Exhibit 1.01
Super Micro Computer, Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2018
I. Introduction
This report for the year ended December 31, 2018 has been prepared pursuant to Rule 13p-1 and the Specialized Disclosure Report on Form SD ("Form SD") under the Securities Exchange Act of 1934 (collectively, the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG").
If a registrant determines that conflict minerals are necessary to the functionality or production of products manufactured or contracted by the registrant to be manufactured, the registrant must submit a Form SD which describes the reasonable country of origin inquiry (“RCOI”) that it undertook to determine whether such necessary conflict minerals originated from the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”).
If, on the basis of its RCOI, a registrant knows or has reason to believe that any of the necessary conflict minerals in its supply chain may have originated in any of the Covered Countries and knows they are not, or has reason to believe that they may not be, from recycled or scrap sources, the issuer must exercise due diligence on the conflict minerals’ source and chain of custody and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
This report has been prepared by Super Micro Computer, Inc. (herein referred to as “Super Micro” the “Company,” “we,” “us,” or “our”). The information contained in this report includes the activities of all of the Company's majority-owned subsidiaries and variable interest entities that are required to be consolidated. This Report has not been subject to an independent private sector audit.
II. Company Overview
We are a global leader in high-performance, high-efficiency server technology and innovation. We develop and provide end-to-end green computing solutions to the cloud computing, data center, enterprise IT, big data, HPC and embedded markets. Our solutions range from complete server, storage, blade and workstations to full racks, networking devices, server management software and technology support and services.
We conduct our operations principally from our headquarters in California and facilities of our subsidiaries in Taiwan, the Netherlands, China and Japan. We sell our server systems and subsystems and accessories through our direct sales force as well as through distributors and Original Equipment Manufacturers ("OEMs").
III. Supply Chain Overview
Our supply chain operations for our server products include sourcing, order management, manufacturing, delivery, and return. We procure server components from the following four major types of suppliers:
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| • | Manufacturers or direct suppliers; |
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| • | Contract manufacturers producing items to match specifications and standards set by us; |
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| • | Distributors or resellers of manufactured components for other manufacturers; and |
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| • | Customers providing us certain parts and materials to be used to fulfill their orders. |
Logistics and service providers were excluded from the reasonable country of origin inquiry ("RCOI") and due diligence measures discussed below because we have concluded that they do not provide us with any products within the scope of the Rule.
As explained further below, we rely upon our suppliers and third parties to provide information on the origin, source and chain of
custody of the conflict minerals contained in product components and materials. We commenced conflict minerals due diligence in 2013.
Based on representations from these suppliers, we have determined that they obtain conflict minerals used in our products from the following types of processing facilities:
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| • | Tin, Tungsten, Tantalum - From smelters which procure the relevant ore and then pass it through smelting, as applicable. |
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| • | Gold - From smelters/ refiners which either obtain gold from the mines or through recycling. |
IV. Conflict Minerals Policy
We are committed to complying with Section 1502 of the Dodd-Frank Act and achieving the goal of confirming that the materials used in our products are procured from conflict-free sources. We have considered the Rule’s requirements and related guidance from the Organization for Economic Cooperation and Development (the “OECD”), and we expect our suppliers to comply with the Code of Conduct of the Responsible Business Electro Alliance (“RBA”) and conduct their business in accordance with our supply chain responsibility expectations, as documented in our Conflict Mineral Policy (the "CM Policy") at http://www.supermicro.com/about/policies/Supermicro_Conflict_Minerals_Statement.pdf.
In support of this policy, we expect to:
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| a. | Exercise due diligence about suppliers for products containing or suspected to contain conflict minerals, consistent with the OECD's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 3rd Edition and the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”), as tailored to include steps appropriate for downstream companies, and encourage our suppliers to do likewise with their suppliers; |
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| b. | Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm that the tantalum, tin, tungsten and gold in our supply chain are procured from conflict-free sources; |
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| c. | Collaborate with our suppliers and others on industry-wide solutions through our membership in the Responsible Minerals Initiative (“RMI”) and participation in industry-wide conflict minerals forums to encourage the manufacture of products that do not directly or indirectly finance or benefit armed groups in the Covered Countries; and |
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| d. | Require our suppliers to subscribe to and follow the RBA Code of Conduct. |
V. Reasonable Country of Origin Inquiry
Our supply chain due diligence "scope of work" included our existing component suppliers that provide products and components that contain one or more 3TG minerals (collectively referred to as "In Scope Suppliers"). To help establish our supply chain sourcing programs, we have adopted the RMI’s Conflict Mineral Reporting Template ("CMRT") and launched a Reasonable Country of Origin (RCOI) survey using the CMRT for In Scope Suppliers, which suppliers represent 100% of our total 2018 product-related sourcing expenditures. We reviewed our In Scope Suppliers and categorized them into three tiers based on procurement value. We identified our top 17 suppliers by procurement value as the first tier, followed by the next top 66 suppliers as the second tier and the remaining 211 suppliers as the third tier. The suppliers in the first and second tiers accounted for 99% of our total 2018 product-related sourcing expenditures. The purpose for this classification was to facilitate a focused follow-up process with our suppliers in securing responses to the CMRT on a timely basis through appropriate allocation of resources. The percentage of CMRT received from our In Scope Suppliers during 2018 was 99% compared to 82% in 2017. We noted a 17% improvement in the response rate from our first two tiers of suppliers, and there was an increase of approximately 22% in responses from our third tier of suppliers. The data on which we relied to determine the country of origin of the minerals was obtained through our membership in the RMI.
After conducting our RCOI, we were unable to determine the country of origin for all of the conflict minerals contained in our products that are not from recycled or scrap sources. Given this result, we determined that the Rule requires us to exercise due diligence on the source and chain of custody of the conflict minerals contained in our products, using a framework that conforms to a nationally or internationally recognized due diligence framework.
VI. Due Diligence
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| a. | Due Diligence Framework |
We have exercised due diligence on the source and chain of custody of the necessary conflict minerals used in our products to identify minerals originating from the Covered Countries that are not from scrap or recycled sources. The design of our due
diligence processes has been developed to conform to the five-step framework proposed by the OECD Guidance and the related supplements for gold, tin, tantalum and tungsten. Given that we do not have a direct relationship with the smelters and refiners that process the conflict minerals that are present in our products, we rely on the RMI and other organizations to conduct third-party audits of smelters and refiners.
Our conflict minerals due diligence process includes:
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| • | Establishment of strong company management systems; |
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| • | Identify and assess risks in the supply chain; |
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| • | Design and implement a strategy to respond to identified risks; |
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| • | Independent 3rd Party Audit of Smelter/Refiners Due Diligence Practices |
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| • | Report annually on supply chain due diligence. |
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| b. | Inherent Limitations on Due Diligence Measures |
As a downstream purchaser of conflict minerals, we do not have direct relationships with smelters or refiners that produce the conflict minerals within our supply chain and the complexity of that supply chain limits our ability to directly obtain information about those producers of conflict minerals. Accordingly, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers 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. Such sources of information, as well as our smelters, may yield inaccurate or incomplete information.
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| c. | Brief Description of Due Diligence Measures Taken |
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| (i) | Establishment of Strong Company Management Systems: |
We have established a management system for complying with applicable conflict minerals reporting and disclosure rules. Our management system includes the development of a Conflict Minerals Oversight Committee led by our Senior VP of Operations, Senior VP and Chief Financial Officer and Chief Compliance Officer, and a team of subject matter experts (Conflict Minerals Committee) is responsible for implementing our conflict minerals compliance policy and strategy. The Conflict Minerals Oversight Committee is briefed periodically about the results of our due diligence efforts and reports periodically to the Audit Committee of our Board of Directors.
We maintain our Conflict Minerals Policy that states our position on the use of conflict minerals. Our Conflict Minerals Policy has been communicated to all existing suppliers and was provided to new suppliers as part of our supplier "onboarding" process. We have provided training to our conflict mineral related team members. Additionally, our policy is prominently posted on our public facing website.
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| (ii) | Identification and Assessment of Risks in the Supply Chain: |
We have made reasonable efforts to identify all In Scope Suppliers that supply products that may potentially contain conflict minerals by conducting a supply chain survey using the RMI CMRT; requesting our In Scope Suppliers to identify smelters and refiners and countries of origin of the conflict minerals in products they supply to us; following up with In Scope Suppliers that do not respond to the CMRT by requesting their responses; comparing smelters and refiners identified by our supply chain survey against the list of facilities that are identified by RMI as conformant with the Responsible Minerals Assurance Process (“RMAP”) assessment protocols, which list provides country of origin; and maintaining documentation of reasonable efforts we have made to identify and assess supply chain risks. We have also reviewed the responses to identify potential red flags for further follow-up.
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| (iii) | Strategic Response to Identified Risks: |
We have implemented a risk mitigation response to monitor and track suppliers, smelters and refiners identified as not meeting the requirements set forth in our Conflict Minerals Policy or contractual requirements to determine their progress in meeting those requirements. We will continuously make reasonable efforts to encourage suppliers who are sourcing from non-conflict-free smelters to move towards the use of conflict-free smelters. If a supplier fails to remedy the risks identified by our compliance risk assessment, we will escalate the matter to the Conflict Minerals Oversight Committee to determine whether to approve or reject the supplier based on the following factors: a cost and benefit analysis; evaluation of potential risk factors; any existing
competitive bids; and whether the supplier is a single source supplier to the Company. If the Oversight Committee decides to continue a business relationship with a non-compliant supplier due to inherent limitations of our supply chain, we will use reasonable efforts to follow up with the supplier for its correction plan, and encourage the supplier to work with smelters that are conformant with the RMAP assessment protocols. We also provide periodic compliance updates or reports to our Conflict Minerals Oversight Committee summarizing our risk mitigation efforts. Additionally, we have made updates to our policy to minimize the potential of onboarding any new suppliers who are not conformant with the RMAP assessment protocols, and thus not in alignment with our objective of sourcing from conflict-free suppliers.
(iv) Independent 3rd Party Audit of Smelter/Refiner’s Due Diligence Practices:
We do not have direct relationships with 3TG smelters and refiners, nor do we independently perform direct audits of these entities that provide the 3TG in our supply chain. As an alternative, we consider information collected and provided by independent third-party audit programs, such as RMAP and we rely upon industry efforts, including RMI’s, to influence smelters and refiners to voluntarily undergo the validation process under the RMAP. Additionally, we engaged a third party consultant with expertise in conflict minerals compliance to conduct an analysis of our conflict minerals program and activities. The consultant performed a gap analysis to identify areas for potential improvement in our program. We have updated our conflict minerals compliance plan based on the results of this analysis.
(v) Report Annually on Supply Chain Due Diligence
A Form SD and a Conflict Minerals Report as an exhibit thereto are filed annually with the SEC. The Form SD and Conflict Minerals Report are also available on our website at https://ir.supermicro.com/financial-information/sec-filings.
VII. Efforts to Determine the Mine or Location of Origin of the Conflict Minerals in Our Products and Facilities Used to Process the Conflict Minerals
The results of our RCOI and due diligence on the source and chain of custody of our necessary conflict minerals are the product of our iterative and escalating data collection and dialogue process with our In Scope Suppliers. This process is designed to obtain information regarding the smelters and refineries from which suppliers source such 3TG minerals and to confirm the status of such smelters or refineries as verified by the RMI as a method of assessing the mine and location of origin of such conflict minerals.
Based on the responses that we received from our suppliers, we identified 323 smelters and refineries as potential sources of 3TG minerals that were reported to be in our supply chain, of which 253 have been verified by the RMI to be conformant with the RMAP assessment protocols, and 9 are active (meaning they are in the process of being audited or have committed to the audit process). Table 1 below presents, by mineral, the total number of smelters and refineries identified and the percentage verified to be RMAP-conformant or in the RMI Verification Process. Year over year, the percentage of verified or in-process smelters has decreased from 87% to 81%. See Appendix I for a list, by name, of smelters and refiners verified as conformant with the RMAP assessment protocols.
Table 1 - Smelters and Refiners Verified as RMAP-Conformant or in the RMI Verification Process by Mineral.
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| | Total Smelters and Refiners by Mineral | | Number Verified or In Process | | Percentage Verified or In Process |
| Gold | 151 |
| | 106 |
| | 70 | % |
| Tantalum | 42 |
| | 40 |
| | 95 | % |
| Tin | 84 |
| | 75 |
| | 89 | % |
| Tungsten | 46 |
| | 41 |
| | 89 | % |
As to the remainder of the smelters and refineries that are not verified by the RMI, we were unable to determine the mines of origin or the minerals sourced from such smelters and refineries.
VIII. Due Diligence Process Improvement Efforts
Due to the level of complexity of our products and the respective supply chains and our position in these supply chains as a downstream company, it will take additional time and resources for a number of our suppliers to verify the source mines and country of origin of all of the minerals used by their smelters and refiners. We intend to take the following steps to continue to improve our due diligence measures and to further mitigate the risk that trade in the conflict minerals contained in our products could benefit armed groups in Covered Countries:
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| a. | Continuing to focus our efforts on collaborating with industry peers through our membership in the RMI to improve the systems of transparency and control in our supply chain, including through our use of the latest revision of the CMRT in connection with our RCOI of our supply chain. |
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| b. | Continuing to partner with our In-Scope Suppliers and others on industry-wide solutions through our membership in RMI in an effort to collaboratively increase the number of verified smelters. |
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| c. | Enhancing our engagement with our relevant first-tier suppliers in order to further build their knowledge and capacity so they are able to provide more complete and accurate information on the source and chain of custody of conflict minerals in our supply chain. Selected suppliers who have demonstrated insufficient knowledge and sophistication related to CM compliance will be provided with CM training. |
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| d. | Encouraging our supply chain to source conflict minerals from smelters that are conformant to the RMAP. Updates to the terms and conditions of our vendor/supplier documents and our supply chain policy will emphasize further to our supply chain (both existing and new suppliers), our goal of achieving a conflict-free supply chain. |
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| e. | Continuing our work to refine the process for conducting follow-up with our surveyed suppliers to more effectively resolve unreasonable or illogical responses in their surveys. Additionally, we continue to refine the use of a specialized software tool to distribute the CMRT, receive responses, follow-up as needed, aggregate and analyze the data and product meaningful and actionable reports on our supply chain. |
FORWARD LOOKING STATEMENTS
This Specialized Disclosure Report on Form SD and any exhibits hereto contain “forward-looking statements” about our plans, intentions, forecasts and other expectations concerning the Company's future actions to engage contract manufacturers, to identify to the extent possible the source of conflicts minerals in its products and to take other actions regarding its product sourcing The Company's actual actions or results may differ materially from those expected or anticipated in the forward-looking statements due to both known and unknown risks and uncertainties .. These forward-looking statements and other information are based on our beliefs as well as assumptions made by us using information currently available. In some cases, you can identify forward-looking statements by terminology including “would,” “could,” “may,” “will,” “should,” “expect,” “intend,” “plan,” “anticipate,” “believe,” “estimate,” “predict,” “potential,” or “continue,” the negative of these terms or other comparable terminology. Risks and uncertainties that could cause actual actions or results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for conflict minerals, the possibility of inaccurate information, fraud and other irregularities, inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on our ability to verify the accuracy or completeness of any supply chain information provided by suppliers, third-party audit programs or others In addition, you should specifically consider various factors contained in our filings with the SEC, including those factors discussed under the caption “Risk Factors” in such filings. These factors may cause our actual results to differ materially from those anticipated or implied in the forward-looking statements. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report. We undertake no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise.
DOCUMENTS INCORPORATED BY REFERENCE
Unless otherwise expressly stated herein, no documents, third-party materials or references to websites (including Super Micro's) are incorporated by reference in, or to be considered to be a part of, this Conflict Minerals Report.
Appendix I
Smelters and Refineries
RMAP-Conformant
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| Metal | Smelter Name as Provided by Supplier | Country Location |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY |
| Gold | Dowa | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
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| 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 | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | Materion | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
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| Gold | PAMP S.A. | SWITZERLAND |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
| Gold | Yamakin Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
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| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Marsam Metals | BRAZIL |
| Gold | SAAMP | FRANCE |
| Gold | Italpreziosi | ITALY |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | Safimet S.p.A | ITALY |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | NPM Silmet AS | ESTONIA |
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| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
| Tantalum | H.C. Starck Ltd. | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
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| Tin | Alpha | UNITED STATES OF AMERICA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Premium Tin Indonesia | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT Babel Inti Perkasa | 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 Karimun Mining | INDONESIA |
|
| | |
| Tin | PT Mitra Stania Prima | 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 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 | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Thaisarco | THAILAND |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Yunnan Tin Company Limited | CHINA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | PT Inti Stania Prima | INDONESIA |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Dua Sekawan | INDONESIA |
| Tin | CV Tiga Sekawan | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Metallo Belgium N.V. | BELGIUM |
|
| | |
| Tin | Metallo Spain S.L.U. | SPAIN |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Sukses Inti Makmur | INDONESIA |
| Tin | PT Kijang Jaya Mandiri | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
| Tin | Modeltech Sdn Bhd | MALAYSIA |
| Tin | Gejiu Jinye Mineral Company | CHINA |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | PT Bangka Serumpun | INDONESIA |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
|
| | |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
RMAP-Active (In the Verification Process)
|
| | |
| Metal | Smelter Name as Provided by Supplier | Country Location |
| Gold | Chugai Mining | JAPAN |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Gold | Remondis Argentia B.V. | NETHERLANDS |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | Bangalore Refinery | INDIA |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
Countries of origin of the conflict minerals these facilities process are believed to include: AUSTRALIA, AUSTRIA, BELGIUM, BOLIVIA (PLURINATIONAL STATE OF), BRAZIL, CANADA, CHILE, CHINA, ESTONIA, FRANCE, GERMANY, INDIA, INDONESIA, ITALY, JAPAN, KAZAKHSTAN, KOREA, REPUBLIC OF YRGYZSTAN, MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF, MALAYSIA, MEXICO, PERU,
PHILIPPINES, POLAND, RUSSIAN FEDERATION, SINGAPORE, SOUTH AFRICA, SPAIN, SWEDEN, SWITZERLAND, TAIWAN, PROVINCE OF CHINA, THAILAND, TURKEY, UNITED ARAB EMIRATES, UNITED STATES OF AMERICA, UZBEKISTAN, VIETNAM
