Document


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
QuickLogic Corporation
(Exact name of registrant as specified in its charter)
 
 
 
 
 
Delaware
 
000-22671
 
77-0188504
(State or other jurisdiction
of incorporation)
 
(Commission
File Number)
 
(IRS Employer
Identification No.)
 
1277 Orleans Drive, Sunnyvale, CA
 
 
 
94089-1138
(Address of principal executive offices)
 
 
 
(Zip Code)

1277 Orleans Drive
Sunnyvale, CA 94089
(Address of principal executive offices) (Zip Code)
Suping (Sue) Cheung
Vice President, Finance and Chief Financial Officer
(408) 990-4000
(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:
 
ý
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2017 to December 31, 2017.

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Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Conflict Minerals Report (the “Report”) of QuickLogic Corporation (“QuickLogic” or the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2017 to December 31, 2017 and attached as Exhibit 1.01 to this Form SD.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals referred to as “Conflict Minerals” are gold, columbite-tantalite (coltan), cassiterite and wolfamite, including their derivatives which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and our Report are the Democratic Republic of Congo, the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

We develop and market low power customizable semiconductor solutions that enable Original Equipment Manufacturers to maximize battery life for highly differentiated, immersive user experiences with Smartphone, Wearable, Hearable, Tablet and Internet-of-Things devices. We deliver these benefits through industry leading ultra-low power customer programmable System on Chip semiconductor solutions, embedded software, and algorithm solutions for always-on voice and sensor processing, and enhanced visual experiences. We are a fabless semiconductor company that provides comprehensive, flexible sensor processing solutions, ultra-low power display bridges, and ultra-low power Field Programmable Gate Arrays, or FPGAs. As a semiconductor company, we have concluded that Conflict Minerals are necessary to the functionality or production of our products.
Our products are manufactured by our industry recognized suppliers in accordance with our specifications. As detailed in our Report, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) reasonably designed to determine if any of these Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources. Our RCOI primarily consisted of submitting the Conflict Minerals Reporting Template (“CMRT”) prepared by the Responsible Minerals Initiative, an initiative of the Responsible Business Alliance and Global eSustainability Initiative for Tier 1 suppliers of our devices in 2017. Responses were reviewed for completeness, reasonableness and consistency, and we routinely followed up for any corrections and clarifications. During 2017, we contracted with Source 44 LLC dba Source Intelligence, a third party vendor to coordinate the efforts of receiving and analyzing the CMRTs. Through Source Intelligence’s database we received detailed information regarding the smelters/refiners and associated mine countries reported in our supply chain.

We submitted this template to six (6) tier 1 suppliers, which represent 100% of the Company's top tier suppliers for 2017. Of these responding suppliers, 100% indicated one or more of the Conflict Minerals are necessary to the functionality or production of the products supplied.
Conflict Minerals Disclosure
This Form SD of the Company is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2017 to December 31, 2017.
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available at http://ir.quicklogic.com/sec.cfm.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 – Exhibits
The following exhibit is filed as part of this report.
Item 2.01 Exhibits.
Exhibit 1.01 – 2017 Conflict Minerals Report of QuickLogic Corporation as required by Items 1.01 and 1.02 of this Form.

2



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.
 
 
 
 
Date: May 15, 2018
 
QuickLogic Corporation
 
 
 
 
/s/ Suping (Sue) Cheung
 
 
 
 
 
Suping (Sue) Cheung
Vice President, Finance and Chief Financial Officer
 


3



EXHIBIT INDEX
 
 
 
 
Exhibit
No.
  
Description
 
 
1.01
  


4
Exhibit


Exhibit 1.01

Conflict Minerals Report
For The Reporting Period from January 1, 2017 to December 31, 2017

This Conflict Minerals Report (the “Report”) of QuickLogic Corporation (“QuickLogic” or the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2017 to December 31, 2017.

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals referred to as “Conflict Minerals” are gold, columbite-tantalite (coltan), cassiterite and wolfamite, including their derivatives which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of Congo (the “DRC”), the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

Description of the Company's Products Covered by this Report

This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2017.

These products, which are referred to in this Report collectively as the "Covered Products," are the following:

QuickLogic Product Platform Families
Description
ARCTICLINK®
Semiconductor device
ARCTICLINK II
Semiconductor device
ARCTICLINK III
Semiconductor device
ARCTICLINK 3 S1
Semiconductor device
ARCTICLINK 3 S2
Semiconductor device
ECLIPSE
Semiconductor device
ECLIPSE II
Semiconductor device
ECLIPSE PLUS
Semiconductor device
EOS S3
Semiconductor device
PASIC®3
Semiconductor device
POLARPRO®
Semiconductor device
POLARPRO II
Semiconductor device
POLARPRO 3
Semiconductor device
POLARPRO 3E
Semiconductor device
QUICKPCI
Semiconductor device
QUICKRAM
Semiconductor device

Description of the Company’s Reasonable Country of Origin Inquiry

As described in this Report, we have determined that the following Conflict Minerals, namely gold, tantalum, tin and tungsten, are necessary to the functionality or production of products contracted to be manufactured by us during the calendar year 2017. As a result, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) reasonably designed to determine if any of these Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources. Our supply chain is complex, and there are many third parties in the supply chain between the ultimate manufacturer of the Covered Products and the original sources of Conflict Minerals. The Company does not directly purchase Conflict Minerals from mines, smelters or refiners. Therefore, the Company must rely on suppliers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products. In designing our

1                            



RCOI, we employed a combination of measures to determine whether the Conflict Minerals in our Covered Products originated from the Covered Countries, and determined that the Company would survey each of its Tier 1 suppliers.

As such, our RCOI primarily consisted of utilizing the Conflict Minerals Reporting Template (“CMRT”) prepared by the Responsible Minerals Initiative, an initiative of the Responsible Business Alliance and Global eSustainability Initiative for Tier 1 suppliers of our devices in 2017. Only CMRT’s 5.01or higher were accepted. Responses were reviewed for completeness, reasonableness and consistency, and we routinely followed up for any corrections and clarifications. During 2017, we contracted with Source 44 LLC dba Source Intelligence, a third party vendor to coordinate the efforts of receiving and analyzing the CMRTs. Through Source Intelligence’s database we received detailed information regarding the smelters/refiners and associated mine countries reported in our supply chain.

We submitted this template to six (6) Tier 1 suppliers and received 100% response rate. Of these responding suppliers, 100% indicated one or more of the Conflict Minerals are necessary to the functionality or production of the products supplied.

Description of the Company’s Due Diligence Process

Based on this information, we performed additional due diligence on the source and chain of custody of these Conflict Minerals pursuant to 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 (“Framework”) to determine if the Conflict Minerals that may have originated in the Covered Countries benefited armed groups.

The Company's due diligence measures have been designed to conform to the framework in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the "OECD Guidance"). The OECD Guidance is an internationally recognized due diligence framework.

In accordance with the five-step OECD Guidance, the design of our due diligence includes, but is not limited to, the following five steps: (i) establishment of strong company management systems, (ii) identification and assessment of risks in the supply chain, (iii) designing and implementing a strategy to respond to identified risks, (iv) carrying out an independent third-party audit of smelter/refiner’s due diligence practices and (v) reporting on supply chain due diligence. A description of certain activities undertaken by us in respect of each of the five steps of the OECD Guidance is described below.

1.
Establishment of Strong Company Management Systems

We have completed a number of steps to establish a management system for addressing the sourcing of Conflict Minerals in our Covered Products. These actions include:

a.
Adopt and Commit to a Supply Chain Policy for Conflict Minerals: Our Conflict Minerals Policy is available at http://www.quicklogic.com/corporate/support/conflict-minerals-policy. Our Policy underscores the Company’s commitment to ethical business conduct and the responsible sourcing of minerals and to working with our suppliers to ensure compliance with SEC regulations.

Our Policy notes the Company’s support of the industry-wide efforts the Responsible Business Alliance and Global eSustainability Initiative are making to address responsible sourcing of minerals through the development of the Responsible Minerals Initiative. Our policy discusses the Company’s adoption and use of the industry standard CMRT created by the Responsible Business Alliance and Global eSustainability Initiative to collect sourcing information related to conflict minerals as an element of our reasonable country of origin inquiry to verify the responsible sourcing of materials and to support compliance with SEC regulations. Listed below under the Findings are the results of the sourcing of minerals provided by the Tier 1 suppliers.

b.
Internal Management to Support Supply Chain Due Diligence: Our Vice President of Operations and Environmental Compliance Specialist (the “Conflict Minerals Team”) participate in the design and execution of our conflict minerals program and cooperate to manage and support our supply chain due diligence. The Conflict Minerals Team identified the suppliers to be contacted and adopted and approved for use the Reporting Template discussed above. The Environmental Compliance Specialist interacts directly with our suppliers and third party, Source Intelligence to obtain updated and current Reporting Templates and analyzes the information provided on the sourcing of the conflict minerals used in the manufacture of the Covered Products. Each response is reviewed to identify missing information and unclear responses. The Environmental Compliance Specialist meets regularly with the Vice President of Operations and Source Intelligence to discuss the results of the due diligence efforts

2                            



and appropriate follow-up measures to be taken with our suppliers. The Vice President of Operations reports on the status of the Company’s supply chain due diligence at regularly scheduled meetings of the Company’s Board of Directors.

c.
Controls and Transparency to Support Supply Chain Diligence: We use the CMRT to identify the smelters and refiners that are in the supply chain of each of our suppliers. We review and compare this list to the list of smelters and refiners identified by the Responsible Minerals Initiative to be active in the Conflict Free Smelter Program. This enables us to identify the smelters and refiners that have been determined to be conflict-free and those that are actively progressing towards an audit to determine their status. We use Source Intelligence's database to further verify the smelter/refiners sourcing information. We have determined that this approach represents the most reasonable effort we can make to determine whether the minerals used in the production of our Covered Products are conflict-free.

d.
Supplier Engagement: We are dependent upon our suppliers to manufacture the Covered Products. We continue to work with our suppliers to support their efforts to identify the sources and status of the Conflict Minerals used in our Covered Products and to encourage each smelter and refiner in our supply chain to become or continue as an active participant in the Conflict Free Smelter Program. We continue to actively engage with our suppliers to strengthen our relationship with them and we have communicated to them our commitment to sourcing Conflict Minerals in a manner that does not benefit armed groups in the Covered Countries.

e.
Grievance Mechanism: We have grievance mechanisms in place that enable employees and suppliers to report violations of the Company’s policies. We have a compliance hotline which is operated by an independent company that may be called at any time to report grievances and invite individuals with grievances to bring these matters to the attention of the Audit Committee of our Board of Directors by written correspondence on a confidential basis. We also employ an email address by which matters may be brought at any time to the attention of our Conflict Minerals Team by sending an email to conflictminerals@quicklogic.com.

2.
Identification and Assessment of Risks in the Supply Chain

Because of our position within our supply chain, it is difficult to identify actors upstream from our Tier 1 suppliers. As discussed above, we identified Tier 1 suppliers and we have relied upon them to provide us with the necessary information about the source of Conflict Minerals contained in the products they manufacture on our behalf. Our suppliers are similarly reliant upon information provided by their suppliers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products.

We requested each of them to complete the CMRT and review the sourcing information provided in response to our requests for accuracy and completeness. In the event we find the responses to the Reporting Template unclear or incomplete, we contact the supplier in question for additional information and clarification. In some cases we may contact the smelter or refiner directly to obtain information. We intend to contact each of our suppliers at least once every six months to check on the status of their continuing due diligence and to obtain updated information. We record all information obtained from the CMRT to identify the smelters and refiners in our supply chain. The list of the smelters and refiners in our supply chain are verified against the lists compiled by the Responsible Minerals Initiative, TI-CMC, LBMA and RJC to determine which smelters and refiners have been determined to be compliant with the Responsible Minerals Assurance Process assessment protocols and certifications.

3.
Designing and Implementing a Strategy to Respond to Identified Risks

In response to this risk assessment, the Company has an approved risk management plan which is implemented, managed and monitored through the above-described Conflict Minerals Team under the oversight of our Board of Directors. Any identified potential risks or quality control flags raised during the evaluation of supplier responses are noted on the Source Intelligence platform and reviewed by the team. We support the continued efforts of the Responsible Minerals Initiative to complete the audits of smelters that have agreed to date to participate in the Responsible Minerals Assurance Process and to encourage other identified smelters to become participants.

As a continuing part of our risk management plan, we have communicated our commitment to the use of conflict-free minerals in the manufacture of our Covered Products and our expectation that the manufacture of our Covered Products will be conflict-free.


3                            



4.
Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

We do not have a direct business relationship with any smelters or refiners in our supply chain and, as a result, we do not directly conduct or request audits. Instead, we support the development and implementation of independent third party audits of smelters by encouraging our suppliers to purchase materials from audited, conflict-free smelters and determine whether the smelters that were used to process these minerals were validated as conflict-free as part of the Responsible Minerals Assurance Process. We monitor smelters or refiners certification status with Source Intelligence and the Responsible Minerals Initiative.

5.
Reporting on Supply Chain Due Diligence

In 2018, we publicly filed the Form SD and this Report with the SEC, and a copy of this Report and the Form SD are publicly available at http://ir.quicklogic.com/sec.cfm.

This Report includes information about the RCOI methodology utilized by the Company, the design of our due diligence process in conformance with the OECD Guidelines, the list of known smelters utilized in our supply chain identified in our due diligence process and a description of our products that incorporate conflict minerals necessary to the functionality or production of such products.

Findings

Based on the information that was provided by the Company’s Tier 1 suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products include the smelters and refiners listed below. Included is whether such smelters have received a “conflict free” designation by the Responsible Minerals Initiative’s Responsible Minerals Assurance Process as of May 15, 2018.
 
Smelter ID
Status
Country
Gold
 
 
 
Advanced Chemical Company
CID000015
CF
UNITED STATES OF AMERICA
Aida Chemical Industries Co., Ltd.
CID000019
CF
JAPAN
Al Etihad Gold LLC
CID002560
CF
UNITED ARAB EMIRATES
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
CF
GERMANY
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
CF
UZBEKISTAN
AngloGold Ashanti Corrego do Sitio Mineracao
CID000058
CF
BRAZIL
Argor-Heraeus S.A.
CID000077
CF
SWITZERLAND
Asahi Pretec Corp.
CID000082
CF
JAPAN
Asahi Refining Canada Ltd.
CID000924
CF
CANADA
Asahi Refining USA Inc.
CID000920
CF
UNITED STATES OF AMERICA
Asaka Riken Co., Ltd.
CID000090
CF
JAPAN
AU Traders and Refiners
CID002850
CF
SOUTH AFRICA
Aurubis AG
CID000113
CF
GERMANY
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
CF
PHILIPPINES
Boliden AB
CID000157
CF
SWEDEN
C. Hafner GmbH + Co. KG
CID000176
CF
GERMANY
CCR Refinery - Glencore Canada Corporation
CID000185
CF
CANADA
Chimet S.p.A.
CID000233
CF
ITALY
Daejin Indus Co., Ltd.
CID000328
CF
KOREA, REPUBLIC OF
DODUCO Contacts and Refining GmbH
CID000362
CF
GERMANY
Dowa
CID000401
CF
JAPAN

4                            



DSC (Do Sung Corporation)
CID000359
CF
KOREA, REPUBLIC OF
Eco-System Recycling Co., Ltd.
CID000425
CF
JAPAN
Emirates Gold DMCC
CID002561
CF
UNITED ARAB EMIRATES
Geib Refining Corporation
CID002459
CF
UNITED STATES OF AMERICA
Gold Refinery of Zijin Mining Group Co., Ltd.
CID002243
CF
CHINA
Heimerle + Meule GmbH
CID000694
CF
GERMANY
Heraeus Metals Hong Kong Ltd.
CID000707
CF
CHINA
Heraeus Precious Metals GmbH & Co. KG
CID000711
CF
GERMANY
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
CF
CHINA
Ishifuku Metal Industry Co., Ltd.
CID000807
CF
JAPAN
Istanbul Gold Refinery
CID000814
CF
TURKEY
Japan Mint
CID000823
CF
JAPAN
Jiangxi Copper Co., Ltd.
CID000855
CF
CHINA
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
CF
RUSSIAN FEDERATION
JSC Uralelectromed
CID000929
CF
RUSSIAN FEDERATION
JX Nippon Mining & Metals Co., Ltd.
CID000937
CF
JAPAN
Kazzinc
CID000957
CF
KAZAKHSTAN
Kennecott Utah Copper LLC
CID000969
CF
UNITED STATES OF AMERICA
Kojima Chemicals Co., Ltd.
CID000981
CF
JAPAN
Korea Zinc Co., Ltd.
CID002605
CF
KOREA, REPUBLIC OF
Kyrgyzaltyn JSC
CID001029
CF
KYRGYZSTAN
LS-NIKKO Copper Inc.
CID001078
CF
KOREA, REPUBLIC OF
Materion
CID001113
CF
UNITED STATES OF AMERICA
Matsuda Sangyo Co., Ltd.
CID001119
CF
JAPAN
Metalor Technologies (Hong Kong) Ltd.
CID001149
CF
CHINA
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
CF
SINGAPORE
Metalor Technologies (Suzhou) Ltd.
CID001147
CF
CHINA
Metalor Technologies S.A.
CID001153
CF
SWITZERLAND
Metalor USA Refining Corporation
CID001157
CF
UNITED STATES OF AMERICA
Metalurgica Met-Mex Penoles S.A. De C.V.
CID001161
CF
MEXICO
Mitsubishi Materials Corporation
CID001188
CF
JAPAN
Mitsui Mining and Smelting Co., Ltd.
CID001193
CF
JAPAN
MMTC-PAMP India Pvt., Ltd.
CID002509
CF
INDIA
Moscow Special Alloys Processing Plant
CID001204
CF
RUSSIAN FEDERATION
Nadir Metal Rafineri San. Ve Tic. A.S.
CID001220
CF
TURKEY
Nihon Material Co., Ltd.
CID001259
CF
JAPAN
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
CF
AUSTRIA
Ohura Precious Metal Industry Co., Ltd.
CID001325
CF
JAPAN
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326
CF
RUSSIAN FEDERATION
OJSC Novosibirsk Refinery
CID000493
CF
RUSSIAN FEDERATION
PAMP S.A.
CID001352
CF
SWITZERLAND
Prioksky Plant of Non-Ferrous Metals
CID001386
CF
RUSSIAN FEDERATION
PT Aneka Tambang (Persero) Tbk
CID001397
CF
INDONESIA
PX Precinox S.A.
CID001498
CF
SWITZERLAND

5                            



Rand Refinery (Pty) Ltd.
CID001512
CF
SOUTH AFRICA
Republic Metals Corporation
CID002510
CF
UNITED STATES OF AMERICA
Royal Canadian Mint
CID001534
CF
CANADA
Samduck Precious Metals
CID001555
CF
KOREA, REPUBLIC OF
SAXONIA Edelmetalle GmbH
CID002777
CF
GERMANY
Schone Edelmetaal B.V.
CID001573
CF
NETHERLANDS
SEMPSA Joyeria Plateria S.A.
CID001585
CF
SPAIN
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
CF
CHINA
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
CF
CHINA
Singway Technology Co., Ltd.
CID002516
CF
TAIWAN, PROVINCE OF CHINA
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
CF
RUSSIAN FEDERATION
Solar Applied Materials Technology Corp.
CID001761
CF
TAIWAN, PROVINCE OF CHINA
Sumitomo Metal Mining Co., Ltd.
CID001798
CF
JAPAN
T.C.A S.p.A
CID002580
CF
ITALY
Tanaka Kikinzoku Kogyo K.K.
CID001875
CF
JAPAN
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
CF
CHINA
Tokuriki Honten Co., Ltd.
CID001938
CF
JAPAN
Torecom
CID001955
CF
KOREA, REPUBLIC OF
Umicore Brasil Ltda.
CID001977
CF
BRAZIL
Umicore Precious Metals Thailand
CID002314
CF
THAILAND
Umicore S.A. Business Unit Precious Metals Refining
CID001980
CF
BELGIUM
United Precious Metal Refining, Inc.
CID001993
CF
UNITED STATES OF AMERICA
Valcambi S.A.
CID002003
CF
SWITZERLAND
Western Australian Mint (T/a The Perth Mint)
CID002030
CF
AUSTRALIA
WIELAND Edelmetalle GmbH
CID002778
CF
GERMANY
Yamakin Co., Ltd.
CID002100
CF
JAPAN
Yokohama Metal Co., Ltd.
CID002129
CF
JAPAN
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
CF
CHINA
Tantalum
 
 
 
Changsha South Tantalum Niobium Co., Ltd.
CID000211
CF
CHINA
D Block Metals, LLC
CID002504
CF
UNITED STATES OF AMERICA
Exotech Inc.
CID000456
CF
UNITED STATES OF AMERICA
F&X Electro-Materials Ltd.
CID000460
CF
CHINA
FIR Metals & Resource Ltd.
CID002505
CF
CHINA
Global Advanced Metals Aizu
CID002558
CF
JAPAN
Global Advanced Metals Boyertown
CID002557
CF
UNITED STATES OF AMERICA
Guangdong Rising Rare Metals-EO Materials Ltd.
CID000291
CF
CHINA
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
CF
CHINA
H.C. Starck Co., Ltd.
CID002544
CF
THAILAND
H.C. Starck Hermsdorf GmbH
CID002547
CF
GERMANY
H.C. Starck Inc.
CID002548
CF
UNITED STATES OF AMERICA

6                            



H.C. Starck Ltd.
CID002549
CF
JAPAN
H.C. Starck Smelting GmbH & Co. KG
CID002550
CF
GERMANY
H.C. Starck Tantalum and Niobium GmbH
CID002545
CF
GERMANY
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
CF
CHINA
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
CF
CHINA
Jiangxi Tuohong New Raw Material
CID002842
CF
CHINA
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
CF
CHINA
Jiujiang Nonferrous Metals Smelting Company Limited
CID000917
CF
CHINA
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
CF
CHINA
KEMET Blue Metals
CID002539
CF
MEXICO
KEMET Blue Powder
CID002568
CF
UNITED STATES OF AMERICA
LSM Brasil S.A.
CID001076
CF
BRAZIL
Metallurgical Products India Pvt., Ltd.
CID001163
CF
INDIA
Mineracao Taboca S.A.
CID001175
CF
BRAZIL
Mitsui Mining and Smelting Co., Ltd.
CID001192
CF
JAPAN
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
CF
CHINA
NPM Silmet AS
CID001200
CF
ESTONIA
Power Resources Ltd.
CID002847
CF
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
QuantumClean
CID001508
CF
UNITED STATES OF AMERICA
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CID001522
CF
CHINA
Solikamsk Magnesium Works OAO
CID001769
CF
RUSSIAN FEDERATION
Taki Chemical Co., Ltd.
CID001869
CF
JAPAN
Telex Metals
CID001891
CF
UNITED STATES OF AMERICA
Ulba Metallurgical Plant JSC
CID001969
CF
KAZAKHSTAN
XinXing HaoRong Electronic Material Co., Ltd.
CID002508
CF
CHINA
Yichun Jin Yang Rare Metal Co., Ltd.
CID002307
CF
CHINA
Tin
 
 
 
Alpha
CID000292
CF
UNITED STATES OF AMERICA
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
CF
CHINA
China Tin Group Co., Ltd.
CID001070
CF
CHINA
CV Ayi Jaya
CID002570
CF
INDONESIA
CV Dua Sekawan
CID002592
CF
INDONESIA
CV Gita Pesona
CID000306
CF
INDONESIA
PT Premium Tin Indonesia
CID000313
CF
INDONESIA
PT Rajehan Ariq
CID002593
CF
INDONESIA
CV United Smelting
CID000315
CF
INDONESIA
CV Venus Inti Perkasa
CID002455
CF
INDONESIA
Dowa
CID000402
CF
JAPAN
EM Vinto
CID000438
CF
BOLIVIA
Fenix Metals
CID000468
CF
POLAND
Gejiu Fengming Metallurgy Chemical Plant
CID002848
CF
CHINA
Gejiu Jinye Mineral Company
CID002859
CF
CHINA
Gejiu Kai Meng Industry and Trade LLC
CID000942
CF
CHINA

7                            



Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
CF
CHINA
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
CF
CHINA
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CID003116
CF
CHINA
Guanyang Guida Nonferrous Metal Smelting Plant
CID002849
CF
CHINA
HuiChang Hill Tin Industry Co., Ltd.
CID002844
CF
CHINA
Huichang Jinshunda Tin Co., Ltd.
CID000760
CF
CHINA
Jiangxi Ketai Advanced Material Co., Ltd.
CID000244
CF
CHINA
Magnu's Minerais Metais e Ligas Ltda.
CID002468
CF
BRAZIL
Malaysia Smelting Corporation (MSC)
CID001105
CF
MALAYSIA
Melt Metais e Ligas S.A.
CID002500
CF
BRAZIL
Metallic Resources, Inc.
CID001142
CF
UNITED STATES OF AMERICA
Metallo Belgium N.V.
CID002773
CF
BELGIUM
Metallo Spain S.L.U.
CID002774
CF
SPAIN
Mineracao Taboca S.A.
CID001173
CF
BRAZIL
Minsur
CID001182
CF
PERU
Mitsubishi Materials Corporation
CID001191
CF
JAPAN
Jiangxi New Nanshan Technology Ltd.
CID001231
CF
CHINA
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
CF
THAILAND
O.M. Manufacturing Philippines, Inc.
CID002517
CF
PHILIPPINES
Operaciones Metalurgical S.A.
CID001337
CF
BOLIVIA
PT Aries Kencana Sejahtera
CID000309
CF
INDONESIA
PT Artha Cipta Langgeng
CID001399
CF
INDONESIA
PT ATD Makmur Mandiri Jaya
CID002503
CF
INDONESIA
PT Babel Inti Perkasa
CID001402
CF
INDONESIA
PT Bangka Prima Tin
CID002776
CF
INDONESIA
PT Bangka Tin Industry
CID001419
CF
INDONESIA
PT Belitung Industri Sejahtera
CID001421
CF
INDONESIA
PT Bukit Timah
CID001428
CF
INDONESIA
PT DS Jaya Abadi
CID001434
CF
INDONESIA
PT Eunindo Usaha Mandiri
CID001438
CF
INDONESIA
PT Inti Stania Prima
CID002530
CF
INDONESIA
PT Karimun Mining
CID001448
CF
INDONESIA
PT Kijang Jaya Mandiri
CID002829
CF
INDONESIA
PT Lautan Harmonis Sejahtera
CID002870
CF
INDONESIA
PT Menara Cipta Mulia
CID002835
CF
INDONESIA
PT Mitra Stania Prima
CID001453
CF
INDONESIA
PT Panca Mega Persada
CID001457
CF
INDONESIA
PT Prima Timah Utama
CID001458
CF
INDONESIA
PT Refined Bangka Tin
CID001460
CF
INDONESIA
PT Sariwiguna Binasentosa
CID001463
CF
INDONESIA
PT Stanindo Inti Perkasa
CID001468
CF
INDONESIA
PT Sukses Inti Makmur
CID002816
CF
INDONESIA
PT Sumber Jaya Indah
CID001471
CF
INDONESIA
PT Timah (Persero) Tbk Kundur
CID001477
CF
INDONESIA
PT Timah (Persero) Tbk Mentok
CID001482
CF
INDONESIA
PT Tinindo Inter Nusa
CID001490
CF
INDONESIA
PT Tommy Utama
CID001493
CF
INDONESIA
Resind Industria e Comercio Ltda.
CID002706
CF
BRAZIL

8                            



Rui Da Hung
CID001539
CF
TAIWAN, PROVINCE OF CHINA
Soft Metais Ltda.
CID001758
CF
BRAZIL
Thaisarco
CID001898
CF
THAILAND
White Solder Metalurgia e Mineracao Ltda.
CID002036
CF
BRAZIL
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
CF
CHINA
Yunnan Tin Company Limited
CID002180
CF
CHINA
Tungsten
 
 
 
A.L.M.T. TUNGSTEN Corp.
CID000004
CF
JAPAN
ACL Metais Eireli
CID002833
CF
BRAZIL
Asia Tungsten Products Vietnam Ltd.
CID002502
CF
VIET NAM
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
CF
CHINA
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
CF
CHINA
Fujian Jinxin Tungsten Co., Ltd.
CID000499
CF
CHINA
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
CF
CHINA
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
CF
CHINA
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
CF
CHINA
Global Tungsten & Powders Corp.
CID000568
CF
UNITED STATES OF AMERICA
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
CF
CHINA
H.C. Starck Smelting GmbH & Co. KG
CID002542
CF
GERMANY
H.C. Starck Tungsten GmbH
CID002541
CF
GERMANY
Hunan Chenzhou Mining Co., Ltd.
CID000766
CF
CHINA
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
CF
CHINA
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
CF
CHINA
Hydrometallurg, JSC
CID002649
CF
RUSSIAN FEDERATION
Japan New Metals Co., Ltd.
CID000825
CF
JAPAN
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
CF
CHINA
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
CF
CHINA
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
CF
CHINA
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
CF
CHINA
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
CF
CHINA
Kennametal Fallon
CID000966
CF
UNITED STATES OF AMERICA
Kennametal Huntsville
CID000105
CF
UNITED STATES OF AMERICA
Malipo Haiyu Tungsten Co., Ltd.
CID002319
CF
CHINA
Niagara Refining LLC
CID002589
CF
UNITED STATES OF AMERICA
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
CF
VIET NAM
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
CF
VIET NAM
Vietnam Youngsun Tungsten Industry Co., Ltd.
CID002011
CF
VIET NAM
Wolfram Bergbau und Hutten AG
CID002044
CF
AUSTRIA
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
CF
CHINA
Xiamen Tungsten Co., Ltd.
CID002082
CF
CHINA
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
CF
CHINA

“CF” indicates that the smelter is audited and certified conflict free by the Responsible Minerals Assurance Process.

Countries of origin that these facilities may source conflict minerals include:

9                            




L1: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States of America, Vietnam, Zimbabwe.

L2: Kenya, Mozambique, South Africa

L3: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia

DRC: Democratic Republic of Congo

Future Steps

We have communicated our expectations, as reflected in our Conflict Minerals Policy, to our contract manufacturers and other suppliers. We have continued to engage with our Tier 1 suppliers to update their information on the source and chain of custody of conflict minerals in our supply chain and to require that all smelters utilized agree to participate in the Responsible Minerals Assurance Process or equivalent program.




10