Exhibit 1.01
SEAGATE TECHNOLOGY PLC
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2015
INTRODUCTION
This Conflict Minerals Report (“Report”) for Seagate Technology Public Limited Company (the “Company,” “Seagate,” “we,” or “our”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1 to December 31, 2015 (the “Reporting Period”). This Report is being filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD and is also posted on our website at http://www.seagate.com/about/global-citizenship/. Information contained on, or accessible through, our website is not a part of this Report.
The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain tin, tantalum, tungsten, or gold (“3TG,” also defined by the rule as “conflict minerals”). The Democratic Republic of the Congo (“DRC”) and its adjoining countries have extensive reserves of 3TG, some of which are illegally sourced and traded by armed groups who are responsible for significant human rights violations. The purpose of the Rule is to encourage companies whose products contain conflict minerals to endeavor to source from suppliers who do not directly or indirectly support such armed groups through their purchasing decisions. The Democratic Republic of the Congo and its adjoining countries, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia, are sometimes referred to in this Report as the “Covered Countries.”
We are a leading provider of electronic data storage technology and solutions. Our principal products are hard disk drives, commonly referred to as disk drives, hard drives or HDDs. In addition to HDDs, we produce a broad range of electronic data storage products including solid state hybrid drives (“SSHD”), solid state drives (“SSD”), PCIe cards and SATA controllers. Our storage technology portfolio also includes storage subsystems and high performance computing solutions.
Hard disk drives are devices that store digitally encoded data on rapidly rotating disks with magnetic surfaces. Disk drives continue to be the primary medium of mass data storage due to their performance attributes, high quality and cost effectiveness. Complementing existing data center storage architecture, solid-state storage devices use integrated circuit assemblies as memory to store data, and most SSDs use NAND-based flash memory. In addition to HDDs and SSDs, SSHDs combine the features of SSDs and HDDs in the same unit, containing a large hard disk drive and an SSD cache to improve performance of frequently accessed data.
Our products are designed for enterprise servers and storage systems in mission critical and nearline applications; client compute applications, where our products are designed primarily for desktop and mobile computing; and client non-compute applications, where our products are designed for a wide variety of end user devices such as digital video recorders, personal data backup systems, portable external storage systems, digital media systems and surveillance systems.
Our product and solution portfolio for the enterprise data storage industry includes storage enclosures, integrated application platforms and HPC data storage solutions. Our storage subsystems support a range of high-speed interconnect technologies to meet demanding cost and performance specifications. Our modular subsystem architecture allows us to support many segments within the networked storage market by enabling different specifications of storage subsystem designs to be created from a standard set of interlocking technology modules.
We are subject to the Conflict Minerals Rule because certain products that we manufacture or contract to be manufactured contain Conflict Minerals that are necessary to the functionality or production of the products. We do not directly source Conflict Minerals from mines, smelters or refiners.
Our focus on the responsible sourcing began well in advance of the adoption of the Rule. Seagate has been a member of the Electronic Industry Citizenship Coalition (“EICC”) since 2004 and our employees have worked closely with this organization to improve our global supply chain. The EICC is an industry collaboration with a focus on improving working conditions and environmental stewardship throughout the electronics supply chain. Through the EICC’s Conflict-Free Sourcing Initiative (the “CFSI”), we have worked and continue to work with other companies focusing on responsible Conflict Minerals sourcing.
We rely on our direct suppliers to provide information with respect to the origin of the 3TG contained in components and materials supplied to us. In all cases, the information relating to the 3TG contained in our products comes from lower tier suppliers and from information provided to us through our membership with EICC and the CFSI.
Contracts with our suppliers can be multi-year contracts and we cannot unilaterally impose new contract terms and flow-down requirements. As we enter into new contracts, or as our contracts renew, we endeavor to add a conflict minerals clause requiring suppliers to provide 3TG sourcing and smelter information. We believe that it will still take a number of years to ensure that substantially all of our supplier contracts contain appropriate flow-down clauses. As described below, we are encouraging our suppliers to provide the 3TG sourcing information even before contracts are renewed.
As of this writing we are unable to determine the origin of the 3TG in our products that are necessary to the functionality or production of the products (“necessary conflict minerals”) that we manufactured or contracted to manufacture during the Reporting Period. For that reason, we are required under the Rule to submit to the SEC a Conflict Minerals Report as an Exhibit to Form SD.
We believe the products that we manufactured or contracted to manufacture that are subject to the reporting obligations of the Rule contain 3TG of indeterminate origin because we have been unable to determine the origin of the 3TG they contain or to determine whether such minerals financed or benefitted armed groups in the Covered Countries.
PRODUCT DESCRIPTION
Our products are designed for enterprise servers and storage systems in mission critical and nearline applications; client compute applications, where our products are designed primarily for desktop and mobile computing; and client non-compute applications, where our products are designed for a wide variety of end user devices such as digital video recorders, personal data backup systems, portable external storage systems, digital media systems and surveillance systems. Seagate’s hardware products in the aggregate contain all four of the conflict minerals, which are necessary to the functionality or production of the products.
Seagate is a partially vertically integrated company: we make our own recording heads and media, which are then assembled into finished functional memory devices. However, Seagate does not directly procure any metals from smelters or refiners; we only purchase parts, components, materials, and subassemblies containing these metals. As such, Seagate occupies the supply chain position of downstream company as defined by the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (the “OECD Guidance”).
DUE DILIGENCE PROGRAM DESIGN
The OECD Guidance established a five-step framework for due diligence as a basis for responsible supply chain management of minerals from conflict-affected and high risk areas. We outline select elements of our due diligence program design below. However these are not all the elements of our due diligence program. To determine the source and chain of custody of 3TG necessary to the production of our products, we conducted due diligence on our supply chain, using measures developed to ascertain whether the minerals originated from the Covered Countries and, if so, whether the purchase of such minerals directly or indirectly benefited non-governmental armed groups.
Due Diligence Design Framework
Our conflict minerals due diligence measures have been designed to conform to the OECD Guidance for 3TG for “downstream companies” (as defined in the OECD Guidance) in all material respects. Our due diligence measures addressed the following steps:
1. Establishing strong Company management systems for 3TG supply chain due diligence;
a. We have a team of senior staff who are members of working groups responsible for the management and continued implementation of our conflict minerals compliance strategy. This involvement includes corporate compliance, financial reporting, internal audit, investor relations and legal.
b. Employees receive training on the EICC Code of Conduct Requirements.
c. Select individuals receive training on our compliance program and due diligence procedures for addressing certain aspects of our due diligence program including review and validation of suppliers conflict minerals reporting template responses.
d. We utilize external counsel and consultants to assist us with our compliance efforts
e. We have adopted a conflict minerals policy. The policy is communicated on our corporate website and communicated to suppliers and employees.
f. We utilize the Conflict Minerals Reporting Template (the “CMRT”) developed by the CFSI to identify smelters and refiners in our supply chain. The CMRT requires that suppliers provide information concerning the usage and sourcing of conflict minerals in their materials, components, and products.
g. Seagate is an active member of the EICC and CFSI.
h. Certain purchase order terms and conditions specifically reference and require EICC Code of Conduct and conflict minerals compliance.
i. A third party was commissioned to perform a website, e-mail and direct contact search of over 200 smelters declared by Seagate’s supply chain. This data was shared in consolidated form with the EICC CFSI smelter list.
2. Identifying and assessing 3TG risks in our supply chain;
a. We request suppliers provide us with CMRTs on the materials, components, parts and products they sell to us.
b. Supplier CMRTs are reviewed for completeness against our internally written standard operating procedures and controls. CMRTs that appear inaccurate or incomplete are rejected and the supplier is requested to perform additional due diligence to address identified issues.
c. Smelters are critically reviewed for compliance to third party smelter certification guidelines and determined if they meet the compliant and active criteria as developed by the CFSI.
3. Designing and implementing strategies to respond to 3TG risks identified;
a. We have procedures for monitoring and reporting on risk to designated senior management
b. Smelters that are determined to not be CFSI certified or actively pursuing third party certification are encouraged by our suppliers and our participation in CFSI to pursue third party certification.
4. Contributing to independent third party audits of the due diligence practices of 3TG smelters and refiners by participating in industry organizations; and
a. We support independent third party audits through our CFSI membership.
b. We assess information provided the CFSI and other certification bodies to determine if a smelter or refiner is compliant with applicable third-party conflict free certification.
5. Reporting on our 3TG supply chain due diligence activities.
a. We file a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission and make them publicly available on our website.
Due Diligence Measures Performed
Our due diligence measures for 2015 included the following activities:
· We revised our Seagate Corporate Policy on Conflict Minerals (the “Policy”), posted it to our external website, and communicated it to Seagate’s direct suppliers. The Policy seeks to eliminate our use of 3TG that contribute to human rights abuses in the DRC and adjoining countries.
· We updated our internal Corporate Standard Operating Procedure for Conflict Minerals Management (the “Standard Operating Procedure”) specifically designed to satisfy the OECD Guidance.
· We developed and implemented a 2015 Seagate Conflict Minerals Management Plan (the “Management Plan”) in accordance with the Standard Operating Procedure.
· We established an internal team to implement the Management Plan. That team has been involved in the following measures designed to support our compliance with the Rule and our Standard Operating Procedure:
1. Establishing requirements in supplier contracts to define Seagate expectations of suppliers regarding sourcing of 3TG and reporting of information to Seagate.
2. Conducting a review to identify relevant direct (i.e., first tier) suppliers of products containing necessary 3TG (“3TG Direct Suppliers”).
3. Requesting that all 3TG direct suppliers provide information to us regarding their 3TG using the template developed by the EICC and the Global e-Sustainability Initiative, known as the CMRT to ascertain, for each of the 3TG, the smelter or refiner where it was processed, the smelter or refiner’s country of origin, the mine(s) of origin, and the location of the mine(s). Our instructions to 3TG Direct Suppliers requested them to make similar efforts to survey their supply chain using the CMRT and to report the facilities and location of mines of origin for the minerals.
4. Reviewing and attempting to validate the information provided by our 3TG Direct Suppliers by establishing a process that includes an assessment of the completeness and reasonableness of the information provided, then conducting follow-up communications to address deficiencies.
5. Comparing the facilities identified by relevant 3TG Direct Suppliers via the supply chain survey against the list of facilities that the CFSI has validated as “conflict free.”
6. Supporting the CFSI through membership in the EICC, participation in the CFSI committee and other sub-committees, and requests of our 3TG Direct Suppliers to encourage the mineral processing facilities in their supply chains to participate in the CFSI.
7. Making periodic reports to Seagate senior management.
Reasonable Country of Origin Inquiry
As a member of the EICC participating in the CFSI, we used due diligence the CFSI conducted on smelters and refiners together with the data our suppliers provided on their CMRTs. The CFSI trains auditors to audit the smelters and refiners. The smelters and refiners that are found to be CFSI compliant are those for which the CFSI auditor has verified that the smelter’s or refiner’s 3TG, if originating in the Covered Countries, came from conflict-free mines and trading.
Based on a “reasonable country of origin inquiry” Seagate does not know or have reason to believe that its necessary conflict minerals originated or may have originated in the Covered Countries, except where CFSI validated smelters or refiners have revealed sources within the Covered Countries that are verified as conflict-free. However, a significant portion of the Seagate supply chain remains undefined with respect to the country of origin of its 3TG, as described below.
Seagate has identified sources in all categories of countries per CFSI definition: L1 (Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Cote D’Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States of America, Vietnam, And Zimbabwe), L2 (Kenya, Mozambique, and South Africa), L3 (Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia), DRC (Democratic Republic of Congo), and R/S (recycled or scrap feedstock). However, all our known DRC and L3 sources have been CFSI validated as conflict-free.
ANALYSIS OF SUPPLIER DATA
The following table depicts the status of our efforts to determine the smelters and refiners in our supply chain as of the end of 2015 for the 3TG used in our hardware products. As noted elsewhere, we separated the smelters and refiners in our supply chain into three categories: (1) CFSI validated conflict- free smelters or refiners; (2) CFSI recognized smelters or refiners that have not yet been validated as conflict-free; and (3) entities not yet CFSI recognized as actual smelters or refiners.
Smelter/Refiner Totals |
| 2013 |
| 2014 |
| 2015 |
|
CFSI Conflict Free |
| 65 |
| 142 |
| 257 |
|
Validated |
| 15 | % | 22 | % | 90 | % |
CFSI Recognized, not |
| 97 |
| 109 |
| 30 |
|
Conflict Free validated |
| 23 | % | 17 | % | 10 | % |
CFSI Unrecognized |
| 266 62 | % | 395 61 | % | 0 0 | % |
Total |
| 428 |
| 646 |
| 287 |
|
These totals reflect the sum of all our divisions in the past three years. We made it a priority to eliminate smelters that were not recognized by CFSI or in the process of becoming validated by CFSI.
For Seagate products, 100% of our 3TG suppliers provided CMRT data to us for 2015.
For Seagate Systems products (formerly Xyratex LTD and Dot Hill Systems Corp.), due to the extensive nature of the inherited supply chain which is undergoing transition into more mainstream Seagate sources, we limited our investigation of that supply chain for 2015 to the top 99.5% of direct materials spending. 100% of those suppliers have provided us with their CMRT data.
For certain Solid State Drive products from our recently acquired Accelerated Solutions Division, where we inherited an extensive supply chain in 2014, we were also able to obtain data on 99.5% of the direct materials spending. 100% of those suppliers have provided us with their CMRT data.
DUE DILIGENCE DETERMINATION
We carried out the diligence process described above in order to ascertain the source and chain of custody of 3TG used in our supply chain. Based on the processes implemented and information gathered therefrom, we were unable to determine the origin of all of the 3TG used in our products, and therefore concluded that for the Reporting Period we were unable to determine whether the necessary 3TG in our products directly or indirectly financed or benefited armed groups in the DRC or any of its adjoining countries. However, we found no evidence that any of our 3TG Direct Suppliers derived 3TG from sources within the DRC or adjoining countries other than from CFSI validated sources.
The list of smelters and refiners in the Seagate supply chain changed significantly in calendar 2015 and continues to change. The list of CFSI validated conflict-free sources has grown significantly in 2015 and continues to grow. Additionally, the list of unrecognized smelter and refiner names given in supplier CMRTs is growing, although we believe that growth was a temporary outcome of acquiring several new product supply chains in 2015. Given the dynamic nature of the smelter/refiner lists appearing on our outbound CMRTs, we provide the following snapshot list of smelters and refiners known to be in our supply chain at some time during calendar 2015:
SMELTER TABLE
Metal |
| Smelter |
| Smelter ID(1) |
Gold |
| Advanced Chemical Company |
| CID000015 |
Gold |
| Aida Chemical Industries Co., Ltd. |
| CID000019 |
Gold |
| Allgemeine Gold-und Silberscheideanstalt A.G. |
| CID000035 |
Gold |
| Almalyk Mining and Metallurgical Complex (AMMC) |
| CID000041 |
Gold |
| AngloGold Ashanti Córrego do Sítio Mineração |
| CID000058 |
Gold |
| Argor-Heraeus S.A. |
| CID000077 |
Gold |
| Asahi Pretec Corp. |
| CID000082 |
Gold |
| Asahi Refining Canada Ltd. |
| CID000924 |
Gold |
| Asahi Refining USA Inc. |
| CID000920 |
Gold |
| Asaka Riken Co., Ltd. |
| CID000090 |
Gold |
| Aurubis AG |
| CID000113 |
Gold |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| CID000128 |
Gold |
| Boliden AB |
| CID000157 |
Gold |
| C. Hafner GmbH + Co. KG |
| CID000176 |
Gold |
| CCR Refinery - Glencore Canada Corporation |
| CID000185 |
Gold |
| Cendres + Métaux S.A. |
| CID000189 |
Gold |
| Chimet S.p.A. |
| CID000233 |
Gold |
| Daejin Indus Co., Ltd. |
| CID000328 |
Gold |
| DODUCO GmbH |
| CID000362 |
Gold |
| Dowa |
| CID000401 |
Gold |
| DSC (Do Sung Corporation) |
| CID000359 |
Gold |
| Eco-System Recycling Co., Ltd. |
| CID000425 |
Gold |
| Elemetal Refining, LLC |
| CID001322 |
Gold |
| Emirates Gold DMCC |
| CID002561 |
Gold |
| Faggi Enrico S.p.A. |
| CID002355 |
Gold |
| Geib Refining Corporation |
| CID002459 |
Gold |
| Heimerle + Meule GmbH |
| CID000694 |
Gold |
| Heraeus Ltd. Hong Kong |
| CID000707 |
Gold |
| Heraeus Precious Metals GmbH & Co. KG |
| CID000711 |
Gold |
| Ishifuku Metal Industry Co., Ltd. |
| CID000807 |
Gold |
| Istanbul Gold Refinery |
| CID000814 |
Gold |
| Japan Mint |
| CID000823 |
Gold |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| CID000855 |
Gold |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| CID000927 |
Gold |
| JSC Uralelectromed |
| CID000929 |
Gold |
| JX Nippon Mining & Metals Co., Ltd. |
| CID000937 |
Gold |
| Kazzinc |
| CID000957 |
Gold |
| Kennecott Utah Copper LLC |
| CID000969 |
Gold |
| KGHM Polska Miedź Spółka Akcyjna |
| CID002511 |
Gold |
| Kojima Chemicals Co., Ltd. |
| CID000981 |
Gold |
| Korea Zinc Co., Ltd. |
| CID002605 |
Gold |
| LS-NIKKO Copper Inc. |
| CID001078 |
Gold |
| Materion |
| CID001113 |
Gold |
| Matsuda Sangyo Co., Ltd. |
| CID001119 |
Gold |
| Metalor Technologies (Hong Kong) Ltd. |
| CID001149 |
Gold |
| Metalor Technologies (Singapore) Pte., Ltd. |
| CID001152 |
Gold |
| Metalor Technologies (Suzhou) Ltd. |
| CID001147 |
Gold |
| Metalor Technologies S.A. |
| CID001153 |
Gold |
| Metalor USA Refining Corporation |
| CID001157 |
Gold |
| Metalúrgica Met-Mex Peñoles S.A. De C.V. |
| CID001161 |
Gold |
| Mitsubishi Materials Corporation |
| CID001188 |
Gold |
| Mitsui Mining and Smelting Co., Ltd. |
| CID001193 |
Gold |
| MMTC-PAMP India Pvt., Ltd. |
| CID002509 |
Gold |
| Moscow Special Alloys Processing Plant |
| CID001204 |
Gold |
| Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| CID001220 |
Gold |
| Navoi Mining and Metallurgical Combinat |
| CID001236 |
Gold |
| Nihon Material Co., Ltd. |
| CID001259 |
Gold |
| Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
| CID002779 |
Gold |
| Ohura Precious Metal Industry Co., Ltd. |
| CID001325 |
Gold |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
| CID001326 |
Gold |
| OJSC Novosibirsk Refinery |
| CID000493 |
Gold |
| PAMP S.A. |
| CID001352 |
Gold |
| Prioksky Plant of Non-Ferrous Metals |
| CID001386 |
Gold |
| PT Aneka Tambang (Persero) Tbk |
| CID001397 |
Gold |
| PX Précinox S.A. |
| CID001498 |
Gold |
| Rand Refinery (Pty) Ltd. |
| CID001512 |
Gold |
| Republic Metals Corporation |
| CID002510 |
Gold |
| Royal Canadian Mint |
| CID001534 |
Gold |
| Samduck Precious Metals |
| CID001555 |
Gold |
| SAXONIA Edelmetalle GmbH |
| CID002777 |
Gold |
| Schone Edelmetaal B.V. |
| CID001573 |
Gold |
| SEMPSA Joyería Platería S.A. |
| CID001585 |
Gold |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| CID001622 |
Gold |
| Sichuan Tianze Precious Metals Co., Ltd. |
| CID001736 |
Gold |
| Singway Technology Co., Ltd. |
| CID002516 |
Gold |
| SOE Shyolkovsky Factory of Secondary Precious Metals |
| CID001756 |
Gold |
| Solar Applied Materials Technology Corp. |
| CID001761 |
Gold |
| Sumitomo Metal Mining Co., Ltd. |
| CID001798 |
Gold |
| T.C.A S.p.A |
| CID002580 |
Gold |
| Tanaka Kikinzoku Kogyo K.K. |
| CID001875 |
Gold |
| The Refinery of Shandong Gold Mining Co., Ltd. |
| CID001916 |
Gold |
| Tokuriki Honten Co., Ltd. |
| CID001938 |
Gold |
| Torecom |
| CID001955 |
Gold |
| Umicore Brasil Ltda. |
| CID001977 |
Gold |
| Umicore Precious Metals Thailand |
| CID002314 |
Gold |
| Umicore S.A. Business Unit Precious Metals Refining |
| CID001980 |
Gold |
| United Precious Metal Refining, Inc. |
| CID001993 |
Gold |
| Valcambi S.A. |
| CID002003 |
Gold |
| Western Australian Mint trading as The Perth Mint |
| CID002030 |
Gold |
| WIELAND Edelmetalle GmbH |
| CID002778 |
Gold |
| Yamamoto Precious Metal Co., Ltd. |
| CID002100 |
Gold |
| Yokohama Metal Co., Ltd. |
| CID002129 |
Gold |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| CID002224 |
Gold |
| Zijin Mining Group Co., Ltd. Gold Refinery |
| CID002243 |
Tantalum |
| Changsha South Tantalum Niobium Co., Ltd. |
| CID000211 |
Tantalum |
| Conghua Tantalum and Niobium Smeltry |
| CID000291 |
Tantalum |
| D Block Metals, LLC |
| CID002504 |
Tantalum |
| Duoluoshan |
| CID000410 |
Tantalum |
| Exotech Inc. |
| CID000456 |
Tantalum |
| F&X Electro-Materials Ltd. |
| CID000460 |
Tantalum |
| FIR Metals & Resource Ltd. |
| CID002505 |
Tantalum |
| Global Advanced Metals |
| CID002557 |
Tantalum |
| Global Advanced Metals |
| CID002558 |
Tantalum |
| Guangdong Zhiyuan New Material Co., Ltd. |
| CID000616 |
Tantalum |
| H.C. Starck Co., Ltd. |
| CID002544 |
Tantalum |
| H.C. Starck GmbH |
| CID002546 |
Tantalum |
| H.C. Starck GmbH Laufenburg |
| CID002545 |
Tantalum |
| H.C. Starck Hermsdorf GmbH |
| CID002547 |
Tantalum |
| H.C. Starck Inc. |
| CID002548 |
Tantalum |
| H.C. Starck Ltd. |
| CID002549 |
Tantalum |
| H.C. Starck Smelting GmbH & Co. KG |
| CID002550 |
Tantalum |
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
| CID002492 |
Tantalum |
| Hi-Temp |
| CID000731 |
Tantalum |
| Jiangxi Guangzhou Qiye Co. Ltd |
| CID002512 |
Tantalum |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| CID000914 |
Tantalum |
| Jiujiang Tanbre Co., Ltd. |
| CID000917 |
Tantalum |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| CID002506 |
Tantalum |
| KEMET Blue Metals |
| CID002539 |
Tantalum |
| Kemet Blue Powder |
| CID002568 |
Tantalum |
| King-Tan Tantalum Industry Ltd. |
| CID000973 |
Tantalum |
| LSM Brasil S.A. |
| CID001076 |
Tantalum |
| Metallurgical Products India Pvt., Ltd. |
| CID001163 |
Tantalum |
| Mitsui Mining & Smelting |
| CID001192 |
Tantalum |
| Molycorp Silmet A.S. |
| CID001200 |
Tantalum |
| Ningxia Orient Tantalum Industry Co., Ltd. |
| CID001277 |
Tantalum |
| Plansee |
| CID002540 |
Tantalum |
| Plansee(2) |
| CID002556 |
Tantalum |
| QuantumClean |
| CID001508 |
Tantalum |
| RFH Tantalum Smeltry Co., Ltd. |
| CID001522 |
Tantalum |
| Solikamsk Magnesium Works OAO |
| CID001769 |
Tantalum |
| Taki Chemicals |
| CID001869 |
Tantalum |
| Telex Metals |
| CID001891 |
Tantalum |
| Tranzact, Inc. |
| CID002571 |
Tantalum |
| Ulba Metallurgical Plant JSC |
| CID001969 |
Tantalum |
| XinXing HaoRong Electronic Material Co., Ltd. |
| CID002508 |
Tantalum |
| Yichun Jin Yang Rare Metal Co., Ltd. |
| CID002307 |
Tantalum |
| Zhuzhou Cemented Carbide Group Co., Ltd. |
| CID002232 |
Tin |
| Alpha |
| CID000292 |
Tin |
| An Thai Minerals Co., Ltd. |
| CID002825 |
Tin |
| An Vinh Joint Stock Mineral Processing Company |
| CID002703 |
Tin |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| CID000228 |
Tin |
| China Tin Group Co., Ltd. |
| CID001070 |
Tin |
| Cooperativa Metalurgica de Rondônia Ltda. |
| CID000295 |
Tin |
| CV Ayi Jaya |
| CID002570 |
Tin |
| CV Gita Pesona |
| CID000306 |
Tin |
| CV Serumpun Sebalai |
| CID000313 |
Tin |
| CV United Smelting |
| CID000315 |
Tin |
| CV Venus Inti Perkasa |
| CID002455 |
Tin |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| CID002572 |
Tin |
| Elmet S.L.U. |
| CID002774 |
Tin |
| EM Vinto |
| CID000438 |
Tin |
| Fenix Metals |
| CID000468 |
Tin |
| Gejiu Kai Meng Industry and Trade LLC |
| CID000942 |
Tin |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| CID000538 |
Tin |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| CID001908 |
Tin |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| CID000244 |
Tin |
| Magnu’s Minerais Metais e Ligas Ltda. |
| CID002468 |
Tin |
| Malaysia Smelting Corporation (MSC) |
| CID001105 |
Tin |
| Melt Metais e Ligas S.A. |
| CID002500 |
Tin |
| Metallic Resources, Inc. |
| CID001142 |
Tin |
| Metallo-Chimique N.V. |
| CID002773 |
Tin |
| Mineração Taboca S.A. |
| CID001173 |
Tin |
| Minsur |
| CID001182 |
Tin |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| CID002573 |
Tin |
| O.M. Manufacturing (Thailand) Co., Ltd. |
| CID001314 |
Tin |
| O.M. Manufacturing Philippines, Inc. |
| CID002517 |
Tin |
| Operaciones Metalurgical S.A. |
| CID001337 |
Tin |
| Phoenix Metal Ltd. |
| CID002507 |
Tin |
| PT Aries Kencana Sejahtera |
| CID000309 |
Tin |
| PT Artha Cipta Langgeng |
| CID001399 |
Tin |
| PT ATD Makmur Mandiri Jaya |
| CID002503 |
Tin |
| PT Babel Inti Perkasa |
| CID001402 |
Tin |
| PT Bangka Prima Tin |
| CID002776 |
Tin |
| PT Bangka Tin Industry |
| CID001419 |
Tin |
| PT Belitung Industri Sejahtera |
| CID001421 |
Tin |
| PT BilliTin Makmur Lestari |
| CID001424 |
Tin |
| PT Bukit Timah |
| CID001428 |
Tin |
| PT Cipta Persada Mulia |
| CID002696 |
Tin |
| PT DS Jaya Abadi |
| CID001434 |
Tin |
| PT Eunindo Usaha Mandiri |
| CID001438 |
Tin |
| PT Inti Stania Prima |
| CID002530 |
Tin |
| PT Justindo |
| CID000307 |
Tin |
| PT Karimun Mining |
| CID001448 |
Tin |
| PT Mitra Stania Prima |
| CID001453 |
Tin |
| PT Panca Mega Persada |
| CID001457 |
Tin |
| PT Prima Timah Utama |
| CID001458 |
Tin |
| PT Refined Bangka Tin |
| CID001460 |
Tin |
| PT Sariwiguna Binasentosa |
| CID001463 |
Tin |
| PT Sukses Inti Makmur |
| CID002816 |
Tin |
| PT Sumber Jaya Indah |
| CID001471 |
Tin |
| PT Timah (Persero) Tbk Kundur |
| CID001477 |
Tin |
| PT Timah (Persero) Tbk Mentok |
| CID001482 |
Tin |
| PT Tommy Utama |
| CID001493 |
Tin |
| PT Wahana Perkit Jaya |
| CID002479 |
Tin |
| Resind Indústria e Comércio Ltda. |
| CID002706 |
Tin |
| Rui Da Hung |
| CID001539 |
Tin |
| Soft Metais Ltda. |
| CID001758 |
Tin |
| Thaisarco |
| CID001898 |
Tin |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| CID002574 |
Tin |
| VQB Mineral and Trading Group JSC |
| CID002015 |
Tin |
| White Solder Metalurgia e Mineração Ltda. |
| CID002036 |
Tin |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| CID002158 |
Tin |
| Yunnan Tin Company Limited |
| CID002180 |
Tungsten |
| A.L.M.T. TUNGSTEN Corp. |
| CID000004 |
Tungsten |
| Asia Tungsten Products Vietnam Ltd. |
| CID002502 |
Tungsten |
| Chenzhou Diamond Tungsten Products Co., Ltd. |
| CID002513 |
Tungsten |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| CID000258 |
Tungsten |
| Dayu Jincheng Tungsten Industry Co., Ltd. |
| CID002518 |
Tungsten |
| Dayu Weiliang Tungsten Co., Ltd. |
| CID000345 |
Tungsten |
| Fujian Jinxin Tungsten Co., Ltd. |
| CID000499 |
Tungsten |
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
| CID000875 |
Tungsten |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| CID002315 |
Tungsten |
| Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
| CID000868 |
Tungsten |
| Ganzhou Seadragon W & Mo Co., Ltd. |
| CID002494 |
Tungsten |
| Ganzhou Yatai Tungsten Co., Ltd. |
| CID002536 |
Tungsten |
| Global Tungsten & Powders Corp. |
| CID000568 |
Tungsten |
| Guangdong Xianglu Tungsten Co., Ltd. |
| CID000218 |
Tungsten |
| H.C. Starck GmbH Goslar |
| CID002541 |
Tungsten |
| Hunan Chenzhou Mining Co., Ltd. |
| CID000766 |
Tungsten |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin |
| CID002579 |
Tungsten |
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
| CID000769 |
Tungsten |
| Hydrometallurg, JSC |
| CID002649 |
Tungsten |
| Japan New Metals Co., Ltd. |
| CID000825 |
Tungsten |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| CID002551 |
Tungsten |
| Jiangxi Jiangwu Cemented Carbide Co., Ltd. |
| CID002321 |
Tungsten |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| CID002318 |
Tungsten |
| Jiangxi Yaosheng Tungsten Co., Ltd. |
| CID002317 |
Tungsten |
| Jiangxi Yichun |
| CID002316 |
Tungsten |
| Jiangxi Yichun |
| CID002535 |
Tungsten |
| Kennametal Fallon |
| CID000966 |
Tungsten |
| Kennametal Huntsville |
| CID000105 |
Tungsten |
| Malipo Haiyu Tungsten Co., Ltd. |
| CID002319 |
Tungsten |
| Niagara Refining LLC |
| CID002589 |
Tungsten |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| CID002543 |
Tungsten |
| Pobedit, JSC |
| CID002532 |
Tungsten |
| Tejing (Vietnam) Tungsten Co., Ltd. |
| CID001889 |
Tungsten |
| Vietnam Youngsun Tungsten Industry Co., Ltd. |
| CID002011 |
Tungsten |
| Wolfram Bergbau und Hütten AG |
| CID002044 |
Tungsten |
| Xiamen Tungsten (H.C.) Co., Ltd. |
| CID002320 |
Tungsten |
| Xiamen Tungsten Co., Ltd. |
| CID002082 |
Tungsten |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| CID002095 |
Our direct suppliers have named these smelters or refiners as their sources of tin, tungsten, tantalum, and gold in the products we buy from them. We have subjected each incoming CMRT to systematic scrutiny often followed by additional supplier communication. This list of 3TG smelter/refiner sources in our supply chain is not exhaustive. Some suppliers still have only partial lists available. As noted, many have provided unrecognized names which we have not yet been able to resolve, so those names are not included here. Nor does the inclusion of any name on our list imply that its products necessarily comprise portions of our products. Inclusion only implies that the 3TG in all our products comes from these sources or from others yet to be determined.
FUTURE PLANS TO IMPROVE DUE DILIGENCE AND SUPPLIER RESPONSIVENESS
Seagate expects to pursue several initiatives to attain a conflict-free 3TG supply chain, including the following:
· Although the number of validated conflict-free 3TG smelters and refiners is climbing steadily, there are still not enough conflict-free validated sources to go around for all industries. As more smelters and refiners become validated, we all benefit. Nevertheless, we continue to seek supplier commitments to conflict-free 3TG, to request suppliers to have their smelters and refiners engage in the validation audit process, and then if necessary to convert to other preferred sources.
· We are also working on developing software to accelerate and track progress, to make our information more complete, accurate, timely and specific using greater automation.
· In 2016, we are in the process of refreshing all our direct supplier data using CMRT 4.0, with which we expect to enhance the quality of the information we obtain this year. We continue to work with the EICC and CFSI to improve processes that encourage responsible sourcing of 3TG in a manner that avoids de facto boycott of legitimate minerals from Covered Countries.
CAUTIONARY NOTE REGARDING FORWARD-LOOKING STATEMENTS
This Conflict Minerals Report contains forward-looking statements, including, in particular, statements about our future plans to improve due diligence and supplier responsiveness and to seek supplier commitments in this regard. These forward-looking statements are based on information available to us as of the date of this Conflict Mineral Report and are based on management’s current views and assumptions. These forward-looking statements also involve a number of known and unknown risks, uncertainties, and other factors that could cause actual events to differ materially from our expectations. Such risks and uncertainties include the veracity of information directly or indirectly provided to us by others and expectations regarding future smelter and refiner participation in conflict-free verification regimens. Except as may be required by law, we undertake no obligation to update forward-looking statements to reflect future events or circumstances.