Qorvo (QRVO) SDConflict minerals disclosure

Qorvo, Inc. (herein referred to as the “Company”, “Qorvo”, “we”, “us”, or “our”) presents this Conflict Minerals Report (“CMR”) for the year ended December 31, 2022 (“Reporting Period”), pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). This CMR should be read in conjunction with the definitions contained in the instructions to Form SD and related rules of the Securities and Exchange Commission (“SEC”). The SEC defines “conflict minerals” as columbite-tantalite (coltan), cassiterite, wolframite, gold, and their derivatives, which are limited to tantalum, tin, and tungsten (also referred to as “3TG”).

Qorvo (Nasdaq: QRVO) is a global leader in the development and commercialization of technologies and products for wireless, wired and power markets. In the second quarter of fiscal year 2023, the Company updated its organizational structure from two operating segments (Mobile Products and Infrastructure and Defense Products) to three operating segments (High Performance Analog (“HPA”), Connectivity and Sensors Group (“CSG”) and Advanced Cellular Group (“ACG”)). This change was made to more closely align technologies and applications with customers and end markets.

HPA is a leading global supplier of radio frequency (“RF”) and power solutions for automotive, defense and aerospace, cellular infrastructure, broadband and other markets.

CSG is a leading global supplier of connectivity and sensor solutions, with broad expertise spanning ultra-wideband (“UWB”), Matter®, Bluetooth® Low Energy, Zigbee®, Thread®, Wi-Fi®, cellular Internet of Things (“IoT”), microelectromechanical system (“MEMS”)-based sensors and bulk acoustic wave (“BAW”)-based sensors.

ACG is a leading global supplier of cellular RF solutions for smartphones, wearables, laptops, tablets and other devices.

Qorvo is committed to the responsible sourcing of minerals and strives to conduct activities that respect and support human rights throughout its global supply chain. We work extensively on the issue of conflict minerals and recognize that collaborative efforts among industry stakeholders are needed to identify and mitigate the potential risks associated with 3TG extraction in the Democratic Republic of the Congo or an adjoining country (collectively referred to as the “Covered Countries”). Qorvo is a member of the Responsible Minerals Initiative (“RMI”), where we actively participate on various RMI sub-teams and regularly collaborate with industry peers and other stakeholders to address 3TG related issues and promote responsible mineral sourcing.

Guidance”). Due to our position in the supply chain, we rely on our suppliers to provide information on the conflict minerals necessary to the functionality and production of Qorvo products, and we collaborate with industry peers and other stakeholders to meet our responsible mineral goals and customer expectations. Suppliers are requested to assist in our Reasonable Country of Origin Inquiry (“RCOI”) and due diligence efforts, which include identifying the smelters and refiners who process the conflict minerals used in components and/or materials supplied to Qorvo.

For the Reporting Period, in accordance with Rule 13p-1, we conducted a good faith RCOI to determine if any of the conflict minerals used in our products originated in the Covered Countries, or from recycled or scrap sources. As a result of this effort, we determined that some of the 3TG used in our products may have originated in the Covered Countries. Therefore, we have exercised due diligence to determine the source of these conflict minerals, as described in this CMR below.

Upon the exercise of our due diligence – which is subject to and limited by our ability to obtain reliable information for the conflict minerals used in our products – we have not identified any occurrence where our 3TG sourcing has directly or indirectly financed or benefited armed groups in the Covered Countries.

For the year ended December 31, 2022, Qorvo’s RCOI process began with identifying our “relevant suppliers” – direct suppliers who supply Qorvo with components and/or materials containing 3TG – and surveying those suppliers with the RMI developed Conflict Minerals Reporting Template (“CMRT”). This survey requested relevant suppliers to identify the smelters and refiners used to process the 3TG contained in the components and/or materials supplied to Qorvo. We evaluated supplier responses for completeness, accuracy, and degree of potential supply chain risk, and engaged with those suppliers whose CMRTs we identified to contain potential risks and/or incomplete or inaccurate data. We also reviewed the smelters and refiners identified by our suppliers against the lists of processing facilities that are validated as conformant to a third-party audit program, such as the RMI’s Responsible Minerals Assurance Process (“RMAP”), London Bullion Market Association (“LBMA”) Responsible Gold Program, or the Responsible Jewellery Council (“RJC”) Chain-of-Custody Certification. To the extent reasonably possible, we determined country of origin information for the SORs identified by our suppliers from sources including supplier CMRT responses, third-party audit programs, and publicly available resources such as smelter and refiner websites, if we determined such publicly available information to be reliable.

Qorvo conducted a 3TG survey of 231 suppliers for the Reporting Period.

As of April 1, 2023, the results of our RCOI were as follows:

We had one supplier that did not provide a response to our 3TG survey for the Reporting Period, and 11 suppliers that have not yet identified all the SORs supplying 3TG to their supply chain. Due to these limitations in our sourcing data, we were unable to determine the origin of all the conflict minerals used in our products for the Reporting Period. Qorvo’s due diligence with these suppliers is ongoing and we continue to work our escalation process to drive improvements in their responses.

Qorvo’s responsible minerals program includes due diligence measures for the use of 3TG in its global supply chain and is designed to conform with the OECD Due Diligence Guidance as it relates to our position in the supply chain as a “downstream” company.

In alignment with the OECD’s five-step framework for risk-based due diligence, Qorvo performed the following activities to exercise due diligence on the sources of 3TG used in our products for the Reporting Period.

The due diligence measures listed above can only provide reasonable, not absolute, assurance regarding the origin of the conflict minerals used in our products. Our due diligence process is based on obtaining accurate 3TG information from our relevant suppliers and those suppliers obtaining similar information from their supply chains to identify the original sources of the 3TG used in our products. As we do not directly purchase from any SORs – nor do the majority of our suppliers – we have very little influence over SOR sourcing. We rely, to a large extent, on the information provided by independent third-party audit programs. Such sources of information may contain incomplete or inaccurate data and may be subject to fraud.

We rely on the good faith efforts of our relevant suppliers to provide us with reasonable representations of the smelters and refiners used to process the 3TG contained in our products for the Reporting Period. However, many of our suppliers provided survey responses representing their supply chains at the company level or included 3TG data for components and/or materials beyond those that were supplied to Qorvo. As a result, the list of processing facilities disclosed in Table 2 below likely contains more facilities than those that were actually used to process the conflict minerals contained in our products.

For the Reporting Period, our suppliers identified 385 facilities as potential sources of the 3TG believed to be in Qorvo’s supply chain. We conducted due diligence on these reported facilities, including whether they are actual smelters or refiners (according to the definitions used by the RMI); whether they are currently operational; and whether they are conformant to a third-party audit program such as the RMAP, LBMA or RJC.

Of the 385 potential SORs identified by our suppliers, 57 were subsequently found to be ineligible for the RMAP as they were either inoperative or did not meet the RMI’s definition of a 3TG smelter or refiner. These facilities are not included in this report as “processing facilities” and are not included in the sections below.

The use of the terms “smelters and refiners” and “processing facilities” throughout this CMR refers to 3TG entities that 1) were reported in a supplier’s CMRT for the Reporting Period; 2) determined to meet the RMI’s definition of a smelter or refiner; and 3) determined to be operational in 2022. In some cases, our suppliers reported facilities that Qorvo believes are not currently eligible to participate in a third-party audit program. These facilities are not included in the data below. However, we continue to conduct due diligence on such entities and work with our relevant suppliers to improve the quality of the 3TG data reported to Qorvo.

For the purposes of this CMR, participation status is defined in the following manner:

Qorvo is committed to the responsible sourcing of 3TG and will continue to advance the implementation of its responsible mineral program with relevant suppliers.

For the 2023 reporting period, we plan to: