Exhibit 1.01
Conflict Minerals Report
Calix, Inc.
For the Year Ended December 31, 2022
This Conflict Minerals Report (“CMR”) is provided to comply with Rule 13p-1 of the Securities Exchange Act of 1934, as amended, for Calix, Inc. (“Calix”) for the calendar year ending December 31, 2022. Rule 13p-1, as implemented by the Securities and Exchange Commission (“SEC”), imposes reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Rule 13p-1 applies to SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products, other than conflict minerals sourced solely from recycled or scrap sources. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten and gold, referred to as 3TG.
If a registrant has reason to believe that any of the conflict minerals in their 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 a registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the source and chain of custody of those conflict minerals.
Overview
Calix is a leading global provider of cloud and software platforms, systems and services that focus on the access network, the portion of the network that governs available bandwidth and determines the range and quality of services that can be offered to subscribers. Calix’s cloud and software platforms enable communication service providers to provide a wide range of revenue-generating services, from basic voice and data to advanced broadband services, over legacy and next-generation access networks. Calix primarily relies upon third-party manufacturing partners to manufacture its products, purchase components or materials that may contain smelted or refined minerals and purchase raw ore or minerals. Calix is several levels removed from the purchase of raw ore and minerals or the mining of conflict minerals which occurs much further upstream in the supply chain.
For purposes of Rule 13p-1, we engaged a third-party vendor to assist with survey efforts and outreach with our third-party manufacturing partners and to make inquiries regarding suppliers further upstream in order to ascertain information on the conflict mineral content in our products as well as the origin of the conflict minerals in components and materials in our products. We rely upon third-party manufacturing partners, consisting of contract manufacturers and original design manufacturers, to source for and produce our products based on our requirements, and in some cases, we have no visibility into the upstream suppliers and do not control the supplier sourcing decisions. In selecting manufacturing partners, we require partners to regularly engage with and assess their supplier base as relevant to the components and materials for Calix products.
Based on evaluations together with our manufacturing partners for 2022, we identified that some components and materials that are included in Calix access systems contain conflict minerals.
Reasonable Country of Origin Inquiry
In order to perform a reasonable country of origin inquiry, or RCOI, we and our third-party vendor worked directly with our suppliers and our third-party manufacturers to conduct surveys of their direct supplier base to determine whether the conflict minerals contained in components of Calix products originated from the Covered Countries. This survey was conducted using the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”), and included inquiries related to the facilities used to process conflict minerals, a supplier’s commitment and processes to support conflict free sourcing and the smelters and refiners used, including a supplier’s further inquiries made upstream in the supply chain to ascertain such information. The survey
was used to collect information to facilitate our understanding of the country of origin of conflict minerals and information on the conflict free status for smelters and refiners used by the supplier or its upstream suppliers.
For 2022, surveys were distributed to approximately 239 suppliers with a reported response rate of 98% for completed surveys. To support improved response rate and quality of the CMRT process, personnel that have oversight responsibilities for conflict minerals within our manufacturing partner organizations review the CMRT responses and engage with our manufacturing partners to conduct follow-up inquiries for CMRT completeness and accuracy. Information regarding the RMI is included in surveys sent to the supplier base and manufacturing partners generally provide information and training to assist suppliers with completing the CMRT.
Based on the RCOI described above, we have reason to believe that some of the components used in the manufacture of our products in 2022 contained conflict minerals that originated from the Covered Countries and were not sourced solely from recycled or scrap sources.
Supply Chain Due Diligence and Assessment
Based on the RCOI on our supply chain and as required by Rule 13p-1, we undertook due diligence on our supply chain. The objective of this due diligence was to ascertain whether the conflict minerals directly or indirectly financed or benefited arms groups in the Covered Countries, including for the smelters identified through the CMRTs as providing conflict minerals that originated from the Covered Countries.
Based on our RCOI for 2022, there were approximately 477 smelters and refiners that were identified by suppliers as a source of conflict minerals, of which 153 were known to be sourcing conflict minerals originating from the Covered Countries. We conducted further due diligence on our supply chain to assess the source and chain of custody of the conflict minerals applying due diligence measures designed to conform with the Organization for Economic Co-operation and Development Due Diligence Guidelines for Responsible Supply Chains of Minerals from High-Risk Areas and related supplements. These further actions included:
•Collection of conflict minerals information from the supply chain utilizing the CMRT
•Reviews of supplier, smelter and refinery information in CMRT responses for plausibility, consistency and completeness
•Follow-up efforts with suppliers for information about identified smelters and refiners
•Engagement with suppliers for further conflict minerals reporting upstream through the supply chain
•Review whether identified smelters and refiners, including those identified as a source of conflict minerals originating from the Covered Countries, are listed as participating in the Responsible Minerals Assurance Process (“RMAP”) operated by the RMI or otherwise verified as conflict free by industry recognized programs
•Conduct supplier outreach as recommended and in support of RMI initiatives, particularly for non-responding suppliers
Based on the due diligence conducted, we determined that 153 of the smelters and refiners identified to supply conflict minerals originating in the Covered Countries are included on the RMI list of conformant, active and eligible smelters and refiners pursuant to the RMAP program operated by the RMI. Based on the information provided by our suppliers, we believe that the facilities that may have been used to process the 3TG minerals in our products include the smelters and refiners listed in Appendix I to this CMR. Pursuant to Rule 13p-1, this CMR is not subject to an independent private sector audit.
Ongoing Risk Management
We intend to continue our work with our manufacturing partners and suppliers to improve response rates to our conflict minerals surveys, including through direct and indirect outreach efforts, and to improve awareness upstream in the supply chain. We also expect to further refine conflict minerals assessments and inquiries as part of our supplier and manufacturer partner evaluation processes. This CMR is also available on Calix’s Investor Relations website at: https://investor-relations.calix.com under Governance – Governance Documents.
Forward-Looking Statements
Statements made in this report that are not statements of historical fact are forward-looking statements. Forward-looking statements are subject to the “safe harbor” provisions of the Private Securities Litigation Reform Act of 1995. Forward-looking statements are based on our current expectations and assumptions about our business and operations and are subject to risks and uncertainties that could cause actual results to differ materially from expectations. These risks and uncertainties include the effect of changes in laws and regulations, economic, market and business conditions, the performance and operations of third-party partners and suppliers, availability of critical components and materials, and other risks as described in our Form 10-K and our quarterly reports on Form 10-Q, each as filed with the SEC. Forward-looking statements speak only as of the date the statements are made and are based on information available to us at the time those statements are made and/or management’s good faith belief as of that time with respect to future events. We assume no obligation to update forward-looking statements to reflect actual performance or results, changes in assumptions or changes in other factors affecting forward-looking information, except to the extent required by applicable securities laws.
Appendix I
| | | | | | | | | | | |
Metal | Smelter or Refiner Name | Smelter or Refiner Country | Smelter ID |
Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 |
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
Gold | African Gold Refinery | UGANDA | CID003185 |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 |
Gold | Aurubis AG | GERMANY | CID000113 |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
Gold | K.A. Rasmussen | NORWAY | CID003497 |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
Gold | L'Orfebre S.A. | ANDORRA | CID002762 |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
Gold | PAMP S.A. | SWITZERLAND | CID001352 |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 |
| | | | | | | | | | | |
Metal | Smelter or Refiner Name | Smelter or Refiner Country | Smelter ID |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 |
Gold | Sovereign Metals | INDIA | CID003383 |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 |
Gold | Sudan Gold Refinery | SUDAN | CID002567 |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
Gold | YAMAKIN CO., LTD. | JAPAN | CID002100 |
Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
Tantalum | Meta Materials | NORTH MACEDONIA, REPUBLIC OF | CID002847 |
Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 |
Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | CID000456 |
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 |
Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 |
Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
Tantalum | KEMET Blue Metals | MEXICO | CID002539 |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
Tantalum | NPM Silmet AS | ESTONIA | CID001200 |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 |
| | | | | | | | | | | |
Metal | Smelter or Refiner Name | Smelter or Refiner Country | Smelter ID |
Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 |
Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 |
Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
Tin | Alpha | UNITED STATES OF AMERICA | CID000292 |
Tin | Metallo Belgium N.V. | BELGIUM | CID002773 |
Tin | Metallo Spain S.L.U. | SPAIN | CID002774 |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 |
Tin | China Tin Group Co., Ltd. | CHINA | CID001070 |
Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 |
Tin | EM Vinto | BOLIVIA (Plurinational State of) | CID000438 |
Tin | Fenix Metals | POLAND | CID000468 |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
Tin | Luna Smelter, Ltd. | RWANDA | CID003387 |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | CID003379 |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
Tin | Minsur | PERU | CID001182 |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM | CID002573 |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (Plurinational State of) | CID001337 |
Tin | Pongpipat Company Limited | MYANMAR | CID003208 |
Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 |
Tin | PT Bukit Timah | INDONESIA | CID001428 |
Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 |
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
Tin | PT Timah Nusantara | INDONESIA | CID001486 |
Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
| | | | | | | | | | | |
Metal | Smelter or Refiner Name | Smelter or Refiner Country | Smelter ID |
Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
Tin | Soft Metais Ltda. | BRAZIL | CID001758 |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIETNAM | CID002834 |
Tin | Thaisarco | THAILAND | CID001898 |
Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | CID002180 |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 |
Tin | VQB Mineral and Trading Group JSC | VIETNAM | CID002015 |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
Tungsten | Meta Materials | NORTH MACEDONIA | CID002847 |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 |
Tungsten | A.L.M.T Corp. | JAPAN | CID000004 |
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | CID002502 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
Tungsten | Cronimet Brasil Ltda | BRAZIL | CID003468 |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | CID003401 |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
Tungsten | KGETS CO., LTD. | KOREA, REPUBLIC OF | CID003388 |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 |
Tungsten | Masan High-Tech Materials | VIETNAM | CID002543 |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | CID001889 |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
Tungsten | Woltech Korea Co., Ltd. | UNKNOWN | CID002842 |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |