EX-1.01 2 cy18cmrex101.htm EXHIBIT 1.01 Exhibit

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PLANTRONICS, INC. CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2018
Introduction

This Conflict Minerals Report for the calendar year ended December 31, 2018 (“CY 2018”) is presented by Plantronics, Inc. (“we” or the “Plantronics”) to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Exchange Act”).

Plantronics is a global company that manufactures and contracts to manufacture communications headsets and related equipment, as listed on our Form SD of which this report is a part, from a global supply chain with many levels. We work with our supplier base to identify the facilities processing Tin, Tantalum, Tungsten and Gold (3TG) in our supply chain.

As part of the RCOI described in Form SD, Plantronics performed a supplier survey using the Responsible Minerals Initiative (RMI) Conflict Minerals Reporting Template (CMRT) during the second half of CY 2018. Fifty-six (56) direct first tier suppliers providing components used in Plantronics products within scope of the rule as described further in the Form SD were included in the survey utilized for both RCOI and Due Diligence. The information obtained in the survey indicated that there was reason to believe that a portion of the 3TG used in Plantronics products may have originated in the Democratic Republic of Congo or the adjoining countries (the “covered countries”) and were not exclusively from scrap or recycled sources, triggering the due diligence steps described in the following sections.

Design and Execution of Due Diligence

We first designed and implemented the majority of our due diligence measures in preparation for the reporting year CY 2013 with incremental modifications we have made over time to improve and refine the process, such as implementing supplier survey software and onsite supplier audits. These measures were continued in CY 2018 and are described herein. They are designed to conform, in all material respects, to the framework in The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD 2016) including the Supplement on Tin, Tantalum and Tungsten, as well as those portions of the OECD Supplement on Gold applicable to downstream companies (collectively the “OECD Guidance”). In accordance with the five step OECD Guidance, our measures are designed to determine, to the best of our ability, the source of the 3TG materials necessary for the functionality and/or production of our products, to ascertain if the materials originated in one of the covered countries, and if so, whether armed groups directly or indirectly benefited as a result.

1.
Establish Strong Company Management Systems

a.
Plantronics has a company Conflict Minerals team consisting of senior representatives from Quality (Senior Director, Quality Excellence), Operations/Materials (Procurement Director, NPD and Sr. Global Supply Manager), Legal (VP, Deputy General Counsel), Compliance (Senior Director, Compliance), and members of their staffs.

b.
Plantronics has a conflict minerals policy statement publicly available at: www.plantronics.com/conflictminerals.

c.
We maintain a grievance reporting system open to both employees and suppliers through our ethics reporting system at www.plantronics.com/conflictminerals. Alternatively, grievances specifically relating to Conflict Minerals may be submitted directly to RMI at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.

d.
In addition to any annual survey using the CMRT, supplier obligations and requirements in this regard have been incorporated into the Supplier Code of Conduct, which is available on the corporate governance section of our website.



In addition, Conflict Minerals Requirements, including due diligence and participation in annual supplier survey, are included in our controlled “Purchasing & Supplier Management” methods and procedures document.

e.
Plantronics purchase orders and contracts include a supplier Conflict Minerals Due Diligence expectations clause.

f.
Plantronics establishes and maintains long term relationships with the majority of our first tier Original Design, Contract, and Custom Part Manufacturers to facilitate engagement with suppliers to improve due diligence performance.

g.
Since we have limited direct relationships with any facilities processing 3TG, we are an active participant in the Responsible Minerals Initiative (RMI) (http://www.responsiblemineralsinitiative.org/about/members-and-collaborations/) to aid the development of conflict free supply chains at the SOR level and further upstream.

h.
Conflict Minerals materials records are maintained pursuant to our records retention policy.

i.
The formal Quarterly Compliance report includes a section providing conflict minerals program progress and findings to upper management.

j.
We created a controlled Methods and Procedures document regarding Conflict Minerals Due Diligence Procedures.

k.
Since CY 2014 we have used a software tool to improve management and auditability of supplier communications, as well as to request, receive, evaluate, store, and determine statistics on incoming CMRTs. The software is linked to the RMI database and is regularly updated regarding SOR operational status, conformance to third party audit standards, as well as RCOI information.

l.
Starting in CY 2015 our supplier quality team has conducted Conflict Minerals Ongoing Compliance surveys of selected first tier suppliers’ conflict minerals due diligence programs. Suppliers are selected based on the criticality of components to Plantronics products and the amount of 3TG likely present and the number of 3TG processing facilities in their supply chain, based on previous years’ surveys. These suppliers are primarily Original Design Manufacturers (ODMs) and cable or transducer suppliers. These surveys assess policy, training, record retention and data validation.

In 2018 five (5) surveys of existing suppliers were performed and three (3) of the surveys found supplier deficiencies which were addressed by corrective action plans, two (2) of which were successfully completed and the third is in progress. In addition, nine (9) potential new suppliers being considered for components or products potentially containing 3TG also underwent the required Conflict Minerals Compliance Survey to be approved.

2.
Identified and Assessed Risk in the Supply Chain

Prior to and during CY 2018 we conducted face to face one-on-one training as well as teleconference training with newly qualified critical component or product suppliers. Training was primarily focused on ensuring a complete SOR list by proper scoping of products and components to identify all likely locations of 3TG, including parts and components purchased by the 1st tier supplier.

We conducted a supplier survey of the fifty-six (56) direct first tier suppliers providing products or components within scope of the rule; necessary for the functionality of our products and likely to contain 3TG. The survey required that the supplier return the current version of the CMRT (5.1x or higher). Our request included information to inform the suppliers of Plantronics’ reporting obligations under the Conflict Minerals Rule as well as the assistance required from our supply chain, and the resulting expectations for the sourcing of conflict minerals. A link to the Plantronics’ Conflict Minerals policy was included in the request.

Reminders, late notices and delinquent notices were sent to non-responsive suppliers. Commodity Managers were involved in escalation at the time of the delinquent notices. We have not found it necessary to restrict business or disengage from any currently active suppliers due to failure to respond to the survey at this point. There may be potential corrective actions pending.

All incoming CMRTs underwent a two-step review process. The first step is a PASS/FAIL check by our Conflict Minerals software for completeness and internal consistency of the declaration and submitted SOR list. A message



was automatically sent by the software system to suppliers submitting CMRTs containing errors, with an explanation of the error and a request for corrective action and re-submission.

In addition to direct suppliers, we used a data mining service to obtain conflict minerals information, also using the RMI CMRT, from thirty-five (35) manufacturers of critical and high usage off-the-shelf components with whom we had no direct relationship.

Once CMRTs passed this first evaluation, they were then evaluated by internal compliance engineers on an ACCEPT/MODIFY basis for consistency with the known content and complexity of the products or components provided. A message was sent to suppliers submitting CMRTs found insufficient or incomplete with an explanation and request for corrective action. We continued to communicate with those suppliers to improve the content and quality of their responses. Greater than ninety percent (90%) of the suppliers responded by returning a CMRT, and eventually ninety-eight percent (98%) of those responses were accepted after review and, in some cases, correction.

Eighty-six (86) of the ninety-one (91) CMRTs (some suppliers provided more than one product level CMRT) reported that all SORs in their supply chain were included. Seventy (70) of the CMRTs indicated covered country sourcing of at least one metal.

Facilities processing 3TG reported by our supply chain are categorized, based on information available through RMI, as
SORs eligible to participate in a recognized audit program.
Entities determined to not be eligible, active SORs during the reporting period
Entities alleged to be SORs, whose business could not be determined during the reporting period.

In addition to SORs known to, or believed to possibly, source from the covered countries and who were not validated as conflict free, Plantronics believes non-eligible, alleged and non-responsive SORs declining to participate in any audit program as a source of risk, since the actual source of the 3TG is not known.

3.
Designed and Implemented a Strategy to Respond to Identified Risks

We have previously conducted research into “alleged” SORs - companies reported that were not on any list of known SORs- reported in our supplier survey to determine the nature of these entities’ business. This effort was done both through collaborative efforts in RMI, and our own independent research in areas where we have associates that speak the local language. Through these efforts the final number of “alleged” SORs has been significantly reduced progressively from the number in previous reporting years, from eighty-three (83) in CY 2013 to forty-six (46) in CY 2014 to none in CY 2015, CY 2016, and CY 2017 final survey results. No alleged SORs were reported in this year’s survey. This is attributable to determining that many of the alleged SORs were indeed legitimate SORs or legitimate SOR aliases, or determination of the company’s actual business, as well as improved supplier reporting.

The only SORs reported this year that were not active, eligible SORs were fourteen (14) that had previously been on the CMRT SOR list and had either ceased operations or changed their business type. We gave feedback concerning the actual reason for removal, such as timing of ceased operations as this information was available through RMI.

We are members and active participants in RMI and a number of working groups, including Due Diligence Practices, SOR Engagement (SET), China SET, and SOR Disposition teams and work within these teams to determine the legitimacy of “alleged SORs” reported by our supply chain or other RMI members as well as conducting outreach in coordination with RMI to encourage legitimate SORs reported by our supply chain that have not been validated as DRC conflict free by a recognized conflict free program such as Responsible Minerals Assurance Process, London Bullion Market Association, Responsible Jewellry Council or TI-CMC, to enter such a program. Plantronics associates attended China Gold Congress as part of RMI team to speak directly with attending China Gold refiners.

We require that suppliers provide information regarding all sources of 3TG in their supply chain. We review this information for accuracy and consistency. We request further information when a response is considered insufficient. We inform suppliers of potential high risk SORs in their supply chain, and request confirmation of the SORs’ presence and possible disengagement.




4.
Carry out independent 3rd Party Audit of SORs’ Due Diligence Practices

Because Plantronics has few direct business relationships with SORs, we worked within industry initiatives to implement validation of DRC conflict free SORs as outlined in OECD Guidance for downstream companies. We relied on the results of audits conducted by RMAP and cross-recognized programs London Bullion Market Association (LBMA) and Responsible Jewelry Council -(RJC) to determine SORs’ Due Diligence Practices.

5.
Report Annually on Supply Chain Due Diligence

Our Form SD and this Report together constitute 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.

Results of due diligence performed

Most of our direct supplier responses represented their supply chain at a company-level rather than being product specific. Therefore, the list of processing facilities contained in this report may contain more facilities than those that actually process the conflict minerals contained in our products. The total number of unique entities reported as SORs by the Plantronics supplier base as result of CY 2018 Supplier Survey was three hundred twenty-four (324). Of these, three hundred seven (307) have been confirmed as being legitimate operating SORs by RMI., fourteen are known to not be operational SORs during CY 2018, and there were no reported entities whose status could not be confirmed as of our cutoff date of May 01, 2019.

Of the three hundred seven legitimate SORs reported by the supplier base, two hundred fifty-five had been validated as being in conformance with an RMI cross-recognized conflict free audit protocol (RMAP, London Bullion Market Association, or Responsible Jewelry Council). Another five were actively engaged in the process, in communication with RMAP, or participating in another cross-recognized program, but had not achieved conformant status as of May 22, 2019.

Forty-seven eligible reported SORs are not participating in a compliance scheme and have status of:
Outreach required: Twenty- nine (29) have not yet been convinced to participate in any audit program., but efforts to encourage them should continue.
Communication Suspended (not interested): seven (7) have stated clearly that they do not want to participate.
Non-conformant: five (5) do not conform, failed audit, previously conformant, but did not complete re-audit or corrective action in a timely manner.
Due Diligence required: six (6) there may be issues other than DRC conflict involved.

Fourteen (14) entities were reported by our supply chain that are not currently considered eligible. These SORs had all been classified as operating SORs and listed on the CMRT at some time. They were reclassified by RMI due to either a change in their business operations or having either temporarily or permanently suspended operations. These are not included on the Smelter list.

The remaining SORs that are not conformant as yet require outreach to encourage participation in a conflict free program. Plantronics actively participates in RMI targeted outreach through email and, in countries where we have associates that speak the local language, telephone calls.

Of the three hundred seven legitimate SORs reported by the supplier base, we determined during RCOI that there was no reason to believe that one hundred fifty-four of the SORs sourced or may have sourced any minerals from the covered countries.

Of the remaining SORs with definitive RCOI information available through RMI or other publicly available information, twenty-three (23) were known or reasonably believed to directly or indirectly source minerals from the DRC, the surrounding countries or countries known as possible routes for smuggling or export of minerals out of the DRC. All twenty-three (23) are RMAP Conformant. The facilities not eliminated during RCOI, along with the location of the facility and the conflict free status are listed in Table I. All countries believed to be the source of 3TG in our products during 2018 are listed in Table II.

The percentage of SORs reported by our supply chain that have been validated as conformant to a recognized program has increased year over year



Smelters and Refiners Reported by Our Supply Chain by Year
Calendar Year
Total Eligible
Total Conformant
% Conformant
2014
159
76
47.80%
2015
299
214
71.57%
2016
336
246
73.21%
2017
320
250
78.13%
2018
324
255
78.70%

The SOR information collected from our suppler base continued to include a number of eligible SORs that had not been audited and validated as conformant by the RMAP, or any other cross recognized program. The existence of such facilities in our supply chain is sufficient to prevent us from declaring with certainty that no armed groups directly or indirectly benefitted as a result of the mining, transport for processing of 3TG in our products. For these reasons, we are unable to determine that any of our products or product categories are DRC Conflict Free.

From CY 2017 to the present, Plantronics has become of aware of OECD Annex II or other risks in the 3TG supply chain unrelated to financing conflict in the DRC and adjoining countries. These risks include, but are not limited to, material sourced in conflict risk areas other than the DRC, SORs in countries under sanction or wholly or partially owned by individuals under sanction, or securing raw materials from sanctioned entities. Other concerns are child or forced labor and money laundering. There are some SORs on CY 2018 SOR list that will require further due diligence.

Two (2) United States sanctioned gold refiners were listed on the CMRTs from three (3) suppliers in our supply chain. We requested that they confirm the presence of those SORs in their supply chain and if they were, to inform us of their actions to disengage from them. These refiners were previously conformant to LBMA, but were removed after sanctions were imposed in April of 2018.

There are two (2) gold refiners involved in media and NGO reports of possible involvement with smuggled DRC gold. One of these was reported in one instance in our supply chain. We have asked that supplier to disengage from that refiner.

There are four (4) other reported SORs on the SOR list that are in RMI Due Diligence status. We have also informed suppliers reporting these SORs of that status with a request for more information.

Of the eight higher risk SORs, none were reported by more than four different suppliers.

Steps to be taken to further mitigate risk

We intend to take the following steps where possible to build on momentum established in previous years to improve the due diligence conducted, and to further mitigate the risk that the necessary conflict minerals in our products benefit armed groups in the Covered Countries or facilitate any other types of human rights violations.

In coordination with RMI, engage directly with selected SORs to help guide them through the RMAP audit process by participating a pre-audit visit. To the extent possible, attend metals industry conferences in conjunction with RMI to use direct contact to encourage participation in validation schemes. As gold appears to exhibit the highest risk in multiple risk categories, focus outreach and due diligence efforts on gold refiners.

Take advantage of added RMI resources by adding a link on our website to RMI conflict minerals specific grievance system in addition to the existing PLT company grievance system and utilize RMI incident reporting tool to evaluate risk and red flags in upstream supply chain.

Strongly encourage our supply chain to source only from conformant SORs, in particular those sourcing responsibly within the DRC and adjoining countries, to the greatest extent possible.

Work with our supply chain to reduce or discontinue sourcing materials from SORs that have consistently refused to participate in any conflict free programs, or SORs that have failed audits or declined to undergo re-audits.




Implement procedures to facilitate removal of SORs considered high risk for reasons other than DRC conflict; US or other sanctions or OECD Annex II issues.

Table I. Plantronics SOR List

The list of reported SORs and status is as of May 22, 2019. RCOI data from RMI is as of March 29, 2019. The list includes one hundred and fifty-three (153) SORs that are either known to obtain at least some minerals from the covered countries or are SORs where the source of the minerals was not disclosed and could not be determined. Gold refiners validated as conformant through LBMA or RJC are included in this list, since they are not required to disclose the country of origin of their minerals. The list does not include those SORs that source only from outside the covered countries as determined through RCOI, or process only recycled or scrap materials. As the majority of our suppliers responded to surveys at a company level rather than with respect to specific products, and due to the complexity of the electronics supply chain, as well as the diversity of both our products and our suppliers’ products, we cannot conclude with certainty that material from all of the SORs reported by our supply chain and included in this report are actually contained in Plantronics’ products.

“Country” refers to the location of the facility, not the source of minerals. The SOR location was not used for RCOI, since it does not necessarily determine the source of the ore, although SOR location near abundant mineral resources can be an indicator of mineral sourcing.

Status is defined as:

Conformant: SORs that have been audited and have been validated as compliant with the RMAP SOR Program or cross recognized (LBMA, RJC) assessment protocols. This includes SORs that were compliant as of 12/31/2018 as well as SORs that have completed audits and become conformant in 2019 prior to this report.

Active or In Communication: On RMI Active list or in communication with RMI. SORs on the Active list have committed to undergo a CFSP audit.

Outreach Required or Not Interested: Thirty-six (36) eligible SORs who have not yet completed a CFSP or cross recognized audit validating a conflict free process. This status includes some SORs indicating that they do not want to participate in a recognized validation system. Many claim the reason to be that they process only scrap or ore from their own mines and do not source ore from the covered countries. While this may be true, with no audit for verification, they are considered as “may source from covered countries”.

Non-Conformant: Five (5) SORs that failed RMAP audit, did not complete audit or re-audit corrective actions in the allotted time, or have previously been audited and have been conformant with the RMAP SOR Program or cross recognized (LBMA, RJC) assessment programs, but have not undergone a re-audit within the required time frame.

Due Diligence Required: Six (6) audit eligible SORs cannot be currently audited until concerns regarding sanctions or suspension from metals exchanges are resolved.

TABLE I
Metal
Smelter Name
Country
SOR ID
Status
Gold
Kazzinc
KAZAKHSTAN
CID000957
CONFORMANT
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
CID000969
CONFORMANT
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
CONFORMANT
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
CONFORMANT
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
CONFORMANT
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
CONFORMANT
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
CONFORMANT
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
CONFORMANT
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
CONFORMANT
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
CID001157
CONFORMANT



Metal
Smelter Name
Country
SOR ID
Status
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
CID001161
CONFORMANT
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
CONFORMANT
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
CONFORMANT
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
CONFORMANT
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
CONFORMANT
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
CONFORMANT
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
CID001220
CONFORMANT
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
CONFORMANT
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
CONFORMANT
Gold
PX Precinox S.A.
SWITZERLAND
CID001498
CONFORMANT
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
CONFORMANT
Gold
PAMP S.A.
SWITZERLAND
CID001352
CONFORMANT
Gold
Aurubis AG
GERMANY
CID000113
CONFORMANT
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
CONFORMANT
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
CONFORMANT
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
CONFORMANT
Gold
Boliden AB
SWEDEN
CID000157
CONFORMANT
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
CONFORMANT
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
CONFORMANT
Gold
Istanbul Gold Refinery
TURKEY
CID000814
CONFORMANT
Gold
Japan Mint
JAPAN
CID000823
CONFORMANT
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
CONFORMANT
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
CONFORMANT
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
CONFORMANT
Gold
Cendres + Metaux S.A.
SWITZERLAND
CID000189
CONFORMANT
Gold
Chimet S.p.A.
ITALY
CID000233
CONFORMANT
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
CONFORMANT
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
CID000920
CONFORMANT
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
CONFORMANT
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
CONFORMANT
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
CONFORMANT
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
CONFORMANT
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
CONFORMANT
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
CID000058
CONFORMANT
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
CONFORMANT
Gold
Asahi Pretec Corp.
JAPAN
CID000082
CONFORMANT
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
CONFORMANT
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
CONFORMANT
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
CONFORMANT
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
CONFORMANT
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
CID001761
CONFORMANT



Metal
Smelter Name
Country
SOR ID
Status
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
CONFORMANT
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
CONFORMANT
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
CONFORMANT
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
CONFORMANT
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
CONFORMANT
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
CONFORMANT
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
CONFORMANT
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
CONFORMANT
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
CONFORMANT
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
CONFORMANT
Gold
Royal Canadian Mint
CANADA
CID001534
CONFORMANT
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
CID001585
CONFORMANT
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
CONFORMANT
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
CONFORMANT
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
CONFORMANT
Gold
Valcambi S.A.
SWITZERLAND
CID002003
CONFORMANT
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
CID002030
CONFORMANT
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
CID002560
CONFORMANT
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
CONFORMANT
Gold
T.C.A S.p.A
ITALY
CID002580
CONFORMANT
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
CONFORMANT
Gold
SAAMP
FRANCE
CID002761
CONFORMANT
Gold
L'Orfebre S.A.
ANDORRA
CID002762
CONFORMANT
Gold
Italpreziosi
ITALY
CID002765
CONFORMANT
Gold
Safimet S.p.A
ITALY
CID002973
CONFORMANT
Gold
Bangalore Refinery
INDIA
CID002863
CONFORMANT
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
CONFORMANT
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002511
ACTIVE
Gold
Chugai Mining
JAPAN
CID000264
ACTIVE
Gold
NH Recytech Company
KOREA, REPUBLIC OF
CID003189
ACTIVE
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
IN COMMUNICATION
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
IN COMMUNICATION
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID003153
OUTREACH REQUIRED
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID002865
OUTREACH REQUIRED
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
OUTREACH REQUIRED
Gold
Pease & Curren
UNITED STATES OF AMERICA
CID002872
OUTREACH REQUIRED
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
OUTREACH REQUIRED
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
OUTREACH REQUIRED
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
OUTREACH REQUIRED
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
OUTREACH REQUIRED
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
OUTREACH REQUIRED
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
CID000773
OUTREACH REQUIRED



Metal
Smelter Name
Country
SOR ID
Status
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
OUTREACH REQUIRED
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
OUTREACH REQUIRED
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
OUTREACH REQUIRED
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000651
OUTREACH REQUIRED
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
OUTREACH REQUIRED
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID000522
OUTREACH REQUIRED
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
CID001546
OUTREACH REQUIRED
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
OUTREACH REQUIRED
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
CID003324
OUTREACH REQUIRED
Gold
Sudan Gold Refinery
SUDAN
CID002567
OUTREACH REQUIRED
Gold
African Gold Refinery
UGANDA
CID003185
OUTREACH REQUIRED
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002852
OUTREACH REQUIRED
Gold
Sai Refinery
INDIA
CID002853
OUTREACH REQUIRED
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
CID000778
NOT INTERESTED
Gold
Morris and Watson
NEW ZEALAND
CID002282
NOT INTERESTED
Gold
Caridad
MEXICO
CID000180
NOT INTERESTED
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
CID001562
NOT INTERESTED
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
CID002854
NOT INTERESTED
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
DUE DILIGENCE REQUIRED
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
DUE DILIGENCE REQUIRED
Gold
SAFINA A.S.
CZECHIA
CID002290
DUE DILIGENCE REQUIRED
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
DUE DILIGENCE REQUIRED
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
DUE DILIGENCE REQUIRED
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
DUE DILIGENCE REQUIRED
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Non-CONFORMANT
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Non-CONFORMANT
Gold
Tony Goetz NV
BELGIUM
CID002587
Non-CONFORMANT
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
CID002708
Non-CONFORMANT
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
CONFORMANT
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
CONFORMANT
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
CONFORMANT
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
CONFORMANT
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
CONFORMANT
Tantalum
Taki Chemical Co., Ltd.
JAPAN
CID001869
CONFORMANT
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
CONFORMANT
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
CONFORMANT
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
CONFORMANT
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
CONFORMANT
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
CONFORMANT



Metal
Smelter Name
Country
SOR ID
Status
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
CID002557
CONFORMANT
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
CID002847
CONFORMANT
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
CONFORMANT
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
CONFORMANT
Tin
PT Tirus Putra Mandiri
INDONESIA
CID002478
CONFORMANT
Tin
Thaisarco
THAILAND
CID001898
CONFORMANT
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
CONFORMANT
Tin
Pongpipat Company Limited
MYANMAR
CID003208
OUTREACH REQUIRED
Tin
Estanho de Rondonia S.A.
BRAZIL
CID000448
OUTREACH REQUIRED
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
OUTREACH REQUIRED
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
OUTREACH REQUIRED
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
OUTREACH REQUIRED
Tin
Super Ligas
BRAZIL
CID002756
OUTREACH REQUIRED
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC
VIET NAM
CID002572
Non-CONFORMANT
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
CONFORMANT
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
CONFORMANT
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
CID000568
CONFORMANT
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
CID002044
CONFORMANT
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
CID002543
CONFORMANT
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
CID002589
CONFORMANT
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313
NOT INTERESTED

TABLE II

The Countries of Origin for the minerals present in Plantronics products are believed to potentially include, but may not be limited to, the following. Information is from RMI SORs, news reports, industry associations, metals brokers’ reports, and USGS reports (Countries listed for 3T are reported to account for ~98% of global mined ore). Data also checked for plausibility against RMI known countries from which conformant 3TG SORs source information was included in RMI RCOI reports.

Tungsten: Democratic Republic of Congo, Burundi, Rwanda, China, Vietnam, Russia, Canada, Bolivia, Australia, Austria, Spain, Portugal, United States, DRC, Mexico, Mongolia, Uzbekistan, Uganda

Tantalum Democratic Republic of Congo, Rwanda, Burundi, Brazil, Mozambique, China, Nigeria, Australia, Uganda, Bolivia, Colombia, Mongolia, Nigeria, Portugal, Russia, Spain, Mozambique

Tin: Bolivia, Brazil, Myanmar, China, Indonesia, Peru, Australia, Democratic Republic of Congo, Malaysia, Nigeria, Rwanda, Vietnam, Burundi, Mongolia, Niger, Portugal, Russia, Tanzania, Thailand, Uganda

Gold: China, Australia, Russia, United States, Peru, Canada, South Africa, Mexico, Uzbekistan, Ghana, Brazil, Papua New Guinea; Democratic Republic of Congo, Kazakhstan, Argentina, Tanzania, Mali, Dominican Republic, Columbia, Philippines Chile, Burkina Faso, Ivory Coast, Mongolia, Turkey, Guinea, Senegal, Togo