EX-1.01 2 ex101cmrmay2020.htm EXHIBIT-1.01 Document

EXHIBIT 1.01
CONFLICT MINERALS REPORT
image_01.jpg

MICROCHIP TECHNOLOGY INCORPORATED
In Accord with Rule 13p-1 Under the Securities Exchange Act of 1934
This report for the year ended December 31, 2019, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1"). Rule 13p-1 was adopted by the United States Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank"). Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain conflict minerals necessary to the functionality or production of their products. Conflict Minerals are defined by Rule 13p-1 as gold, tin, tantalum, and tungsten (“3TG”).
If a registrant has reason to believe that any conflict minerals in their supply chain may have originated in the Democratic Republic of the Congo or an adjoining country ("Covered Countries"), or if they are unable to determine the country of origin of conflict minerals or that their products are manufactured entirely from recycled and scrap sources, then the issuer must exercise due diligence on the source and chain of custody of the conflict minerals. The registrant must annually submit a Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures. This report is Microchip Technology Incorporated's CMR for the reporting calendar year ended December 31, 2019.
For clarity, Microchip is not declaring its product as “DRC Conflict Free” as that would require this CMR to have been subjected to an independent private sector audits (“IPSA”) pursuant to Rule 13p-1 and current SEC guidance, which it has not.

1


1. COMPANY OVERVIEW

MICROCHIP TECHNOLOGY INCORPORATED develops, manufactures, contracts to manufacture and sells specialized semiconductor products used by its customers in a wide variety of embedded control applications. Microchip Technology Incorporated was incorporated in Delaware in 1989. In this CMR, "we," "us," and "our" each refers to Microchip Technology Incorporated and its subsidiaries ("Microchip"). Our executive offices are located at 2355 West Chandler Boulevard, Chandler, Arizona 85224-6199, and our telephone number is (480) 792-7200.

Our Internet address is www.microchip.com. This CMR will be posted on our website with our other SEC filings under About Us/Investor Relations as soon as reasonably practicable after it is electronically filed with the SEC. All our SEC filings are available on our website free of charge. Additionally, this CMR will be posted on our Conflict Minerals webpage at www.microchip.com/conflictminerals. The information on our website is not incorporated into this CMR.

1.1 Microchip Products

Microchip Technology Incorporated is a leading provider of smart, connected, and secure embedded control solutions. Its easy-to-use development tools and comprehensive product portfolio enable customers to create optimal designs, which reduce risk while lowering total system cost and time to market. The company's solutions serve more than 120,000 customers across the industrial, automotive, consumer, aerospace and defense, communications, and computing markets. Headquartered in Chandler, Arizona, Microchip offers outstanding technical support along with dependable delivery and quality. A more detailed discussion of our product categories is contained in our Annual Reports and SEC filings available on: https://www.microchip.com/documentlisting/annual-reports. For the purposes of this report, Microchip’s products are further delineated in the table below separating integrated circuits from all other types of products.

All references to “Microchip” products hereafter include Microchip and all subsidiaries’ products in Categories A and B that were manufactured by Microchip or its subsidiaries, or contracted by Microchip or its subsidiaries to be manufactured, and within the scope of Rule 13p-1 ("Microchip products") unless specifically attributed to Microchip or a specific subsidiary (e.g. "Microchip Category A products" vs. "subsidiary Category A products").
2



Conflict Minerals Disclosure CategoryConflict Minerals Product Description
AIntegrated circuits including touch screen controller ICs (e.g. PIC® Microcontrollers, dsPIC® Digital Signal Controllers, touch and gesture sensing solutions, analog and interface, RF front-end products, wireless audio, USB and wireless solutions, embedded security products, memory products, medical electronics, LED drivers, printer/EL drivers, telecommunications, general industrial.) Integrated circuits including field programmable gate arrays ("FPGAs"), application-specific integrated circuits ("ASICs"), Power-over-Ethernet integrated circuits ("ICs") and midspans.
BRF modules and touch screen controller boards
System-in-Package (SiP) hybrid modules
System on chip solutions ("SoCs"), Power management products; timing and synchronization devices and precise time solutions, voice processing devices; radio frequency ("RF") solutions; discrete components; enterprise storage and communication solution products, security technologies and scalable anti-tamper products; Ethernet solutions; as well as custom design capabilities and services.
R&D application development printed circuit boards and system kits

We conducted an analysis of Microchip products and found that 3TG is necessary to the functionality or production of a substantial portion of Microchip products (Categories A and B).

1.2 Conflict Minerals Report

This report describes our Reasonable Country of Origin Inquiry (“RCOI”), the due diligence measures we took on the 3TG source and chain of custody, a description of the products manufactured or contracted to be manufactured for which we controlled the design and specified or approved the utilized materials, the results of our due diligence efforts, and expected risk assessment and mitigation steps.

1.3 Microchip’s Supply Chain

Microchip Products
For this reporting cycle, we completed an RCOI of all (100%) of our suppliers for Category A products. In calendar year 2019, Microchip began a new RCOI for Category B products. Microchip’s focus however was on Category A products as those are the highest volume, highest revenue products representing greater than 90% of Microchip revenue for this reporting cycle.
3



1.3.1 Category A – Integrated Circuits

Integrated circuits are manufactured and assembled by Microchip and contract manufacturers, and the first-tier supply chain to Microchip is best illustrated by three categories: (1) raw material suppliers; (2) silicon foundries; and (3) assembly subcontractors. Raw material suppliers support Microchip's three primary manufacturing sites where Microchip fabricates integrated circuits on raw silicon and our backend assembly sites.

1.3.2 Category B – Non-Integrated Circuits

The products that comprise Category B are more fully described above. Category B products are assembled by our contract manufacturers, Microchip's design engineers specify the type and manufacturer of each discrete component1 mounted on our Category B products not manufactured by Microchip. The contract manufacturers order the components, bare printed circuit boards, or substrates, where applicable, and materials used in these products from their lower-tier suppliers. Microchip does not have visibility or expertise to know if 3TG is necessary for functionality or production of all the materials, components, and peripheral equipment that make up the components on Category B products. The contract manufacturers may not have that visibility either. Many suppliers to the contract manufacturers, in turn, have suppliers. Transparency throughout the supply chain is challenging and takes time. We found many different methods by which Microchip's internal product design groups produced bills of materials for the contract manufacturers to use. We recognized the presence of obvious, functional 3TG - tantalum in tantalum capacitors, gold on RF impedance-constrained circuit boards and certain connectors, tin used to mount components to circuit boards, as examples. However, understanding where or if other 3TG were present, and whether they were functional, was challenging. We expect our contract manufacturers to provide information on the origin of the 3TG contained in materials chosen and purchased directly by the contract manufacturers (e.g., tin solder and bare circuit boards).

Microchip asked those same contract manufacturers to provide information on the origin of any 3TG contained in other materials, discrete components, and peripheral equipment that make up
1 Resistors, diodes, crystal oscillators, inductors, and capacitors are examples of discrete components.
4


Category B products. To overcome this challenge Microchip diligently conducted outreach to its Category B supply chains. In our RCOI for Category B products (September 2019 through February 2020), we were able to achieve a response rate of 92% from our suppliers overall. Continued growth and influence of conflict minerals programs around the world and Microchip’s diligent work during our annual RCOI will yield greater supply chain transparency over time.

1.5 Conflict Minerals Policy


Microchip has adopted a conflict minerals policy. Our publicly available policy is on our company website at www.microchip.com. Our policy in effect on the date of this filing appears below in italics.
Microchip Technology Incorporated and all related subsidiaries (collectively, “Microchip”) join many others who are deeply concerned regarding the human tragedies occurring in the Democratic Republic of the Congo and adjoining countries (“Covered Countries”) associated, in part, with the mining of columbite-tantalite (tantalum), cassiterite (tin), wolframite (tungsten) and gold (“Conflict Minerals” or “3T&G”).1

These minerals originate from various continents, but armed groups engaged in, or interfering with, mining operations within the Covered Countries are believed to subject workers and indigenous people to serious human rights abuses and are using proceeds from the sale of these Conflict Minerals to finance and sustain regional conflicts. Microchip supports responsible minerals sourcing within the Covered Countries to encourage viable and ethical revenue streams for the local communities. We recognize and support the need to develop programs which allow for improved transparency in 3T&G mining and transport of Conflict Minerals and improved traceability within the 3T&G supply chain.

Microchip, its executive management and its business groups, take corporate governance and business ethics seriously. Tantalum, tin, tungsten, and gold are used in electronics products, including products manufactured by Microchip.

Microchip is diligently working toward a goal of assuring our products are manufactured and are sourced from socially responsible supply chains. In pursuit of that goal Microchip is doing the following:

Participating as a member of the Responsible Minerals Initiative (“RMI”) that engages Smelters and Refiners (“SOR”) and conducts audits of the SOR against responsible minerals sourcing protocols. The RMI maintains lists of SOR that have successfully completed their responsible minerals sourcing audits (including audits by similar industry-specific trade organizations) or are actively participating with the RMI or similar organization (“Conformant” and “active” smelter lists, respectively), and the RMI publishes the industry-standard Conflict Minerals Reporting Template for conducting a Reasonable Country of Origin Inquiry (“RCOI”).
Conducting a bi-annual RCOI and subsequent smelter sourcing due diligence required by the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). Microchip uses the Responsible Minerals Initiative’s Conflict Minerals Reporting Template (“CMRT”) for our RCOI.
Retaining professional third-party smelter sourcing due diligence.
Presenting mineral sourcing risks to Microchip’s senior management.
5


Disallowing SOR into our integrated circuit supply chain that are not cooperating with, or that are no longer cooperating with, the RMI’s Responsible Minerals Assurance Process (RMAP) or similar mineral sourcing audit programs.
Providing information to suppliers and expecting each to source materials from socially responsible supply chains and to accurately and comprehensively disclose their list of SOR, either at company level or specific to those materials incorporated into Microchip’s products.
Publicly disclosing our conflict minerals policy, RCOI implementation procedures, and SOR sourcing due diligence procedures.
Microchip engages SOR where necessary, encouraging participation with the RMI’s RMAP program or their timely completion of the RMI’s third-party responsible minerals sourcing audit.
Include a conflict minerals flow-down clause in new and renewed supplier contracts and purchase terms and conditions.

2. MICROCHIP’S REASONABLE COUNTRY OF ORIGIN INQUIRY (RCOI) RESULTS

The difference in product complexity and size of the respective supply chains of our Category A and B products necessitated different RCOI approaches for this reporting cycle.

2.1 Category A Products

Beginning in June 2019, Microchip sent the RMI CMRT with a set of educational and instructional documents, including a list of prohibited smelters, requesting the completion of the RMI CMRT to well- defined raw materials suppliers and its contract manufacturers for Category A products.
We reviewed the responses against criteria developed to determine valid responses and to identify candidates for subsequent inquiry ("Response Criteria"). For Microchip Category A inquiries, we received responses that we considered valid, including some requiring subsequent inquiry, from all first-tier suppliers.
TABLE 1
        Category A Products, Smelter Metrics - 2242 Total Smelters 
MetalSmelters recognized by the RMI RMAP to be Conformant with their responsible minerals sourcing protocolsSmelters actively participating in sourcing audits by RMI RMAP, TI-CMC, LBMA, or similarSmelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered CountriesSmelters that use 100% scrap or recycled sources
Tantalum37 of 370 of 3718 of 375 of 37
Tin44 of 44
0 of 44
2 of 44
6 of 44
Tungsten40 of 400 of 40
5 of 40
2 of 40
Gold103 of 1030 of 1037 of 10338 of 103

6


All smelters for Category A products known to source from the Covered Countries, or for which there is reason to believe may source from the Covered Countries, are recognized as Conformant with RMI Responsible Minerals Assurance Process (RMAP) responsible mineral sourcing protocols and are listed on the RMI's "Conformant" smelter list.

2.2 Category B Products

For Category B products, Microchip started an RCOI in September 2019. Having identified and queried the printed circuit board manufacturers and the subcontract manufacturers’ unique materials previously, we successfully expanded our inquiry of discrete component manufacturers for all Categories and manufacturers of peripheral equipment.
TABLE 2
Category B Products, Smelter Metrics - 2973 Total Smelters
MetalSmelters recognized by the RMI RMAP to be Conformant with their responsible minerals sourcing protocolsSmelters actively participating in sourcing audits by RMI RMAP, TI-CMC, LBMA, or similarSmelters not actively participating in sourcing audits by RMI RMAP, TI- CMC, LBMA, or similarSmelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered Countries
Tantalum38 of 391 of 390 of 3919 of 39
Tin46 of 571 of 5710 of 572 of 57
Tungsten43 of 472 of 472 of 475 of 47
Gold106 of 1541 of 15447 of 15415 of 154

33 of the 41 smelters for Category B products that are known to source from the Covered Countries, or for which there is a reason to believe may source from the Covered Countries are recognized as Conformant with RMI Responsible Minerals Assurance Process (RMAP). The remaining eight smelters that are known to source from the Covered Countries, or for which there is a reason to believe may source from the Covered Countries, are not recognized as Conformant with the RMI RMAP, thus additional due diligence was conducted. For more information on these eight smelters, please go to section 3.3.1 “Category B Identified Risks.”

65 of the 297 reported smelters for Category B products were found to be 100% scrap recyclers.

2 The total number of reported smelters represents the number of unique operational smelters reported to Microchip in 2019. Certain smelters that were found to be closed or ceased operation before 2019 are not included in this number. These smelters could not have been in or provided materials to Microchip’s supply chain.
3The total number of reported smelters represents the number of unique operational smelters reported to Microchip in 2019. Certain smelters that were found to be closed or ceased operation before 2019 are not included in this number. These smelters could not have been in or provided materials to Microchip’s supply chain
7


3. MICROCHIP DUE DILIGENCE PROCESS

3.1 Design of Due Diligence

We made a good faith effort in the reporting year to work within the framework of the Organization for Economic Co-Operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing ("OECD Guidance") and related Supplements for 3TG, as it relates to our position in the supply chain as a “downstream company.”

3.2 Management Systems

Microchip operates under a set of Guiding Values and a Code of Business Conduct & Ethics that form the foundation of all management systems at Microchip. Continuing through the reporting year, Microchip expressed its concern and commitment regarding conflict minerals sourcing from the DRC and Covered Countries in a publicly available policy statement on conflict minerals as outlined in Section 1.5 above.

In addition, Microchip communicates our concern and commitment regarding conflict minerals sourcing from the DRC and Covered Countries in our Terms and Conditions of Purchase that accompanies every order acknowledgement.

3.2.1 Internal Team

Continuing through the reporting year, Microchip's management system for conflict minerals included a team of corporate representatives from relevant functions, including corporate social responsibility, legal, manufacturing, corporate environmental services, product environmental, supply management, risk management. The team is sponsored by Microchip's CFO, and senior management was briefed about the results of due diligence efforts, including minerals sourcing risks.

The conflict minerals team is responsible for implementing the conflict minerals compliance strategy, including formalizing conflict minerals due diligence practices, developing supplier risk assessment criteria and responses to risk. The team is led by the Senior Manager, Compliance-Trade & Corporate Social Responsibility who acts as the conflict minerals program manager.
8



3.2.2 Supply Chain Control Systems

To encourage the establishment of a system of controls and transparency over the mineral supply, we participate in the RMI. Participation allows Microchip to promote validation programs, increase our knowledge of smelters and refiners in the supply chain, understand the scope and process for audit and validation program plans for metal-specific trade organizations, gain insight into which smelters are known to source from the covered countries, and join discussions of emerging practical due diligence experiences. During the reporting year, Microchip engaged a third-party due diligence consultant experienced with smelter sourcing research and with a proven record of smelter engagement. The consultant reviewed sorted smelter data obtained from our 2019 RCOI for Category A products and raw, unsorted smelter data from our 2019 RCOI for Category B products, and then prepared a technical file for each. Mineral sourcing risk, including customer perception of sourcing risk, is presented to Microchip's senior management.

3.2.3 Microchip Supplier Engagement

Microchip’s supplier engagement activities in the reporting year again focused primarily on Category A suppliers. During the reporting year, we requested completion of the RMI CMRT by raw material suppliers and subcontract manufacturers of Category A products using an educational request letter that included training materials developed by Microchip. Microchip’s training materials consist of a prohibited smelters list, a referral to training materials produced by and available through the RMI. We reviewed responses against criteria designed to determine the number of valid responses ("Response Criteria"), and we followed up with corrections and clarifications as needed. During the reporting year, all reported smelters for Category A products were found to be listed in the RMI “Conformant” smelter lists as of December 31, 2019. Over the course of the year, the RMI de-listed several smelters; additional discussion is presented in Section 3.3, second paragraph, of this CMR.

For Microchip’s Category B products, Microchip continued and expanded its engagement with the second and third-tier discrete component and peripheral equipment
9


suppliers using the RMI CMRT and educational materials. We continue to encounter circumstances where the manufacturer of the discrete component declined to provide a completed CMRT because we are not their direct customer - our contract manufacturers are their direct customer. Still, the contract manufacturers are not responsible for specifying the discrete components. We have begun to work more closely with our contract manufacturers to bridge this gap.

3.2.4 Grievance Mechanism

Microchip has grievance mechanisms whereby employees, suppliers, and others can report suspected non-compliance with legal requirements and suspected non-compliance with Microchip's Code of Business Conduct & Ethics.

Our Code of Business Conduct & Ethics policy (HR-690), Compliance with Laws policy (HR-685) and Reporting Legal Non-Compliance policy (HR-675) include complaint procedures. These policies are publicly available at https://www.microchip.com/about-us/corporate-responsibility/ethics-conduct

For additional conflict minerals related grievance, Microchip employees and external parties may also submit concerns or information to ConflictMinerals@Microchip.com

3.2.5 Maintain Records

Microchip has developed a process for collecting and retaining RCOI and due diligence documentation that was directed, controlled, and archived by the conflict minerals team.

3.3 Identify and Assess Risk in the Supply Chain

Because of our size, the complexity of our products, and the depth, breadth, and evolution of our supply chain, it can be challenging to identify suppliers upstream from our first tier (direct) suppliers. Accordingly, we identify direct suppliers that supply products to us that may contain conflict minerals. We pursue smelter identification using the RMI CMRT; additionally, Microchip leverages our membership in the RMI as an integral part of our supply chain identification and due diligence and risk
10


assessment processes. Additionally, Microchip uses our third-party due diligence consultant to gain insight into SORs’ sourcing practices, and their internal due diligence procedures to help with risk assessment.

3.3.1 Category B Identified Risks

African Gold Refinery (CID003185), a gold refinery, was reported in our Category B products’ supply chain. This smelter, which is located within the Great Lakes Region of the Covered Countries, presents a credible risk of irresponsible sourcing based upon our due diligence research. As such, Microchip promptly engaged its Category B supply chain to remove this smelter. Many suppliers voluntarily removed African Gold Refinery from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 46% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.

Sudan Gold Refining (CID002567), a state-owned gold refinery, was reported in our Category B products’ supply chain. This smelter may present a risk of irresponsible sourcing within the Covered Countries. As such Microchip promptly engaged its Category B supply chain to remove this smelter. Many suppliers voluntarily removed Sudan Gold Refining from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 45% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.

Kaloti Precious Metals (CID002563), a gold smelter, was reported in our Category B products’ supply chain. It has come to our attention during our third-party due diligence review that there is a reason to believe that this smelter may present a risk of irresponsible sourcing within the Covered Countries as this smelter is located in a country without a domestic source of gold. Additionally, Kaloti Precious Metals is not listed on the RMI-RMAP Conformant List for Gold
11


thus has not been audited by any entity accepted by the RMI audit protocols. As such, Microchip promptly engaged its was reported in our Category B supply chain to remove this smelter. Many suppliers voluntarily removed Kaloti Precious Metals from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 50% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.

Fidelity Printers and Refiners Ltd. (CID002515), a gold refinery, was reported in our Category B products’ supply chain. This smelter may present a risk of irresponsible sourcing within the Covered Countries. As such Microchip promptly engaged its Category F supply chain to remove this smelter. Many suppliers voluntarily removed Fidelity Printers and Refiners Ltd. from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 47% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain, and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.

Tony Goetz NV (CID002587), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. As such Microchip promptly engaged its Category B supply chain to remove this smelter. Many suppliers voluntarily removed Tony Goetz NV from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 47% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.

12


Dijllah Gold Refinery FZC (CID003348), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. Many suppliers voluntarily removed Dijllah Gold Refinery FZC from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 42% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.

Fujairah Gold (CID002584), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. Many suppliers voluntarily removed Fujairah Gold from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 42% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.

International Precious Metal Refiners (CID002562), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. Many suppliers voluntarily removed International Precious Metal Refiners from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 43% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.

3.4 Design and Implement a Strategy to Respond to Risks
13



We believe that understanding smelter sourcing practices is the best method that can eventually lead to the determination of a product's conflict status. To that end, Microchip is a member of the RMI. We review the lists of smelters reported by our supply chain against the RMI RMAP "Conformant" smelter lists, their "active" smelter lists, the TI-CMC "active" smelter list (TI-CMC Category A, Members Progressing Toward RMAP Validation), and the KUMA “active” smelter list (KUMA, Members Progressing Toward RMAP Validation). We plan to engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that support conflict in the Covered Countries to seek to establish an acceptable alternative source of 3TG that does not support such conflict. We also engage directly with smelters reported by our supply chain and for which we can locate viable contact information to voluntarily participate in the RMI RMAP or similar sourcing audit programs leading to recognition by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols.

3.5 Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

We do not typically have a direct relationship with 3TG smelters and refiners, and do not perform direct audits of these entities within our supply chain. Microchip does, however, leverage our third-party due diligence consultant to contact smelters and refiners that we do not have direct relationships with or do not have the ability to contact. Using our third-party due diligence consultant, Microchip gains insight into SORs’ sourcing practices, and their internal due diligence procedures. Microchip’s third-party due diligence consultant also encourages non-conformant SORs to become conformant by joining the RMI or affiliated groups on our behalf. Additionally, Microchip utilizes and supports the due diligence conducted by programs like the RMI to conduct and coordinate third-party audits to validate 3TG processors sourcing practices.

During the reporting year, Microchip purchased gold sputter targets from one large refiner, and Tin Anode from one large refiner, each of which is recognized by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols. We support responsible minerals sourcing audits through membership with the RMI.

14


3.6 Report on Supply Chain Due Diligence

In addition to this CMR, we communicate our conflict minerals activities in our annual Sustainability Report and in our conflict minerals sourcing policy, which are available on our company website: www.microchip.com. The information on our website is not incorporated into this CMR.

4. DUE DILIGENCE RESULTS

4.1 Request Information

We conducted a Reasonable Country of Origin Inquiry (“RCOI”) of those suppliers described above using the RMI CMRT. The RMI CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide 3TG to a company's supply chain.

4.2 Summary Results for All Product Categories

As a result of our continuous due diligence with suppliers and smelters through Microchip’s third-party due diligence consultant team, Microchip has determined that approximately 100% of our smelters are RMAP conformant as of the end of our RCOI for our Category A products. These are the same results that we saw at the end of our previous three reporting cycles.

Microchip determined that approximately 78% of our smelters reported in our Category B products are RMAP conformant as of the end of our RCOI. For our Category B products, this is a slight decrease from the results that we saw at the end of 2018 and 2017.

Based on RCOI information provided by suppliers in Microchip's supply chains, our due diligence efforts, and due diligence provided by our third-party due diligence consultant, the SORs that may have processed the 3TG in Microchip's Category A products include those listed in Table 1. The SORs that may have processed the 3TG in Category B products include those listed in Table 2.

Based on our due diligence efforts, Microchip does not have sufficient information to conclusively determine the countries of origin for the 3TG in our products. Based on the information provided by Microchip's suppliers, our third-party due diligence consultant, the RMI, and others, Microchip believes that the countries of origin for the 3TG in our products include the countries listed in Table 5.
15



While we identified 51 smelters for Category A products that use exclusively scrap or recycled sources of 3TG, we determined that no correlation can be made to any specific Microchip Category A product type, technology family, or part number. No Microchip Category A product is made exclusively with 3TG solely sourced from scrap or recycled sources.

65 smelters in our Category B products were found to source from scrap or recycled sources of 3TG exclusively, however, we determined that no correlation can be made to any specific Microchip Category B product types, technology families, or part number. No Category B product is made exclusively with 3TG solely sourced from scrap or recycled sources.

Microchip's independent due diligence produced information suggesting 32 reported smelters for Category A products either are known to source from the Covered Countries, or there is reason to believe may or could source from the Covered Countries based upon business relationships. Each of these smelters is recognized by the RMI RMAP to be Conformant with the organization’s responsible minerals sourcing protocols and is listed on the RMI RMAP “Conformant” smelter lists.

Microchip's independent due diligence produced information suggesting 41 reported smelters for Category B products either are known to source from the Covered Countries or there is reason to believe may source from the Covered Countries. 33 of these smelters are recognized by the RMI RMAP to be “Conformant” with the organization’s responsible minerals sourcing protocols and are listed on the RMI RMAP “Conformant” smelter lists. For the eight smelters reported to be in the supply chain for Category B products that were neither recognized by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols and listed on the RMI RMAP “Conformant” smelter lists nor the organization’s "active" smelter lists, or the TI-CMC "active" smelter list (TI-CMC Category A Members Progressing Toward RMAP Validation), Microchip performed additional due diligence. The review criteria include a determination of the geographic location, whether there is a known, actively mined, and economically viable reserve of 3TG in the area, whether there is positive evidence of responsible and/or irresponsible sourcing, whether there is contrary evidence of responsible sourcing - all from publicly available sources, the smelters’ websites, the UN Group of Experts, NGOs, the RMI and similar organizations, and from our due diligence consultant’s communication with certain smelters. From this due diligence review for all product categories Microchip concludes:
16




There were 8 findings during our due diligence of possible irresponsible mineral sourcing. Please refer to Section 3.3 of this Conflict Minerals Report for the discussion on the steps taken on these eight findings. For the remaining 33 smelters, there was no evidence of irresponsible sourcing.

4.3 Efforts to Determine Mine or Location of Origin

We have determined that participation in RMI, requesting our suppliers complete the RMI CMRT, and retaining a third-party due diligence consultant in the reporting year are reasonable ways to determine the mines or countries of origin of the 3TG in our supply chain.

4.4 Smelters or Refiners

Microchip does not source 3TG directly from the Covered Countries, and Microchip typically does not source 3TG directly from smelters or refiners. The exceptions are gold sputter targets, and Tin Anode. All gold sputter targets, and Tin Anode, were purchased from smelters or refiners recognized by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols.

Based on RCOI information provided by suppliers in Microchip’s supply chains, our own due diligence efforts, and due diligence provided by our consultant, the facilities that may have processed the 3TG in Microchip’s Category A products include those listed in Table 1.

4.4.1 Category B

Microchip does not source 3TG directly from the Covered Countries, and Microchip does not source 3TG directly from smelters or refiners for Category B products. The facilities that may have processed the 3TG in Category B products include those listed in Table 2.

5. STEPS TO BE TAKEN TO MITIGATE RISK

We intend to take the following steps to improve the due diligence conducted to further mitigate risk that the necessary conflict minerals in our products could benefit armed groups in the Covered Countries:

17



a.Continue to work with the RMI and/or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance and/or other SEC recognized framework.
b.Consolidate RCOI and due diligence practices and activities into a conflict minerals management system. Continue to retain a third-party due diligence consultant experienced with smelter sourcing research and direct smelter engagement.
c.Conduct annual reporting year RCOI for Category A products using the RMI CMRT.
d.Conduct annual reporting year RCOI for Category B products using RMI CMRT. Microchip will communicate its expectation that suppliers for Category B products working to remove uncooperative smelters, and smelters that are not actively participating with the RMI RMAP, or similar sourcing programs from the products they provide to Microchip through Microchip's contract manufacturers.
e.Continue to develop supplier engagement strategies that may improve the RCOI response rate for Category B suppliers where Microchip is a second-tier customer or lower.
f.Through our efforts or those of our due diligence consultant, engage with selected smelters to encourage participation with the RMI RMAP responsible minerals sourcing audits.
g.Continue to remove smelters from our Category A supply chain that become uncooperative with the RMI RMAP, or who were at one time, voluntarily participating with the RMI RMAP responsible minerals sourcing audit program or similar programs but who have fallen off the “Conformant” smelter lists unless the RMI places the smelter into its “smelters undergoing extended corrective action” category. Microchip will review the business need for a smelter in this category and may, depending on the cause for removal and the nature and content of affirmative commitments made by the affected smelter, choose to retain the smelter in its supply chain.
h.Engage with direct suppliers found to be supplying us with 3TG from sources that support conflict in any Covered Country to seek to establish an acceptable alternative source of 3TG.

18



TABLE 5

Category A Products

Smelters Reported to be in Supply Chain


MetalSmelter NameSmelter Country
Gold8853 S.p.A.ITALY
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICA
GoldAida Chemical Industries Co., Ltd.JAPAN
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANY
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTAN
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZIL
GoldArgor-Heraeus S.A.SWITZERLAND
GoldAsahi Pretec Corp.JAPAN
GoldAsahi Refining Canada Ltd.CANADA
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICA
GoldAsaka Riken Co., Ltd.JAPAN
GoldAU Traders and RefinersSOUTH AFRICA
GoldAurubis AGGERMANY
GoldBangalore RefineryINDIA
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINES
GoldBoliden ABSWEDEN
GoldC. Hafner GmbH + Co. KGGERMANY
GoldCCR Refinery - Glencore Canada CorporationCANADA
GoldCendres + Metaux S.A.SWITZERLAND
GoldChimet S.p.A.ITALY
GoldChugai MiningJAPAN
GoldDODUCO Contacts and Refining GmbHGERMANY
GoldDowaJAPAN
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OF
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OF
GoldEco-System Recycling Co., Ltd.JAPAN
GoldEmirates Gold DMCCUNITED ARAB EMIRATES
GoldGeib Refining CorporationUNITED STATES OF AMERICA
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINA
GoldHeeSung Metal Ltd.KOREA, REPUBLIC OF
GoldHeimerle + Meule GmbHGERMANY
GoldHeraeus Metals Hong Kong Ltd.CHINA
GoldHeraeus Precious Metals GmbH & Co. KGGERMANY
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINA
GoldIshifuku Metal Industry Co., Ltd.JAPAN
GoldIstanbul Gold RefineryTURKEY
GoldItalpreziosiITALY
GoldJapan MintJAPAN
19



MetalSmelter NameSmelter Country
GoldJiangxi Copper Co., Ltd.CHINA
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATION
GoldJSC UralelectromedRUSSIAN FEDERATION
GoldJX Nippon Mining & Metals Co., Ltd.JAPAN
GoldKazzincKAZAKHSTAN
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICA
GoldKGHM Polska Miedz Spolka AkcyjnaPOLAND
GoldKojima Chemicals Co., Ltd.JAPAN
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OF
GoldKyrgyzaltyn JSCKYRGYZSTAN
GoldL'Orfebre S.A.ANDORRA
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OF
GoldMarsam MetalsBRAZIL
GoldMaterionUNITED STATES OF AMERICA
GoldMatsuda Sangyo Co., Ltd.JAPAN
GoldMetalor Technologies (Hong Kong) Ltd.CHINA
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORE
GoldMetalor Technologies (Suzhou) Ltd.CHINA
GoldMetalor Technologies S.A.SWITZERLAND
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICA
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICO
GoldMitsubishi Materials CorporationJAPAN
GoldMitsui Mining and Smelting Co., Ltd.JAPAN
GoldMMTC-PAMP India Pvt., Ltd.INDIA
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATION
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEY
GoldNihon Material Co., Ltd.JAPAN
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIA
GoldOhura Precious Metal Industry Co., Ltd.JAPAN
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATION
GoldPAMP S.A.SWITZERLAND
GoldPlanta Recuperadora de Metales SpACHILE
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATION
GoldPT Aneka Tambang (Persero) TbkINDONESIA
GoldPX Precinox S.A.SWITZERLAND
GoldRand Refinery (Pty) Ltd.SOUTH AFRICA
GoldREMONDIS PMR B.V.NETHERLANDS
GoldRoyal Canadian MintCANADA
GoldSAAMPFRANCE
GoldSafimet S.p.AITALY
GoldSamduck Precious MetalsKOREA, REPUBLIC OF
GoldSAXONIA Edelmetalle GmbHGERMANY
GoldSEMPSA Joyeria Plateria S.A.SPAIN
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINA
GoldSichuan Tianze Precious Metals Co., Ltd.CHINA
20



MetalSmelter NameSmelter Country
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINA
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATION
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINA
GoldSumitomo Metal Mining Co., Ltd.JAPAN
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OF
GoldT.C.A S.p.AITALY
GoldTanaka Kikinzoku Kogyo K.K.JAPAN
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINA
GoldTokuriki Honten Co., Ltd.JAPAN
GoldTorecomKOREA, REPUBLIC OF
GoldUmicore Brasil Ltda.BRAZIL
GoldUmicore Precious Metals ThailandTHAILAND
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUM
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICA
GoldValcambi S.A.SWITZERLAND
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIA
GoldWIELAND Edelmetalle GmbHGERMANY
GoldYamakin Co., Ltd.JAPAN
GoldYokohama Metal Co., Ltd.JAPAN
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINA
TantalumAsaka Riken Co., Ltd.JAPAN
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINA
TantalumD Block Metals, LLCUNITED STATES OF AMERICA
TantalumExotech Inc.UNITED STATES OF AMERICA
TantalumF&X Electro-Materials Ltd.CHINA
TantalumFIR Metals & Resource Ltd.CHINA
TantalumGlobal Advanced Metals AizuJAPAN
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICA
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINA
TantalumH.C. Starck Co., Ltd.THAILAND
TantalumH.C. Starck Hermsdorf GmbHGERMANY
TantalumH.C. Starck Inc.UNITED STATES OF AMERICA
TantalumH.C. Starck Ltd.JAPAN
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANY
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANY
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINA
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINA
TantalumJiangxi Tuohong New Raw MaterialCHINA
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINA
TantalumJiujiang Tanbre Co., Ltd.CHINA
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINA
TantalumKEMET Blue MetalsMEXICO
TantalumKEMET Blue PowderUNITED STATES OF AMERICA
TantalumLSM Brasil S.A.BRAZIL
TantalumMetallurgical Products India Pvt., Ltd.INDIA
21



MetalSmelter NameSmelter Country
TantalumMineracao Taboca S.A.BRAZIL
TantalumMitsui Mining and Smelting Co., Ltd.JAPAN
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINA
TantalumPower Resources Ltd.MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
TantalumQuantumCleanUNITED STATES OF AMERICA
TantalumResind Industria e Comercio Ltda.BRAZIL
TantalumRFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.CHINA
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATION
TantalumTaki Chemical Co., Ltd.JAPAN
TantalumTelex MetalsUNITED STATES OF AMERICA
TantalumUlba Metallurgical Plant JSCKAZAKHSTAN
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINA
TinAlphaUNITED STATES OF AMERICA
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINA
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINA
TinChina Tin Group Co., Ltd.CHINA
TinDowaJAPAN
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)
TinFenix MetalsPOLAND
TinGejiu Fengming Metallurgy Chemical PlantCHINA
TinGejiu Kai Meng Industry and Trade LLCCHINA
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINA
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINA
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINA
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINA
TinGuanyang Guida Nonferrous Metal Smelting PlantCHINA
TinHuiChang Hill Tin Industry Co., Ltd.CHINA
TinHuichang Jinshunda Tin Co., Ltd.CHINA
TinJiangxi New Nanshan Technology Ltd.CHINA
TinMagnu's Minerais Metais e Ligas Ltda.BRAZIL
TinMalaysia Smelting Corporation (MSC)MALAYSIA
TinMelt Metais e Ligas S.A.BRAZIL
TinMetallic Resources, Inc.UNITED STATES OF AMERICA
TinMetallo Belgium N.V.BELGIUM
TinMetallo Spain S.L.U.SPAIN
TinMineracao Taboca S.A.BRAZIL
TinMinsurPERU
TinMitsubishi Materials CorporationJAPAN
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILAND
TinO.M. Manufacturing Philippines, Inc.PHILIPPINES
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)
TinPT Artha Cipta LanggengINDONESIA
TinPT ATD Makmur Mandiri JayaINDONESIA
TinPT Mitra Stania PrimaINDONESIA
TinPT Refined Bangka TinINDONESIA
22



MetalSmelter NameSmelter Country
TinPT Timah Tbk KundurINDONESIA
TinPT Timah Tbk MentokINDONESIA
TinResind Industria e Comercio Ltda.BRAZIL
TinRui Da HungTAIWAN, PROVINCE OF CHINA
TinSoft Metais Ltda.BRAZIL
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIETNAM
TinThaisarcoTHAILAND
TinTin Technology & RefiningUNITED STATES OF AMERICA
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZIL
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINA
TinYunnan Tin Company LimitedCHINA
TungstenA.L.M.T. Corp.JAPAN
TungstenACL Metais EireliBRAZIL
TungstenAsia Tungsten Products Vietnam Ltd.VIETNAM
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINA
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINA
TungstenFujian Jinxin Tungsten Co., Ltd.CHINA
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINA
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINA
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINA
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINA
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICA
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINA
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANY
TungstenH.C. Starck Tungsten GmbHGERMANY
TungstenHunan Chenzhou Mining Co., Ltd.CHINA
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiCHINA
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINA
TungstenHydrometallurg, JSCRUSSIAN FEDERATION
TungstenJapan New Metals Co., Ltd.JAPAN
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINA
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINA
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINA
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINA
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINA
TungstenKennametal FallonUNITED STATES OF AMERICA
TungstenKennametal HuntsvilleUNITED STATES OF AMERICA
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OF
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINA
TungstenMasan Tungsten Chemical LLC (MTC)VIETNAM
TungstenMoliren Ltd.RUSSIAN FEDERATION
TungstenNiagara Refining LLCUNITED STATES OF AMERICA
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINES
TungstenTejing (Vietnam) Tungsten Co., Ltd.VIETNAM
TungstenUnecha Refractory metals plantRUSSIAN FEDERATION
23



MetalSmelter NameSmelter Country
TungstenWolfram Bergbau und Hutten AGAUSTRIA
TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OF
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINA
TungstenXiamen Tungsten Co., Ltd.CHINA
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINA
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.CHINA

24



TABLE 6

Category B Products

Smelters Reported to be in Supply Chain

MetalSmelter NameSmelter Country
Gold8853 S.p.A.ITALY
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICA
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICA
GoldAfrican Gold RefineryUGANDA
GoldAida Chemical Industries Co., Ltd.JAPAN
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATES
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANY
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTAN
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZIL
GoldArgor-Heraeus S.A.SWITZERLAND
GoldAsahi Pretec Corp.JAPAN
GoldAsahi Refining Canada Ltd.CANADA
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICA
GoldAsaka Riken Co., Ltd.JAPAN
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEY
GoldAU Traders and RefinersSOUTH AFRICA
GoldAurubis AGGERMANY
GoldBangalore RefineryINDIA
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINES
GoldBoliden ABSWEDEN
GoldC. Hafner GmbH + Co. KGGERMANY
GoldCaridadMEXICO
GoldCCR Refinery - Glencore Canada CorporationCANADA
GoldCendres + Metaux S.A.SWITZERLAND
GoldCGR Metalloys Pvt Ltd.INDIA
GoldChimet S.p.A.ITALY
GoldChugai MiningJAPAN
GoldDaye Non-Ferrous Metals Mining Ltd.CHINA
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANY
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATES
GoldDODUCO Contacts and Refining GmbHGERMANY
GoldDowaJAPAN
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OF
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OF
GoldEco-System Recycling Co., Ltd. East PlantJAPAN
GoldEco-System Recycling Co., Ltd. North PlantJAPAN
GoldEco-System Recycling Co., Ltd. West PlantJAPAN
GoldEmirates Gold DMCCUNITED ARAB EMIRATES
GoldFidelity Printers and Refiners Ltd.ZIMBABWE
25



MetalSmelter NameSmelter Country
GoldFujairah Gold FZCUNITED ARAB EMIRATES
GoldGeib Refining CorporationUNITED STATES OF AMERICA
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINA
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINA
GoldGuangdong Jinding Gold LimitedCHINA
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIA
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINA
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINA
GoldHeeSung Metal Ltd.KOREA, REPUBLIC OF
GoldHeimerle + Meule GmbHGERMANY
GoldHeraeus Metals Hong Kong Ltd.CHINA
GoldHeraeus Precious Metals GmbH & Co. KGGERMANY
GoldHunan Chenzhou Mining Co., Ltd.CHINA
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINA
GoldHwaSeong CJ CO., LTD.KOREA, REPUBLIC OF
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINA
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATES
GoldIshifuku Metal Industry Co., Ltd.JAPAN
GoldIstanbul Gold RefineryTURKEY
GoldItalpreziosiITALY
GoldJapan MintJAPAN
GoldJiangxi Copper Co., Ltd.CHINA
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATION
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATION
GoldJSC UralelectromedRUSSIAN FEDERATION
GoldJX Nippon Mining & Metals Co., Ltd.JAPAN
GoldKaloti Precious MetalsUNITED ARAB EMIRATES
GoldKazakhmys Smelting LLCKAZAKHSTAN
GoldKazzincKAZAKHSTAN
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICA
GoldKGHM Polska Miedz Spolka AkcyjnaPOLAND
GoldKojima Chemicals Co., Ltd.JAPAN
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OF
GoldKyrgyzaltyn JSCKYRGYZSTAN
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATION
GoldL'azurde Company For JewelrySAUDI ARABIA
GoldLingbao Gold Co., Ltd.CHINA
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINA
GoldL'Orfebre S.A.ANDORRA
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OF
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINA
GoldMarsam MetalsBRAZIL
GoldMaterionUNITED STATES OF AMERICA
GoldMatsuda Sangyo Co., Ltd.JAPAN
GoldMetalor Technologies (Hong Kong) Ltd.CHINA
26



MetalSmelter NameSmelter Country
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORE
GoldMetalor Technologies (Suzhou) Ltd.CHINA
GoldMetalor Technologies S.A.SWITZERLAND
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICA
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICO
GoldMitsubishi Materials CorporationJAPAN
GoldMitsui Mining and Smelting Co., Ltd.JAPAN
GoldMMTC-PAMP India Pvt., Ltd.INDIA
GoldModeltech Sdn BhdMALAYSIA
GoldMorris and WatsonNEW ZEALAND
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATION
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEY
GoldNavoi Mining and Metallurgical CombinatUZBEKISTAN
GoldNH Recytech CompanyKOREA, REPUBLIC OF
GoldNihon Material Co., Ltd.JAPAN
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIA
GoldOhura Precious Metal Industry Co., Ltd.JAPAN
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATION
GoldPAMP S.A.SWITZERLAND
GoldPease & CurrenUNITED STATES OF AMERICA
GoldPenglai Penggang Gold Industry Co., Ltd.CHINA
GoldPlanta Recuperadora de Metales SpACHILE
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATION
GoldPT Aneka Tambang (Persero) TbkINDONESIA
GoldPX Precinox S.A.SWITZERLAND
GoldQG Refining, LLCUNITED STATES OF AMERICA
GoldRand Refinery (Pty) Ltd.SOUTH AFRICA
GoldRefinery of Seemine Gold Co., Ltd.CHINA
GoldREMONDIS PMR B.V.NETHERLANDS
GoldRoyal Canadian MintCANADA
GoldSAAMPFRANCE
GoldSabin Metal Corp.UNITED STATES OF AMERICA
GoldSafimet S.p.AITALY
GoldSAFINA A.S.CZECHIA
GoldSai RefineryINDIA
GoldSamduck Precious MetalsKOREA, REPUBLIC OF
GoldSamwon Metals Corp.KOREA, REPUBLIC OF
GoldSAXONIA Edelmetalle GmbHGERMANY
GoldSEMPSA Joyeria Plateria S.A.SPAIN
GoldShandong Humon Smelting Co., Ltd.CHINA
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINA
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINA
GoldSichuan Tianze Precious Metals Co., Ltd.CHINA
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINA
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATION
27



MetalSmelter NameSmelter Country
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINA
GoldSovereign MetalsINDIA
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIA
GoldSudan Gold RefinerySUDAN
GoldSumitomo Metal Mining Co., Ltd.JAPAN
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OF
GoldT.C.A S.p.AITALY
GoldTanaka Kikinzoku Kogyo K.K.JAPAN
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINA
GoldTokuriki Honten Co., Ltd.JAPAN
GoldTongling Nonferrous Metals Group Co., Ltd.CHINA
GoldTony Goetz NVBELGIUM
GoldTOO Tau-Ken-AltynKAZAKHSTAN
GoldTorecomKOREA, REPUBLIC OF
GoldUmicore Brasil Ltda.BRAZIL
GoldUmicore Precious Metals ThailandTHAILAND
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUM
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICA
GoldValcambi S.A.SWITZERLAND
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIA
GoldWIELAND Edelmetalle GmbHGERMANY
GoldYamakin Co., Ltd.JAPAN
GoldYokohama Metal Co., Ltd.JAPAN
GoldYunnan Copper Industry Co., Ltd.CHINA
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINA
TantalumAsaka Riken Co., Ltd.JAPAN
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINA
TantalumCP Metals Inc.UNITED STATES OF AMERICA
TantalumD Block Metals, LLCUNITED STATES OF AMERICA
TantalumExotech Inc.UNITED STATES OF AMERICA
TantalumF&X Electro-Materials Ltd.CHINA
TantalumFIR Metals & Resource Ltd.CHINA
TantalumGlobal Advanced Metals AizuJAPAN
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICA
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINA
TantalumH.C. Starck Co., Ltd.THAILAND
TantalumH.C. Starck Hermsdorf GmbHGERMANY
TantalumH.C. Starck Inc.UNITED STATES OF AMERICA
TantalumH.C. Starck Ltd.JAPAN
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANY
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANY
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINA
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINA
TantalumJiangxi Tuohong New Raw MaterialCHINA
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINA
28



MetalSmelter NameSmelter Country
TantalumJiujiang Tanbre Co., Ltd.CHINA
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINA
TantalumKEMET Blue MetalsMEXICO
TantalumKEMET Blue PowderUNITED STATES OF AMERICA
TantalumLSM Brasil S.A.BRAZIL
TantalumMetallurgical Products India Pvt., Ltd.INDIA
TantalumMineracao Taboca S.A.BRAZIL
TantalumMitsui Mining and Smelting Co., Ltd.JAPAN
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINA
TantalumNPM Silmet ASESTONIA
TantalumPower Resources Ltd.MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
TantalumQuantumCleanUNITED STATES OF AMERICA
TantalumResind Industria e Comercio Ltda.BRAZIL
TantalumRFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.CHINA
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATION
TantalumTaki Chemical Co., Ltd.JAPAN
TantalumTelex MetalsUNITED STATES OF AMERICA
TantalumUlba Metallurgical Plant JSCKAZAKHSTAN
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINA
TinAlphaUNITED STATES OF AMERICA
TinAn Vinh Joint Stock Mineral Processing CompanyVIETNAM
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINA
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINA
TinChina Tin Group Co., Ltd.CHINA
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINA
TinDowaJAPAN
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIETNAM
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)
TinEstanho de Rondonia S.A.BRAZIL
TinFenix MetalsPOLAND
TinGejiu City Fuxiang Industry and Trade Co., Ltd.” 
TinGejiu Fengming Metallurgy Chemical PlantCHINA
TinGejiu Kai Meng Industry and Trade LLCCHINA
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINA
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINA
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINA
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINA
TinGuanyang Guida Nonferrous Metal Smelting PlantCHINA
TinHuiChang Hill Tin Industry Co., Ltd.CHINA
TinHuichang Jinshunda Tin Co., Ltd.CHINA
TinJiangxi New Nanshan Technology Ltd.CHINA
TinMa'anshan Weitai Tin Co., Ltd.CHINA
TinMagnu's Minerais Metais e Ligas Ltda.BRAZIL
TinMalaysia Smelting Corporation (MSC)MALAYSIA
29



MetalSmelter NameSmelter Country
TinMelt Metais e Ligas S.A.BRAZIL
TinMetallic Resources, Inc.UNITED STATES OF AMERICA
TinMetallo Belgium N.V.BELGIUM
TinMetallo Spain S.L.U.SPAIN
TinMineracao Taboca S.A.BRAZIL
TinMinsurPERU
TinMitsubishi Materials CorporationJAPAN
TinModeltech Sdn BhdMALAYSIA
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIETNAM
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILAND
TinO.M. Manufacturing Philippines, Inc.PHILIPPINES
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)
TinPongpipat Company LimitedMYANMAR
TinPrecious Minerals and Smelting LimitedINDIA
TinPT Artha Cipta LanggengINDONESIA
TinPT ATD Makmur Mandiri JayaINDONESIA
TinPT Mitra Stania PrimaINDONESIA
TinPT Refined Bangka TinINDONESIA
TinPT Timah Tbk KundurINDONESIA
TinPT Timah Tbk MentokINDONESIA
TinResind Industria e Comercio Ltda.BRAZIL
TinRui Da HungTAIWAN, PROVINCE OF CHINA
TinSoft Metais Ltda.BRAZIL
TinSuper LigasBRAZIL
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIETNAM
TinThaisarcoTHAILAND
TinTin Technology & RefiningUNITED STATES OF AMERICA
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIETNAM
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZIL
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINA
TinYunnan Tin Company LimitedCHINA
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINA
TungstenA.L.M.T. Corp.JAPAN
TungstenACL Metais EireliBRAZIL
TungstenAsia Tungsten Products Vietnam Ltd.VIETNAM
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINA
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINA
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINA
TungstenFujian Ganmin RareMetal Co., Ltd.CHINA
TungstenFujian Jinxin Tungsten Co., Ltd.CHINA
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINA
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINA
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINA
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINA
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICA
30



MetalSmelter NameSmelter Country
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINA
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANY
TungstenH.C. Starck Tungsten GmbHGERMANY
TungstenHunan Chenzhou Mining Co., Ltd.CHINA
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiCHINA
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINA
TungstenHunan Litian Tungsten Industry Co., Ltd.CHINA
TungstenHydrometallurg, JSCRUSSIAN FEDERATION
TungstenJapan New Metals Co., Ltd.JAPAN
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINA
TungstenJiangxi Dayu Longxintai Tungsten Co., Ltd.CHINA
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINA
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINA
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINA
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINA
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINA
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATION
TungstenKennametal FallonUNITED STATES OF AMERICA
TungstenKennametal HuntsvilleUNITED STATES OF AMERICA
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OF
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINA
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINA
TungstenMasan Tungsten Chemical LLC (MTC)VIETNAM
TungstenMoliren Ltd.RUSSIAN FEDERATION
TungstenNiagara Refining LLCUNITED STATES OF AMERICA
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINES
TungstenTejing (Vietnam) Tungsten Co., Ltd.VIETNAM
TungstenUnecha Refractory metals plantRUSSIAN FEDERATION
TungstenWolfram Bergbau und Hutten AGAUSTRIA
TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OF
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINA
TungstenXiamen Tungsten Co., Ltd.CHINA
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINA
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.CHINA

31



TABLE 9

Countries of Origin4
AndorraGermanyMexicoSweden
ArgentinaGhanaMyanmarSwitzerland
AustraliaGuineaNetherlandsTaiwan, Province Of China
AustriaIndiaNew ZealandTajikistan
BelgiumIndonesiaPapua New GuineaTanzania
Bolivia (Plurinational State Of)ItalyPeruThailand
BrazilJapanPhilippinesTurkey
BurundiKazakhstanPoland
Uganda5
CanadaKorea, Republic OfRussian Federation
United Arab Emirates6
ChileRwandaUnited States Of AmericaChina
KyrgyzstanSaudi ArabiaUzbekistanCzechia
LithuaniaSingaporeVietnamDemocratic Republic Of The Congo
Macedonia, The Former Yugoslav Republic OfSouth AfricaZambiaEstonia
MalaysiaSpain
Zimbabwe7
France
Mali
Sudan8




4 Microchip’s Countries of Origin and Reason to Believe Countries of Origin list as provided by the best of our ability.
5 Please refer to Section 3.3, of this Conflict Minerals Report for the discussion of due diligence and removal action taken against African Gold Refinery, the only reported smelter in Uganda.
6 Please refer to Section 3.3, of this Conflict Minerals Report for the discussion of due diligence and removal action taken against Dijllah Gold Refinery FZC, Fujairah Gold, and International Precious Metal Refiners.
7 Please refer to Section 3.3, of this Conflict Minerals Report for the discussion of due diligence and removal action taken against Universal Precious Metals Refining Zimbabwe, the only reported smelter in Zimbabwe.
8 Please refer to Section 3.3, of this Conflict Minerals Report for the discussion of due diligence and removal action taken against Sudan Gold Refinery, the only reported smelter in Sudan.
32



Caution Concerning Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Such forward-looking statements include the statements that continued growth and influence of conflict minerals programs around the world and Microchip's diligent work during our annual RCOI will yield greater supply chain transparency over time, we are working toward a goal to ensure our products are manufactured and/or sourced from socially responsible supply chains, that we plan to engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that support conflict in the DRC and the steps set forth in Section 5 that we intend to take to improve the due diligence conducted. We also use words such as "anticipate," "believe," "plan," "expect," "future," "intend" and similar expressions to identify forward-looking statements. All forward-looking statements involve risk and uncertainty. Our actual results could differ materially from the results anticipated in these forward-looking statements for a number of reasons including changes in our supply chain, our ability or inability to obtain an adequate supply of materials from current or alternative suppliers and the cost of such materials, the level of cooperation we receive from our suppliers with respect to our further due diligence, changes in regulations in the U.S. or other countries (including the Covered Countries), or changes in political or economic conditions in the U.S. or other countries (including the Covered Countries). For a detailed discussion of these and other risk factors, please refer to Microchip's filings on forms 10-K and 10-Q. You can obtain copies of Forms 10-K and 10-Q and other relevant documents for free at Microchip's website (www.microchip.com) or the SEC's website (www.sec.gov) or from commercial document retrieval services. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. 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. You should not place undue reliance on these forward-looking statements. We disclaim any obligation to update information contained in any forward-looking statement.
33