Exhibit 1.01
CONFLICT MINERALS REPORT OF ANALOG DEVICES, INC. IN ACCORDANCE WITH RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934 (UNAUDITED)
Section 1: Introduction
This is the Conflict Minerals Report of Analog Devices, Inc. (Analog Devices, ADI, we, our) for calendar year 2023 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (Rule 13p-1). Numerous terms in this report are defined in Rule 13p-1 and Form SD and the reader is referred to those sources for such definitions and explanations thereof.
Products manufactured or contracted to be manufactured by Analog Devices may contain tantalum, tin, tungsten and/or gold (collectively, conflict minerals) that are necessary to the functionality or production of our products. Based on the reasonable country of origin inquiry (RCOI) described below, Analog Devices either knows that necessary conflict minerals originated in the Democratic Republic of the Congo or an adjoining country (collectively, Covered Countries) and are not from recycled or scrap sources, or has reason to believe that necessary conflict minerals may have originated in the Covered Countries and has reason to believe that they may not be from recycled or scrap sources. Accordingly, we undertook due diligence on the source and chain of custody of the necessary conflict minerals in our products, as described below. Analog Devices is many steps removed from the mining of the conflict minerals; we do not purchase raw ore or unrefined conflict minerals, and we do no purchasing in the Covered Countries. We either purchase conflict minerals indirectly from a smelter or refiner (SOR) for use in our manufacturing processes or purchase components from suppliers that incorporate conflict minerals. The mine or other point of origin of conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined, and converted to ingots, bullion, or other conflict mineral-containing derivatives.
Analog Devices is a global semiconductor leader dedicated to solving our customers’ most complex engineering challenges. We deliver innovations that connect technology to human breakthroughs and play a critical role at the intersection of the physical and digital worlds by providing the building blocks to sense, measure, interpret, connect, and power. We design, manufacture, test, and market a broad portfolio of solutions, including integrated circuits (ICs), software and subsystems that leverage high-performance analog, mixed-signal and digital signal processing technologies. Our comprehensive product portfolio, deep domain expertise and advanced manufacturing capabilities extend across high-performance precision and high-speed mixed-signal, power management and processing technologies – including data converters, amplifiers, power management, radio frequency (RF) ICs, edge processors and other sensors.
Section 2: Product Scope
We design, manufacture, test, and market a broad portfolio of solutions, including ICs, software and subsystems that leverage high-performance analog, mixed-signal and digital signal processing technologies. Our comprehensive solution portfolio, deep domain expertise and advanced manufacturing capabilities extend across high-performance precision and high-speed mixed-signal, power management and processing technologies – including data converters, amplifiers, power management, RF ICs, edge processors and other sensors. The scope of this report applies to semiconductor ICs, monolithic and multi-chip ICs, multi-component ICs, system-in-package modules/hybrid ICs, and other modules and assembled products. Our ICs are designed to address a wide range of real-world signal processing applications. We sell our products to customers worldwide, many of whom use products spanning our core technologies in a wide range of applications. Our IC product portfolio includes both general-purpose products used by a broad range of customers and applications, as well as application-specific products designed for specific target markets. By using readily available, high-performance, general-purpose products in their systems, we help our customers to reduce complexity and accelerate their time to market. Given the high cost of developing more customized ICs, our standard products often provide a cost-effective solution for many low to medium volume applications. More specifically, our analog ICs monitor, condition, amplify or transform continuous analog signals associated with physical forces. By sensing and analyzing signals near their source, we enable processing, decision making and action at the Intelligent Edge, helping us better translate physical forces like temperature, light, and sound into actionable insights, and enabling the innovations that improve quality of life and solve the world’s most pressing challenges. Our analog ICs also provide voltage regulation and power control to electronic systems. We collaborate with customers to design application-specific solutions and help them to solve their toughest technology challenges. We begin with our existing core technologies, which leverage our analog and mixed signal, power management, RF and microwave, edge processors and other sensors, and devise solutions that more closely meet the needs of a specific customer or group of customers. In certain cases, because we have already developed the core technology platform for our general-purpose products, we can create trusted, application-specific solutions quickly and efficiently.
We produce and market a broad range of ICs and products and operate in one reportable segment based on the aggregation of our operating segments. The ICs sold by each of our operating segments are manufactured using similar semiconductor processes, package manufacturing processes and raw materials in either our own production facilities or by third-party wafer fabricators and package manufacturers.
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Section 3: Reasonable Country of Origin Inquiry
Analog Devices engaged with our relevant suppliers to identify SORs in our supply chain. We define relevant suppliers as those who supply materials to Analog Devices that are known to contain any or all of the conflict minerals, where such conflict minerals are necessary to the functionality and/or production of our products. We reach out to our relevant suppliers to request conflict minerals sourcing information using the Responsible Minerals Initiative (RMI)’s Conflict Minerals Reporting Template (RMI CMRT). Information provided by our relevant suppliers is reviewed for completeness and reasonableness, based on our knowledge of the supplier. Further supplier engagement, as necessary, is undertaken for any additional actions regarding their submission, including but not limited to follow-up and escalation on the identified SORs.
Section 4: Due Diligence Framework
Analog Devices’ due diligence measures are designed to conform, in all material respects, with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development (the OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (OECD 2016) (the OECD Framework), including related supplements for each of the conflict minerals. Below is a description of our due diligence measures pursuant to the OECD Framework:
Step 1. Establish strong company management systems
| • | Analog Devices has adopted a policy regarding conflict minerals (Conflict Minerals Policy). The Conflict Minerals Policy is publicly available on our website and is a key component of our conflict minerals program. The Conflict Minerals Policy reflects ADI’s commitment to ethical practices and compliance with applicable laws and regulations. |
| • | An internal team supported by representatives from different internal groups is tasked to implement our Conflict Minerals Policy and oversee ADI’s conflict minerals program (Conflict Minerals Oversight Committee). The Director of Quality, Environmental Product Compliance, is the assigned team leader who reports through the quality organization to the Vice President, Global Quality and Product Engineering. The Conflict Minerals Oversight Committee reviews our conflict minerals program on a semiannual basis. |
| • | We have adopted a process for identifying suppliers, SORs, or recyclers and scrap supplier sources of conflict minerals within the supply chain. ADI leverages the RMI CMRT to gather information regarding SORs from our first-tier suppliers. We also utilize the RMI and its Responsible Minerals Assurance Process (RMAP) to trace the mine of origin of the conflict minerals when such information is available. The RMI conducts independent audits of smelters and refineries to ensure that all certified smelters and refineries are Conformant1 or actively engaged in the RMAP identification of upstream actors in the supply chain. |
| • | We expect our direct suppliers to have policies and procedures in place that are in compliance with our Conflict Minerals Policy to enable transparency and facilitate our compliance with applicable programs and rules. |
| • | As a participating member of the Responsible Business Alliance and the RMI, ADI utilizes these industry resources to support early risk awareness of issues that may impact SOR status. |
Step 2. Identify and assess risk in the supply chain
The OECD Framework for managing risk is largely directed towards the upstream portion of the supply chain (SORs and mines of origin). As a downstream company in the supply chain, ADI participates in the RMAP under the RMI to identify and review the due diligence process of SORs in our supply chain. The RMI assesses and audits whether SORs adhere to RMAP standards, which meet the requirements of the OECD Framework. Compliant SORs are then designated as Conformant and listed as such on the RMI website. We request suppliers provide information regarding SORs in our supply chain by using the RMI CMRT. We review supplier responses to identify areas for further follow-up and key risks in our supply chain.
Step 3. Design and implement a strategy to respond to identified risks
We encourage suppliers who are sourcing from non-Conformant SORs to move towards using Conformant SORs (as identified via the RMI and other industry-developed third-party audit mechanisms). We contact SORs directly to support participation in the RMI and respond to the RMI’s requests for information as they relate to SOR operational changes, audit requirements or SOR status. If a supplier fails to remedy the risks identified by review of SORs reported to ADI, and subsequent supplier or SOR engagement cannot yield resolution, the supplier status will be escalated for review by the Conflict Minerals Oversight Committee to take measures up to and including termination of our relationship with the supplier, if warranted.
| 1 | “Conformant” means that a smelter has successfully completed an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment. Included smelters and refiners were not necessarily Conformant for all or part of 2023 and may not continue to be Conformant for any future period. |
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Step 4. Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
We rely on industry efforts, including the RMI, to conduct third-party audits of eligible SORs against the RMAP standards, which meet the OECD Framework for due diligence practices. As a member of the RMI, we utilize information from these RMAP audits as well as other recognized industry audits of SORs to validate SOR conformance.
Step 5. Report on supply chain due diligence
This report and the associated Form SD have been filed with the U.S. Securities and Exchange Commission (SEC) and are available on our website.
Section 5: Due Diligence Results
Tracing the conflict minerals we use in our SORs and country of origin of each such mineral is a complex endeavor, but an important aspect of responsible sourcing. To help establish and maintain our supply chain compliance sourcing program, we have followed currently established industry guidelines such as those developed by the RMI under the OECD Framework, which enables companies to source minerals from SORs that have been subjected to a rigorous, independent third-party audit.
To implement our RCOI survey process, we adopted the RMI’s industry approach and leveraged the RMI CMRT to gather information from our first-tier suppliers to help us trace the origin of necessary conflict minerals used in our products by identifying SORs, recyclers and scrap supplier sources of conflict minerals. We also utilized the RMI and its RMAP to trace the mine of origin of conflict minerals when such information was available. The RMI conducts independent audits of SORs to ensure that all certified SORs are Conformant or actively engaged in the RMAP.
The responses from our suppliers listed 248 entities as SORs of conflict minerals in their supply chains. A recognized responsible minerals assurance process verified 240 of these entities as Conformant by the RMI. The following is a summary as of April 3, 2024 of SORs used by our suppliers by mineral type:
Metal | Total SORs Identified(1) | Conformant SORs | ||||||
Gold | 95 | 90 | ||||||
Tantalum | 42 | 42 | ||||||
Tin | 73 | 71 | ||||||
Tungsten | 38 | 37 | ||||||
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Total | 248 | 240 | ||||||
| (1) | SORs included in this table were identified to us by the suppliers. However, not all of the included SORs may have processed necessary conflict minerals contained in our products. Some suppliers may have reported to us SORs that were not in our supply chain due to over-inclusiveness in the information received from their suppliers as a result of reporting to us at a “company level,” meaning that they reported to us the conflict minerals content contained in all of their products, not just the products they sold to us, or for other reasons. Additionally, not all of our suppliers responded to our inquiries. |
After exercising the due diligence described above, Analog Devices concluded that some of its necessary conflict minerals originated in the Covered Countries. Analog Devices was unable to determine whether or not such conflict minerals directly or indirectly financed any armed group(s) in the Covered Countries.
Section 6: Other Matters
Based on the information provided by our suppliers through December 31, 2023, we believe that the facilities that may have been used to process conflict minerals in our products include the SORs listed in Annex I below.
Based on information provided by our suppliers and from the RCOI data from the RMI, we believe that the origin of the conflict minerals contained in our products may include the countries listed in Annex II below as well as recycled and scrap sources.
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Analog Devices will undertake the following steps during the next compliance period to continue to improve the due diligence conducted and to further mitigate the risk that our necessary conflict minerals benefit armed groups in the Covered Countries:
| • | Continue to participate in industry initiatives, such as the RMI. We participate actively in the RMI’s plenary sessions. |
| • | Continue to contact SORs identified as a result of the RCOI process and request their participation in obtaining a “conformant” designation from an industry program such as the RMAP program or equivalent if they have not already done so. |
| • | Strengthen our alternate sourcing strategy to transition out suppliers who fail to comply with our conflict minerals requirements. |
| • | Collaborate with our procurement team by providing them with resources that will guide them in choosing the material suppliers containing any or all of the conflict minerals. |
| • | Explore the use of an automated system for our conflict minerals program. |
This report includes forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, which involve risks and uncertainties. Forward-looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. Forward-looking statements can also be identified by words such as “expects,” “plans,” “intends,” “will,” “may,” and similar terms. Forward-looking statements are not guarantees of future actions or performance. Analog Devices assumes no obligation to revise or update any forward-looking statements for any reason, except as required by law.
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ANNEX I (1)
| Metal | Standard Smelter Name | Smelter Country | ||
| Gold | Aida Chemical Industries Co., Ltd.* | Japan | ||
| Gold | Agosi AG* | Germany | ||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC)* | Uzbekistan | ||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao* | Brazil | ||
| Gold | Argor-Heraeus S.A.* | Switzerland | ||
| Gold | Asahi Pretec Corp.* | Japan | ||
| Gold | Asaka Riken Co., Ltd.* | Japan | ||
| Gold | Aurubis AG* | Germany | ||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | Philippines | ||
| Gold | Boliden Ronnskar* | Sweden | ||
| Gold | C. Hafner GmbH + Co. KG* | Germany | ||
| Gold | CCR Refinery - Glencore Canada Corporation* | Canada | ||
| Gold | Chimet S.p.A.* | Italy | ||
| Gold | Chugai Mining* | Japan | ||
| Gold | DSC (Do Sung Corporation)* | Korea, Republic of | ||
| Gold | Dowa* | Japan | ||
| Gold | Eco-System Recycling Co., Ltd. East Plant* | Japan | ||
| Gold | LT Metal Ltd.* | Korea, Republic of | ||
| Gold | Heimerle + Meule GmbH* | Germany | ||
| Gold | Heraeus Metals Hong Kong Ltd.* | China | ||
| Gold | Heraeus Germany GmbH Co. KG* | Germany | ||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | China | ||
| Gold | Ishifuku Metal Industry Co., Ltd.* | Japan | ||
| Gold | Istanbul Gold Refinery* | Turkey | ||
| Gold | Japan Mint* | Japan | ||
| Gold | Jiangxi Copper Co., Ltd.* | China | ||
| Gold | Asahi Refining USA Inc.* | United States of America | ||
| Gold | Asahi Refining Canada Ltd.* | Canada | ||
| Gold | JX Nippon Mining & Metals Co., Ltd.* | Japan | ||
| Gold | Kazzinc* | Kazakhstan | ||
| Gold | Kennecott Utah Copper LLC* | United States of America | ||
| Gold | Kojima Chemicals Co., Ltd.* | Japan | ||
| Gold | LS MnM Inc.* | Korea, Republic of | ||
| Gold | Materion* | United States of America | ||
| Gold | Matsuda Sangyo Co., Ltd.* | Japan | ||
| Gold | Metalor Technologies (Suzhou) Ltd.* | China | ||
| Gold | Metalor Technologies (Hong Kong) Ltd.* | China | ||
| Gold | Metalor Technologies (Singapore) Pte., Ltd.* | Singapore | ||
| Gold | Metalor Technologies S.A.* | Switzerland | ||
| Gold | Metalor USA Refining Corporation* | United States of America | ||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V.* | Mexico | ||
| Gold | Mitsubishi Materials Corporation* | Japan | ||
| Gold | Mitsui Mining and Smelting Co., Ltd.* | Japan | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S.* | Turkey | ||
| Gold | Navoi Mining and Metallurgical Combinat* | Uzbekistan |
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| Gold | Nihon Material Co., Ltd.* | Japan | ||
| Gold | Ohura Precious Metal Industry Co., Ltd.* | Japan | ||
| Gold | MKS PAMP SA* | Switzerland | ||
| Gold | PT Aneka Tambang (Persero) Tbk* | Indonesia | ||
| Gold | PX Precinox S.A.* | Switzerland | ||
| Gold | Rand Refinery (Pty) Ltd.* | South Africa | ||
| Gold | Royal Canadian Mint* | Canada | ||
| Gold | SEMPSA Joyeria Plateria S.A.* | Spain | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | China | ||
| Gold | Sichuan Tianze Precious Metals Co., Ltd.* | China | ||
| Gold | Solar Applied Materials Technology Corp.* | Taiwan, Province of China | ||
| Gold | Sumitomo Metal Mining Co., Ltd.* | Japan | ||
| Gold | Tanaka Kikinzoku Kogyo K.K.* | Japan | ||
| Gold | Shandong Gold Smelting Co., Ltd.* | China | ||
| Gold | Tokuriki Honten Co., Ltd.* | Japan | ||
| Gold | Torecom* | Korea, Republic of | ||
| Gold | Umicore S.A. Business Unit Precious Metals Refining* | Belgium | ||
| Gold | United Precious Metal Refining, Inc.* | United States of America | ||
| Gold | Valcambi S.A.* | Switzerland | ||
| Gold | Western Australian Mint (T/a The Perth Mint)* | Australia | ||
| Gold | Yamakin Co., Ltd.* | Japan | ||
| Gold | Yokohama Metal Co., Ltd.* | Japan | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | China | ||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd.* | China | ||
| Gold | SAFINA A.S.* | Czechia | ||
| Gold | MMTC-PAMP India Pvt., Ltd.* | India | ||
| Gold | KGHM Polska Miedz Spolka Akcyjna* | Poland | ||
| Gold | T.C.A S.p.A* | Italy | ||
| Gold | Remondis PMR B.V.* | Netherlands | ||
| Gold | Korea Zinc Co., Ltd.* | Korea, Republic of | ||
| Gold | TOO Tau-Ken-Altyn* | Kazakhstan | ||
| Gold | Abington Reldan Metals, LLC* | United States of America | ||
| Gold | L’Orfebre S.A.* | Andorra | ||
| Gold | Italpreziosi* | Italy | ||
| Gold | Wieland Edelmetalle GmbH* | Germany | ||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | Austria | ||
| Gold | SungEel HiMetal Co., Ltd.* | Korea, Republic of | ||
| Gold | Planta Recuperadora de Metales SpA* | Chile | ||
| Gold | NH Recytech Company* | Korea, Republic of | ||
| Gold | Eco-System Recycling Co., Ltd. North Plant* | Japan | ||
| Gold | Eco-System Recycling Co., Ltd. West Plant* | Japan | ||
| Gold | Metal Concentrators SA (Pty) Ltd.* | South Africa | ||
| Gold | Weeerefining* | France | ||
| Gold | Gold by Gold Colombia* | Colombia | ||
| Gold | Coimpa Industrial LTDA* | Brazil |
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| Gold | Advanced Chemical Company** | United States of America | ||
| Gold | Bangalore Refinery** | India | ||
| Gold | KP Sanghvi International Pvt Ltd** | India | ||
| Gold | GG Refinery Ltd.** | Tanzania | ||
| Gold | Yunnan Copper Industry Co., Ltd. | China | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | China | ||
| Tantalum | F&X Electro-Materials Ltd.* | China | ||
| Tantalum | Ximei Resources (Guangdong) Limited* | China | ||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | China | ||
| Tantalum | Jiujiang Tanbre Co., Ltd.* | China | ||
| Tantalum | AMG Brasil* | Brazil | ||
| Tantalum | Metallurgical Products India Pvt., Ltd.* | India | ||
| Tantalum | Mineracao Taboca S.A.* | Brazil | ||
| Tantalum | Mitsui Mining and Smelting Co., Ltd.* | Japan | ||
| Tantalum | NPM Silmet AS* | Estonia | ||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | China | ||
| Tantalum | QuantumClean* | United States of America | ||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd.* | China | ||
| Tantalum | Taki Chemical Co., Ltd.* | Japan | ||
| Tantalum | Telex Metals* | United States of America | ||
| Tantalum | Ulba Metallurgical Plant JSC* | Kazakhstan | ||
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd.* | China | ||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | China | ||
| Tantalum | D Block Metals, LLC* | United States of America | ||
| Tantalum | FIR Metals & Resource Ltd.* | China | ||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* | China | ||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | China | ||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | China | ||
| Tantalum | KEMET de Mexico* | Mexico | ||
| Tantalum | Taniobis Co., Ltd.* | Thailand | ||
| Tantalum | Taniobis GmbH* | Germany | ||
| Tantalum | QSIL Metals Hermsdorf GmbH* | Germany | ||
| Tantalum | Materion Newton Inc.* | United States of America | ||
| Tantalum | Taniobis Japan Co., Ltd.* | Japan | ||
| Tantalum | Taniobis Smelting GmbH & Co. KG* | Germany | ||
| Tantalum | Global Advanced Metals Boyertown* | United States of America | ||
| Tantalum | Global Advanced Metals Aizu* | Japan | ||
| Tantalum | Resind Industria e Comercio Ltda.* | Brazil | ||
| Tantalum | Jiangxi Tuohong New Raw Material* | China | ||
| Tantalum | RFH Recycling Metals Co., Ltd.* | China | ||
| Tantalum | Jiujiang Janny New Material Co., Ltd.* | China | ||
| Tantalum | V&D New Materials (Jiangsu) Co., Ltd.* | China | ||
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd.* | China | ||
| Tantalum | Ximei Resources (Guizhou) Technology Co., Ltd.* | China | ||
| Tantalum | PowerX Ltd.* | Rwanda |
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| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd.* | China | ||
| Tantalum | Avon Specialty Metals Ltd.* | United Kingdom of Great Britain and Northern Ireland | ||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | China | ||
| Tin | Alpha* | United States of America | ||
| Tin | PT Aries Kencana Sejahtera* | Indonesia | ||
| Tin | PT Premium Tin Indonesia* | Indonesia | ||
| Tin | Dowa* | Japan | ||
| Tin | EM Vinto* | Bolivia (Plurinational State of) | ||
| Tin | Estanho de Rondonia S.A.* | Brazil | ||
| Tin | Feinhutte Halsbrucke GmbH* | Germany | ||
| Tin | Fenix Metals* | Poland | ||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | China | ||
| Tin | China Tin Group Co., Ltd.* | China | ||
| Tin | Malaysia Smelting Corporation (MSC)* | Malaysia | ||
| Tin | Metallic Resources, Inc.* | United States of America | ||
| Tin | Mineracao Taboca S.A.* | Brazil | ||
| Tin | Minsur* | Peru | ||
| Tin | Mitsubishi Materials Corporation* | Japan | ||
| Tin | Jiangxi New Nanshan Technology Ltd.* | China | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | Thailand | ||
| Tin | Operaciones Metalurgicas S.A.* | Bolivia (Plurinational State of) | ||
| Tin | PT Artha Cipta Langgeng* | Indonesia | ||
| Tin | PT Babel Inti Perkasa* | Indonesia | ||
| Tin | PT Babel Surya Alam Lestari* | Indonesia | ||
| Tin | PT Bukit Timah* | Indonesia | ||
| Tin | PT Mitra Stania Prima* | 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 Timah Tbk Kundur* | Indonesia | ||
| Tin | PT Timah Tbk Mentok* | Indonesia | ||
| Tin | PT Timah Nusantara* | Indonesia | ||
| Tin | PT Tinindo Inter Nusa* | Indonesia | ||
| Tin | PT Tommy Utama* | Indonesia | ||
| Tin | Rui Da Hung* | Taiwan, Province of China | ||
| Tin | Soft Metais Ltda.* | Brazil | ||
| Tin | Thaisarco* | Thailand | ||
| Tin | White Solder Metalurgia e Mineracao Ltda.* | Brazil | ||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | China | ||
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd.* | China | ||
| Tin | CV Venus Inti Perkasa* | Indonesia | ||
| Tin | Magnu’s Minerais Metais e Ligas Ltda.* | Brazil | ||
| Tin | PT ATD Makmur Mandiri Jaya* | Indonesia | ||
| Tin | O.M. Manufacturing Philippines, Inc.* | Philippines | ||
| Tin | CV Ayi Jaya* | Indonesia | ||
| Tin | PT Rajehan Ariq* | Indonesia |
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| Tin | PT Cipta Persada Mulia* | Indonesia | ||
| Tin | Resind Industria e Comercio Ltda.* | Brazil | ||
| Tin | Super Ligas* | Brazil | ||
| Tin | Aurubis Beerse* | Belgium | ||
| Tin | Aurubis Berango* | Spain | ||
| Tin | PT Bangka Prima Tin* | Indonesia | ||
| Tin | PT Sukses Inti Makmur (SIM)* | Indonesia | ||
| Tin | PT Menara Cipta Mulia* | Indonesia | ||
| Tin | HuiChang Hill Tin Industry Co., Ltd.* | China | ||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* | China | ||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd.* | China | ||
| Tin | PT Bangka Serumpun* | Indonesia | ||
| Tin | Tin Technology & Refining* | United States of America | ||
| Tin | PT Rajawali Rimba Perkasa* | Indonesia | ||
| Tin | Luna Smelter, Ltd.* | Rwanda | ||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd.* | China | ||
| Tin | PT Mitra Sukses Globalindo* | Indonesia | ||
| Tin | TRATHO Metal Quimica* | Brazil | ||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda* | Brazil | ||
| Tin | CRM Synergies* | Spain | ||
| Tin | Rian Resources SDN. BHD.* | Malaysia | ||
| Tin | Fabrica Auricchio Industria e Comercio Ltda.* | Brazil | ||
| Tin | DS Myanmar* | Myanmar | ||
| Tin | PT Putera Sarana Shakti (PT PSS)* | Indonesia | ||
| Tin | Mining Minerals Resources SARL* | Congo, Democratic Republic of | ||
| Tin | PT Belitung Industri Sejahtera* | Indonesia | ||
| Tin | Precious Minerals and Smelting Limited** | India | ||
| Tin | Malaysia Smelting Corporation Berhad (Port Klang)** | Malaysia | ||
| Tungsten | A.L.M.T. Corp.* | Japan | ||
| Tungsten | Kennametal Huntsville* | United States of America | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | China | ||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | China | ||
| Tungsten | Global Tungsten & Powders LLC* | United States of America | ||
| Tungsten | Hunan Chenzhou Mining Co., Ltd.* | China | ||
| Tungsten | Japan New Metals Co., Ltd.* | Japan | ||
| Tungsten | Kennametal Fallon* | United States of America | ||
| Tungsten | Wolfram Bergbau und Hutten AG* | Austria | ||
| Tungsten | Xiamen Tungsten Co., Ltd.* | China | ||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | China | ||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | China | ||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | China | ||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | China | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | China | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | China | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | China | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | China | ||
| Tungsten | Asia Tungsten Products Vietnam Ltd.* | Vietnam |
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| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch* | China | ||
| Tungsten | H.C. Starck Tungsten GmbH* | Germany | ||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG* | Germany | ||
| Tungsten | Masan High-Tech Materials* | Vietnam | ||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | China | ||
| Tungsten | Niagara Refining LLC* | United States of America | ||
| Tungsten | China Molybdenum Tungsten Co., Ltd.* | China | ||
| Tungsten | Avon Specialty Metals Ltd* | United Kingdom of Great Britain and Northern Ireland | ||
| Tungsten | Philippine Chuangxin Industrial Co., Inc.* | Philippines | ||
| Tungsten | Lianyou Metals Co., Ltd.* | Taiwan, Province of China | ||
| Tungsten | Hubei Green Tungsten Co., Ltd.* | China | ||
| Tungsten | Cronimet Brasil Ltda* | Brazil | ||
| Tungsten | Ganzhou Sunny Non-Ferrous Metals Co., Ltd.* | China | ||
| Tungsten | Fujian Xinlu Tungsten Co., Ltd.* | China | ||
| Tungsten | Tungsten Vietnam Joint Stock Company* | Viietnam | ||
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd.* | China | ||
| Tungsten | Plansee Composite Materials GmbH* | Germany | ||
| Tungsten | Lianyou Resources Co., Ltd.* | Taiwan, Province of China | ||
| Tungsten | Kenee Mining Corporation Vietnam** | Vietnam |
| * | Smelter name included in the RMAP Conformant Smelters and Refiners as of April 3, 2024. |
| ** | Smelter name included in the RMI Active Smelters and Refiners List as of April 3, 2024. |
| (1) | We note the following in connection with the information contained in the foregoing list: |
| a) | SORs listed above were identified to us by the suppliers. However, not all of the included SORs may have processed necessary conflict minerals contained in our products. Some suppliers may have reported to us SORs that were not in our supply chain due to over-inclusiveness in the information received from their suppliers as a result of reporting to us at a “company level,” meaning that they reported to us the conflict minerals content contained in all of their products, not just the products they sold to us, or for other reasons. Additionally, not all of our suppliers responded to our inquiries. |
| b) | The compliance status and country location reflected in the list is based solely on information made available by the RMI to its members, without independent verification by us. |
| c) | Country Location is the location of the smelter or refiner and is based solely on information made publicly available by RMI, without independent verification by us. |
ANNEX II
Algeria
Andorra
Antigua and Barbuda
Australia
Argentina
Austria
Azerbaijan
Bahamas
Barbados
Bangladesh
Belgium
Benin
10
Belarus
Bolivia
Bosnia and Herzegovina
Botswana
Brazil
Bulgaria
Burkina Faso
Burundi
Cambodia
Cameroon
Canada
Cayman Islands
Chile
China
Chinese Taipei
Colombia
Costa Rica
Côte D’ivoire
Congo, Democratic Republic of The
Croatia
Curacao
Cyprus
Czech Republic
Denmark
Dominican Republic
Egypt
El Salvador
Ecuador
Estonia
Ethiopia
Fiji
Finland
France
French Guiana
Georgia
Germany
Ghana
Grenada
Greece
Guatemala
Guinea
Guyana
Honduras
Hong Kong
Hungary
Iceland
India
11
Indonesia
Ireland
Israel
Italy
Jamaica
Jordan
Korea, Republic of
Kazakhstan
Kenya
Kuwait
Kyrgyzstan
Lao People’s Democratic Republic
Laos
Latvia
Lebanon
Liberia
Liechtenstein
Lithuania
Luxembourg
Macao
Madagascar
Mali
Malta
Mauritania
Mauritius
Mexico
Monaco
Mongolia
Morocco
Mozambique
Myanmar
Namibia
Netherlands
New Zealand
Nicaragua
Niger
Nigeria
Norway
Oman
Pakistan
Panama
Papua New Guinea
Peru
Philippines
Poland
Portugal
Puerto Rico
12
Romania
Russia
Rwanda
Saint Kitts and Nevis
Saint Maarten
Saudi Arabia
Senegal
Serbia
Sierra Leone
Singapore
Slovakia
Slovenia
South Africa
Spain
St Vincent and Grenadines
Sudan
Suriname
Sweden
Tajikistan
Tanzania
Thailand
Trinidad and Tobago
Tunisia
Turkey
Turks and Caicos
Uganda
Ukraine
United Arab Emirates
United Kingdom of Great Britain and Northern Ireland
United States of America
Uruguay
Uzbekistan
Vietnam
Zambia
Zimbabwe
13
