Conflict Minerals Report
Introduction
Advanced Semiconductor Engineering, Inc. (“ASE”, “we”, “our”, “us”) is the world’s largest independent provider of semiconductor packaging and testing services based on 2013 revenues. Our services include semiconductor packaging, production of interconnect materials, front-end engineering testing, wafer probing and final testing services, as well as integrated solutions for electronic manufacturing services in relation to computers, peripherals, communications, industrial, automotive, and storage and server applications. We utilize gold, tantalum, tin and tungsten in certain of our activities.
We have 14 facilities located in Taiwan, China, Malaysia, Japan, Singapore, Korea and the United States that provide packaging, testing and materials services to many semiconductor companies around the world. A typical customer engagement involves receiving consigned silicon wafers from the customer, performing a series of manufacturing services on the wafers, and delivering a completed, packaged integrated circuit back to the customer. In the performance of packaging and materials services, we typically add gold and tin as direct materials in the manufacturing process, and we occasionally add tungsten. We do not add tantalum during the manufacturing processes used by our packaging and materials services. We do not use gold, tin, tungsten or tantalum in our testing services.
Since our acquisition of a controlling interest in Universal Scientific Industrial Co., Ltd. in February 2010, we provide a broad range of electronic manufacturing services with annual revenues in excess of $2 billion to a global customer base. We have seven facilities located in Taiwan, China and Mexico that provide electronic manufacturing services. In providing these services, we acquire numerous electronic and non-electronic components, and assemble them into sub-assemblies and finished products. Typical materials and components which we utilize include solder (tin based), electrolytic capacitors (tantalum bearing), integrated circuits (gold wire) and high temperature wires (tungsten). Gold, tin, tungsten and tantalum are essential to our electronic manufacturing services.
Reasonable Country of Origin Inquiry
For our packaging and materials services, we purchase gold, tin and tungsten from 78 suppliers. Each of these 78 suppliers has supplied us with the information required in a template authored by the Electronic Industry Citizenship Coalition, Incorporated & Global e-Sustainability Initiative, or EICC-GeSI, with an accounting of their conflict mineral smelter or refiner sources, or SoRs. Each of these 78 suppliers is in receipt of our conflict minerals policy, and each has confirmed their understanding of its principles and
their willingness to comply. Additionally, each supplier has provided to us additional documentation, including a declaration certifying they do not purchase conflict minerals from sources within, or from third parties that purchase from, the Democratic Republic of Congo or its nine adjacent countries, or Covered Countries.
For our electronic manufacturing services, we performed a supply chain assessment of all 1,200 suppliers who provided us with gold, tin, tungsten or tantalum in 2013. We organized the list by annual purchase volume (purchase expenditure in dollars) from largest to smallest and made a determination that for our 2013 Conflict Minerals Report we would analyze suppliers supplying us a purchase volume of greater than $3 million. The purchase volume of the resulting 99 companies accounted for 85% of our total purchase volume in 2013.
Below are the results of our reasonable country of origin inquiry, or RCOI.
Gold
Packaging and Materials Services
| | 1. | During 2013, we purchased gold for our packaging and materials services from a total of 35 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from third parties. Based on data we collected, we identified a total of 32 SoRs from which we indirectly purchased gold in 2013 for our packaging and materials services. All 35 of our gold suppliers for our packaging and materials services responded to our request, representing 100% of our total expenditure for gold during 2013 for our packaging and materials services. None of our direct suppliers of gold for our packaging and materials services informed us that they were unable to collect the requested information from their suppliers. |
| | 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on April 25, 2014, 25 of the SoRs from which we indirectly purchased gold in 2013 for our packaging and materials services are participants in the Conflict-Free Smelter Program , or CFSP, operated by the Conflict-Free Sourcing Initiative, or CFSI. |
| | 3. | We asked our suppliers of gold for our packaging and materials services to certify that they only purchased gold from SoRs that purchased gold from conflict-free sources. All 35 of our gold suppliers for our packaging and materials services, accounting for 100% of our total expenditure for gold during 2013 for our packaging and materials services, provided such certifications. The following table summarizes our RCOI for the gold used in our packaging and materials services in 2013. |
| Companies supplying gold for our packaging and materials services | | Number | | | % |
| Companies from which we purchased gold | | 35 | | | | 100% | |
| Companies that were SoRs | | 0 | | | | 0% | |
| Companies that bought from SoRs or other sources | | 35 | | | | 100% | |
| Companies that provided SoR source information | | 35 | | | | 100% | |
| Companies that did not provide SoR source information | | 0 | | | | 0% | |
| Companies that certified that SoRs were conflict-free | | 35 | | | | 100% | |
| Companies that did not certify that SoRs were conflict-free | | 0 | | | | 0% | |
| SoRs of gold for our packaging and materials services (as of April 25, 2014) | | Number | | | % |
| SoRs from which we indirectly purchased gold | | 32 | | | | 100% | |
| SoRs with Smelter ID, CFSP Compliant | | 25 | | | | 78% | |
| SoRs with Smelter ID, CFSP Active | | 0 | | | | 0% | |
| SoRs with Smelter ID, not joined CFSP | | 6 | | | | 19% | |
| SoRs with no Smelter ID | | 1 | | | | 3% | |
Electronic Manufacturing Services
| | 1. | During 2013, we purchased gold for our electronic manufacturing services from a total of 65 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from other third parties. Based on data collected, 106 SoRs were identified from which we indirectly purchased gold in 2013 for our electronic manufacturing services. Forty-four of our gold suppliers for our electronic manufacturing services responded to our request to identify the SoRs for gold during 2013. Twenty-one did not respond. In addition, none of our direct suppliers of gold for our electronic manufacturing services that responded informed us that they were unable to collect the requested information from their suppliers during 2013. |
| | 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on April 25, 2014, 41 of the SoRs from which we indirectly purchased gold in 2013 for our electronic manufacturing services are participants in the CFSP operated by the CFSI. |
| | 3. | We asked our suppliers of gold for our electronic manufacturing services to certify that they only sourced gold from SoRs that purchased gold from conflict-free sources. Seventeen of our gold suppliers for our electronic manufacturing services provided such certifications, while 48 did not. The following table summarizes our RCOI for the gold used in our electronic manufacturing services in 2013. |
| Companies supplying gold for our electronic manufacturing services | | Number | | % |
| Companies from which we purchased gold | | 65 | | | 100% | |
| Representation of total expenditure for gold | | -- | | | 81% | |
| Companies that were SoRs | | 0 | | | 0% | |
| Companies that bought from SoRs or other sources | | 65 | | | 100% | |
| Companies that provided SoR source information | | 44 | | | 68% | |
| Companies that did not provide SoR source information | | 21 | | | 32% | |
| Companies that certified that SoRs were conflict-free | | 17 | | | 26% | |
| Companies that did not certify that SoRs were conflict-free | | 48 | | | 74% | |
| SoRs of gold for our electronic manufacturing services (as of April 25, 2014) | | Number | | % |
| SoRs from which we indirectly purchased gold | | 106 | | | 100% | |
| SoRs with Smelter ID, CFSP Compliant | | 39 | | | 37% | |
| SoRs with Smelter ID, CFSP Active | | 2 | | | 2% | |
| SoRs with Smelter ID, not joined CFSP | | 48 | | | 45% | |
| SoRs with no Smelter ID | | 17 | | | 16% | |
Tin
Packaging and Materials Services
| | 1. | During 2013, we purchased tin for our packaging and materials services from a total of 52 suppliers. None of these suppliers are SoRs, and all of these suppliers purchased tin from SoRs or from other third parties. Based on the data we collected, we identified a total of 27 SoRs from which we indirectly purchased tin in 2013 for our packaging and materials services. All 52 of our tin suppliers for our packaging and materials services responded to our request, representing 100% of our total expenditure for tin during 2013 for our packaging and materials services. None of our direct suppliers of tin for our packaging and materials services informed us that they were unable to collect the requested information from their suppliers. |
| | 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on April 25, 2014, 18 of the SoRs from which we indirectly purchased tin in 2013 for our packaging and materials services are participants in the CFSP operated by the CFSI. |
| | 3. | We asked our suppliers of tin for our packaging and materials services to certify that they only purchased tin from SoRs that purchased tin from conflict-free sources. All 52 of our tin suppliers for our packaging and materials services which accounted for 100% of our total expenditure for tin in 2013 for our packaging and materials services provided such certifications. The following table summarizes our RCOI for the tin used in our packaging and materials services in 2013. |
| Companies supplying tin for our packaging and materials services | | Number | | % |
| Companies from which we purchased tin | | 52 | | | 100% | |
| Companies that were SoRs | | 0 | | | 0% | |
| Companies that bought from SoRs or other sources | | 52 | | | 100% | |
| Companies that provided SoR source information | | 52 | | | 100% | |
| Companies that did not provide SoR source information | | 0 | | | 0% | |
| Companies that certified that SoRs were conflict-free | | 52 | | | 100% | |
| Companies that did not certify that SoRs were conflict-free | | 0 | | | 0% | |
| SoRs of tin for our packaging and materials services (as of April 25, 2014) | | Number | | % |
| SoRs from which we indirectly purchased tin | | 27 | | | 100% | |
| SoRs with Smelter ID, CFSP Compliant | | 13 | | | 48% | |
| SoRs with Smelter ID, CFSP Active | | 5 | | | 19% | |
| SoRs with Smelter ID, not joined CFSP | | 6 | | | 22% | |
| SoRs with no Smelter ID | | 3 | | | 11% | |
Electronic Manufacturing Services
| | 1. | During 2013, we purchased tin for our electronic manufacturing services from a total of 82 suppliers. None of these suppliers are SoRs and all these suppliers purchased tin from SoRs or from other third parties. Based on data collected, 102 SoRs were identified from which we indirectly purchased tin for our electronic manufacturing services in 2013. Sixty-two of our tin suppliers for our electronic manufacturing services responded to our request to identify the SoRs for tin during 2013. Twenty did not respond. None of our suppliers of tin for our electronic manufacturing services that responded informed us that they were unable to collect the requested information from their suppliers during 2013. |
| | 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on April 25, 2014, 24 of the SoRs from which we indirectly purchased tin for our electronic manufacturing services in 2013 are participants in the CFSP operated by the CSFI. |
| | 3. | We asked our suppliers of tin for our electronic manufacturing services to certify that they only sourced tin from SoRs that purchased tin from conflict-free sources. Twenty-five of our tin suppliers for our electronic manufacturing services provided such certifications, while 57 did not. The following table summarizes our RCOI for the tin used in our electronic manufacturing services in 2013. |
| Companies supplying tin for our electronic manufacturing services | | Number | | % |
| Companies from which we purchased tin | | 82 | | | 100% | |
| Representation of total expenditure for tin | | -- | | | 86% | |
| Companies that were SoRs | | 0 | | | 0% | |
| Companies that bought from SoRs or other sources | | 82 | | | 100% | |
| Companies that provided SoR source information | | 62 | | | 76% | |
| Companies that did not provide SoR source information | | 20 | | | 24% | |
| Companies that certified that SoRs were conflict-free | | 25 | | | 31% | |
| Companies that did not certify that SoRs were conflict-free | | 57 | | | 69% | |
| SoRs of tin for our electronic manufacturing services (as of April 25, 2014) | | Number | | % |
| SoRs from which we indirectly purchased tin | | 102 | | | 100% | |
| SoRs with Smelter ID, CFSP Compliant | | 13 | | | 13% | |
| SoRs with Smelter ID, CFSP Active | | 11 | | | 11% | |
| SoRs with Smelter ID, not joined CFSP | | 35 | | | 34% | |
| SoRs with no Smelter ID | | 43 | | | 42% | |
Tungsten
Packaging and Materials Services
| | 1. | During 2013, we purchased tungsten for our packaging and materials services from 1 supplier. This supplier is not an SoR, and did purchase tungsten from an SoR or another third party. Based on data we collected, we identified 1 SoR from which we indirectly purchased tungsten for our packaging and materials services in 2013. Our single tungsten supplier for our packaging and materials services responded to our request, representing 100% of our total expenditure for tungsten for our packaging and materials services during 2013. Our single supplier for tungsten for our packaging and materials services informed us that it was able to collect the requested information from its supplier. |
| | 2. | Based on an inspection of the list available at |
www.conflictfreesourcinginitiative.org conducted on April 25, 2014, the SoR from which we indirectly purchased tungsten for our packaging and materials services in 2013 is an active participant in the Tungsten Industry-Conflict Minerals Council, or TI-CMC, program.
| | 3. | We asked our supplier of tungsten for our packaging and materials services to certify that it only purchased tungsten from SoRs that purchased tungsten from conflict-free sources. Our tungsten supplier for our packaging and materials services, which supplied us 100% of our total expenditure for tungsten for our packaging and materials services during 2013, provided such a certification. The following table summarizes our RCOI for the tungsten used in our packaging and materials services in 2013. |
| Companies supplying tungsten for our packaging and materials services | | Number | | % |
| Companies from which we purchased tungsten | | 1 | | | 100% | |
| Companies that were SoRs | | 0 | | | 0% | |
| Companies that bought from SoRs or other sources | | 1 | | | 100% | |
| Companies that provided SoR source information | | 1 | | | 100% | |
| Companies that did not provide SoR source information | | 0 | | | 0% | |
| Companies that certified that SoRs were conflict-free | | 1 | | | 100% | |
| Companies that did not certify that SoRs were conflict-free | | 0 | | | 0% | |
| SoRs of tungsten for our packaging and materials services (as of April 25, 2014) | | Number | | % |
| SoRs from which we indirectly purchased tungsten | | 1 | | | 100% | |
| SoRs with Smelter ID, CFSP Compliant | | 0 | | | 0% | |
| SoRs with Smelter ID, TI-CMC Active | | 1 | | | 100% | |
| SoRs with Smelter ID, not joined CFSP | | 0 | | | 0% | |
| SoRs with no Smelter ID | | 0 | | | 0% | |
Electronic Manufacturing Services
| | 1. | During 2013, we purchased tungsten for our electronic manufacturing services from a total of 32 suppliers. None of these suppliers are SoRs and all these |
suppliers purchased tungsten from SoRs or from other third parties. Based on data collected, 31 SoRs were identified from which we indirectly purchased tungsten for our electronic manufacturing services in 2013. Thirty of our tungsten suppliers for our electronic manufacturing services responded to our request to identify the SoRs for tungsten during 2013. Two did not reply. None of our direct suppliers of tungsten for our electronic manufacturing services that responded informed us that they were unable to collect the requested information from their suppliers during 2013.
| | 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on April 25, 2014, 13 of the SoRs from which we indirectly purchased tungsten for our electronic manufacturing services in 2013 are active participants in either the CFSP operated by the CFSI or the TI-CMC program. |
| | 3. | We asked our suppliers of tungsten for our electronic manufacturing services to certify that they only purchased tungsten from SoRs that purchased tungsten from conflict-free sources. Thirteen of our tungsten suppliers for our electronic manufacturing services during 2013 provided such certifications, while 19 did not. The following table summarizes our RCOI for the tungsten used in our electronic manufacturing services in 2013. |
| Companies supplying tungsten for our electronic manufacturing services | | Number | | % |
| Companies from which we purchased tungsten | | 32 | | | 100% | |
| Representation of total expenditure for tungsten | | -- | | | 20% | |
| Companies that were SoRs | | 0 | | | 0% | |
| Companies that bought from SoRs or other sources | | 32 | | | 100% | |
| Companies that provided SoR source information | | 30 | | | 94% | |
| Companies that did not provide SoR source information | | 2 | | | 6% | |
| Companies that certified that SoRs were conflict-free | | 13 | | | 41% | |
| Companies that did not certify that SoRs were conflict-free | | 19 | | | 59% | |
| SoRs of tungsten for our electronic manufacturing services (as of April 25, 2014) | | Number | | % |
| SoRs from which we indirectly purchased tungsten | | 31 | | | 100% | |
| SoRs with Smelter ID, CFSP Compliant | | 0 | | | 0% | |
| SoRs with Smelter ID, TI-CMC or CFSP Active | | 13 | | | 42% | |
| SoRs with Smelter ID, not joined CFSP | | 8 | | | 26% | |
| SoRs with no Smelter ID | | 10 | | | 32% | |
Tantalum
Packaging and Materials Services
We do not add tantalum in any manufacturing processes for our packaging and materials services.
Electronic Manufacturing Services
| | 1. | During 2013, we purchased tantalum for our electronic manufacturing services from a total of 33 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on the data collected, 20 SoRs were identified from which we indirectly purchased tantalum for our electronic manufacturing services in 2013. Thirty-two of our tantalum suppliers for our electronic manufacturing services responded to our request to identify the SoRs for tantalum during 2013. One did not reply. None of our direct suppliers of tantalum for our electronic manufacturing services that responded informed us that they were unable to collect the requested information from their suppliers during 2013. |
| | 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on April 25, 2014, 19 of the SoRs from which we indirectly purchased tantalum for our electronic manufacturing services in 2013 are participants in the CFSP operated by the CSFI. |
| | 3. | We asked our suppliers of tantalum for our electronic manufacturing services to certify that they only purchased tantalum from SoRs that purchased tantalum from conflict-free sources. Fifteen of our tantalum suppliers for our electronic manufacturing services provided such certifications, while 18 did not. The following table summarizes our RCOI for the tantalum used in our electronic manufacturing services in 2013. |
| Companies supplying tantalum for our electronic manufacturing services | | Number | | % |
| Companies from which we purchased tantalum | | 33 | | | 100% | |
| Representation of total expenditure for tantalum | | -- | | | 21% | |
| Companies that were SoRs | | 0 | | | 0% | |
| Companies that bought from SoRs or other sources | | 33 | | | 100% | |
| Companies that provided SoR source information | | 32 | | | 97% | |
| Companies that did not provide SoR source information | | 1 | | | 3% | |
| Companies that certified that SoRs were conflict-free | | 15 | | | 46% | |
| Companies that did not certify that SoRs were conflict-free | | 18 | | | 54% | |
| SoRs of tantalum for our electronic manufacturing services (as of April 25, 2014) | | Number | | % |
| SoRs from which we indirectly purchased tantalum | | 20 | | | 100% | |
| SoRs with Smelter ID, CFSP Compliant | | 19 | | | 95% | |
| SoRs with Smelter ID, CFSP Active | | 0 | | | 0% | |
| SoRs with Smelter ID, not joined CFSP | | 1 | | | 5% | |
| SoRs with no Smelter ID | | 0 | | | 0% | |
Part I – Due Diligence
Design of Due Diligence
ASE has adopted the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas as the framework for performing conflict minerals due diligence, and for reporting the structure, process and findings in our Conflict Minerals Report.
Due Diligence Measures Performed
A. Communication
The ASE Group Corporate Policy for Sourcing Conflict Minerals is posted on our website (and attached here as Annex A) as well as distributed to each of our suppliers of conflict minerals who must agree in writing that the policy will be complied with.
Additionally, we require each supplier to certify they are not providing materials or products to us that are not conflict-free.
Finally, every factory manager must certify they comply with our conflict minerals policy. They are also responsible for communicating the policy throughout their organizations and implementing procedures to ensure compliance.
B. Internal Management Team Supporting Supply Chain Due Diligence
Our conflict minerals management team is a comprehensive cross-functional team under the direction of our Chief Operating Officer. The team provides planning, analysis, management, tracking, monitoring and communication for the business wide initiative. Regular and frequent meetings are held to ensure progress against requirements.
C. System of Controls and Transparency
Conflict minerals procedures are documented in our specifications system and managed by our quality organization. The bills-of-materials required for different customer products across all manufacturing operations are controlled by our manufacturing execution system software.
The primary method for gathering conflict mineral data is through the deployment of reporting templates authored by the EICC-GeSI. We store this data on a comprehensive filing system that supports ensuring the currency of the data.
We have not taken steps to perform an in-depth analysis of, or to validate, the information provided to us by our suppliers in their EICC-GeSI declarations submitted to us.
D. Identification And Assessment of Risk in the Supply Chain
Our process for identifying conflict minerals risk in the supply chain is as follows:
| (a) | Identify all direct materials and components in the supply chain that contain conflict minerals |
| (b) | Identify suppliers of materials and components that contain conflict materials |
| (c) | Gather EICC-GeSI templates from all suppliers of conflict minerals |
| (d) | Assess data gathered on templates to identify potential inconsistencies or “red flags” |
| (e) | Follow up as appropriate to resolve items of concern |
| (f) | Depending on the enormity and complexity of the supply chain: |
| | · | Assess the value of the annual purchase volume of all conflict minerals |
| | · | Prioritize conflict mineral sources by dollar volume to leverage impact from available analytical resources |
E. Procedure, Supplier Declarations, Including DRC Conflict-Free Determinations
We request current EICC-GeSI reporting templates from all our suppliers of conflict minerals. We verify reported SoR inputs against the CFSP lists of certified and active SoRs.
We request a certification (Conflict-Free Minerals Compliance Representations) from all conflict minerals suppliers certifying that they are not providing conflict minerals from conflict affected areas within the Covered Countries.
F. Validation of Supplier Declarations
For 2013 reporting purposes, we have not performed in-depth analysis and validation of all supplier declarations provided to us.
G. Mitigating Risk
Our packaging and materials services mitigate supply chain risk to conflict minerals in the following ways:
| (a) | We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers. |
| (b) | For compliance year 2013, we received EICC-GeSI templates from 100% of our conflict mineral suppliers. We also received certifications from 100% of our conflict minerals suppliers that they are not providing materials that are not “DRC Conflict Free.” |
| (c) | For compliance year 2014, we intend to perform additional analysis on the information provided by our major suppliers and begin interfacing with our other suppliers, both on our own and in conjunction with industry organizations such as EICC and GeSI. |
Our electronic manufacturing services mitigate supply chain risk to conflict minerals in the following ways:
| (a) | We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers. |
| (b) | For compliance year 2013, our electronic manufacturing services identified 99 suppliers that accounted for 85% of our conflict minerals content. |
| (c) | For compliance year 2014, we intend to perform additional analysis on the information provided by our major suppliers and begin interfacing with our other suppliers, both on our own and in conjunction with industry organizations such as EICC and GeSI. |
Part II – Products With Necessary Conflict Minerals
We are reporting that we have determined that all conflict minerals necessary to the functionality or production of a product manufactured by ASE or contracted by ASE to be manufactured for the 2013 reporting period are “DRC Conflict Undeterminable.” We have not found that we are using minerals that financed or benefited armed groups.
Description of Products
We offer semiconductor packaging, production of interconnect materials, front-end engineering testing, wafer probing and final testing services, as well as integrated solutions for electronic manufacturing services in relation to computers, peripherals, communications, industrial, automotive, and storage and server applications. We utilize gold, tantalum, tin and tungsten in our packaging, materials services and electronic manufacturing services. We do not use gold, tantalum, tin and tungsten in our testing services.
Our packaging products or services include: advanced packaging (including bumping, flip chip, chip scale and SiP package); IC wirebonding (including leadframe-based packages such as QFP/TQFP, QFN/MCC and PLCC/PDIP and substrate-based packages, such as various BGA package types and LGA); discrete and others.
Our materials products are interconnect materials that connect the input/output on the semiconductor dies to the printed circuit board. Interconnect materials include substrates, which are multi-layer miniature printed circuit boards, and are an important element of the electrical characteristics and overall performance of semiconductors. We produce substrates for use in our packaging operations.
The key products and services we offer to our electronic manufacturing services customers include: computers (including motherboards for server & desktop PC; peripheral; port replicator; network attached storage; and technical services); communications (including Wi-Fi; WiMAX; SiP and Hybrid SiP); consumer products (including control boards for flat panel devices); automotive electronics (including automotive electronic manufacturing services, car LED lighting and regulator/rectifier); and industrial products (including point-of-sale systems and smart handheld devices).
Facilities Used to Process Necessary Conflict Minerals
The SoRs, where known, for all suppliers described above are listed below:
Packaging and Materials Services
| Gold | | Tin | | Tungsten |
| 1AUS046 | | 2BEL017 | | 4USA007 |
| 1CAN064 | | 2BOL010 | | |
| 1CHE004 | | 2BOL022 | | |
| 1CHE035 | | 2BRA018 | | |
| 1CHE063 | | 2BRA054 | | |
| 1CHL014 | | 2BRA063 | | |
| 1CHN053 | | 2CHN011 | | |
| 1CHN054 | | 2CHN012 | | |
| 1CHN065 | | 2CHN047 | | |
| 1DEU017 | | 2CHN048 | | |
| 1DEU018 | | 2IDN009 | | |
| 1HKG019 | | 2IDN027 | | |
| 1HKG036 | | 2IDN028 | | |
| 1JPN005 | | 2IDN030 | | |
| 1JPN015 | | 2IDN032 | | |
| 1JPN021 | | 2IDN040 | | |
| 1JPN028 | | 2IDN042 | | |
| 1JPN034 | | 2IDN049 | | |
| 1JPN039 | | 2JPN020 | | |
| 1JPN040 | | 2MYS016 | | |
| 1JPN057 | | 2PER019 | | |
| 1JPN058 | | 2POL064 | | |
| 1JPN060 | | 2THA046 | | |
| 1JPN071 | | 2USA001 | | |
| 1JPN072 | | Gldschm | | |
| 1JPN073 | | Trotter | | |
| 1JPN074 | | Met Res | | |
| 1KOR032 | | | | |
| 1USA025 | | | | |
| 1USA043 | | | | |
| 1ZAF049 | | | | |
| Metalor | | | | |
| | | | | |
Electronic Manufacturing Services
| Gold | | Tin | | Tantalum | | Tungsten |
| 1AUS046 | | 2BEL017 | | 3AUT011 | | 4AUT012 |
| 1BEL062 | | 2BOL010 | | 3CHN001 | | 4CHN002 |
| 1BRA003 | | 2BOL022 | | 3CHN003 | | 4CHN003 |
| 1BRA061 | | 2BRA018 | | 3CHN009 | | 4CHN004 |
| 1CAN024 | | 2BRA054 | | 3CHN015 | | 4CHN009 |
| 1CAN050 | | 2BRA063 | | 3CHN017 | | 4CHN010 |
| 1CAN064 | | 2CHN011 | | 3CHN019 | | 4CHN014 |
| 1CHE004 | | 2CHN012 | | 3CHN020 | | 4CHN015 |
| 1CHE011 | | 2CHN013 | | 3DEU006 | | 4CHN016 |
| 1CHE035 | | 2CHN014 | | 3JPN008 | | 4CHN018 |
| 1CHE045 | | 2CHN015 | | 3JPN023 | | 4CHN021 |
| 1CHE063 | | 2CHN047 | | 3KAZ014 | | 4CHN022 |
| 1CHE068 | | 2CHN048 | | 3RUS012 | | 4CHN023 |
| 1CHL014 | | 2CHN050 | | 3USA002 | | 4DEU008 |
| 1CHN020 | | 2CHN051 | | 3USA004 | | 4JPN017 |
| 1CHN023 | | 2CHN052 | | 3USA005 | | 4JPN020 |
| 1CHN053 | | 2CHN055 | | 3USA010 | | 4RUS013 |
| 1CHN054 | | 2IDN003 | | 3USA016 | | 4USA001 |
| 1CHN059 | | 2IDN004 | | 3USA018 | | 4USA007 |
| 1CHN065 | | 2IDN005 | | 3ZAF024 | | 4USA026 |
| 1CHN066 | | 2IDN006 | | | | 4VNM019 |
| 1CHN079 | | 2IDN007 | | | | |
| 1DEU001 | | 2IDN008 | | | | |
| 1DEU007 | | 2IDN009 | | | | |
| 1DEU017 | | 2IDN023 | | | | |
| 1DEU018 | | 2IDN024 | | | | |
| 1ESP052 | | 2IDN025 | | | | |
| 1HKG019 | | 2IDN026 | | | | |
| 1HKG036 | | 2IDN027 | | | | |
| 1IDN048 | | 2IDN028 | | | | |
| 1ITA013 | | 2IDN029 | | | | |
| 1JPN005 | | 2IDN030 | | | | |
| 1JPN015 | | 2IDN031 | | | | |
| 1JPN021 | | 2IDN032 | | | | |
| 1JPN022 | | 2IDN033 | | | | |
| 1JPN028 | | 2IDN034 | | | | |
| 1JPN034 | | 2IDN035 | | | | |
| 1JPN039 | | 2IDN036 | | | | |
| 1JPN040 | | 2IDN037 | | | | |
| 1JPN057 | | 2IDN038 | | | | |
| Gold | | Tin | | Tantalum | | Tungsten |
| 1JPN058 | | 2IDN039 | | | | |
| 1JPN060 | | 2IDN040 | | | | |
| 1JPN071 | | 2IDN041 | | | | |
| 1JPN072 | | 2IDN042 | | | | |
| 1JPN073 | | 2IDN043 | | | | |
| 1JPN074 | | 2IDN044 | | | | |
| 1JPN077 | | 2IDN045 | | | | |
| 1JPN078 | | 2IDN049 | | | | |
| 1JPN080 | | 2IDN058 | | | | |
| 1JPN950 | | 2IDN059 | | | | |
| 1KAZ029 | | 2JPN020 | | | | |
| 1KGZ030 | | 2MYS016 | | | | |
| 1KOR012 | | 2PER019 | | | | |
| 1KOR032 | | 2POL064 | | | | |
| 1KOR081 | | 2RUS021 | | | | |
| 1KOR082 | | 2THA046 | | | | |
| 1KOR083 | | 2USA001 | | | | |
| 1KOR084 | | | | | | |
| 1KOR085 | | | | | | |
| 1KOR086 | | | | | | |
| 1KOR087 | | | | | | |
| 1MEX010 | | | | | | |
| 1MEX038 | | | | | | |
| 1NLD051 | | | | | | |
| 1PHL008 | | | | | | |
| 1RUS016 | | | | | | |
| 1RUS026 | | | | | | |
| 1RUS027 | | | | | | |
| 1RUS041 | | | | | | |
| 1RUS044 | | | | | | |
| 1RUS047 | | | | | | |
| 1RUS055 | | | | | | |
| 1RUS067 | | | | | | |
| 1SAU031 | | | | | | |
| 1SWE009 | | | | | | |
| 1TUR006 | | | | | | |
| 1TUR069 | | | | | | |
| 1TUR070 | | | | | | |
| 1TWN056 | | | | | | |
| 1USA025 | | | | | | |
| 1USA033 | | | | | | |
| 1USA037 | | | | | | |
| 1USA043 | | | | | | |
| 1USA075 | | | | | | |
| 1USA076 | | | | | | |
| 1USA088 | | | | | | |
| 1UZB002 | | | | | | |
| 1UZB042 | | | | | | |
| 1ZAF049 | | | | | | |
Country of Origin of Necessary Conflict Minerals
Multiple countries of origin are possible for the necessary conflict minerals produced by each of the SoRs listed above, including the Democratic Republic of Congo or other Covered Countries. A comprehensive list of such countries is not known by us.
Efforts to Determine the Mine or Location of Origin
For this report we focused on determining the SoRs that sourced the conflict minerals used in our products and services and the conflict status of those sources using data from the CFSI. Because multiple countries of origin are possible for the necessary conflict minerals produced by each of the SoRs listed above, including the Democratic Republic of Congo or other Covered Countries, a detailed list of the mines or location of origin of minerals is not known by us.
Part III – Independent Private Sector Audit
Because our reporting status for 2013 is “DRC Conflict Undeterminable,” we are not required to submit an independent private sector audit for 2013.
Annex A – ASE Group Corporate Policy for Sourcing Conflict Minerals
The mining and distribution of “conflict minerals”1 originating from the Democratic Republic of Congo are sometimes controlled by violent organizations in order to fund conflict in that country and adjacent regions. Our industry supply chains are inadvertently subject to metals derived from these conflict minerals which can be introduced through the metals we use such as gold, tin, tantalum and tungsten. ASE Group is dedicated to the elimination of these conflict minerals in our supply chain, and to use only conflict-free minerals2 responsibly sourced around the world. It is also our objective to support the continued use of conflict-free minerals from the DRC and the adjacent regions such that responsible mining is not diminished.
All suppliers to ASE Group must support this policy by:
| | (a) | being diligent in their assessment and validation of their supply chains to ensure ASE Group’s objectives of a transparent supply chain, and conflict-free purchases as inputs to the services and products we produce. |
| | (b) | at all times be in compliance with all regional and international regulations for conflict minerals. |
| | (c) | at all times be in compliance with industry standards for the sourcing and reporting of conflict minerals. |
| | (d) | being diligent and accurate in their formal assurances of conflict-free minerals provided to us. |
1 Conflict minerals are columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives as defined in the Dodd-Frank Act section 1502 and SEC Rule 13p-1 under the Securities Exchange Act of 1934.
2 Conflict-free minerals are conflict minerals that through their distribution directly or indirectly do not benefit violent organizations in the Democratic Republic of Congo and its adjacent regions.
