EX-1.02 2 a2013plexusconflictmineral.htm EXHIBIT 1.02 2013PlexusConflictMineralsReport

EXHIBIT 1.02

CONFLICT MINERALS REPORT OF
PLEXUS CORP.
IN ACCORDANCE WITH RULE 13p-1
UNDER THE SECURITIES EXCHANGE ACT OF 1934
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2013



I.Introduction

This is the Conflict Minerals Report (the “Report”) of Plexus Corp. (“Plexus,” the “Company,” “we,” “us,” or “our”) prepared for calendar year 2013 (excluding conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”). The term “conflict mineral” is defined as (A) columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and Form SD and the reader is referred to those sources, and also to Securities and Exchange Commission (“SEC”) Release No. 34-67716 (August 22, 2012) under the Act for such definitions.

In accordance with Rule 13p-1, we undertook efforts to determine whether the conflict minerals necessary to the functionality or production of products that we manufacture or contract to manufacture were sourced from the Covered Countries, or are from recycled or scrap sources. The Company designed its efforts in conformity with the internationally recognized due diligence framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Due Diligence Guidance”) and related supplements for each of the conflict minerals (the “Supplements”).

The statements below are based on the due diligence activities performed to date and are based on the information available at the time of this filing.  Factors that could affect the accuracy of these statements include, but are not limited to, inaccurate or incomplete supplier data or a lack of available smelter data, errors, omissions or fraud by suppliers or smelters, lack of continuously updated information from suppliers, evolving confirmation of smelters, incomplete information from

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industry or other third-party sources, additional guidance regarding the rules, and other issues. The content of any website referenced in this Report is included for general information only and is not incorporated by reference in this Report.

II.About Plexus

Plexus is an electronics manufacturing services (“EMS”) company that provides product conceptualization, design, commercialization, manufacturing, fulfillment and aftermarket services solutions for original equipment manufacturers (“OEMs”) throughout the world. Plexus does not sell “Plexus-branded” products. We partner with our customers to bring their products to market via our Product Realization Value Stream.

III.Design of Due Diligence Measures

Plexus designed its overall conflict minerals program based on the five-step framework of the OECD Due Diligence Guidance and its Supplements.

Plexus’ implementation of the framework for calendar year 2013 consisted of the following steps, which are discussed in further detail in Section IV.

Step 1:     Establish strong company management systems
Step 2:     Identify and assess risks in the supply chain
Step 3:     Design and implement a strategy to respond to identified risks
Step 4:     Carry out independent third-party audit of smelters'/refiners' due diligence practices
Step 5:     Report annually on supply chain due diligence

We relied upon multi-stakeholder initiatives that provide verification processes for conflict-free minerals from smelters or refiners who may provide those minerals to companies in our supply chain. Plexus, as a purchaser of component parts, is many steps removed from the mining of conflict minerals; we do not purchase raw ore or unrefined conflict minerals and do not have direct contractual relationships with smelters or refiners. To the best of our knowledge, Plexus conducts no purchasing activities directly in the Covered Countries.

IV.
Due Diligence Measures Performed by Plexus

The following describes the measures taken to reasonably determine the country of origin and to exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance for calendar year 2013.


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Step 1: Establish strong company management systems

Conflict Minerals Team – Plexus formed an internal cross-functional team to design and implement the due diligence measures. The team was comprised of members from the Company’s supply chain, legal, information technology and environmental health and safety functions.

Conflict Minerals Policy – Plexus adopted and published a policy affirming the Company’s commitment to comply with the conflict minerals rule and establishing the expectations of our suppliers with respect to the rule. The policy can be found at www.plexus.com/about-us/social-responsibility/our-suppliers. We periodically review the policy and will make updates to the policy as necessary and appropriate.

Company Level Grievance Mechanism – As an additional means of communication regarding conflict minerals, Plexus employees and other stakeholders can communicate directly and confidentially with our Corporate Compliance Officer and executive management by using our Ethics Hotline, as outlined in the Plexus Code of Conduct and Business Ethics located at www.plexus.com (follow the links to “Investor Relations” and then to “Corporate Governance”).

Document Retention – Plexus is retaining documentation regarding its conflict minerals due diligence measures for calendar year 2013 in accordance with its record retention guidelines.

Step 2: Identify and assess risks in the supply chain

We performed the following steps as part of our risk assessment process:

Identify Suppliers In Scope – Our internal cross-functional conflict minerals team identified all suppliers that Plexus utilized in 2013 that may have sold Plexus goods containing conflict minerals.

Conduct Reasonable Country of Origin Inquiry (“RCOI”) – Plexus utilized the industry-developed Electronic Industry Citizen Coalition (“EICC”) – Global e-Sustainability Initiative (“GeSI”) Conflict Minerals Reporting Template (“CMRT”) to query the suppliers identified in our assessment of the supply chain. After collecting CMRTs from suppliers, we evaluated the responses for completeness and content, and we engaged in follow-up communications with suppliers as appropriate. Some suppliers provided us with “company-level” CMRT responses that included information on all products sold by the supplier to its customers even though Plexus may have purchased only a limited subset of components or products from the supplier.

Step 3: Design and implement a strategy to respond to identified risks


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We performed the following steps as part of our risk management plan:

Validate Smelters – As part of the risk mitigation process, we compared the list of smelters/processors collected from suppliers and compared it to the conflict-free smelter lists published by the Conflict-Free Sourcing Initiative (“CFSI”).

Supplier Communications – For suppliers that were unable or unwilling to provide us with a completed CMRT, we communicated in writing our expectation that suppliers provide us with the CMRT in future years. We sent a similar communication to suppliers who provided us with a CMRT but indicated that they were uncertain about or did not know the origin of their conflict minerals. We also followed up with suppliers who provided incomplete or unclear responses.

For suppliers who stated they were sourcing in part from the Covered Countries or had identified smelters that have been known to have sourced from the Covered Countries, we requested additional information regarding the smelters used that were not on the CFSI list.

If a supplier fails to comply with our Conflict Minerals Policy, we may reconsider our willingness to continue to partner with that supplier.

Step 4: Carry out independent third-party audit of smelter/refiner due diligence practices

Plexus is a downstream consumer of conflict minerals and is many steps removed from the smelters and refiners who provide minerals and ores. We do not purchase any conflict minerals in their raw material form and, to the best of our knowledge, do not purchase any products or components directly from the Covered Countries. As a result, we do not perform or direct audits of smelters and refiners within our supply chain.

Plexus is relying on the CFSI’s published lists to verify the conflict-free status of smelters/processors that source from Covered Countries. Additionally, Plexus has sent representation to various industry work groups to participate in efforts to improve supply chain communication to help verify their conflict-free status.

Step 5: Report annually on supply chain due diligence
 
This Report (and the related Form SD) was filed with the SEC and is available on our website at www.plexus.com/about-us/social-responsibility/our-suppliers.

V.
Determination


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We are an EMS company that provides manufacturing and related services to OEMs in the Networking/Communications, Healthcare/Life Sciences, Industrial/Commercial and Defense/Security/Aerospace market sectors. On the basis of the due diligence measures discussed in this Report, we do not have sufficient information from our suppliers or otherwise to conclude whether the conflict minerals in the products we manufacture, or contract to manufacture, originated in the Covered Countries and, if so, whether the conflict minerals were from recycled or scrap sources.

Based on our due diligence activities, we are unable to determine all of the facilities used to process these conflict minerals or their country of origin. Our efforts to determine the mine or location of origin with the greatest possible specificity included the due diligence measures described above. Appendix 1 to this Report lists those facilities identified by our due diligence activities as potentially processing these conflict minerals.

VI.
Steps to Improve Due Diligence

We will continue to communicate our expectations and information requirements to our direct suppliers. We will also continue to monitor changes in circumstances that may impact the facts or our determination. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified.

In addition to those above, the Company is considering taking the following steps during the next compliance period to improve the due diligence conducted and to further mitigate the risk that the conflict minerals necessary to support our operations benefit armed groups, including:

Informing and encouraging suppliers to transition to smelters identified by the due diligence process as “conflict-free” by an independent audit program such as the CFSI.
Actively participating in and supporting industry trade groups to help improve communication throughout the supply chain.
Working with certain suppliers to help educate them on our ongoing expectations supporting responsible sourcing decisions.
Reconsidering our willingness to continue to partner with suppliers that do not comply with our Conflict Minerals Policy.

VII.    Independent Audit

For calendar year 2013, in accordance with SEC rules and related guidance, an independent private sector audit of this Report was not required.


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VIII.    Conflict Minerals Disclosure

This Report (and the related Form SD) is available on our website at www.plexus.com/about-us/social-responsibility/our-suppliers.

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APPENDIX 1
LISTING OF IDENTIFIED FACILITIES

Metal
Smelter or Refiner Facility Name*
Listed on the CFSI’s Published “Conflict-Free” Smelter & Refiner List**
Gold
Aida Chemical Industries Co. Ltd.
No
Gold
Allgemeine Gold- und Silberscheideanstalt A.G.
Yes
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
No
Gold
AngloGold Ashanti Corrego do Sitio Mineração
Yes
Gold
Argor-Heraeus SA
Yes
Gold
Asahi Pretec Corporation
Yes
Gold
Asaka Riken Co Ltd
No
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
No
Gold
Aurubis AG
No
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
No
Gold
Bauer Walser AG
No
Gold
Boliden AB
No
Gold
Caridad
No
Gold
Cendres & Métaux SA
No
Gold
Chimet SpA
Yes
Gold
China National Gold Group Corporation
No
Gold
Chugai Mining
No
Gold
Colt Refining
No
Gold
Daejin Indus Co. Ltd
No
Gold
DaeryongENC
No
Gold
Do Sung Corporation
No
Gold
Doduco
No
Gold
Dowa
Yes
Gold
Eco-System Recycling Co., Ltd.
Yes
Gold
FSE Novosibirsk Refinery
No
Gold
Gansu Seemine Material Hi-Tech Co Ltd
No
Gold
Guangdong Jinding Gold Limited
No
Gold
Heimerle + Meule GmbH
Yes
Gold
Heraeus Ltd Hong Kong
Yes

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Gold
Heraeus Precious Metals GmbH & Co. KG
No
Gold
Hunan Chenzhou Mining Industry Group
No
Gold
Hwasung CJ Co. Ltd
No
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
No
Gold
Ishifuku Metal Industry Co., Ltd.
Yes
Gold
Istanbul Gold Refinery
Yes
Gold
Japan Mint
No
Gold
Jiangxi Copper Company Limited
No
Gold
Johnson Matthey Inc
Yes
Gold
Johnson Matthey Limited
Yes
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
No
Gold
JSC Uralectromed
No
Gold
JX Nippon Mining & Metals Co., Ltd
Yes
Gold
Kazzinc Ltd
No
Gold
Kojima Chemicals Co., Ltd
Yes
Gold
Korea Metal Co. Ltd
No
Gold
Kyrgyzaltyn JSC
No
Gold
L' azurde Company For Jewelry
No
Gold
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
No
Gold
LS-NIKKO Copper Inc
Yes
Gold
Luoyang Zijin Yinhui Metal Smelt Co Ltd
No
Gold
Materion
Yes
Gold
Matsuda Sangyo Co. Ltd
Yes
Gold
Metalor Technologies (Hong Kong) Ltd
Yes
Gold
Metalor Technologies (Singapore) Ltd
Yes
Gold
Metalor Technologies SA
Yes
Gold
Metalor USA Refining Corporation
Yes
Gold
Met-Mex Peñoles, S.A.
No
Gold
Mitsubishi Materials Corporation
Yes
Gold
Mitsui Mining and Smelting Co., Ltd.
Yes
Gold
Moscow Special Alloys Processing Plant
No
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
No
Gold
Navoi Mining and Metallurgical Combinat
No
Gold
Nihon Material Co. LTD
Yes
Gold
Ohio Precious Metals, LLC
Yes

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Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
No
Gold
OJSC Kolyma Refinery
No
Gold
PAMP SA
Yes
Gold
Penglai Penggang Gold Industry Co Ltd
No
Gold
Prioksky Plant of Non-Ferrous Metals
No
Gold
PT Aneka Tambang (Persero) Tbk
No
Gold
PX Précinox SA
No
Gold
Rand Refinery (Pty) Ltd
Yes
Gold
Royal Canadian Mint
Yes
Gold
Sabin Metal Corp.
No
Gold
SAMWON METALS Corp.
No
Gold
Schone Edelmetaal
No
Gold
SEMPSA Joyeria Plateria SA
Yes
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
No
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
No
Gold
Solar Applied Materials Technology Corp.
Yes
Gold
Sumitomo Metal Mining Co., Ltd.
No
Gold
Tanaka Kikinzoku Kogyo K.K.
Yes
Gold
The Great Wall Gold and Silver Refinery of China
No
Gold
The Refinery of Shandong Gold Mining Co. Ltd
No
Gold
Tokuriki Honten Co., Ltd
No
Gold
Tongling nonferrous Metals Group Co., Ltd
No
Gold
Torecom
No
Gold
Umicore Brasil Ltda
No
Gold
Umicore SA Business Unit Precious Metals Refining
Yes
Gold
United Precious Metal Refining, Inc.
Yes
Gold
Valcambi SA
Yes
Gold
Western Australian Mint trading as The Perth Mint
Yes
Gold
Yamamoto Precious Metals Co., Ltd.
No
Gold
Yokohama Metal Co Ltd
No
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
No
Gold
Zijin Mining Group Co. Ltd
No
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
No
Tantalum
Conghua Tantalum and Niobium Smeltry
Yes
Tantalum
Duoluoshan
Yes

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Tantalum
Exotech Inc.
Yes
Tantalum
F&X Electro-Materials Ltd.
Yes
Tantalum
Global Advanced Metals
Yes
Tantalum
H.C. Starck Group
Yes
Tantalum
Hi-Temp
Yes
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Yes
Tantalum
JiuJiang Tanbre Co., Ltd.
Yes
Tantalum
Kemet Blue Powder
Yes
Tantalum
King-Tan Tantalum Industry Ltd
No
Tantalum
LMS Brasil S.A.
Yes
Tantalum
Mineracao Toboca S.A.
Yes
Tantalum
Mitsui Mining & Smelting
Yes
Tantalum
Molycorp Silmet A.S.
Yes
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
Yes
Tantalum
Plansee
Yes
Tantalum
QuantumClean
Yes
Tantalum
RFH Tantalum Smelting Co. Ltd.
Yes
Tantalum
Shanghai Jiangxi Metals Co. Ltd
No
Tantalum
Solikamsk Metal Works
Yes
Tantalum
Taki Chemicals
Yes
Tantalum
Tantalite Resources
Yes
Tantalum
Telex
Yes
Tantalum
Ulba
Yes
Tantalum
Zhuzhou Cement Carbide
Yes
Tin
CNMC (Guangxi) PGMA Co. Ltd.
No
Tin
Cooper Santa
No
Tin
CV Serumpun Sebalai
No
Tin
CV United Smelting
No
Tin
EM Vinto
No
Tin
Fenix Metals
No
Tin
Geiju Non-Ferrous Metal Processing Co. Ltd.
Yes
Tin
Gejiu Zi-Li
No
Tin
Huichang Jinshunda Tin Co. Ltd
No
Tin
Jiangxi Nanshan
No
Tin
Kai Unita Trade Limited Liability Company
No

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Tin
Linwu Xianggui Smelter Co
No
Tin
Liuzhou China Tin
No
Tin
Malaysia Smelting Corporation (MSC)
Yes
Tin
Metallo Chimique
No
Tin
Mineração Taboca S.A.
Yes
Tin
Minmetals Ganzhou Tin Co. Ltd.
No
Tin
Minsur
Yes
Tin
Mitsubishi Materials Corporation
Yes
Tin
Novosibirsk Integrated Tin Works
No
Tin
OMSA
Yes
Tin
PT Artha Cipta Langgeng
No
Tin
PT Babel Inti Perkasa
No
Tin
PT Bangka Putra Karya
No
Tin
PT Bangka Tin Industry
No
Tin
PT Belitung Industri Sejahtera
No
Tin
PT Bukit Timah
Yes
Tin
PT DS Jaya Abadi
No
Tin
PT Eunindo Usaha Mandiri
No
Tin
PT Karimun Mining
No
Tin
PT Mitra Stania Prima
No
Tin
PT Refined Banka Tin
No
Tin
PT Sariwiguna Binasentosa
No
Tin
PT Stanindo Inti Perkasa
No
Tin
PT Tambang Timah
Yes
Tin
PT Timah
Yes
Tin
PT Tinindo Inter Nusa
No
Tin
Rui Da Hung
No
Tin
Thaisarco
Yes
Tin
White Solder Metalurgia e Mineracao Ltda.
Yes
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
No
Tin
Yunnan Tin Company Ltd.
Yes
Tungsten
A.L.M.T. Corp.
Yes
Tungsten
Chongyi Zhangyuan Tungsten Co Ltd
No
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
No
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Yes

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Tungsten
Ganzhou Grand Sea W & Mo Group Co Ltd
Yes
Tungsten
Global Tungsten & Powders Corp.
Yes
Tungsten
HC Starck GmbH
Yes
Tungsten
Hunan Chenzhou Mining Group Co
Yes
Tungsten
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.
No
Tungsten
Japan New Metals Co Ltd
No
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
No
Tungsten
Kennametal Inc.
Yes
Tungsten
Tejing (Vietnam) Tungsten Co Ltd
Yes
Tungsten
Wolfram Bergbau und Hütten AG
Yes
Tungsten
Wolfram Company CJSC
Yes
Tungsten
Xiamen Tungsten Co., Ltd.
Yes
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
No
Tungsten
Zhuzhou Cemented Carbide Group Co Ltd
No

*    Smelter and refiner facility names as reported by the CFSI and listed on the CMRT as of May 15, 2014.
**    Available at www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists. Designations as of May 15, 2014.


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