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SD Filing
Logitech International (LOGI) SDConflict minerals disclosure
Filed: 29 May 15, 12:00am
Exhibit 1.01
LOGITECH INTERNATIONAL S.A.
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM JANUARY 1 TO DECEMBER 31, 2014
SECTION ONE: INTRODUCTION
This report for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). In this Conflict Minerals Report (“CMR”), references to “Logitech”, the “Company”, “we”, “us” or “our” refer to Logitech International S.A. and its majority-owned subsidiaries and variable interest entities that are required to be consolidated.
Logitech manufactures or contracts to manufacture products that may contain gold, tantalum, tin and tungsten (“3TG”) that are necessary to the functionality or production of the products. Accordingly, the Company has undertaken the measures described in this CMR to trace the origin of these minerals and whether they may have been sourced from the Democratic Republic of Congo (“DRC”) or any of its adjoining countries (collectively, the “Covered Countries”).
1. Company Overview
Logitech International S.A., together with its consolidated subsidiaries, (“Logitech” or the “Company”) is a world leader in products that connect people to the digital experiences they care about. Spanning multiple computing, communication and entertainment platforms, we develop and market innovative hardware and software products that enable or enhance digital navigation, music and video entertainment, gaming, social networking, and audio and video communication over the Internet and home-entertainment control.
Logitech was founded in Switzerland in 1981, and Logitech International S.A. has been the parent holding company of Logitech since 1988. Logitech International S.A. is a Swiss holding company with its registered office in Apples, Switzerland, which conducts its business through subsidiaries in Americas (including North and South America), EMEA (Europe, Middle East, Africa) and Asia Pacific (including, among other countries, China, Taiwan, Japan and Australia). Shares of Logitech International S.A. are listed on both the Nasdaq Global Select Market, under the trading symbol LOGI, and the SIX Swiss Exchange, under the trading symbol LOGN.
The Company has two operating segments, peripherals and video conferencing. Logitech’s peripherals segment encompasses the design, manufacturing and marketing of peripherals for personal computers (“PCs”), tablets and other digital platforms. The Company’s video conferencing segment offers scalable high-definition (“HD”) video communications endpoints, HD video conferencing systems with integrated monitors, video bridges and other infrastructure software and hardware to support large-scale video deployments, and services to support these products.
SECTION TWO: LOGITECH PRODUCTS
The Table 1 below lists the product categories developed and marketed by Logitech for the reporting period from January 1 to December 31, 2014. These products are more fully described in our Annual Report, which can be accessed on our Web site or on the Securities and Exchange Commission’s Web site at http://www.sec.gov, and the reports we file that are published by the SIX Swiss Exchange may be accessed at: http://www.six-exchange-regulation.com/obligations/management_transactions_en.html.
The vast majority of the Logitech products are electronic devices which include electronic and electrical components and semiconductors. Because of their specific properties, the 3TG are widely used in semiconductors and in electronic components generally and, by way of consequence, in the consumer electronics industries. This is why Logitech has considered that almost all of its product categories may potentially include one or several Conflict Mineral(s). Accordingly, Logitech has included in the scope of its Conflict Minerals plan all products qualifying as electronic devices. The only product categories that have been excluded from the scope of the Conflict Minerals plan are those related to so-called “passive devices”, namely devices which do not include electronic or electric components, nor any semi-conductors, nor any other metallic component made of any of the 3TG. These excluded categories are included in Table 1, below and consist of: (i) folio protective cases for tablets; (ii) protective cases for smartphones and othernon-electronic, non-electric accessories for smartphones (such as tilt panels, car mounts); (iii) mouse pads.
Table 1: List of Logitech DRC Conflict Undeterminable Products
Product Category | Products | Potentially include “ConflictMinerals” (Yes / No) | DRC Conflict Status | |||
PC Gaming | Gaming mice, keyboards, headsets and other controllers (e.g. steering wheel, joystick, gamepad) | Y | DRC Conflict undeterminable | |||
Mouse pad (hard pad, cloth pad) | N | Not Applicable | ||||
Tablet & Other Accessories | Tablet keyboard and other accessories | Y | DRC Conflict undeterminable |
Folio protective cases (without keyboard) | N | Not Applicable | ||||
Smartphone battery packs | Y | DRC Conflict undeterminable | ||||
Smartphone cases, tilt panel, drive mount | N | Not Applicable | ||||
Mobile Speakers | Includes portable wireless Bluetooth speakers. | Y | DRC Conflict undeterminable | |||
Pointing Devices | PC related mice, trackpads, touchpads, and presenters | Y | DRC Conflict undeterminable | |||
PC Keyboards & Desktops | Includes PC keyboards, keyboards used in living rooms and keyboard/mice combo products. | Y | DRC Conflict undeterminable | |||
Audio-PC & Wearables | PC speakers, PC headsets, and in-ear headphones | Y | DRC Conflict undeterminable | |||
Video | Retail webcam products as well as Unified Communications webcams | Y | DRC Conflict undeterminable | |||
Remotes | Harmony remote controls | Y | DRC Conflict undeterminable |
Other (products we currently intend to transition out or have already transitioned out) | This category comprises a variety of products out of which we currently intend to transition, or have transitioned, because they are no longer strategic to our business. Products currently included in this category include TV camera, Digital Video Security (DVS), other gaming and music products, including over-ear headphones, TV and home speakers, Google TV products, and PC Keyboards & Desktops accessories. | Y | DRC Conflict undeterminable | |||
Video conferencing (sold under the brand “Lifesize”) | HD video communication endpoints, HD video conferencing systems with integrated monitors, video bridges and other infrastructure | Y | DRC Conflict undeterminable |
Logitech is currently transitioning out certain products in its peripherals operating segment. These are identified in Table 1 above under “Other”. Logitech has included in the scope of its Conflict Minerals plan any product under this category that has been manufactured or marketed during the reporting period from January 1 to December 31, 2014.
Logitech may modify in the future the above categorization of its products in line with the requirement to adapt the category classification to business needs.
SECTION THREE: CONFLICT MINERALS DETERMINATION
For the reporting period from January 1 to December 31, 2014, Logitech conducted due diligence on the source and chain of custody of the conflict minerals that are necessary to the functionality or production of the products (“necessary conflict minerals”) that we manufactured or contracted to manufacture, after January 1st, 2014, for which the results of our reasonable country of origin inquiry and the diligence measures conducted on these conflict minerals were as follows:
• | We were not able to obtain adequate information from our supply chain to be able to make any determination as to the source of these conflict minerals. |
These conflict minerals we define collectively as the “CMR conflict minerals” (the “CMR Conflict Minerals”).
Therefore, these products that we manufacture that are subject to the reporting obligations of Rule 13p-1 are “DRC conflict undeterminable”, because we have been unable to determine the origin of the 3TG they contain or to determine whether they came from recycled or scrap sources; the facilities used to process them; their country of origin; or their mine or location of origin. (Please also refer to Table 1 within this report for additional details).
The Company continues to implement and pursue processes to ensure in the future that it is able to obtain the information necessary to make a determination.
SECTION FOUR: DUE DILIGENCE MEASURES
We conducted due diligence on the source and chain of custody of the conflict minerals that are necessary to the functionality or production of our products to ascertain whether these conflict minerals originated in the Covered Countries and financed or benefitted non-state armed groups in any of these countries.
Design of Our Due Diligence Measures
Our conflict minerals due diligence measures have been designed to conform with the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (the “OECD Guidance”), as applicable for tin, tantalum, tungsten, gold and downstream companies (as the term is defined in the OECD Guidance), in all material respects. We designed our due diligence measures to:
1. | establish strong Company management systems for conflict minerals supply chain due diligence; |
2. | identify and assess conflict minerals risks in our supply chain; |
3. | design and implement strategies to respond to conflict minerals risks identified; |
4. | contribute to independent third-party audits of the due diligence practices of conflict minerals smelters and refiners by participating in industry organizations; |
5. | report on our conflict minerals supply chain due diligence activities. |
Due Diligence Measures Performed
Logitech’s due diligence measures were based on multi-industry initiatives with the smelters and refiners of conflict minerals who provide those conflict minerals to Logitech’s suppliers. As a purchaser, Logitech is many steps removed from the mining of the conflict minerals; Logitech does not purchase raw ore or unrefined conflict minerals, and does no purchasing in the Covered Countries. The smelters and refiners are consolidating points for raw ore and are in the best position in the total supply chain to know the origin of the ores. For downstream users like Logitech, it is not possible to determine the origin of conflict minerals without information and clarification from suppliers and smelters.
As a member in the Conflict Free Sourcing Initiative (the “CFSI”), we leveraged the due diligence conducted on smelters and refiners by the CFSI’s Conflict-Free Smelter Program (the “CFSP”). The CFSP uses independent private sector auditors to audit the source, including mines of origin, and chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the CFSP. The smelters and refiners that are found to be CFSP compliant are those for which the independent auditor has verified that the smelter’s or refiner’s conflict minerals originated from conflict free mines in the Democratic Republic of the Congo or any of its adjoining countries.
Our due diligence measures included the following activities:
1) | We utilised the already established internal team to implement Logitech’s Conflict Minerals Program again in 2014. The core team members are comprised from the following business units: Sustainability; Lifesize Compliance; Global Sourcing; Supplier Development Team; Legal; Investor Relations and Finance; |
2) | We maintained public availability of a Conflict Mineral Policy in 2014 at: http://www.logitech.com/assets/51186/logitech-policy-on-conflict-minerals-jan-2014-signed.pdf; |
3) | We established requirements and incorporated these requirements into our standard supplier contracts to define Logitech expectations of suppliers regarding sourcing of conflict minerals and reporting of information to Logitech. These requirements have been provided in our contracts as we entered into new supplier contracts or renewed existing ones. We have amended a certain number of supplier contracts that have been in place for several years. We continue to pursue flow down clauses with all impacted suppliers. In the meantime we are working with the relevant suppliers to insure they provide the 3TG sourcing information until the contracts can be amended; |
4) | We chose to engage with all our direct suppliers of materials, parts, components or products containing 3TG based on the widespread use of 3TG (“3TG Direct Suppliers”). Given our position in the supply chain, we relied heavily on our first-tier suppliers to provide information about the sources of the 3TG used in our products and to identify whether those sources may be from the DRC or an adjoining country; |
5) | We conducted a survey of our 3TG Direct Suppliers using the CFSI Conflict Minerals Reporting Template (the “Template”), which included questions about the location or mine of origin, and obligated those suppliers to make similar efforts to survey their supply chain using the Template and report the facilities and location or mine of origin for necessary conflict minerals. We elected to use this Template as it is the most commonly used tool in numerous industries, thus easing the potential confusion and burden for our suppliers; |
6) | We received responses from 95.86% of the 3TG Direct Suppliers. We reviewed the responses against the criteria designed to evaluate the adequacy of responses. These criteria include, but are not limited to, untimely or incomplete responses as well as inconsistencies within the data reported in the Template; |
7) | We compared the facilities identified by relevant 3TG Direct Suppliers via the supply chain survey against the list of facilities that have received a “conflict-free” designation for tantalum, tin, tungsten and gold, such as the Conflict-Free Smelter List (“CFS List”) published by the Conflict Free Sourcing Initiative (“CFSI”); and, where a supplier indicated that the facility was certified as Conflict-Free, we ensured that the name was listed by the CFSI; |
8) | Based on the data collected to-date, the main risks we have identified are related to the lack of data and the quality of the data. The vast majority of the responses received from suppliers provided data at a company level or were unable to specify the smelter or refiners used in their supply chain. We are therefore unable to determine whether any of the conflict minerals reported by the suppliers were contained in products supplied to us or to validate that any of the smelters of refiners provided by our suppliers are actually in our supply chain; and |
9) | We supported the CFSI Conflict-Free Smelter Program, and required relevant 3TG Direct Suppliers in Logitech supply chain to encourage the facilities in their supply chain to participate in the CFSI Conflict-Free Smelter Program. |
SECTION FIVE: DUE DILIGENCE DETERMINATION
Survey Responses
We reviewed the responses received from our 3TG Direct Suppliers resulting from the survey carried out using the Template.
Responses included the names of 423 entities listed by our suppliers as smelters or refiners. 38.06% (161) of these entities were identified as certified Conflict-Free using the CFSI Compliant Smelter and Refiner Lists. This represents a significant progress compared to calendar year 2013 report, in which Logitech had identified 57 smelters or refiners certified as Conflict-Free, which represented 15.66% of all smelters entities listed by our suppliers.
Table 2: Logitech’s determination for each Conflict Mineral in 2014
Metal | Smelters and refiners verified as conflict-free or | Countries of origin status | ||
Tantalum | 39 of 48 (81%) | DRC Conflict undeterminable | ||
Tin | 51 of 153 (33%) | DRC Conflict undeterminable | ||
Tungsten | 32 of 62 (52%) | DRC Conflict undeterminable | ||
Gold | 80 of 160 (50%) | DRC Conflict undeterminable |
The remaining 262 processing facilities could not be determined to be conflict-free and so the responses could not be validated and their status is deemed unknown. At the time of reporting, 41 are in the process of certification via CFSP.
Logitech supports the refinement and expansion of the list of participating smelters through its membership in the CFSI program.
A small minority of suppliers provided information at a product level or product category level. However all of these suppliers were unable to identify specifically the smelters whose 3TG went into parts supplied to Logitech.
The large majority of the responses received provided data at a company or divisional level or, as described above, were unable to specify the smelters or refiners used for components supplied to Logitech. Thus, our suppliers were unable to represent to us that 3TG from the entities they listed had actually been included in components they supplied to Logitech. In addition, 262 processing facilities were not validated as in fact being smelters or refiners.
We have therefore elected not to present the smelter and refiner names in this report, with the exception of the conflict-free smelters sourcing from Covered Countries. Please see table 3 below for further information on these facilities and their country of origin
Table 3: List of Conflict Free Smelters Determination for Logitech Products
Metal | Smelter Name | Smelter ID | Smelter country | Conflict Mineral Free (CMF) Status | ||||
Gold | Aida Chemical Industries Co. Ltd. | CID000019 | JAPAN | CMF | ||||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | GERMANY | CMF | ||||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | UZBEKISTAN | CMF | ||||
Gold | AngloGold Ashanti Córrego do Sítio Minerção | CID000058 | BRAZIL | CMF | ||||
Gold | Argor-Heraeus SA | CID000077 | SWITZERLAND | CMF | ||||
Gold | Asahi Pretec Corporation | CID000082 | JAPAN | CMF | ||||
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | TURKEY | CMF | ||||
Gold | Aurubis AG | CID000113 | GERMANY | CMF |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | PHILIPPINES | CMF | ||||
Gold | Boliden AB | CID000157 | SWEDEN | CMF | ||||
Gold | C. Hafner GmbH + Co. KG | CID000176 | GERMANY | CMF | ||||
Gold | CCR Refinery – Glencore Canada Corporation | CID000185 | CANADA | CMF | ||||
Gold | Cendres + Métaux SA | CID000189 | SWITZERLAND | CMF | ||||
Gold | Chimet S.p.A. | CID000233 | ITALY | CMF | ||||
Gold | Dowa | CID000401 | JAPAN | CMF | ||||
Gold | Eco-System Recycling Co., Ltd. | CID000425 | JAPAN | CMF | ||||
Gold | Heimerle + Meule GmbH | CID000694 | GERMANY | CMF | ||||
Gold | Heraeus Ltd. Hong Kong | CID000707 | HONG KONG | CMF | ||||
Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 | GERMANY | CMF | ||||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CID000801 | CHINA | CMF | ||||
Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | JAPAN | CMF | ||||
Gold | Istanbul Gold Refinery | CID000814 | TURKEY | CMF | ||||
Gold | Japan Mint | CID000823 | JAPAN | CMF | ||||
Gold | Jiangxi Copper Company Limited | CID000855 | CHINA | CMF | ||||
Gold | Johnson Matthey Inc | CID000920 | UNITED STATES | CMF | ||||
Gold | Johnson Matthey Ltd | CID000924 | CANADA | CMF | ||||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | RUSSIAN FEDERATION | CMF | ||||
Gold | JSC Uralelectromed | CID000929 | RUSSIAN FEDERATION | CMF |
Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | JAPAN | CMF | ||||
Gold | Kazzinc Ltd | CID000957 | KAZAKHSTAN | CMF | ||||
Gold | Kennecott Utah Copper LLC | CID000969 | UNITED STATES | CMF | ||||
Gold | Kojima Chemicals Co., Ltd | CID000981 | JAPAN | CMF | ||||
Gold | Kyrgyzaltyn JSC | CID001029 | KYRGYZSTAN | CMF | ||||
Gold | L’ azurde Company For Jewelry | CID001032 | SAUDI ARABIA | CMF | ||||
Gold | LS-NIKKO Copper Inc. | CID001078 | KOREA, REPUBLIC OF | CMF | ||||
Gold | Materion | CID001113 | UNITED STATES | CMF | ||||
Gold | Matsuda Sangyo Co., Ltd. | CID001119 | JAPAN | CMF | ||||
Gold | Metalor Technologies (Hong Kong) Ltd | CID001149 | HONG KONG | CMF | ||||
Gold | Metalor Technologies (Singapore) Pte. Ltd. | CID001152 | SINGAPORE | CMF | ||||
Gold | Metalor Technologies SA | CID001153 | SWITZERLAND | CMF | ||||
Gold | Metalor USA Refining Corporation | CID001157 | UNITED STATES | CMF | ||||
Gold | Met-Mex Peñoles, S.A. | CID001161 | MEXICO | CMF | ||||
Gold | Mitsubishi Materials Corporation | CID001188 | JAPAN | CMF | ||||
Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | JAPAN | CMF | ||||
Gold | Moscow Special Alloys Processing Plant | CID001204 | RUSSIAN FEDERATION | CMF | ||||
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CID001220 | TURKEY | CMF | ||||
Gold | Navoi Mining and Metallurgical Combinat | CID001236 | UZBEKISTAN | CMF |
Gold | Nihon Material Co. LTD | CID001259 | JAPAN | CMF | ||||
Gold | Ohio Precious Metals, LLC | CID001322 | UNITED STATES | CMF | ||||
Gold | Ohura Precious Metal Industry Co., Ltd | CID001325 | JAPAN | CMF | ||||
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | CID001326 | RUSSIAN FEDERATION | CMF | ||||
Gold | OJSC Kolyma Refinery | CID001328 | RUSSIAN FEDERATION | CMF | ||||
Gold | PAMP SA | CID001352 | SWITZERLAND | CMF | ||||
Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | RUSSIAN FEDERATION | CMF | ||||
Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | INDONESIA | CMF | ||||
Gold | PX Précinox SA | CID001498 | SWITZERLAND | CMF | ||||
Gold | Rand Refinery (Pty) Ltd | CID001512 | SOUTH AFRICA | CMF | ||||
Gold | Royal Canadian Mint | CID001534 | CANADA | CMF | ||||
Gold | Schone Edelmetaal | CID001573 | NETHERLANDS | CMF | ||||
Gold | SEMPSA Joyería Platería SA | CID001585 | SPAIN | CMF | ||||
Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | CID001622 | CHINA | CMF | ||||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | RUSSIAN FEDERATION | CMF | ||||
Gold | Solar Applied Materials Technology Corp. | CID001761 | TAIWAN | CMF | ||||
Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | JAPAN | CMF | ||||
Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | JAPAN | CMF |
Gold | The Refinery of Shandong Gold Mining Co. Ltd | CID001916 | CHINA | CMF | ||||
Gold | Tokuriki Honten Co., Ltd | CID001938 | JAPAN | CMF | ||||
Gold | Umicore Brasil Ltda | CID001977 | BRAZIL | CMF | ||||
Gold | Umicore Precious Metals Thailand | CID002314 | THAILAND | CMF | ||||
Gold | Umicore SA Business Unit Precious Metals Refining | CID001980 | BELGIUM | CMF | ||||
Gold | United Precious Metal Refining, Inc. | CID001993 | UNITED STATES | CMF | ||||
Gold | Valcambi SA | CID002003 | SWITZERLAND | CMF | ||||
Gold | Western Australian Mint trading as The Perth Mint | CID002030 | AUSTRALIA | CMF | ||||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | CHINA | CMF | ||||
Gold | Zijin Mining Group Co. Ltd | CID002243 | CHINA | CMF | ||||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 | CHINA | CMF | ||||
Tantalum | Conghua Tantalum and Niobium Smeltry | CID000291 | CHINA | CMF | ||||
Tantalum | Duoluoshan | CID000410 | CHINA | CMF | ||||
Tantalum | Exotech Inc. | CID000456 | UNITED STATES | CMF | ||||
Tantalum | F&X Electro-Materials Ltd. | CID000460 | CHINA | CMF | ||||
Tantalum | Global Advanced Metals Aizu | CID002558 | JAPAN | CMF | ||||
Tantalum | Global Advanced Metals Boyertown | CID002557 | UNITED STATES | CMF | ||||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 | CHINA | CMF | ||||
Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CID002501 | CHINA | CMF |
Tantalum | H.C. Starck Co., Ltd. | CID002544 | THAILAND | CMF | ||||
Tantalum | H.C. Starck GmbH Goslar | CID002545 | GERMANY | CMF | ||||
Tantalum | H.C. Starck GmbH Laufenburg | CID002546 | GERMANY | CMF | ||||
Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 | GERMANY | CMF | ||||
Tantalum | H.C. Starck Inc. | CID002548 | UNITED STATES | CMF | ||||
Tantalum | H.C. Starck Ltd. | CID002549 | JAPAN | CMF | ||||
Tantalum | H.C. Starck Smelting GmbH & Co.KG | CID002550 | GERMANY | CMF | ||||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | CHINA | CMF | ||||
Tantalum | Hi-Temp | CID000731 | UNITED STATES | CMF | ||||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | CHINA | CMF | ||||
Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | CHINA | CMF | ||||
Tantalum | KEMET Blue Metals | CID002539 | MEXICO | CMF | ||||
Tantalum | KEMET Blue Powder | CID002568 | UNITED STATES | CMF | ||||
Tantalum | King-Tan Tantalum Industry Ltd | CID000973 | CHINA | CMF | ||||
Tantalum | LSM Brasil S.A. | CID001076 | BRAZIL | CMF | ||||
Tantalum | Metallurgical Products India (Pvt.) Ltd. | CID001163 | INDIA | CMF | ||||
Tantalum | Mineração Taboca S.A. | CID001175 | BRAZIL | CMF | ||||
Tantalum | Mitsui Mining & Smelting | CID001192 | JAPAN | CMF | ||||
Tantalum | Molycorp Silmet A.S. | CID001200 | ESTONIA | CMF | ||||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | CHINA | CMF |
Tantalum | Plansee SE Liezen | CID002540 | AUSTRIA | CMF | ||||
Tantalum | Plansee SE Reutte | CID002556 | AUSTRIA | CMF | ||||
Tantalum | QuantumClean | CID001508 | UNITED STATES | CMF | ||||
Tantalum | RFH Tantalum Smeltry Co., Ltd | CID001522 | CHINA | CMF | ||||
Tantalum | Solikamsk Magnesium Works OAO | CID001769 | RUSSIAN FEDERATION | CMF | ||||
Tantalum | Taki Chemicals | CID001869 | JAPAN | CMF | ||||
Tantalum | Telex | CID001891 | UNITED STATES | CMF | ||||
Tantalum | Ulba | CID001969 | KAZAKHSTAN | CMF | ||||
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd | CID002307 | CHINA | CMF | ||||
Tantalum | Zhuzhou Cement Carbide | CID002232 | CHINA | CMF | ||||
Tin | Alpha | CID000292 | UNITED STATES | CMF | ||||
Tin | China Rare Metal Materials Company | CID000244 | CHINA | CMF | ||||
Tin | Cooper Santa | CID000295 | BRAZIL | CMF | ||||
Tin | CV United Smelting | CID000315 | INDONESIA | CMF | ||||
Tin | Dowa | CID000402 | JAPAN | CMF | ||||
Tin | EM Vinto | CID000438 | BOLIVIA | CMF | ||||
Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | CID000538 | CHINA | CMF | ||||
Tin | Magnu’s Minerais Metais e Ligas LTDA | CID002468 | BRAZIL | CMF | ||||
Tin | Malaysia Smelting Corporation (MSC) | CID001105 | MALAYSIA | CMF | ||||
Tin | Melt Metais e Ligas S/A | CID002500 | BRAZIL | CMF |
Tin | Metallo Chimique | CID001143 | BELGIUM | CMF | ||||
Tin | Mineração Taboca S.A. | CID001173 | BRAZIL | CMF | ||||
Tin | Minsur | CID001182 | PERU | CMF | ||||
Tin | Mitsubishi Materials Corporation | CID001191 | JAPAN | CMF | ||||
Tin | OMSA | CID001337 | BOLIVIA | CMF | ||||
Tin | PT ATD Makmur Mandiri Jaya | CID002503 | INDONESIA | CMF | ||||
Tin | PT Babel Inti Perkasa | CID001402 | INDONESIA | CMF | ||||
Tin | PT Bangka Putra Karya | CID001412 | INDONESIA | CMF | ||||
Tin | PT Bangka Tin Industry | CID001419 | INDONESIA | CMF | ||||
Tin | PT Belitung Industri Sejahtera | CID001421 | INDONESIA | CMF | ||||
Tin | PT Bukit Timah | CID001428 | INDONESIA | CMF | ||||
Tin | PT DS Jaya Abadi | CID001434 | INDONESIA | CMF | ||||
Tin | PT Eunindo Usaha Mandiri | CID001438 | INDONESIA | CMF | ||||
Tin | PT Mitra Stania Prima | CID001453 | INDONESIA | CMF | ||||
Tin | PT Panca Mega Persada | CID001457 | INDONESIA | CMF | ||||
Tin | PT Prima Timah Utama | CID001458 | INDONESIA | CMF | ||||
Tin | PT REFINED BANGKA TIN | CID001460 | INDONESIA | CMF | ||||
Tin | PT Sariwiguna Binasentosa | CID001463 | INDONESIA | CMF | ||||
Tin | PT Stanindo Inti Perkasa | CID001468 | INDONESIA | CMF | ||||
Tin | PT Tambang Timah | CID001477 | INDONESIA | CMF | ||||
Tin | PT Timah (Persero), Tbk | CID001482 | INDONESIA | CMF | ||||
Tin | PT Tinindo Inter Nusa | CID001490 | INDONESIA | CMF |
Tin | Thaisarco | CID001898 | THAILAND | CMF | ||||
Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 | BRAZIL | CMF | ||||
Tin | Yunnan Tin Company, Ltd. | CID002180 | CHINA | CMF | ||||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | CHINA | CMF | ||||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | CHINA | CMF | ||||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | CHINA | CMF | ||||
Tungsten | Global Tungsten & Powders Corp. | CID000568 | UNITED STATES | CMF | ||||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 | CHINA | CMF | ||||
Tungsten | Japan New Metals Co., Ltd. | CID000825 | JAPAN | CMF | ||||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | CHINA | CMF | ||||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | CHINA | CMF | ||||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | CID002011 | VIETNAM | CMF | ||||
Tungsten | Wolfram Bergbau und Hütten AG | CID002044 | AUSTRIA | CMF | ||||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | CHINA | CMF | ||||
Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | CHINA | CMF |
Efforts to Determine the Conflict Minerals’ Mine or Location of Origin –
Through our participation in CFSI, the OECD implementation programs, and requesting our suppliers to complete The Template, we have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain, as outlined in Section Four “Due Diligence Measures” above.
SECTION SIX: NEXT STEPS
Logitech will undertake the following steps, during the next compliance period, with the intention of further mitigating the risk that its supply chain sourcing, utilizing necessary conflict minerals may benefit armed groups, including:
• | Attempting to increase the response rate of suppliers and improve the content of the responses by contracting a third party specialist to engage with these suppliers on an individual basis to understand their challenges in compliance and support their transition. |
• | Requesting relevant suppliers to request smelters to participate in obtaining a conflict free designation from an industry program such as the EICC/GeSI Conflict Free Smelter program. |
• | Attempting to validate supplier responses using information collected via independent conflict free smelter validation programs such as the Electronic Industry Citizenship Coalition Global e-Sustainability Initiative (EICC/GeSI) Conflict Free Smelter program to which we provide financial support. |
• | Increasing the number of relevant supplier contracts that include our requirements or obtaining industry standards demonstration of implementation of our standards, by utilising the Conflict Minerals Report template. |
• | Future Non-Conformance: Discontinue doing business with any Logitech Suppliers whom are unable to meet our Conflict Minerals Policy. |