0001178913-24-001310.txt : 20240415 0001178913-24-001310.hdr.sgml : 20240415 20240415084222 ACCESSION NUMBER: 0001178913-24-001310 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20231231 1.02 20231231 FILED AS OF DATE: 20240415 DATE AS OF CHANGE: 20240415 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SILICOM LTD. CENTRAL INDEX KEY: 0000916793 STANDARD INDUSTRIAL CLASSIFICATION: COMPUTER COMMUNICATIONS EQUIPMENT [3576] ORGANIZATION NAME: 06 Technology IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-23288 FILM NUMBER: 24843212 BUSINESS ADDRESS: STREET 1: 14 ATIR YEDA ST. CITY: KFAR-SAVA STATE: L3 ZIP: 4464323 BUSINESS PHONE: 97297644555 MAIL ADDRESS: STREET 1: 14 ATIR YEDA ST. CITY: KFAR-SAVA STATE: L3 ZIP: 4464323 FORMER COMPANY: FORMER CONFORMED NAME: SILICOM LTD DATE OF NAME CHANGE: 19940103 SD 1 zk2431284.htm SD

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD
Specialized Disclosure Report

SILICOM LTD.
(Exact name of registrant as specified in its charter)

ISRAEL  
000-23288 N/A
(State or other jurisdiction
(Commission
(IRS Employer
of incorporation or organization)
File Number)
Identification No.)

 14 Atir Yeda Street, Kfar Sava, Israel   

 4464323
 (Address of principal executive offices)
 (Zip Code)

Eran Gilad
Telephone: +972-9-764-4555
(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

☒          Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.

☐          Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the reporting period from January 1 to December 31.


Introduction

This Specialized Disclosure Report on Form SD ("Form SD") of Silicom Ltd. ("Silicom" or "we") for the year ended December 31, 2023, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended ("Rule"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to "conflict minerals" as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. The Rule imposes certain reporting obligations on SEC registrants whose products contain conflict minerals that are necessary to the functionality or production of their products (such minerals are referred to as "necessary conflict minerals"). For products which contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo ("DRC") or an adjoining country, collectively defined as the "Covered Countries." If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals contained in its products originated or may have originated in a Covered Country and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources, the registrant must conduct due diligence on the necessary conflict minerals’ source and chain of custody as a method to conclude if the necessary conflict minerals contained in those products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries. Products which do not contain necessary conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries are considered "DRC conflict free". In addition, conflict minerals that a registrant obtains from recycled or scrap sources are also considered "DRC conflict free."
 
We use the term "conflict free" in this Form SD in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the Covered Countries.
 
Company Overview
 
Silicom Ltd. is an industry-leading provider of high-performance networking and data infrastructure solutions. Designed primarily to improve performance and efficiency in Cloud and Data Center environments, Silicom’s solutions increase throughput, decrease latency and boost the performance of servers and networking appliances, the infrastructure backbone that enables advanced Cloud architectures and leading technologies like NFV, SD-WAN and Cyber Security. Our innovative solutions for high-density networking, high-speed fabric switching, offloading and acceleration, which utilize a range of cutting-edge silicon technologies as well as FPGA-based solutions, are ideal for scaling-up and scaling-out cloud infrastructures.
 
Silicom products are used by major Cloud players, service providers, Telcos and OEMs as components of their infrastructure offerings, including both add-on adapters in the Data Center and stand-alone virtualized/universal CPE devices at the edge.
 
For more information, please visit: www.silicom.co.il
 
Products
 
Our products are comprised of:

(i)          Server network interface cards (Server Adapters) - These adapters are used mostly in networking appliances which are used both in the Cloud (including public cloud and On Premise cloud) and in the Edge.
(ii)         Smart Cards - Intelligent and/or programmable cards, with features such as encryption, Time Synchronization, acceleration, data compression, redirection and switching, packet processing, time stamping, packet capture solutions, ultra-low latency solutions, and other offloading features. These products are used mostly inside servers which are a part of Cloud and Enterprise Data centers or inside Distributed Units and Central Units which are a part of mobile infrastructures.
(iii)        Smart Platforms - (Edge Products) –including virtualized Customer-Premises Equipment (vCPE) and universal Customer-Premises Equipment (uCPE) (together, "CPE"), Edge devices for SD-WAN, SASE, Telco dedicated routers and NFV deployments.
The products detailed above constitute all products and product lines that we manufactured or sub-contracted to manufacture in the 2023 calendar year. Accordingly, we determined that none of our products qualified as DRC conflict free in the 2023 calendar year.

 
Overview of Silicom's Conflict Minerals Program
 
As a product manufacturer, we are knowledgeable about the design of our products, including the materials needed to construct them. We design the manufacturing processes to build those products and in some cases, design the detailed materials to manufacture those products. As a result, we know that conflict minerals (tantalum, tin, tungsten and gold, also referred to as "3TG") are necessary to the functionality or production of all of our products. Conflict minerals are obtained, via our direct suppliers, from sources worldwide, and our desire is not to eliminate those originating in the Covered Countries but rather to obtain conflict minerals from sources that do not directly or indirectly finance or benefit armed groups in the Covered Countries.
 
Conflict Minerals Sourcing Policy
 
Silicom's policy with respect to the sourcing of conflict minerals is as follows: Silicom expects its suppliers to have in place policies and due diligence measures that will enable it to reasonably assure that products and components supplied to it containing conflict minerals are DRC conflict free. Silicom expects its suppliers to comply with the Global e-Sustainability Initiative and with the Responsible Minerals Initiative ("RMI") (formerly the Conflict Free Sourcing Initiative, or CFSI) and conduct their business in alignment with Silicom's supply chain responsibility expectations.
 
In support of this policy, Silicom will:
 
•
exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and will encourage our suppliers to do likewise with their suppliers.
 
•
provide, and expect its suppliers to cooperate in providing, due diligence information to confirm the 3TG in its supply-chain is DRC conflict free.
 
•
collaborate with its suppliers and others on industry-wide solutions to encourage the manufacturing of products that are DRC conflict free.
 
•
commit to transparency in the implementation of this policy by making available reports on its progress to relevant stakeholders and the public.
 
The full text of Silicom's Conflict Minerals Sourcing Policy is available at http://www.silicom-usa.com/conflict-minerals/. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
 
Supply Chain Description
 
Although Silicom's hardware products contain conflict minerals, Silicom does not purchase any conflict minerals directly from mines and is many steps removed in the supply chain from the mining of the conflict minerals. Silicom purchases materials used in its products from its suppliers and some of those materials contribute necessary conflict minerals to its products and/or production process. The origin of conflict minerals cannot be determined with any certainty once the ores are smelted, refined and converted to ingots, bullion or other conflict minerals containing derivatives. The smelters and refiners (sometimes referred to as "facilities") are consolidating points for ore and are in the best position in the total supply chain to know the origin of the ores. Silicom relies on its direct suppliers to assist with its reasonable country of origin inquiry and due diligence efforts, including the identification of smelters and refiners, for the conflict minerals contained in the materials which they supply.
 
During the past several years, we have asked our potential suppliers to provide evidence of being conflict-free, and the presentation of such evidence has become a major consideration in our engagement process with new suppliers.
 
Silicom has well established and structured the process of new supplier approval, when information about conflict minerals is necessary for supplier approval.
 
 
SECTION 1 – CONFLICT MINERALS DISCLOSURE
 
Item 1.01          Conflict Minerals Disclosure and Report
 
Description of Reasonable Country of Origin Inquiry ("RCOI") Efforts
 
Below is a description of Silicom's efforts to determine whether any of the necessary conflict minerals in its products originated in the Covered Countries during 2023.
 
Silicom conducted an analysis of its products and the production process thereof and found that 3TG are used in some of its products.
 
For 2023, Silicom conducted a supply chain survey with all the suppliers and manufacturers from whom it purchases components used in its products in order to obtain country of origin information for the necessary conflict minerals in its products using the Conflict Minerals Reporting Template ("CMRT"), an industry standard template for conflict minerals reporting designed by the RMI. However, as a result of the complexity of Silicom's products and the constant evolution of its supply chain, it is difficult to identify sub-tier suppliers downstream from the direct suppliers and manufacturers from whom Silicom purchases components used in its products ("Suppliers").
 
Suppliers who are relevant for the survey were thoroughly chosen using following process:
 
A list of all suppliers and manufacturers from whom Silicom purchases its products was generated from Silicom's ERP system. The total number of MFRs was 1059.
 
1.
Irrelevant suppliers and manufacturers were then eliminated from the list mentioned above. Irrelevant suppliers and manufacturers are defined as those who (a) do not provide goods, but rather provide services, office supplies, infrastructure services, etc.; (b) do not provide goods that are part of Silicom's products (i.e. packaging); (c) supply components or materials that do not, by their nature, contain 3TG materials (i.e. paper labels, glue, etc.); and (d) inactive suppliers and manufacturers (i.e. suppliers and manufacturers from whom Silicom did not purchase any products in 2023). After such elimination Silicom remained with 180 suppliers and manufacturers.
 
2.
Silicom sent requests to such 180 suppliers and manufacturers that were active suppliers and manufacturers during 2023.

Silicom requested such suppliers and manufacturers to complete a conflict minerals survey, based on the CMRT.
 
All received CMRTs were checked and verified against a list of active and complaint smelters published by the RMI. In the case of non-conformance in the answers delivered by the suppliers and manufacturers in the CMRTs, Silicom contacted suppliers and manufacturers in order to receive updated valid CMRTs.
 
The supply chain survey requested information from the direct suppliers and manufacturers in order to identify the smelters and refiners and countries of origin of the conflict minerals in products they supply to Silicom. Silicom received responses from its suppliers and manufacturers, representing over  99.8% of its total direct spend with its suppliers and manufacturers during 2023. Silicom compared the smelters and refiners identified in the surveys against the lists of facilities that have received a "conflict free" designation by the RMI. Those designations provide country of origin information on the conflict minerals sourced by such facilities (such as third party software providers' databases).
 
 
In the case of non-responsive suppliers and manufacturers, Silicom, through its Sustainability Team, attempted to contact such suppliers and manufacturers by email and telephone at least three times.
 
Suppliers' and manufacturers' responses were examined and the quality and relevance of their answers were verified when required, including by validation of all CMRTs that were provided to Silicom. The goal of data validation was to increase the accuracy of the responses that were provided to Silicom and identify any discrepancies and contradictory answers in the CMRTs.
 
When a smelter or refiner in Silicom's supply chain was not listed as having received a "conflict free" designation, Silicom asked its suppliers and manufacturers to proactively contact such facility and requested country of origin information for the necessary conflict minerals that it processed. In addition, Silicom is taking all measures that it deems fit in order to replace such suppliers and manufacturers with others who are declared as conflict-free. Silicom documented country of origin information for the smelters and refiners identified by the supply-chain survey.
 
There is a significant overlap between Silicom's RCOI efforts and its due diligence measures performed. Silicom's due diligence measures performed were based on the findings of RCOI and are discussed further in the Conflict Minerals Report filed as Exhibit 1.02 hereto.
 
Conflict Minerals Disclosure
 
This Form SD and the Conflict Minerals Report, filed as Exhibit 1.02 hereto, are publicly available at http://www.silicom-usa.com/conflict-minerals/ as well as the SEC’s EDGAR database at www.sec.gov.
 
Item 1.02          Exhibits 
 
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.02 to this Form SD.
 
SECTION 2 – EXHIBITS
 
Item 2.01          Exhibits
 
 
SIGNATURES
 
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
 
Silicom Ltd.
(Registrant)
 
/s/ Daniel Cohen
 
April 15, 2024
 
By: Daniel Cohen, VP Operations
 
 

 EX-1.01 2 exhibit_1-02.htm EXHIBIT 1.02

Exhibit 1.02

 
Silicom Ltd.
 
Conflict Minerals Report
 
For the Year Ended December 31, 2023
 
This report for the year ended December 31, 2023 is presented to comply with Section 13(p) of the Securities Exchange Act of 1934 and Rule 13p-1 (the "Rule") and Form SD thereunder. The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict. 
 
Design of Conflict Minerals Due Diligence Program
 
The design of our conflict minerals due diligence program is in conformity with the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, "OECD Guidance"), specifically as it relates to our position in the minerals supply chain as a "downstream" purchaser. We designed our due diligence program, management and measures to conform in all material respects with the framework OECD Guidance. 
 
Description of Performed Conflict Minerals Due Diligence Program
 
(i)
Maintaining of Strong Company Management Systems

a.   Silicom has adopted and committed to a Conflict Minerals policy for minerals originating from conflict-affected and high-risk areas. More information about Silicom's Conflict Minerals policy can be found in the RCOI section above.
Our management system includes a Conflict Minerals Qualification Team overseen by the Chief Financial Officer of the Company and run under the supervision of the Company's VP QA & Engineering, and includes a team of subject matter experts from relevant functions including Operations and Purchasing. Senior management is briefed about the results of our due diligence efforts on a regular basis.

b.   In 2019 Silicom became a member of the Responsible Minerals Initiative ("RMI") (formerly the Conflict Free Sourcing Initiative, or CFSI), as a member we participate in all RMI activities such as smelters audits and other activities.
c.   Silicom has implemented a supply chain system of controls and transparency through the use of due diligence software provided by third party software supplier.
d.   In the process of engaging with new manufacturers and suppliers, Silicom requests that such suppliers provide it with complete and valid CMRTs as a condition for Silicom's engagement with such manufacturers and suppliers.

e.   Silicom conducts trainings to suppliers and manufacturers from whom it purchases components used in its products, assists suppliers and manufacturers in educating their own suppliers, by informing them on the Rule, referring suppliers and manufacturers to the RMI website and online training materials and providing Silicom's Conflict Minerals policy and due diligence procedures.
f.   Silicom documents and maintains a record maintenance mechanism to ensure the retaining of relevant documentation in an electronic database for at least 5 years.

g.  Silicom encourages employees, suppliers and manufacturers and stakeholders to report any concerns relating to its conflict minerals program by contacting Silicom on its Conflict Minerals page: http://www.silicom-usa.com/conflict-minerals/.

 
(ii)
Identification and Assessment of Risk in the Supply Chain

Suppliers and manufacturers (including smelters and refiners) of products which include Conflict Minerals which are "necessary to the functionality of the products" were identified through our CMRT analysis.

We identified two primary risks in our supply chain: (1) not receiving on time and accurate information from the suppliers and manufacturers; and (2) reliance on suppliers and manufacturers who are not conflict-free while pursuing our goal of becoming a conflict free company. This assessment assisted us to segment our suppliers and manufacturers into three risk levels (high, medium and low), on which we based our risk strategy.

We conducted a survey of our active suppliers and manufacturers using the template developed by RMI, known as the Conflict Minerals Reporting Template ("CMRT"). Suppliers and manufacturers were requested to use version 6.1 of the CMRT, or newer versions.

(iii)
Design and Implementation of a Strategy to Respond to Identified Risks
 
a.   We performed reviews of suppliers and manufacturers, smelters, and refiners that could be sourcing or processing Conflict Minerals from the Covered Countries, which could not be from recycled or scrap sources.

b.   As part of our risk based approach, we decided to focus our risk management actions on suppliers and manufacturers with a spending volume of over US$ 1,000 in 2023. We requested smelter information from all of our direct suppliers and manufacturers, and prioritized suppliers and manufacturers with a spending volume of over US$ 1,000. In cases where prioritized suppliers and manufacturers did not respond to our initial requests, we attempted to contact them several additional times in order to obtain the necessary information from them.
 
c.  We monitored and tracked suppliers and manufacturers (as described in RCOI section above), smelters and/or refiners identified as not meeting the requirements (or that defined themselves as "Unknown" or "Undeterminable" or "Sourced from DRC") set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements.

d.   New suppliers and manufacturers were required to complete RMI declarations in order to qualify as approved suppliers and manufacturers by us.
 
e.   We provided periodic progress reports to our senior management relating to our risk mitigation efforts.
 
f.   In general, supply chain due diligence is a dynamic process and requires on-going risk monitoring. This process is performed twice a year and an updated CMRT is released after completion of each due diligence cycle.

g.  Follow up letters were sent to high and medium risk suppliers and manufacturers who were identified as having non-compliant smelters in their supply chain. Non-responsive suppliers and manufacturers were reminded to send their responses several times by e-mails and, if they remained non-responsive thereafter, such suppliers and manufacturers were personally approached by our Sustainability Team or by our Purchasing Team and warned that if they remain non-responsive despite our continued attempts to receive their responses, they will be removed from our approved suppliers and manufacturers list. In cases where such suppliers and manufacturers remained non-responsive nonetheless, we removed them from our approved suppliers and manufacturers list.

(iv)   Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
 
         We encourage our suppliers and manufacturers to purchase from RMI Compliant Smelters, and we rely on the RMI compliant and active smelters list, which is available on the RMI website.

(v)
Report on Supply Chain Due Diligence
 
This Report is available on our website at http://www.silicom-usa.com/conflict-minerals/. This Report is being filed to the SEC and is also available on the SEC's EDGAR database at www.sec.gov.
 
Results of our Assessment
 
As a downstream purchaser of conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and manufacturers and those suppliers and manufacturers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also gather required CMRT information from websites of suppliers and manufacturers where conflict minerals reports were available. We also rely, to a large extent, on information collected and provided by independent third-party audit programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud because the information gathered from our suppliers and manufacturers is not on a continuous, real-time basis.
 
Supplier Chain Survey Responses
 
Silicom contacted 180 suppliers and manufacturers, and the response rate achieved was over  99.8% in cost of purchased goods.
 
The Sustainability Team directly contacted Silicom's suppliers and manufacturers in order to collect CMRTs. Following the efforts of the Sustainability Team, 174 suppliers and manufacturers delivered satisfactory CMRTs. For the purposes hereof, Silicom considers CMRT to be satisfactory if they do not include any deficiencies or discrepancies and comply, in form and in substance, with the terms governing the RMI, such as blank rows, scope not matching PN list, inclusion of irrelevant information, etc.
 
14 of the 180 suppliers and manufacturers delivered CMRTs with invalid supplier submissions, like incorrect smelter names or invalid CID identification numbers. Following our requests for improved CMRTs, we received satisfactory CMRTs submissions from all such suppliers and manufacturers.
 
68 suppliers and manufacturers were classified as "Not from DRC" – suppliers and manufacturers who reported that they were sourcing minerals from countries other than the Covered Countries.
 
42 suppliers and manufacturers were classified as "DRC conflict free" – suppliers and manufacturers who reported that the 3TG minerals used in the products provided to Silicom originate from Covered Countries but the smelters are approved by the RMI
 
21 suppliers and manufacturers were classified as "DRC not conflict free" – suppliers and manufacturers who reported that the 3TG minerals used in the products provided to Silicom originate from Covered Countries and the smelters are not approved by the RMI.

 
20 suppliers and manufacturers were classified as "Free no 3TG" – suppliers and manufacturers who reported that 3TG minerals are not necessary for the functionality or production of the products provided to Silicom.
 
12 suppliers and manufacturers were classified as "Undetermined not from DRC" – suppliers and manufacturers who reported that the 3TG used in the products supplied to Silicom do not originate from Covered Countries but since they have not yet concluded their due diligence process, their determination and responses are not yet final and may vary. Consequently, our due diligence for these suppliers and manufacturers is still ongoing.
 
11 suppliers and manufacturers were classified as "Undetermined from DRC" – suppliers and manufacturers who reported that the 3TG used in the products supplied to Silicom originate from Covered Countries and the smelters are approved by the RMI program, but they have not yet concluded their due diligence process so their determination and responses are not yet final and may vary. Consequently, our due diligence for these suppliers and manufacturers is still ongoing.
 
Of the 174 suppliers and manufacturers that delivered satisfactory CMRTs:
 
85 suppliers and manufacturers provided data at a "Company" level;
 
26 suppliers and manufacturers provided data at a "User defined" level; and
 
63 suppliers and manufacturers provided data at a "Product" level.
 
As we are attentive to market requests, we asked several of these suppliers and manufacturers to provide data at a "Company" level as well as at a "Product" level, and such suppliers and manufacturers provided the data at both levels.
 
Below is a summary of the country of origin information collected as a result of our RCOI efforts.
 
Conflict Mineral
Countries of origin and other sources may include the following
Gold
Andorra, Australia, Austria, Belgium, Brazil, Canada, Chile, China, Colombia, Czech Republic, France, Germany, Ghana, India, Indonesia, Italy, Japan, Kazakhstan, Korea Republic, Kyrgyzstan, Lithuania, Malaysia, Mauritania, Mexico, Netherlands, New Zealand, Norway, Philippines, Poland, Portugal, Russian Federation, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Province of China, Thailand, Turkey, United Arab Emirates, United States of America, Uzbekistan.
Tantalum
Japan, United States, Brazil, India, Estonia, Russian Federation, Kazakhstan, Mexico, Thailand, Germany, China.
Tungsten
Japan, United States, Vietnam, Austria, Germany, Russian Federation, Philippines, Brazil, Korea, Taiwan, China.
Tin
China, United States of America, Indonesia, Japan, Bolivia (Florin State), Brazil, Poland, Malaysia, Peru, Thailand, Taiwan, Philippines, Vietnam, Belgium, Spain, Rwanda, Myanmar, India, Russian Federation, Congo, Democratic Republic.

 
Smelters and refiners verified as conflict free (compliant) or in the audit process:
 
Tin
68 of 87 (78%)
Tantalum
32 of 35 (91%)
Tungsten
33 of 42 (79%)
Gold
 92 of 167 (55%)
Total
225 of 331 (68%)

A number of the smelters and refiners detailed above provided more than one necessary conflict mineral.
 
List of the facilities which, to the extent known, processed the necessary conflict minerals used in our products can be found in Appendix 1.
 
Continuous Improvement Efforts to Mitigate Risks
 
During the reporting period for the calendar year ending December 31, 2023, we are continuing to engage in the diligence process described above.
 
We intend to follow up with high risk non-responsive or non-compliant suppliers and manufacturers, work with suppliers and manufacturers to educate them on conflict minerals sourcing, contact selected smelters and refiners that have not received a "conflict free" designation and more. In the event that any of our suppliers and manufacturers do not cooperate with us and do not respond to our efforts in a satisfactory manner, we will disqualify them and remove them from our approved suppliers and manufacturers list.
 
In the event that we continue to engage with suppliers and manufacturers who have not completed their RCOI process, we will ask such suppliers and manufacturers to complete the process and become conflict free at a company or product level as a condition to our continued engagement with them.
 
In addition, being attentive to the market and to our customers, we are currently in the process of qualifying our line of products as "conflict free" by, among other things, requesting from all of our direct suppliers and manufacturers to qualify the goods supplied by them to Silicom as "Conflict Free", replacing, where possible and appropriate, non-compliant suppliers and manufacturers with compliant ones and removal of non-compliant vendors from our approved vendors list.

 
Appendix 1
 
List of smelters used in Silicom's products:
 
Smelter identification
Metal
Smelter Country
CID000004
Tungsten
JAPAN
CID000015
Gold
UNITED STATES OF AMERICA
CID000019
Gold
JAPAN
CID000035
Gold
GERMANY
CID000041
Gold
UZBEKISTAN
CID000058
Gold
BRAZIL
CID000077
Gold
SWITZERLAND
CID000082
Gold
JAPAN
CID000090
Gold
JAPAN
CID000103
Gold
TURKEY
CID000105
Tungsten
UNITED STATES OF AMERICA
CID000113
Gold
GERMANY
CID000128
Gold
PHILIPPINES
CID000157
Gold
SWEDEN
CID000176
Gold
GERMANY
CID000180
Gold
MEXICO
CID000185
Gold
CANADA
CID000189
Gold
SWITZERLAND
CID000197
Gold
CHINA
CID000211
Tantalum
CHINA
CID000218
Tungsten
CHINA
CID000228
Tin
CHINA
CID000233
Gold
ITALY
CID000258
Tungsten
CHINA
CID000264
Gold
JAPAN
CID000292
Tin
UNITED STATES OF AMERICA
CID000309
Tin
INDONESIA
CID000313
Tin
INDONESIA
CID000343
Gold
CHINA




CID000359
Gold
KOREA, REPUBLIC OF
CID000401
Gold
JAPAN
CID000402
Tin
JAPAN
CID000425
Gold
JAPAN
CID000438
Tin
BOLIVIA (PLURINATIONAL STATE OF)
CID000448
Tin
BRAZIL
CID000460
Tantalum
CHINA
CID000468
Tin
POLAND
CID000493
Gold
RUSSIAN FEDERATION
CID000522
Gold
CHINA
CID000538
Tin
CHINA
CID000555
Tin
CHINA
CID000568
Tungsten
UNITED STATES OF AMERICA
CID000616
Tantalum
CHINA
CID000671
Gold
CHINA
CID000689
Gold
KOREA, REPUBLIC OF
CID000694
Gold
GERMANY
CID000707
Gold
CHINA
CID000711
Gold
GERMANY
CID000766
Tungsten
CHINA
CID000767
Gold
CHINA
CID000769
Tungsten
CHINA
CID000773
Gold
CHINA
CID000778
Gold
KOREA, REPUBLIC OF
CID000801
Gold
CHINA
CID000807
Gold
JAPAN
CID000814
Gold
TURKEY
CID000823
Gold
JAPAN
CID000825
Tungsten
JAPAN
CID000855
Gold
CHINA
CID000875
Tungsten
CHINA
CID000914
Tantalum
CHINA
CID000917
Tantalum
CHINA



CID000920
Gold
UNITED STATES OF AMERICA
CID000924
Gold
CANADA
CID000929
Gold
RUSSIAN FEDERATION
CID000937
Gold
JAPAN
CID000942
Tin
CHINA
CID000956
Gold
KAZAKHSTAN
CID000957
Gold
KAZAKHSTAN
CID000966
Tungsten
UNITED STATES OF AMERICA
CID000969
Gold
UNITED STATES OF AMERICA
CID000981
Gold
JAPAN
CID001029
Gold
KYRGYZSTAN
CID001032
Gold
SAUDI ARABIA
CID001056
Gold
CHINA
CID001058
Gold
CHINA
CID001070
Tin
CHINA
CID001076
Tantalum
BRAZIL
CID001078
Gold
KOREA, REPUBLIC OF
CID001093
Gold
CHINA
CID001105
Tin
MALAYSIA
CID001113
Gold
UNITED STATES OF AMERICA
CID001119
Gold
JAPAN
CID001142
Tin
UNITED STATES OF AMERICA
CID001147
Gold
CHINA
CID001149
Gold
CHINA
CID001152
Gold
SINGAPORE
CID001153
Gold
SWITZERLAND
CID001157
Gold
UNITED STATES OF AMERICA
CID001161
Gold
MEXICO
CID001163
Tantalum
INDIA
CID001173
Tin
BRAZIL
CID001175
Tantalum
BRAZIL
CID001182
Tin
PERU
CID001188
Gold
JAPAN
CID001191
Tin
JAPAN
CID001192
Tantalum
JAPAN



CID001193
Gold
JAPAN
CID001200
Tantalum
ESTONIA
CID001204
Gold
RUSSIAN FEDERATION
CID001220
Gold
TURKEY
CID001231
Tin
CHINA
CID001236
Gold
UZBEKISTAN
CID001259
Gold
JAPAN
CID001277
Tantalum
CHINA
CID001305
Tin
RUSSIAN FEDERATION
CID001314
Tin
THAILAND
CID001325
Gold
JAPAN
CID001326
Gold
RUSSIAN FEDERATION
CID001337
Tin
BOLIVIA (PLURINATIONAL STATE OF)
CID001352
Gold
SWITZERLAND
CID001362
Gold
CHINA
CID001386
Gold
RUSSIAN FEDERATION
CID001397
Gold
INDONESIA
CID001399
Tin
INDONESIA
CID001402
Tin
INDONESIA
CID001406
Tin
INDONESIA
CID001419
Tin
INDONESIA
CID001421
Tin
Indonesia
CID001428
Tin
INDONESIA
CID001453
Tin
INDONESIA
CID001457
Tin
INDONESIA
CID001458
Tin
INDONESIA
CID001460
Tin
INDONESIA
CID001463
Tin
INDONESIA
CID001468
Tin
INDONESIA
CID001477
Tin
INDONESIA
CID001482
Tin
INDONESIA
CID001486
Tin
INDONESIA
CID001490
Tin
INDONESIA
CID001493
Tin
INDONESIA
CID001498
Gold
SWITZERLAND
CID001508
Tantalum
UNITED STATES OF AMERICA
CID001512
Gold
SOUTH AFRICA
CID001522
Tantalum
CHINA



CID001534
Gold
CANADA
CID001539
Tin
TAIWAN, PROVINCE OF CHINA
CID001546
Gold
UNITED STATES OF AMERICA
CID001555
Gold
KOREA, REPUBLIC OF
CID001562
Gold
KOREA, REPUBLIC OF
CID001585
Gold
SPAIN
CID001619
Gold
CHINA
CID001622
Gold
CHINA
CID001736
Gold
CHINA
CID001756
Gold
RUSSIAN FEDERATION
CID001761
Gold
TAIWAN, PROVINCE OF CHINA
CID001769
Tantalum
RUSSIAN FEDERATION
CID001798
Gold
JAPAN
CID001810
Gold
TAIWAN, PROVINCE OF CHINA
CID001869
Tantalum
JAPAN
CID001875
Gold
JAPAN
CID001891
Tantalum
UNITED STATES OF AMERICA
CID001898
Tin
THAILAND
CID001908
Tin
CHINA
CID001909
Gold
CHINA
CID001916
Gold
CHINA
CID001938
Gold
JAPAN
CID001947
Gold
CHINA
CID001955
Gold
KOREA, REPUBLIC OF
CID001969
Tantalum
KAZAKHSTAN
CID001980
Gold
BELGIUM
CID001993
Gold
UNITED STATES OF AMERICA
CID002003
Gold
SWITZERLAND
CID002015
Tin
VIET NAM
CID002030
Gold
AUSTRALIA
CID002036
Tin
BRAZIL
CID002044
Tungsten
AUSTRIA
CID002082
Tungsten
CHINA
CID002100
Gold
JAPAN
CID002129
Gold
JAPAN
CID002158
Tin
CHINA
CID002180
Tin
CHINA
CID002224
Gold
CHINA
CID002243
Gold
CHINA
CID002282
Gold
NEW ZEALAND
CID002290
Gold
CZECHIA
CID002312
Gold
CHINA
CID002314
Gold
THAILAND
CID002315
Tungsten
CHINA
CID002316
Tungsten
CHINA
CID002317
Tungsten
CHINA
CID002318
Tungsten
CHINA
CID002319
Tungsten
CHINA



CID002320
Tungsten
CHINA
CID002321
Tungsten
CHINA
CID002455
Tin
INDONESIA
CID002459
Gold
UNITED STATES OF AMERICA
CID002468
Tin
BRAZIL
CID002478
Tin
INDONESIA
CID002492
Tantalum
CHINA
CID002494
Tungsten
CHINA
CID002500
Tin
BRAZIL
CID002502
Tungsten
VIET NAM
CID002503
Tin
INDONESIA
CID002504
Tantalum
UNITED STATES OF AMERICA
CID002505
Tantalum
CHINA
CID002506
Tantalum
CHINA
CID002508
Tantalum
CHINA
CID002509
Gold
INDIA
CID002511
Gold
POLAND
CID002512
Tantalum
CHINA
CID002513
Tungsten
CHINA
CID002516
Gold
TAIWAN, PROVINCE OF CHINA
CID002517
Tin
PHILIPPINES
CID002525
Gold
CHINA
CID002527
Gold
CHINA
CID002539
Tantalum
MEXICO
CID002541
Tungsten
GERMANY
CID002542
Tungsten
GERMANY
CID002543
Tungsten
VIET NAM
CID002544
Tantalum
THAILAND
CID002545
Tantalum
GERMANY
CID002547
Tantalum
GERMANY
CID002548
Tantalum
UNITED STATES OF AMERICA
CID002549
Tantalum
JAPAN
CID002550
Tantalum
GERMANY
CID002551
Tungsten
CHINA
CID002557
Tantalum
UNITED STATES OF AMERICA
CID002558
Tantalum
JAPAN
CID002560
Gold
UNITED ARAB EMIRATES
CID002561
Gold
UNITED ARAB EMIRATES
CID002562
Gold
UNITED ARAB EMIRATES
CID002570
Tin
INDONESIA
CID002572
Tin
VIET NAM
CID002573
Tin
VIET NAM
CID002574
Tin
VIET NAM
CID002580
Gold
ITALY



CID002582
Gold
NETHERLANDS
CID002584
Gold
UNITED ARAB EMIRATES
CID002588
Gold
INDIA
CID002589
Tungsten
UNITED STATES OF AMERICA
CID002593
Tin
INDONESIA
CID002605
Gold
KOREA, REPUBLIC OF
CID002606
Gold
BRAZIL
CID002615
Gold
KAZAKHSTAN
CID002641
Tungsten
CHINA
CID002645
Tungsten
CHINA
CID002696
Tin
INDONESIA
CID002703
Tin
VIET NAM
CID002706
Tin
BRAZIL
CID002707
Tantalum
BRAZIL
CID002708
Gold
UNITED STATES OF AMERICA
CID002724
Tungsten
RUSSIAN FEDERATION
CID002750
Gold
CHINA
CID002756
Tin
BRAZIL
CID002760
Gold
PORTUGAL
CID002761
Gold
FRANCE
CID002762
Gold
ANDORRA
CID002763
Gold
ITALY
CID002765
Gold
ITALY
CID002773
Tin
BELGIUM
CID002774
Tin
SPAIN
CID002776
Tin
INDONESIA
CID002778
Gold
GERMANY
CID002779
Gold
AUSTRIA
CID002816
Tin
INDONESIA
CID002827
Tungsten
PHILIPPINES
CID002830
Tungsten
China
CID002833
Tungsten
BRAZIL
CID002834
Tin
VIET NAM
CID002835
Tin
INDONESIA
CID002842
Tantalum
CHINA
CID002844
Tin
CHINA
CID002845
Tungsten
RUSSIAN FEDERATION
CID002850
Gold
SOUTH AFRICA
CID002852
Gold
INDIA
CID002853
Gold
INDIA
CID002857
Gold
MALAYSIA
CID002858
Tin
MALAYSIA
CID002863
Gold
INDIA
CID002867
Gold
GERMANY
CID002872
Gold
UNITED STATES OF AMERICA
CID002893
Gold
INDIA
CID002918
Gold
KOREA, REPUBLIC OF
CID002919
Gold
CHILE
CID002920
Gold
AUSTRALIA
CID002973
Gold
ITALY
CID003116
Tin
CHINA
CID003153
Gold
LITHUANIA
CID003186
Gold
GHANA
CID003189
Gold
KOREA, REPUBLIC OF
CID003190
Tin
CHINA
CID003205
Tin
INDONESIA
CID003208
Tin
MYANMAR
CID003324
Gold
UNITED STATES OF AMERICA
CID003325
Tin
UNITED STATES OF AMERICA



CID003348
Gold
UNITED ARAB EMIRATES
CID003356
Tin
CHINA
CID003379
Tin
CHINA
CID003381
Tin
INDONESIA
CID003382
Gold
INDIA
CID003383
Gold
INDIA
CID003387
Tin
RWANDA
CID003388
Tungsten
KOREA, REPUBLIC OF
CID003397
Tin
China
CID003401
Tungsten
CHINA
CID003407
Tungsten
TAIWAN, PROVINCE OF CHINA
CID003409
Tin
INDIA
CID003410
Tin
CHINA
CID003417
Tungsten
CHINA
CID003421
Gold
COLOMBIA
CID003424
Gold
JAPAN
CID003425
Gold
JAPAN
CID003427
Tungsten
BRAZIL
CID003449
Tin
INDONESIA
CID003461
Gold
INDIA
CID003463
Gold
INDIA
CID003468
Tungsten
BRAZIL
CID003486
Tin
BRAZIL
CID003487
Gold
INDIA
CID003488
Gold
INDIA
CID003489
Gold
INDIA
CID003490
Gold
INDIA
CID003497
Gold
NORWAY
CID003500
Gold
UNITED STATES OF AMERICA
CID003524
Tin
SPAIN
CID003529
Gold
COLOMBIA
CID003540
Gold
MAURITANIA
CID003548
Gold
INDIA
CID003557
Gold
UNITED STATES OF AMERICA
CID003575
Gold
SOUTH AFRICA
CID003582
Tin
BRAZIL
CID003583
Tantalum
CHINA
CID003609
Tungsten
CHINA
CID003615
Gold
FRANCE
CID003641
Gold
COLOMBIA
CID003663
Gold
CHINA
CID003831
Tin
MYANMAR
CID003868
Tin
INDONESIA
CID003993
Tungsten
VIET NAM
CID004065
Tin
CONGO, DEMOCRATIC REPUBLIC OF THE