Exhibit 1.01
MARVELL TECHNOLOGY GROUP LTD.
CONFLICT MINERALS REPORT
(For the reporting period January 1, 2018 to December 31, 2018)
INTRODUCTION
This Conflict Minerals Report (the “Report”) for Marvell Technology Group Ltd. (“Company,” “Marvell,” “we,” “us” or “our”) is provided in accordance with Rule13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1, 2018 to December 31, 2018 and, unless otherwise indicated herein with respect to a particular statement, covers the activities of all Company subsidiaries, including Cavium, LLC (formerly Cavium, Inc.) (“Cavium”), which we acquired in July 2018. The Report is being filed as Exhibit 1.01 to our specialized disclosure report on Form SD and is also posted on our website at www.marvell.com under the heading “Company” – “Investor Relations” – “Financials” – “SEC Filings.” Information contained on or accessible through our website is not part of this Report.
The Rule imposes certain reporting obligations on Securities and Exchange Commission (“SEC”) registrants who manufacture products containing the minerals and metals referred to in the Rule as “Conflict Minerals.” The Democratic Republic of the Congo (“DRC”) and its adjoining countries have reserves of Conflict Minerals, some of which are illegally sourced and traded by armed groups who are responsible for significant human rights violations. “Armed groups” mean an armed group that is identified as a perpetrator of serious human rights abuses in the annual Country Reports on Human Rights Practices under Sections 116(d) and 502B (b) of the Foreign Assistance Act of 1961 relating to the DRC or an adjoining country. The purpose of the Rule is to encourage companies whose products contain Conflict Minerals to endeavor to source from suppliers who do not directly or indirectly support such armed groups through their purchasing decisions. The Democratic Republic of the Congo and its adjoining countries – Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia – are sometimes referred to in this Report as the “Covered Countries.”
We are subject to the Rule because our products contain Conflict Minerals that are necessary to the functionality or production of such products (“Necessary Conflict Minerals”). Accordingly, we are required under the Rule to conduct a reasonable country of origin inquiry (“RCOI”) designed to determine in good faith whether any of the Necessary Conflict Minerals either originated in the Covered Countries or came from recycled or scrap materials. We do not directly source Conflict Minerals from mines, smelters or refiners.
Supply Chain and Products
Our products typically contain many parts and components obtained from a global network of suppliers, with multiple tiers of suppliers between us and the ultimate sources of the raw materials used in the manufacturing of our products. Raw materials purchased by our direct and indirect suppliers contain Conflict Minerals obtained from smelters and refiners that, in turn, source those minerals from traders and mines in various countries.
We rely on our suppliers to provide information with respect to the origin and source and chain of custody of the Necessary Conflict Minerals contained in parts, components and materials supplied to
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us. In all cases, the information relating to the Necessary Conflict Minerals contained in our products comes from multiple, lower-tier suppliers and from information (i) available to us through our membership with the Responsible Minerals Initiative (“RMI”) (formerly the Conflict-Free Sourcing Initiative), (ii) provided by our customers and (iii) obtained by means of our own research.
We do not own or operate foundries or manufacturing facilities, but outsource the manufacturing, packaging and testing of our products to third-party foundries and subcontractors located primarily in Asia. We are a fabless provider of high-performance, application-specific standard semiconductor products. Our core strength is developing highly integrated and complexsystem-on-a-chip devices, leveraging our technology portfolio of intellectual property in the areas of analog, mixed-signal, digital-signal processing and embedded and standalone integrated circuits. Our current product offerings are primarily in two broad product groups: storage and networking.
Storage Products. Marvell develops fibre channel products and data storage controller solutions spanning cloud, enterprise, edge and personal computing markets. Data storage products include controllers for hard disk drives (“HDDs”) and solid-state drives (“SSDs”) that store and retrieve data with greater speed and reliability while consuming a reduced amount of energy. These products are incorporated into HDDs and SSDs for many different applications, including desktop and laptop personal computers, servers, game consoles, and similar devices. Fibre channel products include both adapters for server connectivity as well as ASICs and adapters for storage system connectivity.
Networking Products. Marvell develops networking products that serveend-users in cloud, consumer, enterprise, and service provider networks. Products include ethernet solutions, embedded processors and WiFi connectivity solutions. Our Ethernet solutions address a wide variety ofend-customer products, from small, cost-effective appliances to large, high-performance modular solutions. Our embedded processors are highly integrated semiconductors that provide single or multiple cores of processing engines, along with intelligent Layer 2 through 7 for enterprise, datacenter, storage, broadband, and service provider applications. We also offer a broad portfolio of connectivity solutions, includingWi-Fi andWi-Fi/Bluetooth integrated SOCs, which are integrated into a wide variety of end devices such as enterprise access points, home gateways and voice assistants, multimedia devices, gaming, printers, automotive infotainment and telematics units.
Products Covered by this Report. For the purposes of the “Reasonable Country of Origin Inquiry and Due Diligence” portion of this Report, unless otherwise indicated, “products” refers to the products in the product categories listed above with respect to which manufacturing was completed or the sale was consummated during calendar year 2018, and “suppliers” refers to, collectively, our direct product suppliers and our component product suppliers.
REASONABLE COUNTRY OF ORIGIN INQUIRY AND DUE DILIGENCE
To comply with the Rule, we conducted a reasonable country of origin inquiry and due diligence on the source and chain of custody of the Necessary Conflict Minerals to determine whether they originated in a Covered Country and financed or benefited armed groups in any of these countries.
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Reasonable Country of Origin Inquiry
Marvell conducted a reasonable country of origin inquiry (RCOI) to determine whether the Necessary Conflict Minerals in our products originated in one of the Covered Countries or are from recycled or scrap sources.
Because we do not purchase conflict minerals directly from any smelter or refiner, we rely on our suppliers to provide us with accurate information about the origin of the minerals in the products and components they supply to us. Our suppliers provide us with this information by submitting a Conflict Minerals Reporting Template (“CMRT”). In addition to the information provided on the CMRT, we rely on (i) information from industry sources such as the RMI, (ii) information provided by our customers, and (iii) information obtained by means of our own research.
Based on the findings of our RCOI, we have reason to believe that some of the Necessary Conflict Minerals present in our products may have originated in the Covered Countries. We are therefore required by the Rule to file with the SEC a Form SD and a Conflict Minerals Report as an exhibit thereto.
Due Diligence Design
On the basis of the information obtained as a result of our RCOI, we conducted a broader due diligence investigation regarding the source and chain of custody of the Necessary Conflict Minerals. There is a significant overlap between our RCOI and due diligence processes, and the due diligence measures that we put in place are an extension of the CMRT-based RCOI process. These due diligence measures have been designed to conform, in all material respects, with the framework specified in the Organization for EconomicCo-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, including the related supplements on gold, tin, tantalum, and tungsten (the “OECD Guidance”), specifically as the OECD Guidance pertains to downstream purchasers in the minerals supply chain. The OECD Guidance specifies a five-step framework for risk-based due diligence for responsible supply chains of minerals sourced from conflict-affected and high-risk areas.
Due Diligence Performed
Step 1: Establish Strong Company Management Systems.
| • | Marvell maintains a Policy Statement on Conflict Minerals (the“Policy Statement”), which provides that Marvell does not support the use of Conflict Minerals that are mined, transported or traded to fund human rights violations, social unrest, political repression or conflict or the use of metal derived from such Conflict Minerals. The Policy Statement is posted on our website at www.marvell.com under the heading “Global Citizenship” – “Supplier Responsibility.” |
| • | Marvell maintains a Supplier Code of Conduct that, among other things, requires our direct suppliers to comply with the Policy Statement, as well as with the Marvell Code of Business Conduct and Ethics and the RBA Code of Conduct. The Supplier Code of Conduct was revised in April 2019, and is posted on our website atwww.marvell.com under the heading “Global Citizenship” – “Supplier Responsibility.” |
| • | Marvell has a Conflict Minerals Working Group (“Working Group”) that is comprised of subject matter experts from the Company’s Quality Systems, Operations and Legal teams. The Working Group oversees Marvell’s reasonable country of origin inquiry and conducts due diligence on the source and chain of custody of Marvell’s Necessary Conflict Minerals. |
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| • | We use a multi-layered approach to convey our supplier responsibility expectations to our direct suppliers. Marvell’s direct suppliers have been provided with our Policy Statement, Supplier Code of Conduct and product and manufacturing specifications (the “Specifications”), and any new direct suppliers are similarly provided such documents as part of the Quality Systems group’s supplier onboarding process. Marvell’s Specifications contain provisions requiring that direct suppliers (i) comply with the Policy Statement and the Supplier Code of Conduct and (ii) cooperate with Marvell in providing the information required by the CMRT. Further, the Specifications stipulate the consequences of breaching such provisions. |
| • | We maintain a data retention policy to retain material Conflict Minerals-related records electronically for a period of at least five (5) years from the date of creation. |
| • | We engaged a third-party conflict minerals due diligence service provider that utilized a proprietary software tool to compile and validate Cavium supplier CMRT data. |
| • | Marvell maintains a confidential Concern Line, administered by an independent third-party service provider, that is available to employees and the general public 24 hours per day, seven days per week. The Concern Line accepts anonymous reports and may be used to report illegal or unethical conduct. Information about the Concern Line is included in our Supplier Code of Conduct, and posted on our website atwww.marvell.com under the heading “Global Citizenship” – “Ethics.” |
Step 2: Identify and Assess Risk in the Supply Chain.
| • | We obtained, either directly or through our third-party conflict minerals due diligence service provider, CMRTs at least once a year from all except one of our suppliers. Although most suppliers provided CMRTs after the end of the 2018 reporting year, certain suppliers provided CMRTs prior to the end of such reporting year. We used our suppliers’ CMRTs to identify smelters and refiners and determine the mine and country of origin of the minerals processed by such smelters and refiners. |
| • | We are a member of the RBA and the RMI, a leading industry program that helps members manage risk by improving Conflict Minerals supply chain transparency. As a member of the RMI, Marvell has access to RMI’s reasonable country of origin data that aids us in determining the mine or location of origin of the Conflict Minerals in our supply chain. |
| • | We cross-check information received from our suppliers against data made available by the RMI and against additional information obtained either from our customers or by means of our own research to determine whether such facilities are conformant with the assessment protocols of the RMI’s Responsible Minerals Assurance Process (the “RMAP”) (formerly the Conflict-Free Smelter Program). The RMI conducts independent third-party audits of smelters’ and refiners’ management systems and sourcing practices to validate conformance with RMAP assessment protocols. The RMAP employs a risk-based approach to validate smelters’ and refiners’ company level management processes for responsible mineral procurement (“RMAP conformant”). When necessary, we engage with smelters and refiners that we identify as at risk of not obtaining a conflict-free designation from a third-party audit program and encourage such smelters and refiners to become RMAP conformant. |
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Step 3: Design and Implement a Strategy to Respond to Identified Risks.
| • | We have developed procedures for obtaining CMRTs from our suppliers at least once a year, and we review their responses, consolidate the information in a central database and follow up with suppliers to address any red flags or inconsistent responses. Some of these activities we handle internally, and some are handled by our third-party conflict minerals due diligence service provider. |
| • | As needed, we survey our suppliers to gain further insights into their Conflict Minerals due diligence programs and processes, reviewing responses, assessing risk and following up with suppliers to address any inconsistencies, insufficient responses or insufficient documentation. |
| • | As needed, either directly or through our third-party conflict minerals due diligence service provider, we work with our suppliers to transition their processing to RMAP conformant smelters or refiners. |
| • | We have shared with our direct suppliers our expectations regarding sourcing from conflict-free designated smelters and refiners by means of our Policy Statement, Supplier Code of Conduct and the Specifications. |
| • | If, on the basis of issues that are identified as a result of either (i) the supplier data acquisition or engagement processes or (ii) the receipt of information from other sources, Marvell determines that there is a reasonable risk that a supplier is sourcing Conflict Minerals that are directly or indirectly financing or benefiting armed groups, Marvell will apply appropriate escalation procedures. |
| • | Such escalation procedures shall be determined at the discretion of the Conflict Minerals Working Group and may range from prompt engagement with the supplier to resolve the sourcing issue, to requiring such supplier to implement a risk management plan (which may involve, as appropriate, remedial action up to and including disengagement from upstream suppliers), to disengagement by Marvell from the applicable supplier. |
Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence.
Given that we do not source the Necessary Conflict Minerals directly from smelters and refiners, we rely on independent third parties, including the RMI, to coordinate and conduct third-party audits of these facilities. We rely on the published results of these third-party audits to validate the responsible sourcing practices of the smelters and refiners in our supply chain.
Step 5: Report on Supply Chain Due Diligence.
As required by the Rule, we have filed a Form SD and a Conflict Minerals Report as an exhibit thereto for the 2018 calendar year reporting period. The Form SD and Conflict Minerals Report are also available on our website atwww.marvell.com under the heading “Company” – “Investor Relations” – “Financials” – “SEC Filings.”
Conflict Minerals Processing Facilities
Based on the information provided by our suppliers, and otherwise obtained through the due diligence process described above, we have provided information regarding the processing facilities from which we source the Necessary Conflict Minerals contained in our products in Appendix A to this Report. Because some of our suppliers provided supply chain information on a company level rather
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than on a product level, this list may include facilities that did not actually process the Necessary Conflict Minerals contained in our products. In addition, the identified smelters and refiners may not include all of the smelters and refiners in our supply chain, as one supplier did not provide a CMRT, and certain CMRTs were collectedmid-year.
Country of Origin of Conflict Minerals
Based on information provided by our suppliers, or otherwise obtained through the due diligence process described above, some of the Necessary Conflict Minerals may have originated from mines located in the Covered Countries.
Efforts to Determine Mine or Location of Origin
As described above, the primary focus of our due diligence on the source and chain of custody of the Necessary Conflict Minerals in our supply chain was on the collection and assessment of (i) data provided by our suppliers on the CMRT, (ii) data provided by the RMI, (iii) data provided by our customers and (iv) data obtained by means of our own research.
During the 2018 reporting year, we received CMRT data indicating that there were certain smelters and refiners in our supply chain that were not RMAP conformant. Therefore, we are unable to conclusively determine the country of origin of the Necessary Conflict Minerals in all our products.
Independent Private Sector Audit
Marvell has not voluntarily elected to describe any of its products as “DRC conflict free,” and for this reason, an independent private sector audit of this Report has not been conducted.
Steps to Mitigate Risk
The Company intends to take the following steps, among others, to further mitigate the risk that the Necessary Conflict Minerals benefit armed groups in the Covered Countries:
| • | We will continue to monitor our suppliers’ Conflict Minerals sourcing practices to ensure that our suppliers remain in compliance with our Policy Statement and Supplier Code of Conduct. |
| • | We will continue to engage with our suppliers to obtain updated information regarding our supply chain, including RMI “known smelters” listed on the RMI’s Smelter Reference List, and the location of the mines from which the Conflict Minerals originate. |
| • | We will continue to support our suppliers’ efforts to encourage their smelters and refiners to obtain a conflict free designation from a third-party audit program. |
| • | We will advise any of our suppliers found to be sourcing from smelters or refiners that we identify as high-risk to establish an alternative source for the Necessary Conflict Minerals. |
| • | We will continue to engage in the RBA, the RMI and other industry initiatives promoting conflict-free supply chains. |
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FORWARD-LOOKING STATEMENTS
Statements relating to due diligence improvements and certain other statements herein are forward-looking in nature and are based on Marvell’s management’s current expectations or beliefs. These forward-looking statements are not a guarantee of performance and are subject to a number of uncertainties and other factors that may be outside of Marvell’s control and that could cause actual events to differ materially from those expressed or implied by the statements made herein.
DOCUMENTS INCORPORATED BY REFERENCE
Unless otherwise stated herein, any documents, third-party materials or references to websites (including Marvell’s) are not incorporated by reference in, or considered to be a part of, this CMR, unless expressly incorporated by reference herein.
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Appendix A
Conflict Minerals Processing Facilities Status as of April 15, 2019
For the 2018 reporting year, our suppliers identified 347 smelters and refiners as potential sources of the Necessary Conflict Minerals used in our products, and 95 of such smelters and refiners are not in conformance with the assessment protocols of the RMAP or another third-party audit program.
Thenon-conformance was attributed to smelters and refiners being inoperative, smelters and refiners not completing a third-party audit, or other causes. We are therefore unable to ascertain the country of origin of all Necessary Conflict Minerals, and for this reason, Marvell has not voluntarily elected to describe any of its products as “DRC conflict free.”
Table 1 contains the name of and mineral processed by each smelter and refiner reported to be in our supply chain for the 2018 reporting year.
Table 1
Smelters and Refiners
| Metal | Smelter Name | |
| Gold | DS PRETECH Co., Ltd. | |
| Gold | NH Recytech Company | |
| Gold | African Gold Refinery | |
| Gold | State Research Institute Center for Physical Sciences and Technology | |
| Gold | Safimet S.p.A | |
| Gold | Planta Recuperadora de Metales SpA | |
| Gold | SungEel HiMetal Co., Ltd. | |
| Gold | Pease & Curren | |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | |
| Gold | Morris and Watson Gold Coast | |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | |
| Gold | Bangalore Refinery | |
| Gold | Modeltech Sdn Bhd | |
| Gold | Universal Precious Metals Refining Zambia | |
| Gold | Sai Refinery | |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | |
| Gold | AU Traders and Refiners | |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | |
| Gold | WIELAND Edelmetalle GmbH | |
| Gold | SAXONIA Edelmetalle GmbH | |
| Gold | Italpreziosi | |
| Gold | L’Orfebre S.A. | |
| Gold | SAAMP |
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| Gold | Abington Reldan Metals, LLC | |
| Gold | TOOTau-Ken-Altyn | |
| Gold | Marsam Metals | |
| Gold | Korea Zinc Co., Ltd. | |
| Gold | Tony Goetz NV | |
| Gold | Remondis Argentia B.V. | |
| Gold | T.C.A S.p.A | |
| Gold | Sudan Gold Refinery | |
| Gold | Kaloti Precious Metals | |
| Gold | Emirates Gold DMCC | |
| Gold | Al Etihad Gold LLC | |
| Gold | Singway Technology Co., Ltd. | |
| Gold | KGHM Polska Miedz Spolka Akcyjna | |
| Gold | Republic Metals Corporation | |
| Gold | MMTC-PAMP India Pvt., Ltd. | |
| Gold | Geib Refining Corporation | |
| Gold | Umicore Precious Metals Thailand | |
| Gold | Guangdong Jinding Gold Limited | |
| Gold | Safina a.s. | |
| Gold | Morris and Watson | |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | |
| Gold | Yokohama Metal Co., Ltd. | |
| Gold | Yamakin Co., Ltd. | |
| Gold | Western Australian Mint (T/a The Perth Mint) | |
| Gold | Valcambi S.A. | |
| Gold | United Precious Metal Refining, Inc. | |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | |
| Gold | Umicore Brasil Ltda. | |
| Gold | Torecom | |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | |
| Gold | Tokuriki Honten Co., Ltd. | |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | |
| Gold | Tanaka Kikinzoku Kogyo K.K. | |
| Gold | Sumitomo Metal Mining Co., Ltd. | |
| Gold | Solar Applied Materials Technology Corp. | |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | |
| Gold | SEMPSA Joyeria Plateria S.A. | |
| Gold | Schone Edelmetaal B.V. |
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| Gold | SAMWON METALS Corp. | |
| Gold | Samduck Precious Metals | |
| Gold | Sabin Metal Corp. | |
| Gold | Royal Canadian Mint | |
| Gold | Rand Refinery (Pty) Ltd. | |
| Gold | PX Precinox S.A. | |
| Gold | PT Aneka Tambang (Persero) Tbk | |
| Gold | Prioksky Plant ofNon-Ferrous Metals | |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | |
| Gold | PAMP S.A. | |
| Gold | OJSC “The Gulidov KrasnoyarskNon-Ferrous Metals Plant” (OJSC Krastsvetmet) | |
| Gold | Ohura Precious Metal Industry Co., Ltd. | |
| Gold | Elemetal Refining, LLC | |
| Gold | Nihon Material Co., Ltd. | |
| Gold | Navoi Mining and Metallurgical Combinat | |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | |
| Gold | Moscow Special Alloys Processing Plant | |
| Gold | Mitsui Mining and Smelting Co., Ltd. | |
| Gold | Mitsubishi Materials Corporation | |
| Gold | MetalurgicaMet-Mex Penoles S.A. De C.V. | |
| Gold | Metalor USA Refining Corporation | |
| Gold | Metalor Technologies S.A. | |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | |
| Gold | Metalor Technologies (Hong Kong) Ltd. | |
| Gold | Metalor Technologies (Suzhou) Ltd. | |
| Gold | Matsuda Sangyo Co., Ltd. | |
| Gold | Materion | |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | |
| Gold | LS-NIKKO Copper Inc. | |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | |
| Gold | Lingbao Gold Co., Ltd. | |
| Gold | L’azurde Company For Jewelry | |
| Gold | Kyrgyzaltyn JSC | |
| Gold | Kojima Chemicals Co., Ltd. | |
| Gold | Kennecott Utah Copper LLC | |
| Gold | Kazzinc | |
| Gold | Kazakhmys Smelting LLC | |
| Gold | JX Nippon Mining & Metals Co., Ltd. | |
| Gold | JSC Uralelectromed | |
| Gold | JSC EkaterinburgNon-Ferrous Metal Processing Plant | |
| Gold | Asahi Refining Canada Ltd. | |
| Gold | Asahi Refining USA Inc. |
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| Gold | Jiangxi Copper Co., Ltd. | |
| Gold | Japan Mint | |
| Gold | Istanbul Gold Refinery | |
| Gold | Ishifuku Metal Industry Co., Ltd. | |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | |
| Gold | HwaSeong CJ Co., Ltd. | |
| Gold | Hunan Chenzhou Mining Co., Ltd. | |
| Gold | Heraeus Precious Metals GmbH & Co. KG | |
| Gold | Heraeus Metals Hong Kong Ltd. | |
| Gold | Heimerle + Meule GmbH | |
| Gold | HeeSung Metal Ltd. | |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | |
| Gold | Refinery of Seemine Gold Co., Ltd. | |
| Gold | OJSC Novosibirsk Refinery | |
| Gold | Eco-System Recycling Co., Ltd. | |
| Gold | Dowa | |
| Gold | DODUCO Contacts and Refining GmbH | |
| Gold | DSC (Do Sung Corporation) | |
| Gold | DayeNon-Ferrous Metals Mining Ltd. | |
| Gold | Daejin Indus Co., Ltd. | |
| Gold | Chugai Mining | |
| Gold | Chimet S.p.A. | |
| Gold | Yunnan Copper Industry Co., Ltd. | |
| Gold | Cendres + Metaux S.A. | |
| Gold | CCR Refinery - Glencore Canada Corporation | |
| Gold | Caridad | |
| Gold | C. Hafner GmbH + Co. KG | |
| Gold | Boliden AB | |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | |
| Gold | Aurubis AG | |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | |
| Gold | Asaka Riken Co., Ltd. | |
| Gold | Asahi Pretec Corp. | |
| Gold | Argor-Heraeus S.A. | |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | |
| Gold | AllgemeineGold-und Silberscheideanstalt A.G. | |
| Gold | Aida Chemical Industries Co., Ltd. | |
| Gold | Advanced Chemical Company | |
| Gold | ARY Aurum Plus (private, 100%) | |
| Gold | Henan Yuguang Gold & Lead Co., Ltd. | |
| Gold | K.A Rasmussen as |
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| Gold | Shandong Humon Smelting Co., Ltd. | |
| Gold | Shandong Yanggu Xiangguang Co. Ltd. | |
| Gold | Shandong Zhongkuang Group Co.,Ltd. | |
| Gold | Shenzhen Zhonghenglong Real Industry Co.,Ltd. | |
| Gold | So Accurate Group, Inc. | |
| Gold | Super Dragon Technology Co., Ltd. | |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | |
| Tantalum | Power Resources Ltd. | |
| Tantalum | Jiangxi Tuohong New Raw Material | |
| Tantalum | Resind Industria e Comercio Ltda. | |
| Tantalum | KEMET Blue Powder | |
| Tantalum | Global Advanced Metals Aizu | |
| Tantalum | Global Advanced Metals Boyertown | |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | |
| Tantalum | H.C. Starck Ltd. | |
| Tantalum | H.C. Starck Inc. | |
| Tantalum | H.C. Starck Hermsdorf GmbH | |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | |
| Tantalum | H.C. Starck Co., Ltd. | |
| Tantalum | KEMET Blue Metals | |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | |
| Tantalum | FIR Metals & Resource Ltd. | |
| Tantalum | D Block Metals, LLC | |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | |
| Tantalum | Ulba Metallurgical Plant JSC | |
| Tantalum | Telex Metals | |
| Tantalum | Taki Chemical Co., Ltd. | |
| Tantalum | Solikamsk Magnesium Works OAO | |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | |
| Tantalum | QuantumClean | |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | |
| Tantalum | NPM Silmet AS | |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | |
| Tantalum | Mineracao Taboca S.A. | |
| Tantalum | Metallurgical Products India Pvt., Ltd. | |
| Tantalum | LSM Brasil S.A. | |
| Tantalum | Jiujiang Tanbre Co., Ltd. | |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. |
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| Tantalum | F&X Electro-Materials Ltd. | |
| Tantalum | Exotech Inc. | |
| Tantalum | Duoluoshan | |
| Tantalum | Guangdong Rising RareMetals-EO Materials Ltd. | |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | |
| Tantalum | Asaka Riken Co., Ltd. | |
| Tantalum | Advanced Metallurgical Group N.V. (AMG) | |
| Tantalum | Hi-Temp Specialty Metals, Inc. | |
| Tantalum | Tranzact, Inc. | |
| Tantalum | Zhuzhou Cemented Carbide Group Co. Ltd | |
| Tin | Tin Technology & Refining | |
| Tin | Pongpipat Company Limited | |
| Tin | PT Bangka Serumpun | |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | |
| Tin | Guangdong HanheNon-Ferrous Metal Co., Ltd. | |
| Tin | PT Lautan Harmonis Sejahtera | |
| Tin | Gejiu Jinye Mineral Company | |
| Tin | Modeltech Sdn Bhd | |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | |
| Tin | PT Menara Cipta Mulia | |
| Tin | PT Kijang Jaya Mandiri | |
| Tin | PT Sukses Inti Makmur | |
| Tin | PT Bangka Prima Tin | |
| Tin | Metallo Spain S.L.U. | |
| Tin | Metallo Belgium N.V. | |
| Tin | Super Ligas | |
| Tin | Resind Industria e Comercio Ltda. | |
| Tin | An Vinh Joint Stock Mineral Processing Company | |
| Tin | CV Tiga Sekawan | |
| Tin | CV Dua Sekawan | |
| Tin | Tuyen QuangNon-Ferrous Metals Joint Stock Company | |
| Tin | Nghe TinhNon-Ferrous Metals Joint Stock Company | |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | |
| Tin | CV Ayi Jaya | |
| Tin | PT Inti Stania Prima | |
| Tin | O.M. Manufacturing Philippines, Inc. | |
| Tin | PT ATD Makmur Mandiri Jaya | |
| Tin | Melt Metais e Ligas S.A. | |
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | |
| Tin | CV Venus Inti Perkasa |
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| Tin | Yunnan Tin Company Limited | |
| Tin | Yunnan ChengfengNon-ferrous Metals Co., Ltd. | |
| Tin | White Solder Metalurgia e Mineracao Ltda. | |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | |
| Tin | Thaisarco | |
| Tin | Soft Metais Ltda. | |
| Tin | Rui Da Hung | |
| Tin | PT Tommy Utama | |
| Tin | PT Tinindo Inter Nusa | |
| Tin | PT Timah (Persero) Tbk Mentok | |
| Tin | PT Timah (Persero) Tbk Kundur | |
| Tin | PT Sumber Jaya Indah | |
| Tin | PT Stanindo Inti Perkasa | |
| Tin | PT Sariwiguna Binasentosa | |
| Tin | PT Refined Bangka Tin | |
| Tin | PT Prima Timah Utama | |
| Tin | PT Panca Mega Persada | |
| Tin | PT Mitra Stania Prima | |
| Tin | PT Karimun Mining | |
| Tin | PT Eunindo Usaha Mandiri | |
| Tin | PT DS Jaya Abadi | |
| Tin | PT Bukit Timah | |
| Tin | PT Belitung Industri Sejahtera | |
| Tin | PT Bangka Tin Industry | |
| Tin | PT Babel Inti Perkasa | |
| Tin | PT Artha Cipta Langgeng | |
| Tin | Operaciones Metalurgical S.A. | |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | |
| Tin | Jiangxi New Nanshan Technology Ltd. | |
| Tin | Mitsubishi Materials Corporation | |
| Tin | Minsur | |
| Tin | Mineracao Taboca S.A. | |
| Tin | Metallic Resources, Inc. | |
| Tin | Malaysia Smelting Corporation (MSC) | |
| Tin | China Tin Group Co., Ltd. | |
| Tin | Gejiu Kai Meng Industry and Trade LLC | |
| Tin | Huichang Jinshunda Tin Co., Ltd. | |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | |
| Tin | GejiuNon-Ferrous Metal Processing Co., Ltd. | |
| Tin | Fenix Metals | |
| Tin | Estanho de Rondonia S.A. | |
| Tin | EM Vinto | |
| Tin | Dowa |
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| Tin | CV United Smelting | |
| Tin | PT Premium Tin Indonesia | |
| Tin | PT Aries Kencana Sejahtera | |
| Tin | CV Gita Pesona | |
| Tin | Alpha | |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | |
| Tin | An Thai Minerals Co., Ltd. | |
| Tin | Da Nang Processing Import and Export Joint Stock | |
| Tin | Feinhütte Halsbrücke GmbH | |
| Tin | Hayes Metals Pty Ltd | |
| Tin | Hongqiao Metals (Kunshan) Co., Ltd. | |
| Tin | PT Babel Surya Alam Lestari | |
| Tin | PT Cipta Persada Mulia | |
| Tin | PT Justindo | |
| Tin | PT Timah Nusantara | |
| Tin | PT Wahana Perkit Jaya | |
| Tin | VQB Mineral and Trading Group JSC | |
| Tin | Zhongshan Jinye Smelting Co., Ltd | |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | |
| Tungsten | Moliren Ltd. | |
| Tungsten | Woltech Korea Co., Ltd. | |
| Tungsten | ACL Metais Eireli | |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | |
| Tungsten | Unecha Refractory metals plant | |
| Tungsten | Hydrometallurg, JSC | |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | |
| Tungsten | Niagara Refining LLC | |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | |
| Tungsten | H.C. Starck Tungsten GmbH | |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
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| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | |
| Tungsten | Jiangxi TongguNon-ferrous Metallurgical & Chemical Co., Ltd. | |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | |
| Tungsten | Jiangxi Minmetals Gao’anNon-ferrous Metals Co., Ltd. | |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | |
| Tungsten | Xiamen Tungsten Co., Ltd. | |
| Tungsten | Wolfram Bergbau und Hutten AG | |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | |
| Tungsten | Kennametal Fallon | |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | |
| Tungsten | Japan New Metals Co., Ltd. | |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | |
| Tungsten | Global Tungsten & Powders Corp. | |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | |
| Tungsten | Kennametal Huntsville | |
| Tungsten | A.L.M.T. Tungsten Corp. | |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | |
| Tungsten | Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd. | |
| Tungsten | Tungsten Diversified Industries LLC |
The smelters and refiners in the list above that report country of origin information to the RMI reported that the Conflict Minerals processed by these facilities originated from the following countries:
Angola, Argentina, Australia, Austria, Azerbaijan, Belgium, Bermuda, Bolivia, Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Dominican republic,DRC- Congo (Brazzaville),DRC- Congo (Kinshasa), Ecuador, Ethiopia, Finland, France, Germany, Ghana, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Italy, Japan, Jersey, Kazakhstan, Kenya, Korea, Kyrgyzstan, Laos, Liberia, Luxembourg, Malaysia, Mali, Mauritania, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, South Africa, Spain, Sudan, Suriname, Sweden, Switzerland, Taiwan, Tajikistan
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