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, 2017
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 (DRC) 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 2017 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, 2017.
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 products to consumers, businesses and service providers. 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 3TGs 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 Tier 1* suppliers of such products should be surveyed on the sourcing of those 3TGs.
*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.
NETGEAR utilized the CMRT version 5.01 or higher to conduct a survey of all in scope suppliers. The CMRT is a free, standardized reporting template developed by the Responsible Minerals Initiative that is known as the industry standard in conflict minerals data collection. During the supplier survey process, we contacted all Tier 1 suppliers and required that they complete a valid CMRT and provide it to the Company for assessment.
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 was also in-charge of all the communication with direct suppliers.
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NETGEAR Conflict Minerals Team and their third party service provider 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 57 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 March 7, 2018 there was no invalid supplier submission 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 RBA (Responsible Business Alliance, previously known as the EICC or the Electronic Industry Citizenship Coalition), required that our suppliers and contract manufacturers acknowledge and implement the RBA’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 Responsible Minerals Initiative (“RMI”), 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 to review conflict minerals due diligence process against NETGEAR’s documented procedure and data accuracy in NETGEAR CMRT. |
| • | 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. |
| • | 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. |
| • | Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. |
| • | Compared information in supplier responses with the list of 3TG processing facilities that received a “conflict-free” designation, produced by the RMAP (Responsible Minerals Assurance Process). |
| • | Each facility that meets the RMI definition of a smelter or refiner of a 3TG is assessed according to red flag indicators defined in the OECD Guidance. To determine the level of risk that each smelter posed to the supply chain the Company assessed three criteria: geographic proximity to the Covered Countries, RMAP audit status, and credible 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 and encouraged them to resubmit a valid response. |
| • | 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 based on these four questions in the CMRT: |
| • | Have you established a conflict minerals sourcing policy? |
| • | Have you implemented due diligence measures for conflict-free sourcing? |
| • | Do you review due diligence information received from your suppliers against your company’s expectations? |
| • | Does your review process include corrective action management? |
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 the RMI that includes information on smelter’s chain of custody of minerals. NETGEAR’s smelter risk calculation is based on 3 criteria: |
| • | Geographic proximity to the DRC and covered countries; |
| • | RMAP audit status; and |
| • | Credible evidence of unethical or conflict sourcing. |
| • | Through the use of the Company’s third party service provider, contacted non-RMAP facilities to encourage them to join the program and undergo an audit |
| • | 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. |
| • | Engaged any suppliers whom we have reason to believe are supplying the Company with 3TGs from sources that may be considered a red-flag and encourage them to establish alternative sources of 3TGs. |
| • | 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 RMAP, 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 RBA and RMI. |
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| • | Participated in RBA & RMI work groups, including smelter engagement and outreach. |
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, 2017 to December 31, 2017, 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 2017, NETGEAR conducted supply chain surveys, using the CMRT, of Tier 1 suppliers that we identified may contribute necessary 3TGs in our products. NETGEAR surveyed 57 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 57 CMRTs collected have been deemed invalid. |
| • | The surveyed suppliers identified 314 legitimate smelters and refiner facilities which may process the necessary 3TGs contained in the products manufactured. |
| • | Of these 314 smelters and refiners, 249 are validated as conflict free by RMI, and, based on information provided by the RMI through RMAP, a further 12 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 20 of these 314 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 RMI. 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 57 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.
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Our due diligence processes are based on the necessity of seeking data from our suppliers and component manufacturers and 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 RMI 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. |
| • | Increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program. |
| • | Emphasize the need for cooperation and support by our Tier 1 suppliers by implementing more direct Netgear-led escalations throughout the program. |
| • | Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers and follow up with suppliers who appear to have gaps in their internal processes for conflict minerals. |
| • | Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of 3TGs. |
| • | Work more closely with our third party conflict minerals service provider to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TGs contained in our products. |
| • | Engage Tier 1 suppliers to encourage smelters or refiners in supply chain, not yet identified by the RMAP or equivalent independent third-party audit, to undergo smelter audits and verify compliance. |
| • | Support our third party service provider in their smelter due diligence activities by signing a letter to be sent to smelters who have yet to enroll in RMAP, encouraging them to do so. |
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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 | Abington Reldan Metals, LLC | UNITED STATES |
| Gold | Advanced Chemical Company | UNITED STATES |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | Asahi Refining USA Inc. | UNITED STATES |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangalore Refinery | INDIA |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Caridad | MEXICO |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Cendres + Métaux S.A. | SWITZERLAND |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| Gold | DODUCO GmbH | GERMANY |
| Gold | Dowa | JAPAN |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | Elemetal Refining, LLC | UNITED STATES |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
| Gold | Geib Refining Corporation | UNITED STATES |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Gujarat Gold Centre | INDIA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
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| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | HeeSung | KOREA, REPUBLIC OF |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Ltd. Hong Kong | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Italpreziosi | ITALY |
| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Gold Co., Ltd. | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | Marsam Metals | BRAZIL |
| Gold | Materion | UNITED STATES |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Modeltech Sdn Bhd | MALAYSIA |
| Gold | Morris and Watson | NEW ZEALAND |
| Gold | Morris and Watson Gold Coast | AUSTRALIA |
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| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | PAMP S.A. | SWITZERLAND |
| Gold | Pease & Curren | UNITED STATES |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Précinox S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Remondis Argentia B.V. | NETHERLANDS |
| Gold | Republic Metals Corporation | UNITED STATES |
| Gold | Royal Canadian Mint | CANADA |
| Gold | SAAMP | FRANCE |
| Gold | Sabin Metal Corp. | UNITED STATES |
| Gold | Safimet Spa. (Gold refiners) | Italy |
| Gold | SAFINA A.S. | CZECH REPUBLIC |
| Gold | Sai Refinery | INDIA |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Singway Technology Co., Ltd. | TAIWAN |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | Sudan Gold Refinery | SUDAN |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | SungEel HiTech | KOREA, REPUBLIC OF |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
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| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Gold | Tony Goetz NV | BELGIUM |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | Exotech Inc. | UNITED STATES |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | H.C. Starck Inc. | UNITED STATES |
| Tantalum | H.C. Starck Ltd. | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | KEMET Blue Powder | UNITED STATES |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineração Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining & Smelting | JAPAN |
10
| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Tantalum | Molycorp Silmet A.S. | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | Power Resources Ltd. | MACEDONIA |
| Tantalum | QuantumClean | UNITED STATES |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | Taki Chemicals | JAPAN |
| Tantalum | Telex Metals | UNITED STATES |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| Tin | Alpha | UNITED STATES |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Dua Sekawan | INDONESIA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | CV Tiga Sekawan | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | Elmet S.L.U. | SPAIN |
| Tin | EM Vinto | BOLIVIA |
| Tin | Estanho de Rondônia S.A. | BRAZIL |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| Tin | Gejiu Jinye Mineral Company | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | CHINA |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | Metallic Resources, Inc. | UNITED STATES |
11
| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Tin | Metallo-Chimique N.V. | BELGIUM |
| Tin | Mineração Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Modeltech Sdn Bhd | MALAYSIA |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT DS Jaya Abadi | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA |
| Tin | PT Inti Stania Prima | INDONESIA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Kijang Jaya Mandiri | INDONESIA |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT O.M. Indonesia | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Sukses Inti Makmur | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Super Ligas | Brazil |
| Tin | Thaisarco | THAILAND |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
12
| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Tin | Yunnan Tin Company Limited | CHINA |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck GmbH | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES |
| Tungsten | Kennametal Huntsville | UNITED STATES |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION |
| Tungsten | Niagara Refining LLC | UNITED STATES |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
13
| Metal | Smelter or Refiner Facility Name | Location of Facility |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
14
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. |
15