EXHIBIT 1.01
SanDisk Corporation
_____________________________
2014 CONFLICT MINERALS REPORT
This Conflict Minerals Report of SanDisk Corporation (together with its subsidiaries unless the context otherwise requires, “SanDisk,” the “Company,” “we,” “us,” or “our”) for calendar year 2014 has been prepared in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended (the “Act”). Numerous terms used but not defined in this report have the meanings assigned to them in Rule 13p-1 and Form SD under the Act.
In accordance with Rule 13p-1, we undertook efforts to determine whether the tungsten, tin, tantalum and gold (collectively, the “conflict minerals”) that are necessary to the functionality or production of a product manufactured by us or contracted by us to be manufactured (“necessary conflict minerals”) in calendar year 2014 were sourced from the Democratic Republic of Congo and adjoining countries, as designated by the U.S. Secretary of State (collectively, the “covered countries”), and, if so, whether such necessary conflict minerals directly or indirectly finance or benefit armed groups in the covered countries. We designed our efforts to be in conformity, in all materials respects, with the internationally recognized due diligence framework set forth in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (the “OECD Framework”) and the related supplements for each of the conflict minerals.
SanDisk is a global leader in flash storage solutions with a strong history of innovative products. Our products include flash storage solutions for enterprise data centers and client computing platforms, as well as removable and embedded flash products for mobile devices, cameras, computing devices, automotive, connected home electronics and other applications. Most of our products are made by combining NAND flash memory with a controller and firmware, as well as numerous other components, all of which, other than firmware, may contain conflict minerals or utilize conflict minerals in the production process. As a “downstream” purchaser, we are many steps removed from the mining of conflict minerals. We buy electronic components and mechanical parts (collectively, “parts”) for integration into the products we sell to our customers. We do not purchase raw ore or unrefined conflict minerals and conduct no purchasing activities directly in the covered countries.
Reasonable Country of Origin Inquiry
In our efforts to determine whether, for calendar year 2014, any necessary conflict minerals originated in the covered countries or are from recycled or scrap sources, we performed, in good faith, a reasonable country of origin inquiry (“RCOI”). To determine which suppliers to include in our RCOI, we identified the manufacturing suppliers of parts within our products that contain or may contain necessary conflict minerals. We then requested each of these suppliers to provide us with conflict minerals data using the Conflict Minerals Reporting Template published by the Conflict-Free Sourcing Initiative (“CFSI”).
In their responses to us, suppliers identified various smelters processing tin, tungsten and tantalum and refiners processing gold (collectively, “smelters”) as facilities that may have processed conflict minerals for our products. We then compiled and reviewed this data and, in doing so, compared the data to lists published by the CFSI of smelters that have been found by the CFSI to be compliant with CFSI’s Conflict-Free Smelter Program assessment protocols, are in progress toward compliance or are otherwise actively participating in the program (collectively, the “CFSI List”), as well as the Good Delivery List published by the London Bullion Market Association (“LBMA”).
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Based on our RCOI, we had reason to believe that the necessary conflict minerals may have originated in the covered countries and may not have come from recycled or scrap sources. Accordingly, we performed due diligence on our supply chain for calendar year 2014, as described in further detail below.
Supply Chain Due Diligence
We designed our supply chain due diligence measures for calendar year 2014 based on the OECD Framework and related supplements in an effort to determine, to the best of our ability, the source and chain of custody of the necessary conflict minerals for our products and, if any necessary conflict minerals originated in a covered country, whether armed groups directly or indirectly benefitted as a result. Our due diligence measures included, among others, the following:
| • | Governance Structure. Our compliance with Rule 13p-1was overseen by an internal, cross-functional team that included representatives from our operations, finance, legal, internal audit and risk management organizations. Working group members reported to our Executive Steering Committee, which in turn reported to the Audit Committee of our Board of Directors, status updates on our due diligence program and compliance with Rule 13p-1. |
| • | Data Assessment Procedures. As part of our RCOI, we requested suppliers to provide information at a company, product category and product-specific level. We tracked supplier responses to our RCOI and reviewed and validated information provided by suppliers using our data management system. We enhanced our data collection and analysis, including through the initial implementation of a third-party conflict minerals data management system. In reviewing supplier responses, we assessed the reasonableness of the information that we received based on factors such as the completeness and quality of the response and noted any “red flags.” We followed up with relevant suppliers, in some cases second-tier suppliers, and industry sources, as needed, to obtain initial responses, additional data and clarifications. |
| • | Smelter Validation. We validated smelters identified by our suppliers against the CFSI List and the LBMA’s Good Delivery List. We categorized the smelters into the following categories: |
| (1) | Compliant. The smelter is either: (a) part of the Conflict-Free Smelter Program, has completed an audit commissioned by the CFSI and has demonstrated that all the conflict minerals processed by the smelter originated from conflict-free sources (“CFSI-compliant”); or (b) accredited by the LBMA (“LBMA-accredited”). |
| (2) | Validated. CFSI has assigned the smelter an identification number, validating that the smelter exists, but the smelter is neither CFSI-compliant nor LBMA-accredited. |
| (3) | Other. The smelter is not on either the CFSI List or the LBMA’s Good Delivery List and further diligence is needed. |
| • | Conflict Minerals Policy. We have a Conflict Minerals Policy that we expect suppliers of production materials, components and manufacturing services throughout our supply chain to support. Our Conflict Minerals Policy is publicly available on our website at http://www.sandisk.com/about-sandisk/corporate-responsibility/social/. |
| • | Supplier Code of Conduct. Our Supplier Code of Conduct includes guidelines related to responsible sourcing of conflict minerals modeled after the Electronic Industry Citizenship Coalition (“EICC”) Code of Conduct. Our Supplier Code of Conduct is publicly available on our website at http://www.sandisk.com/about-sandisk/supplier-management/. |
| • | Internal Training. We provided internal training to personnel in relevant business functions, including operations, research and development, finance, legal, internal audit and risk management, on conflict minerals and compliance with Rule 13p-1. We developed and implemented an internal online tool to ensure standardized and comprehensive conflict minerals training for such personnel. |
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| • | Industry Group Participation. As a member of the EICC, we worked with industry groups focused on advancing social responsibility and promoting the sourcing of conflict-free minerals and engaged regularly with our industry peers in order to further develop and better implement standards, tools and best practices relating to conflict minerals. We were actively involved in the CFSI, with certain SanDisk personnel serving as members on the CFSI’s Smelter Engagement Team and Due Diligence Practices Team. |
DRC Conflict Status
Based on our due diligence efforts described above, we were unable to determine that the necessary conflict minerals did not originate in the covered countries or did not directly or indirectly finance or benefit armed groups in the covered countries. Accordingly, we have concluded that, for calendar year 2014, all of the products manufactured by us or contracted by us to be manufactured are DRC conflict undeterminable.
Product Descriptions
We identified the following products manufactured by us or contracted by us to be manufactured in 2014 that may contain necessary conflict minerals:
| • | Removable Cards: Removable flash cards designed for use in a variety of applications and consumer devices, including digital cameras, camcorders, mobile products such as smartphones, tablets and eReaders, as well as in automobiles, connected home electronics and other applications |
| • | Embedded Products: Embedded flash products designed for use in mobile phones, tablets, notebooks, wearable devices, automobiles, connected home electronics and various other applications, including our iNAND™ embedded flash product line, our multi-chip packages solutions and custom embedded solutions |
| • | Client Solid State Drives: Solid state drives for client computing applications, which encompass desktop computers, notebook computers, tablets and other computing devices |
| • | Enterprise Solid State Drives: Enterprise solid state drives used in high-capacity and/or high-performance data storage applications and encompassing all major storage interface protocols, including Serial Attached SCSI (SAS), Serial ATA (SATA) and Peripheral Component Interconnect Express (PCIe) |
| • | USB Flash Drives: USB flash drives used in computing and consumer devices |
| • | Digital Media Players and Wireless Drives: Flash-based digital media players and wireless media and flash drive products |
| • | Wafers and Components: Flash memory wafers and memory components that we sell to customers who package the memory under their own brands or embed the memory in other products |
Facility Information
Smelters identified to us by our suppliers as facilities that may have processed necessary conflict minerals for our products and that we have categorized as either “compliant” or “validated,” as described above, as well as the countries from aggregate lists of countries from which these smelters collectively source conflict minerals, to the extent such detailed sourcing information has been reported to the CFSI, are listed in Appendix A hereto. Our efforts to determine the mine or location of origin of the necessary conflict minerals in our products with the greatest possible specificity consisted of the due diligence measures described in this report. In particular, as the CFSI, through its Conflict-Free Smelter Program, assesses whether sufficient evidence exists regarding the mine or location of origin of the conflict minerals processed by smelters in the program, we have relied upon the smelter information made available by the CFSI.
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Further Mitigating Steps
To further mitigate the risk that our necessary conflict minerals benefit armed groups in the covered countries and to improve our due diligence processes, we have taken or intend to take the following steps in calendar year 2015:
| • | Continued Supplier Engagement. We continue to engage with suppliers to improve supplier response rates and the accuracy, specificity and completeness of information provided by them. We also continue to impress upon them the importance of sourcing conflict minerals responsibly and garner their efforts to transition to CFSI-compliant or LBMA-accredited smelters. Through such efforts, we aim to ultimately encourage smelters to achieve and maintain compliance with the Conflict-Free Smelter Program or accreditation from the LBMA. We continue to require supplier compliance with our Conflict Minerals Policy and our Supplier Code of Conduct. |
| • | Enhanced Data Management Systems. We are further enhancing our conflict minerals data collection and analysis by, among other things, implementing additional functionality in our third-party conflict minerals data management system. |
| • | Ongoing Smelter Validation. We continue to compare and validate the information we have received from suppliers against updated information collected via the Conflict-Free Smelter Program, as well as the LBMA’s Good Delivery List. |
| • | Continued Industry Collaboration. We continue to participate with the CFSI in creating industry-wide mechanisms relating to conflict minerals compliance using collaborative and collective measures, as well as continue to collaborate with industry peers to improve the systems of transparency and control in our common supply chains. We benchmark our conflict minerals practices against those of our industry peers as they evolve to determine best practices and make further improvements. |
The historical statements contained in this report are based on our RCOI and supply chain due diligence efforts performed in good faith by us for the period covered by this report and on the conflict minerals reporting infrastructure and information available to us at the time of the filing of the Form SD to which this report relates. A number of factors could affect the accuracy of these statements, including unavailable, incomplete or inaccurate supplier, smelter or mine data or other information from industry or other third-party sources, evolving smelter designations or further guidance from the Securities and Exchange Commission regarding Rule 13p-1 and Form SD.
This report also contains forward-looking statements, including our plans to mitigate risk and improve our due diligence processes, which are based on our current expectations and involve numerous risks and uncertainties that may cause these forward-looking statements to be inaccurate. Risks that may cause these forward-looking statements to be inaccurate include: we may fail to carry out these plans in a timely manner or at all; our suppliers, their respective suppliers and smelters, our industry peers or industry groups may not cooperate with us in our efforts to carry out these plans; these plans may not be effective; or other risks detailed from time-to-time in our Securities and Exchange Commission filings and reports, including, but not limited to, our most recent quarterly report on Form 10-Q. We do not intend to update the information contained in this report.
Information contained on the websites referenced in this report, including, but not limited to, information in our Conflict Minerals Policy and Supplier Code of Conduct, is not a part of this report, and the inclusion of such website addresses in this report are inactive textual references only.
SanDisk, iNAND and others are trademarks of SanDisk Corporation. Other trademarks are used for identification purposes only and may be the property of their respective owners.
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Appendix A
| Smelter Names*: | |
| A.L.M.T. TUNGSTEN Corp. | Dowa |
| Advanced Chemical Company | Duoluoshan |
| Aida Chemical Industries Co., Ltd. | Eco-System Recycling Co., Ltd. |
| Allgemeine Gold-und Silberscheideanstalt A.G. | EM Vinto |
| Almalyk Mining and Metallurgical Complex (AMMC) | Estanho de Rondônia S.A. |
| Alpha | Exotech Inc. |
| AngloGold Ashanti Córrego do Sítio Mineração | F&X Electro-Materials Ltd. |
| Argor-Heraeus SA | Faggi Enrico S.p.A. |
| Asahi Pretec Corporation | Feinhütte Halsbrücke GmbH |
| Asaka Riken Co., Ltd. | Fenix Metals |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Fujian Jinxin Tungsten Co., Ltd. |
| Aurubis AG | Gansu Seemine Material Hi-Tech Co., Ltd. |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Ganzhou Huaxing Tungsten Products Co., Ltd. |
| Bauer Walser AG | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Boliden AB | Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
| C. Hafner GmbH + Co. KG | Ganzhou Seadragon W & Mo Co., Ltd. |
| Caridad | Gejiu Kai Meng Industry and Trade LLC |
| CCR Refinery – Glencore Canada Corporation | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Cendres + Métaux SA | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| Changsha South Tantalum Niobium Co., Ltd. | Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Chenzhou Diamond Tungsten Products Co., Ltd. | Global Advanced Metals Aizu |
| Chimet S.p.A. | Global Advanced Metals Boyertown |
| China National Gold Group Corporation | Global Tungsten & Powders Corp. |
| China Tin Group Co., Ltd. | Guangdong Jinding Gold Limited |
| Chongyi Zhangyuan Tungsten Co., Ltd. | Guangdong Xianglu Tungsten Co., Ltd. |
| Chugai Mining | Guangdong Zhiyuan New Material Co., Ltd. |
| CNMC (Guangxi) PGMA Co., Ltd. | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch |
| Colt Refining | H.C. Starck Co., Ltd. |
| Conghua Tantalum and Niobium Smeltry | H.C. Starck GmbH |
| Cooperativa Metalurgica de Rondônia Ltda. | H.C. Starck GmbH Goslar |
| CV Gita Pesona | H.C. Starck GmbH Laufenburg |
| CV Makmur Jaya | H.C. Starck Hermsdorf GmbH |
| CV Serumpun Sebalai | H.C. Starck Inc. |
| CV United Smelting | H.C. Starck Ltd. |
| Daejin Indus Co., Ltd. | H.C. Starck Smelting GmbH & Co.KG |
| DaeryongENC | Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Daye Non-Ferrous Metals Mining Ltd. | Heimerle + Meule GmbH |
| Dayu Weiliang Tungsten Co., Ltd. | Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Do Sung Corporation | Heraeus Ltd. Hong Kong |
| Doduco | Heraeus Precious Metals GmbH & Co. KG |
A - 1
| Smelter Names*: | |
| Hi-Temp Specialty Metals, Inc. | Lingbao Gold Company Limited |
| Huichang Jinshunda Tin Co., Ltd. | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| Hunan Chenzhou Mining Group Co., Ltd. | Linwu Xianggui Ore Smelting Co., Ltd. |
| Hunan Chunchang Nonferrous Metals Co., Ltd. | LSM Brasil S.A. |
| Hwasung CJ Co., Ltd. | LS-NIKKO Copper Inc. |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| Ishifuku Metal Industry Co., Ltd. | Magnu's Minerais Metais e Ligas Ltda. |
| Istanbul Gold Refinery | Malaysia Smelting Corporation (MSC) |
| Japan Mint | Malipo Haiyu Tungsten Co., Ltd. |
| Japan New Metals Co., Ltd. | Materion |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Matsuda Sangyo Co., Ltd. |
| Jiangxi Copper Company Limited | Melt Metais e Ligas S/A |
| Jiangxi Gan Bei Tungsten Co., Ltd. | Metallic Resources, Inc. |
| Jiangxi Ketai Advanced Material Co., Ltd. | Metallo Chimique |
| Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Metallurgical Products India Pvt., Ltd. |
| Jiangxi Nanshan | Metalor Technologies (Hong Kong) Ltd. |
| Jiangxi Richsea New Materials Co., Ltd. | Metalor Technologies (Singapore) Pte., Ltd. |
| Jiangxi Shunda Huichang Kam Tin Co., Ltd. | Metalor Technologies SA |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Metalor USA Refining Corporation |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | Mineração Taboca S.A. |
| Jiangxi Yaosheng Tungsten Co., Ltd. | Minsur |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. | Mitsubishi Materials Corporation |
| Jiujiang Tanbre Co., Ltd. | Mitsui Mining and Smelting Co., Ltd. |
| Johnson Matthey Inc. | Molycorp Silmet A.S. |
| Johnson Matthey Limited | Moscow Special Alloys Processing Plant |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| JSC Uralelectromed | Navoi Mining and Metallurgical Combinat |
| JX Nippon Mining & Metals Co., Ltd. | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Kazzinc | Nihon Material Co., Ltd. |
| KEMET Blue Metals | Ningxia Orient Tantalum Industry Co., Ltd. |
| KEMET Blue Powder | Novosibirsk Processing Plant Ltd. |
| Kennametal Fallon | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| Kennametal Huntsville | O.M. Manufacturing (Thailand) Co., Ltd. |
| Kennecott Utah Copper LLC | O.M. Manufacturing Philippines, Inc. |
| King-Tan Tantalum Industry Ltd. | Ohio Precious Metals, LLC |
| Kojima Chemicals Co., Ltd. | Ohura Precious Metal Industry Co., Ltd. |
| Korea Metal Co., Ltd. | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) |
| Kyrgyzaltyn JSC | OJSC Kolyma Refinery |
| L' azurde Company For Jewelry | OJSC Novosibirsk Refinery |
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| Smelter Names*: | |
| Operaciones Metalurgical S.A. | PT Tinindo Inter Nusa |
| PAMP SA | PT Tommy Utama |
| Penglai Penggang Gold Industry Co., Ltd. | PT Wahana Perkit Jaya |
| Plansee SE Liezen | PT Yinchendo Mining Industry |
| Plansee SE Reutte | PX Précinox SA |
| Prioksky Plant of Non-Ferrous Metals | QuantumClean |
| PT Alam Lestari Kencana | Rand Refinery (Pty) Ltd. |
| PT Aneka Tambang (Persero) Tbk | Republic Metals Corporation |
| PT Aries Kencana Sejahtera | RFH Tantalum Smeltry Co., Ltd. |
| PT Artha Cipta Langgeng | Royal Canadian Mint |
| PT ATD Makmur Mandiri Jaya | Rui Da Hung |
| PT Babel Inti Perkasa | Sabin Metal Corp. |
| PT Babel Surya Alam Lestari | Samduck Precious Metals |
| PT Bangka Kudai Tin | SAMWON Metals Corp. |
| PT Bangka Putra Karya | Schone Edelmetaal |
| PT Bangka Timah Utama Sejahtera | SEMPSA Joyería Platería SA |
| PT Bangka Tin Industry | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| PT Belitung Industri Sejahtera | Shanghai Jiangxi Metals Co. Ltd |
| PT BilliTin Makmur Lestari | Singway Technology Co., Ltd. |
| PT Bukit Timah | So Accurate Group, Inc. |
| PT DS Jaya Abadi | SOE Shyolkovsky Factory of Secondary Precious Metals |
| PT Eunindo Usaha Mandiri | Soft Metais Ltda. |
| PT Fang Di MulTindo | Solar Applied Materials Technology Corp. |
| PT HANJAYA PERKASA METALS | Solikamsk Magnesium Works OAO |
| PT HP Metals Indonesia | Sumitomo Metal Mining Co., Ltd. |
| PT Inti Stania Prima | Taki Chemicals |
| PT Justindo | Tanaka Kikinzoku Kogyo K.K. |
| PT Karimun Mining | Tantalite Resources |
| PT Koba Tin | Tejing (Vietnam) Tungsten Co., Ltd. |
| PT Mitra Stania Prima | Telex Metals |
| PT Panca Mega Persada | Thaisarco |
| PT Pelat Timah Nusantara Tbk | The Great Wall Gold and Silver Refinery of China |
| PT Prima Timah Utama | The Refinery of Shandong Gold Mining Co., Ltd. |
| PT Refined Bangka Tin | Tokuriki Honten Co., Ltd. |
| PT Sariwiguna Binasentosa | Tongling Nonferrous Metals Group Co., Ltd. |
| PT Seirama Tin Investment | Torecom |
| PT Stanindo Inti Perkasa | Ulba Metallurgical Plant JSC |
| PT Sumber Jaya Indah | Umicore Brasil Ltda. |
| PT Supra Sukses Trinusa | Umicore Precious Metals Thailand |
| PT Timah (Persero) Tbk Kundur | Umicore SA Business Unit Precious Metals Refining |
| PT Timah (Persero) Tbk Mentok | United Precious Metal Refining, Inc. |
A - 3
| Smelter Names*: | |
| Valcambi SA | Yamamoto Precious Metal Co., Ltd. |
| Vietnam Youngsun Tungsten Industry Co., Ltd. | Yichun Jin Yang Rare Metal Co., Ltd. |
| VQB Mineral and Trading Group JSC | Yokohama Metal Co., Ltd. |
| Western Australian Mint trading as The Perth Mint | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| White Solder Metalurgia e Mineração Ltda. | Yunnan Copper Industry Co., Ltd. |
| Wolfram Bergbau und Hütten AG | Yunnan Tin Group (Holding) Company Limited |
| Wolfram Company CJSC | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Xiamen Tungsten (H.C.) Co., Ltd. | Zhuzhou Cemented Carbide Group Co Ltd |
| Xiamen Tungsten Co., Ltd. | Zijin Mining Group Co., Ltd. Gold Refinery |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. | |
| * | Smelter names as reported by the CFSI and the LBMA as of April 29, 2015 and May 3, 2015, respectively. |
| Countries of Origin† | ||
| Angola | Guyana | Russia |
| Argentina | Hungary | Rwanda |
| Australia | India | Sierra Leone |
| Austria | Indonesia | Singapore |
| Belgium | Ireland | Slovakia |
| Bolivia | Israel | South Africa |
| Brazil | Japan | South Korea |
| Burundi | Kazakhstan | South Sudan |
| Canada | Kenya | Spain |
| Central African Republic | Laos | Suriname |
| Chile | Luxembourg | Switzerland |
| China | Madagascar | Taiwan |
| Columbia | Malaysia | Tanzania |
| Cote D’Ivoire | Mongolia | Thailand |
| Czech Republic | Mozambique | Uganda |
| Democratic Republic of Congo | Myanmar | United Kingdom |
| Djibouti | Namibia | United States of America |
| Egypt | Netherlands | Vietnam |
| Estonia | Nigeria | Zambia |
| Ethiopia | Peru | Zimbabwe |
| France | Portugal | |
| Germany | Republic of Congo | |
| † | Countries from the aggregate lists of countries from which the smelters listed above collectively source conflict minerals, to the extent such detailed sourcing information had been reported to the CFSI as of March 31, 2015. |
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