date information on the validation status of smelters participating in the CFSP is available at http://www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists/.
  
Metal
Smelter Name
Gold
Advanced Chemical Company
Gold
Aida Chemical Industries Co. Ltd. *
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Gold
Asaka Riken Co Ltd *
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold
Bauer Walser AG
Gold
C. Hafner GmbH + Co. KG *
Gold
Caridad
Gold
Cendres + Métaux SA *
Gold
Chugai Mining
Gold
Colt Refining
Gold
Daejin Indus Co. Ltd
Gold
Daye Non-Ferrous Metals Mining Ltd.
Gold
Do Sung Corporation
Gold
Doduco
Gold
FSE Novosibirsk Refinery
Gold
Gansu Seemine Material Hi-Tech Co Ltd
Gold
Guangdong Jinding Gold Limited
Gold
Guangzhou Jin Ding
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold
Hunan Chenzhou Mining Group Co., Ltd.
Gold
Hwasung CJ Co. Ltd




Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
Gold
Jiangxi Copper Company Limited
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold
JSC Uralelectromed
Gold
Korea Metal Co. Ltd
Gold
Kyrgyzaltyn JSC
Gold
L' azurde Company For Jewelry
Gold
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
Gold
Luoyang Zijin Yinhui Metal Smelt Co Ltd
Gold
Moscow Special Alloys Processing Plant
Gold
Navoi Mining and Metallurgical Combinat
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
Gold
OJSC Kolyma Refinery
Gold
Penglai Penggang Gold Industry Co Ltd
Gold
Prioksky Plant of Non-Ferrous Metals
Gold
PT Aneka Tambang (Persero) Tbk
Gold
Sabin Metal Corp. *
Gold
Samduck Precious Metals
Gold
Samwon Metals Corp.
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd *
Gold
Sichuan Tianze Precious Metals Co., Ltd *
Gold
So Accurate Group, Inc.
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Gold
The Great Wall Gold and Silver Refinery of China
Gold
The Refinery of Shandong Gold Mining Co. Ltd
Gold
Tongling nonferrous Metals Group Co.,Ltd
Gold
Torecom
Gold
Yamamato Precious Metal Co., Ltd *
Gold
Yokohama Metal Co Ltd *
Gold
Yunnan Copper Industry Co Ltd
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Gold
Zijin Mining Group Co. Ltd
Tantalum
King-Tan Tantalum Industry Ltd
Tantalum
Shanghai Jiangxi Metals Co. Ltd
Tin
China Tin Group Co., Ltd *
Tin
CNMC (Guangxi) PGMA Co. Ltd
Tin
Cooper Santa *
Tin
CV Gita Pesona
Tin
CV Makmur Jaya
Tin
CV Serumpun Sebalai *
Tin
EM Vinto *
Tin
Estanho de Rondônia S.A.
Tin
Fenix Metals *




Tin
Gejiu Kai Meng Industry and Trade LLC
Tin
Gejiu Zi-Li
Tin
Huichang Jinshunda Tin Co. Ltd
Tin
Jiangxi Ketai Advanced Material Co., Ltd. *
Tin
Linwu Xianggui Smelter Co
Tin
Melt Metais e Ligas S/A *
Tin
Metallo Chimique *
Tin
Nankang Nanshan Tin Manufactory Co., Ltd
Tin
Novosibirsk Integrated Tin Works
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Tin
O.M. Manufacturing Philippines, Inc.
Tin
PT Alam Lestari Kencana
Tin
PT Aries Kencana Sejahtera *
Tin
PT Artha Cipta Langgeng *
Tin
PT Babel Surya Alam Lestari
Tin
PT Bangka Kudai Tin *
Tin
PT Bangka Putra Karya *
Tin
PT Bangka Timah Utama Sejahtera *
Tin
PT Belitung Industri Sejahtera *
Tin
PT BilliTin Makmur Lestari
Tin
PT Eunindo Usaha Mandiri *
Tin
PT Fang Di MulTindo
Tin
PT HP Metals Indonesia
Tin
PT Inti Stania Prima
Tin
PT Justindo
Tin
PT Karimun Mining *
Tin
PT Koba Tin
Tin
PT Mitra Stania Prima *
Tin
PT Panca Mega Persada *
Tin
PT Pelat Timah Nusantara Tbk *
Tin
PT Prima Timah Utama
Tin
PT Sariwiguna Binasentosa *
Tin
PT Seirama Tin investment
Tin
PT Sumber Jaya Indah
Tin
PT Supra Sukses Trinusa
Tin
PT Tinindo Inter Nusa *
Tin
PT Tommy Utama
Tin
PT Wahana Perkit Jaya
Tin
PT Yinchendo Mining Industry
Tin
Rui Da Hung *
Tin
Soft Metais, Ltda. *
Tin
The Gejiu cloud new colored electrolytic
Tin
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. *




Tungsten
A.L.M.T. Corp.
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd. *
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten
Dayu Weiliang Tungsten Co., Ltd. *
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd. *
Tungsten
Guangdong Xianglu Tungsten Co., Ltd. *
Tungsten
H.C. Starck GmbH *
Tungsten
H.C. Starck Smelting GmbH & Co.KG *
Tungsten
Hunan Chenzhou Mining Group Co., Ltd. *
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd. *
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd. *
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten
Jiangxi Richsea New Materials Co., Ltd. *
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. *
Tungsten
Jiangxi Xianggan No-Ferrous Metals Co, *
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd. *
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd. *
Tungsten
Kennametal Fallon *
Tungsten
Kennametal Huntsville *
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC *
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd. *
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd *
Tungsten
Wolfram Bergbau und Hütten AG *
Tungsten
Wolfram Company CJSC *
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd. *
 
 
 
* Smelter or refiner was on the CFSP Active List or a TI-CMC Member as of 12/22/14







Appendix B

Aggregated Counties of Origin List

This table provides information available from CFSI on countries of origin for smelters that have been validated as compliant with the CFSP. Due to confidential business information concerns, CFSI provides this country of origin information on an aggregated basis. This table reflects information available from CFSI as of December 31, 2014.


Angola
Guyana
Republic of Congo
Argentina
Hong Kong
Republic of Korea
Australia
Hungary
Russian Federation
Austria
India
Rwanda
Belgium
Indonesia
Sierra Leone
Bolivia
Ireland
Singapore
Brazil
Israel
Slovakia
Burundi
Japan
South Africa
Canada
Kazakhstan
South Sudan
Central African Republic
Kenya
Spain
Chile
Lao People's Democratic Republic
Suriname
China
Luxembourg
Switzerland
Colombia
Madagascar
Taiwan
Cote D'Ivoire
Malaysia
Thailand
Czech Republic
Mongolia
The Democratic Republic of Congo
Djibouti
Mozambique
Uganda
Egypt
Myanmar
United Kingdom of Great Britain and Northern Ireland
England
Netherlands
United Republic of Tanzania
Estonia
Nigeria
United States of America
Ethiopia
Peru
Vietnam
France
Plurinational State of Bolivia
Zambia
Germany
Portugal
Zimbabwe