CONFLICT MINERALS REPORT
ARLO TECHNOLOGIES, INC.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934
for the Calendar Year Ended December 31, 2018
Introduction
Rule 13p-1 was adopted by the United States Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to Conflict Minerals as directed by Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010. Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain Conflict Minerals necessary to the functionality or production of their products. Conflict Minerals are defined by Rule 13p-1 as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tungsten, tantalum, and gold (collectively, “3TG” or “Conflict Minerals”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Covered Countries (as defined below).
If a registrant has reason to believe that any 3TG in its supply chain may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country (together with the DRC, the "Covered Countries"), or if it is unable to determine the country of origin of the 3TG in its products, or that its products are manufactured entirely from recycled and scrap sources, then the issuer must conduct due diligence on the source and chain of custody of the 3TG. The registrant must annually submit a Form SD and Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures. Arlo Technologies, Inc. ("Arlo" or the "Company") has determined that Conflict Minerals that may have originated from the Covered Countries are necessary to the functionality or production of some or all of its products, manufacture of which was completed during the 2018 calendar year and, therefore, is required to perform due diligence and file this report annually. This report is Arlo's CMR for the reporting calendar year ended December 31, 2018.
This report is not audited, as Rule 13p-1 and current SEC guidance provide that if the registrant is not declaring products as "DRC Conflict Free," the CMR is not subject to an independent private sector audit.
Although forward-looking statements in this report reflect our good faith judgment, such statements can only be based on facts and factors currently known by us. Consequently, forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include without limitation: the risk that information reported to us by our suppliers from which we directly procure finished goods, components, materials and/or services for our products (direct suppliers), or industry information used by us, may be inaccurate or incomplete; the risk that smelters or refiners (processing facilities) may not participate in the Responsible Minerals Assurance Process (RMAP), formerly the Conflict-Free Smelter Program, which is a voluntary initiative in which independent third parties audit processing facilities’ procurement and processing activities and determine if the processing facilities maintain sufficient documentation to reasonably demonstrate conflict free sourcing; as well as risks discussed under the heading “Risk Factors” in our most recent Quarterly Report on Form 10-Q, including those related to our customer concentration, our dependence on a limited number of third-party suppliers and our being subject to government regulations and policies. Readers are urged not to place undue reliance on forward-looking statements, which speak only as of the date of this report. We undertake no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this Report. Throughout this report, whenever a reference is made to our website, such reference does not incorporate information from the website by reference into this report unless specifically identified as such.
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Section 1 - Company Overview
Arlo combines an intelligent cloud infrastructure and mobile app with a variety of smart connected devices that transform the way people experience the connected lifestyle. Its cloud-based platform creates a seamless, end-to-end connected lifestyle solution that provides users visibility, insight and a powerful means to help protect and connect with the people and things that matter most to them. Arlo enables users to monitor their environments and engage in real-time with their families and businesses from any location with a Wi-Fi or a cellular network internet connection. To date, Arlo has launched several categories of award-winning smart connected devices, including wire-free smart Wi-Fi and LTE-enabled cameras, advanced baby monitors and smart security lights.
Arlo’s internet address is www.arlo.com. This CMR will be posted on the Company’s website with other SEC filings under About Us/Investor Relations/Financials & Filings/SEC Filings as soon as reasonably practicable after it is electronically filed with the SEC. This is the Company’s first CMR filing as a standalone public company since Arlo completed its initial public offering on August 7, 2018 and at that time NETGEAR, Inc. (“NETGEAR”) owned approximately 84.2% of the shares of Arlo’s common stock. On December 31, 2018, NETGEAR completed its distribution of its 84.2% common stock ownership to its NETGEAR’s shareholders and was no longer considered a related party to the Company.
1.1 Arlo Products
All of our products fall in scope of the Conflict Minerals Rule as they contain one or more Conflict Minerals. The following product line descriptions provide additional details:
• | Smart connected devices - cameras, security light, audio doorbell and Arlo chime |
• | Arlo accessories - charging accessories, arlo mounts and arlo skins |
We conducted an analysis of Arlo products and found that small quantities of 3TG, necessary to the products’ functionality or production, are found in substantially all Arlo products.
1.2 Conflict Minerals Report
For all product categories listed under 1.1, we have been unable to conclusively determine the origin of the 3TG that our products contain, or to conclusively determine to what extent they came from recycled or scrap sources; the facilities used to process them; their countries of origin; or their mines or locations of origin. More than 50% of our in-scope suppliers reported at broad levels, often declaring the scope of their Conflict Minerals Reporting Template (“CMRT”) as “company-wide,” not at the level of products actually provided to us.
This report describes our Reasonable Country of Origin Inquiry (“RCOI”) efforts, the due diligence measures we took on the 3TG source and chain of custody, the results of our due diligence efforts, expected risk assessment and mitigation steps.
1.3 Conflict Minerals Policy
Arlo has published its conflict minerals policy on its webpage located at:
https://www.arlo.com/images/pdf/Arlo-Conflict-Minerals-Sourcing-Policy.pdf
We are contributing to industry efforts to address conflict minerals through our involvement as a member of the Responsible Business Alliance (“RBA”), previously known as the EICC or the Electronic Industry Citizenship Coalition, and the Responsible Minerals Initiative (“RMI”).
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Section 2 - Reasonable Country of Origin Inquiry
To determine whether the necessary 3TG in our products originated in the Covered Countries, we first needed to determine the scope of our Conflict Minerals program. As determined and explained above, Arlo has determined that nearly all of its products contain one or more Conflict Minerals and, therefore, we determined that all Tier 1* suppliers of these products should be surveyed on the sourcing of that 3TG.
*Arlo’s definition of Tier 1 Supplier - ODM (Original Design Manufacturer), CM (Contract Manufacturer) and Arlo’s AVL (Approved Vendor List) with which Arlo has directly negotiated the price of goods and services and has a direct control or business relationship, but excluding the following suppliers: plastics and software suppliers; packaging suppliers; suppliers whose previous year’s CMRT declaration confirmed that 3TG are not contained in the applicable component/material; suppliers whose material did not end up in production orders; and suppliers with which there was no price negotiation in the reporting year.
Arlo utilized the CMRT version 5.11 or higher to conduct a survey of all in-scope suppliers. The CMRT is a free, standardized reporting template developed by the RMI that is widely considered the industry standard in conflict minerals data collection. During the supplier survey process, we contacted all Tier 1 suppliers and required that they complete a valid CMRT and provide it to Arlo for assessment.
On average, Arlo direct suppliers were contacted at least three times through email and/or phone call for follow up on their CMRT submission or for clarifying any questions that the Arlo Conflict Minerals Program team or Arlo’s third-party service provider may have had. Arlo’s Conflict Minerals Program team was also in charge of all the communication with direct suppliers.
We received completed CMRTs from all 28 in-scope suppliers. Once all CMRTs were collected, they were evaluated using automated data validation. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on their answers to questions 1 through 6 of the CMRT.
All submitted forms were accepted and classified as valid or invalid so that data is still retained. As of March 20, 2019, there were no invalid supplier submissions that had not been corrected.
Based on the RCOI, we have reason to believe that some of the 3TG may have originated from the Covered Countries. Therefore, in accordance with the Rule, the Company performed due diligence on the source and chain of custody of the 3TG used in manufacture of Arlo products.
Section 3 - Conflict Minerals Due Diligence Program Design
Arlo’s conflict minerals due diligence program is designed to conform in all material aspects with the framework recommended by 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, including supplements, also known as the “OECD Guidance,” as it relates to Arlo’s supply chain position as a “downstream” or finished product manufacturer and purchaser.
Summarized below are the components of Company’s program as they relate to the five-step framework set forth in the OECD Guidance:
3.1 Establish strong company management systems
• | Adopted and publicly communicated a conflict minerals company policy which is posted on the Arlo website at https://www.arlo.com/images/pdf/Arlo-Conflict-Minerals-Sourcing-Policy.pdf |
• | As a member of the RBA, required that our suppliers and contract manufacturers acknowledge and implement the RBA’s Code of Conduct, which includes an obligation to conduct due diligence regarding conflict minerals. |
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• | Assembled internal conflict minerals program team, led by our Quality & Compliance team and supported by a cross-functional team consisting of representatives from Operations, Supply Chain, Legal, Finance and Internal Audit functions. |
• | Established a system of control through the use of our Supplier Code of Conduct and transparency over Arlo’s conflict minerals supply chain by engaging first-tier suppliers and requesting relevant information through the use of a third-party service provider, which utilized due diligence tools created by the RMI, including the CMRT. |
• | Provided updates on our conflict minerals due diligence progress and status on a quarterly basis to Arlo’s Chief Financial Officer. |
• | Educated and trained those personnel responsible to work on Arlo’s Conflict Minerals Program. |
• | Established a grievance mechanism to allow employees, suppliers, and others to report suspected non-compliance with the applicable legal requirement and/or suspected non-compliance with Arlo’s Code of Ethics and Supplier Code of Conduct. These policies are publically available at https://www.arlo.com/en-us/about/corporate-social-responsibility/ethics/ |
• | Established an internal audit to review the conflict minerals due diligence process against Arlo’s documented procedure and data accuracy in Arlo CMRT. |
• | Identified business records relating to conflict minerals due diligence, including records of due diligence processes, findings and resulting decisions, that will be retained in accordance with our records retention policies. |
3.2 Identify and manage risk in the supply chain
• | Identified relevant Tier 1 suppliers that supplied products containing 3TG. |
• | Requested these suppliers to provide information regarding smelters or refiners in our supply chain by using the CMRT. |
• | Reviewed supplier responses for completeness and accuracy. |
• | Risks were identified by analyzing data from the lists provided by suppliers of mineral processing facilities on their CMRT declarations. |
• | Compared information in supplier responses with the list of 3TG processing facilities that received a “conflict-free” designation, produced by the RMAP (Responsible Minerals Assurance Process). |
• | Each facility that meets the RMI definition of a smelter or refiner of 3TG was assessed according to red flag indicators defined in the OECD Guidance. To determine the level of risk that each smelter posed to the supply chain, the Company assessed three criteria: geographic proximity to the Covered Countries, known mineral source country of origin, RMAP audit status, credible evidence of unethical or conflict sourcing, and peer assessments conducted by credible third-party sources. |
• | Contacted non-responsive suppliers, requesting their responses. |
• | Provided suppliers with feedback on responses containing errors, inconsistencies or incomplete information and encouraged them to resubmit a valid response. |
• | Evaluated suppliers on the strength of their internal conflict minerals programs. When suppliers met or exceeded the below criteria (responded “Yes: to all four questions listed below), they were deemed to have a strong program. When they responded “No” to any one or more to the questions, they were deemed to have a weak program. The criteria used to evaluate the strength of their programs was based on these four questions in the CMRT: |
• | Have you established a conflict minerals sourcing policy? |
• | Have you implemented due diligence measures for conflict-free sourcing? |
• | Do you review due diligence information received from your suppliers against your company’s expectations? |
• | Does your review process include corrective action management? |
3.3 Design and implement a strategy to respond to risk
• | Conducted regular conflict minerals program team meetings to review, among other things, Arlo’s Conflict Minerals program, any potential or actual risks identified during due diligence, and the status of supplier responses. |
• | Identified high-risk smelters or refiners in Arlo’s supply chain by using the smelter and refiner database from the RMI that includes information on each smelter’s and refiner’s chain of custody of minerals. Arlo’s smelter & refiner risk calculation is based on three-criteria: |
• | Geographic proximity to the Covered Countries; |
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• | RMAP audit status; and |
• | Credible evidence of unethical or conflict sourcing. |
• | Through the use of the Company’s third-party service provider, contacted non-RMAP facilities to encourage them to join the program and undergo an audit. |
• | Drafted an escalation plan in the event if we have to address non-responsive suppliers and/or to contact suppliers that provided incomplete or inaccurate supply chain information. |
• | Requested that certain suppliers remove specific smelters or refiners from their supply chains that we deemed to be high-risk. |
• | Engaged any suppliers that we had reason to believe are supplying the Company with 3TG from sources that may be considered red flags and encouraged them to establish alternative sources of 3TG. |
• | Informed non-responsive suppliers, near to Arlo’s deadline date for accepting supplier CMRT that we would assess and potentially withhold future business with them if they did not provide their supply chain conflict minerals information using the CMRT. |
• | Conducted Conflict Minerals Program due diligence process audit of Arlo’s ODM partners that contributed to at least 80% of Arlo’s purchase in reporting year. |
3.4 Audit of smelter/refiner’s due diligence practices
• | Relied on the RMAP, the London Bullion Market Association, and the Responsible Jewelry Council to coordinate third-party audits of smelters and refiners to validate the sourcing practices of such facilities in our supply chain. |
• | Provided indirect financial support for these third-party audits through our continued membership in the RBA and RMI. |
• | Participated in RBA and RMI work groups, including smelter engagement and outreach. |
3.5 Report annually on supply chain due diligence
• | Publicly communicated Conflict Minerals Policy on company website at: |
https://www.arlo.com/images/pdf/Arlo-Conflict-Minerals-Sourcing-Policy.pdf
• | Filed our Form SD for the reporting period from January 01, 2018 to December 31, 2018, including this Conflict Minerals Report, with the SEC and made it available on the Investor Relations pages of our website at https://investor.arlo.com/financials-and-filings/sec-filings/default.aspx |
• | Reported supply chain smelter information in this Conflict Minerals Report. |
The content of any website referred to in this report is included for general information only and is not incorporated by reference in this report.
Section 4 - Due Diligence Results
Arlo does not have direct contractual relationships with smelters and refiners; therefore, we relied on our direct suppliers and the entire supply chain to gather and provide specific information on 3TG used in Arlo products.
4.1 Survey Results
In 2018, Arlo conducted supply chain surveys, using the CMRT, of Tier 1 suppliers that we identified that may contribute necessary 3TG in our products. The results of our supply chain survey of our 28 Tier 1 suppliers and the conclusion of our RCOI are as follows:
• | 100% of Arlo-surveyed suppliers provided a response using an accepted version of the CMRT. |
• | None of the 28 CMRTs collected have been deemed invalid. |
• | The surveyed suppliers identified 287 legitimate smelters and refiner facilities that may process the necessary 3TG contained in the products manufactured. |
• | Of these 287 smelters and refiners, 249 were validated as conflict free by RMAP, and, based on information provided by the RMI through RMAP, a further four have agreed to undergo or are currently undergoing a third-party audit. |
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• | We have reason to believe that a portion of the Conflict Minerals processed by 24 RMAP audited smelters or refiners may have originated in the Covered Countries and are not solely from recycled or scrap sources. |
Attached as Table A is a list of all smelters and refiners identified by our suppliers in their CMRTs that appear on the list of legitimate smelters and refiners maintained by the RMI. Since many of the CMRTs we received from suppliers were made on a company-level basis, rather than on a product-level basis, we were not able to identify which smelters or refiners listed in Table A actually processed the 3TG contained in our products. Therefore, the list of processing smelters and refiners disclosed in Table A may identify more facilities than those that actually processed the minerals contained in our products.
A list of potential countries of origin from which the reported smelters and refiners collectively sourced 3TG is provided in Table B. As with the list of smelters and refiners, many responses were provided at the company level and, therefore, this list of countries may identify more countries of origin than were actually the source of the 3TG in our products.
Section 5 - Risk Mitigation and Due Diligence Improvement Plan
5.1 Inherent limitation on due diligence measures
Because of our manufacturing business model, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals in the products we contract to have manufactured. Given our place in the supply chain, we have no direct relationships with smelters or refiners, and therefore possess no independent means of determining the source and origin of Conflict Mineral ores processed by smelters or refiners. Our due diligence processes are based on the necessity of seeking data from our suppliers and component manufacturers and we depend on those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. Because of our relative location within the supply chain in relation to the actual extraction, transport, smelting, and refinement of 3TG, our ability to verify the accuracy of information reported by suppliers is limited. We also rely, to a large extent, on information collected and provided by independent third-party audit programs.
5.2 Steps to be taken to mitigate risk and improve due diligence process
We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries:
• | Continue to work with the RMI and/or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance and/or other SEC recognized framework. |
• | Increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program. |
• | Emphasize the need for cooperation and support by our Tier 1 suppliers by implementing more direct Arlo-led escalations throughout the program. |
• | Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of their responses and follow up with suppliers that appear to have gaps in their internal processes for conflict minerals. |
• | Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of 3TG. |
• | Work more closely with our third-party conflict minerals service provider to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TG contained in our products. |
• | Engage Tier 1 suppliers to encourage smelters or refiners in the supply chain, not yet certified/audited by the RMAP or an equivalent independent third-party audit, to undergo smelter audits and verify compliance. |
• | Support our third-party service provider in its smelter due diligence activities by signing a letter to be sent to smelters that have yet to enroll in RMAP, encouraging them to do so. |
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Table A
Smelter & Refiners Reported to be in Supply Chain of Arlo
Below is a list of smelters and refiners have been identified by our Tier 1 suppliers and may have been used in processing of necessary 3TG contained in Arlo products the manufacture of which was completed during calendar year 2018:
Metal | Smelter or Refiner Facility Name | Location of Facility |
Gold | Advanced Chemical Company | UNITED STATES |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
Gold | Argor-Heraeus S.A. | SWITZERLAND |
Gold | Asahi Pretec Corp. | JAPAN |
Gold | Asahi Refining Canada Ltd. | CANADA |
Gold | Asahi Refining USA Inc. | UNITED STATES |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | AU Traders and Refiners | SOUTH AFRICA |
Gold | Aurubis AG | GERMANY |
Gold | Bangalore Refinery | INDIA |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
Gold | Boliden AB | SWEDEN |
Gold | C. Hafner GmbH + Co. KG | GERMANY |
Gold | Caridad | MEXICO |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
Gold | Cendres + Métaux S.A. | SWITZERLAND |
Gold | Chimet S.p.A. | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | DODUCO Contacts and Refining GmbH | GERMANY |
Gold | Dowa | JAPAN |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | Geib Refining Corporation | UNITED STATES |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | HeeSung | KOREA, REPUBLIC OF |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
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Metal | Smelter or Refiner Facility Name | Location of Facility |
Gold | Italpreziosi | ITALY |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Kazzinc | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC | UNITED STATES |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Gold Co., Ltd. | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | L'Orfebre S.A. | ANDORRA |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Marsam Metals | BRAZIL |
Gold | Materion | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
Gold | Metalor Technologies S.A. | SWITZERLAND |
Gold | Metalor USA Refining Corporation | UNITED STATES |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO |
Gold | Mitsubishi Materials Corporation | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
Gold | Morris and Watson | NEW ZEALAND |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | PAMP S.A. | SWITZERLAND |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Planta Recuperadora de Metales SpA | CHILE |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Précinox S.A. | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
Gold | Remondis Argentia B.V. | NETHERLANDS |
Gold | Republic Metals Corporation | UNITED STATES |
Gold | Royal Canadian Mint | CANADA |
Gold | SAAMP | FRANCE |
Gold | Sabin Metal Corp. | UNITED STATES |
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Metal | Smelter or Refiner Facility Name | Location of Facility |
Gold | Safimet S.p.A | ITALY |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | SEMPSA Joyería Platería S.A. | SPAIN |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | Singway Technology Co., Ltd. | TAIWAN |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | SungEel HiTech | KOREA, REPUBLIC OF |
Gold | T.C.A S.p.A | ITALY |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | Umicore Brasil Ltda. | BRAZIL |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES |
Gold | Valcambi S.A. | SWITZERLAND |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Tantalum | Asaka Riken Co., Ltd. | JAPAN |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | D Block Metals, LLC | UNITED STATES |
Tantalum | Exotech Inc. | UNITED STATES |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Global Advanced Metals Aizu | JAPAN |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Tantalum | H.C. Starck Co., Ltd. | THAILAND |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
Tantalum | H.C. Starck Inc. | UNITED STATES |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
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Metal | Smelter or Refiner Facility Name | Location of Facility |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | KEMET Blue Metals | MEXICO |
Tantalum | KEMET Blue Powder | UNITED STATES |
Tantalum | LSM Brasil S.A. | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
Tantalum | Mineracao Taboca S.A. | BRAZIL |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | NPM Silmet AS | ESTONIA |
Tantalum | Power Resources Ltd. | MACEDONIA |
Tantalum | QuantumClean | UNITED STATES |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemicals | JAPAN |
Tantalum | Telex Metals | UNITED STATES |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tin | Alpha | UNITED STATES |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | CV Ayi Jaya | INDONESIA |
Tin | CV Dua Sekawan | INDONESIA |
Tin | CV Gita Pesona | INDONESIA |
Tin | CV Tiga Sekawan | INDONESIA |
Tin | CV United Smelting | INDONESIA |
Tin | CV Venus Inti Perkasa | INDONESIA |
Tin | Dowa | JAPAN |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
Tin | EM Vinto | BOLIVIA |
Tin | Estanho de Rondônia S.A. | BRAZIL |
Tin | Fenix Metals | POLAND |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | CHINA |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Melt Metais e Ligas S.A. | BRAZIL |
Tin | Metallic Resources, Inc. | UNITED STATES |
Tin | Metallo Belgium N.V. | BELGIUM |
Tin | Metallo Spain S.L.U. | SPAIN |
Tin | Mineracao Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
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Metal | Smelter or Refiner Facility Name | Location of Facility |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Modeltech Sdn Bhd | MALAYSIA |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
Tin | Operaciones Metalurgical S.A. | BOLIVIA |
Tin | Pongpipat Company Limited | MYANMAR |
Tin | PT Aries Kencana Sejahtera | INDONESIA |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | PT Babel Inti Perkasa | INDONESIA |
Tin | PT Bangka Prima Tin | INDONESIA |
Tin | PT Bangka Serumpun | INDONESIA |
Tin | PT Bangka Tin Industry | INDONESIA |
Tin | PT Belitung Industri Sejahtera | INDONESIA |
Tin | PT Bukit Timah | INDONESIA |
Tin | PT DS Jaya Abadi | INDONESIA |
Tin | PT Inti Stania Prima | INDONESIA |
Tin | PT Karimun Mining | INDONESIA |
Tin | PT Kijang Jaya Mandiri | INDONESIA |
Tin | PT Menara Cipta Mulia | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT Panca Mega Persada | INDONESIA |
Tin | PT Premium Tin Indonesia | 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 Sukses Inti Makmur | INDONESIA |
Tin | PT Sumber Jaya Indah | INDONESIA |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
Tin | PT Tinindo Inter Nusa | INDONESIA |
Tin | PT Tommy Utama | INDONESIA |
Tin | Resind Industria e Comercio Ltda. | BRAZIL |
Tin | Rui Da Hung | TAIWAN |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Super Ligas | Brazil |
Tin | Thaisarco | THAILAND |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Company Limited | CHINA |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Tungsten | ACL Metais Eireli | BRAZIL |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
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Metal | Smelter or Refiner Facility Name | Location of Facility |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
Tungsten | Japan New Metals Co., Ltd. | JAPAN |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
Tungsten | Kennametal Fallon | UNITED STATES |
Tungsten | Kennametal Huntsville | UNITED STATES |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Moliren Ltd | RUSSIAN FEDERATION |
Tungsten | Niagara Refining LLC | UNITED STATES |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
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Table B
Countries of Origin
The list of countries of origin for the Conflict Minerals, identified as a result of our RCOI, that may have been used in our products includes, but may not be limited to:
• | Level 1 countries (not identified as conflict regions or plausible areas of smuggling or export from the Covered Countries): Argentina, Armenia, Australia, Austria, Azerbaijan, Benin, Bolivia, Botswana, Brazil, Burkina Faso, Canada, Chile, China, Colombia, Cyprus, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Finland, Georgia, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Iran, Ivory Coast, Kazakhstan, Kyrgyzstan, Laos, Lebanon, Madagascar, Malaysia, Mali, Mauritania, Mauritius, Mexico, Mongolia, Morocco, Myanmar, Namibia, Nicaragua, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Portugal, Puerto Rico, Russian Federation, Saudi Arabia, Senegal, Sierra Leone, Slovakia, Solomon Islands, Spain, Suriname, Swaziland, Sweden, Taiwan, Thailand, Togo, Turkey, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Zimbabwe |
• | Level 2 countries (known or plausible countries for smuggling, export out of region or transit of materials containing tantalum, tin, tungsten or gold): Kenya, Mozambique, South Africa |
• | Level 3 countries (the Covered Countries): DRC, Burundi, Rwanda, Tanzania, Uganda, Zambia |
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