Delaware | 1-12696 | 77-0207692 |
(State or Other Jurisdiction of Incorporation) | (Commission file number) | (I.R.S. Employer Identification No.) |
Not Applicable |
(Former name or former address, if changed since last report) |
S | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013. |
Exhibit Number | Description |
Date: June 2, 2014 | PLANTRONICS, INC. | ||
By: | /s/ Pamela Strayer | ||
Name: | Pamela Strayer | ||
Title: | Senior Vice President and Chief Financial Officer |
1. | Overview |
2. | Due Diligence |
3. | Due Diligence Performed |
1. | Established Strong Company Management Systems |
• | We formed a Conflict Minerals team consisting of representatives from the Compliance, Legal, Operations/Materials, Quality, and Supplier Quality Engineering departments. |
• | We adopted and posted a company conflict minerals policy statement publicly available at http://www.plantronics.com/us/company/corporate-governance/conflict-minerals.jsp. |
• | We maintain a grievance reporting system open to both employees and suppliers. |
• | Since our supply chain is complex, with multiple tiers between us and the facilities processing the minerals, we developed data gathering and assessment procedures for all approved manufacturers of purchased components, and we rely on our suppliers to identify those facilities in our supply chain. Since we do not have direct relationships with those facilities, we are an active participant in the Conflict Free Sourcing Initiative ("CFSI") to aid in the development of conflict free supply chains upstream of the smelter or refiner level. |
• | We added relevant conflict minerals materials to our record retention policy. |
2. | Identified and Assessed Risk in the Supply Chain |
• | We did a material content assessment of our first tier suppliers (i.e., direct suppliers) and engaged those whose products we believed may contain conflict minerals. We conducted a first round of data collection in the fourth quarter of 2012 using the EICC-GeSI CMRT. We received responses from 153 of 155 suppliers in scope. The responses confirmed that some of the minerals were sourced from within the DRC, adjoining countries, and countries outside the area, or were recycled and scrap. |
• | We then ranked suppliers by annual spend, number of components supplied, and geographic location to prioritize higher risk. We identified 34 suppliers who accounted for in excess of 95% of our costs for parts and components containing 3TG during 2013. We continued to work with those suppliers to improve the quality of their responses to determine whether the conflict minerals in components contained in our products were or were not DRC Conflict Free (as defined in Section 1, Item 1.01(d)(4) of Form SD). We used the CMRT to obtain information concerning the facilities (smelter or refiner) used to process their conflict minerals from all of the targeted suppliers. We used the responses from the suppliers and a data mining service to provide conflict minerals information. We also used the CMRT from 20 off-the-shelf component manufacturers, accounting for 80% of greater than 15,000 component part numbers on our Approved Parts List. |
• | By the end of calendar year 2013, the results of the survey still showed a disparity in the levels of due diligence within our supply chain. However, the quality of the smelter lists improved markedly by the end of the reporting period. Our supply chain reported a total of 177 recognized facilities providing 3TG materials. Sixty-seven of these facilities have been validated by the Conflict Free Smelter Program ("CFSP") as DRC Conflict Free as of May 5th, 2014. These 67 facilities were found to source materials from within the DRC, within the adjoining countries, outside the covered countries, from recycled or scrap materials, or the source was not disclosed. In addition there were a number of entities that could not be confirmed as true smelters or refiners, as well as some entities that were confirmed as not true smelters or refiners. We have not been able to verify that materials from all of these processing facilities are actually in our products, since most of the CMRTs received were at the company, not the product, level. |
Source of minerals being processed | Total | # CFSP Validated | ||
Sourcing outside covered countries | 25 | 25 | ||
Processing exclusively recycled or scrap materials | 6 | 5 | ||
Sourcing from covered countries | 12 | 12 | ||
Country of origin of materials not disclosed | 134 | 25 | ||
Totals | 177 | 67 |
3. | Designed and Implemented a Strategy to Respond to Identified Risks |
• | The Conflict Minerals team reported progress and findings to upper management on a quarterly basis. |
• | We developed and documented a process of escalation steps to manage suppliers that did not respond or provide required information about the source of conflict minerals or progress implementing their due diligence processes. We did not find it necessary to restrict business or disengage from any supplier. |
• | We added conflict free mineral sourcing requirements to new and renewed purchase order ("PO") agreements and contracts. |
• | We added conflict minerals requirements to new supplier assessment and existing supplier audit procedures. |
• | We added conflict minerals requirements to our Supplier Code of Conduct. |
• | To better communicate the issues and requirements, we conducted in person training with twenty-eight Asian suppliers in Shenzhen, China, following the CFSI workshop in Hong Kong. |
• | We continued to work within CFSI teams to encourage more smelters to participate in CFSP, particularly those we had reason to believe may source minerals from within the covered countries, but were not yet validated as Conflict Free. |
4. | Carry out independent 3rd Party Audit of Smelters’/Refiners’ Due Diligence Practices |
• | We worked within industry initiatives to implement certification of DRC Conflict Free smelters, and relied on the results of audits conducted by the CFSP to determine smelters’ due diligence practices. We actively participated in outreach to validated smelters to encourage participation in the CFSP as an active contributing member of the CFSI. |
5. | Report Annually on Supply Chain Due Diligence |
• | Our Form SD Specialized Disclosure and this Conflict Minerals Report constitutes our annual report on our Conflict Minerals due diligence. These have been filed with the SEC and are available on our website at www.plantronics.com/conflictminerals. |
4. | Steps to be taken to further mitigate risk |
• | Improve the content of suppliers’ responses through continued training and education |
• | Expand the amount of off-the-shelf part manufacturer conflict minerals data |
• | Continue to validate supplier responses using on-site visits, process audits, and document examination |
• | Continue to utilize information provided via independent conflict free smelter validation programs such as the CFSP |
• | Encourage our supply chain to use validated conflict free smelters, in particular those sourcing responsibly within the DRC and adjoining countries, to the greatest extent possible |
• | Continue to participate in CFSI efforts to determine status of entities alleged to be smelters within the supply chain that could not be validated as true smelters or refiners before calendar year 2013 filing |
• | Continue to participate in CFSI smelter outreach efforts to increase the number of CFSP validated Conflict Free Smelters |
CFSP validated as DRC Conflict Free as of May 5, 2014 | ||
METAL | SMELTER OR REFINER NAME | COUNTRY |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
Gold | AngloGold Ashanti Córrego do Sítio Minerção | BRAZIL |
Gold | Argor-Heraeus SA | SWITZERLAND |
Gold | Asahi Pretec Corporation | JAPAN |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
Gold | Dowa | JAPAN |
Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Johnson Matthey Inc | UNITED STATES |
Gold | Johnson Matthey Ltd | CANADA |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Kennecott Utah Copper LLC | UNITED STATES |
Gold | Kojima Chemicals Co., Ltd | JAPAN |
Gold | Materion | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG |
Gold | Metalor Technologies (Singapore) Pte Ltd | SINGAPORE |
Gold | Metalor Technologies SA | SWITZERLAND |
Gold | Metalor USA Refining Corporation | UNITED STATES |
Gold | Mitsubishi Materials Corporation | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Gold | Nihon Material Co. LTD | JAPAN |
Gold | Ohio Precious Metals, LLC | UNITED STATES |
Gold | PAMP SA | SWITZERLAND |
Gold | Royal Canadian Mint | CANADA |
Gold | SEMPSA Joyería Platería SA | SPAIN |
Gold | Solar Applied Materials Technology Corp. | TAIWAN |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
CFSP validated as DRC Conflict Free as of May 5, 2014 (CONTINUED) | ||
METAL | SMELTER OR REFINER NAME | COUNTRY |
Gold | Tokuriki Honten Co., Ltd | JAPAN |
Gold | Umicore Brasil Ltda | BRAZIL |
Gold | Umicore SA Business Unit Precious Metals Refining | BLEGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES |
Gold | Valcambi SA | SWITZERLAND |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
Tantalum | Duoluoshan | CHINA |
Tantalum | Exotech Inc. | UNITED STATES |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | Global Advanced Metals | USE |
Tantalum | H.C. Starck Group | GERMANY |
Tantalum | Hi-Temp | UNITED STATES |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
Tantalum | Kemet Blue Powder | UNITED STATES |
Tantalum | Mitsui Mining & Smelting | JAPAN |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | Plansee | AUSTRIA |
Tantalum | RFH Tantalum Smeltry Co., Ltd | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemicals | JAPAN |
Tantalum | Tantalite Resources | SOUTH AFRICA |
Tantalum | Telex | UNITED STATES |
Tantalum | Ulba | KAZAKHSTAN |
Tantalum | Zhuzhou Cement Carbide | CHINA |
Tin | Alpha | UNITED STATES |
Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | CHINA |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Mineração Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | OMSA | BOLIVIA |
Tin | PT Bukit Timah | INDONESIA |
Tin | Thaisarco | THAILAND |
Tin | Yunnan Tin Company, Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
Not CFSP validated as DRC Conflict Free as of May 5, 2014 | ||
METAL | SMELTER OR REFINER NAME | COUNTRY |
Gold | Aida Chemical Industries Co. Ltd. | JAPAN |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | Asaka Riken Co Ltd | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | Aurubis AG | GERMANY |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
Gold | Boliden AB | SWEDEN |
Gold | Caridad | MEXICO |
Gold | Cendres + Métaux SA | SWITZERLAND |
Gold | Chimet S.p.A. | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daejin Indus Co. Ltd | KOREA, REPUBLIC OF |
Gold | DaeryongENC | KOREA, REPUBLIC OF |
Not CFSP validated as DRC Conflict Free as of May 5, 2014 (CONTINUED) | ||
METAL | SMELTER OR REFINER NAME | COUNTRY |
Gold | Do Sung Corporation | KOREA, REPUBLIC OF |
Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Ltd. Hong Kong | HONG KONG |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Hwasung CJ Co. Ltd | KOREA, REPUBLIC OF |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Company Limited | CHINA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
Gold | JSC Uralectromed | RUSSIAN FEDERATION |
Gold | Kazzinc Ltd | KAZAKHSTAN |
Gold | Korea Metal Co. Ltd | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | L' azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | CHINA |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | CHINA |
Gold | Met-Mex Peñoles, S.A. | MEXICO |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIAN FEDERATION |
Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Précinox SA | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd | SOUTH AFRICA |
Gold | Sabin Metal Corp. | UNITED STATES |
Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF |
Gold | Schone Edelmetaal | NETHERLANDS |
Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | CHINA |
Gold | So Accurate Group, Inc. | UNITED STATES |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | The Great Wall Gold and Silver Refinery of China | CHINA |
Gold | The Refinery of Shandong Gold Mining Co. Ltd | CHINA |
Gold | Tongling nonferrous Metals Group Co.,Ltd | CHINA |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | JAPAN |
Gold | Yokohama Metal Co Ltd | JAPAN |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Gold | Zijin Mining Group Co. Ltd | CHINA |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | King-Tan Tantalum Industry Ltd | CHINA |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | CNMC (Guangxi) PGMA Co. Ltd. | CHINA |
Tin | Cooper Santa | BRAZIL |
Tin | CV Serumpun Sebalai | INDONESIA |
Tin | CV United Smelting | INDONESIA |
Tin | EM Vinto | BOLIVIA |
Tin | Fenix Metals | POLAND |
Tin | Gejiu Zi-Li | CHINA |
Tin | Huichang Jinshunda Tin Co. Ltd | CHINA |
Tin | Jiangxi Nanshan | CHINA |
Tin | Kai Unita Trade Limited Liability Company | CHINA |
Not CFSP validated as DRC Conflict Free as of May 5, 2014 (CONTINUED) | ||
METAL | SMELTER OR REFINER NAME | COUNTRY |
Tin | Linwu Xianggui Smelter Co | CHINA |
Tin | Metallo Chimique | BELGIUM |
Tin | Minmetals Ganzhou Tin Co. Ltd. | CHINA |
Tin | Novosibirsk Integrated Tin Works | RUSSIAN FEDERATION |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT Babel Inti Perkasa | INDONESIA |
Tin | PT Bangka Putra Karya | INDONESIA |
Tin | PT Bangka Tin Industry | INDONESIA |
Tin | PT Belitung Industri Sejahtera | INDONESIA |
Tin | PT DS Jaya Abadi | INDONESIA |
Tin | PT Eunindo Usaha Mandiri | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT Prima Timah Utama | INDONESIA |
Tin | PT REFINED BANGKA TIN | INDONESIA |
Tin | PT Sariwiguna Binasentosa | INDONESIA |
Tin | PT Stanindo Inti Perkasa | INDONESIA |
Tin | PT Tambang Timah | INDONESIA |
Tin | PT Timah (Persero), Tbk | INDONESIA |
Tin | PT Tinindo Inter Nusa | INDONESIA |
Tin | Rui Da Hung | TAIWAN |
Tin | Soft Metais, Ltda. | BRAZIL |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | CHINA |
Tungsten | A.L.M.T. Corp. | JAPAN |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | Guangdong Xianglu Tungsten Industry Co., Ltd. | CHINA |
Tungsten | H.C. Starck Group | GERMANY |
Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Japan New Metals Co., Ltd. | JAPAN |
Tungsten | Kennametal Fallon | UNITED STATES |
Tungsten | Kennametal Huntsville | UNITED STATES |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
Tungsten | Wolfram Company CJSC | RUSSIAN FEDERATION |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA |