Exhibit 1.01
CONFLICT MINERALS REPORT
NETGEAR, INC.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934
for the Calendar Year Ended December 31, 2016
Introduction
Rule 13p-1 was adopted by the United States Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to Conflict Minerals as directed by Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010. Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain Conflict Minerals necessary to the functionality or production of their products. Conflict Minerals are defined by Rule 13p-1 as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tungsten, tantalum, and gold (collectively, “3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Covered Countries (as defined below).
If a registrant has reason to believe that any 3TGs in their supply chain may have originated in the Democratic Republic of the Congo or an adjoining country ("Covered Countries"), or if they are unable to determine the country of origin of the 3TGs in their products, or that their products are manufactured entirely from recycled and scrap sources, then the issuer must exercise due diligence on the source and chain of custody of the 3TGs. The registrant must annually submit a Form SD and Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures. NETGEAR, Inc. ("NETGEAR" or the "Company") has determined that 3TGs are necessary to the functionality or production of some of its products during the 2016 calendar year and therefore, is required to perform due diligence and file this report annually. This report is NETGEAR's CMR for the reporting calendar year ended December 31, 2016.
This report is not audited, as Rule 13p-1 and current SEC guidance provide that if the registrant is not declaring products as "DRC Conflict Free," the CMR is not subject to an independent private sector audit.
Section 1 - Company Overview
NETGEAR was incorporated in Delaware in January 1996. The Company is a global networking company that delivers innovative networking and Internet connected products to consumers and growing businesses. The Company's products are built on a variety of proven technologies such as wireless (WiFi and LTE), Ethernet and powerline, with a focus on reliability and ease-of-use. The product line consists of wired and wireless devices that enable networking, broadband access and network connectivity. These products are available in multiple configurations to address the needs of the end-users in each geographic region in which the Company's products are sold. NETGEAR utilizes contract manufacturers, original design manufacturers and component vendors to supply components, assemblies and finished products.
NETGEAR’s internet address is www.netgear.com. This CMR will be posted on the Company’s website with other SEC filings under About Us/Investor Relations as soon as reasonably practicable after it is electronically filed with the SEC.
1.1 NETGEAR Products
NETGEAR's product portfolio is comprised of the following product categories:
| • | Ethernet switches, which are multiple port devices used to network computing devices and peripherals via Ethernet wiring; |
| • | Wireless controllers and access points, which are devices used to manage and control multiple WiFi base stations on a campus or a facility providing WiFi connections to smart phones, tablets, laptops and other computing devices; |
| • | Internet security appliances, which provide Internet access through capabilities such as anti-virus and anti-spam; |
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| • | Unified storage, which delivers file and block based data into a single shared storage system, meeting the demands of small enterprises, education, hospitality and health markets through an easy-to-use interface for managing multiple storage protocols; |
| • | Broadband modems, which are devices that convert the broadband signals into Ethernet data that feeds Internet into homes and offices; |
| • | WiFi Gateways, which are WiFi routers with an integrated broadband modem, for broadband Internet access; |
| • | WiFi Hotspots, which create mobile WiFi Internet access that utilizes 3G and 4G LTE data networks for use on the go, and at home in place of traditional wired broadband, Internet access; |
| • | WiFi routers, which create a local area network (LAN) for home or office computer, mobile and Smart Home devices to connect and share a broadband Internet connection; |
| • | WiFi range extenders, which extend the range of an existing WiFi network to eliminate WiFi dead spots; |
| • | Powerline adapters and bridges, which extend wired and WiFi Internet connections to any AC outlet using existing electrical wiring; |
| • | Remote video security systems, which provide WiFi video and audio monitoring and recordings, accessible by smart phones, tablets or PCs and MACs; and |
| • | WiFi network adapters, which enable computing devices to be connected to the network via WiFi. |
We conducted an analysis of NETGEAR products and found that small quantities of 3TG, necessary to their functionality or production, are found in substantially all NETGEAR products.
1.2 Conflict Minerals Report
For all product categories listed under 1.1, we have been unable to conclusively determine the origin of the 3TG that our products contain, or to conclusively determine to what extent they come from recycled or scrap sources; the facilities used to process them; their country of origin; or their mine or location of origin. Our suppliers reported at broad levels, often with the declaration scope as “Company” in their Conflict Minerals Reporting Template (“CMRT”).
This report describes our Reasonable Country of Origin Inquiry (“RCOI”) efforts, the due diligence measures we took on the 3TG source and chain of custody, the results of our due diligence efforts, expected risk assessment and mitigation steps.
1.3 Conflict Minerals Policy
NETGEAR has published its conflict minerals policy on its webpage located at:
http://www.netgear.com/images/conflict_minerals_policy_statement.pdf
Section 2 - Reasonable Country of Origin Inquiry (“RCOI”)
To determine whether the necessary 3TG in our products originated in Covered Countries, we first needed to determine the scope of our Conflict Minerals program. As determined and explained above, NETGEAR has determined that nearly all of its products contain one or more 3TGs and therefore, we determined that all suppliers of such products should be surveyed on the sourcing of those 3TGs. From there, we composed a list of suppliers associated with the covered products. We deemed it impractical to filter this list further to exclude some possibly irrelevant suppliers because we could not determine definitively the presence or absence of 3TGs in all parts supplied to manufacture of our products.
NETGEAR utilized the CMRT version 4.10 or higher to conduct a survey of all in scope suppliers. During the supplier survey process, we contacted all direct suppliers and required that they complete a valid CMRT and provide it to the Company for assessment. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, question 1 of the CMRT asks suppliers whether any of the 3TGs they use are necessary to the functionality or production of their products.
On an average, NETGEAR direct suppliers were contacted at least 3 times through email and/or phone call for follow up on their CMRT submission or for clarifying any questions that NETGEAR Conflict Minerals Program team or their designated 3rd party may have had. NETGEAR’s Conflict Minerals Program team member was also in-charge of all the communication with direct suppliers.
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NETGEAR Conflict Minerals Team also hosted training and Q&A session for all its direct suppliers to address their queries related to Conflict Minerals program and NETGEAR expectations.
We received completed CMRTs from all 59 in scope suppliers. Once all CMRTs were collected they were evaluated using automated data validation. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on their answers to questions 1 through 6.
All submitted forms are accepted and classified as valid or invalid so that data is still retained. As of May 25th, 2017, here were no invalid supplier submissions that could not be corrected.
Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries. Therefore, in accordance with the Rule, the Company performed due diligence on the source and chain of custody of the 3TGs in question.
Section 3 - Conflict Minerals Due Diligence Program Design
NETGEAR’s conflict minerals due diligence program is designed to conform in all material aspects with the framework recommended by the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, also known as OECD Guidance, as it relates to NETGEAR’s supply chain position as a “downstream” or finished product manufacturer and purchaser.
Summarized below are the components of Company’s program as they relate to the five-step framework set forth in the OECD Guidance:
3.1 Establish strong company management systems
| • | Adopted and publicly communicated a conflict minerals company policy which is posted on NETGEAR website at http://www.netgear.com/images/conflict_minerals_policy_statement.pdf |
| • | As a member of the EICC (Electronic Industry Citizenship Coalition), required that our suppliers and contract manufacturers acknowledge and implement the EICC’s Code of Conduct, which includes an obligation to conduct due diligence regarding conflict minerals. |
| • | Assembled internal conflict minerals team, with representation from NETGEAR’s Operations, Legal, Procurement, Finance and Internal Audit. |
| • | Established a system of control through the use of Supplier Code of Conduct and transparency over NETGEAR’s conflict minerals supply chain by engaging first-tier suppliers and requesting relevant information through the use of a third-party supplier management vendor which utilized due diligence tools created by the Conflict Free Sourcing Initiative ("CFSI"), including the CMRT. |
| • | Provided updates on our conflict minerals due diligence progress and status to certain members of NETGEAR’s senior management. |
| • | Educated and trained those personnel responsible to work on NETGEAR’s Conflict Minerals Program. This includes internal team members and suppliers. |
| • | Established a grievance mechanism to allow employees, suppliers, and others to report suspected non-compliance with legal requirement and/or suspected non-compliance with NETGEAR’s Code of Ethics and Supplier Code of Conduct. These policies are publically available at http://www.netgear.com/about/corporate-social-responsibility/ethics/ |
| • | Established an internal audit of our conflict minerals due diligence process. |
| • | Identified business records relating to conflict minerals due diligence, including records of due diligence processes, findings and resulting decisions, that will be retained in accordance with our records retention policies. |
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3.2 Identify and manage risk in the supply chain
| • | Identified relevant Tier 1* suppliers that supplied products containing 3TG by reference to bills of materials. |
| • | Requested such suppliers to provide information regarding smelters or refiners in our supply chain by using the CMRT. |
| • | Reviewed supplier responses for completeness and accuracy. |
| • | Compared information in supplier responses with the list of 3TG processing facilities that received a “conflict-free” designation, produced by the CFSP (Conflict Free Smelter Program). |
| • | Each facility that meets the CFSI definition of a smelter or refiner of a 3TG is assigned a risk of high, medium, or low based on three scoring criteria: geographic proximity to the Covered Countries, CFSP audit status, and known or plausible evidence of unethical or conflict sourcing. |
| • | Contacted non-responsive suppliers, requesting their responses. |
| • | Provided suppliers with feedback on responses containing errors, inconsistencies or incomplete information. |
| • | Evaluated suppliers on the strength of their internal conflict minerals programs. When suppliers meet or exceed the below criteria (yes to all four questions) they are deemed to have a strong program. When they do not meet those criteria they are deemed to have a weak program. The criteria used to evaluate the strength of their programs are: |
| ◦ | Do you have a policy that includes DRC conflict-free sourcing? |
| ◦ | Have you implemented due diligence measures for conflict-free sourcing? |
| ◦ | Do you verify due diligence information received from your suppliers? |
| ◦ | Does your verification process include corrective action management? |
*NETGEAR’s definition of Tier 1 Supplier - ODM (Original Design Manufacturer), CM (Contract Manufacturer) and NETGEAR’s AVL (Approved Vendor List) with whom NETGEAR has directly negotiated the price of goods & services and has direct control or business relationship, but excluding the following suppliers: Plastics and software suppliers; Packaging suppliers; and Suppliers whose materials declarations confirm gold, tantalum, tin and tungsten are not contained in the applicable component.
3.3 Design and implement a strategy to respond to risk
| • | Conducted regular conflict minerals team meetings to review, among other things, NETGEAR’s conflict minerals program, any potential or actual risks identified during due diligence, and the status of supplier responses. |
| • | Reported progress on a quarterly basis to our Senior Vice President, Worldwide Operations & Support. |
| • | Identified high risk smelters in NETGEAR’s supply chain by using smelter database from CFSI that includes information on smelter’s chain of custody of minerals. NETGEAR’s smelter risk calculation is based on 3 scoring criteria: |
| ◦ | Geographic proximity to the DRC and covered countries; |
| ◦ | Conflict-Free Smelter Program (CFSP) audit status; and |
| ◦ | Known or plausible evidence of unethical or conflict sourcing. |
| • | Implemented an escalation plan for non-responsive suppliers and/or address incomplete or inaccurate supply chain information. |
| • | Requested that certain suppliers remove specific smelters or refiners from their supply chain that we deemed to be high-risk or invalid. |
| • | Informed non-responsive suppliers that we will assess, and potentially withhold, future business with them if they do not provide their supply chain conflict minerals information using the CMRT. |
| • | Conducted Conflict Minerals Program due diligence process audit of NETGEAR’s ODM partners. |
3.4 Audit of smelter/refiner’s due diligence practices
| • | Relied on the CFSP, the London Bullion Market Association, and the Responsible Jewellery Council to coordinate third-party audits of smelters and refiners to validate the sourcing practices of such facilities in our supply chain. |
| • | Provided indirect financial support for such third-party audits through our continued membership in the EICC and CFSI. |
| • | Participated in EICC & CFSI work groups, including smelter engagement and outreach. |
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3.5 Report annually on supply chain due diligence
| • | Publicly communicated Conflict Minerals Policy on company website at http://www.netgear.com/images/conflict_minerals_policy_statement.pdf |
| • | Filed our Form SD for the reporting period from January 1, 2016 to December 31, 2016, including this Conflict Minerals Report, with the Securities Exchange Commission and made it available on the Investor Relations pages of our website at http://investor.netgear.com/sec.cfm |
| • | Reported supply chain smelter information in this Conflict Minerals Report. |
The content of any website referred to in this report is included for general information only and is not incorporated by reference in this report.
Section 4 - Due Diligence Results
NETGEAR does not have direct contractual relationships with smelters and refiners, therefore, we relied on our direct suppliers and the entire supply chain to gather and provide specific information on 3TGs used in NETGEAR products.
4.1 Survey Results
In 2016, NETGEAR conducted supply chain surveys, using the CMRT, of Tier 1 suppliers that we identified may contribute necessary 3TGs in our products. NETGEAR surveyed 59 Tier 1 suppliers and the results of our supply chain survey and the conclusion of our reasonable country of origin inquiry are as follows:
| • | 100% of NETGEAR surveyed suppliers provided a response using accepted version of the CMRT. |
| • | None of the 59 CMRTs collected have been deemed invalid. |
| • | The surveyed suppliers identified 305 legitimate smelters and refiner facilities which may process the necessary 3TGs contained in the products manufactured. |
| • | Of these 305 smelters and refiners, 249 are validated as conflict free by CFSI, and, based on information provided by CFSI, a further 10 have agreed to undergo or are currently undergoing a third-party audit. |
| • | We know or have reason to believe that a portion of the minerals processed by 24 of these 305 smelters and refiners may have originated in the Covered Countries and are not solely from recycled or scrap sources. |
Attached as Table A is a list of all legitimate smelters and refiners listed by our suppliers in their CMRTs that appear on the list maintained by the CFSI. Since many of the CMRTs we received from suppliers were made at the company level bases, rather than on a product-level basis, we are not able to identify which smelters or refiners listed in Table A actually processed the 3TGs contained in our products. Therefore, the list of processing smelters and refiners disclosed in Table A may contain more facilities than those that actually processed the minerals contained in our products.
A list of potential countries of origin of from which the reported smelters and refiners collectively source from is provided in Table B. As with the list of smelters and refiners, many responses were provided at the company level and therefore, this list of countries may contain more than those that our products are being sourced from.
NETGEAR developed a point based supplier risk assessment system, specifically for our Conflict Minerals Program, to assess supplier risks based on multiple criteria. Of the 59 Tier 1 suppliers, no supplier received a risk score that is less than NETGEAR’s benchmark score.
Section 5 - Risk Mitigation and Due Diligence Improvement Plan
5.1 Inherent limitation on due diligence measures
Because of our manufacturing business model, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals in the products we contract to have manufactured. Given our place in the supply chain, we have no direct relationships with smelters, refiners, and therefore possess no independent means of determining the source and origin of conflict mineral ores processed by smelters or refiners. Our due diligence processes are based on the necessity of seeking data from our suppliers and component manufacturers and
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those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by independent third-party audit programs.
5.2 Steps to be taken to mitigate risk and improve Due Diligence Process
We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the DRC or adjoining countries:
| • | Continue to work with the CFSI and/or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance and/or other SEC recognized framework. |
| • | Engage with Tier 1 suppliers supplying us with 3TG from sources that support conflict in any covered country to establish an acceptable alternative source of 3TG. |
| • | Continue to work with Tier 1 suppliers to ensure that they have robust due diligence practices. |
| • | Continue to request Tier 1 suppliers to provide accurate, valid, and complete smelter information. |
| • | Provide our Tier 1 suppliers with training resources to educate and create awareness about Conflict Minerals, their role in mitigating the risk and creating transparent supply chain. |
| • | Engage Tier 1 suppliers to encourage smelters or refiners in supply chain, not yet identified by the CFSP or equivalent independent third-party audit, to undergo smelter audits and verify compliance. |
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Table A
Smelter & Refiners Reported to be in Supply Chain of NETGEAR
Below list of smelters and refiners have been identified by our Tier 1 suppliers and may have been used in processing of necessary 3TGs contained in NETGEAR products:
| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Gold | Bangalore Refinery | India |
| Gold | Modeltech Sdn Bhd | Malaysia |
| Gold | Gujarat Gold Centre | India |
| Gold | AU Traders and Refiners | South Africa |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | SAXONIA Edelmetalle Gmbh | Germany |
| Gold | SAAMP | France |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan |
| Gold | Korea Zinc Co., Ltd. | Korea (Republic Of) |
| Gold | Remondis Argentia B.V. | Netherlands |
| Gold | T.C.A S.p.A | Italy |
| Gold | Kaloti Precious Metals | United Arab Emirates |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China |
| Gold | KGHM Polska Miedź Spółka Akcyjna | Poland |
| Gold | Republic Metals Corporation | United States Of America |
| Gold | MMTC-PAMP India Pvt., Ltd. | India |
| Gold | Geib Refining Corporation | United States Of America |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | SAFINA A.S. | Czech Republic |
| Gold | Morris and Watson | New Zealand |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan |
| Gold | Western Australian Mint trading as The Perth Mint | Australia |
| Gold | Valcambi S.A. | Switzerland |
| Gold | United Precious Metal Refining, Inc. | United States Of America |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
| Gold | Umicore Brasil Ltda. | Brazil |
| Gold | Torecom | Korea (Republic Of) |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
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| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | So Accurate Group, Inc. | United States Of America |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | SEMPSA Joyería Platería S.A. | Spain |
| Gold | Schone Edelmetaal B.V. | Netherlands |
| Gold | Samwon Metals Corp. | Korea (Republic Of) |
| Gold | Samduck Precious Metals | Korea (Republic Of) |
| Gold | Sabin Metal Corp. | United States Of America |
| Gold | Royal Canadian Mint | Canada |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | PX Précinox S.A. | Switzerland |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | PAMP S.A. | Switzerland |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold | Elemetal Refining, LLC | United States Of America |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | Mexico |
| Gold | Metalor USA Refining Corporation | United States Of America |
| Gold | Metalor Technologies S.A. | Switzerland |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold | Metalor Technologies (Suzhou) Ltd. | China |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | Materion | United States Of America |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | LS-NIKKO Copper Inc. | Korea (Republic Of) |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Kennecott Utah Copper LLC | United States Of America |
| Gold | Kazzinc | Kazakhstan |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
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| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
| Gold | Asahi Refining Canada Ltd. | Canada |
| Gold | Asahi Refining USA Inc. | United States Of America |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Gold | Japan Mint | Japan |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | HwaSeong CJ CO., LTD. | Korea (Republic Of) |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | China |
| Gold | OJSC Novosibirsk Refinery | Russian Federation |
| Gold | Eco-System Recycling Co., Ltd. | Japan |
| Gold | Dowa | Japan |
| Gold | DODUCO GmbH | Germany |
| Gold | DSC (Do Sung Corporation) | Korea (Republic Of) |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Daejin Indus Co., Ltd. | Korea (Republic Of) |
| Gold | Chugai Mining | Japan |
| Gold | Chimet S.p.A. | Italy |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | Cendres + Métaux S.A. | Switzerland |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Caridad | Mexico |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | Boliden AB | Sweden |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | Aurubis AG | Germany |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Asahi Pretec Corp. | Japan |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | Brazil |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Advanced Chemical Company | United States Of America |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
| Tantalum | Power Resources Ltd. | Macedonia |
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| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tantalum | Resind Indústria e Comércio Ltda. | Brazil |
| Tantalum | Tranzact, Inc. | United States Of America |
| Tantalum | KEMET Blue Powder | United States Of America |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | Global Advanced Metals Boyertown | United States Of America |
| Tantalum | Plansee SE Reutte | Austria |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tantalum | H.C. Starck Ltd. | Japan |
| Tantalum | H.C. Starck Inc. | United States Of America |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
| Tantalum | H.C. Starck GmbH Laufenburg | Germany |
| Tantalum | H.C. Starck GmbH Goslar | Germany |
| Tantalum | H.C. Starck Co., Ltd. | Thailand |
| Tantalum | Plansee SE Liezen | Austria |
| Tantalum | KEMET Blue Metals | Mexico |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Tantalum | D Block Metals, LLC | United States Of America |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | China |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum | Telex Metals | United States Of America |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China |
| Tantalum | QuantumClean | United States Of America |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | NPM Silmet AS | Estonia |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Tantalum | Mineração Taboca S.A. | Brazil |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | LSM Brasil S.A. | Brazil |
| Tantalum | King-Tan Tantalum Industry Ltd. | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | Hi-Temp Specialty Metals, Inc. | United States Of America |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | Exotech Inc. | United States Of America |
| Tantalum | Duoluoshan | China |
| Tantalum | Conghua Tantalum and Niobium Smeltry | China |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
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| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Tin | Gejiu Jinye Mineral Company | China |
| Tin | Modeltech Sdn Bhd | Malaysia |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | China |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
| Tin | PT Kijang Jaya Mandiri | Indonesia |
| Tin | An Thai Minerals Co., Ltd. | Viet Nam |
| Tin | PT Sukses Inti Makmur | Indonesia |
| Tin | PT Bangka Prima Tin | Indonesia |
| Tin | Elmet S.L.U. | Spain |
| Tin | Metallo-Chimique N.V. | Belgium |
| Tin | PT O.M. Indonesia | Indonesia |
| Tin | Resind Indústria e Comércio Ltda. | Brazil |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam |
| Tin | PT Cipta Persada Mulia | Indonesia |
| Tin | CV Tiga Sekawan | Indonesia |
| Tin | CV Dua Sekawan | Indonesia |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam |
| Tin | CV Ayi Jaya | Indonesia |
| Tin | PT Inti Stania Prima | Indonesia |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | Phoenix Metal Ltd. | Rwanda |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | PT Wahana Perkit Jaya | Indonesia |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | CV Venus Inti Perkasa | Indonesia |
| Tin | Yunnan Tin Company Limited | China |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Tin | White Solder Metalurgia e Mineração Ltda. | Brazil |
| Tin | VQB Mineral and Trading Group JSC | Viet Nam |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | Thaisarco | Thailand |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | Rui Da Hung | Taiwan, Province Of China |
| Tin | PT Tommy Utama | Indonesia |
| Tin | PT Tinindo Inter Nusa | Indonesia |
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia |
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia |
| Tin | PT Sumber Jaya Indah | Indonesia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
| Tin | PT Sariwiguna Binasentosa | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
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| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Tin | PT Prima Timah Utama | Indonesia |
| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | PT Karimun Mining | Indonesia |
| Tin | PT Eunindo Usaha Mandiri | Indonesia |
| Tin | PT DS Jaya Abadi | Indonesia |
| Tin | PT Bukit Timah | Indonesia |
| Tin | PT Belitung Industri Sejahtera | Indonesia |
| Tin | PT Bangka Tin Industry | Indonesia |
| Tin | PT Babel Inti Perkasa | Indonesia |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | Operaciones Metalurgical S.A. | Bolivia |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | China |
| Tin | Mitsubishi Materials Corporation | Japan |
| Tin | Minsur | Peru |
| Tin | Mineração Taboca S.A. | Brazil |
| Tin | Metallic Resources, Inc. | United States Of America |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | China Tin Group Co., Ltd. | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | Huichang Jinshunda Tin Co., Ltd. | China |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Fenix Metals | Poland |
| Tin | Estanho de Rondônia S.A. | Brazil |
| Tin | EM Vinto | Bolivia |
| Tin | Dowa | Japan |
| Tin | CV United Smelting | Indonesia |
| Tin | CV Serumpun Sebalai | Indonesia |
| Tin | PT Aries Kencana Sejahtera | Indonesia |
| Tin | PT Justindo | Indonesia |
| Tin | CV Gita Pesona | Indonesia |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | Brazil |
| Tin | Alpha | United States Of America |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
| Tungsten | Moliren Ltd | Russian Federation |
| Tungsten | Woltech Korea Co., Ltd. | Korea (Republic Of) |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | Hydrometallurg, JSC | Russian Federation |
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| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | China |
| Tungsten | Niagara Refining LLC | United States Of America |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Viet Nam |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany |
| Tungsten | H.C. Starck GmbH | Germany |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tungsten | Wolfram Bergbau und Hütten AG | Austria |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Viet Nam |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Viet Nam |
| Tungsten | Kennametal Fallon | United States Of America |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders Corp. | United States Of America |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | Kennametal Huntsville | United States Of America |
| Tungsten | A.L.M.T. Tungsten Corp. | Japan |
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Table B
Countries of Origin
Below is the list of country of origin for the conflict minerals as a result of the RCOI, includes but may not be limited to:
| • | Level 1 countries - countries of origin that are not identified as conflict regions or plausible countries for the export, smuggling or transit of conflict minerals, namely, Argentina, Australia, Austria, Belgium, Brazil, Canada, Chile, China, Columbia, Cote D’Ivoire, Czech Republic, Djibouti, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungry, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Lao People’s Democratic Republic, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Plurinational State of Bolivia, Portugal, Republic of Korea, Russian Federation, Sierra Leone, Singapore, Slovakia, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom of Great Britain, United States of America, Vietnam and Zimbabwe. |
| • | Level 2 countries - countries of origin that are known or plausible countries for the export, smuggling or transit of conflict minerals, namely, Kenya, Mozambique and South Africa. |
| • | Level 3 countries - countries of origin that are the DRC or its adjoining countries, namely, the DRC, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia. |
| • | Recycled/Scrap - smelters or refiners that only process recycled or scrap materials. |
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